xvEPA
            United States
            Environmental Protection'
            Agency	
            Office of Water
            (4303)  " '
EPA 821rR-98-020
ttecfetniber 1998
Development Document for
Proposed Effluent Limitations
Guidelines and Standards for
the Centralized Waste
Treatment Industry
            Volume

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vvEPA
Development Document for
Proposed Effluent Limitations
Guidelines and Standards for
the Centralized Waste
Treatment Industry
                Volume I
                (EPA821-R-98-020)
                Carol M. Browner
                Administrator

                J. Charles Fox
                Assistant Administrator, Office of Water

                Tudor T. Davies
                Director, Office of Science and Technology

                Sheila E. Frace
                Acting Director, Engineering and Analysis Division

                Elwood H. Forsht
                Chief, Chemicals and Metals Branch

                Jan S. Matuszko
                Project Manager

                Timothy E. Connor
                Project Engineer

                Maria D. Smith
                Project Statistician

                December 1998
                U.S. Environmental Protection Agency
                Office of Water
                Washington, DC 20460

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           ACKNOWLEDGEMENTS AND DISCLAIMER

     The Agency would like to acknowledge the contributions of Jan Matuszko, Maria Smith,
     Richard Witt, Tim Connor, Ahmar Siddiqui, Ed Terry, Hugh Wise, Steve Geil, Henry Kahn,
and Beverly Randolph to development of this technical document. In addition EPA acknowledges
the contribution of Science Applications International Corporation under contract 68-C5-0040.

       Neither the United States government nor any of its employees, contractors, subcontractors,
or other employees makes any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of, or the results of such use of, any information, apparatus,
product, or process discussed in this report, or represents that its use by such a third party would not
infringe on privately owned rights.

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                                            TABLE OF CONTENTS
Volume 1:

Chapter 1      BACKGROUND	1-1

       1.0    LEGAL AUTHORITY	i-l

       l.l    LEGISLATIVE BACKGROUND  	i-l
              1.1.1  Clean Water Act  	1-1
                    1.1.1.1 Best Practicable Control Technology Currently Availabl
                           (BPT)-Sec.304(b)(l) of the CWA	1-1
                    1.1.1.2 Best Conventional Pollutant Control Technology (BCT)-Sec
                           304(b)(4) of the CWA	1-2
                    1.1.1.3 Best Available Technology Economically Achievable (BAT)
                           Sec. 304(b)(2) of the CWA	1-2
                    1.1.1.4 New Source Performance Standards (NSPS)~Sec.306 of the
                           CWA	1-2
                    1.1.1.5 Pretreatment Standards for Existing Sources (PSES)
                           Sec.307(b) of the CWA	1-3
                    1.1.1.6 Pretreatment Standards for New Sources (PSNS)-Sec.307(b)
                           of the CWA  	1-3
              1.1.2  Section 304(m) Requirements and Litigation	1-3
              1.1.3  The Land Disposal Restrictions Program:	1-3
                    1.1.3.1 Introduction to RCRA Land Disposal Restrictions (LDR)	1-3
                    1.1.3.2 Overlap Between LDR Standards and the Centralized Waste
                           Treatment Industry Effluent Guidelines	1-5

       1.2    CENTRALIZED WASTE TREATMENT INDUSTRY EFFLUENT GUIDELINE
              RULEMAKMG HISTORY	1-5
              1.2.1  January 27,1995 Proposal	1-5
              1.2.2  September 16,1996 Notice of Data Availability	1-6


Chapter2      DATA COLLECTION	 2-1

       2.1    PRELIMINARY DATA SUMMARY	2-1

       2.2    CLEAN WATER ACT SECTION 308 QUESTIONNAIRES	2-2
              2.2.1  Development of Questionnaires	2-2
              2.2.2  Distribution of Questionnaires	2-3

       2.3    WASTEWATER SAMPLING AND SITE VISITS	2-3
              2.3.1  Pre-1989 Sampling Program	2-3
              2.3.2  1989-1997 Site Visits	2-4
              2.3.3  Sampling Episodes	2-4
                    2.3.3.1 Facility-Selection	2-4
                    2.3.3.2 Sampling Episodes	2-5
                    2.3.3.3 Metal-Bearing Waste Treatment and Recovery Sampling ... 2-10
          :          2.3.3.4 Oily Waste Treatment and Recovery Sampling	2-10

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                    2.3.3.5 Organic-Bearing Waste Treatment and Recovery Sampling .2-11
              2.3.4  1998 Characterization Sampling of Oil Treatment and Recover
                    Facilities	2-11

       2.4     PUBLIC COMMENTS TO THE 1995 PROPOSAL AND THE 1996 NOTICE OF DATA
              AVAILABILITY	2-11

       2.5     ADDITIONAL DATA SOURCES	2-13
              2.5.1  Additional Databases	2-13
              2.5.2  Laboratory Study on the Effect of Total Dissolved Solids on Metal
                    Precipitation  	2-13

       2.6     PUBLIC PARTICIPATION	2-14


Chapter 3     SCOPE/APPLICABILITY OF THE PROPOSED REGULATION	3-1

       3.1     APPLICABILITY	3-1
              3.1.1  Facilities Subject to 40 CFR (Parts 400 to 471)	3-1
              3.1.2  Pipeline Transfers (Fixed Delivery Systems)	3-4
              3.1.3  Product Stewardship	3-5
              3.1.4  Solids, Soils, and Sludges	3-7
              3.1.5  Sanitary Wastes	3-8
              3.1.6  Transporters and/or Transportation Equipment Cleaners	3-8
              3.1.7  Publicly Owned Treatment Works (POTWs)  	3-8
              3.1.8  Silver Recovery Operations from Used Photographic and X-Ray
                    Materials 	3-9
              3.1.9  High Temperature Metals Recovery	3-10
              3.1.10 Landfill Wastewaters  	3-11
              3.1.11 Industrial Waste Combustors	3-11
              3.1.12 Solvent RecycUng/Fuel Blending	3-12
              3.1.13 Re-reBning	3-12
              3.1.14  Used Oil Filter Recycling	3-13
              3.1.15 Marine Generated Wastes  	3-13
              3.1.16 Stabilization	3-14
              3.1.17  Grease Trap/Interceptor Wastes	3-14


Chapter4     DESCRIPTION OF THE INDUSTRY	4-1

       4.1     INDUSTRYSIZE	4-1

       4.2    GENERAL DESCRIPTION	4-2

       4.3    WATER USE AND SOURCES OF WASTEWATER	4-4

       4.4    VOLUME BY TYPE OF DISCHARGE	4-5

       4.5    OFF-SITE TREATMENT INCENTIVES AND COMPARABLE TREATMENT	4-6

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Chapter 5     INDUSTRY SUBCATEGORIZATION	5-1

       5.1    METHODOLOGY AND FACTORS CONSIDERED AS THE BASIS FOR
             SUBCATEGORIZATION	5-1

       5.2    PROPOSEDSUBCATEGORIES  ...'	5-2

       5.3    SUBCATEGORY DESCRIPTIONS	5-2
             5.3.1  Metal-Bearing Waste Treatment and Recovery Subcategory	5-2
             5.3.2  Oily Waste Treatment and Recovery Subcategory	5-3
             5.3.3  Organic Waste Treatment and Recovery Subcategory  	5-3

       5.4    MIXED WASTE SUBCATEGORY CONSIDERATION	5-4


Chapter 6     POLLUTANTS OF CONCERN FOR THE CENTRALIZED WASTE
             TREATMENT INDUSTRY	6-1

       6.1    METHODOLOGY	6-1

       6.2    POLLUTANTS OF CONCERN FOR THE METALS SUBCATEGORY	6-24

       6.3    POLLUTANTS OF CONCERN FOR THE OILS SUBCATEGORY	6-25

       6.4    POLLUTANTS OF CONCERN FOR THE ORGANICS SUBCATEGORY	6-27

       6.5    REFERENCES	6-27


Chapter 7     POLLUTANTS SELECTED FOR REGULATION	7-1

       7.1    TREATMENT CHEMICALS	7-1

       7.2    NON-CONVENTIONAL BULK PARAMETERS 	7-1

       7.3    POLLUTANTS NOT DETECTED AT TREATABLE LEVELS	7-1

       7.4    POLLUTANTS NOT TREATED  	7-6

       7.5    VOLATILE POLLUTANTS	7-6

       7.6    POLLUTANTS SELECTED FOR PRETREATMENT STANDARDS AND
             PRETREATMENT STANDARDS FOR NEW SOURCES (INDIRECT DISCHARGERS) .7-15
             7.6.1  Background	7-15
             7.6.2  Determination of Percent Removals for well-Operated POTWs	7-16
             7.6.3  Methodology for Determining Treatment Technology Percent
                   Removals	7-21
             7.6.4  Pass-Through Analysis Results	7-21
                   7.6.4.1 Pass-Through Analysis Results for the Metals Subcategory . 7-21
                   7.6.4.2 Pass-Through Analysis Results for the Oils Subcategory ... 7-24

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                      7.6.4.3 Pass-Through Analysis Results for the Organics
                             Subcategory	7-26

       7.7    FINAL LIST OF POLLUTANTS SELECTED FOR REGULATION	7-27
              7.7.1   Direct Dischargers 	7-27
              7.7.2   Indirect Dischargers	7-34


Chapter 8     WASTEWATER TREATMENT TECHNOLOGIES	8-1

       8.1    TECHNOLOGIES CURRENTLYW USE	:	8-1

       8.2    TECHNOLOGY DESCRIPTIONS 	8-3
              8.2.1   Best Management Practices	8-3
              8.2.2   Physical/Chemical/Thermal Treatment 	8-3
                      8.2.2.1 Equalization	8-3
                      8.2.2.2 Neutralization	8-5
                      8.2.2.3 Flocculation/Coagulation	8-5
                      8.2.2.4 Emulsion Breaking	8-8
                      8.2.2.5 Gravity Assisted Separation 	8-10
                             1.      GRAVITY OIL/WATER SEPARATION	8-10
                             2.      CLARIFICATION	8-10
                             3.      DISSOLVED AIR FLOTATION	8-13
                      8.2.2.6 Chromium Reduction	8-15
                      8.2.2.7 Cyanide Destruction	8-16
                      8.2.2.8 Chemical Precipitation 	8-19
                      8.2.2.9 Filtration	8-24
                             l.     SAND FILTRATION	8-24
                             2.     MULTIMEDIA FILTRATION	8-25
                             3.     PLATE AND FRAME PRESSURE FILTRATION	8-26
                             4.     MEMBRANE FILTRATION	8-28
                                    A      ULTRAFILTRATION	8-28
                                    B.      REVERSE OSMOSIS	8-28
                             5.     LANCY FILTRATION	8-30
                      8.2.2.10 Carbon Adsorption	8-33
                      8.2.2.11 lonExchange	8-35
                      8.2.2.12 Electrolytic Recovery	'.	8-36
                      8.2.2.13 Stripping	8-39
                              1.     AlRSTRIPPING	8-39
                      8.2.2.14 Liquid Carbon Dioxide Extraction	8-41
               8.2.3  Biological Treatment 	8-41
                      8.2.3.1  Sequencing Batch Reactors	8-43
                      8.2.3.2 Attached Growth Biological Treatment Systems 	8-45
                              1.      TRICKLING FILTERS	8-45
                              2.      BIOTOWERS	8-47
                      8.2.3.3 Activated Sludge	8-47
               8.2.4  Sludge Treatment and Disposal	8-51
                      8.2.4.1 Plate and Frame Pressure Filtration 	8-52
                      8.2.4.2 BeltPressureFiltration	8-54
                      8.2.4.3 Vacuum Filtration 	8-54
                      8.2.4.4 Filter Cake Disposal  	'.	8-57

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             8.2.5   Zero or Alternate Discharge Treatment Options	8-57

       8.3    REFERENCES	8-58


Chapter 9     REGULATORY OPTIONS CONSIDERED AND SELECTED FOR
             BASIS OF REGULATION	9-1

       9.1    ESTABLISHMENT OF BPT	9-1
             9.1.1   Rationale for Metals Subcategory BPT Limitations	9-2
             9.1.2   Rationale for Oils Subcategory BPT Limitations	9-6
             9.1.3   Rationale for Organics Subcategory BPT Limitations	9-11
       9.2    BEST CONVENTIONAL TECHNOLOGY (BCT)	9-13

       9.3    BEST AVAILABLE TECHNOLOGY (BAT)	9-13

       9.4    NEW SOURCE PERFORMANCE STANDARDS (NSPS)	9-14

       9.5    PRETREATMENT STANDARDS FOR EXISTING SOURCES (PSES)	9-15

       9.6    PRETREATMENT STANDARDS FOR NEW SOURCES (PSNS)	9-16


Chapter 10    LONG-TERM AVERAGES, VARIABILITY FACTORS, AND
             LIMITATIONS AND STANDARDS	10-1

       10.1   FACILITY SELECTION	10-1

       10.2   SAMPLE POINT SELECTION	10-2
             10.2.1  Effluent Sample Point	10-2
             10.2.2  Influent Sample Point	10-2
             10.2.3  Special Cases	 10-3

       10.3   DETERMINATION OF BATCH AND CONTINUOUS FLOW SYSTEMS	10-3

       10.4   DATA SELECTION	10-5
             10.4.1  Data Exclusions and Substitutions	10-5
                    10.4.1.1 Operational Difficulties 	10-5
                    10.4.1.2 Treatment Not Reflective of BPT/BCT/BAT Treatment	10-5
                    10.4.1.3 Exclusions to EPA Sampling Data Based Upon the
          :                 Availability of the Influent and Effluent	10-6
                    10.4.1.4 More Reliable Results Available	10-6
                    10.4.1.5 Data from the Facilities Which Accept Waste from More
                           than One Subcategory	10-7
                    10.4.1.6 Substitution Using the Baseline Values	10-7
             10.4.2  Data Aggregation  	10-7
                    10.4.2.1 Aggregation of Field Duplicates  	10-8
                    10.4.2.2 Aggregation of Grab Samples and Multiple Daily Values .. 10-9
                    10.4.2.3 Aggregation of Data Across Streams ("Flow-
                           Weighting")	 10-10

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       10.4.3  Data Editing Criteria 	  10-11
              10.4.3.1 Long-Term Average Test	  10-12
              10.4.3.2 Percent Removal Test	  10-12
              10.4.3.3 Evaluation of Self-Monitoring Data	  10-13

10.5   DEVELOPMENT OF LONG-TERM AVERAGES	,   10-13
       10.5.1  Estimation of Facility-Specific Long-Term Averages	  10-14
       10.5.2  Estimation of Pollutant-Specific Long-Term Averages	  10-14
       10.5.3  Substitutions for Long-Term Averages	  10-14
              10.5.3.1 Baseline Values Substituted for Long-term Averages	  10-14
              10.5.3.2 Arsenic Long-Term Average for Metals Subcategory
                     Option 4	  10-15

10.6   DEVELOPMENT OF VARIABILITY FACTORS	   10-15
       10.6.1  Basic Overview of the Modified Delta-Lognormal Distribution ..  10-15
       10.6.2  Discrete Portion of the Modified Delta-Lognormal Distribution .  10-18
       10.6.3  Continuous Portion of the Modified Delta-Lognormal
              Distribution	  10-18
       10.6.4  Estimation Under the Modified Delta-Lognormal Distribution ..  10-19
       10.6.5  Estimation of Facility-Sped fie Variability Factors	  10-21
              10.6.5.1 Facility Data Set Requirements	  10-21
              10.6.5.2 Estimation of Facility-Specific Daily Variability Factor   10-21
              10.6.5.3 Estimation of Facility-Specific Monthly Variability
                     Factors	  10-22
              10.6.5.4 Evaluation of Facility-Specific  Variability Factors 	  10-28
       10.6.6  Estimation of Pollutant-Specific Variability Factors	  10-29
       10.6.7  Estimation of Group-Level Variability Factors	  10-29
       10.6.S  Transfers of Variability Factors 	  10-29

10.7   LIMITATIONS 	10-31
       10.7.1  Steps Used to Derive Limitations	  10-32
       10.7.2  Example	  10-33

10.8   TRANSFERS OF LIMITATIONS	  10-34
       10.8.1  Transfer of Oil and Grease Lhnitation  for Metals Subcategory
              for Option 4 to Option 3	  10-34
       10.&2  Transfers of Limitations from Other Rulemakings to CWT
              Industry	  1-35
              10.8.2.1 Transfer ofBOD5 and TSS for the Organics Subcategory  10-35
              10.8.2.2 Transfer of TSS for Option 4 of the Metals Subcategory .  10-38

10.9   EFFECT OF GROUP AND POLLUTANT VARIABILITY FACTORS ON
       LIMITATIONS	  1Q-38

10.10  ATTACHMENTS	 l-39

10.11  REFERENCES	 l-40

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Chapter 11    COST OF TREATMENT TECHNOLOGIES	 11-1

       ll.l   COSTS DEVELOPMENT	l l-l
              11.1.1  Technology Costs  	11-1
              11.1.2  Option Costs	11-2
                     11.1.2.1 Land Requirements and Costs 	11-2
                     11.1.2.2 Operation and Maintenance Costs	11-3

       11.2   PHYSICAL/CHEMICAL WASTEWATER TREATMENT TECHNOLOGY COSTS	11-5
              11.2.1  Chemical Precipitation	11-5
                     11.2.1.1 Selective Metals Precipitation-Metals Option 2 and
                            Metals Option 3	11-5
                     11.2.1.2 Secondary Precipitation-Metals Option 2 and Metals
                            Option3 ...'	11-6
                     11.2.1.3 Tertiary Precipitation and pH Adjustment-Metals
                            Option 3	11-8
                     11.2.1.4 Primary Chemical Precipitation-Metals Option 4	11-9
                     11.2.1.5 Secondary (Sulfide) Precipitation for Metals Option 4 ..  11-12
              11.2.2  Plate and Frame Liquid Filtration and Clarification	  11-13
                     11.2.2.1 Plate and Frame Liquid Filtration Following Selective
                            Metals Precipitation	  11-14
                     11.2.2.2 Clarification for Metals Options 2,3, and 4	  11-14
              11.2.3  Equalization	  11-17
              11.2.4  Air Stripping	  11-18
              11.2.5  Multi-Media Filtration	  11-19
              11.2.6  Cyanide Destruction	  11-20
              11.2.7 Secondary Gravity Separation	  11-21
              11.2.8  Dissolved Air Flotation	  11-22

       11.3   BIOLOGICAL WASTEWATER TREATMENT TECHNOLOGY COSTS	  11-25
              11.3.1  Sequencing Batch Reactors	  11-25

       11.4   SLUDGE TREATMENT AND DISPOSAL COSTS	  11-26
              11.4.1  Plate and Frame Pressure Filtration-Sludge Stream	  11-26
              11.4.2  Filter Cake Disposal	  11-29

       11.5   ADDITIONAL COSTS	  11-30
              11.5.1  Retrofit Costs	  11-30
              11.5.2  Monitoring Costs	  11-31
              11.5.3  RCRA Permit Modification Costs	  11-32
              11.5.4  Land Costs	  11-33

       11.6   REFERENCES  	  11-43

       11.7   SUMMARY OF COST OF TECHNOLOGY OPTIONS	  11-44
              11.7.1  BPTCosts	  11-44
              11.7.2 BCT/BATCosts	  11-44
              11.7.3 PSES Costs	  11-44

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Chapter 12   POLLUTANT LOADING AND REMOVAL ESTIMATES	12-1

       12.1   INTRODUCTION	12-1

       12.2   DATA SOURCES	12-1

       12.3   METHODOLOGY USED TO DEVELOP CURRENT LOADINGS ESTIMATES	12-2
             12.3.1  Current Loadings Estimates for the Metals Subcategory	12-2
                    12.3.1.1 Raw Loadings for the Metals Subcategory  	12-4
                    12.3.1.2 Primary Precipitation with Solids-Liquid Separation
                           Loadings 	12-4
                    12.3.1.3 Secondary Precipitation with Solids-Liquid Separation
                           Loadings 	12-5
                    12.3.1.4 Technology Basis for the Proposed BPT/BAT/PSES
                           Option 4 Loadings	12-5
                    12.3.1.5 Selective Metals Precipitation (NSPS/PSNS Proposed
                           Option 3) Loadings	12-5
             12.3.2  Current Loadings Estimates for the Oils Subcategory	12-5
                    12.3.2.1 Issues Associated with Oils Current Performance
                           Analyses	12-9
                    12.3.2.1 Random Assignment of Seven Emulsion Breaking/Gravity
                           Separation Data Sets	  12-31
             12.3.3  Organics Subcategory Current Loadings	  12-33

       12.4   METHODOLOGY USED TO ESTIMATE POST-COMPLIANCE LOADINGS  	  12-35

       12.5   METHODOLOGY USED TO ESTIMATE POLLUTANT REMOVALS	  12-41

       12.6   POLLUTANT LOADINGS AND REMOVALS	  12-41


Chapter 13   NON-WATER QUALITY IMPACTS	'.	13-1

       13.1   AIR POLLUTION	13-1

       13.2   SOLID WASTE	13-3

       13.3   ENERGY REQUIREMENTS	13-5

       13.4   LABOR REQUIREMENTS	13-5


Chapter 14   IMPLEMENTATION	14-1

       14.1   APPLICABLE WASTE STREAMS	14-1

       14.2   DESCRIPTION OF SUBCATEGORY	14-2
             14.2.1  Metals Subcategory Description 	14-2
             14.2.2 Oils Subcategory Description	14-2
             14.2.3 Organics Subcategory Description 	14-3

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       14.3   FACILITY SUBCATEGORIZATION IDENTIFICATION	14-3

       14.4   ON-SITE GENERATED WASTEWATER SUBCATEGORY DETERMINATION	14-7
             14.4,1  On-site Industrial Waste Combustors, Landfills, and
                    Transportation Equipment Cleaning, Operations 	14-7

       14.5   SUBCATEGORY DETERMINATION IN EPA QUESTIONNAIRE DATA BASE	14-7
             14.5.1  Wastes Classified in the Metals Subcategory - Questionnaire
                    Responses	  14-14
             14.5.2  Wastes Classified in the Oils Subcategory - Questionnaire
                    Responses	  14-14
             14.5.3  Wastes Classified in the Organics Subcategory - Questionnaire
                    Responses	  14-14

       14.6   ESTABLISHING LIMITATIONS AND STANDARDS FOR FACILITY DISCHARGES  14-15
             14.6.1  Existing Guidance for Multiple Subcategory Facilities	  14-16
                    14.6.1.1 Direct Discharge Guidance  	  14-16
                    14.6.1.2 Indirect Discharge Guidance	  14-19
             14.6.2  CWT Facilities Also Covered By Another Point Source
                    Category	.	  14-26


Chapter 15   ANALYTICAL METHODS AND BASELINE VALUES 	15-1

       15.1   INTRODUCTION	15-1

       15.2   ANALYTICAL RESULTS	15-1

       15.3   NOMINAL QUANTITATION LIMITS	15-2

       15.4   BASELINE VALUES	15-2

       15.5   ANALYTICAL METHODS	15-5
             15.5.1  Methods 1613,1624,1625,1664 (Dioxins, Organics, HEM)	15-5
             15.5.2  Method 413.1 (Oil and Grease)	15-5
             15.5.3  Method 1620	15-5
             15.5.4  Method 85.01	 15-6
             15.5.5  Methods D4658 and 376.1 (Total SulRde)	15-7
             15.5.6  Methods 410.1, 410.2, and 410.4 (COD andD-COD)	15-7
             15.5.7 Method420.2 (TotalPhenols)	15-7
             15.5.S  Method 218.4 and 3500D (Hexavalent Chromium)	15-8
             15.5.9  Methods 335.2 and 353.2 (Total Cyanide and Nitrate/Nitrite)	15-8
             15.5.10 Remaining Methods	15-8

       15.6   ANALYTICAL METHOD DEVELOPMENT EFFORTS ...	15-8

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LIST OF DEFINITIONS	Defmitions-1
LIST OF ACRONYMS	 Acronyms-1
INDEX 	  Index-1


Volume 2:

Appendix A   POLLUTANT GROUPS	A-l


Appendix B   LISTING OF CHARACTERIZATION DATA FROM
           NON-HAZARDOUS OILS FACILITIES	 B-l


Appendix C   LISTING OF DAILY INFLUENT AND EFFLUENT
           MEASUREMENTS	 C-l


Appendix D   FACILITY-SPECIFIC COMPLIANCE COSTS  	D-l


AppendixE   , ATTACHMENTS TO CHAPTER 10	 E-l


Appendix F   LISTING OF POLLUTANTS OF CONCERN AND CAS NUMBERS ... F-l

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                                                          LIST OF TABLES
Chapter 1

       Table 1-1   Technology Basis for 1995 BPT Effluent Limitations  	1-6

Chapter 2

       Table 2-1   Chemical Compounds Analyzed Under EPA Analytical Methods	2-7

Chapter 3

       Table 3-1   Summary of the Frequency of the Types of Activities and Dispositions
                  Reported	3-6
       Table 3-2   Summary of Frequency of Each Product Class Reported by Facilities  	3-6

Chapter 4

       Table 4-1   Geographic Distribution of CWT Facilities (145 Facilities)	4-3
       Table 4-2   Waste Form Codes Reported by CWT Facilities in 1989	4-3
       Table 4-3   RCRA Codes Reported by Facilities in 1989	4-3
       Table 4-4   Facility Discharge Options  	4-6
       Table 4-5   Quantity of Wastewater Discharged (205 Facilities)  	4-6

Chapters

       Table 6-1   Pollutants of Concern for the Metals Subcategory	6-4
       Table 6-2   Pollutants of Concern for the Oils Subcategory	6-6
       Table 6-3   Pollutants of Concern for the Organics Subcategory  	6-9
       Table 6-4   Pollutants Not Selected as Pollutants of Concern for the Metals
                  Subcategory	6-11
       Table 6-5   Pollutants Not Selected as Pollutants of Concern for the Oils
                  Subcategory	6-16
       Table 6-6   Pollutants Not Selected as Pollutants of Concern for the Organics
                  Subcategory	6-20
       Table 6-7   Concentration of Benzo(a)pyrene in Industrial Products (Osborne &
                  Crosby, 1987) 	6-26

Chapter 7

       Table 7-1   Pollutants Not Detected At Treatable Levels  	7-4
       Table 7-2   Volatile Organic Pollutant Properties By Subcategory	7-8
       Table 7-3   Non-Regulated Volatile Organic Pollutants by Subcategory and Option . .7-14
       Table 7-4   CWT Pass-Through Analysis Generic POTW Percent Removals	7-18
       Table 7-5   Final POTW Percent Removals 	7-19
       Table 7-6   Final Pass-Through Results For Metals Subcategory Option 3	7-22
       Table 7-7   Final Pass-Through Results For Metals Subcategory Option 4	7-23
       Table 7-8   Final Pass-Through Results For Oils Subcategory Option 9	7-24
       Table 7-9  Final Pass-Through Results For Organics Subcategory Option 3/4  	7-26
       Table 7-10 Pollutants Eliminated Due to Non-Optimal Performance	7-27

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       Table 7-11 Pollutants Eliminated Since Technology Basis is Not Standard Method
                  of Treatment	7-28
       Table 7-12 Frequency of Detection of n-Paraffins in CWT Oils Subcategory Wastes  . 7-30
       Table 7-13 Frequency of Detection of Polyaromatic Hydrocarbons in CWT Oils
                  Subcategory Wastes	7-31
       Table 7-14 Frequency of Detection of Phthalates in CWT Oils Subcategory Wastes  .. 7-32
       Table 7-15 Final List of Regulated Pollutants for Direct Discharging CWTs 	7-33
       Table 7-16 Final List of Regulated Pollutants for Indirect Discharging CWT
                  Facilities	7-34

Chapter 8

       Table 8-1  Percent Treatment In-place by Subcategory and by Method of Wastewater
                  Disposal	8-2

Chapter 9

       Table 9-1  Average Influent and Effluent Oil and Grease and Total Petroleum
                  Hydrocarbon (TPH) Concentrations at Sampled Industrial Laundry
                  Facilities	9-10

Chapter 10

       Table 10-1 Facilities and Sample Points Used to Develop Long-term Averages and
                  Limitations	10-4
       Table 10-2 Aggregation of Field Duplicates	10-9
       Table 10-3 Aggregation of Grab Samples and Daily Values  	  10-10
       Table 10-4 Aggregation of Data Across Streams 	  10-11
       Table 10-5 Metals Subcategory: Long-Term Averages Replaced by the Baseline
                  Values  ....'	  10-15
       Table 10-6 Cases where Variability Factors were Transferred	  10-31
       Table 10-7 Long-Term Averages and Variability Factors Corresponding to Exampl
                  for Hypothetical Group X		  10-34
       Table 10-8 BOD5 and TSS Parameters for Organics Subcategory	  10-38
       Table 10-9 TSS Parameters for Metal Finishing	  10-38

Chapter 11

       Table 11-1 Standard Capital Cost Algorithm	11-2
       Table 11-2 Standard Operation and Maintenance Cost Factor Breakdown	11-3
       Table 11-3 CWT Treatment Technology Costing Index - A Guide to the Costing
                  Methodology Sections  	11-4
       Table 11-4 Cost Equations for Selective Metals Precipitation in Metals Options 2
                  and3	H-6
       Table 11-5 Cost Equations for Secondary Chemical Precipitation in Metals Options
                  2 and 3	11-8
       Table 11-6 Cost Equations for Tertiary Chemical Precipitation in Metals Option 3 ..11-9
       Table 11-7 Cost Equations for Primary Chemical Precipitation in Metals Option 4  11-12
       Table 11-8 Cost Equations for Secondary (Sulfide) Precipitation for Metals
                  Option 4	11-5

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       Table 11-9 Cost Equations for Clarification and Plate and Frame Liquid Filtration
                  inMetals Option2,3,4	  11-16
       Table 11-10  Design Parameters Used for Equalization in CAPDET Program	  11-17
       Table 11-11  Summary of Cost Equations for Equalization  	  11-18
       Table 11-12  Cost Equations for Air Stripping	'	  11-19
       Table 11-13  Cost Equations for Multi-Media Filtration 	  11-20
       Table 11-14  Cost Equations for Cyanide Destruction	  11-21
       Table 11-15  Cost Equations for Secondary Gravity Separation 	  11-21
       Table 11-16A Estimate Holding Tank Capacities for DAF. Systems  	  11-22
       Table 11-16B Estimate Labor Requirements for DAF Systems	  11-23
       Table 11-17  Cost Equations for Dissolved Air Flotation (DAF) in Oils Options 8
                    and 9	  11-25
       Table 11-18  Cost Equations for Sequencing Batch Reactors	  11-26
       Table 11-19  Cost Equations for Plate and Frame Sludge Filtration in Metals
                    Option2, 3 and4	  11-28
       Table 11-20  Cost Equations for Filter Cake Disposal for Metals Options 2 and 3 .  11-30
       Table 11-21  Monitoring Frequency Requirements 	  11-31
       Table 11-22  Analytical Cost Estimates  	  11-32
       Table 11-23  RCRA Permit Modification Costs Reported in WTI Questionnaire ...  11-33
       Table 11-24  State Land Costs for the CWT Industry Cost Exercise	  11-34
       Table 11-25  Cost of Implementing BPT Regulations [in 1997 dollars]	  11-44
       Table 11-26  Cost of Implementing PSES Regulations [in of 1997 dollars]	  11-45

Chapter 12

       Table 12-1 Metals Subcategory Pollutant Concentration Profiles for Current
                  Loadings  	12-3
       Table 12-2 Example of Metals Subcategory Influent Pollutant Concentration
                  Calculations	12-4
       Table 12-3 Treatment-in-Place Credit Applied to Oils Facilities	12-9
       Table 12-4 Biphasic Sample Calculations (Summary of rules for combining
                  aqueous/organic phase cones.)  	'	  12-11
       Table 12-5 Examples of Combining Aqueous and Organic Phases for Sample
                  32823	  12-12
       Table 12-6 A  Example of Five Substitution Methods for Non-Detected
                    Measurements of Hypothetical Pollutant X	  12-14
       Table 12-6B  Difference in Oils Subcategory Loadings After Non-Detect
                    Replacement Using EPA Approach	  12-15
       Table 12-7 Oils Subcategory Emulsion Breaking/Gravity Separation Data Sets
                  Before and After Sample-Specific Non-Detect Replacement	  12-16
       Table 12-8 Current Loadings Estimates for the Organics Subcategory (units = ug/L)  12-34
       Table 12-9 Long Term Average Concentrations (ug/L) for All Pollutants of Concer   12-37
       Table 12-10  Summary of Pollutant Loadings and Removals for the CWT Metals
                    Subcategory 	  12-42
       Table 12-11  Summary of Pollutant Loadings and Removals for the CWT Oils
                    Subcategory 	  12-43
       Table 12-12  Summary of Pollutant Loadings and Removals for the CWT Organics
                    Subcategory 	  12-45
       Table 12-13  Summary of Pollutant Loadings and Removals for the Entire CWT
                    Industry	  12-47

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Chapter 13

       Table 13-1 Projected Air Emissions at CWT Facilities 	13-3
       Table 13-2 Projected Incremental Filter Cake Generation at CWT Facilities	13-4
       Table 13-3 National Volume of Hazardous and Non-hazardous Waste Sent to
                  Landfills	I3'4
       Table 13-4 Projected Energy Requirements for CWT Facilities	13-5
       Table 13-5 Projected Labor Requirements for CWT Facilities  	13-6

Chapter 14

       Table 14-1 Waste Receipt Classification	14-4
       Table 14-2 RCRA and Waste Form Codes Reported by Facilities in 1989	14-8
       Table 14-3 Waste Form Codes in the Metals Subcategory	  14-14
       Table 14-4 Waste Form Codes in the Oils Subcategory	  14-14
       Table 14-5 Waste Form Codes in the Organics Subcategory	  14-15
       Table 14-6 Proposed BAT Daily Maximum Limits for Selected Parameters	  14-17
       Table 14-7 "Building Block Approach" Calculations for Selected Parameters for
                  Example 14-1  	  14-18
       Table 14-8. Proposed Daily Maximum Pretreatment Standards for Selected
                  Parameters	  14-21
       Table 14-9 CWF Calculations for Selected Parameters for Example 14-1 Using 40
                  CFR 403 and Guidance in EPA's Industrial User Permitting Guidance
                  Manual	  14'21
       Table 14-10  CWF Calculations for Selected Parameters in Example 14-1  Using the
                    Guidance Manual for Use of Production-Based Pretreatment Standards
                    and Combined Waste Stream Formula	  14-22
       Table 14-11  Daily Maximum Limits and Standards for Example 14-1  	  14-22
       Table 14-12  Allowances for Use in Applying the Combined Waste Stream Formula
                    for CWT Oils Subcategory Flows (PSES or PSNS)	  14-23
       Table 14-13  Allowances for Use in Applying the Combined Waste Stream Formula
                    for CWT Organics Subcategory Flows	  14-23
        Table 14-14  CWF Calculations for Example 14-1 Including Allowances  	  14-24

Chapter 15

        Table 15-1 Analytical Methods and Baseline Values	15-4
        Table 15-2 Baseline values for Method 85.01	15-7

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                                                         LIST OF FIGURES
Chapter 6

       Figure 6-1      Pollutant of Concern Methodology	6-3

Chapter 7

       Figure 7-1      Selection of Pollutants That May Be Regulated for Direct Discharge
                      for Each Subcategory	7-2
       Figure 7-2      Selection of Pollutants to be Regulated for Indirect Discharges fo
                      Each Subcategory	7-3
       Figure 7-3      Determination of Volatile Pollutants for Oils Subcategory.	7-7

Chapter 8

       Figure 8-1      Equalization System Diagram  	8-4
       Figure 8-2      Neutralization System Diagram	8-6
       Figure 8-3      Clarification System Incorporating Coagulation and Flocculation	8-7
       Figure 8-4      Emulsion Breaking System Diagram	8-9
       Figure 8-5      Gravity Separation System Diagram 	8-11
       Figure 8-6      Clarification System Diagram	8-12
       Figure 8-7      Dissolved Air Flotation System Diagram	8-14
       Figure 8-8      Chromium Reduction System Diagram	8-17
       Figure 8-9      Cyanide Destruction by Alkaline Chlorination  	8-18
       Figure 8-10    Chemical Precipitation System Diagram	8-20
       Figure 8-11    Calculated Solubilities of Metal Hydroxides	8-23
       Figure 8-12    Multi-Media Filtration System Diagram	8-27
       Figure 8-13    Ultrafiltration System Diagram 	8-29
       Figure 8-14    Reverse Osmosis System Diagram	8-31
       Figure 8-15    Lancy Filtration System Diagram	8-32
       Figure 8-16    Carbon Adsorption System Diagram	8-34
       Figure 8-17    Ion Exchange System Diagram	'. 8-37
       Figure 8-18    Electrolytic Recovery System Diagram 	8-38
       Figure 8-19    Air Stripping System Diagram	8-40
       Figure 8-20    Liquid CO2 Extraction System Diagram 	8-42
       Figure 8-21    Sequencing Batch Reactor System Diagram  	8-44
       Figure 8-22    Trickling Filter System Diagram 	8-46
       Figure 8-23    Biotower System Diagram	8-48
       Figure 8-24    Activated Sludge System Diagram		8-49
       Figure 8-25    Plate and Frame Filter Press System Diagram	8-53
       Figure 8-26    Belt Pressure Filtration System Diagram	8-55
       Figure 8-27    Vacuum Filtration System Diagram	8-56
Chapter 10

        Figure 10-1
Modified Delta-Lognormal Distribution 	  10-17

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Chapter 11

       Figure 11-1    Metals Option 4 Model Facility Diagram 	  11-35
       Figure 11-2    Treatment Diagram For Oils Option 9 Facility Improvements	  11-39

Chapter 12

       Figure 12-1    Calculation of Current Loadings for Oils Subcategory	12-8
       Figure 12-2    Methodology for Current Loadings Estimates in Oils Subcategory .  12-32

Chapter 14

       Figure 14-1    Waste Receipt Subcategory Classification Diagram	14-6
       Figure 14-2    Facility Accepting Waste in All Three Subcategories With Treatment
                      inEach	  14-17
       Figure 14-3    Facility Which Accepts Wastes in Multiple Subcategories and Treats
                      Separately	  14-25
       Figure 14-4    Categorical Manufacturing Facility Which Also Operates as a CWT  14-26
       Figure 14-5    Facility that Commingles Wastewaters after Treatment	  14-27

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                                                                                 Chapter
                                                                                         1
                                                            BACKGROUND
      This    chapter    provides   background
      information on the development of this re-
proposed rule.   The first sections  detail the
legislative backround while the later sections
provide information on the 1995 CWT proposal
and the 1996 CWT Notice of Data Availability.
LEGAL AUTHORITY
  1.0
        These regulations are proposed under the
authority of Sections 301, 304, 306, 307, 308,
402,  and 501  of the  Clean Water Act,  33
U.S.C.1311,1314,1316,1317, 1318, 1342, and
1361.
LEGISLATIVE BACKGROUND
Clean Water Act
 1.1
1.1.1
        Congress adopted the Clean Water Act
(CWA) to "restore and maintain the chemical,
physical, and biological integrity of the Nation's
waters" (Section 101(a), 33 U.S.C. 1251(a)).  To
achieve  this goal,  the  CWA  prohibits  the
discharge of pollutants into navigable waters
except in compliance with the statute.  The Clean
Water Act confronts  the problem  of water
pollution on a number of different fronts.  Its
primary  reliance, however, is on establishing
restrictions  on  the  types  and  amounts  of
pollutants  discharged from various industrial,
commercial, and public sources of wastewater.
        Congress recognized that regulating only
those sources that discharge effluent directly into
the nation's waters would not be sufficient to
achieve the CWA's  goals. Consequently,  the
CWA requires  EPA to promulgate nationally
applicable pretreatment standards which restrict
pollutant discharges  for those  who  discharge
wastewater indirectly through sewers flowing to
publicly-owned  treatment  works  (POTWs)
(Section 307(b) and (c), 33 U.S.C. 1317(b) &
(c)).    National pretreatment standards  are
established for those pollutants in wastewater
from indirect dischargers which may pass through
or interfere with POTW operations. Generally,
pretreatment standards are designed to  ensure
that wastewater from direct and indirect industrial
dischargers are subject  to similar  levels of
treatment.  In addition, POTWs are required to
implement local treatment limits applicable to
their industrial indirect dischargers to satisfy any
local requirements (40 CFR 403.5).
        Direct dischargers must comply with
effluent  limitations  in  National  Pollutant
Discharge  Elimination  System   ("NPDES")
permits; indirect dischargers must comply with
pretreatment standards.  These limitations and
standards are  established by  regulation  for
categories of industrial dischargers and are based
on the degree of control that can be achieved
using  various  levels  of  pollution  control
technology.

Best Practicable Control Technology
Currently Available (BPT) -
Sec.304(b)(l)oftheCWA            1.1.1.1
       In  the guidelines,  EPA defines BPT
effluent limits for conventional, priority,1  and
         TIn the initial stages of EPA CWA regulation, EPA
         efforts emphasized the achievement of BPT limitations
         for control of the "classical" pollutants (for example,
         TSS, pH, BODS).  However, nothing on the face of
         the statute explicitly restricted BPT limitation to sue
         pollutants. Following passage of the Clean Water Act
         of 1977 with its requirement for points sources to
         achieve best available (continued on next page)
                                            1-1

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Chapter 1 Background
Development Document for the CWT Point Source Category
non-conventional pollutants. In specifying BPT,
EPA looks at a number of factors.  EPA first
considers the cost of achieving effluent reductions
in relation to the effluent reduction benefits. The
Agency also considers: the age of the equipment
and facilities, the processes employed and any
required process changes, engineering aspects of
the control technologies, non-water  quality
environmental   impacts   (including  energy
requirements),  and such  other  factors  as the
Agency deems appropriate (CWA 304(b)(l)(B)).
Traditionally,  EPA  establishes  BPT effluent
limitations based  on the  average of the best
performances of facilities within the industry of
various ages, sizes, processes or other common
characteristics.     Where,  however, existing
performance is  uniformly inadequate, EPA may
require higher levels of control than currently in
place in an industrial category  if the Agency
determines that the technology can be practically
applied.

Best Conventional Pollutant
Control Technology (BCT) -
Sec. 304(b)(4)  of the CWA            1.1.1.2
        The  1977 amendments  to  the  CWA
required EPA to identify effluent reduction levels
for conventional pollutants associated with BCT
technology for discharges from existing industrial
point  sources.   In  addition to other factors
specified  in Section 304(b)(4)(B),  the  CWA
requires that EPA establish BCT limitations after
consideration of a two part "cost-reasonableness"
test.   EPA explained its  methodology for the
development of BCT limitations in July 1986 (51
FR 24974).
        Section   304(a)(4)   designates  the
following as conventional pollutants: biochemical
technology limitations to control discharges of toxic
pollutants, EPA shifted the focus of the guidelines
program to address the listed priority pollutants. BPT
guidelines continue to include limitations to address all
pollutants.
          oxygen demand (BOD5), total suspended solids
          (TSS), fecal coliform,  pH, and any additional
          pollutants defined  by the  Administrator as
          conventional. The Administrator designated oil
          and grease as an additional conventional pollutant
          on July 30, 1979 (44 FR 44501).

          Best Available Technology
          Economically Achievable (BAT) -
          Sec. 304(b)(2) of the CWA             1.1.1.3
                 In  general, BAT effluent  limitations
          guidelines  represent  the  best  economically
          achievable performance of plants in the industrial
          subcategory or category. The factors considered
          in assessing BAT include the cost of achieving
          BAT effluent reductions, the age of equipment
          and facilities involved, the process employed,
          potential process changes, and non-water quality
          environmental   impacts,   including   energy
          requirements.  The Agency retains considerable
          discretion in assigning the weight to be accorded
          these  factors.   Unlike BPT limitations,  BAT
          limitations may be based on effluent reductions
          attainable  through  changes  in  a  facility's
          processes and operations.  As with BPT, where
          existing  performance  is uniformly inadequate,
          BAT may require a higher level of performance
          than  is  currently  being  achieved based on
          technology   transferred   from   a   different
          subcategory or category.  BAT  may be based
          upon process changes or internal controls,  even
          when these technologies are not common industry
          practice.

          New Source Performance Standards
          (NSPS) - Sec. 306 of the CWA         1.1.1.4
                 NSPS reflect effluent reductions that are
          achievable  based   on  the  best   available
          demonstrated control technology. New facilities
          have the opportunity to install the best and most
          efficient production processes and wastewater
          treatment technologies. As a result, NSPS should
          represent the most stringent controls attainable
          through  the  application  of the best  available
                                             1-2

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Chapter 1 Background
Development Document for the CWT Point Source Category
 control technology for all pollutants (that is,
 conventional,  nonconventional,  and  priority
 pollutants).   In  establishing  NSPS, EPA  is
 directed to take into consideration the cost of
'achieving the  effluent  reduction and any non-
 water quality environmental impacts arid energy
 requirements.

 Pretreatment Standards for Existing
 Sources(PSES) 
 Sec. 307(b) of the CWA               1.1.1.5
        PSES  are  designed  to  prevent the
 discharge  of  pollutants that  pass-through,
 interfere-with, or are otherwise incompatible with
 the operation of publicly-owned treatment works
 (POTW). The  CWA authorizes EPA to establish
 pretreatment standards for pollutants that pass-
 through POTWs or interfere  with treatment
 processes or sludge disposal methods at POTWs.
 Pretreatment standards are technology-based and
 analogous to BAT effluent limitations guidelines.
        The General Pretreatment Regulations,
 which  set  forth  the  framework  for the
 implementation  of  categorical  pretreatment
 standards, are found at 40 CFR Part 403.  Those
 regulations contain a definition of pass-through
 that addresses localized rather than national
 instances  of pass-through   and  establish
 pretreatment  standards that  apply  to  all-
 non-domestic  dischargers.   See 52  FR  1586,
 January 14, 1987.

 Pretreatment Standards for New
 Sources (PSNS) -
 Sec. 307(b) of the CWA               1.1.1.6
        Like  PSES, PSNS are  designed to
 prevent the discharges of pollutants that pass-
 through,  interfere-with,  or   are   otherwise
 incompatible  with the  operation of POTWs.
 PSNS are to be issued at the same time as NSPS.
 New indirectdischargers have the opportunity to
 incorporate into their plants the best available
 demonstrated   technologies. '    The Agency
 considers the same factors in promulgating PSNS
          as it considers in promulgating NSPS.

          Section 304(m) Requirements
          and Litigation
1.1.2
                 Section 304(m) of the CWA, added by
         the Water Quality Act of 1987, requires EPA to
         establish schedules for (1) reviewing and revising
         existing effluent  limitations  guidelines  and
         standards  ("effluent  guidelines")  and   (2)
         promulgating  new effluent  guidelines.    On
         January 2, 1990,  EPA published  an Effluent
         Guidelines Plan (55 FR  80) that established
         schedules for developing new and revised effluent
         guidelines for several industry categories.  One of
         the industries for which the  Agency established a
         schedule was the Centralized  Waste Treatment
         Industry.
                 The Natural Resources Defense Council
         (NRDC) and Public Citizen, Inc. filed suit against
         the Agency, alleging violation of Section 304(m)
         and  other   statutory  authorities  requiring
         promulgation of effluent guidelines  (TSTRDC et
         al v.  Browner. Civ. No. 89-2980 (D.D.C.)).
         Under the terms  of a consent decree dated
         January 31, 1992, which settled the litigation,
         EPA agreed, among other things, to  propose
         effluent guidelines for the "Centralized Waste
         Treatment Industry Category by April 31, 1994
         and take final action on these effluent guidelines
         by January 31, 1996. On February 4, 1997, the
         court approved modifications to the Decree which
         revised the deadline to August 1999 for final
         action.    EPA  provided  notice   of these
         modifications on February 26, 1997 at 62 FR
         8726.

         The Land Disposal
         Restrictions Program:                  1.1.3
         Introduction to RCRA Land
         Disposal Restrictions (LDR)           1.1.3.1
                 The  Hazardous  and   Solid  Waste
         Amendments   (HSWA)   to  the   Resource
         Conservation and Recovery Act (RCRA), enacted
                                            1-3

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Chanter 1 Background
Development Document for the CWT Point Source Category
on November 8, 1984, largely prohibit the land
disposal of untreated hazardous wastes. Once a
hazardous waste is prohibited from land disposal,
the statute provides only two options for legal
land disposal: meet the treatment standard for the
waste prior to land disposal, or dispose of the
waste in a land disposal unit that has been found
to satisfy the statutory no migration test.  A no
migration unit is one from which there will be no
migration of hazardous constituents for as long as
the waste remains hazardous (RCRA Sections
3004(d),(e),(g)(5)).     .
        Under  section 3004,  the  treatment
standards that EPA develops may be expressed as
either  constituent concentration  levels or  as
specific methods  of treatment. The criteria for
these standards is that they must substantially
diminish the toxicity of the waste or substantially
reduce the likelihood of migration of hazardous
constituents from the waste so that  short-term
and long-term threats to human health and the
environment are minimized  (RCRA  Section
3004(m)(l)).  For purposes of the restrictions, the
RCRA  program defines land disposal to include
any placement of hazardous waste in a landfill,
surface impoundment, waste pile, injection well,
land treatment facility, salt dome formation, salt
bed formation, or underground  mine or cave.
Land disposal restrictions are published in 40
CFR Part 268.
        EPA  has   used  hazardous   waste
treatability data as the basis for land disposal
restrictions standards. First, EPA has identified
Best   Demonstrated   Available   Treatment
Technology (BDAT) for each listed hazardous
waste.  BDAT is that treatment technology that
EPA finds to be  the most effective for a waste
which is also readily available to generators and
treaters. In some cases, EPA has designated, for
a particular waste stream, a treatment technology
which  has been  shown to successfully treat a
similar, but more difficult to treat, waste stream.
  This ensured that the land disposal restrictions
          standards  for  a listed  waste  stream  were
          achievable since they always reflected the actual
          treatability of the waste itself or of a  more
          refractory waste.
                 As  part  of   the   Land  Disposal
          Restrictions   (LDR),   Universal   Treatment
          Standards (UTS) were promulgated as part of the
          RCRA phase two final rule (July 27,1994). The
          UTS  are  a  series  of  concentrations for
          wastewaters and non-wastewaters that provide a
          single treatment standard for each constituent.
          Previously,  the LDR  regulated  constituents
          according to the identity of the original waste;
          thus, several numerical treatment standards might
          exist for each constituent.  The UTS simplified
          the standards  by having  only one  treatment
          standard for each  constituent in any   waste
          residue.
                 The LDR treatment standards established
          under RCRA may differ from the Clean Water
          Act effluent guidelines proposed here today both
          in their format and in the numerical values set for
          each constituent. The differences result from the
          use of different legal criteria for developing the
          limits and resulting differences in the technical
          and economic  criteria  and data sets  used for
          establishing the respective limits.
                  The differences in format of the LDR and
          effluent guidelines  is that LDR establishes a
          single daily limit for each pollutant parameter
          whereas the effluent guidelines establish monthly
          and daily limits.   Additionally,  the effluent
          guidelines provide for several types of discharge,
          including new vs. existing sources, and indirect
          vs. direct discharge.
                  The  differences in  numerical  limits
          established  under the  Clean Water Act may
          differ, not only from LDR. and  UTS, but also
          from  point-source  category to  point-source
          category (for example, Electroplating, 40 CFR
          Part 413; and Metal Finishing, 40 CFR Part 433).
          The effluent guidelines limitations and standards
          are industry-specific, subcategory-specific, and
                                             1-4

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Chapter 1 Background
Development Document for the CWT Point Source Category
technology-based.   The numerical limits  are
typically based on different data sets that reflect
the  performance   of   specific  wastewater
management and treatment practices. Differences
in the limits reflect differences in the statutory
factors  that the Administrator is required to
consider   in   developing   technically  and
economically   achievable   limitations   and
standards  --   manufacturing  products  and
processes (which, for CWTs  involves types of
waste received for treatment), raw materials,
wastewater characteristics, treatability, facility
size, geographic location, age of facility and
equipment,  non-water  quality environmental
impacts,  and  energy   requirements.     A
consequence of these differing approaches is that
similar   waste  streams can  be  regulated  at
different levels.

Overlap Between LDR Standards and
the Centralized Waste Treatment
Industry Effluent Guidelines           1.1.3.2
        EPA's survey for this guideline identified
no facilities discharging wastewater effluent to
land disposal units.  There is consequently no
overlap between the proposed regulations for the
CWT Industry and the Universal Treatment
Standards.
          by tanker truck, trailer/roll-off bins, drums, barge
          or other forms of shipment."  Facilities which
          received waste  from off-site solely  from via
          pipeline were excluded from the proposed rule.
          Facilities proposed for regulation included both
          stand-alone  waste  treatment  and  recovery
          facilities that treat waste received from off-site as
          well as those facilities that treat on-site generated
          process wastewater with wastes received from
          off-site.
                 The Agency proposed limitations  and
          standards for an estimated 85  facilities in three
          subcategories.    The  subcategories   for  the
          centralized waste treatment (CWT) industry were
          metal-bearing waste treatment and recovery,  oily
          waste treatment and recovery, and organic waste
          treatment and recovery.  EPA based the BPT
          effluent limitations proposed in 1995  on the
          technologies listed in Table 1.1  below. EPA
          based BCT, BAT, NSPS, PSES,  and PSNS on
          the same technologies as BPT.
CENTRALIZED WASTE TREATMENT
INDUSTRY EFFLUENT GUIDELINE
RULEMAKING HISTORY
January 27,1995 Proposal
   1.2
 1.2.1
        On January 27,1995 (60 FR 5464), EPA
proposed  regulations to  reduce discharges to
navigable waters of toxic, conventional, and non-
conventional pollutants in treated wastewater
from  facilities  defined  in  the  proposal as
"centralized  waste treatment facilities."   As
proposed, these  effluent limitations guidelines
and pretreatment standards would have applied to
"any facility that treats any hazardous  or non-
hazardous industrial waste received from off-site
                                            1-5

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Chanter 1 Background
                      Development Document for the CWT Point Source Category
    Table 1.1 Technology Basis for 1995 BPT Effluent Limitations
      Proposed  Name of Subcategory   Technology Basis
      Subpart
                Metal-Bearing Waste   Selective Metals Precipitation, Pressure Filtration, Secondar
                Treatment and        Precipitation, Solid-Liquid Separation, and Tertiary
                Recovery             Precipitation

                                       For Metal-Bearing Waste Which Includes
                                       Concentrated Cyanide Streams:
                                          Pretreatment by Alkaline Chlorination
                                          at Elevated Operating Conditions
         B
Oily Waste Treatment  Ultrafiltration or Ultrafiltration, Carbon Adsorption, and
and Recovery         Reverse Osmosis
                Organic Waste
                Treatment and
                Recovery
                    Equalization, Air Stripping, Biological Treatment, and
                    Multimedia Filtration
September 16,1996 Notice
of Data Availability
                       1.2.2
    Based on comments received on the 1995
proposal and new information, EPA reexamined
its conclusions about the Oily Waste Treatment
and Recovery subcategory, or "oils subcategory".
(The 1995 proposal had defined facilities in this
subcategory  as "facilities  that  treat,  and/or
recover oil from oily waste received from off-
site.") Subsequently, in 1996 EPA noticed the
availability of the new data on this subcategory.
EPA explained that it had underestimated the size
of the oils subcategory, and that the data used to
develop   the   original   proposal  may  have
mischaracterized this  portion of  the  CWT
industry. EPA had based its original estimates on
the  size  of this segment of  the  industry on
information  obtained from the  1991  Waste
Treatment Industry Questionnaire.  The basis
year for the questionnaire was 1989. Many of the
new oils facilities discussed in this notice began
operation after 1989. EPA concluded that many
of these facilities may have started up or modified
their  existing operations   in   response   to
requirements in EPA regulations, specifically, the
provisions of 40  CFR 279,  promulgated  on
September  10,  1992  (Standards  for  the
Management of Used Oil).  These regulations
govern the handling of used oils under the Solid
Waste Disposal Act and CERCLA.  EPA's 1996
notice discussed the additional facilities, provided
a revised description of the  subcategory and
described how the 1995 proposal limitations and
standards, if promulgated, would have affected
such facilities.  The notice, among other items,
also solicited comments on the use of dissolved
air flotation in this subcategory.
                                              1-6

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                                                                               Chapter
                                                                                      2
                                                    DATA COLLECTION
     EPA gathered and evaluated technical and
     economic data from various sources in the
course of developing the effluent limitations
guidelines and standards for the centralized waste
treatment industry.  These data sources include:

   EPA's Preliminary Data Summary for the
    Hazardous Waste Treatment Industry,
   Responses to EPA's "1991 Waste Treatment
    Industry Questionnaire";
   Responses to EPA's "Detailed Monitoring
    Questionnaire";
   EPA's 1990 - 1997 sampling of selected
    Centralized waste treatment facilities;
    Public comments to EPA's  1995 Proposed
    Rule;  .
   Public comments to EPA's  1996 Notice of
    Data Availability;
   Contact  with  members of the  industry,
    environmental    groups,     pretreatment
    coordinators,   Association  of Municipal
    Sewage Authorities (AMSA), regional, state,
    and other government representatives; and
   Other    literature    data,     commercial
    publications, and EPA data bases.

    EPA used data from these sources to profile
the industry with respect to:  wastes received for
treatment and/or recovery; treatment/recovery
processes;  geographical  distribution;   and
wastewater and solid waste disposal practices.
EPA then characterized the wastewater generated
by treatment/recovery  operations  through  an
evaluation of water usage, type  of discharge or
disposal, and the  occurrence of conventional,
non-conventional, and priority pollutants.
    The remainder of this chapter details the data
sources  utilized in  the development of  this
reproposal.
PRELIMINARY DATA SUMMARY
2.1
    EPA began an effort to develop effluent
limitations guidelines and pretreatment standards
for waste treatment operations in 1986. In this
initial study, EPA looked at a range of facilities,
including centralized waste treatment facilities,
landfills, and  industrial waste combustors, that
received hazardous waste  from  off-site  for
treatment, recovery, or disposal. The purpose of
the study was to characterize the hazardous waste
treatment industry, its operations, and pollutant
discharges into national waters. EPA published
the results of this study in the Preliminary Data
Summary for the Hazardous Waste Treatment
Industry in 1989 (EPA 440/1-89/100).  During
the same time period, EPA conducted two similar,
but separate,  studies of the solvent recycling
industry and  the used  oil reclamation and re-
refining industry.  In 1989, EPA also published
the results of these studies in two reports entitled
the Preliminary Data Summary for the Solvent
Recycling Industry (EPA 440/1-89/102) and the
Preliminary  Data  Summary  for Used  Oil
Reclamation  and Re-refining Industry (EPA
440/1-89/014).
    Based on a thorough analysis of the data
presented in the Preliminary Data Summary for
the Hazardous Waste Treatment Industry, EPA
decided it  should develop effluent limitations
guidelines and standards for the centralized waste
treatment industry. EPA also decided to develop
standards  for landfills and  industrial waste
combustors which were proposed on February 6,
1998 in the Federal Register (63  FR 6426 and 63
FR 6392, respectively).  In addition to centralized
waste treatment facilities, EPA also studied fuel
blending operations and waste solidification/
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 Chapter 2 Data Collection
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stabilization facilities. As detailed and defined in
the applicability section of the preamble, EPA
has decided not to propose nationally applicable
effluent limitations guidelines and standards for
fuel blending and stabilization operations.

CLEAN WATER ACT
SECTION 308 QUESTIONNAIRES           2.2
Development of Questionnaires         2.2.1

    A major source'of information and data used
in developing the proposed effluent limitations
guidelines and standards for the CWT category is
industry responses to questionnaires distributed
by EPA under the authority of Section 308 of the
CWA.  EPA developed two questionnaires, the
1991  Waste  Treatment Industry Questionnaire
and the Detailed Monitoring  Questionnaire, for
this study. The 1991 Waste Treatment Industry
Questionnaire was designed to request 1989
technical, economic, and financial data from,
what  EPA believed to be,  a  census  of the
industry. The Detailed Monitoring Questionnaire
was designed to elicit daily analytical data from a
limited  number of facilities  which  would  be
chosen  after receipt and review of the 1991
Waste   Treatment   Industry   Questionnaire
responses.
    In order to niinirnize the burden to centralized
waste treatment facilities, EPA designed the 1991
Waste Treatment Industry Questionnaire such
that recipients could use information reported in
their 1989 Hazardous Waste Biennial Report as
well as  any other readily accessible data. The
technical portion of the questionnaire,  Part A,
specifically requested information on:
       /
   Treatment/recovery processes;
   Types and quantities of waste  received for
    treatment;
   The industrial waste management practices
    used;
   Ancillary waste management operations;
   The quantity  treatment,  and  disposal  of
              wastewater generated during industrial waste
              management;
              Summary analytical monitoring data;
              The degree  of co-treatment (treatment of
              CWT wastewater with wastewater from other
              industrial operations at the facility);
              Cost  of  the  waste  treatment/recovery
              processes; and
              The extent of wastewater recycling or reuse
              at facilities.

              Since the summary monitoring information
          requested in the 1991 Waste Treatment Industry
          Questionnaire    was    not   sufficient   for
          determination  of limitations  and  industry
          variability,   EPA  designed  a    follow-up
          questionnaire,    the    Detailed   Monitoring
          Questionnaire (DMQ), to collect daily analytical
          data from a limited number of facilities. EPA
          requested all DMQ facilities to submit effluent
          wastewater monitoring  data  in the form of
          individual  data  points  rather  than monthly
          aggregates, generally for the 1990 calendar year.
          Some facilities were also requested to submit
          monitoring data for intermediate waste treatment
          points in an effort to obtain pollutant removal
          information    across    specified   treatment
          technologies.
              Since  most  CWT  facilities do not  have
          analytical data for their wastewater treatment
          system influent,  EPA  additionally requested
          DMQ facilities to submit copies of their waste
          receipts for a six week period. Waste receipts are
          detailed logs of individual waste shipments sent
          to a CWT for treatment EPA selected a six week
          period to minimize the burden to recipients and to
          create a manageable database.
             EPA sent draft questionnaires to industry
          trade associations, treatment facilities who had
          expressed interest, and environmental groups for
          review and comment.   EPA also  conducted a
          pre-test of the  1991 Waste Treatment Industry
          Questionnaire at nine centralized waste treatment
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Chanter 2 Data Collection
Development Document for the CWT Point Source Category
facilities to determine if the type of information
necessary would be received from the questions
posed as well as to determine if questions were
designed to minimize the burden to facilities.
EPA  did not conduct a pre-test of the Detailed
Monitoring  Questionnaire  due to the project
schedule limitations.
    Based on comments from the reviewers, EPA
determined the draft questionnaire required minor
adjustments  in  the technical  section  and
substantial revisions for both the economic and
financial sections.  EPA anticipated extensive
comments, since this was EPA's first attempt at
requesting detailed information from a service
industry as  opposed to a manufacturing-based
industry.
    As required by the Paperwork Reduction Act,
44 U.S.C. 3501 et  seq., EPA submitted  the
questionnaire package (including the revised
1991  Waste Treatment Industry Questionnaire
and the Detailed Monitoring Questionnaire) to the
Office of Management and Budget (OMB) for
review, and  published a notice in the Federal
Register to  announce the  questionnaire  was
available for  review and  comment (55  FR
45161). EPA also redistributed the questionnaire
package  to  industry   trade  associations,
centralized waste  treatment industry facilities,
and environmental  groups  that had  provided
comments on the previous draft and to any others
who  requested a copy of the  questionnaire
package.
    No additional comments were received and
OMB cleared the entire questionnaire package for
distribution on April 10,1991.
 Distribution of Questionnaires
  2.2.2
     In 1991, under the authority of Section 308
 of the  CWA,  EPA sent the Waste Treatment
 Industry Questionnaire to 455 facilities that the
 Agency had identified as possible CWT facilities.
 Because there is no specific centralized waste
          treatment  industry  Standard Industrial Code
          (SIC),  identification of facilities was difficult.
          EPA looked to directories of treatment facilities,
          other Agency information sources, and even
          telephone directories to identify the 455 facilities
          which received the questionnaires. EPA received
          responses from 413 facilities indicating that 89
          treated  or  recovered material  from  off-site
          industrial waste  in 1989.  The remaining 324
          facilities did not treat, or recover materials from
          industrial waste  from  off-site.  Four of the 89
          facilities only received waste via a pipeline (fixed
          delivery system) from the  original source of
          wastewater generation.
              EPA obtained  additional information from
          the    1991   Waste    Treatment   Industry
          Questionnaire recipients through follow-up phone
          calls and  written requests for clarification of
          questionnaire responses.
              After   evaluation  of  the  1991   Waste
          Treatment  Industry Questionnaire  responses,
          EPA selected 20 in-scope facilities from the 1991
          Waste Treatment Industry Questionnaire mailing
          list  to complete  the  Detailed  Monitoring
          Questionnaire.   These facilities were selected
          based  on:  the types and quantities of wastes
          received for treatment; the quantity of on-site
          generated  wastewater  not  resulting  from
          treatment or recovery of off-site generated waste;
          the treatment/recovery technologies and practices;
          and the facility's wastewater discharge permit
          requirements. All 20 DMQ recipients responded.
           WASTEWATER SAMPLING
           AND SITE VISITS
           Pre-1989 Sampling Program
  2.3
2.3.1
              From 1986 to  1987, EPA conducted  site
          visits  and  sampled  at  twelve facilities  to
          characterize  the waste  streams and  on-site
          treatment technology performance at hazardous
          waste incinerators, Subtitle C and D landfills, and
          hazardous waste treatment facilities as part of the
          Hazardous Waste Treatment Industry Study. All
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Chapter 2 Data Collection
' Development Document for the CWT Point Source Category
of the facilities in this sampling program had
multiple operations,  such as incineration and
commercial wastewater treatment The sampling
program did not focus on  characterizing the
individual   waste  streams   from  individual
operations. Therefore, the data collected cannot
be used for the characterization of centralized
waste treatment wastewater, the assessment of
treatment performance, or the development of
limitations  and standards.  Information collected
in the study is presented in the Preliminary Data
Summary for the Hazardous  Waste Treatment
Industry (EPA 440/1-89/100).
1989-1997 Site Visits
  2.3.2
    Between 1989 and 1993, EPA visited 27
centralized  waste  treatment  facilities.    The
purpose of these  visits was to collect various
information about the operation of CWTs, and, in
most cases, to evaluate each facility as a potential
week-long sampling candidate.   EPA selected
these facilities based on the information gathered
by  EPA  during the  selection  of the Waste
Treatment Industry Questionnaire recipients and
the subsequent questionnaire responses. ,
    In late 1994, EPA visited an additional four
facilities which specialize in the treatment of
bilge waters and other dilute oily wastes. These
facilities were not in operation at the time the
questionnaire was mailed, but were identified by
EPA  through contact with the  industry  and
AMSA.  EPA visited these facilities to evaluate
them  as potential sampling candidates and to
determine if CWT operations at facilities which
accept dilute oily wastes or used material  were
significantly different than CWT operations at
facilities that accept concentrated oily wastes.
    Following the 1995 proposal, EPA visited
nine  centralized  waste  treatment  facilities,
including eight additional  oils facilities and one
metals facility which had also been visited prior
to the proposal.  EPA selected these facilities
based on information obtained by EPA through
proposal public comments, industry contacts, and
EPA regional staff.  In late 1997, EPA visited
two pipeline  facilities  identified prior to the
proposal (one via the questionnaire  and the
second  through review of the OCPSF database
and  follow-up  phone  calls)  in  order  to
characterize operations at pipeline facilities.
    During each facility site visit, EPA gathered
the following information:

   The process  for  accepting  waste  for
    treatment or recovery;
   The types of waste accepted for treatment;
   Design   and  operating  procedures  for
    treatment technologies;
   The location of potential sampling points;
   Site specific sampling requirements;
   Wastewater generated on-site and its sources;
   Wastewater discharge option and limitations;
   Solid waste disposal practices;
   General facility management practices; and
   Other facility operations.

Site visit reports were prepared for all visits and
are located  in the regulatory record  for  this
proposal.

Sampling Episodes                     2.3.3
Facility Selection                       2.3.3.1
    EPA selected facilities to be sampled by
reviewing the information  received during site
visits and  assessing  whether the  wastewater
treatment system (1) was theoretically effective in
removing pollutants, (2) treated wastes received
from  a variety of sources,  (3) was operated in
such a way as to optimize the performance of the
treatment technologies, and (4) applied waste
management  practices  mat  increased  the
effectiveness of the treatment unit.
    EPA also evaluated   whether the  CWT
portion  of each facility flow was adequate to
assess the treatment system performance for the
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Chapter 2 Data Collection
Development Document for the CWT Point Source Category
centralized waste treatment waste stream.  At
some facilities, the centralized waste treatment
operations were minor portions of the overall site
operation.  In such cases, where the centralized
waste treatment waste stream is commingled with
non-centralized waste treatment streams prior to
treatment, characterization  of this waste stream
and  assessment of treatment performance is
difficult. Therefore, data from these commingled
systems could not be used  to establish effluent
limitations guidelines  and standards  for  the
centralized waste treatment  industry.
    Another   important consideration  in  the
sampling  facility  selection process  was  the
commingling  of wastes from more than  one
centralized waste treatment subcategory.   For'
example, many  facilities treated metal-bearing
and oily waste in the same treatment system. In
such cases, EPA did not select these facilities for
treatment technology sampling since EPA could
not determine whether a decrease in  pollutant
concentrations in the commingled stream would
be  due to ,an  efficient treatment system or
dilution.
    Using  the  criteria  detailed  above, EPA
selected 14 facilities to sample in order to collect
wastewater treatment efficiency data to be used to
establish  effluent  limitations  guidelines  and
standards  for the  centralized waste treatment
industry.  Twelve facilities were sampled prior to
the  1995  proposal and four  facilities (two
additional and two resampled) were sampled after
the proposal.

Sampling Episodes                     2.3.3.2
    After EPA selected a facility to sample, EPA
prepared a draft sampling plan which described
the location of sample points, the analysis to be
performed  at  specified sample  points, and the
procedures to be followed  during the sampling
episode. Prior to sampling, EPA provided a copy
of the draft  sampling plan to  the  facility for
review and comment to ensure EPA properly
          described and understood facility operations. All
          comments  were  incorporated  into  the  final
          sampling plan.
              During the sampling episode, EPA collected
          samples of influent, intermediate, and effluent
          streams, preserved the samples, and sent them to
          EPA-approved laboratories. Facilities were given
          the option to split samples with EPA, but most
          facilities  declined.   Sampling  episodes  were
          generally conducted over a five-day period during
          which EPA obtained 24-hour composite samples
          for  continuous systems and  grab samples for
          batch systems.
              Following the  sampling   episode,  EPA
          prepared a draft sampling report that included
          descriptions of the treatment/recovery processes,
          sampling procedures, and analytical results.  EPA
          provided draft reports to facilities for comment
          and review.  All corrections were incorporated
          into the final report. Both final sampling plans
          and reports for all episodes are located in the
          regulatory record for this reproposal.
              The specific constituents analyzed at each
          episode and sampling point varied and depended
          on the waste type being treated and the treatment
          technology being evaluated. At the initial two
          sampling  episodes,  the   entire  spectrum  of
          chemical  compounds  for which  there  are
          EPA-approved analytical methods were analyzed
          (more than 480 compounds). Table 2-1 provides
          a complete list of these pollutants. After a review
          of the  initial  analytical  data, the number of
          constituents analyzed was decreased by omitting
          analyses for dioxins/furans, pesticides/herbicides,
          methanol,     ethanol,    and    formaldehyde.
          Pesticides/herbicides were analyzed on a limited
          basis depending on the treatment chemicals used
          at facilities.   Dioxin/furan analysis  was only
          performed on a limited basis for solid/filter cake
          samples  to  assess  possible  environmental
          impacts.
              Data resulting from the influent  samples
          contributed  to  the  characterization of  this
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Chapter 2 Data Collection
Development Document for the CWT Point Source Category
industry, development of the list of pollutants of
concern,  and  development  of  raw   waste
characteristics.    EPA  used  the  influent,
intermediate, and effluent points to analyze the
efficacy of treatment  at  the facilities and to
develop   current   discharge   concentrations,
loadings, and treatment technology options for
the centralized waste treatment industry. Finally,
EPA used data collected from the effluent points
to calculate the long term averages (LTAs) for
each of the proposed regulatory options. The use
of this data is discussed in detail in subsequent
chapters.
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Chapter 2. Data Collection
Development Document for the CWTPoint Source Category
Table 2-1.  Chemical Compounds Analyzed Under EPA Analytical Method
Pollutant
CasNum
CLASSSICAL WET CHEMISTRY
Amenable Cyanide
Ammonia Nitrogen
BOD
Chloride
COD
Fluoride
Hexane Extractable Mater.
Hexavalent Chromium
Nitrate/nitrite
PH
Recoverable Oil & Grease
TDS
TOC
Total Cyanide
Total Phenols
Total Phosphorus
Total Solids
Total Sulfide
TSS
C-025
7664-41-7
C-002
16887-00-6
C-004 .
16984-48-8
C-036
18540-29-9
C-005
C-006
C-007
C-010
C-012
57-12-5
C-020
14265-44-2
C-008
18496-25-8
C-009
1613: DlOXINS/FURANS
2378-TCDD *
2378-TCDF
12378-PECDD
12378-PECDF
23478-PECDF
123478-HXCDD
123678-HXCDD
123789-HXCDD
123478-HXCDF
123678-HXCDF
123789-HXCDF
234678-HXCDF
1234678-HPCDD
1234678-HPCDE
1234789-HPCDF
Ocdd
Ocdf
1746-01-6
51207-31-9
40321-76-4
57117-41-6
57117-31-4
39227-28-6
57653-85-7
19408-74-3
70648-26-9
57117-44-9
72918-21-9
60851-34-5
35822-46-9
67562-39-4
55673-89-7
3268-87-9
39001-02-0
1657: PESTICIDES/HERBICIDES
Azinphos Ethyl
Azinphos Methyl
Chlorfevinphos
Chlorpyrifos
Coumaphos
Crotoxyphos
Def
Demeton a
Demeton B
Diazinon
Dichlorfenthion
Dichlorvos
Dicrotophos
Dimethoate
Dioxathion
2642-71-9
86-50-0
470-90-6
2921-88-2
56-72-4
7700-17-6
78-48-8
8065-48-3A
8065-48-3B
333-41-5
97-17-6
62-73-7
141-66-2
60-51-5
78-34-2
Pollutant
Disulfoton
Epn
Ethion
Ethoprop
Famphur
Fensulfothion
Fenthion
Hexamethylphosphoramide
Leptophos
Malathion
Merphos
Methamidophos
Methyl Chlorpyrifos
Methyl Parathion
Methyl Trithion
Mevinphos
Monocrotophos
Naled
Parathion (Ethyl)
Phorate
Phosmet
Phosphamidon E
Phosphamidon Z
Ronnel
Sulfotepp
Sulprofos
Tepp .
Terbufos
Tetiachlorvinphos
Tokuthion
Trichlorfon
Trichloronate
Tricresylphosphate
Trimethylphosphate
CasNum
298-04-4
2104-64-5
563-12-2
13194-48-8
52-85-7
115-90-2
55-38-9
680-31-9
21609-90-5
121-75-5
150-50-5
10265-92-6
5598-13-0
298-00-0
953-17-3
7786-34-7
6923-22-4
300-76-5
56-38-2
298-02-2
732-11-6
297-99-4
23783-98-4
299-84-3
3689-24-5
35400-43-2
107-49-3
13071-79-9
22248-79-9
34643-46-4
52-68-6
. 327-98-0
78-30-8
512-56-1
1656: PESTICIDES/HERBICIDES
Acephate
Acifluorfen
Alachlor
Aldrin
Atrazine
Benfluralin
Alpha-bhc
Beta-bhc
Gamma-bhc
Delta-bhc
Bromacil
Bromoxynil Octanoate
Butachlor
Captafol
Captan
Carbophenothion
Alpha-chlordane
Gamma-chlordane
Chlorobenzilate
30560-19-1
50594-66-6
15972-60-8
309-00-2
1912-24-9
1861-40-1
319-84-6
319-85-7
58-89-9
319-86-8
314-40-9
1689-99-2
23184-66-9
2425-06-1
133-06-2
786-19-6
5103-71-9
5103-74-2
510-15-6
Pollutant
Chloroneb
Chloropropylate
Chlorothalonil
Dibromochloropropane
Dacthal (Dcpa)
4,4'-ddd
4,4'-dde
4,4'-ddt
Diallate a
Diallate B
Dichlone
Dicofol
Dieldrin
Endosulfan I
Endosulfan li
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Endrin Ketone
Ethalfluralin
Etradiazole
Fenarimol
Dicofol
Dieldrin
Endosulfan I
Endosulfan li
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Endrin Ketone
Ethalfluralin
Etradiazole
Fenarimol
Dicofol
Dieldrin
Endosulfan I
Endosulfan li
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Endrin Ketone
Ethalfluralin
Etradiazole
Fenarimol
Dicofol
Dieldrin
Endosulfan I
Endosulfan li
Endosulfan Sulfate
Endrin
Endrin Aldehyde
Endrin Ketone
Ethalfluralin

CasNum
2675-77-6
5836-10-2
1897-45-6
96-12-8
1861-32-1
72-54-8
72-55-9
50-29-3
2303-16-4A
2303-16-4B
117-80-6
115-32-2
60-57-1
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-93-4
53494-70-5
55283-68-6
2593-15-9
60168-88-9
115-32-2
60-57-1
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-93-4
53494-70-5
55283-68-6
2593-15-9
60168-88-9
115-32-2
60-57-1
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-93-4
53494-70-5
55283-68-6
2593-15-9
60168-88-9
115-32-2
60-57-1
959-98-8
33213-65-9
1031-07-8
72-20-8
7421-93-4
53494-70-5
55283-68-6

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  Chanter 2 Data Collection
                            Development Document for the CWT Point Source Category
  Table 2-1.  Chemical Compounds Analyzed Under EPA Analytical Methods (continued
Pollutant
Cas
                               Pollutant
                                                        CasNum
                                                                     Pollutant
Trifluralin         1582-09-8
 1658: PESTICIDES/HERBICIDES
Dalapon            75-99-0
Dicamba          1918-00-9
Dichloroprop       120-36-5
Dinoseb            88-85-7
Mcpa              94-74-6
Mcpp             7085-19-0
Picloram          1918-02-1
2,4-d              94-75-7
2,4-db             94-82-6
2,4,5-t             93-76-5
2,4,5-tp            93-72-1
        1620: METALS
Aluminum         7429-90-5
Antimony         7440-36-0
Arsenic           7440-38-2
Barium            7440-39-3
Beryllium         7440-41-7
Bismuth          7440-69-9
Boron            7440-42-8
Cadmium         7440-43-9
Calcium          7440-70-2
Cerium           7440-45-1
Chromium        7440-47-3
Cobalt            7440-48-4
Copper           7440-50-8
Dysprosium       7429-91-6
Erbium           7440-52-0
Europium         7440-53-1
Gadolinium       7440-54-2
Gallium           7440-55-3
Germanium       7440-56-4
Gold             7440-57-5
Hamium          7440-58-6
Holmium         7440-60-0
Beryllium         7440-41-7
Bismuth          7440-69-9
Boron            7440-42-8
Cadmium         7440-43-9
Calcium          7440-70-2
Cerium           7440-45-1
Chromium        7440-47-3
Cobalt            7440-48-4
Copper           7440-50-8
Dysprosium       7429-91-6
Erbium           7440-52-0
Europium         7440-53-1
Gadolinium       7440-54-2
Gallium          7440-55-3
Germanium       7440-56-4
Gold              7440-57-5
Hafnium   	7440-58-6
            Phosphorus
            Platinum
            Potassium
            Praseodymium
            Rhenium
            Rhodium
            Ruthenium
            Samarium
            Scandium
            Selenium
            Silicon
            Silver
            Sodium
            Strontium
            Sulfur
            Tantalum
            Tellurium
            Terbium
            Thallium
            Thorium
            Thulium
            Tin
            Titanium
            Tungsten
            Uranium
            Vanadium
            Ytterbium
            Yttrium
            Zinc
            Zirconium
7723-14-0
7440-06-4
7440-09-7
7440-10-0
7440-15-5
7440-16-6
7440-18-8
7440-19-9
7440-20-2
7782-49-2
7440-21-3
7440-22-4
7440-23-5
7440-24-6
7704-34-9
7440-25-7
13494-80-9
7440-27-9
7440-28-0
7440-29-1
7440-30-4
7440-31-5
7440-32-6
7440-33-7
7440-61-1
7440-62-2
7440-64-4
7440-65-5
7440-66-6
7440-67-7
                   1624: VOLATILE ORGANICS
             1,1-dichloroethane          75-34-3
             1,1-dichloroethene          75-35-4
             1,1,1-trichloroethane        71-55-6
             1,1,1,2-tetrachloroethane    630-20-6
             1,1,2-trichloroethane        79-00-5
             1,1,2,2-tetrachloroethane     79-34-5
             1,2-dibromoethane         106-93-4
             1,2-dichloroethane         107-06-2
             1,2-dichloropropane         78-87-5
             1,2,3-trichloropropane       96-18-4
             1,3-dichloropropane        142-28-9
             1,4-dioxane               123-91-1
             2-butanone (Mek)          78-93-3
             2-chloro-l,3-butadiene     126-99-8
             2-chloroethylvinyl Ether    110-75-8
             2-hexanone               591-78-6
             2-methyl-2-propenenitrile   126-98-7
             2-propanone (Acetone)      67-64-1
             2-propenal (Acrolein)        107-02-8
             Vanadium                7440-62-2
             Ytterbium                7440-64-4
             Yttrium                  7440-65-5
Acrylonitrile                   107-13-1
Benzene                       71-43-2
Bromodichloromethane          75-27-4
Bromoform                    75-25-2
Bromomethane                 74-83-9
Carbon Disulfide               75-15-0
Chloroacetonitrile               107-14-2
Chlorobenzene                 108-90-7
Chloroethane                  75-00-3
Chloroform                    67-66-3
Chloromethane                 74-87-3
Cis-l,3-dichloropropene        10061-01-5
Crotonaldehyde               4170-30-3
Dibromochloromethane         124-48-1
Dibromomethane               74-95-3
Diethyl Ether                  60-29-7
Ethyl Benzene                 100-41-4
Ethyl Cyanide                  107-12-0
Ethyl Methacrylate              97-63-2
lodomethane                  74-88-4
Isobutyl Alcohol                78-83-1
Methylene Chloride             75-09-2
M-xylene                     108-38-3
O+pXylene                 136777-61-2
Tetrachloroethene              127-18-4
Tetrachloromethane             56-23-5
Toluene                       108-88-3
Trans-l,2-dichloroethene        156-60-5
Trans-l,3-dichloropropene      10061-02-6
Trans-l,4-dichloro-2-butene      110-57-6
Trichloroethene                79-01-6
Trichlorofluoromethane         75-69-4
Vinyl Acetate                  108-05-4
Vinyl Chloride                 75-01-4
        1625: SEMIVOLATILE ORGANICS
 1-methylfluorene               1730-37-6
 1-methylphenanthrene          832-69-9
 1-phenylnaphthalene            605-02-7
 l,2-dibromo-3-chloropropane     96-12-8
 1,2-dichlorobenzene            95-50-1
 1,2-diphenylhydrazine          122-66-7
 1,2,3-trichlorobenzene          87-61-6
 1,2,3-trimethoxybenzene        634-36-6
 1,2,4-trichlorobenzene          120-82-1
 1,2,4,5-tetrachlorobenzene        95-94-3
 l,2:3,4-diepoxybutane          1464-53-5
 1,3-benzenediol (Resorcinol)     108-46-3
 l,3-dichloro-2-propanol          96-23-1
 1,3-dichlorobenzene            541-73-1
 1,3,5-trithiane                 291-21-4
 1,4-dichlorobenzene            106-46-7
 1,4-dinitrobenzene             100-25-4
 1.4-naphthoquinone            130-15-4
                                                      2-8  -

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Chapter 2 Data Collection
Development Document for the CWTPoint Source Category
Table 2-1.  Chemical Compounds Analyzed Under EPA Analytical Methods (continued
Pollutant
1,5-naphthalenediamine
2-bromochlorobenzene
2-chloronaphthalene
2-chlorophenol
2-isopropylnaphthalene
2-methyl-4,6-dinitrophenol
2-methylbenzothioazole
2-methylnaphthalene
2-nitroaniline
2-nitrophenol
2-phenyInaphthalene
2-picoline
2-(Methylthio)benzothiazole
2,3-benzofluorene
2,3-dichloroaniline
2,3-dichloronitrobenzene
2,3,4,6-tetrachlorophenol
2,3,6-tricWorophenol
2,4-diaminotoluene
2,4-dichlorophenol
2,4-dimethyiphenol
2,4-dinitrophenol
2,4-dinitrotoIuene
2,4,5-trichlorophenol
2,4,5-trimethylaniline
2,4,6-trichlorophenol
2,6-dichloro-4-nitroaniline
2,6-dichlorophenol
2,6-dinitrotoluene
2,6-di-tert-bu1yl-p-benzoquinone
3-bromochlorobenzene
3-chIoronitrobenzene
3-methylcholanthrene
3-nitroaniline
3,3-dichlorobenzidine
3,3'-dimethoxybenzidine
3,5-dibromo-4-hydroxybenzonitriIe
3,6-dimethylphenanthrene
4-aminobiphenyl
4-bromophenyl Phenyl Ether
4-chloro-2-nitroaniline
4-chIoro-3-methylphenol

4-chloroaniIine
4-chlorophenyl Phenyl Ether
4-nitroaniIine
4-nitrobiphenyl
4-nitrophenol
4,4-methylene-bis(2-chloroaniline)
4,5-methylene-phenanthrene

5-chloro-o-toluidine
5-nitro-o-toluidine
7,12-dimethylbenz(a)anthracene
Acenaohthene
CasNum
2243-62-1
694-80-4
91-58-7
95-57-8
2027-17-0
534-52-1
120-75-2
91-57-6
88-74-4
88-75-5
612-94-2
109-06-8
615-22-5
243-17-4
608-27-5
3209-22-1
58-90-2
933-75-5
95-80-7
120-83-2
105-67-9
51T28-5
121-14-2
95-95-4
137-17-7
88-06-2
99-30-9
87-65-0
606-20-2
719-22-2
108-37-2
121-73-3
56-49-5
99-09-2
91-94-1
119-90-4
1689-84-5
1576-67-6
92-67-1
101-55-3
89-63-4
59-50-7

106-47-8
7005-72-3
100-01-6
92-93-3
100-02-7
101-14-4
203-64-5

95-79-4
99-55-8
57-97-6
83-32-9
Pollutant
Acenaphthylene
Acetophenone
Alpha-naphthylamine
Alpha-terpineol
Aniline
Anthracene
Aramite
Benzanthrone
Benzenethiol
Benzidine
Benzole Acid
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzyl Alcohol
CasNum
208-96-8
98-86-2
134-32-7
98-55-5
62-53-3
120-12-7 '
140-57-8
82-05-3
108-98-5
92-87-5
65-85-0
56-55-3
50-32-8
205-99-2
191-24-2
207-08-9
100-51-6
1625: SEMNOLATILE ORGANICS
Beta-naphthylamine
Biphenyl
Bis(2-chloroethoxy) Methane
Bis(2-chloroethyl) Ether
Bis(2-chloroisopropyl) Ether
Bis(2-ethylhexyl) Phthalate
Butyl Benzyl Phthalate
Carbazole
Chrysene
Crotoxyphos
Dibenzofuran
Dibenzothiophene
Dibenzo(a,h)anthracene
Diethyl Phthalate
Dimethyl Phthalate
Dimethyl Sulfone .
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Ethyl Methanesulfbnate
Ethylenethiourea
Ethynylestradiol-3-
methyl Ether
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene

HexanoicAcid
Indeno( 1 ,2,3-cd)pyrene
Isophorone
Isosafrole
91-59-8
92-52-4
111-91-1
111-44-4
108-60-1
117-81-7
85-68-7
86-74-8
218-01-9
7700-17-6
132-64-9
132-65-0
53-70-3
84-66-2
131-11-3
67-71-0
84-74-2
117-84-0
101-84-8
122-39-4
882-33-7
62-50-0
96-45-7
72-33-3

206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
1888-71-7

142-62-1
193-39-5
78-59-1
120-58-1
Pollutant
Longifolene
Malachite Green
Methapyrilene
Methyl Methanesulfonate
Naphthalene
N-C10(N-decane)
N-C12 (N-dodecane)
N-C14 (N-tetradecane)
N-C16 (N-hexadecane)
N-C18 (N-octadecane)
N-C20 (N-eicosane)
N-C22 (N-docosane)
N-C24 (N-tetracosane)
N-C26 (N-hexacosane)
N-C28 (N-octacosane)
N-C30 (N-triacontane)
Nitrobenzene
N-nitrosodiethylamine
N-nitrosodimethylamine
N-nitrosodi-n-butylamine
N-nitrosodi-n-propylamine
N-nitrosodiphenylamine
N-nitrosomethyl -Ethylamine
N-nitrosomethyl-phenylamine
N-nitrosomorpholine
N-nitrosopiperidine
N,n-dimethylformamide
O-anisidine
O-cresol
O-toluidine
P-cresol
P-cymene
P-dimethylamino-azobenzene
Pentachlorobenzene
Pentachloroethane
Pentachlorophenol
Pentamethylbenzene
Perylene
Phenacetin
Phenanthrene
Phenol
Phenothiazine

Pronamide
Pyrene
Pyridine
Safrole
Squalene
Styrene
Thianaphthene
(2,3-benzothiophene)
Thioacetamide
Thioxanthone
Triphenylene
Tripropyleneglycolmethyl Ether
CasNum
475-20-7
569-64-2
91-80-5
66-27-3
91-20-3
124-18-5
112-40-3
629-59-4
544-76-3
593-45-3
112-95-8
629-97-0
646-31-1
630-01-3
630-02-4
638-68-6
98-95-3
55-18-5
62-75-9
924-16-3
621-64-7
86-30-6
10595-95-6
614-00-6
59-89-2
100-75-4
68-12-2
90-04-0
95-48-7
95-53-4
106-44-5
99-87-6
60-11-7
608-93-5
76-01-7
87-86-5
700-12-9
198-55-0
62-44-2
85-01-8
108-95-2
92-84-2

23950-58-5
129-00-0
110-86-1
94-59-7
7683-64-9
100-42-5
95-15-8

62-55-5
492-22-8
217-59-4
20324-33-8
                                            2-9

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Chapter 2 Data Collection
Development Document for the CWT Point Source Category
Metal-Bearing Waste Treatment
 and Recovery Sampling               2.3.3.3
    Between 1989 and 1994, EPA conducted six
sampling episodes at facilities classified in the
metals subcategory. Two of these facilities were
re-sampled in 1996 following the proposal. Only
one of those facilities sampled discharged to a
surface water.  The rest are indirect dischargers.
    All of the facilities used metals precipitation
as a means for treatment, but each of the systems
was unique due to the treatment chemicals used
and  the  system configuration and operation.
Most facilities precipitated metals in batches.
One facility segregated waste shipments  into
separate batches to optimize the precipitation of
specific  metals, then commingled the treated
batches to precipitate additional metals. Another
facility had a continuous  system for precipitation
in which the wastewater flowed through a series
of treatment chambers,  each using a different
treatment chemical. EPA evaluated the following
treatment technologies: primary, secondary, and
tertiary    precipitation,   selective    metals
precipitation,  gravity separation,  multi-media
filtration,  clarification,  liquid  and   sludge
filtration, and treatment technologies for cyanide
destruction.
    EPA conducted sampling at metals facilities
after the  1995  proposal to determine what effect
total dissolved solids (TDS) concentrations had
on  the  performance of  metals  precipitation
processes.   This  issue was  raised  in  public
comments to  the  1995 proposed  rule.  EPA
resampledtwo  facilities which had been sampled
prior to  the first  proposal.  The  first facility
formed  the technology  basis for  the  1995
proposed metals subcategory regulatory option
and the second was a facility with high levels of
TDS  in  the influent waste stream.  EPA was
interested in obtaining additional data from the
proposal option facility since they had  altered
their treatment systems from  those previously
sampled  and because EPA failed to collect TDS
          information during the original sampling episode.
          EPA was interested in collecting additional data
          from the second facility because the facility has
          high TDS values. EPA used data from both of
          the post-proposal sampling episodes to develop
          regulatory options considered for the re-proposal.

          Oily Waste Treatment
          and Recovery Sampling                 2.3.3.4
             Between 1989 and 1994, EPA  conducted
          four sampling episodes  at oils subcategory
          facilities.  Two  additional  oils facilities were
          sampled in 1996 following the proposal. All six
          are indirect dischargers and performed an initial
          gravity separation step with or without emulsion
          breaking to remove oil from the wastewater.  At
          two facilities, however, the wastewater from the
          separation  step  was commingled  with  other
          non-oily wastewater prior to further treatment.
          As such, EPA could only use  data from these
          facilities to characterize the waste streams after
          emulsion breaking.   The other  four facilities
          treated the wastewater from the initial separation
          step   without  commingling   with   non-oils
          subcategory wastewaters in systems specifically
          designed to treat oily wastewater.  EPA evaluated
          the following treatment  technologies for this
          subcategory:   gravity  separation,   emulsion
          breaking, ultrafiltration, dissolved air flotation,
          biological treatment, reverse osmosis, carbon
          adsorption, and air stripping.
             EPA conducted sampling at oils facilities in
          late  1994 (just before the proposal)  and again
          after the proposal to address concerns raised at
          the 1994 public meeting and  in the proposal
          public comments.  Specifically, in regards to oils
          wastewater treatment, the commenters  stated that
          (1) the facility which formed the technology basis
          for EPA's  1995 proposed option did not treat
          wastes which were representative of the wastes
          treated by many other oils  facilities, and (2) EPA
          should evaluate dissolved air flotation as a basis
          for the regulatory option.   All three  of the
                                            2-10

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Chapter 2 Data Collection
Development Document for the CWT Point Source Category
facilities  sampled  between  1994 and 1996
utilized dissolved air flotation and treated wastes
which were generally more  dilute than those
treated by the 1995 proposal option facility. EPA
used  data  from  both of  the  post-proposal
sampling episodes to develop regulatory options
considered for this re-proposal.  Data from the
1994  episode  were  not  used  to develop  a
regulatory option due to non-optimal performance
and highly diluted influent streams; however,
EPA used data from this facility to characterize
the waste stream after emulsion breaking.

