United States
Environmental Protection
Agency
Office of Water (4303)
Washington, DC 20460
EPA-821-R-99-019
January 2000
EPA Development Document
for Final Effluent
Limitations Guidelines and
Standards for the Landfills
Point Source Category
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DEVELOPMENT DOCUMENT
FOR
FINAL EFFLUENT LIMITATIONS
GUIDELINES AND STANDARDS
FOR THE
LANDFILLS
POINT SOURCE CATEGORY
Carol M. Browner
Administrator
J. Charles Fox
Assistant Administrator, Office of Water
Geoffrey H. Grubbs
Director, Office of Science and Technology
Sheila E. Frace
Director, Engineering and Analysis Division
Elwood H. Forsht
Chief, Chemicals and Metals Branch
Michael C. Ebner
Project Manager
January 2000
U.S. Environmental Protection Agency
Office of Water
Washington, DC 20460
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ACKNOWLEDGMENTS AND DISCLAIMER
This document has been reviewed and approved for publication by the Engineering Analysis Division,
Office of Science and Technology (OST), U. S. Environmental Protection Agency. The Agency would like
to acknowledge the contributions of OST Staff to the development of this document. This document was
prepared with the support of Science Applications International Corporation under the direction and review
of EPA's Office of Science and Technology.
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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LANDFILLS DEVELOPMENT DOCUMENT
TABLE OF CONTENTS
1.0 LEGAL AUTHORITY 1-1
1.1 Legal Authority 1-1
1.2 Background 1-1
1.2.1 Clean Water Act (CWA) 1-1
1.2.1.1 Best Practicable Control Technology Currently Available (BPT)l-l
1.2.1.2 Best Conventional Pollutant Control Technology (BCT) 1-2
1.2.1.3 Best Available Technology Economically Achievable (BAT) . 1-2
1.2.1.4 New Source Performance Standards (NSPS) 1-3
1.2.1.5 Pretreatment Standards for Existing Sources (PSES) 1-3
1.2.1.6 Pretreatment Standards for New Sources (PSNS) 1-4
1.2.2 Section 304(m) Requirements 1-4
2.0 SUMMARY AND SCOPE 2-1
2.1 Introduction 2-1
2.2 Subcategorization 2-1
2.3 Scope of Final Regulation 2-2
2.4 Best Practicable Control Technology Currently Available (BPT) 2-4
2.5 Best Conventional Pollutant Control Technology (BCT) 2-4
2.6 Best Available Technology Economically Achievable (BAT) 2-4
2.7 New Source Performance Standards (NSPS) 2-5
2.8 Pretreatment Standards for Existing Sources (PSES) 2-5
2.9 Pretreatment Standards for New Sources (PSNS) 2-5
2.10 Implementation of the Rule for Contaminated Ground Water Flows and
Wastewater from Recovering Pumping Wells 2-5
2.11 Implementation of the Rule for Storm Water Discharges 2-7
2.12 Exclusion for Captive Landfill Facilities 2-10
2.13 Determination of Similar Wastes for Captive Landfill Facilities 2-16
3.0 INDUSTRY DESCRIPTION 3-1
3.1 Regulatory History of the Landfills Industry 3-3
3.1.1 RCRA Subtitle C 3-3
3.1.1.1 Land Disposal Restrictions 3-4
3.1.1.2 Minimum Technology Requirements 3-6
3.1.2 RCRA Subtitle D 3-6
3.1.2.1 40 CFR Part 257, Subpart A - Criteria for Classification of Solid
Waste Disposal Facilities and Practices 3-7
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TABLE OF CONTENTS
3.1.2.2 40 CFR Part 257, Subpart B - Conditionally Exempt Small
Quantity Generator Revised Criteria 3-8
3.1.2.3 40 CFR Part 258 Revised Criteria for Municipal Solid Waste
Landfills 3-8
3.1.3 Current Wastewater Regulations 3-9
3.2 Industry Profile 3-10
3.2.1 Industry Population 3-11
3.2.2 Number and Location of Facilities 3-12
3.2.2.1 Captive Landfill Facilities 3-13
3.2.3 General Information on Landfill Facilities 3-14
3.2.4 Waste Receipts and Types 3-15
3.2.5 Sources of Wastewater 3-16
3.2.5.1 Landfill Leachate 3-16
3.2.5.2 Landfill Gas Condensate 3-17
3.2.5.3 Drained Free Liquids 3-17
3.2.5.4 Truck/Equipment Washwater 3-18
3.2.5.5 Laboratory-Derived Wastewater 3-18
3.2.5.6 Storm Water 3-19
3.2.5.7 Contaminated Ground Water 3-19
3.2.5.8 Recovering Pumping Wells 3-20
3.2.6 Leachate Collection Systems 3-20
3.2.7 PretreatmentMethods 3-21
3.2.8 Baseline Treatment 3-22
3.2.9 Discharge Types 3-22
4.0 DATA COLLECTION ACTIVITIES 4-1
4.1 Introduction 4-1
4.2 Preliminary Data Summary 4-1
4.3 Clean Water Act (CWA) Section 308 Questionnaires 4-3
4.3.1 Screener Surveys 4-4
4.3.1.1 Recipient Selection and Mailing 4-4
4.3.1.2 Information Collected 4-5
4.3.1.3 Data Entry, Coding, and Analysis 4-6
4.3.1.4 Mailout Results 4-6
4.3.2 Detailed Technical Questionnaires 4-6
4.3.2.1 Recipient Selection and Mailing 4-7
4.3.2.2 Information Collected 4-7
4.3.2.3 Data Entry, Coding, and Analysis 4-8
11
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TABLE OF CONTENTS
4.3.2.4 Mailout Results 4-9
4.4 Detailed Monitoring Questionnaire 4-9
4.4.1 Recipient Selection and Mailing 4-9
4.4.2 Information Collected 4-10
4.4.3 Data Entry, Coding, and Analysis 4-10
4.5 Engineering Site Visits 4-10
4.6 Wastewater Characterization Site Visits 4-11
4.7 EPA Week-Long Sampling Program 4-12
4.8 Other Data Sources 4-13
4.8.1 Industry Supplied Data 4-13
4.8.2 Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA)/Superfund Amendments and Reauthorization Act (SARA)
Ground Water Data 4-13
4.8.3 POTW Study 4-14
4.8.4 National Risk Management Research Laboratory Data 4-15
4.9 QA/QC and Other Data Editing Procedures 4-15
4.9.1 QA/QC Procedures 4-16
4.9.2 Analytical Database Review 4-16
4.9.2.1 Data Review Narratives 4-16
4.9.2.2 Completeness Checks 4-16
4.9.2.3 Trip Blanks and Equipment Blanks 4-17
4.9.2.4 Field Duplicates 4-18
4.9.2.5 Grab Samples 4-19
4.9.2.6 Non-Detect Data 4-19
4.9.2.7 Bi-Phasic Samples 4-20
4.9.2.8 Conversion of Weight/Weight Data 4-20
4.9.2.9 Average Concentration Data 4-21
4.9.3 Detailed Questionnaire Database Review 4-21
4.9.4 Detailed Monitoring Questionnaire Review 4-22
5.0 INDUSTRY SUBCATEGORIZATION 5-1
5.1 Subcategorization Approach 5-1
5.2 Landfills Subcategories 5-2
5.3 Other Factors Considered for Basis of Subcategorization 5-3
5.3.1 Types of Wastes Received 5-3
5.3.2 Wastewater Characteristics 5-7
5.3.3 Facility Size 5-8
5.3.4 Ownership 5-9
in
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TABLE OF CONTENTS
5.3.5 Geographic Location 5-9
5.3.6 Facility Age 5-11
5.3.7 Economic Characteristics 5-14
5.3.8 Treatment Technologies and Costs 5-14
5.3.9 Energy Requirements 5-15
5.3.10 Non-Water Quality Impacts 5-15
6.0 WASTEWATER GENERATION AND CHARACTERIZATION 6-1
6.1 Wastewater Generation and Sources of Wastewater 6-1
6.2 Wastewater Flow and Discharge 6-4
6.2.1 Wastewater Flow and Discharge at Subtitle D Non-Hazardous
Landfills 6-5
6.2.2 Wastewater Flow and Discharge at Subtitle C Hazardous Landfills . . . 6-6
6.3 Wastewater Characterization 6-7
6.3.1 Background Information 6-8
6.3.1.1 Landfill Leachate 6-8
6.3.1.1.1 Additional Sources of Non-Hazardous Leachate
Characterization Data 6-12
6.3.1.2 Landfill Gas Condensate 6-13
6.3.1.3 Drained Free Liquids 6-14
6.3.1.4 Truck and Equipment Washwater 6-14
6.3.2 Pollutant Parameters Analyzed at EPA Sampling Episodes 6-15
6.3.3 Raw Wastewater Characterization Data 6-17
6.3.4 Conventional, Toxic, and Selected Nonconventional Pollutant
Parameters 6-18
6.3.5 Toxic Pollutants and Remaining Nonconventional Pollutants 6-20
6.3.6 Raw Wastewater at Subtitle D Non-Hazardous Landfills 6-21
6.3.6.1 Raw Wastewater at Subtitle D Municipal Landfills 6-21
6.3.6.2 Raw Wastewater at Subtitle D Non-Municipal Landfills .... 6-21
6.3.6.3 Dioxins and Furans in Raw Wastewater at Subtitle D Non-
Hazardous Landfills 6-23
6.3.7 Raw Wastewater at Subtitle C Hazardous Landfills 6-24
6.3.7.1 Dioxins and Furans in Raw Wastewater at Subtitle C Hazardous
Landfills 6-25
7.0 POLLUTANT PARAMETER SELECTION 7-1
7.1 Introduction 7-1
7.2 Pollutants Considered for Regulation 7-1
IV
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TABLE OF CONTENTS
7.3 Selection of Pollutants of Interest 7-2
7.4 Development of Pollutant Discharge Loadings 7-3
7.4.1 Development of Current Discharge Concentrations 7-3
7.4.1.1 Alternate Methodology for Non-Hazardous Subcategory: Subtitle D
Non-Municipal 7-5
7.4.1.2 Alternate Methodology for the Hazardous Subcategory 7-5
7.4.2 Development of Pollutant Mass Loadings 7-6
7.5 Assessment of Pollutants of Interest 7-7
7.6 Selection of Pollutants to be Regulated for Direct Dischargers 7-7
7.6.1 Non-Hazardous Subcategory Pollutants to be Regulated for Direct
Dischargers 7-8
7.6.2 Hazardous Subcategory Pollutants to be Regulated for Direct
Dischargers 7-14
7.7 Selection of Pollutants to be Regulated for Indirect Dischargers 7-22
7.7.1 Pass-Through Analysis for Indirect Dischargers 7-22
7.7.2 Non-Hazardous Subcategory Pollutants to be Regulated for Indirect
Dischargers 7-25
7.7.3 Hazardous Subcategory Pollutants to be Regulated for Indirect
Dischargers 7-27
.0 WASTEWATER TREATMENT TECHNOLOGY DESCRIPTION 8-1
8.1 Available BAT and PSES Technologies 8-1
8.1.1 Best Management Practices 8-1
8.1.2 Physical/Chemical Treatment 8-3
8.1.2.1 Equalization 8-3
8.1.2.2 Neutralization 8-4
8.1.2.3 Flocculation 8-5
8.1.2.4 Gravity Assisted Separation 8-6
8.1.2.5 Chemical Precipitation 8-8
8.1.2.5.1 Iron (Fe) Coprecipitation 8-11
8.1.2.6 Chemical Oxidation/Reduction 8-11
8.1.2.6.1 Breakpoint Chlorination 8-12
8.1.2.7 Air Stripping 8-14
8.1.2.8 Filtration 8-14
8.1.2.8.1 Sand Filtration 8-15
8.1.2.8.2 Diatomaceous Earth 8-17
8.1.2.8.3 Multimedia Filtration 8-17
8.1.2.8.4 Membrane Filtration 8-18
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TABLE OF CONTENTS
8.1.2.8.4.1 Ultrafiltration 8-18
8.1.2.8.4.2 Reverse Osmosis 8-19
8.1.2.8.5 Fabric Filters 8-21
8.1.2.9 Carbon Adsorption 8-21
8.1.2.10 Ion Exchange 8-23
8.1.3 Biological Treatment 8-24
8.1.3.1 Lagoon Systems 8-26
8.1.3.2 Anaerobic Systems 8-30
8.1.3.3 Attached-Growth Biological Treatment Systems 8-31
8.1.3.4 Activated Sludge 8-34
8.1.3.5 Powder Activated Carbon Biological Treatment 8-38
8.1.3.6 Sequencing Batch Reactors (SBRs) 8-39
8.1.3.7 Nitrification Systems 8-40
8.1.3.8 Denitrification Systems 8-41
8.1.3.9 Wetlands Treatment 8-41
8.1.4 Sludge Handling 8-41
8.1.4.1 Sludge Slurrying 8-42
8.1.4.2 Gravity Thickening 8-42
8.1.4.3 Pressure Filtration 8-42
8.1.4.4 Sludge Drying Beds 8-43
8.1.5 Zero Discharge Treatment Options 8-44
8.2 Treatment Performance and Development of Regulatory Options 8-45
8.2.1 Performance of EPA Sampled Treatment Processes 8-46
8.2.1.1 Treatment Performance for Episode 4626 8-46
8.2.1.2 Treatment Performance for Episode 4667 8-48
8.2.1.3 Treatment Performance for Episode 4721 8-49
8.2.1.4 Treatment Performance for Episode 4759 8-50
8.2.1.5 Treatment Performance for Episode 4687 8-51
9.0 ENGINEERING COSTS 9-1
9.1 Evaluation of Cost-Estimation Techniques 9-1
9.1.1 CostModels 9-1
9.1.2 Vendor Data 9-2
9.1.3 Other EPA Effluent Guideline Studies 9-3
9.1.4 Benchmark Analysis and Evaluation Criteria 9-3
9.1.5 Selection of Final Cost-Estimation Techniques 9-5
9.2 Engineering Costing Methodology 9-6
9.2.1 Treatment Costing Methodology 9-7
VI
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TABLE OF CONTENTS
9.2.1.1 Retrofit Costs 9-9
9.2.2 Land Costs 9-9
9.2.3 Residual Disposal Costs 9-9
9.2.4 Monitoring Costs 9-10
9.2.5 Off-Site Disposal Costs 9-11
9.3 Development of Cost Estimates for Individual Treatment Technologies .... 9-11
9.3.1 Equalization 9-12
9.3.2 Flocculation 9-13
9.3.3 Chemical Feed Systems 9-14
Sodium Hydroxide Feed Systems 9-15
Phosphoric Acid Feed Systems 9-17
Polymer Feed Systems 9-18
9.3.4 Primary Clarification 9-19
9.3.5 Activated Sludge Biological Treatment 9-20
9.3.6 Secondary Clarification 9-22
9.3.7 Multimedia Filtration 9-23
9.3.8 Reverse Osmosis 9-24
9.3.9 Sludge Dewatering 9-25
9.3.10 Granular Activated Carbon 9-26
9.3.11 Breakpoint Chlorination 9-27
9.4 Costs for Regulatory Options 9-28
9.4.1 Facility Selection 9-28
9.4.2 BPT Regulatory Costs 9-29
9.4.2.1 Subtitle D Non-Hazardous Subcategory BPT Costs 9-29
9.4.2.2 Subtitle C Hazardous Subcategory BPT Costs 9-30
9.4.3 BCT Regulatory Costs 9-30
9.4.3.1 Subtitle D Non-Hazardous Subcategory BCT Costs 9-30
9.4.3.2 Subtitle C Hazardous Subcategory BCT Costs 9-31
9.4.4 BAT Regulatory Costs 9-31
9.4.4.1 Subtitle D Non-Hazardous Subcategory BAT Costs 9-31
9.4.4.2 Subtitle C Hazardous Subcategory BAT Costs 9-32
9.4.5 NSPS Regulatory Costs 9-32
9.4.5.1 Subtitle D Non-Hazardous Subcategory NSPS Costs 9-32
9.4.5.2 Subtitle C Hazardous Subcategory NSPS Costs 9-33
10.0 NON-WATER QUALITY IMPACTS 10-1
10.1 Air Pollution 10-1
10.2 Solid and Other Aqueous Wastes 10-3
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TABLE OF CONTENTS
10.3 Energy Requirements 10-5
11.0 DEVELOPMENT OF EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS 11-1
11.1 Development of Long-Term Averages, Variability Factors, and Effluent
Limitations 11-1
11.1.1 Calculation of Long-Term Averages 11-2
11.1.2 Calculation of Variability Factors 11-5
11.1.3 Calculation of Effluent Limitations 11-6
11.2 Best Practicable Control Technology Currently Available (BPT) 11-6
11.2.1 BPT Technology Options for the Subtitle D Non-Hazardous
Subcategory 11-8
11.2.2 BPT Limits for the Subtitle D Non-Hazardous Subcategory 11-11
11.2.3 BPT Technology Options for the Subtitle C Hazardous Subcategory 11-20
11.2.4 BPT Limits for the Subtitle C Hazardous Subcategory 11-23
11.3 Best Conventional Pollutant Control Technology (BCT) 11-27
11.4 Best Available Technology Economically Achievable (BAT) 11-28
11.4.1 BAT Limits for the Subtitle D Non-Hazardous Subcategory 11-29
11.4.2 BAT Limits for the Subtitle C Hazardous Subcategory 11-31
11.5 New Source Performance Standards (NSPS) 11-31
11.6 Pretreatment Standards for Existing Sources (PSES) 11-32
11.6.1 EPA's Decision Not to Establish PSES for the Subtitle D Non-Hazardous
Subcategory 11-34
11.6.1.1 EPA's Rationale for Not Establishing PSES for
Ammonia 11-35
11.6.1.2 EPA's Rationale for Not Establishing PSES for
Benzoic Acid 11-41
11.6.1.3 EPA's Rationale for Not Establishing PSES for
P-Cresol 11-43
11.6.1.4 EPA's Rationale for Not Establishing PSES for
Phenol 11-44
11.6.1.5 Public Comments to the Proposed Rule Regarding Non-
Hazardous PSES 11-45
11.6.2 EPA's Decision Not to Establish PSES for the Subtitle C Hazardous
Subcategory 11-48
11.7 Pretreatment Standards for New Sources (PSNS) 11-53
12.0 REFERENCES 12-1
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TABLE OF CONTENTS
APPENDIX A Section 308 Survey for Landfills - Industry Population Analysis
APPENDIX B Definitions, Acronyms, and Abbreviations
IX
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LIST OF TABLES
2-1 Final Concentration Limitations for Hazardous Landfill Subcategory,
Direct Discharges 2-20
2-2 Final Concentration Limitations for Hazardous Landfill Subcategory,
Direct Discharges 2-21
2-3 Grouping of Subchapter N Effluent Guidelines and Standards 2-22
3-1 Number of Landfills per U.S. State 3-24
3-2 Ownership Status of Landfill Facilities 3-25
3-3 Total Landfill Facility Area 3-26
3-4 Landfill Facility Land Area Ranges 3-27
3-5 Number of Landfill Cells 3-28
3-6 Household and Non-Household Population Served 3-29
3-7 Household vs. Non-Household Customers 3-30
3-8 Wastes Received by Landfills in the United States 3-31
3-9 Total Volume of Waste Received by Landfills in 1992 by Regulatory Classification 3-32
3-10 Annual Tonnage of Waste Accepted by Landfills 3-33
3-11 Wastewater Flows Generated by Individual Landfills 3-34
3-12 Type of Leachate Collection Systems Used at Individual Landfills 3-35
3-13 Pretreatment Methods in Use at Individual Landfills 3-36
3-14 Types of Wastewater Treatment Employed by the Landfills Industry 3-37
3-15 Wastewater Treatment Facility Hours of Operation per Day 3-38
3-16 Wastewater Treatment Facility Average Hours of Operation per Day 3-39
3-17 Wastewater Treatment Facility Days of Operation per Week 3-40
3-18 Wastewater Treatment Facility Average Days of Operation per Week 3-41
3-19 Total Number of Facilities by Discharge Type 3-42
4-1 Screener Questionnaire Strata 4-5
4-2 Types of Facilities Included in EPA's Characterization and Engineering Site Visits . 4-23
4-3 Types of Facilities Included in EPA's Field Sampling Program 4-24
4-4 Episode Numbers for the Engineering Site Visits and Field Sampling Efforts 4-25
5-1 Subcategorization of the EPA Landfills Database 5-16
5 -2 Raw Wastewater Median Concentrations of Pollutants of Interest Common to Both the Hazardous
and Non-Hazardous Landfill Subcategories 5-20
5-3 Comparison of Subtitle D Non-Municipal and Municipal Raw Wastewater Pollutant
Concentrations 5-22
5-4 Summary of EPA Sampling Data for Subtitle D Monofills, Average Raw Leachate Data for
Selected Pollutants 5-24
5-5 Average Contaminated Ground Water Pollutant Concentrations at Hazardous Landfills in the EPA
Database 5-25
x
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LIST OF TABLES
5-6 Average Contaminated Ground Water Pollutant Concentrations at Non-Hazardous Landfills in the
EPA Database 5-27
5-7 Age of Landfills in EPA Sampling Database 5-28
5-8 Median Raw Wastewater Characteristics at Non-Hazardous Landfills of Varying Age5-30
6-1 Wastewater Generated in 1992: Hazardous Subcategory 6-26
6-2 Wastewater Generated in 1992: Non-Hazardous Subcategory Municipal Facilities . . 6-27
6-3 Wastewater Generated in 1992: Non-Hazardous Subcategory Non-Municipal
Facilities 6-29
6-4 Quantity of In-Scope Wastewater Generated in 1992 6-30
6-5 Contaminant Concentration Ranges in Municipal Leachate as Reported in Literature
Sources 6-31
6-6 Landfill Gas Condensate (from Detailed Questionnaire) 6-32
6-7 EPA Sampling Episode Pollutants Analyzed 6-33
6-8 EPA Sampling Episode List of Analytes Never Detected 6-37
6-9 Subtitle D Non-Hazardous Subcategory Median Raw Wastewater Concentration File 6-49
6-10 Subtitle C Hazardous Subcategory Median Raw Wastewater Concentration File ... 6-50
6-11 Range of Conventional and Selected Nonconventional Pollutants Raw Wastewater
Average Concentrations 6-51
6-12 Range of Metals and Toxic Pollutants Raw Wastewater Average Concentrations ... 6-52
6-13 Range of Organic Pollutants Raw Wastewater Average Concentrations 6-53
6-14 Dioxins and Furans at Non-Hazardous EPA Sampling Episodes by Episode and
Sample Point 6-54
6-15 Dioxins and Furans at Hazardous EPA Sampling Episodes by Episode and Sample
Point 6-55
7-1 Non-Hazardous Subcategory Pollutants of Interest 7-29
7-2 Hazardous Subcategory Pollutants of Interest 7-30
7-3 Non-Hazardous Subcategory - POTW Percent Removals 7-31
7-4 Hazardous Subcategory - POTW Percent Removals 7-31
7-5 Non-Hazardous Subcategory - BAT Performance Data 7-32
7-6 Pass-Through Analysis for the Non-Hazardous Subcategory 7-33
7-7 Hazardous Subcategory - BAT Performance Data 7-34
7-8 Pass-Through Analysis for the Hazardous Subcategory 7-35
8-1 Wastewater Treatment Technologies Employed at In-Scope Landfill Facilities 8-53
8-2 Treatment Technology Performance for Facility 4626 - Subtitle D Municipal 8-54
8-3 Treatment Technology Performance for Facility 4667 - Subtitle D Municipal 8-55
8-4 Treatment Technology Performance for Facility 4721 - Subtitle C Hazardous 8-56
8-5 Treatment Technology Performance for Facility 4759 - Subtitle C Hazardous 8-58
8-6 Treatment Technology Performance for Facility 4687 - Subtitle D Municipal 8-60
XI
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LIST OF TABLES
9-1 Cost Comparison 9-34
9-2 Costing Source Comparison 9-35
9-3 Breakdown of Costing Method by Treatment Technology 9-36
9-4 Additional Cost Factors 9-37
9-5 Analytical Monitoring Costs 9-38
9-6 Subtitle D Non-Hazardous Facilities Costed for Off-Site Disposal 9-39
9-7 Unit Process Breakdown by Regulatory Option 9-40
9-8 Chemical Addition Design Method 9-41
9-9 Treatment Chemical Costs 9-42
9-10 Sodium Hydroxide Requirements for Chemical Precipitation 9-43
9-11 BPT/BCT/BAT Option I Subtitle D Non-Hazardous Subcategory 9-44
9-12 BPT/BCT/BAT Option II Subtitle D Non-Hazardous Subcategory 9-49
9-13 BAT Option III Subtitle D Non-Hazardous Subcategory 9-54
11-1 Removal of Pollutant of Interest Metals in the Non-Hazardous Subcategory 11-54
11-2 List of Subtitle D Municipal Solid Waste Facilities Employing Biological Treatment Considered for
BPT in the Non-Hazardous Subcategory 11-55
11-3 Comparison of Raw Wastewater Mean Concentrations of Non-Hazardous Pollutants of Interest
for Municipal Solid Waste Landfills and Hazardous Facility 16041 11-56
11-4 Candidate BPT Facilities for the Non-Hazardous Subcategory Eliminated from BPT Consideration
Because No BOD5 Effluent Data Was Available 11-57
11-5 Treatment Systems In Place at Landfill Facilities Considered for BPT in the Non-Hazardous
Subcategory which Supplied BOD5 Effluent Data 11-58
11-6 Landfill Facilities Considered for BPT in the Non-Hazardous Subcategory which Supplied BOD5
Effluent Data: Flows, Concentration Data, and Reason for Elimination 11-59
11-7 Selected BPT Facilities for the Non-Hazardous Subcategory 11-60
11-8 TSS Data from Landfill Facilities Selected for BPT in the Non-Hazardous
Subcategory 11-61
11-9 Facilities and Sample Points Used for the Development of BPT/B AT Effluent Limitations for the
Non-Hazardous Subcategory 11-62
11-10 BPT Facility Data Excluded from the Calculation of Non-Hazardous BPT/B AT
Limitations 11-64
11-11 BPT/B AT Limitations for the Non-Hazardous Subcategory 11-68
11-12 National Estimates of Pollutant of Interest Reductions for BPT/B AT Options for Municipal Solid
Waste Landfills - Direct Dischargers 11-69
11-13 National Estimates of Pollutant of Interest Reductions for BPT/B AT Options for Non-Municipal
Solid Waste Landfills - Direct Dischargers 11-70
11-14 Annual Pollutant Discharge Before and After the Implementation of BPT for Subtitle D Municipal
Solid Waste Landfill Facilities in the Non-Hazardous Subcategory 11-71
xn
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LIST OF TABLES
11-15 Annual Pollutant Discharge Before and After the Implementation of BPT for Subtitle D Non-
Municipal Solid Waste Landfill Facilities in the Non-Hazardous Subcategory .... 11-72
11-16 Selected BPT Facilities for the Hazardous Subcategory 11-73
11-17 Facilities and Sample Points Used for the Development of BPT/BAT Effluent Limitations for the
Hazardous Subcategory 11-74
11-18 BPT Facility Data Excluded from the Calculation of Hazardous BPT/B AT
Limitations 11-75
11-19 BPT/B AT Limitations for the Hazardous Subcategory 11-80
11 -20 Comparison of Long-Term Averages for Nonconventional and Toxic Pollutants Regulated Under
BAT for the Non-Hazardous Subcategory 11-81
Xlll
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LIST OF FIGURES
3-1 Development of National Estimates for the Landfills Industry 3-43
7-1 Development of Pollutants of Interest 7-36
7-2 Selection of Pollutants to be Regulated 7-37
8-1 Equalization 8-61
8-2 Neutralization 8-61
8-3 Clarification System Incorporating Coagulation and Flocculation 8-62
8-4 Calculated Solubilities of Metal Hydroxides 8-63
8-5 Chemical Precipitation System Diagram 8-64
8-6 Cyanide Destruction 8-65
8-7 Chromium Reduction 8-66
8-8 Typical Air Stripping System 8-67
8-9 Multimedia Filtration 8-68
8-10 Ultrafiltration System Diagram 8-69
8-11 Tubular Reverse Osmosis Module 8-70
8-12 Granular Activated Carbon Adsorption 8-71
8-13 Ion Exchange 8-72
8-14 Aerated Lagoon 8-73
8-15 Facultative Pond 8-74
8-16 Completely Mixed Digester System 8-75
8-17 Rotating Biological Contactor Cross-Section 8-76
8-18 Trickling Filter 8-77
8-19 Fluidized Bed Reactor 8-78
8-20 Activated Sludge System 8-79
8-21 Powdered Activated Carbon Treatment System 8-80
8-22 Sequencing Batch Reactor Process Diagram 8-81
8-23 Gravity Thickening 8-82
8-24 Plate-and-Frame Pressure Filtration System Diagram 8-83
8-25 Drying Bed 8-84
8-26 EPA Sampling Episode 4626 - Landfill Waste Treatment System Block Flow Diagram with
Sampling Locations 8-85
8-27 EPA Sampling Episode 4667 - Landfill Waste Treatment System Block Flow Diagram with
Sampling Locations 8-86
8-28 EPA Sampling Episode 4721 - Landfill Waste Treatment System Block Flow Diagram with
Sampling Locations 8-87
8-29 EPA Sampling Episode 4759 - Landfill Waste Treatment System Block Flow Diagram with
Sampling Locations 8-88
8-30 EPA Sampling Episode 4687 - Landfill Waste Treatment System Block Flow Diagram with
Sampling Locations 8-89
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LIST OF FIGURES
9-1 Option Specific Costing Logic Flow Diagram 9-59
9-2 Equalization Capital Cost Curve 9-60
9-3 Flocculation Capital Cost Curve 9-61
9-4 Flocculation O&M Cost Curve 9-62
9-5 Sodium Hydroxide Capital Cost Curve 9-63
9-6 Sodium Hydroxide O&M Cost Curve 9-64
9-7 Phosphoric Acid Feed Capital Cost Curve 9-65
9-8 Phosphoric Acid Feed O&M Cost Curve 9-66
9-9 Polymer Feed Capital Cost Curve 9-67
9-10 Polymer Feed O&M Cost Curve 9-68
9-11 Primary Clarifier Capital Cost Curve 9-69
9-12 Primary Clarifier O&M Cost Curve 9-70
9-13 Aeration Basin Capital Cost Curve 9-71
9-14 Air Diffusion System Capital Cost Curve 9-72
9-15 Air Diffusion System O&M Cost Curve 9-73
9-16 Secondary Clarifier Capital Cost Curve 9-74
9-17 Secondary Clarifier O&M Cost Curve 9-75
9-18 Multimedia Filtration Capital Cost Curve 9-76
9-19 Multimedia Filtration O&M Cost Curve 9-77
9-20 Reverse Osmosis Capital Cost Curve 9-78
9-21 Sludge Drying Beds Capital Cost Curve 9-79
9-22 Sludge Drying Beds O&M Cost Curve 9-80
9-23 GAC Capital Cost Curve 9-81
9-24 GAC O&M Cost Curve 9-82
9-25 Breakpoint Chlorination Capital Cost Curve 9-83
9-26 Breakpoint Chlorination O&M Cost Curve 9-84
11-1 BPT/BCT/BAT/PSES/PSNS Non-Hazardous Subcategory Option I Flow Diagram 11-82
11-2 BPT/BCT/BAT Non-Hazardous Subcategory Option II & NSPS Flow Diagram ... 11-83
11-3 BPT/BCT/BAT Hazardous Subcategory Option II & NSPS Flow Diagram 11-84
11-4 BAT Non-Hazardous Subcategory Option III Flow Diagram 11-85
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1.0 LEGAL AUTHORITY
1.1 Legal Authority
Effluent limitations guidelines and standards for the Landfills industry are promulgated 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.
