United States Office of Water EPA821-R-98-017
Environmental Protection (4303) December 1998
Agency
&EPA Environmental Assessment For
The Proposed Effluent Limitations
Guidelines, Pretreatment Standards,
And New Source Performance
Standards For The Centralized Waste
Treatment Industry
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ENVIRONMENTAL ASSESSMENT FOR THE
PROPOSED EFFLUENT LIMITATIONS GUIDELINES, PRETREATMENT
STANDARDS, AND NEW SOURCE PERFORMANCE STANDARDS FOR
THE
CENTRALIZED WASTE TREATMENT INDUSTRY
December 1998
U.S. Environmental Protection Agency
Office of Science and Technology
Standards and Applied Science Division
401 M Street, S.W.
Washington, D.C. 20460
Charles Tamulonis
Task Manager
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ACKNOWLEDGMENTS AND DISCLAIMER
The Standards and Applied Science Division, Office of Science and Technology, has reviewed and
approved this report for publication. The Office of Science and Technology directed, managed,
and reviewed the work of Aqua Terra in preparing this report. Neither the United States
Government nor any of its employees, contractors, subcontractors (Tetra Tech, Inc.), or their
employees make any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of or the results of such use of any information, apparatus,
product, or process discussed in this report, or represents that its use by such party would not
infringe on privately owned rights.
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Table of Contents
Executive Summary ES-1
1.0 Introduction 1-1
2.0 Methodology 2-1
2.1 Estimating In-Stream Concentrations 2-2
2.1.1 Direct Discharging Facilities 2-2
2.1.2 Indirect Discharging Facilities 2-5
2.2 Estimating POTW Effects 2-6
2.3 Assumptions and Caveats 2-8
2.4 Conducting Documented Environmental Effects 2-10
2.5 Estimating Toxic Effects 2-10
2.5.1 Estimating Effects on Aquatic Life 2-10
2.5.2 Estimating Effects on Human Health 2-10
2.6 Estimating Human Health Risk Associated with Consumption of Lead- Contaminated
Fish 2-14
3.0 Data Sources 3-1
3.1 Facility-Specific Data 3-1
3.2 Information Used to Evaluate POTW Operations 3-2
3.3 Water Quality Criteria 3-2
3.3.1 Aquatic Life 3-5
3.3.2 Human Health 3-7
4.0 Results 4-1
4.1 Projected Water Quality Impacts 4-1
4.1.1 Combined Environmental Effects of 95 CWT Facilities at Baseline and with
Proposed Limits 4-4
4.1.2 Metals Subcategory 4-5
4.1.3 Oils Subcategory 4-11
4.1.4 Organics Subcategory 4-16
4.2 Documented Environmental Effects 4-19
4.2.1 Permit Violations of CWT Facilities 4-19
4.2.2 Effects of CWT Wastes on POTW Operations and Water Quality 4-19
5.0 References 5-1
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Table of Contents (continued)
APPENDICES
A: Dilution Concentration Potential Values A-l
B: Toxicological Information B-l
C: Pollutants of Concern C-l
D: Documented Environmental Effects D-l
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List of Tables
Page No.
Table ES-1 Summary of Non-Scaled Environmental Effects of 95 CWT Facilities ES-2
Table ES-2 Technology Basis for Selected Options ES-3
Table 1-1 Technology Basis for Selected Options 1-1
Table 3-1 POTW Removals and Biological Inhibition Concentrations 3-3
Table 3-2 POTW Biosolids Pollutant Concentration Criteria 3-5
Table 4-1 The 105 Pollutants of Concern for the CWT Industry 4-2
Table 4-2 Summary of Non-Scaled Environmental Effects of 95 CWT Facilities 4-4
Table 4-3 Annual Reductions in Lead Related Health Effects From Reducing Lead
Exposure of 91,000 People Potentially Impacted by CWT Dischargers 4-5
Table 4-4 Metals Subcategory - Summary of Pollutant Loadings 4-5
Table 4-5 Metals Subcategory - Estimated Annual Reduction of Lead Related Health Effects .... 4-6
Table 4-6 Metals Subcategory - Environmental Effects of Eight Direct Dischargers 4-7
Table 4-7 Metals Subcategory - Projected Criteria Contraventions for Eight Direct
Dischargers 4-7
Table 4-8 Metals Subcategory - Pollutants Projected to Exceed Criteria for Eight Direct 4-8
Table 4-9 Metals Subcategory - Environmental Effects of 37 Indirect Dischargers 4-9
Table 4-10 Metals Subcategory - Projected Criteria Contraventions for 37 Indirect
Dischargers 4-10
Table 4-11 Metals Subcategory - Pollutants Projected to Exceed Criteria for 37 Indirect
Dischargers 4-10
Table 4-12 Metals Subcategory - Projected POTW Inhibition Problems from 37 Indirect
Dischargers 4-11
Table 4-13 Oils Subcategory - Summary of Pollutant Loadings 4-12
Table 4-14 Oils Subcategory - Estimated Annual Reduction of Lead Related Health Effects 4-12
Table 4-15 Oils Subcategory - Environmental Effects of One Direct Discharging CWT
Facility 4-13
iii
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List of Tables (continued)
Page No.
Table 4-16 Oils Subcategory - Environmental Effects of 63 Indirect Dischargers 4-14
Table 4-17 Oils Subcategory - Projected Criteria Contraventions for 63 Indirect Dischargers .... 4-14
Table 4-18 Oils Subcategory - Pollutants Projected to Exceed Criteria for 63 Indirect
Dischargers 4-15
Table 4-19 Oils Subcategory - Projected POTW Inhibition Problems from 63 Indirect
Dischargers 4-16
Table 4-20 Organics Subcategory - Pollutant Loadings for 19 Dischargers 4-16
Table 4-21 Organics Subcategory - Environmental Effects of Four Direct Dischargers 4-17
Table 4-22 Organics Subcategory - Environmental Effects of 15 Indirect Dischargers 4-18
Table 4-23 Organics Subcategory - Projected Criteria Contraventions for 15 Indirect
Dischargers 4-18
Table 4-24 Organics Subcategory - Pollutants Projected to Exceed Criteria for Indirect
Dischargers 4-19
Table 4-25 Documented Environment Impacts of CWT Wastes on POTW Operations
and Water Quality 4-21
Table 4-26 CWT Facilities Included on State 304(L) Short Lists 4-22
Table 4-27 POTWs Which Receive Discharge From CWT Facilities and are Included
on State 304(L) Short Lists 4-23
Table A-1 Dilution Concentration Potential (DCP) Values for Specific Water
Bodies A-2
Table B-l Toxicity Values for the Contaminants Analyzed in the CWT Industry B-2
Table C-l Metals Subcategory - Pollutants of Concern C-2
Table C-2 Oils Subcategory - Pollutants of Concern C-3
Table C-3 Organics Subcategory - Pollutants of Concern C-4
Table D-1 Reported Permit Violations and Other Discharge Effects From CWT Facilities D-3
IV
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Executive Summary
This report assesses the water quality related benefits that would be expected if the U.S. Environmental
Protection Agency (EPA) adopts the proposed effluent limitations, guidelines and pretreatment standards for the
Centralized Waste Treatment (CWT) Industry. EPA estimates that under baseline conditions 205 CWT facilities
discharge approximately 5.22 million Ibs/year of metal and organic pollutants. Under the proposed rule this
pollutant loading would be reduced by 79% or to 1.08 million Ibs/year (see
Table ES-1).
Summary of Non-Scaled Environmental Effects
(a) Ambient Water Quality Effects
EPA analyzed the environmental effects of 95 of the 205 CWT facilities. The analysis comparing modeled
instream pollutant levels to Ambient Water Quality Criteria (AWQC) estimates that current discharge
loadings result in 110 contraventions at 18 receiving water locations. The proposed rule would reduce
pollutant loadings so that only 53 contraventions would occur at 13 receiving water locations.
(b) Human Health Effects
EPA estimates that CWT loadings from the 95 CWT facilities are responsible for 0.95 cancer cases per year.
The proposed rule would reduce this to 0.3 cases per year. In addition, an estimated 91,000 persons would
have reduced lead exposure and related health effects. EPA estimates the proposed rule would reduce lead
uptake enough to prevent the IQ loss of 72 points in children of recreational and subsistent anglers. EPA also
estimates that the IQs of 34 angler children would not drop below 70.
(c)POTW Effects
EPA estimates that six of the 64 Publically Owned Treatment Works (POTWs) analyzed experience
inhibition problems due to CWT wastes. The proposed rule would decrease this number by two. The
proposed rule will also improve biosolids quality of 4,100 metric tons.
(d) Basis of Conclusions
The report bases its conclusion about these benefits on site-specific analyses of current conditions and the
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conditions that would be achieved if EPA adopts the proposed Best Practicable Technology (BPT) currently
available / Best Available Technology (BAT) economically achievable and Pretreatment Standards for
Existing Sources (PSES) regulations. Under the proposed regulations, EPA would limit the discharges of
pollutants into navigable waters of the United States and the introduction of pollutants into POTWs from
existing sources and from new sources in three CWT subcategories. These categories are Metal-Bearing
Waste Treatment and Recovery Operations (metals), Used/Waste Oil Treatment and Recovery Operations
(oils), and Organic Waste Treatment (organics). Many CWT facilities treat or recover wastes in more than
one category
, l
Table ES-1. Summary of Non-Scaled Environmental Effects of 95 CWT Facilities '
Loadings (million Ibs/yr) b> c
AWQC Contraventions
Additional Cancer Cases/yr d
Population of 9 1,000
individuals exposed to lead
health effects d
Population of 19,000
individuals exposed to other
non-cancer effects d
POTWs experiencing
inhibition
Biosolid Quality
Current
5.22
110 at 18 streams
0.95
6 of 64
Proposal
1.08
53 at 13 streams
0.3
4 of 64
Summary
79% reduction
5 streams become "contaminant free" e
0.65 cases reduced each year
Annual benefits are:
Reduction of 1.6 cases of hypertension
Pro tection of 72 IQ points
Prevention of lowering of 34 children's
IQS below 70
Health effects to exposed population are
reduced
Potential inhibition eliminated at 2
POTWs
4, 1 00 metric tons improved
a. Modeled results which are not scaled represent ten direct and 85 indirect CWT waste water dischargers.
b. 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; conventional pollutants are
not included in the analysis.
c. Loadings are scaled to represent all 205 facilities.
d. Through consumption of contaminated fish tissue.
e. "Contaminant free" from CWT discharges; however potential contamination from other point source discharges and non-point
sources is still possible.
Many CWT facilities treat wastes from multiple subcategories. Therefore, EPA aggregated loadings from
each subcategory to estimate the combined environmental effects of the proposed rule.
ES-2
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Proposed Treatment Options
EPA selected the treatment technologies which form the basis of the proposed regulatory option from a larger
set of technology options based on several criteria, including efficiency of pollutant removal + cost and
impacts to CWT facilities. Chapter 9 of the technical development document discusses the technology basis
of each of the selected options for each of the proposed subcategories. Table ES-2 provides a summary of the
technology basis for the selected regulatory option.
Table ES-2. Technology Basis for Selected Options
Metals Suboategory a
BPT/BAT/PSES,b
Option 4:
Batch precipitation,
liquid solid separation,
secondary precipitation
and sand filtration
Oils Suboategojfy
BPT/BAT
Option 9:
Emulsion breaking,
gravity separation,
secondary gravity
separation and dissolved
air flotation
PSES
Option 8:
Emulsion breaking,
gravity separation, and
dissolved air flotation
Organics Sub^ategory
BPT/BAT /PSES
Option 4:
Equalization, and
biological treatment
a. For facilities in the cyanide subset of the metals subcategory, the technology basis is alkaline chlorination at specific operating
conditions.
b. Direct dischargers are covered by BPT / BAT. Indirect dischargers are covered by PSES
Modeling Techniques
EPA employed modeling techniques to assess the potential benefits of the proposed limitations and
standards. First, EPA estimated pollutant concentrations in receiving water bodies for priority and
nonconventional pollutants under current (baseline) and proposed treatment levels. These estimates are
detailed in Chapter 12 of the technical development document. Second, EPA estimated water quality effects
from direct and indirect dischargers for the three subcategories of CWT facilities using stream dilution
modeling.2 EPA analyzed the effects from direct and indirect discharge operations separately. EPA had
The model employed was a simple dilution model that does not account for fate processes.
ES-3
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sufficient data to analyze water quality impacts from 95 of the 205 CWT facilities. Third, EPA combined the
impacts for each of the subcategories to estimate water quality impacts as a result of the rule.
EPA then analyzed benefits in terms of impacts to aquatic life, human health, and POTW operations. EPA
projected the benefits to aquatic life by comparing the modeled instream pollutant concentrations to EPA
aquatic life criteria and toxicity values (acute and chronic ambient water quality criteria). EPA projected
human health benefits by comparing estimated instream pollutant concentrations to health-based toxic effect
values derived using standard EPA methodology (referred to as human health ambient water quality criteria).
In addition, EPA projected potential carcinogenic and noncarcinogenic hazards to the recreational and
subsistence angler populations due to the consumption offish.
The environmental assessment also assesses the potential inhibition of POTW operations and potential
sewage biosolids contamination (thereby, limiting its use for land application) based on current and proposed
pretreatment levels. Inhibition of POTW operations is estimated by comparing modeled POTW influent
concentrations to available inhibition levels. Potential contamination of sewage biosolids is estimated by
comparing projected pollutant concentrations in sewage biosolids to available EPA sewage biosolids
regulatory standards.
Documented Impacts
The Environmental Assessment also summarizes documented environmental impacts on water quality and
POTW operations from centralized waste treatment facilities. The summary data are based on information
obtained from State 304(1) Short Lists and EPA Regional and State Pretreatment Coordinators on the quality
of receiving waters and impacts on POTW facilities. Impacts included seven cases of impairment to POTW
operations due to cyanide, nitrate/nitrite, sodium, zinc, and ammonia, and one case of an impact on the quality
of water due to organics. In addition, four direct CWT facilities and eight POTWs, which receive discharges
from 13 facilities were identified by states as being point sources causing water quality problems.
ES-4
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1. Introduction
This report presents the result of the water quality assessment performed by the U.S. Environmental
Protection Agency (EPA) as part of its effort to develop effluent limitations guidelines and pretreatment
standards for centralized waste treatment (CWT) facilities. EPA based effluent limitations guidelines and
pretreatment standards upon selected treatment technologies (see Table 1-1). The report also explains how
EPA prepared its assessment.
Table 1-1. Technology Basis for Selected Options
Metflls Subettsgory ft
BBT/BAT.//PSE5b
* ,#V" ,--'
Option 4:
Batch precipitation,
liquid solid separation,
secondary precipitation
and sand filtration
Oils Subcategory
BBT/BAT
Option 9:
Emulsion breaking,
gravity separation,
secondary gravity
separation and dissolved
air flotation
Option 8:
Emulsion breaking,
gravity separation, and
dissolved air flotation
Organifs Subcttsgory
BBT-//BAT/B51S
Option 4:
Equalization, and
biological treatment
a. For facilities in the cyanide subset of the metals subcategory, the technology basis is alkaline chlorination at specific operating
conditions.
b. Direct dischargers are covered by BPT / BAT. Indirect dischargers are covered by PSES
EPA estimated the potential effects on aquatic life and human health resulting from exposure to effluent
discharges from centralized waste treatment (CWT) facilities and from publicly owned treatment works
(POTWs) which receive and treat waste from CWT facilities and then discharge to surface waters. EPA has
also used the results of this assessment in the economic analysis of the proposed CWT effluent guidelines.
This report first projects effects associated with current (baseline) conditions and then evaluates potential
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effects expected from adoption of the proposed limitations and standards. Evaluations of the environmental
benefit of meeting the proposed limits and standards are then presented.
