United States
          Environmental Protection
          Agency
Office Of Water
(4303)
EPA 821-R-95-006
January 1995
&EPA      Development Document For
           Proposed Effluent Limitations
           Guidelines And Standards For
           The Centralized Waste
           Treatment Industry

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         DEVELOPMENT DOCUMENT

                    FOR

     PROPOSED EFFLUENT LIMITATIONS

       GUIDELINES AND STANDARDS

                  FOR THE

CENTRALIZED WASTE TREATMENT INDUSTRY
               Carol M. Browner
                 Administrator

               Robert Perciasepe
       Assistant Administrator, Office of Water

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

                Elwood H. Forsht
         Chief, Chemicals and Metals Branch
             Written and Prepared by:

               Debra S. DiCianna
                Project Manager
                 January 1995
        U.S. Environmental Protection Agency
                 Office of Water
             Washington, DC 20460
    Additional Support by Contract No. 68-C1-0006

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                          TABLE OF CONTENTS
EXECUTIVE SUMMARY	  ES-1

SECTION 1  STATUTORY REQUIREMENTS	1-1
     1.1   LEGAL AUTHORITY	1-1
           1.1.1  Best Practicable Control Technology Currently Available (BPT)
                      (Section 304(b)(1) of the CWA)	1-1
           1.1.2  Best Conventional Pollutant Control Technology (BCT)
                      (Section 304(a)(4) of the CWA)	1-2
           1.1.3  Best Available Technology Economically Achievable (BAT)
                      (Sections 304(b)(2)(B) of the CWA)  	1-3
           1.1.4  New Source Performance Standards (NSPS) (Section 306 of the
                      CWA)	...1-3
           1.1.5  Pretreatment Standards for Existing Sources (PSES)
                      (Section 307(b) of the CWA)	1-4
           1.1.6  Pretreatment Standards for New Sources (PSNS) (Section 307(b)
                      of the CWA)	1-4
     1.2   SECTION 304(M) REQUIREMENTS AND LITIGATION	1-5

SECTION 2  DATA COLLECTION	2-1
     2.1   CLEAN WATER ACT SECTION 308 QUESTIONNAIRES	2-1
           2.1.1  Development of Questionnaires	2-1
           2.1.2  Distribution of Questionnaires  	2-4
     2.2   SAMPLING PROGRAM  	2-5
           2.2.1  Pre-1989 Sampling Program  	2-5
           2.2.2  1989 -1993 Sampling Program	2-6
           2.2.3  1994 Sampling Program	2-9

SECTION 3  DESCRIPTION OF THE INDUSTRY  	3-1
     3.1   GENERAL INFORMATION	3-2
     3.2   WASTES RECEIPTS 	3-3
           3.2.1  Waste Receipt Types	3-4
           3.2.2  Procedures for Receipt of Wastes	3-6
     3.3   DISCHARGE INFORMATION	3-8
     3.4   TREATMENT RESIDUALS	3-9
     3.5   INDUSTRY SUBCATEGORIZATION  	3-10
           3.5.1  Development of Subcategorization Scheme  	3-11
           3.5.2  Proposed Subcategories 	3-12

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                    TABLE OF CONTENTS (continued)
SECTION 4  WASTEWATER USE AND WASTEWATER CHARACTERIZATION .. 4-1
     4.1   WATER USE AND SOURCES OF WASTEWATER	4-1
     4.2   WATER USE BY DISCHARGE	4-4
     4.3   WATER USE BY SUBCATEGORY	4-5
     4.4   WASTEWATER CHARACTERIZATION	4-6
           4.4.1  Pollutant Parameters	4-7
           4.4.2 Priority and Non-Conventional Pollutants  	4-9
     4.5   WASTEWATER POLLUTANT DISCHARGES .	4-13
           4.5.1  Metals Subcategory Current Performance	4-13
           4.5.2 Oils Subcategory Current Performance	4-18
           4.5.3 Organics Subcategory Current Performance	4-21

SECTION 5  POLLUTANTS AND POLLUTANT PARAMETERS
           SELECTED FOR REGULATION	5-1
     5.1   POLLUTANT PARAMETERS	5-1
     5.2   PRIORITY AND NON-CONVENTIONAL POLLUTANTS  	5-2
     5.3   SELECTION OF POLLUTANTS TO BE REGULATED FOR PSES AND
                PSNS	5-6
           5.3.1  Pass-Through Analysis Approach  	5-7
           5.3.2 50 POTW Study Data Base	5-8
           5.3.3 RREL Treatability Data Base		5-9
           5.3.4 Final POTW Data Editing	5-9
           5.3.5 Final Pass-Through Analysis Results  	5-14
     5.4   REFRENCES	5-19

SECTION 6  WASTEWATER TREATMENT TECHNOLOGIES 	6-1
     6.1   PHYSICAL/CHEMICALTTHERMAL WASTEWATER TREATMENT
                TECHNOLOGIES	6-1
           6.1.1 Chemical Precipitation	6-2
           6.1.2 Clarification 	6-10
           6.1.3 Plate and Frame Pressure Filtration	6-12
           6.1.4 Emulsion Breaking	6-14
           6.1.5 Equalization	6-16
           6.1.6 Air Stripping	6-17
           6.1.7 Multi-media Filtration	6-21
           6.1.8 Carbon Adsorption	6-24
           6.1.9 Cyanide Destruction	6-30
           6.1.10 Chromium Reduction	6-33
           6.1.11 Electrolytic Recovery	6-36
           6.1.12 Ion Exchange	6-37
           6.1.13 Gravity Separation	6-41

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                     TABLE OF CONTENTS (continued)
           6:1.14 Dissolved Air Flotation	6-42
      6.2   BIOLOGICAL WASTEWATER TREATMENT TECHNOLOGIES	6-45
           6.2.1  Sequencing Batch Reactors	6-47
           6.2.2  Biotowers	6-50
           6.2.3  Activated Sludge  	6-52
      6.3   ADVANCED WASTEWATER TREATMENT TECHNOLOGIES	6-54
           6.3.1  Ultrafiltration	6-54
           6.3.2  Reverse Osmosis	6-57
           6.3.3  Lancy Filtration	6-60
           6.3.4  Liquid Carbon  Dioxide Extraction	6-62
      6.4   SLUDGE TREATMENT AND DISPOSAL	6-63
           6.4.1  Plate and Frame Pressure Filtration	6-66
           6.4.2  Belt Pressure Filtration	6-68
           6.4.3  Vacuum Filtration	6-70
           6.4.4  Filter Cake Disposal	6-72
      6.5   REFERENCES		6-73

SECTION 7 COST OF TREATMENT TECHNOLOGIES	7-1
      7.1   COSTS DEVELOPMENT	7-1
           7.1.1  Technology Costs	7-1
           7.1.2  Option Costs	7-4
      7.2   PHYSICAL/CHEMICAL/THERMAL WASTEWATER TREATMENT
                 TECHNOLOGY COSTS	7-4
           7.2.1  Chemical Precipitation	;	7-4
           7.2.2  Clarification 			7-14
           7.2.3  Plate and Frame Pressure Filtration - Liquid Stream	7-16
           7.2.4  Equalization	7-20
           7.2.5 Air Stripping	7-21
           7.2.6  Multi-Media Filtration	7-23
           7.2.7  Carbon Adsorption	7-24
           7.2.8  Cyanide Destruction	7-26
           7.2.9  Chromium Reduction  	7-28
      7.3   BIOLOGICAL WASTEWATER TREATMENT TECHNOLOGY
                 COSTS	7-30
           7.3.1  Sequencing Batch Reactors	7-30
      7.4   ADVANCED WASTEWATER TREATMENT TECHNOLOGY
                 COSTS	 7-31
           7.4.1  Ultrafiltration	 7-31
           7.4.2  Reverse Osmosis	7-33
      7.5   SLUDGE TREATMENT AND DISPOSAL COSTS  	7-34
           7.5.1 Plate and Frame Pressure Filtration - Sludge Stream	7-34

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                    TABLE OF CONTENTS (continued)


           7.5.2 Filter Cake Disposal	7-36
     7.6   ADDITIONAL COSTS	7-38
           7.6.1 Retrofit Costs	7-38
           7.6.2 Monitoring Costs  	7-38
           7.6.3 RCRA Permit Modification Costs	7-40
           7.6.4 Land Costs	7-41
     7.7   REFERENCES	7-44

SECTION 8 DEVELOPMENT OF LIMITATIONS AND STANDARDS 	8-1
     8.1   ESTABLISHMENT OF BPT	8-1
           8.1.1 Rationale for Metals Subcategory BPT Limitations 	8-3
           8.1.2 Rationale for Oils Subcategory BPT Limitations 	8-9
           8 1.3 Rationale for Organics Subcategory BPT Limitations  	8-14
     8-2   BCT	8-19
     8.3   BAT	8-19
     8.4   NSPS	8-20
     8.5   PSES	•	8-21
     8.6   PSNS	8'22
     8.7   COST OF TECHNOLOGY OPTIONS	8-22
           8.7.1 Proposed BPT Costs	8-23
           8.7.2 Proposed BCT/BAT Costs	8-24
           8.7.3 Proposed PSES Costs	8-24
     8.8   POLLUTANT REDUCTIONS 	8-25
           8.8.1 Conventional Pollutant Reductions	8-25
           8.8.2 Priority and Nonconventional Pollutant Reductions	8-26

SECTION 9 NON-WATER QUALITY IMPACTS	9-1
     9.1   AIR POLLUTION	9-1
     9.2   SOLID AND OTHER AQUEOUS WASTE	9-2
           9.2.1 Filter Cake 	9-3
           9.2.2 Reverse Osmosis Concentrate	9-4
           9.2.3 Ultrafiltration Concentrate  	9-5
           9.2.4 Spent Carbon	9"5
           9.2.5 Air Stripper Oxidizer Catalyst	9-6
      9.3   ENERGY REQUIREMENTS	9-7
      9.4   LABOR REQUIREMENTS  	9-8
                                    IV

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                    TABLE OF CONTENTS (continued)
SECTION 10 IMPLEMENTATION	10-1
      10.1  APPLICABLE WASTE STREAMS  	10-1
      10.2  DETERMINATION OF SUBCATEGORIES	10-2
      10.3  ESTABLISHING LIMITATIONS AND STANDARDS FOR FACILITY
                DISCHARGES 	10-4
           10.3.1 Facilities with One Operation	10-4
           10.3.2 Facilities with Operations Classified in Multiple Subcategories 10-5
Appendix A  RCRA And Waste Form Codes Reported by Facilities in 1989

Appendix B  Initial Pollutants Included in Sampling Program

Appendix C  Acronyms and Definitions

Index

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                               LIST OF TABLES


ES-1  Technology Basis for BPT Effluent Limitations	 ES-3
ES-2  Cost of Implementing Regulations [in millions of 1993 dollars]	 ES-4
3-1   RCRA Codes Reported by Facilities in 1989	3-4
3-2   Waste Form Codes Reported by Facilities in 1989	3-5
3-3   Quantity of Waste Received for Treatment	3-6
3-4   Distribution of Facility Discharge	3-8,
3-5   Quantity of Wastewater Discharged in 1989	3-9
3-6   Quantity of Treatment Residuals in 1989	3-10
4-1   Comparison of total facility discharge to total CWT discharge	4-4
4-2   Summary of Wastewater by Subcategory	4-6
4-3   Influent Concentrations Ranges for Selected Pollutant Parameters	4-8
4-4   Range of Metal Pollutant Influent Concentrations (mg/l)	4-10
4-5   Range of Organic Pollutant Influent Concentrations (mg/l)	4-11
4-6   Metals Subcategory Current Performance	4-16
4-7   Oils Subcategory Current Performance	4-19
4-8   Organics Subcategory Current Performance	4-22
5-1   Pollutants Selected for Regulation  	5-3
5-2   Pollutants Excluded from Regulation Due to the Concentration Detected .... 5-4
5-3   Pollutants Excluded from Regulation Due to Lack of Detection or Analysis
      at the Technology Option Facility  	5-5
5-4   Pollutants Excluded from Regulation Due to Ineffective Treatment	5-6
5-5   Generic Removals for Group C: Hydrocarbons  	5-11
5-6   Generic Removals for Group Q: Ethers	5-11
5-7   Final POTW Removals for CWT Pollutants	5-12
5-8   Volatile Override Analysis for CWT Pollutants  	5-15
5-9   Final Pass-Through Results for Metals Subcategory Option 3	5-16
5-10  Final Pass-Through Results for Oils Subcategory Options 2 and 3  	5-17
5-11  Final Pass-Through Results for Organics Subcategory Option 1  	5-18
6-1   Chemical Precipitation System Performance Data for CWT QID 059	... 6-6
6-2   Chemical Precipitation System Performance Data for CWT QID 105	6-6
6-3   Chemical Precipitation System Performance Data for CWT QID 230	6-7
6-4   Selective Metals Precipitation (Solid Metals Recovery) System
      Performance Data for CWT QID 130	6-7
                                      VI

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                         LIST OF TABLES (continued)
6-5   Selective Metals Precipitation (Liquid Metals Recovery) System
      Performance Data for CWT QID 130	6-8
6-6   Secondary Precipitation System Performance Data for CWT QID 130 ...... 6-8
6-7   Tertiary Precipitation System Performance Data for CWT QID 130	6-9
6-8   Overall Metals Precipitation System Performance Data for CWT QID 130 ... 6-9
6-9   Air Stripping System Performance Data 	6-21
6-10  Carbon Adsorption System Performance Data for Organics Subcategory  .. 6-28
6-11  Carbon Adsorption System Performance Data for Oils Subcategory  	6-29
6-12  Sequencing Batch Reactor System Performance Data	6-49
6-13  Ultrafiltration System Performance Data	6-56
6-14  Reverse Osmosis System Performance Data	6-59
6-15  Lancy Filtration System Performance Data	6-62
6-16  Liquid CO2 Extraction System Performance Data	6-65
7-1   Standard Capital Cost Factors	7-2
7-2   Standard O & M Cost Factors	7-3
7-3   CWT Subcategory Options	7-5
7-4   Monitoring Costs for the CWT Industry Cost Exercise  	7-40
7-5   RCRA Permit Modification Costs Reported in WTI Questionnaire  	7-41
7-6   State Land Costs for the CWT Industry Cost Exercise  		7-43
8-1   BPT Effluent Limitations for the Metals Subcategory	8-6
8-2   BPT Effluent Limitations for the Oils Subcategory (mg/l)	8-11
8-3   BPT Effluent Limitations for the Organics Subcategory (mg/l)	8-16
8-4   Cost of Implementing Proposed BPT Regulations [in millions of 1993 dollars]8-23
8-5   Cost of Implementing Proposed PSES  Regulations [in  millions of 1993 dollar8}24
8-6   Reduction in Direct Discharge of  Priority and Nonconventional Pollutants After
      Implementation of Proposed BPT/BAT Regulations	8-27
8-7   Reduction in Indirect Discharge of Priority and Nonconventional Pollutants After
      Implementation of Proposed PSES Regulations	8-28
9-1   Air Pollution Reductions for the CWT Industry	 9-2
9-2   Filter Cake Generation for the CWT Industry  .	9-4
9-3   Reverse Osmosis Concentrate Generation for the CWT Industry	9-4
9-4   Ultrafiltration Concentrate Generation for the CWT Industry	9-5
9-5   Activated Carbon Requirements for the CWT Industry	9-6
9-6   Air Stripper Oxidizer Catalyst Requirements for the CWT Industry .	9-6

                                      vii

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                         LIST OF TABLES (continued)

9-7   Energy Requirements for the CWT Industry	9-7
9-8   Labor Requirements for the CWT Industry	9-8
10-1  Pollutant Concentrations for Determination of Subcategory	10-3
                                    VIII

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LIST OF FIGURES
3-1
3-2
4-3
6-1
6-2
6-3
6-4
6-5
6-6
6-7
6-8
6-9
6-10
6-11
6-12
6-13
6-14
6-15
6-16
6-17
6-18
6-19
6-20
6-21
6-22
6-23
6-24
Distribution of Centralized Waste Treatment Facilities 	
Waste Receipt Procedures 	
Example of Non-CWT Wastewater Addition 	
Chemical Precipitation System Diagram 	
Clarification System Diagram 	
Plate and Frame Pressure Filtration System Diagram 	
Emulsion Breaking System Diagram 	
Equalization System Diagram 	
Air Stripping System Diagram 	 	
Multi-Media Filtration System Diagram 	
Carbon Adsorption System Diagram 	
Cyanide Destruction System Diagram 	 	 	
Chromium Reduction System Diagram 	 	
Electrolytic Recovery System Diagram 	
Ion Exchange System Diagram 	
Gravity Separation System Diagram 	
Dissolved Air Flotation System Diagram 	
Sequencing Batch Reactor System Diagram 	
Biotower System Diagram 	
Activated Sludge System Diagram 	
Ultrafiltration System Diagram 	
Reverse Osmosis System Diagram 	
Lancy Filtration System Diagram 	
Liquid CO2 Extraction System Diagram 	
Plate and Frame Pressure Filtration System Diagram 	
Belt Pressure Filtration System Diagram 	
Vacuum Filtration System Diagram 	
	 3-2
	 3-7
	 4-13
	 6-4
	 6-11
	 6-13
	 6-15
	 6-18
	 6-19
	 6-23
	 6-25
	 6-31
	 6-35
	 6-38
	 6-40
	 6-43
	 6-44
	 6-48
	 6-51
	 6-53
	 6-55
	 6-58
	 	 6-61
	 6-64
	 6-67
	 6-69
	 6-71
      IX

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EXECUTIVE SUMMARY
      EPA is proposing technology-based limits for the discharge of pollutants  into
navigable waters of the United States and into publicly-owned treatment works by existing
and new facilities that are engaged in the treatment of industrial waste from off-site
facilities  - the Centralized Waste Treatment  Point Source  Category.  This proposed
regulation would establish effluent limitations guidelines for direct dischargers based on
the following treatment technologies:  "best practicable control technology" (BPT), "best
conventional pollutant  control technology" (BCT),  and "best available technology
economically achievable" (BAT).  New source performance standards are based on "best
demonstrated technology." The proposal also would establish pretreatment standards for
new and  existing indirect dischargers.
      EPA identified 85 facilities which are included in the Centralized Waste Treatment
Industry.  The proposed effluent limitations guidelines and standards are intended to cover
wastewater discharges resulting from treatment of, or recovery of components from,
hazardous and non-hazardous industrial waste received from off-site facilities by tanker
truck, trailer/roll-off bins, drums, barges, or other forms of shipment.  Any discharges
generated from the treatment of wastes received through an open or enclosed conduit (i.e.,
pipeline, channels, ditches, trenches, etc.) from the original source of waste generation are
not included in the regulation. EPA has estimated that the proposed regulation will apply
to 72 facilities which discharge wastewater.  Sixteen facilities discharge wastewater
directly; and 56 discharge indirectly to publicly-owned treatment works (POTW). Facilities
in the Centralized Waste Treatment Industry accept many types of wastes for treatment
or recovery. The proposed regulation applies to the following activities:
            Subcategory A: Discharges from operations which treat, or treat and recover
            metals from, metal-bearing waste received from off-site,
                                      ES-1

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            Subcategory B: Discharges from operations which treat, or treat and recover
            oil from, oily waste received from off-site, and
            Subcategory C: Discharges from operations which treat, or treat and recover
            organics from, other organic-bearing waste received from off-site.

Such operations would include facilities whose exclusive operation is the treatment of off-
site generated industrial waste as well as industrial or manufacturing facilities that also
accept waste from off-site for centralized treatment.
      The EPA evaluated various treatment technologies in developing the effluent
limitations and  standards. Table ES-1 lists the treatment technologies that are proposed
for BPT limitations. Two options are being proposed for the Oils Subcategory because
limitations for  the less expensive proposed option are significantly less stringent than
limitations for other industries. However, the more stringent treatment option has a greater
cost The treatment technologies proposed for BPT are the same treatment technologies
proposed for BCT, BAT, NSPS, PSES, and PSNS.
      After identifying treatment technologies, the EPA developed a model for calculating
facility costs to upgrade present facility operations to the technology options proposed.
Table ES-2 presents the capital and annual operating and maintenance costs associated
with the proposed technology options.  In addition to the costs for upgrading facility
operations, costs were also calculated for modifying RCRA permits for facilities which
accept hazardous waste for treatment and for the additional monitoring requirements for
the proposed regulation. Overall, the proposed technology options are estimated to have
an annualized  cost of $49 million for the less stringent Regulatory Option 1 and $74 million
for the more stringent Regulatory Option 2.
                                      ES-2

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Table ES-1. Technology Basis for BPT Effluent Limitations
   Proposed Subpart
Name of Subcategory
Technology Basis
                      Metal-Bearing Waste
                      Treatment and
                      Recovery
                       Selective Metals Precipitation,
                       Pressure Filtration, Secondary
                       Precipitation, Solid-Liquid
                       Separation, and Tertiary
                       Precipitation

                       For Metal-Bearing Waste which
                       includes concentrated Cyanide
                       streams:

                       Pretreatment by Alkaline
                       Chlorination at specific operating
                       conditions
          B
Oily Waste Treatment
and Recovery
Regulatory Option 1: Ultrafiltration

Regulatory Option 2:
Ultrafiltration, Carbon Adsorption,
and Reverse Osmosis
                      Organic Waste
                      Treatment and
                      Recovery
                       Equalization, Air Stripping,
                       Biological Treatment, and
                       Multimedia Filtration
                                    ES-3

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Table ES-2. Cost of Implementing Regulations [in millions of 1993 dollars]
Subcategory
Metals Treatment and Recovery
Oils Treatment and Recovery -
Regulatory Option 1
Oils Treatment and Recovery -
Regulatory Option 2
Organics Treatment and Recovery
Regulatory Option 1
Regulatory Option 2
Number of
Facilities3
44
35
35
22
72
72
Capital
Costs
43.9
5.23
16.8
12.4
61.5
73.1
Annual O&M
Costs
33.5
3.15
29.7
4.5
41.2
67.7
The total number of facilities is less than the sum of the number of facilities in each
subcategory, because many facilities may operate in more than one subcategory.

      EPA estimated the amount of pollutant reductions that would result for each of the
proposed technology options. Currently, 262.1 million pounds of pollutants are estimated
to be discharge directly and indirectly to POTWs.   The proposed  regulation would
decrease the amount of pollutants currently discharge by 129 millions pounds of pollutants
for Regulatory Option 1 and 146 million pounds for Regulatory Option 2.
                                      ES-4

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SECTION 1
STATUTORY REQUIREMENTS
      Effluent limitations guidelines and standards for the Centralized Waste Treatment
Industry are being proposed under the authority of Sections 301, 304, 306, 307, and 501
of the 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), also referred to as "the Act."

1.1    LEGAL AUTHORITY

      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 and standards for industrial discharges.  These guidelines
and standards are summarized briefly in the following sections.

1.1.1  Best Practicable Control Technology Currently Available (BPT)
      (Section 304(b)(1) of the CWA)

      In the guidelines, EPA defines BPT effluent limits for conventional, priority, and
non-conventional pollutants. In specifying BPT, EPA looks at a number of factors. EPA
first considers the cost of achieving effluent reductions in relation to the effluent reduction
benefits.  The Agency  next considers: 1) the age of the equipment and facilities, the
processes employed and any required process changes,  engineering aspects of the
control technologies,  non-water quality  environmental  impacts  (including  energy
requirements), and such  other factors as the Agency  deems  appropriate  (CWA
ง304(b)(1)(B)).  Traditionally,  EPA establishes  BPT effluent limitations based on the
                                     1-1

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average of the best performances of facilities within the industry of various ages, sizes,
processes or other common characteristics. Where, however, existing performance within
a category or subcategory is uniformly inadequate, EPA may require higher levels of
control than currently in place in an industrial category (or subcategory) if the Agency
determines that the technology can be practically applied. BPT may be transferred from
a different subcategory or category.
      In the initial  stages of EPA CWA regulation, EPA efforts emphasized  the
achievement of BPT limitations for control of the "classical" pollutants (e.g., TSS,  pH,
BODS). However, nothing on the face of the statute explicitly restricted BPT limitation to
such pollutants.  Following passage of the Clean Water Act of 1977 with its requirement
for points sources to achieve best available technology limitations to control discharges
of toxic pollutants, EPA shifted its focus to address the listed priority pollutants under the
guidelines program.  BPT guidelines  continue to include limitations  to address all
pollutants.

1.1.2 Best Conventional Pollutant Control Technology (BCT)
      (Section 304(a)(4) of the CWA)

      The 1977 Amendments added Section 301(b)(2)(E) to the Act establishing BCT for
discharges of conventional pollutants from existing industrial point sources.  Section
304(a)(4)  designated the following  as  conventional pollutants:  Biochemical oxygen
demanding pollutants (BOD),  total suspended solids,(TSS), fecal coliforrn,  pH, and  any
additional pollutants defined by the Administrator as conventional.  The Administrator
designated oil and grease as an additional conventional pollutant on July 30,  1979 (44 FR
44501).   BCT is not an additional limitation, but replaces BAT  for  the  control of
conventional pollutants. In addition to other factors specified in Section 304(b)(4)(B), the
Act requires that BCT limitations be established in light of a two-part "cost-effectiveness"
test  [American Paper Institute v. EPA,  660 F.2d 954 (4th Cir. 1981)].  EPA's  current
                                      1-2

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methodology for the general development of BCT limitations was issued in 1986 (51 FR
24974; July9, 1986).

1.1.3  Best Available Technology Economically Achievable (BAT)
      (Sections 304(b)(2)(B) of the CWA)

      In general, BAT effluent limitations guidelines represent the best  economically
achievable performance of plants in the industrial subcategory or category.  The CWA
establishes BAT as a principle means of controlling the direct discharge of priority and
non-conventional pollutants to waters of the United States. The factors considered in
assessing BAT include the cost of achieving BAT effluent reductions, the age of equipment
and facilities involved, the process employed, potential process changes, and non-water
quality environmental impacts,  including  energy requirements.  The Agency retains
considerable discretion in assigning the weight to be accorded these factors. Unlike BPT
limitations, BAT limitations may be based on effluent reductions attainable through
changes in a facility's processes and operations.  As with BPT, where existing performance
is uniformly inadequate, BAT may require a higher level of performance than is currently
being achieved based on technology transferred from a  different subcategory or category.
BAT may  be based upon process changes  or internal  controls, even when  these
technologies are not common industry practice.

1.1.4  New Source Performance Standards (NSPS) (Section 306 of the CWA)
      NSPS reflect effluent reductions that are achievable based on the best available
demonstrated treatment technology.  New plants have the opportunity to install the best
and most efficient production processes and wastewater treatment technologies. As a
result, NSPS  should represent, the most stringent controls  attainable  through  the
application of the best available control technology for all pollutants (i.e., conventional,
nonconventional, and toxic pollutants). In establishing NSPS, EPA is directed to take into
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consideration the cost of achieving the effluent reduction and any non-water quality
environmental impacts and energy requirements.

1.1.5  Pretreatment Standards for Existing Sources (PSES)
      (Section 307(b) of the CWA)

      PSES are designed to prevent the discharge of pollutants that pass-through,
interfere-with, or are otherwise incompatible with the operation of publicly-owned treatment
works (POTW).  The CWA  authorizes  EPA to establish pretreatmenl: standards for
pollutants that pass-through  POTWs  or interfere with treatment processes or sludge
disposal methods  at  POTWs.   Pretreatment standards are technology-based and
analogous to BAT effluent limitations guidelines.
      The General Pretreatment Regulations, which set forth the framework for the
implementation of categorical pretreatment standards, are found in 40 CFR Part 403.
Those regulations contain a definition of pass-through that addresses localized rather than
national instances of pass-through and establishes pretreatment standards that apply to
all non-domestic dischargers (52 FR 1586).

1.1.6  Pretreatment Standards for New Sources (PSNS) (Section 307(b) of the CWA)

      Like PSES, PSNS are designed to prevent the discharges of pollutants that pass-
through, interfere-with, or are otherwise incompatible with the operation of POTWs. PSNS
are to be issued at the same time as NSPS. New indirect dischargers have the opportunity
to incorporate into their plants the best available demonstrated technologies.  The Agency
considers the same factors in promulgating PSNS as it considers in promulgating NSPS.
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1.2   SECTION 304(M) REQUIREMENTS AND LITIGATION

      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 established an Effluent
Guidelines Plan (55 FR 80), in which schedules were established for developing new and
revised effluent guidelines for several industrial categories. One of the industries for which
the Agency established  a schedule was the Waste Treatment Industry Phase I -
Centralized Waste Treatment.
      Natural Resources Defense Council, Inc.  (NRDC) and  Public Citizen,  Inc.
challenged the Effluent Guidelines Plan in a suit filed in U.S. District Court for the District
of Columbia (NRDC et al v. 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 subcategories of the Centralized  Waste
Treatment Industry by April 1994, and take final action by January 1996.  In March 1994,
due to project delays, an unopposed motion was filed to the court to extend the proposal
until December 1994 and  promulgation until September 1996.
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SECTION 2
DATA COLLECTION
      EPA has gathered and evaluated technical and economic data from various sources
in the course of developing the effluent limitations guidelines and standards for the
Centralized Waste Treatment Industry. These data sources include:

            Responses to EPA's "1991 Waste Treatment Industry Questionnaire,"
            Responses to EPA's "Detailed Monitoring Questionnaire,"
            EPA's 1990 - 1994 sampling  of  selected  Centralized Waste Treatment
            facilities,
      •      Literature data, and
            Other EPA studies of Treatment, Storage, Disposal, and Recycling facilities.

      EPA has used data from these sources to profile the industry with respect to:
wastes received for treatment or recovery, treatment/recovery processes, geographical
distribution, and wastewater and solid waste disposal practices. EPA then characterized
the wastewater generated by treatment/recovery operations through an evaluation of water
usage, type of discharge or  disposal,  and  the occurrence of  conventional, non-
conventional, and priority pollutants.

2.1   CLEAN WATER ACT SECTION 308 QUESTIONNAIRES

2.1.1  Development of Questionnaires

      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 Water Act.  These questionnaires typically
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request information concerning treatment processes, wastes received for treatment, and
disposal  practices as  well  as  wastewater treatment  system performance  data.
Questionnaires also request financial and economic data for use in assessing economic
impacts and the economic achievability of technology options.
      EPA  used   its  experience with previous  questionnaires  to  develop two
questionnaires (the 1991 Waste  Treatment Industry Questionnaire and the Detailed
Monitoring  Questionnaire) for this  study.   The 1991  Waste Treatment  Industry
Questionnaire was designed to request 1989 technical, economic, and financial data to
describe industrial operations adequately from a census of the industry.  The Detailed
Monitoring Questionnaire was designed to  elicit daily analytical data from a limited number
of facilities which would be chosen after receipt and review of the 1991 Waste Treatment
Industry Questionnaire responses.
      For the 1991 Waste Treatment Industry Questionnaire, EPA wanted to minimize the
burden to Centralized Waste Treatment facilities because these facilities are also required
to complete extensive paperwork under the Resource Conservation and  Recovery Act.
A questionnaire was developed for which recipients could use information reported in their
1989 Hazardous Waste Biennial Report to complete specific tables as well as any other
readily accessible data.  The questionnaire  specifically requested information on:

      •     treatment/recovery processes,
      •     types of waste received for treatment,
      •     wastewater and solid waste disposal practices,
            ancillary waste management operations,
      •     summary analytical monitoring data,
            the degree of co-treatment  (treatment of waste received from off-site with
            other on-site industrial waste),
      •     cost of waste treatment/recovery processes, and
            the extent of wastewater recycling or reuse at facilities.
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      In the 1991 Waste Treatment Industry Questionnaire, EPA requested summary
monitoring data from  all recipients,  but summary information  is  not  sufficient for
determining limitations and industry variability.   Therefore, the Detailed Monitoring
Questionnaire was designed to collect daily analytical  data from a  limited number of
facilities. Facilities would be chosen to complete the Detailed Monitoring Questionnaire
based on  technical information  submitted  in the  1991 Waste Treatment Industry
Questionnaire, such as on-site treatment technologies, types of waste accepted for
treatment, and present permit limitations.  The burden was also minimized in the Detailed
Monitoring Questionnaire by tailoring the questionnaire to the facility operations.
      Due to the lack of monitoring data on the wastewater treatment system influent,
waste receipt data for a six-week period was also requested in the Detailed Monitoring
Questionnaire. Waste receipt data are forms containing information on specific shipments
of waste. A limit of six weeks was placed on this request  to minimize the burden to
facilities responding as well as to request a manageable set of data.
      EPA sent draft questionnaires to industry trade associations, treatment facilities who
had expressed interest, and environmental groups for review and comment.  A pre-test of
the 1991 Waste Treatment Industry Questionnaire was also conducted at nine Centralized
Waste Treatment facilities to determine if the type of information necessary would be
received from the questions posed  as well as to determine if questions were designed to
minimize the burden to facilities. A pre-test of the Detailed Monitoring Questionnaire was
not possible due to project schedule limitations.
      Based on comments from the reviewers,  EPA determined the draft questionnaire
required minor adjustments in the technical section, but extensive revisions were required
for the economic and financial section. These revisions were  required  because this data
collection effort was the first attempt at requesting information from a service industry as
opposed to a manufacturing-based industry.
      As required  by the  Paperwork  Reduction  Act, 44 U.S.C. 3501  et seq.,  EPA
submitted the questionnaire package  (including the revised 1991  Waste Treatment
Industry  Questionnaire and the  Detailed Monitoring Questionnaire) to  the Office of
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Management and Budget (OMB) for review, and published a notice in the Federal Register
to announce the questionnaire was available for review and comment (55 FR 45161). EPA
also redistributed the questionnaire package to industry trade associations, Centralized
Waste  Treatment Industry  facilities,  and  environmental  groups that  had provided
comments on the previous draft and to any others who requested  a copy  of the
questionnaire package.
      No additional comments were received. In fact, one industry trade association
submitted comments to OMB in favor of the questionnaire and requested OMB's immediate
clearance.  OMB cleared the entire questionnaire package for distribution on April 10,
1991.

2.1.2 Distribution of Questionnaires
      EPA identified 455 facilities as possible Centralized Waste Treatment facilities from
various sources, such as the respondent list to the Survey of Treatment, Storage,
Disposal, and Recycling Facilities, companies listed in the Environmental Information (El)
Directory, companies listed in  major city telephone directories under  environmental
services, and facilities listed in the Toxic Release Inventory (TRI) data which receive waste
from off-site.
      Under the authority of Section 308 of the Act,  EPA distributed the 1991 Waste
Treatment Industry Questionnaire to all 455 facilities in the EPA facility database. EPA
received responses from 413 facilities (a 91 % response rate). In  general,  after review of
the responses, EPA concluded that 326 facilities were not in the scope of the proposed
regulation either because they were closed or the facility did not meet the profile of a CWT
facility.  The responses indicated that 89 respondents received waste from off-site for
treatment or recovery.  Four of the 89 received waste via a  conduit (e.g., pipeline,
trenches, or ditches) from the original source of waste generation and are not covered
under the proposed regulation.  Therefore, 85 facilities were identified as being in the
Centralized Waste Treatment Industry.
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      In addition to information obtained through the 1991 Waste Treatment Industry
Questionnaire, information was also obtained through follow-up phone calls and written
requests for clarification of questionnaire responses.
      After receipt of 1991 Waste Treatment Industry  Questionnaire  responses,
information was reviewed and nineteen facilities were chosen to complete the Detailed
Monitoring Questionnaire based on: types and quantities of wastes received for treatment;
quantity of on-site generated wastewater not resulting from treatment or recovery  of off-site
generated  waste;  treatment/recovery technologies  operated; wastewater discharge
options; and present wastewater permit limitations.

2.2   SAMPLING PROGRAM

2.2.1  Pre-1989 Sampling Program

      From 1986  to 1987, twelve facilities were sampled to  characterize the waste
streams and on-site treatment technology performance at hazardous waste incinerators,
Subtitle C and D landfills, and facilities which receive waste from off-site for treatment as
a part of the Hazardous Waste Treatment Industry Study.  All of the facilities in this
sampling  program had multiple operations,  such  as  incineration  and  commercial
wastewater treatment.   The  sampling  program did not  focus on characterizing  the
individual waste streams from different operations. Therefore, the data collected cannot
be used for the characterization of Centralized Waste Treatment wastewater, assessment
of treatment performance,  or the development of limitations and standards.  Information
collected in the study is presented in the Preliminary Data Summary for the Hazardous
Waste Treatment Industry (EPA 440/1 -89/100).
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2.2.2
1989 - 1993 Sampling Program
2.2.2.1
Facility Selection
      Between 1989 and 1993, EPA visited 26 of the 85 centralized waste treatment
facilities. During each visit, EPA gathered the following information:
            the process for accepting waste for treatment or recovery,
            the types of waste accepted for treatment,
            design and operating procedures for treatment technologies,
      •     general facility management practices,
            wastewater discharge options,
            solid waste disposal practices, and
      •     other facility operations.

After reviewing the information  received during facility site visits, the EPA chose the
facilities to be sampled by assessing whether the wastewater treatment system (1) was
effective in removing pollutants; (2) treated wastes received from a variety of sources, (3)
employed either novel treatment technologies or applied traditional treatment technologies
in a novel manner, and (4) applied waste management practices that increased the
effectiveness of the treatment unit.
      The EPA also needed to determine if the CWT portion of the facility flow was
adequate to assess the treatment system performance for CWT waste streams. For many
facilities, the CWT operations were minor portions of the overall site operation. In such
cases, when the CWT waste stream is commingled prior to treatment, characterizing the
CWT waste stream and assessing the treatment performance in  respect to a CWT waste
stream would be difficult and therefore could not be used to establish effluent limitations
guidelines and standards for the Centralized Waste Treatment Industry.
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      Another important aspect, when selecting facilities for the sampling program was
the quantity of non-CWT wastewater treatment with CWT wastewater. For example, many
facilities treated metal-bearing and oily waste in the same treatment system. The EPA
needed to assess if these pollutants were being removed when these waste streams were
treated in the same treatment system or if dilution was occurring.
       Based on information received during the visits and responses to the 1991 Waste
Treatment Industry Questionnaire, EPA selected eight of the 26 facilities to be included
in the wastewater sampling program  for establishing limitations and standards.  An
additional facility was sampled  to  characterize  the wastes received  and treatment
processes  of a facility that treated only non-hazardous waste.  The other 17 facilities
visited were not sampled, because they did not meet the criteria listed above.
       Based on information received, EPA chose six facilities to be sampled to assess the
performance at facilities which treated metal-bearing waste. All of the facilities visited
used metals precipitation as a means for treatment, but each of the systems was unique
due to the chemicals used and actual treatment set-up. Most facilities precipitated metals
in batches.  Similar waste receipts were mixed and the metals were precipitated in a one
step process. One facility separated each waste shipment into separate treatment tanks
to facilitate the  precipitation of specific metals and then transferred the batch to another
tank to precipitate  additional  metals.  Another facility had a continuous system for
precipitation: whereas, the wastewater flowed from one treatment chamber to another and
in each chamber different chemicals were used.
       For oily wastes, three facilities were sampled to characterize the waste streams and
assess the  treatment performance. All three facilities used chemical emulsion-breaking
processes  to initially separate oil-water mixtures.  For two of the three facilities, the
wastewater from emulsion-breaking was commingled with metal-bearing CWT wastewater
prior to further treatment.  One facility treated the wastewater from emulsion-breaking in
a system specifically designed to treat  oily wastes and  the oily wastewater was not
commingled with other waste streams. No other facilities were identified for sampling
because most of the facilities accepted other types of waste for treatment and  did not
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operate treatment systems specifically designed for treatment of oily wastes as in the case
with two of the facilities sampled.
      Two organic waste treatment facilities were sampled to characterize the waste
streams and assess treatment performance. One facility treated the organic waste stream
by the following sequence of treatment technologies;  two air-strippers in series equipped
with air pollution control devices, biological treatment in a Sequential Batch Reactor,
multimedia filtration, and final polishing by carbon adsorption  units.  The other facility
utilized a patented CO2 extraction process to recover organic compounds for use as fuel
and treated the resulting wastewater via carbon adsorption.  No further facilities were
identified for sampling because most of the facilities treating organic waste have other
industrial operations and the portion of CWT waste was minor in comparison to the overall
facility flow.
2.2.2.2
Sampling Episodes
      After a facility was chosen to participate in the sampling program, a draft sampling
plan was prepared which described the location of sample points and analysis to be
performed at specific sample points as well as the procedures to be followed during the
sampling episode. Prior to sampling, a copy of the draft sampling plan was provided to the
facility for review and comment to ensure the EPA properly described  and understood
facility operations.  All comments were incorporated into the final sampling plan.  During
the sampling episode, teams of EPA employees and contractors collected and preserved
samples.  Samples were sent to EPA approved  laboratories for analysis. Samples were
collected at influent, intermediate, and effluent points. Facilities were given the option to
split samples with the EPA, but most facilities declined.  Following the sampling episode,
a draft sampling report was prepared that included descriptions of the treatment/recovery
processes,  sampling procedures, and analytical results.  After all  information was
gathered, the reports were provided to facilities for review and comment. Corrections were
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incorporated into the final report. The facilities also identified any information in the draft
sampling report that were to be considered Confidential Business Information.
      At the initial two sampling episodes, the entire spectrum of chemical compounds for
which there  are EPA-approved analytical methods were  analyzed (more  than  480
compounds).  All compounds were analyzed because no data was received from facilities
to narrow the list of analytes.  After a review of initial analytical data, the number of
constituents analyzed was decreased to 320 by omitting analysis for dioxins/furans,
pesticides/herbicides, methanol, ethanol, and formaldehyde.  Pesticides/herbicides were
analyzed on  a limited basis depending on the treatment chemicals used at facilities.
Dioxin/furan analysis was performed on a limited basis for  solid/filter cake samples to
assess possible environmental impacts.
      Data was collected for a variety of treatment systems handling a variety of wastes.
Information on the waste stream characteristics is included  in Section 4 and  treatment
system performance is included in Section 6.

2.2.3 1994 Sampling Program

      In 1994, an additional four facilities were visited to  identify the  types of waste
presently being accepted at oily waste treatment facilities.  These facilities were not in
operation at the time the questionnaire was mailed, and they specialize in the treatment
of bilge waters and unstable oil-water mixtures.  In the 1989 -1993 sampling program, oily
waste treatment facilities were characterized as treating concentrated, stable oil-water
emulsions. According to information received from permit writers, the industry trend has
been in the area of bilge water treatment.  From these site visits, one facility was chosen
to be sampled based on the on-site treatment and type of oily waste accepted for
treatment.  At the time of proposal, the analytical data could not be reviewed, but are
included in the regulatory record. The information collected will be used for re-evaluating
EPA's characterization of the oily wastes accepted for treatment.  EPA will re-assess the
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pollutant concentrations detected at oily waste treatment facilities as well as evaluate
additional treatment technologies.
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SECTION 3
DESCRIPTION OF THE INDUSTRY
      Development of a Centralized Waste Treatment Industry is a probable outgrowth
of the increased pollution control measures required by CWA and RCRA requirements.
In order to comply with CWA discharge limits, industries covered by categorical regulations
installed new (or upgraded existing) wastewater treatment facilities in order to treat their
process wastewater.  But the wastewater treatment produced a residual sludge which
required further treatment before disposal under RCRA requirements.  Furthermore, many
industrial process by-products were now, for regulatory purposes,  classified as either
RCRA listed or characteristic hazardous  wastes which  required special handling or
treatment before disposal. Therefore, a market for waste management was developed due
to the demand of waste management services.
      In the early 1990's, this industry experienced a slow down because many existing
facilities were designed to handle larger quantities of wastes than the market produced.
Generally, reduced economic activity, in combination with pollution prevention measures,
resulted in a decrease in the amount  of waste sent off-site for treatment.  Also, the
available  capacity  in  the  industry reflected  industry anticipation  that upcoming
environmental regulations would be increasingly stringent and thereby increase the
demand for waste management services. As a result, when demand  failed to materialize
as expected, competition among facilities increased. This  resulted in facilities operating
below capacity and experiencing economic and financial difficulties. This trend may be
changing at the present. Recently, participants in the March  1994 public meeting for this
proposal stated  that  the  industry is  experiencing new  growth  due to  increasing
environmental regulations.
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3.1   GENERAL INFORMATION

      In 1989, EPA identified 85 facilities that accept by any form of shipment hazardous
or non-hazardous industrial waste from off-site for treatment or recovery. The distribution
of the 85 Centralized Waste Treatment facilities in the United States is pressented in Figure
3-1.  Most facilities are located in the eastern half of the United States with the highest
concentration in the Mid-West.  Many facilities are located close to large industrial areas
to facilitate the transfer of waste from manufacturing facilities.
      Most facilities receive waste via tanker truck. However, other forms of shipment are
used for transporting wastes, such as trailers/roll-off boxes,  drums, and barges. In the
data collection, EPA identified four facilities which were receiving all of the waste from off-
site via a pipeline. In evaluating  the operations and waste accepted at such facilities,  EPA
determined that their operation was not similar to a facility which received waste by other
  Figure 3-1.  Distribution of Centralized Waste Treatment Facilities
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forms of shipment and therefore would not be included in the scope of the proposed
effluent limitations guidelines and standards.
      The wastes sent by way of a conduit (i.e., pipeline, trenches, ditches,  etc.) for
treatment were characterized as process wastewater from existing categorical industries,
not concentrated, difficult-to-treat wastes.  Therefore, Best Professional Judgment (BPJ)
discharge permits for facilities accepting waste via a conduit should be developed using
the categorical standards from the industries which are sending the waste.
      Many facilities have other industrial  operations on-site in addition to a Centralized
Waste Treatment facility. These industrial processes include other waste management
operations (i.e., landfills, incinerators, solidification or fuel blending processes, etc.) or
manufacturing operations. Approximately, 14 facilities are manufacturers of products.  The
most common manufacturing industries represented are organic chemicals and inorganic
chemicals.  The effect of the addition of other industrial wastewater is only discussed if the
other industrial wastewater is co-treated with Centralized Waste Treatment wastewater.
For these types of facilities, in general, CWT wastewater accounts for only 7% of the
overall facility flow.
      Some information normally used to  describe an industry was not available for this
study.   For example, U.S.  Department of Commerce, Bureau of the Census Standard
Industrial Classification (SIC) codes are typically used by industries to describe a facility
operation.  No SIC codes exist for the Centralized Waste Treatment Industry.  Some
facilities have chosen 4959 as the SIC code, Sanitary Services,  Not Elsewhere Classified.
This classification, however, actually pertains to services such as beach maintenance, oil
spill clean-up, snowplowing, etc.