1.2 Background
1.2.1 Clean Water Act (CWA)
The Federal Water Pollution Control Act Amendments of 1972 established a comprehensive program to
"restore and maintain the chemical, physical, and biological integrity of the Nation's waters" (Section
101 (a)). To implement the Act, EPA is to issue effluent limitations guidelines, pretreatment standards, and
new source performance standards for industrial dischargers. These guidelines and standards are
summarized briefly in the following sections.
1.2.1.1 Best Practicable Control Technology Currently Available (BPT)
(Section 304(b)(l) of the CWA)
In the guidelines for an industry category, EPA defines BPT effluent limits for conventional, priority,1 and
nonconventional 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
1 In the initial stages of EPA CWA regulation, EPA efforts emphasized the achievement of BPT limitations for
control of the "classical" pollutants (e.g., TSS, pH, BOD5). However, nothing on the face of the statute
explicitly restricted BPT limitation to such pollutants. Following passage of the Clean Water Act of 1977
with its requirement for points sources to achieve best available technology limitations to control
discharges of toxic pollutants, EPA shifted its focus to address the listed priority pollutants under the
guidelines program. BPT guidelines continue to include limitations to address all pollutants.
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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.
1.2.1.2 Best Conventional Pollutant Control Technology (BCT)
(Section 304(b)(4) of the CWA)
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 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).
1.2.1.3 Best Available Technology Economically Achievable (BAT)
(Section 304(b)(2) of the CWA)
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
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BPT limitations, BAT limitations may be based on effluent reductions attainable through changes in a
facility's processes and operations. As with BPT, where existing performance is uniformly inadequate,
BAT may require a higher level of performance than is currently being achieved based on technology
transferred from a different subcategory or category. BAT may be based upon process changes or internal
controls, even when these technologies are not common industry practice.
1.2.1.4 New Source Performance Standards (NSPS)
(Section 306 of the CWA)
NSPS reflect effluent reductions that are achievable based on the best available demonstrated 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 control technology for all pollutants (i.e.,
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
and energy requirements.
1.2.1.5 Pretreatment Standards for Existing Sources (PSES)
(Section 307(b) of the CWA)
PSES are designed to prevent the discharge of pollutants that pass through, interfere with, or are otherwise
incompatible with the operation of publicly owned treatment works (POTWs). 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. These regulations contain a definition of pass
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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).
1.2.1.6 Pretreatment Standards for New Sources (PSNS)
(Section 307(b) of the CWA)
Like PSES, PSNS are designed to prevent the discharges of pollutants that pass through, interfere-with,
or are otherwise incompatible with the operation of POTWs. PSNS are to be issued at the same time as
NSPS. New indirect dischargers have the opportunity to incorporate into their plants the best available
demonstrated technologies. The Agency considers the same factors in promulgating PSNS as it considers
in promulgating NSPS.
1.2.2 Section 304(m) Requirements
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
Hazardous 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 (NRDC et al. v. Reilly. Civ. No. 89-2980 (D.D.C.)). Under the terms of the consent decree
in that case, as amended, EPA agreed, among other things, to propose effluent guidelines for the "Landfills
and Industrial Waste Combusters" category by November 1997 and final action by November 1999.
Although the Consent Decree lists "Landfills and Industrial Waste Combusters" as a single entry, EPA is
publishing separate regulations for Industrial Waste Combusters and for Landfills.
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2.0 SUMMARY AND SCOPE
2.1 Introduction
The final regulation for the Landfills industry establishes effluent limitations guidelines and standards for the
control of wastewater pollutants. This document presents the information concerning, and rationale
supporting, these effluent limitations guidelines and standards. Section 2.2 discusses the subcategorization
approach, Section 2.3 describes the scope of the regulation, Sections 2.4 through 2.9 summarize the final
effluent limitations and pretreatment standards, and Sections 2.10 through 2.13 discuss several of the
implementation issues associated with this rule.
2.2 Subcategorization
For the final rule, EPA decided that a single set of limitations and standards was not appropriate for the
landfills industry and, thus, developed different limitations and standards for subcategories within the
industry. These subcategories are summarized below:
RCRA Subtitle C Hazardous Waste Landfill Subcategory
Subpart A of 40 CFR Part 445, "RCRA Subtitle C Hazardous Waste Landfill Subcategory," applies to
wastewater discharges from a solid waste disposal facility subject to the criteria in 40 CFR Part 264
Subpart N - Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities and 40 CFR Part 265 Subpart N -Interim Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities. Hazardous waste landfills are subj ect to requirements
outlined in 40 CFR Parts 264 and 265 that include the requirement to maintain a leachate collection and
removal systems during the active life and post-closure period of the landfill. For a discussion of these
criteria, see the Preamble to the proposed landfill guideline at 63 FR 6426, 6430-31. (February 6,1998).
RCRA Subtitle D Non-Hazardous Waste Landfill Subcategory
SubpartB of 40 CFRPart445, "RCRA Subtitle D Non-Hazardous Waste Landfill Subcategory," applies
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to wastewater discharges from all landfills classified as RCRA Subtitle D non-hazardous landfills subj ect
to either of the criteria established in 40 CFR Parts 257 (Criteria for Classification of Solid Waste Disposal
Facilities and Practices) or 258 (Criteria for Municipal Solid Waste Landfills). For a discussion of these
criteria, see the Preamble to the proposed landfill guideline at 63 FR 6426, 6431-32. (February 6,1998).
2.3 Scope of Final Regulation
The final limitations and standards cover pollutants in wastewater discharges associated only with the
operation and maintenance of those landfills regulated under Subtitles C and D of the Resource
Conservation and Recovery Act (RCRA).1 The rule applies to wastewater generated at both active as well
as closed landfills regulated under Subtitle C or Subtitle D of RCRA.
Furthermore, this rule does not apply to wastewater discharges associated with the operation and
maintenance of land application or treatment units, surface impoundments, underground inj ection wells,
waste piles, salt dome or bed formations, underground mines, caves or corrective action units.2
Additionally, this guideline does not apply to waste transfer stations, or any wastewater not directly
attributed to the operation and maintenance of Subtitle C or Subtitle D landfill units. Consequently,
wastewater, such as that generated in off-site washing of vehicles used in landfill operations, is not within
the scope of this guideline.
The wastewater covered by the rule includes leachate, gas collection condensate, drained free liquids,
laboratory-derived wastewater, contaminated storm water, and contact washwater from truck exteriors
and surface areas which have come in direct contact with solid waste at the landfill facility. However,
1 EPA's Subtitle C and Subtitle D regulations define "landfill". See 40 CFR 257.2, 258.2 ("municipal solid
waste landfill") and 260.10. Permitted Subtitle C landfills are authorized to accept hazardous wastes as
defined in 40 CFR Part 261. Subtitle D landfills are authorized to receive municipal, commercial or
industrial waste that is not hazardous (as well as hazardous waste excluded from regulation under
Subtitle C).
2 These terms are defined at 40 CFR 257.2 and 260.10.
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ground water and wastewater from recovery pumping well operations which have been contaminated by
a landfill and are collected and discharged are excluded from this guideline. Section 2.10 discusses the
exclusion from the rule for contaminated ground water flows and for wastewater from recovering pumping
wells. Discharges of non-contaminated storm water, as defined by this guideline, are also not covered by
the rule. EPA defines non-contaminated storm water and discusses the rationale for not covering it in this
guideline at Section 2.11.
The rule does not apply to wastewater discharges generated at a landfill that is associated with an industrial
or commercial operation - so-called "captive" landfills - in most circumstances. The following describes
the applicability of the final rule to captive landfills. The final rule does not apply to discharges of landfill
wastewater from captive landfills so long as one or more of the following conditions are met:
a) The captive landfill is operated in conjunction with other industrial or commercial operations, and
it only receives wastes generated by the industrial or commercial operation directly associated with
the landfill.
b) The landfill is operated in conjunction with other industrial or commercial operations and it receives
both wastes generated by the industrial or commercial operation directly associated with the landfill
as well as other wastes and the other wastes received for landfill disposal are generated by a facility
that is subj ect to the same provisions in 40 CFR Subchapter N as the receiving facility directly
associated with the landfill.
c) The landfill is operated in conjunction with other industrial or commercial operations and it receives
wastes generated by the industrial or commercial operation directly associated with the landfill as
well as other wastes and the other wastes are similar in nature to the wastes generated by the
industrial or commercial operation directly associated with the landfill.
d) The landfill is operated in conjunction with a Centralized Waste Treatment (CWT) facility subj ect
to 40 CFR Part 437 so long as the CWT facility commingles the landfill wastewater with other
non-landfill wastewater for treatment. If a CWT facility discharges landfill wastewater separately
from other CWT wastewater or commingles the wastewater from its landfill only with wastewater
from other landfills, then the landfill discharge is subject to the landfill effluent guidelines.
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e) The landfill is operated in conjunction with other industrial or commercial operations, and it receives
wastes from public service activities (as defined in Appendix B) and the landfill does not receive
a fee or other remuneration for the disposal service.
Section 2.12 discusses in detail EPA's rationale for adopting the conditions described above for the captive
landfill exclusion.
2.4 Best Practicable Control Technology Currently Available (BPT)
EPA established BPT effluent limitations guidelines for conventional, priority, and nonconventional
pollutants for both subcategories. For RCRA Subtitle C hazardous waste landfills, EPA promulgated
effluent limitations standards based on atreatment system consisting of equalization, chemical precipitation,
biological treatment, and multimedia filtration. For RCRA Subtitle D non-hazardous waste landfills, EPA
promulgated effluent limitations standards based on the following treatment: equalization, biological
treatment, and multimedia filtration. Table 2-1 and Table 2-2 list the final effluent limitations and standards
for the Hazardous subcategory and the Non-Hazardous subcategory, respectively.
2.5 Best Conventional Pollutant Control Technology (BCT)
EPA established BCT effluent limitations guidelines equivalent to the BPT guidelines for the control of
conventional pollutants (BOD5, TSS, and pH) for both subcategories. The effluent limitations are the same
as those specified for BOD5, TSS, and pH in Table 2-1 and Table 2-2 for the Hazardous subcategory and
the Non-Hazardous subcategory, respectively
2.6 Best Available Technology Economically Achievable (BAT)
EPA established BAT effluent limitations guidelines equivalent to the BPT guidelines for control of priority
and nonconventional pollutants for both subcategories. Any existing hazardous landfill subject to this
guideline must achieve the following effluent limitations which represent the application of BAT: Limitations
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for ammonia (asN), alpha terpineol, aniline, benzoic acid, naphthalene, p-cresol, phenol, pyridine, arsenic,
chromium and zinc are the same as the corresponding limitations specified in Table 2-1.
Any existing non-hazardous landfill subj ect to this guideline must achieve the following effluent limitations
which represent the application of BAT: Limitations for ammonia (as N), alpha terpinol, benzoic acid, p-
cresol, phenol and zinc are the same as the corresponding limitations specified in Table 2-2.
2.7 New Source Performance Standards (NSPS)
EPA established NSPS effluent limitations guidelines equivalent to the BPT, BCT, and BAT guidelines for
the control of conventional, priority and nonconventional pollutants for both subcategories. Table 2-1 and
Table 2-2 list the final effluent limitations and standards for the Hazardous subcategory and the Non-
Hazardous subcategory, respectively.
2.8 Pretreatment Standards for Existing Sources (PSES)
EPA did not establish PSES for either subcategory. Any source subject to this rule that introduces
wastewater pollutants into a publicly owned treatment works (POTW) must comply with 40 CFR Part
403.
2.9 Pretreatment Standards for New Sources (PSNS)
EPA did not establish PSNS for either subcategory. Any new source subject to this rule that introduces
wastewater pollutants into a POTW must comply with 40 CFR Part 403.
2.10 Implementation of the Rule for Contaminated Ground Water Flows and
Wastewater from Recovering Pumping Wells
During development of the rule, EPA considered whether it should also include contaminated ground water
flows within the scope of this guideline. Historically, many landfill operations have caused the contamination
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of local ground water, mostly as a result of leakage from unlined landfill units in operation prior to the
minimum technology standards for landfills established by RCRA Subtitle C and D regulations.
Subsequently, State and Federal action under the Comprehensive Environmental Response Compensation
and Liability Act (CERCLA) has required facilities to clean up contaminated ground water. In many cases,
this has resulted in the collection, treatment, and discharge of treated ground water to surface waters. In
addition, in the case of RCRA Subtitle C hazardous waste landfills and municipal solid waste landfills
(MSWLFs), applicable regulatory standards require ground water monitoring and post-closure care and,
in the event of ground water contamination, corrective action measures. These requirements may also result
in treatment of contaminated ground water by such landfill facilities.
EPA, however, has not included contaminated ground water flows within its assessment for this guideline.
Several reasons support EPA's decision not to include contaminated ground water as a regulated waste
stream for this rule.
EPA evaluated flows, pollutant concentrations, treatment in place, and current treatment standards for
discharges of contaminated ground water from landfills. From this evaluation, EPA concluded that
pollutants in contaminated ground water flows are often very dilute or are treated to very low levels prior
to discharge. EPA concluded that, whether as a result of corrective action measures taken pursuant to
RCRA authority or State action to clean up contaminated landfill sites, landfill discharges of treated
contaminated ground water are being adequately controlled. Consequently, further regulation under this
rule would be redundant and unnecessary.
EPA is aware that there are landfill facilities that collect and treat both landfill leachate and contaminated
ground water flows. In the case of such facilities, EPA has concluded that decisions regarding the
appropriate discharge limits should be left to the judgment of the permit writer. As indicated by data
collected through the questionnaires and EPA sampling, ground water characteristics are often site specific
and may contain very few contaminants or may, conversely, exhibit characteristics similar in nature to
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leachate. In cases where the ground water is very dilute, the Agency is concerned that contaminated
ground water may be used as a dilution flow. In these cases, the permit writer should develop "best
professional judgment" (BPJ) permit limits based on separate treatment of the flows, or develop BPJ limits
based on a flow-weighted building block approach, in order to prevent dilution of the regulated leachate
flows. However, in cases where the ground water may exhibit characteristics similar to leachate,
commingled treatment may be appropriate, cost effective, and environmentally beneficial. EPA
recommends that the permit writer consider the characteristics of the contaminated ground water before
making a determination if commingling ground water and leachate for treatment is appropriate. EPA
recommends that the permit writer refer to the leachate characteristics data in Chapter 6 in order to
determine whether contaminated ground water at a landfill has characteristics similar to leachate.
Recovering pumping well wastewater is generated as a result of the various ancillary operations associated
with ground water pumping operations. These operations include construction and development, well
maintenance, and well sampling (i.e. purge water). The wastewater will have very similar characteristics
to contaminated ground water. Therefore, for the same reasons that EPA did not include contaminated
ground water as a regulated wastewater, these regulations do not apply to wastewater from recovering
pumping well operations.
2.11 Implementation of the Rule for Storm Water Discharges
EPA received extensive comments on its proposal to include contaminated storm water as a regulated
waste stream under the landfills effluent guidelines. Several commenters stated that contaminated storm
water (storm water that comes into contact with solid waste at the landfill site) should not be subject to the
landfills effluent limitations guidelines because this is already covered by the Final National Pollutant
Discharge Elimination System Storm Water Multi-sector General Permit (MSGP) for Industrial Activities
(September 29,1995; 60 FR 50803), in States where it applies, or by an equivalent general permit issued
by an NPDES authorized State.
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In an effort to clarify the types of storm water runoff that are subj ect to the landfills effluent guidelines, EPA
revised the definition of contaminated and non-contaminated storm water in the final rule. EPA defines
these terms as follows:
Contaminated storm water: Storm water which comes in direct contact with landfill wastes, the
waste handling and treatment areas, or wastewater that is subj ect to the limitations and standards.
Non-contaminated storm water. Storm water which does not come in direct contact with landfill
wastes, the waste handling and treatment areas, or wastewater that is subj ect to the limitations and
standards. Non-contaminated storm water includes storm water which flows off the cap, cover,
intermediate cover, daily cover, and/or final cover of the landfill.
The Storm Water Pollution Prevention Plan (SWPPP) required by the storm water MSGP or an authorized
State's equivalent general permit requires landfill facilities to identify all of the sources of storm water
contamination at the landfill and then implement measures and controls (such as good housekeeping for
materials storage, sediment and erosion controls - particularly from intermediate and final covers) in an
effort to prevent storm water contamination. EPA believes that the storm water MSGP (or an authorized
State's equivalent general permit) adequately controls pollutants from storm water runoff from covered
areas of the landfill. Covered areas of the landfill include the following: capped, final cover, intermediate
cover, and daily cover areas. The Agency believes that the SWPPP and the monitoring requirements in
the storm water MSGP provide adequate controls for reducing the level of pollutants in storm water from
these areas of landfills.
EPA recognizes that there may be some incidental contact with wastes when storm water flows over a daily
or intermediate cover. However, EPA concluded that such contact will not lead to any meaningful
"contamination" of the storm water so long as the landfill complies with the requirements of the storm water
MSGP or an authorized State's equivalent general permit. For example, the Best Management Practices
(BMPs) outlined in Table L-l and L-2 of the storm water MSGP (60 FR 50940) and the monitoring
requirements in Table L-5 and L-6 for TSS and total recoverable iron (60 FR 50943) provide adequate
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controls for the pollutants that would most likely be associated with runoff from covered areas of non-
hazardous landfills.
Similarly, for hazardous landfills, BMPs and monitoring requirements outlined in Table K-2 (60 FR 50935)
and Table K-3 (60 FR 50936), respectively, also require controls for pollutants associated with runoff from
covered areas of a landfill. In EPA's view, BMPs provide a fair degree of control of these pollutants and
the monitoring requirements of the MSGP provide a tool for evaluating the effectiveness of the Storm Water
Pollution Prevention Plan.
As part of the Agency's continuing effort to improve its environmental and pollution control programs, EPA
has concluded that, although the MSGP provides some control for contaminated storm water runoff, the
landfills effluent limitations guidelines provide a more comprehensive level of control for storm water runoff
that has come in direct contact with solid waste, waste handling and treatment areas, or wastewater flows
that are controlled under this rule. Although the storm water MSGP considered circumstances in which
untreated leachate may be incidently commingled with storm water, the Agency explicitly acknowledged
in the MSGP that insufficient data were available to establish numeric limits for storm water that might be
contaminated based on best available technology for MSWLFs (60 FR 50942), non-hazardous industrial
landfills (60 FR 50943), and hazardous landfills (60 FR 50935).
However, EPA has now concluded that the data collected in support of the landfills effluent limitations
guidelines provide the basis for establishing appropriate numeric limitations for contaminated storm water.
EPA specifically noted in the Preamble for the storm water MSGP that it was developing these guidelines
and that where the guidelines applied to discharges, facilities must comply with them (60 FR 50942). In
addition, EPA intends to propose a reissuance of the storm water MSGP which would include the
promulgated landfills effluent limitations for contaminated storm water (as defined by this landfill guideline).
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2.12 Exclusion for Captive Landfill Facilities
As discussed in Section 2.3 above, the rule does not apply to captive landfills in most circumstances. In
developing the proposed guidelines, an important question EPA addressed was how to treat landfill
leachate generated at a landfill that is associated with an industrial or commercial operation - so-called
"captive" landfills. Currently, in the case of wastewater sources that are not subject to effluent limitations
guidelines and standards, NPDES permit writers must impose limitations on discharges of these wastewater
sources that are developed on a case-by-case, best professional judgment (BPJ) basis. Similarly, an
indirect discharger may not introduce any pollutants to a POTW from these sources that will pass through
or interfere with the POTW's operations. Generally, each POTW is required to develop a pretreatment
program and enforce the prohibition on pass through and interference through specific local limits.
EPA initially considered development of effluent guidelines to address any landfill discharging directly to
surface waters of the United States or introducing pollutants into a POTW. Consequently, EPA's technical
evaluation for the proposal included an assessment of virtually all landfill facilities which collect wastewater
as a result of landfilling operations. EPA proposed to exclude wastewater discharges from captive landfills
located at industrial facilities in specific circumstances. In the proposal, a captive landfill would not have
been subject to the guidelines if: 1) it commingled landfill process wastewater with non-landfill process
wastewater for treatment, and 2) the landfill received only waste generated on site or waste generated from
a similar activity at another facility under the same corporate structure.
For the final rule, EPA determined that these requirements are too restrictive and therefore the Agency has
decided not to include captive landfills within the scope of this guideline except in a limited number of
circumstances. The effect of this decision for the final rule is not to allow these wastewater sources to
escape treatment. Landfill wastewater at captive facilities is and will remain subject to treatment and
controls on its discharge. The Clean Water Act (CWA) requires wastewater discharges to meet
technology-based effluent limitations on the discharge whether the mechanism for imposing these limitations
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is EPA-established national effluent limitations guidelines or a permit writer's imposition on a case-by-case
basis of BPJ limitations. In like manner, in order to prevent pass through or interference, indirect
dischargers must limit their introduction of pollutants to aPOTW whether EPA has established national
categorical pretreatment standards for the discharge or a POTW has established local limits.
For the final rule, EPA has modified the proposal to remove the requirement that a facility must commingle
its wastewater from a captive landfill with the facility's non-landfill process wastewater for treatment in
order not to be subj ect to the landfills effluent guideline, in most circumstances. For the reasons described
in detail below, EPA did not remove the commingling requirement for CWTs. In addition, EPA also
changed the conditions under which captive landfills may accept off-site wastes and not be subj ect to this
guideline.
In the proposal, EPA stated that the commingling requirement ensures that wastewater from captive landfills
will undergo adequate treatment (treatment that is comparable to the level of treatment that would be
required by the landfills effluent guideline) prior to discharge. EPA determined that the commingling of
landfill wastewater with industrial wastewater for treatment was an unnecessary requirement to impose in
nationally applicable regulations for the reasons discussed below. Permit writers are establishing
appropriate limits on these discharges by either applying the effluent limitations guidelines applicable to the
associated industrial activity to the discharge or developing other BPJ limitations. EPA recommends that
permit writers use this guideline when developing these BPJ limitations.
From the information developed by the Agency for this rulemaking and confirmed by comments on the
proposal, EPA has concluded that landfill wastewater generated by captive landfills operated in conjunction
with and receiving the bulk of their waste from an industrial or commercial operation will have a similar
pollutant profile to the wastewater generated in the industrial or commercial operation. EPA has further
concluded that the wastewater generated by landfill operations at most of the captive facilities are already
subject to effluent guidelines. In the circumstances in which the wastewater is not expressly subject to
effluent guidelines, EPA has determined that permit writers generally impose BPJ limitations on the
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discharge of landfill wastewater that are similar to the limitations applicable to the discharge of industrial
process wastewater whether commingled or not. EPA has compared the wastewater treatment
technologies employed at many of the industrial facilities operating landfills in conjunction with industrial or
commercial operations to the treatment technologies that EPA used as the basis for the BPT/B AT limits
in this effluent guideline. The Agency's review of such situations shows that the landfill wastewater receives
treatment that is comparable or better than the level of treatment that would be required by the landfills
effluent guideline.
Consequently, EPA has decided to eliminate the requirement of commingling as a condition for a captive
landfill not to be subject to landfill limitations and standards (except in the case of CWTs). EPA has
concluded that landfill wastewater at captive landfills is now and will continue to receive adequate treatment
because the landfill wastewater generally must meet the same effluent limitations that would have been
required had the waste streams been commingled. In cases where the permit writer is establishing BPJ
limitations for the discharge of captive landfill wastewater that is not commingled for treatment, the permit
writer should look at the effluent guidelines applicable to the associated industrial operation and the landfills
effluent guidelines for potential guidance in setting those limitations.
Because of the nature of most CWTs, EPA determined that the reasons that generally supported exclusion
of other captive landfills would not apply in the case of CWTs. As explained above, EPA concluded that
a captive landfill which only received wastes generated in an industrial or commercial operation directly
associated with the landfill or similar wastes would generate a leachate with a similar pollutant profile to the
other wastewater streams produced at the industrial operation. In such circumstances, the data reviewed
by EPA showed that the landfill wastewater and other industrial wastewater are generally commingled for
treatment and subj ect to the same discharge limitations. In these circumstances, it was appropriate not to
subject the landfill to this guideline.
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Because a CWT, by its very nature, may generate a wide array of different solid wastes for landfill disposal,
it may generate a leachate that varies significantly from other streams being treated at the CWT at the time
the leachate is collected. Therefore, EPA concluded that the basis for the exclusion — the similarity in
wastewater — would not necessarily apply in the case of CWTs. EPA decided that, in order to ensure that
the CWT landfill wastewater is treated adequately, the landfill wastewater from a CWT landfill should be
commingled with other CWT wastewater for treatment.
It is worth noting that the maj ority of industrial facilities that operate captive landfills do commingle their
landfill process wastewater with other industrial wastewater for treatment. (February 6, 1998; 63 FR
6430). A review by EPA of individual NPDES permits for captive and intracompany facilities found that,
for the most part, landfill waste streams are mixed with categorical wastes and subject to limitations
comparable to the final limitations for landfills.
Most captive landfill facilities choose to commingle their landfill process wastewater for treatment for
several reasons. First of all, wastewater flows from captive landfills are usually quite small in comparison
to the wastewater flows from other industrial operations at the captive facility. EPA's data show that the
landfill wastewater flows are often less than one percent and typically less than three percent of the
industrial wastewater flows. Therefore, most facilities choose to commingle the relatively small volume of
landfill wastewater with the larger industrial wastewater volumes rather than maintaining and operating a
completely separate wastewater treatment system for the landfill wastewater. Second, as mentioned above,
it is likely that leachate from landfills at industrial operations will reflect a pollutant profile similar to the
facility's industrial process wastewater. Therefore, based on the similarity of the waste streams, facilities
often choose to commingle these streams for treatment. In fact, most of the captive facilities identified in
EPA's database commingle their leachate with other industrial process wastewater for treatment.
Comments submitted in response to the proposed rule suggest that situations do exist where a captive
landfill may not commingle the landfill wastewater with other process wastewater for treatment. In
circumstances where a facility chooses not to commingle landfill leachate for treatment with the other
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process wastewater generated, EPA has concluded, based on comments submitted, that this wastewater
will still be subj ect to categorical or Best Professional Judgment (BPJ) limits reflecting comparable removal s
in most instances.
Lastly, industrial facilities with captive landfills often choose to commingle their waste streams for treatment
in order to avoid additional NPDES or pretreatment requirements that would be necessary if the waste
streams were treated and discharged separately. EPA concluded that the wastewater generated by landfill
operations at most of the captive facilities are already subject to categorical effluent limitations (or
pretreatment standards). Information gathered by EPA prior to proposal and in comments received on the
proposed rule support the conclusion that these wastewater flows were either assessed and evaluated for
the effluent limitations guideline applicable to the facility, or are subj ect to a "building block approach" (for
directs) or the "combined waste stream formula" (for indirects) for developing BPJ limits or standards
established by the permit writer or local control authority. This review indicates that, for the most part,
these landfill waste streams are mixed with categorical wastes for treatment and subject to limitations
comparable to the final landfill regulation.
Based on comments received, the Agency also determined that the requirement in the proposal that solid
wastes deposited in the captive landfill must either be generated on site or from an off-site facility under the
same corporate structure was too restrictive and could often prohibit a company from safely and properly
disposing of solid wastes accepted from tolling, remediation, product stewardship, and public service
activities.
In the proposal, EPA narrowly limited the universe of captive landfills that fall outside the scope of this rule
to captive landfills that only accepted wastes from on site or from off-site facilities under the same corporate
structure. The reason for this was essentially to ensure that the captive landfills were only accepting wastes
that would be similar to those wastes generated on site. This in turn would provide some degree of
assurance that the leachate generated from these wastes would be compatible with the on-site industrial
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wastewater treatment. However, from the comments submitted on this issue, EPA determined this waste
acceptance criterion for the captive exclusion was too restrictive. Those commenting on this issue identified
several waste acceptance practices that are commonly used by captive landfills that would not meet the
proposed exclusion criteria but are consistent with EPA's obj ective that landfill leachate receive treatment
compatible with its expected constituents. Many of these current waste disposal practices are activities that
EPA encourages and, therefore, EPA has revised the exclusion criteria pertaining to waste acceptance for
captive/intracompany landfills in order to accommodate these disposal practices.
Specifically, several commenters requested that EPA broaden the criteria for determining those captive
landfills that fall outside the scope of this rule to include waste acceptance from tolling and contract
manufacturers, product stewardship, company partnerships, and remediation activities. EPA concluded
that waste disposal at captive landfills from these types of activities will, in most cases, result in leachate that
will be adequately controlled through the implementation of categorical or BPJ limitations at the facility.
However, EPA remains concerned that there are circumstances in which inter-company waste products
deposited in the landfill may result in contaminants in the leachate that may not be compatible with the
existing industrial wastewater treatment system or may not be covered adequately by the existing industrial
effluent guideline. Therefore, one of the alternative conditions for the revised applicability provisions of the
guideline described above for captive landfills provides that waste accepted at the captive landfill must be
of a similar nature to the wastes generated at the operation with the associated landfill. Thus, the permitting
authority must determine that wastes accepted for disposal at a captive landfill are of a similar nature to the
waste generated at the facility directly associated with the captive landfill. Factors that the permit writer
should consider in determining whether a waste is similar are described at Section 2.13.