EPA believes that its estimation of benefits is incomplete. EPA cannot currently quantitatively evaluate all
human health and ecosystem benefits associated with water quality improvements. For example, the analyses
have considered the effects of toxic pollutants but do not evaluate the effects of other pollutants (such as five-
day biochemical oxygen demand (BOD5), chemical oxygen demand (COD), and total suspended solids
(TSS)), all of which can produce significant adverse environmental effects. Additionally, EPA has identified
205 CWT facilities, but due to a lack of receiving stream flow information and 44 facilities at zero discharge,
EPA only modelled aquatic life and human health effects of 95 facilities.
Within these limitations, EPA analyzes the effects of current water discharges and assesses the benefits of
reductions in these discharges resulting from this proposal. EPA evaluated water quality benefits of
controlling the discharge from CWT facilities to surface waters and POTWs for direct and indirect
dischargers located throughout the United States. CWT industry waste effluents contain pollutants that when
discharged into freshwater and estuarine ecosystems may alter aquatic habitats, affect aquatic life, and
adversely affect human health. In fact, all 105 pollutants of concern included in this analysis (see Table 4-1)
have at least one toxic effect. Each is a human health carcinogen and/or human health systemic toxicant or
aquatic toxicant. Many of these pollutants are persistent and bioaccumulate in aquatic organisms. In
addition, many of these pollutants may also adversely affect POTW operations and/or cause POTW sludge
contamination. These effects are widely documented. For example, State 304(1) lists detail adverse effects
on aquatic life, human health, and POTW operations.
EPA has organized this report into five sections. Section 2 describes the methodology EPA used to evaluate
water quality effects from direct and indirect discharging facilities and effects on POTW operations from
indirect discharging facilities. Section 3 describes the data sources used for evaluating water quality effects
such as facility-specific data, POTW operational data, water quality criteria, and documented environmental
impact data. Section 4 presents a summary of the results of this analysis. Section 5 provides a complete list
of references cited. Appendices A through C provide additional detail on the specific information addressed
in the main report.
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2. Methodology
EPA evaluates potential water quality effects of direct discharges on receiving streams and of indirect
discharges on POTW operations and their receiving streams using stream modeling techniques, as described
in Sections 2.1.1 and 2.1.2. Direct discharge facilities are those which discharge directly into water bodies
usually following on-site wastewater treatment. Indirect discharge facilities are those which discharge facility
effluent into a publicly owned treatment works (POTWs), which provides subsequent treatment of the facility
effluent.
EPA evaluates potential aquatic life and human health effects resulting from current and projected
contaminant releases separately for the three proposed subcategories of CWT operations. The categories are
as follows: Metal-Bearing Waste Treatment and Recovery Operations (metals), Used/Waste Oil Treatment
and Recovery Operations (oils), and Organic Waste Treatment (organics). Many facilities fall into multiple
subcategory combinations.1 EPA also assesses the effects on POTWs that treat effluent from CWT facilities
(Section 2.2). These effects may include biological upset of treatment processes and sewage biosolids
toxicity.
EPA assesses potential effects on aquatic life by comparing modeled in-stream concentrations to EPA's
aquatic life ambient water quality criteria (AWQCs). Where EPA has not developed water quality criteria,
EPA uses other values representative of that chemical's aquatic toxicity. The Agency compares modeled in-
stream concentrations to both acute and chronic AWQCs when available.
EPA estimates potential effects on human health in the following manner. EPA first compares modeled in-
stream contaminant concentrations for each facility by subcategory under baseline conditions and for the
proposed limitations and standards2. EPA compares these instream concentrations to health-based toxic
1 Many CWT facilities treat wastes from multiple subcategories. Therefore, EPA aggregated loadings from each
subcategory to estimate the combined environmental effects of the proposed rule..
2 EPA uses the long-term averages rather than the proposed limitations and standards for these analyses.
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effect values3 derived using standard EPA methodology. Next EPA estimates potential carcinogenic risks
and noncarcinogenic hazards to the recreational and subsistence angler populations and their households due
to the consumption of contaminated fish. EPA also estimates exposure to contaminants through the water
pathway by comparing modeled in-stream contaminant concentrations to health-based AWQCs for the
ingestion of water and organisms.
2.1 Estimating In-Stream Concentrations
EPA estimates in-stream contaminant concentrations for various flow conditions as the first step in
evaluating effects on aquatic life and human health. EPA uses treatment data collected from industry and
EPA sampling data to estimate contaminant loadings discharged at each facility under baseline conditions and
each proposed regulatory option. Chapter 12 of the technical support document for the proposal explains the
methodology EPA used to estimate current and post-compliance pollutant loadings. The following
subsections describe the methodology and assumptions EPA uses to evaluate effects of direct and indirect
discharging facilities on human health and aquatic life.
2.1.1 Direct Discharge Facilities
EPA projects in-stream concentrations for current and proposed BPT/BAT treatment levels using a simple
stream dilution model that does not account for fate and transport processes (see Equation I).4
n LIOD
C« = W^F X CF W
where:
Cis = in stream pollutant concentration 0/g/L);
The report refers to these either as human health ambient water quality criteria, or health-based AWQCs.
4 Equations used to estimate instream concentrations are adapted from methodology presented in "Technical Support
Document for Water Quality-Based Toxics Control, EPA, March 1991.
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L = facility pollutant loading (Ib/year);
OD = facility operation (days/year);
FF = facility flow (million gallons (MG)/day);
SF = receiving stream flow (MG / day); and
CF = conversion factor 120 fag MG / L Ibs) = 0.2642 (gal/L) x 0.4536 (kg/lbs) x 103
CugMG/kggal).
EPA obtains the facility-specific data (i.e., pollutant loading, operating days, and facility flow) used in
Equation 1 from the sources described in Section 3.1 of this report. In all, EPA uses three different values for
receiving stream flow rate (1Q10 low flow, 7Q10 low flow, and harmonic mean flow (HMF)) for the current
and proposed regulatory options. The 1Q10 and 7Q10 low flows are used to evaluate the potential for acute
and chronic aquatic toxicity, respectively, in receiving streams, as recommended in the Technical Support
Document for Water Quality-based Toxics Control (USEPA, 1991a).5 EPA uses the HMF to estimate the
potential for human health effects.6 Neither the 1Q10 nor 7Q10 flow is appropriate for assessing potential
human health effects because neither has a consistent relationship with the long-term mean dilution.
Because EPA is not able to obtain stream flows for hydrologically complex waters such as bays, estuaries
and oceans, EPA uses site-specific critical dilution factors (CDFs) with Equation 2 to predict pollutant
concentrations for facilities discharging to these complex water bodies. EPA uses site-specific CDFs
developed from a 1992 survey of states and EPA Regions conducted by EPA's Office of Pollution Prevention
and Toxics (OPPT).
LIOD\ ,-,
x CF
FF }
I CDF (2)
where:
Ces = estuary pollutant concentration fag/L);
5The 1Q10 and 7Q10 flows, respectively, are the lowest 1-day and lowest consecutive 7-day average flow during any
10-year period.
6The harmonic means are determined by taking the reciprocal of the mean value of the reciprocal of individual values.
EPA recommends that the long-term harmonic mean flow be used for assessing potential human health effects because it
provides a more conservative estimate than the arithmetic mean flow.
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L = facility pollutant loadings (Ib/year);
OD = facility operation (days/year);
FF = facility flow (MG / day);
CDF = critical dilution factor (unitless); and
CF = conversion factor =120 (/j-g MG / L Ibs).
When EPA cannot obtain CDFs directly, EPA uses dissolved concentration potentials (DCPs) with Equation
3 to calculate the CDF. EPA obtains DCPs from the Strategic Assessment Branch of the National Oceanic
and Atmospheric Administration's (NOAA) Ocean Assessments Division. NOAA developed DCPs based
on freshwater inflow and salinity gradients to predict pollutant concentrations in each estuary in the National
Estuarine Inventory (NET) Data Atlas. These DCPs are applied to predict concentrations of nonreactive
dissolved substances. In addition, the DCPs reflect the predicted estuary-wide response and might not be
indicative of site-specific locations. If neither DCPs nor CDFs are available for an estuary receiving
discharges from CWT facilities, EPA estimates a CDF based on best professional judgement of the size,
depth, and location of the receiving water body. Appendix A provides DCP values used for specific water
bodies.
CDF = CF x
R
FFDCP
(3)
where:
CDF
R
DCP
FF
CF
critical dilution factor (unitless);
pollutant loading after treatment (kg/site/day)
dissolved concentration potential (mg/L);
facility flow (MG / day); and
conversion factor = 0.2642 (mg MG/ kg L) = 106 (mg/kg) x 10'6 (MG/gal) x
0.2642 (gal/L)
In summary, EPA estimates in-stream (Equation 1) or estuary (Equation 2 or 3) pollutant concentrations for
direct discharge facilities to evaluate whether either human health criteria or ambient water quality criteria
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are exceeded. EPA sums pollutant loadings for individual subcategories before calculating concentrations
from multiple subcategory CWTs. When evaluating the combined regulatory option (combinations of the
treatment technology basis for each of the proposed subcategories), EPA determines water body
concentrations by first summing pollutant loadings from all CWT facilities.
2.1.2 Indirect Discharge Facilities
EPA estimates in-stream concentrations for current and proposed PSES requirements using a simple stream
dilution model that does not account for fate processes but does account for POTW influences (see Equation
4). Note that Equation 4 and Equation 1 differ to account for the additional dilution provided by the POTW
flow and the removal of pollutants by POTW treatment processes. Sections 3.1 and 3.2 of this report
describes the sources the facility-specific data used in Equation 4.
n nir^\ - x CF
C = (L OD) x -
1S y } PF + SF
where:
Cis = in stream pollutant concentration Cug/L);
L = facility pollutant loading (Ib/year);
OD = facility operation (days/year);
TMT = POTW treatment removal efficiency (unitless);
PF = POTW flow (MG /year);
SF = receiving stream flow (MG /year); and
CF = conversion factor =120 (/j,g MG / L Ibs).
EPA predicts pollutant concentrations of hydrologically complex water bodies, such as bays, estuaries, and
oceans, that received POTW discharges using Equation 5 and site-specific CDFs.
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C =
es
LIOD x (l-TMT)\
- - x CF
PF }
I CDF (5)
where:
Ces = estuary pollutant concentration 0/g/L);
L = facility pollutant loading (Ib/year);
OD = facility operation (days/year);
TMT = POTW treatment removal efficiency (unitless);
PF = POTW flow (MG /year);
CDF = critical dilution factor (unitless); and
CF = conversion factor =120 (/j-g MG / L Ibs).
When EPA cannot obtain a CDF directly, EPA uses estuarine DCPs with Equation 4 to calculate that CDF.
If neither DCPs nor CDFs are available for estuaries receiving discharges from CWT facilities, EPA
estimates a CDF based on best professional judgment of the size, depth, and location of the receiving water
body. Appendix A provides the DCP values used for specific water bodies.
EPA sums pollutant loadings for individual subcategories before calculating concentrations for POTWs
receiving effluent from multiple subcategory CWT facilities. When evaluating the combined regulatory
option (combinations of the treatment technologies basis for each of the proposed subcategories), EPA
determines water body concentrations by first summing contaminant loadings from all CWT facilities
discharging to each POTW.
2.2 Estimating POTW Effects
EPA calculates effects on POTW operations based either on inhibition of POTW processes (i.e., inhibition of
activated sludge or biological treatment), or contamination of POTW sewage biosolids (thereby limiting a
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POTW's ability to use the biosolids for land application). EPA determines inhibition of POTW operations
by comparing calculated POTW influent levels (Equation 6) with available inhibition levels (see Table 3-1).
where:
C/"T -L^l {Jl-J /"T 7i
p = C4 + - X CF
C = average POTW influent concentration with load contribution of facility (mg/L);
Cd: = average POTW influent concentration for chemical 7 due to other sources (mg/L);
L = facility pollutant loading (Ib/year);
OD = number of operating days for each facility (260 days/year);
PF = POTW flow (million gallons/year); and
CF = conversion factor = 43.7 (mg MG d / Ibs yr L) = 365 (d/yr) x 0.4536 (kg/lbs) x
10'6 (MG/gal) x 0.2642 (gal/L) x 106 (mg/kg).
The term Cd: in Equation 6 represents the contribution of other sources (non-CWT pollutant loads) to the
average POTW concentrationa contribution that varies among POTWs. In the absence of specific
knowledge of each POTW, EPA conservatively estimates Cdj by multiplying the reported chemical-specific
upset criterion by 0.75.7
EPA evaluates potential contamination of sewage biosolids by comparing projected pollutant concentrations
in the biosolids (Equation 7) with regulatory values for land application of sewage biosolids. EPA uses two
sets of regulatory criteria to characterize projected POTW biosolids concentrations (see Table 3-2).
7 Seventy-five percent of the biological inhibition threshold for a given pollutant activated sludge treatment processes is
assumed to be comprised of non-CWT sources. The remaining 25 percent limit is available for CWT sources.
Threshold levels used were obtained from CERCLA Site Discharges to POTW's: Guidance Manual, EPA 1990.
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C = C, + (L x T x
sp dp V
where:
C = biosolids pollutant concentration Cug/L);
Cj = average POTW biosolids pollutant concentration in typical domestic biosolids (mg/kg dry);
L = facility pollutant loading (Ib/year);
TMT = POTW treatment removal efficiency (unitless);
PF = POTW flow (million gallons/year);
SG = biosolids generation factor (Ib dry/million gallons treated); and
CF = conversion factor = 106 (mg/kg) = (0.4536 kg/lb)/(0.4536 kgdiy/lbdiy) x 106 (mg/kg)2.3
2.3 Assumptions and Caveats
EPA makes the following assumptions in this analysis:
EPA models CWT facilities if the receiving streams or the POTWs to which they discharge could be
identified (95 of the 205 facilities). EPA scaled up loading values for the oils subcategory facilities
(from 64 to 122 facilities) to better estimate the full impact of the proposed treatment levels on
loading levels from the CWT industry. Aquatic life and human health effects were estimated based
on 95 facilities for which facility -specific data are available.
CWT facilities operate 260 days per year.
CWT facilities produce only a small portion of the total POTW (domestic) biosolids.
The process water at each facility and the water discharged to a POTW are obtained from a source
other than the receiving stream.
-------
The pollutant load to the receiving stream is continuous and representative of long-term facility
operations. This assumption might overestimate risks to human health and aquatic life.
Complete mixing of discharge flow and stream flow occurs across the stream at the discharge point.
This mixing results in the calculation of an "average stream" concentration even though the actual
concentration might vary across the width and depth of the stream.
EPA did not consider pollutant fate processes such as sediment adsorption, volatilization, and
hydrolysis.. This approach might result in estimated in-stream concentrations that are
environmentally conservative (higher).
Only the potential for metal contamination of sewage biosolids to levels that would prohibit its land
application as a fertilizer or soil conditioner is evaluated. Biosolids criteria levels are only available
for 7 pollutants: arsenic, cadmium, copper, lead, mercury, selenium & zinc.
The analysis dilutes pollutant loadings in 1,400 pounds of primary sludge per million gallons treated.
The 1Q10 and 7Q10 receiving stream flow rates are used to estimate aquatic life effects, and
harmonic mean flow rates to estimate human health effects. The analysis estimates 1Q10 low flows
using the results of a regression analysis of 1Q10 and 7Q10 flows from representative U.S. rivers
and streams conducted by Versar Inc. for EPA's OPPT (Versar, 1992). The analysis estimates
harmonic mean flows from the mean and 7Q10 flows as recommended in the Technical Support
Document for Water-Quality-based Toxics Control (USEPA, 199 la). These flows might not be the
same as those used by specific states to assess effects.