Organic-Bearing Waste Treatment
and Recovery Sampling               2.3.3.5
    EPA had difficulty identifying facilities that
could be used to characterize waste streams and
assess treatment technology performance in the
organics subcategory. A  large portion of the
facilities,  whose  organic   waste  treatment
operations EPA evaluated, had other industrial
operations on-site.   For these facilities, CWT
waste streams represented a minor component of
the overall facility flow.
    Between 1989 and  1994, EPA did identify
and  sample three  facilities that treated  a
significant volume of off-site generated organic
waste relative to non-CWT flows. None of these
facilities were direct discharging facilities. EPA
evaluated treatment technologies including: air
stripping, biological treatment in a sequential
batch    reactor,    multi-media   filtration,
coagulation/flocculation, carbon adsorption, and
CO2 extraction. EPA chose not to use data from
one of the three facilities in calculating effluent
levels achievable with its  in-place technologies
because the facility was experiencing operational
difficulties with the treatment system at the time
of sampling.  In addition, after reviewing the
facility's  waste receipts  during  the sampling
episode,  EPA  determined  that  the   facility
accepted  both oils  subcategory  and organics
subcategory wastestreams and commingled them
          for treatment.  EPA has also not used data from
          a second facility in  calculating effluent  levels
          achievable with its in-place technologies because,
          after  reviewing this  facility's waste  receipts
          during the'sampling  episode, EPA determined
          that  this   facility  also  accepted  both oils
          subcategory    and   organics   subcategory
          wastestreams   and   commingled  them  for
          treatment
          1998 Characterization Sampling of Oil
          Treatment and Recovery Facilities      2.3.4

             EPA received many comments to the original
          proposal concerning the size and diversity of the
          oils treatment and recovery subcategory.  Many
          suggested that the subcategory  needed  to  be
          further subdivided in an effort to better depict the
          industry. As a result, in March and April 1998,
          EPA conducted site visits at eleven facilities
          which treat and/or recover non-hazardous oils
          wastes, oily wastewater, or used oil  material from
          off-site.  While the information collected at these
          facilities was  similar to information collected
          during previous site visits, these facilities were
          selected based on waste receipts.  The facilities
          represent a diverse mix of facility size, treatment
          processes,  and geographical  locations.  EPA
          collected wastewater samples of their  waste
          receipts and discharged effluent at 10 of these
          facilities.  These samples were one-time grabs
          and were analyzed for metals, classicals, and
          semi-volatile organic compounds.  The analytical
          results are located in Appendix B, but EPA has
          not incorporated the results  into the analysis
          presented today. EPA plans to  use this analytical
          data     to    supplement     its    wastewater
          characterization database prior to promulgation.
          PUBLIC COMMENTS TO THE 1995
          PROPOSAL AND THE 1996
          NOTICE OF DATA AVAILABILITY
2.4
              In addition to  data  obtained  through the
          Waste Treatment Industry Questionnaire, DMQ,
                                            2-11

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Chapter 2 Data Collection
Development Document for the CWT Point Source Category
site visits and sampling episodes, commenters on
the January 27, 1995 proposal  (55 FR 45161)
and  the September  16,  1996 Notice of Data
Availability (61 FR 48805) also provided data to
EPA.    In  fact, much  of EPA's  current
characterization of the oily waste treatment and
recovery subcategory is based on comments to
the 1996 Notice of Data Availability.
    As  described earlier, following the 1995
proposal, EPA revised its estimate of the number
of facilities in the  oils  subcategory  and its
description of the oils subcategory. Using new
information provided by the industry during the
1995 proposal comment period  in conjunction
with questionnaire responses and sampling data
used    to   develop  the   proposal,   EPA
recharacterized this subcategory of the industry.
This recharacterization reflected new data on the
wastes treated by the subcategory, the technology
in-place, and the pollutants discharged. As part
of  this recharacterization,  EPA  developed
individual profiles for each of the newly identified
oils  facilities  by modeling  current wastewater
treatment   performance  and treated  effluent
discharge flow rates. In addition, assuming the
same treatment technology options identified at
proposal, EPA recalculated the projected costs of
the  proposed options  under  consideration,
expected pollutant reductions associated with the
options, and  the projected economic impacts.
EPA presented its recharacterization of the oils
subcategory in the September 1996 Notice of
Data Availability (61 FR 48806).
    At  the time of the  1995 proposal,  EPA
estimated there were 35 facilities in the oily waste
treatment and recovery  subcategory. Through
comments received in response to  the proposed
rule,  and communication with the industry, the
National Oil  Recyclers Association, and EPA
Regional staff, EPA  identified an additional 240
facilities that  appeared to treat oily wastes from
off-site. While attempting  to confirm mailing
addresses for each facility, EPA discovered that
          20 of these facilities were either closed or could
          not be located. EPA then revised its profile of the
          oily waste treatment and recovery subcategory to
          include  220 newly-identified  facilities.   The
          information in the Notice of Data Availability
          was based on these 220 additional facilities.
              In lieu of sending questionnaires out to the
          newly-identified oils facilities to collect technical
          and economic information, EPA used data from
          secondary   sources   to   estimate   facility
          characteristics such as wastewater flow.  For
          most facilities, information about total facility
          revenue and employment were available from
          public sources (such as Dunn and Bradstreet).
          EPA then used statistical procedures to match the
          newly-identified facilities to similar facilities that
          had provided responses to  the 1991  Waste
          Treatment  Industry  Questionnaire.     This
          matching enabled EPA to estimate the flow of
          treated  wastewater from each  of  the newly
          identified  facilities.   Where EPA  had actual
          estimates  for facility characteristics from the
          facility or public sources, EPA used the actual
          values.   The estimated facility  characteristics
          included the following:

             RCRA status;
             Waste volumes;
             Recovered oil volume;
             Wastewater volumes treated and discharged;
             Wastewater discharge option;
             Wastewater characteristics;
             Treatment technologies utilized; and
             Economic information.

          EPA hoped to obtain information from each of
          the newly identified facilities through comments
          to the 1996 Notice of Data Availability.  In order
          to facilitate that effort, copies of the Notice and
          the individual facility profile were mailed to each
          of the 220 newly identified facilities.  Of these,
          EPA received comments and revised profiles
          from  100.  Therefore, 120  facilities did not
                                            2-12

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Chapter 2 Data Collection
Development Document for the CWT Point Source Category
provide comments to the Notice or revised facility
profiles.
    EPA determined the following about the list
of newly identified oils facilities:

   50 facilities were within the scope of the oily
    waste treatment and recovery subcategory;
   16 facilities were fuel blenders;
   31 facilities were out of scope of the oily
    waste treatment and recovery subcategory;
    and
 .  3 facilities were closed.
          total estimate of oils facilities to 164.
              For this reproposal, EPA has again revised
          its characterization of the subcategory based on
          information provided prior to the 1995 proposal,
          during the proposal comment period, and during
          the Notice comment period. EPA has used the
          revised   facility   profiles   and  the  earlier
          information  to  perform  the  technical  and
          economic  analyses  presented for  the  oils
          subcategory.  Unless noted otherwise, the final
          results of the analyses are scaled to represent the
          total population of oil facilities.
    EPA polled 9 of the 120 non-commenting
facilities and determined that approximately half
are within the scope of the industry. As a result,
EPA  estimates that half, or sixty, of the 120
non-commenting facilities are within the scope of
the   oily  waste  treatment   and   recovery
subcategory.  As to these sixty facilities that did
not comment, EPA does not necessarily  have
facility specific information for them.
    Finally, through  comments to the Notice,
EPA also obtained facility specific information
on  19 facilities that EPA  had not previously
identified as possible CWT oils  subcategory
facilities.
    Therefore, EPA's updated data base includes
facility-specific information for a total of 104
facilities that are within the scope of the oily
waste treatment and recovery subcategory.  This
total includes the 50 facilities for which EPA
prepared  facility information  sheets,  19  new
facilities identified through the Notice,  and 35
facilities from the questionnaire data base. The
number   of   in-scope   facilities   from   the
questionnaire data base has changed  from the
time of proposal due to other facility applicability
issues, as discussed in Section 3.1.  Finally, as
described above,  EPA estimates that the entire
population of oils subcategory facilities includes
an additional 60 facilities for which EPA does not
have facility specific information. This brings the
          ADDITIONAL DATA SOURCES
          Additional Databases
  2.5
2.5.1
              Several other data sources were used  in
          developing effluent guidelines for the centralized
          waste treatment industry.  EPA used the  data
          included in the report entitled Fate of Priority
          Pollutants in Publicly Owned Treatment Works
          (EPA   440/1-82/303,   September    1982),
          commonly referred to as the "50 POTW Study",
          in determining those pollutants that would  pass
          through a POTW.   EPA's  National  Risk
          Management Research Laboratory (NRMRL),
          formerly called the Risk Reduction Engineering
          Laboratory (RREL), treatability data base  was
          used to supplement the information provided by
          the 50 POTW Study. A description of references
          is presented in Section 7.6.2.
          Laboratory Study on the Effect
          of Total Dissolved Solids
          on Metals Precipitation
2.5.2
             During the comment period for the 1995
          proposal, EPA received comments which asserted
          that high levels of total dissolved solids (TDS) in
          CWT wastewaters may compromise a  CWT's
          ability to meet the proposed metal subcategory
          limitations.  The  data indicated that for some
          metal-contaminated wastewaters, as TDS levels
          increased,  the  solubility  of  the   metal  in
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wastewater  also  increased.    As  such,  the
commenters claimed  that metal-contaminated
wastewaters with high TDS could not be treated
to achieve the proposed limitations.
    At the time of the original proposal, EPA had
no  data on  TDS  levels in CWT  wastewaters.
None of the facilities provided TDS data in their
response  to the Waste  Treatment  Industry
Questionnaire   or  the  Detailed  Monitoring
Questionnaire. Additionally, during the sampling
episodes prior to the  1995 proposal, EPA did not
collect TDS data.  As such, EPA lacked the data
to estimate  TDS  levels in wastewaters  at the
CWT facility which  formed the technology basis
for  the  1995  proposed  metals  subcategory
limitations.
    In order to address the comment,  EPA (1)
collected additional information on TDS levels in
metals subcategory  wastewaters; (2) conducted
additional sampling;  (3)  consulted literature
sources; and (4) conducted bench scale studies.
    First, EPA needed to determine the range of
TDS levels  in  CWT   metals  subcategory
wastewaters. As such, EPA contacted the metals
subcategory    Waste   Treatment    Industry
Questionnaire respondents to determine the level
of  TDS  in their wastewaters.   Most CWT
facilities do not collect information on the level of
TDS in their wastewaters. Those  facilities that
provided information indicated that TDS levels in
CWT metals subcategory wastewaters range from
10,000 ppm to  100,000 ppm (1 - 10 percent).
    Second, EPA resampled the facility which
formed the  technology  basis  for the  1995
proposed metals subcategory limitations as well
as one other metals  subcategory facility, in part,
to determine TDS  levels in their wastewaters.
EPA found TDS levels  of 17,000 to 81,000
mg/L.
    Third, EPA  consulted  various  literature
sources to obtain information about the effect of
TDS levels on chemical precipitation.  EPA found
no data or information which related directly to
          TDS effects on chemical precipitation.
             Fourth, EPA conducted a laboratory study
          designed to determine the effect of TDS levels on
          chemical precipitation treatment performance. In
          this study, EPA conducted a series of bench-scale
          experiments on five metals: arsenic, chromium,
          copper, nickel and titanium.  These metals were
          selected because (1) they are commonly found in
          CWT metals subcategory wastewaters, (2) their
          optimal precipitation is carried out in a range of
          pH levels; and/or (3) the data provided in the
          comments indicated  that TDS  may  have a
          negative  effect on the precipitation of these
          metals. The preliminary statistical analyses of
          the data from these studies show  no consistent
          relationship among the five metals, pH levels,
          TDS concentrations and chemical precipitation
          effectiveness using hydroxide or a combination of
          hydroxide and sulfide. (DCN 23.32 describes the
          study and the  statistical analyses  in  further
          detail.)
             Therefore, because none of these four sources
          provided consistent and convincing evidence that
          TDS compromises a facility's ability to meet the
          proposed metal subcategory limitations, EPA has
          not incorporated the  TDS  levels  into  the
          development of limitations on metals discharges.
          PUBLIC PARTICIPATION
2.6
              EPA  has   strived  to  encourage   the
          participation of all interested parties throughout
          the development of the CWT guidelines  and
          standards.  EPA has met with various industry
          representatives  including  the  Environmental
          Technology  Council  (formerly the Hazardous
          Waste Treatment Council), the National Solid
          Waste Management Association (NSWMA), the
          National Oil Recyclers Association (NORA), and
          the Chemical Manufacturers Association (CMA).
          EPA has also participated in industry meetings as
          well as meetings with individual companies that
          may be affected by this regulation.  EPA also met
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with environmental groups including members of
the Natural Resources Defense Council. Finally,
EPA has made a concerted effort to consult with
EPA regional staff, pretreatment coordinators,
and other state and local entities that will be
responsible for implementing this regulation.
    EPA sponsored two  public meetings,  one
prior to the original proposal on March 8, 1994
and one prior to this re-proposal on July 27,
1997. The purpose of the public meetings was to
share information about the.content and status of
the proposed regulation.  The  public meetings
also gave interested parties an opportunity to
provide information and data on key issues.
    On March 24,  1995, following the original
proposal, EPA sponsored a workshop and public
hearing. The purpose of the workshop was to
provide  information  about  the   proposed
regulation and to present topics on which EPA
was soliciting comments.  The public hearing
gave interested parties the opportunity to present
oral comments on the proposed regulation.
    Finally, as detailed in the Economic Analysis
of Effluent  Limitations   Guidelines   and
Standards for the Centralized Waste Treatment
Industry (EPA 821-R-98-019) , onNovember 6,
1997,   EPA  convened  a  Small  Business
Regulatory Flexibility Act  (SBREFA) Review
Panel in preparing this reproposal.  The review
panel was composed of employees of the EPA
program office  developing this  proposal, the
Office of Information and  Regulatory Affairs
within the Office of Management and Budget and
the Chief Counsel for Advocacy of the Small
Business Administration (SBA). The panel met
over the course of two months and collected the
advice and recommendations  of representatives of
small entities that may be  affected by this re
proposed rule and reported their comments as
well as the Panel's findings  on the following:

   The type and number of small entities that
    would be subject to the  proposal.
             Record  keeping,   reporting  and  other
             compliance requirements that the proposal
             would impose on small entities subject to the
             proposal, if promulgated.
             Identification of relevant Federal rules that
             may overlap  or conflict with the proposed
             rule.
             Description   of   significant   regulatory
             alternatives  to  the proposed  rule which
             accomplish the stated objectives of the CWA
             and minimize any significant economic.

             The  small entity  CWT  population  was
          represented by members of the National Oil
          Recyclers    Association    (NORA),    the
          Environmental Technology Council, and a law
          firm   representing a  coalition of CWTs in
          Michigan. EPA provided each of the small entity
          representatives  and  panel  members  many
          materials related to the development  of this
          reproposal.    As  such,   the  small  entity
          representatives had the opportunity to comment
          on many aspects of this reproposal in addition to
          those specified above.   All of the small entity
          comments and the panel findings are detailed in
          the "Final Report of the SBREFA Small Business
          Advocacy Review  Panel on EPA's  Planned
          Proposed  Rule   for   Effluent  Limitations
          Guidelines  and  Standards  for  the  Waste
          Treatment Industry" which is located in the
          regulatory record  accompanying this rule.
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                                                                               Chapter
                                                                                      3
  SCOPE/APPLICABILITY OF THE PROPOSED REGULATION
      Over half of the comments received on the
      original proposal and the notice of data
availability related to the applicability of this rule.
EPA  has reviewed  these comments and  is
proposing a revised scope for this rule. The vast
majority of these  issues  are  discussed in the
following chapter.
APPLICABILITY
3.1
    The universe of facilities which would be
potentially subject to this guideline include the
following. First, EPA is proposing to establish
limitations and pretreatment standards for stand-
alone waste  treatment and recovery facilities
receiving  materials  from  off-site    classic
"centralized waste treaters." These facilities may
treat and/or recover or recycle hazardous or non-
hazardous waste, hazardous or non-hazardous
wastewater,  and/or used material from off-site.
Second, industrial facilities which process their
own, on-site generated, process wastewater with
hazardous or non-hazardous wastes, wastewaters,.
and/or used material received from off-site, in
certain circumstances may be  subject to  this
proposal  with  respect to a  portion  of their
discharge.
    The   wastewater flows  which  EPA is
proposing to regulate include some or all off-site
waste receipts and on-site wastewater generated
as  a result of  centralized  waste treatment
operations.   The kinds of on-site wastewater
generated at these facilities would  include, for
example,  solubilization wastewater,  emulsion
breaking/gravity separation wastewater, used oil
processing  wastewater,  treatment  equipment
washes, transport washes (tanker truck, drum,
and   roll-off   boxes),   laboratory-derived
       wastewater, air pollution  control wastewater,
       industrial waste combustor wastewater from on-
       site  industrial  waste  combustors,  landfill
       wastewater   from   on-site   landfills,   and
       contaminated stormwater.  A detailed discussion
       of CWT wastewaters is provided in Chapter 4.
FacUities Subject to 40 CFR
(Parts 400 to 471)
                                                                                    3.1.1
           At the time of the original proposal, EPA
       defined a centralized waste treatment facility as
       any facility which received waste from off-site for
       treatment or recovery on a commercial or non-
       commercial basis.   Non-commercial facilities
       were  defined as facilities that accept off-site
       wastes from facilities under the same ownership.
       EPA  received many comments concerning the
       applicability of the CWT rule to facilities that
       perform waste treatment and/or recovery of off-
       site  generated  wastes,  but  whose  primary
       business is something other than waste treatment
       or  recovery.    These  facilities  are generally
       manufacturers who treat wastes generated as a
       result of thek on-site manufacturing operations
       and whose wastewater discharges are already
       subject to existing effluent guidelines and
       standards.  Many of these facilities also accept
       off-site generated wastes for treatment.  In some
       instances, these off-site wastes received at these
       industrial facilities are generated by a facility
       under  the  same  corporate  ownership   
       intracompany transfer  and treated on a non-
       commercial basis. In other instances, the off-site
       waste streams originate from a company under a
       different ownership, an intercompany transfer.
           In general, commenters urged that the scope
       of the guideline should be limited to facilities
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whose sole purpose is the treatment of off-site
wastes and wastewater.  Reasons provided by
commenters  for  limiting  the  scope of the
guideline in this manner include:

   The   wastes  transferred  from  different
    locations within a company (and different
    companies) for treatment with on-site wastes
    are  usually   generated  from  the  same
    categorical process as the on-site generated
    wastes.   Since most of these facilities are
    already  covered  by an existing  effluent
    guideline, coverage of these wastestreams is
    redundant  Monitoring, record keeping, etc.
    would be duplicative.
   This proposed rale will prevent effective
    waste  management  practices  at  many
    manufacturing facilities.   Currently,  many
    companies operate a single, central treatment
    plant and transport waste from "satellite"
    facilities  to the  central treatment facility.
    This allows for effective treatment  while
    controlling   costs.  Additionally,   many
    facilities  transfer a specific wastestream to
    other company  owned  treatment  systems
    (intracompany) that are designed for the most
    efficient   treatment   of  that  type   of
    wastestream.
   Many of these types of facilities only accept
    wastestreams  which are  comparable  and
    compatible with the on-site generated process
    wastestreams.
   These facilities  are  not primarily in the
    business  of waste treatment.  Only a small
    percentage  of wastes treated are from  off-
    site.
   EPA  has  not  performed  the technical
    analyses  that are  necessary  to  support
    application  of     the   CWT  rule   to
    manufacturing facilities regulated by existing
    effluent   guidelines   and    pretreatment
    standards.
           EPA reexamined the database of facilities
       which form the basis of the CWT rule. EPA's
       database   contains    information    on   17
       manufacturing facilities which commingle waste
       generated by on-site manufacturing activities for
       treatment with waste generated off-site and one
       manufacturing facility which does not commingle
       waste  generated  by  on-site  manufacturing
       activities for treatment with waste generate off-
       site.  Nine of these facilities treat waste on a non-
       commercial basis only and nine treat waste on a
       commercial basis. Of the eighteen facilities, eight
       facilities only accept and treat  off-site wastes
       which are from the same categorical process as
       the on-site generated wastestreams.  Ten of the
       facilities, however, accept off-site wastes which
       are not subject to the same categorical standards
       as  the  on-site  generated  wastewater.    The
       percentage   of  off-site   wastewaters  being
       commingled  for   treatment  with   on-site
       wastewater varies from 0.06% to 80% with the
       total volumes varying between 87,000 gallons per
       year to 381 million gallons per year.
           The guidelines, as proposed in 1995, would
       have included both types of facilities within the
       scope of this rule. EPA included these facilities
       in the 1995 proposed CWT rule to ensure that all
       wastes receive adequate treatment  even those
       shipped between facilities  already  subject to
       existing  effluent  limitations  guidelines  and
       standards (ELGs).  EPA agrees that, for off-site
       wastes   which  are generated  by  the  same
       categorical process as on-site generated wastes,
       intracompany and intercompany transfers are a
       viable  and often  preferable  method to treat
       wastestreams efficiently at a reduced cost.  EPA
       does not want to discourage these management
       practices. EPA is still concerned, however, that
       the effluent limitations and categorical standards
       currently in place  may  not  ensure  adequate
       treatment in circumstances where the off-site
       generated wastes  are  not  from  the  same
       categorical group as the on-site  generated wastes.
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It is not duplicative to include within the scope of
the CWT guideline, wastewater that results from
the treatment of off-site wastes not subject to the
guidelines  and  standards  applicable  to the
treatment  of  wastewater  generated  on-site.
Additionally, even though the primary business at
these facilities is not the treatment of off-site
wastes, EPA does not believe that the burden to
these facilities exceeds that of the facilities whose
primary  business is the treatment  of off-site
wastes. EPA has included these facilities in all of
its economic analyses.
    Therefore, based on the Agency's evaluation
of the comments submitted on its earlier proposal
and consideration of additional information, EPA
proposes to include within the scope of the CWT
rule wastewater received  from  off-site  (and
commingled  for   treatment   with  on-site
wastewater) at  facilities  subject to effluent
limitations   guidelines  for   existing  source,
standards of performance for new sources and
pretreatment standards for  new and existing
sources unless all of the following conditions are
met:

   The receiving facility is  subject  to national
    effluent limitations guidelines for existing
    sources, standards of performance for new
    sources, or pretreatment standards for new
    and existing sources; and
   The   wastes received  from .off-site  for
    treatment would be subject to  the  same
    national; effluent limitations  guidelines  for
    existing sources, standards of performance
    for new sources, or pretreatment standards
    for new and existing sources as the on-site
    generated wastes.

For   purposes   of  developing  its   effluent
limitations and pretreatment standards, EPA has
included manufacturing facilities which accept
off-site waste for treatment in all of its analyses
unless the above mentioned conditions were met.
           EPA contemplates that this approach would
       be implemented in the  following manner.  A
       facility  that is currently subject to  an ELG
       receives wastewater from off-site for treatment.
       The wastewater is commingled for treatment with
       wastewater generated on-site.  If the off-site
       wastewater is subject to the same ELG as the
       onsite wastewater (or would be if treated where
       generated), the CWT limitations would not apply
       to the discharge associated  with the off-site
       wastewater flows. In that case, another guideline
       or standard applies. If, however, the off-site
       wastewater is not subject to the same ELG (or if
       none exist) or if the off-site wastewater is not
       commingled  .with  on-site  wastewater   for
       treatment, that portion of the discharge associated
       with off-site flow would be subject  to CWT
       requirements.  The portion of the commingled or
       non-commingled wastewater associated with on-
       site generated wastewater  remains subject to
       applicable limitations  and  standards  for the
       facility.  Alternatively, EPA  is considering an
       option that requires manufacturing facilities that
       treat  off-site  wastes  to meet  all  otherwise
       applicable categorical limitations and standards.
       This approach would determine limitations and
       standards for the off-site wastewater using the
       "combined waste stream formula" or "building
       block  approach"  (see  Chapter  14).    EPA
       envisions  the  second  alternative  would  be
       preferable for  facilities which only receive
       continuous flows of process  wastewaters  with
       relatively consistent pollutant profiles from no
       more than five customers.  The decision to base
       limitations in this manner would be at the permit
       writers discretion only.
           In addition, there are manufacturing facilities
       that may not currently be subject to any effluent
       limitations guidelines or pretreatment standards.
       Some of these may accept off-site  wastewater
       that is commingled for treatment with on-site
       process wastewater. Under EPA regulations, the
       permit writer would develop Best Professional
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Judgement  (BPJ)  local  limits  for  indirect
dischargers for the on-site generated wastewater
flows.  The portion of the discharge resulting
from the treatment of off-site flows would be
subject either to CWT limitations and standards
or to the same BPJ requirements as on-site flows.
CWT limitations would apply if the  off-site
wastes treated at the facility were different from
those generated on-site, whether or not the wastes
were subject to existing guidelines and standards
(or would  be,  if treated  at the site  where
generated).   Alternatively, applying either a
building block or combined wastestream formula
approach, on-site wastewater would be subject to
BPJ  limits  or  standards  and  the   off-site
categorical wastewater  subject to categorical
limits for the industry generating the wastewater.
Pipeline Transfers
(Fixed Delivery Systems)
3.1.2
    As  previously noted, the scope of EPA's
1995 proposal did not extend to facilities  which
received off-site wastes for treatment solely via
an  open or enclosed  conduit (for example,
pipeline, channels, ditches, trenches, etc.).  At
that time, EPA had concluded that facilities which
receive  all their wastes through a pipeline or
trench (fixed delivery systems) from the original
source  of  waste   generation  are  receiving
continuous flows of process wastewater with
relatively consistent pollutant profiles.  As such,
EPA  concluded  that  these  wastes  differ
fundamentally from those received at centralized
waste treatment facilities it had studied as part of
this rulemaking.
    The Agency received many comments on the '
proposal to limit the applicability of the proposed
limits to wastewaters received other than by
pipelines or fixed  delivery systems.   Many
commented that this approach is arbitrary and
that the mode of transportation should not be the
determining factor as to whether or not a facility
is included in the scope of the rule. Commenters
asserted that the character of the waste remains
unchanged regardless of whether it is trucked or
piped to another facility for treatment. Many also
questioned EPA's conclusion that piped waste is
more consistent in strength and treatability from
typical  CWT  wastewaters  studied  for this
proposal.
    EPA  has reevaluated the  database for this
rule. EPA received questionnaire responses from
four centralized waste treatment facilities which
receive  their wastestreams solely via pipeline.
EPA also examined  the database that was
developed for the organic chemicals, plastics, and
synthetic  fibers  (OCPSF)  ELG  to   gather
additional data on OCPSF facilities which also
have centralized  waste  treatment  operations.
Based on the  OCPSF  database,  16 additional
facilities are treating wastewater received solely
via pipeline from off-site for treatment. A review
of the CWT and OCPSF databases supplemented
by telephone calls to selected facilities reveals
that one facility no longer accepts wastes from
off-site, one facility is now operating as a POTW,
and  11 facilities only accept off-site wastes that
were generated by  a facility  within the  same
category as on-site generated waste. (The latter
facilities,  under the criteria explained above,
would no longer be within the  scope of the
proposed rule because they are already subject to
existing effluent guidelines  and  standards.)
Therefore, EPA  identified.  7 facilities  which
receive off-site wastes solely via pipeline which
may be subject to this rulemaking.
    Of these seven facilities, one is a dedicated
treatment  facility which is  not  located at a
manufacturing  site.   The  other six  pipeline
facilities are located at manufacturing facilities
which are already covered by  an existing ELG.
All of the facilities are direct dischargers and all
receive waste receipts  from no more than five
customers (many receive waste receipts from
three or fewer customers).
    Since the 1995 proposal, EPA conducted site
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visits  at  two  of  these  pipeline  facilities.
Information collected during these site visits
confirmed EPA's original conclusion that wastes
received by  pipeline  are  more  consistent in
strength and treatability than "typical"  CWT
wastewaters. These wastewaters are traditional
wastewaters  from  the  applicable  industrial
category that generally remain relatively constant
from day to day in terms of the concentration and
type of pollutant parameters.  Unlike traditional
CWTs, their customers and wastewater sources
do not change and are limited by the physical and
monetary constraints associated with pipelines.
    EPA has also reviewed the discharge permits
for each of these pipeline facilities. EPA found
that,  in all cases,  permit writers  had carefully
applied  the   "building  block  approach"  in
establishing the facility's discharge limitations.
Therefore, in all cases, the treating facility was
required to treat each of the piped wastewaters to
comply  with  otherwise  applicable  effluent
guidelines and  standards.
    Consequently, based on  the information it
has obtained to date, EPA  continues to believe
that (except as discussed below) wastes that are
piped to waste treatment  facilities should be
excluded from the scope of the CWT rule and
covered  by  otherwise   applicable  effluent
guidelines  and  standards.    The  Agency has
concluded   that   effluent  limitations   and
pretreatment standards  for  centralized  waste
treatment facilities should not apply to pipeline
treatment facilities.  EPA believes that it is more
appropriate  for   permit  writers   to develop
limitations for treatment facilities  that receive
wastewater by pipeline on an  individual basis by
applying the "combined waste  stream formula" or
"building block" approach. The one exception to
this approach is for facilities which receive waste
via conduit (that is, pipeline, trenches, ditches,
etc.)  from facilities that are acting merely as
waste collection or consolidation centers that are
not the original source of the waste.   These
       wastewaters would be subject to CWT.  EPA has
       not  identified  any  pipeline  facility  that is
       receiving waste from waste consolidators, but has
       received public  comment that these  facilities
       exist.
           EPA notes that 40 CFR 122.44(m) of the
       Agency's NPDES permitting regulations require
       that an  NPDES  permit for a  private treatment
       works   must  include  conditions  expressly
       applicable to any user, as a limited co-permittee,
       necessary to ensure compliance with applicable
       NPDES requirements. In the  case of a pipeline
       treatment system, this may require that the permit
       writer include conditions in a permit issued to the
       pipeline treatment system and its users, as co-
       permittee, if necessary for the pipeline facility to
       comply   with   the   applicable    limitations.
       Alternatively, EPA may need to  issue permits
       both to  the private treatment  works and to the
       users or require  the user to file a  permit
       application.
       Product Stewardship
3.1.3
           Many  members   of the  manufacturing
       community have adopted "product stewardship"
       programs as an  additional  service for their
       customers to promote recycling and reuse of
       products and to reduce the potential for adverse
       environmental impacts from chemical products.
       Many commenters on the proposal have defined
       "product stewardship" in this way: "taking back
       spent, used, or unused products,  shipping  and
       storage  containers with product residues,  off-
       specification products  and waste materials from
       use of products." Generally, whenever possible,
       these manufacturing plants recover and reuse
       materials in  chemical  processes  at  their
       operations.    Manufacturing companies  that
       cannot reuse the spent, used, or unused materials
       returned to  them treat these  materials in their
       wastewater treatment plant. In industry's view,
       such materials are inherently compatible with the
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treatment system.  EPA received  no specific
information  on  these  product  stewardship
activities  in  the  responses to  the  308 Waste
Treatment Industry Questionnaire. EPA obtained
information  on this  program  from  comment
responses to the 1995  CWT proposal and in
discussions  with  industry  since  the   1995
proposal.  As part of their comment to the 1995
proposal,    the   Chemical   Manufacturer's
Association (CMA) provided results of a survey
of  their  members  on product  stewardship
activities. Based on these survey results, which
are shown in Table 3.1 and Table 3-2, the vast
       majority of materials received under the product
       stewardship programs are materials received for
       product rework. A small amount is classified as
       residual recycling and an even smaller amount is
       classified as drum take backs.  Of the materials
       received, the vast  majority  is reused  in  the
       manufacturing process. With few exceptions, all
       of the materials (which are not reused in the
       manufacturing process) that are treated in the on-
       site wastewater treatment systems, appear to be
       from the same categorical group as the on-site
       manufactured materials.
    Table 3-1 Summary of the Frequency of the Types of Activities and Dispositions Reported

Activity



Disposition


Item
Drum Returns
Residual Recycling
Product Rework
Other
Rework/Reuse
On-site Wastewater Treatment
Off-site Disposal
Number
3
7
50
2
53
22
29
% of Total J
5%
12%
86%
3%
91%
38%
50%
    JBased on information submitted by 33 CMA member facilities. Of these 33 members, 13 reported
    information concerning more than one product type, or activity. Therefore, the percentage of the total is
    based on 58 separate entries on the survey.
    Table 3-2 Summary of Frequency of Each Product Class Reported by Facilities
Product Class
Polymers, Plastics, and Resins
Organic Chemicals
Solvents and Petroleum Products
Inorganic Chemicals
Pesticides
Unspecified
Number of Facilities
17
6
3
4
2
4
Percent of Total'
52%
18%
9%
12%
6%
12%
JBased on Responses from 33 CMA facilities.
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    EPA has decided that wastewater generated
from materials which are taken back for recycling
or reuse should be subject to the CWT regulation
(except as discussed elsewhere).  EPA applauds
the efforts of manufacturing facilities to reduce
pollution and the environmental impacts of their
products and does not want to discourage these
practices. In most of the instances stated in the
product stewardship definition,  manufacturing
facilities are essentially taking back product
which has not been utilized or has not been
chemically altered.  In these  cases where the
treatment of these wastes would be subject to
current guidelines or pretreatment  standards,
under the approach discussed  in Section 3.1.1,
these wastewater flows would not be subject to
CWT requirements.
    EPA remains concerned, however, that there
are circumstances in which used  materials or
waste products may not be compatible with the
otherwise existing treatment system. Therefore,
EPA is not  proposing to  remove all product
stewardship  activities  from the scope  of this
rulemaking.  Those activities that involve used
products or waste materials that are not subject to
effluent guidelines or standards  from the same
category as  the on-site generated wastes  are
subject to today's proposal.    Based  on  the
information provided by manufacturing facilities,
EPA believes that very few product stewardship
activities would be subject to this rule.  EPA's
approach will not curtail product stewardship
activities, in general,  but  will ensure that all
wastes are treated effectively.
       Solids, Soils, and Sludges
3.1.4
          EPA did not distinguish in its information
       gathering efforts between those waste treatment
       and recovery facilities treating aqueous waste and
       those  treating  non-aqueous  wastes  or  a
       combination of both.  Thus, EPA's 308 Waste
       Treatment Industry  Questionnaire and related
       CWT Detailed Monitoring Questionnaire (DMQ)
       asked  for  information  on  CWT  operations
       without regard to the type of waste  treated.
       EPA's sampling program also included  facilities
       which accepted both aqueous and solid wastes for
       treatment. In fact, the facility which formed the
       technology basis  for the  metals subcategory
       limitations  selected  at the  time of the original
       proposal treats both liquid and solid wastes.  As
       such, a facility that accepts wastes from off-site
       for  treatment  and/or  recovery  and which
       generates a wastewater is subject to the CWT rule
       regardless of whether the wastes are aqueous or
       non-aqueous. Therefore, wastewater generated in
       the treatment  of solids  received from off-site
       would be subject to the CWT rule.
          As a further point of clarification,  the main
       concern in the treatment or recycling of off-site
       "solid wastes" is that pollutants contained in the
       solid waste may be  transferred to a process or
       contact water resulting in a wastewater  that may
       require treatment. Examples of such wastewaters
       are:

          entrained water  directly removed through
           dewatering operations (for example, sludge
           dewatering);
          contact  water  added  to  wash  or  leach
           contaminants from the waste material;
          stormwater that comes in direct contact with
           waste material; and
          solvent contaminated wastewater  removed
           from scrap metal recycling.

       The treatment or recovery of solids that remain in
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solid form when contacted with water and which
do not leach any chemicals into the water are
necessarily not subject to this rule. Examples of
excluded  solids recovery  operations  are  the
recycling  of aluminum cans, glass  and plastic
bottles.
Sanitary Wastes
3.1.5
    The CWT proposal would regulate facilities
which treat, or recover materials from, off-site
industrial wastes and wastewaters.  Sanitary
wastes such as chemical toilet wastes and septage
are not covered by the provisions of the proposed
CWT  rule.  EPA  would  expect that,  permit
writers  would  develop   Best Professional
Judgment limitations or local limits  to establish
site-specific   permit requirements  for   any
commercial sanitary waste treatment facility.
    Similarly, sanitary wastes received from off-
site  and treated at an industrial facility  or a
centralized  waste  treatment  facility are  not
covered by provisions of the CWT rule. If these
wastes are mixed with industrial wastes, EPA
would expect  that,  as is  the  case now  with
ancillary  sanitary   waste   flows  mixed  for
treatment at categorical facilities,  the  permit
writer  would  establish   Best Professional
Judgment, site-specific permit requirements.
Transporters and/or Transportation
Equipment Cleaners
3.1.6
    As proposed, the transportation equipment
cleaning  (TEC) regulation only  applies to
facilities that solely accept tanks which have been
previously  emptied or  that contain  a small
amount of product, called a "heel", typically
accounting  for less than one  percent of the
volume of the tank. A facility which accepts a
tank truck, rail tank car, or barge not considered
to be empty for cleaning or treatment is not
subject to the TEC Point Source Category, and
may be subject to the provisions established for
this rule.
    There are some facilities which are engaged
in traditional CWT activities and also engaged in
traditional TEC activities.  If the wastewaters
from the two operations are commingled, under
the approach adopted for the TEC proposal, the
commingled TEC  wastewater flow  would be
subject to  CWT  limits  when  promulgated.
Therefore, a facility performing  transportation
equipment cleaning as well as other centralized
waste treatment services that commingles these
wastes is a centralized waste treatment facility.
All of the wastewater discharges are subject to
provisions of this rule.  If, however, a facility is
performing both operations and the wastestreams
are not  commingled  (that  is,  transportation
equipment cleaning wastewater is treated in one
system and CWT wastes are treated in a second,
separate system), both the TEC rule and CWT
rules apply to the respective wastewaters.
    As a further point of clarification, the CWT
proposal would subject transportation equipment
cleaning wastes received from  off-site to  its
provisions.  Transportation equipment cleaning
wastes received from off-site that are treated at
CWTs  along with  other off-site wastes  are
subject to provisions of this rule.
         Publicly Owned Treatment
         Works (POTWs)
                                                                                        3.1.7
    The   reproposed   CWT   pretreatment
regulations would not themselves establish any
requirements  that apply directly to local POTWs
that receive  off-site  wastes    In the case of
categorical  wastes  (subject  to pretreatment
standards in  40  CFR  parts 400 to  471), the
generator of the wastes must comply with any
applicable standards before introducing the waste
to  the  POTW   regardless  of whether the
wastewater is discharged directly to the sewer or
otherwise hauled to the POTW.  Similarly, for
non-categorical wastes, the generator would need
to meet any applicable local limits regardless of
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the mode of transportation to the POTW.  As
such, therefore, the proposed centralized waste
treatment rule does not apply to POTWs.
    EPA is aware of a POTW which plans to
open a wastewater treatment system to operate in
conjunction with their POTW operations.  This
CWT facility at a POTW will accept categorical
wastewaters, treat them, and then discharge them
to the POTW,  As such, the CWT operation may
be subject to provisions of this rule. It is not a
POTW itself (even if the facility is located at the
same site). In this case, the facility is operating
as a centralized waste treatment facility and all
discharges are subject to provisions of this rule.

Silver Recovery Operations from Used
Photographic and X-Ray Materials     3.1.8

    The proposal  does  not include  electrolytic
plating/  metallic  replacement silver recovery
operations  of used  photographic  and x-ray
materials within the scope of this rule. Based on
the fundamental difference in technology used to
recover silver at facilities devoted exclusively to
treatment of photographic and x-ray wastes, the
Agency  has   decided   to  defer  proposing
regulations for these facilities. The precipitation
processes to recover silver used as the basis for
its metal limits (including silver) is different from
that most widely used  to  recover silver at
facilities that treat only silver bearing wastes 
electrolytic  plating   followed  by  metallic
replacement.   Facilities  which  only  perform
centralized waste treatment silver recovery
operations .(electrolytic  plating  followed  by
metallic replacement) would not fall within the
scope of today's proposal. Permit writers would
use Best Professional Judgement or local limits to
establish   site-specific   permit  requirements.
However,    off-site    wastes    which    are
treated/recovered  at these facilities through  any
other process and/or waste  generated at  these
facilities   as  a  result  of  any  other CWT
treatment/recovery  process  are   subject  to
       provisions of this rule.
           Many  commenters  to the  1995  CWT
       proposal expressed concern over the inclusion in
       the metals subcategory of CWT operations that
       recover metals from used photographic materials
       and solutions and x-ray materials and solutions.
       Commenters were particularly concerned mat
       they would be unable to meet the limitations
       established for silver in the metals subcategory.
       In general,  commenters stated that the scope of
       the proposed  rule  should not  include these
       operations.  Reasons provided include:

           The metals subcategory limitations proposed
           for  the  CWT  rule are  not  based  on
           technologies typically used in silver recovery
           operations.    Silver  recovery  facilities
           typically use electrolytic plating followed by
           metallic replacement with iron.
           The facility used to calculate the BAT silver
           limitation is engaged in a variety of recovery
           operations. This BAT treatment system .does
           not reflect performance of facilities which
           solely treat silver-bearing wastes.
           Existing   effluent  guidelines   should  be
           sufficient.  Many facility discharge permits
           are based on Part 421, effluent guidelines for
           non-ferrous metals manufacturing, Subpart L
           secondary silver subcategory.  In addition, an
           effluent guideline also exists for the industry
           which is the primary source of the recovered
           materials   Part 459 photographic point
           source  subcategory.
           The Silver Coalition and the Association of
           Metropolitan Sewerage Agencies (AMSA)
           have prepared and issued recommendations
           on technology, equipment and management
           practices  for controlling  discharges  from
           facilities that process photographic materials.
           It is  not economical or efficient for these
           waste streams to be recovered on-site due to
           their small volume. If this rule were enacted,
           many  of the  CWTs  processing  used
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    photographic materials  would discontinue
    this operation and silver recovery operations
    would decrease greatly.

    Based on information provided  by  the
industry, EPA estimates that there are 360,000
photographic  and image processing  facilities
which generate silver bearing wastes.  Many of
these facilities generate very small volumes of
silver bearing waste which  would  not  be
economical or efficient to recover on site.  Thus,
there exists a large potential for facilities to
consolidate and treat silver bearing photographic
waste from various sources.
    EPA  believes that the off-site shipment of
silver bearing photographic wastestreams for the
purpose  of  consolidation  and recovery is
beneficial and does not wish to discourage this
practice.  EPA encourages  the  segregation of
wastestreams  as  this leads to  more efficient
recovery.   EPA  is aware that  some of these
consolidated wastestreams are treated at typical
CWTs and some are treated at facilities which
treat photographic wastestreams only.  While
EPA has promulgated effluent guidelines for non-
ferrous    metals   manufacturing  and   the
photographic point source categories  (40 CFR
421, Subpart L and 40 CFR 459, respectively),
the majority of these centralized silver recovery
facilities are not currently subject to any effluent
guideline.
    EPA agrees with proposal commenters that
the  BAT system selected  at the time of the
original proposal does not reflect performance of
facilities which solely treat silver-bearing wastes.
Although  the   facility  which formed  the
technology basis for the 1995 proposed BAT
limitations was engaged in recovering silver from
photographic wastestreams,  EPA does not have
information in its database  on facilities  which
perform  centralized   waste   treatment  of
photographic wastestreams only.
       High Temperature Metals Recovery     3.1.9

          During  the  development  of  the   1995
       proposal, EPA did not include facilities  which
       perform  high  temperature metals  recovery
       (HTMR) within the scope of this rule. EPA is
       aware of three facilities in the U.S. which utilize
       the HTMR process.  High  temperature metals
       recovery facilities generally take solid forms of
       various metal containing materials and produce a
       remelt alloy which is then sold as feed materials
       in the production of metals.  These facilities
       utilize heat-based pyrometallurgical technologies,
       not  the  water-based  precipitation/filtration
       technologies used throughout the CWT industry.
       Based on questionnaire responses and industry
       comments, the HTMR process does not generate
       wastewater.
          For these reasons,  the high temperature
       metals recovery operations have been excluded
       from provisions of the CWT rule. Facilities which
       only perform high temperature metals recovery
       are not  subject to this rule. However,  off-site
       wastes   which are  treated/recovered at  these
       facilities through any  other process and/or wastes
       generated at these facilities as a result of any
       other CWT  treatment/ recovery process  are
       subject to the provisions of this rule.
          As  noted, EPA's data show that HTMR
       operations  generate no  process wastewater.
       Accordingly, EPA is also considering whether
       this  rule, when promulgated, should include a
       subcategory for HTMR operations with a zero
       discharge requirement.
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 Landfill Wastewaters
3.1.10
     EPA  proposed  effluent  guidelines  and
 pretreatment standards for Landfills, 40 CFR Part
 445, on February 6,  1998 (63  FR 6426-6463).
 There, EPA explains how it proposed to treat
 categorical facilities that mix and treat categorical
 wastewater  with  wastewater  from  on-site
 landfills.  EPA proposed to subject the mixed
 wastewater to the applicable categorical limits
 and not the proposed landfill limits.  In the CWT
 industry, there are  some facilities which  are
 engaged both hi CWT activities and in operating
 an  on-site landfill(s).  EPA is  proposing to
 evaluate the mixture of CWT wastewater and
 landfill wastewater in the same way considered
 for the proposed landfill guidelines.  Therefore, a
 facility performing landfill activities as well as
 other centralized waste treatment services that
 commingles  the  wastewaters  would  be  a
 centralized waste treatment facility and all of the
 wastewater discharges  would be subject to the
 provisions of this rule when promulgated.  If a
 facility  is performing both operations and the
 wastestreams are not commingled (that is, landfill
 wastewaters are treated in one treatment system
 and CWT -wastewaters are treated in a second,
 separate, treatment system), the provisions of the
. Landfill rule and CWT rule would apply to their
 respective wastewaters.
     Additionally, under the approach proposed
 for the Landfills rulemaking, centralized waste
 treatment facilities which are dedicated to landfill
 wastewaters only, whether they are located at a
 landfill  "site or not,  would  be subject to  the
 effluent guidelines limitations and pretreatment
 standards for landfills when promulgated. These
 dedicated  landfill centralized  waste  treatment
 facilities would not be subject to provisions of the
 centralized waste treatment rulemaking.
     As  a further point of clarification, landfill
 wastewaters are not specifically excluded from
 provisions of this rule. Landfill wastewaters that
are treated at CWTs along with other off-site
wastestreams are subject to provisions of this
rule. Furthermore, a landfill that treats its own
landfill   wastewater   .and   off-site   landfill
wastewater would be subject to the proposed
Landfill  limits  when   promulgated  in  the
circumstance described in 3.1.1 above.
         Industrial Waste Combustors
                                      3.1.11
                EPA proposed  effluent guidelines  and
         pretreatment  standards  for  Industrial Waste
         Combustors, 40 CFR Part 444 on February 6,
         1998 (63 FR 6392-6423). There, EPA explains
         how it proposed to treat categorical facilities that
         mix  and  treat categorical  wastewater  with
         wastewater  from  on-site  industrial   waste
         combustion. EPA proposed to subject the mixed
         wastewater to the  applicable categorical limits
         and not the proposed industrial waste combustors
         limits.  In the CWT industry, there  are some
         facilities  which are  engaged both  in CWT
         activities  and in industrial waste  combustion.
         EPA is proposing to  evaluate the mixture of
         CWT  wastewater   and   industrial   waste
         combustion  wastewater  in  the  same   way
         considered for the proposed industrial waste
         combustors guidelines.  Therefore,  a  facility
         performing industrial waste combustion activities
         as  well  as other  centralized waste  treatment
         services that commingles the wastewaters would
         be a centralized waste treatment facility and all of
         the wastewater discharges would be subject to the
         provisions of this rule  when promulgated.  If a
         facility is  performing  both operations and the
         wastestreams  are  not commingled  (that is,
         industrial  waste  combustion wastewaters are
         treated in one treatment system  and CWT
         wastewaters are treated in a second, separate,
         treatment system), the provisions of the Industrial
         Waste Combustor rule and  CWT rule would
         apply to their respective wastewaters
              As a further point of clarification, industrial
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waste combustor wastewaters are not specifically
excluded from provisions of this rule. Industrial
waste combustor wastewaters that are treated at
CWTs along with other off-site wastestreams are
subject to provisions of this rule.  Furthermore,
an industrial waste combustor that treats off-site
industrial waste combustor wastewater would be
subject to  the  proposed, Industrial  Waste
Combustor  limits when promulgated  in  the
circumstances described in 3.1.1 above.

Solvent Recycling/Fuel Blending      3.1.12

    The solvent recycling industry was studied by
the EPA  in  the  1980s.  EPA published the
"Preliminary  Data Summary for the  Solvent
Recycling Industry"  (EPA 440/1-89/102)  in
September 1989 which describes this industry
and the processes  utilized.   This  document
defines solvent recovery as  "the recycling of
spent solvents that are not the byproduct or waste
product of a manufacturing process  or cleaning
operation  located on the  same  site."  Spent
solvents are generally  recycled  in two main
operations. Traditional solvent recovery involves
pretreatment of the wastestream (in some cases)
and separation of  the  solvent mixtures by
specially  constructed  distillation  columns.
Wastewater  discharges  resulting  from  this
process  are subject  to  effluent  limitations
guidelines and  standards  for  the  organic
chemicals industry (40 CFR 414).  As such,
wastewaters resulting from traditional solvent
recovery  operations  as defined above are not
subject to this effluent guideline.
    Fuel blending is the second main operation
which falls  under  the  definition  of solvent
recovery.  Fuel blending is the process of mixing
wastes for the purpose of regenerating a fuel for
reuse.  At the  time  of the 1995 proposal, fuel
blending operations were excluded from the CWT
rule since EPA believed the fuel blending process
was  "dry"  (that is,  no  wastewaters  were
       produced).  Based on comments to the original
       proposal  and the Notice of Data Availability,
       EPA has concluded that this is valid and that true
       fuel  blenders do  not generate  any process
       wastewaters and are therefore zero dischargers.
       EPA is concerned, however, that the term "fuel
       blending" may be loosely applied to any process
       where recovered hydrocarbons are combined as a
       fuel product. Such operations occur at nearly all
       used oil and fuel recovery facilities.  Therefore,
       fuel blending operations as defined above would
       be excluded from the CWT rule providing that
       the operations do not generate a wastewater.  In
       the event that wastewater is generated at a fuel
       blending  facility, the  facility is most likely
       performing   some  pretreatment   operations
       (usually to remove water).  These pretreatment
       wastewaters would be subject to this rule.
       Re-refining
3.1.13
           When EPA initially proposed guidelines and
       standards for CWTs, the regulations would have
       limited    discharges    from     used    oil
       reprocessors/reclaimers but did not specifically
       exclude discharges from used  oil re-refiners.
       During review of information received on the
       proposal and  assessment of the  information
       collected, the Agency, at one point, considered
       limiting  the  scope  of  this  regulation  to
       reprocessors/reclaimers only.  However, further
       data gathering efforts have revealed that the
       principal sources of re-refining wastewaters are
       essentially the same for reprocessors/reclaimers
       and re-refiners.  Consequently, the re-refining
       wastewater is included within the scope of this
       proposal.
           The  used oil  reclamation  and re-refining
       industry was studied by EPA in the 1980s. EPA
       published the "Preliminary Data Summary for the
       Used Oil Reclamation and Re-Refining Industry"
       (EPA 440/1-89/014) in September 1989 which
       describes this industry and the processes utilized.
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This  document  generally  characterizes  the
industry in terms of the types of equipment used
to  process  the  used  oil.  Minor processors
(reclaimers) generally separate water and solids
from  the  used  oil   using  simple   settling
technology, primarily in-line filtering and gravity
settling with or without heat addition.   Major
processors (reclaimers)  generally use various
combinations of more sophisticated technology
including screen filtration,  heated  settling,
centrifugation,  and  light  fraction distillation
primarily to remove water. Re-refiners generally
use  the   most  sophisticated  systems   which
generally include, in addition to the previous
technology, a vacuum distillation step to separate
the oil into different components.
    This  proposal  applies  to  the  process
wastewater discharges from used oil re-refining
operations. The principal sources of wastewater
include  oil-water  gravity  separation   (often
accompanied  by chemical/thermal, emulsion
breaking)  and  dehydration  unit  operations
(including light distillation and the first stage of
vacuum distillation).
Used Oil Filter Recycling
3.1.14
    EPA did not obtain information on used oil
filter recycling  through the Waste  Treatment
Industry Questionnaire. However, in response to
the September 1996 Notice of Data Availability,
EPA received comments from facilities which
recycle used oil filters.  In  addition, EPA also
visited several used oil reprocessors that recycle
used oil filters as part of their operations.
    Used oil filter recycling processes range from
simple crushing and draining of entrained oil to
more  involved processes   where filters  are
shredded  and the  metal and filter material are
separated. In all  cases, the oil is recycled, the
crushed filters and separated metal are sent to
smelters,  and  the separated filter material is
recovered as solid fuel.   Also, in  all  cases
          observed, the .operations generate no process
          wastewater.     Therefore,   based   on  this
          characterization,  used   oil   filter   recycling
          operations  would be not  be  subject  to  the
          provisions of the CWT rule as proposed today.
          EPA is also considering whether this rule, when
          promulgated, should include a subcategory for
          used oil  filter recycling with a zero discharge
          requirement for such operation.
          Marine Generated Wastes
                                       3.1.15
    EPA received many comments on the original
proposal relating to marine generated wastes.
Since these wastes are often generated while a
ship is at sea and subsequently off-loaded at port
for treatment, the treatment site could arguably be
classified as a CWT. due to its acceptance of "off
site wastes. Commenters, however, claimed that
marine generated wastes should not be subject to
the CWT rule for the following reasons:

   Unlike most  CWT  wastestreams,  bilge
    and/or ballast water is generally dilute and
    not toxic; and
   Most of the bilge water is generated while the
    ship is docked. If only the small portion of
    bilge  water  contained in  the ship upon
    docking is subject to regulation, it would be
    expensive and inefficient to monitor only that
    small portion for compliance with the CWT
    rule.

    EPA  reexamined its database concerning
these wastes as  well as additional data on the
characteristics of these types of wastes provided
through comments to the 1995 proposal. Based
on data provided by industry on bilge and ballast
water characteristics, bilge and ballast water can
vary greatly in terms of the breadth of analytes
and the concentration of the analytes  from one
ship to another.  In most instances, the analytes
and concentrations are similar to those found in
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wastes  typical of the oils subcategory.  EPA
found that while some shipyards have specialized
treatment centers for bilge and/or ballast wastes,
some  of these wastes are  being treated  at
traditional CWTs.
    For purposes of this rule, EPA is defining a
marine generated waste as waste generated  as
part of the normal maintenance and operation of
a ship, boat, or barge operating on inland, coastal
or open waters. Such wastes include wash water
from equipment and tank cleaning, ballast water,
bilge water, and other wastes generated as part of
routine ship maintenance. EPA has determined
that a waste off-loaded from a ship shall be
considered as being generated on-site at the point
where it is off-loaded provided that the waste is
generated as part of the routine maintenance and
operation of the ship on which it originated.  The
waste will not be considered an off-site generated
waste as long as it is treated and discharged at the
ship servicing facility  where it is off-loaded.
Therefore,  these  facilities  would  not   be
considered centralized waste treatment facilities.
If,  however, marine generated wastes are off-
loaded  and subsequently sent to a centralized
waste treatment facility at a  separate location,
these facilities and their wastestreams would be
subject to provisions of this rule.
Stabilization
3.1.16
    In  the  original  CWT  proposal,  waste
solidification/stabilization   operations   were
specifically not subject to the CWT rule.  The
reason stated for EPA's conclusion was that these
operations are "dry" and do not generally produce
a wastewater. EPA reexamined its database and
concluded that this assessment remains valid. As
such, stabilization/ solidification processes are
not subject to the CWT rule as proposed today.
If, however, the stabilization/solidification facility
produces a wastewater from treatment and /or
recovery of off-site wastes through any other
          operation, those wastewaters would be subject to
          the CWT rule.  EPA is also considering whether
          this rule, when promulgated, should include a
          subcategory for stabilization operations  with a
          zero discharge requirement.
          Grease Trap/Interceptor Wastes
                                       3.1.17
    EPA  received  comments on  coverage of
grease, sand, and oil interceptor wastes by the
CWT rule during the comment period for the
original proposal  and  1996  Notice of  Data
Availability. Some of these wastes are from non-
industrial sources and some are from industrial
sources.   Some are treated at central locations
designed    to    exclusively    treat   grease
trap/interceptor wastes and some of these wastes
are treated at traditional CWTs with traditional
CWT wastes.
    Throughout the development  of this rule,
EPA has maintained that this rule is designed to
cover the treatment and/or recovery of off-site
industrial wastes. As such, as proposed today,
grease/trap interceptor wastes do not fall within
the   scope   of  the  proposal.      Grease
trap/interceptor wastes are defined as animal or
vegetable  fats/oils   from   grease  traps  or
interceptors generated by facilities engaged in
food service activities.  Such facilities include
restaurants, cafeterias, and caterers. Excluded
grease trap/interceptor wastes should not contain
any hazardous chemicals or materials that would
prevent the fats/oils from being recovered and
recycled.    Wastewater  discharges from  the
centralized treatment of wastes produced from oil
interceptors,  which are  designed  to collect
petroleum-based oils, sand,  etc. from industrial
type processes, would be subject to this rule.
                                             3-14

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                                                                               Chapter
                                                                                      4
                            DESCRIPTION OF THE  INDUSTRY
     The  adoption  of the  increased pollution
     control measures required by CWA and
RCRA requirements had a number of ancillary
effects, one of which has been the formation and
development  of a waste  treatment  industry.
Several factors haye contributed to the growth of
this industry. These include: (a) the manner in
which manufacturing facilities have elected to
comply with CWA and RCRA requirements; (b)
EPA's  distinction  for  regulatory  purposes
between on- and off-site treatment of wastewater
in the CWA guidelines program; and  the
RCRA 1992 used oil management requirements.
    A  manufacturing facility's  options  for
managing wastes include on-site treatment or
sending them off-site. Because a large number of
operations (both large and small) have chosen to
send their wastes off-site, specialized facilities
have developed whose sole commercial operation
is the handling of wastewater treatment residuals
and industrial process by-products.
    Many promulgated effluent  guidelines also
encouraged the creation of these central treatment
centers.   Inconsistent treatment of  facilities
which send their waste off-site to CWTs in the
guidelines program has resulted in wastewater
that  is  treated  off-site   being   subject to
inconsistent standards. EPA acknowledges that
this may have created a loop-hole for dischargers
to avoid treating their wastewater to standards
comparable to  categorical  standards  before
discharge. Additionally, RCRA regulations, such
as the 1992 used oil management requirements
(40 CFR 279) significantly influenced the size
and service provided by this industry.
INDUSTRYSIZE
4.1
    Based  upon  responses  to  EPA's  data
gathering efforts, the Agency now estimates that
there are approximately 205 centralized waste
treatment facilities in 38 States.  As shown below
in  Table 4-1, the  major  concentration  of
centralized waste treatment facilities is in  EPA
Regions 4, 5 and 6 due to the proximity of the
industries generating  the wastes   undergoing
treatment. At the time of the original proposal,
EPA estimated there were 85 centralized waste
treatment facilities in the United States. EPA,
however, greatly underestimated the number of
facilities in the proposed oily waste and recovery
subcategory. Through additional data gathering
activities (see discussion in Chapter 2),  EPA
obtained information on additional oils facilities.
Except  for  facilities  that  were included  or
excluded because of scope changes/clarifications,
all of the facilities which have been added since
the original  proposal treat and/or recover oily
waste  and/or  used  oil.  EPA is  aware  that
facilities in the metals and organics subcategories
have  entered  or  left  the  centralized waste
treatment market also. This  is expected  in a
service industry. Even so, EPA believes its initial
estimate of facilities in the other subcategories is
reasonable and no adjustments, other than those
resulting from the redefined scope of the industry,
have been made.
    As  detailed in Chapter  2,  while  EPA
estimates there are 205 CWT facilities, EPA only
has facility-specific information for 145 of these
facilities.  In  preparing this  reproposal,  EPA
conducted its analysis with the known facility
specific information and then used the actual data
to develop additional information to represent the
                                           4-1

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Chapter 4 Description of the Industry    Development Document for the CWT Point Source Category
entire  population.   Unless otherwise stated,
information presented in this document represents
the entire population.  Table 4-1 provides an
example where data is only presented for the
facilities for which  EPA has facility-specific
information.
GENERAL DESCRIPTION
4.2
    Centralized waste treatment facilities do not
fall into a single description and are as varied as
the wastes they accept Some treat wastes from
a few generating facilities while  others treat
wastes from hundreds of generators.  Some treat
only certain types of waste while others accept
many wastes. Some treat non-hazardous wastes
exclusively while others treat hazardous and non-
hazardous  wastes.    Some  primarily  treat
concentrated wastes while others  primarily treat
more dilute wastes. For some,  their primary
business is the treatment of other  company's
wastes  while,  for others,  centralized waste
treatment is ancillary to their main business.
    Centralized waste treatment  facilities treat
both hazardous and/or non-hazardous wastes. At
the time, of the original proposal, a few of the
facilities in the industry database solely accepted
wastes classified as non-hazardous under RCRA.
The  remaining   facilities   accepted   either
hazardous  wastes only or a combination of
hazardous and non-hazardous wastes. The vast
majority of the newly identified oils facilities
accept non-hazardous materials only. As such,
EPA  believes the market for centralized waste
treatment  of  non-hazardous  materials  has
increased during the 1990s.
    EPA has detailed waste receipt information
for the facilities  in the  1991  Waste Treatment
Industry Questionnaire data  base.  Of the 76
in-scope facilities from the proposal data base, 65
of them are RCRA-permitted treatment,  storage,
and disposal facilities (TSDFs).  As such, most of
these facilities were able  to use information
reported in the 1989 Biennial Hazardous Waste
Report  to classify  the  waste  accepted  for
treatment by the appropriate Waste Form  and
RCRA codes. The Waste Form and RCRA codes
reported by the questionnaire respondents are
listed in Table 4-2  and Table 4-3, respectively.
(Table 14-2 in Chapter 14 lists these Waste Form
and RCRA  codes  along  with their associated
property and/or pollutants). Some questionnaire
respondents,   especially  those   that  treat
non-hazardous waste, did not report the Waste
Form Code information due to the variety  and
complexity of their operations.
    EPA does not have detailed RCRA code and
waste code information on waste receipts for the
facilities identified after the original proposal.  It
is  known that the majority of  these facilities
accept  non-hazardous wastes.    Of the 69
post-proposal oily waste facilities for which EPA
has specific data, only 19 are RCRA-permitted
TSDFs.
    Centralized waste treatment facilities service
a  variety of customers.   A CWT generally
receives a variety of wastes daily'from dozens of
customers. Some customers routinely generate a
particular wastestream and are unable to provide
effective on-site treatment of  that particular
wastestream.  Some customers  utilize CWTs
because they  generate  wastestreams  only
sporadically (for example tank removal, tank
cleaning and remediation wastes) and are unable
to  economically  provide  effective  on-site
treatment of these wastes. Others, many which
are small businesses, utilize CWTs  as their
primary source of wastewater treatment.
                                            4-2

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Chapter 4 Description of the Industry    Development Document for the CWT Point Source Category
    Table 4-1. Geographic Distribution of CWT Facilities (145 Facilities)
Region
1
2

3



4









Table 4-2
State
Connecticut
Maine
Massachusetts
Rhode Island
New Jersey
New York
Delaware
Maryland
Pennsylvania
Virginia
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee


#of
CWTs
5
1
1
1
6
4
1
2
6
4
3
8
3
2
1
1
2
6


%of
CWTs
5.5
6.8

8.9



17.9









Region
















. Waste Form Codes Reported by CWT Facilities
5

6


7


8

9



10

State
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
Louisiana
Oklahoma
Texas
Iowa
Kansas
Missouri
Colorado
Montana
Arizona
California
Hawaii
Nevada
Oregon
Washington
# of % of
CWTs CWTs
















6
4
10
2
12
4
3
2
13
= 1
2
1
2
1
1
12
1
1
2
8
26.2

12.4


2.8


2.1

10.3



6.9

in 19891
Waste Form Codes
B001
B101
B102
BIOS
B104
BIOS
B106 B112
B107 B113
BIOS B114
B109 B115
B110 B116
Bill B117
B119
B201
B202
B203
B204
B205
B206
B207
B208
B209
B210
B211
B219
B305
B306
B307
B308
B309
B310
B312
B313
B315
B316
B319
B501
B502
B504
B505
B506

B507
B508
B510
B511
B513

B515
B518
B519
B601
B603

B604
B605
B607
B608
B609

JTable 14-2 in Chapter 14 lists Waste Form Codes and their associated properties.
Table 4-3
. RCRA Codes Reported by Facilities in 19892
RCRA Codes
D001
D002
D003
D004
D005
D006
D007
D008
D009
D010
D011
D012 F009
D017 F010
D035 F011
F001 F012
F002 F019
F003 F039
F004 K001
F005 K011
F006 KOI 3
F007 K014
F008 KOI 5
K016
K031
K035
K044
K045
K048
K049
K050
K051
K052
K061
K063
K064
K086
K093
K094
K098
K103
K104
P011
P012
P013
P020
P022
P028
P029
P030
P040
P044
P048
P050
P063
P064
P069
P071
P074
P078
P087
P089
P098
P104
P106
P121
PI 23
U002
U003
U008
U009 .
U012
U013
U019
U020
U031
U044
U045
U052
U054
U057
U069
U080
U092
U098
U105
U106
U107
U113
U118
U122
U125
U134
U135
U139
U140
U150
U151
U154
U159
U161
U162
U188
U190
U205
U210
U213
U220
U226
U228
U239
    ^Table 14-2 in Chapter 14 lists Waste Form Codes and their associated properties.
                                               4-3

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Chapter 4 Description of the Industry    Development Document for the CWT Point Source Category
    Before a CWT accepts a waste for treatment,
the waste generally undergoes rigorous screening
for compatibility with other wastes being treated
at the facility. Waste generators initially furnish
the treatment facility with a sample of the waste
stream to be treated. The sample is analyzed to
characterize the level of pollutants in the sample
and bench-scale treatability tests are performed to
determine what treatment is necessary to treat the
waste stream. After all  analyses and tests are
performed, the treatment facility determines the
cost for treating the waste stream. If the waste
generator accepts the cost of treatment., shipments
of the waste stream to the treatment facility will
begin.  Generally, for each truck load of waste
received for treatment,  the  treatment  facility
collects a sample from the shipment and analyzes
the sample to determine if it is  similar to the
initial sample tested. If the sample is similar, the
shipment of waste will be treated. If the sample
is not similar but falls within an allowable range
as  determined by the treatment facility, the
treatment facility will reevaluate the  estimated
cost of treatment for the shipment. Then, the
waste generator decides if the waste will remain
at the treatment facility for treatment.  If the
sample is not similar and does not fall within an
allowable range, the treatment facility will decline
the shipment for treatment.
    Treatment facilities  and waste generators
complete extensive amounts of paperwork during
the waste acceptance process.  Most of the
paperwork is required by Federal, State, and local
regulations.  The amount of paperwork necessary
for accepting a waste stream emphasizes the
difficulty of operating centralized waste treatment
facilities.
 WATER USE AND SOURCES
 OF WASTEWATER
4.3
    Approximately   1.9   billion  gallons   of
wastewater are  generated annually at CWT
facilities.  It is difficult to determine the quantity
of wastes attributable to different sources because
facilities generally mix the wastewater prior to
treatment.   EPA has, as  a general  matter,
however, identified the sources described below
as contributing to wastewater discharges at CWT
operations that would be subject to the proposed
effluent limitations and standards.

Waste Receipts. Most off-site waste received by
CWT facilities is aqueous.  These aqueous off-
site waste receipts comprise the largest portion of
the wastewater treated at CWTs. Typical waste
receipts for the metals subcategory include but
are not limited to: spent electroplating baths and
sludges;   spent  anodizing  solutions;  metal
finishing rinse water and sludges; and chromate
wastes. Types of waste accepted for treatment in
the oils subcategory include but are not limited to:
lubricants, used petroleum products, used oils, oil
spill clean-up, bilge  water, tank clean out, off-
specification fuels, and underground storage tank
remediation waste.  Types of wastes accepted for
treatment in the organics subcategory include, but
are not limited to: landfill leachate; groundwater
clean-up; solvent-bearing waste; off-specification
organic products; still bottoms; used antifreeze;
and wastewater from chemical product operations
and paint washes.

Solubilization Water. A portion of the off-site
waste receipts is in a solid form. Water may be
added to the waste to render it treatable.

Waste Oil Emulsion-Breaking Wastewater. The
wastewater generated as a result of the emulsion
breaking or gravity separation process from the
processing of used oil constitutes a major portion
of the wastewater treated at oils facilities. EPA
estimates that, at a typical oils facility, half of the
wastewater treated  is  a  result of oil/water
separation processes.
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Chapter 4 Description of the Industry    Development Document for the CWT Point Source Category
Tanker  Truck/Drum/Roll-Off Box  Washes.
Water is used to clean the equipment used for
transporting wastes.  The amount of wastewater
generated was  difficult to assess because the
wash water is normally added to the wastes or
used as solubilization water.

Equipment Washes. Water is used to clean waste
treatment equipment during unit shut downs  or in
between batches of waste.

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

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

Industrial   Waste   Combustor  or  Landfill
Wastewater from On-Site Landfills.  Wastewater
is generated at some CWT facilities as a result of
on-site landfilling or incineration activities.

Contaminated Stormwater.  This is stormwater
which comes in direct contact with the waste or
waste handling and treatment areas.  If this
contaminated CWT stormwater is introduced to
the treatment system, its discharge is subject to
the  proposed  limitations.   The Agency is
proposing  not  to  regulate  under the CWT
guideline    non-contact    stormwater    or
contaminated stormwater not introduced to the
treatment system. Such flows may, in certain
circumstances,  require permitting under EPA's
existing  permitting  program under  40  CFR
122.26(b)(14)  and 40 CFR  403.  CWTs that
introduce non-contaminated stormwater into their
treatment system will need to identify this as a
source of non-CWT wastewater in their treatment
system  in their permit applications.   This is
necessary in order that the permit writer may take
account of these flows in developing  permit
limitations that reflect actual treatment.
VOLUME BY TYPE OF DISCHARGE
4.4
    In general, three basic options are available
for disposal of wastewater treatment effluent:
direct,  indirect,  and  zero  (or  alternative)
discharge. Some facilities utilize more than one
option (for example, a portion of their wastewater
is discharged to a surface water and a portion is
evaporated).  Direct dischargers  are  facilities
which discharge effluent directly to a surface
water. Indirect dischargers are facilities which
discharge effluent to a publicly-owned treatment
works (POTW).  Zero or alternative dischargers
do not generate a wastewater or do not discharge
to a surface water or POTW. The types of zero
or alternative discharge identified in the CWT
industry are underground injection control (UIC),
off-site transfer for further treatment or disposal,
evaporation,  and  no  wastewater  generation.
Table 4-4 lists the number of facilities utilizing
each discharge option.
    Average   facility  wastewater  discharge
information is presented in Table 4-5 for the
indirect and direct  discharge  options.   The
proposed  effluent limitations guidelines  and
standards for the CWT industry do not apply to
facilities with a zero or alternative discharge.
                                             4-5

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Chapter 4 Description of the Industry   Development Document for the CWT Point Source Category
    Table 4-4 Facility Discharge Options
Discharge Option
Direct
Indirect
Indirect and off-site transfer
Indirect and no wastewater generation
UIC
Off-site transfer
Evaporation
Off-site transfer and evaporation
Zero (not specified)
Total
No. of Facilities with
Specific Data
12
101
1
2
7
14
3
1
4
145
No. of Scaled-Up
Facilities
14
144
1
2
9
22
5
1
7
205
    Table 4-5 Quantity of Wastewater Discharged (205 Facilities)
         Discharge
          Option
Quantity of Wastewater Discharged (Million gallons/year)
                                  Total
               Average
                Minimum
Maximum
Direct
Indirect
535
1,370
38.2
9.3
0.078
0.0013
225
177
OFF-SHE TREATMENT INCENTIVES
AND COMPARABLE TREATMENT
        4.5
    As  noted  before,  the  adoption  of  the
increased pollution control measures required by
the CWA and RCRA regulation was a significant
factor in the formation and development of the
centralized waste  treatment  industry.   Major
contributors to the growth of this industry include
EPA decisions about how to structure its CWA
effluent limitations guidelines program as well as
the manner in which manufacturing facilities have
elected  to comply  with  CWA  and  RCRA
requirements.
    The  CWA requires the  establishment of
limitations and standards for categories of point
sources that discharge into surface  waters or
introduce  pollutants  into  publicly  owned
treatment works. At present, facilities that do not
discharge wastewater (or introduce pollutants to
POTWs) may not be subject to the requirements
of  40 CFR  Subchapter N Parts 400 to 471.
Such facilities include manufacturing or service
facilities that generate no process wastewater,
facilities that recycle all contaminated waters, and
facilities that use  some  kind  of alternative
disposal technology or practice (for example,
deep well injection, incineration, evaporation,
surface impoundment,  land  application, and
transfer to a centralized waste treatment facility).
    Thus, for example, in implementing CWA
and  RCRA requirements in the electroplating
industry,  many   facilities   made  process
modifications to conserve and recycle process
wastewater, to extend the lives of plating baths,
and to minimize the generation of wastewater
treatment sludges. As the volumes of wastewater
were reduced, it became economically attractive
to  transfer     electroplating   metal-bearing
wastewater to off-site centralized waste treatment
facilities for treatment or metals recovery rather
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Chapter 4 Description of the Industry    Development Document for the CWT Point Source Category
than to invest in on-site treatment systems.  In the
case  of the organic chemicals, plastics,  and
synthetic   fibers  (OCPSF)   industry,  many
facilities transferred selected process residuals
and small volumes of process wastewater to off-
site centralized waste treatment facilities.  When
estimating the engineering costs for the OCPSF
industry to comply with the OCPSF regulation,
the Agency assumed,  based on economies of
scale, in the case  of facilities with wastewater
flows less than 500 gallons per day, such plants
would use off-site rather than on-site wastewater
treatment.
    The Agency  believes that  any  wastes
transferred to an off-site CWT facility should be
treated to at least the same level as required for
the  same  wastes if treated  on-site at the
manufacturing  facility.    In  the  absence of
appropriate  regulations  to   ensure   at  least
comparable or  adequate  treatment, the  CWT
facility may inadvertently offer an economic
incentive for increasing the pollutant load to the
environment.   One of the Agency's primary
concerns is the potential  for a discharger to
reduce  its  wastewater pollutant concentrations
through dilution rather than through appropriate
treatment.  This proposal is designed to ensure
that wastes  transferred to centralized  waste
treatment facilities would be treated to the same
levels as on-site treatment or to adequate levels.
    This is illustrated by the information the
Agency obtained  during  the data  gathering
activities for the 1995 proposal. EPA visited 27
centralized waste treatment facilities in an effort
to identify well-designed, well-operated candidate
treatment  systems for sampling.  Two  of the
principal criteria for selecting plants for sampling
were based on whether the plant applied waste
management  practices   that   increased  the
effectiveness of the treatment system and whether
the treatment system was effective in removing
pollutants.  This effort was complicated  by the
level of dilution and co-dilution of one type of
waste with another. For example, many facilities
treated metal-bearing and oily wastes in the same
treatment system and many facilities mixed non-
CWT wastewater with CWT wastewater. 'Mixing
metal-bearing  with  non-metal-bearing   oily
wastewater  and mixing CWT  with non-CWT
wastewater  provides a dilution effect which
generally reduces the efficiency of the wastewater
treatment system.  Of the 27 plants visited, many
were not sampled because of the problems of
assessing  CWT treatment efficiencies  due to
dilution of one type of wastewater with another.
    This proposal would  ensure, to the extent
possible, that metal-bearing'wastes are treated
with metals control technology, that oily wastes
are treated with oils control technology, and that
organic wastes are treated with organics control
technology.
    In developing this proposal, EPA identified a
wide variation in the size of CWT facilities and
the level of treatment provided by these facilities.
Often, pollutant  removals were  poor,  and, in
some cases, significantly lower than would have
been required had the wastewaters been treated at
the site where generated.  In particular, EPA's
survey  indicated that  some  facilities  were
employing only the most basic pollution control
equipment  and,  as a result,   achieved  low
pollutant removals relative to that easily obtained
through the use of other,  readily  available
pollutant  control  technology.    Further,  as
explained   below,   EPA  had  difficulty  in
identifying  more than  a  handful of facilities
throughout the CWT industry that were achieving
optimal removals.
    During  consideration of this proposal, EPA
looked 'at whether it should limit the scope of
national regulation to facilities above a certain
size or flow level because of information before
the Agency suggesting, that, in the case of certain
smaller facilities, the costs of additional controls
would represent  a  significant increase  in their
costs of operation.  For the reasons  explained
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Chapter 4 Description of the Industry   Development Document for the CWT Point Source Category


above, however, EPA has decided not to limit the
scope of this proposal, based either on the size of
a facility or the volume of wastewater flows. The
effect of such an approach, given the structure of
the  industry  and  treatment  level currently
observed, would be effectively to encourage the
movement of wastewater to some of the very
facilities that are not providing treatment that is
equivalent to that which would be expected (and
required) if the wastewater were  treated at the
point of origin. Since this proposal would ensure
adequate controls for wastewater discharges from
CWT facilities that accept waste and wastewater
that would  otherwise  be controlled by other
guidelines,  all members of the CWT industry
should comply with the national CWT standards
regardless of size or potential economic impacts.
                                            4-8

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                                                                              Chapter
                                                                                     5
                           INDUSTRY SUBCATEGORIZATION
METHODOLOGY AND FACTORS
CONSIDERED As THE BASIS
FOR SUBCATEGORIZATION
5.1
     The  CWA requires EPA, in developing
     effluent   limitations   guidelines   and
pretreatment standards that represent the best
available technology economically achievable for
a particular industry category, to consider  a
number of different factors. Among others, these
include the age of the equipment and facilities in
the category, manufacturing processes employed,
types of treatment technology to reduce effluent
discharges, and the cost of effluent reductions
(Section 304(b)(2)(b) of the CWA, 33 U.S.C. 
1314(b)(2)(B)). The statute also authorizes EPA
to take into account other factors that the Agency
deems appropriate.
     One way in which the Agency  has taken
some of these factors into account is by breaking
down  categories  of industries  into separate
classes of similar characteristics. This recognizes
the major differences among companies within an
industry that may reflect, for example, different
manufacturing processes or other factors. One
result of subdividing an industry by subcategories
is to safeguard against overzealous regulatory
standards,  increase the confidence  that the
regulations are practicable, and diminish the need
to address variations between facilities through a
variance  process (Weyerhaeuser Co.  v. Costle,
590F.2d 1011, 1053 (D.C. Cir. 1978)).
     The centralized waste treatment industry, as
previously explained, is not typical of many of
the industries regulated under the CWA because
it does not produce a product. Therefore, EPA
considered  certain  additional   factors   that
specifically apply to centralized waste treatment
operations in its evaluation of how to establish
appropriate  limitations  and  standards  and
whether further subcategorization was warranted.
Additionally, EPA did not consider certain other
factors    typically     appropriate    when
subcategorizing  manufacturing  facilities  as
relevant when evaluating  this  industry.  The
factors EPA considered in the subcategorization
of the  centralized waste  treatment industry
include:

    Facility age;
    Facility size;
    Facility location;
    Non-water quality impacts;
    Treatment technologies and costs;
    RCRA classification;
    Type of wastes received for treatment; and
    Nature of wastewater generated.

     EPA concluded that certain of these factors
did not support further subcategorization of this
industry. The Agency concluded that the age of a
facility is not a basis  for subcategorization as
many older facilities have unilaterally improved
or modified their treatment process over time.
EPA also decided that facility size was not an
appropriate basis for  subcategorizing.   EPA
identified three parameters as relative measures
of facility size: number of employees, amount of
waste receipts accepted, and wastewater flow.
EPA found that CWTs  of varying sizes generate
similar wastewaters and use similar treatment
technologies.  Furthermore, wastes can be treated
to the same level regardless of the facility size.
Likewise, facility location is not a good basis for
subcategorization. Based on the data collected,
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Chapter 5 Industry Subcategorization
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no consistent differences in wastewater treatment
technologies  or performance exist  because of
geographical location. EPA recognizes, however,
that geographic location may have an effect on
the market for CWT services, the cost charged for
these services,  and  the  value of recovered
product.  These issues  are  addressed in the
Economic Assessment Document.
     While  non-water quality  characteristics
(solid waste and air emission effects) are of
concern to EPA, these characteristics  did not
constitute   a  basis  for   subcategorization.
Environmental impacts from solid waste disposal
and from the transport of potentially hazardous
wastewater  are a result of individual facility
practices  and  EPA could  not identify  any
common characteristics particular  to a  given
segment of the industry. Treatment costs were
not used as a basis for subcategorization because
costs will  vary and are dependent  on the
following waste stream variables:  flow rates,
wastewater   quality,  and  pollutant loadings.
Finally,  EPA  concluded  that the  RCRA
classification was not an appropriate basis for
subcategorization as the type of waste accepted
for treatment appears to be more important than
whether the waste was classified as hazardous or
non-hazardous.
     EPA identified only one factor with primary
significance for subcategorizing the centralized
waste treatment industry  the type of waste
received for treatment or recovery.  This factor
encompasses many of the other subcategorization
factors.  The type of treatment processes used,
nature of wastewater generated, solids generated,
and potential air emissions directly correlate to
the type  of wastes  received for treatment or
recovery. For today's proposal, EPA  reviewed its
earlier  subcategorization  approach  and has
decided to retain it.  It is still EPA's conclusion
that the type of waste received for treatment or
recovery  is the  only appropriate basis  for
subcategorization of mis industry.
       PROPOSED SUBCATEGORIES
5.2
            Based on the type of wastes accepted for
       treatment or recovery, EPA has determined that
       there are three subcategories appropriate for the
       centralized waste treatment industry:

          Subcategory  A:  Facilities which  treat,
           recover, or treat and  recover metal,  from
           metal-bearing waste,  wastewater, or  used
           material from off-site (Metals Subcategory);
          Subcategory  B:  Facilities which  treat,
           recover, or treat and recover oil, from oily
           waste,  wastewater,  or used material  from
           off-site (Oils Subcategory); and
          Subcategory  C:  Facilities which  treat,
           recover, or treat and recover organics,  from
           other organic  waste,  wastewater, or  used
           material    from    off-site     (Organics
           Subcategory).

       SUBCATEGORY DESCRIPTIONS             5.3
       Metal-Bearing Waste Treatment
       and Recovery Subcategory            5.3.1

            The facilities in this Subcategory are those
       treating metal-bearing  waste received  from
       off-site  and/or recover metals from  off-site
       metal-bearing  wastes.    Currently,  EPA  has
       identified  59  facilities in this  Subcategory.
       Fifty-two facilities treat  metal-bearing waste
       exclusively, while another six facilities recover
       metals from the wastes  for sale in commerce or
       for return to industrial  processes.  One  facility
       provides metal-bearing  waste treatment  in
       addition  to  conducting   a  metals  recovery
       operation.  The vast majority of these facilities
       have RCRA permits to  accept hazardous waste.
       Types of wastes accepted for treatment  include
       spent  electroplating baths and sludges,  spent
       anodizing solutions, metal finishing rinse water
       and sludge, and chromate  wastes.
            The typical treatment process  used for
       metal-bearing waste is precipitation with lime or
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Chapter 5 Industry Subcategorization
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caustic followed  by  filtration.   The  sludge
generated is then landfilled in a RCRA Subtitle C
or D landfill depending on its content.  Most
facilities that recover metals do not generate  a
sludge that requires disposal. Instead, the sludges
are sold for metal content.  In addition to treating
metal  bearing wastestreams, many facilities in
this subcategory also treat cyanide wastestreams,
many  of which are  highly-concentrated and
complex.  Since the presence of cyanide may
interfere with the chemical precipitation process,
these  facilities  generally pretreat to  remove
cyanide and  then commingle  the pretreated
cyanide wastewaters  with  the  other  metal
containing wastewaters.  EPA estimates that
nineteen of the metals facilities also treat cyanide
wastestreams.
Oily Waste Treatment.
and Recovery Subcategory
5.3.2
     The facilities in this subcategory are those
that treat oily waste, wastewater, or used'material
received from off-site and/or recover oil from
off-site oily materials. Currently, EPA estimates
that there are 164 facilities in this subcategory.
Among the types of waste accepted for treatment
are lubricants, used petroleum products, used oils,
oil spill  clean-up,  bilge water,  tank clean-out,
off-specification fuels, and underground storage
tank remediation waste. Many  facilities in this
subcategory only  provide treatment  for oily
wastewaters while others pretreat the oily wastes
for contaminants such as water and then blend the
resulting oil residual to form a product, usually
fuel.  Most facilities  perform both  types  of
operations.  EPA estimates that  53  of these
facilities only treat oily  wastewaters and  36
facilities primarily recover oil for re-use.  The
remaining 75  facilities both treat oily waste and
recover oil for re-use.
     At the time of the original proposal, EPA
believed that  85 percent of oils facilities were
primarily  accepting   concentrated,  difficult-
to-treat, stable, oil-water emulsions containing
more than 10  percent  oil.   However, during
post-proposal data collection, EPA learned that
many of the wastes treated for oil content at these
facilities were fairly dilute and consisted of less
than 10 percent oils.  EPA now believes that,
while  some  facilities are accepting the  more
concentrated wastes, the majority of facilities in
this subcategory are treating less concentrated
wastes.
     Further, at the time of the original proposal,
only three of the facilities included in the data
base for this subcategory were identified as solely
accepting wastes classified  as   non-hazardous
under RCRA. The remaining facilities accepted
either hazardous wastes alone or a combination of
hazardous and  non-hazardous  wastes.     In
contrast, based on more recent information, EPA
believes  that the majority of facilities in this
subcategory  only accept wastes that would  be
classified by RCRA as non-hazardous.
     The most widely-used treatment technology
in this subcategory is gravity separation and/or
emulsion  breaking.  One-third of this industry
only  uses gravity separation  and/or emulsion
breaking to treat oily wastestreams. One-third of
the industry  also utilizes chemical precipitation
and  one-quarter also  utilizes  dissolved  air
flotation (DAF).
          Organic Waste Treatment
          and Recovery Subcategory
                                        5.3.3
              The facilities in this subcategory are those
          that treat organic waste received from off-site
          and/or recover organics  from off-site organic
          wastes. EPA estimates that there are 25 facilities
          in  this  subcategory.   The  majority of these
          facilities have RCRA permits to accept hazardous
          waste.  Among the types of wastes accepted at
          these facilities are landfill leachate, groundwater
          cleanup, solvent-bearing waste, off-specification
          organic products, still bottoms, used  antifreeze,
          and wastewater from chemical product operations
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Chapter 5 Industry Subcategorization
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and paint washes.
    All of the organics facilities which discharge
to a surface water use equalization and some form
of biological treatment to handle the wastewater.
The vast majority of organics facilities which
discharge to a POTW primarily use equalization.
One third of all the organics facilities also use
activated carbon  adsorption.   Most of the
facilities in the organics subcategory have other
industrial operations as well, and the centralized
waste treatment wastes are mixed with these
wastewaters prior to treatment.  The relatively
constant make-up  of on-site wastewater  can
support the operation of conventional, continuous
biological treatment processes, which otherwise
could be upset by the variability of the off-site
waste receipts.
MIXED WASTE SUBCATEGORY
CONSIDERATION
5.4
     EPA has received numerous comments from
industry that  the subcategorization  scheme
developed for this rule is impractical for CWT
facilities which accept wastes in more than one
subcategory.  These commenters are primarily
concerned about incoming waste receipts  that
may be classified in more than one subcategory.
While CWTs can encourage  their customers to
segregate their wastes, they argue that CWTs can
not  require  segregation of incoming  waste
receipts.     Additionally,  commenters   have
suggested that, for ease of implementation, mixed
waste  subcategory  limitations   should   be
developed   for   all   facilities  in  multiple
subcategories. These commenters are primarily
concerned  that permit  writers  may  impose
additional and substantial record keeping burden
in  order  to classify wastes in each  of the
subcategories. Commenters have suggested that
limitations for the mixed waste subcategory could
combine pollutant limitations  from all three
subcategories, selecting the most stringent value
where they overlap.
    While facilities have suggested developing a
mixed waste subcategory with limitations derived
by combining pollutant limitations from all three
subcategories (selecting the most stringent value
where  they overlap),  EPA does  not  believe
facilities have adequately considered the costs
associated with such  an option.   Assuming
facilities employ appropriate treatment rather
than  dilution  to  meet  these  mixed waste
limitations, EPA compared the compliance cost
for facilities in multiple subcategories with the
mixed waste subcategory limitations as described
above to compliance costs for facilities meeting
the limitations  for the  three  subcategories
separately.  Costs were greater for the mixed
waste subcategory since EPA had to cost for
larger flows, more chemical addition, etc. EPA
chose nine  representative facilities  that treat
wastes in more than one subcategory to  conduct
the comparisoa EPA found that, in all cases, the
costs  of complying with  the  mixed waste
subcategory limitations were two to three times
higher than the costs associated with complying
with  each  of the  subcategory  limitations
separately. Since the market for these services is,
generally, very competitive and since many of
these facilities are small businesses, EPA believes
that few facilities would chose to meet the
limitations for the mixed waste subcategory.
    The primary reason industry suggested the
development of a mixed waste subcategory was
their concern that waste receipts may be classified
in more than  one subcategory. As detailed in
Chapter 13, EPA believes that the information
currently collected is sufficient to classify wastes
into each of the three subcategories.  Using the
recommended    subcategory    determination
procedure, EPA is able to classify each waste
receipt identified by  the industry  during the
development of this rule in a single subcategory.
Therefore, EPA believes that mixed waste receipt
concern has been alleviated.
    The second reason industry suggested the
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Chapter 5 Industry Subcategorization
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development of a mixed waste subcategory was
to   simplify  implementation   for   mixed
subcategory  facilities.     EPA  agrees  with
commenters   that   developing   appropriate
limitations for mixed waste facilities presents 
many challenges, but is  concerned that mixed
wastes receive adequate treatment.  In many
cases, facilities which accept wastes in multiple
subcategories do not have treatment in place to
provide effective treatment of all waste receipts.
While  these  facilities   meet  their  permit
limitations,  compliance  is generally due  to
dilution rather than treatment. As an example, a
facility may have a treatment system comprised
of equalization and biological  treatment and
accepts wastes from the organics subcategory and
the metals subcategory (high concentrations of
metal pollutants). Only the organic subcategory
waste receipts would be treated effectively. The
"mixed waste subcategory" limitations described
above would not prevent ineffective treatment
and could actually encourage it. Therefore, based
on economic considerations as well as concerns
that EPA has about ensuring compliance with
effective treatment, rather than dilution, EPA is
not proposing a mixed waste subcategory.
                                             5-5

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                                                                           Chapter
                                                                                  6
                    POLLUTANTS OF CONCERN FOR THE
   CENTRALIZED WASTE TREATMENT INDUSTRY
     As discussed previously, wastewater receipts
     treated  at  centralized waste treatment
facilities  may  have  significantly  different
pollutants and pollutant loads depending on the
customer and the process generating the waste
receipt.  In fact, at many CWT facilities, the
pollutants and pollutant loads may vary daily and
from batch to batch. As a result, it is difficult to
characterize "typical" CWT wastewaters. In fact,
one of the distinguishing characteristics of CWT
wastewaters   (as   compared  to  traditional
categorical wastewaters) is that there is always
the exception to the rule. For example, at one
facility, EPA analyzed  samples of wastewater
received for treatment from a single facility that
were obtained  during  three different,  non-
consecutive weeks.  EPA found that the weekly
waste receipts varied from the most concentrated
(in terms of metal pollutants) to one of the least
concentrated (in terms of metal pollutants).
METHODOLOGY
6.1
    EPA determined pollutants of concern for the
CWT industry by assessing EPA sampling data
only.    Industry  has  provided  very  little
quantitative  data  on  the  concentrations  of
pollutants  entering their wastewater treatment
systems.    For   the  metals  and organics
subcategory, EPA collected  the data used to
determine the pollutants of concern at influent
points to the wastewater treatment systems.  For
the oils subcategory, EPA collected the data
following  emulsion  breaking  and/or  gravity
separation. The pollutant concentrations at these
points are lower than the original waste receipt
concentrations as a result of the commingling of
a variety of waste streams, and, in the case of the
oils subcategory, as a result of pretreatment.  In 
most cases, EPA could not collect samples from
individual waste shipments because of physical
constraints and excessive analytical costs.
    EPA used two different analytical methods to
analyze samples for oil and grease during the
development of this guideline.  EPA analyzed
samples collected prior to the 1995 proposal
using Method 413.1. This method uses freon and
is being phased out. EPA analyzed oil and grease
samples collected after the 1995 proposal using
the newly proposed EPA Method 1664.  Method
1664 is used to measure oil and grease as hexane
extractable material (HEM) and to measure silica
gel  treated-hexane extractable material (SGT-
HEM).   EPA believes that  oil and grease
measurements from Method 413.1 and Method
1664 are comparable and has used the  data
interchangeably.
    EPA collected influent sampling data over a
limited time span (generally two to five days).
The samples represent a snapshot of the receipts
accepted  for  treatment  during the time the
samples were collected. Because waste receipts
may vary significantly from day to day, EPA
can't know if, in  fact, the  data  are  also
representative of waste receipts during any other
time period.  If EPA had sampled  at more
facilities or over longer periods of time, EPA
would expect to observe a wider range of flows,
pollutants, and pollutant concentrations in CWT
industry raw wastewater. This has complicated
                                         6-1

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Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
the  selection of  pollutants of  concern  and
regulated pollutants, and the estimation of current
performance and removals  associated with this
rulemaking.   Historically,   in    developing
categorical limitations and standards, unlike the
case   for   CWT   waste   receipts,   influent
wastestreams are generally consistent in strength
and nature.
    To establish the pollutants of concern, EPA
reviewed the  analytical  data from  influent
wastewater samples to determine the number of
times a pollutant was detected at treatable levels.
EPA set treatable levels at ten times the method
detection limit to ensure that pollutants detected
as only trace amounts would not be selected. For
most organic pollutants, the method detection
limit is 10 ug/L.  Therefore, for most organic
parameters, EPA has defined treatable levels as
100 ug/L.  For metals  pollutants the method
detection limits range from 0.2 ug/L to  1000
ug/L. EPA then obtained the initial pollutants of
concern   listing   for  each  subcategory  by
establishing which parameters were detected at
treatable levels in at least  10 percent of the
influent wastewater samples.  Ten percent was
used to account for the variability of CWT
wastewaters.  As mentioned previously in Section
2.3.3.2, after the initial two sampling episodes
EPA discontinued the analyses for dioxins/furans,
pesticides/herbicides, methanol,  ethanol,  and
formaldehyde, and as a result these parameters
were not included in the pollutants of concern
analysis.  Figure 6-1 depicts the methodology
EPA used to select pollutants of concern for each
subcategory.
    Tables 6-1 through 6-3 provide a listing of
the  pollutants that  were  determined to be
pollutants of concern  for each  subcategory.
These  tables list the  pollutant  name,  CAS
number, the number of times the pollutant was
analyzed,  the number  of  detects,  the method
detection limit (MDL), the number of detects at
treatable levels, and the minimum and maximum
  concentration detected.  Tables 6-4 through 6-6
  provide a listing of the pollutants that were not
  considered to be pollutants of concern for each
  subcategory  and  the reason they  were  not
' selected.    While  EPA  generally   uses  the
  parameters established as pollutants of concern to
  estimate  pollutant   loadings  and   pollutant
  removals, EPA only selected some  of these
  parameters   for  regulation.    The   regulated
  pollutants are  a subset of  the  pollutants of
  concern and are discussed in Chapter 7. Chapter
  12 discusses pollutant  loading  and  removal
  estimates.
                                             6-2

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Chapter 6 Pollutants of Concern for the CWT Industry
                                             Development Document for the CWT Point Source Category
      /Total list of pollutants analyzed for each \
      I  influent sample at each sampling episode J
              for a single subeategory	/
                 Was the pollutant
             ever detected in any sample?
    Was the pollutant
detected at a concentration
    10 times, the method
     detection limit?
                     Was the
                pollutant detected at a
         concentrations 10 tones the method
              detection limit in at least
                    10 % of the
                         pies?
                                                  Pollutant is not a POC for the
                                                         subeategory
                                                               Pollutant is not a POC for the
                                                                       subeategory
                                                  Pollutant is not a POC for the
                                                         subeategory
         Pollutant is 4 POC for the subeategory
  Figure 6-1.  Pollutant of Concern Methodology
                                                         6-3

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Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-1. Pollutants of Concern for the Metals Subcategory

# Times
Cas No. Analyzed
MDL # Detects
# Detects (ug/1) >10xMDL
CLASSICALS OR CONVENTIONALS
Amenable Cyanide
Ammonia as Nitrogen
BOD 5-Day
COD
Chloride
Fluoride
Hexavalent Chromium
Nitrate/Nitrite
SGT-HEM
Total Cyanide
TDS
TOC
Total Phenols
Total Phosphorus
Oil & Grease
Total Sulfide
TSS
METALS
Aluminum
Antimony
Aiscnic
Barium
Bciyllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Gallium
Indium
Iodine
Indium
Iron
Lead
Lithium
Magnesium
Manganese
Mercury
Molybdenum
Ncodymium
Nickel
Niobium
Osmium
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
C-025
7664417
C-002
C-004
16887006
16984488
18540299
C-005
C-037
57125
C-010
C-012
C-020
14265442
C-007
18496258
C-009

7429905
7440360
7440382
7440393
7440417
7440428
7440439
7440702
7440473
7440484
7440508
7440553
7440746
7553562
7439885
7439896
7439921
7439932
7439954
7439965
7439976
7439987
7440008
7440020
7440031
7440042
7723140
7440097
7782492
7440213
7440224
7440235
21
51
49
50
12
51
39
51
6
26
12
51
46
46
43
46
51