In addition, commenters also requested that EPA include the acceptance of wastes for disposal as a public
service as a category of landfill practices that qualify for the captive exclusion. EPA agrees and has
included such a provision. EPA applauds the efforts of manufacturing facilities who provide members of
their communities with a cost effective and environmentally safe means for disposing of their solid waste.
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Therefore, in the final rule, EPA determined that this rule shall not apply to those landfills operated in
conjunction with other industrial or commercial operations which receive other wastes from public service
activities so long as the company owning the landfill does not receive a fee or other remuneration for the
disposal service. EPA's decision not to subject captive landfills that accept off-site wastes for disposal as
a public service is not inconsistent with its decision generally to condition non-applicability on the similarity
of wastes accepted for disposal. Based on its review of data collected for this guideline and comments
received, EPA concluded that the quantity of wastes accepted for disposal as a public service would not
in any measurable way affect the pollutant profile of the leachate generated by the landfill even if dissimilar.
Of course, these wastewater flows still remain subject to treatment to achieve BPJ permit limits reflecting
the landfill contribution to the facility discharge.
The Agency has determined that whether captive landfills accepting wastes from off site or from a company
not within the same corporate structure on a non-commercial basis should be subj ect to the landfills effluent
guideline should hinge on the ability of the captive landfill to handle the waste in an appropriate manner.
Therefore, the Agency concluded that the waste acceptance criterion for determining those captive landfills
that fall outside the scope of this rule should be based on the similarity of the waste accepted for disposal
from another facility to the waste generated by the industrial or commercial operation directly associated
with the landfill. In the case of captive landfills treating similar wastes, the permit writer should base permit
limits on limitations for the guideline to which the industrial or commercial operation is subj ect or establish
BPJ limitations. Again, the permit writer, if developing BPJ limitations, should consider these landfill
guidelines as guidance in this effort.
2.13 Determination of Similar Wastes for Captive Landfill Facilities
As discussed at Sections 2.3 and 2.12 above, the Agency concluded that discharges from captive landfills
should not be subj ect to the guidelines if the captive landfills only accepted waste for disposal from another
facility that was similar to the waste generated by the industrial or commercial operation directly associated
with the landfill. This section offers guidance to permit writers for determining whether a solid waste
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received for disposal in a captive landfill is similar to those wastes generated by the facility directly
associated with the landfill.
According to EPA's database, many of the industrial or commercial facilities that operate captive landfills
are subj ect to effluent limitations guidelines in 40 CFR Subchapter N. For the most part, facilities subj ect
to a particular industrial category effluent guideline produce similar types of wastes. Therefore, EPA
decided that this rule does not apply to landfills operated in conjunction with other industrial or commercial
operations when the landfill receives wastes generated by the industrial or commercial operation directly
associated with the landfill and also receives other wastes generated by a facility that is subject to the same
provisions in 40 CFR SubchapterN as the waste-receiving facility. However, there are cases where a
captive landfill is directly associated with an industrial or commercial operation that is not subject to an
effluent guideline. Or, a facility, subj ect to an effluent guideline, may operate a landfill in conjunction with
industrial or commercial operations, but may also accept other wastes from facilities that are not subject
to the same effluent guideline or not subject to an effluent guideline at all. In these cases, the permit writer
must determine whether the other wastes received for disposal are of similar nature to the wastes generated
by the industrial or commercial operation directly associated with the landfill. In cases where the permit
writer determines that the other waste accepted by the captive landfill is not similar to the waste generated
by the industrial or commercial activity directly associated with the landfill, the landfill wastewater will be
subject to the landfills effluent limitations. However, if the permit writer determines that the wastes are
similar, then the wastewater from the captive landfill should be subject to the same categorical effluent
guideline (or BPJ limitations) as the industrial or commercial facility.
A permit writer should consider the following factors in deciding whether other wastes received by a
captive landfill are similar to those wastes generated by the industrial or commercial operation directly
associated with the landfill:
1. Are the other wastes received from facilities that are subj ect to the same provisions in 40 CFR
Subchapter N as the facility directly associated with the captive landfill?
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If so, then the landfills effluent guidelines do not apply to this captive landfill. If not, then
the permit writer should consider the other factors listed below.
2. Are the other wastes received from facilities that are part of the same effluent guidelines "grouping"
as shown in Table 2-3?
If so, it i s likely that the wastes are similar and the landfill s effluent guidelines do not apply.
Table 2-3 groups the industrial categories under Subchapter N into the following six
groups: Organics, Metals, Inorganics and Non-Metals, Pesticides, Explosives, and
Asbestos. It is likely that industries within the same industrial effluent guideline "grouping"
will generate similar types of constituents in the solid wastes, and the leachate resulting from
the disposal of these wastes will be controlled adequately by the effluent limitation for the
industrial or commercial facility directly associated with the captive landfill. However, this
may not always be the case and, therefore, EPA left to the local control authority the
determination of whether the landfills effluent guideline should apply to a captive landfill that
accepts wastes from other facilities that are not subj ect to the same provisions in 40 CFR
Subchapter N. The local permitting authority will determine whether a captive landfill
which accepts wastes from other industrial activities, apart from those directly associated
with the landfill, is subj ect to the landfills effluent guidelines based on the similarity of the
other wastes and the likelihood that these wastes will result in leachate that is compatible
with the wastewater treatment technology used to treat the landfill leachate.
3. In the case of hazardous captive landfills, do the other wastes being received have the same
hazardous waste codes as those generated at the facility directly associated with the landfill?
If so, it is possible that the wastes are similar. However, this may not always be the case
and, therefore, EPA left to the local control authority the determination of whether the
landfills effluent guideline should apply to a captive landfill that accepts wastes from other
facilities that are not subject to the same provisions in 40 CFR Subchapter N.
4. Is a significant portion of the waste deposited in the landfill from the industrial or commercial
operation that is directly associated with the captive landfill?
The control authority should analyze the number of customers and the amount of the off-
site or inter-company waste deposited relative to the quantity of on-site or intracompany
waste placed in the captive landfill. Again, the main reason for the exclusion for captive
landfills is that their leachate should resemble the industrial wastewater of the operation
directly associated with the landfill and, therefore, the landfill leachate will be adequately
controlled by the applicable industrial effluent guidelines. However, this logic is only
applicable when the bulk of the waste placed in the landfill is of similar content to that being
produced by the industrial facility directly associated with the landfill. Therefore, when
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applying the captive exclusion, the control authority should analyze the volume and
characteristics of waste received from inter-company waste transfers in determining
whether the leachate generated by the captive landfill will have similar characteristics to the
industrial wastewater generated by the company owning the landfill.
5. Is the facility that is directly associated with the captive landfill deriving any revenues from waste
disposal at the landfill?
In developing the exclusion for captive landfills, EPA's intent was to exclude those non-
commercial landfills that are directly associated with an industrial or commercial operation
and whose leachate is currently being adequately addressed by the facility's categorical or
BPJ limitations. EPA believes that where any revenues are being derived from the
collection of fees for solid waste disposal at a captive landfill, the facility is accepting
wastes on a commercial basis - - wastes that may well be dissimilar to that being disposed
of at the landfill. The captive exception is premised on the fact that, in most cases, leachate
from a landfill associated with an industrial operation will resemble the industrial process
wastewater generated by the industrial operation and, therefore, the landfill leachate will
be adequately controlled by the applicable industrial effluent guidelines or BPJ limitations.
However, this is a reasonable assumption only in circumstances where the waste placed
in the landfill is of similar content to that being produced by the industrial operation directly
associated with the landfill. It is likely that a commercial landfill may accept significant
volumes of waste that are not similar to the wastes generated by the industrial operation
directly associated with the landfill.
6. Is the industrial or commercial facility directly associated with the captive landfill accepting wastes
for disposal as part of public service activities?
If so, and the facility does not receive a fee or other remuneration for the disposal service,
the captive landfill is not subject to this rule. EPA defines public service activities in
Appendix B.
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Table 2-1: Final Concentration Limitations for Hazardous Landfill Subcategory,
Direct Discharges
Pollutant or
Pollutant Property
BOD5
TSS
Ammonia
Arsenic (Total)
Chromium (Total)
Zinc (Total)
Alpha Terpineol
Aniline
Benzoic Acid
Naphthalene
p-Cresol
Phenol
Pyridine
pH
Maximum for 1 day
(mg/L)
220
88
10
1.1
1.1
0.535
0.042
0.024
0.119
0.059
0.024
0.048
0.072
Monthly average shall not exceed
(mg/L)
56
27
4.9
0.54
0.46
0.296
0.019
0.015
0.073
0.022
0.015
0.029
0.025
Shall be in the range 6.0 - 9.0 pH units.
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Table 2-2: Final Concentration Limitations for Non-Hazardous Landfill Subcategory,
Direct Discharges
Pollutant or
Pollutant Property
BOD5
TSS
Ammonia
Zinc
Alpha Terpineol
Benzoic Acid
p-Cresol
Phenol
PH
Maximum for 1 day
(mg/L)
140
88
10
0.20
0.033
0.12
0.025
0.026
Monthly average shall not exceed
(mg/L)
37
27
4.9
0.11
0.016
0.071
0.014
0.015
Shall be in the range 6.0 - 9.0 pH units.
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Table 2-3: Grouping of Subchapter N Effluent Guidelines and Standards
Industrial Category
Dairy products and processing
Grain mills
Canned and preserves fruits and vegetables
Canned and preserved seafood
Sugar processing
Textile mills
Cement manufacturing
Feedlots
Electroplating
Organic chemicals, plastics and synthetic fibers
Inorganic chemicals manufacturing
Soap and detergent manufacturing
Fertilizer manufacturing
Petroleum refining
Iron and steel manufacturing
Nonferrous metals manufacturing
Phosphate manufacturing
Steam electric power plants
Ferroalloy manufacturing
Leather tanning and finishing
Glass manufacturing
Asbestos manufacturing
Rubber processing
Timber products processing
Pulp, paper and paperboard
Builder's paper and board mills
Meat products
Metal finishing
Coal mining
Oil and gas extraction
Mineral mining and processing
Pharmaceutical preparations
Ore mining
Paving and roofing materials (tars & asphalt)
Paint formulation
Ink formulation
Gum and wood chemicals
Pesticides
Explosives manufacturing
Carbon black manufacturing
Photographic equipment and supplies
Hospital
Part#
405
406
407
408
409
410
411
412
413
414
415
417
418
419
420
421
422
423
424
425
426
427
428
429
430
431
432
433
434
435
436
439
440
443
446
447
454
455
457
458
459
460
Characteristics
Organics
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Metals
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Inorganics
Non-metal
X
X
X
X
X
X
X
Pesticides
X
Explosives
X
Asbestos
X
IO
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3.0 INDUSTRY DESCRIPTION
The Landfills industry consists of facilities that receive wastes either as commercial or municipal operations
or as on-site (captive) operations owned by waste generators. These landfill facilities generate wastewater
and discharge it to surface waters, publicly owned treatment works (POTWs), or use some other form of
zero or alternative disposal. The Resource Conservation and Recovery Act (RCRA) defines a landfill as
"an area of land or an excavation in which wastes are placed for permanent disposal, and that is not a land
application unit, surface impoundment, injection well, or waste pile" (40 CFR 257.2). RCRA classifies
landfills as either Subtitle C hazardous or Subtitle D non-hazardous. Wastewater generated and discharged
by landfills can include, but is not limited to, leachate, gas collection condensate, contaminated ground
water, contaminated storm water, drained free liquids, truck/equipment washwater, laboratory-derived
wastewater, and wastewater recovered from pumping wells.
Landfills are commonly classified by the types of wastes they accept and/or by their ownership status.
Some of the terms used to describe a landfill include municipal, sanitary, chemical, industrial, RCRA,
hazardous waste, Subtitle C, and Subtitle D. Although non-hazardous landfills do not knowingly accept
hazardous wastes, these facilities may contain hazardous wastes due to disposal practices that occurred
prior to 1980 and before the enactment of RCRA and its associated regulations. The following section
provides descriptions of landfills in terms of ownership type and regulatory type.
Ownership Status
• Municipal: Municipally-owned landfills are those that are owned by local governments.
Municipally-owned landfills may be designed to accept either Subtitle D or Subtitle
C wastes (see "Regulatory Type").
• Commercial: Commercial landfills are privately-owned facilities and can be designed to receive
either municipal, hazardous, or non-hazardous industrial wastes. Typical non-
hazardous industrial wastes include packaging and shipping materials, construction
and demolition debris, ash, and sludge.
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Captive:
• Intra-company:
Regulatory Type
Subtitle C:
Subtitle D:
Captive landfills are operated in conjunction with other industrial or commercial
operations, and receive the bulk of their wastes from the industrial or commercial
operations. Captive landfills are located on, or adjacent to, the facility they service
and are common at major hazardous waste generators, such as chemical and
petrochemical manufacturing plants.
Landfill facilities operated in conjunction with other industrial or commercial
operations which only receive waste from off-site facilities under the same
corporate structure, ownership, or control. These landfills are similar to captive
sites but receive wastes from multiple locations of one company.
Subtitle C landfills are those disposal operations authorized by RCRA to accept
hazardous wastes as defined in 40 CFRPart 261. Subtitle C landfills are subject
to the criteria in 40 CFR Part 264 Subpart N - Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities and
40 CFR Part 265 Subpart N - Interim Standards for Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal Facilities. Hazardous waste
landfills are subj ect to requirements outlined in 40 CFR Parts 264 and 265 that
include the requirement to maintain a leachate collection and removal systems
during the active life and post-closure period of the landfill. Section 3.1 presents
more details on the regulatory requirements of Subtitle C.
Subtitle D landfills are those disposal operations that are subject to either of the
criteria established in 40 CFR Parts 257 (Criteria for Classification of Solid Waste
Disposal Facilities and Practices) or 258 (Criteria for Municipal Solid Waste
Landfills). The wastes received at Subtitle D landfills include municipal refuse, ash,
sludge, construction and demolition debris, and non-hazardous industrial waste.
These facilities were not designed to receive hazardous wastes; however, prior to
1980 and the enactment of RCRA, older landfills may have received waste later
classified as hazardous under RCRA. Any Subtitle D landfill accepting municipal
refuse after October 9,1993 is classified as a Municipal Waste Disposal Unit, and
is regulated under 40 CFR 258. Any Subtitle D landfill not accepting municipal
waste after October 9,1993 continues to be regulated under 40 CFR 257. For
the purposes of this document, Subtitle D landfills not accepting municipal refuse
are referred to as "Subtitle D non-municipal" landfills.
The following discussions present a regulatory history of this industry and past EPA studies.
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3.1 Regulatory History of the Landfills Industry
Depending on the type of wastes disposed of at a landfill, the landfill may be subject to regulation and
permitting under either Subtitle C or Subtitle D of RCRA. Subtitle C facilities receive wastes that are
identified or listed as hazardous wastes at 40 CFR Part 261. Subtitle D landfills can only accept wastes
that are not defined as hazardous wastes at 40 CFR Part 261. The following sections outline some of the
key regulations that have been developed to control the environmental impacts of Subtitle C and Subtitle
D landfills.
3.1.1 RCRA Subtitle C
Subtitle C of the RCRA of 1976 directed EPA to promulgate regulations to protect human health and the
environment from the improper management of hazardous wastes. Based on this statutory mandate, the
goal of the RCRA program was to provide comprehensive, "cradle-to-grave" management of hazardous
waste. These regulations establish a system for tracking the disposal of hazardous wastes and special
design requirements for landfills depending on whether a landfill accepted hazardous or non-hazardous
waste. Key statutory provisions in RCRA Subtitle C include the following:
Section 3001: Requires the promulgation of regulations identifying the characteristics of
hazardous waste and listing particular hazardous wastes.
Section 3 002: Requires the promulgation of standards, such as manifesting, record keeping, etc.,
applicable to generators of hazardous waste.
Section 3003: Requires the promulgation of standards, such as manifesting, record keeping, etc.,
applicable to transporters of hazardous waste.
Section 3 004: Requires the promulgation of performance standards applicable to the owners and
operators of facilities for the treatment, storage, or disposal of hazardous waste.
Section 3005: Requires the promulgation of regulations requiring each person owning or
operating a treatment, storage, or disposal facility to obtain a permit.
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These regulations establish a system for tracking the disposal of hazardous wastes and performance and
design requirements for landfills accepting hazardous waste. Under RCRA, requirements are initially
triggered by a determination that a waste is hazardous as defined in 40 CFR Part 261. Any party, including
the original generator, that treats, stores, or disposes of a hazardous waste must notify EPA and obtain an
EPA identification number. EPA established performance regulations governing the operation of hazardous
waste landfills at 40 CFR Parts 264 and 265. RCRA Subtitle C hazardous waste regulations apply to
landfills that presently accept hazardous wastes or have accepted hazardous waste at any time after
November 19, 1980.
3.1.1.1 Land Disposal Restrictions
The Hazardous and Solid Waste Amendments (HSWA) to RCRA, enacted 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: 1) meet the EPA-established
treatment standard for the waste prior to land disposal, or 2) 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 of RCRA, the treatment standards that EPA develops may be expressed as either
constituent concentration levels or as specific methods of treatment. Under RCRA Section 3004(m)(l),
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. For purposes of the restrictions,
the RCRA program defines land disposal to include, among other things, any placement of hazardous waste
in a landfill. Land disposal restrictions are published in 40 CFR Part 268.
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EPA has used hazardous waste treatability data as the basis for land disposal restrictions standards. EPA
has identified Best Demonstrated Available Treatment Technology (BDAT) for each listed hazardous
waste. BDAT is the treatment technology that EPA finds to be the most effective in treating a waste and
that also is readily available to generators and treaters. In some cases, EPA has designated as BDAT for
a particular waste stream a treatment technology shown to have successfully treated 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 (LDRs), EPA promulgated Universal Treatment Standards
(UTS) as part of the RCRA phase two final rule (July 27,1994). The UTS are a series of concentrations
for wastewater and non-wastewater 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 existed for each constituent. The UTS simplified the standards by having
only one treatment standard for each constituent in any waste residue. The LDR and the UTS restricted
the concentrations of wastes that could be disposed of in landfills, thus improving the environmental quality
of the leachate from landfills.
The LDR treatment standards established under RCRA may differ from the Clean Water Act effluent
guidelines 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 difference in format of the LDR and effluent guidelines is that LDR establishes a single daily limit for
each pollutant parameter while effluent guidelines establish monthly and daily limits. Additionally, the
effluent guidelines provide for several types of discharge, including new and existing sources, and indirect
and direct discharge.
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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 (e.g., Electroplating, 40 CFR 413;
and Metal Finishing, 40 CFR 433). The effluent guidelines limitations and standards are industry-specific,
subcategory-specific, and 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 following statutory factors that the Administrator is required to consider
in developing technically and economically achievable limitations and standards: manufacturing products
and processes (which for landfills involves types of waste disposed), 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 or identical waste streams are regulated at different levels dependent on the receiving body of the
wastewater (e.g. a POTW, a surface water, or a land disposal facility).
3.1.1.2 Minimum Technology Requirements
To further protect human health and the environment from the adverse affects of hazardous waste disposed
of in landfills, the 1984 HSWA to RCRA established minimum technology requirements for landfills
receiving hazardous waste. These provisions required the installation of double liners and leachate
collection systems at new landfills, at replacements of existing units, and at lateral expansions of existing
units. The Amendments also required all hazardous waste landfills to install ground water monitoring wells
by November 8,1987. Performance regulations governing the operation of hazardous waste landfills are
included at 40 CFR Parts 264 and 265.
3.1.2 RCRA Subtitle D
Landfills managing non-hazardous wastes are currently regulated under the RCRA Subtitle D program.
These landfills include municipal, private intra-company, private captive, and commercial facilities used for
the management of municipal refuse, incinerator ash, sewage sludge, and a range of non-hazardous
industrial wastes.
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3.1.2.1 40 CFR Part 257, Subpart A - Criteria for Classification of Solid Waste Disposal
Facilities and Practices
EPA promulgated the criteria on September 13, 1979 (44 FR 53460) under the authority of RCRA
Sections 1008(a) and 4004(a) and Sections 405(d) and (e) of the Clean Water Act. The criteria in
§257.1 through 257.4 were adopted for determining which solid waste disposal facilities and practices pose
a reasonable probability of adverse effects on health and the environment, and the criteria in §257.5 through
257.30 were adopted to ensure that non-municipal non-hazardous waste disposal units that receive
conditionally exempt small quantity generator (CESQG) waste do not present risks to human health and
the environment taking into account the practicable capability of such units. These criteria apply to all solid
waste disposal facilities and practices. However, certain facilities and practices are not covered by the
criteria, such as agricultural wastes relumed to the soil as fertilizers or soil conditioners, overburden resulting
from mining operations intended for return to the mine site, land application of domestic sewage or treated
domestic sewage, the location and operation of septic tanks, hazardous waste disposal facilities which are
subj ect to regulations under RCRA Subtitle C (discussed above), municipal solid waste landfills that are
subject to the revised criteria in 40 CFR Part 258 (discussed below), and use or disposal of sewage sludge
on the land when the sewage sludge is used or disposed of in accordance with 40 CFR Part 503 (See 40
CFRPart257.1(c)(l)-(ll)).
The criteria include general environmental performance standards addressing the following eight major
areas: flood plains, protection of endangered species, protection of surface water, protection of ground
water, limitations on the land application of solid waste, periodic application of cover to prevent disease
vectors, air quality standards (prohibition against open burning), and safety practices ensuring protection
from explosive gases, fires, and bird hazards to airports. Facilities that fail to comply with any of these
criteria are considered open dumps, which are prohibited by RCRA Section 4005. Those facilities that
meet the criteria are considered sanitary landfills under RCRA Section 4004(a). Landfill wastewater
generated at solid waste disposal facilities that are subject to the requirements of 40 CFR Part 257 Subpart
A are subject to the effluent limitations for the Non-Hazardous subcategory.
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3.1.2.2 40 CFR Part 257, Subpart B - Conditionally Exempt Small Quantity Generator
Revised Criteria
A conditionally-exempt small-quantity generator is generally defined as one who generates no more than
100 kilograms of hazardous waste per month in a calendar year (40 CFR 261.5(a)). Such conditionally-
exempt small-quantity generators (with certain exceptions) are not subject to RCRA Subtitle C
requirements. However, on July 1,1996, EPA did the following: (1) amended Part 257 to establish criteria
that must be met by non-municipal, non-hazardous solid waste disposal units that receive conditionally-
exempt small-quantity generator waste and (2) established separate management and disposal standards
(in 40 CFR 261.5(f)(3) and (g)(3)) for those who generate conditionally-exempt small-quantity generator
waste (see 61 FR 342169). The conditionally-exempt small-quantity generator revised criteria for such
disposal units include location standards, ground water monitoring, and corrective action requirements.
Landfill wastewater generated at solid waste disposal facilities that are subject to the requirements of 40
CFR Part 257 Subpart B are subject to the effluent limitations for the Non-Hazardous subcategory.
3.1.2.3 40 CFR Part 258 Revised Criteria for Municipal Solid Waste Landfills
On October 9,1991, EPA promulgated revised criteria for municipal solid waste landfills in accordance
with the authority provided in RCRA Sections 1008(a)(3), 4004(a), 4010 (c) and Clean Water Act
(CWA) Sections 405(d) and (e) (see 56 FR 50978). Under the terms of these revised criteria, municipal
solid waste landfills are defined to mean a discrete area of land or an excavation that receives household
waste, and is not a land application unit, surface impoundment, injection well, or waste pile, as those terms
are defined in 40 CFR 257.2 and 258.2. In addition to household waste, a municipal solid waste landfill
unit also may receive other types of RCRA Subtitle D wastes, such as commercial solid waste, non-
hazardous sludge, and industrial solid waste. Such a landfill may be publicly or privately owned. A
municipal solid waste landfill unit may be a new unit, existing municipal solid waste landfill unit, or a lateral
expansion.
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The municipal solid waste landfill revised criteria include location standards (Subpart B), operating criteria
(Subpart C), design criteria (Subpart D), ground water monitoring and corrective action (Subpart E),
closure and post-closure care criteria (Subpart F), and financial assurance requirements (Subpart G). The
design criteria specify that new municipal solid waste landfill units and lateral expansions of existing units
(as defined in Section 258.2) must be constructed in accordance with either (1) a design approved by a
Director of a State whose municipal solid waste landfill permit program has been approved by EPA and
which satisfies a performance standard to ensure that unacceptable levels of certain chemicals do not
migrate beyond a specified distance from the landfill (Sections 258.40(a)(l), (c), (d), Table 1) or (2) a
composite liner and a leachate collection system (Sections 258.40(a)(2), (b)). The ground water
monitoring criteria generally require owners or operators of municipal solid waste landfills to monitor ground
water for contaminants and generally implement a corrective action remedy when monitoring indicates that
a ground water protection standard has been exceeded. However, certain small municipal solid waste
landfills located in arid or remote locations are exempt from both design and ground water monitoring
requirements. The closure standards require that a final cover be installed to minimize infiltration and
erosion. The post-closure provisions generally require, among other things, that ground water monitoring
continue and that the leachate collection system be maintained and operated for 3 0 years after the municipal
solid waste landfill is closed. The Director of an approved State may increase or decrease the length of
the post-closure period.
Again, as is the case with solid waste disposal facilities that fail to meet the requirements in 40 CFR Part
257, Subpart A, municipal solid waste landfills that fail to satisfy the revised criteria in Part 258 constitute
open dumps and are therefore prohibited by RCRA Section 4005 (40 CFR 258. l(h)). Landfill wastewater
generated at solid waste disposal facilities (i.e., municipal solid waste landfills) that are subject to the
requirements in 40 CFRPart258 are subject to the effluent limitations for the Non-Hazardous subcategory.
3.1.3 Current Wastewater Regulations
Prior to this regulation, EPA had not promulgated national effluent limitations guidelines for the discharge
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of wastewater from the Landfills industry. In the absence of these guidelines, permit writers have had to
rely on a combination of their own best professional judgement (BPJ), water quality standards, and
technology transfer from other industrial guidelines in setting permit limitations for landfills discharging to
surface waters. In addition, local control authorities also have had to rely on their own best professional
judgement, pass-through analyses, and other local factors in establishing pretreatment standards for the
discharge of landfill wastewater to their municipal sewage systems and POTWs.
In 1989, EPA completed a preliminary study of the Landfills industry. In a report entitled "Preliminary Data
Summary for the Hazardous Waste Treatment Industry," EPA concluded that wastewater discharges from
landfills can be a significant source of toxic pollutants being discharged to surface waters and POTWs. In
a consent decree between NRDC and EPA, dated January 31,1992, EPA agreed, among other things,
to propose effluent guidelines for the "Landfills and Industrial Waste Combusters" category by November
1997 and final action by November 1999.
3.2 Industry Profile
The growth of the Landfills industry is a direct result of RCRA and subsequent EPA and State regulations
that establish the conditions under which solid waste may be disposed. The implementation of the increased
control measures required by RCRA has had a number of ancillary effects on the Landfills industry.
The RCRA requirements have affected the Landfills industry in different ways. On the one hand, it has
forced many landfills to close because they lacked adequate on-site controls to protect against migration
of hazardous constituents from the landfill, and it was not economical to upgrade the landfill facility. As a
result, a large number of landfills, especially facilities serving small populations, have closed rather than incur
the significant expense of upgrading.
Conversely, large landfill operations have taken advantage of economies of scale by serving wide
geographic areas and accepting an increasing portion of the nation's solid waste. For example, responses
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to the EPA's Waste Treatment Industry Survey indicated that 75 percent of the nation's municipal solid
waste is deposited in large landfills representing only 25 percent of the landfill population.
EPA has identified several trends in the waste disposal industry that may increase the quantity of leachate
produced by landfills. More stringent RCRA regulations and the restrictions on the management of wastes
have increased the amount of waste disposed at landfills as well as the number of facilities choosing to send
wastes off site to commercial facilities in lieu of pursuing on-site management options. This will increase
treated leachate discharges from the nation's landfills, thus, potentially putting at risk the integrity of the
nation's waters. Further, as a result of the increased number of leachate collection systems, the volume of
leachate requiring treatment and disposal has greatly increased.
3.2.1 Industry Population
In developing the initial landfill population to be studied for this regulation, EPA used various sources such
as State environmental and solid waste departments, the National Survey of Hazardous Waste Treatment,
Storage, Disposal, and Recycling Facilities respondent list, Environmental Ltd.'s "1991 Directory of
Industrial and Hazardous Waste Management Firms", and other sources discussed in Chapter 4. EPA
identified lO/l??1 landfill facilities as the initial landfill population in the United States in 1992. Of this
group, 9,882 were Subtitle D non-hazardous landfills and 595 were Subtitle C hazardous landfills. Table
3-1 presents the total number of landfill facilities by state in EPA's mailing list database. EPA solicited
technical information from a sample of this initial population via screener surveys, and the Agency sent
Detailed Technical Questionnaires to a statistical sample of the screener survey respondents. A total of 252
landfill facilities received Detailed Technical Questionnaires and 220 facilities responded with sufficient
technical data to be included in the questionnaire database. Chapter 4, Section 4.3 presents a detailed
discussion of screener survey and Detailed Questionnaire strata.
1 The initial landfill population of 10,477 does not include one pre-test facility which was included as a
screener survey respondent.
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Because EPA only sent Detailed Technical Questionnaires to a statistical sample of the initial industry
population, the Agency scaled up the information provided by questionnaire respondents to represent the
entire Landfills industry. By matching up the screener survey stratum with the Detailed Technical
Questionnaire stratum, EPA calculated a weighting factor for each questionnaire respondent and scaled up
any data provided by the respondent by this factor. Therefore, throughout this chapter, EPA presents
national estimates based on the Detailed Technical Questionnaire respondents' data scaled up by their
individual weighting factors. The Agency based the national estimates presented in the tables in this chapter
on all 220 facilities included in the questionnaire database. Figure 3-1 presents the logic used for the
development of the national estimates. EPA presents the methodology for calculating national estimates
in the Final Statistical Development Document for the Landfills Industry (EPA-821-B-99-007).
3.2.2 Number and Location of Facilities
Many of the landfill facilities presented in Table 3-1 do not generate and/or collect wastewater that is
subject to this regulation. Landfill generated wastewater subject to this regulation includes leachate, gas
collection condensate, truck/equipment washwater, drained free liquids, laboratory-derived wastewater,
floor washings, and contaminated storm water. Non-contaminated storm water, contaminated ground
water, and wastewater from recovering pumping wells are not subject to this regulation.