The analysis uses an exposure duration of 365 days to determine the likelihood of actual
contraventions of human health criteria or toxic effect levels.
The analysis uses water quality criteria or toxic effect levels developed for freshwater organisms to
analyze facilities discharging to estuaries or bays.
2-9
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2.4 Compiling Documented Environmental Effects
During the months of June through September 1997, EPA contacted EPA Regional and State Pretreatment
Coordinators regarding effects of CWT discharges on POTWs and surface waters (see Table 4-25). EPA
reviewed State 304(1) Short Lists (USEPA, 199 Ib) for evidence of documented environmental effects on
aquatic life, human health, POTW operations, and the quality of receiving water due to discharges of
pollutants from CWT facilities (see Tables 4-26 and 4-27). EPA also reviewed the Permit Compliance
System (PCS) data.
2.5 Estimating Toxic Effects
2.5.1 Estimating Effects on Aquatic Life
EPA evaluates potential effects on aquatic life on a site-specific basis by comparing modeled in-stream
contaminant concentrations under baseline conditions and following adoption of the proposed rule using
aquatic life criteria and toxicity values (acute and chronic AWQCs). EPA compares the in-stream
concentrations for each chemical discharged from each facility under 1Q10 and 7Q10 flow conditions to
acute and chronic AWQCs, respectively. EPA quantifies contraventions of AWQCs by dividing the modeled
in-stream concentrations for each flow condition by the respective AWQC for each chemical.
2.5.2 Estimating Effects on Human Health
EPA estimates potential effects on human health in the following manner. EPA first compares modeled in-
stream contaminant concentrations for each subcategory under baseline conditions and following adoption of
the proposed limitations and standards. EPA compares these instream concentrations to health-based toxic
effect values8 derived using standard EPA methodology. Next EPA estimates potential carcinogenic risks
and noncarcinogenic hazards to the recreational and subsistence angler population due to the consumption of
contaminated fish. Finally, EPA estimates both the annual incidence of cancer and potential lead related
1 The report refers to these either as human health ambient water quality criteria, or health-based AWQCs.
2-10
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health effects in the potentially exposed angler population. Each of these techniques is discussed in more
detail below.
(a) Human Health AWQCs
EPA uses the modeled in-stream HMF concentration for estimation of human health AWQ. It is more
reflective of average water body conditions then 1Q10 or 7Q10 flow conditions, because health-based
AWQCs are derived for lifetime exposure conditions rather than for subchronic or acute conditions. EPA
quantifies contraventions of health-based AWQCs by dividing the predicted in-stream concentration under
HMF conditions by the health-based AWQC for each chemical discharged from each facility under each
regulatory option and baseline conditions.
(b) Carcinogenic Risks and Noncarcinogenic Hazards
Next, EPA evaluates potential effects on human health by estimating potential carcinogenic risks and
noncarcinogenic hazards. EPA performs this assessment in accordance with available EPA guidance
including Risk Assessment Guidance for Superfund (USEPA, 1989a) and Assessing Human Health Risks
from Chemically Contaminated Fish and Shellfish: A Guidance Manual (USEPA, 1989b). As outlined in
EPA guidance, the technical approach for conducting a risk assessment involves a three-step process:
(1) Toxicity Assessment. EPA uses available human health toxic effect values for the
contaminants of potential concern derived from data sources such as IRIS (USEPA, 1997a), and
HEAST (USEPA, 1996). The list of chemicals of potential concern, with their available
reference dose values (RfD) and cancer slope factors (SF) are in Appendix B.
(2) Exposure Assessment. The exposure assessment involves identifying exposure pathways of
concern, estimating exposure point concentrations, and estimating chronic daily intakes.
Identifying Exposure Pathways of Concern. EPA identifies water-related exposure
pathways and target populations. Pathways quantitatively evaluated include only the
ingestion offish by recreational and subsistence anglers.
Estimating Exposure Point Concentrations. The exposure point concentration (EPC) is
the average concentration contacted over the duration of the exposure period. For the
fish ingestion pathway, EPA calculates fish tissue EPCs by multiplying the
2-11
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contaminant-specific BCF by the estimated in-stream concentration under HMF
conditions using the simple dilution model.
Estimating Chronic Daily Intakes. EPA estimates chronic daily intakes (GDIs) using
exposure models from EPA guidance for each chemical discharged from a facility
under each regulatory option and baseline conditions. EPA expresses GDIs in terms of
milligrams of contaminant contacted per kilogram of body weight per day (mg/kg/day).
EPA calculates a GDI by combining the EPC and exposure parameter estimates (e.g.,
ingestion rate, exposure frequency, exposure duration, body weight, averaging time)
using a chemical intake equation. EPA estimates GDIs for evaluating both
carcinogenic risks (based on a lifetime average daily dose) and noncarcinogenic hazards
(based on an average daily dose during the exposure period). EPA estimates GDIs for
both baseline conditions and proposed regulatory options.
The equation and exposure parameter values used to estimate GDIs for ingestion of fish is presented
below:
GDI =
EPCxBCFxCFxIRxEFxED
BWxAT
(8)
where:
GDI
EPC
CF
BCF
IR
EF
ED
BW
AT
chronic daily intake (mg/kg/day);
exposure point concentration (in-stream concentration under HMF conditions,
in Mg/L);
conversion facto r= 10~6 (kg mg / g /j,g)
bioconcentration factor (11,100 I/kg)
ingestion rate (for the recreational and subsistence anglers, EPA assumes fish
consumption rates of at 16.6 grams/day and 140 grams/day, respectively);
exposure frequency (365 days/year);
exposure duration (70 years);
body weight (70 kg); and
averaging time (70 years x 365 days/year).
2-12
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(3) Risk Characterization. EPA assesses carcinogenic risks and noncarcinogenic hazards for
chemicals using available toxicity criteria for the pathways quantitatively evaluated in this study.
Carcinogenic Risk Calculations
EPA expresses the potential carcinogenic risks associated with the discharges as an increased
probability of developing cancer over a lifetime (e.g., excess individual lifetime cancer
risk)(USEPA, 1989a). EPA quantifies carcinogenic risks using the equation below:
Cancer risk. = CDI. x SF.
(9)
where:
Cancer risk, = potential carcinogenic risk associated with exposure to chemical / (unitless);
CDIZ = chronic daily intake for chemical / (mg/kg/day); and
Sfj = slope factor for chemical/((mg/kg/day)"1).
If the carcinogenic risk exceeds 10~2, EPA guidance (USEPA, 1989a) recommends using the
following equation to estimate carcinogenic risk:
-71 (' CDIi X SFi> ,1 n\
Cancer nskj = I - e (10)
where:
Cancer risk, = potential carcinogenic risk associated with exposure to chemical / (unitless);
CDIZ = chronic daily intake for chemical / (mg/kg/day); and
Sfj = slope factor for chemical/((mg/kg/day)"1)
EPA sums chemical-specific cancer risks in accordance with EPA guidance (USEPA, 1989a) to quantify the
combined cancer risks associated with exposure to a chemical mixture. EPA estimates the total potential
carcinogenic risk for each exposure pathway, for each facility, and for each regulatory option and baseline
conditions.
2-13
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Noncarcinogenic Hazard Calculations
EPA evaluates noncarcinogenic hazards by comparing the estimated dose (e.g., GDI) with a reference dose
(RfD). EPA calculates the hazard quotient, which is used to quantify the potential for an adverse
noncarcinogenic effect to occur, using the following equation:
GDI.
where:
Hqz = hazard quotient for chemical / (unitless);
CDIZ = chronic daily intake for chemical / (mg/kg/day); and
RfDz- = reference dose for chemical / (mg/kg/day).
If the hazard quotient exceeds unity (1), an adverse effect might occur. The higher the hazard quotient, the
more likely that an adverse noncarcinogenic effect will occur as a result of exposure to the chemical. If the
estimated hazard quotient is less than unity, an adverse noncarcinogenic effect is highly unlikely to occur.
EPA recommends summing chemical-specific hazard quotients for contaminants with similar endpoints to
evaluate the combined noncarcinogenic hazard from exposure to a chemical mixture (USEPA, 1989a). The
sum of the chemical-specific hazard quotients is called the hazard index. Using this approach assumes that
chemical-specific noncarcinogenic hazards are additive. Limited data are available for actually quantifying
the potential synergistic and/or antagonistic relationships between chemicals in a chemical mixture. This
assessment sums, only the hazard quotients that have similar target organs and toxicological mechanisms.
2.6 Estimating Human Health Risks Associated with Consumption of Lead-
Contaminated Fish
Because discharges from several CWT metals and oils facilities contain significant quantities of lead, EPA
separately analyzes potential human health risks associated with the consumption of lead-contaminated fish
by recreational and subsistence anglers. Ingestion of lead has been shown to cause adverse health effects in
2-14
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both child and adult populations. Elevated blood lead levels in children may impair intellectual development
as measured by reduced IQ levels. Adult ingestion of lead may cause numerous cardiovascular problems,
including hypertension, coronary heart disease, and strokes. These ailments may cause premature death,
particularly in adults aged 40-75 years old. In addition, elevated blood lead levels in pregnant women may
increase of the risk of neonatal mortality. EPA estimates the potential for such effects by adapting
methodologies developed for assessing human health risks from lead at CERCLA/RCRA sites and for
estimating the benefits of the Clean Air Act.
EPA estimates blood lead levels in children using EPA's "Integrated Exposure Uptake Biokinetic Model for
Lead in Children" (IEUBK-USEPA,1994a). This PC-based model allows the user to estimate the geometric
mean blood lead concentration for a hypothetical child or population of children. Using information on
children's exposure to lead, the model estimates a plausible distribution of blood lead concentrations centered
on the geometric mean blood lead concentration.
To use the IEUBK model, EPA must first estimate the in-stream lead concentration (based on the
methodology described in section 2.1). EPA then projects the daily ingestion of lead based upon the instream
concentration, bioconcentration factor for lead, and fish consumptions rates for children . The IEUBK model
then estimates the geometric mean blood lead level. Although, the model can estimate blood lead
concentrations from multi-pathway exposure (air, soil, diet, water), all other pathway exposures other than
diet were "zeroed out" in order to isolate blood lead levels solely attributable to consumption of lead-
contaminated fish.
As noted above, children are primarily adversely affected through intellectual impairment as measured by
changes in IQ. EPA estimates the health and monetary benefits from decreasing risks for reduced IQ
potential in at-risk populations using the equations used in Lead Benefits Analysis performed for the
Retrospective Study of the Clean Air Act (EPA, 1997c). The specific steps used to estimate the health effects
benefits based on estimated changes in blood levels is described below:
' Volume II- Food Ingestion Factors, Exposure Factors Handbook, EPA, August 1997 (USEPA, 1997b).
2-15
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EPA uses the "1997 Statistical Abstract of the US" to estimate the percentage of the total US
population between 0 and 72 months equal to 0.1031 percent. For each reach, EPA estimates
exposed child population by multiplying the total exposed population for each reach (recreation and
subsistence) by the corresponding percentage of children.
EPA estimates the change in children's IQ using equation (5) from Appendix G of the
Retrospective Study of the Clean Air Act.
(Total Lost IQ\ = &GMk x 1.117 x 0.25 x Popjl (i2)
where:
(Total Lost IQ)],, = Total Reduction of IQ points in Affected Population
AGMK = Change in the Geometric Mean of Affected Population's Blood Lead Level
For adult populations, EPA estimates health effects using methodology contained in its interim approach for
assessing risks associated with adult exposure to lead in soil (Interim Guidance, USEPA 1996a).10
The approach described in the Interim Guidance estimates the effects of ingestion of lead contaminated soil
on blood lead levels of women of child-bearing age. The analysis looks at this subpopulation group in order
to derive risk-based remediation goals (RBRG) that would be protective of the developing fetus of adult
women having site exposure. Although the Interim Guidance equation is based on a scenario quite different
from that analyzed in the CWT environmental assessment (i.e.; consumption of contaminated fish by
recreational and subsistence anglers), the exposure pathways are essentially the same. The main difference
being the matrices which contain the lead contaminant (i.e., soil versus fish). The applicable equation
(Interim Guidance, pg.2. Equation 1) is as follows:
10 Recommendations of the Technical Workgroup for Lead for Interim Approach to Assessing Risks Associated with
Adult Exposures to Lead in Soil, USEPA, December 1996.
2-16
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(PbB\dulPcentral = PbBaduUO x PbS x BKSF x 1R, >
-------
pbBaduit,centrai = Central estimate of blood lead level concentration (//g/dL) in adults (i.e., adults
consuming fish contaminated with lead attributable to CWT discharges
PbBadult 0 = Typical blood lead concentration in adults in absence of exposures to contaminated fish. (2
Isc = In stream Concentration of lead 0/g/L) (Affected receiving water bodies had in stream
concentrations of lead ranging from 0.5 Mg/L to approximately 7.7 Mg/L).
BCF = Bioconcentration Factor for lead ( 49 L/kg)
INGf = Average daily consumption offish (16.5g/day for recreational anglers and 140 g/day for
subsistence anglers).
Af = Absolute gastrointestinal absorption factor for ingested lead in fish (.06 dimensionless).
11
BKSF = Biokinetic Slope Factor relating (quasi-steady state) increase in typical adult blood lead
concentrations to average daily uptake (Mg/dL blood lead increase per Mg/day lead uptake).
(EPA uses the 0.4 slope factor as presented in the Interim Guidance)
Efs = Exposure frequency for ingestion of contaminated fish; (days of exposure during the
averaging period); may be taken as days per year for continuing, long-term exposure (365
days).
CF = Conversion Factor 10"3 (kg/g)
AT = Averaging time; the total period during which food is consumed; 365 day/year for continuing
exposures.
EPA modifies the equation presented in the Interim Guidance to account for ingestion of lead contained in
fish tissue rather than ingestion of lead contained in a soil matrix. The primary source of uncertainty in
applying the Interim Guidance equation to the affected CWT population is:
Using soil lead bioavailability factor to estimate fish lead bioavailability.
The bioavailability of lead ingested in a soil matrix is likely to be different from the ingestion of lead
contained in fish tissue. Studies conducted by Maddaloni and others that are cited in the Interim Guidance
11AFS is the product of Afsoluable * RBFsoilsoluable where: Afsoluable equals 0.1 and RBFsoUsoluable equals 0.6. EPA uses
311 AfSoiuable =(-)-1 to account for the fact that under CWT scenarios lead is ingested in conjunction with a meal.
2-18
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indicate that lead ingested with food is absorbed at a significantly lower rate than when lead is ingested
without food in a soil matrix. It has been suggested that these lower absorption rates may be due to the
presence of chelating substances in food products as well as the fact that readily absorbed food may serve as
a physical barrier to absorption of less soluble substances such as lead. To account for the these differences,
EPA has modified the absorption rate presented in the Interim Guidance (12 percent), which used a "meal
weighted average" rate. For purposes of this analysis, EPA uses an absorption factor of six percent. In all
other aspects, the equation for soil and for fish ingestion are consistent and require no modification.
Using the Equation to Estimate Benefits to the Affected Adult Population
By using the results of the CWT Modeling efforts and adapting methodology from the Interim Guidance
EPA conservatively estimates changes in adult blood lead levels for the affected population. The procedure
involves a four- step process which estimates:
1. In stream concentration of lead using CWT models described in Section 2.1
2. Lead uptake in affected adult population using the established bioconcentration factor for lead
and fish consumption rates for recreational and subsistence anglers.
3. Changes in blood lead levels using Interim Guidance methodology described above
4. Changes in health status from proposed regulations using methodology cited in the CAA Study.
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3. Data Sources
EPA uses readily available Agency and other databases, models, and reports to evaluate water quality effects.
The following sections describe the various data sources that EPA used in this analysis.