3.2   WASTES RECEIPTS
      As previously explained, EPA also collected various information was collected
pertaining to the types of waste  accepted for treatment.  Seventy-two out of the 85
Centralized Waste Treatment facilities are RCRA-permitted  treatment, storage,  and
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disposal facilities (TSDFs). Therefore, a majority of facilities was able to use information
reported in the 1989 Biennial Hazardous Waste Report to classify the wastes accepted for
treatment by the appropriate RCRA and Waste Form Codes.
      Most of the waste treated at Centralized Waste Treatment facilities is characterized
as highly-concentrated and consequently difficult-to-treat. The concentration of pollutants
detected  in the raw wastewater was the  highest detected  in existing categorical
regulations.

3.2.1  Waste Receipt Types

      Facilities received a wide variety of hazardous and non-hazardous industrial waste
for treatment in the Centralized Waste Treatment Industry. For hazardous wastes, RCRA
Codes are often used to categorize wastes. The RCRA codes reported in the 1991 Waste
Treatment Industry Questionnaire are listed in Table 3-1.  Most of the RCRA codes do not
contain information regarding the waste characteristics such as chemical constituent or
concentration of chemical constituents.
Table 3-1.  RCRA Codes Reported by Facilities in 1989.
RCRA Codes
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D011
D012
D017
D035
F001
F002
F003
F004
F005
F006
FOOT
F008
F009
F010
F011
F012
F019
F039
K001
K011
K013
K014
K015
K016
K031
K035
K044
K045
K048
K049
K050
K051
K052
K061
K063
K064
K086
K093
K094
K098
K103
K104
P011
P012
P013
P020
P022
P028
P029
P030
P040
P044
P048
P050
P063
P064
P069
P071
P074
P078
P087
P089
P098
P104
P106
P121
P123
U002
U003
U008
U009
U012
U013
U019
U020
U031
U044
U045
U052
U054
U057
U069
U080
U092
U098
U105
U106
U107
U113
U118
U122
U125
U134
U135
U139
U140
1)150
U151
U154
U159
U161
U162
U188
U190
U205
U210
U213
U220
U226
U228
U239
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      In the Hazardous Waste Biennial Report, Waste Form Codes are used to further
characterize the wastes received for treatment.  The Waste  Form Codes reported by
Centralized Waste Treatment facilities are listed in Table 3-2%  Definitions of the RCRA
Codes and Waste Form Codes are listed in Appendix A.  Some facilities, especially those
that treat non-hazardous waste, did not report the Waste Form Code information due to
the variety and complexity of their operations.

Table 3-2.   Waste Form Codes Reported by Facilities in 1989.
Waste Form
B001
B101
B102
B103
B104
B105
B106
B107
B108
B109
B110
B111
B112
B113
B114
B115
B1.16
B117
B119
B201
B202
B203
B204
B205
B206
B207
B208
B209
B210
B211
B219
B305
B306
B307
B308
B309
Codes
B310
B312
B313
B315
B316
B319

B501
B502
B504
B505
B506
B507

B508
B510
B511
B513
B515
B518

B519
B601
B603
B604
B605
B607

B608
B609




      In Table 3-3, information on the quantity of hazardous and non-hazardous industrial
waste received for treatment or recovery is compiled.  Many facilities which are permitted
to accept hazardous wastes also treat or recover a large quantity of non-hazardous
wastes.  For purposes of the proposed effluent limitations guidelines and standards,
"hazardous wastes" are those defined by RCRA as hazardous. State-defined hazardous
wastes, such as waste oils, are classified as non-hazardous for the purposes of this study.
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Table 3-3. Quantity of Waste Received for Treatment
Type of Waste
Hazardous
Non-Hazardous
Quantity of Waste (gal/yr)
Total
506,415,098
384,316,949
Average
8,052,183
12,974,482
Minimum
1,200
5,825
Maximum
85,200,000
232,599,789
      An additional potential source of information on the characterization of the wastes
treated at a CWT operation is descriptive data from the generator of a v/aste. However,
most CWT facilities did not collect information on the process for which the waste was
generated.  In general, based on information collected for these guidelines and standards,
the most common forms of waste receipts were sludges from tank bottoms or treatment
processes, rinse water from cleaning operations, and soil and wastewater from remediation
activities.

3.2.2 Procedures for Receipt of Wastes

      In the process of gathering information, the procedures for accepting a waste for
treatment or  recovery were studied.  The same general procedure is  used for most
facilities. The process is outlined in Figure 3-2.
      In general, facilities require the waste generator to provide extensive paper work
on the waste, such as analytical data, descriptive characteristics and chain of custody
reports.  Generators must also supply a sample of the waste stream to be treated with
corresponding laboratory analysis.  Then, the Centralized Waste Treatment facility
performs further analysis and bench-scale treatability studies to determine if the waste can
be handled in their treatment/recovery system.  If the facility determines it can handle the
waste, a price for the treatment of the given sample is established.  After a price for
treatment is established, the generator may then begin to transport the approved waste
stream to the treatment facility.
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     Sample of Waste
      Sent to Facility
Waste Profile and
   Bench Scale
Treatability Tests
  are Performed
Treatment Scheme
   is Developed
        Cost for Treatment
          is Determined
             Company Makes Decision
              on Treatmentof Waste
         Waste is Shipped
      to Facility for Treatment
              Shipment is Analyzed to
                Determine if Waste
               Matches Initial Sample
Figure 3-2.  Waste Receipt Procedures
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      Upon receipt of the waste shipment, a sample is taken for analysis. The analysis
is compared to the original sample.  If the analysis matches, the shipment is approved for
treatment.  If the analysis does not match, a new price for treatment may be determined
or the shipment may be refused for treatment.
3.3   DISCHARGE INFORMATION

      In general, three basic options are available for disposal of wastewater treatment
effluent:  direct, indirect, and zero( or alternative) discharge.  Direct dischargers are
facilities that discharge effluent directly into a surface water.  Indirect dischargers are
facilities which discharge effluent to a publicly-owned treatment works (POTW).  Zero or
alternative dischargers do not generate a wastewater nor do they discharge to a surface
water or POTW. The types of zero or alternative discharge identified as employed in the
Centralized Waste Treatment Industry are underground injection control (UIC), off-site
transfer for further treatment, and evaporation. Table 3-4 lists the number of dischargers
for each discharge option.

Table 3-4.  Distribution of Facility Discharge
Discharge Option
Direct
Indirect
Direct and UIC
UIC
Off-Site
Evaporate
No Wastewater Generated
No. of Facilities
15
56
1
4
6
2
1
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      In 1989, more than 3.0 billion gallons of wastewater were generated for disposal.
Average facility information is presented in Table 3-5 for each discharge option.  The
proposed effluent  limitations guidelines  and  standards for  the  Centralized  Waste
Treatment Industry do not apply to facilities with a zero or alternative discharge.
Table 3-5.   Quantity of Wastewater Discharged in 1989
Discharge
Option
Direct
Indirect
UIC
Off-Site
Evaporate
Quantity Discharged in 1989 (gal)
Total
2,314,110,276
702,286,054
119,737,220
2,498,944
1,728,213
Average
144,631,892
12,540,822
24,912,424
416,491
864,106
Minimum
20,605
2,718
4,736,000
9,112
730,000
Maximum
1,169,975,506
155,655,000
51,529,663
1,408,810
998,213
3.4   TREATMENT RESIDUALS

      Various  types of residuals  were generated from the treatment  or  recovery
processes. In 1989, more than 1.1 billion pounds of treatment residuals were generated.
Information on the quantity of treatment residuals and disposal practices by facilities is
presented in Table 3-6.  The disposal practice used depends on the residual content.
Metal-bearing residuals are most predominately disposed in Subtitle C or D landfills. The
regulatory classification of the landfill used is dependent on the quantity of metals present
in the residual and their ability to leach from the residual.  Oily treatment residuals are
typically reused for fuel in on-site or off-site operations.  Organic residuals are usually sent
to incinerators for disposal.
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Table 3-6.   Quantity of Treatment Residuals in 1989
Disposal Practice
Subtitle C Landfill
(33)
Subtitle D Landfill
(31)
Land Application
(2)
Hauled Off-Site
(16)
Recycled Off-Site
(17)
Incineration
(10)
Sold as Product
(4)
Quantity of Treatment Residual in 1989 (Ibs)
Total
2,582,347,377
684,071,793
15,800
163,014,881
816,971,414
5,754,400
59,796,396
Average
- 7,646,890
22,147,611
7,900
10,188,430
48,057,142
575,440
14,949,099
Minimum
75
9
5,780
5,984
300
548
332,000
Maximum
80,053,988
135,142,804
10,020
103,025,422
791,096,475
3,532,314
49,668,281
Note: The number of facilities using each disposal practice is listed in parentheses.
3.5   INDUSTRY SUBCATEGORIZATION

      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 has a uniform set of effluent limitations
which take into  account technology achievability and economic impacts unique to that
subcategory.
      The factors considered in the subcategorization of the Centralized Waste Treatment
Point Source Category include:
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             Type of waste received for treatment,
             Treatment process,
             Nature of wastewater generated,
             Facility size,
             Facility age,
             Facility location,
             Non-water quality impact characteristics, and
             Treatment technologies and costs.

      EPA evaluated these factors and determined that subcategorization is appropriate
for this industry. These evaluations  are discussed in detail in the following section.

3.5.1  Development of Subcategorization Scheme
      In establishing the subcategories set forth in this rulemaking, EPA took into account
all information it was able to collect and develop with respect to the following factors:
waste type received; treatment process; nature of wastewater generated; dominant waste
streams; facility size, age, and location; non-water quality impact characteristics; and
treatment technologies and costs.
      In this industry, a wide variety of wastes are treated at a typical facility. Facilities
employ different waste treatment technologies tailored to the specific type of waste being
treated in a given day. The operation of a facility changes daily depending on the type of
waste accepted for treatment.  Due to changing markets facilities may change the facility
operation frequently. Therefore, many of the traditional  subcategorization bases for
facilities manufacturing products on a consistent basis are not applicable to this industry.
      EPA concluded a number of factors did not provide an appropriate basis for
subcategorization, because the industry must change to meet the market and regulatory
demands.  The Agency concluded  that the age of a facility  should  not be a basis for
subcategorization because many older facilities have unilaterally improved or modified
                                      3-11

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their  treatment  process over  time.   Facility  size  is also  not  a useful basis for
subcategorization for the Centralized Waste Treatment Industry because there is only
limited scale economics associated with waste treatment. Wastes can be treated to the
same level regardless of the facility size.,  Likewise, facility location is not a good basis for
subcategorization; no consistent differences in wastewater treatment performance or costs
exist because of geographical location. Although non-water quality characteristics (solid
waste and air emission effects) are of concern to EPA, these characteristics did not
constitute a basis for subcategorization. Environmental impacts from solid waste disposal
and from the transport of potentially hazardous wastewater are a result of individual facility
practices and EPA could not identify  practices that apply uniformly across different
segments  of the industry.   Treatment  costs  do  not  appear  to  be a basis for
subcategorization  because costs will vary and are dependent on the waste stream
variables such as flow rates, wastewater quality, and pollutant loadings.  Therefore,
treatment costs were not used as a factor in determining subcategories.
       EPA identified only one factor with  primary significance for subcategorizing the
Centralized Waste Treatment Industry: type of waste received for treatment or recovery.
This factor encompasses many of the other subcategorization factors.  The type of
treatment processes used, nature of wastewater generated, solids generated, and air
emissions directly correlate to  the type of waste received  for treatment or recovery.
Therefore, the type of waste received for treatment or recovery was determined to be the
appropriate basis for subcategorization  of this industry.

3.5.2  Proposed Subcategories

       Based on the type of wastes accepted for treatment or recovery, EPA has defined
three subcategories for the Centralized  Waste Treatment Industry.
             Subcategory A:
Operations which treat, or treat and recover metal from,
metal-bearing waste received from off-site,

       3-12

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            Subcategory B:

            Subcategory C:
                   Operations which treat, or treat and recover oil from,
                   oily waste received from off-site, and
                   Operations which treat, or treat and recover organics
                   from, organic-bearing waste received from off-site.
3.5.2.1
Metal-Bearing Waste Treatment and Recovery Subcategory
      This Subcategory applies to discharges resulting from the treatment or recovery of
metal-bearing waste. Currently, 56 facilities have been identified as treating metal-bearing
wastes in some cases for recovery of metals for sale in commerce or for return to industrial
processes.  EPA proposes to regulate the conventional, priority, and non-conventional
pollutants in this Subcategory.  This Subcategory also includes facilities which treat highly-
concentrated, complex cyanides.
3.5.2.2
Oily Waste Treatment and Recovery Subcategory
      This subcategory applies to discharges resulting from the treatment or recovery of
oily waste.  Currently, 35 facilities have been identified as treating and recovering oily
waste.  EPA  proposes to regulate conventional, priority, and non-conventional pollutants
in this subcategory.  Most of the waste accepted for treatment and recovery in 1989 was
stable oil-water emulsions resulting from cleaning fluids and lubricants which are difficult
to treat.  Other types of oily waste accepted for treatment include bilge waters and tank
cleaning wastewater.
                                      3-13

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3.5.2.3
Organic Waste Treatment and Recovery Subcategory
      This subcategory applies to discharges resulting from the treatment and recovery
of organic waste.  Currently, 22 facilities operate organic waste treatment processes.
Organic recycling processes, such as solvent recycling, are not included in this regulation.
The wastes accepted for treatment in this subcategory are typically less concentrated than
the wastes treated in the other subcategories.  Wastes from clean-up of groundwater and
landfill leachate are the  most predominate source of wastewater.   EPA proposes to
regulate the conventional, priority, and non-conventional pollutants in this subcategory.
                                      3-14

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SECTION 4
WASTEWATER USE AND WASTEWATER CHARACTERIZATION
      In 1991, under authority of Section 308 of the Clean Water Act, the Environmental
Protection Agency (EPA) distributed the "1991 Waste Treatment Industry Questionnaire,"
to 455  facilities that EPA had tentatively identified as possible  Centralized Waste
Treatment facilities.  Responses to the questionnaire indicated that 85 facilities received
hazardous and non-hazardous industrial waste from off-site for treatment or recovery via
any form of shipment in 1989. This section presents information on water use at these
facilities. This section also presents information on wastewater characteristics for the
Centralized  Waste Treatment facilities that were sampled by EPA and for those facilities
that provided self-monitoring data.

4.1   WATER USE AND SOURCES OF WASTEWATER

      The Centralized Waste Treatment Industry accepts for treatment large volumes of
waste and wastewater from off-site facilities.  Water use and wastewater generation occur
at various points in a CWT facility's operations.
      Wastewater treated at  CWT facilities, as noted,  includes off-site wastes and
wastewater from on-site operations. In general, the primary Centralized Waste Treatment
wastewater  sources are: waste receipts, solubilization wastewater, tanker truck/drums/roll-
off box washes, equipment washes, air pollution control scrubber blow-down, laboratory-
derived wastewater, and contaminated stormwater.  CWT facilities do not  generate
"process wastewater" (Process wastewater is defined in 40 CFR 122.2 as "any water
which, during manufacturing or processing, comes into direct contact with or results from
the production or use of any raw material, by-product, intermediate product, finished
product, or waste product.") in the traditional sense.  The term is used for manufacturing
or processing operations.  Because the Centralized Waste Treatment Industry operations
do not include or result in "manufacturing processes" or "products," EPA refers to the
                                      4-1

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wastewater treated in the Centralized Waste Treatment Industry by the terms "waste
receipts" for those wastes received from off-site for treatment and "CWT wastewater" for
the water which comes into contact with the  waste received or waste processing  or
handling areas as well as waste receipts.
      Approximately 2.0  billion  gallons  of wastewater  are generated  annually  by
Centralized Waste Treatment facilities.  For most of the individual CWT wastewater
sources, it is difficult to determine specific quantities of each wastewater due to facilities
mixing the wastewater from different sources prior to treatment. The sources of CWT
wastewater are listed below.

            Waste Receipts.  Most of the waste received from customers comes in a
            liquid form and constitutes a large portion of the wastewater treated at a
            CWT facility. Other wastewater sources include wastewater from contact
            with the waste at receipt or during subsequent handling.

      •     Solubilization Water. Some wastes are received in a solid form. Water may
            be added to the waste to render it treatable.

            Waste Oil Emulsion-Breaking Wastewater. The emulsion breaking process
            separates difficult water-oil emulsions and generates a "bottom" or water
            phase.  Approximately 99.2 million gallons of wastewater were generated
            from emulsion-breaking processes in 1989.

            Tanker Truck/Drum/Roll-Off Box Washes. Water is used to clean the interior
            and exterior of equipment used for transporting wastes.  The amount of
            wastewater generated was difficult to assess because the wash water is
            normally added to the wastes or used as solubilization water.
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            Equipment Washes.  Water is used to clean waste treatment equipment
            during unit shut downs or in between batches of waste.

            Air Pollution Control Scrubber Blow-Down. Water or acidic or basic solution
            is  used in air emission control scrubbers to control fumes from treatment
            tanks, storage tanks, and other process equipment. '

            Laboratory-Derived Wastewater. Water is used in on-site laboratories which
            characterize the incoming waste streams and monitor on-site treatment
            performance.

            Contaminated Stormwater. This is stormwater which comes in direct contact
            with the waste.or waste handling and treatment areas.
      The major volume of wastewater effluent discharged from the Centralized Waste
Treatment Industry is stormwater.  Approximately 100 million  gallons are discharged
annually.  Stormwater  may be contaminated by contact with receipts or the waste
processing area or it may be noncontaminated. Most of the wastewater monitoring data
submitted by facilities in the 1991  Waste Treatment Industry  Questionnaire included
noncontaminated stormwater.
      Many  facilities  also have other on-site  industrial operations,  i.e.,  organic
manufacturing.  Waste streams from other industrial processes  may be mixed with
Centralized Waste Treatment process wastewater prior to or after treatment. These other
industrial waste streams are not included as wastewater sources reviewed for effluent
limitations guidelines and standards for the Centralized Waste Treatment Industry. The
monitoring data received from facilities with other industrial waste streams were reviewed
to determine if the discharge streams for which data were submitted included other
industrial wastewater. In cases where the waste streams included other industrial waste,
the monitoring data were adjusted to remove the effect of the other industrial waste stream.
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4.2   WATER USE BY DISCHARGE
      A summary of the CWT wastewater flow by type of discharge was presented in
Table 3-5 for the 85 CWT facilities. This information is based upon data collected in the
1991 Waste Treatment Industry Questionnaire.  The discharge options are direct, indirect,
or zero discharge.  '"Zero" discharge methods include  no discharge, no wastewater
generation, land application, deep well injection,  evaporation, and  off-site disposal or
treatment. One facility discharges wastewater by direct discharge and  deep well injection.
      A large portion  of wastewater discharges from the Centralized Waste Treatment
Industry is not generated by the CWT operations. As previously explained, facilities may
also have other industrial operations which  generate non-CWT wastewater and that
wastewater may  be treated with CWT waste streams.  The  quantity of  non-CWT
wastewater,  noncontaminated stormwater and  other  industrial waste  streams, is
summarized in Table 4-1. Direct dischargers are the most affected by the addition of non-
CWT wastewater, because most of these facilities have other industrial operations.

Table 4-1.  Comparison of total facility discharge to total CWT discharge.
Quantity Discharged
Total
Average
Minimum
Maximum
Total Facility Discharge
(gal/yr)
20,155,462,039
279,936,973
7,748
12,775,000,000
Total CWT Discharge
(gal/yr)
3,016,396,330
41,894,393
2,718
1,169,975,506
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4.3   WATER USE BY SUBCATEGORY

      Off-site waste receipt quantities were used to estimate the quantity of wastewater
per subcategory. The quantity of waste receipts for each subcategory was calculated from
the estimate of waste received from off-site submitted for the  1991 Waste Treatment
Industry Questionnaire.  As discussed in Section 4,  waste receipts were divided into
subcategories by the waste form codes and RCRA codes.
      Other sources of wastewater were apportioned  to each subcategory by reviewing
treatment diagrams indicating the origination of the waste stream.  In cases where CWT
wastewater could not be separated by subcategory, such as laboratory and truck rinsing
wastewater, the CWT wastewater was divided on the basis of the subcategory breakdown.
For example, the laboratory wastewater for a facility 70% in the Metals Subcategory and
30% in the Oils Subcategory was estimated to be 70% Metals Subcategory wastewater
and 30% Oil Subcategory wastewater.
      Table 4-2  summarizes the amount of CWT and  non-CWT wastewater by
subcategory. As previously discussed, many CWT facilities also have other industrial
operations. Wastewater from these other industrial operations on-site is commingled with
CWT wastewater prior to treatment. The amount of other industrial wastewater for each
subcategory is also presented in Table 4-2. As illustrated in Table 4-2, the Centralized
Waste Treatment wastewater for facilities in the Organics Subcategory is a minor portion
of the facility operation.   Most Organics Subcategory facilities  have other industrial
operations such  as organics manufacturing.  Facilities began accepting waste for
treatment because sufficient capacity existed in the treatment system.
                                      4-5

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Table 4-2.   Summary of Wastewater by Subcategory
Type of
Wastewater
Subcategory
Wastewater
Non-CWT
Wastewater
Number of
Facilities
Quantity of Wastewater (gal/yr)
Metal-bearing
Waste
Subcategory
41,795,489,977
19,131,768,908
56
Oily Waste
Subcategory
226,735,481
4,732,004,637
35
Organic Waste
Subcategory
1,359,815,755
19,220,128,314
21
4.4   WASTEWATER CHARACTERIZATION

      A majority of the information reported in this section was collected from the EPA
Sampling  Programs for  the  Centralized Waste Treatment Industry as discussed in
Section 3.  Supplemental information was provided by self-monitoring data supplied in the
1991 Waste Treatment Industry Questionnaire, the Detailed Monitoring Questionnaire, and
the Waste Receipt information. The self-monitoring data were not used as extensively as
planned because many waste streams for which data were supplied included non-CWT
wastewater, and therefore, the data were not useful in properly characterizing Centralized
Waste Treatment operations. Also, the self-monitoring data were only available for a
limited number of pollutants in comparison  to the scope of pollutants studied in the
Sampling Program.
      The data presented in the following sections were collected at influent points to
treatment systems. The concentrations presented are lower than the original waste receipt
concentrations as a result of the commingling of a variety of waste streams. In most cases,
EPA could not collect samples from individual waste shipments because of physical
                                      4-6

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constraints as well as the excessive analytical costs associated with the necessary
analysis.

4.4.1  Pollutant Parameters

      Different pollutant parameters are used to characterize  raw wastewater and
wastewater discharged by Centralized Waste Treatment facilities.  These include:

            Total Suspended Solids (TSS),
            Biochemical Oxygen Demand (BOD5),
            pH, and
            Oil and Grease.
      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 the solution using a 1 micron filter. Raw wastewater TSS content
is a function of the type and form of waste accepted for treatment.  (Typically, the higher
the TSS content the more concentrated the waste stream.) TSS can also be a function of
a number of other external factors, including stormwater runoff and runoff from storage
areas. The total solids are composed of matter which is settleable, in suspension, or in
solution and can be organic, inorganics, or a mixture of both.  Settleable portions of the
suspended solids can be removed in  a variety of ways,  such as during the metals
precipitation process or by multimedia filtration, depending on a facility's operation.  In the
Centralized Waste Treatment Industry, raw wastewater TSS is a function of the form in
which a waste is received for treatment, such as a solid or liquid. Wastewater that results
from the solubilization of solid waste receipts tends to have higher TSS values than waste
received in a  liquid form.  The highest TSS values detected in the Centralized Waste
Treatment  Industry were found in the Metals Subcategory. Metal-bearing waste contain
high TSS levels, due to the industrial waste source as well as many waste receipts being
                                       4-7

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accepted in solid form.  A summary of the raw wastewater TSS levels is presented in
Table 4-3.
Table 4-3. Influent Concentrations Ranges for Selected Pollutant Parameters
Pollutant
Parameter
TSS
BOD*
Oil &_Grease
Influent Concentration Range (mg/l)
Metals
Subcategory
Min
86
4
3
Max
152,767
30,000
5995
Oils Subcategory
Min
190
4,520
49?
Max
22,258
10,067
180000
Organics
Subcategory
Min
44
4,100
16
Max
3,700
48,675
626
      BOD5 is one of the most important gauges of pollution potential of a wastewater and
varies with the amount of biodegradable matter that can be assimilated by biological
organisms under aerobic conditions.  The nature of chemicals discharged into wastewater
effects the BODS due to the differences in susceptibility of different molecular structures
to microbiological degradation.  Compounds with lower susceptibility to decompose by
microorganisms tend to exhibit lower BOD5 values, even though the total organic loading
may be much higher than compounds exhibiting substantially higher BOD5 values.
      The pH of a solution is a unitless measurement which represents the acidity or
alkalinity of a wastewater stream (or aqueous solution), based on the dissociation of the
acid or base in the solution into hydrogen (H+) or hydroxide (OH') ions, respectively. Raw
wastewater pH is a function of the source of waste receipts.  This parameter can vary
widely from facility to facility and can be extremely variable in a single facility's raw
wastewater, depending on wastewater sources. Fluctuations in pH are readily reduced by
equalization followed by neutralization.  Control of pH is necessary to achieve proper
removal of pollutants in treatment systems such as  metals precipitation.
                                      4-8

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      Raw wastewater Oil and Grease is an important parameter in Centralized Waste
Treatment Industry wastewater, especially for the Oils Subcategory. Oil and Grease can
interfere with the operation of wastewater treatment plants and, if not removed prior to
discharge, can interfere with biological life streams and/or create films along surface
waters.

4.4.2 Priority and Non-Conventional Pollutants

      As discussed previously, most of the data presented in this section was collected
during the EPA Sampling Program for the Centralized Waste Treatment Industry. The
pollutants detected at Centralized Waste Treatment facilities were dependent on the type
of waste accepted for treatment at a facility.  The most predominant group of pollutants
detected was metals. Metals were detected in all samples collected. The concentration
of metals  in raw wastewater was the highest found in industrial wastewater samples in
comparison to existing effluent limitations guidelines and standards.  A summary of the
metal pollutants in  raw wastewater by subcategory is presented in Table 4-4.
      Organic pollutants were detected at varying amounts dependent on the subcategory
of the facility sampled.  In the Metals subcategory,  organic compounds were detected at
low levels since the organic compounds were incidental components of the waste receipts.
The type of organics detected  at  Oils and  Organics Subcategory  facilities varied
depending on the subcategory. Organic compounds in the Oils subcategory were more
petroleum-based, such as alkanes and glycols, than in the Organics Subcategory. A
summary of the organic pollutants in raw wastewater by subcategory is presented in
Table 4-5.
                                      4-9

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Table 4-4.  Range of Metal Pollutant Influent Concentrations (mg/l)
Pollutant
Aluminum
Antimony
Arsenic
Barium
Boron
Cadmium
Chromium - Hexavalent
Chromium -Total
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silicon
Silver
Sulfur
Tin
Titanium
Vanadium
Zinc
Metals Subcategory
Win
2.867
0.015
0.030
0.016
3.123
0.019
0.011
0.102
0.064
0.199
4.450
0.208
3.210
0.067
0.001
0.120
0.581
5.931
147.1
0.014
1.990
0.076
708.55
0.145
0.020
0.086
0.600
Max
2,090
1,160
25.961
27.709
1,420
307
40,000
16,300
232
21,000
3,745
4,390
1,360
102.63
3.100
849
1,700
456
8,895
1.520
1,330
6.060
24,100
15,100
7,500
264
7,735
Oils Subcategory
Min
1.200
0.027
0.059
0.398
31.363
0.038

0.363
0.551
1.200
43.60
0.607
22.40
1
0.5
0.733
0.313


0.011

0.033

0.592
0.264

10.349
Max
192.58
0.242
0.487
7.049
1,710
0.498

7.178
0.868
80.482
567.69
21.725
247.12
20.386
0.007
12.400
62.824


0.029

7.740

6.216
1.407

94.543
Organics Subcategory
Min
1.498
0.066
0.047
0.009
3.070
0.009

0.063
0.026
0.224
2.360
0.094
6.310
0.179
0.001
0.290
0.069
3
1,010

1.550

972
0.200
0.020

0.516
Max
157.94
1.540
0.634
2.190
103.33
0.049

1.265
0.731
2.690
88.828
0.687
23.800
1.513
0.007
6.950
2.610
15.900
1,240

3.600

1,990
2.530
20.559

2.352
                                     4-10

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Table 4-5.  Range of Organic Pollutant Influent Concentrations (mg/l)

Pollutant
1 ,1 ,1 ,2-Tetrachloroethane
1 ,1 ,1-Trichloroethane
1 ,1 ,2-Trichloroethane
1 ,1-Dichloroethane
1 ,1 -Dichloroethene
1 ,2.3-Trichloropropane
1 ,2-Dibromoethane
1 ,2-Dichloroethane
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2-Butanone
2-Picoline
2-Propanone
4-Chloro-3-Methylphenol
4-Methyl-2-Pentanone
Acetophenone
Benzene
Benzoic acid
Benzvl alcohol
Bromodichloromethane
Carbon disulfide
Chlorobenzene
Chloroform
Diethvl Ether
Diphenyl Ether
Ethvl Benzene
Metals Subcategory
Min

0.066

0.010
0.410






0.065

0.105
1.880
0.281

0.014
0.193




0.012

0.556

Max

0.628

0.043
2.879






8.135

64.797
13.947
5.568

0.111
39.281




0.337

1.394

Oils Subcategory
Min

0.111









0.057

2.395
4.148


0.070
5.450







0.057
Max

14.455









178.75

2,099.3
83.825


20.425
32.158







18.579
Organics Subcategory
Min
0.249
0.181
0.776
0.070
0.112
0.100
3.081
1.394
1.189
0.114
0.148
1.731
0.054
2.977

0.893
0.336
0.097
3.008
2.022
0.026

0.070
2.819
0.182

0.016
Max
0.644
3.195
1.859
0.108
0.118
0.220
6.094
10.681
1.734
0.226
0.203
322.89
0.125
447,722.0

4.038
0.739
6.203
15.760
13.651
0.073

0.101
10.621
0.211

3.813
                                      4-11

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Table 4-5.  Range of Organic Pollutant Influent Concentrations (mg/l) (continued)
Pollutant
HexanoicAcid
Isophorone
Methylene Chloride
m-Xylene
Naphthalene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
n,n-Dimethylformamide
o+p-Xylene
o-Cresol
3entachlorophenol
3henol
Pyridine
p-Cresol
Tetrachloroethene
Tetrachloromethane
Toluene
Trans-1 ,2-dichloroethene
Trichloroethene
Trichlorofluoromethane
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Metals
Min
0.414
2.144
0.050
0.018
0.045
0.142

0.088
0.062

0.086
0.040
0.032
0.144
0.011


0.061


0.011

0.080

0.015



Max
5.969
2.295
0.734
1.141
2.926
14.086

4.844
20.253

24.369
11.760
27.366
5.090
0.950


7.739


1.378

8.700

0.350



Oils
Min
0.807

0.179
0.117

0.266
0.133
0.901
0.312
0.246
0.795
0.369
0.769

0.063


1.695


0.137

0.477



30.587

Max
14.890

6.019
32.639

579.22
3.954
472.57
319.08
2.530
1,368.0
901.92
2,560.5

14.820


12.325


12.789

99.209



383.15

Organics
Min
1.111
0.060
33.113
0.056
0.112








0.023
0.013
0.180
0.657
0.553
0.132
0.220
2.235
1.391
0.148
1.171
1.194
0.024

0.290
Max
4.963
2.266
13.256
2.500
1.253








264.45
1.671
14.313
1.354
19.453
16.715
6.457
6.808
3.222
3,761.7
1.818
9.897
0.034

0.485
                                     4-12

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4.5   WASTEWATER POLLUTANT DISCHARGES
                                            \   '•
      As previously discussed, most of the effluent monitoring data received from facilities
included non-CWT wastewater, such as other industrial waste streams and stormwater.
Due to the lack of effluent data for CWT wastewater, the EPA had to develop various
methods to estimate the current wastewater pollutant discharge.  This section describes
the various methodologies used to estimate current performance.

4.5.1  Metals Subcategory Current Performance

      As illustrated in Figure  4-1, most of the data supplied by Metals Subcategory
facilities  represented data that included   non-CWT  wastewater  in  the form  of
noncontaminated stormwater and other industrial stormwater added prior to discharge.
Therefore, the amount of a pollutant in the final effluent would be equal to the amount of
the pollutant in CWT process and the corresponding amount in the non-CWT process as
demonstrated in Equation 4.1.
CWT
Opera
Non-CWT
ation Operation

—


                       CWT
NON-CWT
                                    TOTAL
 Figure 4-3  Example of Non-CWT Wastewater Addition
                                     4-13

-------
                    z * FTOTAL-x * FCWT+y * FNON _CWT
(4-1)
where:
      z = Concentration of Pollutant in Final Effluent (mg/l),
      FTOTAL = Total flow at Final Effluent (liters),
      x = Concentration of Pollutant in CWT Process Effluent (mg/l),
      FCWT ~ Total flow at CWT Process Effluent (liters),
      y = Concentration of Pollutant in Final Effluent (mg/l), and
      FNON-CWT = Total flow at Non-CWT Effluent (liters),
      The EPA assimilated a database of the available monitoring data for facility effluent
discharges.  For each facility, the EPA estimated the portion of non-CWT wastewater in
the facility  discharge  and  calculated  the  Centralized Waste  Treatment  effluent
concentration by applying the following formulas (Eqns. 4-2 and 4-3) depending on the
source  of the non-CWT wastewater.   For facilities  where the source  of non-CWT
wastewater was stormwater, the following equation was used:
                               z*F

                                   TOTAL
                                  CWT
                                                                            (4-1)
                                      4-14

-------
For facilities in which the source of non-CWT wastewater was other industrial wastewater,
the following equation was used:
                              z*F
                       x=-
                                  TOTAL
                           CWT
                               +.5*F
                                      (4-1)
NON-CWT
      In Equation 4-1, the value of variable y is dependent on the source of the non-CWT
wastewater.   If the non-CWT wastewater  was non-contaminated  stormwater, the
noncontaminated stormwater was assumed to be significantly lower in concentration in
comparison to the process wastewater, and thus, y was set equal to 0. If the non-CWT
wastewater was other industrial wastewater, the other industrial wastewater was assumed
to be half as concentrated as CWT wastewater, and thus, the variable y was set equal to
.5*x.  EPA concluded  this value was  a reasonable assumption.   A comparison  of
Centralized Waste Treatment raw wastewater with other promulgated industrial effluent
guidelines showed  that Centralized Waste Treatment Industry raw wastewater was
significantly more concentrated that other industrial wastewater, in some instances 10
times more concentrated.
      When  possible,  a facility's current performance was based upon  information for
which data were  reported.   From  the information  submitted,  average discharge
concentrations were calculated for each pollutant.  Average discharge concentrations were
only calculated if more than two data points were available. For facilities that did not
submit analytical data, the average discharge concentration for the subcategory was used.
      The estimated current performance for facilities in the Metals Subcategory is
presented in Table 4-6.
                                     4-15

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Table 4-6. Metals Subcategory Current Performance
Pollutant
Current Discharge Concentration (mg/l)
Classicals
BOO;
Total Cyanide
Oil & Grease
TSS
1,904.58
77.84
270.42
1,371.02
Metals
Aluminum
Antimony
Arsenic
Barium
Boron
Cadmium
Chromium - Hexavalent
Chromium - Total
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Tin
Titanium
Vanadium
Zinc
1.38
2.34
0.81
3.67
40.59
0.32
1.83
2.30
0.38
1.35
12.53
0.40
1.80
0.03
12.63
1.91
0.15
0.42
0.26
24.74
1.08
9.71
2.55
                                    4-16

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Table 4-6. Metals Subcategory Current Performance (continued)
Pollutant
Current Discharge Concentration (mg/I)
Organics
1 , 1 , 1-Trichloroethane
1,1-Dichloroethane
1 , 1 -Dichloroethene
1 ,4-Dioxane
2-Butanone
2-Methylnaphthalene
2-Propanone
4-Chloro-3-methylphenoI
4-Methyl-2-pentanone
Acetophenone
Benzole acid
Benzyl alcohol
Biphenyl
Bis(2-ethylhexyl)phthalate
Carbon disulfide
Diphenyl ether
Ethyl benzene
Hexanoic acid
Methylene chloride
Naphthalene
n,n-DimethyIformamide
o+p-Xylene
Phenol
Styrene
Tetrachloroethene
Toluene
0.08
0.01
0.07
1.49
0.59
0.13
5.53
0.13
0.36
0.07
1.95
0.17
0.07
0.04
0.04
0.11
0.02
0.36
0.03
0.18
0.12
0.04
0.64
0.47
0.03
0.20
                                     4-17

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4.5.2 Oils Subcategory Current Performance

      The types of oils that are accepted for treatment can be characterized as stable or
unstable oil-water emulsion.  Stable oil-water emulsions are difficult to separate because
the emulsions were created to make a specific product, such as lubricants and coolants.
Chemical emulsion-breaking is necessary to separate the  mixture.  Unstable oil-water
emulsions are more easy to separate than stable emulsions. Gravitational settling is
usually sufficient to separate the oil. and water phases. The wastewater generated from
chemical emulsion-breaking and settling requires treatment prior to discharge. From the
information gathered at facilities, the  effluent from chemical-emulsion breaking was
characterized to be similar to the unstable oil-water emulsions prior to settling.
      Most facilities in the Oils Subcategory have operations that are  also categorized in
other Centralized Waste Treatment Industry subcategories.  In most cases, waste receipts
were treated in a Chemical Emulsion-Breaking unit, and then commingled with the other
Subcategory wastewater.  In reviewing data collected after emulsion-breaking and at the
point of mixing the waste streams, most pollutants of concern for the Oils Subcategory
were found at non-detect levels at the point of mixing. Therefore, it was apparent that the
pollutants of concern were being diluted prior to treatment.
      The EPA estimated the current performance of most Oils Subcategory facilities to
be equivalent to the chemical emulsion breaking effluent. Credit was riot given for oily
wastewater commingled with other wastewater because dilution was normally the form of
treatment.  A summary of the estimated current performance for the Oils Subcategory is
presented in Table 4-7.
                                      4-18

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Table 4-7. Oils Subcategory Current Performance
Pollutant
Current Discharge
Concentration (mg/l)
Classical
BOD5
Oil and Grease
TSS
7,164.49
29,396.88
7,209.98
Metals
Aluminum
Antimony
Arsenic
Barium
Boron
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Molybdenum
Nickel
Silver
Tin
Titanium
Zinc
48.93
1.34
0.22
2.53
239.36
0.24
2.20
0.72
15.79
232.26
8.15
7.39
3.05
26.44
1.08
2.10
0.38
42.00
Organics
1,1,1 -Trichloroethane
2-Butanone
2-Propanone
3.64
20.10
221.07
                                     4-19

-------
Table 4-7.  Oils Subcategory Current Performance (continued)
Pollutant
Current Discharge
Concentration (mg/l)
Organics (continued)
4-Chloro-3-Methylphenol
Benzene
Benzoic acid
Ethyl benzene
Hexanoic acid
Methylene chloride
m-Xylene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o+p-Xylene
Phenol
Tetrachloroethene
Toluene
Tripropyleneglycol Methyl Ether
22.31
8.25
16.81
6.61
5.38
1.47
11.37
91.78
3.03
70.39
42.69
3.08
153.22
95.36
282.72
5.19
4.59
2.16
33.95
86.47
                                     4-20

-------
4.5.3 Organics Subcategory Current Performance

      The problems in estimating current performance for the Organics Subcategory are
similar to that of the Metals Subcategory. Most Organics Subcategory facilities have other
industrial operations.  The percentage of CWT wastewater in the overall facility flow was
minimal as was the amount of monitoring data submitted in the questionnaire. Therefore,
the EPA estimated performance based upon the treatment technologies in place.
      Four different classifications were used to determine the current performance of
facilities in the Organics Subcategory. The first classification was used for facilities with
no treatment in place to reduce the pollutants in the organic waste stream. The average
raw waste concentration of pollutants was used for facilities in this classification.  The
second classification was used for facilities which only had multi-media or sand filtration
as the on-site treatment technology for the organic waste stream.  For these facilities, a
20 percent removal of TSS and metal compounds and no removal of other classical and
organic pollutants was assumed to occur from the raw waste concentration levels.  The
third classification was used for facilities with multi-media or  sand filtration units followed
by carbon adsorption. Removal of 20 percent for classical  pollutants, 10 percent for metal
compounds, and 50 percent  for organic pollutants from the raw  wastewater were
estimated.  The percent removals used were based on  estimates of  the treatment unit
effectiveness. The current performance for the remaining facilities was based on analytical
data collected for biological systems with and without multi-media or sand filtration units.
      A summary of the current performance for the Organics Subcategory is presented
in Table 4-8.
                                      4-21

-------
Table 4-8. Organics Subcategory Current Performance
Pollutant
Current Discharge Concentration
(mg/l)
Classicais
BOD,;
Total Cyanide
Oil & Grease
TSS
2,288.61
1.76
9.63
224.69
Metals
Aluminum
Antimony
Arsenic
Barium
Boron
Chromium
Cobalt
Copper
Iodine
Iron
Lead
Lithium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Silicon
Strontium
Sulfur
Tin
2.04
0.22
0.10
1.94
4.89
0.11
0.27
0.32
7.60
3.50
0.09
14.91
0.38
0.02
0.52
3.37
3.14
2.28
4.67
841.15
0.97
                                    4-22

-------
Table 4-8. Organics Subcategory Current Performance (continued)
Pollutant
Current Discharge Concentration
(mall)
Metals (continued)
Titanium
Zinc
0.21
0.25
Organics
1,1,1 ,2-Tetrachloroethane
1,1,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
1,1-Dichloroethane
1,1-Dichloroethene
1 ,2,3-Trichloropropane
1 ,2-Dibromoethane
1 ,2-Dichlorobenzene
1 ,2-Dichloroethane
2,3,4,6-TetrachlorophenoI .
2,3-Dichloroaniline
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4-Dimethyl phenol
2-Butanone
2-Chlorophenol
2-Hexanone
2-Picoline
2-Propanone
4-Methyl-2-pentanone
Acetophenone
Benzene
Benzoic acid
0.16
0.18
	 0.30
0.16
0.15
0.15
0.20
0.06
0.25
3.52
0.10
0.39
0.72
0.04,
3.05
0.06
1.19
0.20
164.89
0.79
0.04
0.20
0.36
                                     4-23

-------
Table 4-8. Organics Subcategory Current Performance (continued)
Pollutant
Current Discharge Concentration
(mg/I)
Organics (continued)
Bromodichloromethane
Carbon disulfide
Chlorobenzene
Chloroform
Diethyl ether
Ethyl benzene
Hexanoic acid
Isophorone
Methylene chloride
m-Xylene
Naphthalene
n.n-Dimethylformamide
o&p-Xylene
o-Cresol
Pentachlorophenol
Phenol
Pyridine
p-Cresol
Tetrachloroethene
Tetrachloromethane
Toluene
trans-1 ,2-DichIoroethene
Trichloroethene
Trichlorofluoromethane
Vinyl Chloride
0.15
0.22
0.15
0.64
0.76
0.17
0.19
0.05
42.07
0.17
0.04
0.77
0.16
0.17
1.79
0.36
0.18
0.10
0.61
0.18
15.75
0.25
0.92
0.16
0.19
                                    4-24

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SECTIONS
POLLUTANTS AND POLLUTANT PARAMETERS
SELECTED FOR REGULATION

      As  previously  discussed,  EPA  evaluated  all  available data characterizing
wastewater for this industry in order to determine the pollutants of concern for the
Centralized Waste Treatment Industry. This section discusses the pollutants and pollutant
parameters detected in the Centralized Waste Treatment Industry.