51
51
51
51
51
51
51
51
51
51
51
26
25
25
25
51
51
26
51
51
51
51
24
51
26
24
25
26
51
26
51
51
15
51
42
50
12
51
28
50
5
22
12
49
41
45
37
16
51

48
33
35
36
25
50
49
51
51
39
51
9
10
10
13
51
50
16
44
50
39
51
7
51
6
11
21
25
24
24
42
51

20
10
2,000
5,000
1,000
100
10
50
5,000
20

1,000
50
10
5,000
1,000
4,000

200
20
10
200
5
100
5
. 5,000
10.
50
25
500
1,000
1,000
1,000
100
50
100
5,000
15
0
10
500
40
1,000
100
1,000
1,000
5
100
10
5,000

15
51
37
50
12
48
19
49
3
22
12
49
10
45
15
9
50

47
29
31
8
9
50
49
46
51
33
51
5
6
10
11
51
49
12
27
49
31
50
3
51
3
4
19
25
18
22
39
51
Minimum
Cone.
(mg/1)
0.00027
0.00040
0.00400
0.06800
0.26200
0.00012
0.00000
0.00030
0.00630
0.00030
13.00000
0.05500
0.00001
0.00030
0.00450
0.00008
0.01000
(ug/1)
723.0
29.0
17.0
7.1
1.7
1,300.0
83.0
6,630.0
661.0
49.0
756.0
1,125.0
800.0
23,800.0
400.0
3,140.0
208.0
129.0
9,330.0
84.0
1.3
14.0
480.0
6,190.0
600.0
149.0
1,730.0
15,100.0
10.0
111.0
13.0
469,500.0
Maximum
Cone.
(mg/1)
2.9000
1.0000
11.0000
86.0000
62.0000
28.0000
40.0000
40.0000
0.0430
8.4000
177.0000
19.0000
0.0029
15.0000
0.1430
1.1000
141.0000
(ug/1)
2,080,000.0
1,160,000.0
1,220,000.0
596,000.0
296.0
1,420,000.0
19,300,000.0
9,100,000.0
65,000,000.0
10,900,000.0
40,200,000.0
36,350.0
61,200.0
537,000.0
253,000.0
7,745,000.0
3,220,000.0
795,000.0
2,980,000.0
6,480,000.0
3,100.0
1,390,000.0
58,400.0
2,460,000.0
57,300.0
21,800.0
2,550,000.0
9,720,000.0
11,800.0
1,330,000.0
130,000.0
77,700,000.0
                                                   6-4

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Chapter 6 Pollutants of Concern for theCWT Industry
Development Document for the CWT Point Source Category
Table 6-1. Pollutants of Concern for the Metals Subcategory
Pollutant
Strontium
Sulfur
Tantalum
Tellurium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANICS
Benzoic Acid
Benzyl Alcohol
Bis(2-Ethylhexyl)Phthalate
Bromodichloromethane
Carbon Bisulfide
Chloroform
Dibromochloromethane
Hexanoic Acid
Methylene Chloride
N-Nitrosomorpholine
N,N-Dimelhylformamide
Pyridine
Tribromomethane
Trichloroethene
Tripropyleneglycol Methyl Ether
2-Butanone
2-Propanone
# Times
Cas No. Analyzed
7440246
7704349
7440257
13494809
7440280
7440315
7440326
7440622
7440655
7440666
7440677

65850
100516
117817
75274
75150
67663
124481
142621
75092
59892
68122
110861
75252
79016
20324338
78933.
67641
26
25
24
24
51
51
51
51
51
51
26

13
13
13
13
13
13
13
13
13
13
13
13
13
13
13
13
13
MDL # Detects Minimum
# Detects (ug/1) >10xMDL Cone.
17
25
7
4
17
44
42
31
38
50
11

13
5
7
3
2
5
3
7
11
3
5
5
3
4
3
4
13
100
1,000
500
1,000
10
30
5
50
5
20
100

50
10
10
10
10
10
10
10
10
10
10
10
10
10
99
50
50
12
25
3
3
11
43
40
22
29
50
5

12
4
6
2
2
3
3
6
8
2
3
3
2
3
2
3
11
202.0
157,000.0
1,270.0
11,700.0
14.0
145.0
36.0
22.0
3.0
2,512.0
200.0
(ug/0
193.0
13.0
18.0
90.0
186.0
161.0
105.0
99.0
11.0
50.0
126.0
140.0
72.0
122.0
147.0
65.0
105.0
Maximum
Cone.
16,300.0
33,300,000.0
20,000.0
182,000.0
275,000.0
15,100,000.0
7,500,000.0
364,000.0
900.0
16,400,000.0
4,860.0
(ug/0
36,756.0
7,929.0
1,063.0
704.0
449.0
731.0
723.0
1,256.0
734.0
167.0
301.0
1,684.0
338.0
360.0
3,212.0
7,826.0
54,083.0
                                                  6-5

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-2.  Pollutants of Concern for the Oils Subcategory
Pollutant
# Times
Cas No. Analyzed
# Detects
MDL # Detects Minimum
(ug/l)>10xMDL " Cone.
CLASSICALS OR CONVENTIONALS
Amenable Cyanide
Ammonia as Nitrogen
BOD 5-Day
BOD
COD
Chloride
Fluoride
Nitrate/Nitrite
SGT-HEM
Total Cyanide
IDS
TOC
Total Phenols
Total Phosphorus
Oil & Grease
TSS
METALS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Chromium
Cobalt
Copper
Germanium
Iron
Lead
Lutetium
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tin
Titanium
Vanadium
Zinc
ORGANICS
Acenaphthene
C-025
7664417
C-002
C-003
C-004
16887006
16984488
C-005
C-037
57125
C-010
C-012
C-020
14265442
C-007
C-009

7429905
7440360
7440382
7440393
7440417
7440428
7440439
7440702
7440473
7440484
7440508
7440564
7439896
7439921
7439943
7439954
7439965
7439976
7439987
7440020
7723140
7440097
7782492
7440213
7440224
7440235
7440246
7704349
7440315
7440326
7440622
7440666

83329
3
24
19
9
28
14
24
24
14
13
18
28
24
24
28
28

28
28
28
28
28
28
28
28
28
28
28
19
28
28
19
28
28
28
28
28
17
19
28
19
28
28
19
17
28
28
28
28

28
3
24
19
9
28
14
23
23
14
12
18
28
24
24
28
28

26
20
26
28
7
28
22
28
28
18
27
2
28
27
3
28
28
20
24
27
17
19
15
19
15
27
13
17
16
16
17
28

6
20
10
2,000
2,000
5,000
1,000
100
50
5,000
20

1,000
50
10
5,000
4,000

200
20
10
200
5
100
5
5,000
10
50
25
500
100
50
100
5,000
15
0
10
40
1,000
1,000
5
100
10
5,000
100
1,000
30
5
50
20

10
1
24
19
9
28
14
19
23
14
5
18
28
24
24
28
26

22
7
18
11
3
28
19
23
19
14
21
2
27
18
3
17
28
14
23
18
16
19
12
19
3
27
8
17
13
14
3
25

6
(mg/1)
0.00003
0.02000
0.50000
3.60000
0.00140
0.01900
0.00012
0.00050
0.35400
0.00002
1.30000
0.29800
0.00280
0.00065
0.03800
0.03400
(ug/1)
213.0
27.0
46.0
33.0
0.8
2,170.0
8.6
27,700.0
9.2
8.5
11.0
10,250.0
494.0
34.0
1,165.0
4,910.0
535.0
0.3
15.0
77.0
4,033.0
23,550.0
11.0
1,862.0
8.0
219,000.0
128.0
90,600.0
127.0
29.0
14.0
34.0
(ug/0
105.0
Maximum
Cone.
(mg/1)
0.00025
1.90000
26.00000
20.00000
120.00000
6.20000
0.33000
0.10300
3.70000
0.00098
33.00000
157.00000
0.18500
19.00000
180.00000
22.00000
(ug/0
192,580.0
1,670.0
9,170.0
7,049.0
113.0
1,710,000.0
498.0
572,750.0
7,178.0
116,000.0
80,482.0
12,360.0
630,000.0
21,725.0
1,315.0
753,000.0
' 44,500.0
56.0
12,400.0
62,800.0
239,000.0
2,880,000.0
1,000.0
87,920.0
7,740.0
11,100,000.0
3,470.0
3,712,000.0
6,216.0
1,407.0
2,000.0
94,543.0
(ug/1)
13,418.0
                                                  6-6

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-2. Pollutants of Concern for the Oils Subcategory
Pollutant
Alpha-TerpineoI
Aniline
Anthracene
Benzene
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzoic Acid
Benzyl Alcohol
Biphenyl
Bis(2-Ethylhexyl)Phthalate
Butyl Benzyl Phthalate
Carbazole
Carbon Disulfide
Chlorobenzene
Chlorofonn
Chrysene
Di-N-Butyl Phthalate
Dibenzofuran
Dibenzothiophene
Diethyl Phthalate
Diphenyl Ether
Ethylbenzene
Fluoranthene
Fluorene
Hexanoic Acid
M-Xylene
Methylene Chloride
N-Decane
N-Docosane
N-Dodecane
N-Eicosane
N-Hexacosane
N-Hexadecane
N-Octadecane
N-Tetracosane
N-Tetradecane
N,N-Dimethylformamide
Naphthalene
O+P Xylene
O-Cresol
P-Cresol
P-Cymene
Pentamethylbenzene
Phenanthrene
Phenol
Pyrene
Pyridine
Styrene
Tetrachloroethene
Toluene
# Times
Cas No. Analyzed
98555
62533
120127
71432
56553
50328
205992
207089
65850
100516
92524
117817
85687
86748
75150
108907
67663
218019
84742
132649
132650
84662
101848
100414
206440
86737
142621
108383
75092
124185
629970
112403
112958
630013
544763
593453
646311
629594
68122
91203
136777612
95487
106445
99876
700129
85018
108952
129000
110861
100425
127184
108883
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
# Detects
10
5
10
28
11
4
6
4
24
7
15
13 '
6
8
14
11
12
11
4
5
9
10
7
28
13
9
22
23
25
24
18
24
26
9
26
25
10
26
5
25
23
11
18
6
7
18
25
12
9
5
19
28
MDL # Detects
(ug/l)>10xMDL
10
10
10
10
10
10
10
10
50
10
10
10
10
20
10
10
10
10
10
10
10
10
10.
10
10
10
10
10
10
10
10
10
10
io
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
8
4
10
24
8
3
5
3
24
3
11
9
4
5
6
6
12
9
3
4
9
10
5
25
12
6
21
22
16
22
14
24
23
6
26
22
4
24
3
23
18
10
18
6
4
14
23
12
6
'5
18
26
Minimum
Cone.
57.0
142.0
110.0
70.0
67.0
65.0
38.0
38.0
3,458.0
40.0
36.0
33.0
118.0
48.0
11.0
12.0
160.0
88.0
104.0
117.0
128.0
145.0
149.0
14.0
47.0
73.0
56.0
24.0
13.0
62.0
17.0
125.0
58.0
16.0
160.0
47.0
18.0
78.0
83.0
152.0
14.0
142.0
220.0
232.0
116.0
12.0
1,351.0
113.0
14.0
289.0
24.0
51.0
Maximum
Cone.
2,245.0
367.0
18,951.0
20,425.0
6,303.0
6,670.0
5,752.0
5,752.0
163,050.0
783.0
10,171.0
838,450.0
49,069.0
1,459.0
2,335.0
326.0
1,828.0
8,879.0
1,262.0
13,786.0
5,448.0
9,309.0
13,751.0
18,579.0
28,873.0
15,756.0
90,080.0
32,639.0
10,524.0
579,220.0
15,354.0
472,570.0
319,080.0
9,561.0
1,367,970.0
901,920.0
10,289.0
2,560,460.0
803.0
53,949.0
16,584.0
8,273.0
2,382.0
4,452.0
11,186.0
49,016.0
48,640.0
22,763.0
1,280.0
843.0
12,789.0
99,209.0
                                                  6-7

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-2.  Pollutants of Concern for the Oils Subcategory
Pollutant
Trichloroethene
Tripropyleneglycol Methyl Ether
1-Methylfluorene
l-Methy]phenanthrene
1,1-Dichloroethene
1,1, 1-Trichloroethane
1,2-Dichloroethane
1 ,2,4-Trichlorobenzene
1 ,4-Dichlorobenzene
1,4-Dioxane
2-Butanone
2-Methyinaphthalene
2-Phenylnaphthalene
2-Propanone
2,3-Benzofluorene
2,4-Dimethylphenol
3,6-Dimethylphenanthrene
4-Chloro-3-Methylphenol
4-Methvl-2-Pentanone
# Times
Cas No. Analyzed
79016
20324338
1730376
832699
75354
71556
107062
120821
106467
123911
78933
91576
612942
67641
243174
105679
1576676
59507
108101
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
28
# Detects
15
11
8
10
7
23
12
8
7
3
26
22
4
27
6
10
5
16
22
MDL # Detects
(ug/l)>10xMDL
10
99
10
10
10
10
10
10
10
10
50
10
10
50
10
10
10
10
50
9
9
6
8
6
19
9
8
7
3
24
16
3
27
5
7
5
14
14
Minimum
Cone.
18.0
1,495.0
42.0
92.0
11.0
10.0
14.0
359.0
454.0
189.0
57.0
80.0
30.0
974.0
162.0
76.0
114.0
460.0
199.0
Maximum
Cone.
7,125.0
383,151.0
5,803.0
7,111.0
1,968.0
14,455.0
713.0
18,899.0
2,334.0
1,323.0
178,748.0
46,108.0
543.0
2,099,340.0
2,755.0
2,171.0
2,762.0
. 83,825.0
20.489.0
                                                 6-8

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-3. Pollutants of Concern for the Organics Subcategory
Pollutant
# Times
Cas No. Analyzed
MDL # Detects Minimum
# Detects (ug/L) >10 xMDL Cone.
CLASSICALS OR CONVENTIONALS
Amenable Cyanide
Ammonia as Nitrogen
BOD 5-Day
COD
Fluoride
Nitrate/Nitrite
Total Cyanide
TOC
Oil & Grease
Total Sulfide :
TSS
METALS
Aluminum
Antimony
Arsenic
Barium
Boron
Calcium
Chromium #
Cobalt
Copper
Iodine
Iron
Lead
Lithium
Manganese
Molybdenum
Nickel
Phosphorus
Potassium
Silicon
Sodium
Strontium
Sulfur
Tin
Titanium
Zinc
ORGANICS
Acetphenone
Aniline
Benzene
Benzole Acid
Bromodichlororrtethane
Carbon Disulfide
Chlorobenzene
Chloroform
Diethyl Ether
Dimethyl Sulfone
Ethane, Pentachloro-
Ethylenethiourea
Hexachloroethane
Hexanoic Acid
C-025
7664417
C-002
C-004
16984488
C-005
57125
C-012
C-007
18496258
C-009

7429905
7440360
7440382
7440393
7440428
7440702
7440473 '
7440484
7440508
7553562
7439896
7439921
7439932
7439965
7439987
7440020
7723140
7440097
7440213
7440235
7440246
. 7704349
7440315
7440326
7440666

98862
62533
71432
65850
75274
75150
108907
67663
60297
67710
76017
96457
67721
142621
5
5
5
' 5
5
5
5
5
5
5
5

5
5
5
5
5'
5
5
5
5
4
5
5
5
5
5
5
4
5
5
5
5
5
5
5
5

5
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
5
5
4
5
5
5
3
5

5
4
5
5
5
5
4
4
5
4-
5
4
5
5
5
5
4
5
5
5
5
5
4
5
5

4
2
5
2
5
4
4
4
4
3
2
2
2
3
20
10
2,000
5,000
100
50
20
1,000
5,000
1,000
4,000

200
20
10
200
100
5,000
10
50
25
1,000
100
50
100
15
10
40
1,000
1,000
100
5,000
100
1,000
30
5
20

10
10
10
50
10
10
10
10

10
20
20
10
10
3
5
5
5-
2
4
5
5
1
2
4

4
3
1
2
5
5
2
3
4
1
5
1
5
5'
4
4
1
5
5
5
5
5
.2
1
4

4
2
3
2
1
1
1
4
4
3
1
2
2
3
(mg/1)
0.00014
0.08300
0.79000
1.40000
0.00060
0.10000
0.00080
0.51000
0.00220
0.00400
0.03300
(ug/1)
148.0
146.0
8.3
1,030.0
2,950.0
1,025,000.0
63.0
253.0
7.0
3,800.0
2,360.0
109.0
1,100.0
179.0
33.0
55.0
3,000.0
383,000.0
1,500.0
2,470,000.0
3,900.0
12,800.0
200.0
9.0
40.0
(ug/1)
336.0
178.0
31.0
5,649.0
26.0
14.0
70.0
5,224.0
182.0
315.0
79.0
8,306.0
75.0
1,111.0
Maximum
Cone.
(mg/1)
0.00620
2.40000
7.60000
11.00000
0.00200
0.34000
0.00780
3.80000
0.04800
0.02400
3.70000
(ug/1)
7,660.0
1,540.0
152.0
136,000.0
4,320.0
1,410,000.0
274.0
731.0
2,690.0
15,100.0
6,430.0
687.0
18,750.0
513.0
6,950.0
2,610.0
15,900.0
1,240,000.0
3,600.0
6,390,000.0
14,000.0
1,990,000.0
2,530.0
64.0
1,210.0
(ug/1)
739.0
392.0
179.0
15,760.0
197.0
1,147.0
101.0
32,301.0
211.5
892.0
135.0
9,655.0
101.0
4,963.0
                                                     6-9

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-3. Pollutants of Concern for the Organics Subcategory
Pollutant
Isopborone
M-Xylene
Melhylene Chloride
N,N-Dimethylfomiamide
CH-PXylene
O-Cresol
P-Cresol
Pentachlorophenol
Phenol
Pyridinc
Tetrachloroethene
Tetrachloromethane
Toluene
Trans- 1 ,2-Dichloroethene
Trichloroethene
Vinyl Chloride
1,1-Dichloroethane
1,1-DichIoroethene
1,1,1-Trichloroethane
1,1,1,2-Tetrachloroethane
1 ,1 ,2-Trichloroethane
1,1,2,2-Tetrachloroethane
1,2-Dibromoethane
1 ,2-Dichlorobenzene
1,2-Dichloroethane
1,2,3-Trichloropropane
1,3-DichIoropropane
2-Butanone
2-Picoline
2-Propanone
2^-Dichloroaniline
2^,4,6-Tetrachlorophenol
2,4-DimethyIphenol
2,4,5-TrichIorophenol
2,4,6-Trichlorophenol
3,4,5-Trichlorocatechol
3,4-Dichlorophenol
3,4,6-Trichloroguaiacol
3,5-Dichlorophenol
3,6-Dichlorocatechol
4-Chlorophenol
4-Methyl-2-Pentanone
4,5-Dichloroguaiacol
4,5,6-Triehloroguaiacol
5-Chloroguaiacol
6-Chlorovanillin
# Times
Cas No. Analyzed
78591
108383
75092
68122
136777612
95487
106445
87865
108952
110861
127184
56235
108883
156605
79016
75014
75343
75354
71556
630206
79005
79345
106934
95501
107062
96184
142289
78933
. 109068
67641
608275
58902
105679
95954
88062
56961207
95772
60712449
591355
3938167
106489
108101
2460493
2668248
3743235
18268763
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
# Detects
2
5
4
3
5
4
4
5
4
5
4
5
5
5
4
5
5
5
5
5
5
1
5
1
4
5
1
5
3
5
3
 5
1
5
5
2
4
3
3
1
1
5
1
2
1
1
MDL # Detects Minimum
(ug/L) >10xMDL Cone.
10
10
10
10
10
10
10
50
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
50

50
10
20
10
10
10
1
1




50




1
1
4
2
1
4
4
4
4
4
4
5
5
5
4
5
2
5
4
5
5
1
5
1
4
4
1
5
2
5
3
5
1'
4
4
1
4
1
3


4



1
60.0
45.0
 2,596.0
23.0
13.0
7,162.0
220.0
25.0
483.0
29.0
2,235.0
1,862.0
148.0
1,171.0
3,551.0
290.0
23.0
112.0
74.0
249.0
776.0
8,602.0
297.0
479.0
855.0
100.0
286.0
894.0
54.0
1,215.0
109.0
594.0
683.0
50.0
50.0
0.002
0.070
0.007
0.040
0.010
7.800
290.000
0.010
0.004
2.400
0.040
Maximum
Cone.
141.0
310.0
87,256.0
225.0
113.0
14,313.0
911.0
677.0
9,491.0
444.0
19,496.0
16,126.0
2,053.0
5,148.0
23,649.0
1,226.0
108.0
461.0
320.0
2,573.0
6,781.0
8,602.0
6,094.0
479.0
5,748.0
839.0
286.0
5,063.0
187.0
12,435.0
636.0
2,698.0
683.0
289.0
546.0
0.050
0.470
0.020
0.170
0.010
7.800
4,038.000
0.010
0.060
2.400
0.040
                                                  6-10

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
METALS
Bismuth
Cerium
Erbium
Europium
Gadolinium
Germanium
Gold
Hafnium
Holmium
Lanthanum
Lutetium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Terbium
Thorium
Thulium
Tungsten
Uranium
Ytterbium
Organics
Acenaphthene
Acenaphthylene
Acetophenone
Acrylonitrile
Adsorbable Organic Halides
Alpha-Terpineol
Aniline
Aniline, 2,4,5-Trimethyl
Anthracene
Aramite
Benzathrone
Benzene
Benzenethiol
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(ghi)perylene
Benzo(k)fluoranthene
Benzonitrile, 3,5-Dibromo-4-Hydroxy-
Beta-Naphthylamine
Biphenyl
Biphenyl, 4-Nitro
Bis(2-Chloroethoxy) Methane
Bis(2-Chloroethyl) Ether
Bis(2-Chloroisopropyl) Ether
Bromomethane
Butyl Benzyl Phthalate
Carbazole
Chloroacetonitrile
Cas No.

7440699
7440451
7440520
7440531
7440542
7440564
7440575
7440586
7440600
7439910
7439943
7440053
7440064
7440100
7440155
7440J66
7440188
7440199
7440202
7440279
7440291
7440304
7440337
7440611
7440644

83329
208968
98862
107131
59473040
98555
62533
137177
120127
140578
82053
71432
108985
92875
56553
50328
205992
191242
207089
1689845
91598
92524
92933
111911
111444
108601
74839
85687
86748
107142
Never
Detected









X






X



X

X




X
X

X



X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
Detected
<10xMDL

X
X

X

X

X


X

X

X


X
X

X


X
X



X

X
X
X














X








Detected in <10%
of infuent samples



X

X

X


X

X

X


X





X

































                                                  6-11

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4.  Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
Chlorobenzene
Chloroethane
Chloromethane
Chrysene
Cis-1 ,3-Dichloropropene
Crotonaldehyde
Crotoxyphos
Di-N-Butyl Phthalate
Di-N-Octyl Phthalate
Di-N-Propylnitrosamine
Dibenzo(a,h)anthracene
Dibenzofuran
Dibenzothiophene
Dibromomethane
Diethyl Ether
Diethyl Phthalate
Dimethyl Phthalate
Dimethyl Sulfone
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Ethane, Pentachloro-
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylbenzene
Ethylenethiourea
Fluoranthene
Euorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene
Indeno(l,2,3-CD)pyrene
lodomethane
Isobutyl Alcohol
Isophorone
Isosafrole
Longifolene
M-Xylene
Malachite Green
Mestranol
Methapyrilene
Methyl Methacrylate
Methyl Methanesulfonate
N-Decane
NrDocosane
N-Dodecane
N-Eicosane
N-Hexacosane
N-Hexadecane
N-Nitrosodi-N-Butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylethylamine
Gas No.
108907
75003
74873
218019
10061015
4170303
7700176
84742
117840
621647
53703
132649
132650
74953
60297
84662
131113
67710
101848
122394
882337
76017
107120
97632
62500
100414
96457
206440
86737
118741
87683
77474
67721
1888717
193395
74884
78831
78591
120581
475207
108383
569642
72333
91805
80626
66273
124185
629970
112403
112958
630013
544763
924163
55185
62759
86306
10595956
Never
Detected
X
X
X

X
X
X
X
X
X
X

X
X

X
X

X
X
X
X
X
X
X

X


X
X
X
X
X
X
X
X

X
X

X
X
X
X
X
'





X


X
X
Detected Detected in <1 0%
<10 x MDL of infuent samples



X







X


X


X







X

X
X








X


X





X
X
X
X
X
X

X
X


                                                 6-12

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
N-Nitrosomethylphenylamine
N-Nitrosopiperidine
N-Octacosane
N-Octadecane
N-Tetracosane
N-Tetradecane
N-Triacontane
Naphthalene
Nitrobenzene
O+P Xylene
O-Anisidine
O-Cresol
O-Toluidine
O-Toluidine, 5-Chloro-
P-Chloroaniline
P-Cresol
P-Cymene
P-Dimethylaminoazobenzene
P-Nitroaniline
Pentachlorobenzene
Pentachlorophenol
Pentamethylbenzene
Perylene
Phenacetin
Phenanthrene
Phenol
Phenol, 2-Methyl-4,6-Dinitro-
Phenothiazine
Pronamide
Pyrene
Resorcinol
Safrole
Squalene
Styrene
Tetrachloroethene
Tetrachloromethane
Thianaphthene
Thioacetamide ,
Thioxanthe-9-One
Toluene
Toluene, 2,4-Diamino-
Trans-l,2-Dichloroethene
Trans- 1 ,3-Dichloropropene
Trans-l,4-Dichloro-2-Butene
Trichlorofluoromethane
Triphenylene
Vinyl Acetate
Vinyl Chloride
l-Bromo-2-Chlorobenzene
l-Bromo-3-Chlorobenzene
1 -Chloro-3-Nitrobenzene
1-Methylfluorene
1 -M ethy Iphenanthrene
1-Naphthylamine
1 -Pheny Inaphthalene
1 , 1 -Dichloroethane
1 , 1 -Dichloroethene
CasNo.
614006
100754 
630024
593453
646311
629594
638686
91203
98953
136777612
90040
95487
95534
95794
106478
106445
99876
60117
100016
608935
87865
700129
198550
62442
85018
108952
534521
92842
23950585
129000
108463
94597
7683649
100425
127184
56235
95158
62555
492228
108883
95807
156605
10061026
110576
75694
217594
108054
75014
694804
108372
121733
1730376
832699
134327
605027
75343
75354
Never
Detected
X
X








X
X
X
X
X
X
X
X
X
X

X
X
X


X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Detected
<10xMDL


X
X
X
X
X
X
X
X














X
X













X

















Detected in <10%
of infuent samples




















X




































                                                 6-13

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory

1,1,1-Trichloroethane
1,1,1,2-Tetrachloroethane
1,1,2-Trichloroethane
1,1,2,2-Tetrachloroethane
l,2-Dibromo-3-Chloropropane
1 ,2-Dibromoethane
1,2-Dichlorobenzene
1,2-Dichloroethane
1,2-Dichloropropane
1,2-Diphenylhydrazine
1,2,3-Trichlorobenzene
1,2,3-Trichloropropane
1,2,3-Trimethoxybenzene
1,2,4-Trichlorobenzene
1,2,4,5-Tetrachlorobenzene
l,2:3,4-Diepoxybutane
1,3-Butadiene, 2-Chloro
l,3-Dichloro-2-Propanol
1,3-Dichlorobenzene
1,3-Dichloropropane
1,3,5-Trithiane
1,4-Dichlorobenzene
1,4-Dinitrobenzene
1,4-Dioxane
1 ,4-Naphthoquinone
1,5-Naphthalenediamine
2-(Methylthio)Benzothiazole
2-Chloroethylvinyl Ether
2-Chloronaphthalene
2-Chlorophenol
2-Hexanone
2-Isopropylnatphthalene
2-Methylbenzothioazole
2-Methylnaphthalene
2-Nitroaniline
2-Nitrophenol
2-Phenylnaphthalene
2-Picoline
2-Propen-l-Ol
2-Propenal
2-Methyl-2-Propenenitrile
2,3-Benzofluorene
2,3-Dichloroaniline
2,3-Dichloronitrobenzene
2,3,4,6-Tetrachlorophenol
2,3,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,6-Di-Tert-Butyl-P-Benzoquinone
2,6-Dichloro-4-Nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
3-Chloropropene
Cas No.
71556
630206
79005
79345
96128
106934
95501
107062
78875
122667
87616
96184
634366
120821
95943
1464535
126998
' 96231
541731
142289
291214
106467
100254
123911
130154
2243621
615225
110758
91587
95578
591786
2027170
120752
91576
88744
88755
612942
109068
107186
107028
126987
243174
608275
3209221
58902
933755
120832
105679
51285
121142
95954
88062
719222
99309
87650
606202
107051
Never Detected Detected in <10%
Detected <10 x MDL of infuent samples
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
                                                  6-14

-------
Chapter 6 Pollutants of Concern for the CWT Industry
       Development Document for the CWT Point Source Category
Table 6-4. Pollutants Not Selected as Pollutants of Concern for the Metals Subcategory
Pollutant
Cas No.
                                                           Never     Detected
                                                          Detected   <10 x MDL
                      Detected in <10%
                      of infuent samples
3-Methylcholanthrene
3-Nitroaniline
3,3'-Dichlorobenzidine
3,3'-Dimethoxybenzidine
3,6-Dimethylphenanthrene
4-Aminobiphenyl
4-Bromophenyl Phenyl Ether
4-Chloro-2-Nitroaniline
4-Chloro-3-Methylphenol
4-Chlorophenylphenyl Ether
4-Methyl-2-Pentanone
4-Nitrophenol
4,4-Methylene-Bis(2-Chloroaniline)
4,5-Methylene-Phenanthrene
5-Nilro-O-Toluidine
7,12-Dimethylbenz(a)anthracene
56495
99092
91941
119904
1576676
92671
101553
89634
59507
7005723
108101
100027
101144
203645
99558
57976
X
X
X
X
X
X
X
X
X
X
X
X
X
X
            X
            X
                                                  6-15

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5.  Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
CLASSICALS OR CONVENTIONALS
Hexavalent Chromium
Total Sulfide
METALS
Bismuth
Cerium
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Gold
Hafnium
Holmium
Indium
Iodine
Indium
Lanthanum
Lithium
Neodymium
Niobium
Osmium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium ,
Scandium
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Tungsten
Uranium
Ytterbium
Yttrium
Zirconium
ORGANICS
Acenaphthylene
Acetophenone
Acrylonitrile
Aniline, 2,4,5-Trimethyl
Aramite
Benzathrone
Benzenethiol
Benzidine
Benzo(ghi)perylene
Benzonitrile, 3,5-Dibromo-4-Hydroxy-
Beta-Naphthylamine
Biphenyl, 4-Nitro
Bis(2-Chloroethoxy) Methane
Bis(2-Chloroethyl) Ether
Never
Cas No. Detected

18540299
18496258

7440699
7440451
7429916
7440520
7440531
7440542
7440553
7440575
7440586
7440600
7440746
7553562
7439885
7439910
7439932
7440008
7440031
7440042
7440053
7440064
7440100
7440155
7440166
7440188
7440199
7440202
7440257
13494809
7440279
7440280
7440291
7440304
7440337
7440611
7440644
7440655
7440677

208968
98862
107131
137177
140578
82053
108985
92875
191242
1689845
91598
92933
111911
111444






X
X
X
X
X
X
X
X
X
X

X

X
X
X
X

X

X
X
X
X


X

X
X

X






X
X
X
X
X
X

X
X
X
X
X
Detected Detected in <10%
<1 0 x MDL of infuent samples


X

X
X

















X

X





X

X


X

X
X
X









X






X




,









X

X











X











X
X












                                                6-16

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5 . Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
Bis(2-Chloroisopropyl) Ether
Bromodichloromethane
Bromomethane
Chloroacetonitrile
Chloroethane
Chloromethane
Cis-l,3-Dichloropropene
Crotonaldehyde
Crotoxyphos
Di-N-Ocryl Phthalate
Di-N-Propylnitrosamine 
Dibenzo(a,h)anthracene
Dibromochloromethane
Dibromomethane
Diethyl Ether
Dimethyl Phthalate
Dimethyl Sulfone
Diphenylamine
Diphenyldisulfide
Ethane, Pentachloro-
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylenethiourea
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachloropropene
Indeno(l,2,3-CD)pyrene
lodomethane
Isobutyl Alcohol
Isophorone
Isosafrole
Longifolene
M+PXylene
Malachite Green
Mestranol
Methapyrilene
Methyl Methacrylate
Methyl Methanesuifonate
N-Nitrosodi-N-Butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylethylamine
N-Nitrosomethylphenylamine
N-Nitrosomorpholine
N-Nitrosopiperidine
N-Octacosane
N-Triacontane
Nitrobenzene
O-Anisidine
O-Toluidine
O-Toluidine, 5-Chloro-
O-Xylene
Never Detected
CasNo. Detected <10xMDL
108601
75274
74839
107142
75003
74873
10061015
4170303
7700176
117840
621647
53703
124481
74953
60297
.131113
67710
122394
882337
76017
107120
97632
62500
96457
118741
87683
77474
67721
1888717
193395
74884
78831
78591
120581
475207
179601231
569642
72333
91805
80626
66273
924163
55185
62759
86306
10595956
614006
59892
100754
630024
638686
98953
90040
95534
95794
95476
X
X'
X
X
X
X
X
X
X

X
X
X
X


X

X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
X
X
X
X
~
X
X
X
X
X

X
X
X

X
X
Detected in <10%
of infuent samples









X




X
X

X














X










X





X



X


                                                  6-17

-------
Chanter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
P-Chloroaniline
P-Dimethylaminoazobenzene
P-Nitroaniline
Pentachlorobenzene
Pentachlorophenol
Perylene
Phenacetin
Phenol, 2-Methyl-4,6-Dinitro-
Phenothiazine
Pronamide
Resorcinol
Safrole
Squalene
Tetrachloromethane
Thianaphthene
Thioacetamide
Thioxanthe-9-One
Toluene, 2,4-Diamino-
Trans-l,2-Dichloroethene
Trans-l,3-Dichloropropene
Trans-l,4-Dichloro-2-Butene
Tribromomethane
Trichlorofluoromethane
Triphenylene
Vinyl Acetate
Vinyl Chloride
l-Bromo-2-Chlorobenzene
l-Bromo-3-Chlorobenzene
l-Chloro-3-Nitrobenzene
1 -Naphthylamine
1 -Phenylnaphthalene
1,1-Dichloroethane
1,1,1 ,2-Tetrachloroethane
1 , 1 ,2-Trichloroethane
1 , 1 ,2,2-Tetrachloroethane
l,2-Dibromo-3-Chloropropane
1,2-Dibromoethane
1,2-Dichlorobenzene
1,2-Dichloropropane
1 ,2-Diphenylhydrazine
1,2,3-Trichlorobenzene
1,2,3-Trichloropropane
1,2,3-Trimethoxybenzene
1,2,4,5-Tetrachlorobenzene
l,2:3,4-Diepoxybutane .
1,3-Butadiene, 2-Chloro
l,3-Dichloro-2-Propanol
1,3-Dichlorobenzene
1,3-Dichloropropane
1,3,5-Trithiane
1,4-Dinitrobenzene
1 ,4-Naphthoquinone
1,5-Naphthalenediamine
2-(Methylthio)Benzothiazole
2-Chloroethylvinyl Ether
2-Chloronaphthalene
Never Detected Detected in <10%
CasNo. Detected <10xMDL of infuent samples
106478
60117
100016
608935
87865
198550
62442
534521
92842
23950585
108463
94597
7683649
56235
95158
62555
492228
95807
156605
10061026
110576
75252
75694
217594
108054
75014
694804
108372
121733
134327
605027
75343
630206
79005
79345
96128
106934
95501
78875
122667
87616
96184
634366
95943
1464535
126998
96231
541731
142289
291214
100254
130154
2243621
615225
110758
91587
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
x 
X
X
X


X

X
X
X
X
X

X
X
X
X
X

X
X

X
X
X
X
X
X
X
X

X
X
X
X
X
X













X








X
X

X





X





X


X








X






                                                  6-18

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-5. Pollutants Not Selected as Pollutants of Concern for the Oils Subcategory
Pollutant
2-Chlorophenol
2-Hexanone
2-Isopropylnatphthalene
2-Methylbenzothioazole
2-Nitroaniline
2-Nitrophenol
2-Picoline
2-Propen-l-Ol
2-Propenal
2-Propenenitrile, 2-Methyl
2,3-Dichloroaniline
2,3-Dichloronitrobenzene
2,3,4,6-Tetrachlorophenol
2,3,6-Trichlorophenol
2,4-Dichlorophehol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,6-Di-Tert-Butyl-P-Benzoquinone
2,6-Dichloro-4-Nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
3-Chloropropene
3-Methylcholanthrene
3-Nitroaniline
3,3'-Dichlorobenzidine
3,3-Dimethoxybenzidine
4-Amiriobiphenyl
4-Bromophenyl Phenyl Ether
4-Chloro-2-Nitroaniline
4-Chlorophenylphenyl Ether
4-Nitrophenol
4,4'-Methylene-Bis(2-Chloroaniline)
4,5-Methylene-Phenanthrene
5-Nitro-O-Toluidine
7, 1 2-Dimethylbenz(a)anthracene
Cas No.
95578
591786
2027170
120752
88744
88755
109068
107186
107028
126987 .
608275
3209221
58902
933755
120832
51285
121142
95954
88062
719222
99309
87650
606202
107051
56495
99092
91941
119904
92671
101553
89634
7005723
100027
101144
203645
99558
57976
Never
Detected
X


X
X


X

X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
Detected Detected in <1 0%
<10 x MDL of infuent samples

X
X


X
X

X

X























X


                                                 6-19

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
CLASSICALS OR CONVENTIONALS
Hexavalent Chromium
Total Phenols
Total Phosphorus
METALS
Beryllium
Bismuth
Cadmium
Cerium
Dysprosium
Erbium
Europium
Gadolinium
Gallium
Germanium
Gold
Hafnium
Holmium
Indium
Indium
Lanthanum
Lutetium
Magnesium
Mercury
Neodymium
Niobium
Palladium
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Selenium
Silver
Tantalum
Tellurium
Terbium
Thallium
Thorium
Thulium
Tungsten
Uranium
Vanadium
Ytterbium
Yttrium
Zirconium
ORGANICS
Acenaphthene
Acenaphthylene
Acrylonitrile
Alpha-Terpineol
Aniline, 2,4,5-Trimethyl
Anthracene
Aramite
Cas No.

18540299
C-020
14265442

7440417
7440699
7440439
7440451
7429916
7440520
7440531
7440542
7440553
7440564
7440575
7440586
7440600
7440746
7439885
7439910
7439943
7439954
7439976
7440008
7440031
7440053
7440064
7440100
7440155
7440166
7440188
7440199
7440202
7782492
7440224
7440257
13494809
7440279
' 7440280
7440291
7440304
7440337
7440611
7440622
7440644
7440655
7440677

83329
208968
107131
98555
137177
120127
140578
Never
Detected

X
X
X

X
X

X
X
X
X
X

X
X

X


X
X

X
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X

X

X
X
X
X
X
X
X
Detected Detected in <10%
<1 0 x MDL of infuent samples







X





X


X

X
X


X




X
















X

X









                                                  6-20

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
Benzathrone
Benzenethiol
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(b)fluoranthene
Ben2(ghi)perylene
Benzo(k)fluoranthene
Benzonitrile, 3,5-Dibromo-4-Hydroxy-
Benzyl Alcohol
Beta-Naphthylamine
Biphenyl
Biphenyl, 4-Nitro
Bis(2-Chloroethoxy) Methane
Bis(2-Chloroethyl) Ether
Bis(2-Chloroisopropyl) Ether
Bis(2-Ethylhexyl)Phthalate
Bromomethane
Butyl Benzyl Phthalate
Carbazole
Chloroacetonitrile
Chloroethane
Chloromethane
Chrysene
Cis-l,3-Dichloropropene
Crotonaldehyde
Crotoxyphos
Di-N-Butyl Phthalate
Dl-N-Octyl Phthalate
Di-N-Propylnitrosamine
Dibenzo(a,h)anthracene
Dibenzofuran
Dibenzothiophene
Dibromochloromethane
Dibromomethane
Diethyl Ether 
Diethyl Phthalate
Dimethyl Phthalate
Diphenyl Ether
Diphenylamine
Diphenyldisulfide
Ethyl Cyanide
Ethyl Methacrylate
Ethyl Methanesulfonate
Ethylbenzene
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloropropene
Indeno(l,2,3-CD)pyrene
lodomethane
Isobutyl Alcohol
Isosafrole
Longifolene
Cas No.
82053
108985
92875
56553
50328
205992
191242
207089
1689845
100516
91598
92524
92933
111911
111444
108601
117817
74839
85687
86748
107142
75003
74873
218019
10061015
4170303
7700176
84742
117840
621647
53703
132649
132650
124481
74953
60297
84662
131113
101848
122394
882337
107120
97632
62500
100414
206440
86737
1 18741
87683
77474
1888717
193395
74884
78831
120581
475207
Never Detected Detected in <10%
Detected <10xMDL of infiient samples
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
. X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
                                                  6-21

-------
Chapter 6 Pollutants of Concern for the CWT Industry
Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategor>
Pollutant
Malachite Green
Mestranol
Methapyrilene
Methyl Methacrylate
Methyl Methanesulfonate
N-Decane
N-Docosane
N-Dodecane
N-Eicosane
N-Hexacosane
N-Hexadecane
N-Nitrosodi-N-Butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosodiphenylamine
N-Nitrosomethylethylamine
N-Nitrosomethylphenylarnine
N-Nitrosomorpholine
N-Nitrosopiperidine
N-Octacosane
N-Octadecane
N-Tetracosane
N-Tetradecane
N-Triacontane
Naphthalene
Nitrobenzene
O-Anisidine
O-Toluidine
O-Toluidine, 5-Chlorc-
P-Chloroaniline
P-Cymene
P-Dimethylaminoazobenzene
P-Nitroaniline
Pentachlorobenzene
Pentamethylbenzene
Perylene
Phenacetin
Phenanthrene
Phenol, 2-Methyl-4,6-Dinitro-
Phenothiazine
Pronamide
Pyrene
Resorcinol
Safrole
Squalene
Styrene
Tetrachlorocatechol
Tetrachloroguaiacol
Thianaphthene
Thioacetamide
Thioxanthe-9-One
Toluene, 2,4-Diamino-
Trans-l,3-Dichloropropene
Trans-l,4-Dichloro-2-Butene
Tribromomethane
Trichlorofluoromethane
Gas No.
569642
72333
91805
80626
66273
124185
629970
112403
1 12958
630013
544763
924163
55185
62759
86306
10595956
614006
59892
100754
630024
593453
646311
629594
638686
91203
98953
90040
95534
95794
106478
99876
60117
100016
608935
700129
198550
62442
85018
534521
92842
23950585
129000
108463
94597
7683649
100425
1198556
2539175
95158
62555
492228
95807
10061026
110576
75252
75694
Never Detected Detected in <10%
Detected <10xMDL of infuent samples
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X,
X
X
X
X
X
X
. X
X
X
X
X
X
X
X
X
X
X
X
X
X
                                                 6-22

-------
Chapter 6 Pollutants of Concern for the CWT Industry      Development Document for the CWT Point Source Category
Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategoiy
Pollutant
Trichlorosyringol
Triphenylene
Tripropyleneglycol Methyl Ether
Vinyl Acetate
1 -Bromo-2-Chlorobenzene
l-Bromo-3-Chlorobenzene
l-Chloro-3-Nitrobenzene
1-Methylfluorene
1-Methylphenanthrene
1-Naphthylamine
1 -Phenylnaphthalene
l,2-Dibromo-3-Chloropropane
1 ,2-Dichloropropane
1 ,2-Diphenylhydrazine
1 ,2,3-Trichlorobenzene
1,2,3-Trimethoxybenzene
1 ,2,4-Trichlorobenzene
1 ,2,4,5-Tetrachlorobenzene
l,2:3,4-Diepoxybutane
1,3-Butadiene, 2-Chloro
l,3-Dichloro-2-Propanol
1 ,3-Dichlorobenzene
1,3,5-Trithiane
1 ,4-Dichlorobenzene
1,4-Dinitrobenzene
1,4-Dioxane
1 ,4-Naphthoquinone
1,5-Naphthalenediamine
2-(Methylthio)Benzothiazole
2-Chloroethylvinyl Ether
2-Chloronaphthalene
2-Chlorophenol
2-Hexanone
2-Isopropylnatphthalene
2-Methylbenzothioazole
2-Methylnaphthalene
2-Nitroaniline
2-Nitrophenol
2-Phenylnaphthalene
2-Picoline
2-Propen-l-Ol
2-Propenal
2-Propenenitrile, 2-Methyl
2-Syringaldehyde
2,3-Benzofluorene
2,3-Dichloronitfobenzene
2,3,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Di-Tert-Butyl-P-Benzoquinone
2,6-Dichloro-4-Nitroaniline
2,6-Dichlorophenol
2,6-Dinitrotoluene
3-Chloropropene
3-Methylcholanthrene
Cas No.
2539266
217594
20324338
108054
694804
108372
121733
1730376
832699
134327
605027
96128
78875
122667
87616
634366
120821 .
95943
1464535
126998
96231
541731
291214
106467
100254
123911
130154
2243621
615225
110758
91587
95578
591786
2027170
120752
91576
88744
88755
612942
109068
107186
107028
126987
134963
243174
3209221
933755
120832
51285
121142
719222
99309
87650
606202
107051
56495
Never Detected Detected in <10%
Detected < 1 0 x MDL  of infuent samples
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X .
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
                                                 6-23

-------
 Chanter 6 Pollutants of Concern for the CWT Industry
     Development Document for the CWT Point Source Category
 Table 6-6. Pollutants Not Selected as Pollutants of Concern for the Organics Subcategory
Pollutant
3-Nitroaniline
3,3-Dichlorobenzidine
3,3'-Dimethoxybenzidine
3,4,5-Trichloroguaiacol
3,5-Dichlorocatechol
3,6-Dimethylphenanthrene
4-Aminobiphenyl
4-Bromophenyl Phenyl Ether
4-Chloro-2-NitroaniIine
4-Chloro-3-Methylphenol
4-Chloroguaiacol
4-Chlorophenylphenyl Ether
4-Nitrophenol
4J4'-Methylene-Bis(2-Chloroaniline)
4,5-Dichlorocatechol
4,5-Methylene-Phenanthrene
4,6-Dichloroguaiacol
5-Nitro-O-Toluidine
5,6-Dichlorovanillin
7,12-Dimethylbenz(a)anthracene
Gas No.
99092
91941
119904
57057837
13673922
1576676
92671
101553
89634
59507
16766306
7005723
100027
101144
3428248
203645
16766317
99558
18268694
57976
Never
Detected
X
X
X

X
X
X
X
X

X
X
X
X

X
X
X
X
X
Detected Detected in <10%
<1 0 x MDL of infuent samples



X





X




X





 POLLUTANTS OF CONCERN FOR
 THE METALS SUBCATEGORY
6.2
     Wastewaters treated at CWT facilities in the
. metals  subcategory   contain  a   range   of
 conventional,   toxic,   and  non-conventional
 pollutants.  EPA analyzed influent samples for
 320 conventional, classical, metal, and organic
 pollutants.  EPA identified 78  pollutants of
 concern, including 43 metals, 17 organics, and 3
 conventional pollutants as presented in Table 6-1.
 EPA excluded 242 pollutants from further review
 because they did not pass the pollutant of concern
 criteria. Table 6-4 lists these pollutants, including
 178 pollutants that were never detected at any
 sampling  episode,  54  pollutants   that  were
 detected at a concentration less than ten times the
 method detection limit, and 10 pollutants that
 were present  in less than ten percent of the
 influent samples. EPA selected only 25 percent
 of the list of pollutants analyzed as pollutants of
 concern, and as expected, the greatest number of
 pollutants of concern in the metals subcategory
 were found  in the metals group.
    Facilities in the metals subcategory had the
highest occurrence and broadest range of metals
detected in their raw wastewater. The sampling
identified a total  of 43  metals above treatable
levels, compared to 32 metals  in the oils
subcategory, and 25 metals  in the organics
subcategory. Maximum metals concentrations in
the metals subcategory were generally at least an
order of magnitude higher than metals in the oils
and organics subcategories, and were often two to
three orders of magnitude greater.  Wastewaters
contained significant concentrations of common
non-conventional metals such as aluminum, iron,
and tin.   In  addition,  given the processes
generating these Wastewaters, waste receipts in
this subcategory generally contained toxic heavy
metals.   Toxic metals  found in the.  highest
concentrations were cadmium, chromium, cobalt,
copper, nickel, and zinc.
    EPA detected three conventional pollutants
(BOD5, TSS, oil and grease) and fifteen classical
pollutants above treatable levels in the metals
subcategory,  including hexavalent chromium,
which was not found in either the oils or organics
                                             6-24

-------
Chapter 6 Pollutants of Concern for the CWT Industry
     Development Document for the CWTPoint Source Category
subcategories.   Concentrations for total  and
amenable    cyanide,     chloride,    fluoride,
nitrate/nitrite, TDS, TSS, and total sulfide were
significantly higher for metals facilities than for
facilities in the other subcategories.
    While sampling showed organic pollutants at
selected facilities in the metals subcategory, these
were not typically found in wastewaters resulting
from  this subcategory.  Many metals facilities
have  placed  acceptance restrictions  on  the
concentration of organic pollutants allowed in the
off-site  wastestreams.    Of the  217 organic
pollutants analyzed in the metals  subcategory,
EPA  only detected 17 above treatable levels, as
compared to more than 72 in the oils subcategory
and 60 in the organics subcategory.  However, of
the organic compounds detected in the metals
subcategory,       three,      specifically,
dibromochloromethane, tribromomethane, and n-
nitrosomorpholine were not detected in any other
subcategory. EPA sampling detected all other
organic pollutants in the. metals sufacategory at
relatively low concentrations, as compared to the
oils and organics subcategories.
POLLUTANTS OF CONCERN FOR
THE OILS SUBCATEGORY
6.3
    As detailed in Chapters 2 and 12, EPA does
not have data to characterize raw wastewater for
the oils subcategory.  Therefore, EPA based its
influent  wastewater  characterization  for  this
subcategory on an evaluation of samples obtained
following the initial gravity separation/emulsion
breaking step. EPA analyzed these samples for
322 conventional, classical, metal, and organic
pollutants.  EPA identified 120  pollutants of
concern, including 72 organics, 32 metals, and 3
conventional pollutants presented in Table 6-2.
EPA eliminated 202 pollutants after applying its
traditional  criteria  for  regulating  pollutants.
Table 6-5  lists  these pollutants, including  145
pollutants  that were never  detected  at   any
sampling  episode,  31  pollutants  that  were
detected at a concentration less than ten times the
method detection limit, and 26 pollutants  that
were  present  in less than ten percent of the
influent samples. EPA selected nearly 40 percent
of the list of pollutants analyzed as pollutants of
concern, the  majority  of which were organic
pollutants.
    Facilities  in the oils  subcategory had the
broadest spectrum of pollutants of concern in
their  raw wastewater  with   3  conventional
pollutants, 13 classical pollutants, and more than
100 organics and metals.  As expected, oil and
grease concentrations in this subcategory were
significantly   higher  than   for  the  other.
subcategories, and varied greatly from one facility
to the next, ranging from 40 mg/L to 180,000
mg/L  (see Table 6-2) after the first stage of
treatment.   The concentrations  of ammonia,
BOD5, COD,  TOC, total phenols, and total
phosphorus were also higher for facilities in the
oils subcategory.
    Wastewaters    contained    significant
concentrations of both non-conventional  and
toxic metals  such as aluminum, boron, cobalt,
iron, manganese, and zinc. EPA's sampling  data
show  most pollutant of concern metals were
detected at higher concentrations  in the  oils
subcategory than those found in the organics
subcategory,    but   at   significantly   lower
concentrations than those found in the metals
subcategory.   Germanium .was the only metal
detected  at   a treatable  level in  the  oils
subcategory   but  not  in   the   other  two
subcategories.
    Of the 72 organic pollutants detected above
treatable levels in the oils subcategory, 40 were
not present  in the other two subcategories.
Twenty four pollutants of concern organics were
common   to   both the  oils  and   organics
subcategories, but  more than half of these
organics  were detected in  oily wastewater  at
concentrations two to three orders of magnitude
higher than  those  found  in  the   organics
                                             6-25

-------
Chapter 6 Pollutants of Concern for the CWT Industry
                  Development Document for the CWT Point Source Category
subcategory wastewaters.   Organic pollutants
found in the highest concentrations were straight
chain hydrocarbons such as n-decane and n-
tetradecane, and aromatics such as naphthalene
and   bis(2-ethylhexyl)phthalate.    EPA  also
detected  polyaromatic  hydrocarbons,  such as
benzo(a)pyrene in  the wastewaters   of oils
facilities.
    Some  industry representatives questioned
EPA's  sampling   results   and  claimed  that
benzo(a)pyrene would  only be  found at oils
facilities which treat hazardous wastes.  EPA
reviewed  the  literature which confirmed that
benzo(a)pyrene may be present in any waste that
comes in contact with oil, coal tar, or petroleum
products.     Tables  6-7   and  6-8   present
concentrations  of  benzo(a)pyrene  in  various
industrial products, some of which are likely to be
encountered at oils subcategory CWTs.
    Though the concentration of benzo(a)pyrene
varies widely across the examined sources, the
information  in  the   tables  indicates  that
carbonaceous combustion products are a source
of benzo(a)pyrene. Because many of these used
products are treated at both hazardous and non-
hazardous  CWT oils facilities, benzo(a)pyrene
may  be detected at either  hazardous or non-
hazardous CWT facilities.
                     Table  6-7.   Concentration  of Benzo(a)pyrene in
                     Industrial Products (Osborae & Crosby, 1987)
Sample
Carbon black
Coal-tar pitch
Asphalt
Creosote
Regular gasoline
Premium gasoline
API Reference oils
Diesel oil
Fuel oil
Heavy lubricating oils
Light lubricating oils
Benzo(a)pyrene Content
2-40 ug/g
1.3-2.4%
0.1-27mg/kg
22mg/kg
0.21 mg/L
0.48 mg/L
0.6-44 mg/kg
0.03 mg/kg
0.03 mg/kg
1.2-4.2 mg/kg
6.0-7.0 mg/kg
    Table 6-8. Concentration of Benzo(a)pyrene in Japanese Diesel Oils (Osborne & Crosby, 1987)
     Oil Type
Aromatic Carbon
  Content (%)
Boiling Range (C)
Benzo(a)pyrene
Content (mg/L)
     Commercial gas oil
     Aromatic-rich gas oil
     Coal-liquified oil
      13.0
      36.0
      64
     184-382
     181-331
     205-382
      1.9
      6.7
     64.5
                                             6-26

-------
Chapter 6 Pollutants of Concern, for the CWT Industry
     Development Document for the CWT Point Source Category
POLLUTANTS OF CONCERN FOR
THE ORGANICS SUBCATEGORY
6.4
    Wastewaters treated at CWT facilities in the
organics  subcategory  contain  a  range  of
conventional,   toxic,   and  non-conventional
pollutants.  EPA analyzed influent samples for
336 classical, metal, and organic pollutants.  EPA
identified 97 pollutants of concern, including 60
organic pollutants, 25 metals, and 3 conventional
pollutants presented in Table 6-3. EPA excluded
241  pollutants because they did  not pass the
pollutant of concern criteria. Table 6-6 presents
these pollutants,  including 214 pollutants that
were never detected at any sampling episode, and
27  pollutants   that   were  detected   at  a
concentration less than ten times the method
detection limit.  EPA determined that only 30
percent of the list of pollutants analyzed were
pollutants of concern.
    As   expected,   wastewaters  contained
significant concentrations of organic parameters,
many of which were highly volatile.  However,
although  EPA analyzed wastewater samples in
the organics subcategory for a more extensive list
of organics than samples in the metals or oils
subcategories, EPA  selected only 20 percent of
those organic pollutants analyzed as pollutants of
concern.  EPA selected a total of 60 organics
above treatable levels in the  influent samples
analyzed.   Thirty-six of these organics  were
present in the organics subcategory but not in the
oils subcategory. EPA determined the remaining
24 organics were pollutants of concern for both
the organics  and oils  subcategories.   EPA's
sampling detected only six of these organic
pollutants at higher concentrations at organics
facilities,  specifically,  chloroform,  methylene
chloride,  o-cresol, tetrachloroethene, trichloro-
ethene, and 1,2-dichloroethane.  EPA found only
9 classical pollutants were pollutants of concern
in the organics  subcategory,  and most were
detected at lower concentrations than those found
in the metals and oils subcategories.
    The sampling detected a total of 25 metals
above treatable levels, but these were present at
concentrations  significantly lower than in the
metals subcategory. EPA's assessment showed
that only three  pollutant of concern  metals
(barium, calcium, and strontium) were detected at
concentrations  above those found in the  oils
subcategory.
       REFERENCES
                                         6.5
       Osborne and Crosby, Cambridge Monographs on
       Cancer Research:  Benzopvrenes.  Cambridge
       University Press; New York, NY; 1987.
                                             6-27

-------

-------
                                                                             Chapter
                                                                                    7
        POLLUTANTS SELECTED FOR REGULATION
     Chapter 6 details the pollutants of concern
     for each subcategory and the methodology
used in selecting the pollutants.  As expected for
the CWT industry, these pollutants of concern
lists contain a broad spectrum of pollutants. EPA
has, however, chosen not to regulate all of these
parameters. This chapter details the pollutants of
concern which were not selected for regulation
under  the proposed  options and provides a
justification  for  eliminating these pollutants.
(The proposed options are detailed in Chapter 9.)
Additionally, Figures  7-1 and 7-2 illustrate the
procedures used to select the regulated pollutants
for direct and indirect dischargers.
TREATMENT CHEMICALS
7.1
     EPA excluded all pollutants which may
serve as treatment chemicals: aluminum, calcium,
chloride, fluoride, iron, magnesium, phosphorus,
potassium, sodium, and sulfur. EPA eliminated
these pollutants  because  regulation  of these
pollutants could interfere with their beneficial use-
as wastewater treatment additives.
NON-CONVENTIONAL BULK
PARAMETERS
7.2
     EPA excluded many non-conventional bulk
parameters such as total dissolved solids (TDS),
chemical oxygen demand (COD), organic carbon
(TOC),  nitrate/nitrite, total  phenols,   total
phosphorus, and total sulfide.  EPA excluded
these parameters because it is more appropriate
to target specific compounds of interest rather
than a parameter which measures a variety of
pollutants  for  this  industry.   The  specific
pollutants which comprise the bulk parameter
       may or may not be of concern to EPA. EPA also
       excluded amenable cyanide since the proposed
       total cyanide limit would also control amenable
       cyanide.
       POLLUTANTS NOT DETECTED AT
       TREATABLE LEVELS
                                       7.3
    EPA eliminated pollutants that were present
below treatable concentrations  in wastewater
influent to the treatment system(s) selected as the
basis for effluent limitations.  For a pollutant to
be retained, the pollutant: a) had to be detected in
the influent sample at treatable levels (ten times
the minimum analytical detection limit) in at least
fifty percent of the samples; or b)  had to be
detected at any level in the influent samples at
least 50  percent of the time and the combined
mean  of the  influent samples  for  the entire
episode had to be greater than or equal to ten
tunes the minimum analytical detection limit.
EPA added the second condition to account for
instances where a slug of pollutant was treated
during the sampling episode.  EPA added this
condition  since  the  CWT  industry's waste
receipts   vary  daily   and  EPA wanted to
incorporate these variations in the calculations of
long term averages and limitations.  Pollutants
excluded from  regulation  for  the  selected
subcategory  options  because they  were not
detected at treatable levels are presented in Table
7-1.
                                          7-1

-------
  Chapter 7 Pollutants Selected for Regulation  Development Document for the CWT Point Source Category
                          POC List
                      Is POC a treatment
                          chemical?
                          IB POC a
                    non-conventional bulk
                         parameter?
                          Was POC
                     treated effectively at
               selected BPT/BAT facilities upon
                       which the effluent
                        limitations are
                              ed?
                            asPO
                      'detected at treatable
                        a significant amount
                f the time at selected BPT facilities
                    upon which the affluent
                        limitations are
                               d
                       Is POC a volatile
                    ollutant (see Figure 7-3)7
                   POC may be regulated for
                      Direct Dischargers
                                                        Yes
             POC will not be regulated for the
                       subcategory
                                                        Yes
             POC will not be regulated for the
                       subcategory
No
             POC will not be regulated for the
                      subcategory
No
             POC will not be regulated for the
                     subcategory
                                                        Yes
             POC will not be regulated for the
                      subcategory
Figure 7-1.  Selection of Pollutants That May Be Regulated for Direct Discharges for Each Subcategory
                                                       7-2

-------
 Chapter 7 Pollutants Selected for Regulation Development Document for the CWT Point Source Category
                     Regulated Pollutants
                    for Direct Discharges
                         Does POC
                pass through a POTW or cause
                        inhibition or
                        interference?
                   POC will be regulated for
                    Indirect Dischargeres
                                                       Yes
No
                                                                       POC will not be regulated for
                                                                             the subcategory
                POC will not be regulated for
                      the subcategory
Figure 7-2. Selection of Pollutants to be Regulated for Indirect Discharges for Each Subcategory
                                                    7-3

-------





















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-------
Chapter 7 Pollutants Selected for Regulation    Development Document for the CWT Point Source Category
POLLUTANTS NOT TREATED
7.4
     EPA excluded  all pollutants  for which the
selected  technology  option  was  ineffective  (i.e.,
pollutant  concentrations  remained  the  same  or
increased across the treatment system). For the oils
subcategory option 8, phenol and 2-propanone were
ineffectively treated,  and for the  oils subcategory
option 9, 2-propanone and 2,4-dimethylphenol were
not treated effectively. For the organics subcategory,
the selected treatment technology did not effectively
treat boron, chromium, lithium, nickel, and tin.  For
the metals subcategory options, with the exception of
selenium (for Option 3), all pollutants of concern were
effectively treated.
VOLATILE POLLUTANTS
7.5
     EPA detected volatile organic pollutants in the
waste receipts of all three subcategories. For this rule,
EPA defines a volatile pollutant as a pollutant which
has a Henry's Law constant in excess of 10"4 atm m3
mol"!.  Table 7-2 lists the organic pollutants (those
analyzed using method 1624 or 1625) by subcategory
along with their Henry's Law constant.  For pollutants
in the  oils subcategory, the solubility in water was
reported in addition to the Henry's Law constant to
determine whether volatile pollutants remained in the
oil-phase or volatilized from the aqueous phase.  If no
data were available on the Henry's Law constant or
solubility for a particular pollutant, then the pollutant
was assigned  an average pollutant group value.
Pollutant groups  were  developed  by  combining
pollutants with similar structures.  If no data were
available for any pollutant in the group, then all
pollutants in the group were not considered volatile.
The assignment of pollutant groups is discussed in
more detail in Section 7.6.2.
                                                 7-6

-------
Chapter 7 Pollutants Selected for Regulation    Development Document for the CWT Point Source Category
                       I   POC List for Oils Subcategoiy
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                                 Pollutant is volatile
The pollutant is not volatile
 Pollutant is in oily phase
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  Pollutant is not volatile
  Figure 7-3. Determination of Volatile Pollutants for Oils Subcategor
                                                      7-7

-------





























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-------
Chapter 7 Pollutants Selected for Regulation    Development Document for the CWT Point Source Category
     As shown in Table 7-2, volatile pollutants
were  regularly detected  at treatable levels in
waste receipts from CWT facilities, particularly
in the oils and organics subcategory.  However,
treatment technologies currently used at many of
these facilities, while removing the pollutants
from the wastewater, do not "treat" the volatiles.
The volatile pollutants are simply transferred to
the air. For example, in the metals subcategory,
wastewater treatment technologies are generally
based on chemical precipitation, and the removal
of volatile pollutants from wastewater following
treatment with chemical  precipitation is due to
volatilization.  Some  CWT facilities recognize
that volatilization may be occurring and have
installed  air  stripping systems equipped with
emissions  control  to  effectively remove  the
pollutants from both the water and the air.
     EPA    evaluated   various   wastewater
treatment technologies during the development of
this rule.  These technologies were considered
because of their efficacy in removing pollutants
from wastewater.  Since EPA is concerned about
removing pollutants  from  all  environmental
media, EPA also evaluated wastewater treatment
trains for the oils  and  organics  subcategories
which included  air stripping with  emissions
control.      .
     EPA  is not proposing  to  regulate"  any
predominantly volatile parameters.  The non-
regulated volatile parameters for the metals,
organics, and oils subcategory options that were
not already excluded as detailed in Sections  7.1,
7.2, 7.3,  and 7.4 are presented  in Table  7-3.
Unlike the metals and the organics subcategories,
for the oils subcategory, volatilization can not be
predicted using the Henry's Law constant only.
Henry's  Law constants are established  for
pollutants in an aqueous phase only. For other
non-aqueous single phase or two-phase systems
(such as oil-water), other volatilization constants
apply.  Estimating these constants in oil-water
mixtures  can lead to engineering calculations
which are  generally based on empirical data.
EPA  chose an approach which is depicted in
Figure 7-3 and discussed below.
     First, EPA reviewed water solubility data to
estimate whether the organic pollutants would be
primarily in an oil phase or aqueous phase.  For
pollutants which have a solubility less than ten
times the minimum analytical detection limit  (the
same edit used to determine pollutants of concern
and long term averages), EPA assumed that the
amount of pollutants in the aqueous phase would
be negligible and that all of the pollutant would
be primarily in an oil phase.  For pollutants which
have  a solubility  greater than  ten  times  the
minimum analytical detection limit, EPA assumed
that  the amount of pollutant in the oil phase
would be negligible and that all of the pollutant
would be primarily in an aqueous phase.  For
pollutants determined to be in  an aqueous phase,
EPA then reviewed the Henry's law constant in
the same manner as the other two subcategories.
For pollutants determined to be in an oil phase,
EPA  assumed that  volatilization would  be
negligible (regardless of their volatility in the
aqueous phase) and has not categorized them as
volatile pollutants.
     Even though EPA has not regulated volatile
pollutants   through  this  rulemaking,  EPA
encourages  all facilities which  accept waste
receipts  containing   volatile  pollutants   to
incorporate air stripping with overhead recovery
into their wastewater treatment systems. EPA
also notes that CWT facilities determined to be
major sources of hazardous  air pollutants are
subject  to  maximum  achievable   control
technology (MACT) as promulgated for off-site
waste and  recovery operations on July 1, 1996
(61FR34140) as 40 CFR Part 63.
                                            7-13

-------
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-------
Chapter 7 goUvttants Selected for Regulation    Development Document for the CWT Point Source Category
POLLUTANTS SELECTED FOR
PRETREATMENT STANDARDS AND
PRETREATMENT STANDARDS FOR NEW
SOURCES (INDIRECTDISCHARGERS)       7.6
Background                           7.6.1

     Unlike direct dischargers whose wastewater
will receive no further treatment once it leaves the
facility, indirect dischargers send their wastewater
streams  to a POTW for further treatment.
Therefore,   for  indirect  dischargers, before
proposing pretreatment standards, EPA examines
whether the pollutants discharged by the industry
"pass through" a POTW to waters of the U.S. or
interfere  with the  POTW operation or sludge
disposal  practices.  Generally, to determine if
pollutants pass through a POTW, EPA compares
the percentage of the pollutant removed by well-
operated POTWs achieving secondary treatment
with the percentage of the pollutant removed by
facilities  meeting BAT effluent limitations. A
pollutant is determined  to  "pass  through" a
POTW when the average percentage removed by
a well-operated POTW is less than the percentage
removed by direct dischargers complying with
BPT/BAT  effluent limitations. In this manner,
EPA can ensure that the combined treatment at
indirect discharging facilities and POTWs is at
least equivalent  to  that  obtained  through
treatment by a direct discharger.
     This approach to the definition of pass-
through satisfies two competing objectives set by
Congress:  (1)   that  standards  for  indirect
dischargers be equivalent to standards for  direct
dischargers, and (2) that the treatment capability
and performance of the POTW be recognized and
taken into account  in regulating the discharge of
pollutants from indirect dischargers. Rather than
compare the mass or concentration of pollutants
discharged to the POTW with the  mass or
concentration of pollutants discharged by a BAT
facility, EPA compares the percentage of the
pollutants  removed by the  facility  with the
POTW removal.   EPA  takes  this  approach
because  a   comparison  of  the  mass  or
concentration of pollutants in a POTW effluent
with pollutants in a BAT facility's effluent would
not take into account the mass of pollutants
discharged  to the POTW from non-industrial
sources, nor the dilution of the pollutants in the
POTW effluent to lower concentrations from the
addition of large amounts of non-industrial water.
     For specific pollutants, such as volatile
organic compounds, EPA may use other means to
determine pass-through. Generally, for volatile
compounds, a volatile override test based on the
Henry's Law constant is used to determine pass-
through.  The volatile override test is applied
where the overall percent removal estimated for a
well-operated  POTW substantially  includes
emission of the pollutant to the air rather than
actual  treatment.    Therefore,  for  volatile
pollutants,  even though the POTW percent
removal data indicate that the pollutant would not
pass through, regulation of the pollutant is
warranted to ensure "treatment" of the pollutant.
     As detailed in Section 7.5, fdr all  three
subcategories, EPA selected technology options
which are not designed to control the emission of
volatile pollutants. Therefore, for the selected
options,  removal of  volatile pollutants  from
wastewater is largely due to the emission of the
pollutant rather than treatment. As such, for this
rulemaking, EPA believes the volatile override
test is  inappropriate and has determined  pass-
through solely by comparing percent removals.
     In selecting the regulated pollutants under
the pretreatment standards, EPA starts with the
pollutants regulated for direct dischargers under
BPT/BAT.  For pretreatment standards, EPA
then excludes three conventional  parameters,
BODS, total suspended solids (TSS), and oil and
grease  (measured  as  HEM)  from  further
consideration without  conducting  the percent
removal  comparison  because  POTWs  are
designed to treat these parameters. Therefore, for
this rulemaking, EPA evaluated 23 pollutants for
                                            7-15

-------
Chanter 7 Pollutants Selected for Regulation    Development Document for the CWTPoint Source Category
metals option 3, 31 pollutants for metals option
4, 51  pollutants  for oils  option 9,  and  23
pollutants for Organics Option 4 for  possible
PSES  and PSNS regulation.   The following
sections  describe  the methodology  used  in
determining percent removals  for the option
technologies, percent removals for  a "well-
operated" POTW, and the results of EPA's pass-
through analysis.
Determination of Percent Removals
for Well-Operated POTWs
7.6.2
     The primary source of the POTW percent
removal data was the "Fate of Priority Pollutants
in Publicly Owned Treatment Works" (EPA
440/1-82/303,  September  1982), commonly
referred to as the "50-POTW Study". However,
the 50-POTW Study did not contain data for all
pollutants for which the pass-through analysis
was   required.    Therefore,  EPA   obtained
additional  data from  EPA's National  Risk
Management Research Laboratory's (NRMRL)
Treatability Database (formerly called the Risk
Reduction  Engineering  Laboratory  (RREL)
Treatability Database).  These sources and their
uses are discussed below.
     The 50-POTW Study presents data on the
performance   of  50  well-operated  POTWs
achieving secondary treatment in removing toxic
pollutants.    The  work performed with  this
database included some data editing criteria.
Because the data collected for evaluating POTW
removals included influent levels that were close
to the detection limit, EPA  devised  the  data
editing hierarchal rules to eliminate low influent
concentration levels, thereby  minimizing the
possibility that low POTW  removals  might
simply reflect low influent concentrations instead
of  being   a  true measure  of  treatment
effectiveness. The hierarchial data editing rules
for the 50-POTW  Study  were as follows:  1)
detected pollutants must have at least three pairs
(influent/effluent) of data points to be included,
2) average pollutant influent levels less than 10
times the pollutant minimum analytical detection
limit  were   eliminated,   along   with   the
corresponding effluent values, and 3) if none of
the  average pollutant  influent  concentrations
exceeded  10  times  the  minimum analytical
detection limit, then the average influent values
less than 20 ug/L were eliminated, along with the
corresponding effluent values.    EPA  then
calculated each POTW percent removal for each
pollutant based on its average influent and its
average effluent values.  The POTW percent
removal used  for each pollutant  in the pass-
through test is the median value of all the POTW
pollutant specific percent removals.
     EPA's  NRMRL  Treatability  Database
provides information, by pollutant, on removals
obtained by various treatment technologies.  The
database provides the user with the specific data
source  and  the industry from  which  the
wastewater  was generated.    EPA  used the
NRMRL database to supplement the treatment
information  provided in the 50-POTW  Study
when there  was insufficient  information  on
specific pollutants. For each of the pollutants of
concern not  found in the 50-POTW database,
EPA obtained data from portions of .the NRMRL
database. EPA then edited these files so that only
treatment technologies  representative of typical
POTW secondary treatment operations (activated
sludge, activated sludge with filtration, aerobic
lagoons) were used. EPA further edited  these
files to include information pertaining only to
domestic or industrial  wastewater.  EPA used
pilot-scale   and  full-scale  data   only,   and
eliminated any bench-scale data. EPA retained
data from papers in a peer-reviewed journal or
government report, but edited out lesser quality
references,  such as reports  which were not
reviewed. Zero and negative  percent removals
were eliminated, as  well as data with less than
two pairs  of   influent/effluent  data points.
Finally, EPA calculated the average percent
                                           7-16

-------

removal for each pollutant from the remaining
pollutant removal data.
     EPA selected the final percent removal for
each pollutant based on a data hierarchy, which
was related to the quality of the data source.  The
following  data  source hierarchy was used for
selecting a percent removal for a pollutant: 1) if
available,  the median percent removal from the
50-POTW Study was chosen using all POTWs
data with influent levels greater than or equal to
10  times the  pollutant minimum analytical
detection limit, 2) if not available, the median
percent removal from the 50-POTW Study was
chosen using all POTWs data with influent levels
greater than 20 ug/L, 3) if not available, the
average percent removal from the  NRMRL
Treatability  Database was  chosen using  only
domestic wastewater,  4) if  not available, the
average percent .removal from the  NRMRL
Treatability Database was chosen using domestic
and  industrial  wastewater,  and  finally  5)  a
pollutant was assigned an average group percent
removal, or  "generic" removal if no other data
was available.  Pollutant groups were developed
by combining pollutants  with similar chemical
structures.   (A  complete list of pollutants and
pollutant groupings are available in Appendix A).
EPA  calculated  the  average  group  percent
removal by using all pollutants in the group with
selected percent removals from either the 50-
POTW Study  or the  NRMRL  Treatability
Database.  EPA then averaged percent removals
together to determine the average group percent
removal. Pollutant groups and generic removals
used in the pass-through analysis are presented in
Table  7-4.  Only groups A, J,  and  CC are
presented  in Table 7-4 since these are the only
groups for which EPA assigned a pollutant an
average group  percent  removal  in  its pass-
through analysis.  The  final  POTW percent
removal assigned to each pollutant is presented in
Table  7-5,  along with  the source and  data
hierarchy of each removal.
                                           7-17

-------
  hnntpr 7 Pollutants Selected for Regulation    Development Document for the CWT Point Source Category
Table 7.4 CWT Pass-Through Analysis Generic POTW Percent Removals
Pollutant
Group A: Metals
Barium
Beryllium
Cadmium
Chromium
Cobalt
Copper
Iridium
Lead
Lithium
Manganese
Mercury
Molybdenum
Nickel
Silver
Strontium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
Average Group Removal

Pollutant
Group J: Anilines
Aniline
Carbazole
Average Group Removal

Pollutant
Group CC: n-Paraffins
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexacosane
n-Hexadecane
n-Octadecane
n-Tetradecane
Average Group Removal
CAS NO.

7440393
7440417
7440439
7440473
7440484
7440508
7439885
7439921
7439932
7439965
7439976
7439987
7440020
7440224
7440246
7440280
7440315
7440326
7440622
. 7440655
7440666
7440177


CAS NO.

62533
86748


CAS NO.

124185
629970
112403
112958
630013
544763
593453
629594

% Removal

27.66
61.23
90.05
91.25
6.11
84.11
74.00
91.83
26.00
40.60
90.16
52.17
51.44
92.42
14.83
53.80
65.20
68.77
42.28
57.93
77.97

60.00

% Removal

62.00

62.00

% Removal

9.00
88.00
95.05
92.40




71.11
Source

50 POTW - 10 X NOMDL
.RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
50 POTW - 10 X NOMDL
50 POTW - 10 X NOMDL
50 POTW - 10 X NOMDL
RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
RREL 5 (ALL WW)
RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
RREL 5 - (DOM WW)
50 POTW - 10 X NOMDL
50 POTW - 10 X NOMDL
RREL 5 - (DOM WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
Average Group Removal


Source

RREL 5 - (ALL WW)
Average Group Removal


Source

RREL 5 - (ALL WW)
RREL 5- (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
Average Group Removal
Average Group Removal
Average Group Removal
Average Group Removal

                                            7-18

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Chapter 7 Pollutants Selected for Regulation    Development Document for the CWT Point Source Category
Table 7.5 Final POTW Percent Removals
Pollutant
CLASSICAL
Ammonia as N
BOD5
Hexavalent Chromium
Oil + Grease
Total Cyanide
Total Suspended Solids
METALS
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium
Cobalt
Copper
Iridium
Lead
Lithium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silicon
Silver
Strontium
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANICS
2-butanone
2-propanone
2,3-dichloroaniline
Metals

X
X
X
X
X
X

X


X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X

Oils

X
X

X
X
X

X
X
X

X
X
X
X
X

X

X
X
X
X
X
X

X

X
X


X


X


Organics

X
X


X
X

X






X
X



X

X


X

X





X


X
X
X
CAS NO.

766417
C-002
18540299
C-007
57125
C-009

7440360
7440382
7440393
7440417
7440428
7440439
7440473
7440484
7440508
7439885
7439921
7439932
7439965
7439976
7439987
7440020
7782492
7440213
7440224
7440246
7440280
7440315
7440326
7440622
7440655
7440666
7440677

78933
67641
608275
Percent
Removal

40.85
91.32
5.68
81.41
70.44
90.29

71.13
90.89
27.66
61.23
20.04
90.05
91.25
6.11
84.11
74.00
91.83
26.00
40.60
90.16
52.17
51.44
34.33
27.29
92.42
14.83
53.80
65.20
68.77
42.28
57.93
77.97
60.00

96.60
83.75
41.00
Source

50POTW-10XNOMDL
50POTW-10XNOMDL
50POTW-10XNOMDL
50POTW-10XNOMDL
50POTW-10XNOMDL
50POTW-10XNOMDL

50POTW-10XNOMDL
50 POTW - 10 X NOMDL
50POTW-10XNOMDL
REEL 5 - (ALL WW)
50 POTW - >20 PPB
50 POTW- 10 X NOMDL
50 POTW- 10 X NOMDL
50 POTW - >20 PPB
50 POTW- 10 X NOMDL
RREL 5 - (ALL WW)
50 POTW- 10 X NOMDL
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
RREL 5 - (DOM WW)
50 POTW - 10 X NOMDL
RREL 5 - (DOM WW)
RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
RREL 5- (DOM WW)
RREL 5- (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW- 10 X NOMDL
Generic Removal-Group A

RREL 5 - (DOM WW)
RREL 5- (ALL WW)
RREL 5 - (ALL WW)
                                            7-19

-------
Chapter 7 Pollutants Selected for Regulation    Development Document for the CWTPoint Source Category
Table 7.5 Final POTW Percent Removals
Pollutant
2,4,6-trichlorophenol
4-chloro-3-methylphenol
Acenaphthene
Acetophenone
Alpha-terpineol
Aniline
Anthracene
Benzo (a) anthracine
Benzo (a) pyrene
Benzo (b) fluoranthene
Benzo (k) fluoranthene
Benzoic Acid
Bis(2-ethylhexyl) phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Diethyl phthalate
Di-n-butyl phthalate
Fluoranthene
Fluorene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetradecane
n,n-Dimethylformamide
o-Cresol
p-Cresol
Pentachlorophenol
Phenol
Pyrene
Pyridine
Metals Oils

X
X

X

X
X
X
X
X
X X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
 x x
Organics
X


X

X





X















X
X
X
X
X

X
CAS NO.
88062
,59507
83329
98862
988555
62533
120127
56553
50328
205992
207089
65850
117817
85687
86748
218019
84662
84742
206440
86737
124185
629970
112403
112958
544763
593453
629594
68122
95487
106445
87865
108952
129000
110861
Percent
Removal
65.00
63.00
98.29
95.34
94.40
62.00
95.56
97.50
95.20
95.40
94.70
80.50
59.78
94.33
62.00
96.90
59.73
79.31
42.46
69.85
9.00
88.00
95.05
92.40
71.11
71.11
71.11
84.75
52.50
71.67
13.88
95.25
83.90
95.40
Source
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW - 1 0 X NOMDL
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW- 10 X NOMDL
RREL 5 - (DOM WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW - 10 X NOMDL
50 PO'TW - 10 X NOMDL
Generic Removal-Group J
RREL 5 - (DOM WW)
50 POTW - > 20 PPB
50 POTW - > 20 PPB
50 POTW - > 20 PPB
50 POTW - > 20 PPB
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
Generic Removal-Group CC
Generic Removal-Group CC
Generic Removal-Group CC
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
RREL 5 - (ALL WW)
50 POTW - >20 PPB
50 POTW- 10 X NOMDL
RREL 5 - (DOM WW)
RREL 5 - (ALL WW)
                                            7-20

-------
Chanter 7 Pollutants Selected for Regulation    Development Document for the CWTPoint Source Category
Methodology for Determining
Treatment Technology
Percent Removals
7.6.3
     EPA calculated treatment percent removals
for each selected BAT option using the data used
to determine the option long term averages and
limitations.  Therefore, the data used to calculate
treatment option percent removals was subjected
to the same data editing criteria as the data used
in  calculating  the  long-term  averages  and
limitations as described in Section 10.   This
editing  included excluding  the  influent and
effluent data for pollutants that were not detected
in the influent at treatable levels, excluding data
for pollutants which were not treated by the
technology,   and  excluding  data  that  were
associated with process upsets.
     After the data were edited, EPA used the
following methodology  to  calculate  percent
removal:

1)   For each pollutant and each sampled
     facility, EPA averaged the remaining
     influent data and effluent data to give
     an average influent concentration and
     an  average  effluent  concentration,
     respectively.

2)   EPA calculated percent removals for each
     pollutant and each sampling episode from
     the average influent and average  effluent
     concentrations using the following equation:

% Removal = CAvg Influent - Avg Effluent) x 100
                  Average Influent

3)  EPA calculated the median percent removal
     for each pollutant for each option from the
     facility-specific percent removals.
Pass-Through Analysis Results  7.6.4

     The results of the Pass-Through Analysis
are presented in Tables 7-6 through  7-9 by
subcategory and treatment option.

Pass-Through Analysis Results
for the Metals Subcategory            7.6.4.1
     For metals subcategory option 3, pass-
through results are presented in  Table 7-6. All
pollutants analyzed passed through and may be
regulated under PSES and PSNS. For metals
subcategory option 4, pass-through results are
presented in Table 7-7.  All non-conventional
pollutants  analyzed  passed through,   and all
metals passed through  with the  exception of
molybdenum and  zirconium.   However, for
organic pollutants  analyzed, only  benzoic  acid
passed  through.   All pollutants  that passed
through are regulated under PSES and PSNS.
                                            7-21

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Chapter 7 Pollutants Selected for Regulation    Development Document for the CWTPoint Source Category
Table 7.6 Final Pass-Through Results For Metals Subcategory Option 3
Pollutant Parameter
CLASSICALS
Hexavalent Chromium
METALS
Antimony
Arsenic
Beryllium
Boron
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silicon
Silver
Thallium
Tin
Titanium
Vanadium
Yttrium
Zinc
Option 3 Removal (%)

93.36

99.71
99.77
99.00
75.15
99.96
99.98
99.59
100.00
99.67
99.99
99.80
88.20
99.87
92.66
99.75
99.32
95.99
99.83
99.76
99.48
94.25
99.99
POTW Removal (%)

5.68

71.13
90.89
61.23
20.04
90.05
91.25
6.11
84.11
91.83
40.60
90.16
52.17
51.44
34.33
27.29
92.42
53.80
65.20
68.77
42.28
57.93
77.97
Pass-Through

yes

yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
                                            7-22

-------
Chanter 7 Pollutants Selected for Regulation    Development Document for the CWT Point Source Category
Table 7.7 Final Pass-Through Results For Metals Subcategory Option 4
Pollutant Parameter
CLASSICALS
Hexavalent Chromium
Total Cyanide
METALS
Antimony
Arsenic
Boron
Cadmium
Chromium .
Cobalt
Copper
Iridium
Lead
Lithium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silicon
Silver
Strontium
Tin
Titanium
Vanadium
Yttrium
Zinc
Zirconium
ORGANICS
2-Butanone
2-Propanone
Benzoic Acid
n,n-Dimethylformamide
Pyridine
Option 4 Removal (%)

98.01
97.07

94.30
91.71
54.70
99.97
99.91
98.47
99.91
99.69
99.95
66.83
99.87
98.38
26.40
99.59
57.54
98.58
99.62
95.89
99.94
99.84
99.46
95.39
99.93
42.13

74.72
65.62
82.99
54.81
48.49
Median POTW Removal (%)

5.68
70.44

71.13
90.89
20.04
90.05
91.25
6.11
84.11
74.00
91.83
26.00
40.60
90.16
52.17
51.44
34.33
27.29
92.42
14.83
65.20
68.77
42.28
57.93
77.97
61.00

96.60
83.75
80.50
84.75
95.40
Pass-Through

yes
yes

yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
no
yes
yes
yes
 yes
yes
yes
yes
yes
yes
yes
no

no
no
yes
no
no
                                            7-23

-------

Pass-Through Analysis Results for the Oils Subcategory                                7.6.4.2
     The final pass-through analysis results for the oils subcategory option 9 are presented in Table 7-8.
Several metals and organic pollutants passed through, and therefore may be regulated under PSES an
PSNS.
Table 7.8 Final Pass-Through Results For Oils Subcategory Option 9
Pollutant Parameter
Option 9 Removal (%) Median POTW Removal (%)   Pass-Through
 CLASSICALS
Total Cyanide
       64.38
70.44
                      no
METALS
.Antimony
Arsenic
Barium
Boron
Cadmium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silicon
Strontium
Tin
Titanium
Zinc
       87.99
       57.64
       91.91
       33.01
       88.08
       86.24
       52.20
       93.85
       88.26
       46.03
       77.43
       53.73
       41.24
       36.94
       42.07
       50.68
       90.78
       89.99
       78.25
71.13
90.89
27.66
20.04
90.05
91.25
 6.11
84.11
91.83
40.60
90.16
52.17
51.44
34.33
27.29
14.83
65.20
68.77
77.97
yes
no
yes
yes
no
no
yes
yes
no
yes
no
yes
no
yes
yes
yes
yes
yes
yes
 ORGANICS
 2-Butanone                      15.41
 4-chloro-3-methylphenol           27.48
 Acenapthene                     96.75
 Alpha-terpineol                   94.77
 Anthracene                      96.67
 Benzo (a) anthracene              95.70
 Benzo (a) pyrene                 96.27
 Benzo (b) flouranthene            95.92
 Benzo (k) fiuoranthene            95.89
                                96.60
                                63.00
                                98.29
                                94.40
                                95.56
                                97.50
                                95.20
                                95.40
                                94.70
                      no
                      no
                      no
                      yes
                      yes
                      no
                      yes
                      yes
                      yes
                                          7-24

-------
Chapter 7 Pollutants Selected for Regulation    Development Document for the C WTPoint Source Category
Benzole acid
Bis (2-ethylhexyl)
phthalate
Butyl benzyl phthalate
Carbazole
Chrysene
Di-n-butyl phthalate
Diethyl phthalate
Fluoranthene
Fluorene
n-Decane
n-Docosane
n-Dodecane
n-Eicosane
n-Hexadecane
n-Octadecane
n-Tetradecane
o-cresol
p-cresol
Phenol
Pyrene
Pyridine
19.32
94.09

92.60
81.09
97.22
88.07
63.97
96.43
92.86
94.98
96.87
96.50
95.54
96.53
97.20
96.85
21.08
34.88
14.88
97.63
21.45
80.50
59.78

94.33
62.00
96.90
79.31
59.73
42.46
69.85
9.00
88.00
95.05
92.40
71.11
71.11
71.11
52.50
71.67
95.25
83.90
95.40
no
yes

no
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
no
no
no
yes
no
                                              7-25

-------
Chapter 7 Pollutants Selected for Regulation    Development DocumentfQrJhe^WT_Point_Sgurce_Categor^_

Pass-Through Analysis Results for the Organics Subcategory                           7.6.4.3
     The results of the pass-through analysis for the organics subcategory option 3/4 are presented i
Table 7-9. Several metals and organic pollutants passed through, and therefore may be regulated under
PSES and PSNS.
Table 7.9 Final Pass-Through Results For Organics Subcategory Option 3/4
Pollutant Parameter
CLASSICALS	
Total Cyanide
Option 3/4 Removal (%)  Median POTW Removal (%)  Pass-Through
        33.46
70.44
no
METALS
Antimony
Cobalt
Copper
Manganese
Molybdenum
Silicon
Strontium
Zinc
        33.27
        17.31
        38.04
         4.22
        57.10
         4.71
        59.51
        60.51
71.13
 6.11
84.11
40.60
52.17
27.29
14.83
77.97
no
yes
no
no
yes
no
yes
no
 ORGANICS
2-butanone
2-propanone
2,3-dichloroaniline
2,4,6-trichlorophenol
Acetophenone
Aniline
Benzoic Acid
n,n-Dimethylfbrmamide
o-Cresol
p-Cresol
Pentachlorophenol
Phenol
Pyridine
69.20
68.57
80.45
45.16
92.44
92.88
94.29
89.26
98.39
85.38
23.19
87.08
61.69
96.60
83.75
41.00
65.00
95.34
62.00
80.50
84.75
52.50
71.67
13.88
95.25
95.40
no
no
yes
no
ho
yes
yes
yes
yes
yes
yes
no
no
                                           7-26

-------
    Chapter 7 Pollutants Selected for Regulation     Development Document for the CWTPoint Source Category
    FINAL LIST OF POLLUTANTS SELECTED FOR REGULATION
    Direct Dischargers
  7.7
7.7.1
         After EPA eliminated pollutants of concern which were treatment chemicals, non-conventional bulk
    parameters, not detected at treatable levels, not treated, or vqlatile, EPA still  had a lengthy list of
    pollutants which could be regulated  particularly in the oils subcategory.  EPA further eliminated
    pollutants that were identified during screening, but not analyzed in a quantitative manner1.  These
    pollutants are iridium, lithium, silicon, and strontium.  EPA also eliminated pollutants that are not toxic
    as quantified by their toxic weighting factor (TWF)2.  A single pollutant, yttrium, has a TWF of zero
    and was, therefore, eliminated.  EPA also eliminated pollutants that were removed by the proposed
    treatment technologies, but whose removal was not optimal. EPA eliminated pollutants that were
    removed by less than 30% with the proposed technology options for the organics subcategory and by less
    than 50% with the proposed technology options for the metals and oils subcategories.  These pollutants
    are listed in Table 7-10.
    Table 7-10 Pollutants Eliminated Due to Non-Optimal Performance
Metals Option 4 Metals Option 3
BOD5 None
Molybdenum
Pyridine
Zirconium








Oils Option 8
BOD5
Boron
Manganese3
Nickel
Selenium
Benzoic Acid
p-Cres.ol
Phenol
Pyridine
2-butanone


Oils Option 9
BOD5
Boron
Manganese
Nickel
Selenium
Benzoic Acid
o-Cresol
p-Cresol
Phenol
Pyridine
2-butanone
4-methyl-2-pentanone
Organics Option 3/4
Cobalt
Manganese
Pentachlorophenol









         Finally, EPA eliminated those pollutants for which the treatment technology forming the basis of
    the option is not a standard method of treatment.  For example, chemical precipitation systems are not
    designed to remove BOD5. Table 7-11 lists these pollutants for each subcategory and option.
        'Analyses for these pollutants were not subject to the quality assurance/quality control (QA/QC) procedur s.
required by analytical Method 1620.
               eighting factors are derived from chronic aquatic life criteria and human health criteria established for the
consumption offish.  Toxic weighting factors can be used to compare the toxiciry of one pollutant relative to another and
are normalized based on the toxicity of copper.  TWFs are discussed in detail in the Cost Effectiveness Analysis Document.

        Removals for this pollutant for option 8 were not less than 50%. However, since removals for this pollutant fo
option 9 (the BAT selected option) were less than 50%, for consistency, they were similarly eliminated for option 8.

                                                 7-27

-------
Chanter 7 Pollutants Selected for Regulation     Development Document for the CWT Point Source Category
Table 7-11. Pollutants Eliminated Since Technology Basis is Not Standard Method of Treatment
Metals Option 4
BOD5
Boron
Metals Option 3
Benzoic Acid
Boron
2-butanone
2-propanone
Oils Option 8/9
Total Cyanide
Organics Option 3/4
Total Cyanide
     For the organics subcategory, EPA's final
list of regulated pollutants for direct discharging
CWT facilities was based on the previous edits.
For  the metals  subcategory,  three  pollutants,
beryllium, molybdenum, and thallium, remained
for metals option 3, but had been'eliminated for
metals  option 4.  For consistency, EPA  also
eliminated these  three pollutants for metals
option 3. EPA's final list of regulated pollutants
for direct discharges in the metals subcategory
was based on these additional edits.
     However, for the organic pollutants in the
oils subcategory, EPA further reduced the number
of regulated pollutants   as  detailed  in  the
following  paragraphs.    EPA  selected  this
approach based  on comments  to the  1995
proposal.
     Therefore,  EPA  organized the remaining
organic pollutants in the  oils subcategory into
pollutant groups.  As detailed in Section 7.6.2,
pollutant groups were developed by combining
pollutants of similar structures.  The remaining
list of organics pollutants in the oils subcategory
are  in  four pollutant  groups:  n-paraffins,
polyaromatic hydrocarbons,  phtalates,  and
aliphatic alcohols.  EPA  reviewed the  influent
characterization  data  from  oils subcategory
facilities (including the additional data collected
at non-hazardous oils facilities)  to determine
which  pollutants in each structural group are
always detected together.   If pollutants  in a
structural group are always detected together,
then EPA can establish some (or one) pollutants
in each group as indicator pollutants. Since the
effectiveness of the treatment technologies which
form the basis of the proposed oils subcategory
limitations is similar for pollutants in each group,
EPA can be confident that regulation of the group
indicator pollutant(s) will ensure control of all the
group pollutants. This approach allows EPA to
reduce the list of regulated pollutants for the oils
subcategory  substantially.  Tables 7-12, 7-13,
and 7-14 summarize the da.ta for each structural
group.   In these tables, an "X"  indicates the
pollutant was detected at the sampled facility
while a "blank" indicates the pollutant was not
detected at the sampled facility.
     Data for n-paraffins  show that while n-
decane  is usually detected in combination with
other n-paraffins,  it was the  sole  n-paraffin
detected at one facility.  Therefore, no other n-
paraffins in this group can be used as an indicator
parameter for n-decane. Additionally, the data
show that n-decane is not an acceptable indicator
parameter for the other pollutants in this group.
The data also show  that n-hexadecane,  n-
octadecane  and  n-tetradecane  were  always
detected together and vice versa. Finally, the data
show that the other n-paraffins were also detected
with  n-hexadecane,   n-octadecane  and  n-
tetradecane, but that the reverse  statement is not
always true.  Therefore,  along with n-decane,
EPA can select n-hexadecane, n-octadecane or n-
tetradecane as an  indicator parameter for the
majority of the n-paraffins.  EPA  selected n-
octadecane.
     Data for the  polyaromatic  hydrocarbons
show that fluroanthene and pyrene were always
detected together and vice-versa.  Likewise, when
the other  polyaromatic  hydrocarbons  were
detected, both  fluoranthene  and pyrene  were
                                             7-28

-------
Chantei^PollutantsSelecte^^

always detected. However, the reverse statement
is not true.  Therefore, EPA can select either
fluoranthene or pyrene as an indicator parameter
for all of the polyaromatic hydrocarbons.  EPA
selected fluoranthene since it was detected most
often.  Data for the phthalate group show that
while   bis-2-ethylhexylphthalate  is   usually
detected with other phthalates, it is sometimes the
only pollutant detected in this group. Therefore,
no other n-pollutant in this group can be used an
indicator parameter for bis-2-ethylhexylphthlate.
The data also show that butyl benzyl phlalate is
usually detected with other phlalates, but that it
was the only phthalate detected at one facility.
Therefore, no other n-pollutant in this group can
be used an indicator parameter for butyl benzyl
phthlate.     Finally,   the  data  show   that
diethylphthalate  and   di-n-butylphthlate  are
always detected with bis-2-ethylhexylphthlate.
As    a   result,   EPA   selected    bis-2-
ethylhexylphthlate and butyl benzylphthlate for
regulation in the pthalate group.
     Table 7-15 shows the final list of pollutants
selected for regulation for direct dischargers.
                                              7-29

-------















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a 
-------
    Chapter 7 Pollutants Selected for Regulation  Development Document for the CWTPoint Source Category
     Table 7-15.      Final List of Regulated Pollutants for Direct Discharging CWTs
       Metals Subcategory
           Option 4
          (BPT, BAT)
Metals Subcategory
 Option 3 (NSPS)
Oils Subcategory
    Option 9
BPT, BAT, NSPS
Organics Subcategory
      Option 3
  BPT, BAT, NSPS
TSS
Oil and Grease
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Hex chromium
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Tin
Titanium
Total cyanide
Vanadium
Zinc




TSS
Oil and Grease
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Hex Chromium
Lead
Manganese
Mercury
Nickel
Silver
Tin
Titanium
Total cyanide
Vanadium
Zinc





Oil and Grease
TSS
Antimony
Arsenic
Barium
Cadmium
Chromium
Cobalt
Copper
Lead
Mercury
Molybdenum
Tin
Titanium
Zinc
Alpha-terpineol
Bis(2-ethylhexyl)
phthalate
Butylbenzyl phthalate
Carbazole
Fluoranthene
N-decane
N-octadecane
SGT-HEM 7
BOD5
TSS
Antimony
Copper
Molybdenum
Zinc
Acetophenone
Aniline
Benzoic Acid
o-Cresol
p-Cresol
Phenol
Pyridine
2-butanone
2-propanone
2,3-dichloroaniline
2,4,6-trichlorophenol







        7EPA has not proposed regulating SGT-HEM. However, EPA has asked for comment on whether SGT-HEM
should be used as an indicator parameter for the organic analytes in this Subcategory.