3.1 Facility-Specific Data
EPA uses various sources for collecting data on CWT facilities. EPA obtains data through EPA site visits
and sampling, responses to CWT questionnaires, comments to the 1995 proposal and 1996 Notice of Data
Availability, and contacts with industry sources, regions and states. EPA uses this information to estimate
many of the facility-specific parameters required for this analysis such as annual discharge volume, current
pollutant loadings, and loadings associated with each regulatory option. EPA's data collection procedure is
described in detail in chapter 2 of the technical development document.
For the CWT facilities which were identified through the WTI Questionnaire, EPA has discharge location
information. For the others, EPA had to make some assumptions about their discharge locations. For direct
dischargers, EPA assumes the adjacent water body is the receiving water. For indirect dischargers, EPA
conducts an analysis to identify the appropriate publicly owned treatment works (POTW) that may receive
the facility discharge. For others, EPA identifies the locations of CWT facilities or POTWs on receiving
water bodies using USGS cataloging units and EPA stream segment (reach) numbers contained in either
EPA's Permit Compliance System (PCS) or Industrial Facilities Discharge (IFD) database. If a reach number
is not available in the EPA databases, EPA uses facility latitude/longitude coordinates to locate facility
discharge points using EPA's Reach File 1 (RF1). For any indirect discharge facilities (those discharging to a
POTW, not directly to a water body), EPA obtains the name, location, and design flow data for each affected
POTW from a variety of sources including EPA's 1996 Clean Water Needs Survey database, IFD, and PCS.
EPA obtains the raw receiving water flow data from the USGS Daily Flow File. In all cases, EPA uses the
closest flow gauge to estimate the flow rate at the point of facility discharge. EPA determines the average
and low-flow statistics (e.g., the 7Q10 low flow) using the Water Quality Analysis System residing on the
3-1
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Agency's NCC mainframe computer. EPA obtains Dissolved Concentration Potentials (DCPs) for estuaries
and bays from the Strategic Assessment Branch of NOAA's Ocean Assessments Division (see Appendix A).
EPA uses Critical dilution factors (CDFs) from the Mixing Zone Dilution Factors for New Chemical
Exposure Assessments (USEPA, 1992b). If neither DCPs nor CDFs are available for a particular facility,
EPA estimates a CDF based on best professional judgment and the dimensions, depth, and general flushing
characteristics of the bay or estuary.
3.2 Information Used to Evaluate POTW Operations
As detailed in the chapter 7 of technical development document, EPA estimates the average percent removal
for each pollutant of concern at well-operated POTWs (those meeting secondary treatment requirements)
using data from a study of 50 well-operated POTWs and data from the Risk Reduction Engineering
Laboratory (RREL). EPA uses inhibition values obtained from the Guidance Manual for Preventing
Interference at POTWs (USEPA, 1987a) and from CERCLA Site Discharges to POTWs: Guidance Manual
(USEPA, 1990) (see Table 3-1).
Whenever a range of values are obtained, EPA uses the most conservative value reported for activated
sludge-based POTWs. For pollutants with no specific inhibition value, EPA uses a value based on
compound type (e.g., aromatics).
EPA uses sewage biosolids regulatory levels1, if available for the pollutants of concern (see Table 3-2). EPA
uses pollutant limits established for the final use or disposal of sewage biosolids applied to agricultural and
nonagricultural land (see Table 3-2). For predicting biosolids generation, EPA assumes that 1,400 pounds of
biosolids are generated for each million gallons of wastewater processed (Metcalf & Eddy, 1972).
3.3 Water Quality Criteria (WQC)
EPA obtains the ambient criteria (or toxic effect levels) for the protection of aquatic life and human health
from a variety of sources including EPA criteria documents, EPA's Assessment Tools for the
1 40 CFR Part 503, Standards for the Use or Disposal of Sewage Sludge, Final Rule (February 19, 1993).
3-2
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Table 3-1. POTW Removals and Biological Inhibition Concentrations
Pollutant
aluminum
antimony
arsenic
barium
boron
cadmium
calcium
chromium
cobalt
copper
iodine
iron
lead
lithium
magnesium
manganese
mercury
molybdenum
nickel
phosphorus
potassium
selenium
silicon
sodium
strontium
sulfur
tin
titanium
zinc
1,1,1 ,2-tetrachloroethane
1,1,1-trichloroethane
1,1,2-trichloroethane
1,1-dichloroethane
% popf
Remofal^
17
71
91
90
70
90
52
93
4.8
88
39
83
92
26
32
41
92
52
58
69
20
34
27
52
15
14
65
69
79
23
92
75
81
Biological
Inhibition
Concentration
(miW"
N/A
N/A
0.04
N/A
10
0.5
N/A
0.1
N/A
0.1
N/A
5
0.1
N/A
N/A
10
0.1
N/A
1
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
0.3
N/A
150
N/A
N/A
Pollutant
acetophenone
alpha-terpinol
anthracene
benzene
benzo(a)anthracene
benzo(a)pyrene
benzo(b)fluoranthene
benzo(k)fluoranthene
benzole acid
benzyl alcohol
biphenyl
bis(2-ethylhexyl) phthalate
bromodichloromethane
butanone
butyl benzyl phthalate
carbazole
carbon disulfide
chlorobenzene
chloroform
chrysene
di-n-butyl phthalate
dibenzofuran
dibenzothiopene
diethyl ether
diethyl phthalate
diphenyl ether
diphenylamine
ether
ethyl benzene
fluoranthene
fluorene
hexanoic acid
isophorone
% POTW
Removal *
95
94
96
95
98
95
95
95
81
78
96
60
92
97
94
85
84
97
77
97
79
85
85
7
60
98
79
52
94
42
70
84
62
Biological
Inhibitiot)
Concentration
(mgtLt
N/A
1000
5
5
500
500
500
500
5
1000
N/A
10
N/A
150
10
1
N/A
5
150
500
10
500
500
N/A
10
1
1
1000
5
500
5
N/A
N/A
3-3
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Table 3-1. (Continued)
Pollutant
1,1-dichloroethene
1,2,3-trichloropropane
1 ,2,4-trichlorobenzene
1,2-dibromoethane
1 ,2-dichlorobenzene
1,2-dichloroethane
1 ,3-dichlorobenzene
1,4-dichlorobenzene
1-methyl fluorene
1-methylphenanthrene
2,3,4,6-tetra chlorophenol
2,3-benzofluorene
2,3-dichloroaniline
2,4,5-trichlorophenol
2,4,6-trichlorophenol
2,4-dimethyl phenol
2-butanone
2-chlorophenol
2-hexanone
2-methylnaphthalene
2-phenylnaphthalene
2-picoline
2-propanone
3,6-dimethyl
phenanthrene
4-chloro-3-methylphenol
4-methyl-2-pentanone
acenaphthylene
acenapthene
% POTW
Rerttevirt a
89
5
92
17
89
89
89
52
88
88
33
88
41
28
65
99
92
85
88
28
88
85
84
88
63
88
99
98
Biological
Inhibition
Concentration
(mgtLf
150
N/A
0.1
N/A
0.1
150
0.1
0.1
5
5
N/A
500
N/A
N/A
N/A
N/A
150
N/A
N/A
5
5
N/A
150
5
N/A
150
5
5
Pollutant
m-xylene
methylene chloride
n-decane
n-dodecane
n-eicosane
n-hexadecane
n-octadecane
n-tetradecane
N.N-dimethylformamide
naphthalene
o+p xylene
o-cresol
p-cresol
p-cymene
pentachlorophenol
pentamethyl benzene
phenanthrene
phenol
pyrene
pyridine
tetrachloroethene
tetra chloromethane
toluene
trans-1 ,2-dichloroethene
trichloroethene
trichlorofluoromethane
tripropyleneglycolmethyl
vinyl chloride
y» po"p?
Remofal:*
99
55
9
95
92
71
71
71
85
96
95
53
72
99
14
92
95
97
84
95
83
92
97
79
93
98
52
93
Biological
InHifjition
Concentration
'%«&? "
5
150
150
150
150
150
150
150
150
5
5
N/A
N/A
5
N/A
5
5
90
500
1
150
N/A
5
N/A
150
N/A
1,000
N/A
a. Calculation is detailed in Chapter 7 of the technical development document
b. The lowest reported concentration at which the activated sludge process is inhibited. EPA evaluated POTW operations using
facility-specific data and information derived from the sources described in Sections 3.1 and 3.2. The individual loadings from
CWT facilities that discharge to the same POTW were summed before the POTW influent and biosolids concentrations are
calculated.
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Table 3-2. POTW Biosolids Pollutant Concentration Criteriad
Pollutant
Arsenic
Cadmium
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Zinc
Pollutant Celling
Value**
fmgftg)
75
85
4,300
840
57
75
420
100
7,500
Pollutant
Concentration
HwJt Values-*
ffflgfcg)
41
39
1,500
300
17
35 c
420
36
2,800
a. Maximum concentration permitted for land application of
biosolids.
b. Concentration limit for continuous unlimited land application of
biosolids.
c. The standard used for molybdenum is 35 mg/kg (59 Federal
Register 9095, February 18, 1994). EPA notes that the PCL
value for molybdenum was deleted from Part 503 effective
February 19,1994. EPA will consider establishing a limit at a
later date.
d. Referenced from 40 CFR Part 503 3-3
Evaluation of Risk (ASTER), and EPA's Integrated Risk Information System (IRIS, USEPA 1997a) uses
ecological toxicity estimations when there are no available published values. The following subsections
describe the hierarchies used to select the appropriate aquatic life and human health values.
3.3.1 Aquatic Life
EPA has established water quality criteria for many pollutants for the protection of freshwater aquatic life
(acute and chronic criteria). The acute value represents a maximum allowable 1-hour average concentration
of a pollutant at any time and can be related to acute toxic effects on aquatic life. The chronic value
represents the average allowable concentration of a toxic pollutant over a 4-day period at which a diverse
3-5
-------
group of aquatic organisms and their uses should not be unacceptably affected, provided that these levels are
not exceeded more than once every 3 years.
EPA uses specific toxicity values2 for pollutants for which no water quality criteria have been developed. In
selecting values from the literature, EPA prefers measured concentrations from flow-through studies under
typical pH and temperature conditions. The test organism must be a North American resident species offish
or invertebrate. The hierarchies used to select the appropriate acute and chronic values are listed below in
descending order of priority.
Acute Aquatic Life Values:
National acute freshwater quality criteria
Lowest reported acute test values (96-hour LC50 for fish and 48-hour EC50/LC50 for daphnids)
Lowest reported LC50 test value of longer duration, adjusted to estimate a 96-hour exposure period
Lowest reported LC50 test value of longer duration, up to a maximum of 2 weeks exposure
Estimated 96-hour LC50 from the ASTER QSAR model
Chronic Aquatic Life Values:
National chronic freshwater quality criteria
Lowest reported maximum allowable toxic concentration (MATC), lowest observable effect
concentration (LOEC), or no observable effect concentration (NOEC)
Lowest reported chronic growth or reproductive toxicity test concentration
Estimated chronic toxicity concentration from a measured acute chronic ratio for a less sensitive
species, quantitative structure activity relationship (QSAR) model, or default acute: chronic ratio of
10:1
2 Acute and chronic effect concentrations reported in published literature or estimated using various
application techniques.
3-6
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3.3.2 Human Health
EPA has established water quality criteria for the protection of human health based on a pollutant's toxic
effects, including carcinogenic potential. EPA has developed these human health criteria values for two
exposure routes: (1) ingesting the pollutant via contaminated aquatic organisms only, and (2) ingesting the
pollutant via both contaminated water and aquatic organisms. These equations are as follows:
For Toxicity Protection (ingestion of organisms only)
HH = RfD x CF
00 IRf x BCF
where:
HH00 = human health value (Mg/L);
RfD = reference dose (mg/day);
IRf = fish ingestion rate (0.0065 kg/day);
BCF = bioconcentration factor (L/kg); and
CF = conversion factor (1,000 //g/mg).
For Carcinogenicity Protection (ingestion of organisms only)
HH = BW x RL x CF
00 SF x IRf x BCF (Eq' 13)
where:
HH00 = human health value (,ug/L);
BW = body weight (70 kg);
RL = risk level (ID'6);
SF = cancer slope factor (mg/kg/day)"1;
3-7
-------
IRf = fish ingestion rate (0.0065 kg/day);
BCF = bioconcentration factor (L/kg); and
CF = conversion factor (1,000 ^g/mg).
For Toxicity Protection (ingestion of water and organisms)
=
R/D x CF
(IRXBCF)
where:
HHWO = human health value 0/g/L);
RfD = reference dose (mg/day);
IR^ = water ingestion rate (2 liters/day);
IRf = fish ingestion rate (0.0065 kg/day);
BCF = bioconcentration factor (L/kg); and
CF = conversion factor (1,000 /^g/mg).
For Carcinogenic Protection (ingestion of water and organisms)
BW x RL x CF
=
~
SF x [IRw + (IRf x BCF)
where:
HHWO = human health value (,ug/L);
BW = body weight (70 kg);
RL = risk level (10-6);
SF = cancer slope factor (mg/kg/day)"1;
IR^ = water ingestion rate (2 L/day);
IRf = fish ingestion rate (0.0065 kg/day);
BCF = bioconcentration factor (L/kg); and
CF = conversion factor (1,000 //g/mg).
-------
EPA derives the values for ingesting specific pollutants by drinking contaminated water and/or eating
contaminated aquatic organisms by assuming an average daily ingestion of 2 liters of water, an average daily
fish consumption rate (16.6 and 140 grams per day offish products for recreational and subsistence anglers,
respectively), and an average adult body weight of 70 kilograms (USEPA, 1989 a).
If a pollutant of concern has a cancer slope factor, then EPA uses values protective of carcinogenicity to
assess the pollutant's potential effects on human health. EPA develops protective concentration levels for
carcinogens in terms of non-threshold lifetime risk level. This analysis relies on criteria at a risk level of 10"6.
This risk level indicates a probability of one additional case of cancer for every 1,000,000 persons exposed.
Toxic effects criteria for non-carcinogens include systemic effects (e.g., reproductive, immunological,
neurological, circulatory, or respiratory toxicity), organ-specific toxicity, developmental toxicity,
mutagenesis, and lethality.
The hierarchy used to select the most appropriate human health criteria values is presented below in
descending order of priority:
Calculated human health criteria values using EPA's IRIS RfDs or SFs used in conjunction with
adjusted 3 percent lipid BCF values derived from Ambient Water Quality Criteria Documents
(USEPA, 1987b); 3 percent is the mean lipid content offish tissue reported in the study from which
the average daily fish consumption rates are derived.
Calculated human health criteria values using current IRIS RfDs or SFs and representative BCF
values for common North American species of fish or invertebrates or estimated BCF values.
Calculated human health criteria values using RfDs or SFs from EPA's Health Effects Assessment
Summary Tables (HEAST) used in conjunction with adjusted 3 percent lipid BCF values derived
from Ambient Water Quality Criteria Documents (USEPA, 1987b).
Calculated human health criteria values using current RfDs or SFs from HEAST and representative
BCF values for common North American species of fish or invertebrates or estimated BCF values.
Criteria from the Ambient Water Quality Criteria Documents (USEPA, 1987b).
Calculated human health values using RfDs or SFs from data sources other than IRIS or HEAST.
3-9
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This hierarchy is based on Section 2.4.6 of the Technical Support Document for Water Quality-based
Toxics Control (USEPA, 1991a). This document recommends using the most current risk information from
IRIS when estimating human health risks. In cases where chemicals have both RfDs and cancer SFs from the
same level of the hierarchy, EPA calculates human health values using the formulas for carcinogenicity,
which always results in the more stringent value of the two given the risk levels employed.