5.1   POLLUTANT PARAMETERS

      Pollutant parameters, which include conventional pollutants, such as TSS and Oil
and  Grease,  and non-conventional pollutant parameters, such as chemical  oxygen
demand (COD) arid total organic carbon  (TOC), are general indicators of water quality
rather than markers of specific compounds.  Because most of the industry are indirect
dischargers, they are not subject to limitations for conventional pollutants normally
included in direct discharge permits but not in indirect discharge permits.
      The pollutant parameters proposed for regulating are a function of the subcategory.
In the Metals Subcategory, the most important pollutant parameter is total suspended
solids because of the correlation to treatment unit effectiveness. In general,  TSS is an
important parameter for all subcategories because of its correlation to the type of waste
accepted for treatment,  and will be covered for all subcategories.  Oil and  Grease is
proposed for regulation for the Metals Subcategory because of its ability to interfere with
the performance of metals treatment systems. Oil and Grease is an extremely important
measure for estimating treatment unit performance for the Oils Subcategory.  The most
important  parameter  for the Organics Subcategory is  BOD5  because it  measures
biodegradability of organic compounds.
                                     5-1

-------
5.2   PRIORITY AND NON-CONVENTIONAL POLLUTANTS

      In the beginning of the industry study, more than 480 priority and non-conventional
pollutants, listed in Appendix B, were analyzed.  These pollutants are a combination of all
pollutants for which the EPA has approved analytical methods, including RCRA and TSCA
compounds.     After  the  initial  two  sampling  episode,   Dioxins/Furans   and
Pesticides/Herbicides were no longer analyzed because they were not detected in the
waste streams at treatable concentrations.  CWT facilities that are RCRA permitted
operations are prohibited from receiving either dioxins/furans or pesticides/herbicides
because the RCRA required treatment for these compounds is incineration.
      The priority and non-conventional pollutants to be regulated were determined by
a series of data reviews.  Analytical data from raw wastewater samples collected during
the EPA Sampling Program were reviewed to determine the number of times a pollutant
was detected at treatable levels.  In most cases, treatable levels were set at 10 times the
minimum level. This would ensure that pollutants detected only at trace amounts would
not be regulated. Regulation would not be required because most pollutants found at trace
amounts will be indirectly controlled through regulation of other pollutants by the proposed
regulations.
      The initial pollutants of concern  for each subcategory were derived from the
pollutants  which were detected  at a treatable level a  minimum of three times in the
subcategory raw waste  stream.  A minimum number  of times  (3) for detection was
established such that a pollutant infrequently detected  would not be regulated for the
entire subcategory. The final list of pollutants to be  regulated was later refined depending
on  the  quantity of  pollutant detected and  the ability  of a  pollutant to  be  controlled
depending upon the regulation of other pollutants.
      After evaluating  all of these factors,  the Agency selected  for regulation 63
pollutants.  The final list of pollutants to be regulated for each subcategory is presented
in Table 5-1.
                                      5-2

-------
 Table 5-1
 Pollutants Selected for Regulation
   Metals Subcategory
   Oils Subcategory
  Organics Subcategory
 Aluminum
 Antimony
 Arsenic
 Barium
 Cadmium
 Chromium
 Cobalt
 Copper
 Hexavalent Chromium
 Iron
 Lead
 Magnesium
 Manganese
 Mercury
 Nickel
 Silver
 Tin
 Titanium
 Total Cyanide
 Zinc
1,1,1-Trichloroethane
2-Propanone
4-chloro-3-methyl phenol
Aluminum
Barium
Benzene
Butanone
Cadmium
Chromium
Copper
Ethyl Benzene
Iron
Lead
Manganese
Methylene Chloride
m-Xylene
Nickel
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o&p-Xylene
Tetrachloroethene
Tin
Toluene
Tripropyleneglycol
Zinc
1,1,1,2-Tetrachloroethane
1,1,1 -Trichloroethane
1,1,2-Trichloroethene
1,1-Dichloroethane
1,2,3-Trichloropropane
1,2-Dibromoethane
1,2-Dichloroethane
2,3-Dichloroaniline
2-Propanone
4-Methyl-2-Pentanone
Acetophenone
Aluminum
Antimony
Barium
Benzene
Benzoic Acid
Butanone
Carbon Disulfide
Chloroform
Diethyl Ether
Hexanoic Acid
Lead
Methylene Chloride
Molybdenum
m-Xylene
o-Cresol
p-Cresol
Phenol
Pyridine,
Tetrachloroethene
Tetrachloromethane
Toluene
trans-1,2-DichIoroethene
Trichloroethene
Vinyl Chloride
Zinc     	
      EPA is not selecting pollutants for regulation for various reasons.  The initial

determination of pollutants to be included in the regulation was the number of times the

pollutant was detected in raw wastewater samples. After these pollutants were removed,
                                        5-3

-------
pollutants used as treatment chemicals were also removed from all data.  Calcium,

Sodium, Potassium, and Phosphorus were the pollutants found in treatment chemicals

removed from the regulated list for all subcategories. These pollutants are added to the

process and are not toxic to water.  Pollutants were  also removed from the list to be

regulated if the pollutant was only detected at one facility, and therefore, not present

throughout the industry.   The  only  pollutants excluded from regulation due to the

presence at an  isolated facility  were Gallium  and Strontium from  the  Organics

Subcategory.
      Additional pollutants were removed from the regulated list if the average influent

concentration detected was below a  treatable level.   For most pollutants,  the

concentration level for was set at 100 ug/l or 10 times the analytical minimum level.  For

Mercury, the concentration was less than 5ug/l due to the toxicity of Mercury in water.

These pollutants are presented  in Table 5-2.
  Table 5-2
  Pollutants Excluded from Regulation Due to the Concentration Detected
  Metals Subcategory
  Beryllium
  Yttrium
  Endosulfan Sulfate
Oils Subcategory

Antimony
Arsenic
Beryllium
Mercury
Selenium
Yttrium
Organics Subcategory

Arsenic
Cadmium
Mercury
Titanium
Yttrium
1,1-Dichloroethane
1,2-Dimethyl phenol
2-Chl9ropheriol
2-Hexanone
2-Picoline
Benzyl Alcohol
Bromodichloromethane
Chlorobenzene
Ethyl Benzene
Isophorone
Naphthalene
n,n-Dimethylformamide
o&p-Xylene
Trichlorofluoromethane
Endosulfan Sulfate
                                       5-4

-------
      Pollutants were also excluded from regulation when they were not detected or

analyzed at the facilities used for the proposed technology option.  Some pollutants were

excluded from analysis to reduce the costs  of sampling episodes.  The pollutants

excluded from analysis were found at concentrations similar to the treatability levels

discussed previously and are not toxic at these concentrations. These pollutants are

listed in Table 5-3.
 Table 5-3
 Pollutants Excluded from Regulation Due to Lack of Detection or Analysis at
 the Technology Option Facility	
  Metals Subcategory
Oils Subcategory
Organics Subcategory
  Cerium
  Gallium
  Indium
  Iodine
  Iridium
  Lithium
  Lutetium
  Neodymium
  Niobium
  Osmium
  Praseodymium
  Rhenium
  Selenium
  Silicon
  Strontium
  Sulfur
  Tantalum
  Tellurium
  Thallium
  Thorium
  Tungsten
  Uranium
  Ytterbium
  Zirconium
  All organic pollutants
None
None
                                      5-5

-------
      Additional pollutants were excluded from regulation because the technology option
proposed was not effective in treating the pollutant (i.e., pollutant concentrations increase
across the treatment system).  These pollutants are listed in Table 5-4.
  Table 5-4
  Pollutants Excluded from Regulation Due to ineffective Treatment
  Metals Subcategory
Oils Subcategory
Organics Subcategory
  None
Benzoic Acid
Hexanoic Acid
Phenol
2,3,4,6-
Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Boron
Iodine
Lithium
Magnesium
Manganese
Nickel
Pentachlorophenol
Tin
5.3   SELECTION OF POLLUTANTS TO BE REGULATED FOR PSES AND PSNS


      Indirect dischargers in the CWT Industry send their wastewater streams to a

POTW for further treatment, unlike direct dischargers, whose wastewater will receive no
further treatment once it leaves their facility. Therefore, the levels of pollutants allowable
in the wastewater of an indirect discharger are dependent upon 1) whether a given
pollutant "passes through" the POTWs treatment system or 2) whether  additional
treatment provided by the POTW will result in removal  of the pollutant to a level
equivalent to that obtained through treatment by a direct discharger.
                                     5-6

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5.3.1  Pass-Through Analysis Approach

      To establish PSES, EPA must first determine which of the CWT pollutants of
concern (identified earlier in this section) pass through, interfere with, or are incompatible
with the operation of POTWs  (including interferences with sludge practices).   EPA
determines pollutant pass-through by comparing the percentage removed by POTWs with
the percentage removed by direct dischargers using BPT/BAT technology.  A pollutant
"passes through" POTWs when the  average  percentage removed by well-operated
POTWs nationwide (those meeting secondary treatment requirements) is less than the
percentage removed by CWT direct dischargers complying with BPT/BAT limitations for
a given pollutant. EPA has assumed, for the purposes of this analysis and based upon
the data it received, that the untreated wastewater at indirect discharge facilities is not
significantly different than that from direct discharge facilities.
      This approach to the definition of pass-through satisfies two competing objectives
set by Congress: (1) that standards for indirect dischargers be equivalent to standards
for direct dischargers and (2) that the treatment capability and performance of the POTW
be recognized and taken into account in regulating the discharge of pollutants  from
indirect dischargers.  Rather than compare the mass or concentration of pollutants
discharged by the POTW with the mass or concentration of pollutants  discharged by a
BAT facility, EPA compares the percentage of the pollutants removed by the facility with
the POTW removal.  EPA takes this approach because a comparison of mass or
concentration of pollutants in a POTW effluent with pollutants in a BAT facility's effluent
would not take into account the mass of pollutants discharged to the POTW from non-
industrial sources  nor the dilution of the pollutants in the POTW effluent to  lower
concentrations from the addition of large amounts of non-industrial wastewater.
                                      5-7

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5.3.2 50 POTW Study Data Base

      For previous effluent guidelines efforts, a study of 50 well-operated POTWs was
used to establish POTW removals for comparison with facility removals for the pass-
through analysis.   The earlier work done with this data base included  an in-depth
comparison of data editing scenarios. The main concern with using the data is the
possibility that low calculated  POTW removals  might  simply  reflect  low  influent
concentrations, and would not be true measures of treatment effectiveness. The editing
rules used in this guideline were devised to minimize this possibility.
      First, a POTW/pollutant combination must have at least three influent values to be
kept in the analysis. Then, because the data base includes influent levels that are close
to the pollutants' analytical nominal detection limits (NOMDLs), the POTW  data were
edited to  eliminate  average POTW/pollutant influent levels less than 10  times the
NOMDLs and the corresponding effluent data, except in the cases where the average
influent concentration did not exceed 10 times the NOMDL. In these cases, the data were
edited to eliminate average POTW/pollutant influent values less than 20  ^gl\  and the
corresponding effluent data. With regard to industry data, EPA considers influent levels
in excess of 10 times the pollutant's NOMDL at a facility to be appropriate for use in
setting effluent limitations. Secondly, EPA has historically found that pollutants with low
influent concentrations  (less  than 20  //g/l) have shown corresponding  effluent
concentrations that were consistently below the NOMDL and could not be quantified.
      The remaining averaged POTW/pollutant influent values and the corresponding
averaged effluent values  were  used to calculate the  average removal for each
POTW/pollutant.  The  median percent removal  achieved  for  each pollutant was
determined from these averaged POTW/pollutant values.
                                      5-8

-------
5.3.3 RREL Treatability Data Base

      Due to the large number of pollutants considered for this industry, additional data
from the EPA Risk Reduction Engineering Laboratory (RREL) Treatability Database were
used to supplement the 50 POTW Study data. Due to the organization of this data base,
the editing rules used for the POTW data base were modified appropriately.
      For each of the pollutants, data from the liquid waste portion of the RREL
Treatability Database  were obtained.  These files were edited so that only treatment
technology data for activated sludge, aerobic lagoons, and activated sludge with filtration
remained. These technologies are representative of typical POTW secondary treatment
operations.  The files  were further edited to include only information pertaining to
domestic or industrial wastewater, unless only other types of wastewater data were
available. Only full-scale or pilot-scale data were used;  bench-scale data were edited
out.  Only data from a paper in a peer-reviewed journal or government report or data base
were retained;  all lesser-quality references were deleted.  Additionally, the retained
references were reviewed and non-applicable study data were accordingly eliminated.
Because the data base is organized into groupings of influent values, the influent editing
rules used for the 50 POTW Study data base could not be applied here.
      From the remaining pollutant removal data, the average percent removal for each
pollutant was calculated.

5.3.4 Final POTW Data Editing

      For each pollutant, the edited percent removals from the 50 POTW Study and
RREL Treatability Data Base  were compared.  The final percent  removal for each
pollutant was chosen based on a data hierarchy, which was related to the quality of the
data source. This hierarchy was:
                                      5-9

-------
      1.    50 POTW Study data (10 times NOMDL edit);

      2.    50 POTW Study data (20 //g/l edit);
      3.    RREL Treatability data (domestic wastewater only edit, if three or more data

            points);
      4.    RREL Treatability data  (domestic and industrial wastewater edit);  then
      5.    Generic pollutant group removal data (see discussion below).


      After the editing of the 50 POTW and RREL Treatability data was finished, there
were some CWT pollutants for which no data were available.  To determine average

removals for these pollutants, all of the CWT pollutants were assigned to a generic group

by chemical structure. These groups were:


      A.    Inorganic Elements;
      B.    Halogenated Hydrocarbons;
      C.    Hydrocarbons;
      D.    Aromatic Hydrocarbons;
      E.    Halogenated Aromatics;
      F.    Organic Acids;
      G.    Aromatic Alcohols;
      H.    Phenolics;
      I.     Halogenated Phenolics;
      J.     Pesticides;
      K.    Heterocyclics;
      L.    Ketones;
      M.    Aromatic Ketones;
      N.    Cyclic Ketones;
      O.    Polyaromatic Hydrocarbons;
      P.    Phthalates;
      Q.    Ethers;  and
      R.    Amides.


      All of the available removals for the pollutants within a given group were averaged;

this average removal was then assigned to any pollutant within that group that did not
previously have a removal value. After the final  selection of CWT pollutants to  be

regulated,  the only generic removals  that  were applicable were for Groups C
                                      5-10

-------
(Hydrocarbons) and Q (Ethers);  these group removals are presented in Tables 5-5 and
5-6, respectively.  The final POTW removals for the CWT pollutants, determined via the
data use hierarchy, are presented in Table 5-7.
Table 5-5.   Generic Removals for Group C: Hydrocarbons
Pollutant Parameter
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
Average Group Removal
Removal (%)
9.00
88.00
95.05
92.40
_
-
ซ.
_
71.11
Source of Data
RREL - All Wastewater Edit
RREL - AH Wastewater Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
_
-
.
-
-
Table 5-6.   Generic Removals for Group Q:  Ethers
Pollutant Parameter
Diethyl Ether
Diphenyl Ether
Tripropyleneglycol Methyl Ether
Average Group Removal
Removal (%)
7.00
86.53
_
46.77
Source of Data
RREL - All Wastewater Edit
RREL - All Wastewater Edit
_
'
                                     5-11

-------
Table 5-7.  Final POTW Removals for CWT Pollutants
Pollutant Parameter
1 .1 ,1 ,2-Tetrachloroethane
1 ,1 ,1-Trichloroethane
1 ,1 ,2-Triehloroethane
1,1-Dichloroethene
1 ,2,3-TrichIoropropane
1 ,2-Dibromoethane
1 ,2-Dichloroethane
2,3-Dichloroaniline
2-Propanone
4-Chloro-3-methylphenol
4-MethyI-2-pentanone
Acetophenone
Aluminum
Antimony
Arsenic
Barium
Benzene
Benzole Acid
Butanone
Cadmium
Carbon Disulfide
Chloroform
Chromium
Cobalt
Copper
Diethyl Ether
Ethyl Benzene
Hexavalent Chromium
Hexanoic Acid
Iron
Lead
Maqnesium
Removal (%)
23.00
90.45
55.98
75.34
5.00
17.00
89.03
41.00
83.75
63.00
87.87
95.34
16.81
71.13
90.89
90.20
94.76
80.50
91.83
90.05
84.00
73.44
91.25
4.81
84.11
7.00
93.79
5.68
84.00
83.00
91.83
31.83
Source of Data
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW ->20,wg/l Edit
50 POTW ->20M9/I Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
RREL - Domestic Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
                                  5-12

-------
Table 5-7.   Final POTW Removals for CWT Pollutants (continued)
Pollutant Parameter
Manganese
Mercury
Methyle'ne Chloride
Molybdenum
m-Xylene
Nickel
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o&p-Xylene
o-Cresol
Phenol
Pyridine
p-Cresol
Silver
Tetrachloroethene
Tetrachloromethane
Tin
Titanium
Toluene
Total Cyanide
trans-1 ,2-Dichloroethene
Trichloroethene
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Zinc
Removal (%)
40.60
90.16
54.28
52.17
65.40
51.44
9.00
88.00
95.05
92.40
71.11
71.11
71.11
71.11
95.07
52.50
95.25
95.40
71.67
92.42
84.61
87.94
65.20
68.77
96.18
70.44
70.88
86.85
46.77
93.49
77.97
Source of Data
RREL - All Wastewater Edit
50 POTW - 10 x NOMDL Edit
50 POTW - 10 x NOMDL Edit
RREL - Domestic Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
Generic removal-Group C
Generic removal-Group C
Generic removal-Group C
Generic removal-Group C
RREL - Domestic Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
RREL - All Wastewater Edit
RREL - All Wastewater Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
50 POTW - >20 ua/\ Edit
50 POTW - 1 0 x NOMDL Edit
Generic removal-Group Q
50 POTW - 1 0 x NOMDL Edit
50 POTW - 1 0 x NOMDL Edit
                                     5-13

-------
5.3.5 Final Pass-Through Analysis Results

      For each CWT option/pollutant, the daily removals were calculated using the
BPT/BAT data.  Then, the average overall BPT/BAT removal was calculated for each
pollutant from the daily removals. The averaging of daily removals is appropriate for this
industry as the BPT/BAT treatment technologies typically have retention times of less
than one day.  For the final pass-through analysis, the final POTW removal determined
for each CWT pollutant was compared to the percent removal achieved for that pollutant
using the BPT/BAT option treatment technologies.
      Those pollutants that were deemed to not pass though were then subjected to a
volatile override test.  A volatile override was applied where the overall percent removal
estimated at a POTW included in substantial part the emission of the pollutant to the air
rather than actual treatment. Therefore, even though the POTW removal data indicated
that a  volatile  pollutant would  not  pass  through, the volatile  override  warranted
establishment of PSES for that pollutant.
      The Henry's  Law  Constant for a pollutant  gives a qualitative indication of its
volatility.  For pollutants with values less than 10"7 atm-m?mole, the chemical is less
volatile than water; for pollutants around 10'3, volatilization from water will be rapid.  The
cut-off used for the volatile override  was a Henry's Law Constant of 2.4 x 10'5 atm-
nrrVmole, or 1CT3 mg/m3/mg/m3.  EPA considers this cut-off to be a conservative edit for
pollutants of medium to high volatility.
      For the CWT pass-through analysis, 12 organic pollutants were found to not pass
through after the preliminary analysis, and were therefore reviewed for volatility.  The
Henry's Law Constants for these pollutants are presented in Table 5-8.  Of these 12
pollutants, eight were affected  by the volatile override;  therefore, these pollutants are
now considered to pass through POTWs.
                                      5-14

-------
Table 5-8.   Volatile Override Analysis for CWT Pollutants
Pollutant Parameter
1 , 1 , 1-Trichloroethane
2-Butanone
2-Propanone
Benzene
Carbon Disulfide
Methylene Chloride
o&p-Xylene
Phenol
Pyridine
Toluene
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Henry's Law Constant
(atm-m3/mole)
4.8 *10'3
2.7 *10'5
2.1 * ID'5
5.6 *10'3
1.2 *10'2
3.2 *10'3
7.0 *10'3
1.3*10*
2.1 * 10-6
5.9 * 10'3
No data available
2.8 *10'2
Volatile Override
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Yes
No
Yes
      Of the 87 pollutants regulated under BAT, 78 were found to pass through for
Regulatory Option 1 (the combination of Metals Option 3, Oils Option 2, and Organics
Option 1), and 81 were found to pass through under Regulatory Option 2 (the combination
of Metals Option 3, Oils Option 3, and Organics Option 1), and are proposed for PSES.
The final pass-through  analysis results for  the CWT  Metals,  Oils,  and Organics
Subcategory Options are presented in Tables 5-9, 5-10, and 5-11, respectively.
                                      5-15

-------
Table 5-9.   Final Pass-Through Results for Metals Subcategory Option 3
Pollutant Parameter
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Hexavalent
Chromium
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Silver
Tin
Titanium
Total Cyanide
Zinc
Option 3
Removal
(%)
99.99
99.76
99.88
85.58
99.93
99.99
99.20
100.00
98.55
99.96
99.97
99.81
99.97
99.81
99.67
99.55
99.90
99.98
95
99.99
POTW
Removal
(%)
16.81
71.13
90.89
90.20
90.05
91.25
4.81
84.11
5.68
83.00
91.83
31.83
40.60
90.16
51.44
92.42
65.20
68.77
70.44
77.97
Prelim.
Pass-
Through
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Volatile
Override
_
_
_
NA
_
_
_
_
-
_
_

_
_
_
_
..
_
_
-
Final
Pass-
Through
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
                                     5-16

-------
Table 5-10.  Final Pass-Through Results for Oils Subcategory Options 2 and 3
Pollutant Parameter
1 ,1 ,1-Trichioroethane
2-Propanone
4-Chloro-3-methylphenol
Aluminum
Barium
Benzene
Butanone
Cadmium
Chromium
Copper
Ethyl Benzene
Iron
Lead
Manganese
Methylene Chloride
m-Xy!ene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
Nickel
o&p-Xylene
Tetrachloroethene
Tin
Toluene
Tripropyleneglycol Methyl
Ether
Zinc
Option
Removal (%)
2
80.21
96.38
80.60
97.48
99.37
64.53
96.37
97.46
84.67
99.66
94.20
93.24
92.57
80.60
51.74
95.08
99.90
97.77
99.85
99.69
97.81
99.76
99.13
99.37
24.40
94.03
91.29
82.87
83.23
27.12
68.82
3
97.71
95.97
98.40
99.80
99.96
93.89
95.63
99.20
99.77
99.96
99.63
99.92
99.72
99.66
81.30
99.80
99.96
99.02
99.94
99.86
99.04
99.89
99.62
99.72
98.37
99.73
99.13
94.35
98.53
82.46
98.51
POTW
Removal
(%)
90.45
83.75
63.00
16.81
90.20
94.76
91.83
90.05
91.25
84.11
93.79
83.00
91.83
40.60
54.28
65.40
9.00
88.00
95.05
92.40
71.11
71.11
71.11
71.11
51.44
95.07
84.61
65.20
96.18
46.77
77.97
Prelim
Pass-
Throuqh
2
No
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
No
No
No
3
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Volatile
Override
Yes
-
--
-
-
Yes
-
-
NA
-
-
-
-
-
Yes
-
-
-
-
-
-
-
-
-
NA
Yes
'
-
Yes
NV
NA
Final
Pass-
Through
2
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
3
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
                                     5-17

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Table 5-11.  Final Pass-Through Results for Organics Subcategory Option 1
Pollutant Parameter
1 ,1 ,1 ,2-TetrachIoroethane
1 ,1 ,1-TrichIoroethane
1 ,1 ,2-Triehloroethane
1 ,1-DichIoroethene
1 ,2,3-TrichIoropropane
1,2-Dibromoethane
1 ,2-Dichloroethane
2,3-Dichloroaniline
2-Propanone
4-MethyI-2-pentanone
Acetophenone
Aluminum
Antimony
Barium
Benzene
Benzoic Acid
Butanone
Carbon Disulfide
Chloroform
Diethyl Ether
Hexanoic Acid
Lead
Methylene Chloride
Molybdenum
m-Xylene
o-Cresol
Phenol
Pyridine
p-Cresol
Tetrachloroethene
Tetrachloromethane
Toluene
trans-1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Zinc
Option 1
Removal
(%)
98.86
91.78
93.71
89.70
95.82
99.74
99.17
67.33
79.44
96.00
97.38
83.57
72.13
94.29
91.40
96.88
69.80
68.01
96.22
69.83
90.43
66.49
97.29
75.38
91.09
99.84
90.34
60.17
92.32
93.60
99.80
98.18
95.82
92.28
92.19
73.75
POTW
Removal
(%)
23.00
90.45
55.98
75.34
5.00
17.00
89.03
41.00
83.75
87.87
95.34
16.81
71.13
90.20
94.76
80.50
91.83
84.00
73.44
7.00
84.00
91.83
54.28
52.17
65.40
52.50
95.25
95.40
71.67
84.61
87.94
96.18
70.88
86.85
93.49
77.97
Prelim Pass-
Through
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Volatile
Override
-
-
-
-
-
-
-
-
No
-
-
-
-
-
Yes
-
Yes
Yes
-
-
_
NA
-
-
-
-
No
No
-
-
-
_
-
-
Yes
NA
Final Pass-
Through
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
                                     5-18

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5.4   REFERENCES

Howard, Philip H., Environmental Fate and Exposure for Organic Chemicals - Volume I -
Large Production and Priority Pollutants, Lewis Publishers, Inc., Chelsea Ml, 1989.

Stecher, Paul G., et al., Editor, The Merck Index - 8th Edition, Merck & Co., Inc., Rahway,
NJ, 1968.

U.S. EPA, Development Document for Effluent Limitations Guidelines and Standards for
the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category - EPA 440/1-
87/009, Washington, DC, October 1987.

U.S. EPA, 50 POTW Study Data Base, 1978-80.

U.S. EPA, Methods for Chemical Analysis of Water and Wastewater, Cincinnati, OH,
1979.

U?S. EPA, Risk Reduction Engineering Laboratory (RREL) Treatability Data Base -
Version 5.0 (Draft),  Cincinnati, OH, 1994.

Weast, Robert C., Editor, Handbook of Chemistry and Physics - 55th Edition, CRC Press,
Inc., Cleveland, OH, 1974.
                                     5-19

-------

-------
SECTION 6
WASTEWATER TREATMENT TECHNOLOGIES
      This section discusses the technologies available for the treatment of wastewater
generated by the CWT Industry.  Many of these technologies are currently in operation
at CWT facilities; the others were chosen for inclusion in this discussion based on their
potential for application in treating the CWT pollutants of concern.
      The processes presented  here   include  both those  that  remove  pollutant
contaminants in wastewater and those that destroy them.  If a wastewater treatment
technology that removes, rather than destroys, a pollutant is selected, then a treatment
residual will be generated. In  many instances, this residual is in the form of a sludge,
which is typically further treated on-site to  prepare it for  disposal.   Subsection 6.4
discusses technologies which can be used to  dewater sludges to concentrate them prior
to disposal. Other types of treatment residuals, such as spent activated carbon and filter
media, are generally sent off-site to a vendor facility for management.
6.1   PHYSICAL/CHEMICAL/THERMAL
      TECHNOLOGIES
WASTEWATER   TREATMENT
      The wastewater treatment technologies presented in this subsection comprise the
 majority of operations found at CWT facilities. These technologies are generally efficient
 and cost-effective.  Included among these technologies are processes, such as filtration,
 which utilize physical interactions to achieve pollutant removal, and others, such as
 chemical precipitation, which utilize a chemical reaction to change the form of a pollutant
 so that it can be removed from the waste stream.  Other technologies,  such as the
 thermal destruction of cyanide, use heat to destroy pollutants.
                                      6-1

-------
6.1.1
Chemical Precipitation
6.1.1.1
Technology Description
      Chemical  precipitation is used  for  the  removal  of  metal  compounds  from
wastewater.  In the chemical precipitation process,  soluble metallic ions and certain
anions are converted to insoluble forms, which precipitate  from the solution.   The
precipitated metals are subsequently removed from the wastewater stream by liquid
filtration or clarification.  The performance of the  process  is affected  by chemical
interactions, temperature, pH, solubility,  and mixing effects.
      Various chemicals can be used as precipitants;  these include caustic (NaOH), lime
(Ca(OH)2), soda ash, sulfide, ferrous sulfate, and acid.  Hydroxide precipitation is effective
in removing such metals as antimony, arsenic, chromium, copper, lead, mercury, nickel,
and zinc. Sulfide precipitation primarily  removes mercury, lead, and  silver.
      Hydroxide precipitation using lime or caustic is the most commonly-used means
of chemical precipitation, and of these, lime is used more often than  caustic.  The chief
advantage of lime over caustic is its lower cost. However, lime is more difficult to handle
and feed, as it must be slaked, slurried,  and mixed, and can plug the feed  system lines.
Lime also produces a larger  volume of sludge, and the sludge is generally not suitable
for reclamation due to its homogeneous nature. Also, dewatered metal sludge is typically
sold to smelters for  reuse,  and the calcium compounds in  lime precipitation sludge
interfere with  smelting.   The metals from caustic  precipitation  sludge can often be
recovered.  The  reaction mechanism for precipitation of a divalent metal  using lime is
shown below:

                       NT  +  Ca(OH)2  -> M(OH)2 +  Ca++

And, the reaction mechanism for precipitation of a divalent metal using caustic is:
                       IVT + 2NaOH  -ป M(OH)2 +  2Na+
                                      6-2

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      In addition to the type of treatment chemical chosen, another important design
factor in the chemical precipitation operation is pH.  Metal hydroxides are amphoteric,
meaning that they can react chemically as acids or bases.  As such, their solubilities
increase toward both lower and higher pH levels. Therefore, there is an optimum pH for
precipitation for each metal, which corresponds to its point of minimum solubility. Another
key consideration in a chemical precipitation application  is the detention time, which is
specific to the wastewater being treated and the desired effluent quality. It may take from
less than an hour to several days to achieve adequate precipitation of the dissolved metal
compounds.
      Chemical precipitation is a two-step process.  It is typically performed in batch
operations where the wastewater is first mixed with the treatment chemical in a tank.  The
mixing  is typically achieved by mechanical means such  as  mixers or recirculation
pumping.  Then, the wastewater undergoes a separation/dewatering process such as
clarification or filtration, where the precipitated metals are removed from solution.  In a
clarification system, a flocculant is sometimes added to aid in the settling process.  The
resulting sludge from the clarifier or filter must be further treated, disposed, or recycled.
A typical chemical precipitation system  is shown in Figure 6-1<
      The batch operation aspect of chemical precipitation makes it an easily-adapted
process for the CWT Industry, where the waste receipts can be highly variable. A facility
can hold its wastes and segregate them by pollutant content for treatment.  This type of
waste treatment management, called selective metals precipitation, can be implemented
in order to concentrate on one or two major pollutants of concern.  This application of
chemical precipitation uses several tanks to allow the facility to segregate its wastes into
smaller batches, thereby avoiding interference with other incoming waste receipts and
increasing treatment efficiency. These specific operations would also produce specific
sludges containing only the target metals, making them suitable for reclamation.
                                       6-3

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                               Treatment Chemical
                                      i
      Wastewater
        Influent
             I	
                                               Chemical Controller
                             CO
                                                        - Treated
                                                         Effluent
                    Chemical Precipitation Tank
Figure 6-1.  Chemical Precipitation System Diagram
                                  6-4

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6.1.1.2       Treatment Performance

      The effluent quality achievable with chemical precipitation depends upon the metals
present in the wastewater and the process operating conditions. It is a demonstrated and
widely-used technology, often removing metal pollutants down to levels of 1 jig/l or less.
      According  to  the  WTI  Questionnaire  data base,  there  are  184 individual
applications of chemical precipitation in the CWT Industry.  Often a single facility will use
several chemical precipitation applications, depending upon the type of waste being
treated. Four specialized  applications of chemical precipitation were identified as BPT for
the Metals Subcategory of the CWT Industry; these are hydroxide chemical precipitation
and selective metals precipitation followed by  secondary  precipitation, then  tertiary
precipitation.
       During the CWT project, EPA conducted sampling  at three facilities (CWT QIDs
059, 105, and 230) that use hydroxide chemical precipitation systems.  At QID 059, the
chemical  precipitation effluent was sent through a filter press.  The effluents from the
chemical  precipitation systems at QIDs 105 and 230 were treated in clarifiers. The
performance  data obtained for these applications are presented in Tables 6-1, 6-2, and
6-3.  As these data show, the systems at QIDs 059 and  105 achieved high metals
removals, in  the 90 to 99.99 percent range.   The data for QID  230 shows poorer
performance.
       EPA also  sampled one facility (CWT QID 130) that operates selective metals
precipitation processes (for both solid and liquid waste receipts), followed by secondary
and tertiary precipitation systems. The effluents from the selective  metals precipitation
processes and the secondary precipitation system were filtered, and the effluent from the
tertiary precipitation system was clarified. The sampling data for these individual systems
are presented in Tables 6-4, 6-5, 6-6, and 6-7.  The sampling data for the overall  metals
treatment train at QID 130 (selective metals precipitation, secondary  precipitation, and
tertiary precipitation) is presented in Table 6-8.  As this table shows, the overall system
at  QID 130 achieved removals of greater than  99 percent for each  of the 10  metals
presented.
                                       6-5

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Table 6-1.   Chemical Precipitation System Performance Data for CWT QID 059
Parameter
Aluminum
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Silver
Zinc
Influent Avg (u.g/1)
620,080
244
228,772
286,191
6,702
33,596
1,458
972,600
1,845
90,040
Effluent Avg (|ig/l)
2,125
5 (ND)
384
60
50
72
86
90,834
91
2,257
Removal (%)
99.66
97.95
99.83
99.98
99.25
99.79
94.10
90.66
95.08
97.49
Table 6-2.   Chemical Precipitation System Performance Data for CWT QID 105
Parameter
Aluminum
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Silver
Zinc
Influent Avg (jig/l)
400,030
48,065
3,652,458
454,740
84,462
26,175
106
631 ,996
2,488
473,078
Effluent Avg (|ig/l)
12,133
217
3,300
16,300
480 (ND)
53
0.2 (ND)
4,243
53
2,427
Removal (%)
96.97
99.55
99.91
96.42
99.43
99.80
99.81
99.33
97.89
99.49
      ND =  Not detected
                                     6-6

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Table 6-3.   Chemical Precipitation System Performance Data for CWT QID 230
Parameter
Aluminum
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Influent Avg (|ig/l)
37,648
22
317
28,136
415
2,214
5
970
167,583
Effluent Avg (ng/l)
1 1 ,837
17 (ND)
37 (ND)
259
250 (ND)
65
2(ND)
169
1,287
Removal (%)
68.56
23.77
88.33
99.08
39.69
97.05
57.45
82.55
99.23
      ND =  Not detected
Table 6-4.   Selective Metals Precipitation (Solid Metals Recovery) System Performance
            Data for CWT QID 130
Parameter
Copper
Lead
Zinc
Influent Avg (|ig/l)
4,228,071
487,786
7,196,571
Effluent Avg (|j,g/l)
19,880
7,334
57,218
Removal (%)
99.53
98.50
99.20
                                      6-7

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Table 6-5.   Selective  Metals  Precipitation   (Liquid   Metals   Recovery)   System
            Performance Data for CWT QID 130
Parameter
Chromium
Copper
Nickel
Silver
Minimum Batch
Removal (%)
(103.39)
28.01
93.95
(4.69)
Maximum Batch
Removal (%)
93.34
97.85
99.99
99.87
Average Batch
Removal (%)
26.70
66.08
97.73
55.35
Table 6-6.   Secondary Precipitation System Performance Data for CWT QID 130
Parameter
Aluminum
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Silver
Zinc
Influent Avg (|j,g/l)
7,679
1,500
21 1 ,924
412,750
3,119
2,346
19
48,883
280
28,949
Effluent Avg (|ig/l)
337
101
690
970
308
61
1
1,060
4(ND)
845
Removal (%)
95.61
93.25
99.67
99.77
90.14
97.40
93.49
97.83
98.57
97.08
      ND =  Not detected
                                     6-8

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Table 6-7.   Tertiary Precipitation System Performance Data for CWT QID 130
Parameter
Aluminum
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Zinc
Influent Avg (u.g/1)
337
101
690
970
308
61
1
1,060
845
Effluent Avg (|j.g/l)
97
82
37
145
50
12
0.20 (ND)
1,251
167
Removal (%)
71.32
18.85
94.63
85.06
83.75
80.96
83.87
(18.07)
80.29
Table 6-8.   Overall Metals Precipitation System Performance Data for CWT QID 130
Parameter
Aluminum
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
Silver
Zinc
Influent Avg (p.g/1)
534,585
129,687
585,899
2,927,792
244,667
45,274
75
510,184
757
3,601,529
Effluent Avg (ng/l)
97
82
37
145
50
12
0.20 (ND)
1 ,251
4(ND)
167
Removal (%)
99.98
99.94
99.99
99.99
99.98
99.97
99.73
99.75
99.47
99.99
       ND  = Not detected
                                      6-9

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6.1.2
Clarification
6.1.2.1
Technology Description
       Clarification  systems provide continuous,  low-cost separation and  removal of
suspended solids from water by the use of gravity.   Clarification is used to remove
particulates,  flocculated  impurities, and  precipitates.   These  systems typically  follow
wastewater treatment processes which generate  suspended solids,  such as chemical
precipitation and biological treatment.
       Clarification units  are often  preceded by a flocculation step to promote settling.
The flocculation process involves the addition of a treatment chemical, or flocculant, to
the wastewater.  There are three different types of flocculants:  inorganic electrolytes,
natural organic polymers, and synthetic polyelectrolytes. The flocculant is rapidly  mixed
with the wastewater to disperse it uniformly. The  duration of the rapid mix step is very
short, usually about one to two minutes. Slow and moderate mixing is provided to allow
the particles to agglomerate into larger, heavier, more settleable  particles.
       In the  clarifier, the wastewater is allowed to flow slowly and uniformly, permitting
the solids more dense than water to settle to the  bottom.  The clarified wastewater is
discharged by flowing from the top of  the clarifier over a weir.  Conventional clarifiers
typically consist of a circular or rectangular tank.  There are more specialized types of
clarifiers which incorporate tubes,  plates, or lamellar networks to increase the settling
area. The sludge which accumulates at the bottom is periodically removed and must be
dewatered and disposed. A circular clarification system is illustrated  in Figure 6-2.
6.1.2.2
Treatment Performance
      According  to   the   WTI   Questionnaire   data   base,   there   are   35
clarification/flocculation systems in operation in the CWT Industry.  CWT QID 105, which
was sampled by EPA during this rulemaking project, employs a clarifier which treats the
wastewater from hydroxide metals precipitation. This clarifier reduces an influent stream
                                       6-10

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               Skimming Scraper
       Overflow
              Influent
                                                                    Effluent
                                                             Skimmings Removal
Sludge Removal
Figure 6-2.  Clarification System  Diagram





                                         6-11

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of approximately 40,000 mg/l TSS (four percent solids) to an effluent of 500 mg/l.  The
collected sludge TSS concentration is about 200,000 mg/l or 20 percent solids.
6.1.3
Plate and Frame Pressure Filtration
6.1.3.1
Technology Description
      Plate and frame pressure filtration systems are used for the removal of solids from
waste streams. The liquid stream plate and frame pressure filtration system is identical
to the system used for the sludge stream (Subsection 6.4.1) with the exception of a lower
solids level in the influent stream. The same equipment is used for both applications, with
the difference being in the sizing of the sludge and liquid units. A  plate and frame filter
press is shown in Figure 6-3.
      A  plate  and frame filter  press  consists of a  number of filter plates or trays
connected to a frame and pressed together between a fixed end and a moving end. Filter
cloth is mounted on the face of each plate.  The sludge is pumped into  the unit under
pressure while the plates are pressed together. The solids are retained  in the cavities
of the filter press and begin to attach to the filter cloth until a cake is formed.  The water,
or filtrate passes through the filter cloth and is discharged from a drainage port in the
bottom of the press.  The sludge influent is pumped into the system until the cavities are
filled. Pressure is applied to the plates until the flow of filtrate stops.
      At the end of the cycle, the pressure is released  and the plates are separated.
The filter cake drops into a hopper below the press.  The filter cake can then be disposed
in a landfill. The filter cloth is washed before the next cycle begins.
      The key advantage of plate  and frame pressure filtration is that it can produce a
drier filter cake than is possible with the other methods of sludge dewatering. The batch
operation of the plate and frame filter press makes it a practical choice for the filtration
of a batch chemical precipitation process effluent. Therefore, it is well-suited for use in
the CWT Industry.  However, its batch operating mode results in greater operating labor
requirements.
                                       6-12

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      Fixed End
     Sludge
     Influent
   Filtrate
Filter Cloth
  Filter Cake
                                                 Applied
                                                 < Force
                                                      Plate Assembly
Figure 6-3.  Plate and Frame Pressure Filtration System Diagram
                                  6-13

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6.1.3.2
Treatment Performance
      Respondents to the WTI Questionnaire reported that 34 plate and  frame filter
presses (treating liquid and sludge streams) are in operation in the CWT Industry. In a
typical plate and frame pressure filtration unit, the filter cake has a dry solids content
between 30 and 50 percent.
6.1.4
Emulsion Breaking
6.1.4.1
Technology Description
      Emulsion breaking is used to treat emulsified oil/water mixtures.  An emulsion, by
definition, is either stable or unstable.  A stable emulsion is one where the droplets of the
dispersed phase are so small that settling and coalescence would occur very slowly or
not at all. An unstable emulsion, or dispersion, settles very rapidly and does not require
treatment to break the emulsion.  Stable emulsions .are often intentionally formed by
chemical addition to stabilize the oil mixture for a specific application.  Some examples
of stable emulsified oils are coolants, lubricants, and antioxidants.                 •
      Emulsion breaking is achieved by the addition of chemicals and/or heat to the
waste oil mixture.  The most commonly-used method  of emulsion breaking is acid-
cracking with or without heat addition. Sulfuric or hydrochloric acid is added to the tank
containing the oil  mixture until the pH reaches 1 or 2. A coagulant is also added.  The
tank contents are agitated for mixing.  After the emulsion bond is broken, the oil residue
is allowed to float to the top of the tank.  At this  point, heat (100 to 150ฐ F) may be
applied  to speed  the separation process.  The oil is then skimmed off by mechanical
means,  or the water is decanted from the  bottom  of the tank. The oil residue is  then
further processed or disposed. A diagram of an emulsion breaking system is presented
in Rgure 6-4.
                                      6-14

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             Chemical
             Addition
  Wastewater
  Influent
T.
" r ->"'** ~
-. f < ',
„ Mixing „
Tanfe
•• ^ v fff


V.V.*.
jjf




r
Oil
Residue
                                                  Sludge
                                                                 Treated

                                                                 Effluent
Figure 6-4.  Emulsion Breaking System Diagram
                                    6-15

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      An advantage of the emulsion breaking process is the high removals that are
possible.  A disadvantage, however, is the high operating costs for treatment chemicals
and heat generation.  One way to minimize operating costs is to pretreat the oil/water
mixture to physically separate any free oil that may be present before emulsion breaking
is performed.
6.1.4.2
Treatment Performance
      Emulsion breaking is a highly effective treatment technology for separating oil from
water.   Typically, emulsions of five to  10 percent oil can be reduced to about 0.01
percent. Emulsion breaking is a common process in the CWT Industry;  it is used by
most of the facilities identified as belonging in the Oils Subcategory.  As such, EPA has
concluded that it is the baseline, current performance technology for the Oils Subcategory
for those facilities that treat emulsified oily wastes.

6.1.5        Equalization
6.1.5.1      Technology Description

      Waste treatment facilities often need to equalize wastes by holding them in a tank
for a certain period of time to get a stable waste stream which is easier to treat.  In the
CWT Industry, equalization is  frequently  used to minimize the variability of incoming
wastes prior to certain treatment operations.  Equalization is found at facilities identified
in all of the CWT subcategories.
      The equalization tank serves many functions. The influent flow is equalized so that
the effluent is discharged to downstream processes at a uniform rate. This levels out the
effect of peak and minimum flows. Additionally, waste contaminants are blended together
to provide a more constant discharge to the treatment system. This is accomplished by
mixing  smaller  volumes  of  concentrated  wastes  with  larger  volumes  at  lower
concentrations.  For example,  the pH can be controlled to prevent fluctuations which
                                      6-16

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could upset the efficiency of downstream treatment system units by mixing acid and
alkaline wastes in the equalization tank.  Equalization tanks are usually equipped with
mixing where the dampening of pollutant concentrations is desired.  An equalization
system is shown in Figure 6-5.
6.1.5.2
Treatment Performance
      According to the WTI Questionnaire response data base, there are 81 equalization
systems in the CWT Industry. Of these, 36 are unstirred and 45 are stirred or aerated.
No performance data were obtained for these systems.