National estimates of the Landfills industry indicate that only 1,662 of the total population of landfill facilities
collect landfill generated wastewater. EPA limited its survey of the industry to those facilities that collect
landfill generated wastewater, or about 16 percent of the total number of landfills located in the U.S. Table
3-2 presents the Subtitle D and Subtitle C landfills that collect landfill generated wastewater by ownership
type. The national estimates for the industry indicate that approximately 43 percent of these landfills are
municipally-owned facilities, 41 percent are commercially-owned, and 13 percent are non-commercial
captives. Table 3-2 also shows that the majority of non-hazardous landfills are municipally- or
commercially-owned facilities, whereas hazardous landfills are primarily commercially-owned or captive
facilities.
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3.2.2.1 Captive Landfill Facilities
Based on EPA's survey of the Landfills industry for this guideline, the Agency identified over 200 captive
and intra-company facilities that operated landfills. This rule does not apply to captive landfills in most
circumstances. See Chapter 2 for EPA's rationale for not including captive landfills under this guideline.
EPA's survey showed that a maj ority of these landfill s were at industrial facilities that are or will be subj ect
to the following three effluent guidelines: Pulp and Paper (40 CFR Part 430), Centralized Waste Treatment
(proposed 40 CFR Part 437, 64 FR 2280 January 13, 1999), or Organic Chemicals, Plastics and
Synthetic Fibers (40 CFR Part 414). In addition, EPA identified approximately 30 landfills subject to one
or more of the following categories: Nonferrous Metals Manufacturing (40 CFR Part 421), Petroleum
Refining (40 CFR 419), Timber Products Processing (40 CFR Part 429), Iron and Steel Manufacturing
(40 CFR Part 420), Transportation Equipment Cleaning (proposed 40 CFR Part 442, 63 FR 34685 June
25, 1998), and Pesticide Manufacturing (40 CFR Part 455).
Industry supplied data estimates that there are over 118 Pulp and Paper facilities with on-site landfills and
that over 90 percent commingle landfill leachate with process wastewater for treatment on site. The
wastewater flow originating from landfills typically represents less than one percent of the total flow through
the facilities' wastewater treatment plant and, in no case, exceeds three percent of the treated flow.
Approximately six percent of pulp and paper mills send landfill generated wastewater to a POTW along
with process wastewater.
Based on responses to the "1992 Waste Treatment Industry: Landfills Questionnaire", EPA estimates that
there are more than 30 facilities subj ect to the Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF)
guideline with on-site landfills. At OCPSF facilities with on-site landfills, landfill leachate typically
represents less than one percent of the industrial flow at the facility, in no case exceeds six percent of the
flow, and is typically commingled with process wastewater for treatment.
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3.2.3 General Information on Landfill Facilities
EPA estimates that landfill facilities located throughout the U. S. cover approximately 726,000 acres of land
area, 20 percent of which is actual disposal area (landfill), 3 percent is for wastewater treatment operations,
and 63 percent is undeveloped land. Table 3-3 presents national estimates of the total landfill area covered
by non-hazardous and hazardous landfill facilities. National estimates indicate that, as of 1992, hazardous
facilities had, on average, used less of their total facility area for waste disposal, only about 5 percent, than
non-hazardous facilities, which, on average, had used approximately 30 percent of their total facility area
for waste disposal. However, since there are far more non-hazardous landfills in the U.S. than hazardous
landfills, Subtitle D landfills have more future capacity than Subtitle C landfills (see Section 3.2.4). Table
3-4 presents facility land area ranges for non-hazardous and hazardous facilities, as well as totals for the
industry. These frequency distributions show that a typical facility is 100 to 1,000 acres in size, and the
actual landfill covers between 10 and 100 acres of that area. As of 1992, the majority of non-hazardous
and hazardous landfill facilities had from 10 acres to 1,000 acres of undeveloped land available; larger
facilities had as much as 1,000 to 10,000 acres of undeveloped land.
Landfills are made up of individual cells which may be dedicated to one type of waste or may accept many
different types of waste. When a landfill cell reaches capacity volume, it is closed and is referred to as an
"inactive" cell. "Active" cells are landfill cells that are not at capacity and continue to accept waste. Table
3-5 presents national estimates of the number of landfill cells, both active and inactive, at non-hazardous
and hazardous landfills. National estimates of landfill facilities in the U. S. indicate that the average number
of cells in a landfill in 1992 was approximately six. The national average of active cells in 1992 was 2.75,
and the national average of inactive cells was 6.05. For hazardous facilities, the average number of cells
in 1992 was 7.6, with an average of 4.2 active cells and 8.2 inactive cells. For non-hazardous facilities,
the average number of cells in 1992 was 5.7, with an average of 2.5 active cells and 5.4 inactive cells.
EPA's survey indicated that there were fewer active landfills in the U. S. than inactive, or closed landfills.
As discussed in Section 3.2, a large number of landfills, especially facilities serving small populations, have
closed rather than incur the significant expense of complying with RCRA requirements.
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The number and type of customers helps to define the size of a landfill. Table 3-6 presents the national
estimates of the household and non-household population served by landfills that collect landfill generated
wastewater. The total population served by the Landfills industry is 46.3 million household and 5.2 million
non-household customers. Non-hazardous landfills serve 99 percent of these customers. Hazardous
landfills account for only 307,000 household customers and 170,000 non-household customers. Table 3-7
presents the frequency distributions of the number of household and non-household customers for the non-
hazardous and hazardous subcategories as well as for both subcategories combined. Most non-hazardous
facilities serve between 100 and 1,000 non-household customers and 10,000 to 100,000 household
customers. EPA's survey indicates that hazardous facilities serve between zero and 10,000 non-household
customers, but serve very few household customers.
3.2.4 Waste Receipts and Types
Wastes received by landfills in the United States vary from municipal solid waste to highly toxic materials.
Table 3-8 presents the national estimates of the types of waste received at landfills and the percentage each
waste represents of the total waste received during the following three periods: pre-1980,1980-1985, and
1986-1992. Sixty-one percent of the waste landfilled during the pre-1980 time period was municipal solid
waste and industrial wastes, while 17 percent was commercial solid waste and construction and demolition
debris. Similar types of waste were disposed in landfills after 1980; however, the percentage of municipal
solid waste and industrial waste decreased, and the amount of commercial solid waste, incinerator residues,
PCB/TSC A wastes, and asbestos-containing wastes increased. The disposal in landfills of "other" waste
types (such as contaminated soils, auto shredder scrap, and tires) also increased after 1980.
Table 3-9 presents the national estimates of wastes received by the Landfills industry in 1992 by regulatory
classification. These data indicate that landfills contained approximately 6.1 billion tons of waste in 1992,
and project a future capacity of 8.3 billion tons. However, the estimated future capacity of Subtitle D
landfills is much larger than the future capacity of Subtitle C landfills. On average, Subtitle D landfills
represent over 97 percent of the future capacity of U.S. landfills.
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Table 3-10 presents the national estimates of the annual tonnage of waste accepted by landfills from 1988
through 1992. In 1988, the annual tonnage of waste accepted by Subtitle C and Subtitle D landfills was
221 million tons and, by 1992, the amount of waste accepted annually increased to 315 million tons. The
annual tonnage of waste accepted by the entire landfill industry increased 20 percent from 1989 to 1990
and 14 percent from 1990 to 1991. However, when considering Subtitle C landfills alone, EPA's survey
found that hazardous landfills experienced a much larger increase in the amount of waste disposed. In
1990, the amount of waste disposed in Subtitle C landfills increased 30 percent from 1989 and, in 1991,
the amount of hazardous waste disposed increased 75 percent from 1990. Over the three year period from
1989 to 1991, the annual tonnage of waste landfilled in Subtitle C landfills increased 127 percent.
Conversely, the annual tonnage of waste accepted by Subtitle D landfills increased 18 percent from 1989
to 1990 and then increased by only 4 percent from 1990 to 1991. Over the same three year period, from
1989 to 1991, the annual tonnage of waste landfilled in Subtitle D landfills increased by only 23 percent.
The greater increase in annual waste deposited in Subtitle C landfills may be the result of more stringent
RCRA regulations and stricter waste acceptance criteria (Subtitle C hazardous waste is restricted from
being disposed in Subtitle D landfills).
3.2.5 Sources of Wastewater
As noted earlier, a number of landfill operations generate wastewater. In general, the types of wastewater
generated by activities include leachate, landfill gas condensate, truck/equipment washwater, drained free
liquids, laboratory-derived wastewater, floor washings, storm water, contaminated ground water, and
wastewater from recovering pumping wells. Table 3-11 presents the national estimates of the number of
landfills that generate each type of wastewater and the minimum, maximum, and median flows. Each of
these wastewater sources are discussed below.
3.2.5.1 Landfill Leachate
Landfill leachate is liquid that has passed through or emerged from solid waste and contains soluble,
suspended, or miscible materials removed from such waste. Over time, the potential for certain pollutants
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to move into the wider environment increases. As water passes through the landfill, it may "leach"
pollutants from the disposed waste, moving them deeper into the soil. This presents a potential hazard to
public health and the environment through ground water contamination and other means. One measure
used to prevent the movement of toxic and hazardous waste constituents from a landfill is a landfill liner
operated in conjunction with a leachate collection system. Leachate is typically collected from a liner
system placed at the bottom of the landfill. Leachate also may be collected through the use of slurry walls,
trenches, or other containment systems. The leachate generated varies from site to site, based on a number
of factors including the types of waste accepted, operating practices (including shedding, daily cover and
capping), the depth of fill, compaction of wastes, annual precipitation, and landfill age. Based on EPA's
survey of the industry, a total of 1,989 landfills generate leachate at flows ranging from one gallon per day
to 533,000 gallons per day, with a median daily flow of approximately 5,620 gallons. Landfill leachate is
subject to this regulation.
3.2.5.2 Landfill Gas Condensate
Landfill gas condensate is a liquid that has condensed in the landfill gas collection system during the
extraction of gas from within the landfill. Gases such as methane and carbon dioxide are generated due to
microbial activity within the landfill and must be removed to avoid hazardous, explosive conditions. In the
gas collection systems, gases containing high concentrations of water vapor condense in traps staged
throughout the gas collection network. The gas condensate contains volatile compounds and accounts for
a relatively small percentage of flow from a landfill. The national estimates presented on Table 3-11 report
a total of 158 landfills that generate landfill gas condensate at daily flows ranging from 3 gallons to 11,700
gallons. The median flow of landfill gas condensate for the Landfills industry is approximately 343 gallons
per day. Landfill gas condensate is subject to the landfills effluent limitations guidelines.
3.2.5.3 Drained Free Liquids
Drained free liquids are aqueous wastes drained from waste containers (e.g., drums, trucks, etc.) or
wastewater resulting from waste stabilization prior to landfilling. Landfills that accept containerized waste
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may generate this type of wastewater. Wastewater generated from these waste processing activities is
collected and usually combined with other landfill generated wastewater for treatment at the wastewater
treatment plant. National estimates presented on Table 3-11 identify 33 landfills that generate drained free
liquids at a median daily flow of 253 gallons. Daily flows range from a minimum of one gallon per day to
a maximum of 82,000 gallons per day. Drained free liquids are subject to the landfills effluent limitations
guidelines.
3.2.5.4 Truck and Equipment Washwater
Truck and equipment washwater is generated during either truck or equipment washes at landfills. During
routine maintenance or repair operations, trucks and/or equipment used within the landfill (e.g., loaders,
compactors, or dump trucks) are washed, and the resultant wastewater is collected for treatment. In
addition, it is common practice for many facilities to wash the wheels, body, and undercarriage of trucks
used to deliver the waste to the open landfill face upon leaving the landfill. On-site wastewater treatment
equipment and storage tanks also are periodically cleaned. It is estimated that 416 landfills generate truck
and equipment washwater at a median flow of 118 gallons per day and at daily flows ranging from 5 gallons
per day to 15,000 gallons per day.
Floor washings are also generated during routine cleaning and maintenance of landfill facilities. National
estimates presented on Table 3-11 indicate there are 70 landfills that generate and collect floor washings
at flows ranging from 10 gallons per day to 5,450 gallons per day. The median flow of floor washings for
the Landfills industry is approximately 743 gallons per day. Both truck and equipment washwater and floor
washings are subject to this rule.
3.2.5.5 Laboratory-Derived Wastewater
Laboratory-derived wastewater is generated from on-site laboratories that characterize incoming waste
streams and monitor on-site treatment performance. This source of wastewater is minimal and is usually
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combined with leachate and other wastewater prior to treatment at the wastewater treatment plant.
Laboratory-derived wastewater is subject to the landfills effluent limitations guidelines.
3.2.5.6 Storm Water
There are two types of storm water, contaminated and non-contaminated. Contaminated storm water is
storm water which comes in direct contact with landfill wastes, the waste handling and treatment areas, or
wastewater that is subject to the limitations and standards. Some specific areas of a landfill that may
produce contaminated storm water include (but are not limited to) the following: the open face of an active
landfill with exposed waste (no cover added), the areas around wastewater treatment operations, trucks,
equipment or machinery that has been in direct contact with the waste, and waste dumping areas. Non-
contaminated (non-contact) storm water is storm water that does not come in direct contact with landfill
wastes, the waste handling and treatment areas, or wastewater that is subject to the limitations and
standards. Non-contaminated storm water includes storm water which flows off the cap, cover,
intermediate cover, daily cover, and/or final cover of the landfill. National estimates indicate that there are
1,135 landfills that generate storm water at flows ranging from 10 gallons per day to 2 million gallons per
day, with a median daily flow of approximately 26,800 gallons. Storm water that does not come into
contact with the wastes would not be subject to the limitations and standards, as discussed in Chapter 2
of this document.
3.2.5.7 Contaminated Ground Water
Contaminated ground water is water below the land surface in the zone of saturation that has been
contaminated by landfill leachate. Contamination of ground water may occur at landfills without liners or
at facilities that have released contaminants from a liner system into the surrounding ground water. Ground
water also can infiltrate the landfill or the leachate collection system if the water table is high enough to
penetrate the landfill area. EPA identified approximately 163 landfills that generate contaminated ground
water. Daily flows ranged from 6 gallons per day to 987,000 gallons per day, with a median daily flow of
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approximately 12,800 gallons. EPA excluded contaminated ground water from regulation under this
guideline as discussed in Chapter 2 of this document.
3.2.5.8 Recovering Pumping Wells
In addition to the contaminated ground water generated during ground water pumping operations, there
are various ancillary operations that also generate a wastewater stream. These operations include well
construction and development, well maintenance, and well sampling (i.e. purge water). This wastewater
will have very similar characteristics to the contaminated ground water. EPA's survey of the Landfills
industry identified 50 landfills that generate wastewater from recovering pumping wells. Daily flows range
from a minimum of 0.3 gallons to a maximum 80,200 gallons and a median daily flow of 136 gallons. EPA
excluded wastewater recovered from pump wells from regulation under this guideline as discussed in
Chapter 2 of this document.
3.2.6 Leachate Collection Systems
Most facilities subject to the landfills effluent guidelines generate and collect landfill leachate. To prevent
waste material, products of waste decomposition, and free moisture from traveling beyond the limits of the
disposal site, landfill facilities utilize some type of leachate collection system. The leachate collection system
also reduces the depth of leachate buildup or level of saturation over the liner.
The leachate collection system usually contains several individual components. Two main leachate
collection systems may be necessary, an underdrain system and a peripheral system. The underdrain
system is constructed prior to landfilling and consists of a drainage system that removes the leachate from
the base of the fill. The peripheral system can be installed after landfilling has occurred and, as such, is
commonly used as a remedial method. The underdrain system includes a drainage layer of high
permeability granular material, drainage tiles to collect the diverted flow laterally, and a low permeability
liner underlying the system to retard the leachate that percolates vertically through the unsaturated zone of
refuse. Where the leachate meets the low permeability layer, saturated depths of leachate develop and
hydraulic gradients govern the leachate flow within the drainage layer (see reference 8).
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There are several different types of leachate collection systems employed by the Landfills industry. Table
3-12 presents the different types of leachate collection systems and the national estimates of the number
of landfills which employ each system. A simple gravity flow drain field is the most basic and commonly
used type of collection system, employed by 50 percent of the industry. According to EPA's 1992 survey,
compound leachate collection systems consisting of a liner system and collection pipes are used by 20
percent of the industry. French drains, which are gravel channels used to facilitate leachate drainage, are
used by 15 percent of the landfills in the U.S. Other types of leachate collect on systems utilized by 10
percent of the Landfills industry include collection sumps and risers, combined gas/leachate extraction wells,
perforated toe drains to pump stations, and gravity flow in pipes to a holding pond, basin, or pump station
to storage tanks.
3.2.7 Pretreatment Methods
Several types of waste accepted by landfills for disposal may require some type of pretreatment. Wastes
that may require pretreatment include free liquids, containerized waste, and bulk wastes. Free liquids may
be drained, removed, or stabilized. Containerized waste and bulk wastes may be shredded, stabilized, or
solidified. Table 3-13 presents the types of pretreatment methods currently in use by the Landfills industry
and national estimates of the number of landfills that pretreat these wastes.
Approximately 75 percent of non-hazardous landfills do not accept free liquids and, of those that do, 20
percent do not pretreat the liquids before treatment at an on-site wastewater treatment facility or treatment
off site. In comparison, approximately 65 percent of hazardous landfills accept free liquids and pretreat
by stabilizing, draining, or removing the liquid. Forty percent of non-hazardous landfills accept
containerized waste, compared to almost 75 percent of hazardous landfills. The most common type of
pretreatment for containerized waste is solidification followed by stabilization. Most landfills accept bulk
wastes, although many facilities do not pretreat this type of waste. Bulk wastes are usually treated by
stabilization or solidification and stabilization. Other types of pretreatment for bulk wastes include
compaction, chemical treatment, flocculation, macro/microencapsulation, and recycling.
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3.2.8 Baseline Treatment
Many landfills in the United States currently have wastewater treatment systems in place. The most
common treatment system used to treat landfill wastewater is biological treatment. However, chemical
precipitation and combinations of biological treatment, chemical precipitation, equalization, and filtration
also are used widely. Table 3-14 presents the types of treatment and the national estimates of the number
of landfills in the industry that employ each type of wastewater treatment. As expected, indirect and zero
dischargers often do not employ on-site treatment because they either ship their wastewater off site or use
alternate disposal methods such as deep well injection, incineration, evaporation, land application, or
recirculation. Chapter 8 presents a detailed discussion of treatment technology and performance.
EPA's survey of the Landfills industry solicited wastewater treatment facility operating information from
non-hazardous and hazardous landfills. Table 3-15 presents the national estimates of the number of landfill
facilities that operate wastewater treatment systems between 1 and 24 hours per day. Direct and zero or
alternative discharge facilities tend to operate treatment systems continuously, whereas many indirect
discharge facilities operate less than 24 hours per day. Table 3-16 presents the average daily hours of
operation of a typical on-site wastewater treatment facility. Table 3-17 presents the national estimates of
the number of landfill facilities that operate wastewater treatment systems between 1 and 7 days per week.
Again, direct and zero or alternative discharge facilities commonly operate their treatment systems
continuously, whereas indirect dischargers do not. Table 3-18 presents the average number of days per
week a typical wastewater treatment facility is in operation.
3.2.9 Discharge Types
EPA's Detailed Technical Questionnaire identified landfills that discharged wastewater directly to a surface
water, indirectly to POTWs, and others that disposed of their landfill wastewater through zero or alternative
discharge. Direct discharge facilities are those that discharge their wastewater directly to a receiving stream
or body of water. Indirect discharging facilities discharge their wastewater indirectly to a POTW. Zero
or alternative discharge facilities use treatment and disposal practices that result in no discharge of
3-22
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wastewater to surface waters. Zero or alternative disposal options for landfill generated wastewater include
off-site treatment at another landfill wastewater treatment system or a Centralized Waste Treatment facility,
deep well injection, incineration, evaporation, land application, solidification, and recirculation.
Table 3-19 presents the national estimates of the number of landfill facilities grouped by discharge type.
These estimates show that the maj ority of non-hazardous facilities responding to the survey were indirect
dischargers, whereas the majority of hazardous facilities were zero dischargers. Although EPA identified
hazardous landfills discharging directly to surface waters, none of these facilities are subject to the landfills
effluent limitations guidelines.
3-23
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Table 3-1: Number of Landfills per U.S. State
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
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
Puerto Rico
Guam
Total
Subtitle D
Landfills
238
201
90
134
630
216
125
8
91
277
15
112
182
101
118
118
121
73
291
50
722
762
257
97
128
257
41
127
58
467
121
565
244
85
119
189
231
41
12
127
193
112
601
92
73
440
72
57
183
218
0
0
9,882
Subtitle C
Landfills
38
1
2
3
16
12
22
14
9
17
1
6
14
29
13
8
33
17
2
5
1
9
4
3
7
1
8
3
0
8
7
10
39
1
24
7
10
22
0
9
0
9
70
7
0
8
9
5
3
45
3
1
595
Total
Landfills
276
202
92
137
646
228
147
22
100
294
16
118
196
130
131
126
154
90
293
55
723
771
261
100
135
258
49
130
58
475
128
575
283
86
143
196
241
63
12
136
193
121
671
99
73
448
81
62
186
263
3
1
10,477
3-24
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Table 3-2: Ownership Status of Landfill Facilities
Ownership Status
Commercial
Non-Commercial (intra-company)
Non-Commercial (captive)
Municipal
Federal Government
Government (other than Federal or
Municipal)
Indian Tribal Interest
Other
Total
Number of Landfill Facilities
Subtitle D
Non-Hazardous
Sub category
506
5
121
708
4
0
0
1
1,345
Subtitle C
Hazardous
Sub category
171
48
94
2
2
0
0
0
317
Industry Total
677
53
215
710
6
0
0
1
1,662
3-25
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Table 3-3: Total Landfill Facility Area
Facility Land Type
Total Facility Area
Wastewater Treatment Area
Waste Disposal Area (landfill)
Undeveloped Land
Landfill Facility Area (acres)
Subtitle D
Non-Hazardous
Sub category
416,733
9,424
119,700
254,610
Subtitle C
Hazardous
Sub category
309,194
10,147
16,552
207,085
Industry Total
725,927
19,571
136,323
459,811
3-26
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Table 3-4: Landfill Facility Land Area Ranges
Sub category
All Facilities
Land Area Range
(acres)
0
>0-1
>1-10
>10-100
>100-1,000
>1,000-10,000
Total
Subtitle C
Hazardous
Subtitle D
Non-Hazardous
0
>0-1
>1-10
>10-100
>100-1,000
>1,000-10,000
Total
0
>0-1
>1-10
>10-100
>100-1,000
>1,000-10,000
Total
Number of Landfill Facilities
Total Facility
Area
0
0
9
490
1,044
119
1,662
0
0
2
95
136
84
317
0
0
7
395
909
34
1,345
Wastewater
Treatment
Area
747
320
437
136
22
0
1,662
38
128
70
65
15
0
316
708
191
366
72
7
0
1,344
Waste
Disposal
Area (landfill)
28
16
126
1,128
362
0
1,660
5
14
47
199
52
0
317
23
2
79
930
310
0
1,344
Undeveloped
Land
110
2
69
561
745
85
1,662
49
0
2
99
106
60
316
61
2
67
551
638
25
1,344
3-27
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Table 3-5: Number of Landfill Cells
Sub category
All Facilities
Subtitle C
Hazardous
Subtitle D
Non-Hazardous
Type of Landfill Cell
Total cells
Active cells
Inactive cells
Total cells
Active cells
Inactive cells
Total cells
Active cells
Inactive cells
Number of Cells
Estimated Mean
6.12
2.75
6.05
7.64
4.23
8.24
5.68
2.48
5.41
Estimated Total
13,299
4,608
8,690
3,776
1,112
2,663
9,523
3,496
6,027
3-28
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Table 3-6: Household and Non-Household Population Served
Population Served
Non-Household
Household
Number of Customers
Subtitle D
Non-Hazardous
Sub category
5,043,542
46,007,775
Subtitle C
Hazardous
Sub category
170,420
307,243
Industry Total
5,213,962
46,315,018
3-29
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Table 3-7: Household vs. Non-Household Customers
Number of Non-Household Customers
0
1
>1-10
>10-100
>100-1,000
>1,000-10,000
>10,000-100,000
>100,000-1,00,000
Total
Number of Household Customers
0
1
>1-10
>10-100
>100-1,000
>1,000-10,000
>10,000-100,000
>100,000-1,00,000
Total
Number of Landfill Facilities
Subtitle D
Non-Hazardous
Sub category
76
83
33
202
544
351
55
2
1,346
180
0
55
29
42
195
742
102
1,345
Subtitle C
Hazardous
Sub category
123
40
12
4
87
51
0
0
317
313
0
0
0
0
2
0
2
317
Industry Total
205
124
45
203
628
400
54
2
1,661
506
0
55
28
42
195
733
103
1,662
3-30
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Table 3-8: Wastes Received by Landfills in the United States
Waste Type
Municipal Solid Waste
Household Hazardous Waste
Yard Waste
Commercial Solid Waste
Institutional Wastes
Industrial Wastes
Agricultural Waste
Pesticides
PCB, TSCA Wastes
Asbestos-Containing Waste
Radioactive Waste
Medical or Pathogenic Waste
Superfund Clean-Up Wastes
Mining Wastes
Incinerator Residues
Fly Ash, Not Incinerator Waste
Construction/Demolition Debris
Sewage Sludge
Dioxin Waste
Other Sludge
Other Waste Types
Industry Total
Mean % for Time
Period Pre-1980
38.3
0.217
4.76
8.56
1.36
22.8
0.340
0.033
0.192
0.905
0.019
0.255
0.000
0.519
1.01
4.49
8.40
1.81
0.000
4.89
1.23
100.09
Mean % for Time
Period 1980-85
33.4
0.218
4.39
9.92
1.43
19.6
0.297
0.009
1.12
3.73
0.002
0.182
0.021
0.47
1.43
5.82
5.91
3.15
0.039
4.90
4.49
100.528
Mean % for
Time Period
1986-92
33.9
0.215
3.76
9.94
2.14
17.4
0.284
0.321
0.980
3.42
0.001
0.123
0.014
0.180
3.14
6.30
7.95
2.88
0.024
2.91
5.25
101.132
3-31
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Table 3-9: Total Volume of Waste Received by Landfills in 1992 by Regulatory Classification
Time Frame
Current
Future
Regulatory Class
Pre 1980
RCRA Subtitle C
RCRA Subtitle D
TSCA
NRC
Local Regulation
CERCLA
Other Regulation
Total Volume Landfilled
Pre 1980
RCRA Subtitle C
RCRA Subtitle D
TSCA
NRC
Local Regulation
CERCLA
Other Regulation
Total Volume Landfilled
All Facilities
Estimated
Total
Number
Landfills
561
333
906
108
461
4
560
2,146
86
201
884
34
2
293
50
501
1,706
Total Volume
Landfilled
(tons)
954,273,421
159,252,888
1,501,319,521
53,167,884
2,365,983,720
10,507,627
1,018,656,724
6,063,161,789
Future Capacity
(tons)
101,032,485
66,313,422
6,056,763,187
11,202,929
300,860
962,479,373
4,297,618
1,126,823,595
8,329,213,474
Subtitle C Hazardous Subcategory
Estimated
Total
Number
Landfills
190
323
115
102
57
2
114
491
193
33
28
57
50
127
266
Total Volume
Landfilled
(tons)
155,418,921
158,994,443
249,656,514
52,654,468
6,374,393
72,587
36,250,349
659,421,679
Future Capacity
(tons)
65,192,737
96,321,683
10,897,045
4,710,196
4,297,618
30,749,439
212,168,721
Subtitle D Non-Hazardous
Subcategory
Estimated
Total
Number
Landfills
370
10
791
6
404
2
446
1,655
86
8
851
6
2
236
374
1,441
Total Volume
Landfilled
(tons)
798,854,500
258,445
1,251,663,007
513,416
2,359,609,326
10,435,040
982,406,374
5,403,740,110
Future Capacity
(tons)
101,032,485
1,120,685
5,960,441,504
305,884
300,860
957,769,177
1,096,074,156
8,117,044,753
OJ
to
-------
Table 3-10: Annual Tonnage of Waste Accepted by Landfills
Year
1988
1989
1990
1991
1992
Annual Tonnage of Waste (tons)
Subtitle D
Non-Hazardous
Sub category
185,184,608
196,377,576
232,535,432
241,454,300
252,101,069
Subtitle C
Hazardous
Sub category
36,305,235
28,867,681
37,413,692
65,402,768
63,022,850
Industry Total
221,489,843
225,245,257
269,949,125
306,857,068
315,123,919
3-33
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Table 3-11: Wastewater Flows Generated by Individual Landfills
Type of Wastewater Generated
Floor washing
Landfill leachate
Contaminated ground water
Storm water run-off
Landfill gas condensate
Recovering pumping wells
Truck/equipment washwater
Drained free liquids
Other
Total
Number
of
Landfills
70
1,989
163
1,135
158
50
416
33
2
4,016
Minimum
Average Flow
(gal/day)
10
1
6
10
3
0.3
5
1
0
Maximum
Average Flow
(gal/day)
5,450
533,000
987,000
2,067,000
11,700
80,200
15,000
82,000
0
Industry
Median
(gal/day)
743
5,620
12,800
26,800
343
136
118
253
0
00
-------
Table 3-12: Type of Leachate Collection Systems Used at Individual Landfills
Type of Leachate
Collection
None
Simple Gravity Flow
Drain Field
French Drain System
Compound Leachate
Collection
Suction Lysimeters
Other
Total
Number of Landfills
Subtitle D
Non-Hazardous
Sub category
46
977
341
416
0.