3-10
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4. Results
4.1 Projected Water Quality Effects
This section presents the results of the analysis of the environmental effects of the CWT discharges at both
baseline and following the adoption of proposed limits and standards. The first subsection, Environmental
Effects of 95 CWT facilities at Baseline and with Proposed Limits and standards, presents the non-
scaled environmental effects of 95 of the 205 CWT facilities that EPA has identified. Specifically, EPA
analyzed 10 of 14 direct and 85 of 147 indirect wastewater dischargers discharging up to 105 pollutants (see
Table 4-1). The 110 CWT facilities not evaluated either are zero dischargers (44) or have insufficient data to
conduct the water quality analysis.
The following subsections present analysis results for each CWT subcategory (metals, oils, and organics).
Each subsection begins with a general overview and then presents results for both the direct and indirect
wastewater discharges analyzed. Many facilities have operations in multiple subcategories, and therefore the
sum of the number of facilities presented in the metals, oils, and organics subcategories is greater than the
total (95). To prevent double counting of loadings at multiple subcategory facilities, EPA only includes
wastes from metals, oils, and organic waste treatment trains in the metals, oils, and organics subcategories,
respectively.
As previously explained, EPA estimates the potential benefits of controlling discharges from CWT facilities
by using modeling techniques to quantify impacts on water quality in receiving water bodies (i.e., potential
impacts on human health and aquatic life), and POTW operations (i.e., biological inhibition and biosolid
contamination). Specifically, EPA compares under current and proposed requirements estimated pollutant
concentrations to water quality criteria or toxic effect levels for both aquatic life and human health. EPA
analyzes direct and indirect dischargers separately. The study did not evaluate the effects of the proposed
technologies on discharging conventional pollutants (e.g., BOD, COD, TSS). For example, although under
baseline conditions, CWT facilities discharge 29.5 million pounds per year of conventional pollutants, the
benefits analysis focuses entirely on reductions in metals and organic pollutants. Finally, EPA assesses the
effects of indirect discharges on POTW operations and biosolids contamination.
4-1
-------
Table 4-1. The 105 Pollutants of Concern for the CWT Industry'
Pollutantsb'c
POLLUTANT
4-Chloro-3 -Methylphenol
4-Methyl-2-Pentanone
Acenaphthene
Acenaphthylene
Acetophenone
Alpha-terpineol
Aluminum
Anthracene
Antimony
Arsenic
Barium
Benzene
Benzo (a) anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzofluorene, 2,3-
Benzoic acid
Benzyl alcohol
M
E
T
A
L
S
X
X
X
X
X
o
I
L
S
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
o
R
G
A
N
I
C
S
X
X
X
X
X
X
POLLUTANT
Biphenyl
Bis(2-ethylhexyl)
phthalate
Boron
Butanone, 2-
Butyl Benzyl
Phthalate
Cadmium
Carbazole
Carbon disulfide
Chlorobenzene
Chloroform
Chromium
Chrysene
Cobalt
Copper
Cresol, o-
Cresol, p-
Cyanide
Di-n-butyl phthalate
Di-n-octyl phthalate
M
E
T
A
L
S
X
X
X
X
X
X
0
I
L
S
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
0
R
G
A
N
I
C
S
X
X
X
X
X
X
X
X
X
POLLUTANT
Dibenzofuran
Dibenzothiophene
Dibromoethane, 1,2-
Dichloroaniline, 2,3-
Dichlorobenzene, 1,2-
Dichlorobenzene, 1,4-
Dichloroethane, 1,2-
Dichloroethene, 1,1-
Dichloromethane
Diethyl phthalate
Dimethyl phenanthrene, 3,6-
Dimethyl phenol, 2,4-
Diphenyl ether
Diphenylamine
Ethylbenzene
Fluoranthene
Fluorene
Hexanoic acid
Iron
M
E
T
A
L
S
X
0
I
L
S
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
0
R
G
A
N
I
C
S
X
X
X
X
X
X
X
a. EPA details the pollutants of concern (POCs) in chapter six of the technical development document. This analysis only includes a
portion of the POCs identified in Chapter 6.
b. Pollutant counts for each CWT industry subcategory are as follows: 23 metals; 89 oils; and 45 organics.
c. The POCs considered in this analysis are presented, by subcategory, in Appendix C.
(Continued onto next page)
4-2
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Table 4-1. The 105 Pollutants of Concern for the CWT Industry a (Continued)
Pollutants b>c
POLLUTANT
Lead
Lithium
Manganese
Mercury
Methyl fluorene, 1 -
Methylnaphthalene, 2-
Methylphenanthrene,
1-
Molybdenum
N-Decane
N-Docosane
N-Dodecane
N-Eicosane
N-Hexadecane
N-Octadecane
N-Tetradecane
Naphthalene
Nickel
M
E
T
A
L
S
X
X
X
X
X
o
I
L
S
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
o
R
G
A
N
I
C
S
X
X
X
X
POLLUTANT
P-Cymene
Pentachlorophenol
Pentamethylbenzene
Phenol
Phenylnaphthalene,
2_
Propanone, 2-
Pyrene
Pyridine
Selenium
Silicon
Strontium
Styrene
Tetrachloroethene
Tetrachloroethane,
1,1,1,2-
Tetrachl oromethane
Tetrachlorophenol,
2,3,4,6 -
Tin
M
E
T
A
L
S
X
X
X
X
0
I
L
S
X
X
X
X
X
X
X
X
X
X
X
0
R
G
A
N
I
C
S
X
X
X
X
X
X
X
X
X
POLLUTANT
Titanium
Toluene
Trans- 1 ,2-dichloroethene
Trichlorobenzene, 1,2,4-
Trichloroethane, 1,1,1-
Trichloroethane, 1,1,2-
Trichloroethene
Trichlorophenol, 2,4,5-
Trichloropropane,
1 23-
A,Z,,~>
Tripropyleneglycol
methylether
Vinyl chloride
Xylene, m-
Xylene, o-, p-
Zinc
M
E
T
A
L
S
X
X
0
I
L
S
X
X
X
X
X
X
X
X
X
0
R
G
A
N
I
C
S
X
X
X
X
X
X
X
X
X
X
a. EPA details the pollutants of concern (POCs) in chapter six of the technical development document. This analysis only includes a
portion of the POCs identified in Chapter 6.
b. Pollutant counts for each CWT industry subcategory are as follows: 23 metals; 89 oils; and 45 organics.
c. The POCs considered in this analysis are presented, by subcategory, in Appendix C.
4-3
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4.1.1 Combined Environmental Effects of 95 CWT Facilities at Baseline and with Proposed Limits
EPA estimates that under baseline, 205 CWT facilities discharge approximately 5.22 million Ibs/year of
metals and organic pollutants. Under the proposed rule pollutant loadings would be reduced by 79% or to
1.08 million Ibs/year. The analysis comparing non-scaled (95 of the 205 facilities) modeled instream
pollutant levels to Ambient Water Quality Criteria (AWQC) estimates that current discharge loadings result
in 110 contraventions of criteria at 18 receiving water location. As seen in Table 4-2, the proposed rule
would reduce the number of contraventions to 53 at 13 receiving water locations. EPA estimates that CWT
discharges to surface waters are responsible for 0.95 cancer cases per year, but would be reduced to 0.3 cases
per year under the proposed rule. In addition, an estimated 91,000 persons would have reduced lead exposure
and related health effects. EPA also estimates the proposed rule would reduce lead uptake enough to prevent
the IQ loss of 72 points in angler children (i.e., children living in a recreational angler's household), and that
the IQs of 34 children would not drop below 70 (see Table 4-3). EPA estimates that six of the 64 POTWs
analyzed experience inhibition problems due to CWT wastes. Under the proposed rule inhibition problems
would be eliminated at two POTWs. The proposed rule would also improve the quality of 4,100 metric tons
ofbiosolids.
Table 4-2. Summary of Non-Scaled Environmental Effects of 95 CWT Facilities '
Loadings (million Ibs/yr) b> c
AWQC Contraventions
Additional Cancer Cases/yr d
Population of 91 ,000 individuals
exposed to lead health effects d
Population of 19,000 individuals
exposed to other non-cancer effects d
POTWs experiencing inhibition
Biosolid Quality
Current
5.22
110 at
18
streams
0.95
6 of 64
Proposal
1.08
53 at
13 streams
0.3
4 of 64
Summary
79% reduction
5 streams become "CWT industry
contaminant free"
0.65 cases reduced each year
Annual benefits are:
Reduction of 1.6 cases of hypertension
Pro tection of 72 IQ points
Prevention of lowering of 34 children's IQs
below 70
Health effects to exposed population are reduced
Potential inhibition eliminated at 2 POTWs
4, 1 00 metric tons improved
a. Modeled results represent 10 direct and 85 indirect waste water dischargers.
b. 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in the analysis.
c. Loadings are scaled to represent all 205 facilities.
d. Lhrough consumption of contaminated fish tissue.
4-4
-------
Table 4-3. Annual Reductions in Lead Related Health Effects From Reducing Lead Exposure of
91,000 People Potentially Affected by CWT Dischargers a
Lead Health Effect
Hypertension (Cases)
Coronary Heart Disease (Cases)
Cerebral Accidents (cases)
Brain Infarction (cases)
Premature Mortality (cases)
IQ point reduction (IQ points)
Children with IQ < 70 (cases)
Men
1.6
0.1
<0.01
<0.01
0.06
NAb
NA
Female
NA
<0.01
<0.01
NA
<0.01
NA
NA
Child
NA
NA
NA
NA
NA
72
34
Neo-Natal
NA
NA
NA
NA
0.05
NA
NA
Total
1.6
0.1
<0.01
NA
0.11
72
34
a. Oil and metal dischargers are included. Organic dischargers do not have lead in waste stream.
b. Not Applicable (NA).
4.1.2 Metals Subcategory
EPA estimates that 59 metal CWT facilities discharge at baseline approximately 1.74 million Ibs/year of
metals and organics to surface waters (see Table 4-4). Under the proposed rule, this pollutant loading would
be reduced by 91% or to 0.15 million Ibs/year.
EPA analyzed the environmental effects of 45 of the 59 metal CWT facilities. EPA estimates the proposed
rule would reduce lead health related effects and prevent the IQ loss of approximately 36 points in angler
children, and the IQs of about 18 children from dropping below 70 (see Table 4-5).
Table 4-4. Metals Subcategory - Summary of Pollutant Loadings
Loadings (pounds/year) a> b
Current
Proposed (Option 4)
BPT/BAT/PSES
No. of Pollutants Evaluated
No. of Facilities Evaluated d
Direct Dischargers
1,460,000
100,000
23
8
Indirect Dischargers c
280,000
50,000
23
37
Total
1,740,000
150,000
23
45
a. Consists of 23 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only
conventional pollutants are not included in this analysis.
b. Loadings are scaled to represent all 59 metal facilities.
c. For Indirect dischargers, loading estimates have been adjusted to account for POTW removals.
d. The total universe consists of 59 facilities (9 directs, 41 indirects and 9 zero dischargers).
4-5
-------
Table 4-5. Metals Subcategory - Estimated Annual Reduction of Lead Related Health Effects
Lead Health Effect
Hypertension (Cases)
Coronary Heart Disease (Cases)
Cerebral Accidents (cases)
Brain Infarction
Premature Mortality (cases)
IQ Point Reduction in Children (IQ points)
Children with IQ < 70 (cases)
Direct
Dischargers (2)
0.5
<0.1
<0.1
<0.1
<0.1
15.5
7
Indirect
Dischargers (1 )
0.3
<0.1
<0.1
<0.1
<0.1
20
10.5
Total
0.8
<0.1
<0.1
<0.1
<0.1
35.5
17.5
(a) Metals Subcategory - Direct Dischargers
EPA estimates that nine direct discharging CWT facilities discharge at baseline approximately 1.46 million
Ibs/year of metals and organics (see Table 4-6). The proposed BAT/BPT (Option 4) levels would reduce this
pollutant loading by 93%, or to 0.1 million Ibs/year.
EPA analyzed the modeled environmental effects of eight of the nine direct discharging CWT facilities. The
analysis comparing modeled instream pollutant levels to AWQC estimates that 11 contraventions in one
stream would be reduced to six (see Table 4-7). Most of the contraventions are for chronic aquatic life
criteria (see Table 4-8).
EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. EPA also projects
that no human populations are exposed to pollutants that could result in non-cancer effects under current
treatment levels. However, EPA estimates that two facilities discharge lead at levels which potentially could
cause adverse health effects in recreational and subsistence angler populations totaling approximately 32,000
individuals. The proposed discharge levels would prevent the IQ loss of 15.5 points in angler children, and
the dropping of seven children's IQs below 70.
4-6
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Table 4-6. Metals Subcategory - Environmental Effects of Eight Direct Dischargers a
Loadings (million Ibs/yr) b
AWQC Contraventions
Additional Cancer Cases/yr c
Population of 32,000
individuals exposed to lead
health effects c
Population exposed to other
non-cancer effects c
Current
1.46
1 1 at one stream
<0.1
0
Proposal
0.1
6 at one stream
<0.1
0
Summary
93% Reduction
Annual benefits are:
Reduction of 0.5 cases of hypertension
Protection of 15. 7 IQ points
Prevention of lowering of 7 children's
IQs below 70
a. Modeled results represent eight of nine direct waste water dischargers. Loadings are scaled to represent all nine facilities.
b. 23 of 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
c. Lhrough consumption of contaminated fish tissue.
Table 4-7. Metals Subcategory - Projected Criteria Contraventions for Eight Direct Dischargers
Acute Aquatic
Life
Chronic Aquatic
Life
Human Health
(Organisms
Only)
Human Health
(Water and
Organisms)
Total *
Current
Streams (No.) b
Pollutants(No)c
1
1
1
10
1
1
1
1
1
11
Proposed Option
Streams (No.)
Pollutants (No.)
0
0
1
6
0
0
0
0
1
6
a. Pollutants may exceed criteria on a number of streams, therefore, total does not equal sum of pollutants exceeding criteria.
b. Number of receiving streams is eight.
c. Number of the 23 different pollutants analyzed that exceed ambient water quality and human heath-based criteria.
4-7
-------
Table 4-8. Metals Subcategory - Pollutants Projected to Exceed Criteria for Eight Direct Dischargers
Pollutants
Arsenic
Aluminum
Boron
Cadmium
Copper
Lead
Mercury
Molybdenum
Selenium
Silver
Zirconium
Total
Pollutants
Acute Aquatic Life * b
Current
1(20)
~
1
Proposed
Option
~
0
Chronic Aquatic Life a' b
Current
1(590)
1(690)
1(1.3)
1(18)
1(7.67)
1(0.09)
1(58)
1(9.3)
1(1.5)
1(16.4)
10
Proposed
Option
1(180)
1(12.5)
1(37.5)
1(7.49)
1(0.44)
1(16.4)
6
Human Health a'b
Current
l(0.95)c
~
1
Proposed
Option
~
0
a. Number(s) in parentheses represent instream concentration (jj.g/L).
b. Numbers outside of parentheses represent the number of occurrence(s) of a pollutant; however different pollutants may be
discharged from the same water body so the total number of occurrences are not the sum of the water bodies where
contraventions occur.
c. Arsenic at 0.95/^g/L is estimated to exceed human health criteria for both organisms only (HH00 ,As^ = 0.14 ,ag/L) and water and
organisms (HHWO (As) = 0.017 ,ug/L)
(b) Metals Subcategory - Indirect Dischargers
EPA estimates that 41 indirect discharging CWT facilities currently discharge 0.28 million Ibs/year of metals
and organics (see Table 4-9). The proposed PSES (Option 4) treatment level would reduce pollutant
loadings by 82%, or to 0.05 million Ibs/year.