6.1.6       Air Stripping

6.1.6.1      Technology Description

      Air stripping  is an  effective treatment  method  for removing  dissolved volatile
organic compounds from wastewater. The removal is accomplished by passing high
volumes of  air through the agitated  wastewater stream.   The process results in a
contaminated off-gas  stream which, depending upon air emissions standards, usually
requires air pollution control  equipment.
      Stripping  can performed  in tanks or in spray or packed towers.  Treatment in
packed towers is the most efficient application.  The packing typically consists of plastic
rings or saddles.  The two  types of towers that are commonly-used, cross-flow and
countercurrent, differ  in design  only in the location of the air inlets.  In the  cross-flow
tower, the air is drawn through the sides for the total height of the  packing.  The
countercurrent tower draws the entire air flow from the bottom. The cross-flow towers
have been found to be more susceptible to scaling problems and are less efficient than
the countercurrent towers. A countercurrent air stripper is shown in Figure 6-6.
      The driving force of the air stripping mass-transfer operation is the difference in
concentrations between the  air  and liquid streams. Pollutants are  transferred from the
                                      6-17

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   Wastewater
   Influent
D
                             CO
                       Equalization
                           Tank
             r
[Equalized
Effluent
Figure 6-5.  Equalization System Diagram


                              6-18

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    Wastewater
    Influent
           Blower
                            Off-gas
                                             Distributor
                                              Support
                                                     Treated
                                                     Effluent
Figure 6-6.  Air Stripping System Diagram
                                 6-19

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more concentrated wastewater stream to the less concentrated air stream until equilibrium
is reached; this equilibrium relationship is known as Henry's Law. The strippability of a
pollutant is expressed as its Henry's Law Constant, which is a function of both its volatility
and solubility.
      Air strippers are designed according to the strippability of the pollutants to  be
removed.  For evaluation purposes, the organic pollutants were divided into three general
strippability ranges (low, medium, and high) according to their Henry's Law Constants.
The low strippability group (Henry's Law Constants of 10"3 [mg/m3 air]/[mg/m3 water] and
lower) are not effectively removed. Pollutants in the medium (10~1  to 10"3) and high (10"1
and greater) groups are effectively stripped. Pollutants with lower Henry's law constants
require greater column height,  more trays or  packing material, greater pressure and
temperature, and more frequent cleaning than pollutants with a higher strippability.
      The air stripping process is adversely affected by low temperatures.  Air strippers
experience lower efficiencies at  lower temperatures, with the possibility of freezing within
the tower. For this reason, depending on the location  of the tower, it may be necessary
to preheat the wastewater and the air feed streams. The column and packing materials
must be cleaned regularly to ensure that low effluent levels are attained.
6.1.6.2
Treatment Performance
      Air stripping has proved to be an  effective process in the removal of volatile
pollutants from wastewater.  It is generally limited to influent concentrations of less than
100 mg/l organics.  Well-designed and operated systems can achieve over 99 percent
removals.
      One facility in the CWT Industry uses an air stripper to treat an organic-bearing
waste stream. This operation at CWT QID 059 was sampled by EPA, and these results
are  presented in Table 6-9.  The highly volatile  constituent toluene had an average
influent concentration of 551 |ig/l and an effluent level of 10 ng/j (98.2 percent removal).
The pollutant 1,2-dichloroethane  had an average influent level of 2,211 \ig/\ and an
effluent level of 10 \ig/\ (99.6 percent removal).
                                      6-20

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Table 6-9.   Air Stripping System Performance Data
Parameter
1 ,1 ,2-Trichloroethane
1 ,2-Dichloroethane
Chloroform
Methylene Chloride
Tetrachloroethene
Tetrachloromethane
Toluene
Trans-1 ,2-dichloroethene
Trichloroethene
Vinyl Chloride
Influent
Avg
(WO
2,481
2,736
11,615
32,217
6,973
5,527
551
2,211
9,332
555
Stripper #1
Effluent
Avg frig/l)
95
37
50
98
8
40
10 (ND)
16
41
10 (ND)
Stripper #2
Effluent
Avg (|ig/l)
19
29
30
385
12
12
10 (ND)
10 (ND)
22
10 (ND)
Removal (%)
(Influent to
Stripper #2)
99.24
98.93
99.75
98.80
99.83
99.79
98.18
99.55
99.76
98.20
       ND  =  Not detected
6.1.7
Multi-media Filtration
6.1.7.1
Technology Description
       Multi-media, or granular bed, filtration is used for achieving supplemental removal
 of residual  suspended  solids from  the effluent of chemical and biological treatment
 processes.   In granular bed filtration, the wastewater stream is sent through a bed
 containing one or more  layers of different granular materials.  The solids are retained in
 the voids between the  media particles while the wastewater passes through the bed.
 Typical media used in  granular bed filters include anthracite coal,  sand,  and garnet.
 These  media  can be  used alone, such as  in  sand filtration, or  in a  multi-media
 combination.  Multi-media filters are designed  such that the  individual layers of media
                                      6-21

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remain fairly discrete. This is accomplished by selecting appropriate filter loading rates,
media grain size, and bed density.
      A multi-media filter operates with the finer, denser media at the bottom and the
coarser, less  dense media at the top.  A common arrangement is garnet at the bottom
of the bed, sand, in the.middle,,and anthracite coal at the top.  Some mixing of these
layers occurs and is anticipated.  During filtration, the removal of the suspended solids
is accomplished by a complex process involving one  or more  mechanisms, such as
straining, sedimentation, interception, impaction, and adsorption. The medium size is the
principal characteristic that affects the filtration operation.  If the medium is  too small,
much of the driving force will be wasted in overcoming the frictional resistance of the filter
bed.  If the medium  is too large, small particles will travel through the bed, preventing
optimum filtration.
      The flow  pattern  of multi-media filters is  usually top-to-bottom.   Upflow filters,
horizontal filters,  and biflow filters are also used.  A top-to-bottom multi-media filter is
represented in Figure 6-7.  The classic multi-media filter operates by gravity; however,
pressure filters are occasionally used.
      The complete filtration  process involves two phases: filtration and backwashing.
As the filter becomes filled with trapped solids, the efficiency of the filtration process falls
off. Head loss is a measure of solids trapped in the filter.  As the  head loss across the
filter bed increases to a limiting value, the end of the filter run is reached and the filter
must be backwashed to remove the suspended solids in the bed.  During backwashing,
the flow through the filter is reversed so that the solids trapped in the media are dislodged
and can exit the filter.  The bed may also be agitated with air to aid in solids removal.
The backwash water is then recycled back into the wastewater feed stream.
      An  important feature  in filtration and backwashing  is  the underdrain.   The
underdrain is the support structure for the filtration bed.  The underdrain provides an area
for the accumulation of the filtered water without it being clogged from the filtered solids
or the media  particles. During backwash, the underdrain provides even flow distribution
over the bed.
                                      6-22

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        Coarse Media-
         Finer Media
        Finest Media
            Support
     Underdrain Chamber
                            Wastewater Influent
                                                      Backwash
                                  Coat
Silica Sand
                  Backwash
                             Treated Effluent
Figure 6-7. Multi-Media Filtration System Diagram
                                6-23

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6.1.7.2
Treatment Performance
      Respondents to the WTI Questionnaire report that there are 10 sand filters and 9
multi-media filters in use in the CWT Industry. A multi-media filter, installed following a
biological treatment system at CWT QID 059, was sampled by EPA for this project. The
results of this sampling show that the average TSS concentration was reduced from 1,164
to 198 mg/l, providing a 83 percent removal. This reduced the BOD5 of the waste stream
from 17,622 to 1,700 mg/l, or by 90 percent. The COD was  reduced from 53,451 to
2,400 mg/l, or by 96 percent.

6.1.8        Carbon Adsorption

6.1.8.1      Technology Description

      Activated carbon  adsorption is a demonstrated treatment technology  for the
removal of organic pollutants from wastewater. Most applications use granular activated
carbon (GAG) in column reactors.  Sometimes powdered activated carbon (PAC) is used
alone or in conjunction with another process, such as biological treatment.  However,
GAG  is the  more commonly-used method;  a diagram of a downflow fixed-bed GAG
system is presented in Figure 6-8.
      The  mechanism of adsorption is  a combination of physical,  chemical,  and
electrostatic interactions between the activated carbon and the  adsorbate, although the
attraction is primarily physical. Activated carbon  can be made from many carbonaceous
sources including  coal, coke, peat, wood, and coconut shells.
      The key design parameter is adsorption capacity;  this is a measurement of the
mass of contaminant adsorbed  per  unit  mass of carbon, and  is a function  of the
compound  being  adsorbed,  the  type  of carbon used,  and the  process design  and
operating conditions.  In general, the adsorption  capacity  is inversely proportional to the
adsorbate solubility.  Nonpolar, high molecular  weight organics with low solubility are
readily adsorbed. Polar, low molecular weight organics with high solubilities are more
                                     6-24

-------
    Fresh
    Carbon
    Fill
      Collector/
      Distributor
          Spent
          Carbon
          Discharge
                                   Wastewater
                                   Influent
Backwash
                                                   Backwash
                                                      Treated
                                                      Effluent
Figure 6-8.  Carbon Adsorption System Diagram
                                 6-25

-------
poorly adsorbed.   Competitive adsorption of other compounds  has an  effect on
adsorption.  The carbon may preferentially adsorb one compound over another;  this
competition could result in an adsorbed compound being desorbed from the carbon.
      In a fixed-bed system, the pollutants are removed in increasing amounts as the
wastewater flows through the bed. In the upper area of the bed, the pollutants are rapidly
adsorbed.  As more wastewater passes through the bed, this rapid adsorption zone
increases until it  reaches the bottom of the bed.   At this point, all of the available
adsorption sites are filled and the carbon is said to be exhausted. This condition can be
detected by an increase in the effluent pollutant concentration, and is called breakthrough.
      GAG  systems are usually comprised of several  beds  operated  in series.  This
design allows the first bed to go to exhaustion, while the other beds still have the capacity
to treat to an acceptable effluent quality.  The carbon in the first bed is replaced, and the
second bed then becomes the lead bed. The GAG  system piping is designed  to allow
switching of bed order.
      After the carbon is exhausted, it can  be removed and regenerated.  Usually heat
or steam is used to reverse the  adsorption  process.  The light organic compounds are
volatilized and the heavy organic compounds are pyrolyzed.  Spent carbon can also be
regenerated by contacting it with  a solvent which dissolves the adsorbed pollutants.
Depending on system  size and economics, some facilities may choose to dispose of the
spent  carbon instead of  regenerating  it.    For very  large  applications, an  on-site
regeneration facility is  sometimes constructed.  For smaller applications, such as in the
CWT Industry, it is generally cost-effective to use a vendor service to deliver regenerated
carbon and remove the spent carbon.  These vendors transport the spent carbon to their
centralized facilities for regeneration.

6.1.8.2      Treatment Performance

       GAG adsorption is a widely-used wastewater treatment technology. Generally, the
COD of the waste stream can be reduced to less than 10 mg/l and the BOD to less than
2 mg/l. Removal efficiencies typically are in the range of 30  to 90 percent.
                                      6-26

-------
      According to the WT1 Questionnaire data base, there are 11 GAG applications in
the CWT Industry, treating both organic and oily waste streams. During this rulemaking
project, EPA sampled GAG systems at two Organics Subcategory facilities (CWT QID 059
and 090) and one Oils  Subcategory facility (CWT QID 409).  The data obtained from
these sampling efforts are presented in Tables 6-10 and 6-11.
      As these results show, the sampled GAG systems did not perform as well as would
be expected. The COD  reductions for three of the units were very low (0.2,1.5, and 23.8
percent), with the organics unit at QID 090 showing an increase in COD. In general, the
data for the unit at QID 090 show that many pollutants were not detected in the influent,
with  very high analytical method detection levels. This makes it difficult to gauge the
performance for this unit on an individual pollutant basis.  The COD data, however, show
that the overall performance of this unit is poor.
      Poor  GAG system  performance can  sometimes  be  attributed to  competitive
adsorption between compounds in the waste stream. The pollutant methylene chloride
is often  used as a measure of adsorption competition in a GAG system. This is because
it is readily adsorbed, and also  desorbed by competitive compounds.  The two oils units
showed very low methylene chloride removals of 18.8 and 49.4 percent; these beds may
have been subject to competitive adsorption effects.  Conversely, the two organics units
demonstrated methylene removals of 87.0 and 89.5 percent;  these numbers are in the
range of expected performance.
      Another possible explanation for the poor performance of these units is the effect"
of the pollutant parameter oil and grease. The commonly-applied limit on oil and grease
loading to a GAG  system is 10 mg/l.   Oil and grease can coat the carbon particles,
thereby inhibiting the adsorption process. The two oils units and the organics unit at QID
090 had oil and grease loadings of 2,489, 49, and 76 mg/l, respectively. And, all three
of these systems showed oil and grease removals in the  60 to 85 percent range.  This
indicates that the carbon beds may have been adversely effected  by oil and  grease
coating. The organics unit at QID 059 had a significantly lower oil and grease loading of
6 mg/l, which is below the 10 mg/l limit.
                                      6-27

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                                        6-29

-------
      Judging from the data collected, all of these GAG systems have TSS-related
problems. The commonly-used TSS loading limit to a GAG system is 50 mg/l. Solids can
plug the  bed, resulting in excessive head loss.  Both of the organics  units had TSS
loadings (198 and 1,505 mg/i) in excess of this limit. The two oils units had TSS loadings
of 6 and  1 mg/l, well below the limit.  However, the effluents from the oils units showed
increases in wastewater TSS concentrations; this is not expected, as well-operated GAG
units usually provide filtration.
      All of the wastewaters from the sampled GAG systems showed increases in metals
concentrations. This may be a result of pH fluctuations within the units solubilizing metals
in the waste stream.  Overall, the poor performance of the CWT GAG units may have
been caused by the inherent difficulty of operating carbon adsorption units for variable
waste streams.

6.1.9       Cyanide Destruction

6.1.9.1      Technology Description

      Cyanide is a very toxic pollutant and, therefore, wastes containing cyanide are an
important environmental concern.  The major  portion of  cyanide-bearing wastes are
produced by electroplating and metal finishing operations.
      Three procedures used to perform cyanide destruction are discussed here; these
are  alkaline chlorination with  gaseous  chlorine, alkaline  chlorination  with sodium
hypochlorite, and confidential business information (CBI) cyanide destruction. A diagram
of an alkaline chlorination system is presented in Figure 6-9.  Alkaline chlorination can
destroy free dissolved hydrogen cyanide and can oxidize all simple and some complex
inorganic cyanides;  however, it cannot effectively oxidize stable iron, copper, and nickel
cyanide complexes. The addition of heat to the alkaline chlorination process can facilitate
the more complete destruction of total cyanides.
                                      6-30

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    Caustic Feed
     Wastewater
       Influent  .
Hypochlorite or Chlorine Feed
Figure 6-9. Cyanide Destruction System Diagram
                           Treated
                           Effluent
                                6-31

-------
      In alkaline chlorination  using gaseous chlorine,  the  oxidation  process is
accomplished by direct addition of chlorine (CI2) as the oxidizer and sodium hydroxide
(NaOH) to maintain pH levels. The reaction mechanism is:
      NaCN  + CI2
2NaCNO +  3CL  +
+ 2NaOH
6NaOH  -
                                        NaCNO +  2NaCI +  HO
                                     2NaHCO,
                N2  + 6NaCI  + 2H2O
      The destruction of the cyanide takes place in two stages.  The primary reaction is
the partial oxidation of the cyanide to cyanate at a pH above 9.  In the second stage, the
pH is lowered to the 8  to 8.5 range for the oxidation of the cyanate to  nitrogen and
carbon dioxide (as sodium bicarbonate).  Each part of cyanide requires 2.73 parts of
chlorine to convert it to  cyanate and an additional 4.1 parts ofchlorine to oxidize the
cyanate to nitrogen  and carbon dioxide.  At least 1.125 parts  of sodium hydroxide is
required to control the pH with each stage.
      Alkaline chlorination can also be conducted with sodium hypochlorite (NaOCI) as
the oxidizer.  The oxidation of cyanide waste using sodium hypochlorite is  similar to the
gaseous chlorine process.  The reaction mechanism is:
                     NaCN  + NaOCI ->  NaCNO  + NaCI
2NaCNO +  SNaOCI
H2O
                                   2NaHCO
                            N
                                                            SMaCI
      In the first step, cyanide is oxidized to cyanate with the pH maintained in the range
of 9 to 11 .  The second step oxidizes cyanate to carbon dioxide (as sodium bicarbonate)
and nitrogen at a controlled pH of 8.5.  The amount of sodium hypochlorite and sodium
hydroxide needed to perform the oxidation is 7.5 parts and 8 parts per part of cyanide,
respectively.
                                    6-32

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6.1.9.2
Treatment Performance
      Respondents to the WTI Questionnaire report that there are 30 cyanide destruction
operations in-place in the CWT Industry. Of these, one is a thermal unit, one is the CBI
unit, and the rest are chemical reagent systems. During this project, EPA sampled one
of each  of three cyanide treatment applications discussed in this subsection.
      The alkaline chlorination process using gaseous chlorine was sampled at CWT QID
255. The average amenable cyanide concentration was reduced from 1,563 mg/l in the
influent to 64.7 mg/l in  the effluent;  this is a 96 percent removal.  The average total
cyanide concentration was reduced from 1,721 mg/l  in the influent to 354.9 mg/I in the
effluent; this equals a removal of 79 percent.
      The sodium hypochlorite system, operated at an extended retention time,  was
sampled at CWT QID 105. The average influent concentration of amenable cyanide was
1,548 mg/l;  this was reduced  by 82 percent to an effluent concentration of 276.1 mg/l.
The average influent concentration of total cyanide was 4,634 mg/i; this was reduced by
97 percent to 135.7 mg/l.
      The CBI system was sampled at CWT QID 450. The average influent amenable
cyanide concentration was 3,317 mg/l and the effluent concentration was 8.2 mg/l, giving
a removal of 99.8 percent. This system reduced the average total cyanide concentration
from 6,467 to 10.4 mg/l; this is equal to a 99.8 percent removal.
6.1.10
Chromium Reduction
6.1.10.1     Technology Description

      Reduction is a chemical reaction in which electrons  are transferred from one
chemical to another. The main application of chemical reduction in wastewater treatment
is the reduction of hexavalent chromium to trivalent chromium.  The reduction enables the
trivalent chromium to be precipitated from solution in conjunction with other metallic salts.
Sulfur dioxide, sodium bisulfite, sodium metabisulfite,  and ferrous sulfate are strong
                                     6-33

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reducing agents and are commonly used in industrial wastewater treatment applications.
Two types of chromium reduction are discussed here; these are reduction through the
use of sodium metabisulfite or sodium bisulfite and reduction through the use of gaseous
sulfur dioxide.  A diagram of a chromium reduction system is presented in Figure 6-10.
      These chromium reduction reactions are reactions are favored by a low pH of 2
to 3.  At pH levels above 5, the reduction  rate is  slow.  Oxidizing agents such  as
dissolved oxygen and ferric iron interfere with the reduction process by consuming the
reducing agent.  After the reduction process, the trivalent chromium is removed  by
chemical precipitation.
      Chromium reduction using sodium metabisulfite (Na2S2O5) and sodium bisulfite
(NaHSOg) are essentially similar. The mechanism for the reaction using sodium bisulfite
as the reducing agent is:
3NaHS03 + 3H2SO4
2H2CrO4
                                          Cr2(SO4)3 +  3NaHSO4  + 5H2O
      The  hexavalent chromium is  reduced to trivalent  chromium  using sodium
metabisulfite, with sulfuric acid used to lower the pH of the solution.  The amount of
sodium metabisulfite needed to reduce the hexavalent chromium is reported as 3 parts
of sodium bisulfite per part of chromium, while the amount of sulfuric acid is 1 part per
part of chromium. The theoretical retention time is about 30  to 60 minutes.
      A second process uses sulfur dioxide (SO2) as the reducing agent.  The reaction
mechanism is:
                    3SO
     3H2O
                                            3H2SO3
3HSO
                       2H2Cr04
            Cr2(SO4)3
                                                      5H2O
      The hexavalent chromium is reduced to trivalent chromium using sulfur dioxide,
with sulfuric acid used to lower the pH of the solution. The amount of sulfur dioxide
needed to reduce the hexavalent chromium is reported as 1 .9 parts of sulfur dioxide per
                                     6-34

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                     Sulfuric
                       Acid
                           Treatment
                           Chemical
         pH Controller
          Wastewater
            Influent
                                Chemical Controller
                                                            Treated
                                                           Effluent
                               Reaction Tank
Figure 6-10.
Chromium Reduction System Diagram
                                    6-35

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part of chromium, while the amount of sulfuric acid is 1 part per part of chromium.  At a
pH of 3, the theoretical retention time is approximately 30 to 45 minutes.

6.1.10.2     Treatment Performance

      According to the WTI Questionnaire  response  data  base, chromium reduction
operations are conducted at 38 facilities in the CWT Industry.  Of these 38 facilities, there
are four sulfur dioxide  processes,  21  sodium bisulfite  processes, and two sodium
metabisulfite processes. The remaining systems use various other reducing agents. As
part of this  rulemaking project, EPA sampled one of each of the two types of reduction
processes discussed in this subsection.
      For the chromium reduction process  using sodium metabisulfite, sampling was
conducted at CWT QID 067. Only one batch was sampled at this facility;  the influent
hexavalent chromium concentration was 10 |ig/l and the effluent concentration was 285
|ig/l. This shows an increase in hexavalent chromium  concentration.
      The  chromium reduction process using sulfur dioxide was sampled at CWT QID
255.  The average influent hexavalent chromium concentration was 940,253 ng/l; the
average effluent concentration was 30  |ig/l.  This shows a reduction of 99.99 percent.

6.1.11      Electrolytic Recovery

6.1.11.1      Technology Description

      Electrolytic recovery is used for  the reclamation of  metals from wastewater.  It is
a common technology in the electroplating, mining, and electronic industries.  It is used
for the recovery of copper, zinc, silver, cadmium, gold, and other heavy metals. Nickel
is poorly recovered due to its low standard potential.
      The electrolytic recovery process uses an  oxidation and  reduction reaction.
Conductive electrodes  (anodes and  cathodes) are  immersed in the  metal-bearing
wastewater, with electrical energy applied to them. At the cathode, a metal ion is reduced
                                      6-36

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to its elemental form (electron-consuming reaction).  At the same time, gases such as
oxygen, hydrogen, or nitrogen form at the anode (electron-producing reaction).  After the
metal coating  on the cathode reaches a desired thickness, it may be removed and
recovered. The metal-plated cathode can then be used as the anode.
      The equipment consists  of an electrochemical  reactor with electrodes,  a gas-
venting system, recirculation pumps, and a power supply. A diagram of an electrolytic
recovery system is presented in Figure 6-11.  Electrochemical reactors are typically
designed to produce high flow rates to increase the process efficiency.
      A conventional electrolytic recovery system is effective for the recovery of metals
from relatively high-concentration wastewater.  A specialized adaptation of electrolytic
recovery,  called extended surface electrolysis,  or ESE,  operates effectively at lower
concentration  levels.  The ESE system uses a spiral cell containing a flow-through
cathode which  has a very open structure and therefore a lower resistance to fluid flow.
This also  provides  a larger electrode surface.  ESE  systems are often used  for the
recovery of copper, lead, mercury, silver, and gold.
6.1.11.2
Treatment Performance
       Respondents to the WTI  Questionnaire report that there  are three electrolytic
 recovery units in operation in the CWT Industry. No performance data were obtained for
 these units.
 6.1.12
Ion Exchange
 6.1.12.1     Technology Description

       Ion exchange is commonly used for the removal of heavy metals from relatively
 low-concentration waste streams, such as electroplating wastewater.  A key advantage
 of the ion exchange process is that it allows for the recovery and reuse of the metal
                                      6-37

-------
             M+++2e-
    Deposited
      Metal
                         Porous Insulating Separator
                                                                  2(
-------
contaminants.  Ion exchange can also be designed to be selective to certain metals, and
can provide effective removal from wastewater having high background contaminant
levels. A disadvantage is that the resins can be fouled by some organic substances.
      In an ion exchange system, the wastewater stream is passed through a bed of
resin.  The resin contains bound groups of ionic charge on its  surface, which are
exchanged for ions of the same charge in the wastewater.  Resins are classified by type,
either cationic  or anionic; the selection is dependent upon the wastewater contaminant
to  be  removed.    A  commonly-used  resin  is polystyrene  copolymerized  with
divinylbenzene.
      The ion  exchange process involves four steps: treatment, backwash, regeneration,
and rinse.  During the treatment step, wastewater is passed through the resin bed. The
ion exchange process continues until pollutant breakthrough occurs. The resin is then
backwashed to  reclassify the  bed  and  to  remove  suspended solids.   During the
regeneration  step, the  resin  is contacted with either an  acidic  or alkaline  solution
containing  the ion originally present in the resin.  This  "reverses" the ion exchange
process and removes the metal ions from the resin. The bed is then rinsed to remove
residual regenerating solution. The resulting contaminated regenerating solution must be
further processed for reuse or disposal.  Depending upon system size and economics,
some facilities choose to remove the spent resin and replace it with resin regenerated off-
site instead of regenerating the  resin in-place.
       Ion  exchange equipment ranges from  simple, inexpensive systems  such  as
domestic  water softeners, to  large, continuous  industrial applications.  The  most
commonly-encountered industrial setup is a fixed-bed resin in a vertical column, where
the resin is regenerated in-place. A diagram of this type of system is presented  in Figure
6-12.  These  systems can be  designed so  that the  regenerant flow is concurrent or
countercurrent to the treatment flow. A countercurrent design, although more complex
to operate, provides a  higher treatment efficiency.  The beds can contain a single type
of resin for selective treatment,  or the beds can be mixed to provide for more complete
deionization of the waste stream. Often, individual beds  containing different resins are
arranged  in series, which makes regeneration easier than in the mixed bed system.
                                      6-39

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    Wastewater
    Influent
        Used
        Regenerant
                                 Regenierant
                                 Solution
                                                  Distributor
                                                   Support
                                Treated
                                Effluent
Figure 6-12.
Ion Exchange System Diagram
                                6-40

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6.1.12.2     Treatment Performance
                                   r-        "ij-
      Ion exchange is very effective in the treatment of low-concentration metal-bearing
wastewater.  A common application,  chromic acid recovery,  has a  demonstrated
performance of 99.5 percent.  Sampling data from the Metal Finishing Industry Study
showed a removal of copper from rinsewater of over 99  percent, and nickel removals
from 82 to 96 percent.
      According to the WTI Questionnaire  data base,  one facility (CWT QID 255)
reported using the ion exchange process. No performance data were obtained for this
application.

6.1.13      Gravity Separation

6.1.13.1     Technology Description

      Gravity  separation  is a simple, economical,  and widely-used method for the
treatment of certain oily wastewater. It is effective in the removal of free and dispersed
oils and grease from oil/water mixtures.  It is not applicable to the removal of emulsified
or soluble oils.  Many facilities use gravity separation as a pretreatment step to remove
free oils prior to emulsion breaking treatment.
      It is necessary to determine the  nature  of the oily waste stream to be treated
before a treatment technology can  be selected. The primary factors to be considered
include:  the concentration of oil in the waste stream and the size of the oil droplets; the
specific gravity of the  oil  compared to that of the  wastewater;  and the  presence  of
surfactants or chemical emulsifiers.  Free, or dispersed oils are present in the wastewater
as discrete droplets with little or no water attached to them. These droplets will easily rise
to the surface of the oil/water mixture due to their low specific gravity. Large droplets rise
more readily than do small droplets.
      Once the oil has risen to surface of the wastewater, it must be removed.  This is
done mechanically via skimmers, baffles, plates, slotted pipes, or dip tubes.  Because
                                      6-41

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gravity separation is such a widely-used technology, there is an abundance of equipment
configurations available.  A very common unit is the API (American Petroleum Institute)
separator, shown in Figure 6-13. This unit uses an overflow and an underflow baffle to
skim the floating oil layer from the surface.  The  resulting oilyTesidue from a gravity
separator must then be further processed or disposed.
6.1.13.2
Treatment Performance
      Gravity separation is a demonstrated and effective method for removing free oils
and grease from wastewater. Depending upon the nature of the waste stream and the
equipment application, gravity separation with mechanical removal can remove over 99
percent of the free  oil concentration.    There  are 18  gravity separation/skimming
applications and four plate/tube coalescers used in the CWT Industry. No performance
data were obtained for these systems.
6.1.14
Dissolved Air Flotation
6.1.14.1     Technology Description

      Flotation is the process of influencing suspended particles to rise to the surface of
a tank where they can be collected and removed. Gas bubbles are introduced into the
wastewater and attach themselves to the particles, thereby reducing their specific gravity
and causing them  to float.   Flotation processes are  utilized  because they effectively
reduce the sedimentation times of suspended solids that have a specific gravity slightly
greater than 1.0.
      Dissolved air flotation (DAF) is a one of several flotation techniques employed in
the treatment of wastewater. DAF is commonly used to extract free and dispersed oil and
grease from oily wastewater.  For wastes containing emulsified oils, DAF applied after
emulsion breaking can improve treatment performance and shorten retention time. A flow
diagram of a DAF system is presented in Figure 6-14.
                                     6-42

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Oil Retention
Baffle

        o
     Wastewater
     Influent
                            Diffusion Device     ฃ!•
                            (vertical baffle)      Skimmer
                            	so
                        I  I  i  I  I   I      ^-^
                                     ^v
                                Scraper
                  Sludge
                  Hopper
Oil
Retention
Baffle
                                                       Treated
                                                       Effluent
Figure 6-13.
         Gravity Separation System Diagram
                           6-43

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                   Float Removal Device
                                                           Treated
                                                           Effluent
   Float
   Wastewater
   Influent
   (Saturated
   with Air)
^ Sludge (If Produced)
Figure 6-14.       Dissolved Air Flotation System Diagram
                                  6-44

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      In DAF, air is injected into the wastewater stream while it is under pressure in a
pipeline. When the wastewater enters the flotation tank, the pressure is reduced and fine
air bubbles are released. These bubbles make contact with the suspended particles via
two separate mechanisms.  If a flocculant is used, the  rising air bubbles can be trapped
inside of the flocculated masses as they increase in size.  The other type of contact is
adhesion, which is a result of the intermolecular attraction between the solid particle and
the air bubble.
      The  performance of the DAF unit relies on having adequate air bubbles present
to float all of the suspended solids to the surface of the tank.  Partial flotation of solids
will occur if inadequate or excessive amounts of air bubbles are present. Therefore, the
air-to-solids ratio in  the  DAF  unit determines the  effluent  quality and the  solids
concentration in the float.
6.1.14.2
Treatment Performance
      DAF technology is a well-demonstrated and an effective method of treating certain
oily wastewater.  Respondents to the WTI Questionnaire report that there were five DAF
units in operation in the CWT Industry; no performance data were obtained for these
units.

6.2   BIOLOGICAL WASTEWATER TREATMENT TECHNOLOGIES

      A portion of the CWT Industry accepts waste receipts containing organic pollutants,
which are often  amenable to biological degradation.  This subset  of CWT facilities is
referred to as the Organics Subcategory.
      Biological treatment systems use microbes which consume, and thereby destroy,
organic compounds as a food source.  In addition to the carbon supplied by the organic
pollutants, these microbes also need energy and supplemental nutrients, such as nitrogen
and phosphorus, for growth.   Aerobic microbes require  oxygen  to  grow, whereas
                                      6-45

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anaerobic microbes are destroyed by oxygen.  An adaptive type of anaerobic microbe,
a facultative anaerobe, can grow with or without oxygen.
      The success of biological treatment is also dependent on other factors, such as
the pH  and temperature of the wastewater, the nature of the pollutants, the nutrient
requirements of the microbes, the presence of other inhibiting pollutants, and variations
in the feed stream loading. Certain compounds, such as heavy metals, are toxic to the
microorganisms and must be removed from the waste stream prior to biological treatment.
Load variations  are  a  major concern,  especially in the _CWT Industry, where waste
receipts vary overtime in both concentration and volume.
      There are several adaptations of biological treatment.  These adaptations differ in
three basic ways. First, a system can be aerobic, anaerobic, or facultative. Second, the
microorganisms  can either be attached to  a  surface  (as  in a trickling filter), or be
unattached in a liquid suspension (as in an activated sludge system). The third difference
is whether the system  operation is batch or continuous.  In this industry, commercial
facilities which receive  all of their wastes from off-site are restricted to consideration of
a batch process, which is not effected by waste load variations. Continuous biological
treatment systems, such as conventional activated sludge systems, are typically only
found at CWT facilities which receive their wastes from both on-site and off-site sources.
At many of these facilities, on-site manufacturing operations produce a relatively constant
waste stream that can  support a continuous biological treatment system. The effect of
the off-site waste receipt variability is dampened by the presence of the on-site waste
stream.
      According to the WTI Questionnaire data base, there are 12 activated  sludge
systems (one with PAC addition), four aerobic systems, two facultative systems, one
denitrification system, one sequencing batch reactor (SBR), two biotowers, one surface
impoundment, and one land application system in the  CWT Industry.  There were no
anaerobic processes reported.  The types of biological  treatment processes which are
found in the CWT Industry and are discussed in this subsection are SBRs, biotowers, and
activated sludge systems.
                                      6-46

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6.2.1
Sequencing Batch Reactors
6.2.1.1
Technology Description
      A  sequencing batch reactor (SBR) is a suspended  growth  system  in which
wastewater is mixed with existing biological floe in an aeration basin.  SBRs are unique
in that a  single tank acts as an equalization tank, an aeration tank, and a clarifier.  An
SBR is operated on a batch basis where the wastewater is mixed and aerated with the
biological floe for a specific period of time. The contents of the basin are allowed to settle
and the supernatant is  decanted.  The batch operation  of an SBR makes it a feasible
biological treatment option for the  CWT Industry, where the  wastewater volumes and
characteristics are often highly variable.  An SBR is shown in Figure 6-15.
      The SBR has a four cycle process: fill, react, settle, and decant.  The fill cycle has
three phases.  The first phase, called static fill, introduces the wastewater to the system
under static conditions.  This  is the anaerobic period for biological phosphorus uptake.
The second phase of the fill cycle is where the wastewater is mixed to eliminate the scum
layer and prepare the microorganisms to receive oxygen. In the third phase, aeration is
added if aerobic conditions are desired. The react cycle is a time-dependent process that
continually mixes and aerates the wastewater while allowing the biological degradation
process to complete. The settling cycle utilizes a large surface area and a lower settling
rate to allow settling under quiescent conditions.  During the decant cycle, approximately
one-third of the tank volume is decanted by subsurface withdrawal. This treated, clarified
effluent can then be further treated or discharged.
      Excess biomass is periodically removed from the SBR when the quantity exceeds
that  needed for operation.  The sludge that is removed from the SBR can  be reduced in
volume by thickening using a filter press.  The sludge can be disposed in a landfill or
used as  an agricultural fertilizer.
                                      6-47

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       Process
        Cycle
                                    Fill
                                                    React
                                                    Settle
                                                     Decant
Figure 6-15.
Sequencing Batch Reactor System Diagram
                                6-48

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6.2.1.2
Treatment Performance
      According to the WTI Questionnaire respondents, one SBR was in operation in the
CWT Industry. EPA sampled'this application at CWT QID 059; the sampling results are
given in Table 6-12.  This SBR reduced the average BOD5 concentration from 4,800 to
1,750 mg/l, for a 63.5 percent removal.  The average nitrate-nitrite (as N) concentration
was  reduced from 46.6 to 1.5 mg/l, for a 96.8 percent removal.  The pollutants phenol
and carbon disulfide were reduced by 82 and 90.3 percent, respectively.  The effluent
from this SBR was further treated in a carbon adsorption system.
Table 6-12.  Sequencing Batch Reactor System Performance Data
Parameter
BOD5
COD
D-COD
TOG
2-Propanone
Ammonia as N
Carbon Disulfide
Nitrate-Nitrite as N
Pentachlorophenol
Phenol
Influent Avg (|ig/l)
4,800,000
6,525,000
53,500,000
2,225,000
10,608
992,500
158
46,550
949
2,000
Effluent Avg
(Hfl/l)
1 ,750,000
3,525,000
28,500,000
1 ,047,500
2,558
1 ,050,000
15
1,475
814
359
Removal (%)
63.54
45.98
46.73
52.92
75.88
(5.79)
90.32
96.83
14.24
82.03
                                     6-49

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6.2.2
Biotowers
6.2.2.1
Technology Description
      A biological treatment tower, or biotower, is an adaptation of biological treatment
which can be operated in a continuous or semi-continuous manner. A waste stream is
inoculated with bacteria  and is  passed through a packed reactor where biological
degradation occurs. The  system  is operated in a one-pass,  flow-through configuration.
A diagram of a biotower is presented in Figure 6-16.
      The biotower is a tank which is packed approximately two-thirds full with plastic
honeycomb waffles.  These waffles  provide an increased reaction surface area.  An
inoculum is prepared which consists of a commercially-available freeze-dried bacteria
culture which has been rehydrated in water. A separate nutrient solution consisting of
ammonia and phosphorus is also prepared.  The inoculum, nutrient solution, and
wastewater stream are fed into the bottom of the biotower. They are mixed and passed
up through the packing by air blowers. The treated effluent exits from the top of the
biotower.
      After biological treatment, the effluent is sent to a separator where a flocculant is
added to aid in settling of the solids.  The settled solids can then be dewatered and
disposed.
6.2.2.2
Treatment Performance
      There are two biotowers in operation in the CWT Industry.  One system treats a
waste stream which is primarily composed of leachate from an on-site landfill operation.
No performance data was obtained for this application.  The other system at CWT QID
130 treats  high-TOC wastewater from a metals recovery  operation.  EPA conducted
sampling at this facility during the CWT project; the biotower performance data that were
collected shows poor performance of the unit.  No significant BOD5, COD, or TOG
removals were recorded during the sampling period.
                                     6-50

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   Inoculum
    Nutrient
    Solution
    Wastewater
    Influent
                                                  Treated
                                                  Effluent
                                                    Blower
Figure 6-16.
Biotower System Diagram
                                 6-51

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6.2.3
Activated Sludge
6.2.3.1
Technology Description
      The activated sludge process is a continuous-flow, aerobic biological process. The
microorganisms are in kept in suspension in the wastewater by mixing. This suspension
is called a mixed liquor.  The microorganisms oxidize soluble and suspended organics to
carbon dioxide and water using oxygen.  Types of activated sludge systems include
extended aeration, contact stabilization, high-rate modified  aeration, step aeration, and
oxygen-activated sludge.
      The principal design parameters for an activated sludge system  are the mixed
liquor suspended solids (MLSS) of the system  and the biological oxygen demand (BOD)
or chemical oxygen demand (COD) of the  influent stream.  The MLSS is a measure of
the quantity of microorganisms available for biodegradation, while the BOD or COD is a
measure of the organic loading to the  system.  Other key design parameters are the
detention time, the length of time that the  wastewater must remain in contact with the
microorganisms to achieve  the  desired  level of  treatment, and F/M, the food-to-
microorganism ratio.  F/M is the loading rate of BOD (or food) applied to the  MLSS  (or
microorganisms).
      A diagram of a conventional activated sludge system is shown in Figure 6-17. The
system consists of an aeration basin, which is both aerated and  mixed.  An activated
sludge system is typically followed by  a secondary clarifier to remove the suspended
solids. The resulting sludge from the secondary clarifier must then be dewatered and
disposed.
6.2.3.2
Treatment Performance
      Respondents to  the WTI Questionnaire  report that there are  12 conventional
activated sludge systems in  operation in the CWT Industry.  These  applications are
                                     6-52

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                                                Secondary
                                                Clarification
   Wastewater
   Influent
                         Aeration
                          Basin
                                                            Treated
                                                            Effluent
                      Recycled Sludge
                                                          Waste
                                                          Excess
                                                          Sludge
Figure 6-17.
Activated Sludge System Diagram
                                  6-53

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primarily found at facilities that treat on-site wastes in conjunction with off-site waste
receipts. No performance data were obtained for activated sludge systems.

6.3   ADVANCED WASTEWATER TREATMENT TECHNOLOGIES

      The technologies presented here can be used as independent operations or as
advanced wastewater treatment processes to remove the pollutants remaining after
preliminary treatment. These operations are not as commonly-found as those discussed
in the preceding subsections.
6.3.1
Ultrafiltration
6.3.1.1
Technology Description
      Ultrafiltration (UF) is used for the treatment of metal-finishing wastewater and oily
wastes. It can remove substances with molecular weights greater than 500, including
suspended solids, oil and grease, large organic molecules, and complexed heavy metals.
UF is used when the solute molecules are greater than ten times the size of the solvent
molecules, and are less than one-half micron.  In the CWT  Industry, UF is applied in the
treatment of oil/water emulsions. Oil/water emulsions contain both soluble and insoluble
oil. Typically the insoluble oil is removed from the emulsion by gravity separation assisted
by chemical addition. The soluble oil is then removed by UF. Oily wastewater containing
0.1 to 10 percent oil can be effectively treated by UF.  A UF system is typically used as
an in-plant treatment technology, treating the oil/water emulsion prior to mixing with other
wastewater. A UF system is shown in Figure 6-18.
      In UF, a semi-permeable  microporous membrane  performs  the  separation.
Wastewater is sent through membrane modules under  pressure.  Water and low-
molecular-weight solutes (for example, salts and some surfactants) pass through the
membrane and are removed as permeate.  Emulsified oil and suspended solids are
rejected by the  membrane and  are  removed as concentrate.   The concentrate is
                                     6-54

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                       Permeate (Treated Effluent)
  Wastewater
  Feed
Concentrate
                          Membrane Cross-section
Figure 6-18.      Ultrafiltration System Diagram


                                  6-55

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recirculated through the membrane unit until the flow of permeate drops. The permeate
can either be discharged or passed along to another treatment unit. The concentrate is
contained and held for further treatment or disposal.
      The primary design consideration in UF is the membrane selection. A membrane
pore size is chosen based on the size of the contaminant particles targeted for removal.
Other design parameters to be considered are the solids concentration, viscosity, and
temperature of the feed stream, and the membrane permeability and thickness.
6.3.1.2
Treatment Performance
       According to the WTI Questionnaire data base, there are three UF applications
in the CWT Industry.  A UF system which treats oily wastewater at CWT QID 409 was
sampled by EPA; these results are presented in Table 6-13. This system removed 87.5
percent of the influent oil and grease and 99.9 percent of the TSS.  Several organic and
metal pollutants were over 90 percent removed.
Table 6-13.  Ultrafiltration System Performance Data
Parameter
Barium
2-Butanone
COD
Copper
Ethylbenzene
Lead
m-Xylene
n-Decane
Oil & Grease
TSS
Influent Avg (|ig/l)
2,790
39,276
54,976,900
14,101
12,220
9,930
19,585
55,561
19',926,350
6,388,400
Effluent Avg (|ig/l)
18
1,426
9,601 ,850
48
734
738
1,019
60
2,489,185
6,300
Removal (%)
99.36
96.37
82.53
99.66
94.00
92.57
94.80
99.89
87.51
99.90
                                     6-56

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6.3.2
Reverse Osmosis
6.3.2.1
Technology Description
      Reverse osmosis (RO) is a process for separating dissolved solids from=water.  It
is commonly used to treat oily or metal-bearing wastewater.  RO is applicable when the
solute molecules are approximately the same size as the solvent molecules.  A semi-
permeable, microporous membrane and pressure are used to perform the separation.
RO systems are typically used as end-of-pipe polishing processes, prior to final discharge
of the treated wastewater.
      Osmosis is the diffusion of a solvent (such as water) across a semi-permeable
membrane from a less concentrated solution into a more concentrated solution.  In the
reverse osmosis process, pressure greater than the normal osmotic pressure is applied
to the more concentrated solution (the waste stream being treated), forcing the purified
water through the membrane and into the less concentrated stream which is called the
permeate. The low-molecular-weight solutes (for example, salts and some surfactants)
do  not pass through the membrane.  They are  referred to as concentrate.  The
concentrate is recirculated through the membrane unit until the flow of permeate drops.
The permeate can either be discharged or passed along to another treatment unit. The
concentrate is contained and held for further treatment or disposal.  An RO system is
shown in Figure 6-19.
      The performance of an  RO system is dependent upon the dissolved solids
concentration and temperature of the feed stream, the applied pressure, and the type of
membrane selected.  The key RO membrane properties to be considered are: selectivity
for water over ions, permeation rate, and durability. RO modules are available in various
membrane configurations, such  as spiral-wound, tubular, hollow-fiber,  and plate and
frame.  In addition to the membrane modules, other capital items  needed for an RO
installation include  pumps,  piping, instrumentation, and storage tanks.   The major
operating cost is attributed to membrane replacement.
                                      6-57

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                        Permeate (Treated Effluent)
    Wastewater
    Feed
Concentrate
                           Membrane Cross-section
Figure 6-19.      Reverse Osmosis System Diagram
                                 6-58

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6.3.2.2
Treatment Performance
      Respondents to the WTI Questionnaire reported that there were three RO systems
in operation in the CWT Industry.  A spiral-wound RO system treating an oily waste
stream at CWT QID  409 was sampled by EPA.  The  performance data obtained are
presented in Table 6-14. As the data show, this unit reduced the average oil and grease
concentration  by  87.4 percent.   Many  of the metal pollutants were  also effectively
removed, most notably aluminum, barium, calcium, chromium, cobalt, iron, magnesium,
manganese, nickel, and titanium, all of which were over 98 percent reduced.

Table 6-14.  Reverse Osmosis System Performance Data
Parameter
Oil & Grease
Aluminum
Chromium
Cobalt
Iron
Lead
Magnesium
Manganese
Nickel
Zinc
Influent LTA (jig/l)
386,928
3,785
254
441
15,494
986
25,162
1,164
43,862
5,396
Effluent LTA (ng/l)
48,898
32
. 4(ND)
4
147
28
292
16
820
201
Removal (%)
87.36
99.15
98.43
99.09
99.05
97.16
98.84
98.63
98.13
96.28
      LTA =  Long-term average
      ND  =  Not detected
                                     6-59

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6.3.3
Lancy Filtration
6.3.3.1
Technology Description
      The Lancy Sorption Filter System is a patented method for the continuous recovery
of heavy metals. Metals not removed by conventional waste treatment technologies can
be reduced to low concentrations by the  Lancy sorption filtration process.
      In the first stage of the Lancy filtration process, a soluble sulfide is added to the
wastewater in a reaction tank, converting  most of the heavy metals to sulfides.  From the
sulfide reaction tank, the solution is passed through the sorption filter media. Precipitated
metal sulfides and other suspended solids are filtered out. Any remaining soluble metals
are absorbed by the media. Excess  soluble sulfides are also removed from the waste
stream.
      The Lancy filtration process can reportedly reduce zinc, silver, copper, lead, and
cadmium to less than 0.05 mg/l and mercury to less than 2 (ig/l.   In addition to the
effective removal of heavy metals, the system  has a high solids filtration capacity and a
fully automatic, continuous operation.  The system continuously recycles and reuses the
same filter media thereby saving on operating costs. The system can be installed with
a choice of media discharge - slurry or solid cake. The Lancy  Sorption Filtration System
is  shown in Figure 6-20.
6.3.3.2
Treatment Performance
      A Lancy sorption filtration application at CWT QID 255 was sampled by EPA. This
unit is a polishing treatment for the effluent from a chemical precipitation, clarification, and
sand filtration treatment sequence.  The data from this system are presented in Table 6-
15. These data show, that of the target metals, mercury was reduced to a concentration
of 2 jig/l.  None of the other target metals, however, were reduced to concentrations as
low as 0.05 mg/l.  In fact, many of the pollutant concentrations actually increased. This
                                      6-60

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Wastewater
  Influent
               Recycle
       Recycle
        Tank
                                                             Treated ^^
                                                             Effluenr
                                             Sorption
                                               Filter
                                     2
                                                   Media Dischar
Figure 6-20.
              Lancy Filtration System Diagram
                                 6-61

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poor performance may not be representative  of the normal operation of this Lancy
application, as the unit was being tested during the sampling episode.

Table 6-15.  Lancy Filtration System Performance Data
Parameter
TSS
Cadmium
Chromium
Copper
Hexavalent
Chromium
Lead
Manganese
Mercury
Silver
Zinc
Influent LTA (|ig/l)
638,900
120
461
1,382
73
631
1,396
15
142
4,047
Effluent LTA (|ig/l)
471 ,600
58
306
252
34
536
75
2
138
974
Removal (%)
26.19
51.67
33.62
81.77
53.42
15.05
94.63
86.67
2.82
75.93
6.3.4
      LTA =  Long-term average
Liquid Carbon Dioxide Extraction
6.3.4.1
Technology Description
      Liquid  carbon  dioxide (CO2) extraction is  used to extract and  recover organic
contaminants from aqueous waste streams.  A licensed, commercial application of this
technology is utilized in the CWT Industry under the name "Clean Extraction System
(CES)".  The process can be effective in the removal of organic substances such as
hydrocarbons, aldehydes and ketones, nitriles, halogenated compounds, phenols, esters,
and heterocyclics.  It  is not effective in the removal of some compounds which are very
                                     6-62

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water-soluble, such as ethylene glycol, and low molecular weight alcohols. It can provide
an alternative in the treatment of waste streams which historically have been incinerated.
      The waste stream is fed into the top of a pressurized extraction tower containing
perforated plates, where it is contacted-with a countercurrent stream of liquefied CO2.
The organic contaminants in the waste stream are dissolved in the CO2; this extract is
then sent to a separator, where the  CO2 is redistilled.  The distilled CO2  vapor is
compressed and reused. The concentrated organics bottoms from the separator can then
be disposed or recovered.  The treated  wastewater stream which exits the extractor
(raffinate) is pressure-reduced, and may be further treated for residual organics removal
if necessary to meet discharge standards. A diagram of the CES is presented in Figure
6-21.