196
1,976
Subtitle C Hazardous
Sub category
87
266
38
93
2
49
535
Industry Total
132
1,242
379
509
2
246
2,510
3-35
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Table 3-13: Pretreatment Methods in Use at Individual Landfills
Type of Waste
Free Liquids
Containerized
Waste
Bulk Wastes
Pretreatment Method
No Pretreatment
None Accepted
Drained or Removed
Stabilization
Other
Total
No Pretreatment
None Accepted
Shredded
Stabilized
Solidified
Other
Total
No Pretreatment
None Accepted
Baled
Shredded
Stabilized
Solidified
Other
Total
Number of Landfills
Subtitle D Non-
Hazardous
Sub category
324
1,277
51
38
17
1,707
515
1,008
23
6
41
110
1,703
993
414
33
82
15
74
100
1,711
Subtitle C
Hazardous
Sub category
113
283
115
172
84
767
100
180
70
135
138
80
703
216
61
2
49
201
126
38
693
Industry Total
437
1,560
166
211
101
2,475
616
1,188
94
141
179
190
2,408
1,209
475
35
131
216
200
138
2,404
3-36
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Table 3-14: Types of Wastewater Treatment Employed by the Landfills Industry
Type of Treatment
No treatment
Biological treatment
Chemical precipitation
Chemical precipitation and biological treatme
Filtration and biological treatment
Equalization and biological treatment
Equalization, biological treatment, and filtrati
Equalization, chemical precipitation, and
biological treatment
Equalization, chemical precipitation, biologic
treatment, and filtration
Number of Landfills
Direct
Discharge
81
119
63
nt 32
45
65
Dn 37
26
d 26
Indirect
Discharge
691
37
45
10
4
28
4
8
2
Zero
Discharge
468
19
8
0
5
7
5
0
0
3-37
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Table 3-15: Wastewater Treatment Facility Hours of Operation per Day
Hours of
Operation
(hours/day)
0
1-23
24
Total
Subtitle D
Non-Hazardous
Sub category
Direct
0
11
161
172
Indirect
0
295
508
803
Zero
0
40
330
370
Subtitle C
Hazardous
Sub category
Direct
0
11
122
133
Indirect
0
4
20
24
Zero
0
6
153
159
Industry Total
Direct
0
23
283
306
Indirect
0
275
552
827
Zero
0
42
488
530
00
oo
-------
Table 3-16: Wastewater Treatment Facility Average Hours of Operation per Day
Sub category
All Facilities
Subtitle C
Hazardous
Subtitle D
Non-Hazardous
Average Hours of Operation/Day
Direct Discharge
22.80
22.78
22.83
Indirect Discharge
19.16
22.18
18.52
Zero Discharge
22.55
23.46
21.89
3-39
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Table 3-17: Wastewater Treatment Facility Days of Operation per Week
Days of
Operation
(days/week)
0
1-6
7
Total
Subtitle D
Non-Hazardous
Sub category
Direct
0
7
165
172
Indirect
0
225
578
803
Zero
0
40
330
370
Subtitle C
Hazardous
Sub category
Direct
0
19
115
134
Indirect
0
2
22
24
Zero
0
6
153
159
Industry Total
Direct
0
30
275
305
Indirect
0
203
624
827
Zero
0
42
488
530
OJ
o
-------
Table 3-18: Wastewater Treatment Facility Average Days of Operation per Week
Sub category
All Facilities
Subtitle C
Hazardous
Subtitle D
Non-Hazardous
Average Days of Operation/Week
Direct Discharge
6.72
6.56
6.94
Indirect Discharge
6.47
6.83
6.39
Zero Discharge
6.81
6.77
6.84
3-41
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Table 3-19: Total Number of Facilities by Discharge Type
Sub category
All Facilities
Subtitle C
Hazardous
Subtitle D
Non-Hazardous
Discharge Type
Direct
306
134
172
Indirect
827
24
803
Zero
529
159
370
Total
1,662
317
1,345
3-42
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Figure 3-1: Development of National Estimates for the Landfills Industry
Collected data on landfill facilities from various sources and
developed initial landfill population
10,477 landfill facilities identified
9,882 Subtitle D non-hazardous landill facilities
595 Subtitle C hazardous landfill facilities
4,996 landfill facilities were selected to
receive screener surveys
3,628 landfill facilities responded to the screener
survey.
Of the 3,628 respondents, 859 were considered
in-scope (i.e., generating some type of landfill
generated wastewater)
252 landfill facilities were selected to receive
Detailed Questionnaire
220 landfill facilities responded to the Detailed
Questionnaire with suffient technical detail to be
included in database
151 Subtitle D non-hazardous landfill facilities
16 Subtitle C hazardous landfill facilities
53 facilities are excluded from regulation
27 landfill facilities were
selected to complete a
Detailed Monitoring
Questionnaire
National estimates were calculated based upon assigning a
weighting factor for each facility in the Detailed Questionnaire
database
1,662 total landfill facilities which generate in-scope wastewater
based on national estimates:
1,345 Subtitle D non-hazardous landill facilities
317 Subtitle C hazardous landfill facilities
3-43
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4.0 DATA COLLECTION ACTIVITIES
4.1 Introduction
As part of the development of the Landfills effluent guideline, EPA collected data from a variety of different
sources. These sources included existing data from previous EPA and other governmental data collection
efforts, industry-provided information, new data collected from questionnaire surveys, and field sampling
data. This chapter discusses each of these data sources, as well as EPA's quality assurance/quality control
(QA/QC) efforts and data editing procedures. Chapters 5 through 11 present summaries and analyses of
the data collected by EPA.
4.2 Preliminary Data Summary
EPA's initial effort to develop effluent limitations guidelines and pretreatment standards for the waste
treatment industry began in 1986. EPA conducted a study of the hazardous waste treatment industry in
which it determined the scope of the industry, the operations performed, the type of wastewater generated,
and types of discharges. For this study, EPA looked at a hazardous waste treatment industry that included
landfills with leachate collection and treatment facilities, incinerators with wet scrubbers, and aqueous
hazardous waste treatment facilities. This study characterized the wastewater generated by facilities in the
industry and the wastewater treatment technologies used to treat this wastewater. In addition, the study
included industry profiles, the cost of wastewater control and treatment, and environmental assessments.
EPA published the results of this study in a report entitled "Preliminary Data Summary for the Hazardous
Waste Treatment Industry" (EPA 440/1-89-100), in September, 1989.
The Agency used data from the following sources in developing the preliminary data summary:
• EPA Office of Research and Development databases (includes field sampling data from 13
hazardous waste landfills in 1985).
• State Agencies (includes a Wisconsin sampling program of 20 municipal landfills in 1983).
4-1
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EPA Office of Emergency and Remedial Response Contract Laboratory Program (CLP)
Statistical Database, "Most Commonly Occurring Analytes in 56 Leachate Samples."
1980-83 data.
National Enforcement Investigations Center (NEIC) sampling program conducted for the
Hazardous Waste Groundwater Task Force during 1985.
EPA sampling at 6 landfill facilities (1986-1987).
Subtitle D leachate data for miscellaneous Subtitle D landfills, compiled by the EPA Office
of Solid Waste.
The EPA Preliminary Data Summary identified 911 landfills that generate leachate. Of these, 173
di scharged their leachate directly to surface waters, while 3 5 5 di scharged indirectly through publicly owned
treatment works (POTWs). The remaining 383 used other methods of leachate disposal. The most
common "other" disposal method was contract hauling to a commercial aqueous waste treatment facility.
However, some facilities land-applied their leachate (spraying of the leachate over the landfill) or injected
it into a deep well for disposal.
The key findings of the EPA Preliminary Data Summary included:
Some leachates were found to contain high concentrations (e.g., over 100,000 micrograms
per liter (|ig/l)) of toxic organic compounds.
Raw leachates were found to contain high concentrations of BOD5, COD, and TOC.
Leachate flow rates varied widely due to climatic and geological conditions and landfill size.
An average landfill was estimated to have a leachate generation rate of approximately
30,000 gallons per day (gpd).
As a result of Resource Conservation and Recovery Act (RCRA) regulations, the number
of leachate collection systems used at landfills was expected to increase.
RCRA regulations also would cause solid waste generators to increase their use of
commercial landfill facilities.
4-2
-------
EPA found that a wide range of biological and physical/chemical treatment technologies were in use by
landfills, capable of removing high percentages of conventional, nonconventional, and toxic pollutants.
Advanced treatment technologies identified in this study include air stripping, ammonia stripping, activated
carbon, and lime precipitation.
After a thorough analysis of the landfill data presented in the Preliminary Data Summary, EPA identified
the need to develop an effluent guidelines regulation for the Landfills industry in order to set national
guidelines and standards. EPA based its decision to develop effluent limitations guidelines on the
Preliminary Data Summary's assessment of the current and future trends in the Landfills industry, its analysis
of the concentrations of pollutants in the raw leachate, and the study's discussion on the treatment and
control technologies available for effective pollution reduction in landfill leachate.
4.3 Clean Water Act (CWA) Section 308 Questionnaires
A major source of information and data used in developing effluent limitations guidelines and standards
consisted of industry responses to detailed technical and economic questionnaires, and the subsequent
detailed monitoring questionnaires, distributed by EPA under the authority of Section 308 of the CWA.
These questionnaires requested information on each facility's industrial operations, ownership status, solid
wastes disposed, treatment processes employed, and wastewater discharge characteristics. EPA first
developed a database of various types of landfills in the United States using information collected from the
following: 1) State environmental and solid waste departments, 2) other State agencies and contacts, 3)
the National Survey of Hazardous Waste Treatment Storage, Disposal and Recycling Facilities respondent
list, 4) Environmental Ltd.'s 1991 Directory of Industrial and Hazardous Waste Management Firms, 5) the
Resource Conservation and Recovery Act (RCRA) 1992 list of Municipal Landfills, and 6) the Resource
Conservation and Recovery Information System (RCRIS) National Oversight Database. Based upon these
sources, EPA identified 10,477 landfill facilities in the U.S. in 1992. Of this group, 9,882 were Subtitle D
landfills while 595 were Subtitle C landfills.
4-3
-------
EPA entered all of these facilities into a database which served as the initial population for EPA to collect
industry-provided data. EPA's data collection process involved the following three stages:
• Screener Surveys
• Detailed Technical Questionnaires
• Detailed Monitoring Questionnaires
The following sections discuss each of these data collection activities. A more detailed discussion of the
landfills survey population can be found in Appendix A.
4.3.1 Screener Surveys
EPA developed a screener survey to collect data on all of the landfill sites in the U.S. identified by the
sources above.
4.3.1.1 Recipient Selection and Mailing
EPA divided the 10,477 facilities into four strata for the purpose of determining the screener survey
recipients. The Agency defined these strata as the following:
1. Subtitle C facilities.
2. Subtitle D facilities that are known wastewater generators.
3. Subtitle D facilities in states with less than 100 landfills and are not known to be
wastewater generators.
4. Subtitle D facilities in states with more than 100 landfills and are not known to be
wastewater generators.
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The Agency decided that all of the facilities in strata 1,2, and 3 would receive the screener survey, while
only a random sample of the facilities in stratum 4 would receive the survey. Table 4-1 presents the sample
frame, number of facilities sampled, and the number of respondents to receive the screener survey.
Table 4-1: Screener Questionnaire Strata
Screener Stratum
(g)
1
2
3
4
Total
Number in Frame
(Ng)
595
134
892
8,856
10,477
Number Sampled
K)
595
134
892
3,375
4,996
Number of Responses
K)
524
120
722
2,621
3,987
4.3.1.2 Information Collected
Information collected by the screener surveys included the following:
• mailing address.
• landfill type, including types and amount of solid waste disposed and landfill capacity.
• wastewater generation rates as a result of landfill operations, including leachate, gas
condensate, and contaminated ground water.
• regulatory classification and ownership status.
• wastewater discharge status.
• wastewater monitoring practices.
• wastewater treatment technology in use.
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4.3.1.3 Data Entry, Coding, and Analysis
EPA operated a toll-free help line to assist the screener recipients with filling out the 3-page survey. The
Agency responded to several thousand phone calls from facilities over a six week period. The help line
answered questions regarding applicability, EPA policy, and economic and technical details.
EPA reviewed all screener surveys returned to the Agency to verify that each respondent completed the
critical questions in the survey (e.g., wastewater generation and collection, number and types of landfills,
discharge status, and wastewater treatment technology). The screeners were in a bubble-sheet format and
were scanned directly into a computer database. Once entered, EPA checked the database for logical
inconsistencies and contacted facilities to resolve any inconsistencies.
After the QA process, EPA divided the facilities in the database into the following two groups: 1) facilities
that indicated they collected landfill generated wastewater; and 2) those that did not. EPA considered
facilities that did not collect landfill generated wastewater to be out of the scope of this regulation and
therefore did not investigate these facilities any further.
4.3.1.4 Mailout Results
Of the 4,996 screener questionnaires mailed by EPA, 3,628 responded, and of those, EPA determined
that 3,581 were potentially in-scope and complete . The Agency entered these surveys into the screener
database. Of these, EPA identified 859 facilities that generate and collect one or more types of landfill
generated wastewater.
4.3.2 Detailed Technical Questionnaires
Once EPA analyzed the information from the screener surveys in the database, EPA developed a detailed
technical and economic questionnaire to obtain more information from facilities that collect landfill generated
wastewater.
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4.3.2.1 Recipient Selection and Mailing
EPA used the 859 facilities that generated and collected landfill wastewater from the screener database,
plus one pre-test questionnaire facility that was not in the screener database, as the frame for selection of
facilities to be sent a Detailed Questionnaire. EPA divided these facilities into the following eight strata:
1. Commercial private, municipal, or government facilities that have wastewater treatment and
are direct or indirect dischargers.
2. Commercial private, municipal, or government facilities that have wastewater treatment and
are not direct or indirect dischargers.
3. Non-commercial private facilities with wastewater treatment
4. Facilities with no wastewater treatment
5. Commercial facilities that accept PCB wastes
6. Municipal hazardous waste facilities
7. Small businesses with no wastewater treatment
8. Pre-test facilities that were not in the screener population
The Agency decided all facilities in strata 1, 5,6, 7, and 8 would receive the Detailed Questionnaire. EPA
sent the Detailed Questionnaire to a random sample of the facilities in strata 2, 3, and 4.
These selection criteria resulted in a mailing of the Detailed Questionnaire to 252 facilities. Chapter 3,
Section 3.2.1 briefly discusses the population analysis (referred to as national estimates) conducted from
these questionnaire recipients.
4.3.2.2 Information Collected
The Detailed Questionnaire solicited technical and costing information regarding landfill operations at the
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selected facilities. EPA divided the questionnaire into the following four main sections:
Section A - Facility Identification and Operational Information:
1. General facility information, including the following: ownership status, landfill type, the
number of landfills on site, regulatory status, discharge status, when the landfill began
accepting waste, and projected closure date.
2. Landfill operation, including the following: types of waste accepted at the landfill, the
amount of waste accepted, landfill capacity, how the waste was organized in the landfill,
landfill caps, and landfill liners.
3. Wastewater generation from landfill operations, including the following: the types of
wastewater generated and the generation rates, and the ultimate disposal of the wastewater
generated and collected.
Section B - Wastewater Treatment:
1. Description of treatment methods employed by the facility to treat the wastewater identified
in Section A. This description includes a discussion of commingled wastewater,
wastewater treatment technologies, residual waste disposal, and treatment plant capacities.
Section C - Wastewater Monitoring Data:
1. A summary of the monitoring data pertaining to the landfill generated wastewater identified
in Section A that were collected in 1992 by the facility, including the following: minimum,
maximum, averages, number of observations, and sampling and analytical methods.
Section D - Detailed Wastewater Treatment Design Information:
1. Detailed technical design, operation and costing information pertaining to the wastewater
treatment technologies identified in Section B.
4.3.2.3 Data Entry, Coding, and Analysis
EPA operated a toll-free help line to assist the questionnaire recipients with filling out the Detailed
Questionnaire. EPA responded to over one thousand phone calls from facilities over a three-month period.
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While some calls pertained to questions of applicability, most were of a technical nature regarding specific
questions in the questionnaire.
Once EPA received the completed questionnaires, the Agency thoroughly reviewed each one for technical
accuracy and content. After review, the questionnaire was coded for double-key entry into the
questionnaire database. EPA resolved all discrepancies between the two inputted values by referring to
the original questionnaire.
EPA followed several QA/QC procedures when developing the questionnaire database, including a manual
completeness and accuracy check of a random selection of 20 percent of the questionnaires and a database
logic check of each completed questionnaire. These QA/QC procedures helped verify the questionnaires
for completeness, resolve any internal consistencies, and identify outliers in the data. EPA checked all
outliers for accuracy.
4.3.2.4 Mailout Results
Of the 252 recipients, 220 responded with sufficient technical and economic data to be included in the final
EPA Detailed Questionnaire database.
4.4 Detailed Monitoring Questionnaire
In addition to the Detailed Questionnaire, EPA also requested detailed wastewater monitoring information
from 27 facilities included in the Detailed Questionnaire database via a Detailed Monitoring Questionnaire.
4.4.1 Recipient Selection and Mailing
EPA selected facilities to receive Detailed Monitoring Questionnaires based upon their responses to the
Detailed Questionnaire. EPAreviewed each facility's monitoring summary, discharge permit requirements,
and their on-site treatment technologies. From these responses, EPA selected 27 facilities to receive a
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Detailed Monitoring Questionnaire which could provide useful information on technology performance,
pollutant removals, and wastewater characterization.
4.4.2 Information Collected
EPA requested recipients of the Detailed Monitoring Questionnaire to send analytical data (1992,1993,
and 1994 annual data) on daily equalized influent to their wastewater treatment system, as well as effluent
data from the treatment system. The three years of analytical data assisted EPA in calculating the variability
factors (discussed in Chapter 11) used in calculating the industry effluent limits. EPA also requested
analytical data for intermediate waste treatment points for some facilities. In this manner, EPA was able
to obtain performance information across individual treatment units in addition to the entire treatment train.
4.4.3 Data Entry, Coding, and Analysis
EPA conducted a thorough review of each Detailed Monitoring Questionnaire response to ensure that the
data provided was representative of the facility's treatment system. EPA collected data from 24 semi-
continuous and continuous treatment systems and 2 batch treatment systems. The Agency developed a
Detailed Monitoring Questionnaire database which included all monitoring data submitted by the selected
facilities.
4.5 Engineering Site Visits
EPA visited 19 facilities, including one facility outside the U.S. The purpose of these visits was to evaluate
each facility as a potential week-long sampling candidate to collect treatment performance data. EPA
selected these facilities based on the responses to the Detailed Questionnaire and attempted to include
facilities from a broad cross section of the industry. EPA visited landfills of various ownership status
(municipal, commercial, captive), landfills that accept various waste types (construction and demolition, ash,
sludge, industrial, municipal, hazardous), and landfills in different geographic regions of the country.
Facilities selected for engineering site visits employed various types of treatment processes, including the
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following: equalization, chemical and biological treatment, filtration, air stripping, steam stripping, and
membrane separation.
EPA visited each landfill for one day. During the engineering site visit, EPA obtained information on the
following:
• the facility and its operations.
• the wastes accepted for treatment and the facility's acceptance criteria.
• the raw wastewater generated and its sources.
• the wastewater treatment on site.
• the location of potential sampling points.
• the site-specific sampling needs (access to facility and sample points, and required
sampling safety equipment).
Table 4-2 presents a summary of the types of landfill facilities that EPA included in the engineering site
visits.
4.6 Wastewater Characterization Site Visits
While conducting engineering site visits, EPA also collected samples for raw wastewater characterization
at 15 landfills. EPA collected grab samples of untreated wastewater at various types of landfills and
analyzed for constituents in the wastewater including conventionals, metals, organics, pesticides and
herbicides, PCBs, and dioxins and furans. Chapter 6 presents the characterization data obtained by EPA.
Table 4-2 also presents a summary of the type of landfill facilities that EPA included in the characterization
site visits and the number of wastewater characterization samples collected.
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4.7 EPA Week-Long Sampling Program
To collect wastewater treatment performance data, EPA conducted week-long sampling efforts at six
landfills. EPA selected these facilities based on the analysis of the information collected during the
engineering site visits. Table 4-3 presents a summary of the types of landfills sampled and treatment
technologies evaluated.
EPA prepared a detailed sampling plan for each sampling episode. The Agency collected wastewater
samples at influent, intermediate, and effluent sample points throughout the entire on-site wastewater
treatment system. Sampling at five of the facilities consisted of 24-hour composite samples for five
consecutive days. For the sixth facility, EPA took composites of four completed batches over five days.
At all facilities, the Agency collected individual grab samples for oil and grease. Volatile organic grab
samples were composited in the laboratory prior to analysis.
EPA analyzed samples using EPA Office of Water approved analytical methods. The following table
presents the pollutant group and the analytical method used:
Pollutant Group Analytical Method
Conventional and Nonconventionals Standard Methods
Metals EPA 1620
Organics EPA 1624, 1625
Herbicides, Pesticides, PCBs EPA 1656, 1657,1658
Dioxins/Furans EPA 1613
EPA used influent data to characterize raw wastewater for the industry and develop the list of pollutants
of interest (see Chapter 6 for raw wastewater characterization and Chapter 7 for pollutant of interest
selection). The Agency used influent, intermediate, and effluent data to evaluate performance of the
wastewater treatment systems and develop current discharge concentrations, pollutant loadings, and the
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best available treatment (BAT) options for the Landfills industry. EPA used effluent data to calculate long-
term averages for each of the regulatory options.
Table 4-4 presents the facilities included in the engineering site visits, the raw wastewater characterization
sampling effort, and the week-long sampling effort. Note that facilities utilized only for the engineering site
visits do not have sampling episode numbers.
4.8 Other Data Sources
In addition to the original data collected by EPA, the Agency used other data sources to supplement the
industry database. Each of these data sources is discussed below.
4.8.1 Industry Supplied Data
EPA requested the Landfills industry to provide relevant information and data. The Agency received
leachate and ground water characterization and treatability studies from several facilities, including 25
discharge monitoring report (DMR) data packages. EPA used industry-supplied data to characterize the
industry, develop pollutant loadings, and develop effluent limitations.
4.8.2 Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA)/Superfund Amendments and Reauthorization Act (SARA) Ground
Water Data
EPA obtained ground water data from the "CERCLA Site Discharges To POTWs Treatability Manual"
(EPA 540/2-90-007), prepared by the Industrial Technology Division of the EPA Office of Water
Standards and Regulations for the EPA Office of Emergency and Remedial Response. The Agency used
data from this study to supplement the ground water data collected during characterization and week-long
sampling events. The purpose of the CERCLA study was to do the following:
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Identify the variety of compounds and concentration ranges present in ground water at
CERCLA sites.
Collect data on the treatability of compounds achieved by various on-site pretreatment
systems.
Evaluate the impact of CERCLA discharges to a receiving POTW.
For the CERCLA study, a total of eighteen CERCLA facilities were sampled. However, EPA only used
data from facilities that received ground water contaminated as a result of landfilling activities in its analysis
of contaminated ground water at landfill facilities. Based in part on this data and for the reasons discussed
in Chapter 2, EPA decided not to include contaminated ground water as a regulated wastewater under this
guideline. In addition, for the proposal, EPA combined the data from seven CERCLA facilities with EPA
sampling data to help characterize the hazardous subcategory and to develop both the current discharge
concentrations and pollutant loadings for facilities in the hazardous subcategory. However, since EPA did
not include contaminated ground water as a wastewater subject to this guideline, for the final rule, EPA
removed all CERCLA data from the Subtitle C raw wastewater characterization database. The data
presented in subsequent chapters for hazardous wastewater characterization do not include CERCLA data.
4.8.3 POTW Study
The primary source of POTW percent removal data was the "Fate of Priority Pollutants in Publicly Owned
Treatment Works" (EPA 440/1-82-303), commonly referred to as the "50-POTW Study." The 50-
POTW Study presents data on 50 well-operated POTWs with secondary treatment in removing toxic
pollutants. At most of these plants, a minimum of 6 days of 24-hour sampling of influent, effluent, and
sludge streams was completed. Each sample was analyzed for conventional, selected non-conventional,
and priority pollutants. The basic objective of the study was to generate, compile, and report data on the
occurrence and fate of the 129 priority toxic pollutants in 50 POTWs. Preliminary evaluations of the data
were also conducted. The report presents all of the collected data, results of the preliminary evaluations,
and results of the calculations to determine the following: 1) the concentrations of priority pollutants in the
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influent to POTWs, 2) the concentrations of priority pollutants discharged from the POTWs, 3) the
concentrations of priority pollutants in the effluent from intermediate process streams, and 4) the
concentrations of priority pollutants in the POTW sludge streams.
Some of the data collected for evaluating POTW removals in the 50-POTW Study included influent levels
of pollutants that were close to the detection limit. EPA eliminated these values to reduce the possibility
that low POTW removals might simply reflect low influent concentrations instead of being a true measure
of treatment effectiveness. For further discussion on the editing rules EPA applied to the 50-POTW Study
for use in the assessment of POTW removal, see Chapter 7, Section 7.7.1.
4.8.4 National Risk Management Research Laboratory Data
EPA's National Risk Management Research Laboratory (NRMRL) developed a treatability database
(formerly called the Risk Reduction Engineering Laboratory (RREL) database). This computerized
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 augment the POTW database for certain pollutants which
the 50-POTW Study did not evaluate. EPA edited the NRMRL data so that only treatment technologies
representative of typical POTW secondary treatment operations were used. Additional edits applied by
EPA are discussed in detail in Chapter 7, Section 7.7.1.
4.9 QA/QC and Other Data Editing Procedures
This section presents the quality assurance/quality control (QA/QC) procedures and editing rules used to
analyze the different analytical data sets described in the previous sections (e.g., industry supplied data,
Detailed Questionnaire data, Detailed Monitoring Questionnaire data, EPA field sampling, and analytical
data collected by other EPA offices). For a complete discussion of all of the conventions used in calculating
effluent limitations see the "Statistical Support Document for Final Effluent Limitations Guidelines and
Standards for the Landfills Point Source Category" (EPA-821-B-99-007).
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4.9.1 QA/QC Procedures
Each analytical data source received a QA/QC review before being included in the EPA analytical,
Detailed Questionnaire, and Detailed Monitoring Questionnaire databases. The specific QA/QC activities
completed for each analytical data source are discussed below.
4.9.2 Analytical Database Review
EPA's Sample Control Center (SCC) developed and maintained the analytical database, and provided a
number of QA/QC functions. SCC documented the results of the QA/QC procedures in data review
narratives. EPA then performed completeness checks to ensure the completeness of the analytical
database. Both of these QA/QC activities are discussed below. In addition, the following paragraphs
outline the editing procedures and data conventions used to finalize the landfill analytical database, to
characterize each industry subcategory, and to develop current discharge information and pollutant
loadings.
4.9.2.1 Data Review Narratives
The Sample Control Center performed a QA/QC data review and documented its findings in the data
review narrative that accompanied each laboratory data package. The data review narrative identified
missing data and any other data discrepancies encountered during the QA/QC review. EPA then checked
the narratives against the data and sampling episode traffic reports to make sure SCC did not overlook any
data discrepancies.
4.9.2.2 Completeness Checks
EPA performed a data completeness check of the analytical database by cross referencing the list of
pollutants requested for analysis with the list of pollutants the laboratory actually analyzed at each sample
point. To accomplish this, EPA prepared the following:
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• a list of all requested analytical methods and method numbers.
• a list of all pollutants and CAS numbers specified under each requested analytical method.
• a schedule of analyses requested by episode for each sample point.
The purpose of the completeness check was to verify that the laboratory performed all of the analyses
requested and that SCC posted the results to the database in a consistent manner. The completeness
check resulted in identifying the following:
• any pollutant that was scheduled to be analyzed but was not analyzed.
• pollutants that were analyzed but were not scheduled to be analyzed.
• any pollutant for which the expected number of samples analyzed did not agree with the
actual number of samples analyzed.
SCC evaluated and resolved discrepancies by subsequent QA/QC reviews. SCC documented all changes
to data in the landfill analytical database in a status report entitled "Status of the Waste Treatment Industry:
Landfills Database".
4.9.2.3 Trip Blanks and Equipment Blanks
SCC addressed qualifiers assigned to data as a result of trip blank and equipment blank contamination in
the same way that it addressed contamination of lab method blanks, detailed below:
• Sample Results Less than Five Times Blank Results: When the sample result was less than
five times the blank result, there were no means by which to ascertain whether the
presence of the analyte could have attributed to blank contamination. Therefore, the result
was included in the database as non-detect, with a nominal detection limit equal to the
dilution-adjusted instrument detection limit.
• Sample Results Greater than Five Times but Less than Ten Times Blank Results: These
data were of acceptable quality and were used to represent maximum values.
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Sample Results Greater than Ten Times Blank Results or Analyte not Detected in Sample:
The presence of the analyte in the blank did not adversely affect the data in those cases
where the sample results were greater than ten times the associated blank results or when
the analyte was not detected in associated samples. Such data were acceptable without
qualification.
4.9.2.4 Field Duplicates
EPA collected field duplicates during the EPA sampling episodes to help determine the accuracy and
consistency of the sampling techniques employed in the field. In the analytical database, EPA represented
field duplicate results by the letter "D" preceding the sample point number. The Agency combined
duplicate samples that it considered acceptable on a daily basis using the following rules:
If all duplicates were non-detect values, then the aggregate sample was labeled non-detect
(ND), and the value of the aggregate sample was the maximum of the ND values.
If the maximum detected value was greater than the maximum ND value, then the
aggregate sample was labeled NC, and the value of the aggregate sample was the sum of
the non-censored (NC) and ND values divided by the total number of duplicates for that
independent sample.
If the maximum NC value was less than or equal to the maximum ND value, then the
aggregate sample was labeled ND and the value of the aggregate sample was the maximum
of the ND values.
If all duplicates were NC values, then the aggregate sample was labeled NC and the value
of the aggregate sample was the average of the NC values.
In the laboratory, SCC calculated analytical precision by determining the relative percent difference of
paired spiked samples. EPA considered data acceptable if the relative percent difference was within the
laboratory criteria for analytical precision.
EPA considered duplicate relative percent difference values as acceptable if they were within the laboratory
criteria for analytical precision plus or minus 10 percent.
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4.9.2.5 Grab Samples
Most data presented in the analytical database represent composite sample results, but other types of
results exist due to sampling requirements. Most grab sample results were represented by the letters "A",
"B", or "C" following the sample point number in the analytical database for grabs collected on the same
day. EPA collected grab samples of this nature only for oil and grease/hexane extractable material and
EPA included these samples when calculating average concentrations of pollutants. The Agency averaged
grab samples of any kind on a daily basis before using them in data analyses.
4.9.2.6 Non-Detect Data
EPA assigned non-detect data numeric values so that they could be used in the data analyses. In general,
non-detect data can be set either at the method detection limit, at the instrument detection limit, at half of
the method detection limit, or zero. Detection limits can be standardized (as in the method detection limit)
or variable (as in the instrument detection limit or the sample detection limit, which may vary depending on
dilution). The instrument detection limit is the lowest possible detection limit: the instrument cannot detect
the contaminant below this level. In many cases, the method detection limit is significantly higher than the
instrument detection limit.
For the Landfills effluent guideline, EPA defined all non-detect data collected from the EPA sampling
episodes as follows: 1) the value used for non-detect data was represented by the detection limit reported
in the analytical database, and 2) if the detection limit of the non-detect data was greater than the detected
results, the average was calculated using all of the data, but the results were flagged for review on an
individual basis. When flagged results were reviewed as a whole, the high detection limits were found to
be on the same order of magnitude as the detect values; therefore, all flagged data were included in
calculating averages.