                                                 7-33

-------
    Chapter 7 Pollutants Selected for Regulation  Development Document for the CWT Point Source Category
    Indirect Dischargers                                                                     7.7.2
         As detailed in Section 7.6, all pollutants regulated for direct dischargers which pass-through
    well-operated POTWs are regulated for indirect dischargers. Table 7-16 shows the final list of
    regulated pollutants for indirect dischargers selected by EPA.
    Table 7-16.
Final List of Regulated Pollutants for Indirect Discharging CWT Facilities
Metals Subcategory
Option 4
PSES
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Hex chromium
Lead
Manganese
Mercury
Nickel
Selenium
Silver
Tin
Titanium
Total cyanide
Vanadium
Zinc
Metals Subcategory
Option 3
PSNS
Antimony
Arsenic
Cadmium
Chromium
Cobalt
Copper
Hex chromium
Lead
Manganese
Mercury
Nickel
Silver
Tin
Titanium
Total cyanide
Vanadium
Zinc

Oils Subcategory
Option 8 (PSES)
Option 9 (PSNS)
Antimony
Barium
Cobalt
Copper
Molybdenum
Tin
Titanium
Zinc
Alpha-terpineol
Bis-2-ethylhexyl
phthalate
Carbazole
Fluoranthene
N-decane
N-octadecane
SGT-HEM 8


Organics Subcategory
Option 3
PSES, PSNS
Molybdenum
Aniline
Benzoic Acid
o-Cresol
p-Cresol
2,3-dichloroaniline












        8EPA has not proposed regulating SGT-HEM.  However, EPA has asked for comment on whether SGT-HEM
should be used as an indicator parameter for the organic analytes in this Subcategory.

                                                  7-34-

-------
                                                                               Chapter
                                                                                      8
      WASTEWATER TREATMENT TECHNOLOGIES
     This  section  discusses   a   number  of
     wastewater    treatment    technologies
considered by EPA for the development of these
guidelines and standards for the CWT Industry.
Many  of these  technologies are being used
currently at CWT facilities.  This section also
reviews  other  technologies  with potential
application in treating certain CWT pollutants of
concern.
    Facilities in  the CWT industry use a wide
variety  of technologies  for treating  wastes
received for treatment or recovery .operations and
wastewater generated on site. The technologies
are grouped into the following five categories for
this discussion:

   Best Management Practices, section 8.2.1;
   Physical/Chemical/Thermal     Treatment,
    section 8.2.2;
   Biological Treatment, section 8.2.3;
   Sludge Treatment  and  Disposal,  section
    8.2.4; and
   Zero Discharge Options, section 8.2.5.

    The processes reviewed  here include both
those that remove  pollutant contaminants in
wastewater and those that destroy them. Using a
wastewater treatment technology that removes,
rather than destroys, a pollutant will produce a
treatment residual.   In many instances, this
residual is in the form of a sludge, that, typically,
a CWT further treats on site in preparation for
disposal. Section 8.2.4 discusses  technologies for
dewatering sludges to concentrate them prior to
disposal. In the case of other types of treatment
residuals, such as spent activated carbon and
filter media, CWT facilities generally send those
off site to a vendor facility for management.
TECHNOLOGIES CURRENTLY IN USE
8.1
    EPA obtained information on the treatment
technologies in use in the CWT industry from
responses to the Waste Treatment Industry (WTI)
Questionnaire, site visits, public comments to the
original proposal and the 1996 Notice of Data
Availability.  As described in Section 4, of the
estimated 205 CWT facilities, EPA has obtained
detailed facility-specific technology information
for 116 of the direct and indirect discharging
CWT facilities.   Although EPA has facility-
specific information for 145 facilities, only 116
of   these   facilities   provided  technology
information. The detail provided regarding the
technology information differs depending on the
source.   Information for the 65 facilities that
completed the WTI Questionnaire was the most
explicit because the questionnaire contained a
detailed  checklist of  wastewater  treatment
technologies, many of which are discussed in this
section.  Technology  information from other
sources, however, is much less descriptive.
    Table 8-1 presents  treatment technology
information by subcategory for the 116 indirect
and direct discharging CWT facilities for which
EPA has facility-specific treatment technology
information. The information  in Table 8-1 has
not been scaled to represent the entire population
of CWT facilities.  Responses to the WTI
Questionnaire provide the primary basis  for the
technology information for the metals and the
organics subcategories. Comments to the 1996
Notice of Data Availability provide the primary
                                           8-1

-------
Chapter 8 Wastewater Treatment Technologies  Development Documentfoiithe^WTPoMt_Source_Categor^


source of the technology information for the oils
subcategory. It should be noted that a number of
facilities commingle different subcategory wastes
for treatment.  EPA has attributed these treatment
technologies to all appropriate subcategories.
Table 8-1. Percent Treatment Ih-place by Subcategory and by Method of Wastewater Disposal

Number of Facilities with
Treatment Technology Data
Equalization4
Neutralization4
Flocculation
Emulsion Breaking
Gravity-Assisted Separation
Skimming4
Plate/Tube Separation4
Dissolved Air Flotation
Chromium Reduction4
Cyanide Destruction4
Chemical Precipitation
Filtration
Sand Filtration4
Mutimedia Filtration4
Ultrafiltration
Reverse Osmosis4
Carbon Adsorption
Ion Exchange4
Air Stripping
Biological Treatment
Activated Sludge
Sequencing Batch Reactors4
Vacuum Filtration4

Metals Subcategorv
Direct Indirect

91
78
89
44
11
89
22
0
22
33
33
78
44
11
11
0
11
22
0
0
56
33
0
11
67

41 '
68
73
51
29
61
27
10
5
76
46
88
32
15
5
0
0
12
2
7
2
0
2
17
61
Oils Subcategorv
Direct Indirect

31'2
100
100
100
33
100
100
0
33
0
100
0
33
0
0
0
0
67
0
0
100
100
0
100
100

80W
65
61
48
56
85
58
19
23
48
23
34
19
16
0
8
3
18
0
11
11
0
0
6
39
Oreanics Subcategorv
Direct Indirect

4;
75
100
75
25
100
25
0
50
0
25
25
25
0
0
0
0
0
0
0
100
100
0
25
75

141
71
57
57
50
64
57
21
0
57
29
64
21
21
7
0
0
21
0
0
7
0
7
7
36
 JSum does not add to 116 facilities.  Some facilities treat wastes in multiple subcategories.
 *bf the 3 direct discharging oils facilities for which EPA has facility-specific information, only one completed the
 WTI Questionnaire.
 ^Dfthe 80 indirect discharging oils facilities for which EPA has facility-specific information, only 31 completed
 the WTI Questionnaire.
 4Information for these technologies for the oils subcategory is based on responses to the WTI Questionnaire only.
                                                8-2

-------
Chapter 8 Wastewater Treatment Technologies  Development Document for the C WT Point Source Category
TECHNOLOGY DESCRIPTIONS
Best Management Practices
  8.2
8.2.1
Physical/Chemical/
Thermal Treatment
Equalization
  8.2.2
8.2.2.1
     In addition to physical/chemical treatment
technologies, CWT facilities employ a number of
ancillary means to prevent or reduce the discharge
of pollutants.   These efforts are termed "best
management practices. EPA believes that CWT
facilities  should  design  best  management
practices in the CWT industry with the following
objectives in mind:

   Maximize the amount of waste materials and
    residuals  that  are recycled  rather  than
    disposed as residuals, as wastewater, or as
    waste material.
   Maximize recycling and reuse of wastewaters
    generated on site.
   Minimize the introduction of uncontaminated
    wastewaters into the treatment waste stream.
   Encourage waste generators to minimize the
    mixing of different wastes.
   Segregate wastes  for treatment particularly
    where  waste segregation would   improve
    treatment   performance   and  maximize
    opportunities for recycling.

    Waste segregation is one of the most
important tools available for maximizing waste
recycling and improving treatment performance.
For  example,  separate  treatment  of wastes
containing different types of metals allows the
recovery  of  the individual  metals  from  the
resultant sludges. Similarly, separate treatment
collection and treatment of waste oils will allow
recycling.   Many oils subcategory  facilities
currently practice waste oil recycling.
                    GENERAL DESCRIPTION
             The wastes received at many facilities in the
         CWT industry vary considerably in both strength
         and volume. Waste treatment facilities often need
         to equalize wastes by holding wastestreams in a
         tank for a certain period of time prior to treatment
         in order to obtain a stable waste stream which is
         easier to treat.   CWT facilities frequently  use
         holding tanks to consolidate small waste volumes
         and to  minimize the variability  of incoming
         wastes prior to certain treatment operations. The
         receiving or initial treatment tanks of a facility
         often serve as equalization tanks.
             The equalization tank serves many functions.
         Facilities use equalization tanks to consolidate
         smaller volumes of wastes  so that,  for batch
         treatment  systems, full  batch volumes  are
         available.  For continuous treatment  systems,
         facilities equalize the waste volumes so that they
         may introduce effluent to downstream processes
         at a uniform rate and strength. This dampens the
         effect of peak and minimum flows. Introducing
         a waste stream with a more uniform pollutant
         profile to the treatment system facilitates control
         of the operation of downstream treatment units,
         resulting  in  more  predictable and  uniform
         treatment results. Equalization tanks are usually
         equipped with agitators or aerators where mixing
         of the  wastewater is desired  and to prevent
         suspended solids from settling  to the bottom of
         the unit An example of effective equalization is
         the mixing of acid and alkaline wastes. Figure 8-
         1 illustrates an equalization system.
             EPA  does   not  consider the  use   of
         equalization tanks for dilution  as a legitemate
         use. In this context, EPA defines dilution as the
         mixing of more concentrated wastes with greater
         volumes of less concentrated wastes in a manner
         that reduces the concentration of pollutant in the
         concentrated wastes to a level  that enables the
         facility to avoid treatment of the pollutant.
                                             8-3

-------
Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    Wastewater
       Influent
                         Equalization Tank
Equalized
Wastewater
Effluent
Figure 8-1. Equalization System Diagram
                                    8-4

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Chanter 8 Waste-water Treatment Technologies  Development Document for the CWTPoint Source Category
             INDUSTRY PRACTICE
    EPA found equalization  being  used  at
facilities in all of the CWT subcategories. Of the
65 CWT facilities in EPA's WTI Questionnaire
data base that provided information concerning
the use of equalization, 44 operate equalization
systems.  Of these, approximately 44 percent
emply unstirred tanks and 56 percent use stirred
or aerated tanks.
    The combining of separate waste receipts in
large receiving  tanks  provides for  effective
equalization  even though  it is not necessarily
recognized as such. Nearly every facility visited
by EPA performed equalization, either in tanks
specifically designed for that purpose or in waste
receiving tanks.    Consequently,  EPA  has
concluded that equalization is underreported in
the data base.
Neutralization
8.2.2.2
            GENERAL DESCRIPTION
    Wastewaters treated at CWT facilities have
a wide range of pH values depending on the types
of wastes accepted.  Untreated wastewater may
require neutralization to eliminate either high or
low pH values prior to certain treatment systems,
such as biological treatment. Facilities often use
neutralization systems also in conjunction with
certain chemical treatment processes, such  as
chemical precipitation, to adjust the pH of the
wastewater to  optimize treatment efficiencies.
These facilities may add acids, such as sulfuric
acid or hydrochloric acid, to  reduce pH, and
alkalies, such as sodium hydroxides, to raise pH
values. Many metals subcategory facilities use
waste acids and waste alkalies for pH adjustment.
Neutralization may  be  performed in a holding
tank, rapid mix tank, or an equalization tank.
Typically, facilities use neutralization systems at
the end of a treatment system to control the pH of
the discharge to between 6 and 9 in order to meet
NPDES and POTW pretreatment limitations.
               Figure 8-2 presents  a flow diagram  for a
           typical neutralization system.

                        INDUSTRY PRACTICE
               EPA found neutralization systems in-place at
           facilities   identified  in   all  of  the  CWT
           subcategories. Of the 65 CWT facilities in EPA's
           WTI Questionnaire data  base that provided
           information concerning the use of neutralization,
           45 operate neutralization systems.
           Flocculation/Coagulation
                                      8.2.2.3
           GENERAL DESCRIPTION
    Flocculation is the stirring or agitation of
chemically-treated water to induce coagulation.
The terms coagulation and flocculation are often
used  interchangeably.     More  specifically,
"coagulation" is the reduction of the net electrical
repulsive forces at particle surfaces by addition of
coagulating chemicals, whereas "flocculation" is
the agglomeration of the destabilized particles by
chemical  joining and  bridging.   Flocculation
enhances  sedimentation or filtration treatment
system performance by increasing particle size
resulting  in increased  settling rates and filter
capture rates.
    Flocculation      generally      precedes
sedimentation and filtration processes and usually
consists of a rapid mix tank or in-line mixer, and
a flocculation tank. The waste stream is initially
mixed while a coagulant and/or a coagulant aid is
added. A rapid mix tank is usually designed for
a detention time of 15 seconds to several minutes.
After mixing, the coagulated wastewater flows to
a flocculation basin where slow mixing of the
waste  occurs.   The slow mixing allows  the
particles  to  agglomerate  into  heavier,  more
settleable/filterable solids.  Either mechanical
paddle mixers or diffused air provides mixing.
Flocculation basins are typically designed for a
detention time of 15 to 60 minutes. Figure 8-3
presents  a diagram of a clarification system
incorporating coagulation  and flocculation.
                                             8-5

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Chaoter 8 Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category
3

Wastewater i
Influent
n  T n
w.

/ control
H k
' 	 NPI itraliypri
Neutralization Tank Wastewater
Effluent
Figure 8-2. Neutralization System Diagram
8-6


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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category
  Coagulant
     Influent 
                                                                    Clarifier
                  Rapid Mix     Flocculating
                   Tank          Tank
                                                                                            Effluent
                                                                                 * Sludge
Figure 8-3.  Clarification System Incorporating Coagulation and Flocculation
                                                8-7

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  antpr R
                   Treatment Technologies  Develonment Document for the CWT Point Source Category
    There are three different types of treatment
chemicals      commonly      used      in
coagulation/flocculation processes:   inorganic
electrolytes,  natural  organic  polymers,  and
synthetic polyelectrolytes. The selection of the
specific treatment chemical is highly dependent
upon the characteristics and chemical properties
of the contaminants.  Many CWT facilities use
bench-scale jar tests to determine the appropriate
type and optimal dosage of coagulant/flocculent
for a given waste stream.

             INDUSTRY PRACTICE
    Chemical treatment methods to enhance the
separation of pollutants from water as  a solid
residual may include both chemical precipitation
and   coagulation/flocculation.      Chemical
precipitation  is  the  conversion  of  soluble
pollutants  such as metals into an  insoluble
precipitate   and   is   described  separately.
Flocculation is often an integral step in chemical
precipitation, gravity separation, and filtration.
Of the  65  CWT facilities  in EPA's  WTI
Questionnaire   data   base   that   provided
information    concerning    the   use    of
coagulation/flocculation,    31         operate
coagulation/flocculation systems.  However, due
to the integral nature of flocculation in chemical
precipitation   and  coagulation,   and   the
interchangeable use of the terminology, the use of
coagulation/flocculation at CWT facilities may
have been underreported.
 Emulsion Breaking
8.2.2.4
            GENERAL DESCRIPTION
    One process used to treat emulsified oil/water
 mixtures is emulsion breaking. An emulsion, by
 definition, is either stable or unstable.  A stable
 emulsion is one where small droplets of oil are
 dispersed within the water and are prevented from
 coalescing by repulsive electrical surface charges
 that  are  often a  result  of  the presence  of
emulsifying agents and/or surfactants.  In stable
emulsions,  coalescing  and  settling  of  the
dispersed oil droplets would occur very slowly or
not  at  all.    Stable  emulsions  are  often
intentionally formed by chemical addition to
stabilize the oil mixture for a specific application.
Some examples of stable emulsified oils  are
metal-working   coolants,    lubricants,    and
antioxidants.    An  unstable  emulsion,   or
dispersion, settles very rapidly and does  not
require treatment to break the emulsion.
    Emulsion breaking is achieved through the
addition   of chemicals  and/or  heat to  the
emulsified  oil/water  mixture.    The  most
commonly-used method of emulsion breaking is
acid-cracking where sulfuric or hydrochloric acid
is added to the oil/water mixture until the pH
reaches 1 or 2. An alternative to acid-cracking is
chemical  treatment  using emulsion-breaking
chemicals such as surfactants and coagulants.
After addition of the treatment chemical, the tank
contents are mixed. After the emulsion bond is
broken, the oil residue is allowed to float to the
top of the tank. At this point, heat (100 to 150
F)  may  be applied  to speed the separation
process. The oil is then skimmed by mechanical
means, or the water is decanted from the bottom
of the tank.  The oil residue  is then further
processed or disposed. A diagram of an emulsion
breaking system is presented in Figure 8-4.

            INDUSTRY PRACTICE
    Emulsion breaking is a common process in
the CWT industry. Of the 116 CWT facilities in
EPA's WTI Questionnaire and NOA comment
data base that provided information concerning
the  use  of emulsion breaking, 49 operate
emulsion breaking systems. Forty-six of the 83
oils subcategory facilities in EPA's data base use
emulsion-breaking. As such, EPA has concluded
that emulsion breaking is the baseline, current
performance technology  for oils subcategory
facilities that treat emulsified oily wastes.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category
                Chemical
                Addition
Oil
Residue
   Wastewa
    Influent
                                                                         Treated

                                                                         Effluent
                                                        Sludge
 Figure 8-4.     Emulsion Breaking System Diagram

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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
Gravity Assisted Separation
8.2.2.5
1.  GRAVITY OIL/WATER SEPARATION
           GENERAL DESCRIPTION
    Like emulsion breaking,  another in-place
treatment process primarily used to remove oil
and grease and related pollutants from oil/water
mixtures, is gravity separation.  Unlike emulsion
breaking, gravity separation is only effective for
the bulk removal of free oil and grease. It is not
effective in the removal of emulsified or soluble
oils.   Gravity  separation  is  often used  in
conjunction with emulsion  breaking at  CWT
facilities.
    Gravity separation may be performed using
specially designed tanks or it may occur within
storage  tanks.  During   gravity   oil/water
separation, the wastewater is held under quiescent
conditions long enough to allow the oil droplets,
which have a lower specific gravity than water, to
rise  and form a layer on the surface.   Large
droplets rise more readily than smaller droplets.
 Once the oil has risen to  the  surface of the
wastewater, it must be removed.  This is done
mechanically  via  skimmers,  baffles,  plates,
slotted pipes, or dip tubes.   When treatment or
storage tanks serve as gravity separators, the oil
may be decanted off the surface or, alternately,
the separated water may be drawn off the bottom
until the oil layer appears.  The resulting oily
residue from a gravity separator must then be
further processed or disposed.
    Because gravity separation is such a widely-
used technology, there is  an  abundance  of
equipment  configurations available.   A very
common unit is the API (American Petroleum
Institute) separator, shown in Figure 8-5.  This
unit uses an overflow and an underflow baffle to
skim the floating oil  layer from the surface.
Another oil/water  gravity  separation process
utilizes  parallel  plates  which  shorten  the
necessary  retention time  by shortening the
distance the  oil droplets  must  travel before
separation occurs.
             INDUSTRY PRACTICE
    Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data base that
provided  information  concerning the use  of
oil/water gravity separation, 16 operate skimming
systems, seven operate coalescing plate or tube
separation systems,  and 42 operate oil/water
gravity separation systems. Oil/water separation
is such  an integral step at oils  subcategory
facilities  that every oils subcategory facility
visited  by EPA performed gravity oil/water
separation, either in tanks specifically designed
for that purpose or in waste receiving or storage
tanks.

2.  CLARIFICATION
           GENERAL DESCRIPTION
    Like   oil/water   separators,  clarification
.systems  utilize gravity to provide continuous,
low-cost separation and removal of particulates,
flocculated  impurities,  and precipitates  from
water. These systems typically follow wastewater
treatment processes  which generate  suspended
solids,  such  as chemical  precipitation  and
biological treatment.
    In a clarifier, wastewater is allowed to flow
slowly and uniformly, permitting the solids more
dense than water to settle to the bottom. The
clarified wastewater is discharged by flowing
from the top of the clarifies over a weir.  Solids
accumulate at the bottom of a clarifier  and a
sludge must be periodically removed, dewatered
and disposed.     Conventional  clarifiers are
typically  circular or rectaingular tanks.  Some
specialized  types   of clarifiers  additionally
incorporate tubes, plates, or lamellar networks to
increase the settling area.  A circular clarification
system is illustrated in Figure 8-6.
                                            8-10

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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
          Oil Retention
          Baffle
                      \
                   o
     Wastewater
     Influent
Diffusion Device     9"
(vertical baffle)
Skimmer
              \
                                                Scraper
                               Sludge
                               Hopper
Oil
Retention
Baffle
                                          Treated
                                          Effluent
 Figure 8-5.     Gravity Separation System Diagram

                                          8-11

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  nntpr s Wntfpwater Treatment Technolosies  Develooment Document for the CWTPoint Source Category
                Skimming Scraper
       Overflow
              Influent
                                                 Baffle
                                                                       Effluent
                                                                Skimmings Removal
Sludge Removal
Figure 8-6.     Clarification System Diagram
                                           8-12

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Chapter 8 Waste-water Treatment Technologies  Development Document for the CWT Point Source Category
             INDUSTRY PRACTICE
    Of the 65 CWT facilities in  EPA's  WTI
Questionnaire   data  base  that   provided
information concerning the use of clarification
systems, 39 pperate settling systems and seven
operate  coalescing  plate  or tube  separation
systems.  EPA did not obtain detailed enough
treatment technology information from the Notice
of  Data Availability  comments  for the oils
subcategory facilities to determine the presence or
absence of clarification systems. In general, oils
subcategory facilities are more likely to utilize
gravity oil/water  separation.   However, oils
facilities  that  also  utilize solids generation
processes  such as chemical  precipitation  or
biological  treatment  as  part of  their waste
treatment train will likely utilize  clarification
systems.

3.  DISSOLVED AIR FLOTATION
           GENERAL DESCRIPTION
    Flotation is the process of using fine bubbles
to  induce  suspended  particles to  rise  to the
surface of a tank where they can be collected and
removed. Gas bubbles are introduced into the
wastewater and attach themselves to the particles,
thereby  reducing their  specific  gravity  and
causing them to  float.  Fine bubbles may be
generated by dispersing air mechanically, by
drawing them from the water using a vacuum, or
by  forcing air into  solution under elevated
pressure followed by pressure release. The latter,
called dissolved  air  flotation  (DAF),  is the
flotation process used most frequently by CWT
facilities and is  the  focus of the  remaining
discussion.
    DAF is commonly used to remove suspended
solids and dispersed oil  and grease from oily
wastewater.   It  may effectively  reduce the
sedimentation times of suspended particles that
have  a specific gravity close to that of water.
Such  particles may include both solids  with
specific gravity slightly greater than water and
oil/grease particles with specific gravity slightly
   less  than  water.    Flotation  processes  are
   particularly useful for inducing the removal of
   oil-wet  solids that  may exhibit a combined
   specific gravity nearly the same as water. Oil-wet
   solids are difficult to remove from wastewater
   using gravity sedimentation alone, even  when
   extended sedimentation times are utilized. Figure
   8-7 is a flow diagram of a DAF system.
      The major components  of a conventional
   DAF unit include a centrifugal pump, a retention
   tank, an air compressor, and a flotation tank. For
   small volume  systems,  the  entire  influent
   wastewater stream is pressurized  and contacted
   with air in a retention tank for several minutes to
   allow time for the  air to dissolve.    The
   pressurized water that is nearly saturated with air
   is then passed through a pressure reducing valve
   and introduced into  the flotation tank .near the
 .  bottom.  In larger units, rather than pressurizing
   the entire wastewater  stream, a portion of the
   flotation cell effluent is recycled through the
   pressurizing pump and the retention tank.  The
   recycled   flow   is  then   mixed  with   the
   unpressurized main stream just prior to entering
   the flotation tank.
      As soon as the pressure  is released,  the
   supersaturated air begins to come out of solution
   in the form of fine bubbles.  The bubbles attach
   to suspended particles and become enmeshed in
   sludge floes, floating them to the surface.   The
   float is continuously swept from the tank surface
   and is discharged over the end wall of the  tank.
   Sludge, if generated, may be collected from the
   bottom of the tank.
      The  mechanics  of  the  bubble-particle
   interaction include: (1) attachment of the bubbles
   on the particle surface, (2) collision between a
   bubble and a particle, (3)  agglomeration of
   individual particles  or a floe structure as  the
   bubbles rise, and (4) absorption of the bubbles
   into a floe structure as it forms. As such, surface
   chemistry plays a critical role in the effective
   performance of air flotation.
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fhanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
                     Float Removal Device
   Float
   Wastewater
   Influent
   (Saturated
   with Air)
                                                                 Treated
                                                                 Effluent
                                                              Baffle
Sludge (If Produced)
 Figure 8-7.     Dissolved Air Flotation System Diagram

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Chapter 8 Wastewater Treatment Technologies   Development Document for the CWT Point Source Category
    Other operating variables which affect the
performance  of  DAF  include  the  operating
pressure,  recycle ratio, detention time, the
air/solids ratio, solids and hydraulic loading rates,
and the application of chemical aids.
    The operating pressure of the retention tank
influences the size of the bubbles released.  If the
bubbles are too large, they do not attach readily to
the suspended particles. If the bubbles are too
fine, they will disperse and break up fragile floe.
Wastewater  treatment   textbooks  generally
recommend a bubble size of 100 micrometers.
The  most practical way to establish the proper
rise rate is to  conduct experiments at various air
pressures.
    The  air-to-solids  ratio  in the  DAF unit
determines the   effluent  quality  and  solids
concentration in  the  float.   This is because
adequate  air bubbles  are  needed to  float
suspended  solids to the surface of the  tank.
Partial flotation of solids will occur if inadequate
or excessive amounts of air bubbles are present.
    Researchers   have  demonstrated that the
addition of chemicals to the water stream is an
effective means of increasing the  efficiencies of
DAF treatment systems. The use of coagulants
can drastically increase the oil removal efficiency
of DAF units.  Three types of  chemicals are
generally utilized to improve the efficiency of air
flotation units used for  treatment of produced
water; these chemicals are surface active agents,
coagulating agents, and polyelectrolytes. The use
of treatment  chemicals  may also enhance the
removal of metals in air flotation units. EPA's
collection of  data from the CWT industry has
shown that many  facilities use DAF systems to
remove metals from their waste streams.

             MDUSTRY PRACTICE
    Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data base that
provided information concerning use of DAF, 21
operate DAF  systems.
Chromium Reduction
8.2.2.6
           GENERAL DESCRIPTION
    Reduction is a chemical reaction in which
electrons are transferred from one chemical to
another. The main reduction application at CWT
facilities is the reduction of hexavalent chromium
to trivalent chromium, which is  subsequently
precipitated from the wastewater in conjunction
with other metallic salts. A low pH of 2 to 3 will
promote chromium reduction reactions.   At pH
levels  above  5, the reduction rate is slow.
Oxidizing agents such as dissolved oxygen and
ferric iron interfere with the reduction process by
consuming the reducing agent.
    The use of strong reducing agents such as
sulfur   dioxide,  sodium  bisulfite,  sodium
metabisulfite,   and   ferrous  sulfate   also
promotesshexavalent chromium reduction.  The
two most commonly used reducing agents in the
CWT  industry are  sodium  metabisulfite or
sodium bisulfite and gaseous sulfur dioxide.  The
remaining discussion will focus on  chromium
reduction using these agents only.  Figure 8-8 is
a diagram of a chromium reduction system.
    Chromium  reduction   using   sodium
metabisulfite (Na^S^) and  sodium bisulfite
(NaHSO3)   are  essentially  similar.     The
mechanism for the reaction using sodium bisulfite
as the reducing agent is:
       3NaHSO3 + 3H2SO4 + 2H2CrO4
       - Cr2(SO4)3 + 3NaHSO4  + 5H2O

    The hexavalent  chromium  is reduced to
trivalent chromium using sodium metabisulfite,
with sulfuric acid used to lower the pH  of the
solution. The amount of sodium metabisulfite
needed to reduce the hexavalent chromium is
reported as 3 parts of sodium bisulfite per part of
chromium, while the amount of sulfuric acid is 1
part per part  of chromium.  The theoretical
retention time is about 30 to 60 minutes.
    A second process uses sulfur dioxide (SO2)
as the reducing agent The reaction mechanism is
as follows:
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  anter R Wastewater Treatment Technoloaies  Development Document for the CWT Point Source Category
          3S02 + 3H2O - 3H2SO3
   3H2S03 + 2H2Cr04 - Cr2(SO4)3 + 5H2O
    The  hexavalent  chromium is reduced to
trivalent  chromium using sulfur dioxide, with
sulfuric acid used to lower the pH of the solution.
The amount of sulfur dioxide needed to reduce
the hexavalent chromium is reported as 1.9 parts
of sulfur dioxide per part of chromium, while the
amount of sulfuric acid is  1  part per part of
chromium. At a pH of 3, the theoretical retention
time is approximately 30 to 45 minutes.

             INDUSTRY PRACTICE
    Of the  65 CWT facilities in EPA's WTI
Questionnaire   data   base  that  provided
information concerning the use of chromium
reduction,  35 operate  chromium  reduction
systems.  All of the 35 facilities are in the metals
subcategory. At these 35 facilities, there are four
sulfur dioxide processes, 21  sodium  bisulfite
processes,  and  two  sodium  metabisulfite
processes.  The remaining systems use various
other reducing agents.
 Cyanide Destruction
8.2.2.7
            GENERAL DESCRIPTION
    Electroplating and metal finishing operations
 produce the major portion  of cyanide-bearing
 wastes  accepted at CWT facilities.    EPA
 observed three  separate cyanide  destruction
 techniques during site visits at CWT facilities.
 The first two methods are alkaline chlorination
 with gaseous chlorine and alkaline chlorination
 with sodium hypochlorite. The third method is a
 cyanide destruction process, details of which the
 generator has claimed are confidential business
 information (CBI). The two alkaline chlorination
 procedures are discussed here.
     Alkaline  chlorination  can  destroy  free
 dissolved hydrogen cyanide and can oxidize all
 simple and some complex inorganic cyanides. It,
 however, cannot effectively oxidize stable iron,
 copper, and nickel cyanide  complexes.   The
addition  of heat to  the  alkaline chlorination
process  can  facilitate  the  more  complete
destruction of total cyanid.es.  The use of an
extended retention time can also improve overall
cyanide destruction. Figure 8-9 is a diagram of
an alkaline chlorination system.
    In alkaline  chlorination  using  gaseous
chlorine,  the oxidation process is accomplished
by direct addition of chlorine (C12) as the oxidizer
and sodium hydroxide (NaOH) to maintain pH
levels. The reaction mechanism is:
           NaCN + C12 + 2NaOH
          - NaCNO  + 2NaCl + H2O
         2NaCNO + 3C12 + 6NaOH
      - 2NaHCO3 + N2 + 6NaCl + 2H2O
    The destruction of the cyanide takes place in
two stages. The primary reaction is the partial
oxidation of the cyanide to cyanate at a pH above
9.  In the second stage, the pH is lowered to a
range of 8 to 8.5 for the oxidation of the cyanate
to  nitrogen  and carbon  dioxide  (as  sodium
bicarbonate).  Each part of cyanide requires 2.73
parts of chlorine to convert it to cyanate and  an
additional 4.1 parts of chlorine to oxidize the
cyanate to nitrogen and carbon dioxide. At least
1.125 parts of sodium hydroxide are required to
control the pH with each stage.
    Alkaline chlorination can also be conducted
with   sodium  hypochlorite  (NaOCl)   as  the
oxidizer.  The oxidation of cyanide waste using
sodium hypochlorite  is similar to the gaseous
chlorine process. The reaction mechanism is:
       NaCN  + NaOCl -  NaCNO + NaCl
         2NaCNO +  3NaOCl + H2O
          - 2NaHCO3 + N2 + 3NaCl
    In the first step, cyanide is oxidized to
 cyanate with the pH maintained in the range of 9
 to 11.  The second step oxidizes cyanate to
 carbon dioxide (as  sodium bicarbonate) and
 nitrogen at a controlled pH of 8.5.  The amount of
 sodium  hypochlorite and  sodium  hydroxide
 needed to perform the oxidation is 7.5 parts and
 8 parts per part of cyanide., respectively.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category
                      Su If uric
                        Acid
                              .V
          pH Controller
           Wastewater
             Influent
    Treatment
    Chemical
V
A"
         Chemical Controller
                                                             - Treated
                                                              Effluent
                                Reaction Tank
Figure 8-8.     Chromium Reduction System Diagram


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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
        Caustic Feed
Hypochlorite or Chlorine Feed
         Wastewater
         Influent     
              Acid Feed
      Treated
      Effluent
                                               First Stage
                            Second S
  age
 Figure 8.9     Cyanide Destruction by Alkaline Chlorination
                                     8-18

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Chapter 8 Wastewater Treatment Technologies  Development Document for the C WTPoint Source Cateeorv
             INDUSTRY PRACTICE
    Of the 65 CWT facilities  in EPA's WTI
Questionnaire   data   base   that   provided
information  concerning  the use  of  cyanide
destruction,  22  operate  cyanide destruction
systems. All of the 22 facilities are in the metals
subcategory.  Of these 22 facilities, one is  a
thermal unit, one is the CBI unit, and the rest are
chemical reagent systems.
Chemical Precipitation
8.2.2.8
            GENERAL DESCRIPTION
    Many  CWT   facilities   use   chemical
precipitation to remove metal compounds from
wastewater.   Chemical precipitation  converts
soluble metallic ions  and  certain  anions  to
insoluble forms, which precipitate from solution.
Chemical precipitation  is usually performed in
conjunction    with    coagulation/flocculation
processes which facilitate the agglomeration of
suspended and colloidal material. Most metals
are relatively insoluble as hydroxides, sulfides, or
carbonates. Coagulation/flocculation processes
are used  in conjunction  with precipitation  to
facilitate removal by agglomeration of suspended
and colloidal materials.  The precipitated metals
are subsequently removed from the wastewater
stream  by liquid filtration or clarification (or
some other form of gravity-assisted separation).
Other treatment processes such as equalization,
or  chemical   oxidation  or  reduction  (e.g.,
hexavalent chromium reduction) usually precede
the chemical precipitation process.  Chemical
interactions, temperature, pH,  solubility of waste
contaminants, and mixing effects all affect the
performance  of the  chemical  precipitation
process.
    Chemical precipitation is a two-step process.
At CWT  facilities,  it is typically performed  in
batch operations. In the first step, precipitants
are mixed with the wastewater, typically  by
mechanical means, such as mixers, allowing the
formation of the insoluble metal precipitants.
The detention time in this step of the process is
specific to the wastewater being treated, the
treatment chemicals used, and the desired effluent
quality.   In the second step, the precipitated
metals  are  removed  from  the  wastewater,
typically through filtration or clarification.  If
clarification is used,.a flocculent is sometimes
added to aid the settling process. The resulting
sludge from the clarifier or filter must be further
treated, disposed, or recycled. A typical chemical
precipitation system is shown in Figure 8-10.
    Various  chemicals  may   be  used   as
precipitants.    These  include  lime,  sodium
hydroxide (caustic), soda ash, sodium sulfide, and
ferrous sulfate.  Other chemicals used in the
precipitation process  for pH adjustment and/or
coagulation include sulfuric and phosphoric acid,
ferric chloride, and  polyelectrolytes.  Often,
facilities use a combination of these chemicals.
CWT   facilities  generally    use   hydroxide
precipitation   and/or  sulfide  precipitation.
Hydroxide precipitation is effective in removing
metals such as antimony, arsenic,  chromium,
copper,  lead, mercury, nickel, and zinc. Sulfide
precipitation is used instead of, or in addition to,
hydroxide precipitation to remove specific metal
ions including lead, copper, silver, cadmium, zinc,
mercury, nickel, thallium, arsenic, antimony, and
vanadium.     Both  hydroxide  and  sulfide
precipitation are discussed in greater detail below.
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  nf *r s Wactpwatpr Treatment Technologies  Development Document for the CWT Point Source Category
                                Treatment Chemical


                                        \7
     Wastewater
        Influent

                                                  Chemical Controller
                     Chemical Precipitation Tank
Figure 8-10.    Chemical Precipitation System Diagram

                                     8-20
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                                                             Effluent

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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    Hydroxide precipitation using lime or caustic
is the most commonly-used means of chemical
precipitation at CWT facilities. Of these, lime is
used more  often  than caustic.   The  reaction
mechanism for each of these is as follows:

            Ca(OH)2 - M(OH)2i  + Ca^.

            2NaOH - M(OH)2J + 2Na++

    The chief advantage of lime over caustic is
its lower cost However, lime is more difficult to
handle and feed, as it must be slaked,  slurried,
and mixed, and can plug the, feed system lines.
Lime also produces a larger volume of sludge
than caustic, and  the sludge is generally not
suitable for reclamation due to its homogeneous
nature.
    Sulfide  precipitation  is  the  next most
commonly-used means of chemical precipitation
at CWT facilities.  It is used to remove lead,
copper, silver, cadmium, zinc, mercury, nickel,
thallium, arsenic, antimony, and vanadium from
wastewaters. An advantage of the sulfide process
over the hydroxide process is that  it can reduce
hexavalent chromium to the trivalent state under
the same process conditions required for metals
precipitation. The use of sulfides also allows for
the precipitation of metals when chelating agents
are present.  The two most common- sulfide
precipitation processes are the soluble sulfide
process  and  the   insoluble  sulfide  (Sulfex)
process.
    In the soluble sulfide process, either sodium
sulfide  or  sodium  hydrosulfide,  both  highly
soluble, is added in high concentration either as a
liquid reagent or from rapid mix tanks using solid
reagents.   This  high concentration of soluble
sulfides results in  rapid precipitation of metals
which then results  in the  generation of  fine
precipitate  particles  and hydrated colloidal
particles. These fine particles do not settle or
filter well without the addition of coagulating and
flocculating agents to aid in the formation of
larger, fast-settling floe. The high concentration
of soluble sulfides may also lead to the generation
of highly toxic and odorous hydrogen sulfide gas.
To  control this problem, the treatment facility
must carefully control the  dosage and/or the
process vessels must be enclosed and vacuum
evacuated. The reaction mechanism for soluble
sulfide precipitation is:
                  +s" -  MSI.
    The basic principle governing the insoluble
sulfide process is that ferrous sulfide (FeS) will.
disassociate into ferrous  and sulfide  ions, as
predicted by its solubility, producing a sulfide
concentration  of approximately 2 mg/1 under
normal  conditions.   In  the insoluble sulfide
process,  a  slurry  of freshly  prepared FeS
(prepared by reactive FeSO4 and NaHS) is added
to the  wastewater.   As  the  sulfide ions are
consumed in precipitating the metal  pollutants,
additional FeS  will  disassociate.   This will
continue as long as other heavy metals  with lower
equilibrium  constants  are present in solution.
Because most heavy metals have sulfides that are
less  soluble  than  ferrous  sulfate,  they will
precipitate as metal sulfides. In addition, if given
enough time, any metal hydroxides present will
dissolve and precipitate out as sulfides.  If the
operation is performed under alkaline conditions,
the released ferrous ion will precipitate out as a
hydroxide. The following reactions occur when
FeS is added to a solution that contains dissolved
metal and metal hydroxide:

              FeS - Fe+,+ + S"

           '  M4"*  +S"  - MSI
           M(OH)2- M++
          Fe++ + 2(OH)--Fe(OH)2l

    One  advantage of  the insoluble  sulfide
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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
process over the soluble sulfide process is that the
insoluble sulfide process generates no detectable
H2S gas odor.  This  is because the dissolved
sulfide concentration is maintained at a relatively
low concentration. Disadvantages of the insoluble
sulfide process include considerably higher than
stoichiometric   reagent   consumption   and
significantly higher sludge generation than either
the hydroxide or soluble sulfide process.
    Wastewater treatment facilities often choose
to combine hydroxide precipitation and sulfide
precipitation  for optimal  metals  removal.  A
common configuration is a two-stage process in
which hydroxide precipitation is followed by
sulfide precipitation with each stage followed by
a separate solids removal step. This will produce
the  high  quality  effluent  of  the  sulfide
precipitation process while significantly reducing
the  volume  of sludge  generated  and  the
consumption of sulfide reagent.
    In addition to the type of treatment chemical
chosen, another important operational variable in
chemical precipitation is pH. Metal hydroxides
are   amphoteric,  meaning  they  can   react
chemically as acids or bases.  As such, their
solubilities increase toward both lower and higher
pH levels. Therefore, there is an optimum pH for
hydroxide  precipitation for each metal,  which
corresponds to its point of minimum solubility.'
Figure 8-11  presents calculated solubilities of
metal hydroxides. For example, as demonstrated
in this figure, the optimum pH range where zinc
is the least soluble is between 8 and 10. The
solubility of metal sulfides is not as sensitive to
changes in pH as hydroxides and  generally
decreases as pH increases.  The typical operating
pH range for sulfide precipitation is between 7
and 9.  Arsenic and antimony are" exceptions to
this rule and require a pH below 7 for optimum
removal. As such, another advantage of sulfide
precipitation over hydroxide precipitation is that
most metals can be removed to extremely low
concentrations at a single pH.
    For wastewater contaminated with a single
metal, selecting the optimum treatment chemical
and  treatment pH  for .-precipitation  simply
requires  the  identification  of the  treatment
chemical/pH combination  that  produces the
lowest solubility of that metal.  This is typically
done using a series of bench-scale treatability
tests.     However,  when   wastewater   is
contaminated with more 1han  one  metal, as is
often the case for wastewaters at CWT facilities,
selecting the optimum treatment chemical and pH
for a single-stage precipitation process becomes
more difficult  and often  involves a tradeoff
between optimal removal of two or more metals.
In general, for wastewater contaminated with
multiple metals, EPA has concluded that a single-
stage precipitation process does not provide for
adequate treatment.  In such cases, a series  of
chemical treatment steps  using different pH
values and/or different treatment chemicals may
be more appropriate.  Each of these treatment
steps needs to be followed by a solids  separation
step in order to prevent the resolubilization of
metal  precipitates  during  the  subsequent
treatment step.
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 Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Sovrce Category
                100
                 10-.
                  1 -
                0.1 -
               0.01 -
              0.001 -
             0.0001
                    0         2         4        6        8        10        12        14
                                                      PH
Figure 8-11. Calculated Solubilities of Metal Hydroxides
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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    In order to take advantage of the effects of
pH and treatment chemical selection on metals
precipitation, a facility may hold its wastes and
segregate them by pollutant content for treatment.
This type of waste treatment management, called
selective metals precipitation, may be adopted in
order to optimize the recovery of specific metal
pollutants.  In instances where the  segregated
wastes contain several metals,  the  pH of the
precipitation process may be adjusted so that the
desired metal for  recovery is  precipitated in
greater proportion than  the  other  metals.
Multiple precipitation steps are then performed in
series on a single waste stream using different pH
values,  resulting   in  different metals  being
selectively precipitated into  separate  sludges.
The production of specific sludges  containing
only the target metals makes the sludges more
suitable for reclamation. If the sludge is to be
sold to a  smelter  for  re-use,  then hydroxide
precipitation  using only  caustic   should  be
performed.  The calcium compounds from lime
would interfere with the smelting process.
    Selective  precipitation  is  advantageous
because the metals may be reclaimed and re-used
rather than disposed as a sludge in a landfill and
because it allows  for optimal removal  of the
metals of concern. However,  selective metals
precipitation does have additional costs such as
those  associated  with  the  extra  tanks  and
operating   personnel  required   for  waste
segregation.

             INDUSTRY PRACTICE
    Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data  base that
provided  information concerning  the use of
chemical  precipitation,  57 operate  chemical
precipitation systems. Fifty-one of these facilities
treat metals  subcategory wastewaters.    As
discussed previously, a single facility  may use
several chemical precipitation steps, depending
upon the type of waste being treated. Of the 51
chemical  precipitation  systems   at   metals
subcategory facilities,  13  operate  secondary
precipitation processes,  .four operate tertiary
precipitation  processes,  and   one  employs
selective chemical precipitation processes.

Filtration                             8.2.2.9
    Filtration  is a method for separating solid
particles from a fluid through the use of a porous
medium.  The driving  force in filtration is a
pressure gradient caused by gravity, centrifugal
force, pressure, or a vacuum.  CWT facilities use
filtration treatment processes to remove solids
from wastewaters after physical/chemical  or
biological treatment,  or as the primary source of
waste treatment. Filtration processes utilized in
the CWT industry include a broad range of media
and membrane separation technologies.
    To aid in removal, the filter medium may be
precoated with a filtration aid  such as ground
cellulose or  diatomaceous earth.  Polymers  are
sometimes injected  into the  filter feed piping
downstream   of  feed   pumps   to   enhance
flocculation of smaller floes to improve solids
capture.  The following sections  discuss  the
various  types  of filtration  in use  at  CWT
facilities.

1.  SAND FILTRATION
           GENERAL DESCRIPTION
    Sand filtration processes consist of either a
fixed or moving bed of media that traps  and
removes suspended  solids  from water passing
through the media. There are two types of fixed
sand bed filters: pressure and gravity.  Pressure
filters contain media in an enclosed, watertight
pressure vessel and require a feed pump to force
the water through the media.  A  gravity filter
operates on the basis  of differential pressure of a
static head  of water above  the media, which
causes flow through the filter. Filter loading rates
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Chapter 8 Waste-water Treatment Technologies  Development Document for the CWT Point Source Category
for sand filters are typically between 2 to 6
gpm/sq ft.
    Fixed media filters have influent and effluent
distribution systems consisting of pipes and
fittings.  A stainless steel screen covered with
gravel generally serves as the tank bottom and
support for the sand. Dirty water enters the top
of the filter and travels downward.
    Moving bed filters use an air lift pump and
draft tube to recirculate sand from the bottom to
the top of the filter vessel, which is usually open
at the top.  Dirty water entering the filter at the
bottom must travel upward, countercurrently,
through the downward moving fluidized sand
bed. Particles are strained from the rising water
and carried downward with the sand. Due to the
difference in specific gravity, the lighter particles
are removed from the filter when the sand is
recycled through a separation box often located at
the top of the filter.  The heavier sand falls back
into the filter, while the lighter particles are
washed over a weir to waste.
    Both fixed media and moving bed filters
build up head  loss  over time.  Head  loss is a
measure of solids trapped in the filter. As the
filter  becomes filled  with trapped solids, the
efficiency of the filtration process falls off, and
the filter must  be backwashed.  Reversing the
flow will backwash filters so that the solids in the
media are  dislodged  and may exit the  filter.
Sometimes air is dispersed into the sand bed to
scour the media.
    Fixed  bed  filters may be automatically
backwashed  when the  differential  pressure
exceeds a preset limit or when a timer starts the
backwash cycle.  A supply of clean backwash
water is required. Backwash water and trapped
particles  are   commonly  discharged  to  an
equalization tank upstream  of the wastewater
treatment system's gravity separation system or
screen for removal.  Moving bed filters  are
continuously backwashed and  have a constant
rate of effluent flow.

            INDUSTRY PRACTICE
    Of the 65  CWT  facilities in EPA's WTI
Questionnaire   data   base   that   provided
information concerning  use of sand filtration,
eight operate sand filtration systems.

2.  MULTIMEDIA FILTRATION
           GENERAL DESCRIPTION
    CWT facilities may  use multimedia, or
granular bed, filtration to achieve supplemental
removal of residual suspended solids from the
effluent of chemical and  biological treatment
processes.   In granular bed  filtration, the
wastewater  stream is  sent through  a  bed
containing  two or more layers  of different
granular materials. The solids are retained in the
voids between  the  media particles while the
wastewater passes through the bed.  Typical
media used in granular  bed filters include
anthracite coal,  sand, and garnet.
    A multimedia filter  is designed so that the
finer, denser media is at the bottom and the
coarser, less dense media at the top. A common
arrangement is garnet  at the bottom of the bed,
sand in the middle, and anthracite coal at the top.
Some mixing  of these layers  occurs and  is
anticipated. During filtration, the removal of the
suspended solids is accomplished by a complex
process involving one or more mechanisms such
as   straining,   sedimentation,   interception,
impaction, and adsorption. The medium  size is
the  principal  characteristic  that  affects the
filtration operation.  If the medium is too small,
much of the driving  force will  be wasted  in
overcoming the frictional resistance of the filter
bed. If the medium is too large, small particles
will travel through the bed, preventing optimum-
filtration.
    By designing the filter bed so that pore size
decreases from the influent to the effluent  side of
the bed, different size particles are filtered out at
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Chanter 8 Wastewater Treatment Technoloaies  Development Document for the CWT Point Source Category
different depths (larger particles first) of the filter
bed. This helps prevent the build up of a single
layer of solids at the bed surface which can
quickly increase the pressure drop over the bed
resulting in shorter filter runs and more frequent
backwash  cycles.   Thus, the  advantage  of
multimedia filtration over sand filtration is longer
filter runs and less frequent backwash cycles.
    The  flow pattern of multimedia filters  is
usually top-to-bottom.  Upflow filters, horizontal
filters, and biflow filters are also used. Figure 8-
12  is a top-to-bottom multimedia filter.  The
classic multimedia filter operates by gravity.
However, pressure filters are occasionally used.
    The complete filtration process involves two
phases: filtration and backwashing. As the filter
becomes filled with trapped solids, the efficiency
of the filtration process falls off.  Head loss is a
measure of solids trapped in the filter.  As the
head loss across  the filter bed  increases to a
limiting value, the end of the filter run is reached
and the filter must be backwashed to remove the
suspended  solids   in   the   bed.    During
backwashing, the flow through the filter  is
reversed so that the solids trapped in the media
are dislodged and can exit the filter. The bed may
also be agitated with air to aid in solids removal.
Backwash  water and  trapped  particles  are
commonly discharged to an equalization tank
upstream of the wastewater treatment system's
gravity separation system or screen for removal.
     An  important feature in  filtration and
backwashing is the underdrain. The underdrain is
the support structure for the filtration bed. The
underdrain provides an area for the accumulation
of the filtered water without it being clogged from
the filtered solids or the media particles.  During
backwash, the underdrain provides  even flow
distribution over the bed.  This  is important
because the backwash flowrate is set so that the
filter bed expands  but the media is not carried out
with the backwashed solids.  The media with
different densities then settle  back down  in
somewhat  discrete layers  at  the  end of the
backwash step.

            INDUSTRY PRACTICE
    Of the 65 CWT facilities  in EPA's WTI
Questionnaire   data  base   that   provided
information  concerning  use   of  multimedia
filtration, four  operate multimedia filtration
systems.

3.  PLATE AND FRAME PRESSURE FILTRATION
           GENERAL DESCRIPTION
    Another filtration system for the removal of
solids  from waste streams is a plate and frame
pressure filtration systems.  Although plate and
frame filter presses are more commonly used for
dewatering sludges, they are also used to remove
solids  directly from wastewater streams.  The
liquid stream plate and frame pressure filtration
system is identical to the system used for the
sludge stream (section 8.4.1) with the exception
of a lower solids level in the influent stream. The
same equipment is used for both applications,
with the difference being the sizing of the sludge
and liquid units. See section 8.4.1 for a detailed
description of plate and frame pressure filtration.
No CWT facilities in EPA's database use plate
and frame filtration.
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Chapter 8 Waste-water Treatment Technologies  Development'Document for the C WTPoint Source Category
                               Wastewater Influent
         Coarse Media
          Finer Media
         Finest Media
             Support
     Underdrain Chamber
                                                            Backwash
Backwash
                                Treated Effluent
Figure 8-12.    Multi-Media Filtration System Diagram




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Chanter 8 Wastewater Treatment Technolosies  Development Document for the CWT Point Source Category
4.  MEMBRANE FILTRATION
           GENERAL DESCRIPTION
    Membrane filtration systems are processes
which employ semi-permeable membranes and a
pressure   differential  to  remove  solids  in
wastestreams.       Reverse   osmosis   and
ultrafiltration are two commonly-used membrane
filtration processes.

A.  ULTRAFILTRATION
           GENERAL DESCRIPTION
    CWT facilities commonly use ultrafiltration
(UF)  for  the  treatment  of metal-finishing
wastewater and  oily wastes.  It  can remove
substances with molecular weights greater than
500, including suspended solids, oil and grease,
large organic molecules, and complexed heavy
metals.    UF  can be  used when the solute
molecules are greater than ten times the size of
the solvent molecules, and are less than one-half
micron. In the CWT industry, UF is applied in
the treatment of oil/water emulsions.  Oil/water
emulsions contain both soluble and  insoluble oil.
Typically the insoluble oil is removed from the
emulsion  by  gravity  separation  assisted  by
emulsion  breaking.  The soluble oil is then
removed by UF. Oily wastewater containing 0.1
to 10 percent oil can be effectively treated by UF.
Figure 8-13 shows a UF system.
    In  UF,  a  semi-permeable  microporous
membrane performs the separation. Wastewater
is  sent  through membrane  modules  under
pressure.   Water and  low-molecular -weight
solutes (for example, salts and some surfactants)
pass through the membrane and are removed as
"permeate.  Emulsified oil and suspended solids
are rejected by the membrane and are removed as
concentrate.   The  concentrate is recirculated
through the membrane unit until the flow of
permeate drops.  The permeate may either be
discharged or passed along to another treatment
unit.  The concentrate is  contained and held for
 further treatment or disposal.   An  important
 advantage of UF over reverse osmosis is that the
 concentrate may be  treated  to remove  the
 concentrated solids and the separated water may
 then be retreated through the UF system.
     The primary design consideration in UF is
 the membrane selection. A membrane pore size
 is  chosen based on the size of the contaminant
 particles targeted for removal.   Other design
 parameters to be considered  are  the solids
 concentration, viscosity, and temperature of the
 feed  stream,   pressure differential,  and  the
 membrane permeability and thickness. The rate
 at which a membrane fouls is also an important
 design consideration.

             INDUSTRY PRACTICE
     Of the 116 CWT facilities in EPA's WTI
 Questionnaire and NOA comment data base that
 provided   information  concerning   use   of
 ultrafiltration,  six operate ultrafiltration systems.
 B.  REVERSE OSMOSIS
            GENERAL DESCRIPTION
     Reverse osmosis (RO)  is  a process for
 separating dissolved solids from water.  CWT
 facilities commonly use RO  in treating oily or
 metal-bearing  wastewater.   RO is  applicable
 when the solute molecules are approximately the
 same  size  as  the  solvent  molecules.   A
 semi-permeable,  microporous membrane  and
 pressure are used to perform the separation. RO
 systems are typically used as polishing processes,
 prior to final discharge of the treated wastewater.
 Reverse osmosis systems have been demonstrated
 to be effective in removing dissolved metals.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
                          Permeate (Treated Effluent)
   Wastewater
   Feed
Concentrate
                              Membrane Cross-section
Figure 8-13.   Ultrafiltration System Diagram
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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    Osmosis is the diffusion of a solvent (such as
water) across a semi-permeable membrane from
a  less  concentrated  solution into  a  more
concentrated  solution.  In the reverse osmosis
process, pressure greater than the normal osmotic
pressure is applied to the more  concentrated
solution (the waste stream being treated), forcing
the purified water through the membrane and into
the less concentrated stream which is called the
permeate. The low-molecular-weight solutes (for
example, salts and some surfactants) do not pass
through the membrane. They are referred to as
concentrate.   The concentrate  is recirculated
through the membrane unit until the flow of
permeate drops.  The  permeate can either be
discharged or passed along to another treatment
unit.  The concentrate is contained and held for
further treatment or disposal. Figure 8-14 shows
an RO system.
    The  performance  of an  RO  system  is
dependent    upon   the   dissolved   solids
concentration and temperature of the feed stream,
the applied pressure, and the type of membrane
selected. The key RO membrane properties to be
considered are: selectivity for water over ions,
permeation rate, and durability. RO modules are
available in various  membrane configurations,
such as spiral-wound, tubular, hollow-fiber, and
plate and frame.  In addition to the membrane
modules, other capital  items needed for an RO
installation     include    pumps,     piping,
instrumentation, and storage tanks.  The major
operating  cost is  attributed  to  membrane
replacement   A  major consideration  for RO
systems is the disposal  of the concentrate due to
its elevated concentrations of salts, metals, and
other dissolved solids.

             INDUSTRY PRACTICE
    Of the 65 CWT facilities in EPA's WTI
Questionnaire  data  base   that   provided
information concerning use of reverse osmosis,
two operate reverse osmosis systems.

5.  LANCY FILTRATION
           GENERAL DESCRIPTION
    The  Lancy  Sorption  Filter System is  a
patented method for the continuous recovery of
heavy metals.  The Lancy sorption filtration
process  may reduce metels  not  removed  by
conventional waste treatment technologies to low
concentrations.
    In the first stage  of the Lancy filtration
process,  a soluble sulfide is  added  to the
wastewater in a reaction  tank, converting most of
the heavy metals  to sulfides.  From the sulfide
reaction tank, the solution is passed through the
sorption filter media. Precipitated metal sulfides
and other suspended solids are filtered out. Any
remaining soluble metals are absorbed by the
media. Excess soluble sulfides are also removed
from the  waste stream.
    The  Lancy  filtration  process  reportedly
reduces zinc, silver, copper, lead, and cadmium to
less than 0.05 mg/1 and mercury to less  than 2
yug/l.   In addition to the effective removal of
heavy metals, the system  has a  high  solids
filtration  capacity  and  a  fully  automatic,
continuous operation. The system continuously
recycles and reuses the same filter media thereby
saving on operating costs,.  The system may be
installed with a choice of media discharge - slurry
or solid cake. Figure 8-15 illustrates the Lancy
Sorption Filtration System..
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Chapter S Wastewater Treatment Technologies Development Document for the CWTPoint Source Category
                          Permeate (Treated Effluent)
    Waste water
    Feed
Concentrate
                              Membrane Cross-section
Figure 8-14.    Reverse Osmosis System Diagram

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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
                                                                    Treated,
     Wastewater
       Influent
                                                             Media Discharge
              Recycle
              Tank
 Figure 8-15.    Lancy Filtration System Diagram

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Chanter 8 Wastewater Treatment Technoloaies  Development Document for the CWTPoint Source Category
             INDUSTRY PRACTICE
    Of the  65 CWT facilities in EPA's WTI
Questionnaire   data  base   that  provided
information concerning use of filtration systems,
only one operates the Lancy Sorption Filtration
System. This unit is used for polishing effluent
from a treatment sequence including chemical
precipitation,  clarification, and sand filtration.
EPA obtained performance data for this system
during a sampling episode at one of the metals
subcategory facilities.  The performance data
showed that some metals were reduced to the
target levels while the concentration of some
pollutants increased.  This may not represent
optimal performance of the system, however,
because the facility reported that they were
experiencing operational problems throughout the
sampling episode.
 Carbon Adsorption
8.2.2.10
           GENERAL DESCRIPTION
    Activated   carbon   adsorption   is   a
demonstrated wastewater treatment technology
that uses activated carbon to remove dissolved
organic  pollutants  from  wastewater.   The
activated  carbon  is  made   from   many
carbonaceous sources including coal, coke, peat,
wood, and cpconut shells.  The carbon source
material is "activated" by treating it  with  an
oxidizing gas to form a highly porous structure
with a large internal surface area.  CWT facilities
generally use granular forms of activated carbon
(GAC) in fixed bed columns to treat wastewater.
However, some use powdered activated carbon
(PAC)  alone or in conjunction with biological
treatment.  Figure 8-16 presents a diagram of a
fixed-bed GAC collumn.
    In a fixed bed system, the wastewater enters
the top of  the unit and is  allowed  to flow
downward through a bed of granular activated
carbon. As  the wastewater comes  into contact
with the activated carbon, the dissolved organic
compounds  adsorb  onto  the surface of  the
activated carbon. In the upper area of the bed, the
pollutants are  rapidly  adsorbed.    As  more
wastewater passes through the bed,  this  rapid
adsorption zone moves downward until it reaches
the bottom of the bed. At this point, all of the
available adsorption sites  are filled and  the
carbon is said to be exhausted. This condition
can be detected by an increase in the effluent
pollutant   concentration,   and   is   called
breakthrough.
    GAC systems  are  usually comprised  of
several beds  operated in series.   This design
allows the first bed to go to exhaustion, while the
other beds still have the capacity to treat to an
acceptable effluent quality.  The carbon in the
first bed is replaced, and the  second bed then
becomes the lead bed. The GAC system piping
is designed to allow switching of bed order.
    After the carbon is exhausted,  it can  be
removed and regenerated. Usually heat or steam
is used to reverse the adsorption process.  The
light organic compounds are volatilized and the
heavy organic compounds are pyrolyzed. Spent
carbon may also be regenerated by contacting it
with  a solvent which dissolves the  adsorbed
pollutants.    Depending  on  system  size and
economics, some facilities may choose to dispose
of the spent carbon instead of regenerating it.  For
very large applications, an  on-site  regeneration
facility is  more economical.     For smaller
applications, such as in the CWT industry, it is
generally cost-effective to use a vendor service to
deliver regenerated carbon and remove the spent
carbon. These vendors transport the  spent carbon
to their centralized facilities for regeneration.
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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
     Fresh
     Carbon
     Fill
       Collector/
       Distributor
           Spent
           Carbon
           Discharge
                                      Wastewater
                                      Influent
Backwash
                                                        Backwash
                                                           Treated
                                                           Effluent
Figure 8-16.    Carbon Adsorption System Diagram

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Ctvaoter 8 Waste-water Treatment Technologies  Development Document for the CWT Point Source Category
    The   carbon  adsorption  mechanism  is
complicated  and,  although  the  attraction  is
primarily physical, is a combination of physical,
chemical,  and electrostatic interactions between
the activated carbon and the organic compound.
The key design parameter for activated carbon is
the adsorption capacity of the carbon.   The
adsorption capacity is a measure of the mass of
contaminant adsorbed per unit mass of activated
carbon and is a function of the compound being
adsorbed, the  type  of carbon used, and the
process design and  operating conditions. In
general, the  adsorption  capacity  is inversely
proportional   to  the  adsorbate   solubility.
Nonpolar, high molecular weight organics with
low solubility are  readily adsorbed. Polar, low
molecular weight organics with high solubilities
are more poorly adsorbed.
    Competitive adsorption between compounds
has an effect on adsorption.   The carbon may
preferentially adsorb one compound over another.
This  competition  could result in  an adsorbed
compound being desorbed from the carbon. This
is most pronounced when carbon adsorption is
used  to treat wastewater  with highly variable
pollutant character and concentration.

             INDUSTRY PRACTICE
    Of the 116 CWT facilities in EPA's WTI
Questionnaire and NOA comment data base that
provided  information concerning use of carbon
adsorption,   17  operate  carbon  adsorption
systems.
Ion Exchange
8.2.2.11
            GENERAL DESCRIPTION
    A common process employed to remove
 heavy metals from relatively low-concentration
 waste streams, such as electroplating wastewater,
 is ion exchange.  A key advantage of the ion
 exchange process is that the metal contaminants
can be recovered and reused. Another advantage
is that ion exchange may be designed to remove
certain metals only, providing effective removal
of  these  metals  from   highly-contaminated
wastewater. A disadvantage is that the resins
may be fouled by some organic substances.
    In an  ion exchange system, the wastewater
stream is  passed through a bed of resin.  The
resin contains bound groups of ionic charge on its
surface, which are exchanged for ions of the same
charge in the wastewater. Resins are classified by
type, either cationic or anionic. The selection is
dependent upon the wastewater contaminant to be
removed. A commonly-used resin is polystyrene
copolymerized with divinylbenzene.
    The  ion exchange process  involves  four
steps:  treatment, backwash,  regeneration, and
rinse.  During the treatment step, wastewater is
passed  through the resin bed and ions  are
exchanged until pollutant breakthrough occurs.
The resin is then backwashed to reclassify the bed
and to remove suspended  solids.  During the
regeneration step,  the resin is contacted  with
either an acidic or alkaline solution containing
high concentrations of the ion originally present
in the resin. This "reverses" the ion exchange
process and removes the metal ions from the
resin. The bed is then rinsed to remove residual
regenerating  solution.       The   resulting
contaminated regenerating solution must be
further  processed  for  reuse  or  disposal.
Depending  upon system size and economics,
some facilities choose to remove the spent resin
and replace it  with resin  regenerated off-site
instead of regenerating the resin in-place.
    Ion exchange equipment ranges from simple,
inexpensive systems  such as domestic  water
softeners,   to  large,   continuous  industrial
applications. The  most commonly-encountered
industrial setup is a fixed-bed resin in a vertical
column, where the resin is regenerated in-place.
Figure 8-17 is a diagram of this type of system.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category
These systems may  be designed so that the
regenerant flow is concurrent or countercurrent to
the treatment flow.   A countercurrent design,
although more complex to operate, provides a
higher treatment efficiency.   The beds may
contain a  single type  of resin for  selective
treatment, or the beds may be mixed to provide
for more complete deionization of the  waste
stream.   Often, individual beds containing
different resins are arranged in series,  which
makes regeneration easier than in the mixed bed
system.

             INDUSTRY PRACTICE
    EPA is aware of only one CWT facility using
ion exchange.
Electrolytic Recovery
8.2.2.12
           GENERAL DESCRIPTION
    Another process for reclaiming metals from
wastewater  is  electrolytic recovery.   It is  a
common technology in the electroplating, mining,
and  electronic industries.  It is used for the
recovery of copper, zinc, silver, cadmium, gold,
and  other heavy metals.   Nickel is  poorly
recovered due to its low standard potential.
    The electrolytic recovery process uses an
oxidation and reduction reaction.   Conductive
electrodes (anodes and cathodes) are immersed in
the metal-bearing wastewater, with an electric
potential applied to them. At the cathode, a metal
ion is reduced  to its elemental form (electron-
consuming reaction).  At  the same time, gases
such as oxygen, hydrogen, or nitrogen form at the
anode (electron-producing reaction).  After the
metal coating on the cathode reaches a desired
thickness, it may be removed and recovered.  The
metal-stripped  cathode can then be used as the
anode.
    The equipment consists of an electrochemical
reactor  with electrodes, a gas-venting system,
recirculation pumps, and a power supply.  Figure
8-18 ia a diagram of an electrolytic recovery
system.  Electrochemical reactors are typically
designed to produce high flow rates to increase
the process efficiency.
    A conventional electrolytic recovery system
is  effective for the  recovery of metals from
relatively high-concentration wastewater.   A
specialized adaptation of electrolytic recovery,
called  extended surface  electrolysis,  or ESE,
operates effectively at lower concentration levels.
The ESE system uses a spiral cell containing a
flow-through cathode which has a very open
structure and therefore a lower resistance to fluid
flow.   This also  provides a larger electrode
surface.  ESE  systems are often used for the
recovery of copper,  lead, mercury,  silver, and
gold.

            INDUSTRY PRACTICE
    Of the  65  CWT facilities in EPA's WTI
Questionnaire   data  base   that    provided
information  concerning   use of  electrolytic
recovery,  three operate  electrolytic  recovery
systems.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    Wastewater
    Influent
         Used
         Regenerant
  Regenerant
  Solution
                                                       Distributor
                                                        Support
Treated
Effluent
Figure 8-17.    Ion Exchange System Diagram
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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
                                                                     0 +  1/20
     Deposited
       Metal
                            Porous Insulating Separator
Figure 8-18.    Electrolytic Recovery System Diagram

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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
Stripping
8.2.2.13
    Stripping is a method for removing dissolved
volatile organic compounds  from wastewater.
The removal is accomplished by passing air or
steam through the agitated waste stream.  The
primary  difference between  air stripping and
steam stripping is that steam stripping is operated
at higher temperatures and the resultant off-gas
stream is usually condensed and recovered or
incinerated.   The off-gas from  air  stripping
contains non-condenseable air which must  be
either passed through an adsorption unit  or
incinerated in order to prevent transfer of the
volatile pollutants to the environment. EPA is
not aware of any applications of steam stripping
technologies in the CWT industry.

1.  AIR STRIPPING
           GENERAL DESCRIPTION
            r
    Air  stripping  is  effective  in  removing
dissolved  volatile  organic  compounds from
wastewater.  The removal is accomplished  by
passing high volumes of air through the agitated
wastewater stream.   The process results in a
contaminated off-gas stream which, depending
upon air emissions standards, usually requires air
pollution control equipment.     Stripping  can
be performed in tanks or in spray  or  packed
towers. Treatment in packed towers is the most
efficient  application.   The  packing typically
consists of plastic rings or saddles.  The two
types of towers that are commonly used, cross-
flow and countercurrent,  differ in design only in
the location of the air inlets. In the cross-flow
tower, the air is drawn through the sides for the
total height of the packing.  The countercurrent
tower draws the entire air flow from the bottom.
Cross-flow towers have  been found to be more
susceptible to scaling problems  and are less
efficient than countercurrent towers. Figure 8-19
is a countercurrent air stripper.
    The driving force of the air stripping mass-
transfer   operation  is  the   difference   in
concentrations between the air and water streams.
Pollutants  are  transferred from  the  more
concentrated  wastewater stream  to the  less
concentrated  air  stream until  equilibrium  is
reached. This equilibrium relationship is known
as Henry's Law. The strippability of a pollutant
is expressed as its Henry's Law Constant, which
is a function  of both its  volatility or vapor
pressure and solubility.
    Air strippers are designed  according to the
strippability of the pollutants to be removed. For
evaluation purposes, organic pollutants can be
divided into three general  strippability ranges
(low, medium, and high)  according to their
Henry's Law Constants.  The low strippability
group  (Henry's Law Constants of 10"4 [mg/m3
air]/[mg/m3 water] and lower) are not effectively
removed. Pollutants in the medium (10"1 to 10"4)
and high(10'1 and greater) groups are effectively
stripped.  Pollutants with  lower Henry's law
constants  require greater column height, more
trays or packing material, greater temperature,
and more frequent cleaning than pollutants with
a higher strippability.
    The  air  stripping  process is  adversely
affected by low  temperatures.  Air strippers
experience   lower  efficiencies   at    lower
temperatures, with  the possibility  of freezing
within the tower.  For this reason, depending on
the location of the tower, it may be necessary to
preheat the wastewater and the air feed streams.
The column and  packing materials must  be
cleaned regularly to ensure that low  effluent
levels are attained.   .
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
     Wastewater
     Influent
                                 Off-gas
             Blower
                                                   Distributor
                                                   Support
                                                            Treated
                                                            Effluent
Figure 8-19.   Air Stripping System Diagram
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    ter 8 Wastewater Treatment Technologies  DevelopmenUDocument for the CWTPoint Source Category
    Air stripping has proved to be an effective
process in the removal of volatile pollutants from
wastewater.  It is  generally limited to influent
concentrations of less than 100 mg/1 organics.
Well-designed and operated systems can achieve
over 99 percent removals.

            INDUSTRY PRACTICE
    Of the  65 CWT facilities  in EPA's WTI
Questionnaire   data   base  that  provided
information concerning use of air stripping, 11
operate air stripping systems.

Liquid Carbon Dioxide Extraction    8.2.2.14

            GENERAL DESCRIPTION
    Liquid carbon dioxide (CO2) extraction is a
process  used  to extract and  recover organic
contaminants from aqueous waste streams.  A
licensed,   commercial   application  of  this
technology is utilized in the CWT industry under
the name  "Clean Extraction System" (CES).
The process may be effective in the removal of
organic  substances   such  as  hydrocarbons,
aldehydes  and  ketones, nitriles,  halogenated
compounds, phenols, esters, and heterocyclics.  It
is  not  effective  in  the  removal of  some
compounds which are very water-soluble, such as
ethylene  glycol,  and  low  molecular weight
alcohols. It may  provide an alternative in the
treatment of waste streams which historically
have been incinerated.
    In liquid carbon dioxide extraction, the waste
stream  is  fed  into  the  top of a  pressurized
extraction  tower containing perforated plates,
where it is contacted with a countercurrent stream
of liquefied CO2.  The organic contaminants in
the waste stream are dissolved in the CO2; this
extract is then sent to a separator, where the CO2
is  redistilled.   The  distilled CO2  vapor  is
compressed and  reused.   The  concentrated
organics bottoms from the separator can then be
disposed or recovered.  The treated wastewater
stream which exits the extractor (raffinate) is
pressure-reduced and may be further treated for
residual organics removal if necessary to meet
discharge standards. Figure 8-20 is a diagram of
the CES is presented in.

             INDUSTRY PRACTICE
    EPA is aware of only one facility using this
technology in the  CWT industry. Pilot-scale
information submitted to EPA  by the CWT
facility showed effective removal for a variety of
organic  compounds.    EPA  sampled  this
commercial  CWT  CES   unit  during  this
rulemaking effort. Performance was not optimal,
however, as  the  facility reported operational
problems with the unit throughout the sampling
episode.
Biological Treatment
8.2.3
    A portion of the CWT industry accepts waste
receipts that contain organic pollutants, which are
often amenable to biological degradation.  This
subset of CWT facilities  is referred to as the
organics subcategory. In addition, a portion of
the facilities in the oils subcategory also use
biological treatment to treat wastewater separated
from oily wastes.
    Biological treatment systems use microbes
which consume, and thereby destroy, organic
compounds as a food source. The microbes use
the organic compounds as both  a source of
carbon  and as  a source  of energy.    These
microbes may also need supplemental nutrients
for growth, such as nitrogen and phosphorus, if
the waste stream is deficient in these nutrients.
Aerobic microbes require  oxygen to grow,
whereas anaerobic microbes will grow only in the
absence of oxygen. Facultative microbes are an
adaptive type of microbe that can grow with or
without oxygen.
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Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
          Extract
Vapor CO2
     Feed
                     Extractor
                        Liquid CO2
                                                  Separator
                      Makeup
                      CO,
                                                            I
                                                                 Compressor
             Water
 Organics
Figure 8-20.    Liquid CO2 Extraction System Diagram

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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    The success  of biological  treatment is
dependent on many factors, such as the pH and
temperature of the wastewater, the nature of the
pollutants,  the  nutrient  requirements  of the
microbes, the presence of inhibiting pollutants,
and variations in the feed stream loading. Certain
compounds, such as heavy metals, may be toxic
to the microorganisms and must be removed from
the waste stream prior to biological treatment.
Load variations are a major concern, especially in
the CWT industry, where waste receipts vary over
time in both concentration and volume.
    There are several adaptations of biological
treatment These adaptations differ in three basic
ways. First, a system may be aerobic, anaerobic,
or facultative. Second, the microorganisms may
either be attached to a surface (as in a trickling
filter), or be unattached in a liquid suspension (as
in an activated  sludge  system).    Third, the
operation may be either batch or continuous.
    Of  the  116  facilities  in   the   WTI
Questionnaire and NOA comment data base that
responded to EPA's inquiry concerning the use of
biological  treatment,  17 operate  biological
treatment systems.  There were no anaerobic
systems reported.   Theses  systems  include
sequencing  batch  reactors,  attached  growth
systems (biotowers and  trickling  filters)  and
activated sludge systems.  With the exception of
trickling  filters,  EPA  sampled  at least  one
application  of each of the following biological
treatment technologies during the development of
these effluent guidelines.
Sequencing Batch Reactors
8.2.3.1
            GENERAL DESCRIPTION
    A sequencing batch reactor (SBR) is a
suspended growth system in which wastewater is
mixed with existing biological floe in an aeration
basin. SBRs are unique in that a single tank acts
as an equalization tank, an aeration tank, and a
           clarifier.  An SBR is operated on a batch basis
           where the wastewater is mixed and aerated with
           the biological floe for a specific period of time.
           The contents of the basin are allowed to settle and
           the supernatant is decanted. The batch operation
           of an SBR makes it a useful biological treatment
           option for  the  CWT  industry,  where  the
           wastewater volumes and characteristics are often
           highly variable.  Each batch can  be treated
           differently depending on waste  characteristics.
           Figure 8-21 shows an SBR.
              The SBR has a four cycle process:  fill, react,
           settle, and decant.  The fill cycle has two phases.
           The first  phase, called static fill, introduces the
           wastewater to the system under static conditions.
           This  is an  anaerobic period and may enhance
           biological phosphorus uptake.  During the second
           phase of the fill cycle wastewater is mechanically
           mixed to eliminate the scum layer and prepare the
           microorganisms to receive oxygen. In the second
           cycle, me  react cycle, aeration is performed.  The
           react cycle is a time-dependent process where
           wastewater is continually mixed and aerated,
           allowing  the biological degradation process to
           occur.  The third cycle, called the settling cycle,
           provides quiescent conditions throughout the tank
           and  may accommodate low  settling rates by
           increasing the settling time.  During the last or
           decant cycle, the treated wastewater is decanted
           by subsurface withdrawal from below the scum
           layer. This treated, clarified effluent may then be
           further treated or discharged.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
        Process
         Cycle

Fill
                                                             React
                                                             Settle
                                                             Decant
Figure 8-21.    Sequencing Batch Reactor System Diagram

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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    When the quantity of biomass in the SBR
exceeds that needed for operation, the excess
biomass is removed. The sludge that is removed
from the  SBR may be reduced in volume by
thickening and dewatering using any of the sludge
treatment processes discussed in section 8.2.4.
The dewatered sludge may be disposed in a
landfill or used as an agricultural fertilizer.
    An SBR carries out all of the functions of a
conventional continuous flow activated sludge
process,   such   as   equalization,  biological
treatment, and sedimentation, in a time sequence
rather than a space sequence.  Detention times
and loadings vary with each batch and are highly
dependent  on the  specific  raw  wastewater
loadings.  Typically,  an SBR operates with a
hydraulic detention time of 1 to 10 days and a
sludge retention time of 10 to 30  days.   The
mixed  liquor   suspended   solids  (MLSS)
concentration is maintained at 3,500 to 10,000
mg/1.  The overall control of the system may be
accomplished automatically  by   using  level
sensors or timing devices. By using a single tank
to perform all of the required functions associated
with biological treatment, an SBR reduces land
requirements.  It  also  provides  for  greater
operation flexibility for treating wastes with
viable characteristics by allowing the capability
to vary detention time and mode of aeration in
each stage.  SBRs also may be  used to achieve
complete     nitrification/denitrification    and
phosphorus removal.
             INDUSTRY PRACTICE
    EPA is aware of only one CWT facility that
uses  an SBR.  This facility is  in the organics
subcategory, and its SBR unit was sampled
during the  development  of  these effluent
guidelines.

Attached Growth Biological
Treatment Systems                   8.2.3.2
    Another system  used to  biodegrade  the
organic components  of a wastewater is  the
attached growth biological treatment system. In
these systems, the  biomass  adheres  to the
surfaces  of  rigid  supporting  media.   As
wastewater contacts the supporting medium, a
thin-film biological slime develops and coats the
surfaces. As this film (consisting primarily of
bacteria, protozoa, and fungi) grows, the slime
periodically  breaks  off the  medium  and  is
replaced by new growth. This phenomenon of
losing the slime layer is called sloughing and is
primarily a function of organic  and  hydraulic
loadings on the system.  The effluent from the
system is usually discharged to a clarifier to settle
and remove the agglomerated solids.
    Attached   growth  biological  systems are
appropriate for treating industrial wastewaters
amenable to aerobic biological treatment. When
used in conjunction with suitable pre- and post-
treatment processes, attached growth biological
systems  remove  suspended  and  colloidal
materials effectively.  The two major types of
attached growth systems used at CWT facilities
are trickling filters and biotowers.  The following
section describes these processes.

l.  TRICKLING FILTERS
           GENERAL DESCRIPTION
    Trickling filtration is an aerobic fixed-film
biological treatment  process that consists  of a
structure, packed with inert medium such as rock,
wood, or plastic. The wastewater is distributed
over the upper surface of the medium by either a
fixed  spray   nozzle  system or a  rotating
distribution system. The inert medium develops
a biological slime that absorbs and biodegrades
organic pollutants.  Air flows through the  filter by
convection, thereby providing the oxygen needed
to maintain aerobic conditions. Figure 8-22 is a
flow diagram of a trickling filter.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
Figure 8-22.    Trickling Filter System Diagram



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Chanter 8 Wastewater Treatment Technologies   Development Document for the CWT Point Source Category
    Trickling filters are classified as low-rate or
high-rate, depending  on the organic loading.
Typical design organic loading values range from
5 to 25 pounds and 25 to 45 pounds BOD5 per
1,000 cubic feet per day for low-rate and high-
rate, respectively. A low-rate filter generally has
a media bed depth of 1.5 to 3 meters and does not
use recirculation. A high-rate filter may have a
bed depth from 1 to 9 meters and recirculates a
portion of the effluent for further treatment.

            INDUSTRY PRACTICE
    EPA is aware of only one CWT facility that
uses a trickling filter.  This facility is in the oils
subcategory.

2.  BlOTOWERS
            GENERAL DESCRIPTION
    A variation of a trickling filtration process is
the aerobic biotower. Biotowers may be operated
in a continuous or semi-continuous manner and
may be operated  in  an upflow or downflow
manner.  In the downflow mode, influent is
pumped to the top of a tower, where it flows by
gravity through the tower. The tower is packed
with plastic or redwood media containing the
attached  microbial   growth.     Biological
degradation occurs as the wastewater passes over
the media.  Treated wastewater collects in the
bottom of the tower. If needed, additional oxygen
is provided via air blowers countercurrent to the
wastewater  flow.   In  the  upflow mode, the
wastewater  stream is fed into the bottom of the
biotower and is passed up through the packing
along with diffused air supplied by air blowers.
The treated effluent exits from the top of the
biotower.
    Variations of this treatment process involve
the inoculation of the raw influent with bacteria
and the  addition of nutrients.   Wastewater
collected in the biotowers is delivered to a
clarifierto separate the biological solids from the
treated effluent.  A diagram of a biotower is
presented in Figure 8-23.

            INDUSTRY PRACTICE
    EPA is aware of two biotowers in operation
in the CWT Industry. One system treats a waste
stream which is primarily composed of leachate
from an  on-site landfill operation.  The  other
system treats  high-TOC  wastewater from a
metals recovery  operation.   EPA conducted
sampling at this facility during the development
of these effluent guidelines.
Activated Sludge
8.2.3.3
           GENERAL DESCRIPTION
    The   activated  sludge   process  is   a
continuous-flow,  aerobic biological  treatment
process that employs suspended-growth aerobic
microorganisms    to   biodegrade    organic
contaminants. In this process, a suspension of
aerobic  microorganisms  is  maintained  by
mechanical mixing or turbulence  induced  by
diffused  aerators in an aeration basin.  This
suspension of microorganisms is called the mixed
liquor.    Figure  8-24 is a diagram  of a
conventional activated sludge system.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    Inoculum
     Nutrient
     Solution
    Wastewater
    Influent
                                                         Treated
                                                         Effluent
                                                          Blower
Figure 8-23.   Biotower System Diagram
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Chanter S "Wastewater Treatment Technoloaies  Development Document for the CWTPoint Source Category
    Wastewater
    Influent
           T
                            Aeration
                              Basin
                         Recycled Sludge
                                                      Secondary
                                                     Clarification
                                                                 Waste
                                                                 Excess
                                                                 Sludge
 Figure 8-24.    Activated Sludge System Diagram

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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
    Influent is introduced into the aeration basin
and is allowed to mix with the contents. A series
of biochemical reactions is  performed in the
aeration basin, degrading organics and generating
new biomass.    Microorganisms  oxidize the
soluble and suspended  organic pollutants to
carbon dioxide and water using the  available
supplied  oxygen.    These  organisms  also
agglomerate colloidal and particulate  solids.
After a specific contact period in the aeration
basin, the mixture is passed to a settling tank, or
clarifier, where the microorganisms are separated
from the treated water. A major portion of the
settled solids in the clarifier is recycled back to
the aeration system  to  maintain the desired
concentration of microorganisms in the reactor. 
The remainder of the settled solids is wasted and
sent to sludge handling facilities.
    To ensure biological stabilization of organic
compounds in activated sludge systems, adequate
nutrient levels must be available to the biomass.
The   primary  nutrients   are   nitrogen   and
phosphorus. Lack of these nutrients can impair
biological activity and result in reduced removal
efficiencies.   Certain wastes may have   low
concentrations  of  nitrogen  and  phosphorus
relative to the oxygen demand.  As a result,
nutrient  supplements  (e.g.,  phosphoric  acid
addition for additional phosphorus) have  been
used  in activated sludge  systems at CWT
facilities.
    The effectiveness of the  activated  sludge
process is  governed by several  design   and
operation  variables.  The  key variables are
organic loading, sludge retention time, hydraulic
or  aeration  detention   time,  and   oxygen
requirements. The organic loading is described
as the food-to-microorganism  (F/M)  ratio, or
kilograms of BOD5 applied daily to the system
per kilogram of mixed liquor suspended solids
(MLSS).   The MLSS in the aeration tank is
determined  by the rate  and concentration of
activated sludge returned to the tank. The organic
loading (F/M ratio) affects the BOD5 removal,
oxygen requirements, biomass production, and
the settleability  of the biomass.  The  sludge
retention time (SRT) or sludge age is a measure
of the average retention time of solids in the
activated sludge system.  The SRT affects the
degree  of treatment and  production  of waste
sludge.  A high SRT results in a high quantity of
solids in the system and therefore a higher degree
of treatment while also resulting in the production
of less waste sludge.  The hydraulic  detention
time determines the size of the aeration tank and
is calculated using the F/M ratio,  SRT, and
MLSS. Oxygen requirements are based on the
amount required for biodegradation of organic
matter and the amount required for endogenous
respiration of the microorganisms. The design
parameters will vary with the type of wastewater
to be treated and are usually determined  in a
treatability study.
    Modifications of the activated sludge process
are common, as the process is extremely versatile
and  can be adapted  for  a wide  variety  of
organically  contaminated wastewaters.   The
typical modification may include a variation of
one  or more  of the  key design parameters,
including the F/M loading, aeration location and
type,  sludge  return,  and   contact  basin
configuration. The modifications in practice have
been identified by the major characteristics that
distinguish the particular configuration.  The
characteristic types and modifications are briefly
described as follows:

   Conventional. The aeration tanks are  long
    and narrow,  with plug flow  (i.e.,  little
    forward or backwards mixing).

   Complete Mix.    The aeration  tanks  are
    shorter and wider, and the aerators, diffusers,
    and entry points of the  influent and return
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Chapter 8 Wastewater Treatment Technologies  . Development.Document for the C WT Point Source Category
    sludge are arranged so that the wastewater
    mixes completely.

    Tapered ^Aeration.  A modification of the
    conventional process in which the diffusers
    are arranged  to  supply more air to the
    influent end of the tank, where the oxygen
    demand is highest.

    Step  Aeration.   A  modification  of the
    conventional process in which the wastewater
    is introduced to the aeration tank at several
    points, lowering the peak oxygen demand.

    High Rate Activated Sludge. A modification
    of conventional or tapered aeration in which
    the aeration times are shorter, the pollutants
    loadings  are  higher  per unit mass  of
    microorganisms in the tank.  The rate of
    BOD5 removal for this process is higher than
    that   of  conventional  activated  sludge
    processes, but the total removals are lower.

    Pure Oxygen.  An activated sludge variation
    in which pure oxygen instead of air is added
    to the aeration tanks, the tanks are covered,
    and   the   oxygen-containing  off-gas  is
    recycled.  Compared to normal air aeration,
    pure oxygen  aeration requires a smaller
    aeration tank volume and treats high-strength
    wastewaters and widely fluctuating organic
    loadings more efficiently.

    Extended Aeration.  A variation of complete
    mix in which low organic loadings and long
    aeration   times  permit  more complete
    wastewater degradation and partial aerobic
    digestion of the microorganisms.

    Contact Stabilization.  An activated sludge
    modification using two aeration stages. In
    the first, wastewater is aerated with the return
    sludge in the contact tank for 30  to  90
    minutes, allowing finely suspended colloidal
    and  dissolved  organics  to  absorb to the
    activated sludge. The solids are settled out in
    a clarifier and  then aerated  in the sludge
    aeration (stabilization) tank for 3 to 6 hours
    before flowing into the first aeration tank.

   Oxidation  Ditch Activated  Sludge.   An
    extended aeration process in which aeration
    and  mixing are provided by brush  rotors
    placed across  a  race-track-shaped  basin.
    Waste enters the ditch at one end, is aerated
    by the rotors, and circulates,

             INDUSTRY PRACTICE
    Because activated  sludge  systems  are
sensitive  to  the  loading  and flow variations
typically found at CWT facilities, equalization is
often required prior to activated sludge treatment.
Of the  65  CWT  facilities  in  EPA's  WTI
Questionnaire   data  base   that   provided
information concerning use of activated sludge,
four operate activated sludge systems.
Sludge Treatment and Disposal
8.2.4
    Several of the waste treatment processes used
in the CWT industry generate a sludge.  These
processes  include  chemical  precipitation  of
metals,  clarification, filtration, and biological
treatment. Some oily waste treatment processes,
such as dissolved air flotation and centrifugation,
also produce sludges.  These sludges typically
contain between one and five percent solids.
They require dewatering to concentrate them and
prepare them for transport and/or disposal.
    Sludges  are  dewatered  using  pressure,
gravity, vacuum, or centrifugal force.  There are
several   widely-used,   commercially-available
methods for sludge dewatering. Plate and frame
pressure filtration, belt pressure filtration, and
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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
vacuum filtration are the primary methods used
for sludge dewatering at CWT facilities. A plate
and frame filter press can produce the driest filter
cake of these three systems, followed by the belt
press, and lastly, the vacuum filter. Each of these
sludge dewatering methods are discussed below.
    In some instances, depending upon the nature
of the sludge and the dewatering process used, the
sludge may first be stabilized, conditioned, and/or
thickened prior to dewatering.  Certain sludges
require stabilization (via chemical addition or
biological  digestion)  because  they  have  an
objectionable odor or are a health threat. Sludges
produced by the CWT industry usually do not fall
into this category.  Sludge conditioning is used to
improve dewaterability; it can be accomplished
via the addition of heat or chemicals.  Sludge
thickening, or concentration, reduces the volume
of sludge to be dewatered and is accomplished by
gravity settling, flotation, or centrifugation.

Plate and Frame Pressure Filtration   8.2.4.1

            GENERAL DESCRIPTION
    Plate and frame pressure filtration systems is
a widely used method for the removal of solids
from waste streams.  In the CWT industry, plate
and frame pressure filtration system are used for
filtering solids out of treated wastewater streams
and  sludges.  The same equipment is used for
both applications, with the difference being the
solids level in the influent stream and the sizing
of the sludge and liquid units.  Figure 8-25 is a
plate and frame filter press.
    A plate and frame filter press consists of a
number of recessed  filter  plates  or  trays
connected to a  frame  and  pressed together
between a fixed end and a moving end.  Each
plate is constructed with a drainage surface on the
depressed portion of  the face.  Filter cloth is
mounted on the face of each plate and then the
plates  are  pressed  together.   The  sludge is
pumped  under  pressure  into the  chambers
between the plates of the assembly while water
passes through the media and drains to the filtrate
outlets. The solids are retained in the cavities of
the filter press between the cloth surfaces and
form a cake that ultimately fills the chamber. At
the end of the cycle when the filtrate flow stops,
the pressure  is released and the plates are
separated.  The filter cake drops into a hopper
below the press.  The  filter cake may then be
disposed in a landfill. The filter cloth is washed
before the next cycle begins.
    The  key  advantage  of plate  and  frame
pressure filtration is that it can produce a drier
filter cake than is possible with the other methods
of sludge dewatering.  In a typical plate and frame
pressure filtration unit, the filter cake may exhibit
a dry solids content between 30 and 50 percent.
It is well-suited for use in the CWT industry as it
is a batch process.  However, its batch operation
results in greater operating labor requirements.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWI'Point Source Catesorv
                          T
 Figure 8-25: Plate and Frame Filter Press System Diagram




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Chanter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
         '   INDUSTRY PRACTICE
    Of the 65 CWT facilities in  EPA's WTI
Questionnaire   data  base  that   provided
information  concerning  the  use  of pressure
filtration, 34 operate pressure filtration systems.
Of these34 facilities, 25 operate plate and frame
pressure filtration systems, three  operate belt
pressure filtration  systems,  and  six did not
specify the type of presure  filtration systems
utilized.
Belt Pressure Filtration
8.2.4.2
           GENERAL DESCRIPTION
    A belt pressure filtration system uses gravity
followed by mechanical compression and shear'
force to produce a sludge filter cake. Belt filter
presses  are  continuous  systems  which  are
commonly used to dewater biological treatment
sludge. Most belt filter installations are preceded
by a flocculation step, where polymer is added to
create a sludge  which has the  strength to
withstand being compressed between the belts
without being squeezed out. Figure 8-26 shows
a typical belt filter press.
    During the press operation, the sludge stream
is fed onto the first of two moving cloth filter
belts.  The sludge is gravity-thickened as the
water drains through the belt. As the belt holding
the sludge advances,  it approaches  a  second
moving belt.  As the first and second belts move
closer together, the sludge is compressed between
them.  The pressure is increased as the two belts
travel together over and under a series of rollers.
The turning of the belts around the rollers shear
the cake which furthers the dewatering process.
At the end of the roller pass, the belts move apart
and the cake drops off.  The feed belt is  washed
before the sludge feed point  The dropped filter
cake may then be disposed.
    The advantages of a belt filtration system are
its lower labor requirements and lower power
consumption. The disadvantages are that the belt
filter presses produce a poorer quality filtrate, and
require a relatively large volume of belt wash
water.
    Typical  belt  filtration applications  may
dewater an undigested activated sludge to a cake
containing 15 to 25 perceni: solids. Heat-treated,
digested sludges may be reduced to a cake of up
to 50 percent solids.