EPA modeled the environmental effects of 37 of the 41 indirect discharging CWT facilities. The analysis
comparing modeled instream pollutant levels to AWQC estimates that 13 contraventions in two streams
would be reduced to seven contraventions in two streams (see Tables 4-10). Most of the contraventions are
for chronic aquatic life criteria (see Table 4-11).
EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. However, EPA
estimates that one facility discharges lead at levels which potentially could cause adverse health effects in
recreational and subsistence angler populations totaling approximately 17,000 individuals (see Table 4-9).
The proposed discharge levels would prevent the IQ loss of 20 points in angler children, and the lowering of
ten children's IQs below 70. EPA also estimates a decreased risk of non-cancer effects to an additional
-------
16,800 anglers. The proposed PSES levels would reduce risks to these adult and child populations
significantly.
EPA estimates that one of the 30 POTWs experience inhibition problems due to two pollutants in CWT
wastes (see Tables 4-12). The proposed rule would decrease the number of pollutants to one. The proposed
rule would also allow one POTW to switch its biosolids disposal from incineration to surface disposal.
Table 4-9. Metals Subcategory - Environmental Effects of 37 Indirect Dischargers a> b
Loadings (million Ibs/yr) c
AWQC Contraventions
Additional Cancer Cases/yr d
Population of 17,000
individuals exposed to lead
health effects d
Population of 16,800
individuals exposed to other
non-cancer effects d
POTWs experiencing
inhibition e
Biosolid Quality
Current
0.28
1 3 at 2 streams
<0.1
1 POTW with two
pollutants
Proposal
0.05
7 at 2 streams
<0.1
1 POTW with one
pollutant
Summary
82% Reduction
Annual benefits are:
Reduction of 0.3 cases of hypertension
Protection of 20 IQ points
Prevention of lowering of 10.5
children's IQs below 70
Health effects are significantly
reduced
Potential inhibition reduced by one
pollutant
1 POTW able to switch from
incineration to surface disposal
a. Modeled non-scaled results represent 37 of 41 indirect waste water dischargers. Loadings are scaled to represent all 41 indirect
facilities.
b. For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
c. 23 of 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; conventional
pollutants such as Chemical Oxygen. Demand (COD), BOD5 and Total Suspended Solids (TSS); Total Phenols, hexanoic acid
and Hexane Extractable Material are not representative of the loadings.
d. Through consumption of contaminated fish tissue.
e. Total number of POTWs receiving discharges from Metal subcategory CWTs is 30.
4-9
-------
Table 4-10. Metals Subcategory - Projected Criteria Contraventions for 37 Indirect Dischargers
Acute
Aquatic
Life
Chronic
Aquatic
Life
Human Health
(Water and
Organisms)
Human Health
(Organisms
Only)
Total a
Current
Streams (No.) b
Pollutants (No.) c
1
5
1
12
2
2
1
1
2
13
Proposed Option
Streams (No.)
Pollutants (No.)
1
2
1
6
2
1
1
1
2
7
a. Pollutants may exceed criteria on a number of streams, therefore, the total does not equal the sum of pollutants exceeding criteria.
b. Number of receiving streams is 30 (20 rivers and 10 estuaries).
c. Number of different pollutants that exceed ambient water quality and human heath based criteria.
Table 4-11. Metals Subcategory - Pollutants Projected to Exceed Criteria for 37 Indirect
Dischargers
Pollutants
Aluminum
Antimony
Arsenic °
Boron
Cobalt
Copper
Lead
Mercury
Molybdenum
Nickel
Selenium
Tin
Zinc
Total
Pollutants
Acute Aquatic Life B' b
Current
1(131)
1(650)
1(20)
1(95)
1(242)
5
Proposed
Option
1(20)
1(64)
2
Chronic Aquatic Life a'b
Current
1(951)
1(473)
1(1930)
1(50)
1(16)
1(6.6)
1(1.0)
1(334)
1(277)
1(69)
1(73)
1(176)
12
Proposed
Option
1(146)
1(512)
1(15)
1(0.02)
1(170)
1(47)
6
Human Health (Water & Orgs.) a'b
Current
2(0.16-0.022)
1
Proposed Option
2(0.16-0.022)
1
a. Number(s) in parentheses represent instream concentrations (ug/L).
b. Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be
discharged from the same water body. Therefore the total number of occurrences are not the sum of the waterbodies where
contraventions occur.
c. Exceeds human health-based criteria (organisms only) under current conditions: 1(0.163).
4-10
-------
Table 4-12. Metals Subcategory - Projected POTW Inhibition Problems from 37 Indirect
Dischargers
Biological Inhibition
Current
POTWs (No.) a
Pollutants (No.) b
Total Problems
1
2C
1
Proposed Option
POTWs (No.)
Pollutants (No.)
Total Problems
1
ld
1
a. 37 CWT facilities discharge to 30 POTWs
b. 23 of 105 pollutants are analyzed
c. lead and boron
d. boron
4.1.2 Oils Subcategory
EPA estimates that 128 oil CWT facilities discharge at baseline approximately 1.92 million Ibs/year of
metals and organics to surface waters (see Table 4-13). Under the proposed rule, pollutant loadings would be
reduced by 72% or to 0.53 million Ibs/year.
EPA analyzed the environmental effects of 64 of the 128 oil CWT facilities. EPA estimates that the
proposed limits would reduce additional annual cancer cases from 0.94 to 0.3 (see Table 4-16). EPA also
estimates the proposed rule would reduce lead health related effects and prevent the IQ loss of approximately
36 points in angler children, and the IQs of 16 children from dropping below 70 (see Table 4-14).
(a) Oils Subcategory - Direct Dischargers
EPA estimates that under baseline conditions three direct discharging CWT oils Subcategory facilities
discharge approximately 43,000 Ibs/year of metals and organics (see Table 4-15). Under the proposed
BAT/BPT (Option 9) levels, pollutant loadings would be reduced by 53%, or to 20,000 Ibs/year.
EPA modeled the environmental effects of one of three direct discharging CWT facilities. Under current
conditions, the one facility does not discharge pollutants at levels that exceed AWQC or human health based
4-11
-------
criteria. EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. EPA
projects that no human populations are exposed to pollutants that could result in non-cancer effects under
current treatment levels.
Table 4-13. Oils Subcategory - Summary of Pollutant Loadings
Loadings (pounds/year) a' b
Current
Proposed (BPT/BAT- Option 9)
(PSES - Option 8)
No. of Pollutants Evaluated
No. of Facilities Evaluated
Direct
Dischargers
43,000
20,000
89
1
Indirect
Dischargers c
1,872,000
511,000
89
63
Total
1,915,000
531,000
89
64
a. Consists of 89 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only
conventional pollutants are not included in this analysis.
b. Loadings are scaled to represent all 128 oil facilities.
c. For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
d. The total universe consists of 128 facilities (3 directs, 92 indirects and 33 zero dischargers).
Table 4-14. Oils Subcategory - Estimated Annual Reduction of Lead Related Health Effects
Lead Health Effect
*
Hypertension (Cases)
Coronary Heart Disease (Cases)
Cerebral Accidents (cases)
Brain Infarction
Premature Mortality (cases)
IQ Point Reduction in Children (IQ points)
Children with IQ < 70 (cases)
Indirect
Dischargers (1 )
0.6
<0.1
<0.1
<0.1
<0.1
35.6
16
4-12
-------
Table 4-15. Oils Subcategory - Environmental Effects of One Direct Discharging CWT Facility'
Current Proposal Summary
Loadings (Ibs/yr) b
AWQC Contraventions
Additional Cancer Cases/yr c
Population exposed to non-cancer effects °
43,000
0
<0.1
20,000
0
<0.1
53% Reduction
a. Modeled results represent one of three direct waste water dischargers. Loadings are scaled to represent all three facilities.
b. 89 of 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
c. Lhrough consumption of contaminated fish tissue.
(b) Oils Subcategory - Indirect Dischargers
EPA estimates that 92 indirect discharging CWT facilities currently discharge 1.87 million Ibs/year of metals
and organics (see Table 4-16). Under the proposed PSES (Option 8) treatment level, pollutant loadings
would be reduced by 73%, or to 0.51 million Ibs/year.
EPA modeled the environmental effects of 63 of the 92 indirect discharging oil CWT facilities. The analysis
comparing modeled instream pollutant levels to AWQC estimates that 18 contraventions in 15 streams would
be reduced to nine contraventions in nine streams (see Tables 4-17 and 4-18).
EPA estimates that under the proposed rule, annual cancer cases from consumption of contaminated fish from
water bodies receiving oils indirect dischargers would be reduced from 0.94 cases per year to less than 0.3
cases per year. EPA also estimates that one facility discharges lead at levels which potentially could cause
adverse health effects in recreational and subsistence angler populations totaling approximately 42,000
individuals. EPA estimates that the proposed rules would prevent the loss of 36 IQ points in children of
anglers, and prevent the lowering of 16 children's IQs below 70. EPA also estimates the PSES limits would
reduce the risk of non-cancer effects to an additional 2,100 anglers.
EPA estimates that four of the 48 POTWs experience inhibition problems due to two pollutants in CWT
wastes (see Table 4-19). The proposed rule would decrease the number of POTWs to three. The proposed
rule would also allow one POTW to switch its biosolids disposal from incineration to surface disposal.
4-13
-------
Table 4-16. Oils Subcategory - Environmental Effects of 63 Indirect Dischargers
a,b
Loadings (million Ibs/yr) c
AWQC Contraventions
Additional Cancer Cases/yr d
Population of 42,000
individuals exposed to lead
health effects d
Population of 2,100 individuals
exposed to other non-cancer
effects d
POTWs experiencing
inhibition e
Biosolid Quality
Current
1.87
1 1 at one stream
0.94
4 POTWs with
two pollutants
1POTW
Proposal
0.51
6 at one stream
<0.3
3 POTWs with
two pollutants
0 POTWs
Summary
73% Reduction
A reduction of 0.64 cases / year
Annual benefits are:
Reduction of 0.5 cases of
hypertension
Protection of 15. 7 IQ points
Prevention of lowering of 7
children's IQs below 70
Health effects are reduced
Potential inhibition reduced by one
POTW
1 POTW able to switch from
incineration to surface disposal
a. Modeled non-scaled results represent 63 of 92 indirect waste water dischargers. Loadings are scaled to represent all 92 indirect
dischargers.
b. For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
c. 89 of 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
d. Through consumption of contaminated fish tissue.
e. Total number of POTWs receiving discharges from Metal subcategory CWTs is 48.
Table 4-17. Oils Subcategory - Projected Criteria Contraventions for 63 Indirect Dischargers
Acute
Aquatic
Life
Chronic
Aquatic
Life
Human Health
(Water and
Orgs.) '. .
Human
Health
(Orgs, Only)
Total*
Current
Streams (No.) b
Pollutants (No.) c
1
1
2
8
15
10
15
4
15
18
Proposed Options (8)
Streams (No.)
Pollutants (No.)
0
0
2
2
9
7
9
3
9
9
a. Pollutants may exceed criteria on a number of streams, therefore the total does not equal the sum of pollutants exceeding criteria.
b. 48 POTWs discharge into 48 waterbodies (27 rivers and 21 estuaries).
c. 89 pollutants of 105 (see Table 4-1).
4-14
-------
Table 4-18. Oils Subcategory - Pollutants Projected to Exceed Criteria for 63 Indirect Dischargers
Pollutants
benzo (a) anthracene
benzo(b)fluoranthene
benzo (a) pyrene
bis(2-ethylhexyl
jhthalate
chrysene
1 , 1 -dichloroethene
1 ,4-dichlorobenzene
fluoranthene
methylene chloride
phenanthrene
arsenic
aluminum
boron
iron
lead
mercury
molybdenum
zinc
Total
Pollutants
Acute Aquatic Life
Current
1(152)
1
Proposed
Option
0
Chronic Aquatic Life
Current
1(0.11)
1(9.1)
1(600)
2(62 - 175)
1(1050)
1(3.2)
1(0.02)
1(28)
8
Proposed
Option
1(312)
2(62 - 175)
2
Human Health (Water and Orgs.)
Current
5(0.0028 - 0.02)
1(0.04)
15(0.0004-0.04)
1(9.6)
5(0.005 - 0.003)
1(0.07)
1(1.3)
1(5.1)
12(0.0004 - 0.4)
1(1.4)
10
Proposed
Option
1(0.004)
9(0.0001 - 0.009)
1(0.004)
1(0.07)
1(4.8)
7(0.0003 - 0.08)
1(0.2)
7
Human Health (Orgs. Only)
Current
15(0.0006-0.04)
1(9.6)
5(0.03 - 0.4)
1(1.4)
4
Proposed
Option
9(0.0001 - 0.009)
1(0.08)
1(0.2)
3
a. Number(s) in parentheses represent instream concentrations (/^g/L).
b. Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be discharged from the same water body. Therefore the total
number of occurrences are not the sum of the waterbodies where contraventions occur.
4-15
-------
Table 4-19. Oils Subcategory - Projected POTW Inhibition Problems from 63 Indirect Dischargers
Biological Inhibition
Current
POTWs (No.) b
Pollutants (No.) c
Total Problems
4
2 a
4
Proposed Option 8
POTWs (No.)
Pollutants (No.)
Total Problems
3
2
3
a. arsenic, boron
b 48 POTWs discharge into 48 waterbodies (27 rivers and 21 estuaries).
c. 89 pollutants of 105 (see Table 4-1).
4.1.3 Organics Subcategory
EPA estimates that 19 organic CWT facilities discharge at baseline approximately 1.57 million Ibs/year of
metals and organics to surface waters (see Table 4-20). Under the proposed rule, pollutant loadings would be
reduced by 74% or to 0.4 million Ibs/year. EPA analyzed the environmental effects of all 19 organic
Subcategory CWT facilities.
Table 4-20. Organics Subcategory - Pollutant Loadings for 19 Dischargers
Loadings (pounds/year) a> **
Current
Proposed (Option 4)
BPT/BAT/PSES
No. of Pollutants Evaluated
No. of Facilities Evaluated b
Direct
Dischargers
390,000
390,000
45
4
Indirect
Dischargers
1,180,000
10,000
45
15
Total
1,570,000
400,000
45
19
a. Consists of 45 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only
conventional pollutants are not included in this analysis.
b. The total universe consists of 19 facilities.
4-16
-------
(a) Organics Subcategory - Direct Dischargers
EPA estimates that under baseline conditions four direct discharging CWT facilities discharge approximately
0.39 million Ibs/year of metals and organics facilities (see Table 4-21). Under the proposed BAT/BPT
(Option 4) levels, pollutant loadings would remain at about 0.39 million Ibs/year.
EPA modeled the environmental effects of all of the four organic direct discharging CWTs. The analysis
comparing modeled instream pollutant levels to AWQC estimates that one contravention in one stream would
still occur under the proposed rule. EPA estimates cancer risk from fish consumption to be much less than
0.1 cases per year. EPA also projects that no human populations are exposed to pollutants that could result
in non-cancer effects under current or proposed treatment levels.
Table 4-21. Organics Subcategory - Environmental Effects of Four Direct Dischargers a
Loadings (million Ibs/yr) b
AWQC Contraventions
Additional Cancer Cases/yr c
Population exposed to non-cancer effects c
Current
0.39
one at one stream
<0.1
0
Proposal
0.39
one at one stream
<0.1
0
Summary
No Reduction
a. Modeled results and loadings represent all of the four direct waste water dischargers.
b. 45 of 105 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
c. Lhrough consumption of contaminated fish tissue.
(b) Organics Subcategory - Indirect Dischargers
EPA estimates that 15 indirect discharging CWT facilities currently discharge 1.18 million Ibs/year of metals
and organics (see Table 4-22). Under the proposed PSES (Option 4) treatment level, pollutant loadings
would be reduced by 99%, or to 0.01 million Ibs/year.