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4.9.2.7 Bi-Phasic Samples
In one sampling episode for a captive hazardous landfill at an industrial facility, some samples collected
became bi-phasic. That is, EPA collected aqueous samples, but from the time that EPA collected the
sample to the time EPA analyzed it, the sample formed a solid, organic phase. Therefore, the analyzed
sample consisted of an aqueous portion and an organic portion. For these samples, EPA reported
analytical results for each phase separately. The Agency calculated consolidated results for the bi-phasic
samples by factoring the percent of each phase relative to the total sample volume with the results of each
phase and adding the weighted results together. Pollutants were not always detected in both the aqueous
and organic phases of a bi-phasic sample. In instances where EPA detected a pollutant in one phase and
not in the other phase, the detection limit was set at zero, which removed the non-detect phase from the
equation. When both phases were non-detect, EPA used the lowest of the two detection limits as the
result.
4.9.2.8 Conversion of Weight/Weight Data
In some cases, EPA analyzed wastewater samples collected in the field as solids due to criteria specified
in the analytical method. The Agency reported these results in the database in solids units of ug/kg or ng/kg.
EPA converted these results to ug/L and ng/L, respectively, so that they could be used in data analysis.
The landfill analytical database contained a file called "solids" that contained percent solids values for those
samples associated with a result that were reported on a weight/weight basis. This percent solids value was
necessary to convert results from a weight/weight basis to a weight/volume basis.
The following formula was utilized to convert the "amount" from a weight/weight basis to a weight/volume
basis. This formula assumed a density of 1:
Amount (weight/weight) x [Percent Solids/100] = Amount (weight/volume)
where,
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Amount = The result contained in the "amount" field in the "result" file.
Percent Solids = The percent solids result contained in the "percent" field in the "solids" file.
After conversion, the amount was expressed in weight/volume units as shown below:
Weight/Weight Units
Pg/kg
ng/kg
ug/kg
ug/g
mg/kg
Weight/Volume Units
Pg/L
ng/L
ug/L
ug/mL
mg/L
4.9.2.9 Average Concentration Data
EPA employed all data conventions discussed above when calculating the average concentration of a group
of data. The Agency calculated average concentrations to develop raw waste loads, current discharge
concentrations, and percent removal values. To calculate the average concentration of a pollutant at a
particular sample point, the following hierarchy was used: 1) all non-detect data was set at the detection
limit listed in the database, 2) all weight/weight units were converted to weight/volume units using the
percent solids file, 3) all units were then converted to ug/L, 4) the bi-phasic sample results were combined
into one consolidated result, 5) both duplicate pairs and grab samples were combined using the rules
discussed above, and 6) the long-term average was calculated by adding all results and dividing by the
number of results.
4.9.3 Detailed Questionnaire Database Review
EPAreviewed each Detailed Questionnaire for the following: 1) completeness, 2) internal consistency, and
3) outliers. Outliers refer to data values that are well outside those expected for this industry. For example,
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EPA considered flow rates above 10 million gallons per day to be outliers. In cases such as this, the
QA/QC reviewer would verify the accuracy and correctness of the data.
All information that EPA entered into a computer database was given a 100 percent QA/QC check to
ensure that all data were inputted properly. This was accomplished by double key entry, and any
discrepancies between the two inputted values compared with the original submission were corrected by
the QA/QC reviewer.
Section 4.3.2 discusses additional handling procedures for Detailed Questionnaires.
4.9.4 Detailed Monitoring Questionnaire Data Review
EPA evaluated Detailed Monitoring Questionnaire data using the same procedures outlined for the Detailed
Questionnaire process. The QA/QC steps included reviews for the following: 1) completeness, 2) internal
consistency, and 3) outliers.
Section 4.4 discusses additional handling procedures for Detailed Monitoring Questionnaires.
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Table 4-2: Types of Facilities Included in EPA's Characterization and Engineering Site Visits
Ownership Type
Municipal
Commercial
Non-C ommerci al
(captive, intra-company)
Waste Type
Subtitle D
Subtitle C
Landfill Type
Subtitle D Non-Hazardous
(Municipal)
(Non-Municipal)
Subtitle C Hazardous
Ground Water
Characterization Site Visits
4
9
2
Engineering Site Visits*
9
8
1
Characterization Samples Collected
13
5
15
3
Characterization Samples Collected
10
(2)
(8)
5
3
15
(14)
(1)
3
0
*One engineering site visit was conducted outside the U.S.
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Table 4-3: Types of Facilities Included in EPA's Field Sampling Program
Episode
4626
4667
4687
4690
4721
4759
Ownership Type
Municipal
X
X
X
Commercial
X
X
Non-Commercial
X
Waste Type
Subtitle D
X
X
X
Subtitle C
X
X
X
Landfill Subcategoiy
Non-Hazardous
X
X
X
Hazardous
X
X
X
Treatment Technology
Equalization, chemical
precipitation, biological
treatment, filtration
Equalization/stripper,
chemical precipitation,
biological treatment, GAC,
filtration
Equalization, filtration,
reverse osmosis
Air stripping
Steam stripping
Equalization, biological
treatment
Equalization, chemical
precipitation, biological
treatment
J^.
K>
-------
Table 4-4: Episode Numbers for the Engineering Site Visits and Field Sampling Efforts
Episode
Number
4491
4503
4626
4630
4631
4638
4639
4644
4667
4683
4687
4738
4690
4721
4684
4685
4759/4682
4659
-
-
-
-
-
-
-
-
-
-
-
-
Sampling/
Site Visits
E,C
C
E,W
C
C
C
C
C
E,W
C
E,W
C
E,W, C
E,W, C
C
C
E,W,C
C
E
E
E
E
E
E
E
E
E
E
E
E
C = Raw Wastewater Characterization Sampling Episode (1-day sampling episode)
E = Engineering Site Visit
W = Five-day Sampling Episode
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5.0 INDUSTRY SUBCATEGORIZATION
In developing technology-based regulations for the Landfills industry, EPA considered whether a single set
of effluent limitations and standards should be established for the industry, or whether different limitations
and standards were appropriate for subcategories within the industry. The Clean Water Act (CWA)
requires EPA, in developing effluent limitations, to assess several factors, including manufacturing
processes, products, the size and age of a site, wastewater use, and wastewater characteristics. The
Landfills industry, however, is not typical of the industries regulated under the CWA. Therefore, EPA
looked at additional factors that are specifically tailored to the characteristics of landfill operations in
deciding appropriate limitations for landfill facilities. The factors considered for the subcategorization of
the Landfills industry are listed below:
• Resource Conservation and Recovery Act (RCRA) Regulatory classification
• Types of wastes received
Wastewater characteristics
Facility size
• Ownership
• Geographic location
• Facility age
• Economic impacts
• Treatment technologies and costs
• Energy requirements
• Non-water quality impacts
5.1 Subcategorization Approach
Based on an evaluation of the above factors, EPA determined that there was a notable distinction between
wastewater associated with Subtitle C landfills and those from Subtitle D landfills. A wider range of toxic
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organic pollutants and higher concentration of metals was found at the Subtitle C landfills. Thus, the most
significant differences observed in wastewater characteristics at landfills are directly correlated to the wastes
received at the landfill which, in turn, are most obviously linked to the landfill's RCRA status. Therefore,
EPA concluded that the most appropriate basis for subcategorization is by landfill classification under
RCRA.
Additionally, the Agency believes that this subcategorization approach has the virtue of being easiest to
implement because it follows the same classification previously established under RCRA and is currently
in use (and widely understood) by permit writers and regulated entities. The Agency believes that any
subcategorization at odds with existing RCRA classification approaches will potentially create unnecessary
confusion to the regulated community. The subcategories are described below.
5.2 Landfills Subcategories
EPA is subcategorizing the Landfills industry into two subcategories as follows:
RCRA Subtitle C Hazardous Waste Landfill Subcategory
Subpart A of 40 CFR Part 445, "RCRA Subtitle C Hazardous Waste Landfill Subcategory," applies to
wastewater discharges from a solid waste disposal facility subject to the criteria in 40 CFR Part 264
SubpartN - "Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities" and 40 CFR Part 265 SubpartN -"Interim Standards for Owners and Operators of Hazardous
Waste Treatment, Storage, and Disposal Facilities." Hazardous waste landfills are subject to requirements
outlined in 40 CFR Parts 264 and 265 that include the requirement to maintain a leachate collection and
removal systems during the active life and post-closure period of the landfill. For a discussion of these
criteria, see Chapter 3, Section 3.1: "Regulatory History of the Landfills Industry", or see the Preamble to
the proposed landfill guideline at 63 FR 6426, 6430-31. (February 6, 1998).
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RCRA Subtitle D Non-Hazardous Waste Landfill Subcategory
SubpartB of 40 CFRPart445, "RCRA Subtitle D Non-Hazardous Waste Landfill Subcategory," applies
to wastewater discharges from all landfills classified as RCRA Subtitle D non-hazardous landfills subj ect
to either of the criteria established in 40 CFR Parts 257 (Criteria for Classification of Solid Waste Disposal
Facilities and Practices) or 258 (Criteria for Municipal Solid Waste Landfills). For a discussion of these
criteria, see Chapter 3, Section 3.1: "Regulatory Flistory of the Landfills Industry", or see the Preamble to
the proposed landfill guideline at 63 FR 6426, 6431-32 (February 6, 1998).
Table 5-1 presents the subcategorization of all of the landfill facilities in the EPA database by questionnaire
identification number. All landfill facilities included in this table completed a Detailed Questionnaire and
collect wastewater; however, not all of the facilities included in this table are within the scope of the rule.
Landfill facilities not covered by this rule include captive landfills, landfills that generate no in-scope
wastewater, and zero or alternative discharge facilities. Chapter 2 discusses further the applicability of the
rule.
5.3 Other Factors Considered for Basis of Subcategorization
EPA also evaluated the appropriateness and significance of developing subcategories based on the other
factors presented earlier in this chapter. The following subsections present EP A's evaluation of each of
these factors.
5.3.1 Types of Wastes Received
The type of solid waste that is deposited in a landfill often has a direct correlation to the characteristics of
the leachate produced by that landfill. Wastes deposited in landfills range from municipal solid waste and
non-hazardous materials to hazardous wastes containing contaminants such as pesticides. An analysis of
the data collected as part of this study showed that there are differences in the wastewater generated by
facilities that dispose of hazardous wastes as compared to non-hazardous wastes. These differences are
reflected in both the number and types of pollutants of interest (as defined in Chapter 7) identified in each
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subcategory and in the concentrations of these pollutants found in the wastewater generated. Tables
presented in Chapters 6 (Tables 6-9 through 6-15) and 7 (Tables 7-1 and 7-2) of this document show
these differences.
Specifically, the pollutants of interest list for the Non-Hazardous subcategory contains a total of 32
pollutants, whereas the pollutants of interest list for the Hazardous subcategory contains 63 pollutants (see
Chapter 7 for discussion on pollutants of interest). In addition, there are more than twice as many pollutant-
of-interest metals present in the hazardous landfill leachate (12) as in non-hazardous landfill leachate (5),
and there are twice as many organic pollutants of interest present at hazardous landfills (28) than at non-
hazardous landfills (14). Pollutants analyzed during EPA sampling episodes were detected approximately
47 percent of the time at hazardous facilities versus approximately 31 percent of the time at non-hazardous
facilities. Tables 6-9 through 6-13 in Chapter 6 present the median, minimum, and maximum
concentrations of the pollutants of interest for both subcategories and, although there are cases where the
concentrations found at non-hazardous landfills are greater than the concentrations found at hazardous
landfills, EPA detected higher concentrations of most pollutants of interest at hazardous landfills. In the
proposed rule, EPA included data from numerous CERCLA facilities in the calculation of hazardous landfill
raw wastewater pollutant characteristics. However, since these discharges consisted primarily of ground
water and because the final rule does not cover ground water, EPA decided not to use the CERCLA data
to characterize hazardous landfills. Table 5-2 presents the median concentrations of pollutants of interest
common to both subcategories for hazardous and non-hazardous landfills.
In conclusion, EPA has determined that the most practical method of distinguishing the type of waste
deposited in a landfill is achieved by utilizing the RCRA classification of landfills. As discussed in Section
5.1, the RCRA classification selected as the basis for subcategorization is based on the type of waste
received by the landfill, hazardous or non-hazardous. Therefore, the type of waste disposed at a landfill
is a factor that is taken into consideration because it is directly encompassed by the RCRA classification
scheme — the selected subcategorization method.
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In addition to subcategorizing the Landfills industry based on RCRA classification, EPA also considered
further subcategorizing the Subtitle D Non-Hazardous subcategory to account for differences between non-
hazardous landfills and non-hazardous monofills. Subtitle D monofills, a class of non-hazardous landfills,
accept only one type of waste that include, but are not limited to, construction and demolition debris, ash,
and sludge. EPA decided not to further subcategorize Subtitle D landfill facilities. This decision is based
on the following two considerations: (1) similarities in waste acceptance and leachate characteristics
between monofills and other Subtitle D Non-Hazardous landfills; and (2) ease of implementation. First,
EPA compared the number and type of pollutants present in Subtitle D municipal and non-municipal
leachate. As shown in Table 6-9 in Chapter 6, there are nine pollutants of interest for Subtitle D non-
municipal solid waste landfills whereas there are 32 pollutants of interest for Subtitle D municipal solid
waste landfills. Although there were fewer pollutants of interest detected at non-municipal solid waste
landfills, there were no pollutants of interest at non-municipal solid waste landfills that were not also present
at municipal solid waste landfills. This is not unexpected, as the waste deposited in municipal solid waste
landfills and dedicated monofills is not mutually exclusive. Although cells at a dedicated landfill may prohibit
disposal of municipal refuse, a municipal solid waste landfill may also accept ash, sludge, and construction
and demolition wastes. EPA also compared the median raw wastewater concentration data from Subtitle
D municipal solid waste and non-municipal solid waste landfills in the EPA database in Table 6-9 and
determined that the concentrations present at non-municipal solid waste landfills were equivalent to or less
than the concentrations present at municipal solid waste landfills. EPA acknowledges that certain types of
Subtitle D non-municipal solid waste landfills have a low organic content in their wastewater, and as a result
some monofills, such as ash monofills, may not be able to operate biological treatment systems such as
those selected for BPT/BAT for the Non-Hazardous subcategory. For those monofills that do not accept
organic wastes, EPA found that many of the facilities could meet the subcategory limitations without
treatment and, for those that could not, alternative technologies were available at costs no greater than
those technologies EPA evaluated (and determined) to be economically achievable for the subcategory as
a whole. EPA included the costs associated with these alternate technologies in the final cost impact
analysis. See Chapter 11 for further discussion.
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To further assess the differences between municipal solid waste and non-municipal solid waste landfills in
the Non-Hazardous subcategory, EPA evaluated leachate characteristics from Subtitle D non-municipal
solid waste landfills in published reports. Table 5-3 includes data from three reports1 that analyzed
construction and demolition monofills, ash monofills, and co-disposal sites and compares these data to the
median raw wastewater data collected from non-hazardous municipal solid waste landfills as part of the
Landfills industry study. The data contained in these reports indicate that the leachate characteristics at
construction and demolition, co-disposal, and ash monofill facilities are comparable to the leachate
characteristics from municipal solid waste landfills. Both the number and type of parameters in the leachate
do not differ among these types of facilities, and concentration levels for all pollutants are comparable, with
many parameters found at lower concentrations in the data from the construction and demolition, co-
disposal, and ash monofill facilities. Therefore, EPA has concluded that untreated leachate characteristics
at these facilities were not significantly different than at other non-hazardous landfill facilities and did not
merit further subcategorization.
In addition, EPA collected data from six Subtitle D monofills during the EPA sampling program, including
two sludge monofills, two ash monofills, and two construction and demolition monofills. Table 5-4 presents
the average raw wastewater data for selected pollutants, along with the types of waste landfilled at each
monofill. EPA evaluated its monofill data along with commenter submitted data and the data referenced
in Table 5-3 and determined that there are differences in wastewater characteristics between different types
of monofills. Most of these differences result from the fact that not all monofills accept the same types of
waste. Some monofills accept primarily organic wastes (construction and demolition, sludge), others
accept primarily inorganic wastes (ash, lime), and many monofills accept a combination of organic and
inorganic wastes. As a result of the various types of monofills, EPA determined that a single subcategory
for all monofills would still not address the situation where a certain class of constituents is regulated even
1 "A Study of Leachate Generated from Construction and Demolition Landfills", Department of Environmental
Engineering Sciences, University of Florida, August 1996; "Characterization of Municipal Waste Combustion
Ashes and Leachates from Municipal Solid Waste Landfills, Monofills, and Co-Disposal Sites", U.S. EPA, EPA
530-SW-87-028D, October 1987; "Characterization of Municipal Waste Combustion Ash, Ash Extracts, and
Leachates", U.S. EPA, EPA 530-SW-90-029A, March 1990.
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though not all types of monofills contain those constituents (e.g. a utility ash monofill with low raw
wastewater BOD5 concentrations would still be in the same subcategory as a sludge monofill which may
contain moderate levels of BOD5). Thus, EPA would need to establish a separate subcategory for each
type of monofill to address the differences among them. Therefore, rather than develop multiple monofill
subcategories, EPA decided that, since the types of pollutants and concentrations of pollutants found at
monofills are, for the most part, equivalent to or less than those found at municipal solid waste landfills, a
single subcategory is appropriate for Subtitle D landfills. EPA concluded that the pollutants regulated for
the Subtitle D Non-Hazardous subcategory will control the discharges from all types of Subtitle D landfills,
including monofills.
The second consideration was based on ease of implementation. As discussed in Section 5.2, the RCRA
classification scheme selected as the basis for subcategorization clearly defines non-hazardous, hazardous,
and municipal solid waste landfill facilities. However, RCRA does not make any further distinction nor
further divide the Subtitle D landfill facilities based on whether they are monofills or if they receive multiple
types of waste. Therefore, by further subcategorizing the Subtitle D facilities into monofills and multiple
waste landfills, a new classification scheme would be introduced to permit writers and regulated facilities.
EPA concluded that the current RCRA classification scheme is widely understood by permit writers and
regulated landfill facilities, making it the easiest of the subcategorization approaches to implement.
Additionally, there are many facilities that operate both dedicated cells (similar to monofills) and municipal
solid waste cells at the same landfill and commingle the wastewater prior to treatment. Establishing one
subcategory for all non-hazardous landfills will ease implementation issues and adequately control
discharges from the Landfills industry.
5.3.2 Wastewater Characteristics
EPA concluded that leachate characteristics from non-hazardous and hazardous landfills differed
significantly from each other in the types of pollutants detected and the concentrations of those pollutants.
The tables supporting this conclusion are presented in Chapter 6 (Tables 6-9 through 6-13) and Chapter
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7 (Tables 7-1 and 7-2) of this document. As expected, EPA found that the leachate from hazardous
landfills contained a greater number of contaminants at higher concentrations than leachate from non-
hazardous landfills, as discussed in Section 5.3.1. This conclusion supports subcategorization based on
RCRA classification of hazardous and non-hazardous landfills.
In EPA's evaluation of contaminated ground water, the wastewater characteristics of contaminated ground
water from hazardous landfills differed significantly from the contaminated ground water characteristics at
non-hazardous waste landfills, as shown in Table 5-5 and Table 5-6, respectively. Contaminated ground
water from non-hazardous landfills contained only 16 pollutants of interest (as defined in Chapter 7)
compared to the contaminated ground water from hazardous waste landfills which contained a total of 54
pollutants of interest. In addition, effluent data collected in support of this rule demonstrate that
contaminated ground water flows at hazardous and non-hazardous facilities are, in general, currently
adequately treated as a result of existing corrective action programs under RCRA.
Due to the site-to-site variability of contaminated ground water, EPA has decided that the treatment of
these flows is best addressed through the RCRA Corrective Actions program. RCRA Corrective Action
programs at the federal, state, and local level have the ability to consider the site-to-site variability of the
contaminated ground water and provide the most applicable treatment necessary to control the
contaminants. Therefore, EPA has decided to exclude contaminated ground water from this regulation.
Chapter 2 fully describes EPA's decision not to include contaminated ground water as a landfill wastewater
covered by this regulation.
5.3.3 Facility Size
EPA considered subcategorization of the Landfills industry on the basis of facility size and found that
landfills of varying sizes generate similar wastewater and use similar treatment technologies. Based upon
a review of the industry-provided data in the landfills' database, there was no observed correlation between
waste acceptance amount or wastewater flow rate and the selection of treatment technologies. For
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example, a landfill facility can add cells or increase its waste receipt rate depending on the local market
need without altering or changing the characteristics of the wastewater generated. In addition, the size of
a landfill was not determined to be a factor in cost-effectiveness of the regulatory options considered by
EPA. Finally, EPA has determined that wastewater from landfills can be treated to the same level
regardless of facility size. EPA did not promulgate a de-minimis flow exemption for this guideline; however,
EPA has accounted for landfill facilities that generate small volumes of wastewater by estimating compliance
costs for the BPT/B AT options based on treating their wastewater off-site at a CWT facility (see Section
9.2.5).
5.3.4 Ownership
EPA considered subcategorizing the industry by ownership. A significant number of landfills are owned
by state, local, or federal governments, while others are commercially or privately owned. Landfills
generally fall into the following two major categories of ownership: municipal or private. Landfills owned
by municipalities are primarily designed to receive non-hazardous solid waste such as municipal solid waste,
non-hazardous industrial waste, construction and demolition debris, ash, and sludge. However,
municipally-owned landfills may also be designed to accept hazardous wastes.
Privately-owned landfills can also provide for the disposal of non-hazardous solid waste such as those
mentioned above, and, like municipally-owned facilities, may also be designed to accept hazardous wastes.
EPA found that current commercially- and municipally-owned landfills generally accept and manage wastes
strictly by the RCRA classification and, although there are distinct economic differences, there is no
distinction in the wastewater characteristics and wastewater treatment employed at commercially- or
municipally-owned landfills. Since all landfill types could be of either ownership status, EPA determined
that subcategorization based upon municipal and private ownership was not appropriate.
5.3.5 Geographic Location
EPA considered subcategorizing the industry by geographic location. Landfill sites are not limited to any
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one region of the United States. A table presenting the number of landfills by state is presented in Chapter
3 (Table 3-1). While EPA included landfills from all sections of the country in the Agency's survey efforts,
collection of wastewater characterization data as part of EPA's sampling episodes was limited to landfill
facilities in the Northeast, South, and Midwest, where annual precipitation is either average or above
average. Although wastewater generation rates appear to vary with annual precipitation, which is indirectly
related to geographic location, EPA could not establish a direct correlation between leachate characteristics
and geographic location due to lack of sampling data from arid parts of the United States. However, the
Agency believes that seasonal variations in rainfall cause only minor fluctuations in leachate characteristics
due to dilution effects and volume of leachate generated. In addition, many landfill facilities have developed
site-specific best management practices to control the amount of rainwater that enters a landfill and
eventually becomes part of the leachate. These practices include proper contouring of landfill cells,
extensive use of daily cover, and capping of inactive landfill cells to minimize the amount of rainwater that
enters the landfill. EPA's data collection efforts indicate that landfill facilities in less arid climates are more
likely to use these management practices to control their wastewater generation and flows to the on-site
wastewater treatment plant. The data collected by EPA did not indicate any significant variations in
wastewater treatment technologies employed by facilities in colder climates versus warmer climates.
EPA notes that geographic location may have a differential impact on the costs of operating a landfill. For
example, the cost of additional equipment required for the operation of the landfill or treatment system or
tipping fees charged for the hauling of waste may differ from region to region. These issues were addressed
in the economic impact assessment of the final rule.
Therefore, since the effect of geographic location appears to have a minimal impact on wastewater
characteristics or can be easily addressed at minimal effort and cost, EPA determined that
subcategorization based upon geographic location was not appropriate.
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5.3.6 Facility Age
EPA considered subcategorization based on the age-related changes in leachate concentrations of
pollutants for different age classes of landfills based on the evaluation of several factors. Several
considerations lead to the conclusion that age-related limits are not appropriate. First, a facility's
wastewater treatment system typically receives and commingles leachate from several landfills or cells of
different ages. The Agency has not observed any facility which has found it advantageous or necessary to
treat age-related leachates separately. The Agency did, however, sample two landfill facilities that had only
one cell. One of the facilities had been receiving wastes for nine years in its landfill cell, while the other
facility had only been receiving waste for one year. EPA compared the raw wastewater concentrations
of the constituents in these two cells and found the concentrations to be very similar. In addition, most of
the constituents in both cells were close to the median raw wastewater concentration for the Non-
hazardous subcategory. Second, based on responses to the questionnaire, discussions with landfill
operators and historical data, EPA understands that leachate pollutant concentrations appear to change
substantially over the first two to five years of operation but then change only slowly thereafter.
These two observations imply that treatment systems must be designed to accommodate the full range of
concentrations expected in influent wastewater. EPA concluded that the BPT/BAT/NSPS treatment
technologies are able to treat the variations in landfill wastewater likely to occur due to age-related changes.
EPA has taken into account the ability of treatment systems to accommodate age-related changes in
leachate concentrations, as well as short-term fluctuations by promulgating effluent limitations which reflect
the variability observed in monitoring data spanning up to three years.
Additionally, EPA addressed age-related effects on treatment technologies, costs, and pollutant loads by
utilizing data collected from a variety of landfills in various stages of age and operation (e.g. closed, inactive,
active). EPA sampled landfills of various ages and stages of operation (active, inactive, closed), lined and
unlined, and concluded that the landfill database used to develop the effluent limitations represents leachate
typically found at Subtitle D landfills. In addition, EPA received comments from several commenters stating
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that the leachate characterization data presented in the proposal was consistent with their own monitoring
data.
However, several commenters on the proposed rule stated that EPA's sampling data did not represent
adequately the age-related differences that can exist between leachates from landfills of different ages.
Table 5-7 presents the age of the landfills sampled by EPA. The table includes the sampling episode
number and RCRA classification of each landfill, the number of cells in each landfill, whether the landfill is
lined or not, the year the landfill began accepting waste, the year it stopped accepting waste, and the
projected landfill closure date, if available. All information on landfill ages were obtained from the Detailed
Questionnaire or the sampling reports from these facility's sampling episodes. All of EPA's sampling
episodes occurred during a two year period from 1993 to 1995. Grouping facilities shown in Table 5-7
according to the year the facility began accepting waste and by regulatory history, there are ten pre-1980
landfills (before 1980 Section 3001 of RCRA); five landfills that fall in the 1980 to 1983 range (before the
1984 Hazardous and Solid Waste Amendment to RCRA); five landfills that fall in the 1984 to 1988 range
(before Land Disposal Restrictions (LDR)); and five landfills that are post-1988 (after LDR). The landfill
facilities sampled by EPA were between one and 43 years of age at the time of sampling. As seen in Table
5-7, the majority of landfill facilities sampled contained more than one cell, and often more than one landfill,
and many of these landfill facilities commingled the leachate discharges from cells and landfills of various
ages. As mentioned above, the Agency sampled raw wastewater at two landfill cells of different ages and
found the concentrations of constituents to be very similar. EPA did not identify any facility that treated
leachates separately due to differences in age.
To determine if significant differences existed between landfills of various ages, EPA compared pollutant
concentration data from Subtitle D landfill facilities of different ages in the EPA database. Table 5-8
presents the median raw wastewater concentration for selected conventional, nonconventional, organic and
metal pollutants for non-hazardous landfills with available raw wastewater data in the EPA database by age
group. EPA determined the raw wastewater median concentrations in the table by: 1) calculating the
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average concentration of a pollutant at a landfill facility using data from EPA sampling episodes, Detailed
Questionnaires, and Detailed Monitoring Questionnaires, and then 2) calculating the median concentration
of the landfill facility average concentrations.
As seen in Table 5-8, when landfills of various ages from EPA's landfill effluent guidelines database are
compared, it is difficult to pinpoint any particular trend (i.e. organic pollutant concentrations decrease
significantly with age). The absence of any particular trend associated with pollutant concentrations across
landfill facilities of various ages may be due to the fact that most of the older landfill facilities in EPA's
database have newer landfill cells whose leachate is commingled for treatment with the leachate from the
older landfill cells. EPA acknowledges that age-related changes in landfill leachate characteristics would
be expected from individual landfill cells. Most of the older landfill cells have lower concentrations of
BOD5, COD, and most organic pollutants indicating a smaller amount of degradable compounds from the
aged waste (reference 13). In addition, aged leachates contain high levels of chemically reduced
compounds, such as ammonia, and high chlorides because of the anaerobic environment of the landfill.
These trends tend to be true for individual landfill cells. Again, however, as mentioned above, the Agency
sampled raw wastewater at two landfill cells of different ages and found the concentrations of constituents
to be very similar. However, when looking at a landfill facility as a whole (where leachates from several
cells of various ages are commingled for treatment), the landfills effluent guidelines database does not fully
support such a trend. Furthermore, the time frame of these age-related changes is not consistent in every
landfill. Several factors including size of a cell, composition and disposition of refuse, precipitation levels,
and the influence of leachate from older cells on newer cells, can, and do, affect how a leachate's
composition changes with time. However, in general, these pollutant concentrations are within the same
order of magnitude and the Agency concluded that this age-related variability in wastewater characteristics
can be adequately controlled by the BPT/BAT treatment options, as demonstrated by the BAT facilities
sampled by EPA.
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Based on this analysis of the effects of age on wastewater characteristics, EPA determined that
subcategorization based on facility age is not appropriate.
5.3.7 Economic Characteristics
EPA also considered subcategorizing the industry based on the economic characteristics of the landfill
facilities. If a group of facilities with common economic characteristics, such as revenue size, was in a much
better or worse financial condition than others, EPA could consider subcategorization on economics.
However, based on the results of the Detailed Questionnaires, financial conditions of facilities showed no
significant pattern of variation across possible subcategories, such as municipally- and commercially-owned
facilities. In addition, EPA determined that the economic impacts of the compliance costs associated with
the BPT/BAT regulations did not inordinately effect any particular segment of the Landfills industry.
Therefore, EPA determined that subcategorization based on the economic characteristics of landfills
facilities was not justified.
5.3.8 Treatment Technologies and Costs
Wastewater treatment for this industry ranges from primary systems such as equalization, screening, and
settling, to advanced tertiary treatment systems such as filtration, carbon adsorption, and membrane
separation. EPA found that the selected treatment technology employed at a facility was dependent on
wastewater characteristics and permit requirements. Landfills with more complex mixtures of toxic
pollutants in their wastewater generally had more extensive treatment systems and may utilize several
treatment processes (e.g., facilities with high levels of both organic and inorganic pollutants may employ
both a chemical and biological treatment system). However, subcategorizing by the waste type received
by a landfill as outlined in the RCRA classification of landfills is less difficult to implement and results in
addressing the same factors as using treatment processes employed. As a result, EPA did not consider
treatment technologies or costs to be a basis for subcategorization.