6.3.4.2      Treatment Performance

      Pilot-scale operational data for a commercial CES unit are presented in Table 6-16.
This information was submitted to EPA by the CWT company which operates the system.
These data show high removals for a variety of organic compounds ranging up to 99.99
plus percent for methylene chloride.   The commercial CWT CES unit was sampled by
EPA during this rulemaking effort.  The percent removals achieved during the sampling
episode are also  presented in Table  6-16.   These removals are  not as high  as those
reported for the pilot-scale unit.

6.4   SLUDGE TREATMENT AND DISPOSAL

      There are  several waste treatment processes used in the CWT Industry which
generate a sludge.   These processes  include  chemical  precipitation of metals,
clarification, and biological treatment.  Some oily waste treatment processes, such as
emulsion breaking and dissolved air  flotation,  also produce sludges.  These sludges
typically contain  between one  and  five percent solids.  They require dewatering to
concentrate them and prepare them for transport and/or disposal.
                                      6-63

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          Extract
Vapor CO2
     Feed
                    Makeup
                    CO,
                    Extractor
             T
             Water
                      Liquid CO2
  T
                                              Separator
                                                            Compressor
 Organics
Figure 6-21.      Liquid CO2 Extraction System Diagram


                                   6-64

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6-65

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      Sludges are dewatered using pressure, which is caused by applied force, gravity,
vacuum, or centrifugal force.  There are several widely-used, commercially-available
methods for sludge dewatering. The methods which are found in the CWT Industry and
are discussed in this subsection are: plate and frame pressure filtration, belt pressure
filtration, and vacuum filtration.  A plate and frame filter press can produce the driest filter
cake of these three systems, followed by the belt press, and lastly, the vacuum filter.
      In some instances, depending upon the nature of the sludge and the dewatering
process used, the sludge may first be stabilized, conditioned, and/or thickened prior to
dewatering.  Certain sludges require stabilization (via chemical addition or biological
digestion) because they have  an  objectionable odor or are a health threat.  Sludges
produced by the CWT Industry usually do not fall into this category.  Sludge conditioning
is used to improve dewaterability;  it can be accomplished via the  addition of heat or
chemicals.   Sludge thickening,  or concentration, reduces the volume  of sludge to be
dewatered and is accomplished by gravity settling, flotation, or centrifugation.
6.4.1
Plate and Frame Pressure Filtration
6.4.1.1
Technology Description
      Plate and frame pressure filtration systems are used for the removal of solids from
waste streams. The sludge stream plate and frame pressure filtration system is identical
to the system used for the liquid stream (Subsection 6.1.3) with the exception of the
increase of higher solids level in the influent stream.  The same equipment is used for
both applications, with the difference being  in the sizing of the sludge and liquid units.
A plate and frame filter press is shown in Figure 6-22.
      A plate  and  frame filter press consists of  a number of filter plates or trays
connected to a frame and pressed together between  a fixed end and a moving end. Filter
cloth is  mounted on the face of each plate. The sludge is pumped into the  unit under
pressure while the plates are pressed together. The solids are retained in the cavities
of the filter press and begin to attach to the filter cloth until a cake is formed. The water,
                                      6-66

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     Fixed End
    Sludge
     Influent
  Filtrate •<—I
Filter Cloth
  Filter Cake
                                                 Applied
                                                 xForce
                                                      Plate Assembly
Figure 6-22.       Plate and Frame Pressure Filtration System Diagram
                                  6-67

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or filtrate passes through the filter cloth and is discharged from a drainage port in the
bottom of the press.  The sludge influent is pumped into the system until the cavities are
filled. Pressure is applied to the plates until the flow of filtrate stops.
      At the end of the cycle, the pressure is released  and the plates are separated.
The filter cake drops into a hopper below the press.  The filter cake can then be disposed
in a landfill.  The filter cloth is washed before the next cycle begins.
      The key advantage of plate and frame pressure filtration is that it can produce a
drier filter cake than  is possible with the  other methods of sludge dewatering. It is well-
suited for use in the CWT Industry as it is a batch process. However, its batch operation
results in greater operating labor requirements.
6.4.1.2
Treatment Performance
      Respondents to the WTI Questionnaire reported that 34 plate and frame filter
presses (treating liquid and sludge streams) are used in the CWT Industry. In a typical
plate and frame pressure filtration unit, the filter cake can exhibit a dry solids content
between 30 and 50 percent.
6.4.2
Belt Pressure Filtration
6.4.2.1
Technology Description
      A belt pressure filtration system uses gravity followed by mechanical compression
and shear force to produce a sludge filter cake.  Belt filter presses  are  continuous
systems which are commonly used to dewater biological treatment sludge. Most belt filter
installations are preceded by a flocculation step, where polymer is added to create a
sludge which has the strength to withstand being compressed between the belts without
being squeezed out. A typical belt filter press is illustrated in Figure 6-23.
      During the press operation, the sludge stream is fed onto the first of two moving
cloth filter belts. The sludge is gravity-thickened as the water drains through the belt.  As
                                       6-68

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  Sludge
  Influent
                 Drainage    Compression
                   Zone         Zone
                                            Wash Water
                                Shear
                                Zone
                                                               Filter
                                                               Cake
Figure 6-23.
Belt Pressure Filtration System Diagram
                                  6-69

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the belt holding the sludge advances, it approaches a second moving belt. As the first
and second belts move closer together, the sludge is compressed between them.  The
pressure is increased as the two belts travel together over and under a series of rollers.
The turning of the belts around the rollers shear the cake which furthers the dewatering
process. At the end of the roller pass, the belts move apart and the cake drops off.  The
feed belt is washed before the sludge feed point. The dropped filter cake can then be
disposed.
      The advantages of a belt filtration system are its lower labor requirements and
lower power consumption. On the minus side, belt filter presses produce a poorer quality
filtrate, and require a relatively large volume of belt wash water.
6.4.2.2
Treatment Performance
      Typical belt filtration applications can dewater an undigested activated sludge to
a cake containing 15 to 25 percent solids.  Heat-treated, digested sludges can be reduced
to a cake of up to 50 percent solids.  According to the WTI Questionnaire data base,
there are six belt filter presses in-place in the CWT Industry;  however, no performance
data were obtained for these systems.
6.4.3
Vacuum Filtration
6.4.3.1
Technology Description
      A commonly-used process for dewatering sludge is rotary vacuum filtration. These
filters come in drum, coil, and belt configurations. The filter medium can be made of
cloth, coil springs, or wire-mesh fabric. A typical application is a rotary vacuum belt filter;
a diagram of this equipment is shown in Figure 6-24.
      A continuous belt of filter fabric is wound around a horizontal rotating drum and
rollers.  The drum is perforated and is connected to a vacuum.  The drum is partially
immersed in a shallow tank containing the sludge.  As the drum rotates, the vacuum
                                      6-70

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   Vacuum
   Source
                                                         Filter Cake
                                                         Discharge
                                          /
                                                             Media

                                                    Spray Wash
Figure 6-24.
Vacuum Filtration System Diagram
                                 6-71

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which is applied to the inside of the drum draws the sludge onto the filter fabric.  The
water from the sludge passes through the filter and into the drum, where it exits via a
discharge port.  As the fabric leaves the drum and passes over the roller, the vacuum is
released.  The filter cake drops off of the belt as it turns around the roller.  The filter cake
can then be disposed.
      Because vacuum filtration  systems are relatively expensive to operate, they are
usually preceded by  a thickening step which  reduces the volume of sludge to be
dewatered.  It is a continuous process and therefore requires less operator attention.
6.4.3.2
Treatment Performance
      Vacuum filtration can reduce activated  sludge  to a  cake containing 12 to 20
percent solids.  Lime sludge can be  reduced to a cake of 25 to 40 percent solids.
According to  the  WTI  Questionnaire respondents, there  are 10  vacuum filtration
installations  in the CWT  Industry.   No  performance data were  obtained for these
installations.
6.4.4
Filter Cake Disposal
      After a sludge is dewatered, the resultant filter cake must be disposed. The most
common method of filter cake management used in the CWT Industry is transport to an
off-site landfill for disposal. Other disposal options are incineration or land application.
Land application is usually restricted to biological treatment residuals.
                                      6-72

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6.5   REFERENCES
Standard Methods for Examination of Water and Wastewater. 15th Edition, Washington
D. C.

Henricks, David, Inspectors Guide for Evaluation of Municipal  Wastewater Treatment
Plants. Culp/Wesner/Culp, El Dorado Hills, CA, 1979.

Technical  Practice  Committee, Operation of Wastewater Treatment Plants, MOP/11,
Washington, D. C., 1976.

Clark, Viesman, and Hasner, Water Supply and Pollution Control. Harper and Row
Publishers, N.Y., N.Y., 1977.

Environmental Engineering Division, Computer Assisted Procedure For the Design and
Evaluation  of Wastewater  Treatment Systems (CAPDET),  U.  S.  Army Engineer
Waterways Experiment Station, Vicksburg, Mississippi, 1981.

1991 Waste Treatment Industry Questionnaire. U. S. Environmental Protection Agency,
Washington, D. C.

Osmonics,  Historical Perspective  of Ultrafiltration and Reverse Osmosis  Membrane
Development. Minnetonka, Minn., 1984.

Organic Chemicals and Plastics and Synthetic Fibers (OCPSR Cost Document. SAIC,
1987.

Effluent Guidelines Division, Development Document for Effluent Limitations Guidelines
& Standards for the Metal Finishing . Point Source Category, Office of Water Regulation
& Standards, U.S.  EPA, Washington, DC, June 1983.

Effluent Guidelines Division, Development Document For Effluent Limitations Guidelines
and Standards for the Organic Chemicals  Plastics and Synthetic Fibers  (OCPSF),
Volume II, Point Source Category,  EPA 440/1-87/009, Washington, D.C., October 1987.

Engineering News  Record (ENR). McGraw-Hill Co., N.Y., N.Y., March 30, 1992.

Comparative Statistics of Industrial and Office Real Estate Markets, Society of Industrial
and Office Realtors of the National Association of Realtors, Washington, DC, 1990.

Effluent Guidelines Division, Development Document for Effluent Limitations Guidelines
& Standards for the Pesticides Industry., Point Source Category,  EPA 440/1-85/079,
Washington, D.G.,  October, 1985.
                                     6-73

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Peters, M., and Timmerhaus, K., Plant Design and Economics for Chemical Engineers,
McGraw-Hill, New York, N.Y., 1991.

Chemical Marketing Reporter. Schnell Publishing Company,  Inc., N.Y,., N.Y., May 10,
1993.

Palmer, S.K.,  Breton,  M.A.,  Nunno, T.J., Sullivan,. D.M., and  Supprenaut, N.F.,
Metal/Cyanide  Containing Wastes Treatment Technologies. Alliance Technical Corp.,
Bedford, MA, 1988.

Freeman, H.M., Standard Handbook of Hazardous Waste Treatment and Disposal, U.S.
EPA, McGraw-Hill, N.Y., N.Y., 1989.

Corbitt,  Robert,  Standard  Handbook of Environmental  Engineering.  McGraw-Hill
Publishing Co., N.Y., N.Y., 1990.

Perry, H.. Chemical Engineers Handbook. 5th Edition. McGraw-Hill, N.Y., N.Y., 1973.

Development Document for BAT. Pretreatment Technology and New Source Performance
Technology for the Pesticide Chemical Industry. USEPA,  4/92.

Vestergaard, Clean Harbors Technology Corporation to SAIC - letter dated 10/13/93.
                                    6-74

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SECTION 7
COST OF TREATMENT TECHNOLOGIES

      This section presents the costs estimated for compliance with the CWT effluent
limitations guidelines and standards. Subsection 7.1 provides a general description of
how the individual treatment technology and regulatory option costs were developed. In
Subsections 7.2 through  7.5, the development  of  capital  costs, operating  and
maintenance (O & M) costs, and land requirements for each of the specific wastewater
and sludge treatment technologies is described in  detail.
      Additional compliance costs to be incurred by facilities, which are not dependent
upon  a regulatory option  or treatment technology, are presented in  Subsection  7.6.
These additional items are retrofit costs, monitoring costs, RCRA permit modification
costs, and land costs.

7.1   COSTS DEVELOPMENT

7.1.1   Technology Costs

      Cost information for the technologies selected is available from  several sources.
The first source of information is the data  base developed from  the 1991 Waste
Treatment Industry (WTI)  Questionnaire responses. A  second source of information is
the Organic Chemical and Plastics and Synthetic Fibers (OCPSF)  industrial effluent
limitations guidelines and standards development document, which utilizes the 1983  U.S.
Army Corps of Engineers' Computer Assisted Procedure  for Design and Evaluation of
Wastewater Treatment Systems (CAPDET). A third source is engineering literature.  The
fourth source of information is the CWT sampling facilities.  The fifth source of information
is vendors' quotations. Vendors' recommendations were used extensively in the costing
of the various  technologies. The data from the WTI Questionnaire contained a limited
amount of process cost information, and was used wherever possible.
                                      7-1

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      The total costs developed include the capital costs of the investment, annual O & M
costs, land requirement costs, sludge disposal  costs, monitoring costs, RCRA permit
modification costs, and retrofit costs. All of the costs were either scaled up or scaled down
to 1989 dollars using the Engineering News Record (ENR) Construction Cost Index, as
1989 is the base year for the WTI Questionnaire.
      The capital costs for the technologies are primarily based on vendors' quotations.
The equipment costs typically include the cost of the treatment unit and some ancillary
equipment associated with that technology.  Investment costs added to the equipment cost
include piping, instrumentation  and controls,  pumps,  installation, engineering, and
contingency.   The standard  factors  used to estimate the capital costs are listed in
Table 7-1.

Table 7-1.  Standard Capital Cost Factors
Factor
Equipment Cost
Installation
Piping
Instrumentation and Controls
Total Construction Cost (TCC)
Engineering
Contingency
Total Indirect Cost
Total Capital Cost
Capital Cost
Technology-Specific Cost
25 to 55 percent of equipment cost
31 to 66 percent of equipment cost
6 to 30 percent of equipment cost
Equipment + Installation + Piping +
Instrumentation and Controls
1 5 percent of TCC
15 percent of TCC
Engineering + Contingency
Total Construction Cost + Total Indirect Cost
      The annual O & M costs for the various systems were derived from the vendors'
information or from engineering literature.   The annual O & M cost is comprised of
energy, maintenance, taxes and insurance, labor, treatment chemicals (if needed), and
                                      7-2

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residuals management (also  if needed).  The standard factors used to estimate the
O & M costs are listed in Table 7-2.  All of the parameters used  in costing the CWT
Industry are explained further in this section.

Table 7-2.    Standard O & M Cost Factors
Factor
Maintenance
Taxes and Insurance
Labor
Electricity
Residuals Management
Granular Activated Carbon
Lime (Calcium Hydroxide)
Polymer
Sodium Hydroxide (100 percent
solution)
Sodium Hydroxide (50 percent
solution)
Sodium Hypochlorite
Sulfur Dioxide
Sulfuric Acid
Total O & M Cost
O & M Cost (1989 $)
4 percent of Total Capital Cost
2 percent of Total Capital Cost
$30,300 to $31 ,200 per man-year
$0.08 per kilowatt-hour
Technology-Specific Cost
$0.70 per pound
$57 per ton
$3.38 per pound
$560 per ton
$275 per ton
$0.64 per pound
$230 per ton
$80 per ton
Maintenance + Taxes and Insurance + Labor +
Electricity + Chemicals + Residuals
                                       7-3

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7.1.2 Option Costs

      Engineering costs were developed for each of the individual treatment technologies
which comprise the CWT regulatory options. These technology-specific costs, broken
down into capital, O & M, and land components, are explained further in this section.
      To estimate the cost of an entire regulatory option, it is necessary to sum the costs
of the individual treatment technologies which make  up that option.  In some instances,
an option consists of only one treatment technology;  for those cases, the option cost is
equal to the technology cost.
      The  CWT subcategory regulatory options are  described in Table 7-3.   The
treatment technologies included  in each option are listed, and the subsections which
contain the corresponding cost information are indicated.

7.2   PHYSICAL/CHEMICAL/THERMAL WASTEWATER TREATMENT TECHNOLOGY
      COSTS

7.2.1  Chemical Precipitation

      Chemical precipitation systems  are  used to  remove dissolved metals  from
wastewater.  Lime and  caustic  were selected  as  the precipitants because  of their
effectiveness in removing dissolved metals. The chemical precipitation capital and O & M
costs were  calculated for a flow rate range of 0.000001 to 5.0 MGD.
7.2.1.1
Chemical Precipitation - Metals Option 1
      The CWT Metals Option 1 chemical precipitation system equipment consists of a
mixed reaction tank with pumps, a treatment chemical feed system, and an unmixed
wastewater holding tank. The system is operated on a batch basis, treating one batch
per day, five days per week.  The average chemical precipitation batch duration reported
by respondents to the WTI Questionnaire was four hours. Therefore, a one batch per day
                                     7-4

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Table 7-3.   CWT Subcategory Options
Subcategory/Option
Metals 1
Metals 2
Metals 3
Metals - Hexavalent Chromium
Waste Pretreatment
Metals - Cyanide Waste
Pretreatment
Oils 2
Oils 3
Oils 4
Organics 1
Organics 2
Treatment Technology
Chemical Precipitation
Liquid Filtration or
Clarification/Sludge Filtration
Selective Metals Precipitation
Liquid Filtration
Secondary Precipitation
Liquid Filtration or
Clarification/Sludge Filtration
Metals Option 2 Technologies
Tertiary Precipitation
Clarification
pH Adjustment
Chromium Reduction using Sulfur
Dioxide
Cyanide Destruction at Special
Operating Conditions
Ultrafiltration
Oils Option 2 Technology
Carbon Adsorption
Reverse Osmosis
Oils Option 3 Technologies
Carbon Adsorption
Equalization
Air Stripping
Sequencing Batch Reactor
Multi-Media Filtration
Organics Option 1 Technologies
Carbon Adsorption
Subsection
7.2.1.1
7.2.3.1 or
7.2.2/7.5.1
7.2.1.2
7.2.3.2
7.2.1.3
7.2.3.2 or
7.2.2/7.5.1
(above)
7.2.1.4
7.2.2
7.2.1.4
7.2.9
7.2.8
7.4.1
(above)
7.2.7
7.4.2
(above)
7.2.7
7.2.4
7.2.5
7.3.1
7.2.6
(above)
7.2.7
                                    7-5

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treatment schedule would provide sufficient time for the average facility to pump, treat,
and test its waste. A holding tank, equal to the daily waste volume, up to a maximum
size of 5,000 gallons (equivalent to one tank truck receipt), was prpvided to allow facilities
flexibility in managing waste receipts.
      Total capital cost estimates were developed  for the Metals Option  1  chemical
precipitation systems.  For facilities with no chemical precipitation system in-place, the
components of the chemical precipitation system included the precipitation  tank with a
mixer, pumps, and a feed system.  In addition, the holding tank equal to the size of the
precipitation tank, up to 5,000 gallons, was also included.  These cost estimates were
obtained from manufacturers' recommendations.
      For facilities that already have a  precipitation tank (treatment in-place), a capital
cost upgrade was determined; this consists of the cost of a holding tank only.
      The resulting chemical precipitation capital cost and capital upgrade cost equations
for Metals Option 1 are presented as Equations 7-1 and 7-2, respectively.
      ln(Y1) = 14.019 + 0.481 ln(X) - 0.00307(ln(X))2                         (7-1)

      In(Y1) = 10.671 - 0.083ln(X) - 0.032(ln(X))2                            (7-2)

      X = Flow Rate  (MGD) and
      Y1  =  Capital Cost (1989$).
where:
      The O & M cost estimates for facilities with no treatment in-place were based on
estimated energy usage, maintenance, labor, taxes and insurance, and chemical usage
cost.  The energy costs included electricity, lighting, and controls. The labor cost was
approximated at two hours per batch.
      Chemical cost estimates were calculated based on stoichiometric, pH adjustment,
and buffer adjustment requirements. For facilities with no chemical precipitation in-place,
the stoichiometric requirements were  based on the amount of chemicals required to
precipitate each of  the  metals  from  the Metals Subcategory average raw  influent
                                       7-6

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concentrations to Metals Option 1 levels.  The chemicals used were lime at 75 percent
of the required removals and caustic at 25 percent of the required removals.  The pH
adjustment and buffer adjustment requirements were estimated to be 50 percent of the
stoichiometric requirement. Finally, a 10 percent excess of chemical dosage was added.
      The O & M cost equation for Metals Option 1 chemical precipitation is:
where:
ln(Y2)= 15.206 + 1.091ln(X) + 0.05(ln(X))2                            (7-3)

X = Flow Rate (MGD) and
Y2 = O &M Cost (1989$).
      An O & M upgrade cost was estimated for facilities with the chemical precipitation
treatment in-piace.  It was assumed that these facilities already meet current Metals
Subcategory performance levels. The ratio of current-to-Metals Option 1 versus raw-to-
current  levels is approximately 0.03, therefore, the energy,  maintenance, and labor
components of the O & M upgrade  cost were calculated at three percent of the total
O & M cost for these components. Taxes and insurance were based on the total capital
cost for the holding tank.
      Chemical upgrade costs were calculated based on  current-to-Metals Option 1
removals with no additional chemicals used for pH .adjustment and solution buffering, as
these steps would be part of the in-place treatment system.  A 10 percent excess of
chemical dosage was added to the stoichiometric requirements.
      The O & M upgrade cost equation for Metals Option  1 chemical precipitation is:
       ln(Y2)= 11.702 + 1.006ln(X) + 0.044(ln(X))2
                                                                   (7-4)
 where:
        X = Flow Rate (MGD) and
       Y2 = O&M Cost (1989$).
                                       7-7

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      Land requirements for the chemical precipitation systems were estimated for
facilities with no chemical precipitation in-place and for facilities requiring only an upgrade.
The land  requirements were obtained  by adding a perimeter of 20 feet around the
equipment dimensions.   These  data were plotted and the land area equation  was
determined. The land requirement and  land requirement upgrade equations for metals
Option 1 chemical precipitation are presented as Equations 7-5 and 7-6, respectively.
      ln(Y3) = -1.019 + 0.299In(X) + 0.015(ln(X))2
      ln(Y3)= -2.866 - 0.023ln(X) - 0.006(ln(X))2
                                                             (7-5)

                                                             (7-6)
where:
      X = Flow Rate (MGD) and
      Y3 = Land  Requirement (Acres).
7.2.1.2
Selective Metals Precipitation - Metals Option 2
      The CWT Metals Option 2 selective metals precipitation system equipment consists
of four mixed reaction tanks, each sized for 25 percent of the total daily flow, with pumps
and treatment chemical feed systems.  Four tanks are included to allow the facility to
segregate its  wastes  into smaller batches,  thereby facilitating metals recovery  and
avoiding interference with other incoming waste receipts. A four batch per day treatment
schedule was used, where the sum of four batch  volumes equal the facility's daily
incoming waste volume.
      Capital cost estimates forthe selective metals precipitation systems were estimated
using the same methodology as outlined for the  Metals Option 1 chemical precipitation
systems.  However, four precipitation tanks were costed, each tank sized to receive 25
percent of the overall flow.
      The capital cost equation for Metals Option 2 selective metals precipitation is:
      In(Y1) = 14.461 + 0.544ln(X) + 0.0000047(ln(X))2
                                      7-8
                                                             (7-7)

-------
where:
      X = Flow Rate (MGD) and
      Y1 = Capital-Cost (1989 $).

      The O & M cost estimates for the selective metals precipitation system for facilities
with no chemical precipitation treatment in-place were estimated using the same
methodology as outlined for Metals  Option 1.  However, since the proposed design
included four tanks instead of one, the labor cost was estimated at four times the labor cost
of the single chemical  precipitation unit.  Maintenance and  taxes and insurance were
based on the total capital cost. Energy requirements were estimated the same as for the
Metals Option 1 chemical precipitation systems since energy is related to the flow of the
system.
      Treatment chemical  costs were estimated based on the same principles as for
Metals Option 1 chemical precipitation. The stoichiometric requirements were calculated
based on the Metals Subcategory average raw influent concentrations to Metals Option 1
removal levels.  The chemicals used were caustic at 40 percent of the required removals
and lime at 60 percent of the required removals.
       For facilities with chemical precipitation in-place,  an O & M upgrade cost was
estimated using the same methodology as for Metals Option 1 with the exception of the
chemical costs. Chemical costs were estimated using a different methodology since these
facilities already meet Metals Option 1  levels. The in-place treatment system is assumed
to use a dosage ratio of 25 percent caustic and 75 percent lime to achieve the raw influent
to current performance removals.  The selective  metals precipitation upgrade requires
these facilities to change their existing dosage mix to 40 percent caustic and 60 percent
lime to reach current performance levels,  then apply the full 40 percent/60 percent dosage
to further achieve the current performance to Metals Option 1 removals.   The increase
in caustic cost (to  increase from  25 percent to 40 percent) minus the lime credit  (to
decrease  from  75 percent  to 60 percent)  were  accounted for in  the  in-place
treatment removals  from raw to current levels.   Metals Option 2 uses a higher percentage
                                       7-9

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of caustic  than does  Metals  Option 1 because the sludge  resulting from  caustic
precipitation facilitates metals recovery.
      The  O & M cost and O & M upgrade cost equations for Metals Option 2 selective
metals precipitation are presented as Equations 7-8 and 7-9, respectively.

      ln(Y2) = 15.566 + 0.999ln(X) + 0.049(ln(X))2                          (7-8)

      ln(Y2) = 14.276 + 0.789ln(X) + 0.041 (ln(X))2                          (7-9)
where:
      X =  Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).

      The  land requirements for selective metals precipitation were calculated based on
the equipment dimensions. The system dimensions were scaled up to represent the total
land required for the system plus peripherals (pumps, controls, access areas, etc.). The
rule-of-thumb used to scale the dimensions adds a 20-foot perimeter around the unit.
The land requirement equation for Metals Option 2 selective metals precipitation is:
where:
In(Y3) = -0.575 + 0.420In(X) + 0.025(ln(X))2
•
X = Flow Rate (MGD) and
Y3 = Land Requirement (Acres).
                                                                         (7-10)
7.2.1.3
       Secondary Precipitation - Metals Option 2
      The CWT Metals Option 2 secondary precipitation system follows the selective
metals precipitation/filtration step. This equipment consists of a mixed reaction tank with
pumps and a treatment chemical feed system, sized for the full daily batch volume.
      The capital cost estimates for the secondary precipitation treatment systems were
estimated using the same methodology as outlined for Metals Option 1.  However, in this
                                      7-10

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case, no costs were included for a holding tank.  These cost estimates are for those
facilities that have no chemical precipitation, in-plaee.. For the facilities that already have
chemical precipitation in-place, the capital cost for the secondary precipitation treatment
systems were assumed to be zero. These in-place chemical precipitation systems would
serve as_ secondary precipitation systems after the  installation of upstream  selective
metals precipitation units.
      The capital cost  equation for Metals Option 2 secondary precipitation is:
where:
In (Y1) = 13.829 + 0.544ln(X) + 0.00000496(ln(X))2                    (7-11)

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).
      O & M cost estimates were developed for the secondary precipitation treatment
systems for facilities with and without chemical precipitation in-place.  For facilities with
no treatment  in-place, the annual O & M  costs  were  developed  using  the same
methodology used for Metals Option  1.  However, the chemical cost estimates were
based on stoichiometric requirements only. Lime was used to precipitate the metals from
Metals Option 1 to Metals Option 2 levels with a  10 percent excess dosage factor.
      For facilities with chemical precipitation in-place, an O & M upgrade cost was
calculated.  The O & M upgrade cost assumed that all of the components of the annual
O & M  cost except chemical costs were zero.   The  chemical costs  are the same as
calculated for the full O & M costs.
      The O & M cost and O & M upgrade cost equations for Metals Option 2 secondary
precipitation are presented as Equations 7-12 and 7-13, respectively.
       In (Y2) = 11.684 + 0.477ln(X) + 0.024(ln(X))2
       In (Y2) = 10.122 + 1.015ln(X) + 0.00151 (ln(X))2
                                                                    (7-12)
                                                                    (7-13)
                                       7-11

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where:
      X = Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).

      Land  requirements for the secondary  precipitation  treatment  systems were
estimated by adding a perimeter of 20 feet around the equipment dimensions.  The land
requirement equation for Metals Option 2 secondary precipitation is:
      In (Y3) = -1.15 + 0.449ln(X) + 0.027(ln(X))2
                                                            (7-14)
where:
      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).
7.2.1.4
Tertiary Precipitation - Metals Option 3
      The CWT Metals Option 3 tertiary precipitation system equipment consists of a
rapid mix tank and a pH adjustment tank (following Metals Option 3 clarification).  The
wastewater is fed to the rapid mix neutralization tank where lime slurry is added to raise
the pH.  Effluent from the neutralization tank then flows to the clarifier for solids removal.
The clarifier overflow goes to a pH adjustment tank where sulfuric acid is added to
achieve the desired final pH. The following discussion explains the development of the
cost estimates (i.e.  capital, O & M,  and land) for the rapid mix tank and  the pH
adjustment tank. Cost estimates for the clarifier are discussed in Subsection 7.2.2 of this
report.
      The capital cost  estimates for the rapid  mix tank were developed assuming one
tank with a continuous flow and a 15-minute detention time. The equipment cost includes
one tank, one agitator, and one lime feed system.
      The capital cost estimates for the pH adjustment tank were developed assuming
continuous flow and a five-minute detention time. The equipment cost includes one tank,
one agitator, and one sulfuric acid feed system.
                                     7-12

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      The other components (i.e. piping, instrumentation and controls, etc.) of the total
capital cost for  both the rapid mix and pH adjustment tank were estimated using the
Metals Option 1 methodology.   The capital cost equations for the rapid  mix and pH
adjustment tanks are presented as Equations 7-15 and 7-16, respectively.

      ln(Y1)  = 12.318 + 0.543ln(X) - 0.000179(ln(X))2                       (7-15)
where:
ln(Y1) = 11.721 + 0.543ln(X) + 0.000139(ln(X))2                       (7-16)

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).
      The  O & M cost  estimates for the rapid  mix and pH adjustment tank were
estimated using  the Metals Option 1  methodology.   The  labor requirements were
estimated at one man-hour per day.
      Chemical costs for the rapid mix tank were estimated  based on lime addition to
achieve the stoichiometric requirements for Metals Option 2 to Metals Option 3 removals
with a 10 percent excess.  The chemical requirements for the pH adjustment tank were
estimated based on the addition of sulfuric acid to lower the pH from  11.0 to 9.0.  The
O & M cost equations for the rapid mix tank and pH adjustment tank are presented as
Equations 7-17 and 7-18, respectively.
      ln(Y2) = 10.011 + 0.385ln(X) + 0.022(ln(X))2
 where:
ln(Y2) = 9.695 + 0.328ln(X) + 0.019(ln(X))2

X = Flow Rate (MGD) and
Y2 = O &M Cost (1989$).
                                                                  (7-17)
                                                                         (7-18)
                                      7-13

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      The land requirement equations for the rapid mix and pH adjustment tank are
presented as Equations 7-19 and 7-20, respectively.
      ln(Y3) = -2.330 + 0.352ln(X) + 0.019(ln(X))2

      ln(Y3) = -2.67 + 0.30ln(X) + 0.033(ln(X))2
where:
      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).

7.2.2 Clarification
(7-19)

(7-20)
      Clarification systems  provide continuous, low-cost separation and  removal of
suspended solids from water.  Clarification is used to remove particulates, flocculated
impurities, and precipitates. These clarification systems are equipped with a flocculation
unit and are costed with the  addition of the flocculation step.
      The costs for clarification systems were obtained from vendors. The influent total
suspended solids (TSS)  design  concentration  used was 40,000 mg/l or four percent
solids. The effluent sludge TSS concentration was 200,000 mg/i or 20 percent solids.
The effluent overflow TSS concentration was 500 mg/l at a flow rate of 80 percent of the
influent flow. These parameters were taken from CWT QID 105. The clarification system
was evaluated for a flow rate range of 0.000001 to 1.0  MGD.
      The clarification system includes a clarification unit, flocculation unit, pumps, motor,
foundation, and necessary accessories. The total construction cost includes the system
costs, installation, installed piping, and instrumentation and controls.
      The O & M costs for all  Metals  Options were determined by energy  usage,
maintenance, labor, flocculant cost, and taxes and insurance.  Energy was divided into
cost for electricity, lighting, and controls.  The labor requirements for Metals Options 1
and 2 were estimated  between three  hours  per day (for the smaller systems)  to four
hours per day (for the larger systems), while  the labor requirement for Metals Option 3
                                      7-14

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was one hour per day.  The polymer dosage used in the flocculation step was 2.0 mg
polymer per liter of wastewater. This dosage was taken from the MP&M cost model.
      The clarification capital cost equation for all the Metals Options is presented as
Equation 7-21. The clarification O & M cost equations for Metals Options 1 and 2 and
Metals Option 3 are presented as Equations 7-22 and 7-23, respectively.
where:
where:
ln(Y1) = 11.552 + 0.409Iri(X) + 0.020(ln(X))2

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).

In(Y2) = 10.429 + 0.174ln(X) + 0.0091 (In(X))2

Y2 = O&M Cost (1989$).
                                                                         (7-21)
                                                                         (7-22)
      ln(Y2) = 10.294 + 0.362ln(X) + 0.019(ln(X))2                           (7-23)
where:
      Y2 = O&M Cost (1989$).
      A clarification system upgrade was calculated to estimate the increase in 0 & M
costs for facilities that already have a clarification system in-place.  These facilities would
need to improve pollutant removals from their current performance levels to Metals
Option 1 levels. To determine the required increase from current performance to Metals
Option 1 levels, a comparison of the sum of the Metals Subcategory current performance
pollutant concentrations to Metals Option 1 levels versus the Metals Subcategory raw
influent pollutant concentrations to  current performance levels was calculated.  This
increase was determined to be three percent, as follows:
       O & M Upgrade  = Current - Metals Option 1  = 0.03 = 3%
       Increase          Raw - Current
                                                                   (7-24)
                                      7-15

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      Therefore, in order for these facilities to perform at Metals Option 1 levels, an
O & M cost upgrade of three percent of the total O & M costs would be realized for each
facility.  The O & M upgrade cost equation for Metals Option  1 clarification is:

      ln(Y2) = 7.166 + 0.238ln(X) + 0.013(In(X))2                            (7-25)
where:
      X = Flow Rate  (MGD) and
      Y2 = O&M Cost (1989$).

      To develop the clarification land requirements, the overall system dimensions were
scaled up to  represent the total land required for the system plus peripherals (pumps,
controls, access areas, etc.). The equation relating the flow of the clarification system to
the land requirement for all Metals Options is:
      ln(Y3) = -1.773 + 0.513ln(X) + 0.046(ln(X))2
                                                              (7-26)
where:
      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).
7.2.3 Plate and Frame Pressure Filtration - Liquid Stream

      Pressure filtration systems are used for the removal of solids from waste streams.
These systems typically follow chemical precipitation or clarification.
7.2.3.1
Plate and Frame Filtration - Metals Option 1
      The plate and frame pressure filtration system costs were estimated for a liquid
stream; this is the full effluent stream from a chemical precipitation process.  The liquid
stream consists of 96 percent liquid and four percent (40,000 mg/l) solids. These influent
                                      7-16

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parameters were taken from CWT QID 105.  The capital and O & M  costs  were
calculated for a range of 0.000001 to 1.0 MGD.
      The components of the plate and frame pressure filtration system include: filter
plates; filter cloth; hydraulic pumps; pneumatic booster pumps; control panel; connector
pipes;  and support platform.   Equipment and operational costs  were obtained from
manufacturers' recommendations.  The capital cost equation for Metals Option 1  liquid
filtration is:
where:
ln(Y1)=  14.826 + 1.089ln(X) + 0.050(ln(X))2                          (7-27)

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).
      The O & M costs were based on estimated electricity usage, maintenance, labor,
taxes and insurance, and filter cake disposal costs.  The labor requirements were
approximated at thirty minutes per cycle per filter press.
      Filter cake disposal costs were derived from responses to the WTI Questionnaire.
The disposal cost was estimated at $0.74 per gallon of filter cake; this is based on the
cost of contract hauling and disposal in a Subtitle C or Subtitle D landfill. A more detailed
explanation of the filter cake disposal costs development is presented in Subsection 7.5.2.
To determine the total annual O & M costs for a plate and frame filtration system, the
filter cake disposal cost  must be added to the other O & M costs.  The O & M cost
equation for Metals Option 1  liquid filtration is:
       ln(Y2) =  12.406 + 0.381 ln(X) + 0.014(ln(X))2
                                                                   (7-28)
 where:
       X = Flow Rate (MGD) and
       Y2 = O&M Cost (1989$).
                                      7-17

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      A pressure filtration system upgrade was calculated to estimate the increase in
O & M costs for facilities that already have a pressure filtration system in-place.  These
facilities would need to improve pollutant removals from their current performance levels
to Metals  Option  1   levels.   To determine  the  percentage  increase  from current
performance to Metals Option  1 levels, the ratio of the current performance to  Metals
Option 1 levels versus the raw data to current performance levels was calculated.  This
incremental increase was determined to be three percent, as follows:
      O & M Upgrade  = Current - Metals Option 1  = 0.03 = 3%
      Increase           Raw - Current
(7-29)
      Therefore, in order for the facilities to perform at Metals Option 1 levels, an O & M
cost upgrade of three percent of the total O & M costs (except for taxes and insurance,
which are a function of the capital cost) would be realized for each facility.  The filter cake
disposal upgrade costs are presented in Subsection 7.5.2.  The O & M upgrade cost
equation for Metals Option 1 liquid filtration is:

      ln(Y2) = 8.707 + 0.333ln(X) + 0.012(ln(X))2                           (7-30)
where:
      X = Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).

      The land requirements for the  plate and frame pressure filtration systems were
calculated by adding a perimeter of 20 feet around the equipment dimensions. The land
requirement equation for Metals Option  1 liquid filtration is:
      ln(Y3) = -1.971 + 0.281 ln(X) + 0.018(ln(X))2
(7-31)
where:
      X = Flow Rate (MGD) and
      Y3 e Land Requirement (Acres).

                                      7-18

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7.2.3.2
      Plate and Frame Filtration - MetalsOption 2
      The plate and frame  pressure filtration  system liquid stream costs for Metals
Option 2 are based on the same parameters and are from the same vendors as Metals
Option 1.  The capital and O & M costs were computed the same as for the Metals
Option 1 liquid filtration systems. The Metals Option 2 capital and O & M costs are based
on two pressure filtration units processing two batches per day. These units were sized
at 25 percent of the total liquid stream flow each.
      The Metals Option 2 O & M costs parameters were similar to the Metals Option 1
parameters.  The electricity  costs were similar because  electricity usage is based on
wastewater flow rate. The labor costs were scaled up by four to account for the two units
at two batches per day.  The maintenance and taxes and insurance were based on the
Metals Option 2 capital costs.  The filter cake disposal costs were the same as for Metals
Option 1 and are presented in Subsection 7.5.2. The total O & M costs for Metals Option 2
are calculated by adding the filter cake disposal costs to the O & M costs. The capital and
O & M cost equations for Metals Option 2 liquid filtration are presented as Equations 7-32
and 7-33, respectively.
where:
In(Y1) = 14.024 + 0.859ln(X) + 0.040(ln(X))2

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).

ln(Y2) = 13.056 + 0.193In(X) + 0.00343(ln(X))2
                                                                         (7-32)
                                                                         (7-33)
where:
      Y2 = O&M Cost (1989$).
       The land requirements for the plate and frame pressure filtration systems were
 calculated by adding a perimeter of 20 feet around the equipment dimensions for one
                                      7-19

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system and doubling the area to account for the two systems. The land requirement
equation for Metals Option 2 liquid filtration is:

       In(Y3) = -1.658 + 0.185ln(X) + 0.009(ln(X))2                           (7-34)
where:
       X = Flow Rate (MGD) and
       Y3 = Land Requirement (Acres).

7.2.4  Equalization

       Waste treatment facilities often need to equalize wastes by holding them in a tank
for a period of time to get a stable waste stream which is easier to treat. In the  CWT
Industry, equalization is frequently used to minimize the variablity of incoming wastes.
       The equalization cost estimates were obtained from OCPSF's use of the  1983
CAPDET program.  The equalization process utilizes a mechanical aeration basin. The
following default design parameters were used:
            Aerator mixing requirements = 0.03 hp per 1,000 gallons;
       •     Oxygen requirements = 15.0 mg/l per hour;
            Dissolved oxygen in basin = 2.0 mg/l;
            Depth of basin = 6.0 feet; and
       •     Detention time = 24 hours.
       A detention time of 24 hours is appropriate, as this was the median equalization
detention  time  reported  by  respondents to the WTI  Questionnaire.  The range of
wastewater flows  selected for these analyses was 0.001 to 5.0 MGD.
       Capital costs were calculated based upon total project costs less: miscellaneous
nonconstruction costs, 201  planning costs, technical costs, land costs, interest during
construction, and  laboratory costs.  O & M costs were obtained directly from the  initial
year O & M costs. The capital and O & M cost equations for the equalization systems
are presented as  Equations 7-35 and 7-36, respectively.
      ln(Y1) = 12.057 + 0.433ln(X) + 0.043(ln(X))2
                                      7-20
(7-35)

-------
where:
      X = Flow Rate (MGD) and ,
      Y1 = Capital Cost (1989$).

      ln(Y2) = 11.723 + 0.311ln(X) + 0.019(ln(X))2
                                                                   (7-36)
where:
      Y2 = O&M Cost (1989$).
      The CAPDET program was used to develop land requirements for the equalization
systems.  The requirements are scaled up to represent the total land required for the
system plus peripherals (pumps, controls, access areas, etc.).  The equation relating the
flow of the equalization system to the land requirement is:
where:
ln(Y3) = -0.912 + 1.120ln(X) + 0.011(In(X))2

X = Flow Rate (MGD) and
Y3 = Land Requirement (Acres).
                                                                         (7-37)
7.2.5 Air Stripping

      Air stripping is an effective wastewater treatment method for removing dissolved
gases and highly volatile odorous compounds from wastewater streams by passing high
volumes of air through an agitated gas-water mixture.
      The air stripping  technology  cost  was  based on  removing medium volatile
pollutants. The medium volatile pollutant 1,2-dichloroethane was used for the calculations
with an influent level of 4,000 |ig/l and effluent level of 68 |ig/l. The equipment costs were
calculated for a flow rate range of 0.0001 to 1.0 MGD and were obtained from vendor
services. The air stripping  unit costs included transfer pumps, control panels, blowers,
and ancillary equipment.  Catalytic oxidizers were also included in the capital cost for air
pollution control purposes.  The capital cost equation for air stripping systems is:
                                      7-21

-------
where:
ln(Y1) = 12.899 + 0.486ln(X) + 0.031(ln(X))2                          (7-38)

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989$).
      The O & M costs were  determined by electricity  usage, maintenance, labor,
catalyst replacement, and taxes and insurance. The electricity usage for the air strippers
was determined by the amount of horsepower needed to operate the systems.  The
electricity usage for the catalytic oxidizers was approximated  at  50 percent of  the
electricity used for the air strippers. The labor requirement for the air strippers was three
hours per day.  The catalysts used in the catalytic oxidizer are precious metal catalysts
and their lifetime is approximately four years. Therefore, the catalyst beds are completely
replaced about every four years. The costs for replacing the spent catalysts were divided
by four to convert them to annual costs.  The  O & M cost equation for air stripping
systems is:
      ln(Y2) = 10.865 + 0.298ln(X) + 0.021 (ln(X))2
                                                                   (7-39)
where:
      X = Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).
      To develop land requirements for the air stripping and catalytic oxidizer systems,
the individual system dimensions were combined, and a 20-foot perimeter was added to
the plot. The dimensions of the air strippers, in terms of length and width, are very small
compared to the catalytic oxidizers. The equation relating the flow of the system to the
land requirement is:
      ln(Y) = -2.207 + 0.536ln(X) + 0.042(ln(X))2
                                                                   (7-40)
                                      7-22

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where:
      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).