             INDUSTRY PRACTICE
    Of the  65 CWT facilities in EPA's  WTI
Questionnaire  data   base   that   provided
information  concerning  the  use  of pressure
filtration, 36 operate pressure filtration systems.
Of these 34 facilities, 25 operate plate and frame
pressure filtration systems, three operate belt
pressure filtration systems, and six did not
specify the  type  of presure filtration systems
utilized.
                   Vacuum Filtration
                                     8.2.4.3
                              GENERAL DESCRIPTION
                       A commonly-used process for dewatering
                   sludge is rotary vacuum filtration.  These filters
                   come in drum, coil, and belt configurations. The
                   filter medium may be made of cloth, coil springs,
                   or wire-mesh fabric. A typical application is a
                   rotary vacuum belt filter;   a diagram  of this
                   equipment is shown in Figure 8-27.
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Chapter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
   Sludge
   Influent
                    Drainage    Compression
                      Zone           Zone
                                                  Wash Water
Shear
Zone
                                                                       Filter
                                                                       Cake
Figure 8-26.   Belt Pressure Filtration System Diagram

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                   Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category
                                                                                      Filter Cake
                                                                                      Discharge
                                                                                    Filter Media

                                                                                Spray Wash
                  Figure 8-27.    Vacuum Filtration System Diagram

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       & Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category
    In a rotary vacuum belt filter, a continuous
belt of filter fabric is wound around a horizontal
rotating drum and rollers. The drum is perforated
and is connected to a vacuum.  The drum is
partially immersed in a shallow tank containing
the sludge.  As the drum  rotates, the vacuum
which is applied to the inside of the drum draws
the sludge onto the filter fabric. The water from
the sludge passes through the filter and into the
drum, where it exits via a discharge port. As the
fabric leaves the drum and passes over the roller,
the vacuum is released. The filter cake drops off
of the belt as it turns around the roller.  The filter
cake may then be disposed.
    Vacuum  filtration may  reduce  activated
sludge to a cake containing 12 to 20 percent
solids. Lime sludge may be reduced to a cake of
25 to 40 percent solids.
    Because  vacuum  filtration systems are
relatively expensive to operate, they are usually
preceded by a thickening step which reduces the
volume of sludge to be dewatered. An advantage
of  vacuum filtration is that it is a continuous
process  and  therefore requires less  operator
attention.

            1 INDUSTRY PRACTICE
    Of the 65 CWT  facilities in EPA's WTI
Questionnaire   data   base   that    provided
information  concerning the  use  of vacuum
filtration, eight operate vacuum filtration systems.

Filter Cake Disposal                  8.2.4.4
    After a sludge is dewatered, the resultant
filter cake must be disposed. The most common
method of filter cake management used in the
CWT industry is transport  to an off-site landfill
for disposal.    Other  disposal  options are
incineration or land application. Land application
is  usually  restricted  to  biological treatment
residuals.
Zero or Alternate Discharge
Treatment Options
8.2.5
    This  section   discusses  zero  discharge
wastewater treatment and disposal methods. In
this  context,  zero  discharge  refers  to  any
wastewater disposal method other than indirect
discharge to a POTW or direct discharge to a
surface water. A common zero discharge method
employed by CWT facilities that generate small
volumes of wastewater is transportation of the
wastewater to an off-site disposal facility such as
another CWT facility. Other methods discussed
below include deep well disposal, evaporation,
and solidification.
    Deep well disposal consists of pumping the
wastewater into a disposal well, that discharges
the liquid into a deep aquifer. . Normally, these
aquifers are thoroughly characterized to insure
that they are not hydrogeologically-connected to
a drinking water supply.  The characterization
requires the confirmation  of the existence of
impervious layers  of rock above and below the
aquifer. Pretreatment of the wastewater using
filtration is often  practiced to  prevent the
plugging of the face of the receiving aquifer.
    Traditionally used as a method of sludge
dewatering, evaporation (or solar evaporation)
also  can involve the discharge and ultimate
storage of wastewater into  a shallow, lined, on-
site basin or ditch. Because the system is open to
the atmosphere, the  degree of evaporation  is
greatly dependent upon climatic conditions. This
option  is generally available  only to those
facilities located in arid regions.
    Solidification is a process in which materials,
such as fly ash, cement, and lime, are added to the
waste to produce a solid. Depending on both the
contaminant and binding material, the solidified
waste  may be  disposed  of in a  landfill  or
incinerated.
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWTPoint Source Category

            INDUSTRY PRACTICE
    EPA has information for 24 CWT facilities
not discharging directly to surface waters or
POTWs that employ zero and alternate discharge
methods.  Of those 24 facilities, seven dispose of
wastewater by deep well injection, 13 transport
wastewater to an off-site commercial or intra-
company  wastewater  treatment  facility,  two
dispose  of wastewater  by  evaporation,  one
solidifies wastewater and landfills it on-site, and
one discharges wastewater to a privately-owned
treatment works.
REFERENCES
8.3
Standard Methods for Examination of Water and Wastewater. 15th Edition, Washington DC.

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

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

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

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

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

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

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

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

Effluent Guidelines Division, Development Document  For Effluent Limitations Guidelines  and
Standards for the Organic Chemicals. Plastics and Synthetic Fibers TOCPSFX Volume II, Point Source
Category, EPA 440/1-87/009, Washington, DC, October 1987.
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Chaoter 8 Wastewater Treatment Technologies Development Document for the CWT Point Source Category
Engineering News Record (ENRX McGraw-Hill Co., New York, NY, March 30, 1992.

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

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

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

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

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

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

Corbitt, Robert, Standard Handbook of Environmental Engineering. McGraw-Hill Publishing Co., New
York, NY, 1990.

Perry, H., Chemical Engineers Handbook. 5th Edition. McGraw-Hill, New York, NY, 1973.

Development Document for BAT. Pretreatment Technology and New Source Performance Technology
for the Pesticide Chemical Industry. USEPA, April  1992.

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

Brown and Root, Inc., "Determination of Best Practicable Control Technology Currently Available to
Remove Oil and Gas," prepared for Sheen Technical Subcommittee, Offshore Operators Committee,
New Orleans, (March 1974).

Churchill, R.L., "A  Critical Analysis of Flotation Performance," American Institute  of Chemical
Engineers, 290-299, (1978).

Leech, C.A., "Oil Flotation Processes for Cleaning Oil Field Produced Water," Shell Offshore, Inc.,
Bakersfield, CA, (1987).

Luthy, R.C., "Removal of Emulsified Oil with Organic Coagulants and Dissolved Air Flotation," Journal
Water Pollution Control Federation.  (1978), 331-346.

Lysyj, I., et al., "Effectiveness of Offshore Produced Water Treatment," API et al., Oil Spill prevention,
Behavior Control and Clean-up Conference (Atlanta, GA) Proceedings, (March 1981).

Pearson, S.C., "Factors Influencing Oil Removal Efficiency in Dissolved Air Flotation Units," 4th
Annual Industrial Pollution Conference, Houston, TX, (1976).
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Chapter 8 Wastewater Treatment Technologies  Development Document for the CWT Point Source Category


Viessman, W., And Hammer, M.J., Water Supply and Pollution Control. Harper Collins Publishers, New
York, NY, 1993.

Wyer, R.H., et al.,  "Evaluation of Wastewater Treatment Technology for Offshore Oil Production
Facilities," Offshore Technology Conference, Dallas, TX, (1975).

Eckenfelder, Welsey, Industrial Pollution Control. New York: McGraw-Hill, 1989.

Joint Task Force, Design of Municipal Wastewater Treatment Plants. MOP 8,  Alexandria: Water
Environment Federation, 1991.

Tchobanoglous, George, Wastewater Engineering. 2nd Ed., New York: McGraw-Hill, 1979.

Development  Document for the Proposed Effluent Limitations Guidelines  and Standards for the
Landfills Point Source Category. USEPA, January, 1998.

Development Document for the Proposed Effluent Limitations Guidelines and Standards for Industrial
Waste Combustors. USEPA, December 1997.
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                                                                           Chapter
                                                                                  9
          REGULATORY OPTIONS CONSIDERED AND
                SELECTED FOR BASIS OF REGULATION
    This section presents the technology options
    considered by EPA  as the basis for the
proposed effluent limitations  guidelines  and
standards for the CWT industry. It also describes
the methodology for EPA's selection of the
proposed technology options.   The limitations
and standards discussed in this section are Best
Practicable   Control   Technology   Currently
Available (BPT), Best Conventional Pollutant
Control Technology  (BCT),   Best  Available
Technology Economically Achievable (BAT),
New Source Performance Standards (NSPS),
Pretreatment Standards for Existing Sources
(PSES), and Pretreatment Standards for New
Sources (PSNS).
ESTABLISHMENT OF BPT
9.1
    Section  304(b)(l)(A)  requires  EPA  to
identify effluent reductions attainable through the
application  of  "best  practicable   control
technology currently available for classes and
categories of point sources."  EPA determines
BPT effluent levels based upon the average of the
best existing performance by facilities of various
sizes, ages, and unit processes within  each
industrial category or subcategory. However, in
industrial categories where present practices are
uniformly inadequate, EPA may determine that
BPT requires higher levels of control than any
currently in place if the technology to  achieve
those levels can be practicably applied.
    In  addition,  CWA Section  304(b)(l)(B)
requires a cost reasonableness assessment  for
BPT limitations. In determining the BPT limits,
EPA must consider the total  cost of treatment
 technologies in relation to the effluent reduction
 benefits achieved.
     In  balancing costs against the benefits of
 effluent reduction, EPA considers the volume and
 nature of expected discharges after application of
 BPT,  the  general  environmental  effects  of
 pollutants, and the cost and economic impacts of
 the required level of pollution control.
     In  assessing BPT for this industry,  EPA
 considered  age,  size, unit processes,  other
' engineering  factors,  and   non-water  quality
 impacts pertinent to the facilities treating waste in
 each subcategory. For all subcategories, no basis
 could be found for identifying different BPT
 limitations based on age, size, process, or other
 engineering .factors for the  reasons previously
 discussed. For a service industry whose service
 is wastewater treatment, the pertinent factors for
 establishing the limitations are cost of treatment,
 the level  of effluent reductions obtainable, and
 .non-water quality effects.
     EPA determined  that,  while some CWT
 facilities are providing adequate treatment of all
 wastestreatns, wastewater treatment  at some
 CWT facilities is poor. EPA has determined that
 facilities  which mix different types of highly
 concentrated  CWT  wastes  with  non-CWT
 wastestreams or with  storm water are not
 providing BPT  treatment.   In addition, while
 some  CWT  facilities pretreat  subcategory
 wastestreams for optimal removal  prior to
 commingling, some facilities mix wastes from
 different  subcategories without pretreatment.
 This practice essentially dilutes the waste rather
 than treats the  waste. As such, the mass of
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CHAPTER 9 Reg. Options Considered and Selected     Development Document for the CWT Point Source Category
pollutants  being  discharged  at some  CWT
facilities is  higher  than that which can  be
achieved,  given  the  demonstrated  removal
capacity of treatment systems that the Agency
reviewed.  Many CWT facilities recognize that
commingling often leads only to dilution and have
encouraged their customers to segregate wastes as
much  as  possible.     Waste  minimization
techniques  at most manufacturing facilities have
also led to increased waste stream segregation.
    Comparison of EPA sampling data and CWT
industry-supplied   monitoring   information
establishes that,  in the case of metal-bearing
wastestreams,  virtually  all the facilities are
discharging large amounts of heavy metals. As
measured by total suspended solids (TSS) levels
following  treatment,  TSS concentrations are
substantially  higher than  levels observed at
facilities in other industry categories  employing
the very same treatment technology.
    In the case of oil discharges, many facilities
are achieving low removal of oil  and grease
relative to  the performance required for  other
point source  categories.  Many collect samples
infrequently  to analyze for metal and organic
constituents  in  their discharge  since   these
parameters are not included in their discharge
permits.    Further, facilities  treating organic
wastes,  while  successfully removing organic
pollutants through biological treatment, fail to
remove metals associated with these organic
wastes.
    The  poor  pollutant  removal performance
observed for some direct discharging  CWT
facilities is not unexpected.   As pointed out
previously, some of these facilities are treating
highly concentrated wastes that, in many cases,
are process residuals  and sludges  from  other
point source categories. EPA's review of permit
limitations for the direct dischargers show that, in
most cases, the dischargers are subject to "best
professional judgment" limitations which were
based  primarily on  guidelines for facilities
treating  and  discharging  much  more  dilute
wastestreams. EPA has concluded that treatment
performance in the industry is often inadequate
and that the mass of pollutfants being discharged
is  high,   given the  demonstrated removal
capability of treatment option that the Agency has
reviewed.
    EPA's options to  evaluate treatment systems
in place  at  direct  discharging  CWTs were
extremely limited since most of the facilities in
this industry are indirect dischargers.  This is
particularly true of the melals and oils facilities.
Many indirect discharging CWTs are not required
to control discharges of conventional pollutants
because the receiving POTWs  are designed to
achieve removal of conventional pollutants and
therefore,  generally do nol:  monitor or optimize
the performance of their treatment systems for
control of conventional pollutants. Because BPT
applies to  direct dischargers, the data used to
establish limitations  and standards are normally
collected from such facilities.  For this rule, EPA
relied  on  information and data from  widely
available treatment technologies in use at CWT
facilities discharging indirectly    so  called
"technology transfer."   EPA  concluded that
certain technologies  in  place  at  indirect
discharging CWT facilities are appropriate for
use  as the  basis   for  regulation  of  direct
dischargers.
Rationale for Metals Subcategory
BPT Limitations
9.1.1
    In developing BPT limitations for the metals
subcategory, EPA considered three regulatory
options (two previously assessed for the 1995
proposal as well as one new treatment option).
All rely on chemical precipitation to reduce the
discharge  of pollutants  from CWT facilities.
The three currently available treatment systems
for which EPA assessed performance for the
metals subcategory BPT are discussed below.
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CHAPTER 9 Reg. Options Considered and Selected
Development Document for the CWT Point Source Category
METALS SUBCATEGORY OPTION 2' - SELECTIVE
METALS    PRECIPITATION.     LIQUID-SOLID
SEPARATION. SECONDARY PRECIPITATION. AND
LIQUID-SOLID SEPARATION
    The first treatment option (Option 2) that
EPA  evaluated is based on  "selective metals
precipitation." "Selective metals precipitation" is
a specialized metals removal technology that
tailors precipitation conditions to the metal to be
removed.   The extent to which a metal is
precipitated from a solution will vary with a
number of factors including pH, temperature, and
treatment   chemicals.      Selective  metals
precipitation adjusts these conditions sequentially
in order to provide maximum precipitation of
metals. Selective metals precipitation requires
segregation of incoming wastestreams and careful
characterization of the metals  content of the
waste  stream.    Next,  there  are  multiple
precipitations in batches at different pH levels in
order to achieve maximum removal of specific
metals. Selective metals precipitation results in
the formation of a metal-rich filter cake.  This
treatment  option requires numerous treatment
tanks  and  personnel  to  handle  incoming
wastestreams, greater  quantities of treatment
chemicals, and increased monitoring of the batch
treatment processes. One of the benefits of this
technology, however, is that it results in a metal-
rich filter  cake that facilities employing this
treatment  have the option of selling as  feed
material for metal reclamation. For metal streams
which contain concentrated cyanide complexes,
achievement of the BPT limitations under this
option  would require  alkaline chlorination at
specific operating  conditions prior to metals
    lrThe numbering of options reflects the numbering
for the 1995 proposal.  Options 2 and 3 were first
considered for that proposal.  Option 4 is a new
technology EPA evaluated for this proposal. EPA is
no longer evaluating Option 1 as the treatment basis
for the proposed limitations and standards.
    treatment.  These BPT cyanide limitations are
    discussed in greater detail below.

    METALS SUBCATEGORY OPTION 3' - SELECTIVE
    METALS    PRECIPITATION.     LIQUID-SOLID
    SEPARATION.   SECONDARY    PRECIPITATION,
    LIQUID-SOLID     SEPARATION.    TERTIARY
    PRECIPITATION. AND CLARIFICATION
        The second treatment option EPA evaluated
    (Option 3) is the  same as Option 2  with an
    additional  third  precipitation  step added for
    increased pollutant removals.  Again, for metals
    streams which  contain concentrated  cyanide
    complexes, like Option 2, BPT limitations for
    Option 3 are also based on alkaline chlorination
    at specific operating conditions prior to metals
    precipitation.

    METALS SUBCATEGORY OPTION  41 - BATCH
    PRECIPITATION.   LIQUID-SOLID  SEPARATION.
    SECONDARY   PRECIPITATION.   AND    SAND
    FILTRATION
        The new technology EPA evaluated as the
    basis of BPT for this regulation(Option 4) is a
    two stage precipitation process. The first stage of
    this technology  is  similar to  the  Option  1
    chemical  precipitation  technology considered
    (and rejected)  for the earlier proposal and is
    based on  chemical precipitation,  followed by
    some  form of solids  separation and sludge
    dewatering.  In Option 4, however, a second
    precipitation step is also performed followed by
    sand filtration.  Since most CWT metal facilities
    utilize single-stage chemical precipitation only,
    generally BPT limitations  based on Option 4
    would require facilities to use increased quantities
    of treatment  chemicals,  perform  additional
    monitoring of batch processes,  perform  an
    additional  precipitation step,  and add a sand
    filtration step.   Once again,  for metals  which
    contain concentrated cyanide  complexes, like
    Options 2 and 3, alkaline chlorination at specific
    operating conditions is also part of the Option 4
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CHAPTER 9 Reg. Options Considered and Selected    Development Document for the CWT Point Source Category
treatment process that forms the basis for BPT
limitations.

    The Agency is proposing to  adopt BPT
limitations based on Option 4 for the metals
subcategory.   EPA's decision to base BPT
limitations  on  Option  4  treatment reflects
primarily an evaluation of two factors: the degree
of effluent  reductions attainable through this
technology and the  total  cost of the proposed
treatment in relation to the effluent reductions
benefits (These are detailed in Chapter 11 and
12).  Option 4 technology is readily applicable to
all  facilities that are  treating metal-bearing
wastestreams.  It is currently used at 25 percent
of the facilities in this  subcategory. The adoption 
of this  level  of control would  represent a
significant reduction in pollutants discharged into
the environment by facilities in this subcategory.
Option 4 would remove approximately  13.8
million  pounds  annually  of  conventional
pollutants now discharged to the Nation's waters.
The Agency also assessed the total cost of water
pollution controls  likely  to be incurred  for
Option 4 in relation to the effluent reduction
benefits  and  determined  these  costs  were
economically reasonable,  less than $0.19 per
pound.
    The Agency has decided not to propose BPT
limitations based on Option 3, selective metals
precipitation, for a number of reasons.   First,
while  both Option  3 and Option  4 provide
significant pollutant removals, are economically
achievable, and expected to result in non-water
quality benefits through increased recycling of
metals, Option 3 is nearly four times as costly as
Option 4.  Furthermore, there is little, if any,
expected increase in total removals associated
with the Option 3 technology.  (Total removals
associated with Option 3 are virtually identical to
those achieved by Option 4 ~ less than  1.25
percent greater.) Second, EPA has some concern
about whether selective metals precipitation could
be  applied throughout the industry because
currently, only one  facility is employing this
technology.  Moreover, as noted above, the
effectiveness of selective: metals  precipitation
depends, in part, on the separation and holding of
wastestreams in numerous treatment tanks.  EPA
is aware that there may be physical constraints on
the ability  of certain facilities to  install the
additional, required treatment tanks.  These and
other factors support EPA's determination not to
propose  limitations  based  on  the  Option  3
technology.
    The  Agency used chemical  precipitation
treatment technology performance data from the
Metal Finishing regulation (40 CFR Part 433) to
establish direct discharge limitations for TSS
because the facility  from which the Option  4
limitations were derived is an indirect discharger
and the  treatment system is  not designed to
optimize removal of conventional parameters.
EPA has concluded that the transfer of this data
is  appropriate given the  absence of adequate
treatment technology for this pollutant at the only
otherwise  well-operated  BPT  CWT facility.
Given the treatment of similar wastes with similar
TSS concentrations at  both metal finishing and
centralized waste treatment facilities, use of the
data is warranted.  Moreover, EPA has every
reason to  believe that chemical  precipitation
treatment systems will perform similarly when
treating  TSS in waste in this  subcategory.
Because CWT is based on additional chemical
precipitation and solid-liquid  separation steps,
facilities should be able to meet the  transferred
limit.  Finally, since the metal finishing TSS
limitation was based on chemical precipitation
followed by clarification, EPA has costed all
direct  discharging  CWT   facilities  for  a
clarification unit prior to the sand filtration unit.
    EPA believes it is important to note that BPT
limitations established by Option 4 are based on
data  from a single,  well-operated system.  In
reviewing technologies ciorrently in  use in this
subcategory, however, EPA found that facilities
generally  utilize  a  single  stage  chemical
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CHAPTERS Res. Ontions Considered and Selected
Development Document for the CWTPoint Source Category
precipitation step  not a technology calculated
to achieve significant metals removals for the
wastestreams observed at these operations. EPA
did identify a handful of facilities which utilize
additional metals wastewater treatment, generally
secondary  chemical  precipitation.    Of these
facilities, EPA believes that only one accepts a
foil spectrum of waste, often with extremely high
metals concentrations and is, therefore, designed
and operated to achieve optimal performance for
a  wide  range  of raw  waste  concentrations.
Consequently, EPA is proposing to adopt BPT
limitations based on performance data from this
one, well-designed and operated facility.

              CYANIDE SUBSET
    As discussed above, the presence of high
cyanide concentrations detrimentally affects the
performance of metal precipitation processes due
to the formation  of metal-cyanide complexes.
Effective treatment of such  wastes typically
involves a cyanide destruction step prior to any
metal precipitation steps. Consequently, in the
case of metal streams which contain concentrated
cyanide complexes, EPA based BPT limitations
on an additional treatment step to destroy cyanide
prior to metals precipitation. EPA considered the
following  three  regulatory options  for  the
destruction of cyanide.

CYANIDE  SUBSET  OPTION  1  -  ALKALINE
CHLORINATION
    The   Option   1   technology,  alkaline
chlorination,  is  widely  used  for  cyanide
destruction in this industry as well as in others.
For this subset, it represents current performance.

CYANIDE  SUBSET   OPTION  2 -  ALKALINE
CHLORINATION   AT   SPECIFIC   OPERATING
CONDITIONS
     The technology basis for Option 2 BPT
limitations is also alkaline chlorination.  The
differences between the technology basis for
Option  1  and  Option  2 cyanide  destruction
     treatment are specific operating conditions which
     have been claimed confidential.
        The oxidation of cyanide waste by alkaline
     chlorination is a two step process.  In the first
     step, cyanide  is  oxidized  to  cyanate in the
     presence of hypochlorite, and sodium hydroxide
     is used to maintain a  specific pH range. The
     second step oxidizes cyanate to carbon dioxide
     and nitrogen at a controlled pH. The application
     of heat  can  facilitate  the   more  complete
     destruction of total cyanide.

     CYANIDE SUBSET OPTION  3  - CONFIDENTIAL
     CYANIDE DESTRUCTION
         EPA evaluated a third technology which is
     extremely   effective   in   reducing   cyanide.
     Application of this technology resulted in cyanide
     reductions of 99.8 percent for both amenable and
     total cyanide.  The Option 3 technology is also
     claimed confidential.

         For the 1995 proposal, the Agency proposed
     limitations based on Cyanide Option 2 for the
     cyanide  subset of the metals subcategory. For
     this proposal, this technology remains the basis
     for the BPT limitations for metals streams with
     concentrated   cyanide complexes.   Although
     Option 3 provides greater removals than Option
     2, the Agency has decided to reject Option 3 as a
     basis for BPT limitations because the technology
     is not publicly available. The cyanide destruction
     system used at the one facility employing Option
     3 is a proprietary  process that  does not employ
     off-the-shelf technology. There are, in addition,
     several  reasons supporting  the  selection  of
     limitations based on Option 2.  First, the facility
     achieving  Option  2 removals accepts  a full
     spectrum of cyanide waste.  Consequently, the
     treatment used by the Option 2 facility can be
     readily applied to all facilities in the subset of this
     subcategory.  Second, adoption of this level of
     control would represent a significant reduction in
     pollutants discharged into the environment  by
     facilities in this subset.   Finally, the Agency
                                             9-5

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CHAPTER 9 Reg. Options Considered and Selected    Development Document for the CWT Point Source Category
assessed the total cost for Option 2 in relation to
the effluent reduction benefits and determined
these  costs were  economically  reasonable.
Rationale for Oils Subcategory
BPT Limitations
9.1.2
    EPA  has  considered twelve technology
options in establishing BPT  effluent reduction
levels   for  the   oils   subcategory  during
development of this rule.  The first four options
were evaluated at the time of the 1995 proposal
(60 FR 5478); the other eight options following
the  1995  proposal.   The twelve technology
options considered are:

Option 1:   emulsion breaking/gravity
            separation
Option 2:   emulsion breaking/gravity
            separation and ultrafiltration
Option 3:   emulsion breaking/gravity
            separation, ultrafiltration, carbon
            adsorption, and reverse osmosis
Option 4:   emulsion breaking/gravity
            separation, ultrafiltration, carbon
            adsorption, reverse osmosis, and
            carbon adsorption
Option 5:   emulsion breaking/gravity
            separation, ultrafiltration, and
            chemical precipitation
Option 6:   emulsion breaking/gravity
            separation, dissolved air flotation,
            and gravity separation
Option 7:   emulsion breaking/gravity
            separation, secondary gravity
            separation, dissolved air flotation,
            and biological treatment
Option 8:   emulsion breaking/gravity
            separation and dissolved air
            flotation
Option 8v:  emulsion breaking/gravity
            separation, air stripping, and
            dissolved air flotation
Option 9:   emulsion breaking/gravity
            separation, secondary gravity
            separation, and dissolved air
            flotation
Option 9v:  emulsion breaking/gravity
            separation, air stripping, secondary
            gravity separation, and dissolved
            air flotation
Option 10:  emulsion breaking/gravity
            separation and secondary gravity
            separation

    As  detailed in the  1995 proposal, while
emulsion breaking/gravity separation (Option 1)
is widely used in this subcategory, EPA dropped
it from further  consideration at the time of the
original proposal since emulsion breaking/gravity
separation  did not  adequately  control  the
pollutants of concern and,  therefore,  did not
represent a BPT technology. The Agency  also
dropped  the Option  4  technology (emulsion
breaking/gravity   separation,   ultrafiltration,
carbon adsorption, reverse osmosis, and carbon
adsorption) from consideration at the time of the
original proposal because EPA's analysis showed
that some  pollutant  concentrations  actually
increased  following   the   additional   carbon
adsorption.
    At the time of the 1995 proposal, the Agency
co-proposed BPT limitations based on emulsion
breaking/gravity separation and ultrafiltration as
well as emulsion breaking/gravity separation and
ultrafiltration with added carbon adsorption and
reverse  osmosis to remove metal  compounds
found at significant levels in this subcategory.
Because  the costs associated  with the latter
option were four times higher than ultrafiltration
alone, EPA  was concerned about its impacts on
facilities in this subcategory.  After the  1995
proposal, EPA collected  additional  information
on facilities in the oils subcategory and  revisited
its conclusion about the size and nature of the oils
subcategory. EPA published a Notice of Data
Availability in   1996  describing the   new
                                             9-6

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CHAPTER 9 Res Ootions Considered and Selected
Development Document for the CWT Point Source Category
information and EPA's revised assessment of the
oils subcategory.  Based on analyses presented in
the 1996 Notice, EPA determined it should no
longer  consider  emulsion  breaking/gravity
separation  and  ultrafiltration  with  added
treatment steps (Option 3) as the basis for BPT
limitations because  the projected total costs
relative to effluent reductions  benefit were not
economically reasonable.
    Based on comments to the 1995 proposal and
the 1996 Notice of Data Availability, EPA was
strongly  encouraged   to   look   at  alternate
technology options to emulsion breaking/gravity
filtration  and ultrafiltration. This concern was
driven in large measure by the fact that many of
the facilities in the oils subcategory are classified
as "small businesses" and the  economic cost of
installing and operating ultrafiltration technology
was quite high.  Additionally, many commenters
stated that ultrafiltration  is   a  sophisticated
technology which would be difficult to  operate
and  maintain  with  the  majority of these
wastestreams.  Commenters also noted that the
Agency had failed to consider non-water quality
impacts   adequately      particularly  those
associated with the disposal of the concentrated
filtrate from these operations. As  a result, based
on comments to the original proposal, the 1996
Notice of Data  Availability, and  additional site
visits, EPA identified  several other treatment
options that were efficient, produced tighter oil
and grease limits, and were less expensive. As
such,  EPA is no longer  considering emulsion
breaking/gravity separation and ultrafiltration
(Option  2) as  an appropriate technology for
limitations for the oils subcategory.
    Following the 1995 proposal and the 1996
Notice of Data Availability, EPA preliminarily
considered Options 5  - 9v in  establishing BPT
effluent reduction levels for  this subcategory.
However, EPA dropped Options 5, 6, and 7 early
in the process.  EPA dropped Option 5 since it
relied on ultrafiltration  which,  as described
 previously,  the  Agency   determined   was
     inappropriate for this subcategory. The Agency
     dropped Option 6 since EPA is unaware of any
     CWT facilities that currently use the Option 6
     treatment   technologies   in  the   sequence
     considered.  Finally,  EPA dropped Option 7
     because EPA's  sampling data  showed little
     additional pollutant reduction associated with the
     addition of the biological treatment system.
         Following the SBREFA panel, at the request
     of panel members, EPA also examined another
     option, Option 10, which is based on emulsion
     breaking/gravity separation followed by a second
     gravity separation step.  The Agency has now
     concluded  that  it  should not  propose BPT
     limitations based on this technology.
         EPA recognizes  that a majority  of the
     industry  currently employs  primary emulsion
     breaking/gravity  separation  (typically  as  a
     pretreatment step prior to dissolved air flotation,
     biological treatment, or chemical precipitation).
     However, the data EPA has examined supports
     the Agency's concerns that the performance of
     emulsion breaking and/or gravity separation unit
     operations  are inadequate because they do not
     achieve acceptable pollutant removals.  For
     example,  one  of the  facilities in  the oils
     subcategory that EPA sampled discharged a
     biphasic sample  (oil and  water)  from  the
     emulsion breaking/gravity separation unit during
     an EPA sampling visit. When EPA analyzed the
     sample, the biphasic liquid stream had a relatively
     small organic phase percentage, yet contained
     extremely high overall concentrations of toxic
     pollutants,   especially priority,  semi-volatile
     organics   (such  as  polynuclear   aromatic
     hydrocarbons, phthalates, aromatic hydrocarbons,
     n-paraffins, and phenols).  Hence, the Agency
     believes that gravity separation systems without
     further treatment provide inadequate removals
     and, thus, do not represent BPT treatment for this
     subcategory.
         Therefore, the four new technology options
     considered  for  the oils  subcategory  BPT
     limitations are:
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CHAPTER 9 Reg. Options Considered and Selected    Development Document for theCWT Point Source Category
Option 82:   emulsion breaking/gravity
            separation and dissolved air
            flotation
Option Sv2: emulsion breaking/gravity
            separation, air stripping, and
            dissolved air flotation'
Option 92:   emulsion breaking/gravity
            separation, secondary gravity
            separation, and dissolved air
            flotation
Option 9v2: emulsion breaking/gravity
            separation, air stripping, secondary
            gravity separation, and dissolved
            air flotation

Each of these are discussed below.

OILS SUBCATEGORY OPTION 82 - DISSOLVED AlR
FLOTATION
    The  technology  basis  for Option  8  is
dissolved air flotation (DAF).  DAF separates
solid or liquid particles from a liquid phase by
introducing air bubbles into the liquid phase. The
bubbles attach to the particles and rise to the top
of the mixture.  Often chemicals are added  to
increase  the removal of metal constituents.
Generally,  BPT limitations based on Option 8
would require facilities with currently installed
DAF systems to perform better monitoring and.
operation of their system or to install and operate
a DAF system. For oils streams with significant
concentrations of metals, Option 8  would also
require   increased   quantities   of  treatment
chemicals to enhance metals removals.
     As noted above, EPA is no longer considering
Oils Options 1- 4 proposed in 1995.   During
development  of today's  proposal,  EPA  also
preliminarily  considered  seven  other   options
numbered 5 - 9v.  EPA has chosen to focus  its
attention on Options 8 through 9v.
OILS SUBCATEGORY OPTION 8 V2 -AlR STRIPPING
WITH EMISSIONS CONTROL AND DISSOLVED AIR
FLOTATION
    The technology basis for Option 8v is the
same as Option  8 except air  stripping with
emissions control is added to control the release
of volatile pollutants into the air. The wastewater
effluent limitations and standards are the same
for Options 8 and 8v.

OILS SUBCATEGORY OPTION 92 - SECONDARY
GRAVITY SEPARATION  AND DISSOLVED  AIR
FLOTATION
    The technology basis for limitations based on
Option 9 is secondary gravity  separation and
DAF.  Secondary gravity separation involves
using a series of tanks to separate the oil and
water and then skimming the oily component off.
The resulting water moves: to the next step. The
gravity separation steps ure then followed by
DAF. As mentioned previously, EPA believes all
oils  facilities currently utilize  some form of
gravity   separation,  although  most  perform
primary gravity separation only. Generally, BPT
limitations  based on  Option 9 would require
facilities to perform additional gravity separation
steps, perform better monitoring and operation of
their DAF system, or install and operate a DAF
system.  For oils streams with relatively high
concentrations of metals, Option 9 would also
require the  use   of  increased  quantities  of
treatment chemicals to enhance the removal of
metals.

OILS SUBCATEGORY OPTION 9 v2 - AIR STRIPPING
WITH  EMISSIONS   CONTROL.   SECONDARY
GRAVITY SEPARATION. AND DISSOLVED  AIR
FLOTATION.
    The technology basis for Option 9v is the
same as for Option 9 with the addition of air
stripping with emissions control to control the
release of volatile pollutants into the air.  The
wastewater effluent limitations and guidelines are
the same for Options 9 and 9v.
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CHAPTER 9 Ree. Options Considered and Selected
Development Document for the CWT Point Source Category
    The Agency is proposing BPT limitations for
the oils subcategory based on Option 9 (emulsion
breaking/gravity separation, secondary gravity
separation, and dissolved air flotation) for two
reasons.  First, the adoption of this level  of
control would represent a significant reduction in
pollutants discharged into  the environment by
facilities in this subcategory.  Second, the Agency
assessed  the  total  costs  of water  pollution
controls likely to be incurred for this option in
relation to the effluent reduction benefits and
determined  these  costs   were  economically
reasonable.
    EPA proposes to reject emulsion breaking/
gravity separation and DAF alone as the basis for
BPT limitations because the estimated costs of
complying with both options are equivalent and
the estimated removals associated with the added
gravity separation step are greater. Additionally,
BPT pollutant removals based on Option 8, for a
number  of parameters (particularly  oil and
grease), are much less stringent than current BPT
effluent limitations guidelines promulgated for
other industries.  EPA believes that the vast
majority  of  DAF  systems  in use  in this
subcategory are not performing optimally.  As
mentioned earlier, all of the DAF systems studied
by EPA were used at facilities that discharge to
POTWs. As such,  optimal control  of oil and
grease is not required. Many do not even monitor
the oil and grease levels in  the material entering
and, in some cases, leaving the DAF.
    EPA has  studied the performance of DAF
systems in other largely  indirect discharging
industries and has found the  same lack of optimal
performance.   EPA believes that all facilities,
including indirect dischargers, should monitor the
levels of oil and grease entering and leaving the
DAF system.  Even though oil and grease levels
are not of great concern for indirect dischargers,
removal of many organic compounds is directly
related to removal of oil and grease. As such, the
overall efficacy of the DAF system in removing
the vast majority of specific toxic parameters can
    be improved by improving removals of oil and
    grease.
         The facilities that were sampled were not
    required to optimize their oil and grease removals
    because they discharge to POTWs that treat these
    pollutants.     Current  POTW/local  permit
    limitations for oil and grease in this subcategory
    range from 100 mg/L to 2,000 mg/L.  Many have
    no oil and grease limits at all. One of the systems
    sampled was designed to remove oil and grease to
    concentrations below 100 ug/L.  Consequently,
    EPA based the proposed oil and grease limitation
    on data from this single facility.
         EPA has  also  reviewed data  from the
    Industrial Laundries and the TECI rulemaking for
    dissolved  air flotation systems.  For  similar
    influent oil  and grease  concentrations, these
    systems removed oil and grease to levels well
    below  those achieved at  the  DAF systems
    sampled  for development  of this  regulation.
    Table 9-1 shows average influent and effluent
    concentrations of oil  and grease and TPH at
    sampled   industrial  laundry  facilities  with
    chemical emulsion breaking  or dissolved  air
    flotation.  Given the similarities in  the treated
    waste, EPA  is considering whether  use of this
    data  is  appropriate  in  determining  CWT
    limitations.
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CHAPTER 9 Reg. Options Considered and Selected     Development Document for the CWTPoint Source Category


Table 9-1.   Average  Influent and Effluent Oil and Grease and  Total Petroleum  Hydrocarbon (TPH)
            Concentrations at Sampled Industrial Laundry Facilities
Episode
Number
Treatment
Technology
5-Day Average Influent and Effluent
Concentrations When Sampled (mg/L)

Oil and
(measured
Influent
A
B
C
D
Dissolved Air Flotation
Dissolved Air Flotation
Chemical Emulsion
Breaking
Dissolved Air Flotation
777.2
1
1
1,
,530
,030
110*
Grease
as HEM)
Effluent
23.8
50.7
952
216*
(measured
Influent
308.6
681
159
245*
TPH
as SGT-HEM)
Effluent
10.4
15.7
164
41.4*
    The pollutant loadings presented for this facility are based on 4-day average concentrations because a process
    upset made the data for one day unusable
    EPA projects additional pollutant removals
associated with the technology that is the basis
for the proposed limitations, has costed facilities
for the additional technology (a series of gravity
separation steps) associated with this option, and
has determined that it is economically achievable.
However, EPA believes that many CWT facilities
may be able to achieve these limitations using
emulsion breaking/gravity separation and DAF
only.  As  described above, EPA believes  that
many  DAF systems  in this  industry are  not
performing optimally. Careful observations of
the influent and effluent of these systems would
allow facilities to better understand and control
the resulting effluent.
      The Agency  is  not  proposing BPT
limitations based on air stripping with overhead
recovery or destruction. While limitations based
on air  stripping with  overhead  recovery or
destruction would  seem  to  provide  some
additional  protection from volatile  and  semi-
volatile pollutants to all environmental media, no
substantial additional removal of volatile  and
semi-volatile parameters from the water would be
achieved through these options. While gravity
separation systems and dissolved air flotation
systems are often effective in removing volatile
and semi-volatile pollutants from water, a large
portion of these volatile and semi-volatile organic
pollutants are emitted into the surrounding air.
Thus, while  removing the pollutants  from the
wastewater, these systems do not remove these
pollutants  from  the  environment, but rather
transfer  a large  portion  of them to another
environmental medium.  The use of air stripping
coupled  with emissions  capture  reduces  or
eliminates the air emissions that otherwise would
occur by the air stripping of the volatile organic
pollutants in gravity separation and dissolved air
flotation systems. However, compliance with any
proposed limitation would not require installation
of such equipment.
    EPA   highly  recommends   that  plants
incorporate air stripping with overhead recovery
or destruction into their wastewater treatment
systems  for  more  complete environmental
protection. EPA also notes that CWT facilities
determined to be major sources of hazardous air
pollutants are currently  subject to maximum
achievable control  technology  (MACT)  as
promulgated  for  off-site  waste and  recovery
operations  on July  1,  1996 (61  FR 34140).
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CHAPTER 9 Reg. Options Considered and Selected
     Development Document for the CWT Point Source Category
Rationale for Organics Subcategory
BPT Limitations
9.1.3
    In  developing BPT  limitations for  the
organics subcategory, EPA re-examined  the
treatment options  considered  for  the  1995
proposal as well as assessed two new treatment
options. As a result of this re-examination, EPA
is no longer considering as a basis for BPT
limitations the two options considered earlier (60
FR 5479).  The first treatment  system EPA
examined as a basis for BPT limitations included
the following treatment steps:  equalization, two
air strippers in series equipped with a carbon
adsbrption  unit  for  control of air emissions,
biological treatment in the form of a sequential
batch reactor, and, finally, a multimedia filtration
unit. The second option was the same as the first,
but included a final carbon adsorption step.
    For  the  previous proposal,  the Agency
selected BPT limitations  based  on the first
treatment system, even though, theoretically, the
second system under consideration should have
provided greater removal of pollutants.  EPA
selected the first system as the technology basis
since  EPA's  sampling  data showed  that,
following the carbon adsorption treatment step,
specific pollutants of concern actually increased.
Therefore, for today's proposal, EPA is no longer
considering the second system which includes the
final carbon adsorption unit as the basis for BPT
limitations.  Additionally, EPA has concluded
that it should no longer consider the first system
(equalization, i air stripping, biological treatment,
and multimedia filtration) as the basis for BPT
limitations.   The multimedia filtration step is
primarily included in the treatment train to protect
the carbon adsorption unit installed downstream
from high TSS levels.  Since EPA rejected the
option which includes the carbon adsorption unit,
EPA similarly rejects the option which includes
the multimedia filtration step.
    The two  technology options considered for
the organics subcategory BPT are:
Option 3:  equalization,   air-stripping  with
           emissions  control,  and biological
           treatment; and
Option 4:  equalization     and    biological
           treatment

Each of these are discussed below.

ORGANICS    SUBCATEGORY   OPTION   3    -
EQUALIZATION. AIR STRIPPING WITH EMISSIONS
CONTROL. AND BIOLOGICAL TREATMENT
    Option 3  BPT effluent limitations are based
on the following treatment system: equalization,
two air-strippers in series equipped with a carbon
adsorption unit for control of air emissions, and
biological treatment in the form of a sequential
batch reactor (which is  operated on a  batch
basis).
    Waste  treatment facilities  often  need  to
equalize wastes by holding wastestreams in a
tank for a certain period of time prior to treatment
in order to obtain a stable waste stream which is
easier to treat. CWT facilities frequently use
holding tanks to consolidate small waste volumes
and  to  minimize the variability of incoming
wastes prior to certain treatment operations. The
receiving or initial treatment tanks of a facility
often serve as equalization tanks.
    Air  stripping  is  effective  in  removing
dissolved volatile  organic compounds  from
wastewater.  The removal  is accomplished  by
passing high volumes of air  through the agitated
wastewater stream.  The process results in a
contaminated off-gas stream which, depending
upon air emissions standards, usually requires  air
pollution control equipment.
    A sequencing  batch reactor (SBR) is  a
suspended growth system in  which wastewater is
mixed with existing biological floe in an aeration
basin. SBRs are unique in that a single tank acts
as an equalization tank, an  aeration tank, and a
clarifier. An SBR is operated on a batch basis
where the wastewater is mixed and aerated with
the biological floe for a specific period of time.
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CHAPTER 9 Ree. Options Considered and Selected     Development Document for the CWT Point Source Category
The contents of the basin are allowed to settle and
the supernatant is decanted. The batch operation
of an SBR makes it a useful biological treatment
option  for the  CWT  industry,  where  the
wastewater volumes and characteristics are often
highly variable.   Each  batch  can be treated
differently depending'on waste characteristics.
    An SBR carries out all of the functions of a
conventional continuous flow activated sludge
process,   such   as   equalization,  biological
treatment, and sedimentation, in a time sequence
rather than a space sequence.  Detention times
and loadings vary with each batch and are highly
dependent on  the  specific raw  wastewater
loadings. By using a single tank to perform all of
the required functions associated with biological
treatment, an SBR reduces land requirements. It
also provides for greater operation flexibility for
treating wastes with variable characteristics by
allowing the capability to vary detention time and
mode of aeration in each stage.  SBRs  also may
be  used   to  achieve complete  nitrification/
denitrification and phosphorus removal.

ORGANICS   SUBCATEGORY   OPTION   4   -
EQUALIZATION AND BIOLOGICAL TREATMENT
    Option 4 BPT effluent limitations are based
on  the same  treatment system  as Option 3
without the use of air strippers.

    The  Agency is proposing to  adopt BPT
effluent limitations for the organics subcategory
based on the Option 4 technology. The Agency's
decision to select Option 4 is based primarily on
the pollutant reductions, the cost and impacts to
the industry,  and non-water quality  impacts.
Unlike the other BPT proposed limitations, the
adoption of limitations based on Option 4 would
not represent a significant reduction in pollutants
discharged into the environment by facilities in
this subcategory.  EPA believes that  all direct
discharging facilities in this subcategory currently
employ equalization and biological treatment
systems.   EPA has assumed that all facilities
 which currently utilize equalization and biological
 treatment will be able to meet the BPT limitations
 without additional capital  or operating costs.
 However,  many  of  these  facilities  are  not
 currently  required  to  monitor  for  organic
 parameters or are only required to monitor one or
 two times  a year.  The costs associated with
 complying   with  BPT  limitations   for  this
 subcategory are, therefore,  associated with
 additional monitoring only. The Agency believes
 the additional monitoring is warranted and will
 promote more effective treatment  at  these
 facilities.
     The Agency  proposes to reject Option 3.
 BPT effluent  limitations based on  Option 3
 treatment would be essentially the same as those
 established by Option 4.  The main difference
 between Options 4 and 3 is that Option 3, which
 includes air stripping with emissions  control,
 would be  effective in reducing the levels of
 volatile and semi-volatile organic pollutants in all
 environmental media-not just the water. While
 biological systems are often effective in removing
 volatile and semi-volatile pollutants from water,
 a large portion of these volatile and semi-volatile
 organic pollutants are  emitted by biological
 systems into the  surrounding air.  Thus, while
' removing them from the wastewater, the typical
 biological  system  does not  remove  these
 pollutants  from  the  environment  but rather
 transfers a large portion of them to another
 environmental medium.  The use of air stripping
 with emissions control reduces or eliminates the
 air emissions that otherwise would occur by the
 volatilization of the volatile organic pollutants in
 the biological system.
      While  EPA  is  concerned  about volatile
 pollutants,  particularly for this subcategory, it
 believes that the use of the CAA to address air
 emissions from CWT wastewater is preferable.
 EPA also notes that CWT facilities determined to
 be major sources  of hazardous air pollutants are
 subject  to . maximum  achievable  control
 technology (MACT) as promulgated for off-site
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CHAPTER. 9 Ree. Options Considered and Selected
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waste and recovery operations on July 1, 1996
(61 FR 34140) as 40 CFR Part 63.
    The  Agency used  biological  treatment
performance,data from the Thermosetting Resin
Subcategory of the OCPSF regulation to establish
direct discharge limitations for BOD5 and TSS,
because the  facility  from  which  Option 4
limitations were derived is an indirect discharger
and the treatment system is not  operated to
optimize  removal of  conventional  pollutants.
EPA has concluded that the transfer of these data
is appropriate given the absence  of adequate
treatment technology for these pollutants at the
only otherwise well-operated BPT CWT facility.
Given the treatment of similar wastes at  both
OCPSF and CWT facilities,  use of the data is
warranted. Moreover,  EPA has every reason to
believe that the same  treatment systems will
perform similarly when treating the wastes in this
subcategory.
    Once again, the selected BPT option is based
on the performance  of a single facility. Many
facilities that are treating wastes  that will be
subject to  the  organics subcategory  effluent
limitations also operate other industrial processes
that generate much larger amounts of wastewater
than  the quantity of off-site-generated organic
waste receipts.   The  off-site-generated CWT
organic waste receipts are directly mixed with the
wastewater from the other industrial processes for
treatment.  Therefore, identifying facilities to
sample for limitations development was difficult
because the waste receipts and treatment unit
effectiveness could not  be properly characterized
for off-site-generated  waste.   The treatment
system on which Option 4 is based was one of the
few facilities identified which treated  organic
waste receipts  separately from other on-site
industrial wastewater.
     BEST CONVENTIONAL
     TECHNOLOGY (BCT)
9.2
        EPA is proposing BCT equal to BPT for the
     conventional pollutants regulated under BPT for
     all subcategories  of the CWT  industry.   In
     deciding whether to propose BCT limits, EPA
     considered whether there are technologies that
     achieve   greater  removals  of  conventional
     pollutants than proposed for BPT, and whether
     those technologies are cost-reasonable under the
     standards established by the C WA. This is called
     the "BCT Cost Test." For all three subcategories,
     EPA identified no technologies that can achieve
     greater removals of conventional pollutants than
     those that are the basis for BPT that are also cost-
     reasonable   under  the   BCT   Cost   Test.
     Accordingly, EPA is proposing  BCT effluent
     limitations equal to the proposed BPT effluent
     limitations guidelines and standards.

     BEST AVAILABLE TECHNOLOGY (BAT)     9.3

        EPA is proposing BAT effluent limitations
     for all subcategories of the CWT industry based
     on the same technologies selected as the basis for
     BPT  for each subcategory.  Therefore, the
     proposed BAT limitations are the same as the
     proposed BPT limitations.  The proposed BAT
     effluent limitations would control identified toxic
     and non-conventional pollutants discharged from
     facilities. As described in the BPT discussion, in
     general, the adoption of this level of control
     would represent  a  significant  reduction in
     pollutants discharged  into the environment by
     facilities in this subcategory. Additionally, EPA
     has evaluated the economic impacts associated
     with adoption of these limitations and found them
     to be economically achievable.
         With the exception of the metals subcategory,
     EPA  has not  identified  any more stringent
     treatment technology option different from those
     evaluated for  BPT that might represent best
     available technology economically achievable for
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CHAPTER 9 Ree. Options Considered and Selected
   Development Document for theCWT Point Source Category
this industry. For the metals subcategory, EPA
did consider as BAT technology two treatment
technologies that it had evaluated for the 1995
proposal, Options 2 and 3, based on the use of
selective metals precipitation. However, the costs
to the industry for  Option 2 and Option 3 are
more than four times greater than the cost of the
BPT option, Option 4, with no additional toxics
removal3. Given the comparable toxic removals,
EPA has concluded it should not adopt a more
costly option.
    For the oils and organics subcategories, EPA
has evaluated treatment technologies for BAT
limitations which theoretically should provide
greater removal of pollutants of concern.  For
example, EPA  identified  an add-on treatment
technology  to   technologies  'considered  for
BPT-carbon adsorption-that should have further
increased removals of pollutants  of concern.
However, EPA's data show increases rather than
decreases in concentrations of specific pollutants
of concern.  Consequently, EPA is not proposing
BAT limitations based on this technology.
NEW SOURCE PERFORMANCE
STANDARDS (NSPS)
9.4
    As previously noted, under Section 306 of
the Act, new industrial direct dischargers must
comply with standards which reflect the greatest
degree of effluent reduction achievable through
application of the best available demonstrated
control technologies.  Congress envisioned that
new treatment systems could meet tighter controls
than existing sources because of the opportunity
to incorporate the most efficient processes and
treatment systems into plant design. Therefore,
    EPA's data show that Option 4 would remove a
greater level of toxic pound-equivalents than Option 3.
Whether or not this is related to the small size of
EPA's sampling data set, EPA believes either option
would   achieve   comparable  pound-equivalent
removals.
Congress directed EPA to consider the best
demonstrated process changes, in-plant controls,
operating methods  and end-of-pipe treatment
technologies  that  reduce  pollution  to  the
maximum extent feasible.
    For the oils and the organics subcategories,
EPA is proposing NSPS that would control the
same  conventional toxic and non-conventional
pollutants proposed  for control  by the BPT
effluent limitations.  The  technologies used to
control pollutants at existing facilities are fully
applicable to new facilities.  Furthermore, EPA
has   not  identified  any   technologies   or
combinations   of   technologies   that   are
demonstrated for new sources that are different
from those used to establish BPT/BCT/BAT for
existing sources.  Therefore, EPA is establishing
NSPS oils and organic subcategories similar to
the oils and organics subcategories for existing
facilities and proposing NSPS limitations that are
identical to those proposed for BPT/BCT/BAT.
    For the metals subcategory, however, EPA is
proposing NSPS effluent limitations based on the
technology proposed in 1995: selective metals
precipitation, liquid-solid separation, secondary
precipitation, liquid-solid  separation, tertiary
precipitation, and clarification. This technology
provides the most stringent controls attainable
through the application of the  best available
control technology.
    In establishing NSPS, EPA is directed to take
into consideration the  cost of achieving the
effluent reduction and  any non-water quality
environmental impacts and energy requirements.
Option 3 provides the opportunity for the new
source  to recover  selected metals from  the
wastestreams they accept, whereas Option 4 does
not provide this flexibility. (With Option 3, the
metals would be recovered and could be re-used,
but with Option 4 the metals would be collected
as a sludge and deposited in a landfill).  EPA
believes that this technology is fully applicable to
all  metal wastestreams in the  CWT industry,
including those with high concentrations of total
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CHAPTER 9 Reg. Options Considered and Selected
   Development Document for the CWT Point Source Category
dissolved solids (TDS).  Commenters  to the
original proposal had questioned whether the
level of TDS in wastewater would increase the
solubility of the metals and negatively affect the
ability of the Option 3 treatment technology to
perform optimally.  As  detailed in Chapter 2,
EPA has concluded that the evidence does not
support a direct relationship between TDS and
the solubility of metals in water.  Finally, EPA
has concluded that there is no barrier to entry for
new sources  to install,  operate, and maintain
treatment systems that  will achieve  discharge
levels   associated   with  these  Option   3
technologies.
PRETREATMENT STANDARDS FOR
EXISTING SOURCES (PSES)
9.5
    Indirect dischargers in the CWT industry, like
the direct dischargers, accept wastes for treatment
that contain many toxic and non-conventional
pollutants.  Like direct  dischargers,  indirect
dischargers may be expected to discharge many
of these pollutants to POTWs at significant mass
and  concentration levels.  EPA estimates that
CWT  indirect dischargers annually discharge
-8.5 million pounds of pollutants.
    CWA Section 307(b)  requires  EPA to
promulgate pretreatment standards to prevent
pass-through  of pollutants from POTWs to
waters  of the  United  States or  to  prevent
pollutants from interfering with the operation of
POTWs.   EPA is establishing PSES for this
industry to prevent pass-through of the same
pollutants controlled by BAT from POTWs to
waters  of the  United  States.   A  detailed
description  of  the  pass-through   analysis
methodology  and the results  are presented in
Chapter 7.

          PSES OPTIONS CONSIDERED
     For the metals and  organics subcategories,
the Agency is proposing to establish pretreatment
standards for  existing sources (PSES) based on
the same technologies as proposed for BPT and
BAT.  These standards would apply to existing
facilities in the metals or organics subcategories
of the CWT industry that discharge wastewater to
POTWs and would  prevent pass-through  of
pollutants and help control sludge contamination.
Based onEPA's pass-through analysis, all of the
BAT  pollutants  controlled  by  the  metals
subcategory and  half of the BAT  pollutants
controlled by the organics  subcategory would
pass-through and are proposed for PSES.  As
detailed in  Chapter  7, the pollutants in the
organics subcategory that were determined not to
pass-through  are:  antimony,  copper,  zinc,
acetophenone,    pyridine,    and     2,4,6-
trichlorophenol.
    In establishing PSES, the Agency generally
sets the technology basis for PSES equivalent to
BAT and then conducts a pass-through analysis.
However, if the extent of the economic impacts is
questionable,   the   Agency   also  considers
alternative technology options.   In developing
PSES  for the oils subcategory, EPA carefully
considered several types of economic impacts:  to
the CWT oils facilities, to the CWT oils firms,
and to  specific segments of the CWT industry
such as small businesses.  Early results from
these analyses supported basing PSES on Option
8 rather than Option  9 (the basis for the BAT
limitations) since  the  additional  technology
associated  with  Option 9,  while  removing
additional pollutants, was associated with higher
costs and  greater adverse  economic impacts.
Therefore, EPA. preliminarily concluded that
Option 9 was not economically  achievable for
indirect dischargers.
    As explained in  Chapter 2, EPA held a
number of discussions with the small business
community engaged in oils treatment operations.
EPA also convened a SBREFA review panel for
this proposal.  The panel and the  small  entity
representatives   provided   many  pertinent
discussions and insights on possible impacts of
this regulation to  small  businesses.    Many
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CHAPTER 9 Ree. Ootions Considered and Selected
  Development Document for the CWT Point Source Category
commented that  even  Option  8  was  too
expensive.  However, EPA believes  that any
waste transferred to a CWT facility should be
treated to at least the same or similar level as that
required for the same wastes if treated on-site at
the manufacturing facility. Therefore,  EPA has
concluded  that  Option  8  is  economically
achievable even  with the projected  level  of
impacts.
    More recent results of the economic analysis
for this  proposal (which include final  cost
estimates, etc.) indicate that projected impacts for
Option 9, while greater than Option 8,  were not
as  high  as  originally  projected  in  EPA's
preliminary analyses.   However,  while EPA
estimates that removals for Option 9 for indirect -
dischargers are approximately one percent higher
than removals for Option 8, EPA believes that
many facilities could actually achieve the Option
9 limitations with the Option 8 technology alone
if designed and operated efficiently.
    Still,  in estimating the economic impacts
associated with Option 9, EPA costed facilities
for the additional treatment technology associated
with the Option 9 technology basis.  As such,
EPA estimates additional process closures and
impacts to small businesses associated with the
Option 9 technology basis.
    Therefore, the proposed PSES standards for
the oils subcategory are based on the  Option 8
technology      emulsion   breaking/gravity
separation and DAF.  Fifteen of the 20 BAT
pollutants controlled by the oils subcategory
would  pass-through  and are  proposed  for
regulation.  As detailed  in Chapter 7, the five
pollutants in  the oils  subcategory that were
determined not to pass-through are:   arsenic,
cadmium, chromium,  lead, and mercury.
 PRETREATMENT STANDARDS FOR
 NEWSOURCES (PSNS)
9.6
       sources (PSNS) at the same time it promulgates
       new source performance standards (NSPS). New
       indirect  discharging facilities, like new direct
       discharging facilities, have the opportunity to
       incorporate the  best  available  demonstrated
       technologies,  including  process  changes,  in-
       facility  controls,  and  end-of-pipe treatment
       technologies.
          As discussed in Chapter 7, EPA determined
       that a broad range of pollutants discharged by
       CWT industry facilities pass-through POTWs.
       The same technologies discussed previously for
       BAT, NSPS, and PSES are available as the basis
       for PSNS.
          EPA is proposing that PSNS be set equal to
       NSPS for toxic and non-conventional pollutants
       for all subcategories.  Since the  pass-through
       analysis  remains  unchanged,  the Agency is
       proposing to establish PSNS for the same toxic
       and non-conventional pollutants as are being
       proposed for PSES.  EPA considered the cost of
       the proposed PSNS technology for new facilities.
       EPA concluded that such costs are not so great as
       to present a barrier to entry, as demonstrated by
       the fact that currently operating facilities are
       using these technologies.
    Section 307 of the Act requires  EPA to
 promulgate pretreatment  standards  for new
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                                                                            Chapter
                                                                                 10
                     LONG-TERM AVERAGES, VARIABILITY
        FACTORS, AND LIMITATIONS AND STANDARDS
     This chapter describes the data selected and
     statistical  methodology  used by EPA  in
calculating the  long-term averages,  variability
factors, and limitations. Effluent limitations and
standards1  for each subcategory are based on
long-term average effluent values and variability
factors that account for variation in treatment
performance  within a  particular   treatment
technology over time. This chapter replaces the
discussion of how limitations were determined in
the 1995 statistical support document.2
 FACILITY SELECTION
10.1
    In determining the long-term averages and
 limitations for each pollutant of concern and each
 subcategory  option,  EPA   first   evaluated
 information about individual facilities and the
 analytical data from their treatment systems. As
 a result  of this evaluation, EPA selected only
 those  facilities  that  operated  the  model
.technology  to  achieve  adequate  pollutant
 removals for use in calculating subcategory long-
 term averages  and limitations. EPA used data
 from the appropriate influent and effluent sample
 points to  develop the  long-term  averages,
 variability factors, and limitations. Table 10-1
 identifies these facilities and sampling points for
 the  proposed  options.   The EPA sampling
 episodes are identified with an '' preceding the


        !In the remainder of this chapter,
 references to 'limitations' includes 'standards.'

        Statistical Support Document For
 Proposed Effluent Limitations Guidelines And
 Standards For The Centralized Waste Treatment
 Industry, EPA 821-R-95-005, January 1995.
facility's 4-digit number (for example, E4378).
Data supplied by the facilities ("self-monitoring
data")  are  not preceded  by  any alphabetic
character (for example, facility 602).. The table
includes some options that EPA did not use as the
basis for the proposed limitations.  These are
included because the data are listed in Appendix
C and/or in items in the record for the proposed
rulemaking.
    EPA selected some facilities for more than
one subcategory option if the facility treated its
wastes using more than  one  of  the model
technologies.  For example, EPA selected facility
4378 for both options 2 and 3 in the Metals
subcategory  because the effluent from sample
point SP07  represents the option 2 model
technology and the effluent from SP09 represents
the option 3 model technology.  For the Oils
subcategory, facilities 4814A, 4814B, and 701
had the model technology  for option 8.   The
model technology for option 9 is a combination of
the option 8 model technology and an additional
pretreatment step of gravity separation and are
based on facilities 4813, 4814A,  4814B, and
701.   Even though the technology basis for
Option 9 is based on an additional treatment step,
EPA included the data from the option 8 facilities
to ensure that the limitations were based on
facilities which treat the full breadth of pollutants
and pollutant concentrations found  in oils
subcategory wastes. Thus,  EPA selected these
facilities to  characterize  both   the  model
technology for options 8 and 9.
    If the concentration data from a facility was
collected over two or more distinct time periods,
EPA analyzed the data from  each  time period
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Chanter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
separately. In the documentation, EPA identifies
each  time period  with  a  distinct  "facility"
identifier. For example, facilities 4378 and 4803
are actually one facility, but the corresponding
data are from two time  periods.  In effluent
guidelines for other industrial categories, EPA
has made  similar assumptions for such data,
because  data  from  different time periods
generally   characterize   different   operating
conditions due to changes such as management,
personnel, and procedures.
    Further, if EPA obtained the concentration
data from both an EPA sampling episode  and
self-monitoring data provided by the facility,
EPA  analyzed  the data from each source
separately.  Again, this is similar to assumptions
that EPA has made for effluent guidelines for
other industrial categories. The exception to this
general rule was for facility 701 in which EPA
combined data mat EPA and the facility collected
during overlapping time periods.  The facility
provided effluent measurements collected on four
consecutive days by the  control authority  and
monthly effluent measurements collected by the
facility.  EPA, however, only collected influent
and effluent measurements on  one  day. (In
Table  10-1,  the data from the facility  are
identified as '701.' The EPA sampling data is
identified as 'E5046.' In this document, the data
from the two sources are collectively identified as
'facility  701.')    EPA  believes  that it  is
inappropriate    to    include   the   effluent
measurements from E5046  in its calculations
because  the sample was collected  as a grab
sample rather than as a composite sample of the
continuous flow system  at that  sample point.
However,   EPA   retained   the   influent
measurements because influent measurements
were otherwise unavailable and this information
was crucial for determining if the facility accepted
wastes  containing the  pollutants  that were
measured in the effluent. EPA also used this
influent information in evaluating the pollutant
removals for facility 701.
    Although EPA collected the data for Episode
4814 during the same time period and from the
same facility, EPA has detennined that data from
facility 4814 should be used to characterize two
separate facilities.- Facility 4814 has two entirely
separate treatment trains which EPA  sampled
separately.  Because the systems were operated
separately and treated different wastes, EPA has
treated the data as if they were collected from two
different  facilities (EPA has  identified  the
systems as 4814A and 4814B)
SAMPLE POINT SELECTION
Effluent Sample Point
 10.2
10.2.1
    For  each facility,  EPA  determined the
effluent sample point representing wastewater
discharged by the model technology selected as
the basis for that  subcategory  option.   For
example, the effluent discharged from sample
point SP09  at facility 4378  is  the effluent
resulting from the model technology selected for
option 3 of the Metals subcategory.
Influent Sample Point
10.2.2
    Influent data were  available for all EPA
sampling episodes.  However, relevant influent
data were  not available for any of the self-
monitoring effluent data except for Facility 701
(as explained in section  10.1).  As detailed
previously  in  Chapter 12,  for the metals and
organics  subcategories,  this   influent  data
represent pollutant concentrations  in  "raw",
untreated wastes.   For the oils subcategory,
however, influent  data  represent  pollutant
concentrations      following      emulsion
breaking/gravity separation. Therefore, for each
facility,  EPA  determined the relevant influent
sample point for the waste entering the model
technology  selected  as  the  basis  for  that
subcategory option.
    In  some  cases,  EPA  estimated influent
pollutant concentrations by combining pollutant
measurements from two or more influent sample
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Chanter 10 LT As, VFs, and Limitations and Standards
       Development Document for the CWT Point Source Category
points into a single flow-weighted value.  For
example, in Option 3 of the metals subcategory,
EPA  collected influent samples at five points
(SP01, SP03, SP05, SPOT, and SP10) during the
sampling episode  at  Facility  4803.    EPA
calculated a single value from these five sampling
points representing the influent to the model
technology using the methodology described in
Section 10.4.3.3.
Special Cases
10.2.3
    As  detailed previously  in  Chapter 2,  for
samples collected during EPA sampling episodes,
EPA did not analyze for the full spectrum of
pollutants at each sampling point. The specific
constituents  analyzed at each episode  and
sampling point varied and depended on the waste
type being treated and the treatment technology
being evaluated. For example, for the metals
subcategory,'EPA did not generally analyze for
organic  pollutants  in effluent  from chemical
precipitation and clarification.   Therefore, in
some cases, for specific pollutants, EPA selected
a different sample point to represent influent to
and effluent from the model treatment technology
than the sample point selected for all other
pollutants.  For example, for Episode 4803 in
Metals Option 3, EPA selected sample point 15
to  represent  the   effluent  from  the  model
technology.   Since EPA did not  analyze  the
wastewater collected at sample  point 15 for oil
and  grease,  sgt-hem, total cyanide, and organic
constituents, for these pollutants only, EPA
selected sample point 16 to represent the effluent
point for Episode 4803 of Metals Option 3. EPA
believes this is appropriate since the treatment
step between sample point 15 and sample point
16 should not have affected the levels of these
pollutants in the wastewater.
 DETERMINATION OF BATCH AND
 CONTINUOUS FLOW SYSTEMS
  10.3
    For each influent and effluent sample point of
interest, EPA  determined whether wastewater
flows were 'continuous'or 'batch.' At sample
points associated with continuous flow processes,
EPA collected composite samples for all analytes
except for oil and grease (for which the analytical
methods specify grab samples). At sample points
associated  with batch flow processes,  EPA
collected grab samples. For self-monitoring data,
EPA assumed the wastewater flow to be either
continuous  or batch based on  the type of
discharge at the facility (i.e., continuous or batch
discharge).
    EPA made different assumptions depending
on the two types of flow processes.  For a sample
point associated with a continuous flow process,
EPA aggregated all measurements within a day to
obtain one value for the day. This daily value
was then used in the calculations of long-term
averages, variability factors, and limitations. For
example, if samples were collected at the sample
point on four consecutive days, the  long-term
average would be the arithmetic average of four
daily values. (Sections 10.4.2 and  10.5 discuss
data aggregation and calculation of long-term
averages, respectively.) In contrast, for a sample
point associated with a batch flow process, EPA
aggregated all measurements within a batch to
obtain one value for the batch process.  This
batch value was then used as if it were a daily
value. For example, if one sample was collected
from each  of 20 batches  treated on  four
consecutive days  (i.e., a total of 20 samples
during a four day period), the long-term average
would be the arithmetic average of the 20 batch
values.   For simplicity,  the remainder of the
chapter refers to both types of aggregated values
(i.e., daily and batch values) as 'daily values.' In
addition, references to 'sampling day' or 'day'
mean either a sampling day at a continuous flow
facility or a batch from a batch flow facility. The
sample points followed by an asterisk in Table
10-1  are associated with batch  flow systems.
EPA assumed all other sample points to be
associated with continuous flow systems.
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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
Table 10-1 Facilities and Sample Points Used to Develop Long-term Averages and Limitations
Subcategory
Metals











Cyanide Subset
ofMetals
Subcategory
Oils









Option Facility
1A E1987
E4382
613
E4798
2 E4378


3 E4378


602
E4803

4 E4798
700
1 E4393
2 E4055
1C E4381
E4382
E4440
E4620
E4813

E4814A
E4814B
8/8v E4814A
E4814B
701 and
E5046 f
Pollutants
All
All
analytes that pass tests in
E4382
All
Total cyanide
Organics
All others
Total cyanide
Organics
All others
Analytes passing the tests
inE4378ORE4803
Oil and Grease,
SGT-HEM, total cyanide,
and organics
All others
All
Analytes passing the tests
inE4798
Total cyanide
Total cyanide
All 
All
All
All
Total cyanide
All others
All
All
All
All
AU
Effluent Sample
Point
SP03
SP12;
SP16*
SP03
SP07
SP07
SP07
SP09
SP09
SP09
SP01
SP16
SP15
SP05
SP01
SP07
SP03*
SP01*
SP11
SP06
SP02
SP06
SP05
SP07
SP08
SP09
SP10
SP01 from 701
Influent Sample Point
SP01, SP02
dav3 flows:
SP01=25()Ogal
SP02=1290gal
(on other days, samples weren't
collected at both sample points.)
SP07
none
SP02
SP06
SP08
SP01= 5,000 gal *
SP03=20,000 gal *
SP06
SP08
SP01= 5,000 gal
SP03=20,000 gal
none
SP12
SP01= 3,400 gal *
SP03=12,600 gal *
SP05=18,000 gal *
SP07= 8,000 gal *
SP10= 4,355 gal * J
SP02
none
SP06
SP02*
none
none
none
none
none
none
none
none
SP07
SP08
none from 701 and SP01 from
E5046
                                               10-4

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Chapter 10 LTAs, VFs, and Limitations and Standards
      Development Document for the CWT Point Source Category
 Table 10-1 Facilities and Sample Points Used to Develop Long-term Averages and Limitations
Subcategory
Oils (cont)




Organics

Option Facility
9/9v E4813

E4814A
E4814B
701 and
E5046 f
0 E4377
E4472
3/4 E1987
Pollutants
Total cyanide
All others
All others
All
All
All
All
All
Effluent Sample
Point
SP07
SP07
SP09
SP10
SP01 from 701
SP01
SP01
SP12
Influent Sample Point
SP06
SP05
SP07
SP08
none from 701 and SP01 from
E5046
none
none
SP07B
* Batch flow systems.  All others are continuous flow systems.
J EPA collected samples from four separate batches at SP10. The flows associated with the four batches 10A,
10B, IOC, and 10D were 3500 gal, 5130 gal, 3500 gal, and 5130 gal, respectively. EPA used the average flow
of 4355 gal in flow-weighting SP10 with the four other sample points SP01, SP03, SP05, and SP07.
f These are identified as facility 701 in other tables in this document and in the record.
When multiple sample points are identified in this table, the data listing and data summaries identify the last sample
point.  For example, for facility 4803 (metals subcategory, option 3), the influent sample point is identified as
'SP10.'
DATA SELECTION
10.4
    EPA performed  a detailed review  of the
analytical data and sampling episode reports. As
a  result, EPA  corrected  some errors  in the
database. EPA also re-evaluated the bases for the
data  exclusions  and  assumptions as used in
calculating limitations for the  1995 proposal.
EPA made some modifications to its approach for
this proposal after reviewing the assumptions it
used  for excluding or modifying certain  data.
These are discussed in this section. The database
was corrected and the corrected version has been
placed in the record to this proposed rulemaking.

Data Exclusions and Substitutions     10.4.1

    In some cases, EPA did not use all of the data
detailed in Table 10-1  to calculate long-term
averages, variability factors and limitations.  This
section  details  these  data  exclusions   and
substitutions Other than the data exclusions and
substitutions described in this section and those
resulting  from  the   data  editing  procedures
(described in section 10.4.3), EPA has used all
the data from the facilities and sample points
presented in Table 10-1.

Operational Difficulties      10.4.1.1
    EPA excluded data that were collected while
the  facility  was   experiencing  operational
difficulties. For the data used in calculating long-
term  averages and  limitations,  this occurred
during sampling at episode 4814 only.  During
the second day of sampling, 9/17/96, the facility
was required to shut-down  and re-start the
operation of both of their DAP systems due to
poor performance and equipment failures.  As
such, EPA excluded all data collected on 9/17/97
associated with sample point 09 at facility 4814A
and sample point 10  at facility 4814B.

Treatment Not Reflective of
BPT/BCT/BAT Treatment             10.4.1.2
    EPA reviewed  the  effluent data used  to
develop the limitations and excluded any facility
data set where the  long-term  average  did not
reflect    the   performance    expected    by
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Chanter 10 LTAs. VFs, and Limitations and Standards      Development Document for the CWT Point Source Category
BPT/BCT/BAT treatment. Other than excluding
mercury values from facility 602 in option 3 of
the metals subcategory, the other excluded facility
data sets were for conventional parameters (i.e.,
oil and grease, BODS, and TSS).  In all cases,
these data sets were collected at facilities that are
indirect dischargers and that are not required to
optimize performance of their system for removal
of these  pollutants.    In  most  cases, the
conventional pollutants are not limited by the
POTW and the facility is not required to monitor
for these pollutants.  These exclusions were for
oil and  grease (facilities 4813,  4814A, and
4814B for option 93 of the oils subcategory),
BODS  (facility  1987 for option  3/4 of the
organics subcategory), TSS (facility 1987 for
option 3/4  of the organics subcategory, and
facilities 4798 and 700 for option 4 of the metals
subcategory).
    Similarly, in calculating long-term averages
for oils option 9, EPA excluded the TSS data for
facilities 4813, 4814A, and 4814B.  However,
EPA used these data to  calculate variability
factors for TSS for oils option 9 since EPA
believes that  the  data  reflected  the overall
variability associated with the model technology.
(Sections 10.5,  10.6, and 10.7  describe  the
development   of  the  long-term   averages,
variability factors, and limitations, respectively.)

Exclusions to EPA Sampling Data
Based Upon the Availability of the
Influent and Effluent                 10.4.1.3
    For the  data  from  the EPA sampling
episodes, EPA determined the availability of the
influent and effluent data for each sampling day.
Both influent and effluent levels are important in
evaluating   whether  the  treatment  system
efficiently removed the pollutants.  In addition,
the  pollutant  levels  in  the  influent  indicate

         3EPA did not similarly exclude data for
facilities 4814A and 4814B from the Option 8
calculations since EPA did not select this option as
the basis of the proposed BPT/BCT limitations.
whether the pollutants existed at treatable levels.
In most cases, influent and effluent data were
both available for a given day.
    For the  cases when  effluent data  were
unavailable for some days, but influent data were
available, EPA generally  determined  that the
influent data still provided useful information
about the pollutant levels and should be retained.
However, for the organic pollutants at facility
4378, the effluent data were only available for
one day while the influent data were available for
several days.  In this case, EPA determined that
the influent levels on that single date should be
considered and the  levels on the other  dates
excluded.
    When the effluent data were available but
influent data  were unavailable, EPA determined
that the effluent  data should be excluded from
further consideration. Without the influent data,
EPA could not evaluate the treatability of the
pollutants and the effectiveness of the treatment
system.

More Reliable Results Available     10.4.1.4
    In some cases, EPA had. analytical data which
represent a single facility (and time period) that
were analyzed by two different laboratories  or
using two different analytical methods. For two
of these  cases,  EPA determined  that one
analytical result was more reliable than the other
and excluded  the less reliable result. This section
describes these cases.
    In limited instances, facility 700 provided
two analytical results  for  the same date from
different  laboratories.  For the total  cyanide
effluent data  collected on 1.1/6/96, the analytical
results  from  the two  laboratories  differed
considerably.   The    facility   representative
considered the result  generated by the off-site
laboratory to be more reliable than the result
generated by  the facility's on-site laboratory and
recommended that EPA use the off-site data only.
EPA agrees  with this suggestion and  has used
only the value from the off-site laboratory.
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    Some chlorinated phenolics in episode 1987
were analyzed by both method 85.01 and method
1625.  Thus, for a given sample, there were two
results for a specific chlorinated phenolic. Of the
pollutants of concern, these compounds were
pentachlorophenol,   2,3,4,6-tetrachlorophenol,
2,4,5-trichlorophenol, and 2,4,6-trichlorophenol.
Where two  results were provided for the same
pollutant in a sample, EPA used the analytical
result from Method 1625.  This decision is based
on the knowledge that Method 1625 is an isotope
dilution  GC/MS  procedure,  and therefore
produces more reliable results than  Method
85.01.

Data from Facilities Which
Accepted Waste from More
than One Subcategory               10.4.1.5
    EPA also excluded data that were collected
during time periods when the facility treated
wastes from more than  one CWT subcategory.
For the  oil and grease  calculations for metals
option 4, EPA excluded all oil and grease values
greater than 143 mg/L since this was the highest
value of oil and grease measured in the influent
samples collected at any  metals subcategory
facility.  EPA  believes that values of oil and
grease in the effluent above this  level indicate
that the facility was also treating oils subcategory
wastes and has, therefore, excluded this data from
its calculations.

Substitution Using the
Baseline Values                      10.4.1.6
    In  developing  the  pollutant  long-term
averages and limitations, EPA compared each
laboratory-reported sample result to a baseline
value  (defined in Chapter 15).   For certain
pollutants, EPA substituted a larger value than
the measured value or sample-specific detection
limit in  calculating the long-term averages and
limitations. These pollutants were measured by
Methods 1624 and 1625 (organic pollutants) and
Method 1664  (n-hexane  extractable  material
(HEM) and silica gel treated n-hexane extractable
  material (sgt-hem)).  For these pollutants, EPA
  substituted the value of the minimum level (ML)
  specified  in the method and assumed that the
  measurement was non-detected when a measured
  value  or  sample-specific detection limit was
  reported with a value less than the ML.   For
  example,  if the ML was  10  ug/1  and  the
  laboratory reported a detected value of 5 ug/1,
  EPA assumed that the concentration was non-
  detected with a sample-specific detection limit of
  10 ug/1. For all other pollutants, EPA used the
  reported  measured  value  or sample-specific
  detection limit.
  Data Aggregation
10.4.2
      In some cases, EPA determined that two or
  more  samples  had  to   be  mathematically
  aggregated to obtain a single value.  In some
  cases, this meant that field  duplicates,  grab
  samples, and/or multiple daily observations were
  aggregated for a single sample point. In other
  cases, data from multiple  sample points were
  aggregated to obtain a single value representing
  the influent to the model technology.
      In   all   aggregation   procedures,  EPA
  considered the censoring type associated with the
  data.  EPA considered measured values to  be
  detected.  In statistical terms, the censoring type
  for   such data  was   'non-censored'   (NC).
  Measurements reported as being less than some
  sample-specific detection limit (e.g., <10 mg/L)
  are censored and were considered to be non-
  detected (ND). In the tables and data listings in
  this document and the record for the proposed
  rulemaking, EPA has used the abbreviations NC
  and ND to indicate the censoring types.
      The distinction between the two censoring
  types is important because the procedure used to
  determine the  variability factors  considers
  censoring type explicitly.   This  estimation
  procedure modeled the facility data sets using the
  modified delta-lognormal distribution.  In this
  distribution, data are modeled as a mixture of two
  distributions corresponding to different process
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Chanter 10 LTAs. VFs, and Limitations and Standards
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conditions.  Because this industry treats different
types of waste from day to day, EPA assumed
that  the  process   conditions   leading   to
non-detected values are generally different than
process conditions leading to the detected values.
(For example, a facility may treat wastewater
with relatively high levels of organics and  low
levels of metals and the next day treat wastes that
have  high  metals  concentrations  and non-
detectable  levels of  organics.)   Thus,  the
distinctions between detected and non-detected
measurements were important in estimating the
variability factors.
    Because each aggregated data value entered
into the model as a single value, the censoring
type  associated with  that  value  was   also
important.  In many cases, a single aggregated
value was created from unaggregated data  that
were all either detected or non-detected. In the
remaining cases with a mixture of detected and
non-detected   unaggregated   values,   EPA
determined that the resulting aggregated value
should be considered to be detected because the
pollutant was measured at detectable levels.
    This section describes each of the different
aggregation procedures. .They are presented in
the order that the aggregation was performed.
That is, field  duplicates were aggregated first,
grab and multiple samples second, and finally
multiple streams. For example, if EPA has  four
pairs of data (i.e., four influent samples and four
duplicate influent samples), then EPA aggregated
each of the four pairs to obtain four values  one
for each pair of data. These four values were  then
aggregated to obtain  one daily  value for the
influent stream.  As a further example, suppose
the same  facility had  two additional streams
entering into  the treatment system. Thus, the
influent into  the treatment  system would be
characterized by the combination of the pollutant
levels of the three streams. To obtain one value
to characterize the influent, the pollutant levels in
the three streams would be 'flow-weighted' by
the  wastewater flow  in each  stream.   The
  following three sections specify the procedures
  used to aggregate field duplicates, grab samples
  (and daily values), and multiple influent streams,
  respectively.

  Aggregation of Field Duplicates      10.4.2.1
      During the EPA sampling episodes,  EPA
  collected a small number of field duplicates.
  Generally, ten percent of the number of samples
  collected were duplicated.  Field duplicates are
  two or more  samples collected for the  same
  sampling point at approximately the same  time,
  assigned different sample numbers, and flagged
  as  duplicates  for a single  sample point at a
  facility.-  Because the analytical data from each
  duplicate pair characterize the same  conditions at
  that time  at  a  single sampling  point,  EPA
  aggregated the data to obtain one data value for
  those conditions. The data value associated with
  those conditions was the arithmetic average of the
  duplicate pair. In most cases, both duplicates in
  a pair had the same censoring type.  In  these
  cases, the censoring type of the aggregate was the
  same as the duplicates.  In the remaining cases,
  one duplicate was a non-censored value and the
  other duplicate was a non-detected value.  In
  these cases, EPA determined that the appropriate
  censoring   type   of  the   aggregate   was
  'non-censored' because  the pollutant had been
  present  in  one sample.   (Even  if the  other
  duplicate had a zero value4, the pollutant still
  would have been present if the samples had been
  physically combined.) Table  10-2 summarizes
  the procedure for  aggregating the analytical
  results   from  the  field   duplicates.    This
  aggregation step  for the duplicate  pairs was  the
  first step in the aggregation procedures for both
  influent and effluent measurements.
          4This is presented as a 'worst-case'
   scenario. In practice, the laboratories cannot
   measure 'zero' values. Rather they report that the
   value is less than some level (see chapter 15).
                                             10-8

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Chapter 10 LT As, VFs, and Limitations and Standards
                   Development Document for the CWT Point Source Category
Table 10-2.  Aggregation of Field Duplicates
 If the field duplicates are:
Censoring type of  Value of aggregate is:
   average is:
                                        Formulas for
                                        aggregate value of
                                        duplicates:
Both non-censored
Both non-detected
NC
ND
arithmetic average of
measured values
arithmetic average of sample-
(DL,+DL2)/2
 One non-censored and one
 non-detected
             specific detection limits
 NC         arithmetic average of
             measured value and sample-
	specific detection limit	
                                             (NC + DL)/2
NC=non-censored (or detected)    ND=non-detected
                          DL=sample-specific detection limit
Aggregation of Grab Samples
and Multiple Daily Values           10.4.2.2
    This section  describes the aggregation  of
grab  samples  and multiple  daily  values  for
effluent sample points associated with continuous
flow facilities (defined in section 10.3).
    During the EPA sampling episodes, EPA
collected  two  types of  samples:  grab  and
composite.  Typically,  for a continuous flow
system,  EPA  collected  composite samples;
however, for oil and grease, the method specifies
that grab samples must  be  used.  For  that
pollutant, EPA  collected four  grab samples
during  a sampling  day  at  a  sample point
associated with a continuous flow system.  To
obtain one value  characterizing the pollutant
levels at the sample point on a single day, EPA
mathematically aggregated the  measurements
from the grab samples.
    In  the  self-monitoring  data, facilities
occasionally reported more than one value for a
single day.  If the sample point was associated
with  a continuous  flow system,  then EPA
mathematically aggregated the results to obtain
one daily value.
    EPA  used the  same procedure for grab
samples and multiple daily values. The method
arithmetically  averaged the  measurements  to
obtain a single value for the day. When one or
more measurements  were non-censored, EPA
                     determined that the appropriate censoring type of
                     the aggregate was 'non-censored' because  the
                     pollutant was present.  Table 10-3 summarizes
                     the procedure.
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Chanter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CV\T Point Source Category
Table 10-3
Aggregation of Grab Samples and Daily Values
If the grab or multiple
samples are:
          Censoring type of  Daily value is:
           Daily Value is:
                       Formulas for Calculating
                       	Daily Value:	
All non-censored
All non-detected
 Mixture of non-censored
 and non-detected values
 (total number of
 observations is n=k+m)
               NC        arithmetic average of measured
                          values
               ND        arithmetic average of sample-
                          specific detection limits
               NC        arithmetic*average of measured
                          values and sample-specific
                          detection limits
                                                                                n
                                                                                n
                                                                                   m
                                                                 n
NC=snon-censored (or detected)
                       ND=non-detected
               DL=sample-specific detection limit
Aggregation of Data Across
Streams ("Flow-Weighting")         10.4.2.3
    After field duplicates and grab samples were
aggregated, the data were further aggregated
across sample points.  This step was necessary
when more than one sample point characterized
the wastestream of concern.  For example, this
situation occurred for facility 4803 where five
different wastestreams entered into the treatment
process.     EPA  sampled  each  of  these
wastestreams individually at sample points SP01,
                                 SP03, SP05, SPOT, and SP10. In aggregating
                                 values across sample points, if one or more of the
                                 values were non-censored, then the aggregated
                                 result was non-censored (because the pollutant
                                 was present in at least one stream). When all of
                                 the values were non-detected, then the aggregated
                                 result was considered to be non-detected.  The
                                 procedure for aggregating data across streams is
                                 summarized in Table 10-4.   The  following
                                 example   demonstrates   the   procedure  for
                                 hypothetical pollutant X at a facility with three
                                 streams entering into the treatment system.
Example of calculating an aggregated flow-weighted value:
    Sample Point
      SP33
      SP34
      SP35
                Flow (gal)
                10,000
                20,000
                5,000
Concentration (uefD
        10
        50
        100
Censoring
 ND
 NC
 ND
                                            10-10

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Chapter 10 LTAs, VFs. and Limitations and Standard
                               Development Document for the CWT Point Source Categor
    Calculation to obtain aggregated, flow-weighted value:
           (10,000gal    IQug/L)   (20,000gal   50ug/L)    (5,000gal    IQOug/L)
                              10,000gal  + 20,OOOgaJ + 5,OOOgaJ
                                          = 45.7 ug/L
    because one of the three values was non-censored, the aggregated value of 45.7 ug/L is no
    censored.
Table 10-4
Aggregation of Data Across Streams
 If the n observations are:
                         Censoring
                           type is:
Formulas for value of aggregate
 All non-censored
                            NC
 All non-detected
                            ND
                                                                   /=r
                                                                 1=1
 Mixture of k non-censored and
 m non-detected

 (total number of observations is n=k+m)
                            NC
                                           k
                                          
                                          1=1
                                                                   1=1
NC=non-censored (or detected)    ND=non-detected
                                       DL=sample-specific detection limit
Data Editing Criteria
    After excluding some data (as detailed in
Section 10.4.1) and aggregating the data, EPA
applied data editing criteria to select facility data
sets from the EPA sampling episodes to use in
calculating   the   long-term   averages   and
limitations.  These criteria were specified by the
'long-term average test' and 'percent removals
                       10.4.3    test.'   In addition, the  criteria for the  self-
                                 monitoring data depended upon the results of the
                                 data editing  criteria  for  the data that  EPA
                                 collected at the facilities.  These  data  editing
                                 criteria are described in the following sections.
                                 When the influent data at a facility failed the
                                 editing criteria, EPA excluded the effluent data
                                 for  the  facility  in calculating the  long-term
                                 averages and limitations for the corresponding
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Chapter 10 LTAs, VFs, and Limitations and Standards
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option in the subcategory.   For example,  at
facility 1987,  if the arsenic data from influent
sample  point 07B failed any of the editing
criteria, then the effluent data at sample point
SP12 were excluded from calculating the long-
term averages and limitations for option 4 of the
organics subcategory. For each of the proposed
options and pollutants of concern evaluated for
long-term averages and limitations, Attachment
10-1 indicates whether the data failed the data
editing criteria,  indicates  when no data were
available for a pollutant at any of the facilities, or
provides the facility-specific long-term average
(calculated as described in section 10.5).

Long-Term Average Test             10.4.3.1-
    EPA established the long-term  average test
('LTA test') to ensure that the pollutants were
present in the influent at sufficient concentrations
to evaluate treatment effectiveness at the facility.
After the  data aggregation described in section
10.4.2, EPA compared the daily values of the
influent  and their long-term average  to the
baseline values  described in chapter  15.  The
influent had to pass one of the following two
steps to pass the LTA test:

Step 1: Fifty    percent   of  the   influent
       measurements had  to  be  detected  at
       concentration levels equal to or greater
       than ten times the baseline value for the
       pollutant  (these values are  listed  in
       Attachment 15-1); or

Step 2: The influent long-term average had to be
        equal to or  greater than ten times the
        baseline value and at least 50 percent of
        the influent measurements had  to  be
        detected (at any level).  Section 10.5
        describes the calculations for long-term
        averages.
  Percent Removal Test                10.4.3.2
      If the influent data passed either step in the
  LTA test, then EPA calculated the facility's
  influent and effluent averages without all of the
  data  aggregation  steps  described  in section
  10.4.2.  This is a deviation from the procedure
  used to calculate the influent averages used in
  LTA test (in section 10.4.3.1) and the effluent
  long-term averages used in the limitations (in
  section  10.7).  For the percent removals, EPA
  used a  different  aggregation procedure  that
  emphasized the detection of pollutant levels.  In
  this  modified   aggregation  procedure,  EPA
  aggregated field duplicates using the procedure in
  section 10.4.2.1  and flow weighted wastestreams
  using the procedure in Section 10.4.2.3. EPA did
  not aggregate batches, grabs, or multiple daily
  values (other than duplicates) as an interim step
  prior to  obtaining one  overall  value for the
  wastestream. For example, if a facility had five
  influent  measurements  of which  three were
  batches from sample point 33 and the remaining
  two  were a duplicate pair at sample point 34,
  EPA first aggregated the duplicate measurements
  at sample point 34 to obtain one value for the
  duplicate pair. EPA then arithmetically averaged
  the three batches from sample point 33 without
  considering the flows corresponding to  each
  batch.  For the percent removals, the influent
  average was then the flow-weighted average of
  two values: one from sample point 33 and one
  from sample point 34. In. contrast, the influent
  average  for  the  LTA test would have flow-
  weighted the batches from sample point 33 using
  the flows for each batch.
      The  percent removal test  compared the
  influent and effluent averages to determine if the
  treatment associated  with the effluent  sample
  point removed any of the pollutant.  If the
  removals were negative, then EPA excluded the
  effluent data from developing  the long-term
  averages and limitations.
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Chapter 10 LTAs, VFs, and Limitations and Standards
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               Percent removal =  Influent averaSe ~ Effluent averaSe x  100
                                            Influent average
Evaluation of Self-Monitoring Data    10.4.3.3
    EPA used self-monitoring data for effluent at
three facilities  in developing  the long-term
averages and limitations.  These facilities were
602, 700,  and 701.  These facilities provided
concentration values for some of the pollutants
that EPA considered in developing the long-term
averages  and limitations.  However, the self-
monitoring data were for effluent only (i.e., no
influent data were provided). In its evaluation of
the data, EPA  determined that influent data
provided critical evidence that the facility treated
wastes containing these pollutants.  Thus, EPA
used influent data from its sampling episodes to
determine  if  the  facility  accepted  wastes
containing these pollutants.
    For  facility  701,  EPA  collected influent
information during the same time period as the
effluent  data provided  by  the facility.   As
described in section 10.1, EPA used  this influent
information .with the facility 701  effluent data.
    For the remaining two facilities, 602 and 700,
EPA considered  the  pollutant levels in the
influent  at the  EPA sampling  episodes.   As
explained  in section  10.1, different  facility
numbers  may refer to  the  same facility.  For
example, for option 3 of the metals subcategory,
facilities  602, 4378, and  4803 are  the  same
facility.  (Facilities 4378 and 4803 were EPA
sampling episodes.) If the influent data at facility
4378 or facility 4803 met the data editing criteria
(i.e., LTA test and percent removals test), then
EPA used the effluent data from facility 602 in
calculating the long-term averages and limitations
for the pollutant.  If the influent  data for  the
pollutant at  facility 4378 and facility 4803  did
not meet the criteria, then EPA excluded the data
  from facility 602. In a similar manner, facilities
  4798 and  700 for option  4 of  the  metals
  subcategory were linked. If the influent data for
  a pollutant  at facility 4798 (an EPA sampling
  episode at the same facility as facility 700) met
  the  data  editing criteria, then EPA used the
  effluent data from facility 700 in calculating the
  long-term  averages and  limitations  for the
  pollutant.  If the influent data for the pollutant at
  facility 4798 did not meet the criteria, then EPA
  excluded the data from facility 700.
  DEVELOPMENT OF LONG-TERM
  AVERAGES
10.5
      In order to develop the long-term averages
  and proposed limitations for the centralized waste
  treatment industry, it was necessary to estimate
  long-term averages and variability factors. This
  section discusses  the  estimation of long-term
  averages by facility ("facility-specific") and by
  option ("pollutant-specific").  For each pollutant
  of concern (see Chapter 7), EPA calculated long-
  term averages for each regulatory option and each
  subcategory. The long-term average represents
  the average performance level that a facility with
  well-designed and operated model technologies is
  capable of achieving.
      EPA  calculated the  long-term average for
  each pollutant for each facility by arithmetically
  averaging  the  pollutant concentrations.   The
  pollutant long-term average for an option was the
  median of the long-term  averages from selected
  facilities with the technology basis for the option.
  The  following  two subsections  describe  the
  estimation of the facility-specific and pollutant-
  specific long-term averages.
                                            10-13

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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the GMT Point Source Category
Estimation ofFacility-Spectfic
Long-Term Averages
10.5.1
    The facility-specific long-term average for
each pollutant for each facility is the arithmetic
average of the daily pollutant concentrations of
wastewater from the facility. EPA substituted the
sample-specific  detection limit for each non-
detected measurement.
    For   example,   for  facility  A,  if  the
concentration values for hypothetical pollutant X
are:
10 mg/1,
13 mg/1,
non-detect ("ND") with sample-specific detection
    limit = 5 mg/1,
12 mg/1, and
15 mg/1

then the facility-specific long-term average is
calculated using the sample-specific detection
limit of 5 mg/1 for the non-detected measurement.
This facility-specific long-term average is equal
to the average of the five values:
(10 + 13 + 5 + 12 + 15)/5 mg/1 = 11 mg/1.
Estimation of Pollutant-Specific
Long-Term Averages
10.5.2
    The pollutant-specific long-term average was
the median of the  facility-specific long-term
averages  from the  facilities  with the model
technologies for the option.  The median is the
midpoint of the values ordered (i.e., ranked) from
smallest to largest. If there is an odd number of
values (with n=number of values), then the value
of the (n-H)/2 ordered observation is the median.
If there are an even number of values, then the
two values of the n/2 and [(n/2)+l] ordered
observations are arithmetically averaged to obtain
the median value.
    For example, for subcategory Y option Z, if
the four (i.e., n=4)  facility-specific long-term
averages for pollutant X are:
Facility        Long-term average
   A                  20 mg/1
   B                  9 mg/1
   C                  16 mg/1
   D                  10 mg/1

then the ordered values are:
Order   Facility         Long-term average
    1      B                  9 mg/1
    2      D                  10 mg/1
    3      C                  16 mg/1
    4      A                  20 mg/1

And the pollutant-specific long-term average for
option Z is the median of the ordered values (i.e.,
the average of the 2nd and 3rd ordered values):
(10+16)/2 mg/1 = 13 mg/1.

   The pollutant-specific long-term averages
were used in developing the limitations for each
pollutant within each proposed option.