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5.3.9 Energy Requirements
The Agency did not subcategorize based on energy requirements because energy usage was not considered
a significant factor in this industry and is not related to wastewater characteristics. Energy costs resulting
from this regulation were accounted for in the cost section of this development document (Chapter 9) and
in the economic impact assessment.
5.3.10 Non-Water Quality Impacts
The Agency evaluated the impacts of this regulation on the potential for increased generation of solid waste
and air pollution. The non-water quality impacts did not constitute a basis for subcategorization. Non-water
quality impacts and costs of solid waste disposal are included in the economic analysis and regulatory
impact analysis for this regulation. See Chapter 10 for more information regarding non-water quality
impacts.
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Table 5-1: Subcategorization of the EPA Landfills Database
Hazardous Subcategory Detailed
Questionnaire ID Numbers
16005
16007
16017
16018
16019
16031
16032
16034
16036
16037
16040
16041
16042
16044
16045
16051
16066
16067
16068
16069
16081
16086
16087
16094
16095
Non-Hazardous Subcategory Detailed
Questionnaire ID Numbers
16001
16003
16008
16009
16011
16012
16013
16014
16015
16016
16020
16023
16024
16025
16026
16027
16028
16029
16033
16035
16038
16039
16043
16046
16047
16128
16129
16130
16131
16132
16135
16137
16139
16148
16150
16151
16152
16153
16154
16155
16156
16158
16159
16160
16161
16162
16163
16164
16165
16166
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Table 5-1: Subcategorization of the EPA Landfills Database (continued)
Hazardous Subcategory Detailed
Questionnaire ID Numbers
16101
16104
16105
16106
16108
16110
16134
16136
16140
16141
16142
16143
16144
16145
16146
16147
16149
16167
16168
16169
16178
16179
16182
16183
16192
Non-Hazardous Subcategory Detailed
Questionnaire ID Numbers
16048
16049
16050
16052
16053
16054
16055
16056
16057
16058
16059
16060
16061
16062
16063
16064
16065
16070
16071
16072
16073
16074
16075
16076
16077
16170
16171
16173
16174
16175
16176
16177
16180
16184
16185
16186
16187
16189
16190
16191
16193
16196
16199
16200
16201
16202
16203
16204
16205
16206
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Table 5-1: Subcategorization of the EPA Landfills Database (continued)
Hazardous Subcategory Detailed
Questionnaire ID Numbers
16197
16210
16218
16235
16238
Non-Hazardous Subcategory Detailed
Questionnaire ID Numbers
16078
16079
16083
16084
16085
16088
16090
16091
16092
16093
16097
16098
16099
16102
16103
16107
16109
16111
16113
16114
16115
16116
16117
16118
16119
16208
16211
16212
16215
16217
16219
16220
16221
16222
16223
16224
16225
16228
16230
16231
16232
16233
16234
16236
16239
16240
16241
16242
16243
16245
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Table 5-1: Subcategorization of the EPA Landfills Database (continued)
Hazardous Subcategory Detailed
Questionnaire ID Numbers
Non-Hazardous Subcategory Detailed
Questionnaire ID Numbers
16120
16121
16122
16123
16124
16125
16127
16246
16248
16249
16250
16251
16252
16253
5-19
-------
Table 5-2: Raw Wastewater Median Concentrations of Pollutants of Interest Common to Both the
Hazardous and Non-Hazardous Landfill Subcategories
Non-Hazardous
Pollutants of Interest
Hazardous
Median Concentration
Non-Hazardous
Median Concentration*
(mg/L)
Ammonia
BOD
COD
Nitrate/Nitrite
IDS
TOC
Total Phenols
TSS
268
621
1,309
1.6
15,958
441
25
151
75-82
67 - 240
994 - 1,100
0.65 - 0.95
2,894 - 4,850
236 - 377
0.25 - 0.57
21 - 137
(ug/L)
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzoic Acid
Hexanoic Acid
Methylene Chloride
0-Cresol
Phenol
P-Cresol
Toluene
Tripropyleneglycol Methyl Ether
Chromium
Strontium
466
1,048
2,889
500
96
2,482
2,703
118
79
4,400
144
104
853
36
3,044
11
1,082
992
101
123
100
5,818
37
15
102
75
108
197
28
1,671-4,615
5-20
-------
Table 5-2: Raw Wastewater Median Concentrations of Pollutants of Interest Common to Both the
Hazardous and Non-Hazardous Landfill Subcategories (continued)
Non-Hazardous
Pollutants of Interest
Titanium
Zinc
Hazardous
Median Concentration
33
100
Non-Hazardous
Median Concentration*
64
100
Non-Hazardous subcategory median concentrations are presented as a range because raw
wastewater data was calculated separately for municipal solid waste and non-municipal solid
waste facilities.
5-21
-------
Table 5-3: Comparison of Subtitle D Non-Municipal and Municipal Raw Wastewater Pollutant Concentrations (ug/L)
Pollutant
Metals
Arsenic
Barium
Boron
Chromium
Hexavalent Chromium
Molybdenum
Silicon
Strontium
Titanium
Zinc
Organics
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzole Acid
Dichloroprop
Disulfoton
Hexanoic acid
MCPA
MCPP
Methylene Chloride
N , N-Dimethylformamide
0-Cresol
Phenol
P-Cresol
Toluene
Tripropyleneglycol Methyl Ether
Co r~\ Qt,,^17
& ]J otuuy
Mean (1)
12.3
661
NA
NA
NA
NA
NA
NA
NA
658
49
NA
NA
130
NA
15,457
NA
3.3
NA
NA
NA
26.4
NA
50
384
NA
61
NA
Facilities
Det/Total(2)
12/16
13/13
NP
NP
NP
NP
NP
NP
NP
15/15
1/5
NP
NP
2/8
NP
4/9
NP
2/4
NP
NP
NP
4/9
NP
2/8
3/6
NP
7/9
NP
EPA Characterization Studies - Data Range
1990
Ash
Monofills
ND(50) - 400
ND(2) - 9,220
NA
ND(7) - 32
NA
NA
470 - 15,300
NA
NA
5.2-370
NA
NA
NA
NA
NA
ND(50) - 73
NA
NA
NA
NA
NA
NA
NA
NA
ND(10) - 32
NA
NA
NA
1987
Co-Disposal
8-46
270 - 890
NA
ND(10) - 13
NA
NA
NA
NA
NA
9-1,210
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND(50) -2,100
NA
ND(50) - 120
NA
Monofills
10-218
NA
NA
5-914
NA
NA
NA
NA
NA
48 - 3,300
NA
ND(50)
ND(50)
ND(50)
ND(50)
ND(50)
ND(50)
NA
ND(50)
NA
NA
ND(50)
ND(50)
ND(50)
ND(1.5)
ND(50)
ND(50)
ND(50)
Subtitle D Municipal
Raw Wastewater Median Concentration
Median
32.4
483
3,910
28
30
10
15,759
1,671
64
100
11
1,082
991
101
123
100
6
6
5,818
403
233
37
10
15
102
75
108
197
Mean
50.4
720
3,874
46
77
27
28,817
1,569
66
1,476
118
5,119
2,407
3,789
334
7,220
10
9
13,148
816
432
70
214
298
287
246
166
568
Max
179
3,500
16,250
240
247
69
159,000
2,146
157
31,813
323
36,544
8,614
46,161
1,061
33,335
29
20
37,256
4,370
1,900
237
1,008
2,215
1,425
998
598
1,235
-------
Table 5-3: Comparison of Subtitle D Non-Municipal and Municipal Raw Wastewater Pollutant Concentrations (ug/L) (continued)
Pollutant
Conventional/Nonconventionals
BOD
COD
Ammonia Nitrogen
TDS
TSS
Total Phenols
Nitrate/Nitrite
TOC
Dioxins/Furans
1234678-HpCDD
OCDD
C & D Study
Mean (1)
87,320
754,500
20,420
2,263,100
1,859,100
620
NA
306,540
NA
NA
Facilities
Det/Total(2)
14/14
16/17
16/78
17/18
17/18
7/7
NP
7/7
NP
NP
EPA Characterization Studies - Data Range
1990
Ash
Monofills
NA
NA
4,380 - 77,400
924,000-41,000,000
NA
NA
NA
17-420,000
ND(NV) - 0.222(2)
ND(NV) -0.107
Co-Disposal
NA
1,300,000-
3,900,000
160,000-410,000
NA
1,930,000-
7,970,000
NA
NA
438,000-1,310,000
0.12-0.7712'
0.21 -15
1987
Monofills
NA
5-1,200,000
1,200-36,000
NA
NA
NA
NA
59,100-636,000
0.009 - 172(2)
0.06-120
Subtitle D Municipal
Raw Wastewater Median Concentration
Median
240,000
994,000
81,717
2,894,289
137,000
571
651
376,521
0.00014
0.0018
Mean
1,228,534
2,024,932
238,163
4,195,518
735,308
142,838
5,844
661,477
0.0024
0.030
Max
7,609,318
11,881,700
2,900,000
17,533,000
14,470,000
2,051,249
50,800
3,446,084
0.0071
0.0824
to
oo
All units in ug/1 unless otherwise noted
*: The number of sites that detected the parameter/the total number of sites that sampled the parameter
(1): Mean includes non-detects for metals and conventionals/nonconventionals and does not include non-detects for organics and dioxins/furans
(2): Total homolog concentration
NA: Not Analyzed
ND: Not Detected
NV: Not Available
NP: Not Applicable
-------
Table 5-4: Summary of EPA Sampling Data for Subtitle D Monofills Average Raw Leachate Data for Selected Pollutants
Episode
4503
4630
4631
4638
4639
4644
Waste Type Landfilled
mill sludge (clay, lime, cellulose),
fly ash, bark
POTW sludge
municipal resource recovery ash
C&D debris, state-regulated non-
hazardous waste
municipal resource recovery ash,
WWTP residues
C&D, yard waste, bricks, rubble,
waste oil
BOD5
TSS
Ammonia
Zinc
Alpha
Terpineol
Benzoic
Acid
P-Cresol
Phenol
(mg/L)
120
85
12
67
4
13
104
292
11
22
4
4
53.2
118
75
0.67
0.1
0.85
0.028
0.086
0.033
0.102
0.06
0
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.092
ND
ND
ND
fj\
to
ND: Non-Detect
NA: Data not provided.
-------
Table 5-5: Average Contaminated Ground Water Pollutant Concentrations at Hazardous Landfills
in the EPA Database (ug/L)
Hazardous Groundwater
Pollutant oflnterest Gas #
1,1-Dichloroethane 75243
1,1,1-Tnchloroethane 71556
1,1,2,2-Tetrachloroethane 79345
1,2,4-Tnchlorobenzene 120821
1,2-Dichlorobenzene 95501
1 ,2-Dichloroethane 107062
1,2,3-Tnchloropropane 96184
1,3-Dichlorobenzene 541731
1 ,4-Dichlorobenzene 106467
1,4-Dioxane 123911
2,4-Dichlorophenol 120832
2378-TCDD 1746016
2378-TCDF 51207319
2,4,5-T 93765
2,4,5-TP 93721
2-Propanone 67641
Ammonia as Nitrogen 7664417
Arsenic 7440382
Benzene 71432
BenzoicAcid 65850
Benzyl Alcohol 100516
Bis(2-chloroethyl)ether 111444
Bis(2-ethylhexyl)phthalate 117817
BOD C-002
Boron 7440428
Cadmium 7440439
Chlorobenzene 108907
Chloroform 67663
COD C-004
Copper 7440508
Dalapon 75990
Dicamba 1918009
Dichlorvos 62737
MDL
10
10
10
10
10
10
10
10
10
10
10
0.00001
0.00001
0.2
0.2
50
10
10
10
50
10
10
10
2000
100
5
10
10
5000
25
0.2
0.2
5
QID
16018
Inf
520
920
QID
16031
Eff
2
5
2
1
2
2
QID
16032
Eff
2700
23600
QID
16034
Inf
230
180
46
QID
16036
Inf
113
185
0.5 ND
4
QID
16094
Eff
1 ND
1 ND
1 ND
1 ND
1 ND
1 ND
QID
16095
Inf Eff
89 5 ND
370 5 ND
QID
16136
Inf
4606
QID
16141
Eff
50 ND
3 ND
QID
16144
Inf Eff
121522 10
37598 10
218139 445
265 19ND
10491 19 ND
1376889 357
1300084 138
16628 19 ND
25655 19 ND
6429 3738
101 109 ND
0.00016
0.0066
5
2
25424 446
27444 17760
80 13
37922 10
1330 1920
298 282
16518 34716
1039 19ND
86500 55230
846 770
9 8
12936 10
132025 32
6423889 2445850
53 521
109
34
236
to
-------
Table 5-5: Average Contaminated Ground Water Pollutant Concentrations at Hazardous Landfill
in the EPA Database (ug/L) (continued)
Hazardous Groundwater
Pollutant oflnterest Gas #
Dinoseb 88857
Dioxathion 78342
Ethyl Benzene 100414
Hexane Extractable Material C-036
Hexanoic Acid 142621
Lithium 7439932
Methylene Chloride 75092
Molybdenum 7439987
Naphthalene 91203
Nickel 7440020
Nitrate/Nitrite C-005
Pentachlorobenzene 608935
Phenol 108952
Silicon 7440213
Strontium 7440246
TOG C-012
Toluene 108883
Trans-l,2-Dichloroethene 156605
Tnchloroethene 79016
TSS C-009
Zinc 7440666
MDL
0.5
5
10
5000
10
100
10
10
10
40
50
20
10
100
100
1000
10
10
10
4000
20
QID
16018
Inf
372
573
QID
16031
Eff
2
2
2
5
5
QID
16032
Eff
QID
16034
Inf
54
120
QID
16036
Inf
5
QID
16094
Eff
1 ND
QID
16095
Inf Eff
19 5 ND
QID
16136
Inf
4100
2573
QID
16141
Eff
10
1000 ND
37000
QID
16144
Inf Eff
14
270
14694 10
1700222 8750
16368 28013
305 219
123572 40
13 13
3766 19 ND
136 1462
2136 1571
4333 38 ND
6029 1537
6738 6602
17156 12360
2055028 730700
22080 10
84660 14
272606 33
121639 26450
576 3451
MDL: Method detection limit
QID: Questionnaire ID
E: Sampling episode
ND: Non-detect with respect to instrument detection limit (IDL)
*: IDL is greater than detected value
-------
Table 5-6: Average Contaminated Ground Water Pollutant Concentrations at Non-Hazardous Landfills in the EPA Database (ug/L)
Non-Hazardous Groundwater
Pollutant of Interest Cas #
1,1-Dichloroethane 75243
1,1,1-Trichloroethane 71556
1,2-Dichloroethane 107062
2,4,5-T 93765
2,4,5-TP 93721
2-Propanone 67641
Ammonia as Nitrogen 7664417
Arsenic 7440382
Benzene 71432
Benzyl Alcohol 100516
BOD C-002
Boron 7440428
Cadmium 7440439
Chlorobenzene 108907
Chloroform 67663
COD C-004
Copper 7440508
Dalapon 75990
Dicamba 1918009
Dinoseb 88857
Ethyl Benzene 100414
Methylene Chloride 75092
Naphthalene 91203
Nickel 7440020
Nitrate/Nitrite C-005
Phenol 108952
Silicon 7440213
Strontium 7440246
TOC C-012
Toluene 108883
Trans- 1,2-Dichloroethene 156605
Trichloroethene 79016
TSS C-009
Zinc 7440666
MDL
10
10
10
0.2
0.2
50
10
10
10
10
2000
100
5
10
10
5000
25
0.2
0.2
0.5
10
10
10
40
50
10
100
100
1000
10
10
10
4000
20
E4683
Inf
10 ND
10 ND
10 ND
0.2 ND
0.2 ND
50 ND
1340
2 ND
10 ND
10 ND
14000
173
4 ND
10 ND
10 ND
28000
12
0.2 ND
0.2 ND
0.5 ND
10 ND
10 ND
10 ND
14 ND
2660
10 ND
3530
201
10000 ND
10 ND
10 ND
10 ND
4000 ND
15.2
QID
16016
Eff
0.3 ND
0.5 ND
0.3 ND
2000 ND
10.5
16
0.3 ND
1000
18
0.5 ND
0.5 ND
21637
38
0.3 ND
1
36 ND
30
54.5 ND
0.3 ND
0.3 ND
0.35
35
QID
16085
Inf Eff
5.5
1.4 ND
1.4 ND
0.2 ND
0.2 ND
50 ND
1284 256
4.3
1.4 ND 5.7
10 ND
1000 ND 751
362
0.4 19
1.4 ND
1.7
51000
10 ND
0.2 ND
0.2 ND
0.5 ND
1.4 ND
3.3 ND
10 ND
59
1300
5718 ND
3880
657
40000
1.4 ND
2.8 5.7
10 ND
24000 5593
70
QID
16088
Inf Eff
8.6 1
2.1 1 ND
2.1 ND 1 ND
2
5
50 ND
1300 409
3 2
2.2 1 ND
10 ND
1000 ND
97
4 ND 15
2.1 ND 1.5 ND
2.1 ND 1 ND
14000
10 ND
6
10
3
2.1 ND 1 ND
2.1 ND 3.5 ND
10 ND
14 ND 27
1340
10 ND
3270
200
10000 ND
2.1 ND 1 ND
3.6 1 ND
2.1 ND 1 ND
4000 ND
16
QID
16129
Inf Eff
22
17
15
1 ND
1.9 ND
742
80551 563
13
13
19
213655 1835
1091
5 ND
12
15
53 121
50 ND
15
49 0.6
12
45 21
145
47
38 0.5 ND
19 0.5
43848 2651
82 24
QID
16132
Eff
0.35 ND
0.45 ND
0.35 ND
1.3
11
0.35 ND
3.8
0.35 ND
10
0.35 ND
0.45
16
3996
0.35 ND
0.35 ND
0.45
QID
16163
Eff
4 ND
5 ND
8
25
2
5 ND
33300
2.5
5 ND
40
10000 ND
5 ND
5 ND
1
MDL: Method detection limit
QID: Questionnaire ID
E: Sampling episode
ND: Non-detect with respect to instrument detection limit (IDL)
*: IDL is greater than detected value
-------
Table 5-7: Age of Landfills in EPA Sampling Database
Episode
4491
4503
4626
4630
4631
4638
4639
4644
4659
4667
4683
RCRA
Classification
Subtitle D
Lined (varies)
Subtitle D
Unlined
Subtitle D
Lined (comp)
Subtitle D
Lined (clay)
Subtitle D
Lined (comp)
Subtitle C
Lined (clay)
Subtitle C
Lined (clay)
Subtitle D
Lined (dbl comp)
Subtitle D
Lined (comp)
Subtitle D
Lined (clay)
Subtitle C
Unlined
Subtitle C
Lined (clay)
Subtitle D
Lined (varies)
Subtitle D
Unlined
Subtitle D - GW
Lined (varies)
Number
of Cells
25
1
1
5
5
-
10
5
2
2
-
-
4
1
7
Year Landfill
Began Accepting
Waste
1970
1974
1986
1988
1987
1972
1972
1990
1988
1989
1958
1981
1974
1962
1981
Year Landfill
Stopped
Accepting Waste
1994
1990
1993
1994
-
1982
1982
-
-
-
1981
1988
1993
1974
-
Projected
Closure
1999
1992-3
2000
2003
-
1991
1991
-
-
-
1981
-
1997
1991
2017
5-28
-------
Table 5-7: Age of Landfills in EPA Sampling Database (continued)
Episode
4687
4690
4738
4721
4759
RCRA
Classification
Subtitle D
Lined (comp)
Subtitle C
Unlined
Subtitle C
Lined (comp)
Subtitle C
Unlined
Subtitle D
Unlined
Subtitle C
Lined (clay)
Subtitle D
Unlined
Subtitle D
Lined (clay)
Subtitle C
Lined (clay)
Subtitle C
Lined (varies)
Number
of Cells
1
9
2
8
1
1
2
4
2
39
Year Landfill
Began Accepting
Waste
1994
1952
1980
1968
1992
1982
1991
1984
1980
1975
Year Landfill
Stopped
Accepting Waste
-
1973
1993
1979
1993
1985
1993
1994
1993
1993
Projected
Closure
-
1976
2008
1980
1998
1986
1998
1998
1997
2000
(comp): composite liner (synthetic and clay)
(varies): cells lined with either synthetic, asphalt, clay, composite or double lined composite
5-29
-------
Table 5-8: Median Raw Wastewater Characteristics at Non-Hazardous Landfills
of Varying Age
Pollutant
Ammonia
BOD5
COD
TOC
TSS
Alpha Terpineol
Benzoic Acid
P-Cresol
Phenol
Chromium
Zinc
Landfill Age Group (Year in which Landfill Facility Began Accepting
Waste)
Pre-1980
Median Cone.
140mg/L(15)
210mg/L(18)
596 mg/L (17)
445mg/L(15)
202 mg/L (17)
746 ug/L (2)
75 ug/L (4)
25 ug/L (5)
17 ug/L (8)
27 ug/L (16)
145 ug/L (16)
1980-1990
Median Cone.
95 mg/L (10)
125 mg/L (13)
930 mg/L (11)
377 mg/L (8)
49 mg/L (9)
123 ug/L (1)
9,308 ug/L (1)
117 ug/L (2)
242 ug/L (4)
31 ug/L (9)
93 ug/L (12)
1991 -Present
Median Cone.
48 mg/L (3)
344 mg/L (4)
3,038 mg/L (4)
150 mg/L (3)
100 mg/L (4)
-
-
-
820 ug/L (1)
10 ug/L (3)
139 ug/L (4)
(): Parentheses denote number of observations (number of landfills with data).
5-30
-------
6.0 WASTEWATER GENERATION AND CHARACTERIZATION
In 1994, under the authority of Section 308 of the Clean Water Act (CWA), the Environmental Protection
Agency (EPA) distributed a questionnaire entitled "Waste Treatment Industry Questionnaire Phase II:
Landfills" to 252 facilities that EPA had tentatively identified as possible generators of landfill wastewater.
Some of the facilities employed on-site wastewater treatment, while others did not. EPA selected these
facilities for survey purposes to represent a total of 1,024 potential generators of landfill wastewater. A
total of 220 questionnaire respondents generated landfill leachate in 1992. This section presents information
on wastewater generation at these facilities based on the questionnaire responses. In addition, this section
also summarizes the information on wastewater characteristics for landfill facilities that EPA sampled and
for those facilities that provided self-monitoring data.
6.1 Wastewater Generation and Sources of Wastewater
Landfill facilities do not generate "process wastewater" as EPA has traditionally defined it. At 40 CFR Part
122.2, EPA defines process wastewater as "any water which, during manufacturing or processing, comes
into direct contact with or results from the production or use of any raw material, by-product, intermediate
product, finished product or waste product". EPA typically uses this definition of process wastewater for
manufacturing or processing operations. Since landfill operations do not include or result in "manufacturing
processes" or "products", EPA refers to the wastewater treated at landfill facilities as landfill generated
wastewater.
In general, the types of wastewater generated by activities associated with landfills and collected for
treatment, discharge, or reuse are the following: leachate, landfill gas condensate, truck/equipment
washwater, drained free liquids, laboratory derived wastewater, floor washings, recovering pumping wells,
contaminated ground water, and storm water runoff. For the purposes of the Landfill industry study, EPA
considers all of these wastewater sources "in-scope" except for contaminated ground water, recovering
pumping wells, and non-contaminated storm water.
6-1
-------
In 1992, landfill facilities in the U.S. generated approximately 22.7 billion gallons of wastewater. For the
purposes of this guideline, EPA considers approximately 7.3 billion gallons of this wastewater "in-scope".
The remaining 15.4 billion gallons of wastewater generated at landfills consist of contaminated ground
water, wastewater recovered from pump wells, and non-contaminated storm water. The primary sources
of wastewater at landfills are defined below.
Landfill leachate as defined at 40 CFR Part 258.2, is liquid that has passed through or emerged from solid
waste and contains soluble, suspended, or miscible materials removed from such waste. Over time, the
seepage of water through the landfill as a result of precipitation may increase the mobility of pollutants and,
thereby, increase the potential for their movement into the wider environment. As water passes through
the layers of waste, it may "leach" pollutants from the disposed waste, moving them deeper into the soil.
This mobility may present a potential hazard to public health and the environment through ground water
contamination and other means. One measure used to prevent the movement of toxic and hazardous waste
constituents from a landfill is a landfill liner operated in conjunction with a leachate collection system.
Leachate is typically collected from a liner system placed at the bottom of the landfill. Leachate also may
be collected through the use of slurry walls, trenches, or other containment systems. The leachate
generated varies from site to site based on a number of factors including the types of waste accepted,
operating practices (including shedding, daily cover, and capping), the depth of fill, compaction of wastes,
annual precipitation, and landfill age. Landfill leachate accounts for over 97 percent of the total volume of
in-scope wastewater.
Landfill gas condensate is a liquid which has condensed in the landfill gas collection system during the
extraction of gas from within the landfill. Gases such as methane and carbon dioxide are generated due to
microbial activity within the landfill and must be removed to avoid hazardous and explosive conditions. In
gas collection systems, gases containing high concentrations of water vapor condense in traps staged
throughout the gas collection network. The gas condensate contains volatile compounds and accounts for
a relatively small percentage of flow from a landfill.
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Drained free liquids are aqueous wastes drained from waste containers (e.g., drums, trucks, etc.) or
wastewater resulting from waste stabilization prior to landfilling. Landfills that accept containerized waste
may generate this type of wastewater. Wastewater generated from these waste processing activities i s
collected and usually combined with other landfill generated wastewater for treatment at the wastewater
treatment plant.
Truck/equipment washwater is generated during either truck or equipment washes at landfills. During
routine maintenance or repair operations, trucks and/or equipment used within the landfill (e.g., loaders,
compactors, or dump trucks) are washed and the resultant wastewater is collected for treatment. In
addition, it is common practice for many facilities to wash the wheels, body, and undercarriage of trucks
used to deliver the waste to the open landfill face upon leaving the landfill. On-site wastewater treatment
equipment and storage tanks are also periodically cleaned and their associated washwaters are collected.
Floor washings generated during routine cleaning and maintenance of the facility also are collected for
treatment.
Laboratory-derived wastewater is generated from on-site laboratories which characterize incoming waste
streams and monitor on-site treatment performance. Landfill facilities usually combine the very small
amounts of wastewater from this source with leachate and other wastewater for treatment at the wastewater
treatment plant.
Contaminated storm water is storm water which comes in direct contact with landfill wastes, the waste
handling and treatment areas, or wastewater that is subj ect to the limitations and standards. Some specific
areas of a landfill that may produce contaminated storm water include (but are not limited to) the following:
the open face of an active landfill with exposed waste (no cover added); the areas around wastewater
treatment operations; trucks, equipment or machinery that has been in direct contact with the waste; and
waste dumping areas. Storm water that does not come into contact with these areas was not considered
to be within the scope of this study.
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Landfill operations also generate and discharge wastewater that is not covered by this regulation. These
sources include non-contaminated storm water, contaminated ground water, and wastewater from
recovering pumping wells. Chapter 2: "Scope of the Regulation" discusses the exclusion of these flows.
A brief description of this wastewater is presented below.
Non-contaminated (non-contact) storm water is storm water that does not come in direct contact with
landfill wastes, the waste handling and treatment areas, or wastewater that is subject to the limitations and
standards. Non-contaminated storm water includes storm water which flows off the cap, cover,
intermediate cover, daily cover, and/or final cover of the landfill.
Contaminated ground water is water below the land surface in the zone of saturation which has been
contaminated by landfill leachate. Contaminated ground water occurs at landfills without liners or at
facilities that have released contaminants from a liner system into the surrounding ground water. Ground
water can also infiltrate the landfill or the leachate collection system if the water table is high enough to
penetrate the landfill area.
Recovering pumping wells generate wastewater as a result of the various ancillary operations associated
with ground water pumping operations. These operations include construction and development, well
maintenance, and well sampling (i.e. purge water). The wastewater will have very similar characteristics
to contaminated ground water.
6.2 Wastewater Flow and Discharge
Tables 6-1 through 6-4 present national estimates of the flows for primary wastwater sources found at
landfills reported in "Section A" of the "Waste Treatment Industry Questionnaire Phase II: Landfills".
Chapter 3, Section 3.2.1 discusses how EPA calculated national estimates. The Agency based the national
estimates presented in Tables 6-1 through 6-4 on 167 of the 220 facilities that generate and treat landfill
leachate. EPA excluded the remaining 53 facilities from this guideline as discussed in Chapter 2. EPA
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considers these 167 landfill facilities as "in-scope" facilities, or within the scope of the regulation. The tables
report the flows by subcategory, as follows: Non-Hazardous subcategory (broken down into Subtitle D
municipal solid waste and non-municipal solid waste facilities) and Hazardous subcategory. The tables also
show the amount of wastewater flow from landfills by discharge status, as follows: direct, indirect, and zero.
Direct discharge facilities are those that discharge their wastewater directly into a receiving stream or body
of water. Based on national estimates, there were no direct discharging hazardous landfills identified in the
Landfills industry study. Indirect discharging facilities discharge their wastewater indirectly to a publicly-
owned treatment works (POTW). Zero or alternative discharge facilities use treatment and disposal
practices that result in no discharge of wastewater to surface waters or POTWs. Alternative disposal
options for landfill generated wastewater include off-site treatment at another landfill wastewater treatment
system or a Centralized Waste Treatment facility, deep well injection, incineration, evaporation, land
application, and recirculation back to the landfill.
Tables 6-1, 6-2, and 6-3 present wastewater flows by subcategory (Hazardous and Non-Hazardous,
which is divided into Municipal and Non-Municipal) and discharge type for the different types of
wastewater generated by landfills in 1992. Total flows are reported for wastewater treated on site and off
site, discharged untreated to a POTW or surface water, and recycled flows that are put back into the
landfill. Wastewater flows identified as "Other" treatment include evaporation, incineration, or deep well
injection.
Table 6-4 combines the in-scope wastewater flows from Tables 6-1, 6-2, and 6-3. Table 6-4 does not
include out-of-scope flows from contaminated ground water, recovering pumping wells, or storm water.
The table presents the national estimates of facilities subject to this guideline and the estimated wastewater
flows from these facilities.
6.2.1 Wastewater Flow and Discharge at Subtitle D Non-Hazardous Landfills
Landfill facilities generated approximately 7 billion gallons of in-scope wastewater at non-hazardous landfills
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in 1992. Flows collected from leachate collection systems are the primary source of wastewater,
accounting for over 98 percent of the in-scope wastewater generated at non-hazardous landfills.