7.2.6 Multi-Media Filtration

      Filtration is a proven technology for the removal of residual suspended solids from
wastewater.  The media used in the  CWT multi-media filtration process are sand and
anthracite coal, supported by gravel. Large particulate matter is captured by the coarse,
lighter media near the top of the filter bed.  Flow controls are self-adjusting to regulate
treatment and backwash rates regardless of fluctuations in water pressure, thus helping
to prevent a loss of filter media from the tank.
      To  size the  multi-media  filtration systems, the design average influent total
suspended solids design concentration used was 165 mg/l. The design average effluent
total suspended solids concentration  was 124 mg/l.  These  concentrations were taken
from the data for CWT QID 059.  The  system costs were calculated for a flow rate range
of 0.001 to 1.0 MGD and were obtained from vendor services.
      The total capital costs for the multi-media filtration systems represent  equipment
and installation costs.  The total construction cost includes the costs  of the filter,
instrumentation and controls,  pumps,  piping, and installation. The capital cost equation
for multi-media filtration systems is:
 where:
ln(Y1) = 11.218 + 0.865ln(X) + 0.066(ln(X))2                          (7-41)

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).
       The O & M costs include energy usage,  maintenance, labor, and  taxes  and
 insurance. Energy is the cost of electricity to run the pumps, lighting, and instrumentation
                                      7-23

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and controls. The labor requirement for the multi-media filtration system was four hours
per day. The O & M cost equation for multi-media filtration systems is:
      ln(Y2) = 11.290 + 0.580!n(X) + 0.057(ln(X))2
                                                                   (7-42)
where:
      Y2 = O&M Cost (1989$).
      To develop land requirements for multi-media filtration systems, overall system
dimensions were provided by the vendor. The equation relating the flow of the system
to the land requirement is:
where:
ln(Y3) = -2.971 + 0.097ln(X) + 0.008(ln(X))2                           (7-43)

X = Flow Rate (MGD) and
Y3 = Land Requirement (Acres).
7.2.7 Carbon Adsorption

      Activated carbon adsorption is an effective treatment technology for the removal
of organic pollutants from wastewater. It is included in Oils Options 3 and 4 and Organics
Option 2.  The considered application for the CWT Industry is granular activated carbon
(GAG) in column reactors. The equipment consists of two beds operated in series. This
configuration allows the beds to go to exhaustion and be replaced on a rotating basis.
The GAG  capital costs are the same for all of the regulatory options considered. The
capital and O & M costs were calculated for a flow rate range of 0.00001 to 0.24 MGD.
The capital costs consist of the adsorber construction cost, initial carbon fill, freight, and
supervision. The GAG capital cost equation is:
      ln(Y1) = 15.956 + 1.423ln(x) + 0.050(ln(X))2
                                                                   (7-44)
                                      7-24

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where:
      X = Flow Rate (MGD) and
      Y1 = Capital Cost (1989$).

      The  O & M  costs are primarily attributed to carbon usage.  The key design
parameter is adsorption capacity;  this is a measurement of the mass of  pollutant
adsorbed per unit mass of carbon. For each regulatory option system, the pollutants of
concern and their associated removals were tabulated.  Using the adsorption capacities,
the specific carbon requirements were calculated. The carbon usage for each option was
scaled down by one-third;  this accounts for the series-bed design of the systems.
      The total O & M cost components are electricity, maintenance, labor, freight, and
taxes and insurance, in addition to the carbon usage. The freight cost for shipping the
carbon is dependent upon the amount of carbon and the distance that it is shipped. The
average freight cost used is $3,000 per 20,000-pound shipment.  Labor requirements are
three hours per day.  The GAG O & M cost  equations for Oils Option 3, Oils Option 4,
and Organics Option 2 are presented  as Equations 7-45, 7-46, and 7-47,  respectively.

      ln(Y2) = 14.516 + 1.086ln(X) + 0.060(ln(X))2                         (7-45)

      ln(Y2) = 15.949 + 1.310In(X) + 0.068(ln(X))2                         (7-46)
 where:
ln(Y2) = 17.621 +1.455ln(X) + 0.067(ln(X))2                          (7-47)

X = Flow Rate (MGD) and
Y2 = O&M Cost (1989$).
       The land requirement estimates for the GAG systems are the same for all three
 options. The equipment dimensions supplied by the vendor were used to determine the
 land needed.  A standard 20-foot perimeter was added to the equipment dimensions to
 account for access, piping, and controls. The resultant land  requirement equation is:
                                      7-25

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       ln(Y3) = -1.780 + 0.319ln(X) + 0.017(ln(X))2                           (7-48)
 where:
       X = Flow Rate (MGD) and
       Y3 = Land Requirement (Acres).

 7.2.8  Cyanide Destruction

       Cyanide destruction oxidation is capable of achieving removal efficiencies of 99
 percent or greater and to the levels of detection.  Chlorine is primarily used as the
 oxidizing agent in this process, which is called alkaline chlorination, and can be utilized
 in the elemental or hypochlorite form.
      The capital and O & M costs curves for cyanide destruction systems with special
 operating conditions  were obtained from vendor services.  The concentration used for
 influent amenable cyanide was 1,548,000 |j.g/l and for total cyanides was 4,633,710 jig/l.
 The effluent for these pollutants was 276,106 |o.g/l for amenable cyanides and  135,661
 p.g/1 for total cyanides. These rates show a removal of 82 percent for amenable cyanide
 and 97 percent for total cyanides. These concentrations were taken from the sampling
 data for CWTQID 105.
      The oxidation of cyanide waste using sodium hypochlorite is a two step process.
 In the  first step, cyanide is oxidized to cyanate  in the presence of hypochlorite and
 sodium hydroxide with the base required to maintain a pH range of 9 to 11.  The second
 step oxidizes cyanate to carbon dioxide and nitrogen at a controlled pH of 8.5.  The
 amounts of sodium hypochlorite and sodium hydroxide needed to perform the oxidation
 are 7.5 parts and 8.0 parts per part of cyanide, respectively.  At these levels, the total
 reduction  occurs at a retention time of 16 to 20 hours. The application  of heat can
facilitate  the more complete  destruction  of total cyanide.  The system costs were
calculated on a batch volume range from 1.0 to 1,000,000 gallons per day and because
of the extended retention time, a basis of one batch per day is used.
      The capital cost equation for the cyanide destruction system represents equipment
and installation costs.  The equipment items include a two-stage reactor with a retention
                                     7-26

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time of 16 hours, feed system and controls, pumps, piping, and foundation. The two-
stage reactor  includes a covered tank, mixer,  and containment  tank.   The total
construction cost includes the tank costs, instrumentation and controls, pumps, piping,
and installation. The capital cost equation is:
where:
ln(Y1) = 13.977 + 0.546In(X) + 0.0033(ln(X))2                         (7-49)

X = Batch Size (MGD) and
Y1 = Capital Cost (1989 $).
      The O & M costs were determined by energy usage, chemical costs, maintenance,
labor, and taxes and insurance. The labor requirement forthe cyanide destruction system
was three hours per day.  The O & M cost equation is:

      ln(Y2) = 18.237 + 1.318ln(X) + 0.04993(1 n(X))2                        (7-50)
where:
      X = Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).

      The vendor information was used to develop land requirements for the cyanide
destruction systems with special operating conditions. The equation relating the flow of
the system to the land requirement is:
where:
ln(Y3) = -1.168 + 0.419ln(X) + 0.021 (ln(X))2

X = Flow Rate (MGD) and
Y3 =  Land Requirement (Acres).
                                                                         (7-51)
                                      7-27

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7.2.9 Chromium Reduction

      Reduction  is a chemical reaction in which  electrons are transferred from one
chemical to another;  The main application of chemical reduction to the treatment of
wastewater is in  the  reduction of hexavalent chromium to trivalent chromium.  The
reduction enables the trivalent chromium to be precipitated from solution in conjunction
with other metallic salts.
      To develop the costs for chromium reduction systems using sulfur dioxide, costs
were obtained  from  vendors.  The average  influent  hexavalent  chromium  design
concentration used was 752,204 jig/1; the maximum concentration was 3,300,000 |ig/l.
The average effluent concentration was 30 jig/1. These concentrations were taken from
the sampling data for CWT QID 255.
      The hexavalent chromium is reduced to trivalent chromium using sulfur dioxide and
sulfuric acid. The sulfuric acid is used to lower the  pH of the solution and the sulfur
dioxide is used for the reduction process.  After the reduction process, the trivalent
chromium is then removed by precipitation.  The amount of sulfur dioxide needed to
reduce the hexavalent chromium was reported as 1.9 parts of sulfur dioxide per part of
chromium, while the amount of sulfuric acid was 1.0 part per part of chromium. At these
levels, the total reduction occurs at a retention time of 45 to 60 minutes.  The system
costs were calculated for a batch volume range from 1,000  gallons to 1,000,000 gallons
on a basis of two  batches per day.
      The capital cost equation forthe chromium reduction system represents equipment
and installation costs. The equipment items include a reduction reactor, feed system and
controls, pumps, piping, and foundation.  The reactor includes a covered tank, mixer, and
containment tank. The total construction cost includes the tank costs, instrumentation and
controls, pumps, piping, and installation.
      Capital costs for system upgrades were developed to estimate the incremental cost
required to install  a new chemical feed mechanism on an existing chromium reduction
system that utilizes a treatment chemical other than sulfur dioxide.   Fror the upgrade
                                     7-28

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costs, the piping and instrumentation and  controls equipment items were used to
determine the total construction cost.
      The capital cost and capital upgrade cost equations are presented as  Equations
7-52 and 7-53, respectively.   -
      ln(Y1) = 13.737 + O.GOOIn(X)                                        (7-52)

      ln(Y1) = 12.068 + 0.492ln(X) - 0.000496(ln(X))2                       (7-53)

      X = Volume per Day (MGD) and
      Y1 = Capital Cost (1989 $).
where:
      The O & M costs were determined by energy usage, chemical costs, maintenance,
labor, and taxes and insurance.  The labor requirement for the chromium reduction
system was four hours per day.
      O & M costs for system upgrades were developed to estimate the incremental cost
required to  operate an existing chromium reduction system that utilizes a treatment
chemical, other than sulfur dioxide, that is a waste product for which a facility does not
incur a purchase cost. The chemical cost items were used to determine the total O & M
cost.
      The O & M cost and O & M upgrade cost equations are presented as Equations
7-54 and 7-55, respectively.
       ln(Y2) = 13.167 + 0.998ln(X) + 0.079(ln(X))2
 where:
       ln(Y2) = 13.123 + 1.365ln(X) + 0.059(ln(X))2

       X = Flow Rate (MGD) and
       Y2 = O&M Cost (1989$).
(7-54)

(7-55)
                                      7-29

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      To  develop  land requirements for chromium reduction systems, approximate
dimensions were calculated using the diameters of the systems. The land was calculated
by estimating the size for the  reaction tank, storage tanks,  and feed system.   The
equation relating the flow of the system to the land requirement is:
where:
ln(Y3) = -1.303 + 0.185ln(X) - 0.036(ln(X))2
•
X = Flow Rate (MGD) and
Y3 = Land Requirement (Acres).
                                                                       (7-56)
7.3   BIOLOGICAL WASTEWATER TREATMENT TECHNOLOGY COSTS
7.3.1  Sequencing Batch Reactors
      A sequencing  batch  reactor (SBR) is a suspended  growth system in which
wastewater is mixed with existing biological floe in an aeration basin.  SBR's are unique
in that a single tank acts as an equalization tank, an aeration tank, and a clarifier.
      The capital and O & M costs curves for the SBR systems were obtained from a
vendor service.  The average influent BOD5, ammonia as N, and nitrate-nitrite as N
design concentrations used were 4,800 mg/l,  995 mg/l,  and 46 mg/l, respectively. The
average effluent BOD5, ammonia as N, and nitrate-nitrite as N concentrations used were
1,600 mg/l, 615 mg/l, and 1.0 mg/l, respectively. These concentrations were obtained
from the sampling data from CWT QID 059. The system costs were calculated for a flow
rate range of 0.001 to 1.0 MGD.
      The capital costs for the SBR systems were estimated using the vendor quotes
and represent equipment and installation costs.  The equipment items include a tank
system, sludge handling equipment, feed system and controls, pumps, piping, blowers,
and valves.  The SBR capital cost equation is:
      ln(Y1) = 15.707 + 0.512ln(X) + 0.0022(ln(X))2
                                    7-30
                                                                 (7-57)

-------
where:
      X = Flow Rate (MGD) and
      Y1 = Capital Cost (1989 $).

      The O & M costs were determined by power, maintenance, labor, and taxes and
insurance.  Power was estimated using the vendor values for horsepower used.  The
labor requirement  for a SBR system was  four hours per day.   The SBR O & M  cost
equation is:
                                                                      (7-58)
      ln(Y2) = 13.139 + 0.562ln(X) + 0.020(ln(X))2
where:
      X = Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).
      To develop land requirements for SBR systems, overall system dimensions were
provided by the  vendor.  The equation  relating the flow of the system to the land
requirement is:
where:
      ln(Y3) = -2.971 + 0.097ln(X) + 0.008(ln(X))2

      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).
7.4   ADVANCED WASTEWATER TREATMENT TECHNOLOGY COSTS
                                                                      (7-59)
7.4.1  Ultrafiltration

      Ultrafiltration (UF) systems are used by industry for the treatment of metal-finishing
wastewater, textile industry effluent, and oily wastes.  In the CWT industry, UF is applied
for the treatment of oily wastewater.
                                     7-31

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      The components of the UF system include: booster pumps; cartridge prefilters;
control units; high pressure  pump and motor assembly; membrane/pressure vessel
assembly; and reject holding tanks.  Capital equipment  and operational  costs were
obtained from manufacturers' quotations. The capital cost equation was developed by
adding installation, engineering, and contingency costs to the vendors' equipment cost.
The system costs were calculated for a flow rate range of 0.000001 to 1.0 MGD.  The UF
capital cost equation is:

      In(Y1) = 14.672 + 0.8789ln(X) + 0.044(ln(X))2                         (7-60)
where:
      X = Flow Rate (MGD) and
      Y1 = Capital Cost (1989 $).

      The O & M costs were based on estimated electricity usage, maintenance, labor,
taxes, and insurance.  The electricity usage and  costs were provided by the vendors.
The  labor requirement  for the UF system was approximated at two hours per day.
Concentrate disposal costs were based upon a concentrate generation rate of two percent
of influent flow.  The cost of concentrate disposal was quoted as $0.50 per gallon from
CWT QID 409. The UF O & M cost equation is:
where:
ln(Y2) = 15.043 + 1.164In(X) + 0.057(ln(X))2                         (7-61)

X = Flow Rate (MGD) and
Y2 = O&M Cost (1989$).
      Land requirements were calculated for UF systems using the system dimensions
plus a 20-foot perimeter. The UF land requirement equation is:
      ln(Y3) = -1.632 + 0.42ln(X) + 0.035(ln(X))2
                                                                  (7-62)
                                     7-32

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where:
      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).
7.4.2  Reverse Osmosis

      Reverse osmosis (RO) is a high-pressure, fine membrane process for separating
dissolved solids from water. A semi-permeable, microporous membrane and pressure
are used to perform the separation.  RO systems are typically used  as  end-of-pipe
polishing processes, prior to final discharge of recovered wastewater.
      The components of the RO system include a booster pump, cartridge prefilters, RO
unit, and a reject holding tank.  The capital cost equation was developed by adding
installation, engineering, and contingency costs to the vendors' equipment cost.  The
capital and O & M costs were calculated for a flow rate range of 0.000001 to 1.0 -MGD.
The RO capital cost equation is:
where:
ln(Y1) = 15.381 + 0.919ln(X) + 0.04(ln(X))2                            (7-63)

X = Flow Rate (MGD) and
Y1 = Capital Cost (1989 $).
      The O & M costs were based on estimated electricity usage, maintenance, labor,
 taxes, and insurance. The electricity usage and costs were provided by the vendors.
 The labor requirement for the RO system was approximated at two hours per day.
 Concentrate disposal costs were based on a concentrate generation rate of 28  percent
 of influent flow (CWT QID 409). The cost of concentrate disposal was quoted at $0.46
 per gallon. The RO O & M cost equation is:
       ln(Y2) = 17.599 + 1.303ln(X) + 0.048(ln(X))2
                                                                  (7-64)
                                     7-33

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where:
      X = Flow Rate (MGD) and
      Y2 = O&M Cost (1989$).

      Land requirements were calculated for RO systems using the system dimensions
plus a 20-foot perimeter. The RO land requirement equation is:

      ln(Y3) = -2.346 + 0.166!n(X) * 0.012(In(X))2                           (7-65)
where:
      X = Flow Rate (MGD) and
      Y3 = Land Requirement (Acres).

7.5   SLUDGE TREATMENT AND DISPOSAL COSTS

7.5.1  Plate and Frame Pressure Filtration - Sludge Stream

      Pressure filtration systems are used for the removal of solids from waste streams.
These systems typically follow chemical precipitation or clarification.
      The plate and frame pressure filtration system costs were estimated for a sludge
stream;  this consists of the sludge which is collected in the clarification step following
some chemical precipitation processes. The sludge stream consists of 80 percent liquid
and 20 percent (200,000 mg/l) solids.  The influent flow rate used for the sludge stream
is 20 percent of the influent flow rate for the liquid wastewater stream.  These influent
parameters were taken  from CWT QID 105.
      The components of the plate and frame pressure filtration system include: filter
plates; filter cloth; hydraulic pumps; pneumatic booster pumps; control panel; connector
pipes; and support platform.  Equipment and operational costs were  obtained  from
manufacturers' recommendations. The capital cost equation was developed by adding
installation, engineering, and contingency costs to the vendors' equipment  costs.  The
                                     7-34

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system costs were calculated for a flow rate range of 0.000001 to 1.0 MGD. The capital
cost equation for Metals Option 1 sludge filtration is:
where:
ln(Y1) .= 14.827 + 1,087ln(X) + 0.050(ln(X))2                           (7-66)

X = Flow Rate (MGD) of Liquid Stream and
Y1 = Capital Cost (1989 $).
      The O & M costs were based on estimated electricity usage, maintenance, labor,
taxes and insurance, and filter cake disposal costs. The labor requirement for the plate
and frame pressure filtration system was approximated  at thirty minutes per cycle per
filter press.
      Filter cake disposal costs were derived from responses to the WTI Questionnaire.
The disposal cost was estimated at $0.74 per gallon of filter cake; this is based on the
cost of contract hauling and disposal in a Subtitle C or Subtitle D landfill. A more detailed
explanation of the filter cake disposal costs development is presented in Subsection 7.5.2.
To determine the total O & M costs for a plate and frame filtration system, the filter cake
disposal costs must be added to the other O & M  costs.
      The O & M cost equation for Metals Option 1 sludge filtration is:
where:
ln(Y2) = 12.239 + 0.388ln(X) + 0.016(In(X))2                           (7-67)

X = Flow Rate (MGD) of Liquid Stream and
Y2 = O&M Cost (1989$).
       A pressure filtration system upgrade was calculated to estimate the increase in
 O & M costs for facilities that already have a pressure filtration system in-place.  These
 facilities would need to improve pollutant removals from their current performance levels
 to  Metals Option  1  levels.   To determine  the  percentage  increase  from current
 performance to  Metals Option  1 levels, the ratio of the current performance to  Metals
                                       7-35

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 Option 1 levels versus the raw data to current performance levels was calculated. This
 increase was determined to be three percent, as follows:
       O & M Upgrade = Current - Metals Option 1 =  0.03 =  3%
       Increase          Raw - Current
(7-68)
       Therefore, in order for the facilities to perform at Metals Option 1 levels, an O & M
 cost upgrade of three percent of the total O & M costs (except for taxes and insurance,
 which are a function of the capital cost) would be realized for each facility.  The O & M
 upgrade cost equation for Metals  Option 1 sludge filtration is:
       ln(Y2) = 8.499 + 0.331 ln(X) + 0.013(ln(X))2
(7-69)
where:
       X = Flow Rate (MGD) of Liquid Stream and
       Y2 = O&M Cost (1989$).

       Land requirements were calculated for the  plate and frame pressure filtration
systems using the system dimensions plus a 20-foot perimeter.  The land requirement
equation for Metals Option 1 sludge filtration  is:

       ln(Y3)= -1.971+0.281 ln(X) +0.018(ln(X))2                           (7-70)
where:
       X = Flow Rate (MGD) of Liquid Stream and
       Y3 = Land Requirements (Acres).

7.5.2  Filter Cake Disposal

      The liquid  stream and sludge stream pressure filtration systems presented in
Subsections 7.2.3 and 7.5.1, respectively, generate a filter cake residual.  There is an
annual O & M cost that is associated with the disposal of this residual.  This cost must
                                      7-36

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be added to the pressure filtration equipment O & M costs to arrive at the total O & M
costs for the pressure filtration operation.
      To determine the cost of transporting filter cake to an off-site facility for disposal,
an analysis of the WTI Questionnaire response data base was performed. Data from a
subset of questionnaire respondents were pulled for analysis.  This subset consisted of
Metals Subcategory facilities that  are direct and/or indirect  dischargers, and  would
therefore be costed for CWT compliance.  From these responses, the reported costs for
both the Subtitle C and Subtitle D contract haul/disposal methods of filter cake disposal
were tabulated. This information was edited to eliminate  incomplete or combined data
that could not be used.
      From this data set, the median cost for both the Subtitle C and Subtitle D disposal
options were determined.  Then, the weighted average of these median  costs was
determined. The average was weighted to reflect the ratio of hazardous (67 percent) to
nonhazardous (33 percent) waste receipts at these Metals Subcategory facilities. The
final disposal cost is $0.74 per gallon of filter cake.
      The filter cake disposal costs were calculated for a flow rate  range of 0.000001 to
1.0 MGD. The O & M cost equations for filter cake disposal for the Metals Options 1 and
2 plate and frame filtration full systems and system upgrades are presented as Equations
7-71 and 7-72,  respectively.
      Z = 0.109169 + 7,6953499.8(X)
       Z = 0.101186 + 230,879.8(X)
(7-71)
(7-72)
where:
       X = Flow Rate (MGD) of Liquid Stream and
       Z = Filter Cake Disposal Cost (1989 $).
                                       7-37

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7.6    ADDITIONAL COSTS

7.6.1  Retrofit Costs

       Costs were assigned to the CWT Industry on both an option- and facility-specific
basis.  The  option-specific  approach costed  a sequence of individual treatment
technologies,  corresponding to a particular regulatory option, for a subset of facilities
defined as belonging to that  regulatory subcategory.  Within the costing of a specific
regulatory option, treatment technology costs were assigned on a facility-specific basis
depending  upon the technologies determined to be currently in-place at the facility.
       Once it was determined that a treatment technology cost should be assigned to
a particular facility, there were two design scenarios which were considered. The first
was the installation of a new individual treatment technology as a part of a new treatment
train. The  full capital costs presented in Subsections 7.2 through 7.5 of this document
apply to this scenario.  The second scenario was the installation of a new individual
treatment technology which  would have to be  integrated  into  an  existing  in-place
treatment train.  It is in the case of this second scenario that retrofit costs were applied.
These retrofit costs cover such items as piping and structural modifications which would
be required in an existing piece of equipment to accommodate the installation of a new
piece of equipment prior to or within an existing treatment train.
       For all facilities which received  retrofit costs, a retrofit factor of 20 percent was
applied to the total capital cost of the newly-installed or upgraded treatment technology
unit that would need to integrated into  an existing treatment train.

7.6.2  Monitoring Costs

       Monitoring  costs will be realized  by CWT facilities who discharge  process
wastewater directly to a receiving stream or indirectly to a POTW.   Direct discharge
effluent monitoring requirements are mandated  in NPDES permits.   Indirect discharge
monitoring  requirements are mandated by the operating authority of the POTW.
                                      7-38

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      The method developed for the OCPSF Industry was used as the basis for the CWT
monitoring cost estimation.  The following generalizations have been used to estimate
compliance monitoring costs:
      1)    Monitoring costs are based on the number of outfalls through which process
            wastewater is discharged.  The cost for a single outfall is multiplied by the
            number of outfalls to arrive at the total costs for a facility.
      2)    Flow monitoring equipment costs, are included in, the capital costs for the
            specific treatment technologies.
      3)    Sample collection costs (labor and equipment) and sample shipping costs
            are not included.
      4)    The monitoring costs (based on frequency and analytical methods) are
            incremental to the monitoring currently being incurred by the CWT facility.
      Respondents to the WTI Questionnaire reported their POTW discharge monitoring
requirements.  For direct discharger, NPDES permits were  reviewed. This information
shows that most facilities are currently required to monitor for several classical  pollutant
parameters (e.g.  BOD5, TSS, pH, and cyanide).  And, for the parameters that are not
addressed, these analyses are relatively inexpensive.  Therefore,  costs for  classical
pollutant analyses are not included in the cost estimation.
      Many facilities are required to monitor for commonly-regulated metals (e.g. lead,
copper, and nickel); however, the CWT list of pollutants includes many more metals than
any facility currently quantifies.  Therefore, costs for metals monitoring are included in the
cost estimation.
      Very few facilities are required to monitor for organic compounds, so costs are
included for these analyses. EPA method 1624 is used for the quantification of volatile
organic compounds, and  Method 1625 is  used for the quantification of semivolatile
organic compounds.
       The frequency of monitoring currently required in the CWT  Industry varies widely
for any specific parameter from daily to semi-annually.  An  estimated weekly frequency
was used  for the cost estimation. This  frequency includes a full scan  as one of the
analyses each month.
                                      7-39

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      The OCPSF methodology assumes that larger dischargers would be required to
monitor for more parameters within a pollutant group. As such, the analytical cost would
increase based on the number of parameters to be quantified.  The monitoring costs,
adjusted to 1989 dollars, are presented in Table 7-4.
Table 7-4.  Monitoring Costs for the CWT Industry Cost Exercise
Flow Rate Range (MGD)
<0.5
0.5 - 4.99
5 - 9.99
>10
Annual Monitoring Costs
(1989$)
per Outfall
40,680
61 ,725
68,100
134,525
7.6.3 RCRA Permit Modification Costs

      Respondents to the WTI Questionnaire whose RCRA Part B permits were modified
were asked to report the following  information  pertaining to the cost of obtaining the
modification:
            Legal fees;
      •     Administrative costs;
            Public relations costs;
      •     Other costs;  and
      •     Total costs.
      The purpose of the permit modification was also asked.  Anticipated changes to
a facility's RCRA permit as a result of the implementation of CWT regulations include the
upgrade of existing equipment and/or the installation of new treatment technologies to
achieve effluent limitations.  These changes correlate with the purposes identified by the
WTI Questionnaire respondents as  "new tanks", "new units", "new technologies", and
"other - modification of existing  equipment".  The applicable costs  are summarized in
Table 7-5.
                                     7-40

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Table 7-5.   RCRA Permit Modification Costs Reported in WTI Questionnaire
Modification
New Units
New Technology
Modify Existing
Equipment
Average
QID
081
255
081
090
402
-
Year
1990
. 1990.
1990
1990
1991
-
Total Cost
(reported $)
26,000
7,000
82,000
6,300,000*
14,080
-
Total Cost
(1989$)
25,357
6,827
79,793
6,144,231*
13,440
31 ,400
            This cost includes equipment and installation costs;  no cost breakdown is
            given. Therefore, this cost was not used in calculating the average cost.
7.6.4  Land Costs

       An important factor in the calculation of treatment technology costs is the value of
the land needed for the installation of the technology.  Due to continuing development,
the availability and therefore  the cost of land can prove to be a significant part of the
capital cost. To determine the amount of land required  for costing purposes, the land
requirements  for each treatment technology were calculated for the range of system
sizes. These land requirements were fitted to a curve  so that a land  requirement, in
acres, could  be  calculated for every treatment  system costed.  The  individual land
 requirements  were then multiplied by the corresponding land cost estimates to obtain
facility-specific cost estimates.  Since land costs  may vary widely across the country, a
 nationwide average figure would not be representative. Therefore, the average land costs
 for suburban sites in each state were obtained from the 1990 Guide to Industrial and Real
 Estate Office  Markets survey.
       According to the survey, the unimproved sites  are the most desirable of  the
 existing inventory and are zoned for industrial use;  therefore, unimproved land costs
                                       7-41

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were used  in  this  analysis.   The survey  categorizes the  states into regions by
geographical location: northeast, north central, south, and west.  For states that have no
land prices available in the survey, the regional average figures were used.  In calculating
the regional average costs for the  western region, Hawaii  wasi not included.  This is
because Hawaii's land cost is disproportionately high and its inclusion would have skewed
the regional average.
      The survey report data are also broken down by site size ranges; these are zero
to 10 acres, 10 to 100 acres, and greater than 100 acres. The respondents to the WTI
Questionnaire reported total facility areas ranging from less than one acre to 2,700 acres
and undeveloped facility areas from zero to 1,775 acres. Since the CWT facilities fall into
all three size ranges covered by the report data, the three  size-specific land costs for
each state were averaged to arrive at the final costs for the industry.  As Table 7-6
indicates, that the least expensive state is Kansas  with a land cost of $7,042 per acre.
The most expensive state is Hawaii with a land  cost of $1,089,000 per acre.
                                      7-42

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Table 7-6.   State Land Costs for the CWT Industry Cost Exercise
State
Alabama
Alaska*
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho*
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana*
Land Cost per
Acre (1989$)
22,773
81,105
46,101
15,899
300,927
43,560
54,232
54,450
63,273
72,600
1,089,000
81,105
36,300
21 ,078
8,954
7,042
29,040
56,628
19,602
112,530
59,895
13,649
21 ,054
13,068
39,930
81,105
State
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota*
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island*
South Carolina
South Dakota*
Tennessee
Texas
Utah*
Vermont*
Virginia
Washington
West Virginia*
Wisconsin
Wyoming*
Washington DC

Land Cost per
Acre (1989 $)
24,684
36,300
52,998
89,443
26,929
110,013
33,880
20,488
14,578
24,321
50,820
32,307
59,822
21 ,296
20,488
20,873
47,674
81,105
59,822
39,930
63,670
47,345
17,424
81,105
174,240

             No data available for state, used regional average.
                                      7-43

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7.7   REFERENCES
Standard Methods for Examination of Water and Wastewater. 15th Edition, Washington,
DC.

Henricks, David, Inspectors Guide for Evaluation  of Municipal Wastewater Treatment
Plants. Culp/Wesner/Culp, El Dorado Hills, CA, 1979.

Technical  Practice  Committee, Operation of Wastewater Treatment Plants. MOP/11,
Washington, DC, 1976.

Clark, Viesman, and Hasner, Water Supply and  Pollution Control. Harper and Row
Publishers, New York, NY, 1977.

1991  Waste Treatment  Industry  Questionnaire  Respondents Data Base.  U.  S.
Environmental Protection Agency, Washington, DC.

Osmonics,  Historical Perspective of Ultratiltration  and  Reverse Osmosis  Membrane
Development. Minnetonka, MN, 1984.

Organic Chemicals  and  Plastics and Synthetic Fibers (OCPSF) Cost Document. SAIC,
1987.

Effluent Guidelines Division, Development Document For Effluent Limitations Guidelines
and Standards  for  the  Organic  Chemicals. Plastics and Synthetic Fibers (OCPSF).
Volume II, Point Source  Category, EPA 440/1-87/009, Washington, DC, October 1987.

Engineering News Record (ENR). McGraw-Hill, New York, NY, March 30, 1992.

Comparative Statistics of Industrial and Office Real  Estate Markets.  Society of Industrial
and Office Realtors  of the National Association of Realtors, Washington, DC, 1990.

Peters, M., and Timmerhaus, K.,  Plant  Design and Economics for Chemical Engineers,
McGraw-Hill, New York,  NY, 1991.

Chemical Marketing Reporter. Schnell Publishing Company, Inc., New York, NY, May 10,
1993.

Palmer, S.K.,  Breton,  M.A., Nunno,  T.J., Sullivan,  D.M.,  and  Supprenaut,  N.F.,
Metal/Cyanide   Containing  Wastes  Treatment   Technologies. Alliance  Technical
Corporation, Bedford, MA, 1988.

Freeman, H.M., Standard Handbook of Hazardous Waste Treatment and Disposal. U.S.
Environmental Protection Agency, McGraw-Hill, New York, NY, 1989.
                                    7-44

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SECTION 8
DEVELOPMENT OF LIMITATIONS AND STANDARDS
      This section describes various waste treatment technologies and their costs,
pollutants proposed for regulation, and pollutant reductions associated with the different
treatment technologies obtained for the proposed effluent limitations guidelines and
standards for the Centralized Waste Treatment Industry. The limitations and standards
discussed in this section are Best Practicable Control Technology Currently Available
(BPT), Best Conventional Pollutant Control Technology (BCT), Best Available Technology
Economically  Achievable  (BAT),  New  Source  Performance  Standards (NSPS),
Pretreatment Standards for Existing Sources (PSES), and Pretreatment Standards for
New Sources (PSNS).

8.1   ESTABLISHMENT OF BPT

      Generally, EPA bases BPT upon the average of the best current performance (in
terms of treated  effluent discharged)  by facilities of various sizes, ages, and unit
processes within an industry or subcategory.  The factors considered in establishing the
best practicable control technology currently available (BPT) include: (1) the total cost of
applying the technology relative to the effluent reductions that result, (2) the age of
process equipment and facilities involved, (3) the processes employed and required
process changes, (4) the engineering aspects of the control technology, (5) non-water
quality environmental impacts such as energy requirements, air pollution and solid waste
generation, and (6) such other factors as the Administrator deems appropriate (section
304(b)(2)(B) of the Act). As noted,  BPT technology represents the average of the best
existing performances of facilities within the industry. When existing performance is
uniformly inadequate,  EPA may require a higher level of control than is currently in place
in an industrial category if EPA determines that the technology can be practically applied.
BPT may be transferred from a different subcategory  or category.  However, BPT
                                      8-1

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normally focuses on end-of-process treatment rather than process changes or internal
controls, except when these technologies are common industry practice.
      The cost/effluent reduction inquiry for BPT is a limited balancing one, committed
to EPA's discretion, that does not require  the Agency to  quantify effluent reduction
benefits in monetary terms. See, e.g., American Iron and Steel Institute v. EPA, 526 F.
2d 1027 (3rd Cir., 1975).  In balancing costs against the effluent reduction benefits, EPA
considers the volume and nature of discharges expected after application of BPT, the
general environmental effects of pollutants,  and the cost and  economic impacts of the
required level of pollution control. In developing guidelines,  the Act does not require or
permit consideration of water quality problems attributable to  particular point sources, or
water quality improvements  in particular  bodies of water.   Therefore, EPA has not
considered these factors in developing the  proposed limitations.  See Weyerhaeuser
Company v. Costle, 590 F. 2d 1011 (D.C. Cir. 1978).
      EPA concluded that the wastewater treatment performance  of the facilities it
surveyed was, with very limited exceptions,  uniformly poor. Under these circumstances,
for each subcategory,  EPA has preliminarily  concluded that only one treatment system
meets the statutory test for best practicable, currently available technology. EPA has
determined  that  the  performance of facilities  which mix different types of highly
concentrated CWT wastes with non-CWT waste streams or  with stormwater are not
providing BPT treatment.  The mass of pollutants being discharged is unacceptably high.
Thus,  comparison  of EPA  sampling data and CWT industry-supplied monitoring
information establishes that, in the case of metal-bearing waste streams, virtually all the
facilities are discharging large total quantities of heavy metals.  As measured by total
suspended solids (TSS) levels following treatment, TSS concentrations are substantially
in excess of levels observed at facilities in other industry categories employing the same
treatment technology — 10 to 20 times greater than observed for other point source
categories.
      In the case of oil discharges, most facilities are achieving low removal of oils and
grease relative to the performance required for other point source categories. Further,
                                      8-2

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facilities treating organic wastes, while successfully-removing organic pollutants through
biological treatment, fail to remove metals associated with these organic wastes.
      The poor pollutant removal performance observed generally for discharging CWT
facilities is not unexpected. As pointed out previously, these facilities are treating highly
concentrated wastes that, in many cases, are process residuals and sludges from other
point source categories.  EPA's review of permit limitations for the direct dischargers show
that,  in  most cases,  the dischargers are  subject to "best professional judgment"
concentration limitations which were developed from guidelines for facilities treating and
discharging much more dilute waste streams.  EPA has concluded  that treatment
performance in the industry is widely inadequate and that the mass of pollutants being
discharged is unacceptably high, given the demonstrated removal capability of treatment
operation that the Agency reviewed.

8.1.1 Rationale for Metals Subcategory BPT Limitations

      In determining BPT, EPA evaluated metals precipitation as the principal treatment
practice within the subcategory. Forty-seven of the 56 facilities in the Metals Subcategory
use metals precipitation as a means for waste treatment.  The precipitation techniques
used by facilities varied in the treatment chemicals used and operation of the precipitation
system, e.g., batch, continuous, or selective metals precipitation.  In  the process of
selecting facilities for sampling, there was difficulty is  gathering  data  from direct
dischargers for establishing limitations and standards. Because BPT applies to direct
dischargers, the data used to establish limitations and standards developed are normally
collected from such facilities.  Most facilities in the Metals Subcategory, however, are
indirect dischargers and therefore do not monitor or optimize the performance of their
treatment system for treatment of conventional pollutants. (Indirect dischargers generally
are not required  to control their discharges of conventional pollutants because the
receiving POTWs are designed to achieve the conventional removals.) Therefore, when
reviewing the analytical data collected, EPA concluded that the treatment performance
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by  indirect dischargers could not  be characterized  as the average of the best
performance,  because systems  were obviously  not operated  so as to remove
conventional pollutants. After evaluating various metals precipitation processes, EPA
considered three regulatory options to reduce the discharge of pollutants by Centralized
Waste Treatment facilities.
      The three technology options considered for the Metals Subcategory BPT are:
      •      Option  1 - Chemical precipitation, Solid-Liquid separation, and Sludge
             dewatering.   Under Option  1, BPT limitations  would be based upon
             chemical precipitation with a lime/caustic solution followed by some form of
             separation and sludge dewatering to control the discharge of pollutants in
             wastewater.    The  data reviewed  for   this  option   showed that
             settling/clarification followed by pressure filtration of sludge yields removals
             equivalent to  pressure filtration.   In general,  while the proposed BPT
             limitations would require the improvement of current treatment technologies
             in-place through increased  quantities of treatment chemicals and additional
             monitoring of batch processes, this precipitation process is employed by
             many facilities. For metals streams which contain concentrated cyanide
             complexes, the proposed BPT limitations  are based on alkaline chlorination
             at specific operating conditions prior to metals treatment.   As previously
             noted, without treatment of cyanide waste streams prior to metals treatment,
            metals removals are significantly reduced.
             Option 2 - Selective  Metals Precipitation, Pressure Filtration, Secondary
            Precipitation, and Solid-Liquid Separation. The second option evaluated for
             BPT for Centralized Waste Treatment facilities is based on the use of
            numerous  treatment tanks  and  personnel to handle incoming waste
            streams, and the use  of  greater quantities  of caustic  in the treatment
            chemical mixture.  (Caustic sludge is easier to recycle.) Option 2 is based
            on additional tanks and personnel to segregate incoming waste streams
            and to monitor the  batch treatment processes to maximize the precipitation
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            of specific metals in order to generate a metal-rich filter cake.  The metal-
            rich filter cake could possibly be sold to metal smelters to incorporate into
            metal  products.     Like Option 1, for  metals streams which contain
            concentrated cyanide  complexes, under Option 2, BPT limitations are
            based on alkaline chlorination at specific  operating conditions prior to
            metals treatment.
            Option 3 -  Selective Metals Precipitation, Pressure Filtration, Secondary
            Precipitation, Solid-Liquid Separation,  and Tertiary Precipitation.  The
            technology basis for Option 3 is the same as Option 2 except an additional
            precipitation step at the end of treatment is added.  For metals streams
            which contain concentrated cyanide complexes, like Option 1 and 2, for
            Option 3, alkaline chlorination at specific operating conditions would be the
            basis for BPT limitations.
      The Agency is proposing to adopt BPT effluent limitations based on Option 3 for
the Metals Subcategory. These limitations were developed based on an engineering
evaluation of the average of the best demonstrated methods to control the discharges of
the regulated pollutants in this Subcategory. The proposed BPT limitations for the Metals
Subcategory are presented in Table 8-1.  Draft long-term averages for Options 1 and 2
are presented in the Statistical Support Document for  Proposed Effluent Limitations
Guidelines and Standards for the Centralized Waste Treatment Industry as well as the
methodology for calculating the variability factors used to calculate limitations.
      EPA's tentative decision to base BPT limitations on Option 3 treatment reflects
primarily an evaluation of three factors: the degree of effluent reduction attainable, the
total cost of the proposed treatment technologies in relation to  the effluent reductions
achieved, and potential non-water quality benefits.  In  assessing BPT, EPA considered
the age, size, process, other engineering factors, and non-water quality impacts pertinent
to the facilities treating wastes  in this  Subcategory.  No basis could be  found for
identifying different BPT limitations based on age, size, process or other  engineering
factors.  Neither the age nor  the size of the CWT facility will directly affect  either the
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Table 8-1.  BPT Effluent Limitations for the Metals Subcategory
Pollutant or Pollutant
Parameter
Maximum for
Any One Day
Monthly Average
Conventional Pollutants
Oil & Grease
TSS
45
55
11
18
Priority and Non-Conventional Pollutants
Aluminum
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Hexavalent Chromium
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Silver
Tin
Titanium
Total Cyanide
Zinc
0.72
0.14
0.076
0.14
0.73
0.77
0.73
1.0
0.14
2.4
0.37
9.9
0.18
0.013
5.4
0.028
0.20
0.021
4.4
1.2
0.16
0.031
0.017
0.032
0.16
0.17
0.16
0.23
0.077
0.54
0.082
2.2
0.039
0.0030
1.2
0.0063
0.044
0.0047
1.2
0.27
In-Facility BPT Limitations for Cyanide Pretreatment
Total Cyanide
350
130
                                      8-6

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character or treatabiiity of the CWT wastes or the cost  of treatment.  Further, the
treatment process and engineering aspects of the technologies considered have a
relatively insignificant effect because in most cases they represent fine tuning or add-ons
to treatment technology already  in use.    These factors consequently did not weigh
heavily in the development of these guidelines.  For a service industry whose service is
wastewater treatment, the most pertinent factors for establishing the limitations are costs
of treatment, the level of effluent reductions obtainable, and non-water quality effects.
      Generally, for purposes of defining BPT effluent limitations, EPA looks at the
performance of the best operated treatment system and calculates limitations from some
level of average performance of these "best" facilities. For example, in proposing BPT
limitations for the pulp, paper and paper board category, EPA compared the average
removal performance of the best 90 percent of paper mills and the performance level
representing the average for the best 50 percent of the  mills (58 FR 66078, 66105
(December 17,  1993)). For this industry, as previously explained, EPA concluded that
treatment performance is, in virtually all cases, poor. Without separation of metal-bearing
streams for selective precipitation,  metal removal levels are uniformly inadequate across
the industry.  Consequently, BPT performance  levels are based on data from the one
well-operated system using selective metals precipitation that was sampled by EPA.
      The demonstrated  effluent reductions attainable through  the Option  3 control
technology represent the BPT  performance  attainable  through the application  of
demonstrated treatment measures currently in operation in this industry. The Agency is
proposing to adopt BPT limitations based on the removal performance of the Option 3
treatment system for the following reasons.  First, these removals are demonstrated by
a facility in this subcategory and can readily be applied to all facilities in the subcategory.
The adoption of this level of control would represent a significant reduction in pollutants
discharged into the environment
       Second, the Agency assessed the total cost of water pollution controls likely to be
incurred for Option 3 in relation to the effluent reduction benefits and determined these
costs were reasonably achievable.  While the absolute costs of selective metals
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precipitation (Options 2 and 3) are significantly higher than Option 1, EPA concluded the
costs were still reasonable.   EPA's cost assessment shows that  selective metals
precipitation would  not  adversely  affect profitability within this subcategory.   EPA
calculated that four facilities would experience decreased profitability while seven would
show an increase  in profitability.  The expenses associated with  selective metals
precipitation would  not cause any of the 12 direct dischargers currently to go from a
profitable to unprofitable status. Addition of a further precipitation step (Option 3) did not
change these  results.
      Third, adoption of these BPT limits could promote the non-water quality objectives
of the CWA. Use of the Option 3 treatment regime — which generates a metal-rich filter
cake that may be recovered and smelted — could reduce the quantity of waste which are
being disposed of in landfills.
      The Agency proposes to reject Option 1  because, as  discussed above,  EPA
concluded that mixing disparate metal-bearing waste streams is  not the best practicable
treatment technology currently in  operation  for  this subcategory  of  the industry.
Consequently, effluent levels associated with this treatment option would not represent
BPT performance levels. Option 2 was rejected, although similar to Option 3, because
the greater removals obtained through addition of tertiary precipitation at Option 3 were
obtained at a relatively insignificant increase in costs over Option 2.
      In the process of selecting facilities for sampling, there was difficulty is gathering
data from direct dischargers for establishing limitations and standards.  Since BPT applies
to direct dischargers, the limitations and standards developed are  normally collected from
such facilities.  Most facilities in the Metals Subcategory are indirect dischargers and do
not monitor or optimize  the performance of their treatment system for treatment of
conventional pollutants.  Therefore, when reviewing the analytical data collected,  EPA
concluded that performance by indirect dischargers is not representative of the average
of the best performance because  these systems were not operated properly for the
removal of conventional pollutants, thus, incidentally reducing metals removals.
                                       8-8

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8.1.2 Rationale for Oils Subcategory BPT Limitations

      In determining BPT for the Oily Subcategory, EPA evaluated a variety of different
treatment methods used within the subcategory. Treatment varies depending on the type
of oils accepted for treatment and other on-site operations. A majority of facilities, 29 out
of 34, use chemical emulsion-breaking as a means to separate stable oil-water emulsions.
The remaining facilities treat less stable oily wastes  by gravity separation, dissolved air
flotation (DAF), or in flocculation/clarification treatment system designed for a wide variety
of waste streams.
      Treatment  of the  wastewater resulting  from  emulsion-breaking  is  also
accomplished by a variety of methods. Most of the facilities which use emulsion-breaking
treat the resulting wastewater in a flocculation/clarification treatment system designed to
treat a variety  of waste  streams.  Only one  facility was identified as treating the
wastewater resulting from emulsion-breaking in a system specifically designed for the
pollutants in an  oily waste stream. After evaluating various treatment operations, EPA
identified four regulatory options (identified  from operations at the one facility which was
specifically designed for the treatment of  oily wastes) for consideration to reduce the
discharge of pollutants by Centralized Waste Treatment facilities.
      The four technology options considered for the  Oils Subcategory BPT are:
             Option 1 - Emulsion-Breaking.  Under Option 1, BPT limitations would be
             based on present performance of emulsion-breaking processes using acid
             and heat to separate oil-water emulsions. At present, most facilities have
             this technology in place unless unstable oil-water mixtures are accepted for
             treatment.  Stable oil-water  emulsions require some emulsion-breaking
             treatment because gravity separation or flotation alone is inadequate to
             breakdown the oil-water waste stream.
             Option 2 - Ultrafiltration. Under Option 2,  BPT limitations are based on the
             use of ultrafiltration for treatment of less concentrated, unstable oily waste
                                       8-9

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             receipts or for the additional treatment of wastewater from the emulsion-
             breaking process.
             Option 3 - Ultrafiltration, Carbon Adsorption, and Reverse Osmosis.  The
             Option 3  BPT effluent limitations are  based on the use  of Carbon
             Adsorption and Reverse Osmosis in addition to the Option 2 technology.
             The reverse osmosis unit removes metals compounds found at significant
             levels  for this subcategory.  Inclusion  of a carbon adsorption  unit is
             necessary in order to protect the reverse osmosis unit by filtering out any
             large particles which may damage the reverse osmosis unit or decrease
             membrane performance.
       •      Option 4 - Ultrafiltration, Carbon Adsorption, Reverse Osmosis, and Carbon
             Adsorption.  Option 4 is similar to  Option 3 except for the additional carbon
             adsorption unit for final effluent polishing.
       The Agency is proposing  BPT effluent limitations for the Oily  Waste Subcategory
based on Option 3 as well as Option 2 treatment systems. The proposed BPT limitations
for the Oils Subcategory are presented in Table 8-2.  Draft long-term averages for
Options 1 and 4 are presented in the Statistical Support Document for Proposed Effluent
Limitations Guidelines and Standards for the Centralized Waste Treatment Industry as
well as the methodology for calculating the variability factors used to calculate limitations.
The EPA has preliminarily concluded that both options represent best practicable control
technologies. The technologies are in-use in the industry and the data collected by the
Agency show that the limitations are being achieved. In assessing BPT, EPA considered
age, size, process, other engineering factors, and non-water quality  impacts pertinent to
the facilities treating wastes in this subcategory. No basis could be found for identifying
different BPT limitations based on age, size, process or other engineering factors for the
reasons previously discussed.    For a  service industry whose service is wastewater
treatment, the pertinent factors here for establishing the limitations are costs of treatment,
the level of effluent reductions obtainable, and non-water quality effects.
                                      8-10

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Table 8-2.  BPT Effluent Limitations for the Oils Subcategory (mg/l)
Pollutant or Pollutant
Parameter
Option 2
Maximum
for
any One
Day
Monthly
Average
Option 3
Maximum
for
any One
Day
Monthly
Average
Conventional Pollutants
Oil & Grease
TSS
30,000
24
5,900
8.2
240
4.0
64
1.4
Priority and Non-Conventional Pollutants
1,1,1 -Trichloroethane
2-Propanone
4-Chloro-3-Methyl Phenol
Aluminum
Barium
Benzene
Butanone
Cadmium
Chromium
Copper
Ethyl Benzene
Iron
Lead
Manganese
Methylene Chloride
m-Xylene
Nickel
1.6
41
5.2
2.3
0.10
9.0
3.7
1.5
2.2
2.0
1.1
75
5.0
5.4
3.9
1.6
120
1.0
22
4.4
0.57
0.026
6.8
2.0
0.37
0.54
0.50
0.86
19
1.2
1.3
2.0
1.2
29
0.18
130
0.96
0.085
0.0027
1.8
13
0.0046
0.010
0.016
0.085
0.40
0.076
0.043
2.2
0.074
2.2
0.12
44
0.54
0.038
0.0012
1.4
4.3
0.0020
0.0045
0.0073
0.066
0.18
0.034
0.019
0.91
0.058
0.99
                                      8-11

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Table 8-2.  BPT Effluent Limitations for the Oils Subcategory (mg/l) (continued)
Pollutant or Pollutant
Parameter
Option 2
Maximum
for
any One
Day
Monthly
Average
Option 3
Maximum
for
any One
Day
Monthly
Average
Priority and Non-Conventional Pollutants (continued)
n-Decane
n-Docosane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o&p-Xylene
Tetrachloroethene
Tin
Toluene
Tripropyleneglycol Methyl
Ether
Zinc
0.18
0.18
0.18
0.18
0.18
0.18
0.18
0.86
0.23
0.82
17
280
22
0.096
0.096
0.096
0.096
0.096
0.096
0.096
0.65
0.14
0.20
13
150
5.6
0.19
0.19
0.19
0.19
0.19
0.19
0.19
0.045
0.032
0.12
1.8
160
0.54
0.067
0.067
0.067
0.067
0.067
0.067
0.067
0.035
0.016
0.056
1.4
57
0.24
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      Among the options considered by the Agency, both Options 2 and 3 would provide
for significant reductions in regulated pollutants discharged into the environment over
current practice in the industry represented by Option 1.  EPA is nonetheless, concerned
about the cost of Option 3 because it is substantially more expensive than Option 2.
However, EPA's economic assessment indicates, that under either Option 2 or 3, although
one of four direct dischargers will experience some reduction in profitability, the other
three facilities will see an increase. Even under Option 3, no facility in the subcategory
would  move from  a profitable to unprofitable status.  In these circumstances,  EPA
concluded that the costs of Option 3 may not be wholly disproportionate to the effluent
reductions benefits achieved, particularly when other factors are taken into account.
      As noted, the Agency is proposing Option 2 because it is a currently available and
cost-effective  treatment option.   However, the  BPT  pollutant removal  performance
required for a number of specific pollutants (particularly oil and grease and metals) is less
stringent than current BPT effluent limitations guidelines promulgated for other industries.
EPA is concerned about the potential for encouraging off-site shipment of oily waste now
being treated on-site if the limitations for this subcategory are significantly different from
those other BPT effluent limitations currently in effect.
      The Agency proposes to reject Option 1, because the technology does not provide
for adequate control of the regulated pollutants.  The Agency also proposes to reject
Option  4  because less pollutant  reductions  occur in comparison to  Option 3.
Theoretically, Option 4 should provide for the maximum reduction of pollutants discharged
due to the addition of carbon adsorption units, but specific  pollutant concentrations
increase across the carbon adsorption unit according to the analytical data collected.
       Even though, as previously explained, BPT limitations are generally defined by the
average effluent reduction performance of the best existing treatment systems, here, as
was the case with the BPT metal-bearing wastes limitations, the options being proposed
as the basis for BPT effluent limitations are based upon the treatment performance at a
single facility. EPA concluded that existing performance at the other facilities is uniformly
inadequate because many facilities  that will be subject to the limitations for the Oily
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Waste Subcategory now commingle the oily wastewater with other wastes prior to
treatment. The Agency has determined that the practice of mixing waste streams before
treatment results in inadequate removal of the regulated pollutants of concern for the Oils
Subcategory.   Oily wastewater contains significant  levels of organic and  metals
compounds.  If the oily wastewater is mixed with other CWT wastewater, these organic
and metals compounds  are often found at non-detectable levels pjior to treatment
because the oily wastewater is effectively diluted by the other wastewater to the point that
the compounds are no longer detectible. The treatment system on which the Options 2
through 4 effluent limitations are based was designed specifically for the treatment of
segregated oily wastewater.