EPA modeled the environmental effects of all of the 15 organic indirect discharging CWT facilities. The
analysis comparing modeled instream pollutant levels to AWQC estimates that three contraventions in four
streams would be reduced to zero contraventions in zero streams (see Tables 4-23 and 4-24).
4-17
-------
EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. EPA also
estimates that organic indirect discharges do not substantially increase risk of non-cancer effects to local
anglers. No POTWs are estimated to be affected by CWT organic discharges.
Table 4-22. Organics Subcategory - Environmental Effects of 15 Indirect Dischargers a> b
Loadings (million Ibs/yr) °
AWQC Contraventions
Additional Cancer Cases/yr d
Population exposed to non-
cancer effects d
POTWs experiencing
inhibition e
Biosolid Quality
Current
1.18
three at four
streams
<0.1
0
0
0
Proposal
0.01
zero at zero
streams
<0.1
0
0
0
Summary
99% Reduction
a. Modeled results represent all of the 15 indirect waste water dischargers.
b. For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
c. Consists of 45 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only
conventional pollutants are not included in this analysis.
d. Through consumption of contaminated fish tissue.
e. Total number of POTWs receiving discharges from organic subcategory CWTs is 15.
Table 4-23. Organics Subcategory - Projected Criteria Contraventions for 15 Indirect Dischargers
Acute Aquatic
Life
Chronic Aquatic
Life
Human Health
(Water and Orgs.)
Human Health
(Qrgs. Only)
Total8
Current
Streams (No.)
Pollutants (No.) b
0
0
1
2
4
1
0
0
4
3
Proposed Option
Streams (No.)
Pollutants (No.)
0
0
0
0
0
0
0
0
0
0
a. Pollutants may exceed criteria on a number of streams, therefore, the total does not equal the sum of pollutants exceeding criteria.
b. Number of different pollutants that exceed ambient water quality and human heath based criteria.
4-18
-------
Table 4-24. Organics Subcategory - Pollutants Projected to Exceed Criteria for Indirect Dischargers
Pollutants
Aluminum
Boron
Methylene
chloride
Total
Pollutants
Acute Aquatic
Lifea'b
Current
0
Proposed
Option
0
Chronic Aquatic
Lifea'b
Current
1(125)
1(38)
2
Proposed
Option
0
Human Health
(Water and Orgs.)a»b
Current
4(5.5-310)
1
Proposed
Option
0
Human Health
(Orgs, Only)a»b
Current
0
Proposed
Option
0
a. Number(s) in parentheses represent instream concentrations Oug/1).
b. Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be
discharged from the same water body. Therefore the total number of occurrences are not the sum of the water bodies where
contraventions occur.
4.2 Documented Environmental Effects
4.2.1 Permit Violations of CWT Facilities
EPA Regional personnel and the corresponding State Pretreatment Coordinators identified a total of 35
facilities which have had various permit violations (see Appendix D, Table D-l). Of the 35 facilities that
have reported violations, only five continue to have discharge violations or continue to present problems for
the receiving POTW. Violations may take the form of a permit exceedence, local limit exceedence, pass
through problem for receiving POTW, negative effect on surface water quality, or negative effect on water
odor. The most commonly cited violations involve metal discharges.
4.2.2 Effects of CWT Wastes on POTW Operations and Water Quality
EPA identified environmental effects on POTW operations and water quality due to discharges of pollutants
from nine indirect CWT facilities. Effects include seven cases of impairment to POTW operations due to
cyanide, nitrate/nitrite, sodium, zinc and ammonia, and one case of an effect on the quality of receiving water
due to organics (Table 4-25). In addition, the states identified four direct centralized waste treatment
facilities and eight POTWs, which receive the discharge from 13 facilities, as point sources causing water
quality problems included on state 304(1) Short Lists (see Tables 4-26 and 4-27).
4-19
-------
Pollutants of concern include cadmium, copper, cyanide, lead, mercury, nickel, selenium, silver, zinc, and
organics. Section 304(1) of the Water Quality Act of 1987 requires States to identify water bodies impaired
by the presence of toxic substances, to identify point source discharges of these toxics, and to develop
Individual Control Strategies (ICSs) for these discharges. The Short List is a list of waters for which a State
does not expect achievement of the applicable water quality standards (numeric or narrative) to be achieved
after technology-based requirements have been met due entirely or substantially to point source discharges of
Section 307(a) toxics.
4-20
-------
Table 4-25. Documented Environment Effects of CWT Wastes on POTW Operations and Water Quality
' POTW
Case #1
Case #2
Case #3
Case #4
Case #5
Case #6
Case #7
Case #8
Case #9
Identified Impacts
High concentrations of nitrate, nitrate and sodium in CWT's batch discharges responsible for interference of
POTW operations (1 993/1 994). High chlorine demand of discharges caused loss of chlorine residual and
resulted in POTW fecal coliform violations; $5000 fine is pending.
Permit violations for phosphorus and total cyanide (1992/1993). Discharge of high levels of cyanide caused
interference of POTW operations and results in $10,000 fine.
Municipality below POTW developed drinking water taste and odor problems. Organics discharged by CWT
identified as source.
Permit violations of Total Toxic Organics(TTO), cyanide, nickel, fats, oils and grease (FOG), lead, zinc and
mercury (1989-1990). Resulted in $60,000 fine.
Zinc and Ammonia pass-through events from CWT discharges caused POTW NPDES violations in 1991 and
1996, respectively.
Ammonia-nitrate pass-through from CWT discharge caused POTW NPDES violations due to nitrification
inhibition (1991/1 992). POTW fined CWT facility $3 ,450 for violation.
Zinc pass-through from CWT discharge caused POTW NPDES violations on 3 occasions (1993). Since
CWT receives both wastewater and hazardous wastes, under CFR section 261.4, they claim they do not need a
RCRA permit. In 1 997 a law suit between the CWT and both the POTW and Citizens was settled. The CWT
paid $650,000 and $300,000 to the POTW and citizens, respectively.
High strength ammonia discharge from CWT caused inhibitions problems resulting in low pH POTW NPDES
violations on 3 occasions (1991).
POTW permit violations of copper and cyanide resulted in a pass-through event. CWT fined cost of all
analytic and administrative work needed to be performed subsequent to the violations. This order expired in
1998, and now the POTW is collecting new compliance data.
Source: EPA Regions and State Pretreatment Coordinators.
4-21
-------
Table 4-26. CWT Facilities Included on State 304(L) Short Lists
'NPDES
AL0003247
CT0001376
NJ0003867
PA0027715
Facility Name
Sloss Industries
Pratt & Whitney
CP Chemicals
Mill Service
City
Birmingham
East Hartford
Sewaren
Yukon
Waterbody
Five Mile Creek
Willow Brook
(Connecticut River)
Woodbridge Creek
(Arthur Kill)
Sewickley Creek
Reach Number
03160111006
01080205024
02030104003
05020006045
Listed Pollutants
Cadmium, Copper, Cyanide,
Lead, Zinc
Copper, Nickel, Zinc
Copper, Lead, Nickel, Zinc
Copper, Lead, Silver
Source: Compiled from OW files dated April/May 1991.
4-22
-------
Table 4-27. POTWs Which Receive Discharge From CWT Facilities and are Included on State 304(L) Short Lists
Facility Name
Clean Harbors
Environmental Waste
Control
Edwards Oil
DYNECOL
American Tank
Service
American Waste Oil
CYANOKEM
Chemical Waste
Management
Waste Conversion
Envirite
ETICAM
Belpar Environmental
Crosby and Overton
City
Baltimore
Inkster
Detroit
Detroit
Ferndale
Belleville
Detroit
Newark
Hatfield
York
Warwick
Prince George
Kent
Receiving
POTW
Back River WWTP
Detroit WWTP
Detroit WWTP
Detroit WWTP
Detroit WWTP
Detroit WWTP
Detroit WWTP
Passaic Valley
Sewage Comm.
Hatfield TWP
Mun. Authority
Springettsbury TWP
Warwick WWTP
Hopewell POTW
Metro (Renton STP)
POTW
NPDES
MD0021555
MI0022802
MI0022802
MI0022802
MI0022802
MI0022802
MI0022802
NJ0021016
PA0026247
PA0026808
RI0100234
VA0066630
WA0029581
Waterbpdy
Back River to Curtis Bay
Detroit River
Detroit River
Detroit River
Detroit River
Detroit River
Detroit River
Upper New York Bay
W.B. Neshaminy Creek
to Neshaminy River
Codorus Creek
Pawtuxet River
Gravelly Run to James
River
Green River
Reach Number
18050004002
04090004009
04090004009
04090004009
04090004009
04090004009
04090004009
02030104001
02040201011
02050306066
0109004029
02080206041
17110013004
Pollutants
Lead, Mercury, Selenium
Cadmium, Copper, Lead,
Mercury, PCBs
Cadmium, Copper, Lead,
Mercury, PCBs
Cadmium, Copper, Lead,
Mercury, PCBs
Cadmium, Copper, Lead,
Mercury, PCBs
Cadmium, Copper, Lead,
Mercury, PCBs
Cadmium, Copper, Lead,
Mercury, PCBs
Cadmium, Lead, Mercury
27 Organics
-
Lead, Silver
Copper, Lead, Zinc
-
Source: Compiled From OW Files Dated April/May 1991.
4-23
-------
APPENDIX A
DILUTION CONCENTRATION POTENTIAL (DCP) VALUES
-------
Appendix A. Dilution Concentration Potential (DCP) Values for Specific
Water Bodies
Receiving Water Body
Dilution Concentration Potential
Detroit River, MI
Pacific Ocean (Vernon, CA)
James River, VA (Chesapeake Bay)
Puget Sound, WA
Niagra River, NY
Lake Michigan, IL
San Francisco Bay, CA
South Oyster Bay, NY
Upper New York Bay, NJ
Curtis Bay, MD (Chesapeake Bay)
Alameda Creek, CA
Arthur Kill, NJ
Pacific Ocean (Long Beach, CA)
Green River, WA
Carney's Point, NJ
Clear Creek, TX
Corpus Cristi Bay, TX
San Francisco Bay, CA
Tucker Bayou, TX
Neches River, TX
Pacific Ocean (Los Angeles, CA)
Pacific Ocean (Honolulu, HI)
Calcasieu, LA
Deleware River, NJ
San Francisco Bay (E. Palo Alto), CA
Pacific Ocean (Santa Fe Springs, CA)
Tallaboa Bay, PR
Bayou Sara, AL
Lake Erie, OH
Casco Bay, ME
Atlantic Ocean (Miami, FL)
Pacific Ocean (Compton, CA)
Holmes Run/Cameron Run, VA (Chesapeake Bay)
Charles River, MA
St. Johns River, FL
Mobile Bay, AL
0.2
0.685
0.072
0.039
0.2
0.0042
1.371
0.054
0.233
0.072
0.048
0.223
0.2
0.2
0.2
0.41
0.467
0.048
0.41
0.38
0.685
1.5
1.18
0.014
0.104
0.685
1.371
0.08
0.2
0.061
0.4
0.685
0.072
0.27
0.083
0.08
A-2
-------
Appendix A. Dilution Concentration Potential (DCP) Values for Specific
Water Bodies
Receiving Water Body
Dilution Concentration Potential
Mississippi River, LA
Atlantic Ocean (Pompano Beach, FL)
Elizabeth River, VA
Cedar Bayou, TX
Pensacola Bay, FL
Lake Michigan, WI
Alamitos Creek, CA
Pascagoula River, MS
Boston Bay, MA
0.01
1.0
0.14
0.41
0.46
0.3
0.192
0.17
0.27
A-3
-------
APPENDIX B
TOXICOLOGICAL INFORMATION
-------
Appendix B. Toxicity Values for the Contaminants Analyzed in the Centralized Waste Treatment Industry
Chemical
Xylene, o-, p-
4-Chloro-3-methylphenol
4-Methyl-2-pentanone
Acenaphthene
Acenaphthylene
Alpha-terpineol
Aluminum
Ammonia
Anthracene
Antimony
Arsenic
Barium
Benzene
Benzo (a) anthracene
Benzo(a)pyrene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
Benzofluorene, 2,3-
Benzoic acid
Benzyl alcohol
Biphenyl
Bis(2-ethylhexyl) phthalate
Boron
Butanone, 2-
RfD
2
0.05
0.06
0.3
0
0
0.07
4
0.3
0.05
0.02
0.09
0.6
SF
1.75
0.02
9
1.06
7.3
1.02
0.48
0.01
4
BCF
208
79
2.4
242
286
231
478
1
44
5.21
4620
11100
30
30
10100
15
4
436
130
1
Acute
AWQC
2600
4050
505000
1688
14533
748
2.78
88
360
410000
5300
10
5
576
180000
10000
360
400
3220000
Chronic
AWQC
660
1300
56200
23
665
5503
87
2.2
30
190
2813
530
1
0.08
26
17178
1000
170
360
31.6
263420
Human Health
Organism
100000
220000
2670
6800
4300
0.14
71.3
0.031
0.00013
0.35
0.75
2871800
810000
1235
5.9
6500000
Human Health
Water and Organism
42000
3000
1700
1175
4100
13.9
0.017
1000
1.2
0.0028
0.00013
0.03
0.066
130000
10000
724
1.8
21000
B-l
-------
Chemical
Butyl benzyl phthalate
Cadmium
Carbazole
Carbon disulfide
Chlorobenzene
Chloroform
Chromium
Chrysene
Cobalt
Copper
Cresol, o-
Cresol, p-
Cyanide
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzofuran
Dibenzothiophene
Dichlorobenzene, 1,2-
Dichlorobenzene, 1,4-
Dichloroethane, 1,2-
Dichloroethene, 1,1-
RfD
0.2
0
0.1
0.02
0.01
1
0.05
0.05
0.1
0.02
0.09
0.009
SF
0.02
0.00
6
0.03
2
0.02
4
0.09
1
0.6
BCF
414
64
251
11.5
10.3
3.75
16
4620
360
18
17.6
89
5460
1349
1100
55.6
55.6
1.2
5.6
Acute
AWQC
2320
3.9
2180
2100
2370
13300
1700
1020
1620
18
8400
7500
850
690
1700
420
1580
1120
116000
108000
Chronic
AWQC
260
1.1
875
2
2100
6300
210
102
49
12
1809
2570
500
69
280
122
550
763
11000
8614
Human Health
Organism
5200
84.1
2.2
94000
21000
470
670000
0.03
29900
31000
12000
39.4
17000
8.07
98.6
3.2
Human Health
Water and Organism
3000
14.5
0.96
3400
680
5.7
33000
0.0028
1300
1700
1700
2700
37.34
2700
1.24
0.38
0.057
B-2
-------
Chemical
Dichloromethane
Diethyl ether
Diethyl phthalate
Dimethylphenanthrene ,
3.6-
Dimethylphenol, 2,4-
Diphenyl ether
Diphenylamine
Ethylbenzene
Fluoranthene
Fluorene
Hexanoic acid
Iron
Lead
Lithium
Lutetium
Manganese
Mercury
Methylfluorene, 1-
Methylnaphthalene, 2-
Methylphenanthrene, 1-
Molybdenum
N-Decane
N-Docosane
N-Dodecane
RfD
0.06
0.8
0.02
0.025
0.1
0.04
0.04
0.3
0.005
0
0.005
SF
0.00
8
BCF
0.91
73
94
930
269
37.5
1150
30
16
49
5500
3300
2566
8800
100000
14500
Acute
AWQC
330000
31800
2120
4000
4760
9090
3980
212
320000
82
2.4
541
909
18000
53000
18000
Chronic
AWQC
82500
10000
1970
213
378
4600
6.16
8
16437
1000
3.2
388
0.012
63
309
27.8
1300
68000
1300
Human Health
Organism
1600
118019
2300
1000
29000
370
14000
0.15
Human Health
Water and Organism
4.7
22631
540
480
3100
300
1300
50
100
0.14
B-3
-------
Chemical
N-Eicosane
N-Hexadecane
N-Octadecane
N-Tetradecane
Naphthalene
Nickel
P-Cynene
Pentamethylbenzene
Phenol
Phenylnaphthalene, 2-
Phosphorus
Propanone, 2-
Pyrene
Pyridine
Selenium
Silicon
Strontium
Styrene
Sulfur
Tin
Titanium
Toluene
Trichlorobenzene, 1,2,4-
Trichloroethane , 1,1,1-
Trichloroethene
RfD
0.04
0.02
0.6
0.1
0.03
0.001
0.005
0.6
0.2
0.6
0.2
0.01
0.09
SF
BCF
100000
32300
10100
19500
10.5
47
770
1.4
0.39
1110
2
4.8
13.5
10.7
1202
5.6
10.6
Acute
AWQC
18000
18000
18000
1600
1400
6500
4200
6210000
1010
93800
20
4020
5500
930
42300
40700
Chronic
AWQC
1300
1300
1300
370
160
130
200
1000000
101
25000
5
402
18.6
191
1000
286
1300
100
Human Health
Organism
41026
4600
4600000
2800000
291
5400
11000
160000
200000
89.6
170000
80.7
Human Health
Water and Organism
1354
610
21000
3500
228
34.8
170
6700
6800
71.3
3100
2.7
B-4
-------
Chemical
Tripropyleneglycol-
methylether
Xylene, m-
Zinc
RfD
2
0.3
SF
BCF
208
47
Acute
AWQC
2484600
16000
120
Chronic
AWQC
683870
3900
110
Human Health
Organism
100000
69000
Human Health
Water and Organism
42000
9100
B-5
-------
APPENDIX C
POLLUTANTS OF CONCERN CONSIDERED FOR THIS ANALYSIS
-------
Table C-l. Metals Subcategory - Pollutants of Concern a
Pollutants b
Aluminum
Antimony
Arsenic
Barium
Benzoic acid
Boron
Butanone, 2-
Cadmium
Chromium
Cobalt
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Nickel
Propanone, 2-
Selenium
Silicon
Tin
Titanium
Zinc
a. Chapter six of the technical development document details the POCs for this subcategory; this list is a subset of those listed in
Chapter six.