Substitutions for
Long-Term Averages                  10.5.3
Baseline Values Substituted,
for Long-Term Averages             10.5.3.1
   After calculating the pollutant-specific long-
term averages for the proposed options, EPA
compared these values to the baseline values
provided in chapter  15.   EPA performed this
comparison in response to comments on the 1995
proposal. These comments stated that it was not
possible to measure to the  low levels required in
that proposal.  If the long-term average was less
than the baseline  value,  EPA  substituted the
baseline value for the pollutant-specific long-term
average. Table 10-5 identifies the pollutants for
options 3 and 4 in the Metals subcategory where
this  situation  occurs.  (This situation  did  not
occur for the other subcategories.)
                                           10-14

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Chanter 10 LTAs, VFs, and Limitations and Standards
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 Table 10-5 Metals Subcategory: Long-Term Averages Replaced by the Baseline Values
Option
3



4

. Pollutant
' "beryllium
manganese
silver
tin
titanium
vanadium
indium
vanadium
CAS number
7440417
7439965
7440224
7440315
7440326
7440622
7439885
7440622
Baseline Value Long-Term Average
(mg/L) (mg/L)
5
15
10
30
5
50
1000
50
1
12
5
28
4
11
500
12
 Arsenic Long-Term Average for
 Metals Subcategory Option 4         10.5.3.2
    In developing the limitations for arsenic for
 option 4 of the metals Subcategory, EPA used the
 long-term average from option 1A.  During the
 EPA    sampling   episode,   the   influent
 concentrations of arsenic were at levels less than
 EPA's   criteria   for  treatable   levels   (see
 explanation of LTA test in section 10.4.3.1).
 Thus,  the data  editing criteria  excluded the
 arsenic data from both facilities 4798 and 700.
 However, the arsenic concentration at facilities in
. option 1A were at treatable levels. Because the
 treatment technology in option 4 should provide
 better removals than option 1 A, EPA expects that
 facilities utilizing the option 4 technologies can
 achieve arsenic effluent concentration levels at
 least as low as the values from facilities using the
 option  1A  technologies.   Thus,   EPA  has
 transferred the long-term average from option 1A
 to option 4.5


         5Because the data for option 4 provided
 group variability factors (see section 10.6.7) for the
 semi-metals group (which includes arsenic), EPA
 did not transfer develop variability factors using the
 data from option 1 A. Because each group is
 composed of pollutants with similar chemical
 structure, EPA expects the variability of the model
 technology in option 4 to be consistent for all
 pollutants in the group and thus used the variability
 factor from option 4.
  DEVELOPMENT OF
  VARIABILITY FACTORS
 10.6
      In developing the variability factors that were
  used in calculating the limitations, EPA  first
  developed  facility-specific  variability  factors
  using the modified delta-lognormal distribution.
  Second,  EPA  used   these   facility-specific
  variability factors  to  develop  the  group-level
  variability factors.  (Chapter 7  describes the
  assignment of pollutants to groups. Appendix A
  provides  a list of the groups and the associated
  pollutants.)   Third, EPA used the pollutant-
  specific variability factors to develop the group-
  level variability factors. For pollutants assigned
  to groups, EPA then used the group variability
  factors  in  calculating the  limitations.   For
  pollutants that were not assigned to groups, EPA
  used the pollutant-specific variability factor.
      The following sections describe the modified
  delta-lognormal distribution and the estimation of
  the   facility-specific,   pollutant-specific,  and
  group-level variability factors.
   Basic Overview of the Modified
   Delta-Lognormal Distribution
10.6.1
      EPA selected the modified delta-lognormal
   distribution   to   model   pollutant  effluent
   concentrations   from  the  centralized  waste
   treatment industry in developing the variability
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Chanter 10 LTAs. VFs. and Limitations and Standards     Development Document for the CWT Point Source Category
factors. In this industry, wastewater is generated
from treating wastes from different sources and
industrial processes. A typical effluent data set
from  a facility in this industry consists of a
mixture of measured (detected) and non-detected
values.   Within a data set,  gaps between  the
values of detected measurements and the sample-
specific  detection limits associated  with non-
detected measurements may indicate that different
pollutants were present in the different industrial
wastes  treated by  a facility.   Non-detected
measurements may indicate that the pollutant is
not generated by a particular source or industrial
process.      The   modified  delta-lognormal
distribution is appropriate  for  such data sets
because  it models the data as a mixture of
measurements  that  follow  a  lognormal
distribution and non-detect measurements that
occur with a certain probability.  The model also
allows  for  the  possibility that  non-detect
measurements occur at multiple sample-specific
detection limits. Because the data appeared to fit
the modified delta-lognormal model reasonably
well,  EPA believes that this model is  the most
appropriate model of those evaluated for the
centralized waste treatment data.
    The modified delta-lognormal distribution is
a  modification   of the  'delta  distribution'
originally developed by Aitchison and Brown.6
The resulting mixed distributional model, that
combines a continuous density portion with a
discrete-valued spike at zero, is also known as the
delta-lognormal distribution. The delta in the
name refers to the proportion of the  overall
distribution    contained    in   the   discrete
distributional spike at zero, that is, the proportion
of zero amounts.  The remaining non-zero, non-
censored (NC) amounts are grouped together and
fit to a lognormal distribution.
        6 Aitchison, J. and Brown, J.A.C. (1963)
 The Lognormal Distribution. Cambridge University
 Press, pages 87-99.
   EPA   modified    this   delta-lognormal
distribution to incorporate:  multiple  detection
limits.  In the modification of the delta portion,
the single spike located at zero is replaced by a
discrete distribution made up of multiple spikes.
Each spike in this modification is associated with
a  distinct   sample-specific  detection   limit
associated with non-detected (ND) measurements
in the database.7 A lognorrnal density is used to
represent the set  of measured  values.   This
modification of the delta-lognormal distribution
is shown in Figure 10-1.
   The following two subsections describe the
delta  and lognormal  portions of the modified
delta-lognormal distribution in further detail.
        Previously, EPA had modified the delta-
 lognormal model to account for non-detected
 measurements by placing the distributional "spike"
 at the detection limit (i.e., a single positive value,
 usually equal to the nominal method detection limit)
 rather than at zero. For further details, see Kahn and
 Rubin, 1989. This adaptation was used in
 developing limitations and standards for the organic
 chemicals, plastics, and synthetic fibers (OCPSF)
 and pesticides manufacturing rulemakings. The
 current modification was used in the pulp and paper
 and pharmaceutical industry rulemakings.
                                             10-16

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Chapter 10 LTAs, VFs, and Limitations and Standards	Development Document for the CWT Point Source Category
                             Figure 10-1
       Modified  Delta -Lognormal Distribution
                 Censoring Type   	 NC
                                10-17

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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
Discrete Portion of the Modified Delta-Lognormal Distribution
10.6.2
   In the discrete portion of the modified delta-lognormal distribution, non-detected values we e
associated with multiple values corresponding to the reported sample-specific detection limits.
   Multiple spikes were then constructed and linked to the values of the k distinct sample-specific
detection limits observed in the facility data set for the pollutant.  In the model, 8 represents the
proportion of non-detected values and is the  sum of smaller fractions, 8;, each representing the
proportion of non-detected values associated with the distinct value of a particular sample-specific
detection limit.  By letting D; equal the value of the 1th smallest distinct detection limit in the data set and
the random variable XD  represent a randomly chosen non-detected measurement, the cumulative
distribution function of the discrete portion of the modified delta-lognormal model can be mathematically
expressed as:
                                                                                        (1)
                                                                                        (2)
The mean and variance of this discrete distribution can be calculated using the fallowing formulas
                                      k    k
                                = ^E   E   *,Wf -
                                    2
   (3)
Continuous Portion of the Modified Delta-Lognormal Distribution
10.6.3
    This section describes the lognormal portion of the modified delta-lognormal distribution.  The
continuous, lognormal portion of the modified delta-lognormal distribution was used to model the
detected measurements from the centralized waste treatment industry database.
    The cumulative probability distribution of the continuous portion of the modified delta-lognormal
distribution can be mathematically expressed as
                           Pi(X
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CKanter 10 LT As, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
                                            o2) (exp(o2) -
   (5)


   (6)
where
                                     _
                                           log(x)
                                       t=i
                                  ~
                                                                                        (7)
                          measured value of the 1th detected
                                    measurement
                          n  = number of detected values
    As shown in the next section, the continuous portion of the modified delta-lognormal distribution
 combines tiie discrete and continuous portions to model data sets that contain a mixture of non-detected
 and detected measurements.
 Estimation Under the Modified Delta-Lognormal Distribution
10.6.4
    It is possible to fit a wide variety of observed effluent data sets to the modified delta-lognormal
 distribution.  Multiple detection limits for non-detect measurements can be handled, as can measured
 ("detected") values.  The same basic framework can be used even if there are no non-detected values in
 the data set.  Thus, the modified delta-lognormal distribution offers a large degree of flexibility in
 modeling effluent data.
    The modified delta-lognormal random variable U can be expressed as a combination of three other
 independent variables, that is,

                                                                                        (8)
 where XD represents a random non-detect from the discrete portion of the distribution, Xc represents a
 random detected measurement from the continuous lognormal portion, and Iu is an indicator variable
 signaling whether any particular random measurement is detected or not. Using a weighted sum, the
 cumulative distribution function from the discrete portion of the distribution (equation 1) can be
 combined with the function from the continuous portion (equation 4) to obtain the overall cumulative
                                            10-19

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Chanter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
probability distribution of the modified delta-lognormal distribution as follows,
          Pr(L7<;u)  =
         6, + (1 -S)$ [(log(u) -
                        6 +(1-8)$ [(log(u)-n)/o)]
                                                              if  0
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Chanter 10 LTAs, VFs, and Limitations and Standards
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Estimation of Facility-Specific
Variability Factors
10.6.5
    This  section  applies  the  methodology
described in the previous section to the estimation
of facility-specific variability factors for each
pollutant.  EPA estimated the daily variability
factors  by fitting a modified delta-lognormal
distribution  to  the daily measurements.   In
contrast,  EPA  estimated monthly  variability
factors  by fitting a modified delta-lognormal
distribution  to the monthly averages.   These
averages were developed using the same number
of  measurements as the assumed monitoring
frequency for the pollutant.  EPA is assuming
that some pollutants such as organics will be
monitored weekly (approximately four times a
month) and  others will  be monitored  daily
(approximately  20 times a month).8  Section
11.5.2  identifies these  assumed  monitoring
frequencies.  The following sections describe the
facility data set  requirements  to be used in
estimating variability factors, and the estimation
of facility-specific daily and monthly variability
factors  that were  used in developing the
limitations.  These facility-specific variability
factors are listed in Attachment 10-3.

Facility Data Set Requirements       10.6.5.1
    Estimates of the necessary parameters for the
lognormal portion of the distribution can be
calculated with  as few as two distinct detected
values  in a  data set (which may also include
non-detected measurements).   EPA used the
facility data set for a pollutant if the data set
contained:
  three detected observations with two or more
   distinct values.

Further, the each facility data set for a'pollutant
had to pass the data editing criteria described in
section 10.4.3.
   In statistical terms, each measurement was
assumed to be  independently  and identically
distributed from the other measurements of that
pollutant in the facility data set.

Estimation of Facility-Specific
Daily Variability Factors             10.6.5.2
   The facility-specific daily variability factor is
a function of the expected value, E(U),   and
the  99th  percentile.,  of the modified  delta-
lognormal   distribution  fit   to   the  daily
concentration  values of the pollutant in the
wastewater from the facility.   The  expected
value, E(U),  was estimated using equation 10.
   The 99th percentile of the  modified delta-
lognormal distribution fit to each data set was
estimated by using an iterative approach. First,
D0=0, 80=0, and  Dk+1  =   were defined as
boundary conditions  where D; equaled the r*
smallest detection limit and 8; was the associated
proportion of non-detects at the r* detection limit.
Next, a cumulative distribution function, p,  for
each data subset was computed as a step function
ranging from  0 to 1. The general form, for a
given value c, was:
    four or more observations with two or more
    distinct detected concentration values; or
         Compliance with the monthly average
 limitations will be required in the final rulemaking
 regardless of the number of samples analyzed and
 averaged.
                                            10-21

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Chapter 10 LTAs. VFs, and Limitations and Standards     Development Document for the CV/T Point Source Category
                                              ,   D
                                                                (13)
where <& is the standard normal cumulative distribution function. The following steps were completed
to compute the estimated 99th percentile of each data subset:

Step 1  Using equation 13, k values of p at c=Dm, m=l,...,k were computed and labeled pm.

Step 2  The smallest value of m (m=l,...,k), such that pm > 0.99, was determined and labeled as PJ. If
        no such m existed, steps 3 and 4 were skipped and step 5 was computed instead.

Step 3  Computed p* = PJ - 8j.

Step 4  If p* < 0.99, then P99 = Dj
        else if p* > 0.99, then
P99=
                           exp
ft
                                       \-l
                                             0-99 -
                                                   i=0
                                               (1-6)

        where <&'* is the inverse normal distribution function.

Step 5  If no such m exists such that pm > 0.99 (m=l,...,k), then
                                                            6
                                                                                     (14)
                         P99=exp
                                           ;-i
                                              0.99-6
                                               (1-6)
                                                                (15)
The facility-specific daily variability factor, VF1, was then calculated as:

                                           P99
                                   VF1 =
                                           E(U)
                                                                (16)
Estimation of Facility-Specific Monthly Variability Factors                            10.6.5.3
   EPA estimated the monthly variability factors by fitting a modified delta-lognormal distribution to
the monthly averages. EPA developed these averages using the same numberof measurements as the
assumed monitoring frequency for the pollutant EPA is assuming that some pollutants such as organics
will  be monitored weekly (approximately four times a month) and others will be monitored daily
                                          10-22

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   Chapter 10  LTAs, VFs, and Limitations and Standards
Development Document for the CWTPoint Source Category
   (approximately 20 times a month).9  Section 11.5.2 identifies these assumed monitoring frequencies.

                    ESTIMAHON OF FACILITY-SPECIFIC 4-DAY VARIABILITY FACTORS
       Variability factors  based on 4-day  monthly averages were estimated  for  pollutants with the
   monitoring frequency assumed to be weekly (approximately four times a month).  In order to calculate
   the 4-day variability factors (VF4), the assumption was made that the approximating distribution of U4,
   the sample mean for a random sample of four independent concentrations, was also derived from the
   modified delta-lognormal distribution.10 To obtain the expected value of the 4-day averages, equation
   10 is modified for the mean of the distribution of 4-day averages in equation  17:
                            E(U4) =
                                           (17)
   where  (X4)D denotes the mean of the discrete portion of the distribution of the average of four
   independent concentrations, (i.e., when all observations are non-detected values) and  (X4)c  denotes
   the mean of the continuous lognormal portion (i.e., when all observations are detected).
       First, it was assumed that the probability of detection (8) on each of the four days was independent
   of the measurements on the other three days.  (As explained in section_10.6.5.1, daily measurements were
   also assumed to be independent.) Thus, 84 = 84 and because  E(X^)D = E(XD),  then equation 17
   can be expressed as
                                       6D
                                      -^  + (l-84)exp(A4+0.5o24)
                                           (18)
                           ^^                     A4 usmgequafionlSandbecause
                                                          -  0.562
                                                1=1
                                           (l-o4)
                                     = E(U):


                                           (19)
    The expression for  524 was derived from the following relationship
        9The attachments to this chapter (except Attachment 10-5 which provides the proposed limitations) sometimes
identify two monthly variability factors and monthly average limitations for a single pollutant in an option. These two
sets of variability factors and limitations correspond to monitoring four and twenty times a month.  In developing the
limitations, EPA considered both monitoring frequencies. However, EPA is proposing only the monitoring frequencies
identified in section 11.5.2.

        10This assumption appeared to be reasonable for the pulp and paper industry data that had percentages of non-
detected and detected measurements similar to the data sets for the centralized waste treatment industry. This conclusion
was based on the results of a simulation of 7,000 4-day averages.  A description of this simulation and the results are
provided in the record for the proposed rulemaking.
                                                10-23

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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWTPoint Source Category
                                                                                     (20)
by substftuting the following
                                                         and
                                          (21)
into equation 20. This substitution provides the following

which further simplifies to
                                                                                     (22)

                                                (1 -84)exp(2A4 -^[expCd2,) -1]

                                 46                                                 (23)
                                     -i-

                                     /=!  o
Next, equation 24 results from solving for  [exp(d24) -1 ]  in equation 23.



  exp(d24)-l =
                           	-82(l-84]

                            4                   I  1=1
                                                                                     (24)
Then solving for exp(p.4+0.5624)  using equation 18 and substituting  E(U4)  = E(U)  results in






                                                                        >J            (25)
            exp(A4+0.5o24)  =
 k




1=1
 k


 ,
i=l
                                      (1-84)
                  (1-84)
                                          10-24

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Chanter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWTPoint Source Category
Letting
                             k

                            i=l
simplifies equation 25 to
                                                  (1-64)

Next, solving for O24 in equation 24 and using the substitution in equation 27 provides
                                *  k
                               El
                          , _   1=1 j=i
                   t"V"4/  	
            1
                                                                     f
                                                               M       (1-64);
                                                 -84)2
                                                                                         (26)
                                                                                          (27)
                                                                      (28)
Finally, using the relationship  Var(U4) =  Var(U)/4  and rearranging terms:
  6-24=log

4r|2
                                          4r)2
                                                                                          (29)
    Thus, estimates of  p.4  and  624  in equations 19 and 29, respectively, were derived by using
 estimates of 8j,...,8k (sample proportion of non-detects at observed sample-specific detection limits
 D^.-.jDk),, E(U) from equation 10, and  Var(U) from equation 12.
    In finding the estimated 95th percentile of the average of four observations, four non-detects, not all
 at the same sample-specific detection limit, can generate an average that is not necessarily equal to Dl5
 D^..., or Dk.  Consequently, more than k discrete points exist in the distribution of the 4-day averages.
 For example, the average of four non-detects at k=2 detection limits, are at the following discrete points
 with the associated probabilities:
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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWTPoint Source Category
D*
                                                           8*,.
1
2
3
4
5
A
(3D1+D2)/4
. (2Di+2DJ/4
(D1+3D2)/4
A
V
48/8,
68/S,,2
461823
8,4
    When all four observations are non-detected values, and when k distinct non-detected values exist,
the multinomial distribution can be used to determine associated probabilities. That is,
                       Pr
k
y^ U.D.
TJ j=l
I 4 4 J
4!
Ui!u2!-1
k
nsu/
giS '
                                                                                        (30)
where U; is the number of non-detected measurements in the data set with the D( detection limit.  The
number of possible discrete points, k*, for k=l,2,3,4, and 5 are as follows:
        k  kl
        1  1
        2  5
        3  15
        4  35
        5  70

    To find the estimated 95th percentile of the distribution of the average of four observations, the same
basic steps (described in section 10.6.5.2) as for the 99th percentile of the distribution of daily
observations, were used with the following changes:

Step 1  Change P^ to P9S, and 0.99 to 0.95.
Step 2  Change Dm to Dm*, the weighted averages of the sample-specific detection limits.
StepS  Change 6; to 6;*.
Step 4  Change k to k*, the number of possible discrete points based on k detection limits.
StepS  Change the estimates of 8,  & and  *  to estimates of 84, fl4,  and  624,  respectively.

Then, using J5(I74)  =  E(U),  the estimate of the facility-specific 4-day variability factor, VF4, was
calculated as:
                                     VF4 =
       P95
       to
(3D
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Chanter 10 LTAs VFs and Limitations and Standards
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          AUTOCORRELATION IN THE
            DAILY MEASUREMENTS
    Before estimating the facility-specific 20-day
variability  factors,  EPA  considered whether
autocorrelation was likely to be present in the
effluent data. When data are said to be positively
autocorrelated, it means that measurements taken
at consecutive time  periods are related.   For
example, positive autocorrelation would  be
present  in  the   data  if  the final  effluent
concentration of oil  and  grease was relatively
high one day and was likely to remain at similar
high values the next and possibly succeeding
days.   Because  EPA  is  assuming that some
pollutants (BOD5, TSS, oil and grease, metals,
and total cyanide) will be monitored daily, EPA
based the  20-day  variability  factors on  the
distribution   of   the   averages   of   20
measurements.11  If concentrations measured on
consecutive days were positively correlated, then
the autocorrelation would have had an effect on
the estimate  of the variance of the monthly
average and thus on the 20-day variability factor.
(The estimate of the long-term average and the
daily variability factor would not be affected by
autocorrelation.)
    EPA believes that autocorrelation  in  any
significant  amount is unlikely to be present in
daily  measurements in wastewater from  this
industry.   Thus,  EPA has not  incorporated
autocorrelation into its estimates of the 20-day
variability   factors.     In  many  industries,
measurements in final  effluent are likely to be
similar from one day to the next because of the
consistency from day-to-day in the production
processes and in final effluent discharges due to
         1 ! In other rulemakings, EPA has used the
 averages of 30 measurements when the assumed
 monitoring frequency was daily measurements
 throughout the month. However, many centralized
 waste treatment facilities are closed on weekends.
 Therefore, EPA assumed that 20 daily
 measurements rather than 30 would be collected
 each month.
  the hydraulic retention time of wastewater in
  basins, holding ponds, and other components of
  wastewater treatment systems. Unlike these other
  industries, where the industrial processes are
  expected to produce the same type of wastewater
  from one day to the next, the wastewater from
  centralized waste treatment industry is generated
  by treating wastes from  different  sources  and
  industrial processes.   The wastes treated  on a
  given day will often be different than the waste
  treated on the following day.  Because of this,
  autocorrelation would be expected to be absent
  from  measurements  of wastewater from the
  centralized waste treatment industry.
      EPA believes that a statistical evaluation of
  appropriate data sets  would likely support its
  assertion that autocorrelation is absent from daily
  measurements in the centralized waste treatment
  industry. However, the monitoring data that EPA
  has received thus far are insufficient for the
  purpose of evaluating the autocorrelation.12 To
  determine autocorrelation  in  the  data,  many
  measurements  for each  pollutant would  be
  required with values for every single day over an
  extended period of time.   Such data were not
  available  to  EPA.   In  the preamble to the
  proposal, EPA requests additional data that can
  be used to evaluate autocorrelation in the data.
           12In the 1995 statistical support document,
   EPA included a discussion of the autocorrelation in
   the effluent data from facility 602. The document
   states that the facility provided 'sufficient amounts of
   pollutant measurements.' That statement is not
   correct.  To have sufficient amounts of data, the data
   set would need to include many more measurements
   for every single day. In addition, in the 1995
   document, the conclusions about statistical
   significance were flawed due to an error in the
   software.
                                             10-27

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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for ^CW^PointSourceCategory_

                ESTIMATION OF FACILITY-SPECIFIC 20-DAY VARIABILITY FACTORS
    Based upon the discussion on autocorrelation in the previous section, it was assumed that consecutive
daily measurements were independent of one another, and therefore
                 E(U20) =  E(U)     and      Vai(U20) =

                                                                     (32)
where  E(U)  and  Var(L/) were calculated as shown in section 10.6.5.3.2 (see equations 10 and 12).
Finally, since tJ2ols approximately normally distributed by the Central Limit Theorem, the estimate of
the 95th percentile of a 20-day mean and the corresponding facility-specific 20-day variability factor
(VF20) were approximated by
                     P9520 = E(U20)  +  [<

By using the substitutions in equation 32, equation 33 simplified to

                     P9520 = E(U)  +  [*'
                                                                                        (33)
                                                      Vai(U)
                                                      20
                                                                     (34)
Then, the estimate of the facility-specific 20-day variability factor, VF20, was calculated using:
VF20  =
                             E(U)
                                        because   E(U20) =  E(U)
                                                                                        (35)
where $"'(0.95) is the 95th percentile of the inverse normal distribution.
Evaluation of Facility-Specific
Variability Factors                   10.6.5.4
    Estimates of the necessary parameters for the
lognormal  portion of the  distribution can  be
calculated with as few as two distinct measured
values in a data set (which may also include
non-detected measurements);  however,  these
estimates are likely to be unstable unless a more
sizable number of measured values is available.
As stated in section  10.6.5.1, EPA  used the
modified delta-lognormal distribution to develop
facility-specific variability  factors for data sets
that had a four or more observations with two or
more distinct measured concentration values or
three measured values with two or more distinct
values.   Some  variance  estimates produced
unexpected results such as a daily variability
                             factor with a value less man 1.0 which would
                             result in a limitation with a value less than the
                             long-term average.  This was an indication that
                             the estimate of  "  (the log standard deviation)
                             was unstable. To identify situations producing
                             unexpected results, EPA carefully reviewed all of
                             the  variability  factors and compared daily to
                             monthly variability factors.  EPA determined that
                             when the facility's  daily variability factor was
                             less than 1.0, the daily and monthly variability
                             factors for that pollutant should be excluded from
                             further consideration.   Similarly,  when  the
                             facility's  monthly  variability  factors   for  a
                             pollutant were greater than the daily variability
                             factor,  EPA excluded the daily and monthly
                             variability factors from further consideration. If
                             the daily variability factor was greater than 10.5,
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Chanter 10 LTAs VFs and Limitations and Standards
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EPA reviewed the data in detail to determine if
one or more values were the result of process
upsets or data errors.
Estimation of Pollutant-Specific
Variability Factors
10.6.6
    After the facility-specific variability factors
were estimated for a pollutant as described in
section 10.6.5, the pollutant-specific variability
factor was calculated.   The pollutant-specific
daily  variability  factor  was the mean of the
facility-specific daily variability factors for that
pollutant  in  the  subcategory  and  option.
Likewise,   the    pollutant-specific   monthly
variability factor was the mean of the facility-
specific  monthly variability  factors  for that
pollutant in the subcategory and option.   For
example, for option 4 of the Metals subcategory,
the cadmium daily variability factor was  the mean
of the cadmium daily variability factors  from
facilities 4798 and facility 700.  A more detailed
example of estimating pollutant-specific monthly
variability factors is provided in section 10.7.2.
Attachment 10-213 lists  the pollutant-specific
variability factors.
 Estimation of Group-Level
 Variability Factors
10.6.7
    After the pollutant-specific variability factors
 were estimated as described in section 10.6.6, the
         13Attachments 10-2 through 10-7 include
 some pollutants for which EPA has not proposed
 limitations.  In some cases, the data from these
 additional pollutants were used to develop the group
 variability factors (see section 10.6.7). For other
 pollutants, at some point in developing the proposal,
 EPA considered proposing limitations; however,
 EPA later excluded them from the proposed
 limitations (see chapter 7 for further explanation).
 These attachments reflect the calculations prior to
 transfers of limitations as described in section 10.8.
 In addition,  a revision to the TSS limitations for oils
 subcategory option 9 is not incorporated into these
 attachments.
group-level variability factors were calculated.
Each group contained pollutants that had similar
chemical  structure (e.g.,  the  metals  group
consisted  of metal pollutants).   For some
pollutants such as BOD5, EPA determined that
there were no other pollutants that  could be
considered chemically similar for the purpose of
determining variability factors; therefore, these
pollutants were not assigned to a group.14 For the
pollutants (such as BOD5) that were not assigned
to  a group,  the pollutant-specific  variability
factors were used in  developing limitations.
However, in most cases, group-level variability
factors were used in developing limitations. (The
derivation  of limitations is described in section
10.7.1.) Appendix A identifies the groups and
the pollutants assigned to them.
    The group-level daily variability factor was
the  median  of  the pollutant-specific  daily
variability  factors for the pollutants within the
group.  Similarly for  the monthly variability
factors, the group-level monthly variability factor
was the median of the pollutant-specific monthly
variability factors for the pollutants within the
group.  Attachment 10-4 provides the group-level
daily and monthly variability factors that could be
calculated  for the proposed options.
           Transfers of Variability Factors
                                        10.6.8
              In some cases, EPA transferred variability
           factors for pollutants when its associated group-
           level variability factors could not be estimated.
           In these cases, the facility  data  sets for that
           pollutant and the other pollutants in the group
           were excluded (section 10.4.1), did not meet the
           data editing criteria (section 10.4.3), did not meet
           the    facility     data    set     requirements
           (section   10.6.5.1),  or  the  facility-specific
           variability   factors  were  excluded   (section
           10.6.5.4).

                   14In some data listings, such cases are
           sometimes identified with a group; however, the
           group name and the pollutant name are the same.
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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category

    EPA transferred variability factors for these
cases using other group-level variability factors in
the option for the subcategory.15  In developing
these  transferred  variability  factors,  EPA
calculated the transferred variability factors as the
median (i.e., mid-point value) of the group-level
variability factors from all groups except the
metals, semi-metals, and non-metals groups. For
example, for hypothetical subcategory X, suppose
its option 2 had five groups: TSS, oil and grease,
n-paraffins, aromatics, and metals.  In addition,
suppose that group-level variability factors had
been calculated for all groups except n-paraffins,
then the transferred daily variability factor for the
pollutants in the n-paraffins group would be the
median of the group-level daily variability factors
from the TSS, oil and grease,  and  aromatics
group.   (The daily variability factor from the
metals   group  would  be  excluded.)    The
transferred monthly (4-day) variability factor
would be the 4-day variability factor from the
aromatics group, because 4-day variability factors
were not calculated for TSS and  oil and grease
(because the monitoring frequency was assumed
to be 20 times per month.)
        ISIn the 1995 proposal, EPA proposed
using fraction-level variability factors when group-
level variability factors were unavailable. EPA has
determined that more appropriate transfers are
available.
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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWTPoint Source Category
Table 10-6  Cases where Variability Factors were Transferred
Subcategory
Metals
Oils



Organics



 Option Pollutant Transferred Variability Factors *
Daily Monthly
4 Hexavalent chromium 3.348 1.235
8/8v alpha-terpineol 2.907 1.467
carbazole
9/9v alpha-terpineol 3.434 1.682
carbazole
3/4 acetophenone 4.330 1.992
aniline
benzoic acid

/fonitoring Frequency
(days per month)
20
4

4

4



 LIMITATIONS
10.7
    The proposed limitations and standards are
 the result of multiplying the long-term averages
 by the appropriate variability factors.  The same
 basic procedures apply to the calculation of all
 limitations and standards for  this  industry,
 regardless of whether the technology is BPT,
 BCT, BAT, NSPS, PSES or PSNS.
    The proposed limitations for pollutants for
 each option are provided as 'daily maximums'
 and   'maximums   for  monthly   averages.'
 Definitions provided in 40 CFR 122.2 state that
 the  daily  maximum limitation is the "highest
 allowable  'daily discharge'" and the maximum
 for monthly average limitation (also referred to as
 the "monthly average limitation") is the "highest
 allowable  average of 'daily discharges' over a
 calendar month, calculated as the sum of all 'daily
 discharges' measured during a calendar month
 divided by the number of 'daily  discharges'
 measured during that month."  Daily discharges
 are  defined to be the '"discharge of a pollutant'
 measured during a calendar day or any 24-hour
 period that reasonably represents the calendar day
 for purposes of samplings.".
     EPA calculates the limitations based upon
 percentiles chosen with the intention, on one
 hand,  to  be   high enough to  accommodate
 reasonably anticipated variability within control
 of the facility and,  on the other hand, to be low
enough  to  reflect  a  level  of performance
consistent with the Clean Water Act requirement
that these effluent limitations be based on the
"best"  technologies.   The  daily  maximum
limitation is an estimate of the 99th percentile of
the distribution of the daily measurements. The
monthly average limitation is an estimate of the
95th percentile of the distribution of the monthly
averages of the daily measurements.  EPA used
the 95th percentile rather than the 99th percentile
for monthly average limitations  because the
variability of monthly averages is less than the
variability of individual daily measurements. The
percentiles for both  types  of limitations are
estimated using  the  products  of  long-term
averages and variability factors.
    In the first of two steps in estimating both
types of limitations, EPA determines  an average
performance  level  (the "long-term average"
discussed in section  10.7) that a facility with
well-designed and operated model technologies
(which reflect the appropriate level of control) is
capable of achieving. This long-term average is
calculated from the data from the facilities using
the model technologies for  the  option.  EPA
expects that all facilities subject to the limitations
will design and operate their treatment systems to
achieve the long-term average performance level
on a consistent basis because facilities with well-
designed and operated model technologies have
demonstrated that this can be done.
                                             10-31

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Chapter 10 LTAs, VFs. and Limitations and Standards     Development Document for the CWT Point Source Category
    In the second step of developing a limitation,
EPA determines an allowance for the variation in
pollutant concentrations when processed through
extensive and well designed treatment systems.
This allowance  for variance  incorporates all
components  of variability including shipping,
sampling, storage, and analytical variability. This
allowance  is incorporated into the limitations
through the  use  of  the  variability  factors
(discussed in section 10.6) which are calculated
from the data from the facilities using the model
technologies. If a facility operates its treatment
system to meet the relevant long-term average,
EPA expects the facility to be able to meet the
limitations. Variability factors assure that normal
fluctuations in a facility's treatment are accounted
for in the limitations.  By accounting for these
reasonable  excursions above  the  long-term
average, EPA's use of variability factors results
in limitations that are  generally well above the
actual long-term averages.
    After completing the data screening tests to
select the appropriate data sets, EPA calculated
the long-term averages for the limitations. For
some pollutants of concern, none of the facility
data sets with the technology basis for the option
met the  data  screening criteria;  thus,  these
pollutants  of concern are not proposed to be
regulated for that option. These pollutants are
listed in Chapter 7, Table 7-1. Further, because
of these criteria, the options within a subcategory
may have  slightly different lists of pollutants
proposed to be regulated.  These data were used
to develop long-term  averages and variability
factors, by pollutant and technology option, for
each subcategory.  The limitations  prior  to
transfers are listed in Attachment 10-7.
Steps Used to Derive Limitations
10.7.1
    This section summarizes the steps used to
derive the limitations.  These steps were used
separately for the daily maximum limitation and
          the monthly average limitation. Depending on the
          assumed monitoring frequency of the pollutant,
          either the 4-day variability factor or the 20-day
          variability  factor  was  used  in deriving the
          monthly average limitation.

          Step 1  EPA calculated the facility-specific long-
                  term averages and variability factors for
                  all  facilities  that   had   the   model
                  technology  for   the  option   in  the
                  subcategory. EPA calculated variability
                  when  the  facility had  four or more
                  observations with two or more  distinct
                  detected values or three detected values
                  with two or distinct values.  In addition,
                  the facility data set for the pollutant had
                  to meet the data screening criteria.

          Step 2  For each option in the subcategory, EPA
                  calculated the median of the  facility-
                  specific long-term  averages and the
                  mean of the facility-specific variability
                  factors from the facilities with the model
                  technology to provide  the pollutant-
                  specific   long-term    average   and
                  variability factors for each pollutant.

          Step 3  EPA   calculated,  the   group-level
                  variability factor using the median of the
                  pollutant-specific variability factors for
                  the pollutants within each group.
Step 4  In  most cases, EPA calculated the
        limitation for  a pollutant  using the
        product of the  pollutant-specific  long-
        term  average   and  the   group-level
        variability factor.   If the  group-level
        variability factor could not be estimated
        (because none of the pollutant-specific
        variability factors in the group could be
        estimated),  then   EPA   transferred
        variability factors (see section  10.6.8)
                                            10-32

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Chapter 10 LTAs, VFs, and Limitations and Standards
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        and the used pollutant-specific long-term
        average in calculating the limitation.  If
        the pollutant was not  assigned to  a
        group,   then  EPA  calculated  the
        limitation  using  the product  of the
        pollutant-specific long-term average and
        the pollutant-specific variability factors.
        (See exceptions to step  4 described  in
        section 10.8.2.)
        Example
                                  10.7.2
            This example illustrates the derivation of limitations using the steps described
        above. In this example, four pollutants, A, B, C, and D all belong to hypothetical
        group X.  The facility-specific long-term  averages and variability factors for the
        pollutants are shown in Attachments 10-1 and 10-3, respectively (step 1).  Table 10-7
        shows the pollutant-specific long-term averages and variability factors calculated as
        described in step 2. Then, using the procedure in step 3, the group-level variability
        factor (see attachment 10-4 in Appendix E) is the median of the variability factors for
        pollutants A, B, and C (D is excluded because facility-specific variability factors could
        not be calculated for any of the facilities that provided  data on pollutant D).
           The group-level daily variability factor for group X is 2.2 which is the median of
            2.2 (pollutant A), 2.4 (pollutant B), and 2.1 (pollutant C).
           The group-level 4-day variability factor for group X is 1.4 which is the median of
            1.5 (pollutant A), 1.4 (pollutant B), and 1.2 (pollutant C).

            In this example, the limitations are calculated using the pollutant-specific long-term
        averages and the group-level variability factors in the following way:
            Daily maximum limitation
                 = pollutant-specific long-term average
                    * group-level daily variability factor

                For each pollutant, the daily maximum limitation is:
                    Pollutant A: 15 mg/1 * 2.2 = 33 mg/1
                    Pollutant B: 14 mg/1 * 2.2 = 31 mg/1
                    Pollutant C: 22 mg/1 * 2.2 = 48 mg/1
                    Pollutant D: 20 mg/1 * 2.2 = 44 mg/1

            Monthly average limitation
                 = pollutant-specific long-term average
                    * group-level 4-day variability factor
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 Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category


                For each pollutant, the monthly average limitation is:
                   Pollutant A: 15 mg/1 * 1.4 = 21 mg/1
                   Pollutant B: 14 mg/1 * 1.4 = 20 mg/1
                   Pollutant C: 22 mg/1 * 1.4 = 31 mg/1
                   Pollutant D: 20 mg/1 * 1.4 = 28 mg/1
        Table 10-7. Long-Term Averages and Variability Factors Corresponding to Example for Hypothetical
        Group X
Pollutant
A





B




C



D



Facility
Al
A2
A3
A4
AS
Pollutant-specific
Bl
B2
B3
B4
Pollutant-specific
Cl
C2
C3
Pollutant-specific
Dl
D2
D3
Pollutant-specific
Long-term
Average (mg/1)
10
12
15
20
26
15
(median)
17
16
10
12
14
(median)
22
24
12
22
(median)
20
22
14
20
(median)
Daily Variability
Factor
2.1
2.3
. 2.0
1.8
2.8
2.2
(mean)
2.7
2.2
2.3
*
2.4
(mean)
1.9
*
2.3
2.1
(mean)
*
*
*
*
4-day Variability
Factor
1.4
1.5
1.4
1.3
1.9
1.5
(mean)
1.7
1.2
1.3
*
1.4
(mean)
1.1
*
1.3
1.2
(mean)
*
*
*
*
        * could not be estimated (i.e., the data set did not contain four or more observations with two
        or more distinct detected values or three detected values with two or more distinct values.)
TRANSFERS OF LIMITATIONS
10.8
    In some  cases, EPA was either unable to
calculate a limitation using the available data for
an  option or  determined  that the  treatment
provided by facilities employing the option did
not represent BPT/BCT/BAT treatment. In these
cases, EPA transferred limitations from another
option or from another industrial category. The
following sections describe each case where the
limitations were transferred.

Transfer of Oil and Grease
Limitation for Metals Subcategory
Option 4 to Option 3                   10.8.1

   Because of the relatively low levels of oil and
grease in the influent of the facilities with the
model technology for Metals subcategory option
3, application of the LTA test to the influent data
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Chapter 10 LTAs, VFs, and Limitations and Standards
       Development Document for the CWT Point Source Category
(described  in  section  10.4.3.1)  resulted in
excluding the effluent data.  EPA believes that
this parameter should be regulated for all options
in this subcategory. EPA based the oil and grease
limitations upon data from facilities with the
option 4 model technology.  In effect, EPA has
transferred the limitations from option 4 to option
3 for oil and grease.  EPA has concluded that
transfer of this data is appropriate given that the
technology basis for metals option 3 includes
additional treatment steps than the technology
basis for metals option 4.  As  such, EPA has
every reason to believe that facilities employing
the  option 3  technology  could  achieve the
limitations based on the option 4 technology.
Transfers of Limitations from Other
Rulemakings to CWT Industry
10.8.2
    In some cases, the model technology did not
optimally remove BOD5 and TSS for an option in
a  subcategory.  EPA believes  this occurred
because the  limitations are largely  based on
indirect discharging facilities that are not required
to control or optimize their treatment systems for
the removal of conventional parameters.  Thus,
EPA transferred the BPT/BCT limitations (for
direct dischargers data) from effluent guidelines
from other industries with similar wastewaters
and treatment technologies.  In one case, EPA
proposes  the transfer  of the  BPT/BCT TSS
limitations from the Metal Finishing rulemaking
to the Metals subcategory BPT/BCT limitations
(option 4). In the other case, EPA proposes the
transfer  of  the BPT/BCT BOD5  and TSS
limitations from the Organic Chemical, Plastics,
and Synthetic Fibers (OCPSF) rulemaking to the
Organics  subcategory  BPT/BCT limitations
(option 3/4).    EPA used different procedures
from the one discussed in section  10.7.1 to
develop the proposed limitations for BOD5 and
TSS for the  organics subcategory and TSS for
option 4 in the  Metals  subcategory.    The
following  sections  describe  these  different
procedures.

Transfer ofBOD5 and TSS
for the Organics Subcategory         10.8.2.1
   EPA based the transferred limitations of
BOD5 and TSS for the organics subcategory on
biological treatment performance data used to
develop the limitations  for  the thermosetting
resins subcategory in the Organic Chemicals,
Plastics, and Synthetic Fibers (OCPSF) industry
rulemaking.  As described in the preamble to the
proposed rulemaking, EPA determined that the
transfer of  the data was warrarrted  because
facilities in the organics subcategory treat wastes
similar to wastes treated by OCPSF facilities.
   For   the  organics  subcategory  of  the
centralized  waste  treatment  industry,  the
proposed daily maximum limitations for BOD5
and  TSS  were transferred  directly from the
OCPSF rulemaking.   No modifications  were
required before transferring these daily maximum
limitations.
   Some modifications of the OCPSF monthly
average limitations  were required before the
values could be transferred  to the centralized
waste treatment industry. The OCPSF limitations
for BODS and TSS were based on assumptions of
a  monitoring  frequency  of  30 days  and the
presence of autocorrelation in the measurements.
In the proposed rulemaking for the centralized
waste treatment industry, the monthly limitations
for BODS and TSS were based on an assumed
monitoring  frequency  of 20  days  and  no
autocorrelation (see  section  10.6.5.3.2  for a
discussion of the absence of autocorrelation in the
centralized waste treatment data). Therefore, the
following conversion steps were necessary to
convert the OCPSF 30-day variability factors to
20-day variability factors.
   The following formula  was  used in the
OCPSF  rulemaking to calculate  the  30-day
variability factors.  This formula incorporates
autocorrelation  between  measurements   on
adjacent days (i.e., the lag-1 autocorrelation).
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Chanter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
                        VF3Q  = 1+1.645.
                               (eq2-l)/30(p,o)
                                     30
                                                                                      (36)
where the function f30(p,tf) represents the additional variability attributable to autocorrelation, and is
given by
                                      9      29
                   f30(p,o)  = 1+	(30-)(epo -1)                      (37)
                                  30(e2- l)*=i

The above two formulas can be generalized to estimate n-day variability factors. These formulas are:
               VFn = 1+1.645.
                                  (e0-l)fn(p,0)
                                                   m.2
(38)
                                         n
where

4(p>) =
                                                                                      (39)
For the proposed limitations, the autocorrelation, p, has been assumed to be absent; thus, the value of
p is set equal to zero. Therefore, the value of fn(0,o) is equal to 1, and equation 38 becomes:
         VF  =  1+1.645
                                          (6
                                             n
(40)
Because all of the values were detected (i.e., there were no non-detected measurements) in the OCPSF
data base for BOD5 and TSS, the delta-lognormal distribution of these data is the same as the lognormal
distribution (i.e., the delta portion does not apply because it is used to model non-detect measurements).
Therefore, an estimate of o2 was obtained from the  daily variability factor from the lognormal
distribution by using the following equation:
                                Wl =  e
                                         c4>-'(0.99)- 
                                                                         (41)
where $'1(0.99) is the 99th percentile of the inverse normal distribution. (The value of 4>'I(0.99) is
2.326.)  By solving this equation using maximum likelihood estimation for a and substituting it into
                                           10-36

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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
equation 40, an estimate of VFn may be obtained. Finally, the n-day limitation is given by:
                                                                                      (42)
Limit -  m
The expected value, E(X) can be estimated by solving for E(X) in the following equation for the daily
maximum limitation (which is the same for both the OCPSF, and centralized waste treatment industries):
                                            E(X)
                                                                                      (43)
to obtain
E(X) =4
                                           Limit
                                                                                      (44)
Then, equation 40 (using the estimate of a2 from equation 41) and equation 44 can be substituted into
equation 42 to obtain:
                      "**  -
                                 Limit
1+1.645,
                   e -1
                     n
                                            (45)
    In particular, for the monthly average limitation based  on assuming daily monitoring (i.e.,
approximately 20 times a month), the limitation is
                      Limit20 =
                                  VK
1 + 1.645,
                     20
                                                    (46)
    Table 10-8 provides the values of the BOD5 and TSS limitations and other parameters for the
thermosetting resins subcategory from the  OCPSF  industry and the organics subcategory in the
centralized waste treatment industry.
                                           10-37

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Chapter 10 LTAs, VFs, and Limitations and Standards     Development Document for the CWT Point Source Category
Table 10-8  BOD, and TSS Parameters for Organics Subcategory
Parameter
a
Long-Term Average (mg/1)
VF,
VF30
VF20
Daily Maximum Limitation (mg/1)
Monthly Average Limitation (mg/1)
OCPSF: Thermosetting Resins
Subcategory
BOD,
0.6971
41
3.97
1.58
n/a
163
61
TSS
0.8174
45
4.79
1.45
n/a
216
67
Centralized Waste Treatment:
Organics Subcategory
BOD,
0.
41
3.
n/a
1.
163
53.
6971

97

29

0
TSS
0.8174
45
4.79
n/a
1.36
216
61.3
Transfer of TSS for Option 4 of
the Metals Subcategory              10.8.2.2
   For  TSS  for  option  4   of the  metals
Subcategory,  EPA transferred  the proposed
limitations directly from  the  Metal Finishing
rulemaking (see Table 10-9).   EPA based the
Metal Finishing monthly average limitation for
TSS upon an assumed monitoring frequency of
ten  days per month  and the  absence  of
autocorrelation in the measurements.  EPA has
also  assumed an absence of autocorrelation in
TSS  for the centralized waste treatment industry.
However, EPA assumed a monitoring frequency
of 20 measurements  a month for TSS  for the
centralized waste treatment industry, rather than
the  ten measurements assumed in the metal
finishing rulemaking. EPA will consider whether
it should adjust the monthly average limitation
from the metal finishing  rulemaking for the
increase   in   monitoring  frequency.     This
adjustment would result  in a monthly average
limitation with a  slightly lower  value  than
presented in the proposal.  (The monitoring
frequency does not effect the value of long-term
averages and daily maximum limitations.)
Table 10-9  TSS Parameters: for Metal Finishing
Metal Finishing TSS Values
TSS (mg/L)
Long-Term Average (mg/1)            16.8
Daily variability factor                 3.59
Monthly Variability Factor              1.85
Assumed monitoring frequency       10/month
Daily Maximum Limitation (mg/1)       60.0
Monthly Average Limitation (mg/1)      31.0
EFFECT OF GROUP AND
POLLUTANT VARIABILITY
FACTORS ON LIMITATIONS
      10.9
    In the preamble to the proposed rulemaking,
EPA solicited comment on using pollutant (or
'pollutant-specific') variability factors rather than
group  (or  'group-level') variability  factors in
calculating  the  limitations.    For  the  1995
proposed limitations and in today's proposed
limitations, EPA generally used the product of the
group  variability factor and the pollutant long-
term  average  in  calculating  each  pollutant
limitation.    For  today's re-proposal,  EPA
alternatively considered  using  the  pollutant
variability factor instead of the group variability
factor.  (Group and pollutant variability factors
are listed in Attachment 10-6.)  For pollutants
where  pollutant variability factors could not be
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Chapter 10 LTAs, VFs. and Limitations and Standards     Development Document for the CWT Point Source Category


calculated (due to data constraints), EPA .would
continue to use the group variability factor. >
    Using the group variability factor eliminates
the extremely low and high pollutant variability
factors.  Thus, limitations for some pollutants
would be  more  stringent and  for others less
stringent. Attachment 10-7 provides a listing of
the limitations calculated using both  methods.
    EPA  believes  that the  variability of  the
pollutants with similar chemical structures would
behave similarly in treatment systems; thus, EPA
believes that using a single group variability
factor may be appropriate for those pollutants. In
the preamble to the proposed rulemaking, EPA
solicited comment on whether the pollutant or
group variability factors  or  some combination
should be used in calculating the limitations to
accurately reflect the variability of the pollutants
discharged  by the centralized waste treatment
industry.
 ATTACHMENTS
10.10
    Attachments 10.1 through 10.7 to this chapter
 are located in Appendix E at the end of the
 document
                                             10-39

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Chapter 10 LTAs, VFs, and Limitations and Standards	Development Document for the CWT Point Source Category
REFERENCES
10.11
Aitchison, J. and J.A.C. Brown. 1963. The Lognormal Distribution. Cambridge University Press, New
    York.

Barakat, R. 1976.  "Sums of Independent Lognormally Distributed Random Variables."  Journal
    Optical Society of America, 66: 211-216.

Cohen, A.  Clifford. 1976.  Progressively Censored Sampling in the Three Parameter Log-Normal
    Distribution.  Technometrics, 18:99-103.

Crow, E.L. and Shimizu. 1988.  Lognormal Distributions: Theory and Applications. Marcel Dekker,
    Inc., New York.

Engineering and Analysis Division, EPA.  "Comment Response Document (Volume VI)." Record
    Section 30.11, DCN 14497 in the Pulp and Paper Phase I Rulemaking Docket.

Engineering and Analysis Division, EPA.  "Statistical Support Document for the Pulp and Paper
    Industry: Subpart B." November 1997, Record Section 22.5, DCN 14496 in the Pulp and Paper
    Phase I Rulemaking Docket.

Fuller, W.A. 1976. Introduction to Statistical Time Series. John Wiley & Sons;, New York.

Kahn, HD., and M.B. Rubin.  1989.  "Use of Statistical Methods in Industrial Water Pollution Control
    Regulations in the United States." Environmental Monitoring and Assessment. Vol. 12:129-148.

Owen, WJ. and T.A. DeRouen. 1980. Estimation of the Mean for Lognormal Data Containing Zeroes
    and  Left-Censored Values, with Applications to the Measurement of Worker Exposure to Air
    Contaminants. Biometrics, 36:707-719.

U.S. Environmental Protection Agency, Effluent Guidelines Division.  1983. Development Document
    for Effluent Limitations Guidelines and Standards for the Metal Finishing Point Source Category:
    Final. EPA 440/1-83/091. Pages A-l to A-7, A-l 1, A-12, and VII-260 to VII-262.

U.S. Environmental Protection Agency, Industrial Technology Division.  1987. Development Document
    for Effluent Limitations Guidelines and Standards for the Organic Chemicals. Plastics, and Synthetic
    Fibers Point Source Category. Volume I, Volume II. EPA 440/1-87/009.

U.S. Environmental Protection Agency, Office of Water. 1993.  Statistical Support Document for
    Proposed Effluent Limitations Guidelines and Standards for the Pulp. Paper, and Paperboard Point
    Source Category. EPA-821-R-93-023.

U.S. Environmental Protection Agency, Office of Water. 1995.  Statistical Support Document for
    Proposed Effluent Limitations  Guidelines and Standards for the Centralized Waste Treatment
    Industry. EPA 821-R-95-005.
                                         10-40

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                                                                              Chapter
                                                                                  11
                 COST  OF TREATMENT TECHNOLOGIES
   In this chapter,  EPA presents  the costs
   estimated for compliance with the proposed
CWT  effluent  limitations   guidelines   and
standards.   Section  11.1 provides a general.
description of how  the individual  treatment
technology and regulatory option costs were
developed.  In sections 11.2 through 11.4, EPA
describes the development of costs for each of the
wastewater and sludge treatment technologies.
    In  section 11.5,  EPA presents additional
compliance costs to be incurred by facilities,
which  are not technology  specific.   These
additional items are retrofit costs, monitoring
costs, RCRA permit modification costs, and land
costs.
    In   Section  11.6,  EPA  presents  some
examples of capital and O&M cost calculations
for CWT  facilities using this methodology.
Finally,   Section   11.7   summarizes,   by
subcategory, the total capital expenditures  and
annual  O&M  costs  for  implementing  the
proposed regulation.  Appendix D contains, by
subcategory,'the facility-specific capital, O&M,
land, RCRA, and monitoring cost estimates for
each facility to comply with the  proposed
limitations and standards.
COSTS DEVELOPMENT
Technology Costs
 11.1
11.1.1
    EPA  obtained  cost  information for the
technologies selected from the following sources:

   the data base developed from the 1991 Waste
    Treatment  Industry (WTI)  Questionnaire
    responses (This contained some process cost
    information,  and  was  used  wherever
    possible.),
   technical information  developed  for EPA
    rulemaking efforts such as the guidelines and
    standards for:  the  Organic  Chemicals,
    Plastics, and  Synthetic Fibers (OCPSF)
    category, Metal Products and  Machinery
    (MP&M) category, and Industrial Laundries
    industries category,
   engineering literature,
   the CWT sampling/model facilities, and
   vendors' quotations (used extensively  in
  .  estimating   the  cost  of  the  various
    technologies).

    The total costs developed by EPA include the
capital costs of investment, annual O&M costs,
land requirement costs, sludge disposal costs,
monitoring costs,  RCRA  permit modification
costs, and retrofit costs.   Because  1989 is the
base year for the WTI Questionnaire,  EPA scaled
all of the costs either up or down to 1989 dollars
using the Engineering  News Record  (ENR)
Construction Cost Index.
    EPA  based  the  capital costs for  the
technologies primarily on vendors' quotations.
The standard factors used to estimate the capital
costs are listed in Table 11-1. Equipment costs
typically include the cost of the treatment unit and
some ancillary equipment associated with that
technology. Other investment costs in addition to
the   equipment    cost    include    piping,
instrumentation and controls, pumps, installation,
engineering, delivery, and contingency.
    EPA estimated certain design parameters  for
costing purposes. One such parameter is the flow
rate used  to  size many  of the  treatment
technologies. EPA used the total daily flow in all
cases, unless specifically stated. The total daily
flow represents the annual flow divided by 260,
                                          .11-1

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Chapter 11 Cost of Treatment Technologies    Development Document for the CWT Point Source Categor
the standard number of operating days for a CWT
per year.
    EPA derived the annual O&M costs for the
various systems from vendors' information or
from engineering literature, unless otherwise
statedl  The annual O&M costs represent the
costs of maintenance, taxes and insurance, labor,
energy, treatment chemicals (if needed),  and
residuals management (also if needed). Table 11-
2 lists the standard factors EPA used to estimate
the O&M costs.
    Sections 11.2 through  11.4 present cost
equations for capital costs, O&M costs, and land
requirements for each technology and option.  For
          most technologies, EPA also developed capital
          cost upgrade and O&M cost upgrade equations.
          EPA used these equations for facilities which
          already have the treatment technology  forming
          the basis of the option (or some portion of the
          treatment technology) in place. EPA also presents
          the flow rate ranges recommended for use in each
          equation.  EPA is confident the equations are
          representative of costs for such facilities within
          these ranges. Outside these ranges, the equations
          become extrapolations.  EPA does not believe
          these  equations, however,  yield representative
          results below the recommended low flow rate.
    Table 11-1. Standard Capital Cost Algorithm
      Factor
                        Capital Cost
      Equipment Cost
      Installation
      Piping
      Instrumentation and Controls
                  Technology-Specific Cost
              25 to 55 percent of Equipment Cost
              31 to 66 percent of Equipment Cost
               6 to 30 percent of Equipment Cost
      Total Construction Cost
               Equipment + Installation + Piping
                + Instrumentation and Controls
      Engineering
      Contingency
             15 percent of Total Construction Cost
             15 percent of Total Construction Cost
      Total Indirect Cost
                 Engineering + Contingency
      Total Capital Cost
          Total Construction Cost + Total Indirect Cost
Option Costs
11.12
    EPA developed engineering costs for each of
the  individual treatment  technologies which
comprise the CWT regulatory options. These
technology-specific costs are broken down into
capital,  O&M, and land  components.    To
estimate the cost of an entire regulatory option, it
is necessary to sum the costs of the individual
treatment  technologies which  make  up  that
option. In a few instances, an option consists of
only one treatment technology; for those cases,
the  option cost  is  obviously  equal  to  the
technology 'cost.    The  CWT   subcategory
technology options  are shown in Table 11-3.  The
treatment technologies included in each option are
listed,  and the subsections  which contain the
corresponding cost information are indicated.
    EPA  generally calculated the capital and
O&M  costs for each of the individual treatment
technologies using a flow rate range of 1 gallon
per day to five million gallons per day. However,
the flow rate ranges recommended for use in the
equations are in a smaller range and are presented
for each cost equation in Sections 11.2 to 11.4.

Land Requirements and Costs         11.1.2.1
    EPA calculated land requirements  for each
piece of new equipment based on the equipment
dimensions. The land requirements include the
                                             11-2

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWTPoint Source Cat&gor
total  area  needed  for the  equipment plus
peripherals (pumps, controls, access areas, etc.).
Additionally, EPA included a 20-foot perimeter
around each unit. In the cases where adjacent
tanks or pieces of equipment were required, EPA
used a 20-foot perimeter  for  each piece of
equipment, and configured the geometry to give
the minimum area requirements possible.  The
land requirement equations  for each technology
are presented in the tables throughout sections
11.2 to  11.4.   EPA then multiplied the land
requirements by the corresponding land costs (as
detailed in 11.5.4) to obtain facility specific land
cost estimates.

Operation and Maintenance Costs     11.1.2.2
    EPA based O&M costs  on estimated energy
usage, maintenance, labor, taxes and insurance,
and chemical usage cost.   With the principal
exception of chemical usage and labor costs, EPA
calculated  the  O&M  costs  using  a  single
methodology.   This methodology is  relatively
consistent for each treatment technology, unless
specifically noted otherwise.
    EPA's energy usage costs include electricity,
lighting, and controls. EPA estimated electricity
requirements at 0.5 Kwhr per 1,000 gallons of
wastewater treated.  EPA assumed lighting and
controls to cost $1,000  per year and electricity
cost  $0.08   per   Kwhr.     Manufacturers'
recommendations form  the  basis of  these
estimates.
    EPA based maintenance, taxes, and insurance
on  a percentage of the total  capital cost as
detailed in Table 11-2.
    Chemical usage and labor requirements are
technology specific.  These costs are detailed for
each specific technology according to the index
given in Table 11-3.
     Table 11-2. Standard Operation and Maintenance Cost Factor Breakdow
      Factor
         O&M Cost (1989 $/year)
      Maintenance
      Taxes and Insurance
      Labor
      Electricity
      Chemicals:
        Lime (Calcium Hydroxide)
        Polymer
        Sodium Hydroxide (100 percent solution)
        Sodium Hydroxide (50 percent solution)
        Sodium Hypochlorite
        Sulfuric Acid
        Aries Tek Ltd Cationic Polymer
        Ferrous Sulfate
        Hydrated Lime
        Sodium Sulfide
      Residuals Management	
       4 percent of Total Capital Cost
       2 percent of Total Capital Cost
      $30,300 to $31,200 per man-year
          $0.08 per kilowatt-hour

               $57 per ton  .
             $3.38 per pound
               $560 per ton
               $275 per ton
             $0.64 per pound
               $80 per ton
             $1.34 per pound
             $0.09 per pound
             $0.04 per pound
             $0.30 per pound
         Technology-Specific Cost
      Total O&M Cost
 Maintenance + Taxes and Insurance + Labor
     + Electricity + Chemicals + Residuals
                                             11-3

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
Table 11-3. CWT Treatment Technology Costing Index - A Guide to the Costing Methodology Sections
Subcategory/
Option


Metals 2






Metals 3





Metals 4


Metals -
Cyanide Waste
Pretreatment
Oils 8
Oils 8v
Oils 9

Oils 9v
Organics 4

Organics 3
Treatment Technology
Selective Metals Precipitation
Plate and Frame Liquid Filtration
Secondary Chemical Precipitation
Clarification
Plate and Frame Sludge Filtration
Filter Cake Disposal
Selective Metals Precipitation
Plate and Frame Liquid Filtration
Secondary Chemical Precipitation
Clarification
Tertiary Chemical Precipitation and pH Adjustment
Clarification
Plate and Frame Sludge Filtration
Filter Cake Disposal
Primary Chemical Precipitation
Clarification
Secondary (Sulfide) Chemical Precipitation
Secondary Clarification (for Direct Dischargers Only)
Multi-Media Filtration
Plate and Frame Sludge Filtration^
Cyanide Destruction at Special Operating Conditions
Dissolved Air Flotation
Dissolved Air Flotation
Air Stripping
Secondary Gravity Separation
Dissolved Air Flotation
Secondary Gravity Separation
Dissolved Air Flotation
Air Stripping
Equalization
Sequencing Batch Reactor
Equalization
Sequencing Batch Reactor
Air Stripping
Section
11.2.1.1
11.2.2.1
11.2,1.2
11.2.2.2
11.4.1
11.4.2
11.2.1.1
11.2.2.1
11.2.1.2
11.2.2.2
11.2.1.3
11.2.2.2
11.4.1
11.4.2
11.2.1.4
11.2.2.2
11.2.1.5
11.2.2.2
11.2.5
11.4.1
11.2.6
11.2.8
11.2.8
11.2.4
11.2.7
11.2.8
11.2.7
11.2.8
11.2.4
11.2.3
11.3.1
11.2.3
11.3.1
11.2.4
 'Metals Option 4 sludge filtration includes filter cake disposal.
                                              11-4

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Chapter 11 Cost of Treatment Technologies	Development Document for the CWT Point Source Category
PHYSICAL/CHEMICAL WASTEWATER
TREATMENT TECHNOLOGY COSTS         11.2
Chemical Precipitation                11.2.1

    Wastewater treatment facilities widely use
chemical  precipitation  systems  to  remove
dissolved metals  from  wastewater.    EPA
evaluated systems that utilize sulfide, lime, and
caustic as the  precipitants  because of their
common use  in CWT chemical precipitation
systems  and  their  effectiveness  in  removing
dissolved metals.

Selective Metals Precipitation-Metals
Option 2 and Metals Option 3         11.2.1.1
    The selective metals precipitation equipment
assumed by EPA for costing purposes for Metals
Option 2 and  Metals Option 3 consists of four
mixed reaction tanks, each sized for 25  percent of
the total  daily flow, with pumps and treatment
chemical feed systems.  EPA costed for four
reaction tanks  to allow a facility to segregate its
wastes into  small  batches, thereby facilitating
metals recovery and avoiding interference with
other incoming waste receipts.   EPA assumed
that these four tanks would provide adequate
surge  and equalization capacity  for a metals
subcategory CWT.  EPA based costs on a four
batch per day treatment schedule (that is, the sum
of four batch volumes equals the facility's daily
incoming waste volume).
    As shown in Table 11-3, plate and frame
liquid  filtration  follows   selective  metals
precipitation for Metals Options 2 and 3.  EPA
has not presented the costing discussion for plate
and frame liquid filtration in this section (consult
section 11.2.3.2). Likewise, EPA has presented
the discussion for sludge filtration and filter cake
disposal  in  sections  11.4.1   and  11.4.2,
respectively.

               CAPITAL COSTS
    Because only one facility  in the metals
subcategory has selective metals precipitation in-
place, EPA included selected metals precipitation
capital costs for all facilities (except one) for
Metals Options 2 and 3.
    EPA obtained the.equipment capital  cost
estimates  for the selective metals precipitation
systems from vendor quotations.  These costs
include the cost of the mixed reaction tanks with
pumps and treatment chemical feed systems.  The
total  construction  cost  estimates   include
installation,  piping and  instrumentation,  and
controls.    The total capital  cost  includes
engineering and contingency at a percentage of
the  total construction  cost  plus   the total
construction cost (as explained in Table 11-1).
The equation for calculating selective  metals
precipitation capital costs for Metals Option 2
and Option 3 is presented in Table 11-4 at the
end of this section.

        CHEMICAL USAGE AND LABOR
            REQUIREMENT COSTS
    EPA  based the  labor  requirements  for
selective  metals precipitation  on the  model
facility's operation. EPA estimated the labor cost
at eight man-hours per batch (four  treatment
tanks per batch, two hours  per treatment tank per
batch).
    EPA estimated selective metals precipitation
chemical  costs based on stoichiometric,  pH
adjustment, and buffer adjustment requirements.
For  facilities  with  no  form  of   chemical
precipitation  in-place,   EPA   based   the
stoichiometric requirements on the amount of
chemicals required to precipitate each  of the
metal and semi-metal pollutants of concern from
the metals subcategory  average raw influent
concentrations to current performance levels (See
Chapter  12  for  a  discussion of raw influent
concentrations  and  current  loadings).    The
chemicals used were caustic at 40 percent of the
required removals and lime at 60 percent of the
required removals.  (Caustic at 40 percent  and
lime at 60 percent add up to 100 percent of the
stoichiometric requirements.)  These  chemical
                                            11-5

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
dosages reflect the operation of the selective
metals precipitation model facility.   Selective
metals  precipitation  uses a relatively  high
percentage of caustic because the sLudge resulting
from caustic precipitation is amenable to metals
recovery.  EPA estimated the pH adjustment and
buffer adjustment requirements to be 40 percent
of the stoichiometric requirement  EPA added an
excess  of 10  percent to the pH  and buffer
adjustment requirements, bringing the total to 50
percent.   EPA included a 10 percent  excess
because this is typical of the operation of the
CWT facilities visited and sampled by EPA.
    EPA estimated selective metals precipitation
upgrade costs for facilities that currently utilize
some form of chemical precipitation. Based
on responses to the Waste Treatment Industry
              Questionnaire, EPA assumed that the in-place
              chemical precipitation systems use a dosage ratio
              of 25%  caustic and 75% lime and  achieve a
              reduction of pollutants from "raw" to "current"
              levels. The selective metals precipitation upgrade
              would require a change in the existing dosage mix
              to 40% caustic and 60  % lime. Therefore, the
              selective  metals   precipitation   upgrade  for
              facilities with in-place chemical precipitation is
              the increase in caustic cost (from 25 % to 40%)
              minus the lime credit (to decrease from 75% to
                  The O&M cost equation for selective metals
              precipitation is presented in Table  11-4 along
              with  the  O&M  upgrade  cost equation for
              facilities with primary and secondary chemical
              precipitation in-place.
Table 11-4. Cost Equations for Selective Metals Precipitation in Metals Options 2 and 3
 Description
Equation
Recommended
Flow Rate Range
(MOD)  .
 Capital.cost
ln(Yl) = 14.461 + 0.5441n(X) + 0.0000047(ln(X))2  1.0 E -6 to 5.0
 O&M cost forfacilities with no chemical    ln(Y2) = 15.6402 + l.OOlln(X) + 0.04857(ln(X))2    3.4 E -5 to 5.0
 precipitation treatment in-place
 O&M upgrade cost for facilities with
 precipitation in-place
 Land requirements
ln(Y2) = 14.2545 + 0.80661n(X) + 0.04214(ln(X))2  7.4 E -5 to 5.0
ln(Y3) = -0.575 + 0.4201n(X) + 0.025(ln(X))2
1.6 E-2 to 4.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 - Land Requirement (Acres)
X = Flow Rate (million gallons per day)
Secondary Precipitation  Metals
Option 2 and Metals Option 3          11.2.1.2
    The secondary precipitation system in the
model technology for Metals Option 2 and Metals
Option 3 follows selective metals precipitation
and plate and frame liquid  filtration.  This
secondary  chemical  precipitation  equipment
consists of a single mixed reaction tank with
pumps and a treatment chemical  feed system,
              which is sized for the full daily batch volume.
                  As shown in Table 11-3, clarification follows
              secondary chemical precipitation  for Metals
              Options 2 and 3.   The costing discussion for
              clarification following secondary precipitation is
              presented in section 11.2.2.2. The discussions
              for sludge filtration and the; associated filter cake
              disposal are  presented in sections 11.4.1, and
               11.4.2, respectively.
                                              11-6

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Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
    Many facilities  in the metals subcategory
currently  have chemical precipitation units in-
place.  For these facilities, cost upgrades may be
appropriate. EPA used the following set of rules
to decide whether a facility's costs  should be
based  on  a full cost equation or an upgrade
equation for the secondary chemical precipitation
step of metals Options 2 and 3:

   Facilities with no chemical precipitation la-
    place should use the full capital and O&M
    costs.
   Facilities with primary chemical precipitation
    in-place should assume no capital costs, no
    land requirements, but an O&M upgrade cost
    for the primary step.
   Facilities    with    secondary   chemical
    precipitation  currently   in-place  should
    assume   no  capital  costs,  no   land
    requirements,  and no O&M costs  for the
    secondary step.

               CAPITAL COSTS
    For   facilities   that have  no  chemical
precipitation in-place, EPA calculated capital cost
estimates   for  the  secondary  precipitation
treatment systems from vendor quotations.
      EPA estimated the other components (i.e.,
piping, instrumentation and controls, etc.) of the
total capital cost by applying the same factors
and additional costs as detailed for selective
metals precipitation (see Section 11.2.1.1  above).
The  capital   cost  equation   for  secondary
precipitation in Metals Option 2 and Option 3 is
shown in Table 11-5 at the end of this section.
    For the facilities that have at least  primary
chemical precipitation in-place, EPA assumed
that  the   capital   cost  for   the  secondary
precipitation treatment system would be zero.
The in-place  primary   chemical precipitation
systems would serve as  secondary precipitation
systems  after  the   installation  of upstream
selective metals precipitation units.
               CHEMICAL USAGE AND LABOR
                   REQUIREMENT COSTS
           EPA developed O&M cost estimates for the
       secondary precipitation step of Metals Option 2
       and  3  for facilities with and without chemical
       precipitation currently in-place.  For facilities
       with no chemical precipitation in-place, EPA
       calculated  the  amount  of lime required  to
       precipitate each of the metals and semi-metals
       from the metals subcategory current performance
       concentrations (achieved with  the  previously
       explained selective metals precipitation step) to
       the  Metals   Option  2  long-term   average
       concentrations.  EPA then added a ten percent
       excess  dosage factor and  based the chemical
       addition costs on the required amount  of lime
       only, which is  based  on the  operation of the
       model facility for this technology. EPA assumed
       the labor cost to be two hours per batch, based on
       manufacturers' recommendations.
           For facilities with chemical precipitation in-
       place, EPA calculated an O&M upgrade  cost. In
       calculating the O&M upgrade cost, EPA assumed
       that there would be no additional costs associated
       with any of the components of the annual O&M
       cost, except for increased chemical costs.
           Since.  EPA already  applied  credit  for
       chemical  costs for facilities  with   primary
       precipitation in  estimating the selective metals
       precipitation  chemical  costs,  the  chemical
       upgrade  costs  for  facilities  with   primary
       precipitation are identical to facilities  with no
       chemical precipitation in-place.
           Since  EPA assumed  that facilities with
       secondary precipitation would achieve the metals
       option 2 long term average concentrations with
       their current system and chemical additions (after
       installing  the  selective metals  precipitation
       system), EPA assumed these facilities would not
       incur any additional chemical costs. In turn, EPA
       also  assumed  that facilities  with secondary
       precipitation units in-place would incur no O&M
       upgrade costs.
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Chanter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
Table 11-5. Cost Equations for Secondary Chemical Precipitation in Metals Options 2 and 3
 Description
                             Equation
Recommended Flow
Rate Range (MOD)
                              In (Yl) = 13.829 + 0.5441n(X) + 0.00000496(ln(X)r
                              In (Y2) = 11.6553 + 0.483481n(X) + 0.02485(ln(X))2
Capital cost
O&M cost for facilities with no
chemical precipitation in-place
O&M upgrade cost for facilities     In (Y2) = 9.97021 + 1.001621n(X) + 0.00037(ln(X))2
with primary precipitation in-place
 Land requirements
                             In (Y3) = -1.15 + 0.4491n(X) + 0.027(ln(X))2
1.0 E-6 to 5.0
6.5 E-5 to 5.0

5.0 E-4 to 5.0

4.0 E-3 to 1.0
Yl - Capital Costs (1989 $)
Y2 - Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X  Flow Rate (million gallons per day)
Tertiary Precipitation andpH
Adjustment- Metals Option 3          11.2.1.3
    The tertiary chemical precipitation step for
Metals   Option   3  follows  the  secondary
precipitation and clarification steps. This tertiary
precipitation system  consists  of a rapid mix
neutralization tank and a pH adjustment tank.  In
this step, the wastewater is fed to the rapid mix
neutralization tank where lime slurry is added to
raise the  pH  to  11.0.    Effluent from  the
neutralization tank then flows  to a clarifier for
solids removal. The clarifier overflow  goes to a
pH adjustment tank where sulfuric acid is added
to  achieve the desired final pH of 9.0.  This
section explains the  development of the cost
estimates for the rapid mix neutralization tank
and the pH adjustment tank.  The discussions for
clarification, sludge  filtration, and associated
filter cake disposal are presented in  Sections
11.2.2.2, 11.4.1, and 11.4.2, respectively.

               CAPITAL COSTS
    EPA developed the capital cost estimates for
the rapid mix tank assuming continuous flow and
a 15-minute detention time, which is based on the
model  facility's   standard  operation.    The
equipment cost includes one tank, one agitator,
and one lime feed system.
    EPA developed the capital cost estimates for
                                                the pH adjustment tank  assuming continuous
                                                flow and a five-minute detention time, also based
                                                on the model facility's operation. The equipment
                                                cost includes one tank,  one agitator,  and one
                                                sulfuric acid feed system.
                                                    EPA estimated the other components (i.e.,
                                                piping, instrumentation and controls, etc.) of the
                                                total capital cost for both the rapid mix and pH
                                                adjustment tank by applying the same factors and
                                                additional costs as detailed for selective metals
                                                precipitation (see Section 11.2.1.1 above).  The
                                                capital cost equations for the rapid mix and pH
                                                adjustment tanks are presented in Table 11-6 at
                                                the end of this section.

                                                        CHEMICAL USAGE AND LABOR
                                                             REQUIREMENT COSTS
                                                    EPA did not assign O&M costs, and in turn,
                                                chemical usage and labor requirement costs for
                                                tertiary precipitation  and pH adjustment to the
                                                few facilities which have tertiary precipitation
                                                (and pH adjustment) systems in-place. For those
                                                facilities without tertiary precipitation (and pH
                                                adjustment)  in-place, EPA estimated the labor
                                                requirements at  one  man-hour per day for the
                                                rapid mix and pH adjustment tanks.  EPA based
                                                this estimate  on the model  facility's typical
                                                operation.
                                                    EPA estimated chemical costs for the rapid
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Chanter 11 Cost of Treatment Technologies     .Development Document for the CWT Point Source Category
mix tank based on lime addition to achieve the
stoiehiometric  requirements  of  reducing the
metals in the wastewater from the Metals Option
2  long-term averages to the Metals Option 3
long-term averages, with a  10 percent excess.
EPA estimated the chemical requirements for the
              pH adjustment tank based on the addition of
              sulfuric acid to lower the pH from 11.0 to 9.0,
              based on the model facility's operation.   The
              O&M cost equations for the rapid mix tank and
              pH adjustment tank are presented in Table 11-6.
Table 11-6. Cost Equations for Tertiary Chemical Precipitation in Metals Option 3
Description
Equation
Recommended
Flow Rate Range
(MOD)
 Capital cost for rapid mix tank
 Capital cost for pH adjustment tank
 O&M cost for rapid mix tank
 O&M cost for pH adjustment tank
 Land requirements for rapid mix tank
 Land requirements for pH adjustment tank
ln(Yl) = 12.318 + 0.5431n(X) - 0.000179(ln(X))2     1.0 E -5 to 5.0
ln(Yl) = 11.72,1 + 0.5431n(X) + 0.000139(ln(X))2    1.0 E -5 to 5.0
ln(Y2) = 9.98761 + 0.375141n(X) + 0.02124(ln(X))2  1.6 E -4 to 5.0
ln(Y2) = 9.71626 + 0.332751n(X) + 0.0196(ln(X))2   2.5 E -4 to 5.0
ln(Y3) = -2.330 + 0.3521n(X) + 0.019(ln(X))2        1.0 E -2 to 5.0
ln(Y3) = -2.67 + 0.301n(X) + 0.033(ln(X))2          1.0 E -2 to 5.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
Primary Chemical Precipitation -
Metals Option 4                      11.2.1.4
    The primary chemical precipitation system
equipment for the model technology for Metals
Option 4 consists of a mixed reaction tank with
pumps, a treatment chemical feed system, and an
unmixed wastewater holding tank. EPA designed
the system to operate on a batch basis, treating
one batch per day, five, days per week.   The
average chemical  precipitation  batch duration
reported  by  respondents  to   the   WTI
Questionnaire was four hours. Therefore,  a one
batch per day treatment schedule should provide
sufficient time for the average facility to pump,
treat, and test its waste. EPA also included a
holding tank, equal to the daily waste volume, up
to a maximum size of 5,000 gallons (equivalent
to  the  average  tank  truck receipt volume
throughout  the  industry),  to  allow  facilities
              flexibility in managing  waste receipts.  (The
              Metals Option 4 model facility utilizes a holding
              tank.)
                  As shown in Table 11-3, clarification follows
              primary chemical precipitation for metals Option
              4.   The  costing discussion for  clarification
              following primary precipitation in Metals Option
              4  is  presented  in  section 11.2.2.2.    The
              discussions   for   sludge  filtration  and  the
              associated filter cake disposal are presented in
              sections 11.4.1, and 11.4.2, respectively.

                             CAPITAL COSTS
                  EPA developed total capital cost estimates
              for  the  Metals  Option  4  primary chemical
              precipitation systems.   For facilities with  no
              chemical  precipitation   units  in-place,  the
              components of the chemical precipitation system
              included  a  precipitation  tank  with a mixer,
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Chanter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
pumps, and a feed system.  In addition, EPA
included a holding tank equal to the size of the
precipitation tank, up to 5,000  gallons.  EPA
obtained    these    cost    estimates   from
manufacturer's recommendations.
    EPA estimated the  other components (i.e.,
piping, instrumentation and controls, etc.) of the
total capital cost for both the rapid mix and pH
adjustment tank by applying the same factors and
additional costs as detailed for selective metals
precipitation (see Section 11.2.1.1 above).
    For facilities that already have any chemical
precipitation (treatment in-place), EPA included
as capital expense only the cost of a holding tank.
The capital cost equations for primary chemical
precipitation and the holding tank only for Metals '
Option 4 are presented in Table 11-7.

        LABOR AND CHEMICAL COSTS
    EPA approximated the labor cost for primary
chemical precipitation in Metals Option 4 at two
hours per batch, one batch per day. EPA based
this approach on the model facility's operation.
    EPA estimated chemical costs based on
stoichiometric,  pH  adjustment,  and  buffer
adjustment requirements.  For facilities with no
chemical precipitation in-place, EPA based the
stoichiometric requirements  on the amount of
chemicals required to precipitate each of the
metal  pollutants of concern from the metals
subcategory average raw influent concentrations
to  Metals  Option   4  (Sample  Point-03)
concentrations. Metals Option 4, Sample Point-
OS concentrations represent the sampled effluent
from primary chemical precipitation at the model
facility.  The chemicals used were lime at 75
percent of the required removals and caustic at 25
percent of the required removals, which are based
on the option facility's operation.  EPA estimated
the pH  adjustment  and  buffer adjustment
requirements  to  be   50   percent  of  the
stoichiometric requirement, which includes a 10
percent excess of chemical dosage. The O&M
cost equation for primary chemical precipitation
in Metals Option 4 for facilities with no treatment
in-place is presented in Table 11-7.
    For facilities which already have chemical
precipitation treatment in-place, EPA estimated
an  O&M upgrade cost.  EPA assumed that
facilities with primary chemical precipitation in-
place have effluent concentrations  exiting the
primary  precipitation/solid-liquids  separation
system equal to the metals subcategory primary
precipitation current loadings. Similarly, EPA
assumed that facilities with secondary chemical
precipitation in place have effluent concentrations
exiting the secondary precipitation/solid-liquids
separation system equal to metals  subcategory
secondary precipitation current loadings (see
chapter 12 for  a  detailed  discussion of metals
subcategory primary and secondary chemical
precipitation current loadings).
    For  the portion of  the O&M upgrade
equation associated with energy, maintenance,
and labor,  EPA calculated the  percentage
difference between  the primary precipitation
current loadings and Metals Option 4 (Sample
Point-03) concentrations.  For facilities which
currently have primary precipitation systems this
difference is an increase of approximately two
percent.  Therefore, EPA calculated the energy,
maintenance, and labor components of the O&M
upgrade cost for facilities with primary chemical
precipitation in-place at two percent of the O&M
cost for facilities with no chemical precipitation
in-place.
      For the  portion  of the O&M upgrade
equation associated with  energy, maintenance,
and  labor,   EPA  calculated the  percentage
difference  between  secondary   precipitation
current loadings and Metals Option 4 (Sample
Point-03)   concentrations.    For  secondary
precipitation systems, this difference is  also an
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Chapter 11 Cost of Treatment Technologies
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increase  of,  approximately  two  percent1.
Therefore,   EPA   calculated   the   energy,
maintenance, and labor components of the O&M
upgrade  cost  for  facilities  with  secondary
chemical precipitation in-place at two percent of
the O&M cost for facilities with no chemical
precipitation in-place.
   For the chemical cost portion of the O&M
upgrade,  EPA also  calculated upgrade  costs
depending on whether the facility had primary
precipitation or secondary precipitation currently
in-place. For facilities with primary precipitation,
EPA calculated chemical upgrade costs based on
current-to-Metals  Option 4 (Sample Point-03)
removals. Similarly for facilities with secondary
precipitation, EPA calculated chemical upgrade
costs based on secondary precipitation removals
to Metals Option 4 (Sample Point -03) removals.
In both cases, EPA did not include costs for pH
adjustment or  buffering chemicals since these
chemicals should already be used in the in-place
treatment system. .Finally, EPA included a 10
percent excess  of  chemical  dosage  to the
stoichiometric requirements of the precipitation
chemicals.
    EPA then combined the energy, maintenance
and labor components of the O&M upgrade with
the chemical portion of the O&M  upgrade to
develop two sets of O&M upgrade equations for
the primary chemical precipitation portion of
Metals Option 4.    These cost equations  for
Metals Option 4 (primary chemical precipitation
O&M upgrade costs) for facilities with primary
and secondary treatment in place are presented
Table 11-7.
        1 While pollutant concentrations resulting
 from secondary chemical precipitation are generally
 lower than those resulting from primary chemical
 precipitation, the percentage increase (when
 rounded) for primary and secondary precipitation are
 the same.
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
Table 11-7. Cost Equations for Primary Chemical Precipitation in Metals Option 4
Description
                                Equation
Recommended Flow
Rate Range (MOD)
                                                                              1.0E-6to5.0

                                                                              1.0 E-6 to 0.005
Capital cost for primary precipitation   ln(Yl) = 14.019 + 0.4811n(X) - 0.00307(ln(X))2
and no treatment in-place
Capital cost for holding tank only -     ln(Yl) = 10.671 - 0.0831n(X) - 0.032(ln(X))2
used for facilities with chemical
precipitation currently in-place.
O&M cost for primary precipitation    ln(Y2) = 15.3086 + 1.083491n(X) + 0.04891(ln(X))2    1.7 E -5 to 5.0
and no treatment in-place
O&M upgrade for facilities with
primary precipitation in-place
O&M upgrade for facilities with
secondary precipitation in-place
Land requirements
                                ln(Y2) = 11.4547 + 1.043371n(X) + 0.04575(ln(X))2    2.0 E -5 to 5.0

                                ln(Y3) = 10.9647 + 0.98525In(X) + 0.04426(ln(X))2    1.7 E -5 to 5.0
                                ln(Y3) = -1.019 + 0.299m(X) + 0.015(ln(X))2
Land requirements (associated with    ln(Y3) = -2.866 - 0.023m(X) - 0.006(ln(X))2
holding tank only)	      ;

Yl = Capital Costs (1989 $)
Y2  Operation and Maintenance Costs (1989 $ /year)
Y3 - Land Requirement (Acres)
X - Flow Rate (million gallons per day)
6.7 E-5 to 1.0
1.0 E-5 to 0.5
Secondary (Sulfide) Precipitation
for Metals Option 4                   11.2.1.5
    The  Metals  Option  4  secondary  sulfide
precipitation system follows the primary metals
precipitation/clarification step. This equipment
consists of a mixed reaction tank with pumps and
a treatment chemical feed system, sized for the
full daily batch volume. For direct dischargers,
the overflow from secondary sulfide precipitation
would carry on to a clarifier and then multi-media
filtration.  For indirect discharges, the overflow
would  go immediately to  the filtration unit,
without clarification.  Cost estimates for the
clarifier are discussed in section 11.2.2.2 of this
document.    Cost  estimates for  multi-media
filtration are presented in section 11.2.5.
    For costing purposes, EPA assumed  that
facilities  either have  secondary  precipitation
currently in-place and attributes no additional
capital and O&M costs to these facilities, or EPA
assumes  that facilities do not have secondary
                                                   sulfide precipitation in-place and, consequently,
                                                   EPA developed costs for Ml O&M and capital
                                                   costs.  Therefore, EPA has not developed upgrade
                                                   costs associated with secondary precipitation in
                                                   Metals Option 4.

                                                                  CAPITAL COSTS
                                                       EPA developed capital cost estimates for the
                                                   secondary sulfide precipitation systems in Metals
                                                   Option 4 from vendor's quotes. EPA estimated
                                                   the   other     components    (i.e.,    piping,
                                                   instrumentation, and controls, etc.) of the sulfide
                                                   precipitation system  by  applying  the  same
                                                   methodology, factors  and  additional  costs  as
                                                   outlined for the primary chemical  precipitation
                                                   system for Metals Option 4 (see Section 11.2.1.4
                                                   above).  The capital cost equation for Metals
                                                   Option 4  secondary  sulfide  precipitation is
                                                   presented in Table 11-8 at the end of this section.
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
        LABOR AND CHEMICAL COSTS
    For facilities with no secondary precipitation
systems  in-place,  EPA  estimated the  labor
requirements at two hours per batch, one batch
per day. EPA based this estimate on standard
operation at the Metals Option 4 model facility.
    For secondary sulfide precipitation in Metals
Option 4, EPA did not base the chemical cost
                estimates  on   stoichiometric   requirements.
                Instead, EPA estimated the chemical costs based
                on dosage rates for the addition of polymer and
                ferrous sulfide obtained during the sampling of
                the Metals  Option 4  model  plant with BAT
                performance. The O&M cost equation for the
                Metals Option 4, secondary sulfide precipitation
                is presented in Table 11-8.
Table 11-8. Cost Equations for Secondary (Sulfide) Precipitation for Metals Option 4
 Description
Equation
                           Recommended
                           Flow Rate Range
                           (MOD)
 Capital cost for secondary precipitation   In (Yl) = 13.829 + 0.544ln(X) + 0.00000496(ln(X))2   1.0 E -6 to 5.0
 and no treatment in-place
 O&M cost for secondary precipitation    In (Y2) = 12.076 + 0.634561n(X) + 0.03678(ln(X))2
 and no treatment in-place
 Land requirements
In (Y3) = -1.15 + 0.4491n(X) + 0.027(ln(X))2
                            1.8 E-4 to 5.0

                            2.5 E-4 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
Plate and Frame Liquid
Filtration and Clarification
      11.2.2
    Clarification systems  provide continuous,
low-cost separation and removal of suspended
solids from water. Waste treatment facilities use
clarification to remove particulates, flocculated
impurities,  and  precipitants, often  following
chemical   precipitation.     Similarly,  waste
treatment facilities  also use plate and frame
pressure systems to remove solids from waste
streams. As described in this section, these plate
and frame  filtration systems  serve  the  same
function as clarification and are used to remove
solids  following chemical  precipitation from
liquid  wastestreams.   The major difference
between clarification systems and plate and frame
liquid  filtration systems  is that the sludge
generated by clarification generally needs to be
processed further prior to landfilling, whereas, the
sludge generated  by plate and frame liquid
filtration does not.
    EPA costed facilities to include a plate and
frame liquid filtration system following selective
metals precipitation in Metals Options 2 and 3.
The components  of the plate  and frame liquid
filtration system include: filter plates, filter cloth,
hydraulic pumps, control panel, connector pipes,
and a support platform. Since EPA costed all
metals facilities for selective metals precipitation
systems for metals Options 2  and 3 (except the
one  facility   which   already   utilizes  this
technology), EPA also costed all metals facilities
for plate  and frame  liquid filtration  systems.
Consequently, EPA did not develop any upgrade
costs associated with the use of plate and frame
liquid filtration.
    EPA also costed  facilities  to  include  a
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Chanter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
clarifier following secondary precipitation for
Metals Option 2 and following both secondary
and tertiary precipitation for Metals Option 3.
For Metals  Option 4, EPA  costed facilities to
include  a clarifier following primary  chemical
precipitation   and    following   secondary
precipitation (for direct dischargers only). EPA
designed and costed a single clarification system
for all options and locations in the treatment
train.   The components  of this  clarification
system include a clarification unit, flocculation
unit, pumps, motor, foundation, and accessories.
Plate and Frame Liquid
Filtration Following Selective
Metals Precipitation
112.2.1
               CAPITAL COSTS
    The  plate  and  frame  liquid  filtration
equipment  following  the  selective  metals
precipitation step for the model technology in
Metals Option 2 and 3 consists of two plate and
frame liquid filtration systems.  EPA assumed
that each system would be used to process two
batches per day for a total of four batches.  EPA
costed  the plate and  frame liquid  filtration
systems in this manner to allow facilities to
segregate  their wastes into  smaller batches,
thereby facilitating selective  metals  recovery.
EPA sized each of the units to process a batch
consisting of 25 percent of the  daily flow and
assumed that the influent to the plate and frame
filtration units would consist of 96 percent liquid
and four percent (40,000 mg/1) solids (based on
the model facility). EPA based the capital cost
equation for plate and frame liquid filtration for
Metals Options 2 and 3 on information provided
by vendors. This capital cost equation is listed in
Table 11-9.

 CHEMICAL USAGE AND LABOR REQUIREMENTS
    EPA estimated that labor requirements for
plate and frame  liquid filtration  for  Metals
Options 2 and 3 would  be 30 minutes per batch
per filter press (based on the  metals Options 2
and 3 model facility).  There are no chemicals
associated with the operation of the plate and
frame filtration systems.  EPA estimated  the
remaining components of O&M using the factors
listed in Table 11-2.  The: O&M equation for
plate and frame liquid filtration is listed in Table
11-9.
    Even though the metal-rich sludge generated
from selective metals precipitation and plate and
frame liquid filtration may be recycled and re-
used, EPA additionally included costs associated
with disposal of these sludges in a landfill.  The
discussion for filter cake disposal is presented
separately in Section 11.4.2.  These disposal
costs are additional O&M costs which must be
added to the O&M costs calculated above to
obtain the total O&M costs associated with plate
and frame liquid filtration for Metals Options 2
and 3.
           Clarification for Metals
           Options 2,3, and 4
                                     11.2.2.2
                         CAPITAL COSTS
               EPA obtained the capital cost estimate for
           clarification systems  from  vendors.    EPA
           designed the clarification system assuming an
           influent   total   suspended   solids   (TSS)
           concentration  of 40,000 mg/L  (four  percent
           solids) and  an effluent TSS concentration of
           200,000 mg/L (20 percent solids).  In addition,
           EPA  assumed a design overflow rate of 600
           gpd/ft2. EPA estimated the influent and effluent
           TSS concentrations and overflow rate based on
           the   WTI    Questionnaire   response   for
           Questionnaire ID 105.  The: capital cost equation
           for clarification is presented in Table 11-9 at the
           end of this section. As detailed earlier, the same
           capital  cost equation  is used for  all  of the
           clarification systems for all of the  metals options
           regardless of its location in the treatment train.
           EPA  did not develop capital cost upgrades for
           facilities which already have: clarification systems
           in-place.  Therefore, facilities which currently
           have clarifiers have no land or capital costs.
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Chapter XI Cost of Treatment Technologies
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 CHEMICAL USAGE AND LABOR REQUIREMENTS
    EPA estimated the labor requirements for the
clarification systems for Metals Options 2 and 3
following secondary precipitation and  Metals
Option 4 following primary and secondary (for
direct  dischargers only)  precipitation at three
hours per day for low-flow clarifiers and four to
six hours per day for high-flow clarifiers. Based
on  manufacturers  recommendations,   EPA
selected the flow cut-off between high-flow and
low-flow systems to be 1000 gallons per day.
For the clarifier following tertiary precipitation in
Metals Option 3  only, EPA  estimated the labor
requirement at one hour per day (based on the
operation of the Metals Option 3 model facility).
For  all  clarifiers for  all metals options and
treatment train   locations,  EPA estimated  a
polymer dosage  rate of  2.0  mg  per  liter  of
wastewater (for the flocculation step) based on
the MP&M industry cost model. EPA estimated
the remaining components of O&M using the
factors listed in Table  11-2.   The two cost
equations developed for clarification are listed in
Table 11-9. One equation is used for the clarifier
following the tertiary precipitation step of Metals
Option 3 and the other equation is used for all
other  Metals options and  locations   in the
treatment train.
    As shown in Table 11-3, sludge filtration
follows   clarification   for  the   secondary
precipitation step of Metals Options 2 and 3 and
the primary and secondary  (direct dischargers
only) of Metals Option 4. The costing discussion
and  equations  for sludge  filtration and the
associated filter cake disposal are presented in
Section 11.4.1 and 11.4.2, respectively.
    For facilities which already have clarification
systems  or plate and frame liquid filtration
systems in-place for each option and location in
the treatment train, EPA estimated clarification
upgrade costs.   EPA assumed  that in-place
clarification systems and in-place plate and frame
liquid  filtration  systems   are   equivalent.
Therefore, if a  facility has an in-place liquid
filtration system which  can serve the  same
       purpose as a clarifier, EPA costed this facility for
       an up-grade  only  and not a new clarification
       system.
           For the clarification step following secondary
       precipitation in Metals Options 2 and 3, in order
       to quantify the O&M increase necessary for the
       O&M upgrade,  EPA compared the  difference
       between    secondary   precipitation   current
       performance  concentrations  and  the Metals
       Option 2 long- term averages.  EPA determined
       facilities  would  need to increase their current
       removals by 3 percent.  Therefore, for in-place
       clarification systems (or plate and frame liquid
       filtration  systems)  which could  serve  as  the
       clarifier    following    secondary    chemical
       precipitation  for Metals Option 2 and 3, EPA
       included an O&M cost upgrade of three percent
       of the O&M costs for a brand new system (except
       for taxes, insurance, and maintenance which are
       a function of the  capital cost).  The  O&M
       upgrade  equations  for  clarification  following
       secondary  chemical precipitation for Metals
       Option 2 and 3 (one for facilities which currently
       have  a clarifier and  one for facilities  which
       currently have a plate and frame liquid filtration
       system) are listed in Table 11-9.
           For facilities which already have clarifiers or
       plate and frame liquid filtration systems in-place
       which could serve as the clarifier following the
       tertiary chemical precipitation of Metals Option
       3, EPA did not estimate any O&M upgrade costs.
       EPA  assumed the in-place technologies could
       perform as well as (or better) than the technology
       costed by EPA.
           For facilities which already have clarifiers or
       plate and frame liquid filtration systems in-place
       which could serve as the clarifier following the
       primary chemical precipitation of Metals Option
       4, EPA compared the difference between primary
       precipitation current loadings and the long-term
       averages for Metals Option 4, Sample Point 03
       (Sample  Point 03 follows primary precipitation
       and clarification at the Metals Option 4 model
       facility).  EPA determined that facilities would
       need   to  increase  their  removals  by  2%.
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
Therefore, for in-place clarification systems (or
plate and frame liquid filtration systems) which
could serve as the  clarifier following primary
chemical precipitation for Metals Option 4, EPA
included an O&M cost upgrade of two percent of
the O&M costs for a brand new system (except
for taxes, insurance, and maintenance which are
a  function of the  capital cost).   The O&M
upgrade equations  for clarification  following
primary  chemical  precipitation   for  Metals
Option4 (one for facilities which currently have a
                                                    clarifier and  one for facilities  which currently
                                                    have a plate and frame liqiuid filtration system)
                                                    are listed in Table 11-9.
                                                        EPA did not calculate an O&M upgrade
                                                    equation for  the  clarification step  following
                                                    secondary    chemical   precipitation   (direct
                                                    dischargers only) of Melials Option  4.   EPA
                                                    costed all direct discharging facilities for a new
                                                    clarification system following secondary chemical
                                                    precipitation for Metals Option 4 since none of
                                                    the  direct  discharging metals  facilities  had
                                                    treatment in-place for this step.
Table 11-9.  Cost Equations for Clarification and Plate and Frame Liquid Filtration in Metals Option 2,3,4
Description
                                          Equation
Recommended
Flow Rate
Range (MOD)
Capital cost for plate and frame liquid filtration for ln(Yl) =
Metals Options 2 and 31
Capital Cost for Clarification for Metals Options   ln(Yl) =
2,3, and 4
O&M cost for plate and frame liquid filtration for  ln(Y2) =
Metals Options 2 and 31
                                                  14.024 + 0.8591n(X) + 0.040(ln(X)r

                                                  11.552 + 0.4091n(X) + 0.020(ln(X))2

                                                  13.056 + 0.1931n(X) + 0.00343(ln(X))2

O&M cost for Clarification for Metals Options    ln(Y2) = 10.673 + 0.2381n(X) + 0.013(ln(X))2
2,33,and4
O&M cost for clarification for Metals Option 34   ln(Y2) = 10.294 + 0.3621n(X) + 0.019(ln(X))2
O&M upgrade for Clarification for Metals'       ln(Y2) = 7.166 + 0.2381n(X) + 0.013(ln(X))2
Options 2 and 3  facilities which currently have
clarification in-place5
O&M upgrade for Clarification for Metals       ln(Y2) = 8.707 + 0.3331n(X) + 0.012(ln(X)f
Options 2 and 3  facilities which currently have .
plate and frame liquid filtration in-place
1.0 E-6 to 1.0

4.0 E-5 to 1.0

1.0 E-6 to 1.0

1.2 E-4 to 1.0

8.0 E-5 to 1.0
7.0 E-5 to 1.0


1.0 E-6 to 1.0
O&M upgrade for Clarification for
Metals Option 46
Land requirements for plate and frame liquid
filtration for Metals Options 2 and 3
Land requirements for clarification
ln(Y2) = 6.8135 + 0.33151n(X) + 0.0242(ln(X))2
ln(Y3) = -1.658 + 0.1851n(X) + 0.009(ln(X))2
ln(Y3) = -1.773 + 0.5131n(X) + 0.046(ln(X))2
1.2 E -3 to 1.0
1.0 E -6 to 1.0
1.0 E -2 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
'Follows selective metals precipitation
3For metals option 3, this equation is used for clarification following secondary chemical precipitation only
''This equation is used for clarification following tertiary precipitation only.
5For  Metals Option 3, this equation is used for clarification following secondary precipitation only. No O&M
upgrade costs included for tertiary precipitation.
^This equation is used for clarification following primary precipitation only. No facilities require O&M upgrades
for clarification following secondary chemical precipitation.
                                                11-16

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Chapter 11 Cost of Treatment Technologies
   Development Document for the CWTPoint Source Category
Equalization
11.2.3
    To improve treatment, facilities often need to
equalize wastes by holding them in a tank. The
CWT industry frequently uses equalization to
minimize  the variability  of incoming wastes
effectively.
    EPA costed an equalization system which
consists of a mechanical aeration basin based on
responses to the  WTI   Questionnaire.  EPA
obtained the equalization cost estimates from the
1983 U.S. Army Corps of Engineers' Computer
Assisted Procedure for Design and Evaluation of
Wastewater   Treatment Systems  (CAPDET).
EPA originally used this  program to estimate
equalization  costs  for the  OCPSF Industry.
Tablell-10  lists the default design parameters
that EPA used in the CAPDET program. These
default design parameters are reasonable for the
CWT industry since they reflect values seen in
the CWT industry.  For  example,  the default
detention time  (24 hours) is appropriate since
this was the median equalization detention time
reported  by  respondents   to   the   WTI
Questionnaire.
Tablell-10. Design Parameters Used for
            Equalization in CAPDET Program

 Aerator mixing requirements = 0.03 HP per
 1,000 gallons';
 Oxygen requirements = 15.0 mg/1 per hour;
 Dissolved oxygen in basin = 2.0 mg/1;
 Depth of basin = 6.0 feet; and
 Detention time = 24 hours.
facilities would perform as well as (or better than)
the system costed by EPA.