8.1.3 Rationale for Organics Subcategory BPT Limitations

      Determining BPT for the Organics Subcategory was a difficult process.  Most
facilities in the Organics Subcategory have other non-CWT operations, such as organics
manufacturing. The portion of CWT wastes and wastewater treated at the facility was
minor in comparison to the overall facility flow.  The CWT flows are a majority of  the
overall facility flow for only nine out of the 16 facilities in the Subcategory. For organic
waste streams, biological treatment is typically the predominant technology used. Due
to the types of pollutants identified in the Organics Subcategory, most facilities in this
Subcategory use air stripping as a means for controlling volatile organics and multimedia
or carbon adsorption for final effluent polishing. As discussed in Section 3, one facility
was identified which developed a treatment system for recovering the organic constituents
in the waste stream, but data  from this facility could not be used  for limitation
development because it was not being operated so as to optimize removals at the time
of the  EPA sampling episode.  Therefore, the EPA used the treatment technologies
located at one facility to develop the two options for this subcategory.
      The two technology options considered for the Organics Subcategory BPT are:
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            Option 1 - Equalization, Air-Stripping, Biological Treatment, and Multi-media
            Filtration.  BPT Option  1 effluent guidelines are based on the following
            treatment system: equalization, two air-strippers in series equipped with a
            carbon adsorption unit for control of air emissions, biological treatment in
            the form of a sequential batch reactor (which is operated on a batch basis),
            and finally multi-media filtration units for control of solids.
            Option 2 - Equalization, Air-Stripping, Biological Treatment, Multi-media
            Filtration, and Carbon Adsorption. Option 2 is the same as Option 1 except
            for the addition of carbon adsorption units.
      The Agency is proposing to adopt BPT effluent limitations based on the Option 1
technology for the Organics Subcategory. The proposed BPT limitations for the Organics
Subcategory are presented in Table 8-3.  Draft long-term averages for Options 2 are
presented  in  the  Statistical  Support Document for  Proposed  Effluent  Limitations
Guidelines and Standards for the Centralized Waste Treatment Industry as well as the
methodology for calculating the variability factors used to calculate limitations.  The
demonstrated effluent  reductions attainable through Option  1   control  technology
represent the best practicable performance attainable through the application of currently
available treatment measures.  EPA's decision to propose effluent limitations defined by
the removal performance  of  the Option 1 treatment  systems is  based primarily on
consideration  of several factors:  the effluent  reductions  attainable, the economic
achievability of the option and non-water quality environmental benefits. Once again, the
age and size of  the facilities, processes  and  other engineering factors were not
considered pertinent to establishment of BPT limitations for this Subcategory.
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Table 8-3.  BPT Effluent Limitations for the Organics Subcategory (mg/I)
Pollutant or Pollutant
Parameter
Maximum for Any
One Day
Monthly Average
Conventional Pollutants
BOD,
Oil & Grease
TSS
163
13
216
53
4.9
61
Priority and Non-Conventional Pollutants
1,1,1 ,2-Tetrachloroethane
1,1,1 -Trichloroethane
1 ,1 ,2-Trichloroethane
1 ,1-Dichloroethene
1 ,2,3-Trichloropropane
1 ,2-Dibromoethane
1,2-Dichloroethane
2,3-Dichloroaniline
Butanone
2-Propanone
4-Methyl-2-Pentanone
Acetophenone
Aluminum
Antimony
Barium
Benzene
Benzoic Acid
Carbon Disulfide
Chloroform
0.013
0.021
0.21
0.037
0.016
0.014
0.031
0.17
1.1
1.6
0.093
0.048
1.3
0.42
3.8
0.014
0.49
0.16
0.56
0.011
0.018
0.17
0.027
0.014
0.011
0.025
0.14
0.84
1.3
0.074
0.022
0.75
0.24
2.2
0.011
0.24
0.11
0.48
                                     8-16

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Table 8-3.  BPT Effluent Limitations for the Organies Subcategory (mg/l) (continued)
Pollutant or Pollutant
Parameter
Maximum for Any
One Day
Monthly Average
Priority and Non-Conventional Pollutants
Diethyl Ether
Hexanoic Acid
Lead
Methylene Chloride
Molybdenum
m-Xylene
o-Cresol
Phenol
Pyridine
D-Cresol
Tetrachloroethene
Tetrachloromethane
Toluene
trans-1 ,2-dichloroethene
Trichloroethene
Vinyl Chloride
Zinc
0.070
0.51
0.16
1.1
0.98
0.014
0.051
0.79
0.71
0.098
0.73
0.013
0.014
0.15
1.2
0.071
0.43
0.056
0.25
0.095
0.97
0.57
0.011
0.025
0.38
0.24
0.040
0.53
0.011
0.011
0.11
0.86
0.052
0.25
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       The  Agency is  proposing to adopt  BPT  limitations based  on the  removal
 performance of the Option 1 treatment system for the following reasons. First, the cost
 of achieving the pollutant discharge levels associated with the Option 1 treatment system
 is reasonable. The annualized costs for treatment are low.  Further, EPA estimates that
 meeting the Option 1 BPT limitations, while adversely affecting the profitability of two of
 six direct dischargers would increase the profitability of the other four. No facility moves
 from profitable to unprofitable status.  Second, the costs are not only low generally but
 low relative to the removals achieved. Third, significant non-water quality benefits may
 be expected from the installation of air stripping units equipped with carbon adsorption
 units which prevent volatilization of organic compounds.
       According to the data collected, the Option 1 treatment system provides a greater
 effluent pollutant reduction level than the more expensive Option 2.  Theoretically, Option
 2 should provide for the maximum reduction of pollutants discharged due to the addition
 of carbon adsorption units, but specific pollutants of concern increased across the carbon
 adsorption unit according to the analytical data collected. Due to the poor performance
 of carbon adsorption in EPA's database for this industry, Option 2 is rejected. The poor
 performance may be a result of pH fluctuations in the carbon adsorption unit resulting in
 the solubilization of metals. Similar trends have been found for all of the data collected
 on carbon adsorption units in this industry.
       The Agency  used biological treatment performance  data from the  OCPSF
 regulation to establish direct discharge limitations for BOD5 and TSS, because the facility
from which Option 1 and 2 limitations were derived is an indirect discharger  and the
treatment system is not operated to optimize removal  of conventional pollutants. EPA has
 concluded that the transfer of this data is appropriate given the absence of adequate
treatment technology for these pollutants at the only otherwise well-operated BPT CWT
facility. Given the treatment of similar wastes at both OCPSF and centralized waste
treatment facilities, use of the data is warranted. Moreover, EPA has every reason to
believe that the same treatment systems will perform similarly when treating the wastes
in this subcategory.
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      Once again, the selected BPT option is based on the performance of a single
facility. Many facilities that are treating wastes that will be subject to effluent limitations
for the Organic-Bearing Waste Subcategory also operate other industrial processes that
generate much larger amounts of wastewater than the quantity of off-site generated
organic waste receipts. The off-site generated organic waste receipts are directly mixed
with the wastewater from the other industrial processes for treatment.  Therefore,
identifying facilities to sample for limitations development was difficult because the waste
receipts and treatment unit effectiveness could not be properly characterized for off-site
generated waste. The treatment system for which Options 1 and 2 is based upon was
one of the few facilities identified which treated organic waste receipts separately from
other on-site industrial wastewater.

8.2   BCT

      EPA is proposing BCT equivalent to the BPT guidelines for  the conventional
pollutants covered under BPT. In developing BCT limits, EPA considered whether there
are technologies that achieve greater removals of conventional pollutants than proposed
for BPT, and whether those technologies are cost-reasonable according to the BCT Cost
Test.  In all three subcategories, EPA identified no technologies that can achieve greater
removals of conventional pollutants than proposed for BPT that are also cost-reasonable
under the BCT Cost Test, and accordingly EPA proposes BCT effluent limitations equal
to the proposed BPT effluent limitations guidelines and standards.

8.3   BAT
       EPA is proposing BAT effluent limitations for all subcategories of the Centralized
Waste Treatment Industry based upon the same technologies evaluated and proposed
for BPT for each subcategory.  The proposed BAT effluent limitations would control
identified priority and non-conventional pollutants discharged from facilities.
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       EPA has not identified any more stringent treatment technology option which it
considered to represent BPT level of control applicable to facilities in this industry for the
metals, oils, and organics subcategories. EPA identified an add-on treatment technology
— carbon adsorption — that should have further increased removals of pollutants of
concern.   However,  as explained  above,  EPA's  data  show  increases  rather than
decreases in concentrations of specific pollutants of concern.

8.4    NSPS

       As previously noted, under section 306 of the Act, new industrial direct dischargers
must comply with standards which reflect the greatest  degree of effluent reduction
achievable through application of the best  available demonstrated control technologies.
Congress envisioned that new treatment systems could meet tighter controls than existing
sources because of the opportunity to incorporate the most efficient processes  and
treatment systems into plant design. Therefore, Congress directed EPA to consider the
best demonstrated process changes, in-plant controls,  operating methods  and end-of-
pipe treatment technologies that reduce pollution to the maximum extent feasible.
       EPA is proposing NSPS that would control the same conventional, priority,  and
non-conventional pollutants proposed for control by the BPT effluent limitations. The
technologies  used to control pollutants at existing facilities are fully applicable to new
facilities.  Furthermore, EPA has not  identified  any technologies or combinations of
technologies that are demonstrated for new sources that are different from those used to
establish BPT/BCT/BAT for existing sources. Therefore, EPA is establishing NSPS
subcategories similar to the subcategories for existing facilities and proposing NSPS
limitations that are identical to those proposed for BPT/BCT/BAT.
                                      8-20

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8.5   PSES
      Indirect dischargers in the Centralized Waste Treatment Industry, like the direct
dischargers, accept for treatment wastes containing many priority and non-conventional
pollutants. As in the case of direct dischargers, indirect dischargers may be expected to
discharge many of these pollutants to POTWs at significant mass and concentration
levels. EPA estimates that indirect dischargers annually discharge approximately 85.3
million pounds of pollutants.
      Section 307(b) requires EPA to promulgate pretreatment standards to prevent
pass-through of pollutants from POTWs to waters of the U.S. or to prevent pollutants from
interfering with the operation of POTWs. EPA is establishing PSES for this industry to
prevent pass-through of the same pollutants controlled by BAT from POTWs to waters of
the U.S.
      The Agency is proposing pretreatment standards for existing sources (PSES)
based on the same technologies as proposed for BPT and BAT for 78 of the 87 priority
and non-conventional pollutants regulated  under BAT for Regulatory  Option 1 (the
combination of Metals Option 3, Oils Option 2, and Organics Option 1) and 81 of the 87
priority pollutants regulated under BAT for Regulatory Option 2 (the combination of Metals
Option 3, Oils Option 3, and Organics Option 1). A discussion of the pollutants excluded
from PSES are included in Section 5. These standards would apply to existing facilities
in all subcategories of the Centralized Waste Treatment  Industry that indirectly discharge
wastewater to  publicly-owned treatment works  (POTWs).   These limitations were
developed based  on the same technologies  as proposed today  for BPT/BAT,  as
applicable to each of the affected subcategories. PSES set at these points would prevent
pass-through of pollutants, help control sludge contamination and reduce air emissions.
      The Agency considered the age, size, processes, other engineering factors, and
non-water quality environmental impacts pertinent to facilities in developing PSES. The
Agency did not identify any basis for establishing different PSES limitations based on age,
size, processes, or other engineering factors.
                                      8-21

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 8.6    PSAfS

       Section 307(c) of the Act requires EPA to promulgate pretreatment standards for
 new sources (PSNS) at the same time it promulgates new source performance standards
 (NSPS).  New indirect discharging facilities, like new direct discharging facilities, have the
 opportunity to incorporate the best available demonstrated technologies,  process
 changes, in-facility controls, and end-of-pipe treatment technologies.
       EPA determined that a broad range of pollutants discharged by Centralized Waste
 Treatment Industry facilities pass-through POTWs. The same technologies discussed
 previously for BAT, NSPS, and PSES are available as the basis for PSNS.
       EPA is proposing that pretreatment standards for new sources be set equal to
 NSPS for priority and non-conventional pollutants for all subcategories. The Agency is
 proposing to establish PSNS for the same priority and non-conventional pollutants as are
 being proposed for NSPS. EPA considered the cost of the proposed PSNS technology
 for new facilities. EPA concluded that such costs are not so great as to present a barrier
 to entry,  as demonstrated by the fact that currently operating facilities are using these
 technologies.

 8.7    COST OF TECHNOLOGY OPTIONS

       The Agency estimated the cost for Centralized Waste Treatment facilities to
 achieve each of the proposed effluent limitations and standards. All cost estimates in this
 section are expressed in 1993 dollars.  The cost components reported in this section
 represent estimates of the investment cost of purchasing and installing equipment, the
 annual operating and maintenance costs associated with that equipment, additional costs
for discharge monitoring, and costs  for facilities to  modify existing RCRA permits.  The
following sections present costs for BPT, BCT, BAT, and PSES.
                                     8-22

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8.7.1  Proposed BPT Costs
      The, Agency, estimated the cost of implementing the proposed BPT effluent
limitations guidelines and standards by calculating the engineering costs of meeting the
required effluent limitations for each direct discharging CWT.   This facility-specific
engineering cost assessment for BPT began with a review of present waste treatment
technologies. For facilities without a treatment technology in-place equivalent to the BPT
technology, the  EPA estimated the cost to upgrade its treatment technology, to use
additional treatment chemicals to achieve the new discharge standards, and to employ
additional personnel, where applicable, for the option. The only facilities given no cost
for compliance were facilities with the treatment-in-place prescribed for that option.
Details pertaining to the development of the technology costs are included in Section 7.
The capital expenditures for the process change component of proposed BPT are
estimated to be $17.7 million with annual O&M costs of $14.3 million for Regulatory
Option 1 (the combination of Metals Option 3, Oils Option 2, and Organics Option 1) and
$20.6 million with annual O&M costs of $21.7 million for  Regulatory  Option 2 (the
combination of  Metals Option 3, Oils Option 3,  and Organics Option 1).  Table 8-4
summarizes,  by subcategory, the capital expenditures and annual O&M costs for
implementing proposed BPT.
Table 8-4.  Cost of Implementing Proposed BPT Regulations [in millions of 1993 dollars]
Subcategory
Metals Treatment and Recovery
Oils Treatment and Recovery -
Regulatory Option 1
Oils Treatment and Recovery -
Regulatory Option 2
Organics Treatment
Regulatory Option 1
R^ni il^torv Ontion ^
Number of
Facilities1
12
4
4
6
16
16
Capital
Costs
15.4
1.02
3.84
1.32
17.7
906
Annual
O&M Costs
10.5
0.779
8.15
3.06
14.3
91.7
 1Because some direct dischargers include operations in more than one subcategory, the sum of the facilities
 with operations in any one subcategory exceeds the total number of facilities.
                                      8-23

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 8.7.2  Proposed BCT/BAT Costs

       The Agency estimated that there would be no cost of compliance for implementing
 proposed BCT/BAT, because the technology is identical to BPT and the costs are
 included with proposed BPT.

 8.7.3  Proposed PSES Costs
       The Agency estimated the cost for implementing proposed PSES with the same
assumptions and methodology used to estimate cost of implementing BPT.  The capital
expenditures for the process change component of PSES are estimated to be $43.8
million with annual O&M costs of $26.8 million for Regulatory Option 1  (the combination
of Metals Option 3, Oils Option 2, and Organics Option 1) and $52.6 million with annual
O&M costs of $45.9 million for Regulatory Option 2 (the combination of Metals Option 3,
Oils Option 3, and Organics Option 1).  Table 8-5 summarizes, by subcategory, the
capital expenditures and annual O&M costs for implementing proposed PSES.

Table 8-5. Cost of Implementing Proposed PSES Regulations [in millions of 1993 dollars]
Subcategory
Metals Treatment and Recovery
Oils Treatment and Recovery -
Regulatory Option 1
Oils Treatment and Recovery -
Regulatory Option 2
Organics Treatment
Regulatory Option 1
Regulatory Option 2
Number
of
Facilities
44
31
31
16
56
56
Capital
Costs
27.598
4.084
12.607
10.736
43.8
52.6
Annual
O&M Costs
22.267
2.294
20.894
1.365
26.8
45.9
Because some indirect dischargers include operations in more than one subcategory, the sum of the facilities
with operations in any one subcategory exceeds the total number of facilities.
                                     8-24

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8.8   POLLUTANT REDUCTIONS

8.8.1  Conventional Pollutant Reductions

      EPA has calculated how much adoption of the proposed BPT/BCT limitations
would reduce the total quantity of conventional pollutants that are discharged. To do this,
for each subcategory, the Agency developed an estimate of the long-term average
loading (LTA) of BOD5,  TSS, and Oil and Grease that would be discharged after the
implementation of BPT. Next, these BPT/BCT LTAs for BOD5, TSS, and Oil and Grease
were  multiplied by 1989 wastewater flows for each direct discharging facility in the
subcategory to calculate  BPT/BCT mass discharge loadings for BOD5, TSS, and Oil and
Grease for each facility.  The BPT/BCT mass discharge loadings were subtracted from
the estimated current loadings to calculate the pollutant reductions for each facility. Each
subcategory's BPT/BCT pollutant reduction was summed to estimate the total facility's
pollutant reduction for  those facilities treating wastes  in  multiple subcategories.
Subcategory reductions, obviously, were obtained by summing individual subcategory
results.  The Agency estimates that the proposed regulations will reduce BOD5 discharges
by approximately 34.5 million pounds per year for Regulatory Option 1 (the combination
of Metals Option 3, Oils Option 2, and Organics Option 1) and 36.9 million pounds per
year for Regulatory Option 2  (the combination of Metals Option 3,  Oils Option 3, and
Organics Option 1); TSS discharges by approximately 30.3 million pounds per year for
both Regulatory Options; and Oil and Grease discharges by approximately 52.4 million
pounds  per year for Regulatory Option 1 (the combination of Metals Option 3, Oils Option
2, and Organics Option 1) and 56.9 million pounds per year for Regulatory Option 2 (the
combination of Metals Option 3, Oils Option 3, and Organics Option 1).
                                     8-25

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8.8.2 Priority and Nonconventional Pollutant Reductions
8.8.2.1
Methodology
      The proposed BPT, BCT,  BAT, and PSES, if promulgated, will also reduce
discharges of priority and non-conventional pollutants. Applying the same methodology
used to estimate conventional pollutant reductions attributable to application of BPT/BCT
control technology, EPA has also estimated  priority and non-conventional pollutant
reductions for each facility by subcategory.  Because EPA has proposed BAT limitations
equivalent to BPT, there are obviously no further pollutant reductions associated with BAT
limitations.
      Current loadings were estimated using data collected by the Agency in the field
sampling program and from the questionnaire data supplied by the industry.  For many
facilities, data were not available for all pollutants of concern or without the addition of
other non-CWT wastewater.  Therefore, methodologies were developed  to estimate
current  performance  for  each  subcategory.   Performance  of  on-site treatment
technologies was assessed with wastewater permit information and monitoring data
supplied in the  1991  Waste Treatment Industry  Questionnaire  and the Detailed
Monitoring Questionnaire.
8.8.2.2
Direct Facility Discharges (BPT/BAT)
      The estimated reductions in pollutants directly discharged in treated final effluent
resulting from implementation of proposed BPT/BAT are listed in Table 8-6.  Pollutant
reductions are presented for Regulatory Option 1 (the combination of Metals Option 3,
Oils Option 2, and Organics Option 1) and Regulatory Option 2 (the combination of
Metals Option 3, Oils Option 3, and Organics Option 1). The Agency estimates that
proposed BPT/BAT regulations will reduce direct facility discharges of priority, and non-
                                     8-26

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conventional pollutants by 56.1 million pounds per year for Regulatory Option 1 and 58.2
million pounds per year for Regulatory Option 2.

Table 8-6.   Reduction in Direct Discharge of Priority and Nonconventional Pollutants
            After Implementation of Proposed BPT/BAT Regulations
            (units = Ibs/year)
Subcategory
Metals Treatment and Recovery
Oils Treatment and Recovery -
Regulatory Option 1
Oils Treatment and Recovery -
Regulatory Option 2
Organics Treatment
Regulatory Option 1
Regulatory Option 2
Metal
Compounds
871,832
294,543
319,847
3,065,679
4,232,054
4,257,358
Organic
Compounds
245,525
556,627
610,937
O1
802,153
856,462
all facilities had the treatment-in-place for removal of organic compounds.
8.8.2.3
PSES Effluent Discharges to POTWs
      The estimated reductions in pollutants indirectly discharged to POTWs resulting
from implementation of proposed PSES are listed in Table 8-7.  Pollutant reductions are
presented for Regulatory Option 1  (the combination of Metals Option 3, Oils Option 2, and
Organics Option 1) and Regulatory Option 2 (the combination of Metals Option 3, Oils
Option  3,  and  Organics  Option 1).   The  Agency  estimates that proposed PSES
regulations will reduce indirect facility discharge to POTWs by 76.8 million pounds per
year for Regulatory Option 1 and for Regulatory Option 2 81.9 million pounds per year.
                                      8-27

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Table 8-7.   Reduction in Indirect Discharge of Priority and Nonconventional Pollutants
            After Implementation of Proposed PSES Regulations
            (units = Ibs/year)
Subcategory
Metals Treatment and Recovery
Oils Treatment and Recovery - Regulatory
Option 1
Oils Treatment and Recovery - Regulatory
Option 2
Organics Treatment
Regulatory Option 1
(with Oils Option 2)
Regulatory Option 2
(with Oils Option 3)
Metal
Compounds
428,040
709,834
771,668
415,812
1,553,686
1,615,520
Organic
Compounds
120,545
1,341,439
1,474,708
3,521,560
4,983,544
5,116,813
                                     8-28

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SECTION 9
NON-WATER QUALITY IMPACTS
      During wastewater treatment, the pollutants of concern are either removed from
the waste stream or destroyed.  If the pollutants are removed, they are transferred from
the water to another medium as a treatment residual.  Subsequent disposition of these
wastewater treatment residuals results in non-water quality impacts. The removal of
organic pollutants from the wastewater also prevents them from being released into the
atmosphere, which affects air quality.
      Wastewater treatment  also  results in other, non-water,  non-residual, impacts.
These impacts are the consumption of energy used to power the wastewater treatment
equipment, and the  use of additional personnel to provide the wastewater treatment
equipment operating labor.
       Sections 304(b) and 306 of the Clean Water Act require EPA to consider the non-
water quality environmental impacts and energy requirements of certain regulations.
Pursuant to these requirements, EPA has considered the effect of the CWT BPT, BCT,
BAT, NSPS, PSES, and PSNS regulations on air pollution, solid waste generation, and
energy consumption. Additionally,  EPA has considered the positive effect of employment
gains for the industry resulting from the increased operating labor requirements of these
regulations.

9.1    AIR POLLUTION

       CWT facilities treat waste  streams which contain significant concentrations of
volatile organic  compounds  (VOCs).   These waste streams  usually  pass through
collection and treatment units that are open to the atmosphere. This exposure may result
in the volatilization of VOCs from the wastewater.
       No negative air quality impacts are anticipated as a result of the CWT regulations.
 Rather, the  implementation of technologies for compliance with the regulations should
                                      9-1

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reduce the emissions of VOCs into the atmosphere.   In the Organics Subcategory
treatment trains, air stripping and granular activated carbon (GAG) adsorption treatment
results in the removal of VOCs from the wastewater.  In the Oils Subcategory treatment
trains, the ultrafiltration, reverse osmosis, and GAG treatment units also provide VOC
removals.  These VOCs, instead of being released into the air, are transferred to a
treatment residual.  Taken here as a positive impact, removal of these VOCs results in
a negative impact in terms of solid and aqueous treatment residuals generation. Table
9-1 presents the estimated reductions in VOC emissions resulting from compliance with
the CWT regulations. Solid and aqueous impacts are discussed later.
Table 9-1.   Air Pollution Reductions for the CWT Industry
CWT
Subcategory
Oils
Organics
Option
2
3
4
1
2
VOCs Removed (million Ibs/year)
Indirects
63.7783
82.8056
85.1056
1 ,302.6800
1 ,303.7248
Directs
24.2875
33.1970
34.3239
708.3285
709.0126
Total
88.0658
116.0028
119.4295
2,01 1 .0085
2,012.7374
9.2   SOLID AND OTHER AQUEOUS WASTE

      Solid and other aqueous waste would be generated by several of the wastewater
treatment technologies expected to be implemented to comply with the CWT regulations.
The costs for disposal of these other waste residuals were included in the compliance
cost estimates prepared for the regulatory options.
      The solid and other aqueous waste treatment residuals are filter cake, reverse
osmosis  and uitrafiltration concentrate,  spent activated carbon,  and deactivated air
                                     9-2

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stripper oxidizer catalyst.  These residuals are described and quantified in the following
discussions.

9.2.1  Filter Cake

      In the CWT Metals Subcategory treatment trains, hydroxide precipitation of metals
generates a sludge residual.  This sludge is dewatered, and the resultant filter cake is
disposed or recycled.  At one CWT facility that EPA sampled during this project, the use
of selective metals precipitation allows for the reclamation of the metal-bearing filter cake.
Therefore,  the total quantities of  metals treatment filter  cake estimated  for CWT
compliance may not necessarily require  disposal.  However,  in the CWT economic
evaluation, contract hauling for off-site disposal in a Subtitle C or D  landfill was the
method costed.  In the Organics Subcategory treatment train, the sequencing batch
reactor (SBR) produces a biological treatment sludge which is also  dewatered and
disposed off-site.
      It is estimated that compliance with Metals Options 1,2, or 3 and Organics Options
1 or 2 would result in the disposal of 3.9  million  gallons, or  39 million  pounds, of
hazardous and nonhazardous filter cake. The itemized estimated filter cake generation
for the CWT Industry is presented in Table 9-2.
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Table 9-2.   Filter Cake Generation for the CWT Industry
CWT
Subcategory
Organics
Metals
Option
1
2
1
2
3
Filter Cake Generated (million gal/year)
Hazardous
Indirect
0.1870
0.1870
0.9905
0.9905
0.9905
Direct
0
0
1.2439
1.2439
1 .2439
Total
0.1870
0.1870
2.2344
2.2344
2.2344
Nonhazardous
Indirect
0.3798
0.3798
0.4879
0.4879
0.4879
Direct
0
0
0.6126
0.6126
0.6126
Total
0.3798
0.3798
1.1005
1.1005
1.1005
9.2.2  Reverse Osmosis Concentrate

      In the Oils Subcategory treatment trains, reverse osmosis (RO) treatment of oily
streams results in the generation of a concentrated residual stream. At the CWT facility
which uses this technology, the concentrated residual is either recycled via fuel-blending
or disposed.   Therefore, the  total quantities of RO concentrate estimated for CWT
compliance may not necessarily require disposal.  However,  in the  CWT economic
evaluation, contract hauling for off-site  disposal was. costed.  The estimated  RO
concentrate generation for the CWT Industry is presented in Table 9-3.

Table 9-3.  Reverse Osmosis Concentrate Generation for the CWT Industry
CWT Oils Subcategory Option
2
3
4
RO Concentrate Generated (MGal/year)
Indirects
0
42.2458
42.2458
Directs
0
15.9214
15.9214
Total
0
58.1672
58.1672
                                      9-4

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9.2.3  Ultrafiltration Concentrate
      In the Oils  Subcategory treatment trains,  ultrafiltration  (UF)  treatment of oily
streams results in the generation of a concentrated residual stream. At the CWT facility
which uses this technology, the concentrated residual is either recycled via fuel-blending
or disposed.  Therefore, the total quantities of UF  concentrate estimated for  CWT
compliance  may not necessarily  require disposal.  However,  in the CWT economic
evaluation, contract  hauling  for  off-site disposal  was  costed.  The  estimated  UF
concentrate generation for the CWT Industry is presented in Table 9-4.

Table 9-4.   Ultrafiltration Concentrate Generation for the CWT Industry
CWT Oils Subcategory
Option
2
3
4
UF Concentrate Generated (MGal/year)
Indirects
2.9864
2.9864
2.9864
Directs
1.1372
1.1372
1.1372
Total
4.1236
4.1236
4.1236
9.2.4 Spent Carbon

      In the Oils and Organics Subcategories treatment trains, granular activated carbon
(GAG) adsorption treatment of waste streams results in the generation of exhausted, or
spent activated carbon.  In the CWT economic evaluation, removal of the spent carbon
for regeneration by a vendor was costed.  The estimated activated carbon usage for the
CWT Industry is presented in Table 9-5.
                                       9-5

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Table 9-5.   Activated Carbon Requirements for the CWT Industry
CWT Subcategory
Oils
Organics
Option
2
3
4
1
2
Carbon Usage (million Ibs/year)
Indirects
0
1 .0794
2.1624
0
5.4402
Directs
0
0.5289
4.4126
0
3.5618
Total
0
1 .6083
6.5750
0
9.0020
9.2.5  Air Stripper Oxidizer Catalyst

      In the Organics Subcategory treatment train, air stripping treatment of waste
streams results in the generation of a contaminated off-gas, which requires the application
of an air pollution control device.  A catalytic oxidizer was costed for the CWT economic
evaluation. Over time, its catalyst becomes deactivated; the replacement of the spent
catalyst by a vendor was costed.  The estimated air stripper catalyst usage for the CWT
Industry is presented in Table 9-6.

Table 9-6.   Air Stripper Oxidizer Catalyst Requirements for the CWT Industry
CWT Organics Subcategory
Option
1
2
Catalyst Usage (Ibs/year)
Indirects
109.1
109.1
Directs
59.4
59.4
Total
168.5
168.5
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9.3   ENERGY REQUIREMENTS
      In all of the CWT Subcategories, operation of wastewater treatment equipment
results in the consumption of energy. This energy is used to power pumps, mixers, and
other equipment components, to power lighting and controls, and to generate heat. The
itemized estimated energy usage for the CWT Industry is presented in Table 9-7. As can
be seen in this table, the proposed CWT Regulatory Option 1  (the combination of Oils
Option 2, Organics Option 1, Cyanide Waste Pretreatment, and Metals Option 3) would
require the consumption of 17.71 million kilowatt-hours per year of electricity. This is the
equivalent of 9,925 barrels per year of #2 fuel oil. The proposed CWT Regulatory Option
2 (the combination of Oils Option 3, Organics Option 1, Cyanide Waste Pretreatment, and
Metals Option 3) would require the consumption of 21.95 million kilowatt-hours per year
of electricity, or 12,300 barrels per year of #2 fuel oil.

Table 9-7.   Energy Requirements for the CWT Industry
CWT Subcategory
Oils
Organics
Cyanide Waste
Pretreatment
Metals
Option
2
3
4
1
2
2
1
2
3 '
Energy Usage (kwhr/year)
Indirects
5,799,279
8,872,953
8,918,041
619,642
639,494
219,603
99,790
3,553,280
4,117,529
Directs
3,566,654
4,735,779
4,763,509
294,821
307,819
55,683
137,339
2,649,986
3,035,628
Total
9,365,933
13,608,732
13,681,550
914,463
947,313
275,286
237,129
6,203,266
7,153,157
                                      9-7

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9.4   LABOR REQUIREMENTS

      The installation of new wastewater treatment equipment for compliance with the
CWT regulations would result in increased operating labor requirements for GWT facilities.
It is estimated that compliance with the CWT regulations would result in industry-wide
employment gains;  the estimated labor needs are presented in Table 9-8.

Table 9-8.   Labor Requirements for the CWT Industry
CWT Subcategory
Oils
Organics
Cyanide Waste
Pretreatment
Metals
Option
2
3
4
1
2
2
1
2
3
Operating Labor Requirements
Indirect Dischargers
(hours/yr)
14,560
58,630
91 ,480
48,234
60,279
17,520
22,456
1 ,062,640
1 ,089,940
(men/yr)
7.3
29.3
45.8
24.1
30.1
8.6
11.2
531.3
545.0
Direct Dischargers
(hours/yr)
2,080
8,540
12,920
16,266
22,836
2,190
15,242
223,580
229,820
(men/yr)
1.0
4.3
6.5
8.1
11.4
1.1
7.6
111.8
114.9
                                     9-8

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SECTION 10
IMPLEMENTATION
      Implementation of a regulation is the final step in the regulatory process.  If a
regulation is not effectively implemented, the removals and environmental  benefits
estimated for the regulation may not be achieved.
      In discussions with permit writers and pretreatment authorities, many stated that
close communication with CWT facilities was important for effective implementation of
discharge permits.  Due to the difficulty in treating the concentrated waste  streams
identified in the CWT Industry, many facilities also maintain close communication with the
waste generator. Many CWT facilities work with generators to ensure the waste received
for treatment is,  in fact, substantially similar to that reported in the original paperwork for
accepting the waste for treatment. CWT facilities also work with generators to reduce the
mixing of various waste streams.  The facility on which the proposed Metals Subcategory
limitations are based asked waste generators not to mix wastes from various processes.
This  assisted  the process of selective  metals precipitation.   Therefore,  close
communication among permit writers/pretreatment authorities, waste generators, and
CWT facilities is an important aspect in effective implementation of the effluent guidelines
limitations and standards.

10.1  APPLICABLE WASTE STREAMS

      Effective implementation of the regulation depends on accurate determination of
which waste streams are covered by  the each subcategory of the regulation and careful
management of individual waste streams by the generators of the waste and the CWT
facility.  Section 4 describes the sources of wastewater for the CWT Industry including
waste receipts; tanker truck, trailer/roll-off bins and drum wash water; solubilization water;
and contaminated stormwater.  One of the most difficult wastewater sources to identify
is contaminated stormwater. Many facilities discharge stormwater, but not necessarily
                                      10-1

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contaminated stormwater. Contaminated stormwater is defined as any wastewater which
comes in direct contact with waste receipts and waste handling or treatment areas.
      During site visits at CWT facilities, EPA identified many circumstances in which
uncontaminated stormwater is added to CWT wastewater for treatment or after treatment
but prior to effluent discharge monitoring.  In most  cases, the addition of stormwater
probably resulted in  dilution of the waste stream.   In some cases, stormwater,
contaminated or uncontaminated,  was used as solubilization water for wastes in the solid
phase to render the waste treatable in order to reduce water costs.

10.2  DETERMINATION OF SUBCATEGORIES

      Since 30 percent of facilities receive wastes which may be classified in more than
one subcategory, one  of the  most important  aspects of implementation is the
determination of which subcategory's limitations are  applicable to a facility's operation.
EPA recommends that permit writers and pretreatment authorities work  with CWT
facilities to assess the process for which wastes are accepted for treatment.  In Section
3, a process that many CWT facilities  used for waste acceptance is outlined.  This
process ensures  that CWT facilities are  aware of the types  of waste accepted for
treatment and the types of pollutants which are contained in the waste.
      After characterizing wastes accepted for treatment, the pollutant concentrations
listed in Table 10-1 may be used as a guide for determining the subcategory of wastes
accepted for treatment. It is important to note that various pollutants were detected in all
three subcategories. Organic pollutants were found in the Metals and Oils Subcategories
and metal  pollutants were detected in the Organics Subcategory.   Waste stream
subcategories are determined by the concentration levels reported. In developing the
regulation, EPA did not find any single waste receipt which could be classified in multiple
subcategories. This most probably would occur if waste streams were mixed by the waste
generator.
                                      10-2

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Table 10-1.  Pollutant Concentrations for Determination of Subcategory
  Metals Subcategory
            Oils Subcategory
Organics Subcategory
  If any of the following
  metals are found at a
  concentration greater
  than the values listed
  below:
 Aluminum
 Antimony
 Arsenic
 Barium
 Cadmium
 Chromium
 Cobalt
 Copper
 Lead
 Magnesium
 Manganese
 Mercury
 Molybdenum
 Nickel
 Tin
 Titanium
 Zinc
 1993mg/l
  1.6mg/l
  0.7 mg/l
  7.1 mg/l
  0.5 mg/l
  7.2 mg/l
  0.9 mg/l
 80.0 mg/l
 22.0 mg/l
  250 mg/l
 20.4 mg/l
0.007 mg/l
   13 mg/l
   62 mg/l
  6.3 mg/l
   21 mg/l
 94.5 mg/l
  If Total Cyanide is
  greater than 68 mg/l, in-
  facility monitoring after
  CN pretreatment is
  required.
            If the Oil & Grease
            concentration is greater
            than 700 mg/l.
If concentrations
detected are less than
the cut-offs for the
Metals and Oils
Subcategory.
      Permit writers and pretreatment authorities should also review the  types of

operations at a facility. Facilities which operate Oils Recovery and Metals Recovery are

included in the Oils Subcategory and Metals Subcategory, respectively. Oils  recovery

processes are typically chemical emulsion breaking processes where the addition of acid
or heat are used to break stable oil-water emulsions.  During the EPA sampling program,
                                      10-3

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stable oil-water emulsions were not sampled prior to treatment because  approved
analytical methods were not applicable for the waste type. Any wastewater generated
from an Oils Recovery process is classified as Oils Subcategory wastewater.