b. Although the total number of documented metals and organics pollutants is 28, only 23 pollutants were analyzed due to a lack of
information on AWQC and toxicological information.
C-2
-------
Table C-2. Oils Subcategory - Pollutants of Concern a
Pollutants b
4-Chloro-3-Methylphenol
4-Methyl-2-Pentanone
Acenaphthene
Acenaphthylene
Alpha-terpineol
Aluminum
Anthracene
Antimony
Arsenic
Barium
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzofluorene, 2,3-
Benzoic acid
Benzyl alcohol
Biphenyl
Bis(2-ethylhexyl) phthalate
Boron
Butanone, 2-
Butyl Benzyl Phthalate
Cadmium
Carbazole
Carbon disulfide
Chlorobenzene
Chloroform
Chromium
Chrysene
Cobalt
Copper
Cresol, o-
Cresol, p-
Di-n-butyl phthalate
Di-n-octyl phthalate
Dibenzofuran
Dibenzothiophene
Dichlorobenzene, 1,2-
Dichlorobenzene, 1,4-
Dichloroethane, 1,2-
Dichloroethene, 1,1-
Dichloromethane
Diethyl phthalate
Dimethylphenanthrene, 3,6-
Dimethylphenol, 2,4-
Diphenyl ether
Diphenylamine
Ethylbenzene
Fluoranthene
Fluorene
Hexanoic acid
Iron
Lead
Manganese
Mercury
Methylfluorene, 1-
Methylnaphthalene, 2-
Methylphenanthrene, 1-
Molybdenum
N-Decane
N-Docosane
N-Dodecane
N-Eicosane
N-Hexadecane
N-Octadecane
N-Tetradecane
Naphthalene
Nickel
P-Cymene
Pentamethylbenzene
Phenol
Phenylnaphthalene, 2-
Propanone, 2-
Pyrene
Selenium
Silicon
Strontium
Styrene
Tin
Titanium
Toluene
Trichlorobenzene, 1,2,4-
Trichloroethane, 1,1,1-
Trichloroethene
Tripropyleneglycolmethylether
Xylene, m-
Xylene, o-, p-
Zinc
a. Chapter six of the technical development document details the POCs for this subcategory; this list is a subset of those listed in
Chapter six.
b. Although the total number of documented metals and organics pollutants is 93, only 89 pollutants were analyzed due to a lack of
information on AWQC and toxicological information.
c-:
-------
Table C-3. Organics SubcategoryPollutants of Concern
Pollutants b
4-methyl-2-pentanone
aluminum
antimony
barium
benzene
boron
2-butanone
chloroform
chromium
cobalt
copper
o-cresol
p-cresol
cyanide
1 ,2-dichloroethane
1,1-dichloroethene
hexanoic acid
tetrachloroethene
tetrachloromethane
trans- 1,2-dichloroethene
vinyl chloride
2,3 ,4,6-tetrachlorophenol
2,4,5-trichlorophenol
iron
lithium
manganese
molybdenum
phenol
2-propanone
pyridine
methylene chloride
nickel
pentachlorophenol
tin
toluene
1,1,1 -trichloroethane
trichloroethene
m-xylene
zinc
1,1,1 ,2-tetrachloroethane
1 , 1 ,2-trichloroethane
1,2,3-trichloropropane
1 ,2-dibromoethane
2,3-dichloroaniline
acetophenone
a. Chapter six of the technical development document details the POCs for this subcategory; this list is a subset of those listed in
Chapter six.
b. Although the total number of documented metals and organics is 56, only 45 pollutants were analyzed due to a lack of information
on AWQC and toxicological information.
C-4
-------
APPENDIX D
DOCUMENTED ENVIRONMENTAL EFFECTS
D- 1
-------
DOCUMENTED ENVIRONMENTAL EFFECTS
(Excerpts taken from the May 5, 1998 memo prepared by ABT Associates, for Charles
Tamulonis, titled Summary of Documented POTW Problems from Centralized Waste
Treatment Facilities and Potential Monetization of Case Studies. Memo is in the CBI
record)
Problems with CWT facilities were identified through a series of phone conversations
made during the months of June through September 1997 with EPA regional coordinators
regarding 156 CWT facilities nationwide.
A total of 35 facilities were reported as having problems with their discharge. These
problems may take the form of a permit exceedence, local limit exceedence, pass through
problem for receiving POTW, negative impact on surface water quality, or negative
impact on water odor.
The most commonly cited violations involve metals discharge. Permit violations for lead,
silver, arsenic, zinc copper, nickel, mercury, and aluminum were reported by POTWs as
originating from CWT facilities. Other commonly cited violations involved ammonia and
oil and grease. Table 1 below presents the reported violations at 35 facilities in eight
different EPA regions . Table 1 also lists the impacts of the violations on POTWs, the
actions taken by the facility in response to the violation, and the current violation status of
the facility.
As Table 1 demonstrates, violations at CWT facilities have not been insignificant.
However, of the 35 facilities that have reported violations, only five continue to have
discharge violations or continue to present problems for the receiving POTW. Three
facilities have ceased discharging processed wastewater to the POTW, 16 have remedied
the problem through more stringent quality assurance and quality control (QA/QC)
procedures, and the current status of the remaining 11 facilities is not known.
1 Regions 8 and 9 reported no violations.
D-2
-------
Table D.I. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Facility 1
Facility 2
Facility 3
Facility 4
Facility 5
Facility 6
Facility 7
Facility 8
Reported Violation
Violation data were not available;
either this facility does not have
violations or is a minor permittee.
High chlorine demand and high
concentrations of nitrate, nitrite,
sodium, lead, silver, and arsenic in
influent to the POTW.
Ffigh cyanide and metal concentrations
in influent flow to the POTW in the
past. Facility has no non-compliance
issues now.
Unacceptably high levels of copper,
lead, nickel and zinc in receiving
water.
Permit violations (specific violation
data were not available.)
Permit violations (specific violation
data were not available.)
Ffigh concentration of phosphorus and
cyanide in influent flow to the POTW.
Ffigh concentrations of cadmium, lead
and mercury in influent flow to the
POTW.
Impacts on Receiving Waterbody
or POTW
POTW had fecal coliform
violations due to high chlorine
demand. Also potential pass-
through of lead and silver and
arsenic.
Interference with POTW
operations.
Potential impact on surface water
quality (potential pass-through of
cadmium, lead and mercury).
Actions Taken
Facility was fined $5,000.
POTW was placed on the
RI State 304 list.
Information on steps
taken to remediate the
problem is not available.
Information on steps
taken to remediate the
problem is not available.
Facility was fined
$10,000.
Facility was required to
upgrade its waste
characterization system.
POTW was placed on the
State 304(L) Short list.
Current Status
Facility improved its QA/QC and
screens every batch of pollutants.
Recent violations are minor and
sporadic.
Facility adopted more stringent
QA/QC procedures.
Facility has not had any
significant violations over the past
3 years.
Facility no longer treats waste at
this site.
D-3
-------
Table D.I. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Facility 9
Facility 10
Facility 11
Facility 12
Facility 13
Facility 14
Facility 15
Facility 16
Facility 17
Reported Violation
Fligh concentrations of copper, lead
and silver discharged to the receiving
water.
Fligh concentrations of copper (0.06
mg/1) and aluminum (1.41 mg/1)
discharged to receiving water.
Fligh concentrations of organics in
influent flow to the POTW.
Fligh concentrations of TTO, cyanide,
nickel, fats, oils and grease, lead, zinc,
and mercury.
Fligh concentrations of lead and zinc
in influent flow to the POTW.
A couple of minor, one-time
exceedances in the past.
Monitoring the temperature and
chlorine content of their discharge.
Monitoring of gas extraction
condensate.
Fligh concentrations of cadmium,
copper, cyanide, lead, and zinc
discharged to receiving water.
Impacts on Receiving Waterbody
or POTW
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Customers complained about the
taste and odor of the local
drinking water supply.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Actions Taken
POTW was placed on the
State 304(L) Short list.
POTW was placed on the
State 304(L) Short list.
Facility was fined
$60,000 for permit
violations. POTW was
placed on the State
304(L) Short list.
POTW was placed on the
State 304(L) Short list.
POTW was placed on the
State 304(L) Short list
POTW was placed on the
State 304(L) Short list.
Current Status
Facility has not had any
significant violations since 1991.
Low level concentrations are still
a concern.
Facility has had an excellent
compliance record for the past
few years.
The site has not engaged in non-
compliance practices with the
exception of occasional reporting
violations since Waste
Management took over.
The last violation was in 1994.
D-4
-------
Table D.I. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Facility 18
Facility 19
Facility 20
Facility 21
Facility 22
Facility 23
Reported Violation
Fligh concentrations of oil and grease,
phenols, and ammonia discharged to
receiving water.
Fligh concentrations of lead, cyanide,
oil and grease dicharged to receiving
water. They also had temperature and
pH problems.
High concentrations of BOD (50.0
mg/L), TSS (238.0 mg/L), oil and
grease (13.2 mg/L), zinc (320 ,ag/L)
as well as CBOD, copper, pH and
fecal coliform discharged to receiving
water. The facility also had problems
with boiler blowdown, softener
regeneration backwash, and sanitary
wastes.
High concentrations of zinc (2410
Mg/L), fats, oils, and grease (348
mg/L), nickel (1,700 mg/L), and
ammonia (8.92 mg/L) in influent flow
to the POTW.
High concentrations of organics
(including benzene) and metals in
influent flow to the POTW.
High concentrations of ammonia,
cyanide, and oil and grease in influent
flow to the POTW.
Impacts on Receiving Waterbody
or POTW
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
POTW had NPDES violations
due to zinc pass-through. There
was also an incident with
ammonia pass-through for which
the facility was fined.
Discharged organic waste has
produced health and
environmental hazards and foul
odors.
POTW had NPDES violations
due to discharge containing
ammonia-nitrate which caused
nitrification inhibition.
Actions Taken
For the ammonia there
was a prohibited
discharge surcharge of
$175 and one to two
thousand dollars to
reimburse the POTW.
A civil lawsuit was settled
and the POTW received
$650,000 and the
Citizen's suit received
$300,000.
The POTW fined the
facility $3,450 for these
violations.
Current Status
Thay are currently involved in a
lawsuit due to which further
information on violations and
remediation processes was not
available.
The facility tied all of its non-
contacting cooling water
processes together and now
discharges to the POTW. They
are only directly discharging
groundwater and storm water.
Facility adopted more stringent
QA/QC procedures.
The facility is now bound by local
limits developed by the POTW
for organics. The facility has not
improved.
Facility adopted more stringent
QA/QC procedures.
D-5
-------
Table D.I. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Facility 24
Facility 25
Facility 26
Facility 27
Faciliity 28
Facility 29
Facility 30
Facility 31
Reported Violation
Ffigh concentrations of ammonia in
influent flow to the POTW.
Ffigh concentrations of dissolved
oxygen levels and a sewer overflow
event.
Slug loading was caused at the POTW
due to the discharge of malodorous
solids into the sewer system, reducing
air flow in the plant's oxidation dishes.
Ffigh concentrations of copper,
cyanide, zinc and lead in influent flow
to the POTW.
Ffigh concentrations of zinc, copper
and lead in influent flow to the
POTW.
Ffigh concentrations of zinc and
copper in influent flow to the POTW.
Ffigh concentrations of total
recoverable phenolics, TSS, BOD, pH,
single phenol compound, COD, free
cyanide amenable to chlorination and
bis(2-ethylhexyl)phthalate discharged
to receiving water.
Ffigh concentrations of organics and
benzene discharged to receiving water.
Impacts on Receiving Waterbody
or POTW
POTW had NPDES violations
for low pH causing inhibition
problems.
Interference with POTW
operations.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Actions Taken
POTW was placed on the
State 304(L) Short list.
POTW has fined the
facility for administrative
and analytic work.
The facility has been
subject to administrative
and penalty orders. A
violator may have to pay
$2,000 per violation per
day up to $10,000 for
administrative orders.
Current Status
Facility adopted more stringent
QA/QC procedures and screens
every batch of pollutants.
The facility has ceased operation.
Facility adopted more stringent
QA/QC procedures.
Facility adopted more stringent
QA/QC procedures.
Facility adopted more stringent
QA/QC procedures.
The facility could not comply
with POTW limits and now they
haul waste by truck to
Indianapolis.
The facility has had no significant
violations recently.
The facility has not committed
any violations for a number of
years.
D-6
-------
Table D.I. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Facility 32
Facility 33
Facility 34
Facility 35
Reported Violation
Facility had a reporting problem but it
was not a situation of non-compliance.
Ffigh concentrations of chromium
(7.42 mg/L), nickel (2.97 mg/L), zinc
(5.17 mg/L), and nonpolar fats, oil and
grease (407.3 mg/L) discharged to
receiving water.
Ffigh concentrations of copper, zinc,
chromium, lead, nickel and fluoride.
Ffigh concentrations of sulfate,
phenols and pH.
Impacts on Receiving Waterbody
or POTW
Potential impact on surface water
quality. POTW placed on 304
(L) short list.
Potential impact on surface water
quality.
Potential impact on surface water
quality.
Actions Taken
The issue was resolved
without any major
problems to the POTW.
The facility was fined
$4,840 which covered all
post- violation charges,
including follow-up
inspections, sampling and
analytic tests.
A telephone conversation
and a notice of violation.
Compliance Telephone
Memorandums.
Current Status
The facility and POTW have been
unable to reach a negotiated
settlement.
The facility has some equipment
upgrades to improve the
efficiency of the facility, not to
address compliance issues.
D-7
------- |