               CAPITAL COSTS
    The  CAPDET  program calculates capital
costs which are "total  project costs."  These
"total project  costs" include all  of the  items
previously listed in Table 11-1  as well  as
miscellaneous   nonconstruction  costs,   201
planning  costs, technical  costs,  land costs,
interest during construction  ,  and laboratory
costs.  Therefore, to obtain capital costs for the
equalization systems  for this  industry,  EPA
calculated capital costs based on total project
costs minus:   miscellaneous  nonconstruction
costs, 201 planning costs, technical costs, land
costs, interest during construction, and laboratory
costs.  The resulting capital cost equation for
equalization is presented in Table 11-11 at the
end of this section.

    OPERATION AND MAINTENANCE COSTS .
    EPA obtained O&M costs directly from the
initial  year O&M  costs  produced  by  the
CAPDET program.  The O&M cost equation for
equalization systems is presented in Table 11-11.

           LAND REQUIREMENTS
    EPA used the CAPDET program to develop
land requirements for the equalization systems.
EPA scaled up the requirements to represent the
total land required for the system plus peripherals
(pumps, controls, access areas, etc.). The land
requirement equation for equalization systems is
also presented in Table 11-11.
    EPA  did  not calculate capital  or O&M
upgrade equations for equalization. If a CWT
facility  currently has an equalization tank in-
place, the facility received no costs associated
with  equalization.    EPA assumed  that  the
equalization tanks currently in-place at CWT
                                           11-17

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
Table 11-11. Summary of Cost Equations for Equalization
 Description
Equation
                   Recommended Flow Rate
                   Range (MOD)
 Capital cost for equalization
 O&M cost for equalization
 Land requirements
ln(Yl) = 12.057 + 0.4331n(X) + 0.043(ln(X))2     6.6 E -3 to 5.0
ln(Y2)= 11.723 + 0.3111n(X) + 0.019(ln(X))2     3.0E-4to5.0
ln(Y3) = -0.912 + 1.1201n(X) + 0.01 l(ln(X))2      1.4 E-2 to 5.0
Yl - Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 - Land Requirement (Acres)
X - Flow Rate (million gallons per day)
Air Stripping
           11.2.4
    Air  stripping is  an effective  wastewater
treatment method for removing dissolved gases
and volatile compounds from wastewater streams.
The technology  passes high volumes of  air
through  an agitated gas-water mixture.   This
promotes volatilzation  of compounds,   and,
preferably  capture  in  air  pollution control
systems.
    The air stripping system costed by  EPA
includes transfer pumps,  control panels, blowers,
and ancillary  equipment.  EPA also included
catalytic oxidizers as part of the system for air
pollution control purposes.
    If a CWT  facility currently  has  an  air.
stripping system in-place, EPA did not assign the
facility any costs associated  with air stripping.
EPA assumed that the air  stripping systems
currently in-place  at  CWT facilities would
perform as well  as (or  better than) the system
costed by EPA.

               CAPITAL COSTS
    EPA's air stripping system is  designed to
remove   pollutants  with   medium  to  high
volatilities.    EPA used  the  pollutant  1,2-
dichloroethane,  which has   a  Henry's  Law
Constant of 9.14 E -4 atm*L/mol, as the design
basis with an influent  concentration of 4,000
ug/L and an effluent concentration of 68  ug/L.
EPA based these concentration on information
collected on the model facility's operation. EPA
used the same design basis for the air stripping
systems costed for the option 8v and 9v in the
oils subcategory.
    EPA obtained the equipment costs from
vendor quotations. The capital cost equation for
air stripping systems is presented in Table 11-13
at the end of this section.

    OPERATION AND MAINTENANCE COSTS
    For  air  stripping, O&M  costs  include
electricity,    maintenance,   labor,    catalyst
replacement,  and taxes and insurance.  EPA
obtained the O&M costs from the same vendor
which provided the capital cost estimates.
    EPA based the electricity usage  for the air
strippers on the amount of horsepower needed to
operate the   system  and approximated  the
electricity usage for the catalytic oxidizers at 50
percent of the electricity use:d for the air strippers.
EPA based both the horsepower requirements and
the electricity requirements  for the  catalytic
oxidizer on vendor's recommendations. EPA
estimated the labor requirement for  the air
stripping system at three hours per day,  which is
based on the model facility's  operation. EPA
assumed that the catalyst beds in the  catalytic
oxidizer would require replacement  every four
years based on the rule of thumb (provided by the
vendor) that precious metal catalysts have a
                                            11-18

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Chapter 11 Cost of Treatment Technologies
              Development Document for the CWT Point Source Category
lifetime of approximately four years.     EPA
divided the costs for replacing the spent catalysts
by four to convert them to annual costs. As is the
standard used by EPA for this industry, taxes and
                      insurance were estimated at 2 percent of the total
                      capital cost. The resulting O&M cost equation
                      for air stripping systems is presented in Table 11-
                      12.
Table 11-12. Cost Equations for Air Stripping
 Description
Equation
                   Recommended Flow Rate
                   Range(MGD)
 Capital cost for air stripping
 O&M cost for air stripping
 Land requirements
ln(Yl) = 12.899 + 0.4861n(X) + 0.03 l(ln(X))2      4.0 E -4 to 1.0
ln(Y2) = 10.865 + 0.2981n(X) + 0.021(ln(X))2      8.5 E -4 to 1.0
ln(Y3) = -2.207 + 0.5361n(X) + 0.042(ln(X))2       0.1 to 1.0	
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
Multi-Media Filtration
           11.2.5
    Filtration is  a proven technology  for the
removal  of residual  suspended  solids  from
wastewater.  The multimedia filtration system
costed by EPA for this industry is a system which
contains sand and anthracite  coal, supported by
gravel.
    EPA based  the  design  for  the  model
multimedia filtration system on the TSS effluent
long- term  average concentration for Metals
Option 4 '15 mg/L. EPA assumed that the
average  influent  TSS  concentration  to the
multimedia filtration system would range from 75
to  100  mg/L.    EPA  based  the  influent
concentration     range      on     vendor's
recommendations on realistic TSS concentrations
resulting from wastewater treatment following
chemical precipitation and clarification.
    EPA did not  calculate capital or O&M
upgrade equations for multi-media filtration. If a
CWT facility currently has a multimedia filter in-
place,  EPA  assigned the  facility  no  costs
associated  with  multi-media filtration.  EPA
assumed that the multi-media filter currently in-
place at CWT facilities would perform as well as
(or better than) the system costed by EPA.

               CAPITAL COSTS
    EPA based the capital costs of multi-media
filters  on  vendor's recommendations.  The
resulting capital cost equation for multi-media
filtration systems is presented in Table 11-13.

        CHEMICAL USAGE AND LABOR
            REQUIREMENT COSTS
    EPA estimated the labor requirement for the
multi-media filtration system at four hours per
day,  which  is  based   on  manufacturer's
recommendations.    There are  no  chemicals
associated with the operation of a multimedia
filter.  The  O&M cost  equation for the multi-
media filtration system is presented in Table 11-
13.
                                            11-19

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Categor
Table 11-13. Cost Equations for Multi-Media Filtration
 Description
Equation
                           Flow Rate Range
                           (MOD)	
 Capital cost for multi-media filtration
 O&M cost for multi-media filtration
 Land requirements
ln(Yl) = 12.0126 + 0.480251n(X) + 0.04623(m(X))2   5.7 E -3 to 1.0
ln(Y2) = 11.5039 + 0.724581n(X) + 0.09535(ln(X))2   2.3 E -2 to 1.0
ln(Y3) = -2.6569 + 0.193711n(X) + 0.02496(ln(X))2    2.4 E -2 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X - Flow Rate (million gallons per day)
Cyanide Destruction
      11.2.6
    Many  CWTs achieved  required  cyanide
destruction  by  oxidation.    These  facilities
primarily use chlorine (in either the elemental or
hypochlorite form) as the oxidizing agent in this
process. Oxidation of cyanide with chlorine is
called alkaline chlorination.
    The oxidation of cyanide waste using sodium
hypochlorite is a two step process.  In the first
step,  cyanide is oxidized to cyanate in the
presence of hypochlorite, and sodium hydroxide
is used to maintain a pH range of 9 to  11. The
second step oxidizes cyanate to carbon dioxide
and nitrogen at a controlled pH of 8.5.  The
amounts of sodium hypochlorite and sodium
hydroxide needed to perform the oxidation are
8.5 parts and 8.0 parts per  part of  cyanide,
respectively. At these levels, the total reduction
occurs at a retention time of 16 to 20 hours. The
application  of heat  can facilitate  the more
complete destruction of total cyanide.
    The cyanide destruction system costed by
EPA includes a two-stage reactor with a retention
time of 16 hours,  feed system  and  controls,
pumps, piping, and foundation.  The two-stage
reactor includes  a covered  tank,  mixer,  and
containment tank. EPA designed  the system
based on a total cyanide influent concentration of
4,633,710 ug/L and an effluent concentration of
total cyanide of 135,661 ug/L.  EPA based these
influent and effluent concentrations  on data
collected during  EPA's  sampling  of cyanide
destruction systems.
    Because the system used by the facility which
forms the basis of the proposed cyanide limitation
and standards uses special operation conditions,
EPA assigned full capital and O&M costs to all
facilities which perform cyanide destruction.

               CAPITAL COSTS
    EPA obtained the capital costs curves for
cyanide  destruction   systems  with   special
operating conditions from vendor services. The
capital cost equation is  presented in Table 11-14.

        CHEMICAL USAGE AND LABOR
            REQUIREMENT COSTS
    In  estimating chemical  usage and labor
requirements, EPA assumed the systems would
treat one batch  per  day.   EPA  based  this
assumption  on   responses   to   the  WTI
Questionnaire.       Based    on    vendor's
recommendations, EPA   estimated  the labor
requirement for the cyanide destruction to be
three hours per day. EPA determined the amount
of sodium hypochlorite and  sodium hydroxide
required based on the stochiometric amounts to
maintain   the   proper   pH   and   chlorine
concentrations   to   facilitate  the   cyanide
destruction as described earlier.  The O&M cost
equation for cyanide destruction is presented in
Table 11-14.
                                            11-20

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  a^ter 11 Cost of Treatment Technologies
                                         Development Document for the CWTPoint Source Categor
Table 11-14. Cost Equations for Cyanide Destruction
 Description
                               Equation
                                     Recommended Flow
                                     Rate Range (MOD)
 Capital cost for cyanide destruction

 O&M cost for cyanide destruction

 Land requirements
                               ln(Yl) = 13.977 + 0.5461n(X) + 0.0033(ln(X))2     1.0 E -6 to 1.0

                               ln(Y2) = 18.237 + 1.3181n(X) + 0.04993(ln(X))2    1.0 E-5 to 1.0

                               ln(Y3) = -1.168 + 0.4191n(X) + 0.021(ln(X))2      1.0 E -4 to 1.0
Yl = Capital Costs (1989 $)
Y2 = Operation and Maintenance Costs (1989 $ /year)
Y3 = Land Requirement (Acres)
X = Flow Rate (million gallons per day)
Secondary Gravity Separation
                                      11.2.7
    Primary gravity separation provides oil and
grease removal from oily wastewater.   During
gravity separation, the wastewater is held in tanks
under quiescent conditions long enough to allow
the oil droplets to rise and form a layer on the
surface, where it is skimmed.
    Secondary   gravity   separation  .systems
provide additional oil and grease removal for oily
wastewater.   Oily  wastewater, after primary
gravity separation/emulsion breaking, is pumped
into a series of skimming tanks where additional
oil and grease  removal is  obtained before the
wastewater enters the dissolved air flotation unit.
The  secondary gravity separation equipment
discussed here consists of a  series of three
skimming  tanks  in  series.    The  ancillary
equipment for each tank consists of a mix tank
with pumps and skimming equipment.
    In  estimating  capital and  O&M  cost
associated  with secondary gravity separation,
EPA assumed that facilities either currently have
             or do not have secondary gravity separation.
             Therefore, EPA did not develop any secondary
             gravity separation upgrade costs.

                            CAPITAL COSTS
                 EPA obtained the capital cost estimates for
             the secondary  gravity separation system  from
             vendor quotes.  The capital cost equation for
             secondary gravity separation  is  presented in
             Table 11-15 at the end of this section.

                      CHEMICAL USAGE AND LABOR
                         REQUIREMENT COSTS
                , EPA estimated the labor  requirement to
             operate secondary gravity separation to be 3 to 9
             hours per day  depending on the size of the
             system.  EPA obtained this estimate from one of
             the model facilities for Oils Option 9. There are
             no chemicals associated with the operation of the
             secondary gravity separation system.  The O&M
             Cost  equation  for  the  secondary   gravity
             separation system is presented in Table 11-15.
 Table 11-15. Cost Equations for Secondary Gravity Separation
 Description
                                   Equation
                                          RecommendedFlow
                                          Rate Range (MOD)
 Capital cost for secondary gravity separation  ln(Yl) = 14.3209 + 0.387741n(X) - 0.01793(ln(X))2  5.0 E -4 to 5.0
                                     ln(Y2) = 12.0759 + 0.44011n(X) + 0.01544(ln(X))2   5.0 E -4 to 5.0
                                                                               1.0 E-6 to 1.0
O&M cost for secondary gravity separation
Land reauirements
ln(Y3) = -0.2869 + 0.313871n(X) + 0.01191(ln(X))2
 Yl = Capital Costs (1989 $)
 Y2 = Operation and Maintenance Costs (1989 $ /year)
 Y3 = Land Requirement (Acres)
 X = Flow Rate (million gallons per day)
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Categor
Dissolved Air Flotation
11.2.8
    Flotation  is   the  process  of  inducing
suspended particles to rise to the surface of a tank
where  they can  be collected  and  removed.
Dissolved Air Flotation (DAF) is one  of several
flotation techniques employed in the treatment of
oily wastewater.   DAF is  commonly used to
extract free and dispersed oil and grease from oily
wastewater.

               CAPITAL COSTS
    EPA developed capital cost estimates for
dissolved air  flotation systems  for the oils
subcategory Options 8  and 9. EPA  based the
capital cost estimates  for  the  DAF units on'
vendor's quotations. EPA assigned facilities with
DAF units currently in-place no capital costs.
For facilities with no DAF treatment in-place, the
DAF system consists of a feed unit, a chemical
addition mix tank, and a flotation tank.  EPA also
included a sludge filtration/dewatering  unit. EPA
developed capital cost estimates for a series of
flow rates ranging from 25 gpm (0.036 MOD) to
1000 gpm (1.44 MOD). EPA was  unable to
obtain costs estimates for units with flows below
25 gallons per minute since manufacturers do not
sell systems smaller than those designed for flows
below 25 gallons per minute.
      The  current DAF system capital  cost
estimates include a sludge filtration/dewatering
unit For facilities which do not have a DAF unit
in-place, but have other treatment systems that
produce sludge (i.e. chemical precipitation and/or
biological treatment), EPA assumed that the
existing sludge filtration unit could accommodate
the additional sludge produced by the  DAF unit.
For these facilities, EPA did not include sludge
filtration/dewatering costs  in the capital cost
estimates. EPA refers to the capital cost equation
for these facilities as "modified" DAF costs. The
resulting total capital cost equations for the DAF
and modified DAF  treatment  systems  are
presented in Table 11-17 at the end  of this
section.
     Because the smallest design capacity for
DAF systems  that EPA could  obtain  from
vendors is 25  gpm and since  more than 75
percent of the oils subcategory facilities have
flow rates lower than 25 gpm, EPA assumed that
only facilities with flow rates above 20 gpm
would operate their DAF systems everyday (i.e.
five days per week). EPA assumed that  the rest
of the facilities could hold their wastewater and
run their DAF systems from one to four days per
week depending on their flowrate. Facilities that
are not operating their DAF treatment systems
everyday would need to install a holding tank to
hold  their  wastewater  until  treatment.
Therefore, for facilities which do not currently
have DAF treatment in place and which have flow
rates less than  20  gallons per  minute, EPA
additionally included costs for a holding tank. For
these facilities, EPA based capital costs on a
combination of DAF  cosls (or modified DAF
costs) and holding tank costs. Table 11-16A lists
the capacity of the holding tank costed for various
flowrates.
          Table 11-16A. Estimate Holding Tank
                        Capacities for DAF Systems
Flowrate Holding Tank Capacity
(GPM) (gallons)
<5
5-10
10-15
15-20
>20
7,200
14,400
21,600
28,800
none
          The resulting capital cost equation for the holding
          tank associated with the DAF and modified DAF
          systems is presented in Table 11-17 at the end of
          this section.
                                           11-22

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             of Treatment XecKnolosies
Development Document for the CWTPoint Source Category
        CHEMCAt USAGE AND LABOR
            REQUIREMENT COSTS
    EPA  estimated  the  labor  requirements
associated with the model technology at four
hours per day for the small systems to eight hours
per day for the large systems, which is based on
the average  of the Oils Options 8 and 9 model
facilities. EPA used the same labor estimate for
DAF and "modified" DAF systems.
    As discussed in the capital cost section, EPA
has assumed that facilities with flow rates below
20   gpm  will  not operate the  DAF  daily.
Therefore, for these lower flow rate facilities,
EPA only included labor to operate the DAF (or
"modified" DAF) systems for the days the system
will be operational.  Table 11-16B lists the
number of days per week EPA assumed  these
lower flow facilities would operate their  DAF
systems-
Table  11-16B.   Estimate Labor  Requirements
                for DAF Systems
Flowrate Labor Requirements
(GPM) , (days/week)
<5
5-10
10-15
15-20
>20
1
2
3
4
5
       As detailed earlier, however, EPA also
 assumed that facilities with flow rates below 20
 gpm,  would  also  operate  a holding  tank.
 Therefore, for facilities with flow rates below 20
 gallons per minute, EPA included additional labor
 to operate the holding tank.
     EPA calculated chemical cost estimates for
 DAF  and "modified"  DAF systems based on
 additions of aluminum sulfate, caustic soda, and
 polymer. EPA costed for facilities to add 550
 mg/L alum, 335 mg/L polymer and 1680 mg/L of
       NaOH.   EPA also included  costs for perlite
       addition at  0.25 Ibs per Ib of dry solids for
       sludge conditioning and  sludge  dewatering
       operations  (for  DAF,  not "modified" DAF
       systems). EPA based the chemical additions on
       information gathered from literature, the database
       for the proposed Industrial Laundries Industry
       guidelines and standards, and sampled facilities.
           For a special set of facilitiesreferred to as
       "group 5 facilities" in the  oils subcategory
       current performance modeling estimates  EPA
       estimated the  chemical additions at 760 mg/L
       alum, 460 mg/L polymer, and 2300 mg/L NaOH.
       EPA  costed  these  facilities  for  additional
       chemicals because the  concentration of metal
       analytes assigned to the group 5 facilities was
       significantly higher than the metal concentrations
       assigned to the facilities in the other modeling
       groups (See Chapter 12).  Hence, it would be
       necessary to  use larger dosages of flocculent
       chemicals  to  remove  the  higher  metals
       concentrations associated with these group  5
       facilities.  Therefore, in addition to the four O&M
       equations developed for DAF and modified DAF
       systems with flowrates above and below 20 gpm,
       EPA additionally developed four O&M equations
       for these group 5 facilities
           Finally, similar to  the  labor requirements
       shown in table  11-16B, EPA based chemical
       usage cost estimates for the DAF and modified
       DAF systems assuming five days per week
       operation for facilities with flowrates greater than
       20 gpm and from one to four days per week for
       facilities with flowrates of 5 to 20 gpm.
           The eight equations relating the various types
       of O&M costs developed for DAF treatment for
       facilities with no  DAF treatment in-place are
       presented in  Table 11-17  at the  end of this
       section.
           For  facilities with DAF treatment in-place,
       EPA estimated  O&M upgrade costs.  These
       facilities  would  need  to  improve  pollutant
       removals from    their current DAF current
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Chapter 11 Cost of Treatment Technologies
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performance concentrations to the Oils Option 8
and Option 9 long-term averages. As detailed in
Chapter  12,  EPA  does  not  have  current
performance concentration data for the majority
of the oils facilities with DAF treatment in-place.
EPA does, however, have seven data sets which
represent effluent concentrations from emulsion
breaking/gravity separation. While the pollutant
concentrations in wastewater exiting emulsion
breaking/gravity separation treatment are higher
(in  some  cases, considerably higher) than the
pollutant concentrations  in wastewater exiting
DAF treatment, EPA has, nevertheless, used the
emulsion breaking/gravity separation data sets to
estimate DAF upgrade costs.  For each of the
seven emulsion breaking/gravity separation data
sets, EPA calculated  the percent  difference
between these concentrations and the Option 8
and Option 9 long-term averages. The median of
these seven calculated percentages is 25 percent.
    Therefore, EPA estimated the energy, labor,
and chemical cost components of the  O&M
upgrade cost as 25 percent of the full O&M cost
of anew system. EPA assumed that maintenance,
and taxes and insurance would be zero since they
are functions of the capital cost (that is, there is
no capital cost for the upgrade). EPA developed
two separate  O&M upgrade cost equations for
facilities which currently have DAF treatment in
place  one for facilities with flowrates up to 20
gpm and one for facilities with flow rates greater
than 20 gpm.  Similarly, EPA developed two
separate O&M  upgrade  equations  one for
facilities which currently have DAF treatment in-
place and were assigned Group 5 concentrations
in the first step of EPA's current performance
modeling procedure and one for facilities which
currently have DAF treatment in-place and were
assigned concentrations from one of the other six
groups  in the  first step  of  EPA's  current
performance  modeling  procedure.  The  four
equations representing O&M upgrade costs for
facilities  with  DAF treatment  in-place  are
       presented in Table 11-17.
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Chapter 11 Cost of Treatment Technologies
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Table 11-17.  Cost Equations for Dissolved Air Flotation (DAF) in Oils Options 8 and9
Description
Equation
                                            Recommended Flow
                                            Rate Range (MOD)
 Total capital cost for DAF
 Total capital cost for modified DAF
 Holding tank capital cost for DAF and
 modified DAF'
 O&M cost for DAF with flowrate above
 20gpm
 O&M cost for modified DAF with
 flowrate above 20 gpm
 O&M cost for DAF with flowrate below
 20 gpm
 O&M cost for modified DAF with
 flowrate below 20 gpm
 O&M cost for group 5, DAF with flowrate
 above 20 gpm
 O&M cost for group 5, modified DAF
 with flowrate above 20 gpm
 O&M cost for group 5, DAF with flowrate
 below 20 gpm
 O&M cost for group 5, modified DAF
 with flowrate below 20 gpm
 O&M upgrade for DAF with flowrate
 below 20 gpm
 O&M upgrade for DAF with flowrate
 above 20 gpm
 O&M upgrade for group 5, DAF with
 flowrate below. 20 gpm
 O&M upgrade for group 5, DAF with
 flowrate above 20 gpm
 Land required for holding tank'
 Land required for DAF and modified DAF
ln(Yl) = 13.9518 + 0.294451n(X) - 0.12049(ln(X))2
ln(Yl) = 13.509 + 0.294451n(X) - 0.12049(ln(X))2
ln(Yl) = 13.4616 + 0.54421m(X) + 0.00003(ln(X))2

        14.5532 + 0.964951n(X) + 0.01219(ln(X))2

        14.5396 + 0.976291n(X) + 0.0145 l(ln(X))2

        21.2446 + 4.148231n(X) + 0.36585(ln(X))2

        21.2005 + 4.074491n(X) + 0.34557(ln(X))2

        14.8255 + 0.97411n(X) + 0.01005(ln(X))2

        14.8151 + 0.982861n(X) + 0.01176(ln(X))2

        21.8136 + 4.252391n(X) + 0.36592(ln(X))2

        21.6503 + 4.119391n(X) + 0.33896(ln(X))2

        19.0459 + 3.55881n(X) + 0.25553(m(X))2

        13.1281 + 0.997781n(X) + 0.01892(ln(X))2

        19.2932 + 3.509231n(X) + 0.23946(ln(X))2
ln(Y2)

In(Y2)

ln(Y2)

ln(Y2)

ln(Y2)

m(Y2)

ln(Y2)

ln(Y2)

ln(Y2)

ln(Y2)

ln(Y2)

ln(Y2)
      = 13.4098 + 0.999251n(X) + 0.01496(ln(X))2
ln(Y3) = -1.5772 + 0.359551n(X) + 0.02013(ln(X))2
ln(Y3) = -0.5107 + 0.512171n(X) - 0.01892(ln(X))2
0.036 to 1.44
0.036 to 1.44
5.0 E-4 to 0.05

0.036 to 1.44

0.036 to 1.44

7.2 E -3 to 0.029

7.2 E-3 to 0.029

0.036 to 1.44

0.036 to 1.44

7.2 E-3 to 0.029

7.2 E -3 to 0.029

7.2 E -3 to 0.029

0.036 to 1.44

7.2 E -3 to 0.029

0.036 to 1.44

5.0 E-4 to 0.05
0.036 to 1.44
 Yl = Capital Costs (1989 $)
 Y2 = Operation and Maintenance Costs (1989 $ /year)
 Y3 = Land Requirement (Acres)
 X = Flow Rate (million gallons per day)
 'Only facilities with flow rates below 20 gpm receive holding tank costs.
 BIOLOGICAL WASTEWATER
 TREATMENT TECHNOLOGY COSTS         11.3
 Sequencing Batch Reactors            11.3.1

     A sequencing  batch  reactor (SBR)  is  a
 suspended growth system in which wastewater is
 mixed with retained biological floe in an aeration
 basin. SBR's are unique in that a single tank acts
 as an equalization tank, an aeration tank, and a
 clarifier.
                     The SBR  system costed by EPA for the
                 model technology consists of a SBR tank, sludge
                 handling equipment, feed system and controls,
                 pumps, piping, blowers, and valves. The design
                 parameters that EPA used for the SBR system
                 were the  average influent and effluent BOD5,
                 ammonia, and nitrate-nitrite concentrations. The
                 average influent concentrations were 4800 mg/L,
                 995 mg/L, and 46 mg/L for BOD5, ammonia, and
                 nitrate-nitrite, respectively.  The average effluent
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
BOD5,     ammonia,    and     nitrate-nitrite
concentrations used were 1,600 mg/1, 615 mg/1,
and 1.0 mg/1, respectively.  EPA obtained these
concentrations from the sampling data at the SBR
model facility.        EPA assumed that all
existing biological treatment systems in-place at
organics subcategory  facilities can meet  the
limitations of this proposal without incurring
cost.  This includes facilities which utilize  any
form  of biological treatment  not just SBRs.
Therefore, the costs presented here only apply to
facilities without biological treatment in-place.
EPA  did not develop  SBR upgrade costs for
either capital or O&M.
                            CAPITAL COSTS
                 EPA estimated the capital costs for the SBR
             systems  using vendor  quotes which include
             installation costs. The SBR. capital cost equation
             is presented in Table 11-18 at the end of this
             section.

                 OPERATION AND MAINTENANCE COSTS
                 The O&M costs for the SBR system include
             electricity, maintenance, labor, and taxes and
             insurance. No chemicals are utilized in the SBR
             system. EPA assumed the labor requirements for
             the SBR system to be four hours per day and
             based   electricity    costs   on    horsepower
             requirements.   EPA obtained the  labor and
             horsepower requirements  from vendors.   EPA
             estimated maintenance,  taxes, and insurance
             using the factors detailed in Table 11-2.  The
             SBR O&M cost equation is presented in Table
             11-18.
Table 11-18. Cost Equations for Sequencing Batch Reactors
Description
Equation
                         Recommended
                         Flow Rate
                         Range(MGD)
Capital cost for sequencing batch reactors
O&M cost for sequencing batch reactors
Land requirements
ln(Yl) = 15.707 + 0.5121n(X) + (K0022(ln(X))2
ln(Y2) = 13.139 + 0.5621n(X) + 0.020(ln(X))2
ln(Y3) = -0.531 + 0.9061n(X) + 0.072(ln(X))2
                          1.0 E -7 to 1.0
                          3.4 E -7 to 1.0
                          1.9 E-3 to 1.0
Yl - Capital Costs (1989 $)
Y2 - Operation and Maintenance Costs (1989 $ /year)
Y3 - Land Requirement (Acres)
X - Flow Rate (million gallons per day)
SLUDGE TREATMENT AND
DISPOSAL COSTS
Plate and Frame Pressure
Filtration  Sludge Stream
     11.4

    11.4.1
    Pressure filtration systems are used for the
removal of solids from waste streams.  This
section details sludge stream filtration which is
used to treat the solids removed by the clarifiers
in the metals options.
    The pressure filtration system costed by EPA
for sludge stream filtration consists of a plate and
frame filtration system.  The components of the
plate  and frame filtration system include: filter
plates, filter cloth, hydraulic pumps, pneumatic
booster pumps, control panel, connector pipes,
and a support platform.  For design purposes,
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Ckaoter 11 Cost of Treatment Technologies
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EPA assumed the sludge stream to consist of 80
percent liquid and 20 percent (200,000 mg/1)
solids. EPA additionally assumed the sludge
stream to be 20 percent of the total volume of
wastewater  treated.   EPA based these design
parameters on CWT Questionnaire 105.
    In costing for sludge stream treatment, if a
facility does not have sludge filtration systems in-
place, EPA estimated capital costs to add a plate
and frame pressure filtration system to their on-
site treatment train2. If a facilty's treatment train
includes more than one clarification step in its
treatment train (such as for Metals Option 3),'
EPA only costedthe facility for a single plate and
frame filtration system.  EPA assumed one plate
and frame filtration  system  could be  used to
process  the sludge  from multiple  clarifiers.
Likewise,  if:a  facility already had a sludge
filtration system in-place, EPA assumed that the
in-place system would be sufficient and did not
estimate any sludge  filtration capital costs for
these facilities.

               CAPITAL COSTS
    EPA developed the capital cost equation for
plate  and frame sludge filtration  by  adding
installation, engineering, and contingency costs to
vendors' equipment cost estimates. EPA used the
same capital cost equation for the plate and frame
sludge filtration system  for  all  of the metals
options.  The plate and frame sludge filtration
system capital cost equation is presented in Table
 11-19.

         2If a facility only had to be costed for a
plate and frame pressure filtration system to process
the sludge produced during the tertiary chemical
precipitation and clarifications steps of metals
 Option 3, EPA did not cost the facility for a plate
 and frame pressure filtration system. Likewise, EPA
 assumed no O&M costs associated with the
 treatment of sludge from the tertiary chemical
 precipitation and clarification steps in Metals Option
 3. EPA assumed that the total suspended solids
 concentration at this point is so low that sludge
 stream filtration is unnecessary.
           OPERATION AND MAINTENANCE COSTS
                  METALS OPTION 2 AND 3
           The operation and maintenance costs  for
       metals option 2 and 3 plate and frame sludge
       filtration   consist   of   labor,    electricity,
       maintenance,  and taxes  and insurance.   EPA  .
       approximated the labor requirements for the plate
       .and frame sludge filtration system to be thirty
       minutes per batch based on the Metals Option 2
       and 3 model facility. Because no chemicals are
       used with the plate and frame sludge filtration
       units, EPA did not include costs for chemicals.
       EPA estimated electricity, maintenance, and taxes
       and irisurance using the factors listed in Table 11-
       2. The resulting plate and frame sludge filtration
       O&M cost equation is listed in Table 11-19.
           For facilities which already have a sludge
       filtration system in-place, EPA included plate and
       frame filtration O&M upgrade costs. Since the
       sludge generated from the secondary precipitation
       and clarification steps in metals option 2 and 3 is
       the sludge which requires treatment for these
       options, these facilities would  be required to
       improve pollutant removals from their secondary
       precipitation current performance concentrations
       to the long term averages for Metals Options 2.
       Therefore, EPA calculated the percent difference
       between   secondary   precipitation   current
       performance and the Metals Option 2 long-term
       averages. EPA determined this percentage to be
       an increase of three percent.
           As such, for facilities  which currently have
       sludge filtration systems  in place, for  metals
       option 2 and 3, EPA included an O&M upgrade
        cost which is three percent of the O&M costs of
        a new system (except for taxes and insurance,
       which  are a function of the capital cost). The
        O&M upgrade cost equation for sludge filtration
        in Metals Option 2 and Option 3 is presented in
        Table 11.19.

            OPERATION AND MAINTENANCE COSTS
                      METALS OPTION 4
            The  operation and maintenance costs  for
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
metals option 4 consists  of labor,   chemical
usage,  electricity,   maintenance,  taxes,  and
insurance, and filter cake disposal.  The O&M
plate  and  frame   sludge  filtration   costing
methodology For Metals Option 4 is very similar
to the one discussed previously for Metals Option
2  and 3.   The primary  differences  in the
methodologies are the estimation of labor, the
inclusion of filter cakedisposal,  and the O&M
upgrade methodology.
    EPA approximated the labor requirement for
Metals Option 4 plate and frame sludge filtration
systems at 2 to 8  hours per day depending on the
               size of the system.  As was the case for metals
               option 2 and 3, no chemicals are used in the plate
               and frame sludge  filtration  units  for  metals
               Option  4,  and EPA  estimated  electricity,
               maintenance and taxes and insurance  using the
               factors listed in Table 11-2. EPA also included
               filter cake disposal costs at $0.74 per  gallon of
               filter cake. A detailed discussion of the basis for
               the  filter cake disposal costs is presented in
               Section 11.4.2.  The O&M cost equation for
               sludge filtration for Metals Option 4 is presented
               in Table 11-19.
Table 11-19.  Cost Equations for Plate and Frame Sludge Filtration in Metals Option 2,3 and 4
Description
Equation
Recommended Flow
Rate Range (MOD)
Capital costs for plate and fiame sludge     ln(Yl) = 14.827 + 1.0871n(X) + 0.0050(ln(X))2    2.0 E -5 to 1.0
filtration
O&M costs for sludge filtration for Metals  ln(Y2) = 12.239 + 0.3881n(X) + 0.016(ln(X))2     2.0 E -5 to 1.0
Option 2 and 3 u
O&M costs for sludge filtration for Metals  ln(Y2)= 15.9321 + 1.1771n(X) + 0.04697(ln(X))2 1.0E-5to 1.0
Option 44
O&M upgrade costs for sludge filtration for ln(Y2) = 8.499 + 0.33 lln(X) + 0.013(ln(X))2      2.0 E -5 to 1.0
Metals Option 2,3J'3
O&M upgrade cost for sludge filtration for  ln(Y2)= 12.014+ 1.178461n(X) + 0.050(ln(X))2  1.0E-5to 1.0
Metals Option 4*
Land requirements for sludge filtration     ln(Y3) = -1.971 + 0.2811n(X) + 0.018(ln(X))2     1.8 E -3 to 1.0

Yl = Capital Costs (1989 $)
Y2 - Operation and Maintenance Costs (1989 $ /year)
Y3 - Land Requirement (Acres)
X ~ Flow Rate (million gallons per day)
^Following secondary chemical precipitation/clarification only. EPA assumed the sludge generated from tertiary
precipitation/clarification would not produce a significant quantity of sludge.
*This equation does not include filter cake disposal costs.
''This equation includes filter cake disposal costs.
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Chapter 11 Cost of Treatment Technologies
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    For facilities which already have a sludge
filtration system in-place, EPA included sludge
stream filtration O&M upgrade costs. For Metals
Option 4, EPA included these O&M upgrade
costs for processing the sludge generated from
the primary precipitation and clarification steps3.
These facilities would need to improve pollutant
removals from their primary precipitation current
performance concentrations to Metals Option 4
(Sample Point-03) concentrations. This sample
point represents the  effluent from the liquid-
solids separation unit following primary chemical
precipitation at the  Metals Option  4 model
facility.  Therefore, EPA calculated the percent
difference between primary precipitation current
performance concentrations and Metals Option 4
(Sample  Point  03)   concentrations.    EPA
determined that there was an increase of two
percent.
    As such, for facilities which currently have
sludge filtration systems in place,  for metals
option 4, EPA included an O&M cost upgrade of
two percent of the total O&M costs (except for
taxes and insurance, which are a function of the
capital cost). The O&M upgrade cost equation
for  sludge  filtration  for  Metals  Option  is
presented in Table 11-19.
Filter Cake Disposal
11.4.2
    The liquid stream and sludge stream pressure
filtration  systems presented in Sections 11.2.3
and 11.4.1, respectively,  generate a filter cake
residual.  There is an annual O&M cost that is
associated with the disposal of this residual.  This
cost must be added to the pressure filtration
equipment O&M costs to arrive at the total O&M
         3 EPA did not include O&M upgrade costs
 for the sludge generated from the secondary
 precipitation and clarification step (direct
 dischargers only).
costs for pressure filtration operation4.
    To  determine the cost of transporting and
disposing filter cake to an off-site facility, EPA
performed  an   analysis  on   a  subset  of
questionnaire   respondents   in   the   WTI
Questionnaire response database.  This subset
consists of metals subcategory facilities that are
direct  and/or  indirect  dischargers  and  that
provided  information  on contract haul  and
disposal cost to hazardous (Subtitle C) and non-
hazardous (Subtitle D) landfills. From this set of
responses, EPA tabulated two sets of costs 
those reported for Subtitle C contract haul and
disposal  and those reported for Subtitle  D
contract haul and disposal, the reported costs for
both the  Subtitle C and Subtitle D  contract
haul/disposal. EPA then edited this information
by excluding data that was incomplete or that was
not separated by RCRA classification.
    EPA used the reported costs information in
this data set to determine the median cost for both
the Subtitle C and Subtitle D disposal options,
and then calculated the weighted average of these
median costs.  The average was weighted to
reflect the ratio of hazardous (67 percent) to
nonhazardous (33 percent) waste receipts at these
Metals Subcategory facilities. The final disposal
cost is $0.74 per gallon of filter cake.
    EPA  calculated a single disposal cost for
filter cake  using  both hazardous and  non-
hazardous landfilling costs. Certain facilities will
incur costs, however, that, in reality, are higher
and others will incur costs  that, in reality, are
lower.    Thus,  some  low  revenue metals
subcategory   facilities  that  generate  non-
hazardous sludge may show a higher economic
burden than is representative. On the other hand,
some low revenue metals subcategory facilities
that generate hazardous sludge may show a lower
                    4Note that these costs have already been
            included in the O&M equation for plate and frame
            sludge filtration for Metals Option 4.
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Chanter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
economic burden than is representative. EPA has
concluded that in the end, these over- and under
estimates  will  balance  out  to   provide  a
representative cost across the industry.
    The O&M cost equation for  filter cake
disposal for Metals Option 2 and Option 3 is
presented  in Table  11-20.     Table  11-20
additionally presents an O&M upgrade for filter
cake disposal resulting from Metals Option 2 and
           Option 3 for facilities that already generate filter
           cake as part of their operation.
               This upgrade is 3 percent of the cost of the
           O&M upgrade for facilities that do not already
           generate filter cake as a part of their operation.
           EPA used 3 percent because this was the same
           percentage calculated for plate and frame sludge
           filtration for these same options.
Table 11-20. Cost Equations for Filter Cake Disposal for Metals Options 2 and 31
Description
Equation
                       Recommended Flow
                       Rate Range (GPM)
O&M cost for filter cake disposal
O&M upgrade for filter cake disposal
Z = 0.109169 + 7,695,499.8(X)
Z = 0.101 186 + 230,879.8(X)
1.0 E -6 to 1.0
1.0 E -6 to 1.0
Z  Filter Cake Disposal Cost (1989 $ / year)
X  Flow Rate (million gallons per day)
'Filter cake disposal costs for Metals Option 4 are included in the sludge filtration equations.
ADDITIONAL COSTS
Retrofit Costs
  11.5
 11.5.1
    EPA assigned costs to the CWT Industry on
both an option- and facility-specific basis. The
option-specific approach estimated compliance
cost  for  a sequence of individual treatment
technologies,  corresponding to  a  particular
regulatory option, for a subset of facilities defined
as  belonging to that regulatory subcategory.
Within the costing of a specific regulatory option,
EPA  assigned treatment technology costs on a
facility-specific  basis  depending  upon  the
technologies determined to be currently in-place
at the facility.
    Once  EPA  determined that a treatment
technology cost should be assigned to a particular
facility, EPA considered two scenarios. The first
was the installation of a new individual treatment
technology as a part of a new treatment train. The
full capital costs presented in Subsections 11.2
through  11.4 of this document apply to  this
 scenario.    The  second  scenario  was   the
 installation of a  new  individual  treatment
 technology which would have to be integrated
 into an existing in-place treatment train.  For
 these facilities, EPA applied retrofit costs. These
. retrofit costs  cover such items as piping and
 structural modifications which would be required
 in   an  existing   piece  of equipment   to
 accommodate the installation of a new piece of
 equipment prior to or within an existing treatment
 train.
     For all facilities which received retrofit costs,
 EPA added a retrofit factor of 20 percent of the
 total  capital  cost of the  newly-installed  or
 upgraded treatment technology unit that would
 need to be integrated into an existing treatment
 train. These costs are in addition to the specific
 treatment technology capital costs calculated with
 the technology specific equations described in
 earlier sections.
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Chapter 11 Cost of Treatment Technologies
   Development Document for the CWT Point Source Category
Monitoring Costs
11.5.2
    CWT  facilities  that  discharge  process
wastewater directly to a  receiving  stream  or
indirectly to a POTW will have monitoring costs.
EPA regulations require both direct discharge
with  NPDES permits and indirect dischargers
subject to categorical pretreatment standards to
monitor their effluent.
    EPA used the following generalizations to
estimate the CWT monitoring costs:

1.  EPA included analytical cost for parameters
    at each subcategory as follows:

     TSS, O&G, Cr+6, total  CN, and foil
      metals analyses for the metals subcategory
      direct dischargers, and Cr+6, total CN, and
      full  metals  analyses   for  the  metals
      subcategory indirect dischargers;
     TSS, O&G, and  foil metals  and semi-
      volatiles analyses'for the oils subcategory
      option 8 and 9 direct dischargers, and foil
      metals,   and  semi-volatiles  for  oils
      subcategory  options 8 and  9  indirect
      dischargers;
      TSS, O&G, and foil metals, volatiles and
      semi-volatiles  analyses  for  the  oils
      subcategory direct  dischargers,  and foil
      metals, volatiles,  and semi-volatiles  for
      oils subcategory option 8V and 9V indirect
      dischargers;
      TSS, BOD5,  O&G, 6 individual metals,
      volatiles, and semi-volatiles analyses for
      the organics subcategory option 3 direct
      dischargers,  and   6  individual metals,
      volatiles, and semi-volatiles analyses for
      the organics subcategory option 3 indirect
      dischargers; and
      TSS, BOD5,  O&G, 6 individual metals,
      and  semi-volatiles   analyses   for   the
      organics  subcategory  option  4  direct
      dischargers, and 6 individual metals and
      semi-volatiles analyses  for the  organics
      subcategory option 4 indirect dischargers.

    EPA notes that these analytical costs may be
overstated  for  the  oils  and   the   organics
subcategories  because   EPA's   final  list of
pollutants proposed  for  regulation  for  these
subcategories do not include all  of the parameters
included above.

2.  The monitoring  frequencies are  listed in
    Table 11-21 and are as follows:
Table 11-21. Monitoring Frequency Requirements
Parameter
Conventional*
Total Cyanide and Cr+6
Metals
Semi- Volatile Organics
Volatile Organics
Monitoring Frequency (samples/month)
Metals Subcategory
20
20
20
~
Oils Subcategory
20
4
4
4**
Organics Subcategory
20
4
4
4**
     *Conventioiial monitoring for direct dischargers only.
     **Volatile organics monitoring for oils option 8V and 9V and organics option 3 only.
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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
3.  For facilities in multiple subcategories, EPA
    applied full multiple, subcategory-specific
    monitoring costs.

4.  EPA  based the monitoring costs on  the
    number of outfalls through which process
    wastewater is discharged.  EPA multiplied
    the cost for a single outfall by the number of
    outfalls to arrive at the total costs  for a
    facility.    For  facilities  for  which this
    information is not available, EPA assumed a
    single outfall per facility.

5.  EPA did not base monitoring costs on flow
    rate.

6.  EPA did not include sample collection costs
    (labor and equipment) and sample shipping
    costs, and

7.  The monitoring cost (based on frequency and
    analytical methods) are  incremental to  the
    monitoring currently being incurred by the
    CWT  Industry.  EPA  applied  credit  to
    facilities for current monitoring-in-place
    (MP). For facilities where actual monitoring
    frequencies are unknown, EPA  estimated
    monitoring  frequencies  based  on  other
    subcategory facilities with known monitoring
    frequencies.

    The cost of the analyses needed to determine
compliance for the  CWT pollutants are shown
below in Table 11-22.  EPA obtained these costs
from actual quotes  given  by  vendors and
converted to  1989 dollars  using the ENR's
Construction Cost Index.
Table 11-22. Analytical Cost Estimates

Analyses
Cost
($1989)
BOD5                                $20
TSS                                 $10
O&G                                $32
Cr+6                                $20
Total CN                             $30
Metals:                              $335
   Total (27 Metals)                   $335
   Per Metal1                          $35
Volatile Organics (method 1(524)2        $285
Semi-volatile Organics (method 1625)2   $615

'For 10 or more metals, use the foil metals analysis
cost of $335.

2There is no incremental cost per compound for
methods 1624 and 1625 (although there may be a
slight savings if the entire scan does not have to be
reported). Use the foil method cost, regardless of
the actual number of constituent parameters.
required.
RCRA Permit Modification Costs
  11.5.3
    Respondents to the WTI Questionnaire who
indicated that their RCRA Part B permits were
modified were asked to report  the following
information pertaining to the: cost of obtaining the
modification:

   Legal fees;
   Administrative costs;
   Public relations costs;
   Other costs; and
   Total costs.
                                                    EPA also requested the reason for the permit
                                                modification. Table 11-23 lists the RCRA permit
                                                modification costs reported for installation of new
                                                units,  installation  of  new technology,  and
                                                modifications to existing equipment. As shown,
                                                the average cost for these permit modifications is
                                                $31,400.   EPA  anticipates that many CWT
                                                facilities with RCRA Part B  permits  will be
                                           11-32

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Civsoter 11 Cost oTreatrtvent Technologies
   Development Document for the CWTPoint Source Category
required to modify their permits to include the
upgrade  of existing equipment  and/or the
installation of new treatment technologies to
          achieve the proposed CWT effluent limitations
          and standards.   Therefore,  for  all RCRA B
          facilities, EPA additionally included a one-time
          cost of $31,400 to modify their permit.
 Table 11-23. RCRA Permit Modification Costs Reported in WTI Questionnaire
Modification
New Units
New Technology
Modify Existing
Equipment
Average
QID
081
255
081
090
402
-
Year
1990
1990
1990
1990
1991
-
Total Cost
(reported $)
26,000
7,000
82,000
6,300,000*
14,080
-
Total Cost
(1989 $)
25,357
6,827
79,793
6,144,231*
13,440
31,400
    This cost includes equipment and installation costs; no cost breakdown is given.
    Therefore, this data was not used in calculating the average cost.
 Land Costs
11.5.4
    An  important  factor in the calculation of
 treatment technology costs is the value of the land
 needed for the installation of the technology. To
 determine the amount of land required for costing
 purposes, EPA calculated the land requirements
 for each treatment technology for the range of
 system sizes. EPA fit these land requirements to
 a curve and  calculated land  requirements, in
 acres, for every treatment system costed. EPA
 then multiplied the individual land requirements
 by the corresponding state land cost estimates to
 obtain facility-specific cost estimates.
    EPA used different land cost estimates for
 each state rather than a single nationwide average
 since land costs may  vary widely across the
 country. To!estimate land costs for each state,
 EPA obtained average land costs for suburban
 sites for each  state from the 1990  Guide to
 Industrial and Real Estate Office Markets survey.
 EPA based these land costs  on "unimproved
 sites" since, according to the survey, they are the
 most desirable.
     The survey additionally provides land costs
 broken down by size ranges. These are zero to 10
 acres, 10 to 100 acres, and greater than 100 acres.
 Since CWT facilities fall into all three size ranges
 (based on responses to the WTI Questionnaire),
 EPA averaged the three size-specific land costs
. for each state to arrive at the final land costs for
 each state.
     The  survey did  not provide land  cost
 estimates for Alaska, Idaho, Montana, North
 Dakota, Rhode  Island, South Dakota,  Utah,
 Vermont or West Virginia For these states, EPA
 used regional  averages of land costs.  EPA
 determined the states comprising each region also
 based on the aforementioned survey since the
 survey categorizes the states  by geographical
 region (northeast, north central, south, and west).
 In estimating the regional average  costs for the
                                             11-33

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
western region, EPA did not include Hawaii since
Hawaii's  land  cost is  high and would have
skewed the regional average.
    Table 11-24 lists the land cost per acre for
each state. As Table 11-24 indicates, the least
expensive state is Kansas with  a land  cost of
$7,042 per acre and the most expensive state is
Hawaii with a land cost of $1,089,000 per acre.
    Table 11-24. State Land Costs for the CWT Industry Cost Exercise
State Land Cost per Acre (1989$) State Land Cost per Acre (1989$)
Alabama
Alaska*
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho*
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana*
22,773
81,105
46,101
15,899
300,927
43,560
54,232
54,450
63,273
72,600
1,089,000
81,105
36,300
21,078
8,954
7,042
29,040
56,628
19,602
112,530
59,895
13,649
21,054
13,068
39,930
81,105
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota*
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island*
South Carolina
South Dakota*
Tennessee
Texas
Utah*
Vermont*
Virginia
Washington
West Virginia*
Wisconsin
Wyoming*
Washington DC

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

    * No data available for state, used regional average.
                                            11-34

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Chapter 11 Cost of Treatment Technologies
    Development Document for the CWTPoint Source Category
        EXAMPLE 11-1:

        Costing exercise for direct discharging metals subcategory facility with treatment in-place.

        Example Facility Information:

        Current Treatment In-Place:
        Primary Chemical Precipitation + Clarification + Plate and Frame Sludge Filtration

        Daily. Flow =   0.12196 MOD (Million Gallons/Day)
               [NOTE: Daily Flow = X in costing equations]

        Treatment Upgrades To Be Costed:
        Primary Chemical Precipitation Upgrade + Clarifier Upgrade + Sludge Filtration Upgrade

        Full Treatment Technologies To Be Costed:
        Secondary Chemical Precipitation + Secondary Clarification + Multimedia Filtration
                      Section 11.2.1.4
Section 1 1.2.2
Section 11.2.1.3

1
Primary
Chemical
Precipitation

i




^

Clar
\
>
>
iQgj. Secondary
/ Precipitation
>
f Secoi
\Clai
Section 11.2.2
r  \
f
idary
Lfierx1
t
Sludge Multimedia
Filter Filter
Section 11. 4. 1.1
>
Section 11.2.6
f >
f
          Figure 11-1. Metals Option 4 Model Facility Diagram
                                               11-35

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Chapter 1 1 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
        EXAMPLE 11-1. CONTINUED:

        Capital Costs:

           Primary chemical precipitation upgrade, from Table 1 1-7, Section 1 1 .2. 1 .4.
            The maximum size holding tank to be costed for a primary chemical precip.
            upgrade is 0.005 MOD. In addition, there is a 20% retrofit cost for the upgrade.

            ln(Yl) = 10.671 - 0.083*ln(X) - 0.032*(ln(X))2
                   = 10.671 - 0.083 *ln(0.005) - 0.032*(ln(0.005))2
                   = 10.212
        .-.   Yl    = $27,240.25 * 1.2 = $32,688.30 *

           Clarification capital cost upgrade, following primary precipitation = $0.00 +

           Sludge filtration capital cost upgrade = $0 .00 

           Secondary chemical precipitation, full capital costs, from Table 11-8, Section 1 1 .2. 1 .5

            ln(Yl) = 13.829 + 0.544*ln(X) + 4.96E-6*(ln(X))2
                   = 12.68441
        .-.   Yl    =$322,678.63*

           Clarification, following secondary chemical precipitation,  from Table 11-9, Section
            11.2.2.2

            ln(Yl) = 1 1 .552 + 0.409*ln(X) + 0.020*(ln(X))2
                   = 10.77998
        .-.   Yl    = $48,049.17 

           Multi-media filtration capital costs, from Table 11-13, Section 11.2.5

            ln(Yl) = 12.0126 + 0.48025*ln(X) + 0. 04623 *(ln(X))2
                   = 11.20679
        .-.   Yl    =$73,628.54*

           Total capital cost (TCC)

            TCC   =  (Individual Capital Costs)
        .-.   TCC   = $477,045 
                                               11-36

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Chaotet \ 1 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
        EXAMPLE 11-1. CONTINUED:
        Operation and Maintenance Costs:
           Primary chemical precip. O&M upgrade, from Table 11 -7, Section 11.2.1.4

            ln(Y2) = 11.4547 + 1.04337*ln(X) + 0.04575*(ln(X))2
                   = 11.4547 + 1.04337*ln(0.12196) + 0.04575*(ln(0.12196))2
                   = 9.46192
        .-.  Y2    = $12,860.60 

           Clarification O&M upgrade, following primary chemical precipitation, from Table 11-9,
            Section 11.2.2

            ln(Y2) = 6.81347 + 0.33149*ln(X) + 0.0242*(ln(X))2
                   = 6.22313
        .-.  Y2    = $504.28 4-

           Sludge filtration O&M upgrade, from Table 11-19, Section 11.4.1

            ln(Y2) = 12.014 + 1.17846*In(X) + 0.05026*(ln(X))2
                    = 9.75695
        /.  Y2    = $17,273.90 > (which includes filter cake disposal costs)

           Secondary chemical precip. O&M costs, from Table 11-8, Section 11.2.1.5

            ln(Y2)  = 12.076 + 0.63456*ln(X) + 0.03678*(ln(X))2
                    = 10.9037
        .-.  Y2     = $54,375.79 

           Clarification O&M costs, following secondary chemical precipitation, from Table 11-9,
            Section 11.2.2.2

            ln(Y2)  = 10.673 + 0.238*ln(X) + 0.013*(ln(X))2
                    = 10.22979
         .-.  Y2     =$27,716.56*

            Multimedia Filtration O&M Costs, from Table 11-13, Section 11.2.5

             ln(Y2)  = 11.5039 + 0.72458*ln(X) + 0.09535*(ln(X))2
                    = 10.40146
         .-.   Y2     = $32,907.65 
             Total Operation and Maintenance Cost (O&MTot)

             O&MTot =  (Individual O& M Costs)
             O&MTot = $145,640 
                                               11-37

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Chapter 11 Cost of Treatment Technologies      Development Document for the CWT Point Source Category


        EXAMPLE ll-l. CONTINUED:

        Land Requirements:

           Primary chemical precipitation upgrade land requirement associated with capital cost
            upgrade (Table 11-7, section 11.2.1.4).         The maximum size holding tank to be
            costed for a primary chemical precipitation upgrade is 0.005 MGD.

            ln(Y3)   = -2.866 - 0.0231n(X) - 0.006(ln(X))2
                    = -2.866 - 0.0231n(0.005) - 0.006(ln(0.005))2
                    = -2.913
        .'.   Y3     =  0.054 acre *

           Clarifier, following primary chemical precip., land requirement = 0.0 acre *

           Sludge filtration unit land requirement = 0.0 acre *

           Secondary chemical precipitation land requirement, from Table 11-8, Section 11.2.1.5

            ln(Y3)  = -1.15 + 0.449*ln(X) + 0.027*(ln(X))2
                    --1.975
        .-.   Y3     =0.139 acre*

           Clarification, following secondary chemical precipitation, land requirement, from Table 11-
            9, Section 11.2.2.2

            ln(Y3)  =-1.773+0.513*ln(X) + 0.046*(ln(X))2
                    = -2.6487
        .-.   Y3     =0.071 acre*

           Multimedia filtration land requirement, from Table 11-13,  Section 11.2.5

            ln(Y3)  = -2.6569 + 0.1937*ln(X) + 0.02496*(ln(X))2
                    = -2.95396
        .-.   Y3     =0.0521 acre*

           Total land requirement (TLR)

            TLR    =  (Individual Land Requirement)
        .-.   TLR    = 0.316 acre 
                                              11-38

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Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
        EXAMPLE 11-2:

        Costing  exercise for  a direct discharging oils subcategory facility with only emulsion
        breaking/gravity separation in-place.

        Example Facility Information:

        Current Treatment In-Place:
        Primary Emulsion Breaking/Gravity Separation
        Daily Flow =   0.0081 MOD (Million Gallons/Day) [= 5.63 gpm]
              [NOTE: Daily Flow = X in costing equations]

        Treatment Upgrades To Be Costed:
        None

        Full Treatment Technologies To Be Costed:
        Secondary Gravity Separation + Dissolved Air Flotation (DAF)
                             Section 11.2.8
>.

Secondary
Gravity
\Separadon/

/

>fc

Section 11.2.9
Dissolved Air
Flotation
Direct Discharge
>
"
          Figure 11-2. Treatment Diagram For Oils Option 9 Facility Improvements
                                              11-39

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Chanter 11 Cost of Treatment Technoloaies
Development Document for the CWTPoint Source Category
        EXAMPLE 11-2. CONTINUED:
        Capital Costs:
                Secondary gravity separation, from Table 11-15, Section 1 1 .2.7

                ln(Yl)  = 14.3209 + 0.38774*ln(X) - 0.01793*(ln(X))2
                        = 14.3209 - 0.38774*ln(0.0081) - 0.01793*(ln(0.0081))2
                        = 12.0377
                Yl     =$169,014.42*'

                Dissolved air flotation costs, from Table 11-17, Section 11.2.8

                ln(Yl)  = 13.9518 + 0.29445*ln(X) - 0.1 2049 *(ln(X))2
                        = 11.6415
                Yl     =$113,720.41*

                Holding tank for dissolved air flotation (flow < 20 gpm, hence holding tank is sized),
                from Table 11-17, Section 1 1 .2.8

                ln(Yl)  = 13.4616 + 0.54421*ln(X) + 0.00003*(ln(X))2
                        = 10.8414
                Yl     =$51,094.88*

                Total capital cost (TCC)

                TCC    =  (Individual Capital Costs)
                TCC    = $333,830 
                                              11-40

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Chapter 11 Cost of Treatment Technologies      Development Document for the CWT Point Source Category
        EXAMPLE 11-2. CONTINUED:

        Operation and Maintenance Costs:

               Secondary gravity separation, from Table 11-15, Section 11.2.7

                ln(Y2)  = 12.0759 + 0.4401*ln(X) + 0.01594*(ln(X))2
                        = 12.0759 + 0.4401*ln(0.0081) + 0.01594*(ln(0.0081))2
                        = 10.3261
                Y2     = $30,519.46 +

               Dissolved air flotation (flow < 20 gpm), from Table 11-17, Section 11.2.8

                ln(Y2)  = 21.2446 + 4.14823*ln(X) + 0.36585*(ln(X))2
                        = 9.7523
                Y2     = $17,193.12 

               Total Operation and Maintenance Cost (O&MTot)

                O&MTot =  (Individual O& M Costs)
                O&MTot =$47,713 
                                             11-41

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category


        EXAMPLE 11-2. CONTINUED:

        Land Requirements:

                Secondary gravity separation, Table 11-15, Section 11.2.7

                ln(Y3)  =-0.2869 + 0.31387*ln(X) + 0.01191*(ln(X))2
                        = -0.2869 + 0.31387*ln(0.0081) + 0.01191*(ln(0.0081))2
                        = -1.5222
                Y3      =0.218 acre*

                Dissolved air flotation (sized at 25 gpm, the minimum available), from Table 11-17,
                Section 11.2.8

                ln(Y3)  = -0.5107 + 0.51217*ln(X) - 0.01892*(ln(X))2
                        = -2.4224
                Y3      =0.089 acre*

                Holding tank, from Table 11-17, Section 11.2.8

                ln(Y3)  = -1.5772 + 0.35955*ln(X) + 0.02013*(ln(X))2
                        = -2.8419
                Y3      =0.058 acre*

                Total land requirement (TLR)

                TLR    =  (Individual Land Requirement)
                TLR    = 0.365 acre 
                                             11-42

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Chanter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
REFERENCES
                                                                                            11.6
Standard Methods for Examination of Water and Wastewater. 15* Edition, Washington, DC.

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

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

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

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

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

Organic Chemicals  and Plastics and Synthetic Fibers fOCPSF') Cost Document SAIC, 1987.

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

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

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

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

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

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

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

Development Document for the Proposed Effluent Limitations Guidelines and Standards for the Metal Products
and Machinery Phase 1 Point Source Category. U.S. Environmental Protection Agency, EPA 821-R-95-021, April
 1995.

Control and Treatment Technology for the Metal Finishing Industry. Sulfide Precipitation. Summary Report EPA
625/8-80-003, April 1980.
                                              11-43

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Chapter 11 Cost of Treatment Technologies     Development Document for the CWT Point Source Category
SUMMARY OF COST OF
TECHNOLOGY OPTIONS
  11.7
        This section summarizes the estimated
capital and annual O&M expenditures for CWT
facilities to achieve each of the proposed effluent
limitations and standards.  All cost estimates in
this section  are  expressed  in  terms of 1997
dollars.
          BPT Costs
                                      11.7.1
                 BPT costs apply to all CWT facilities
          that discharge wastewater  to  surface  waters
          (direct dischargers). Table 11-25 summarizes, by
          subcategory, the total capital expenditures  and
          annual O&M costs for implementing BPT.
Table 11-25. Cost of Implementing BPT Regulations [in 1997 dollars]
Subcategory Number of Facilities
Metals Treatment and Recovery
Oils Treatment and Recovery
Organics Treatment
Combined Regulatory Option
9
5
4
14
1 Total Capital Costs
3,069,500
931,600
75,600
4,076,700
Annual O&M Costs
1,532,100
176,700
59,600
1,768,500
'There are 14 direct dischargers.  Because some direct dischargers include operations  in more than one
subcategory, the sum of the facilities with operations in any one subcategory exceeds the total number of facilities.
        EPA notes that this BPT cost summary
does not include the additional capital costs of the
second clarifier that may.be associated with the
transferred  TSS limitations  for  the metals
subcategory.  EPA will re-visit its  BPT costs
estimates   for  this   subcategory   prior  to
promulgation.
BCT/BAT Costs
11.7.2
               The Agency estimated that there
would be no incremental cost of compliance for
implementing BCT/BAT, because the technology
used to develop
          BCT/BAT limitations is identical to BPT and the
          costs are included with BPT.
          PSES Costs
                                      11.7.3
         The  Agency  estimated the  cost for
implementing   PSES   applying,  the  same
assumptions and methodology used to estimate
cost of implementing BPT. The major difference
is that the PSES costs are applied to all CWT
facilities that discharge wastewater to a POTW
(indirect dischargers). Table 11-26 summarizes,
by subcategory, the capital expenditures  and
annual O&M costs for implementing PSES.
                                           11-44

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Chapter 11 Cost of Treatment Technologies
Development Document for the CWT Point Source Category
Table 11-26.  Cost of Implementing PSES Regulations [in of 1997 dollars]
Subcategory Number of Facilities2
Metals Treatment and Recovery
Oils Treatment and Recovery -
Organics Treatment
Combined Regulatory Option
41
123
14
147
Total Capital Costs
7,209,100
17,778,400
11,084,600
36,072,000
Annual O&M Costs
2,822,500
6,531,900
1,149,900
10,505,400
JThere are 147 indirect dischargers. Because some indirect dischargers include operations in more than one
subcategory, the sum of the facilities with operations in any one subcategory exceeds the total number of facilities.
                                               11-45

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                                                                             Chapter
                                                                                 12
 POLLUTANT LOADING AND  REMOVAL ESTIMATES
INTRODUCTION
12.1
     This  chapter presents  annual  pollutant
     loading and removal estimates for the CWT
industry associated with each of the subcategories
and regulatory options considered  by EPA in
developing the proposed effluent limitations and
pretreatment standards.   EPA estimated the
pollutant loadings  and removals from  CWT
facilities to evaluate the effectiveness of different
treatment technologies and to evaluate how costly
these regulatory  options were in terms  of
pollutant  removals.   EPA  also  used this
information in analyzing potential benefits from
the removal of pollutants discharged to surface
waters directly or indirectly through  publicly
owned treatment works (POTWs).      EPA
estimated  raw,  current,  and  post-compliance
pollutant loadings and pollutant removals for the
industry using data collected from the industry
throughout development of the proposed rule.
This assessment uses the following definitions for
raw,  current, and post-compliance  pollutant
loadings:
   Raw loadings - For the metals and organics
    subcategory,  raw loadings represent CWT
    waste receipts, that is, typically untreated
    wastewater as received from customers. For
    the oils subcategory, raw loadings represent
    the effluent from the initial processing of oil
    bearing, CWT waste receipts, that is, effluent
    from  emulsion  breaking  and/or  gravity
    separation.
   Current loadings   These  are the pollutant
    loadings  in  CWT  wastewater  that are
    currently being discharged to POTWs and
    surface waters. These loadings account for
    wastewater treatment currently in place at
    CWTs.
   Post-compliance loadings  These are the
    pollutant loadings in CWT wastewater that
    would be discharged to POTWs and surface
    waters if the proposed rule is promulgated.
    EPA calculated these loadings assuming that
    all CWTs would achieve treatment at least
    equivalent to that which may be achieved by
    employing the technology option selected as
    the basis of the limitations or standards.

    The following information is presented in this
chapter:
   Section 12.2 summarizes the  data sources
    used to estimate  pollutant loadings and
    removals;
    Section 12.3 discusses the methodology used
    to estimate current loadings;
   Section 12.4 discusses the methodology used
    to   estimate  post-compliance  pollutant
    loadings;
   Section 12.5 discusses the methodology used
    to estimate pollutant removals;
   Section 12.6 presents the pollutant loadings
    and removals for  each  regulatory option,
    including  current  and  post-compliance
    pollutant loadings.
        DATA SOURCES
                                      12.2
               As previously explained in Chapter 2,
        EPA primarily relied on three data sources to
        estimate  pollutant  loadings  and  removals:
        industry responses to the 1991 Waste Treatment
        Industry Questionnaire, industry responses to the
        Detailed   Monitoring   Questionnaire,   and
        wastewater sampling data collected  by EPA.
                                          12-1

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Chapter 12 Pollutant Loading and Removal Estimates
          Development Document for the CWT Point Source Category
Chapter 2 of this document discusses each of
these data sources in detail.
            Current Loadings Estimates for
            the Metals Subcategory
                                      12.3.1
METHODOLOGY USED TO DEVELOP
CURRENT LOADINGS ESTIMATES
12.3
        EPA calculates current loadings for a
specific facility from the effluent flow rate of the
facility and the concentration of pollutants in its
effluent obtained from effluent monitoring data.
EPA does not have data for every facility in the
database to calculate current loadings.  For some,
EPA has no effluent monitoring data, while for
others, EPA may have only limited monitoring
data for a few parameters.  In many cases, EPA
has effluent monitoring data, but the data do not
represent CWT wastewaters only. As discussed
previously, most CWT facilities commingle CWT
wastewaters with non-CWT wastewaters such as
industrial  wastestreams or stormwater prior to
monitoring for compliance. Most CWT facilities
with waste receipts in more than one subcategory
commingle   CWT   wastestreams   prior   to
monitoring  for performance.   Some  facility
supplied  data,  therefore,  is  insufficient  for
estimating current loadings.
        When possible, EPA determined current
loadings for an individual facility  based  on
information reported by that facility. For most
CWT facilities,  however, EPA had to develop
estimated current loadings.  EPA's methodology
differs depending on the subcategory of CWT
facilities and individual facility characteristics.
Factors that EPA took into account in estimating
current loadings include: 1) the analytical data
available   for  the   subcategory;    2)   the
characteristics of the facilities in the subcategory;
and 3) the facility's treatment train. For facilities
in  multiple  subcategories,  EPA  estimated
loadings for that portion of the wastestream in
each subcategory and subsequently added them
together.  The sections that follow discuss the
current  loadings  methodologies   for  each
subcategory.
        EPA calculated current loadings for the
metals  subcategory  facilities  by  assigning
pollutant concentrations based on the type of
treatment currently in-place at each facility. EPA
placed in-place treatment for this subcategory in.
one of five classes:
1) raw, or no metals treatment;
2)  primary  precipitation  with  solids-liquid
    separation;
3)  primary  precipitation  with  solids-liquid
    separation plus secondary precipitation with
    solids-liquid separation;
4)  primary  precipitation  with  solids-liquid
    separation plus secondary precipitation with
    solids-liquid separation followed by multi-
    media    filtration   (EPA   based   the
    BAT/BPT/PSES proposed limitations and
    standards  for  this subcategory  on this
    technology); and
5)  selective metals precipitation with  solids-
    liquid separation plus secondary precipitation
    with solids-liquid separation plus tertiary
    precipitation  with solids-liquid separation
    (EPA  based the NSPS/PSNS  proposed
    limitations   and   standards    on   this
    technology).

Table 12.1 shows the current loadings estimates
for each classification and the following five
sections (12.3.1.1 through  12.3.1.5) detail the
estimation procedure for each classification.
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Table 12.1.  Metals Subcategory Pollutant Concentration Profiles for Current Loadings
Pollutant of Concern
CONVENTIONALS
Oil and Grease 2
Total Suspended Solids (TSS)
PRIORITY METALS
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
NON-CONVENTIONAL METALS
Aluminum
Barium
Boron
Cobalt
Iridium
Iron
Lithium
Manganese
Molybdenum
Silicon
Strontium
Tin
Titanium
Vanadium
Yttrium
Zirconium
CLASSICAL PARAMETERS
Chemical Oxygen Demand (COD)
Hexavalent Chromium
Ammonia as N
Cyanide
Raw
Treatment
(ug/L)

685,300
27,957,052

116,714
1,790
44,629
1,186",645
1,736,413
211,044
300
374,739
328
1,105
461
978,167

378,955
941
153,726
25,809
51,231
588,910
114,438
26,157
48,403
284,693
7,605
1,337,924
795,623
38,570
96
1,477

13,963,394
1,923,560
216,097
12,285
BAT Selective
Primary Secondary Option Metals
Precipitation Precipitation Technology Precipitation
(ug/L) (ug/L) (ug/L) (ug/L)

143,160
840,000

7,998
84
21
387
448
393
50
2,787
514
91
26
3,900

5,580
N/A;
31,730
254
3,283
15,476
53,135
245
3,403
2,590
3,561
1,026
239
37
26
N/A'

10,628,000
4,114
120,790
763

93,348
833,266

768
280
63
671
800
356
6
1,968
433
70
240
3,550

27,422
221
32,131
200
3,500
8,018
976
2,195
2,690
1,238
1,223
552
45
85
48
762

4,537,778
361
89,997
1,910

56,279
113,197

170
143
45
1,177
581
117
1
1,070
347
23
N/A;
422

856
N/AJ
8,403
115
500
6,803
1,927
49
1,747
1,447
100
90
57
12
5
1,287

1,333,333
800
15,630
82

< 5,000
9,250

21
11
82
40
169
55
0
270
210
5
21
206

73 '
WA1
66,951
57
N/AJ
387
N/A'
12
528
356
N/AJ
28
4
11
5
N/AJ

108,802
43
9,123
N/A'
 'Concentration values for certain pollutants were not available for some classifications.
 2EPA determined that the oil and grease concentration listed for raw loadings includes data from a facility (4382)
 which commingles oils subcategory waste receipts with metals subcategory receipts. The recalculated raw loadings
 oil and grease concentration is 27,589 ug/L, after excluding the data from the facility 4382. EPA will incorporate
 this change into the overall loadings and removals calculations between proposal and promulgation.
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Chapter 12 Pollutant Loading and Removal Estimates
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Raw Loadings for the
Metals Subcategory                 12.3.1.1
     EPA classified metals subcategory facilities
with no chemical precipitation in the "raw" class
(even if they had other treatment in place, such as
activated carbon).  EPA assigned  the "raw"
current loadings estimates to three facilities in the
metals subcategory.  EPA based its estimates for
raw wastewaters on  data  from eight sample
points at five sampling episodes (refer to Table
12-2  for sample  episode  and  sample point
identifiers). The data from these episodes include
composite samples from continuous systems and
grab samples from  batch systems. In order to
compare and use continuous  and batch system
data interchangeably, EPA calculated a daily'
average value for the batch systems by averaging
sample measurements from  all batches for a
single day. Therefore, if the facility treated nine
batches during a four day
  sampling episode, EPA  calculated four daily
  averages for the episode. EPA incorporated non-
  detect measurements  at  the  sample-specific
  detection levels. The Agency averaged duplicate
  batch samples together first, and then included
  the  averaged  value  in  the  daily average
  calculation.
      Once EPA calculated daily averages  for the
  batch systems, EPA then averaged the batch daily
  averages  with the daily composite  values to
  obtain raw pollutant concentrations.   As an
  illustrative example, Table 12-2 shows the data
  used to obtain the raw wastewater estimation for
  aluminum: 378,955 ug/L. Table 12-2 shows that
  this  estimation comes  from twenty-nine daily
  averages (some  from continuous systems and
  some  from batch  systems)  from  fifty-nine
  analyses.  Raw wastewater estimations for other
  pollutants were calculated in a similar manner.
Table 12-2. Example of Metals Subcategory Influent Pollutant Concentration Calculations7
Sample Point
Episode 4378-01
Episode 4378-03
Episode 4055-01
Episode 1987-01
Episode 1987-02
Episode 4393-01
Episode 4382-07
Episode 4393-05
Raw Aluminum Daily Averages (ug/L)
389,338 189,223
2,080,000 2,090,000
31,800 838,275
839,000 792,000
577,500 53,400
3,730 29,400
84,400 139,000
72,400 3,765
3,128
745,000
260,000
859,000


171,000
6,150
8,376
91,700 130,000




145,000 330,000
15,900 11,200
# of measurements
23 (2 duplicate values)
1 1 (2 duplicate values)
5
3
3(1 duplicate value)
2(1 non-detect value)
6 (1 duplicate value)
6(1 duplicate and
1 non-detect value)
'The Raw Aluminum Concentration is 378,955 ug/L  the average of sample values in the table.
Primary Precipitation with Solids-
Liquid Separation Loadings          12.3.1.2
    EPA  estimated  pollutant concentrations
resulting from primary precipitation and solids-
liquid separation using data from EPA sampling
episodes   and  industry  supplied  effluent
monitoring data.  EPA  used data  from three
sampling episodes and one  facility's effluent
monitoring  data submissions to represent the
  current loadings for 32 of the metals subcategory
  facilities.   The  episodes used  are detailed
  monitoring questionnaire 613 (industry supplied
  effluent  monitoring data),. sample  point  16;
  episode 4382, sample point 12; episode  1987,
  sample point 3; and episode 4798, sample point
  3. The facility supplied effluent monitoring data
  was  collected as  grab  samples  from  batch
  systems. For each day, EPA averaged the batch
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Chanter 12 Pollutant Loading and Removal Estimates
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samples together to obtain a daily average.
Conversely, the EPA sampling episode data came
from continuous systems.  Regardless of the
sample type,  the analysis averaged the daily
average values from a facility together to give a
facility average, then combined the four facility
averages  to  give  a pollutant  concentration
average.  Table 12.1 shows the concentrations
representing primary precipitation for the relevant
pollutants of concern.

Secondary Precipitation with Solids-
Liquid Separation Loadings          12.3.1.3
    EPA estimated current loadings for facilities
with secondary chemical precipitation using data
from three  sampling points at three  separate
episodes.  These are episode 4393, sample point
13; episode 4382, sample point 12; and episode
4798, sample point  05  (which represents the
technology  basis  for  the  proposed  metals
subcategory BPT/BAT/PSES option). EPA then
averaged the facility average effluent values from
liquid-solids  separation  following  secondary
chemical precipitation to give concentrations for
the relevant pollutants of concern. Table 12-1
summarizes these average values.'

Technology Basis for the Proposed
BPT/BAT/PSES Option 4 Loadings   . 12.3.1.4
    EPA  used  the long-term averages  from
Metals Option 4  batch primary precipitation
with solids-liquid  separation  plus  secondary
precipitation   with  solids-liquid  separation
followed by multi-media filtration - to represent
current loadings at three facilities in the metals
subcategory:  The facility sampled by EPA that
employs   the   technology   basis   for  the
BPT/BAT/PSES Option, obviously, is assigned
its current loadings. EPA modeled the loadings
for two facilities that utilize tertiary precipitation
with the BPT/BAT/PSES option current loadings.
EPA  believes that facilities  utilizing tertiary
precipitation will not need to alter their system to
meet the proposed pretreatment  standards and
  limitations.    By  assigning current loadings
  estimates based on the Option 4 technology basis
  to  the  tertiary  systems,  EPA  may have
  overestimated current loadings at  these two
  facilities.' However, EPA does not estimate any
  post-compliance pollutant  reductions at these
  facilities.

  Selective Metals Precipitation (NSPS/
  PSNSProposed Option 3) Loadings  12.3.1.5
      Only one facility  in the metals subcategory
  utilizes selective  metals precipitation.  EPA
  sampled this facility during development of this
  rule.  Therefore, the current loadings pollutant
  concentrations for this facility are not estimates,
  but measured data.  Table  12.1 summarizes these
  pollutant concentrations.
   Current Loadings Estimates
   for the Oils Subcategory
12.3.2
      Based on questionnaire responses and site
  visits, EPA found that all facilities which treat
  oily  wastewaters, for which  EPA has  data,
  currently  employ emulsion  breaking and/or
  gravity separation. If emulsions are present in the
  incoming waste receipts, the facility first makes
  use of emulsion breaking.   If not, the waste
  receipts generally bypass emulsion breaking and
  .the facility processes the waste through a gravity
  separation step for gross separation of the water
  and the oil phase.  A facility may often follow up
  these pretreatment steps  by other wastewater
  treatment technologies. Therefore, EPA believes
  that, at a minimum, it may characterize current
  loadings  for oils subcategory discharges  by
  analyzing samples obtained from the effluent of
  emulsion breaking/gravity separation.
       EPA has seven data sets  which represent
  effluent   from   emulsion    breaking/gravity
  separation systems.  EPA collected these seven
  data sets during EPA  sampling  episodes  at
  various types of oily waste facilities.  Six of these
  seven data sets represent facilities that treat oily
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 Chapter 12 Pollutant Loading and Removal Estimates
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 wastewater and recover/process used oil.  One
 facility,  which primarily accepts bilge water,
 performs oily wastewater treatment only.  The '
 annual  volume of  treated  oily  wastewater
 discharged at these facilities ranges from 174,000
 gallons/year to 35 million gallons/year.  Two of
 the data sets represent facilities that only accept
 non-hazardous wastes, while the other five data
 sets represent facilities which are permitted by
 RCRA to additionally accept hazardous wastes.
    For  each pollutant of concern, each of the
 seven emulsion breaking/gravity separation data
 sets contains the mean concentration of the data
 collected over  the sampling  episode (usually a
 duration  of .five  days). This mean includes
 measured (detected)  and non-detected  values.
 The value  substituted for each non-detected
 measurement was either 1) the sample-specific
 detection limit or 2) the average of the measured
 (detected)  values  across  all  seven data sets.
 Section 12.3.2.1 discusses EPA's representation
 of non-detect values for this analysis.  Section
 12.3.2.1  further discusses EPA's representation
 of the one biphasic sample.  Table 12-7 presents
 a compiled summary of these seven data sets.
 For each episode and each pollutant, the table
 presents the mean concentration of the data
 collected over the sampling episode. Figure 12-1
shows  the procedure EPA  used to estimate the
 mean concentration data over the seven sampling
 episodes.
    EPA has facility-specific information in its
database for 84 oils subcategory  facilities. Of
these 84 facilities, EPA has  sampling data for
seven.  For the remainder of the facilities, EPA
does not have current loadings data. EPA does,
however, have facility-specific information on the
volume of wastewater being discharged and the
treatment train currently in use. EPA evaluated
several ways  to associate one  of the  seven
emulsion breaking/gravity separation data sets to
each of the facilities for which EPA needed to
estimate current performance. EPA, therefore,
  reviewed the seven emulsion breaking/gravity
  separation data sets to determine if there was a
  relationship  between  the   concentration  of
  pollutants,  and facility flow, but  found  no
  evidence of relationship.
      Consequently, EPA randomly assigned one
  of the seven data sets to each of the facilities that
  required current loadings estimates. For facilities
  which  only employ emulsion breaking/gravity
  separation, EPA estimated current loadings for
  each pollutant  using values  in the randomly
  assigned data  set.  For  facilities  which use
  additional treatment after that step, EPA further
  reduced  the pollutant loadings  for   certain
  pollutants (or all pollutants depending on the
  technology) in the randomly assigned data set to
  account for the additional  treatment-in-place at
  the facility.

             TREATMENT-IN-PLACE
      As mentioned previously, there are many
  configurations  of  treatment trains  in  this
  subcategory. While EPA does not have sampling
  data representing  each  of these  treatment
  configurations,  EPA does have sampling data
  representing each  of the  individual treatment
  technologies currently in  place at oily waste
  facilities. While EPA collected all of the data at
  CWT facilities, EPA collected some of the data it
  used to develop  treatmerit-in-place  credits at
  facilities in other CWT subcategories. For some
  technologies, EPA has sampling data from a
  single  facility, while for  others,  EPA  has
  sampling data from multiple CWT facilities.
      In  order to estimate the current pollutant
  reductions due to additional treatment-in-place at
  oils facilities, for each technology, EPA compiled
  and reviewed all CWT sampling data for which
  EPA collected influent and effluent data.  EPA
  subjected the influent data to a similar screening
  process as the one used in determining long-term
  averages.   For each  episode, EPA retained
  influent and effluent data for a specific pollutant
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Chapter 12 Pollutant Loading and Removal Estimate
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only if the pollutant was detected in the influent
at treatable levels (10 times the baseline value1)
at least 50 percent of the time.  For each facility,
EPA then  calculated  an "average"  percent
removal  for  metals  (averaging  the  percent
removal  for each metal), an "average" percent
removal for organics, and an "average" percent
removal for BOD5 TSS, and oil and grease. EPA
rounded  the averages to the nearest 5 percent.
When the "average" percent removal for more
than one third of the pollutants in  a compound
class (i.e., metals, organics, BOD5  TSS, and oil
and grease) was zero  or less, EPA set  the
"average"  percent removal for the  class  of
compounds equal to zero. EPA recognizes that
treatment technologies are not equally effective in
reducing all metals and/or all organics from
wastewater,  but  believes  this   provides   a
reasonable estimate. The result is that, for some
pollutants,  .EPA  believes   it   may   have
underestimated the removals associated with the
additional  treatment-in-place,  while for other
pollutants, EPA may have overestimated  the
removals.
    Table  12-3  shows  the  percent  removal
credited to each technology.   For  technologies
that EPA  evaluated at more  than one CWT
facility, the value for each class of compounds
represents the lowest value at the facilities. For
example, EPA sampled at two  facilities that use
multimedia filtration.    The  average  percent
removal  of metal pollutants  at facility 1 and
facility  2  is  60  percent  and   30  percent,
respectively. Table 12-3 shows that EPA used 30
percent to estimate metals removal in multimedia
filtration systems.  EPA believes that using the
lower percent removal of the "best" performers
provides a reasonable estimate of the percent
removals of these technologies  for the rest of the
industry  and  may  even overstate the percent

     'Defined in chapter 15.
  removals for some facilities that may not be
  operating the treatment technologies efficiently.
      For some classes of compounds and some
  technologies, EPA does not have empirical data
  from the  CWT industry  to estimate  percent
  removals. For these cases, EPA assumed percent
  removals based on engineering judgement. EPA
  assumed that air stripping is only effective for the
  removal of volatile  and semi-volatile  organic
  pollutants.   EPA also assumed that chemical
  precipitation is  ineffective for the treatment of
  organic pollutants. Finally, EPA assumed a 50
  percent reduction  in  organic CWT pollutants
  through  carbon  adsorption treatment.  EPA
  recognizes that carbon  adsorption, given the
  correct design  and  operating  conditions can
  achieve  much  higher  pollutant  removals.
  However, for this industry, EPA believes that the
  complex matrices,  variability in waste receipts,
  and high  loadings would compromise carbon
  adsorption performance.
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Chapter 12 Pollutant Loading and Removal Estimates
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                                    Examine the data
                                    from the 7 facilities
                                    sampled by EPA
                                    For each pollutant,
                                    examine the data
                                    from each sample
                                                               No
         Use EPA method to
         obtain one value for
           each pollutant
                  Calculate
                MNC = mean
              of detected values
              from all 7 facilities
                                                                   Compare each
                                                                   sample-specific
                                                                 detection limit (DL)
                                                                      to MNC
                             Is
                          treatment
                       system batch or
                           ntinuous?
     Calculate pollutant
     LTA for the facility
     as mean of its daily
           values
                     Calculate pollutant
                     LTA for the facility
                     as mean of its batch
                           values
 Figure 12-1  Calculation of Current Loadings for Oils Subcategor
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Chapter 12 Pollutant Loading and Removal Estimates
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Table 12-3. Treatment-in-Place Credit Applied to Oils Facilitie
Pollutant
Group



BOD5
Oil and
Grease
TSS
Metals
Organics
Treatment Technology
Chemical
Precipitation


0
45

85
75
0*
Carbon
Adsorption


0
45

0
0
50*
Air
Stripping


0*
0*

0*
0*
70
Ultra
filtration


55
85

100
75
85
Biological



50
65

50
15
75
Multi-
media/
Sand
Filtration
10
0

55
30
0
DAF



10
60

80
50
40
Secondary
Separtion


5
30

0
0
50
* Value is based on engineering judgement.
    In determining current loadings for facilities
with  additional treatment-in-place, EPA then
reduced  the current  loadings  concentrations
established  for  the  facility  with  gravity
separation/emulsion  breaking  alone  by  the
appropriate percent removal as defined above.
For facilities with multiple treatment technologies
in their treatment train, EPA credited each of the
treatment technologies in the order that the
process occurs in their treatment train.

Issues Associated with Oils
Current Performance Analyses        12.3.2.1
    This section describes four issues associated
with estimating the current performance of the
oils subcategory. The first issue is  the dilution
required in analyses of some highly concentrated
samples  representing the  baseline  technology
(emulsion breaking/gravity  separation).   The
second issue is the appropriate procedure for
incorporating the concentrations of a biphasic
sample into the estimates of current performance.
The third issue is the appropriateness of various
substitution  methods  for  the  non-detected
measurements, especially of diluted samples.  The
fourth issue discussed is  EPA's approach to
assigning the seven emulsion breaking/gravity
separation data sets randomly to oils facilities.
          DILUTION OF SAMPLES DURING
             LABORATORY ANALYSIS
      Effluent from  emulsion  breaking/gravity
  separation   operations    may    be   highly
  concentrated, which may present difficulties in
  analyzing such effluent.  Consequently, in its
  analysis of some samples, EPA needed to dilute
  the samples in order to reduce matrix difficulties
  (such as interference) to facilitate the detection or
  quantitation of certain target compounds.  For
  some organic compounds, moreover, EPA also
  had to dilute samples where a highly concentrated
  sample could not be concentrated to the method-
  specified final volume.
      If EPA  diluted  a sample  for analytical
  purposes, EPA adjusted the particular pollutant
  measurement to correct  for the dilution.  For
  example, if a sample was diluted by 100 and the
  measurement was 7.9 ug/L, the reported value
  was adjusted to 790 ug/L (i.e., 7.9 ug/L * 100).
  In general, the sample-specific detection limits
  (DLs) for a pollutant were equal to or greater
  than the nominal quantitation limit described in
  Chapter 15. Dilution generated sample-specific
  DLs greater than the nominal quantitation limit.
       Because wastes generated using the proposed
  technologies will be  less concentrated  than
  emulsion breaking/gravity separation operations,
  EPA does not believe effluent  samples collected
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Chapter 12 Pollutant Loading and Removal Estimates
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to demonstrate compliance with the proposed
limitations and standards will necessitate dilution
and therefore result in effluent values with large
sample-specific DLs.  Further, a laboratory can
overcome potential analytical interferences using
procedures such as those suggested in Guidance
on    the    Evaluation,   Resolution,    and
Documentation   of   Analytical   Problems
Associated with Compliance Monitoring (EPA
821-B-93-001).     Thus,  in  demonstrating
compliance, EPA would not allow dilution of a
sample to  a sample-specific DL greater than the
limitation or standard.