10.3  ESTABLISHING LIMITATIONS AND STANDARDS FOR FACILITY DISCHARGES
10.3.1
Facilities with One Operation
      The simplest case for establishing discharge limitations and standards is for
facilities classified in one CWT subcategory. If all water discharged is classified as CWT
wastewater, the limitations for the subcategory of concern are applied at the outfall or
discharge point.  Permit writers or pretreatment authorities should review the facility
wastewater sources to determine if any portion of the wastewater discharge results from
the treatment or addition of non-CWT wastewater (i.e., stormwater or other industrial
wastewater). The permit writer or pretreatment authority should determine the effluent
discharge limitation for each pollutant by flow-proportioning CWT limitations as illustrated
in Equation 10-1.
           tlMIT'
                _XCWT*FLOWCWT+XNON-CWT*FLOWNON-CWT
                               FLOW.
                                                           (40-1)
                                     TOTAL
where:
      XUMIT = Permit Discharge Concentration,
      XCWT = CWT Limitation,
      FLOWCWT = CWT Flow,
      XNON-CWT = Limitation for Non-CWT Waste Stream, and
                  = Non-CWT Flow.
                                     10-4

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      If the waste stream is added after treatment of the CWT waste stream occurs, the
permit writer or pretreatment authority many establish the discharge limitations prior to
the addition of the non-CWT waste stream.
10.3.2
Facilities with Operations Classified in Multiple Subcategories
      After facilities have been classified in multiple subcategories, permits may be
established based  on site specific configurations.   Facilities which  have separate
treatment systems for each of the waste steams may monitor for compliance with the
limitations after each of the separate treatment systems or may monitor for compliance
after mixing of the waste streams for discharge. When facilities mix the wastewater from
each separate treatment system, Equation 10-2 may be used to determine the discharge
limitations for each pollutant.  CWT facilities that mix the wastewater prior to discharge
but  after treatment  must demonstrate that limitations are being  achieved through
treatment not dilution. Therefore, if any pollutants are not detected at the discharge point,
analysis of the waste streams prior to mixing is required to ensure compliance with the
limitations and standards.
        XMETAL*FLOWMETAL+XOILS*FLOWOILS+XORGANICS*FLOWORGANICS
  '•LIMIT"
                                FLOW.
                                                             (50-1)
                                      TOTAL
where:
      XLIMIT = Permit Discharge Concentration,
      XMETALS = Metals Subcategory Limitation,
      FLOWMETALS = Metals Subcategory Flow,
      XQILS = Oils Subcategory Limitation,
      FLOWOILS = Oils Subcategory Flow,

                                       10-5

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      XORGANICS = Organics Subcategory Limitation, and
                    = Organics Subcategory Flow.
      Facilities which mix waste prior to complete treatment of the wastewater may also
use Equation 10-2  to  determine the discharge limitations for each pollutant, but
monitoring for compliance is more difficult.  The CWT facility must demonstrate to the
permit writer or pretreatment authority that the treatment system can achieve the effluent
limitations through treatment, not dilution.
      The first step  in determining if a treatment system can achieve the limitations is
analyzing the waste stream prior to addition with other wastes.  If pollutants of concern
for the waste type are detected after mixing of waste streams and the effluent discharge
limitations  are met, the CWT facility has demonstrated compliance.  If pollutants  of
concern for the waste type are not detected after mixing with other wastes, the  CWT
facility must demonstrate to the permit writer or pretreatment authority that the treatment
system  can achieve the effluent limitations  and standards.    CWT facilities  may
demonstrate that treatment systems can achieve the effluent limitations and standards in
various ways.  If the  treatment facility has any treatability studies for the design of the
treatment system which contain data on pollutant concentrations, this information may be
used.  Facilities may also submit data from text books which discuss the types  of
pollutants which are removed from the treatment technologies in place.  For example, a
facility classified in both the Metals and Organics subcategories may  have biological
treatment as the on-site treatment technology.  Various text books  on the design  of
biological treatment systems discuss the pollutants removed and the possible treatment
levels, but metal pollutants are not typically treated in biological treatment systems to any
appreciable level.  Therefore, the facility, in the above case, would be required to add
treatment for the metals portion of the waste stream to demonstrate compliance with the
effluent limitations  and standards.
      EPA identified many circumstances where additional treatment may be necessary
to demonstrate compliance. Many facilities accept metal-bearing and oily wastes.  The
                                      10-6

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wastewaterfrom Oils Recovery is typically mixed with the metal-bearing waste stream for
treatment in a metal precipitation process. The metals precipitation process may treat the
metal compounds detected  in both waste streams,  but  will  not treat the organic
constituents present in the oily waste stream. In many instances, the oily wastewater flow
is relatively small in comparison to the metal-bearing waste stream and mixing of the
waste streams results in pollutants of concern not being detected.  Therefore, when
establishing the permit for such an operation, a facility would  be required to demonstrate
compliance with the  effluent limitations  by submitting treatability data or technical
references to the  permit writer or pretreatment authority illustrating that the effluent
limitations are achievable in the on-site treatment system.  If the facility is  unable to
demonstrate compliance for the on-site treatment system, additional treatment would be
necessary to effectively treat the pollutants which are not treated in the present treatment
system.
                                       10-7

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                                   INDEX


Activated Sludge
      Technology Description (6-51)
      Treatment Performance (6-52)
Air Pollution Control Scrubber Blow-down (4-3)
Air Pollution Reduction Impacts (9-1)
Air Stripping
      Costs (7-21)
      Land Requirements (7-22)
      Oxidizer Catalyst Replacement Impacts (9-5)
      Technology Description (6-17)
      Treatment Performance (6-20)
Applicable Waste Streams (10-1)
Aqueous Waste Disposal Impacts (9-2)
BAT (1-3, 8-19)
      Costs (8-24)
BCT (1-2, 8-19)
      Costs (8-24)
Belt Pressure Filtration
      Technology Description (6-68)
      Treatment Performance (6-70)
Biotowers
      Technology Description (6-49)
      Treatment Performance (6-51)
BOD (4-7)
      Influent Concentration (4-8)
BPT(1-1)
      Costs (8-23)
      Established (8-1)
      Limitations - Metals Subcategory (8-6)
      Limitations - Oils Subcategory (8-11)
      Limitations - Organics Subcategory (8-16)
      Metals Subcategory - Rationale (8-3)
      Oils Subcategory - Rationale (8-9)
      Organics Subcategory - Rationale (8-14)

                                   INDEX-1

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BPT (continued)
      Technology Options - Metals Subcategory (8-4)
      Technology Options - Oils Subcategory (8-9)
      Technology Options - Organics Subcategory (8-14)
Carbon Adsorption
      Costs (7-24)
      Land Requirements (7-25)
      Spent Carbon Replacement Impacts (9-5)
      Technology Description (6-24)
      Treatment Performance (6-26)
Chemical Precipitation
      Costs (7-4)
      Land Requirements (7-8)
      Technology Description (6-2)
      Treatment Performance (6-5)
Chromium Reduction
      Costs (7-28)
      Land Requirements (7-30)
      Technology Description (6-33)
      Treatment Performance (6-36)
Clarification
      Costs (7-14)
      Land Requirements (7-16)
      Technology Description (6-10)
      Treatment Performance (6-10)
Cost Factors
      Capital (7-2)
      O & M (7-3)
Costs
      BCT/BAT (8-24)
      BPT (8-23)
      Capital, Explanation of (7-2)
      Filter Cake Disposal (7-36)
      Implementation (Es-4)
                                  INDEX-2

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Costs (continued)
      Land (7-41)
      Monitoring (7-38)
      0 & M, Explanation of (7-2)
      PSES (8-24)
      RCRA Permit Modification (7-40)
      Retrofit (7-38)
      Technology Options (8-22)
Current Performance (4-13)
      Metals Subcategory (4-13, 4-16)
      Oils Subcategory (4-18)
      Organics Subcategory (4-21)
CWT Industry
      General Information (3-2)
      Location (3-2)
      Number of Facilities (3-2)
      Other Industrial Operations (3-3)
Cyanide Destruction
      Costs (7-26)
      Land Requirements (7-27)
      Technology Description (6-30)
      Treatment Performance (6-33)
Discharge Information
      Comparison of Total Facility Discharge (4-4)
      Distribution of Facilities (3-8)
      Options Used (3-8)
      Pollutants (4-13)
      Quantity Discharged (3-9)
      Quantity Discharged in 1989 (3-9)
Dissolved Air Flotation
      Technology Description (6-42)
      Treatment Performance (6-45)
Electrolytic Recovery
      Technology Description (6-36)
      Treatment Performance (6-37)
                                   INDEX-3

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Emulsion Breaking
      Technology Description (6-14)
      Treatment Performance (6-16)
Energy Requirements Impacts (9-6)
Equalization
      Costs (7-20)
      Land Requirements (7-21)
      Technology Description (6-16)
      Treatment Performance (6-17)
Equipment Washes (4-3)
Facility Statistics
      Wastes Receipts (3-3)
Filter Cake Disposal
      Costs (7-36)
      Impacts (9-3)
Gravity Separation
      Technology Description (6-41)
      Treatment Performance (6-42)
Impacts
      Air Pollution Reductions (9-1)
      Air Stripper Oxidizer Catalyst Replacement (9-5)
      Energy Requirements (9-6)
      Filter Cake Disposal (9-3)
      Labor Requirements (9-7)
      Non-water Quality (9-1)
      Reverse Osmosis Concentrate Disposal (9-3)
      Solid and Other Aqueous Waste Disposal (9-2)
      Spent Carbon Replacement (9-5)
      Ultrafiltration Concentrate Disposal (9-4)
Implementation (10-1)
      Applicable Waste Streams (10-1)
      Determination of Subcategories (10-2)
      Establishment of Limitations (10-4)
                                   INDEX-4

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Influent Concentrations
      Metal Pollutants (4-10)
      Organic Pollutants (4-11)
      Pollutant Parameters (4-8)
Ion Exchange
      Technology Description (6-37)
      Treatment Performance (6-41)
Laboratory-derived Wastewater (4-3)
Labor Requirements Impacts (9-7)
Lancy Filtration
      Technology Description (6-59)
      Treatment Performance (6-60)
Land Costs (7-41)
Limitations
      Cyanide Pretreatment (8-6)
      Metals Subcategory (8-6)
      Oils Subcategory (8-11)
      Organics Subcategory (8-16)
      Technology Basis (Es-2)
Liquid Carbon Dioxide Extraction
      Technology Description (6-62)
      Treatment Performance (6-64)
Metals Subcategory
      BPT - Rationale (8-3)
      Current Performance (4-13, 4-16)
      Influent Concentrations (4-8, 4-10, 4-11)
      Pollutants  Selected for Regulation (5-3)
      Technology Options (8-4)
Monitoring Costs (7-38)
Multi-media Filtration
      Costs (7-23)
      Land Requirements (7-24)
      Technology Description (6-21)
      Treatment Performance (6-22)
Non-water Quality Impacts (9-1)
NSPS (1-3, 8-20)

                                   INDEX-5

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Oil and Grease (4-7)
       Influent Concentration (4-8)
Oils Subcategory
       BPT - Rationale (8-9)
       Current Performance (4-18)
       Influent Concentrations (4-8, 4-10, 4-11)
       Pollutants Selected for Regulation (5-3)
      Technology Options (8-9)
Organics Subcategory
       BPT-Rationale (8-14)
       Current Performance (4-21)
       Influent Concentrations (4-8, 4-10, 4-11)
       Pollutants Selected for Regulation (5-3)
      Technology Options (8-14)
Pass-through Analysis
      50 Potw Study Data Base (5-8)
      Approach (5-7)
       Data Editing (5-9)
       Final Potw Removals (5-12)
       Results (5-14)
      Results - Metals Subcategory (5-16)
      Results - Oils Subcategory (5-17)
      Results - Organics Subcategory (5-18)
      RREL Treatability Data Base (5-9)
      Volatile Override (5-15)
pH (4-7)
Pipeline Exclusion (3-3)
Plate and Frame Pressure Filtration - Liquid Stream
      Costs (7-16), (7-19)
      Land Requirements (7-18), (7-19)
      Technology Description (6-12)
      Treatment Performance (6-14)
Plate and Frame Pressure Filtration - Sludge Stream
      Costs (7-34)
      Land Requirements (7-36)
      Technology Description (6-66)

                                   INDEX-6

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Plate and Frame Pressure Filtration - Sludge Stream (continued)
      Treatment Performance (6-68)
Pollutant Reductions (8-25)
      BPT (8-26)
      Conventional Pollutants (8-25)
      Direct Discharges (8-26)
      Indirect Discharges (8-27)
      Methodology (8-26)
      PSES (8-27)
Pollutants Excluded from Regulation
      Due to Ineffective Treatment (5-6)
      Due to Isolated Detection (5-4)
      Due to Low Concentrations (5-4)
      Due to No Analysis at Technology Option (5-5)
Pollutants Selected for Regulation (5-3)
      For Pretreatment Standards (5-6)
Priority and Non-conventional Pollutants (4-9)
Procedures for Receipt of Waste (3-6)
PSES (1-4, 8-21)
      Costs (8-24)
PSNS (1-4, 8-22)
Quantity of Waste (3-6)
Questionnaires
       Pre-test  (2-3)
      1991 Waste Treatment Industry Questionnaire (2-1, 2-2)
      Development (2-1)
      Distribution (2-4)
      DMQ(2-1,2-2)
RCRA Codes (3-4)
RCRA Permit Modification Costs (7-40)
Retrofit Costs (7-38)
Reverse Osmosis
      Concentrate Disposal Impacts (9-3)
      Costs (7-33)
      Land Requirements (7-34)
      Technology Description (6-56)

                                   INDEX-7

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Reverse Osmosis (continued)
      Treatment Performance (6-57)
Sampling Program (2-5)
      1989-1993(2-6)
      1994(2-9)
      Facility Selection Criteria (2-6)
      Metal-bearing Waste (2-7)
      Oily Wastes (2-7, 2-9)
      Organic Wastes (2-8)
      Pre-1989 (2-5)
      Sampling Episodes Procedures (2-8)
Secondary Precipitation
      Costs (7-10)
      Land Requirements (7-12)
      Treatment Performance (6-5)
Section 304(m) (1-5)
Selective Metals Precipitation
      Costs (7-8)
      Land Requirements (7-10)
      Technology Description (6-3)
      Treatment Performance (6-5)
Sequencing Batch Reactors
      Costs (7-30)
      Land Requirements (7-31)
      Technology Description (6-47)
      Treatment Performance (6-47)
Sic Code (3-3)
Solid Waste Disposal Impacts (9-2)
Solubilization Water (4-2)
Stormwater
      Contaminated (4-3)
      Quantity Discharged (4-3)
Subcategories
      Determination of (10-2)
      Metal-bearing Waste Treatment (3-13)
      Oily Waste Treatment (3-13)

                                   INDEX-8

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Subcategories (continued)
      Organic Waste Treatment (3-14)
Subcategorization (3-10)
      Development of Scheme (3-11)
      Proposed Scheme (3-12)
Tanker Truck/drum/roll-off Box Washes (4-2)
Tertiary Precipitation
      Costs (7-12)
      Land Requirements (7-14)
      Treatment Performance (6-5)
Treatment Residuals (3-9)
TSS (4-7)
      Influent Concentration (4-8)
Ultrafiltration
      Concentrate Disposal Impacts (9-4)
      Costs (7-31)
      Land Requirements (7-32)
      Technology Description (6-54)
      Treatment Performance (6-56)
Vacuum Filtration
      Technology Description (6-70)
      Treatment Performance (6-72)
Waste Form Codes (3-5)
Waste Oil Emulsion-breaking Wastewater (4-2, 4-3)
Waste Receipts (3-3, 4-2)
      Acceptance Procedures (3-6)
      Quantity (3-6)
Wastewater
      By Subcategory (4-6)
      Characterization (4-6)
      Sources (4-1)
                                   1NDEX-9

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Appendix A. RCRA and Waste Form Codes Reported by Facilities in 1989

RCRA Codes
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D011
D012

D017
D035
F001
F002
F003
Ignitable Waste
Corrosive Waste
Reactive Waste
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endrin(1,2,3,4,10,1O-hexachloro-1,7-epoxy-1,4,4a,5,6,7,8,8a-
oct3hydro-1,4-endo-5,8-dimeth-3no-napthalene)
2,4,5-TP Silvex (2,4,5-trichlorophenixypropionic acid)
Methyl ethyl ketone
The following spent halogenated  solvents used in degreasing:
tetrachloroethylene;  trichloroethane;  carbon  tetrachloride  and
chlorinated fluorocarbons and all spent solvent mixtures/blends used
in degreasing containing, before use, a total of 10 percent or more
(by volume) of one or more of the above halogenated solvents or
those solvents listed in F002, F004, and F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures
The following spent halogenated solvents: tetrachloroethylene; 1,1,1-
trichloroethane; chlorobenzene; 1,1,2-trichloro-1,2,2-trifluoroethane;
ortho-dichlorobenzene;   trichloroethane;   all   spent     solvent
mixtures/blends containing, before use, a total of 10 percent or more
(by volume) of one or more of the above halogenated solvents or
those solvents listed in F001, F004, and F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures
The following spent nonhalogenated solvents; xylene, acetone, ethyl
acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl
alcohol,  cyclohexanone,  and  methanol;  all  spent    solvent
mixtures/blends containing, before use, one or more of the above
nonhalogenated solvents, and a total of 10 percent or more (by
volume) of one or more of those solvents listed in F001, 002, F004,
and F005; and still bottoms from the recovery of these spent solvents
and spent solvent mixtures.
                                      A-1

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Appendix A. RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)
RCRA Codes (continued)
F004
F005
F006
F007
F008

F009

F010

F011

F012

F019

F039
K001

K011

K013
The following spent nonhalogenated solvents: cresols, cresylic acid,
and nitrobenzene; and the still bottoms from the recovery of these
solvents; all spent solvent mixtures/blends containing before use a
total of 10 percent or more (by volume) of one or more of the above
nonhalogenated solvents or those solvents listed in F001, F002, and
F005; and still bottoms from the recovery of these spent solvents and
spent solvent mixtures
The following spent nonhalogenated solvents:  toluene, methyl ethyl
ketone,  carbon  disulfide,  isobutanol,  pyridine,  benzene,   2-
ethoxyethanol, and 2-nitropropane;  all spent solvent mixtures/blends
containing, before use, a total of 10 percent or more (by volume) of
one or more of the above nonhalogenated solvents or those solvents
listed in F001, F002, or F004; and  still bottoms from the recovery of
these spent solvents and spent solvents mixtures
Wastewater treatment sludges from electroplating operations except
from the following processes: (1) sulfuric acid anodizing of aluminum;
(2) tin plating on carbon steel; (3) zinc plating (segregated basis) on
carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel:
(5) cleaning/stripping associated with tin, zinc, and aluminum plating
on carbon steel; and (6) chemical etching and milling of aluminum
Spent cyanide plating bath solutions from electroplating operations
Plating bath residues from the  bottom  of  plating  baths from
electroplating operations in which cyanides are used in the process
Spent stripping  and cleaning bath solutions from electroplating
operations in which cyanides are used in the process
Quenching bath residues from oil baths from metal heat treating
operations in which cyanides are used in the process
Spent cyanide solutions from slat bath pot cleaning from metal heat
treating operations
Quenching waste water treatment  sludges from metal heat treating
operations in which cyanides are used in the process
Wastewater treatment sludges from the chemical conversion coating
of aluminum
Multi-source leachate
Bottom sediment sludge from the treatment of wastewater from wood
preserving processes that use creosote and/or pentachldrophenol
Bottom stream  from the  wastewater stripper  in the production of
acrylonitrile
Bottom stream  from the  acetonitrile column in the production of
acrylonitrile
                                      A-2

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Appendix A. RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)
RCRA Codes (continued)
K014

K015
K016

K031

K035

K044

K045
K048
K049
K050

K051
K052
K061

K064

K086
K093

K094

K098
K103
K104

P011
P012

P013
P020
P022
Bottoms from the acetonitrile purification column in the production of
acrylonitrile
Still bottoms from the distillation of benzyl chloride
Heavy ends or distillation residues from the production of carbon
tetrachloride
By-product salts generated in the production of MSMA and cacodylic
acid
Wastewater treatment sludges  generated in the production of
creosote
Wastewater  treatment  sludges  from  the  manufacturing   and
processing of explosives
Spent carbon from the treatment of wastewater containing explosives
Dissolved air flotation (DAF) float from the petroleum refining industry
Slop oil emulsion solids from the petroleum refining industry
Heat exchanger bundle cleaning sludge from the petroleum refining
industry
API separator sludge from the petroleum refining industry
Tank bottoms (leaded) from the petroleum refining industry
Emission control dust/sludge from the primary production of steel in
electric furnaces
Acid plant blowdown slurry/sludge resulting from the thickening of
blowdown slurry from primary copper production
Solvent washes and sludges, caustic washes and sludges, or water
washes and sludges from cleaning tubs and equipment used in the
formulation  of  ink from pigments, driers, soaps, and stabilizers
containing chromium and lead
Distillation light ends from the production of phthalic anhydride from
ortho-xylene
Distillation bottoms from the production of phthalic anhydride from
ortho-xylene
Untreated process wastewater from the production of toxaphene
Process residues from aniline extraction from the production of aniline
Combined wastewater streams generated from nitrobenzene/aniline
production
Arsenic pentoxide (t)
Arsenic (III) oxide (t)
      Arsenic trioxide (t)
Barium cyanide
Dinoseb, Phenol,2,4-dinitro-6-(1 -methylpropyl)-
Carbon bisulfide (t)
                                      A-3

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Appendix A. RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)
RCRA Codes (continued)
P028

P029
P030
P040

P044
P048

P050


P063

P064

P069

P071

P074

P078

P087

P089

P098
P104
P106
P121
P123

U002

U003
      Carbon disulfide (t)
Benzene, (chloromethyl)-
      Benzyl chloride
Copper cyanides
Cyanides (soluble cyanide salts), not elsewhere specified (t)
0,0-diethy! 0-pyrazinyl phosphorothioate
      Phosphorothioic acid, 0,0-diethyl 0-pyrazinyl ester
Dimethoate (t)
      Phosphorodithioic acid,
      0,0-dimethyl S-[2-(methylamino)-2-oxoethyl]ester (t)
2,4-dinitrophenol
      Phenol,2,4-dinitro-
Endosulfan
      5-norbornene-2,3-dimethanol,
      1,4,5,6,7,7-hexachloro,cyclic sulfite
Hydrocyanic acid
      Hydrogen cyanide
Methyl isocyanate
      Isocyanic acid, methyl ester
2-methyllactonitrile
      Propanenitrile,2-hydroxy-2-methyl-
0,0-dimethyl 0-p-nitrophenyl phosphorothioate
      Methyl parathion
Nickel (II) cyanide
      Nickel cyanide
Nitrogen (IV) oxide
      Nitrogen dioxide
Osmium tetroxide
      Osmium oxide
Parathion (t)
      Phosphorothiotic acid,0,0-diethyl O-(p-nitrophenyl) ester (t)
Potassium cyanide
Silver cyanide
Sodium cyanide
Zinc cyanide
Toxaphene
      Camphene,octachloro-
2-propanone (i)
      Acetone  (i)
Ethanenitrile (i,t)
                                      A-4

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Appendix A. RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)

RCRA Codes (continued)
U008

U009

U012

U019
U020

U031

U044

U045

U052

U057
U069

U080

U092

U098

U105

U106

U107

U113

U118

U122

U125
      Acetonitrile (i,t)
2-propenoic acid (i)
      Acrylic acid (i)
2-propenenitrile
      Acrylonitrile
Benzenamine (i,t)
      Aniline (i,t)
Benzene (i,t)
Benzenesulfonyl chloride (c,r)
      Benzenesulfonic acid chloride (c,r)
1-butanol (i)
      N-butyl alcohol (i)
Methane, trichloro-
      Chloroform
Methane,chloro-(i,t)
      Methyl chloride (i,t)
Cresylicacid
      Cresols
Cyelohexanone (i)
Dibutyl phthalate
      1,2-benzenedicarboxylic acid, dibutyl ester
Methane, dichloro-
      Methylene chloride
Methanamine, N-methyl-(i)
      Dimethylamine (i)
Hydrazine, 1,1 -dimethyl-
      1,1 -dimethylhydrazine
2,4-dinotrotoluene
      Benzene, 1 -methyl-2,4-dinitro-
2,6-dinitrotoluene
      Benzene, 1-methyl-2,6-dinitro
Di-n-octyl phthalate
      1-2-benzenedicarboxylicacid, di-n-octyl ester
2-propenoic acid, ethyl ester (i)
      Ethyl acrylate (i)
2-propenoic acid, 2-methyl-, ethyl ester
      Ethyl methacrylate
Formaldehyde
      Methylene oxide
Furfural (i)
                                       A-5

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Appendix A. RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)

RCRA Codes (continued)
U134

U135

U139

U140

U150

U151
U154

U159

U161

U162

U188

U190

U205

U210

U213

U220

U226

U228

U239
      2-furancarboxaldehyde (i)
Hydrogen fluoride (c,t)
      Hydrofluoric acid (c,t)
Sulfur hydride
      Hydrogen sulfide
Ferric dextran
      Iron dextran
1-propanol, 2-methyl- (i,t)
      Isobutyl alcohol (i,t)
Melphalan
      Alanine, 3-[p-bis(2-chloroethyl)amino] phenyl-,L-
Mercury
Methanol (i)
      Methyl alcohol (i)
Methyl ethyl ketone (i,t)
      2-butanone (i,t)
4-methyl-2-pentanone (i)
      Methyl isobutyl ketone (i)
2-propenoic acid,2-methyl-,methyl ester (i,t) ,
      Methyl methacrylate (i,t)
Phenol
      Benzene,  hydroxy-
Phthalic anhydride
      1,2-benzenedicarboxylic acid anhydride
Selenium disulfide (r,t)
      Sulfur selenide (r,t)
Tetrachloroethylene
      Ethene,1,1,2,2-tetrachloro
Tetrahydrofuran  (i)
      Furan, tetrahydro- (i)
Toluene
      Benzene,  methyl-
1,1,1 -trichloroethane
      Methylchloroform
Trichloroethylene
      Trichloroethene
Xylene (i)
      Benzene,  dimethyl- (i,t)
                                      A-6

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Appendix A.  RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)

Waste Form Codes

B001        Lab packs of old chemicals only
B101        Aqueous waste with low solvent
B102        Aqueous waste with low other toxic organics
B103        Spent acid with metals
B104        Spent acid without metals
B105        Acidic aqueous waste
B106        Caustic solution with metals but no cyanides
B107        Caustic solution with metals and cyanides
B108        Caustic solution with cyanides but no metals
B109        Spent caustic
B110        Caustic aqueous waste
B111        Aqueous waste with reactive sulfides
B112        Aqueous waste with other reactives (e.g., explosives)
B113        Other aqueous waste with high dissolved solids
B114        Other aqueous waste with low dissolved solids
B115        Scrubber water
B116        Leachate
B117        Waste liquid mercury
B119        Other inorganic liquids
B201        Concentrated solvent-water solution
B202        Halogenated (e.g., chlorinated)  solvent
B203        Nonhalogenated solvent
B204        Halogenated/Nonhalogenated solvent mixture
B205        Oil-water emulsion or mixture
B206        Waste oil
B207        Concentrated aqueous solution  of other organics
B208        Concentrated phenol ics
B209        Organic paint, ink, lacquer, or varnish
B210        Adhesive or epoxies
B211        Paint thinner or petroleum distillates
B219        Other organic liquids
B305        "Dry" lime or metal hydroxide  solids chemically "fixed"
B306        "Dry" lime or metal hydroxide  solids not "fixed"
B307        Metal scale, filings, or scrap
B308        Empty or crushed metal drums or containers
B309        Batteries or Battery parts, casings, cores
B310        Spent solid filters or adsorbents
B312        Metal-cyanides salts/chemicals
B313        Reactive cyanides salts/chemicals
B315        Other reactive salts/chemicals

                                     A-7

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Appendix A.  RCRA and Waste Form Codes Reported by Facilities in 1989 (continued)
Waste Form Codes (continued)
B316
B319
B501
B502
B504
B505
B506
B507
B508
B510
B511
B513
B515
B519
B601

B603
B604
B605
B607
B608
B609
Other metal salts/chemicals
Other waste inorganic solids
Lime sludge without metals
Lime sludge with metals/metal hydroxide- sludge
Other wastewater treatment sludge
Untreated plating sludge without cyanides
Untreated plating sludge with cyanides
Other sludges with cyanides
Sludge with reactive sulfides
Degreasing sludge with metal scale or filings
Air pollution control device sludge (e.g., fly ash, wet scrubber sludge)
Sediment or lagoon dragout contaminated with inorganics only
Asbestos slurry or sludge
Other inorganic sludges
Still bottoms of halogenated (e.g., chlorinated) solvents or other organic
liquids
Oily sludge
Organic paint or ink sludge
Reactive or polymerized organics
Biological treatment sludge
Sewage or other untreated biological sludge
Other organic sludges
                                     A-8

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Appendix B.  Initial Pollutants Included in Sampling Program
Conventional/Non-Conventional
Amenable Cyanide
Ammonia as N
BOD
COD
Total Cyanide
d-COD
Fluoride
Nitrate-nitrite as N
Oil + Grease

Dioxins/Furans
Octachlorodibenzo-p-dioxin
Octochlorodibenzo-furan
Total Heptachlorodibenzo-p-dioxin
Total Heptachlorodibenzofurans
Total Hexachlorodibenzo-p-dioxins
Total Hexachlorodibenzo-furans
Total Pentachlorodibenzo-p-dioxins
Total Pentachlorodibenzofurans
Total Tetrachlorodibenzo-p-dioxins
Total Tetrachlorodibenzo-furans
1,2,3,4,6,7,8-heptachloro-
      benzo-p-dioxin
1,2,3,4,6,7,8-neptachloro-dibenzofuran
PH
Sulfide, Total
TOC
TOX
TSS
Hexavalent Chromium
Total Phenols
Total Phosphorus
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
1,2,3,4,7,8-hexachlorodibenzofuran
1,2,3,4,7,8,9-heptachlorodibenzofuran
1,2,3,6,7,8-hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-heptachlordibenzofuran
1,2,3,7,8-pentachlorodibenzo-p-dioxin
1,2,3,7,8-pentachlorodibenzofuran
1,2,3,7,8,9-hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-hexachlorodibenzofuran
2,3,4,6,7,8-hexachlorodibenzofuran
2,3,4,7,8-pentachlorodibenzofuran
2,3,7,8-tetrachlorodibenzo-p-dioxin
2,3,7,8-tetrachlorodibenzofuran
Alcohol/Formaldehydes
Ethanol
Formaldehyde
Methanol
Pentachlorophenol
Tetrachlorocatechol
Tetrachloroguaiacol
Trichlorosyringol
2-syringealdehyde
2,3,4,6-tetrachlorophenol
2,3,6-trichIorophenoI
2,4-dichlorophenol
2,4,5-trichlorophenol
2,4,6-trichlorophenol
2,6-dichlorophenol
3,4-dichlorophenol
3,4,5-trichlorocatechol
3,4,6-trichloroguaiacol
3,5-dichlorocatecol
3,5-dichlorophenol
3,6-dichlorocatechol
4-chlorophenol
4,5-dichlorocatechoI
4,5-dichloroguaiacol
4,5,6-trichloroguaiacol
4,6-dichloroguaiacol
5-chloroguaiacoI
5,6-dichlorovanilIin
6-chlorovanillin
                                       B-1

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Appendix B.  Initial Pollutants Included in Sampling Program (continued)
Metals
Aluminum
Antimony
Arsenic
Barium
Beryllium
Bismuth
Boron
Cadmium
Calcium
Cerium
Chromium
Cobalt
Copper
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
indium
Iodine
Indium
Iron
Lanthanum
Lead
Lithium
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Neodymium

Organics
Acenaphthene
Acenaphthylene
Acetophenone
Acrylonitrile
Nickel
Niobium
Osmium
Palladium
Phosphorus
Platinum
Potassium
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Tin
Titanium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zinc
Zirconium
Alpha-terpineol
Aniline
2,4,5-trimethylaniline
Anthracene
                                     B-2

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Appendix B. Initial Pollutants Included in Sampling Program (continued)
Organics (continued)
Aramite
Benzanthrone
Benzene
Benzenethiol
Benzidine
Benzo(a)antracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzoic Acid
Benzonitrile,3,5-dibromo-4-hydroxy
Benzyl Alcohol
Beta-naphthylamine
Biphenyl
Biphenyl,4-nitro
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
Bromodichloromethane
Bromomethane
Butanone
Butyl Benzyl Phthalate
Carbazole
Carbon Disulfide
Chloroacetonitrile
Chlorobenzene
Chloroethane
Chloroform
Chloromethane
Chrysene
cis-1,3-dichloropropene
Crotonaldehyde
Crotoxyphos
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Di-n-propylnitrosamine
Dibenzo(a, h)anthracene
Dibenzofuran
Dibenzothiophene
Dibromochloromethane
Dibromomethane
Diethyl Ether
Diethyl Phthalate
Dimethyl Phthalate
Dimethyl Sulfone
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Pentachloroethane
Ethyl Cyanide
Ethyl Emthacrylate
Ethyl Methanesulfonate
Ethyl Benzene
Ethylene Thiourea
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene
Hexanoic Acid
lndeno(1,2,3-cd)pyrene
lodomethane
Isobutyl Alcohol
Isophorone
Isosafrole
Longifolene
m-Xylene
Malachitegreen
Mestranol
Methapyrilene
Methyl Methacrylate
Methyl Methane Sulfonate
Methylene Chloride
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
                                     B-3

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Appendix B. Initial Pollutants Included in Sampling Program (continued)
Organics (continued)
n-Nitrosodi-n-butylamine
n-Nitrosodiethylamine
n-Nitrosodimethylamine
n-Nitrosodiphenylamine
n-Nitrosomethyiethylamine
n-Nitrosomethylphenylamine
n-Nitrosomorpholine
n-Nitrosopiperidine
n-Octacosane
n-Octadecane
n-Tetracosane
n-Tetradecane
n-Triacontane
n,n-Dimethylformamide
Naphthalene
Nitrobenzene
o+p-Xylene
o-Anisidine
o-Cresol
o-Toluidine
o-Toluidine,5-chloro-
p-Chloroaniline
p-Cresol
p-Cymene
p-Dimethylaminoazobenzo
p-Nitroaniline
Pentachlorobenzene
Pentachlorophenol
Pentamethylbenzene
Perylene
Phenacetin
Phenanthrene
Phenol
Phenol,2-methyl-4,6-dinitro
Phenol Thiazine
Pronamide
Pyrene
Pyridine
Resorcinol
Safrole
Squalene
Styrene
Tetrachloroethene
Tetrachloromethane
Thianaphthene
Thioacetamide
Thioxanthe-9-one
Toluene
Toluene,2,4-diamino
trans-1,2-dichloroethene
trans-1,3-dichloropropene
trans-1,4-dichloro-2-butene
Tribromomethane
Trichloroethene
Trichlorofluoromethane
Triphenylene
Tripropyleneglycol Methyl Ether
Vinyl Acetate
Vinyl Chloride
1 -Bromo-2-chlorobenzene
1 -Bromo-3-chlorobenzene
1-Chloro-3-nitrobenzene
1-Methyl Fluorene
1 -Methylphenanthrene
1-Naphthylamine
1-Phenyl Naphthalene
1,1-Dichloroethane
1,1-Dichloroethene
1,1,1 -Trichloroethane
1,1,1,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
1,2-Dibromo-3-chloropropane
1,2-Dibromoethane
1,2-Dichlorobenzene
1,2-Dichloroethane
1,2-Dichloropropane
1,2-Diphenyl Hydrazine
1,2,3-Trichlorobenzene
1,2,3-Trichloropropane
1,2,3-Trimethoxybenzene
1,2,4-Trichlorobenzene
                                      B-4

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Appendix B. Initial Pollutants Included in Sampling Program (continued)
Organics (continued)
1,2,4,5-Tetrachlorobenzene
1,2:3,4-Diepoxybutane
1,3-Butadiene,2-chloro-
1,3-Dichloro-2-propanol
1,3-Dichlorobenzene
1,3-Dichloropropene
1,3,5-Trithiane
1,4-Dichlorobenzene
1,4-Dinitrobenzene
1,4-Dioxane
1,4-Naphthoquinone
1,5-Naphthalenediamine
2-(Methylthio)benzothiazole
2-Chloroethylvinyl Ether
2-Chloronaphthalene
2-Chlorophenol
2-Hexanone
2-lsopropylnaphthalene
2-Methylbenzothiozole
2-Methylnaphthalene
2-Nitroaniline
2-Nitrophenol
2-PhenylnaphthaIene
2-Picoline
2-Propanone
2-Propen-1-ol
2-Propenal
2-Propenenitrile,z-methyl-
2,3-Benzofluorene
2,3-Dichloroaniline
2,3-Dichloronitrobenzene
2,3,4,6-Tetrachlorophenol
2,3,6-TrichlorophenoI
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,6-di-tert-butyl-p-benzoquinone
2,6-Dichloro-4-nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
3-Chloropropene
3-Methylchlolanthrene
3-Nitroaniline
3,3'-Dichlorobenzidine
3,3'-Dimethoxybenzidine
3,6-Dimethylphenanthrene
4-Aminophenyl
4-Bromophenyl Phenyl  Ether
4-Chloro-2-nitroaniline
4-Chloro-3-methylphenol
4-Chlorophenylphenyl Ether
4-Methyl-2-pentanone
4-Nitrophenol
4,4'-Methylenebis(2-chloroaniline)
4,5-Methyline Phenanthrene
5-Nitro-o-toluidine
7,12-Dimethyl  Benz(a)anthracene
Pesticides/Herbicides
a-Chlordane
Acetic Acid(2,4-dichlorophenoxy)
Aldrin
Alpha-bhc
Azinphos-ethyl
Azinphos Methyl
Beta-bhc
Carbophenothion(trithion)
Chlorobenzilate
Chlorofenvinphos
Chorpyrifos
Coumaphos
Crotoxyphos-cgc/fpd
Dalapon
Delta-bhc
Demeton
Diallate
Diazinon
Dicamba
Dichlorofeuthion
                                      B-5

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Appendix B. Initial Pollutants Included in Sampling Program (continued)
Pesticides/Herbicides
Dichlorprop
Dichlorvos
Dicrotophos(bidrin)
Dieldrin
Dimethoate
Dioxathion
Disulfoton
Endosultan Sulfate
Endosulfan-i
Endosulfan-ii
Endrin
Endrin Aldehyde
Endrin Ketone
Ethion
Ethoprop
Famphur
Fensulfothion
Funthion
G-chlordane
Heptachlor
Heptachlor Epoxide
Isodrin
Leptophos
Lindane(gamma-bhc)
Malathion
Mcpa
Mcpp
Merphos a
Merphos B (Def)
Methoxychlor
Methyl Chlorpyrifos
Methyl Parathion
Methyl Trithion
Mevinphos(phosdrin)
Mirex
Monocrotophos
Naled(dibrom)
Nitrofen(tok)
Parathion
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
Pentachloronitrobenzene
Phorate
Phosmet
Phosphamidone
Phosphamidon Z
Ronnel
Santox(epn)
Sulprofos
Terbufos
Tetrachlorinphos
Tetraethyldithiopyrophosphate
Toxaphene
Trichloronate
Trifluralin(treflan)
2-Sec-butyl-4,6-dinitrophenol
2,4-DB
2,4,5-TrichlorophenoxyaceticAcid
2,4,5-TrichlorophenoxypropionicAcid
4,4'-DDD
4,4'-DDE
4,4'-DDT
Captafol
Captan
Kepone
Phosphamidon
Phosphoric Acid.trimethyl Ester
Phphoric Acid,tri-o-tolye Ester
Phosphoric Triamide.hexamethyl
TEPP
Trichlor Fon
1,4-Naphthoquinone,2,3-dichloro
Dithiocarbamate Anion
                                     B-6

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APPENDIX C.
ACRONYMS AND DEFINITIONS
Administrator-"The Administrator of the U.S. Environmental Protection Agency.
Agency-The U.S. Environmental Protection Agency.
Average monthly discharge limitation -  The highest  allowable average of "daily
discharges" over a calendar  month, calculated as  the sum of all "daily discharges"
measured  during the calendar month divided by the number of "daily discharges"
measured during the month.
BAT - The best available technology economically achievable, as described in Sec.
304(b)(2) oftheCWA.
BCT- The best conventional pollutant control technology, as described in Sec. 304(b)(4)
oftheCWA.
BOD5 - Biochemical oxygen demand - Five Day. A measure of biochemical decomposition
of organic matter in a water sample. It is determined by measuring the dissolved oxygen
consumed by microorganisms to oxidize the organic contaminants in a water sample under
standard laboratory conditions of five days and 70ฐC. BOD5 is not related to the oxygen
requirements in chemical combustion.
BPT - The  best practicable control technology currently available, as described in Sec.
304(b)(1) oftheCWA.
Centralized waste treatment facility - Any facility that treats any hazardous or non-
hazardous  industrial wastes received from off-site by tanker truck,  trailer/roll-off bins,
drums, barge, or other forms of shipment. A "centralized waste treatment facility" includes
1) a facility that treats waste received from off-site exclusively and 2) a facility that treats
wastes generated on-site as well as waste received from off-site.
Centralized waste treatment wastewater - Water that comes in contact with wastes
received from off-site for treatment or recovery or that comes in contact with the area in
which the off-site wastes are received, stored or collected.
Clarifier-A. treatment unit designed to remove suspended materials from wastewater-
typically by  sedimentation.
COD - Chemical oxygen demand. A bulk parameter that measures the oxygen-consuming
capacity of refractory organic and inorganic matter present in water or wastewater. COD
is expressed as the amount of oxygen consumed from a chemical oxidant in a specific test.
Commercial facility - Facilities that accept waste from off-site for treatment from facilities
not under the same ownership  as their facility.
                                     C-1

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 APPENDIX C.      ACRONYMS AND DEFINITIONS (continued)
 Conventional pollutants-The pollutants identified in Sec. 304(a)(4) of the CWA and the
 regulations thereunder (biochemical oxygen demand (BOD5), total  suspended solids,
 (TSS), oil and grease, fecal coliform, and pH).
 CWA - Clean Water Act. The Federal Water Pollution Control Act Amendments of 1972
 (33 U.S.C. 1251 et seq.), as amended, inter alia, by the Clean Water Act of 1977 (Public
 Law 95-217) and the Water Quality Act of 1987 (Public Law 100-4).
 CWT- Centralized Waste Treatment
 Daily discharge - The discharge of a pollutant measured during any calendar day or any
 24-hour period that reasonably represents a calendar day.
 Direct  discharger - A facility that discharges or may discharge treated or untreated
 pollutants into waters of the United States.
 Effluent - Wastewater discharges.
 Effluent limitation - Any restriction, including schedules of compliance, established by a
 State or the Administrator on quantities, rates, and concentrations of chemical, physical,
 biological, and other constituents which are discharged from point sources into navigable
 waters, the waters of the contiguous zone,  or the ocean.  (CWA Sections 301 (b) and
 304(b).)
 EPA - The U.S. Environmental Protection Agency.
 Facility- A facility is all contiguous property owned, operated, leased or under the control
 of the same person. The contiguous property may be divided by public or private right-of-
 way.
 Fuel Blending - The process of mixing organic waste for the purpose of generating a fuel
 for reuse.
 Indirect discharger- A facility that discharges or may discharge pollutants into a publicly-
 owned treatment works.
 LTA - Long-term average.  For purposes of the effluent guidelines,  average pollutant
 levels achieved over a period of time by a facility,  subcategory, or technology option.
 LTAs were  used in developing  the limitations and standards in today's  proposed
 regulation.
 Metal-bearing wastes - Wastes that contain  metal pollutants from  manufacturing or
 processing facilities or other commercial operations.  These wastes may include, but are
 not limited to, the following: process wastewater, process residuals such as tank bottoms
or stills and process wastewater treatment residuals,  such as treatment sludges.
New Source - "New source" is defined at 40 CFR 122.2 and 122.29.

                                      C-2

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 APPENDIX C.      ACRONYMS AND DEFINITIONS (continued)


 Non-commercial facility - Facilities that accept waste from off-site for treatment only from
 facilities under the same ownership as their facility.
 Non-conventional pollutants - Pollutants that are neither conventional pollutants nor
 priority pollutants listed at 40 CFR Section 401.
 NPDES - The National Pollutant Discharge Elimination System authorized under Sec. 402
 of the CWA.  NPDES requires permits for discharge of pollutants from any point source
 into waters of the United States.
 NSPS - New Source Performance Standards.
 OCPSF - Organic  Chemicals, Plastics, and Synthetic  Fibers Manufacturing Effluent
 Guideline.
 Off-Site - "Off-site" means outside the boundaries of a facility.
 Oily Wastes  - Wastes that contain  oil and grease from manufacturing  or processing
 facilities or other commercial operations. These wastes may include, but are not limited
 to, the following: spent lubricants, cleaning fluids, process wastewater, process residuals
 such  as tank bottoms or stills and process wastewater treatment residuals, such  as
 treatment sludges.
 On-site - "On-site" means within the boundaries of a facility.
 Organic-bearing Wastes - Wastes that contain organic pollutants from manufacturing or
 processing facilities or other commercial operations.  These wastes may include, but are
 not limited to, process wastewater, process residuals such  as tank bottoms or stills and
 process wastewater treatment residuals, such as treatment sludges.
 Outfall - The mouth of conduit drains and  other conduits from which a facility effluent
 discharges into receiving waters.
 Pipeline -  "Pipeline" means an open or closed conduit used for the conveyance of
 material. A pipeline includes a channel, pipe, tube, trench or ditch.
 Point source category - A category of sources of water pollutants.
 Pollutant (to water) - Dredged spoil, solid waste, incinerator residue, filter backwash,
 sewage, garbage, sewage sludge, munitions,  chemical wastes, biological materials, certain
 radioactive materials, heat, wrecked or discarded equipment, rock, sand, cellar dirt, and
 industrial, municipal, and agricultural waste  discharged into water.
POTWorPOTWs - Publicly-owned treatment works, as defined at 40 CFR 403.3(0).
 Pretreatment standard - A regulation that establishes industrial wastewater effluent quality
required for discharge to a POTW. (CWA Section 307(b).)
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APPENDIX C.
ACRONYMS AND DEFINITIONS (continued)
Priority pollutants - The pollutants designated by EPA as priority in 40 CFR Part 423
Appendix A.
Process wastewater- "Process wastewater" is defined at 40 CFR 122.2.
PSES - Pretreatment standards for existing sources of indirect discharges, under Sec.
307(b)oftheCWA.
PSNS - Pretreatment standards for new sources of indirect discharges, under Sec. 307(b)
and(c)oftheCWA.
RCRA - Resource Conservation and Recovery Act (PL 94-580) of 1976, as amended.
SIC- Standard Industrial Classification (SIC). A numerical categorization system used by
the U.S. Department of Commerce to catalogue economic activity.  SIC codes refer to the
products, or group of products, produced or distributed, or to services rendered by an
operating establishment. SIC codes are used to group establishments by the economic
activities in which they are engaged.  SIC  codes often  denote  a facility's primary,
secondary, tertiary, etc. economic activities.
Solidification - The addition of agents to convert liquid or semi-liquid hazardous waste
to a solid before burial to reduce the leaching of the waste material and the possible
migration  of the waste  or  its constituent from the facility.   The process  is usually
accompanied by stabilization.
Stabilization - A hazardous waste  process that  decreases the mobility of waste
constituents by means other than solidification.  Stabilization techniques include mixing
the waste with sorbents such as fly ash to remove free liquids.  For the purpose of this
rule, chemical precipitation is not a technique for stabilization.
TSS - Total Suspended Solids.  A measure of the amount of particulate matter that is
suspended in a water sample.  The measure is obtained by filtering a water  sample of
known volume. The particulate material retained on the filter is then dried and weighed.
Variability factor-The daily  variability factor is the ratio of the estimated 99th  percentile
of the distribution of daily values divided by the expected value, median or mean, of the
distribution of the daily data. The monthly variability factor is the estimated 95th  percentile
of the distribution of the monthly averages of the data divided by the expected value of the
monthly averages.
Waste Receipt - Wastes received for treatment or recovery.
Wafers of the United States - The same meaning set forth in 40 CFR 122.2.
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APPENDIX C.
ACRONYMS AND DEFINITIONS (continued)
Zero discharge - No discharge of pollutants to waters of the United States or to a POTW.
Also included in this definition are discharge of pollutants byway of evaporation, deep-well
injection, off-site transfer, and land application.
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