             DIPHASIC SAMPLES
    EPA used a number of different analytical
methods to determine the pollutant levels in the
effluent samples from  facilities  that employ
chemical emulsion breaking/gravity separation
for treating oily wastewater.   Each method is
specific to a particular analyte or to structurally
similar  chemical compounds such  as volatile
organics  (analyzed   by  Method  1624)  and
semivolatile  organics  (analyzed  by  Method
1625).  In developing the laboratory procedures
described  in Method 1625,  EPA  included a
procedure for analyzing aqueous samples and
another  procedure  for  analyzing  biphasic
samples.  Some effluent samples from  emulsion
breaking/gravity separation were biphasic. That
is, each sample separated into two distinct layers,
an aqueous layer and an organic one.  In these
instances, if the phases could not be mixed, EPA
analyzed each phase (or layer) separately. Thus,
each pollutant in a sample analyzed by Method
1625 had two  analytical results, one for the
organic phase and the  other  for the aqueous
phase. There were three such samples in the oils
subcategory.   Only sample  number  32823
(episode 4814B), however, represents oily wastes
following emulsion breaking/gravity separation.
This sample is part of one of the seven data sets
representing    emulsion     breaking/gravity
  separation randomly assigned to facilities without
  concentration  data.   For  this sample,  EPA
  combined the  two concentration values  into a
  single value for each pollutant analyzed using
  Method 1625.  The discussion below describes
  the   procedures   for   combining   the   two
  concentration values and Table 12-4 summarizes
  these procedures. Table 12-5 provides examples
  of these procedures. DCN* 23.13
      If the pollutant was detected in the organic
  phase, EPA adjusted the analytical  results to
  account for the percent of the  sample in each
  phase.  For sample  32823, 96 percent  of the
  sample volume was aqueous and the remaining 4
  percent was organic. Thus, EPA multiplied the
  aqueous value (detected value or sample-specific
  DL) by 0.96 and the organic value by 0.04. EPA
  then summed the two adjusted values to obtain
  the total concentration value for the pollutant in
  the sample.
      If the pollutant was not detected  in the
  organic  phase, EPA  used  several  different
  procedures depending on the pollutant and its
  concentration  in the aqueous phase.   A factor
  which complicated  EPA;is analysis  was  that
  sample-specific DLs for pollutants in the organic
  phase were  10003 times  greater  than the
  minimum levels  for Method 1625.   When a
  measurement result indicates  that a pollutant is
  not detected, then the reported sample-specific
  DL is an upper bound for the actual concentration
  of  the pollutant  in  the  sample.  When some
  sample-specific DLs for the organic phase (which
  were  1000 times the  minimum  level) were


      2 Items identified with document control
  numbers (DCN) are located in the record to the
  proposed rulemaking.

        Because the volume of'the organic phase was
  small, the organic phase sample required  dilution
  (by 1000) for analysis. In contrast, the aqueous
  phase had sufficient amount so that it was not
  diluted.
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Chapter 12 Pollutant Loading and Removal Estimates
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multiplied  by 0.04,  the  adjusted non-detected
values were greater than the measured amount in
the  aqueous  phase.    EPA  concluded that
substituting the sample-specific DL for the non-
detected results in the organic phase in these
circumstances might over-estimate the amount of
pollutant in the sample. Thus, EPA applied one
of the two alternative substitution procedures
described  below for the sample-specific DLs
resulting from the organic phase.
    First, if EPA did not detect the pollutant in
either phase, EPA considered the sample to be
non-detect  at the sample-specific DL  of the
aqueous phase. This value for the aqueous phase
was equal  to the minimum  level specified in
Method 1625.
    Second, if the pollutant was detected in the
aqueous phase (and non-detected in the organic
phase), EPA used a procedure that compared the
non-detected  organic values to the detected
aqueous value adjusted by a partition ratio (550).
EPA determined this partition ratio using the
average of the ratios of the detected organic phase
concentrations to the detected aqueous phase
              concentrations for the pollutants that had detected
              values in both phases.  There were twenty-two
              pollutants that were used to calculate this value of
              550.  These  pollutants  are  in  four  structural
              groupings of organic pollutants: chlorobenzenes,
              phenols,  aromatic  ethers,  and   polynuclear
              aromatic hydrocarbons. The ratios were similar
              in each of the structural groupings; consequently,
              EPA determined  that a  single value for  the
              partition  ratio  was appropriate.   EPA then
              multiplied the aqueous phase concentration value
              by this partition ratio of 550.  If this value was
              less than the sample-specific DL of the pollutant
              in the organic phase, EPA substituted this value
              for the organic  phase  sample-specific DL.
              Otherwise, EPA used the organic phase sample-
              specific DL.  EPA then multiplied the values for
              the aqueous and organic phases by the relative
              volume amounts (0.96 and 0.04, respectively)
              and summed them to  obtain one value for  the
              sample.
Table 12-4. Diphasic Sample Calculations (Summary of rules for combining aqueous/organic phase cones.)
Censoring types (i.e., detected or non-detected)
Aqueous phase
NC .
ND
ND
NC
Organic phase
NC
NC
ND
ND (DL>550*AQ)
ND (DL<=550*AO1)
Combined result
(same as aqueous)
NC
ND
ND
NC
Method for obtaining
combined value
0.96*AQ + 0.04*ORG
0.96* AQ (use DL) + 0.04*ORG
AQ (use DL)
0.96*AQ + 0.04*(550*AQ)
0.96* AO + 0.04*ORG ("use DL)
AQ = value for aqueous phase
ORG = value for organic phase
NC = non-censored (detected)
ND = non-detected            DL = sample-specific detection limit
                                            12-11

-------
Chapter 12 Pollutant Loading and Removal Estimates
                            Development Document for the CWT Point Source Category
Table 12-5. Examples of Combining Aqueous and Organic Phases for Sample 32823
Pollutant

Accnaphthene
Benzo(a)pyrene
4,5-Methylene
Phcnanthrene f
Aniline
1-phenyl
-naphthalene f
Reported Cones. (ug/L)
Aqueous Phase
668.6
158.4
ND(10)
ND (10)*
10.49
Organic Phase
319,400
162,950
118,330
ND (10,000)
ND (10,000)
Concentration for Calculation for Sample
Sample (ug/L)
13,418
6,670
ND (4,743)
ND(10)
240.9
(0.96*668.6 ug/L)
+ (0.04*3 19,400 ug/L)
(0.96* 158.4 ug/L)
+ (0.04* 162,950 ug/L)
(0.96*10 ug/L)
+ (0.04* 11 8,330 ug/L)

(0.96* 10.49 ug/L)
+(0.04*550*10.49 ug/L)
Comment
Concentrations are
weighted by relative
amounts of the
sample volume in
each phase: 96%
aqueous and 4%
organic
no calculation
necessary
The sample-specific
DL of 10,000 ug/L
Alpha-
Terpineol
1,885.8     ND (10,000)
                                                                             for the organic phase
                                                                             is greater than 5570
                                                                             ug/L (i.e., 550 times
                                             	10.49 ug/L)	
                                              2,210     (1,885.8 ug/L*0.96)     The sample-specific
                                                        + (10,000 ug/L*0.04)    DL of 10,000 ug/L
                                                                             for the organic phase
                                                                             is less than 1,037,190
                                                                             (i.e., 550 times
                                                                             1885.8 ug/L)

* ND=non-detected measurement. The sample-specific DL is provided in the parentheses.
 t None of measurements of the pollutants of concern from this sample resulted in a non-detected measurement
for the aqueous phase with a detected measurement for the organic phase. This analyte is shown for demonstration
purposes.
 JNone of measurements of the pollutants of concern from this sample resulted in a detected measurement for the
aqueous phase with a sample-specific DL for the organic phase that was greater than 550 times the measurement
from the aqueous phase.  This analyte is shown for demonstration purposes.
  NON-DETECT DATA IN COMPLEX SAMPLES
    EPA included  values for  measurements
reported as "non-detected" when it calculated the
mean for each pollutant of concern in the seven
emulsion breaking/gravity separation data sets.
In some instances, the measurements reported as
non-detected had sample-specific detection limits
that were  well  in  excess of  the minimum
analytical detection limits.  The high sample-
specific detection limits occurred because the
samples  contained  many  pollutants  which
interfered with the analytical techniques.  EPA
considered several approaches for handling these
sample-specific  non-detected   measurements
because, by definition, if a pollutant  is  'not
                               detected', then the pollutant is either not present
                               at all (that is, the concentration is equal to zero)
                               or has a concentration values somewhere between
                               zero and the sample-specific detection limit (DL).
                                  EPA   considered  the   following   five
                               approaches to selecting a value to substitute for
                               non-detected measurements:

                               1.  Assume that the pollutant is not present in
                                  the sample and substitute zero for the non-
                                  detected measurement (that is, ND=0).
                               2.  Assume that  the pollutant is present in the
                                  sample  at a  concentration equal to  the
                                  minimum  analytical   level   (that   is,
                                             12-12

-------
Chapter 12 Pollutant Loading and Removal Estimates
Development Document for the CWT Point Source Category
    ND=minimum  analytical  detection  limit
    (MADL)).
3.  Assume that the pollutant is present at a
    concentration  equal to  half the sample-
    specific DL (that is, ND=DL/2). (In general,
    the values of the sample-specific DLs are
    equal to or greater than the values of the
    minimum analytical detection limits used in
    the second approach.)
4.  Assume that the pollutant is present at a
    concentration equal to the sample-specific
    DL  (that  is,  ND=DL).    This  is  the
    substitution approach that was used in the
    1995 proposal, for the  influent pollutant
    loadings for the other two subcategories, and
    for the proposed limitations  and standards
    for all three subcategories.
5.  Assume that the pollutant is present at a
    concentration  equal to either the sample-
    specific DL or the mean of the detected (or
    non-censored)  values   (MNC)  of  the
    pollutant4 EPA used the lower of the two
    values (that is, ND=minimum   of DL or
    MNC).

    EPA  ultimately  selected  the  approach
described in 5. because Agency concluded that it
provided the most  realistic estimate of current
performance in these data sets.
      Table 12-6A shows how EPA applied the
  five  substitution  approaches   to   data  for
  hypothetical pollutant X for seven facilities. The
  example shows the types of calculations EPA
  performed in comparing the five approaches. The
  example includes facilities that treat wastes on a
  batch and continuous basis.  It  also includes a
  mixture    of   detected   and    non-detected
  measurements as well as duplicate samples. For
  each facility, the table lists the analytical results
  reported by the laboratory for pollutant X.  If the
  reported  value  is  non-detected,  then  this
  analytical result is identified in the table as "ND"
  with the  reported sample-specific DL in the
  parenthesis.   If the  value  is  detected,  the
  analytical (measured) result is shown in the table
  and is identical in all five approaches because the
  substitutions apply only to  non-detected values.
  Finally, for each of the seven facilities, the table
  shows five long-term averages for pollutant X~
  one for each of the five substitution approaches.
    4For each pollutant, EPA calculated the mean
(or average) of the detected (or non-censored)
values (MNC) using all detected values in the seven
data sets except for the biphasic sample. The
substitutions were only applied to non-detected
measurements observed in aqueous samples because
the non-detected measurements in the biphasic
sample were evaluated separately as described in the
previous section. While EPA believes that biphasic
samples can result from some wastes in this
subcategory after processing through emulsion
breaking/gravity separation, EPA believes that it is
appropriate to use only detected measurements from
aqueous samples in calculating the mean that will be
compared to each sample-specific DL in aqueous
samples.
                                            12-13

-------
Chanter 12 Pollutant Loading and Removal Estimates
Development Document for the CWT Point Source Category
Table 12-6A. Example of Five Substitution Methods for Non-Detected Measurements of
             Hypothetical Pollutant X
Facility


A





B


C



D






E






F





G





Sampling Day Reported
or Batch
Number
Batch 1
Batch 1
Batch 2
Batch 3
Batch 4

Dayl
Day 2

Dayl
Day 2
Day 3

Dayl
Day 2
(duplicate)
Day 2
(duplicate)
Day 3

Dayl
Day 2
Day 3
Day 4

DayS

Dayl
Day 2
DayS
Day 4
DayS

Dayl
Day 2
DayS
Day 4

MNC
Values
(ug/L)
99
95
ND (300)*
84
258
A:LTA
ND (100)
ND (1000)
B:LTA
57
84
26
C:LTA
73
ND (100)

ND(10)

62
D:LTA
411
257
79
ND
(1000)
ND (220)
E: LTA
ND (300)
320
44
47
180
F:LTA
1234
855
661
1377
G:LTA
= 315
Approach Approach 2
1
ND=0
99
95
0
84
258
122
0
0
0
57
84
26
56
73
0

0

62
45
411
257
79
0

0
149
0
320
44
47
180
118
1234
855
661
1377
1032
(MNC =
ND=MADL f
(MADL=10 ug/L)
99
95
10
84
258
125
10
10
10
57
84
26
56
73
. 10

10

62
48
411
257
79
10

10
153
10
320
44
47
180
120
1234
855
661
1377
1032
Approach
3
ND=DL/2
99
95
150
84
258
160
50
500
275
57
84
26
56
73
50

5

62
54
411
257
79
500

110
271
150
320
44
47
180
148
1234
855
661
1377
1032
Approach
4
ND=DL
99
95
300
84
258
197
100
1000
550
57
84
2.6
56
73
100

10

62
613
411
257
79
1000

220
393
300
320
44
47
180
178
1234
855
661
1377
1032
Approach 5
ND=
min(DL,MNC)
99
95
300
84
258
197
100
315
208
57
84
26
56
73
100

10

62
63
411
257
79
315

220
256
300
320
44
47
180
178
1234
855
661
1377
1032
mean of detected values from all seven facilities)
 *  ND=non-detected measurement. The sample-specific detection limit is provided in the parentheses.
 f  MADL=minimum analytical detection level
                                               12-14

-------
Chapter 12 Pollutant Loading and Removal Estimates
   Development Document for the CWT Point Source Category
    While Table 12-6A provides an  example
using the five approaches, DCN 23.8 shows the
results of the substitution values under the first
four approaches to the actual seven concentration
data sets from the seven facilities with emulsion
breaking/gravity separation. DCN 23.21 shows
the results of using the fifth approach. After
evaluating the five approaches, EPA prefers
Approach 5  because it tends to minimize the
effect of large detection levels on the long-term
averages while providing reasonable estimates of
the actual concentrations.   Furthermore, EPA
feels that Approach 5 is superior to the other four
approaches.  In particular, the first and second
approaches (substitutions of zero or the MADL,
respectively, for non-detects) are poor choices
because they are likely to provide unrealistically
low estimates of the analyte concentrations in
samples   with high sample-specific  detection
limits, especially when all detected values are
substantially greater than zero and the MADL. In
addition, the third and  fourth  approaches
(substitution of the sample-specific DL or DL/2,
respectively)  are  poor choices  because the
substitutions could exceed the detected values in
some  cases,  and thus, possibly could over
estimate  the concentrations  in  non-detected
measurements. EPA's  analyses also show that
there is  little or no  difference in  the  averages
between using the sample-specific DL or half the
sample-specific  DL  for   many   of  the
facility/analyte data sets.   Thus,  EPA  has
followed the approach outlined  in   5  above
because it concluded that this approach provides
reasonable estimates of the actual concentrations
because   the  substituted  values  are  neither
unrealistically low  nor  exceed  the  greatest
detected value.
         Table 12-7 shows the pollutant concentration
     data sets for the seven facilities (identified as A,
     B, etc.) using the "Originial" approach (that is,
     Approach 1: sample-specific DL substituted for
     non-detected measurements) and the 'Replaced'
     approach (that  is, Approach  5).   Each set
     provides the overall mean (i.e., the average of all
     values  detected and non-detected), the mean of
     the detected values, and the mean of the NDs (i.e.,
     the mean of the substituted values). Both provide
     the same detected mean value because, unlike the
     non-detected measurements,  no  substitutions
     were made for  detected  measurements.   In
     contrast, the overall mean and the mean of the
     NDs vary when one or more values in a facility
     data set exceed the mean detected value for the
     pollutant.
         Table  12-6B shows the relative effects of
     EPA's preferred approach in comparison to
     Approach  1  on  the  estimates  of  priority,
     conventional,   and   non-priority   pollutant
     concentrations for baseline loadings and the total
     removals changes for toxic weighted pollutants.
     In comparison  to Approach  1 (EPA's 'original
     method),   EPA's   preferred  (or  'replaced')
     approach  (that is,  Approach  5)  had  little
     noticeable effect on the baseline loadings for the
     oils  subcategory.  In other words, the current
     loadings are approximately the same using either
     approach.   There  is,  however, a significant
     decrease in toxic pound-equivalent removals with
     EPA's preferred approach. Hence, overall toxic
     pound-equivalent removal estimates using EPA's
     preferred approach decreased by approximately
     34% from those calculated  using its original
     approach (that is, substituting the sample-specific
     detection   limit    for   all    non-detected
     measurements).  The cost effectiveness document
     provides  more  information  on  toxic pound-
     equivalent removals.
Table 12-6B. Difference in Oils Subcategory Loadings After Non-Detect Replacement Using EPA Approach
 Priority Metals & Organics     Non-Priority Metals &
  Current Loading  (percent  Organics Current Loading
                 change)          (percent change)
                     -5
+ 1
 Conventional Pollutant
      Current Loading
	(percent change)
                   0
Pound-Equivalent
   Net Removals
 (percent change)
            -34
                                            12-15

-------
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-------
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CO

-------
Chapter 12 Pollutant Loading and Removals Estimates
Development Document for the CWT Point Source Category
Random Assignment of Seven
Emulsion Breaking/Gravity
Separation Data Sets                12.3.2.2
    While EPA's assignment of one of the seven
emulsion breaking/gravity separation data sets to
each  oils facility  for which EPA needed to
estimate current performance was random, the
SBREFA  Panel raised the  concern  that  this
approach   may  not  have  resulted   in  a
representative assignment of loadings.
    The following explains EPA's procedure. To
obtain estimates of current pollutant loadings
associated  with  emulsion  breaking/gravity
separation, EPA developed  estimates of  the
pollutant  loadings at each of the 84 facilities
identified  as having wastestreams  in the  oils
subcategory. To obtain  estimates of pollutant
loadings,  EPA needed concentration and flow
information for each facility.  EPA had flow
information from all facilities, but had data on
pollutant  .concentrations  from  only    seven
facilities where EPA had sampled the  emulsion
breaking/gravity separation operations. Section
12.3.2.1 describes these seven concentration data
sets.  To obtain concentration estimates for the
remaining facilities in the oils subcategory, EPA
assigned one of the seven available concentration
data sets  to each of those 77 facilities without
pollutant  concentration data at random.  EPA
assigned each set to no more than 11 facilities.
Then,  EPA estimated each facility's  pollutant
loadings  as the  product  of the total  oils
wastewater flow at the facility and the pollutant
concentrations in its assigned data set. Figure 12-
2 shows this procedure.
    EPA assigned the seven data sets to each of
the 77 oil subcategory facilities for which there
was no actual concentration data. EPA assigned
the data  sets randomly.  Thus, EPA did not
weight some data sets more heavily than others.
After this assignment of the data sets, however,
EPA determined that there was one additional
facility that would fall within the scope  of the
proposed oils subcategory, and one facility that
  was no longer in-scope. EPA removed from the
  data base the one  facility and selected actual
  concentration data for the newly included facility
  randomly.  The result of this procedure is that
  each of the seven data sets represented data for
  11,  12, or 13 facilities.  EPA then calculated
  pollutant loadings for the total of 84 facilities.
       While  EPA had  randomly  assigned the
  concentration  data,  EPA   reexamined   its
  procedure to assure itself that the results were, in
  fact, statistically random and concluded they were
  (see DCNs 23.5, 23.6, and 23.31).  Further
  review of the data established that two of the
  facilities sampled by EPA had large wastewater
  flows as compared to all CWT oils subcategory
  facilities.  Of the 84 oils subcategory facilities,
  flows for these two facilities represented the sixth
  and second highest wastewater flows.  Total
  flows  and total  loadings  for  any  groups of
  facilities that included these facilities would exert
  influence regardless of the random assignment of
  the  concentration data for facilities for which
  none was available.  In addition, the sampled
  facility with the highest  toxic loadings  was
  assigned to the  group with only a total of 11
  facilities (the smallest number of facilities in any
  group).
                                            12-31

-------
Chapter 12 Pollutant Loading and Removals Estimates
Development Document for the CWT Point Source Category
                                                  Each facility provides flow
                                                        information
                        Each sampled faclty fe
                          assigned its own
                        concentration data set
                    Randomly assign 1 of 7
                   concentration data sets to
                          facSity
                                L
                           J
                                                    Calculate loading using
                                                  assigned concentration data
                                                    set and faciJt/s flow
                                                        Doos facility
                                                   have treatment h-place
                                                that provides better removals than
                                                   chemical emulsion/gravity
                                                        separation?
                Incorporate appropriate
                reductions into facH/s
                      badings
                          Loadings remain the same
Figure 12-2.  Methodology for Current Loadings Estimates in Oils Subcategory
                                                         12-32

-------
 Chapter 12 Pollutant Loading and Removals Estimates
        Development Document for the CWT Point Source Category
 Organics Subcategory
 Current Loadings
12.3.3
     EPA had limited available data from the
 organics subcategory and very little data which
 represent organic subcategory CWT wastewater
 only.   The vast  majority of organic facilities
 commingle   large   quantities   of  non-CWT
 wastewater  prior to the point of  discharge.
 Therefore, EPA estimated current loadings based
 on the treatment technologies in place except for
 the  two facilities for which EPA has analytical
 data representing organic subcategory wastewater
. only.
     Based on a review of technologies currently
 used at organic subcategory facilities, EPA placed
 in-place treatment for this subcategory in one of
 five classes:
     1) raw;
     2) filtration only;
     3) carbon adsorption;
     4) biological treatment; and
     5)  biological treatment  and multimedia
     filtration.

     The   discussion  below  describes  the
 methodology  EPA  used to  estimate  current
 loadings for each classification. Table 12-8 lists
 the  current  performance  estimates  for  each
 classification. This table does not include current
 loadings estimates for all pollutants of concern in
 the organics subcategory. EPA excluded the non-
 conventional  bulk parameters, such as chemical
 oxygen demand, many pollutants which serve as
 treatment chemicals,  and  all  pollutants not
 detected at treatable levels in the wastewater
 influent to the treatment system selected as the
 basis for effluent limitations.
     EPA used the first classification ("raw") for
 seven  organic subcategory  facilities with  no
 reported treatment in place for the reduction of
 organic constituents.  EPA based its  current
 loadings estimate for "raw wastewater" on EPA
 sampling data at two organic facilities.  These
 were Episode 1987, sample points 07A and 07B
and Episode 44725, sample point 01. For each
pollutant  of concern  and each  facility, EPA
calculated a long-term average or mean. This
mean  includes measured (detected) and non-
detected values. For non-detected values, EPA
used the sample-specific detection limit.  Once
EPA had calculated the long-term  average  or
mean  for each facility and  each pollutant  of
concern, EPA then calculated the mean of the
long-term averages from the two facilities for
each pollutant of concern to estimate the "raw"
current loadings concentrations reported in Table
12-8.
    EPA  classified in  the  second category
("filtration  only")  three  organic subcategory
facilities which only had multi-media or sand
filtration as the on-site treatment technology for
the organic  waste stream.  For these facilities,
EPA    adjusted    the   "raw    wastewater"
concentrations to account for 55 percent removal
of TSS, 30 percent removal of metal parameters,
10 percent removal of BOD5  and no removal of
other  classical or organic pollutants.   EPA
estimated the percent reductions for facilities in
this  group  using  the  procedure  previously
described in Section 12.3.2.
    EPA placed in the third category two organic
subcategory facilities  with carbon  adsorption
(usually   preceded  by sand or  multi-media
filtration). EPA adjusted the "raw wastewater"
concentrations to account for 50 percent removal
of organic pollutants, 45 percent removal of oil
and grease, and no removal of all other pollutants.
Again, EPA also estimated the percent removals
              2After further review, EPA determined that data
          from one episode (4472) represented a combination of
          organics and oils subcategory wastewater.  EPA will
          re-visit its current loadings estimates classifications
          prior to promulgation and incorporate the  following
          changes to the oil and grease loadings concentrations:
          29,875 ug/L for raw treatment, 29,875  ug/L  for
          filtration only;  19,419 ug/L for  carbon adsorption,
          5,440 ug/L for biological treatment, and 5,290 ug/L
          for biological treatment plus multimedia filtration.
                                             12-33

-------
Chanter 12 Pollutant Loading and Removals Estimates
Development Document for the CWI Point Source Category
for facilities in this category using the procedure
previously described in Section 12.3.2.
    EPA   based   the   current   loadings
concentrations  for   the   fourth  and  fifth
classification on EPA sampling data collected at
Episode 1987.    EPA calculated the  current
loadings estimates for each pollutant of concern
using a similar procedure to that described above
   for  the "raw" organics  subcategory  current
   performance. EPA based the: percent removals for
   five organic subcategory facilities in the fourth
   classification (biological treatment) on analytical
   data collected at sample point 12. For the two
   organic subcategory facilities  in  the  fifth
   classification   (biological    treatment   and
   multimedia filtration) EPA based removals on
   analytical data collected at sample point 14.
Table 12-8. Current Loadings Estimates for the Organics Subcategory (units = ug/L)
Pollutant
CONVENTIONAL POLLUTANTS
BODS
Total Cyanide
Oil and Grease
TSS
METAL POLLUTANTS
Aluminum
Antimony
Boron
Chromium
Cobalt
Iron
Lithium
Manganese
Molybdenum
Nickel
Phosphorus
Silicon
Strontium
Sulfur
Tin
Zinc
ORGANIC POLLUTANTS
Acetophenone
Aniline
Benzene
Benzoic Acid
Chloroform
Dimethyl Sulfone
Ethylene-thiourea
Hexanoic Acid
M-xylene
Methylene Chloride
N,N-dimethylformamide
O-cresol
RawJ

22,027,643
3,270
176,649
1,454,857

56,363
456
48,098
553
277
32,175
11,888
710
1,337
1,426
6,925
2,813
5,088
1,601,750
984
1,402

1,528
1,367
2,776
10,469
4,449
1,449
5,150
2,240
1,206
1,962,725
32,846
7,339
Filtration
Only

19,824,879
3,270
176,649
654,686

39,454
319
33,668
387
194
22,522
8,321
497
936
998
4,848
1,969
3,561
1,121,225
689
981

1,528
1,367
2,776
10,469
4,449
1,449
5,150
2,240
1,206
1,982,725
32,846
7,339
Carbon
Adsorption

22,027,643
3,270
97,157
1,454,857

56,363
456
48,098
553
277
32,175
11,888
710
1,337
1,426
6,925
2,813
5,088
1,601,750
984
1,402

764
684
1,388
5,234
2,224
724
2,575
1,120
603
981,362
16,423
3,699
Biological Biological
Treatment* Treatment and
Multimedia
Filtration

2,440,000
2,176
17(5,649
480,000

2,474
569
48,098
553
437
3,948
11,888
227
943
1,426
6,925
2,680
2,060
1,370,000
984
382

36
10
10
320
73
158
4,400
64
10
204
11
185

1,564,000
2,120
3,900
399,000

2,474
569
48,098
553
437
3,948
11,888
227
943
1,426
6,925
2,680
2,060
1,370,000
984
382

36
10
10
320
73
158
4,400
64
10
204
11
185
                                             12-34

-------
Chapter 12 Pollutant Loading and Removals Estimates
       Development Document for the CWT Point Source Category
Table 12-8. Current Loadings Estimates for the Organics Subcategory (units = ug/L)
Pollutant
P-cresol
Pentachlorophenol
Phenol
Pyridine
Tetrachloroethene
Tetrachloromethane
Toluene
Trans- 1 ,2-dichloroethene
Trichloroethene
Vinyl chloride
1 , 1 -dichloroethane
1 , 1 -dichloroethene
1,1,1 -trichloroethane
1,1,1 ,2-tetrachloroethane
1 , 1 ,2-trichloroethane
1 ,2-dibromoethane
1 ,2-dichloroethane
1 ,2,3-trichloropropane
2-butanone
2-propanone
2,3-dichloroaniline
2,3 ,4,6-tetrachlorophenol
2,4,5-trichlorophenol
2,4,6-trichlorophenol
4-methyl-2-pentanone
Raw;
3,367
6,968
6,848
3,881
2,382
1,706
746,124
1,228
4,645
691
544
579
1,444
121
1,191
2,845
4,713
575
59,991
6,849,320
1,349
3,340
1,365
1369
3479
Filtration
Only
3,367
6,968
6,848
3,881
2,382
1,706
746,124
1,228
4,645
691
544
579
1,444
121
1,191
2,845
4,713
575
59,991
6,849,320
1,349
3,340
1,365
1369
3479
Carbon Biological Biological
Adsorption Treatment* Treatment and
Multimedia
Filtration
1,683
3,484
3,424
1,940
1,191
853
373,062
614
2,323
345
272
290
722
364
595
1,422
2,357
288
29,996
3,424,660
675
1,670
683
684
1739
66
791
362
116
112
14
10
22
69
10
10
10
10
10
13
10
10
10
878
2,061
23
629
97
86
146
66
791
362
116
112
14
10
22
69
10
10
10
10
10
13
10
10
10
878
2,061
23
629
97
86
146
* Current performance estimates for biological treatment and biological treatment with multimedia filtration are
equal for metal and organic constituents because EPA only analyzed for conventional parameters at Episode 1987,
sample point 14.
1 EPA used sampling data from Episodes 1987 and 4472 to estimate these "raw" concentrations. After reviewing
the data further, EPA determined that data collected at Episode 4472 did not represent "raw" organic subcategory
wastewater only and will re-visit between proposal and promulgation.
METHODOLOGY USED TO ESTIMATE
POST-COMPLIANCE LOADINGS
12A
    Post-compliance pollutant loadings for each
regulatory option represent the total industry
wastewater    pollutant    loadings     after
implementation of the proposed rule.  For each
proposed option,  EPA determined  an average
performance level (the "long-term average") that
a facility with well designed and operated model
technologies (which reflect the appropriate level
of control) is capable of achieving. In most cases,
EPA calculated these long-term averages using
data  from  CWT  facilities  operating  model
technologies.   For a  few  parameters, EPA
determined that CWT performance was uniformly
inadequate and transferred effluent long-term
averages from other sources.
    To   estimate  post-compliance  pollutant
loadings for each facility for a particular option,
EPA used the long-term average concentrations,
the facility's annual wastewater discharge flow,
and a  conversation factor  in the  following
equation:
                                             12-35

-------
Chanter 12 Pollutant Loading and Removals Estimates     Development Document for the CWI'Point Source Category
 Postcompliance long-term average concentration
                  (mg/L)
    Facility annual discharge flow x     1 Ib
                               453,600 mg
   - Facility postcompliance annual loading
                (Ibs/yr)

    EPA expects that all facilities subject to the
effluent limitations and standards will design and
operate their treatment systems  to achieve the
long-term  average  performance  level  on  a
consistent  basis because  facilities with well-
designed and operated model technologies have
demonstrated that this can be done. Further, EPA
has accounted  for potential treatment system
variability in pollutant removal through the use of
variability factors.  The variability factors used
to  calculate the  proposed  limitations  and
standards were determined from data for the same
facilities employing the treatment technology
forming   the   basis   for  the   proposal.
Consequently,   EPA  has  concluded  that the
standards and limitations take into account the
level of treatment variation well within the
capability of an individual CWT to control. If a
facility is designed and operated to achieve the
long-term average on a consistent basis, and if the
facility maintains adequate control of treatment
variation, the allowance for variability provided
in the limitations is sufficient.
    Table 12-9 presents the long-term averages
for the selected option for each subcategory.  The
pollutants for which data is presented in Table
12-9 represent the pollutants  of concern  at
treatable levels at the facilities which form the
basis of the options. The pollutants selected for
regulation are a much smaller subset.
                                              12-36

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-------
Chapter 12 Pollutant Loading and Removals Estimates
      Development Document for the CWT Point Source Category
METHODOLOGY USED TO ESTIMATE
POLLUTANT REMOVALS
12.5
POLLUTANT LOADINGS
AND REMOVALS
12.6
    For each regulatory option, the difference
between baseline loadings and post-compliance
loadings represent the pollutant removals. For
direct discharging CWT facilities, this represents
removals  of pollutants being  discharged  to
surface waters.   For indirect, dischargers, this
represents   removals   of  pollutants   being
discharged to POTWs less the removals achieved
by  POTWs.   EPA calculated the  pollutant
removals, for each facility using the following
equation:

  Baseline Loadings - Postcompliance Loadings
             = Pollutant Removals

    EPA used the following methodology  to
estimate pollutant removals:

1)  If the post-compliance loading of a pollutant
    was higher than the baseline loading, EPA
    set the removal to zero;
2)  If EPA did not identify a particular pollutant
    in the wastewater of a facility at baseline and
    that pollutant was present at baseline in the
    wastewater of a facility used as the basis for
    determining  limitations   and   standards
    associated with one of the regulatory options,
    EPA set the removal to zero.);
3)  If EPA did not calculate a long-term average
    for a pollutant for a technology  option (i.e.,
    the post-compliance loading for the pollutant
    could not be calculated), EPA set the removal
    to zero; and
4)  For indirect  dischargers, EPA additionally
    reduced the pollutant removal estimate by the
    POTW removal percentage. Therefore, the
    pollutant  removal  estimates  for indirect
    dischargers  only  account for  pollutant
    removals  over  and  above  the  POTW
    removals.
            EPA estimated annual baseline and  post-
         compliance loadings for each of the subcategories
         and the respective regulatory options using the
         methodology described in Sections 12.3 through
         12.5 of this document. For the oils subcategory,
         EPA extrapolated the facility-specific loadings
         and removals from the 84  in-scope discharging
         facilities to provide estimates  of an  estimated
         total population of 141 discharging oils facilities.
         Facilities with no wastewater discharge ("zero
         dischargers") have  no  pollutant loadings or
         removals.
            Tables 12-10 through 12-13 present the total
         baseline and post-compliance loadings  and the
         pollutant removals  for  the facilities in  each
         subcategory.
                                            12-41

-------
Chapter 12 Pollutant Loading and Removals Estimates	Development Document for the CWTPoint Source Category
Table 12-10.  Summary of Pollutant Loadings and Removals for the CWT Metals Subcategory1
Pollutant of Concern
Current Wastewater
Pollutant Loading
(Ibs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Wastewater
Pollutant Loading
flbs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Pollutant
Reductions
(Ibs/vr)
Direct Indirect
Discharges Discharges
CONVENTIONALS
Biochemical Oxygen
Demand 5-Day (BODS)
Oil and Grease (measured as HEM)
Total Suspended Solids (TSS)
PRIORITY METALS
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
TOTAL PRioRrrYMETALs
NON-CONVENTIONAL METALS
Aluminum
Barium
Boron
Cobalt
Indium
Iron
Lithium
Manganese
Molybdenum
Silicon
Strontium
Tin
Titanium
Vanadium
Yttrium
Zirconium
TOTAL NON-CONVENTIONAL
METALS
CLASSICAL PARAMETERS
Chemical Oxygen Demand (COD)
Hexavalent Chromium
Ammonia as N
Cyanide


8,366,557
519,480
6,109,653

34,215
676
5,380
140,366
205,011
26,012
164
52,686
1,838
421
347
127,400
594,516

82,842
308
168,406
3,865
17,288
114,752
146,215
5,645
16,864
41,066
10,831
159,531
93,683
4,686
122
857

866,961

32,170,276
235,527
411,874
5,295


N/A
N/A
N/A

7,504
37
16
289
669
139
16
5,024
1,226
24
82
3,359
18,385

3,455
64
92,315
885
3,122
9,248
125,992
1,007
5,863
6,810
10,106
1,856
586
119
43
223

261,694

N/A
15,106
N/A
1,046


570,816
74,445
64,680

608
301
125
1,727
1,811
441
4
3,917
1,346
80
347
1,605
12,312

3,042
308
34,766
435
3,499
24,042
5,884
175
6,445
5,100
350
330
188
150
21
835

85,570

4,733,770
2,431
60,506
304


N/A
N/A
N/A

184
29
9
147
278
36
1
1,945
854
6
82
347
3,918

377
64
25,153
401
953
4,329
5,056
107
3,126
3,876
319
116
64
81
8
223

44,253

N/A
2,660
N/A
96


7,795,741
445,035
6,044,973

33,607
375
5,255
138,639
203,200
25,571
160
48,769
492
341
0
125,795
582,204

79,800
0
133,640
3,430
13,789
90,710
140,331
5,470
10,419
35,966
10,481
159,201
93,495
4,536 '
101
22

781,391

27,436,506
233,096
351,368
4,991


N/A
N/A
N/A

7,320
8
7
142
391
103
15
3,079
372
18
0
3,012
14,467

3,078
0
67,162
484
2,169
4,919
120,936
900
2,737
2,934
9,787
1,740
522
38
35
0

217,441

N/A
12,446
N/A
950
'All loadings and reductions take into account the removals by POTWs for indirect discharges.
HEM - Hexane extractable material
                                              12-42

-------
Chanter 12 Pollutant Loading and Removals Estimates
Development Document for the CWT Point Source Category
Table 12-11.  Summary of Pollutant Loadings and Removals for the CWT OHs Subcategory*
Pollutant of Concern
Current Wastewater
Pollutant Loading
flbs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Wastewater
Pollutant Loading
flbs/vrt
Direct Indirect
Discharges Discharges
Post-Compliance Pollutant
Reductions
flbs/vr)
Direct Indirect
Discharges Discharges
 CONVENTIONALS
 Biochemical Oxygen
 Demand 5-Day (BODS)
 Oil and Grease (measured as HEM)
 Total Suspended Solids (TSS)
 PRIORITY ORGANICS
 1,1,1-Trichloroethane
 1,2,4-Trichlorobenzene
 1,4-Dichlorobenzene
 1,1-Dichloroethene
 1,2-Dichloroethane
 2,4-Dimethylphenol
 Acenapthene
 Anthracene
 Benzene
 Benzo(a)anthracene
 Benzo(a)pyrene
 Benzo(b)fluoranthene
 Benzo(k)fluoranthene
 Bis(2-ethylhexyl) Phthalate
 Butyl Benzyl Phthalate
 Chlorobenzene
 Chloroform
 Chrysene
 Diethyl Phthalate
 Di-ii-butyl Phthalate
 Ethylbenzene
 Fluoranthene
 Fluorene
 Methylene Chloride
 Naphthalene
 Phenanthrene
 Phenol
 Pyrene
 Tetrachloroethene
 Toluene
 Trichloroethene
 TOTAL PRIORITY ORGANICS
 NON-CONVENTIONAL ORGANICS
 l-Methylfluorene
 1-Methylphenanthrene
 2,3-Benzofluorene
 2-Butanone
 2-Methylnaphthalene
 2-Phenylnaphthalene
 2-Propanone
 3,6-Dimethylphenanthrene
 4-Chloro-3-methylphenol
 4-Methyl-2-pentanone
 -Terpineol
 Benzoic Acid
 Benzyl Alcohol
 Biphenyl
 Carbazole
 Carbon Disulfide
 Dibenzofuran
 Dibenzothiopene
 Diphenyl Ether
1,099,760
324,206
291,300
38
12
8
4
3
19
10
14
166
11
9
8
8
24
13
2
5
15
13
3
129
12
10
26
. 52
50
393
35
11
677
7 '
1,787
12
29
14
392
45
4
4,313
14
207
51
8
875
8
37
5
5
10
16
105
N/A
N/A
N/A
80S
723 
1,012
185
66
1,088
80
242
562
60
123
100
122
126,764
576
14
396
102
1,902
171
794
4,514
1,459
3,616
2,319
933
2,020
1,309
823
2,122
308
155,313
384
592
236
1,508
. 13,986
90
62,551
236
18,504
2,158
196
18,858
287
189
209
141
101
414
201
845,531
4,840
4,214
13
10
7
4
3
19
10
12
84
9
6
6
5
7
4
2
5
8
13
3
36
2
10
26
39
"13
393
10
11
314
7
1,091
5
8
9
392
26
2
4,313
8
61
51
4
875
8
20
5
4
10
10
94
N/A
N/A
N/A
71
56
230
112
61
1,088
13
42
117
15
19
18
20
287
18
11
303
16
1,304
62
107
812
348
3,353
328
196
1,598
135
303
574
179
11,796
48
76
236
1,144
5,581
90
62,551
236
18,504
1,894
17
13,631
287
19
109
26
14
90
201
254,229
319,366
287,086
25
2
1
0
0
0
0
2
82
2
3
2
3
17
9
0
0
7
0
0
93
10
0
0
13
37
0
25
0
363
0
696
7
21
5
0
19
2
0
6
146
0
4
0
0
17
0
1
0
6
11
N/A
N/A
N/A
737
667
782
73
5
0
67
200
445
45
104
82
102
126,477
558
3
93
86
598
109
687
3,702
1,111
263
1,991
737
422
1,174
520
1,548
129
143,517
336
516
0
364
8,405
0
0
0
0
264
179
5,227
0
170
100
115
87
324
0
                                                       12-43

-------
Chapter 12 Pollutant Loading and Removals Estimates      Development Document for the CWTPoint Source Category
Table 12-11.  Summary of Pollutant Loadings and Removals for the CWT Oils Subcategory;
Pollutant of Concern
HexanoicAcid
ro-Xylene
n-Dccane
Ji-Docosane
n-Dodecane
n-Ecosane
n-Hexadccane
n-Octadecane
n-Tetradecane
o-Cresol
o-&p-Xylene
p-Cresol
p-Cymene
Pentamethylbenzene
Pyridine
Styrene
Tripropyleneglycol Methyl Ether
TOTAL NON-CONVENTIONAL
ORGANICS
PRIORITY METALS
Antimony
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
TOTAL PRIORITY METALS
NON-CONVENTIONAL METALS
Aluminum
Barium
Boron
Cobalt
Iron
Manganese
Molybdenum
Silicon
Strontium
Tin
Titanium
TOTAL NON-CONVENTIONAL METALS
CLASSICAL PARAMETERS
Chemical Oxygen Demand
-------
Chapter 12 Pollutant Loading and Removals Estimates
                Development Document for the CWT Point Source Category
 Table 12-12. Summary of Pollutant Loadings and Removals for the CWT Organics Subcategory7
Pollutant of Concern
Current Wastewater
Pollutant Loading
(lbs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Wastewater
Pollutant Loading
(Ibs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Pollutant
Reductions
(Ibs/vrt
Direct Indirect
Discharges Discharges
 CONVENTIONALS
 Biochemical Oxygen Demand
 5-Day (BOD5)
 Oil and Grease (measured as HEM)
 Total Suspended Solids (TSS)
 PRIORITY ORGANICS
 1,1,1-Trichloroethane
 1,1,2-Trichloroethane
 1,1-Dichloroehtane
 1,1-Dichloroethene
 1,2-DichIoroethane
 Benzene
 Chloroform
 Methylene Chloride
 Pentachlorophenol
 Phenol
 Tetrachloroethene
 Toluene
 Trichloroethene
 Vinyl Chloride
 TOTAL PRIORITY ORGANICS
 NON-CONVENTIONAL ORGANICS
 1,1,1,2-Tetrachloroethane
 1,2,3-Trichloropropane
 1,2-Dibromoethane
 2,3,4,6-Tefrachlorophenol
 2,3-Dichloroaniline
 2,4,5-Trichlorophenol
 2,4,6-TrichlorophenoI
 2-Butanone
 2-Propanone
 4-Methyl-2-pentanone
 Acetophenone
 Aniline
 Benzoic Acid
 Diethyl Ether
 Dimethyl Sulfonone
 Ethylenethiourea
 Hexanoic Acid
 m-Xylene
 N,N-Dimethylformamide
 o-Cresol
 Pyridine
 p-Cresol
 Tetrachloromethane
 Trans-l,2-Dichloroehtene
 TOTAL NON-CONVENTIONAL
 ORGANICS
 PRIORITY METALS
 Antimony
 Chromium
 Copper
 Nickel
 Zinc
5,366
23,062
5,888
1
2
1
1
1
1
9
27
103
47
15
1
9
1
219
1
1
1
82
3
13
11
115
269
19
5
1
42
0
21
574
8
1
1
24
15
9
2
3
N/A
N/A
N/A
154
463
48
183
314
109
631
258,747
1,779
54
368
7,722
211
110
270,893
1,312
1,576
1,926
661
' 243
292
140
2,432
361,967
1,028
21
151
594
7,640
22
750
108
638
4,957
1,019
53
280
165
400
5,366
23,062
5,888
1
2
1
1
1
1
9
27
103
47
15
1
9
1
219
1
1
1 .
82
3
13
11
115
269
19
5
1
42
0
21
574
8
1
1
24
15
9
2
3
N/A
N/A
N/A
0
1
1
1
0
1
6
40
243
3
7
0
2
0
305
4
4
5
140
7
26
10
26
146
8
1
1
19
24
2
648
5
2
2
31
2
7
1
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
N/A
N/A
N/A
154
462
47
182
314
108
625
258,707
1,536
51
361
7,722
209
110
270,588
1,308
1,572
1,921
521
236
266
130
2,406
361,821
1,020
20
150
575
7,616
20
102
103
636
4,955
988
51
273
164
398
1,221
388,375
1,221
1,094
                                                                  387,252
74
72
92
186
50
40
13
29
351
96
74
72
92
186
50
40
5
29
351
34
0
0
0
0
0
0
8
0
0
62
                                                      12-45

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Chanter 12 Pollutant Loadine and Removals Estimates
Development Document for the CWT Point Source Category
Table 12-12. Summary of Pollutant Loadings and Removals for the CWT Organics SubcategoryJ
Pollutant of Concern
Current Wastewater
Pollutant Loading
flbs/vr)
Direct Indirect
Post-Compliance Wastewater
Pollutant Loading
flbs/vnrt
Direct Indirect
P ost-Compliance Pollutant
Reductions
flbs/vr)
Direct Indirect
nischarpps nisrharces
TOTAL PRIORTTY METALS
NON-CONVENTIONAL METALS
Aluminum
Boron
Calcium
Iodine
Iron
Lithium
Magnesium
Manganese
Molybdenum
Phosphorus
Potassium
Silicon
Sodium
Strontium
Sulfur
Tin
TOTAL NON-CONVENTIONAL
METALS
CLASSICAL PARAMETERS
Total Cvanide
474

323
6,279
0
0
515
1,552
0
30
123
904
0
350
0
269
178,861
128
189,334

285
529

15,395
5,535
0
1,982
1,847
3,911
0
219
204
751
0
893
0
1,723
496,299
147
528,906

352
474

323
6,279
0
0
515
1,552
0
30
123
904
0
350
0
269
178,861
128
189,334

285
459

854
545
0
0
292
3,911
0
68
161
0
0
858
0
803
0
147
7,639

260
0

0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
70

14,541
4,990
0
1,982
1,555
0
0
151
43
751
0
35
0
920
496,299
0
521,267

92
'All loadings and reductions take into account the removals by POTWs for indirect discharges.
HEM - Hexane extractable material
                                               12-46

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Chapter 12. Pollutant Loading and Removals Estimates
                  Development Document for the CWTPointSource Category
Table 12-13. Summary of Pollutant Loadings and Removals for the Entire CWT Industry'
Pollutant of Concern
CONVENTIONALS2
TOTAL PRIORITY ORGANICS
Current Wastewater
Pollutant Loading
flbs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Wastewater
Pollutant Loading
(lbs/vr)
Direct Indirect
Discharges Discharges
Post-Compliance Pollutant
Reductions
flbs/vr)
Direct Indirect
Discharges Discharges
16,225,792 N/A 1,524,397 N/A 14,701,395 N/A
2,006 426,206 1,310 12,101 696 414,105
TOTAL NON-CONVENTIONAL
ORGANICS
TOTAL PRIORITY METALS
TOTAL NON-CONVENTIONAL
METALS
  13,463
 601,238
1,502,013
  68,604
1,079,386     1,343,796
  8,865
 13,232

285,287
136,032
 11,748

407,104
  4,598
588,006

794,099
1,365,951
  56,856
 936,692
JA11 loadings and reductions take into account the removals by POTWs for indirect discharges.
HEM - Hexane extractable material
2Oil and grease loadings and removals for the metals subcategory are not included in this table.
                                                12-47

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                                                                              Chapter
                                                                                  13
                             NON-WATER QUALITY IMPACTS
    Sections 304(b) and 306 of the Clean Water
    Act  provide  that   non-water   quality
environmental  impacts  are among the factors
EPA  must consider in establishing  effluent
limitations  guidelines and standards.  These
impacts are the environmental consequences not
directly associated with wastewater that may be
associated with the regulatory options considered.
For this rule, EPA evaluated the potential effect
of the proposed options on air emissions,  solid
waste generation, and energy consumption.
    This section quantifies the non-water quality
impacts associated with the options evaluated for
this proposal. Cost estimates for the impacts, and
the methods used to estimate these costs are
discussed in Chapter 11 of this document.. In all
cases, the costs associated with non-water quality
impacts were included in EPA's cost estimates
used in the economic evaluation of the proposed
limitations and standards.
AIR POLLUTION
13.1
    CWT  facilities   receive   and  produce
wastewaters    that    contain    significant
concentrations of organic compounds, some of
which are listed in Title 3 of the Clean Air Act
Amendments  (CAAA) . of  1990.    These
wastewaters often pass through a series of
collection and treatment units.  These units are
open to the atmosphere and allow wastewater
containing organic compounds to contact ambient
air.   Atmospheric exposure  of the organic-
containing wastewater may result in significant
water-to-air  transfers   of  volatile  organic
compounds (VOCs).
    The primary sources of VOCs in the CWT
industry are the wastes treated in the oils and the
organics subcategory. In general, CWT facilities
have not installed air or wastewater treatment
technologies designed to control the release of
VOCs to the atmosphere.  Additionally,  most
CWT facilities do not employ best management
practices designed  to control VOC emissions
(such  as   covering  their  treatment  tanks).
Therefore, as soon as these VOC-containing oil
and organic subcategory wastewaters  contact
ambient air, volatilization will begin to occur.
    Thus, volatilization of VOCs and HAPs from
wastewater may begin immediately on receipt, as
the wastewater enters the CWT facility, or as the
wastewater is discharged from the process unit.
Emissions  can also occur  from wastewater
collection units such as process drains, manholes,
trenches, sumps,  junction  boxes,  and  from
wastewater treatment  units  such as screens,
settling basins, equalization basins, biological
aeration basins, dissolved air flotation systems,
chemical precipitation systems, air or steam
strippers lacking air emission control devices, and
any other units where the wastewater is in contact
with the air. In some  cases, volatilization will
begin  at  the  facility  and  continue  as the
wastewaters are discharged to the local river or
POTW.
    EPA believes air emissions from existing
CWT facilities would be similar before or after
implementation of any of the proposed options.
This is due primarily to the nature of VOCs, the
failure  of  CWT   facilities  to  equip  their
wastewater treatment  systems with emissions
                                          13-1

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Chapter 13 Non-Water Quality Impacts
Development Document for the CWT Point Source Category
controls, and the lack of best  management
practices designed to control the  emissions of
volatile pollutants. While EPA does not project
any net increase in air emissions as a result of the
implementation   of   the   proposed   effluent
guidelines and standards,  EPA does project a
shift in the location of the VOC emissions.
    Table   13-1   provides  information  on
incremental   VOC  emissions resulting  from
implementation of the proposed rule at CWT oils
and organics facilities.  EPA has  not provided
information   for the metals  subcategory, but
believes these emissions would be negligible. For
this analysis, EPA defined a volatile pollutant as
described in Chapter 7 and calculated volatile
pollutant baseline and post-compliance loadings
and reductions as described in Chapter 12. EPA
additionally assumed that 80% of the volatile
pollutant reduction would be due to volatilization.
EPA selected 80% based  on an assessment of
information developed during the development of
OCPSF guidelines (see pages 275-285 of the
October 1987 "Development  Document  for
Effluent Limitations Guidelines and Standards
for the OCPSF Point Source Category  (EPA
440/1-87/009)).  EPA believes  the information
presented in Table 13-1 represents a "worst-case"
scenario in  terms of incremental volatile air
emissions,  since the  analysis  assumes  no
volatilization of pollutants at baseline.   As
explained earlier, EPA believes that the majority
of these pollutants are already being volatilized in
the absence of additional treatment technologies.
    Table 13-1 also shows that, for this worst-
case scenario, the sum of the annual VOC air
emissions at CWT facilities would not exceed
400 tons of HAPs.  Under the Clean Air Act,
major sources of pollution by HAPs are defined
as having either: (1) a total emission  of 25
tons/year or higher for the total HAPs from all
emission points at a facility; or (2) an emission of
 10 tons/year or higher from all emission points at
a facility. Based on these criteria, incremental air
       emissions from this worst-case scenario analysis
       of  the  proposed  BPT/BAT/PSES organics
       subcategory options would cause three facilities
       to be classified as major sources. For the oils and
       metals subcategories, EPA. does not project any
       major sources due to incremental removals. Since
       EPA believes that the three organics subcategory
       CWT facilities classified as major sources would
       be  classified  as  such in the  absence  of  the
       implementation of the proposed options, EPA has
       determined that air emission impacts from  the
       proposed options are acceptable.
            Finally, while this proposal is not based on
       technology that uses air stripping with emissions
       control to abate the release of volatile pollutants,
       EPA encourages all facilities which accept waste
       containing volatile pollutants to incorporate air
       stripping with overhead recovery or destruction
       into  their   wastewater   treatment  systems.
       Additionally, EPA also notes that CWT sources
       of  hazardous  air  pollutants  are  subject  to
       maximum   achievable  control    technology
       (MACT) as promulgated for off-site waste and
       recovery operations on July 1, 1996  (61  FR
       34140) as 40 CFR Part 63.
                                            13-2

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Chapter 13 Non-Water Quality Impacts
 Development Document for the CWT Point Source Category
Table 13-1. Projected Air Emissions at CWT Facilities
Subcategory
Oils
Organics
VOCs Emitted
(tons/yr)
69
329
Priority VOCs
Emitted
(tons/yr)
32
323
Number of Projected
MACT* Facilities
0
3
Major Constituents
Toluene
Methylene Chloride
and Toluene
    *   MACT requires 25 tons of volatile emissions for a facility to be a major source or 10 tons of a single
        pollutant at a single facility.
SOLID WASTE
13.2
    Solid waste will be generated by several of
the  proposed  treatment  technologies  EPA.
evaluated.  These wastes include sludges from
biological treatment, chemical precipitation and
clarification, gravity separation, and dissolved air
flotation systems.
    To estimate the incremental sludge generated
from the proposed options, EPA subtracted the
volume of sludge currently being generated by the
CWTs from the estimated volume of sludge that
would be generated after implementation of the
options.  EPA-calculated the volume of sludge
currently being generated by CWT facilities for
all sludge-generating technologies currently being
operated at CWT facilities. EPA then calculated
the volume of sludge that would be generated by
CWT  facilities after implementation  of the
proposed options.   Table  13-2 presents the
estimated  increase in volumes of filter  cake
generated by CWT facilities that would result
from implementation of the proposed limitations
and standards.
    The precipitation and subsequent separation
processes proposed as the technology basis for
the metals subcategory will produce a metal-rich
filter cake. In most instances, the resulting filter
cake will require disposal in Subtitle C and D
landfills. EPA estimates that the annual increase
in filter cake generated by the metals subcategory
facilities will  be  3.71  million gallons.   In
evaluating  the  economic  impact  of  sludge
disposal, EPA assumed that all of the sludge
generated would be disposed in a landfill. This
assumption does not take into consideration the
fact that an undetermined portion of the generated
filter cake may be recovered in secondary metals
manufacturing processes  rather  than  being
disposed in a landfill.
   The  dissolved air flotation system and
additional gravity separation step proposed as the
technology basis for the oils subcategory will
produce a filter cake with varying solids and oil
content.  This filter cake may be either disposed
in Subtitle C and D landfills or in some cases
through  incineration.   EPA  estimates  that the
annual increase in filter cake generated by the oils
subcategory facilities  will  be  22.68  million
gallons.   These   estimates   are   based  on
implementation of option  8 technology for
indirect dischargers (PSES)  and option 9 for
direct dischargers (BPT/BAT). EPA applied a
scale-up factor to include the estimated volume of
filter  cake  generated by  the NOA   non-
respondents.  In evaluating the economic impact
of sludge disposal, EPA assumed that all of the
sludge generated would be disposed in a landfill.
    Biological  treatment  proposed   as  the
technology basis for the organics subcategory will
produce  a filter cake that consists primarily of
biosolids. This filter cake can be disposed by a
variety of means including disposal at Subtitle C
and Subtitle D landfills, incineration, composting,
                                             13-3

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Chapter 13 Non-Water Quality Impacts
Development Document for the CWT Point Source Category
and  land application.  However, contaminants
contained in the sludges may limit the use of
composting and land application. EPA estimates
that the annual increase in filter cake generated by
the organics subcategory facilities will be 4.31
million  gallons.  In  evaluating the economic
impact of sludge disposal, EPA assumed that all
of the sludge generated would be disposed in a
landfill.
    Table 13-3 presents the percentage of the
national volume of hazardous and non-hazardous
waste sent to landfills represented by the increase
       for each regulatory  option.  The information
       presented in this table represents the tonnage of
       waste  accepted  by landfills in 1992  and was
       based  on  information .collected during  the
       development of the proposed Landfills  Point
       Source Category (see pages 3-32 of the January
       1998 "Development Document for Proposed
       Effluent Limitations Guidelines and Standards
       for the Landfills Point Source Category" (EPA-
       821-R-97-022)).  Based on this analysis, EPA
       has determined that the solid waste impacts of the
       proposed regulatory options are acceptable.
    Table 13-2. Projected Incremental Filter Cake Generation at CWT Facilities

CWT
Subcategory
Metals

Oils

Organics
Total
Filter Cake Generated (million gal/yr)
Option
4
8

9
4
-
Indirect
0.
10


2.
13
80
.04


89
.73
Hazardous
Direct
1.68
_

0
0
1.68
Total
2.48
10.04

0
2.89
15.41
Non-Hazardous
Indirect Direct Total
0.40
12.28

-
1.42
14.1
0.83
_

0.36
0
1.19
1.23
12.28

0.36
1.42
15.29
    Table 13-3. National Volume of Hazardous and Non-hazardous Waste Sent to Landfills
CWT
Subcategory
Metals
Oils

Organics
Total
Option

4
8
9
4

Percentage of Annual Tonnage of Waste
Disposed in National Landfills
Hazardous
0.032
0.093
0
0.024
0.149
Non-hazardous
0.004
0.028
0.001
0.003
0.036
                                            13-4

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Chapter 13 Non-Water Quality Impacts
 Development Document for the CWT Point Source Category
ENERGY REQUIREMENTS
13.3
    EPA estimates that the attainment of the
proposed   options   will   increase   energy
consumption by a small increment over present
industry use.  The projected increase in energy
consumption is primarily due to the incorporation
of components such as pumps, mixers, blowers,
lighting, and controls.  Table 13-4 presents the
estimated increase in energy requirements that
would result  from the implementation of the
proposed  limitations  and  standards.   The
estimated total increase in energy consumption of
7.51 million kilowatt hours per year that would
result  from  compliance  with the proposed
regulation equates to 4,209 barrels of oil per day.
According to the United  States Department of
Energy-Energy Information Administration
website   (http ://www.eia.doe.gov/pub/energy/
overview/aer),  the  United  States  currently
consumes 18.3 million barrels of oil per day.
Therefore,  EPA has  determined that  energy
impacts  from the  proposed rule would  be
acceptable.
        LABOR REQUIREMENTS
                                       13.4
            The installation of new wastewater treatment
        equipment  along with  improvements  in the
        operation of existing equipment for compliance
        with the proposed  limitations  and standards
        would  result  in  increased  operating  labor
        requirements for CWT facilities. It is estimated
        that compliance with the CWT regulations would
        result in industry-wide employment gains.  Table
        13-5  presents  the estimated increase in labor
        requirements for the CWT industry.
    Table 13-4. Projected Energy Requirements for CWT Facilities
Energy Usage (kwh/yr)
CWT Subcategory Option
Metals 4
Cyanide Waste ^
Pretreatment
Oils 8
Organics 4
Total
Indirect
Dischargers
1,805,369
129,000
3,336,584
505,175
5,776,128
Direct
Dischargers
1,551,195
18,046
137,061
24,069
1,730,371
Total
3,356,564
147,046
3,336,584
137,061
529,244
7,506,499
                                           13-5

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Chapter 13 Non-Water Quality Impacts
                      Development Document for the CWT Point Source Category
    Table 13-5. Projected Labor Requirements for CWT Facilities
                                             Operating Labor Requirements
Q ,CWT Option
Subcategory
Indirect Dischargers
(Hours/yr) (Men/yr)
Direct Dischargers
(Hours/yr) (Men/yr)
Total
(Hours/yr) (Men/yr)
        Metals
       Cyanide
        Waste
     Pretreatment
         Oils
       Organics
4

2

8
9
4
85,448      42.7

16,425       8.2

57,825      25.9

29,042      14.5
27,105

2,190
2,496
 936
13.6     112,553      56.3
 1.1       18,615
1.2
0.5
57,825
 2,496
29,978
 9.3

25.9
 1.2
 15
        Total
       188,740     91.3
                      32,727
            16.4
         221,467
                                                                                    107.7
                                              13-6

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                                                                               Chapter
                                                                                    14
                                                      IMPLEMENTATION
  Implementation of a regulation is a critical step
  in the regulatory process. If a regulation is not
effectively  implemented,  the  removals and
environmental  benefits  estimated  for  the
regulation may  not  be achieved.   Likewise,
ineffective  implementation could  hinder  the
facility's  operations  without  achieving  the
estimated environmental benefits. In discussions
with permit writers and pretreatment authorities
many stated that close communication with C WT
facilities   is   important    for    effective
implementation of discharge permits.  Control
authorities need to have a thorough understanding
of a CWT's operations to effectively implement
this rule. Likewise, CWT facilities must maintain
close communication with the waste generators in
order to accurately characterize and treat the
incoming waste streams.
APPLICABLE WASTE STREAMS
14.1
    Chapter  5   describes  the  sources   of
wastewater for the CWT industry, which include
the following:

Off-site-generated wastewater:
   Waste   receipts   via   tanker    truck,
    trailer/roll-off bins, and drums.

On-site-generated wastewater:
   Equipment/area washdown
   Water separated  from recovered/recycled
    materials
   Contact/wash  water from recovery  and
    treatment operations
   Transport container washdown
   Solubilization water
   Laboratory-derived wastewater
   Air pollution control wastewater
   Incinerator   wastewater   from   on-site
    incinerators
   Landfill wastewater from on-site landfills
   Contaminated stormwater.

All of these waste streams should be classified as
process wastewater and are thus subject to the
appropriate  subcategory  discharge  standards.
EPA believes that uncontaminated stormwater
should not be mixed with waste receipts prior to
complete treatment of the waste receipts since
this arrangement may allow discharge standards
to  be  met by  dilution rather  than  proper
treatment.  However, EPA is concerned that only
contaminated stormwater (i.e. stormwater whic
comes  in contact with waste receipts and waste
handling and treatment areas) be classified as a
process wastewater. During site visits at CWT
facilities, EPA observed many circumstances in
which    uncontaminated   stormwater   was
commingled with the CWT wastewaters prior t
treatment or was added after treatment prior to
effluent discharge monitoring. EPA believes that
permit  writers and  pretreatment authorities
should be responsible for determining  which
stormwater  sources  warrant  designation  as
process  wastewater.    Additionally,   control
authorities should require facilities to monitor and
meet   their  CWT  discharge  requirements
following wastewater treatment  and prior to
combining these treated CWT wastewaters with
non-process wastewaters. If a control authority
allows  a facility  to  combine treated CWT
wastewaters with non-process wastewaters prior
to compliance monitoring, the control authori y
should  ensure  that  the   non-contaminated
stormwater dilution flow is factored into the
facility's permit limitations.
                                           14-1

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Chapter 14 Implementation
Development Document for the CWT Point Source Categor
    EPA  has also  observed situations where
stormwater, contaminated and uncontaminated,
was  recycled  as  process  water  (e.g.,  as
solubilization water for wastes in the solid phase
to  render the  wastes  treatable).    In these
instances, dilution is  not the  major source of
pollutant  reductions (treatment).   Rather,  this
leads to reduced wastewater discharges. Permit
writers  and  pretreatment authorities  should
investigate  opportunities  for  use  of  such
alternatives  and  encourage   such  practices
wherever feasible.

DESCRIPTION OF SUBCATEGORY  14.2

    One  of  the most important  aspects of
implementation  is the determination of which
subcategory's limitations  are  applicable  to  a
facility's operations). As detailed in Chapter 5,
EPA established a subcategorization scheme
based on the character of the wastes being treated
and the treatment technologies utilized.   The
subcategories are as follows:

Subcategory A:  Metals Subcategory:
    Facilities which treat, recover, or treat and
    recover metal,  from metal-bearing waste,
    wastewater, or used material received from
    offsite;

Subcategory B:  Oils Subcategory:
    Facilities which treat, recover, or treat and
    recover oil, from oily waste, wastewater, or
    used material received from offsite; and

Subcategory C:  Organics Subcategory:
    Facilities which treat, recover, or treat
    and recover organics, from other organic
    waste, wastewater, or used  material
    received from offsite;

    The  determination of a  Subcategory  is
primarily based on the type of process generating
       the waste, the characteristics of the waste, and the
       type of treatment technologies which would be
       effective in treating the wastes. It is important to
       note that various pollutants were detected in all
       three subcategories. That is,, organic constituents
       were detected in metal Subcategory wastewater
       and vice versa. The following sections provide a
       summary description of the wastes in each of the
       three subcategories; a more detailed presentation
       is in Chapter 5.
       Metals Subcategory Description
14.2.1
           Waste  receipts classified in  the metals
       subcategory include, but are not limited to:  spent
       electroplating baths and sludges, spent anodizing
       solutions, air pollution control water and sludges,
       incineration wastewaters, waste liquid mercury,
       metal finishing rinse water and sludges, chromate
       wastes,  cyanide-containing wastes,  and waste
       acids  and bases.   The primary  concern with
       metals  subcategory waste  streams  is  the
       concentration of metal constituents, and some
       form of chemical precipitation with solid-liquid
       separation is essential. These raw waste streams
       generally contain few organic consituents and
       have low oil and grease levels.  The range of oil
       and  grease  levels  in   metal  subcategory
       wastestreams sampled by EPA was 5 mg/L (the
       minimum analytical detection limit) to 143 mg/L.
       The average oil and grease level measured  at
       metals facilities by EPA was 39 mg/L.   As
       expected, metal concentrations in wastes from
       this  subcategory  were   generally  high   in
       comparison to other subcategories.  In general,
       wastes that contain significant  quantities  of
       inorganics and/or metals should be classified in
       the metals subcategory.
        Oil Subcategory Description
14.2.2
           Waste  receipts   classified  in  the  oils
        subcategory include,  but  are not limited to:
                                            14-2

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Chapter 14 Implementation
Development Document for the CWT Point Source Categor
lubricants, used petroleum products, used oils, oil
spill clean-up, interceptor wastes, bilge water,
tank  cleanout,   off-specification  fuels,   and
underground storage tank remediation waste.
Based on EPA's sampling data, oil and grease
concentrations  in   these  streams  following
emulsion  breaking  and/or  gravity  separation
range from 23 mg/L to 180,000 mg/L.  The
facility average value is 5,976 mg/L. Based on
information provided by industry, oil and grease
content in these waste receipts prior to emulsion
breaking and/or gravity separation varies  between
0.1% and 99.6% (1,000 mg/L to 996,000 mg/L).
  Additionally,  as   measured  after emulsion
breaking and/or gravity separation, these oily
wa.stewaters generally contain a broad  range of
organic and metal constituents. Therefore, while
the primary concern is often a reduction in oil and
grease  levels, oils  subcategory  wastewaters
require  treatment for metal constituents  and
organic constituents also. In general, wastes that
do  not  contain  a recoverable  quantity of oil
should  not be classified  as  being in  the  oils
subcategory. The only exception to that would be
wastes  contaminated with  gasoline or  other
hydrocarbon fuels.

Organics Subcategory Description     14.2.3

    Waste receipts  classified in the  organics
subcategory include, but are  not  limited to:
landfill  leachate, contaminated groundwater
clean-up, solvent-bearing waste, off-specification
organic product, still bottoms, used  glycols,
wastewater from adhesives  and epoxies,  and
wastewater from chemical product operations and
paint washes.  These wastes generally contain a
wide variety  and   concentration  of  organic
compounds,   low   concentrations   of  metal
compounds'(as compared to waste receipts in the
metals subcategory), and low concentrations of
oil and grease.   The concentration  of oil  and
grease in organic subcategory samples measured
       by EPA ranged from 2mg/L to 42 mg/L with an
       average value of 22 mg/L. The primary concern
       for organic  wastestreams  is the reduction in
       organic constituents which generally  requires
       some form of biological treatment.  In general,
       wastes that do not contain significant quantities
       of inorganics, metals, or recoverable quantities of
       oil or fuel should be classified as belonging to the
       organics subcategory.
       FACILITY SUBCATEGORIZATION
       IDENTIFICATION
14.3
           EPA  believes that the  paperwork  and
       analyses currently performed at CWT facilities as
       part of their waste acceptance procedures (as
       outlined in Chapter 4) are generally sufficient for
       making a subcategory determination.  EPA has
       strived    to     base    its    recommended
       subcategorization  determination procedure on
       information generally obtained during these waste
       acceptance and confirmation procedures.  EPA
       discourages  permit  writers and pretreatment
       authorities from requiring additional monitoring
       or  paperwork  solely  for  the  purpose  of
       subcategory determinations.  In most cases, as
       detailed below,  EPA believes the subcategory
       determination can be made on the type of waste
       receipt, e.g., metal-bearing sludge, waste oil,
       landfill leachate.  EPA believes that  all CWT
       facilities  should,  at  a  minimum,  collect
       information  from the generator on the type of
       waste  receipt   since  this  is  the  minimum
       information required  by  CWT  facilities  to
       effectively treat off-site wastes.
           To  determine   an   existing   facility's
       subcategory classifications), the facility should
       review its incoming  waste receipt data for  a
       period of one year. The facility should first use
       Table  14-1 below to classify each of its waste
       receipts  for  that one year  period  into  a
       subcategory.    Finally,  the  facility  should
       determine the relative percent of off-site wastes
       accepted in each subcategory (by volume).
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Chapter 14 Implementation
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  Table 14-1 Waste Receipt Classification
  Metals Subcategory
spent electroplating baths and/or sludges;
metal finishing rinse water and sludges;
chromate wastes;
air pollution control water and sludges;
incineration wastewaters;
spent anodizing solutions;
waste liquid mercury;
cyanide-containing wastes (>136 mg/L); and
waste acids and bases with or without metals.
  Oils Subcategory
used oils;
oil-water emulsions or mixtures;
lubricants;
coolants;
contaminated groundwater clean-up from petroleum sources;
used petroleum products;
oil spill clean-up;
bilge water;
rinse/wash wasters from petroleum or oily sources;
interceptor wastes;
off-specification fuels;
underground storage remediation waste; and
tank clean-out from petroleum or oily sources
   Organics Subcategory
landfill leachate;
contaminated groundwater clean-up from non-petroleum sources
solvent-bearing wastes;
off-specification organic product;
still bottoms;
used glycols;
wastewater from paint washes;
wastewater from adhesives and/or epoxies;
wastewater from chemical product operations; and
tank clean-out from organic, non-petroleum sources	
     If the waste receipt is listed above, the
Subcategory determination is made solely from
the  information provided in Table  14-1.  If,
however, the waste receipt is unknown or not
listed above, the facility should use the following
hierarchy   to   determine  the   appropriate
subcategory:

1).  If the waste receipt contains  oil and
     grease at or in excess of 100 mg/L, the
     waste receipt should be classified in
     the oils subcategory;
                     ' 2).  If the waste receipt contains oil and
                           grease <100 mg/L, and has  either
                           cadmium, chromium, copper, or nickel
                           concentrations in excess of the values
                           listed below, the waste receipt should
                           be classified in the metals subcategory.
                              cadmium       0.2 mg/L
                              chromium      8.9 mg/L
                              copper         4.9 mg/L
                              nickel          37.5 mg/L
                      3).  If the waste receipt contains oil and
                           grease < 100 mg/L, and does not have
                           concentrations of cadmium, chromium,
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     copper, or nickel  above any of the
     values listed above, the waste receipt
     should be classified in  the organics
     subcategory.

This process is also illustrated in Figure 14-1.
     Members of the  CWT industry  have
expressed concern that wastes may be received
from the generator as a "mixed waste", i.e., the
waste  may be  classified in more than  one
subcategory. Based on the information collected
during the development of this rule, using the
subcategorization procedure recommended in this
section, EPA is able to classify  each waste receipt
identified by the industry into the appropriate
subcategory. Therefore, EPA  believes that these
"mixed  waste receipt" concerns  have  been
addressed  in  the  current  subcategorization
procedure.
     Once    the     facility's    subcategory
determination has been made, the facility should
not be required to make an annual determination.
However, if a single subcategory facility alters
their operation to  accept wastes from another
subcategory or if a mixed waste facility alters its
annual   operations  to  change  the  relative
percentage of waste receipts in one subcategory
by more than 20 percent, the facility should notify
the appropriate permit writer or pretreatment
authority and the subcategory determination
should be re-visited. EPA also recommends that
the subcategory determination be re-evaluated
whenever the permit is re-issued.
     For new CWT facilities, the facility should
estimate  the  percentage of  waste  receipts
expected in each subcategory. Alternatively, the
facility could compare the treatment technologies
being   installed  to  the  selected  treatment
technologies for each subcategory.  After the
initial  year of operation, the permit  writer or
pretreatment authority should re-visit the CWT's
subcategory  determination  and  follow  the
procedure outlined for existing facilities.
     Some facilities, such as  those located near
       auto  manufacturers,  claim  that  their  waste
       streams vary significantly for very limited time
       spans each year, and that they would be unable to
       meet limitations  based on their  annual waste
       receipts during these time periods. In these cases,
       one set of limits or standards may  not  be
       appropriate for the permit's entire period. EPA
       recommends that a tiering approach be used in
       such situations. In tiered permits, the  control
       authority  issues   one permit  for  "standard"
       conditions and another set which take effect when
       . there is a significant change in the waste receipts
       accepted.    EPA's Industrial User Permitting
       Guidance Manual (September 1989) recommends
       that tiered permits should be considered when
       production'rate varies by 20 percent or greater.
       Since this rule is not production based, EPA
       recommends that for the CWT industry, tiered
       permits   should   be  considered  when  the
       subcategory determination varies  for selected
       time  periods by  more than 20 percent.  An
       example  when a tiered  approach  may  be
       appropriate in the CWT industry would be if a
       CWT facility's major customer (in terms of flow)
       does  not  operate for a two week  period in
       December.  The CWT facility would not  be
       receiving  waste receipts from the generating
       facility during their two week closure which could
       greatly alter the relative percent of waste accepted
       by the CWT facility for the two week period only.
              As explained previously, many facilities
       have waste streams that vary on a daily basis.
       EPA cautions that the tiering approach should
       only be used for facilities which have limited,
       well-defined, "non-standard" time periods.  A
       tiered permit should only be considered when the
       control authority  thoroughly understands  the
       CWTs operations and when a substantial change
       in  the  relative percentages  of waste in each
       subcategory  would  effect  permit  conditions.
       Additionally, a tiered permit is never required if
       compliance is measured on a subcategory basis
       after each treatment system.
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            Is the waste receipt listed
                 ia Table 14-1?
                          No
            . Does the receipt contain
              oil and grease at or in
               excess of 100 mg/L?
             Does it have any of the
              following metals in
            concentrations exceeding:
              Cadmium: 0.2 mg/L?
              Chromium: 8.9 mg/L?
               Copper: 4.9 mg/L?
               Nickel: 37.5 mg/L?
                          No
            The waste receipt is in the
              organics subcategory
                                          Yes
              Consult Table 14-1 for
                 subcategorization
Yes
             The waste receipt is in the
                 oils subcategory
Yes
             The waste receipt is in the
                metals subcategory
  Figure 14-1. Waste Receipt Subcategory Classification Diagra
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Chapter 14 Implementation
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ON-SITE GENERATED WASTEWATER
SUBCATEGORY DETERMINATION
14.4
     Section  14.3   details  the   subcategory
determination for off-site waste receipts.  For
other on-site generated wastewater sources such
as those described in Section 14.1, wastewater
generated in support of, or as the  result of,
activities associated with each subcategory should
be classified in that subcategory.  For facilities
that are classified in a single subcategory, the
facility   should  generally  classify  on-site
wastewater in that subcategory. For facilities that
are classified in more than one  subcategory,
however, the facility should apportion the on-site
generated   wastewater  to  the   appropriate -
subcategory.  Certain waste streams may be
associated with more than one subcategory such
as stormwater, equipment/area washdown, air
pollution control wastewater, etc.   For these
wastewater sources, the volume generated should
be apportioned to each associated subcategory.
For example, for contaminated  stormwater, the
volume  can  be apportioned  based  on  the
proportion of the surface area  associated with
operations in each subcategory.  Equipment/area
washdown may be assigned to a subcategory
based on the volume of waste treated in each
subcategory.  Alternatively, control authorities
may  assign the on-site  wastestreams  to a
subcategory based on the appropriateness of the
selected subcategory treatment technologies.

On-site Industrial Waste Combustors,
Landfills, and Transportation
Equipment Cleaning Operations      14.4.1

     As noted previously,  wastewater  from
on-site industrial waste combustors, landfills, and
transportation equipment and cleaning operations
that is commingled  with CWT wastewater for
treatment shall be classified as CWT process
wastewater. Like the off-site waste receipts, the
subcategory determination of these wastewaters
should be based  on the characteristics  of the
wastewater  and  the  appropriateness  of  the
application of treatment technologies associated
with each subcategory.
     For wastewater associated with industrial
waste  combustors,  the  wastewater should be
classified as a metals subcategory wastestream.
This reflects the treatment technology selected in
the recently proposed rule for Industrial Waste
Combustors (63 FR 6392-6423).   For landfill
wastewater, the wastewater should be classified
as an organics subcategory wastestream. This
also reflects the treatment technology selected in
the recently  proposed rule for Landfills (63 FR
6426-6463)1. For wastewaters associated with
transportation  equipment   cleaning,   these
wastestreams should be classified in a manner
similar to that used for off-site waste receipts.

SUBCATEGORY DETERMINATION IN EPA
QUESTIONNAIRE DATA BASE             14.5

     In  order  to estimate  the  quantities of
wastewater being discharged, current pollutant
loads,  pollutant  reductions,  post compliance
costs,  and  environmental benefits  for each
subcategory, EPA developed a methodology to
classify waste streams for CWT facilities in the
EPA Waste Treatment Industry Questionnaire
database into each  of the proposed subcategories.
The following is a list of the rules used by EPA in
the subcategory  .determination of the  wastes
reported  in 308 Questionnaires.  The rules rely
primarily on  Waste   Form   Codes   (where
available) plus RCRA wastes codes. Table 14-2
lists the  waste  form  codes  utilized  in this
classification.
                 'For leachate generated at Subtitle C
         landfills (hazardous), the selected technology basis
         is chemical precipitation and biological treatment.
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    Chapter 14 Implementation
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Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 198
                                              RCRA COPES
D001   Ignitable Waste
D002   Corrosive Waste
D003   Reactive Waste
D004   Arsenic
D005   Barium
D006   Cadmium
DO 07   Chromium
D008   Lead
D009   Mercury
DO 10   Selenium
DO 11   Silver
D012   Endrin(l,2)3,4,10,10-hexachlorc-lJ7-epoxy-l,4,4a,5,6,7,8,8a-octahydro-l,4-endo-5,8-dimeth-ano
        napthalene)
D017   2,4,5-TP Silvex (2,4,5-trichlorophenixypropionic acid)
D035   Methyl ethyl ketone
FOO1   The following spent halogenated solvents used in degreasing: tetrachloroethylene; Irichloroethane; carbon
        tetrachloride and chlorinated fluorocarbons and all spent solvent mixtures/blends used in degreasing
        containing, before use, a total of 10 percent or more (by volume) of one or more of the above halogenated
        solvents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery of these spent
        solvents and spent solvent mixtures
F002   The following spent halogenated solvents: tetrachloroethylene; 1,1,1-trichloroetharie; chlorobenzene; 1,1,2-
        trichloro-1,2,2- trifluoroethane; ortho-dichlorobenzene; trichloroethane; all spent solvent mixtures/blends
        containing, before use, a total of 10 percent or more (by volume) of one or more of the above halogenated
        solvents or those solvents listed in F001, F004, and F005; and still bottoms from the recovery of these spent
        solvents and spent solvent mixtures
F003   The following spent nonhalogenated solvents: xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether,
        methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends
        containing, before use, one or more of the above nonhalogenated solvents, and a toial of 10 percent or more
        (by volume) of one or more of those solvents listed in F001, F002, F004, and F005-1  and still bottoms from
        the recovery of these spent solvents and spent solvent mixtures.
F004   The following spent nonhalogenated solvents: cresols, cresylic acid, and nitrobenzene; and the still bottoms
        from the recovery of these solvents; all spent solvent mixtures/blends containing before use a total of 10
        percent or more (by volume) of one or more of the above nonhalogenated solvents or those solvents listed in
        F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures
F005   The following spent nonhalogenated solvents: toluene, methyl ethyl ketone, carbon disulfide, isobutanol,
        pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before
        use, a total of 10 percent or more (by volume) of one or more of the above nonhalogenated solvents or those
        solvents listed in F001, F002, or F004; and still bottoms from the recovery of these spent solvents and spent
        solvents mixtures
F006   Wastewater treatment sludges from electroplating operations except from the following processes: (1)
        sulfuric acid anodizing of aluminum; (2) tin plating on carbon steel;  (3) zinc plating (segregated basis) on
        carbon steel; (4) aluminum or zinc-aluminum plating on carbon steel: (5) cleaning/stripping associated with
        tin, zinc, and aluminum plating on carbon steel; and (6) chemical etching and milling of aluminum
F007   Spent cyanide plating bath solutions from electroplating operations
F008   Plating bath residues from the bottom of plating baths from electroplating operations  in which cyanides are
        used in the process	
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Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
F009   Spent stripping and cleaning bath solutions from electroplating operations in which cyanides are used in the
        process
F010   Quenching bath residues from oil baths from metal heat treating operations in which cyanides are used in the
        process
FO11   Spent cyanide solutions from slat bath pot cleaning from metal heat treating operations
FO12   Quenching waste water treatment sludges from metal heat treating operations in which cyanides are used in
        the process
FO 19   Wastewater treatment sludges from the chemical conversion coating of aluminum
F039   Multi-source leachate
KOO1   Bottom sediment sludge from the treatment of wastewater from wood preserving processes that use creosote
        and/or pentachlorophenol
KOI 1   Bottom stream from the wastewater stripper in the production of acrylonitrile
KO13   Bottom stream from the acetonitrile column in the production of acrylonitrile
KOI 4   Bottoms from the acetonitrile purification column in the production of acrylonitrile
KOI 5   Still bottoms from the distillation of benzyl chloride
KOI 6   Heavy ends or distillation residues from the production of carbon tetrachloride
K031   By-product salts generated in the production of MSMA and cacodylic acid
K035   Wastewater treatment sludges generated in the production of creosote
K044   Wastewater treatment sludges from the manufacturing and processing of explosives
K045   Spent carbon from the treatment of wastewater containing explosives K048 air flotation (DAF) float from the
        petroleum refining industry K049 Slop oil emulsion solids from the petroleum refining industry
K050   Heat exchanger bundle cleaning sludge from the petroleum refining industry
K051   API separator sludge from the petroleum refining industry
K052   Tank bottoms (leaded) from the petroleum refining industry
K061   Emission control dust/sludge from the primary production of steel in electric furnaces
K064   Acid plant blowdown slurry/sludge resulting from the thickening of blowdown slurry from primary copper
        production
K086   Solvent washes and sludges, caustic washes and sludges, or water washes and sludges from cleaning tubs and
        equipment used in the formulation of ink from pigments, driers, soaps, and stabilizers containing chromium
        and lead
K093   Distillation light ends from the production of phthalic anhydride from ortho-xylene
K094   Distillation bottoms from the production of phthalic anhydride from ortho-xylene
K098   Untreated process wastewater from the production of toxaphene
K103   Process residues from aniline extraction from the production of aniline K104 Combined wastewater streams
        generated from nitrobenzene/aniline production
P011   Arsenic pentoxide (t)
PO12   Arsenic (III) oxide (t) Arsenic trioxide (t)
P013   Barium cyanide
P020   Dinoseb, PhenoI,2,4-dinitro-6-(l-methylpropyl)-
P022   Carbon bisulfide (t)
        Carbon disulfide (t)
P028   Benzene, (chloromethyl)
        -Benzyl chloride
P029   Copper cyanides
P030   Cyanides (soluble cyanide salts), not elsewhere specified (t)	
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    Chapter 14 Implementation
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Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
P040   0,0-diethyl 0-pyrazinyl phosphorothioate
        Phosphorothioic acid, 0,0-diethyl 0-pyrazinyl ester
P044   Dimethoate (t)
        Phosphorodithioic acid,
        0,0-dimethyl S-[2-(methylamino)-2-oxoethyl]ester (t)
P048   2,4-dinitrophenol
        Phenol,2,4-dinitro-
P050   Endosulfan
        5-norbornene-2,3-dimethanol,
        l,4,5,6,7,7-hexachloro,cyclic sulfite
P063   Hydrocyanic acid
        Hydrogen cyanide
P064    Methyl isocyanate
        Isocyanic acid, methyl ester
P0<39   2-methyllactonitrile
        Propanenitrile,2-hydroxy-2-methyl-
P071    0,0-dimethyl 0-p-nitrophenyl phosphorothioate
        Methyl parathion
P074   Nickel (E) cyanide
        Nickel cyanide
P078   Nitrogen (TV) oxide
        Nitrogen dioxide
P087    Osmium tetroxide
        Osmium oxide
P089   Parathion (t)
        Phosphorothiotic acid,0,0-diethyl 0-(p-nitrophenyl) ester (t)
P098   Potassium cyanide
P104   Silver cyanide
PI06   Sodium cyanide
P121   Zinc cyanide
PI23   Toxaphene
        Camphene,octachloro-
U002   2-propanone (i)
        Acetone (i)
U003   Ethanenitrile (i,t)
        Acetonitrile (i,t)
U008   2-propenoic acid (i)
        Acrylic acid (i)
U009   2-propenenitrile
         Acrylonitrile
UO12    Benzenamine (i,t)
         Aniline (i,t)
U019    Benzene (i,t)	
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    Chapter 14 Implementation
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Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
U020   Benzenesulfonyl chloride (c,r)
        Benzenesulfonic acid chloride (c,r)
U031   l-butanol(i)
        N-butyl alcohol (i)
U044    Methane, trichloro-
        Chloroform
U045   Methane,chloro-(i,t)
        Methyl chloride (i,t)
U052   Cresylicacid
        Cresols
U057   Cyclohexanone (i)
U069   Dibutyl phthalate
        1,2-benzenedicarboxylic acid, dibutyl ester
U080   Methane,dichloro-
        Methylene chloride
U092   Methanamine, N-methyl-(i)
        Dimethylamine (i)
U098   Hydrazine, 1,1-dimethyl-
        1,1 -dimethylhy drazine
U105   2,4-dinotrotoluene
        Benzene, l-methyl-2,4-dinitro-
U106   2,6-dinitrotoluene
        Benzene, l-methyl-2,6-dinitro
U107   Di-n-octyl phthalate
        1-2-benzenedicarboxylic acid, di-n-octyl ester
U113   2-propenoic acid, ethyl ester (i)
        Ethyl acrylate (i)
Ul 18   2-propenoic acid, 2-methyl-, ethyl ester
        Ethyl methacrylate
U122   Formaldehyde
        Methylene oxide
U125   Furfural (i)
        2-furancarboxaldehyde (i)
Ul 34   Hydrogen fluoride (c,t)
        Hydrofluoric acid.(c,t)
U135   Sulfur hydride
        Hydrogen sulfide
U139   Ferric dextran
        Iron dextran
U140   1 -propanpl, 2-methyl- (i,t)
        Isobutyl alcohol (i,t)
U150   Melphalan
        Alanine, 3-[p-bis(2-chloroethyl)amino] phenyl-,L-
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Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
U151   Mercury
U154   Methanol(i)
        Methyl alcohol (i)
Ul 59   Methyl ethyl ketone (i,t)
        2-butanone (i,t)
U161   4-methyl-2-pentanone (i)
        Methyl isobutyl ketone (i)
U162   2-propenoic acid,2-methyl-,methyl ester (i,t)
        Methyl methacrylate (i,t)
U188   Phenol
        Benzene, hydroxy-
U190   Phthalic anhydride
        1,2-benzenedicarboxylic acid anhydride
U205   Selenium disulfide (r,t)
        Sulfur selenide (r,t)
U210   Tetrachloroethylene
        Ethene, 1,1,2,2-tetrachloro
U213   Tetrahydrofuran (i)
        Furan, tetrahydro- (i)
U220   Toluene
        Benzene, methyl-
U226   1,1,1-trichloroethane
        Methylchloroform
U228   Trichloroethylene
        Trichloroethene
U239   Xylene(i)
        Benzene, dimethyl- (i,t)
                                          WASTE FORM CODES
BOO 1   Lab packs of old chemicals only
B101   Aqueous waste with low solvent
B102   Aqueous waste with low other toxic organics
BIOS   Spent acid with metals
Bl 04   Spent acid without metals
B105   Acidic aqueous waste
B106   Caustic solution with metals but no cyanides
B107   Caustic solution with metals and cyanides
BIOS   Caustic solution with cyanides but no metals
B109   Spent caustic
B110   Caustic aqueous waste
Bill   Aqueous waste with reactive sulfides
B112   Aqueous waste with other reactives (e.g., explosives)
B113   Other aqueous waste with high dissolved solids
B114   Other aqueous waste with low dissolved solids
B115   Scrubber water	

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Table 14-2. RCRA and Waste Form Codes Reported by Facilities in 1989
B116   Leachate
B117   Waste liquid mercury
B119   Other inorganic liquids
B201   Concentrated solvent-water solution
B202   Halogenated (e.g., chlorinated) solvent
B203   Nonhalogenated solvent
B204   Halogenated/Nonhalogenated solvent mixture
B205   Oil-water emulsion or mixture
B206   Waste oil
B207   Concentrated aqueous solution of other organics
B208   Concentrated phenolics
B209   Organic paint, ink, lacquer, or varnish
B210   Adhesive or epoxies
B211   Paint thinner or petroleum distillates
B219   Other organic liquids
B305   "Dry" lime or metal hydroxide solids chemically "fixed"
B306   "Dry" lime or metal hydroxide solids not "fixed"
B307   Metal scale, filings, or scrap
B308   Empty or crushed metal drums or containers
B309   Batteries or Battery parts, casings, cores
B310   Spent solid filters or adsorbents
B312   Metal-cyanides salts/chemicals
B313   Reactive cyanides salts/chemicals
B315   Other reactive salts/chemicals
B316   Other metal salts/chemicals
B319   Other waste inorganic solids
B501   Lime sludge without metals
B502   Lime sludge with metals/metal hydroxide sludge
B504   Other wastewater treatment sludge
B505   Untreated plating sludge without cyanides
B506   Untreated plating sludge with cyanides
B507   Other sludges with cyanides
B508   Sludge with reactive sulfides
B510   Degreasing sludge with metal scale or filings
B511   Air pollution  control device sludge (e.g., fly ash, wet scrubber sludge)
B513   Sediment or lagoon dragout contaminated with inorganics only
B515   Asbestos slurry or sludge
B519   Other inorganic sludges
B601   Still bottoms of halogenated (e.g., chlorinated) solvents or other organic liquids
B603   Oily sludge
B604   Organic paint or ink sludge
B605   Reactive or polymerized organics
B607   Biological treatment sludge
B608   Sewage or other untreated biological sludge
B609   Other organic sludges                    	  	
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Wastes Classified in the Metals Subcategory - Questionnaire Responses
                                                                14.5.1
    The wastes that EPA classified in the metals subcategory include the following:
    All wastes reported in Section G, Metals Recovery, of the 308 Questionnaire; and
    All wastes with Waste Form Codes and RCRArodes meeting the criteria specified in Table 14-3
 Table 14-3. Waste Form Codes in the Metals Subcategory
   All Inorganic
   Liquids
   All Inorganic
   Solids
   All Inorganic
   Sludges
Waste Form Codes
B101-B119
Waste Form Codes
B301-B319
Waste Form Codes
B501-B519
Exceptions:
Waste Form Codes Bl 16, and BIO I, B102, Bl 19
when combined with RCRA Codes:
F001-F005 and other organic F, K, P, and U Codes

Exceptions:
Waste Form Code B301
when combined with RCRA Codes::
F001-F005 and other organic F, K, P, and U Codes
         *
Exceptions:
Waste Form Code B512
when combined with RCRA Codes::
F001-F005 and other organic F, K, P, and U Codes
 * These exceptions were classified as belonging in the organics subcategory

Wastes Classified in The Oils Subcategory - Questionnaire Responses                    14.5.2

    The wastes EPA classified in the oils subcategory include the following:
   All wastes reported in Section E, Waste Oil Recovery, of the 308 Questionnaire;
   All wastes reported in Section H, Fuel Blending Operations, of the 308 Questionnaire that
    generate a wastewater as a result of the fuel blending operations; and
   All wastes with Waste Form Codes and RCRA codes meeting the criteria in Table 14-4.
 Table 14-4. Waste Form Codes in the Oils Subcategory
Organic Liquids

Organic Sludge

Waste Form Codes
B205, B206
Waste Form Code
B603
Exceptions:
None
Exception!!:
None
Wastes Classified in the Organics Subcategory - Questionnaire Responses
                                                               14.5.3
 The wastes EPA classified in the organics subcategory include the following:
   All wastes with Waste Form Codes and RCRA codes meeting the criteria specified in Table 14-5
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 Table 14-5. Waste Form Codes in the Organics Subcategory
Organic Liquids
Organic Solids
Organic Sludges
Inorganic Liquids
Waste Form Codes
B201-B204, B207-B219
Waste Form Codes
B401-B409
Waste Form Codes
B601.B602, B604-B609
Waste Form Codes
B101,B102,B116,B119
Exceptions:
None
Exceptions:
None
Exceptions:
None
when combined with RCRA Codes:
F001-F005 and other organic F, K, P, and U
Codes
   Inorganic Solids      Waste Form-Code B301
   Inorganic Sludges     Waste Form Code B512
         when combined with RCRA Codes:
         F001-F005 and other organic F, K, P, and U
         Codes
         when combined with RCRA Codes:
         F001-F005 and other organic F, K, P, and U
         Codes
    For wastes that can not be easily classified
into  a subcategory  such  as lab-packs, the
subcategory determination was based on other
information provided such as RCRA codes and
descriptive   comments.     Therefore,   some
judgement was required in assigning some waste
receipts to a subcategory.

ESTABLISHING LIMITATIONS AND
STANDARDS FOR FACILITY DISCHARGES  14.6

 In establishing limitations and standards for
CWT facilities, it is important for the permit
writer or pretreatment authority to ensure that the
CWT facility has an optimal waste management
program.   First, the control  authority should
verify that the CWT  facility is identifying and
segregating waste streams to the extent possible
since segregation of similar waste streams is the
first step in obtaining optimal mass removals of
pollutants from industrial wastes.  Next, the
control authority should verify that the CWT
facility is employing treatment  technologies
designed and operated to optimally treat all off-
site  waste receipts.   For example, biological
treatment is inefficient for treating concentrated
metals waste streams like those found in the
       metals subcategory or wastestreams with oil and
       grease compositions and concentrations like those
       found in  the  oils  subcategory.    In  fact,
       concentrated metals streams and high levels of oil
       and grease compromise the ability of biological
       treatment  systems  to  function.    Likewise,
       emulsion breaking/gravity  separation,  and/or
       dissolved air flotation is typically insufficient for
       treating  concentrated  metals wastewaters  or
       wastewaters containing organic pollutants which
       solubilize readily in water.   Finally,  chemical
       precipitation  is insufficient for treating organic
       wastes and waste streams with high oil and grease
       concentrations.
           Once the control authority has established
       that the  CWT facility is segregating its waste
       receipts   and   has   appropriate   treatment
       technologies  for all off-site waste receipts, the
       permit writer or pretreatment authority can then
       establish limitations or standards which ensure
       that the CWT facility is operating its treatment
       technologies  optimally. Available guidance in
       calculating NPDES categorical limitations for
       direct discharge facilities can be found in the U.S.
       EPA NPDES  Permit Writers'  Manual (December
       1996,  EPA-833-B-96-003).    Sources   of
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information  used  for   calculating   Federal
pretreatment standards  for  indirect  discharge
facilities  include  40  CFR Part 403.6, the
Guidance Manual  for the Use of Production-
Based Pretreafrnent Standards and the Combined
Waste Stream Formula (September 1985), and
EPA's  Industrial  User  Permitting  Guidance
Manual  (September  1989).    However,  as
illustrated in the next section, for the CWT point
source category, only 40 CFR Part 403.6 and
EPA's  Industrial  User  Permitting  Guidance
Manual should be used as a source of information
for  calculating Federal  CWT  pretreatment
standards for indirect dischargers.

Existing Guidance for Multiple
Subcategory Facilities                14.6.1
Direct Discharge Guidance          14.6.1.1
    For  instances  where  a direct  discharge
facility's operations are  covered  by multiple
subcategories, the NPDES permit writer must
apply  the limits  from  each subcategory in
deriving the technology-based effluent limits for
the facility. If all wastewaters regulated by the
effluent guidelines are  combined  prior to
treatment or discharge to navigable waters, then
the permit writer  would simply combine the
allowable pollutant loadings for each subcategory
to arrive at a single, combined set of technology-
based effluent limits  for the facility - the
"building block" approach (pages 60 & 61, U.S.
EPA NPDES Permit Writers' Manual. December
1996), In those circumstances when the limits for
one subcategory  regulate  a  different  set of
pollutants than the limits applicable to another
subcategory, the permit writer must ensure proper
application of the guidelines. If one subcategory
wastestream that  does not limit a particular
pollutant is combined with another wastestream
that limits the pollutant, then the permit writer
must ensure  that  the non-regulated pollutant
stream  does not dilute  the  regulated pollutant
stream to the point where the pollutant is not
analytically detectable.   If this circumstance
       occurs, then the permit writer is authorized to
       establish internal monitoring points, as allowed
       under 40 CFR  122.45(h).
        The  methodology for  developing  "building
       block"  daily  maximum  limits  for  selected
       pollutants for a hypothetical CWT facility is
       illustrated in Example 14-1.
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Chapter 14 Implementation
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     Example 14-1
        Facility A accepts wastes in all three CWT subcategories with separate subcategory
        treatment systems and a combined end-of-pipe outfall.  This facility treats 20,000
        I/day of metal-bearing wastes, 10,000 I/day of oily wastes, and 45,000,  I/day of
        organic wastes.
                 Metals Waste
                 20,000 L/day
  Oils Waste
 10,000 L/day
                     I
                    Metals
                  Treatment
     Oils
  Treatment
Organics Waste
 45,000 L/day
   Organics
  Treatment
                                                     Discharge
                                                    75,000 L/day

          Figure 14-2. Facility Accepting Waste in All Three Subcategories With Treatment in Each.
            For this example, EPA has proposed chromium and lead BAT limits for the metals and
        oils subcategories;  fluoranthene limits  for only the  oils  subcategory;  and  2,4,6-
        trichlorophenol limits for only the organics subcategory. Table 14-6 shows the proposed
        daily maximum limits for these pollutants.
        Table 14-6. Proposed BAT Daily Maximum Limits for Selected Parameters
Pollutant
Chromium
Lead
Flouranthene
2,4,6-trichlorophenol

Metals Daily
Maximum Limit, mg/1
2.9
0.29
none
none
Subcategory
Oils Daily Maximum
Limit, mg/1
0.65
0.35
.045
none

Organics Daily
Maximum Limit, mg/1
none
none
none
0.16
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