Landfill facilities subject to this guideline have several options for the discharge of their wastewater. EPA
estimates that there are 143 Subtitle D non-hazardous facilities discharging wastewater directly into a
receiving stream or body of water, accounting for 1.1 billion gallons per year. In addition, there are 756
facilities discharging wastewater indirectly to a POTW, accounting for 4.7 billion gallons per year.
Also, there are a number of facilities which use treatment and disposal practices that result in no discharge
of wastewater to surface waters. The Agency estimates that there are 338 of these zero or alternative
discharge facilities. Several zero or alternative discharge facilities in the Non-Hazardous subcategory
recycle wastewater flows back into the landfill. The recirculation of leachate is generally believed to
encourage the biological activity occurring in the landfill and accelerates the stabilization of the waste. The
recirculation of landfill leachate is not prohibited by federal regulations, although many states have
prohibited the practice. EPA estimates that 348 million gallons of landfill wastewater are recirculated back
to Subtitle D non-hazardous landfill units each year.
6.2.2 Wastewater Flow and Discharge at Subtitle C Hazardous Landfills
Hazardous landfill facilities generated approximately 342 million gallons of in-scope wastewater in 1992.
Flows collected from leachate collection systems are the primary source of wastewater, accounting for
approximately 72 percent of the in-scope wastewater generated at hazardous landfills, and routine
maintenance activities such as truck/equipment washing and floor washing account for 26 percent of the
flows.
Landfill facilities have several options for the discharge of their wastewater. EPA's survey of the Landfills
industry did not identify any hazardous landfills subj ect to the guideline that discharge in-scope wastewater
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directly to surface waters. EPA estimates that there are 6 facilities discharging wastewater indirectly to
POTWs, accounting for 40 million gallons per year.
The Agency estimates that 139 hazardous landfill facilities use zero or alternative discharge disposal options
which account for over 302 million gallons per year. EPA estimates that 102 facilities ship wastewater off
site for treatment, often to a treatment plant located at another landfill or to a Centralized Waste Treatment
facility. Shipping off site accounts for 9 million gallons per year of wastewater. Another 36 facilities use
underground injection for disposal of their wastewater, accounting for 312 million gallons per year, while
1 facility solidifies less than 0.1 million gallons per year of landfill wastewater.
6.3 Wastewater Characterization
The Agency collected the information reported in this section through its sampling program and data
supplied by the Landfills industry via technical questionnaires. EPA sampling programs consisted of five-
day events at landfills with selected BAT treatment systems (EPA sampled both raw leachate and treated
effluent at these facilities) as well as one-day events to characterize raw leachate quality at landfill facilities.
The Agency also used industry-provided data, as supplied in the Detailed Questionnaire and in the Detailed
Monitoring Questionnaire responses, to characterize landfill generated wastewater. In addition, for the
proposal, EPA used data collected as part of the Centralized Waste Treatment Industry study (see
reference 31) and Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
ground water study (see reference 25) in the characterization of the wastewater from hazardous landfill
facilities. However, after proposal, EPA decided not to include CERCLA data in characterizing hazardous
landfill leachate because CERCLA discharges consisted primarily of ground water, which is not a
wastewater flow covered by this regulation. Chapter 4 discusses these data sources in detail as well as the
QA/QC procedures and editing rules used to evaluate these data. EPA characterized the raw wastewater
for each subcategory by taking the median influent concentration from all data sources for each pollutant
detected in that subcategory. This pollutant concentration is referred to as the Median Raw Wastewater
Concentration File.
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This section presents background information on the types of wastewater generated at landfill facilities and
the factors that affect the wastewater characteristics. It also discusses the pollutant parameters analyzed
and detected at EPA sampling episodes and the methodology for developing the Median Raw Wastewater
Concentration File. This section also presents available literature data on the wastewater characteristics
of Non-Hazardous subcategory landfill generated wastewater.
6.3.1 Background Information
Landfill generated wastewater is comprised of several wastewater sources that EPA discussed in Section
6.1. Wastewater that is subject to the landfill regulation includes landfill leachate, landfill gas condensate,
truck/equipment washwater, drained free liquids, laboratory-derived wastewater, floor washings, and
contaminated storm water runoff. Wastewater sources at landfills which are not subject to the landfill
regulation include contaminated ground water, wastewater from recovering pumping wells, and non-
contaminated storm water. The following section discusses the primary sources of in-scope landfill
generated wastewater.
6.3.1.1 Landfill Leachate
Leachate is the liquid which passes through or emerges from solid waste, and contains soluble, suspended,
or miscible materials removed from such waste. Several factors affect leachate quality, including the
following:
• types of waste accepted/deposited
• operating practices (shredding, cover, and capping)
• amount of infiltration
depth of fill
compaction
age
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Waste types received for disposal are the most representative characteristic of a landfill and, therefore, of
the wastewater generated, since the main contaminants in the wastewater are derived from the materials
deposited into the fill (see Chapter 5: Industry Subcategorization). The amount of infiltration and the age
of a landfill primarily affect the concentration of contaminants in the leachate. The remaining factors mainly
influence the rate of infiltration.
EPA considered the following two factors when characterizing landfill leachate: the concentration of
contaminants in the leachate and the volume of leachate generated. On a relative basis, the highest
concentrations of contaminants are typically present in leachate of new or very young landfills. However,
the overall loads (i.e., the mass) of pollutants are generally not very large because new landfills typically
generate low volumes of leachate. As the volume of waste approaches the capacity of the landfill and the
production of leachate increases, both the pollutant loadings (flow x concentration) and the concentrations
of certain contaminants (mainly organic pollutants) increase. The increase of pollutant concentration is
attributed to the onset of decomposition activities within the landfill and to the leachate traversing the entire
depth of refuse. Therefore, large pollutant loadings from a typical landfill occur during a period of high
leachate production and high contaminant levels (see reference 13). The exact periods of varying leachate
production cannot be quantified readily but are site specific and dependent on each of the above variables.
Over a period of time (as the landfill ages and leaching continues), the concentration of contaminants in the
leachate decreases (see reference 13). The landfill may continue to generate substantial quantities of
leachate; however, pollutant loadings are lower due to the lower concentrations of soluble, suspended, or
miscible contaminants remaining in the landfill. As decomposition of the landfill continues, the landfill attains
a stabilized state of equilibrium where further leaching produces leachate with lower loadings than during
the period of peak leachate production. This stabilized state is presumably the result of decomposition of
landfill waste by indigenous microorganisms, which will remove many of the contaminants usually
susceptible to further leaching.
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Biological decomposition of landfill municipal refuse is often modeled after the anaerobic breakdown of
other organic wastes. The following discussion of the decomposition process has been adapted from a
report on the characteristics of landfill leachate prepared by the Wisconsin Department of Natural
Resources (see reference 13).
Biological activity occurs in a landfill shortly after deposition of organic material. At first, wastes high in
moisture content decompose rapidly under aerobic conditions, creating large amounts of heat. As oxygen
is depleted, the intermediate anaerobic stage of decomposition begins. This change from aerobic to
anaerobic conditions occurs unevenly through the landfill and depends upon the rate of oxygen diffusion
in the fill layers. In the first stage of anaerobic decomposition, extra-cellular enzymes convert complex
organic wastes to soluble organic molecules. Once the organic wastes are solubilized, the second stage
of anaerobic decomposition converts them to simple organic molecules, such as acetic, propionic, and
butyric acids, and other organic acids. These soluble organic acids enter the leachate percolating through
a landfill, resulting in decreased pH of the leachate and increasing oxygen demand. Anaerobic activity in
the landfill can also lower the reduction oxidation (redox) potential of the wastes which, under low pH
conditions, can cause an increase in inorganic contaminants. Eventually, bacteria within the landfill begin
converting the organic acids to methane. The absence of organic acids in the landfill increases the pH of
the leachate which can lead to a decrease in the solubility of inorganic contaminants, lowering inorganic
concentrations in the leachate (see reference 13).
The age or degree of decomposition of a landfill may, in certain circumstances, be ascertained by observing
the concentration of various leachate indicator parameters, such as BOD5, TDS, or the organic nitrogen
concentration (see reference 13). The concentrations of these leachate indicator parameters can vary over
the decomposition life of a landfill. Typically, older landfills have lower concentrations of BOD5, COD,
and most organic pollutants, indicating a smaller amount of degradable compounds from the aged waste.
In addition, aged leachates can contain high levels of chemically reduced compounds, such as ammonia,
and high chlorides because of the anaerobic environment of the landfill. However, using these indicator
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parameters alone does not take into account any refuse-filling variables, such as processing of wastes prior
to disposal and fill depth. To compensate for these additional variables, researchers examined ratios of
leachate parameters over time (see reference 13). One such ratio is the ratio of BOD5 to COD in the
leachate. Leachates from younger landfills typically exhibit BOD5 to COD ratios of approximately 0.8,
while older landfills exhibit a ratio as low as 0.1. The decline in the BOD5 to COD ratio with age is due
primarily to the readily decomposable material (phenols, alcohols) degrading faster than the more
recalcitrant compounds (heavy molecular weight organic compounds). As a result, as the landfill ages the
BOD5 of the leachate will decrease faster than the COD. Other ratios examined that reportedly decrease
overtime include the following: volatile solids to fixed solids, volatile acids to TOC, and sulfate to chloride
(see reference 13).
It is common to find that the sum of individual organic contaminants does not always match the measured
TOC and/or COD value. Compounds that comprise this difference are not always readily identified due
to the complex nature of leachate and due to the presence of other organic compounds found in leachate.
Myriad organic compounds exist in decomposing refuse and most of the organics in leachate are soluble.
Reportedly, free volatile acids constitute the main organic fraction in leachate (see reference 13). However,
other organic compounds have been identified in landfill leachates including carbohydrates, proteins, and
humic and fulvic-like substances. Gaps in mass balance results are typically attributed to these compounds.
Responses to EPA's Detailed Questionnaire indicate that 1,625 in-scope landfills collect leachate at a
median daily flow of 6,000 gallons per day. In 1992, in-scope landfills in the U. S. generated approximately
7.2 billion gallons of landfill leachate. Of this, approximately 1.6 billion gallons were treated on site, 719
million gallons were treated off site, 3.7 billion gallons were sent untreated to POTWs, 417 million gallons
were sent untreated to a surface water, 348 million gallons were recycled back to the landfill, and 358
million gallons were treated or disposed by other methods, such as off-site treatment at another landfill
wastewater treatment system or a Centralized Waste Treatment facility, deep well inj ection, incineration,
evaporation, or land application.
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6.3.1.1.1 Additional Sources of Non-Hazardous Leachate Characterization Data
Most of the existing literature regarding non-hazardous landfill leachate characteristics resulted from studies
taken at an isolated range of municipal landfills in the 1970s and 1980s. Data presented in these reports
on pollutant concentrations found in leachate are typically expressed in ranges due to the variability of
leachate from various landfills. The range of pollutant concentration values, as well as the lack of specific
information on factors affecting leachate results (e.g., sampling methods, analytical methods, landfill waste
types, etc.) limit the usefulness of these data. However, these data are mentioned as additional background
information in support of EPA's characterization activities. Table 6-5 presents a summary of available
municipal leachate characteristic data from the following sources:
• Five published papers: George, 1972; Chian and DeWalle, 1977; Metry and Cross, 1977;
Cameron, 1978; and Shams-Korzani andHenson, 1993.
McGinley, Paul M. and Kmet, P. "Formation, Characteristics, Treatment and Disposal of Leachate
from Municipal Solid Waste Landfills." Wisconsin Department of Natural Resources Special
Report, August 1984, and
Sobotka & Co., Inc. Case history data compiled and reported to U. S. EPA's Economic Analysis
Branch, Office of Solid Waste, July 1986.
The variability and high pollutant concentrations in older landfill leachate characterization data can be
attributed to landfills that accepted waste prior to the enactment of the Resource Conservation and
Recovery Act (RCRA) in 1980. Landfills in operation prior to this date may have disposed of a multitude
of different industrial and/or toxic wastes in addition to municipal solid waste. The disposal of these high-
strength wastes could account for the large variability observed in leachate characteristics data collected
from municipal landfills in this period. After the promulgation of RCRA, EPA established controls that
specified the type and characteristics of wastes that may be received by either a hazardous (Subtitle C) or
non-hazardous (Subtitle D) facility (see Chapter 3: Section 3.1 for the discussion on regulatory history).
EPA has also mandated other control measures, such as leachate collection systems, under RCRA for both
types of landfills. By instituting the acceptance criteria and leachate control standards under RCRA, the
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characteristics of the leachate from both hazardous and non-hazardous landfills do not vary as greatly as
observed in landfills prior to 1980. EPA's data shows that RCRA regulations have resulted in smaller
concentration ranges for pollutants from landfills. EPA did observe pollutant variability in the data it
collected; however, the variability was not as great as found in the data from older literature sources.
6.3.1.2 Landfill Gas Condensate
Landfill gas condensate forms in the collection lines used to extract and vent landfill gas. Condensate
collects at low points in the gas collection lines and landfill facilities usually pump it to the on-site wastewater
hoi ding tank or treatment system. Responses to EP A's Detailed Questionnaire indicate that 158 in-scope
landfills collect landfill gas condensate at a median daily flow of 343 gallons per day. In 1992, in-scope
landfills in the U.S. generated approximately 23 million gallons of landfill gas condensate. Of this,
approximately 20 million gallons were treated on site, 1.7 million gallons were treated off site, and 0.8
million gallons were sent untreated to POTWs. Of the 155 facilities collecting gas condensate, 66
commingle condensate with leachate for treatment on site, 79 facilities do not treat the condensate on site,
and 10 facilities treat landfill gas condensate separately from other landfill generated wastewater.
Landfill gas condensate represents a small amount of the total wastewater flow for the industry. Hazardous
waste landfills produce 9 million gallons/year of gas condensate, or about 4 percent of the leachate flow
volume. Municipal solid waste landfills produce 14 million gallons/year of gas condensate, or about 0.2
percent of the leachate flow volume.
Of the 37 respondents to the Detailed Questionnaire that collect landfill gas condensate, five facilities treat
the condensate separately from leachate. These facilities treated landfill gas condensate with one or more
of the following technologies: equalization, neutralization, oil-water separation, granular activated carbon,
and air stripping. All five facilities discharged the treated waste stream indirectly to a POTW. Table 6-6
presents landfill gas condensate monitoring data provided in the Detailed Questionnaire from two facilities
that collect and treat landfill gas condensate separately from other landfill generated wastewater. Facility
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16012 presented landfill gas condensate monitoring data after treatment by hydrocarbon/aqueous phase
separation and caustic neutralization, and facility 16015 presented monitoring data after treatment by
equalization, caustic neutralization, and carbon adsorption.
6.3.1.3 Drained Free Liquids
Drained free liquids are liquids drained from containerized waste prior to landfilling. Wastewater
characteristics and volume of drained free liquids vary greatly depending upon the contents and origin of
the waste. However, they will have similar characteristics to the containerized waste and, therefore, similar
characteristics to landfill leachate. Drained free liquids include other wastewater generated by waste
processing activities, such as waste stabilization. Waste stabilization includes the chemical fixation or
solidification of the solid waste. Wastewater generated from these activities includes decant from the waste
treated and any associated rinse waters. This waste processing wastewater is collected separately and then
combined with leachate and other landfill operation wastewater for treatment at the wastewater treatment
facility.
Responses to EPA's Detailed Questionnaire indicate that 25 in-scope landfills collect drained free liquids
at a median daily flow of 3 gallons per day. In 1992, in-scope landfills in the U.S. generated approximately
0.5 million gallons of drained free liquids. Of this, approximately 715 gallons were treated on site and
47,000 gallons were treated or disposed by other methods such as treatment by a CWT or deep well
injection.
6.3.1.4 Truck and Equipment Washwater
Landfill facilities generate truck and equipment washwater during either truck or equipment washes at the
landfill. Depending on the type and usage of the vehicle/equipment cleaned and the type of landfill, the
washwater volume and characteristics can vary greatly. For hazardous and non-hazardous landfill facilities,
washwater will typically be more dilute in strength in comparison to typical leachate characteristics and
contain mostly solids. Insoluble solids, consisting of mostly inorganics, metals, and low concentrations of
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organic compounds are the primary source of contaminants in the washwater. Since truck and equipment
washwater tends to contain the same constituents as the waste being landfilled and are similar in
characteristic to the landfill leachate, they are typically combined for treatment with leachate and other
landfill generated wastewater.
Responses to EPA's Detailed Questionnaire indicate that 356 in-scope landfills collect truck and equipment
washwater at a median daily flow of 141 gallons per day. In 1992, in-scope landfills in the U.S. generated
approximately 101 million gallons of truck and equipment washwater. Of this, approximately 38 million
gallons were treated on site, 9 million gallons were sent untreated to POTWs, 1.3 million gallons were
either treated off site, recycled back to the landfill, or sent untreated to a surface water, and 53 million
gallons were treated or disposed by other methods, such as off-site treatment at another landfill wastewater
treatment system or a Centralized Waste Treatment facility, deep well injection, incineration, evaporation,
or land application.
Floor washings are also generated during routine cleaning and maintenance of landfill facilities. Responses
to EPA's Detailed Questionnaire indicate that 68 in-scope landfills collect floor washings at a median daily
flow of 985 gallons per day. In 1992, in-scope landfills in the U.S. generated approximately 45 million
gallons of floor washings. Of this, approximately 6.4 million gallons were treated on site, 3.3 million gallons
were sent untreated to POTWs, and 35 million gallons were treated or disposed by other methods, as
discussed above.
6.3.2 Pollutant Parameters Analyzed at EPA Sampling Episodes
EPA conducted 19 sampling episodes at 18 landfill facilities. The Agency conducted five episodes at
hazardous landfill facilities and 13 at non-hazardous facilities. EPA conducted one-day sampling episodes
for the purpose of collecting raw wastewater samples to characterize landfill generated wastewater.
Samples collected during the week-long sampling episodes included raw wastewater samples as well as
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intermediate and effluent samples to evaluate the entire wastewater treatment system. Chapter 4 discusses
these data collection activities in further detail.
Table 6-7 presents the pollutants analyzed at the one-day and week-long sampling episodes. EPA
analyzed for a total of 470 pollutants in the raw wastewater, intermediate, and treated effluent waste stream
samples, including 232 toxic and nonconventional organic compounds, 69 toxic and nonconventional
metals, 4 conventional pollutants, and 165 toxic and nonconventional pollutants including pesticides,
herbicides, dioxins, and furans. The list of pollutants analyzed are included under the following analytical
methods: method 1613 for dioxins/furans, method 1620 for metals, method 1624 for volatile organics,
method 1625 for semivolatile organics, and methods 1656, 1657, and 1658 for pesticides/herbicides, as
well as classical wet chemistry methods.
Table 6-8 presents the list of pollutants analyzed at EPA sampling episodes by subcategory and episode
number and whether EPA detected the pollutant in the facility's raw wastewater. If EPA did not detect
a pollutant at a facility, Table 6-8 lists an ND (non-detect) in the appropriate row. If EPA did detect a
pollutant at a facility, Table 6-8 lists a blank, and in cases where EPA did not sample for a pollutant at a
facility, Table 6-8 lists a dash.
EPA collected composite samples at the week-long sampling events at episodes 4626,4667,4687,4690,
4721, and 4759, while EPA collected grab samples at the remaining 12 one-day sampling events. The
Agency developed a preliminary list of pollutants of interest by eliminating those pollutants that EPA never
detected at any facility in a subcategory from the initial list of 470 pollutants. For the Non-Hazardous
subcategory, EPA sampling never detected 316 pollutants in the raw wastewater at Subtitle D municipal
facilities and 324 pollutants in the raw wastewater at Subtitle D non-municipal facilities. For the Hazardous
subcategory, EPA sampling never detected 250 pollutants in the raw wastewater. Therefore, out of the
470 pollutants initially analyzed for, EPA detected 154 pollutants at least once at Subtitle D municipal
facilities and 146 pollutants at least once at Subtitle D non-municipal facilities. For the Hazardous
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subcategory, EPA detected 220 pollutants at least once at hazardous facilities. Using the editing criteria
presented in Chapter 7, the Agency reduced this preliminary list of pollutants of interest to the final list of
32 pollutants of interest for the Non-Hazardous subcategory (32 pollutants of interest for Subtitle D
municipal facilities and 9 pollutants of interest for Subtitle D non-municipal facilities) and 63 pollutants of
interest for the Hazardous subcategory. Tables 6-9 and 6-10 present the median concentration for the
pollutants of interest for both subcategories.
6.3.3 Raw Wastewater Characterization Data
In order to characterize wastewater from the Landfills industry, EPA compiled raw wastewater data from
EPA sampling, the Detailed Questionnaire, the Detailed Monitoring Questionnaire, and the Centralized
Waste Treatment Industry (CWT) database.
EPA reviewed each data source to determine if the data was representative of landfill generated
wastewater. First, EPA selected only those sample points corresponding to raw wastewater. Second,
EPA used several criteria to eliminate sampling data not considered representative of raw landfill
wastewater. In characterizing landfill raw wastewater, EPA included only sampled wastewater containing
at least 85 percent leachate and/or gas condensate. Therefore, EPA eliminated raw wastewater data that
consisted mainly of wastewater that is not subj ect to this rule (e.g., storm water, ground water, or sanitary
wastewater). Also, EPA eliminated wastewater data containing industrial process wastewater. This
eliminated the possibility of finding pollutants that may not have originated in a landfill.
Next, EPA grouped all data points according to the classification of the landfill, e.g. municipal solid waste,
hazardous waste, or Subtitle D non-municipal solid waste. Many facilities provided data from both
technical questionnaires (the Detailed Questionnaire and the Detailed Monitoring Questionnaire), and in
several instances, EPA conducted sampling at a facility that also provided data in the technical
questionnaires. In these cases, EPA combined all data from the facility to obtain a facility average
concentration for each pollutant. For each subcategory, EPA gathered the facility averages for all pollutants
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into a file called the Raw Wastewater Source File. EPA then calculated the median of the facility average
concentrations in the Source File to determine the median raw wastewater concentration for each pollutant
in the subcategory. Tables 6-9 and 6-10 present the median values for the Non-Hazardous and Hazardous
subcategories, respectively. EPA refers to this file as the Median Raw Wastewater Concentration File.
Tables 6-11 through 6-13 present, by subcategory, the minimum and maximum of the facility average
concentrations in the Raw Wastewater Source File, along with the number of observations and number of
non-detect values. Note that although EPA included CERCLA data in the characterization of hazardous
landfill leachate for the proposal, EPA did not include CERCLA data for raw wastewater characterization
for the final rule. The CERCLA data consists primarily of contaminated ground water and, since
contaminated ground water is not subj ect to the regulations, EPA determined that CERCLA data should
not be used for hazardous landfill wastewater characterization. Therefore, the raw wastewater
characterization data for the Hazardous subcategory presented in Tables 6-11 through 6-13 do not include
CERCLA data.
6.3.4 Conventional, Toxic, and Selected Nonconventional Pollutant Parameters
The Clean Water Act defines different types of pollutant parameters used to characterize raw wastewater.
These parameters include conventional, nonconventional, and toxic pollutants. Conventional pollutants
found in landfill generated wastewater include the following:
Total Suspended Solids (TSS)
5-day Biochemical Oxygen Demand (BOD5)
pH
Oil and Grease (measured as Hexane Extractable Material)
Total solids in wastewater are defined as the residue remaining upon evaporation of the liquid at just above
its boiling point. TSS is the portion of the total solids that can be filtered out of solution using a 1 micron
filter. Raw wastewater TSS in leachate is a function of the type and form of wastes accepted for disposal
6-18
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at landfill facilities. Landfill design and operational parameters such as depth of fill, compaction, and
capping also influence the concentration of TSS. BOD5 is one of the most important gauges of pollution
potential of a wastewater and varies with the amount of biodegradable matter that can be assimilated by
biological organisms under aerobic conditions. The nature of the chemicals contained in landfill generated
wastewater affects the BOD5 due to the differences in susceptibility of different molecular structures to
microbiological degradation. Landfill generated wastewater containing compounds with lower susceptibility
to decomposition by microorganisms tends to exhibit lower BOD5 values, even though the total organic
loading may be much higher when compared to wastewater exhibiting substantially higher BOD5 values.
For example, a landfill generated wastewater may have a low BOD5 value while, at the same time,
exhibiting a high TOC or COD concentration. Raw wastewater BOD5 values can vary depending on the
waste deposited in the landfill and the landfill age, as noted previously in Section 6.3.1.1.
The pH of a solution is a unitless measurement which represents the acidity or alkalinity of a wastewater
stream (or aqueous solution) based on the disassociation of the acid or base in the solution into hydrogen
(FT) or hydroxide (OH") ions, respectively. Raw wastewater pH can be a function of the waste deposited
in a landfill but can vary depending on the conditions within the landfill, as noted previously in Section
6.3.1.1. Fluctuations in pH are controlled readily by equalization followed by neutralization. Control of
pH is necessary to achieve proper removal of pollutants in treatment systems such as metals precipitation
and biological treatment systems.
Oil and grease also may be present in selected landfill generated wastewater. Proper control of oil and
grease is important because it can interfere with the operation of certain wastewater treatment system
processes such as chemical precipitation and the settling operations in biological systems. If it is not
removed prior to discharge, excessive levels of oil and grease can interfere with the operation of POTWs
and can create a film along surface waters, disrupting the biological activities in those waterways.
6-19
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Table 6-11 presents the minimum and maximum facility average concentration data for TSS, BOD5, and
oil and grease for each landfill subcategory and the minimum and maximum facility average values for pH.
EPA obtained the minimum and maximum values presented for each pollutant in the table from the Raw
Wastewater Source File for both subcategories. The Source File contains many pollutants which EPA
detected at least once in a subcategory but were not necessarily selected as pollutants of interest. EPA
discusses the selection of pollutants of interest in Chapter 7.
EPA also used certain classical nonconventional pollutants for the purposes of raw wastewater
characterization. These pollutant parameters include the following: ammonia as nitrogen, nitrate/nitrite, total
dissolved solids, total organic carbon, total phenols, chemical oxygen demand, amenable cyanide, and total
phosphorus. All of these pollutants are pollutants of interest for either the Non-Hazardous or Hazardous
subcategory, with the exception of total phosphorus. For the purposes of presenting raw wastewater
characterization data, EPA included these nonconventional pollutants with the conventional pollutants for
each landfill subcategory in Table 6-11.
6.3.5 Toxic Pollutants and Remaining Nonconventional Pollutants
Table 6-12 presents the minimum and maximum facility-average concentration data for metals and toxic
pollutants for the Non-Hazardous and Hazardous subcategories. EPA obtained the minimum and maximum
values presented for each pollutant in the table from the Raw Wastewater Source File for both
subcategories. Most of the pollutants included in Table 6-12 are pollutants of interest for either the Non-
Hazardous or Hazardous subcategory. EPA detected a wide range of metals in raw wastewater from
landfill facilities in both subcategories including both toxic pollutant and nonconventional pollutant metals.
Table 6-13 presents the minimum and maximum facility average concentration data for organic toxic and
nonconventional pollutants for the two subcategories. EPA obtained the minimum and maximum values
presented for each pollutant in the table from the Raw Wastewater Source File for both subcategories.
All pollutants included in Table 6-13 are pollutants of interest for either the Non-Hazardous or Hazardous
6-20
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subcategory. EPA detected a wide range of organic pollutants in raw wastewater at landfill facilities in both
subcategories. Many of these are common organic pollutants found in municipal or commercial waste.
6.3.6 Raw Wastewater at Subtitle D Non-Hazardous Landfills
6.3.6.1 Raw Wastewater at Subtitle D Municipal Landfills
Raw wastewater generated at Subtitle D municipal landfills contained a range of conventional, toxic, and
nonconventional pollutants. This wastewater also contained significant concentrations of common
nonconventional metals such as iron, magnesium, and manganese. These metals are naturally occurring
elements found in raw water, and the presence of these metals in landfill raw wastewater can be attributed
to background levels in the water source used at the facility. Generally, toxic heavy metals were found at
relatively low concentrations. EPA did not find toxic metals such as arsenic, cadmium, mercury, and lead
at treatable levels in any of EPA's sampling episodes. Typical organic pollutants found in leachate included
2-butanone (methyl ethyl ketone) and 2-propanone (acetone), which are common solvents used in
household products (such as paints and nail polish), and common industrial solvents such 4-methyl-2-
pentanone and 1,4-dioxane. EPA detected only trace concentrations of only two pesticides (dichloroprop
and disulfoton) in wastewater from municipal landfills. Additionally, EPA's data showed high loads of
organic acids such as benzoic acid and hexanoic acid resulting from anaerobic decomposition of solid
waste.
EPA identified 32 pollutants of interest for Subtitle D municipal landfills, including the following: eight
conventional/nonconventional pollutants, six metals, 16 organics and pesticides/herbicides, and two
dioxins/furans. In the Agency's sampling episodes, EPA never detected 316 pollutants, while
approximately 122 pollutants were detected but were not present above the minimum level.
6.3.6.2 Raw Wastewater at Subtitle D Non-Municipal Landfills
A subset of the Subtitle D Non-Hazardous landfill subcategory is the Subtitle D non-municipal landfill.
6-21
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These types of landfills do not accept municipal solid waste or household refuse. Rather, these facilities
accept a number of different types of non-hazardous, non-municipal solid wastes. Waste types accepted
at Subtitle D non-municipal facilities include, but are not limited to, municipal incinerator ash, industrial non-
hazardous wastes and sludges, wastewater treatment plant sludge, yard waste, and construction and
demolition wastes.
EPA identified 9 pollutants of interest for Subtitle D non-municipal landfills, including the following: eight
conventional/nonconventional pollutants and one metal. In the Agency's sampling episodes, EPA never
detected 324 pollutants, while 136 pollutants were detected but were not present above the minimum level.
Many Subtitle D non-municipal facilities accept two or more of the non-municipal waste types discussed
above. Certain facilities accept only one type of waste and are referred to as "monofills". EPA performed
an analysis to determine if significant differences existed in raw wastewater characteristics from Subtitle D
municipal landfills and these monofill facilities. As discussed in Chapter 5, Section 5.3.1, EPA analyzed
characterization data collected at municipal solid waste landfills and monofills as part of EPA's sampling
program and analyzed data from several published reports, including prior EPA studies, analyzing
construction and demolition monofills, ash monofills, and co-disposal sites. EPA evaluated these data to
identify any pollutants found at significant concentrations in monofills that were not found in Subtitle D
municipal landfills.
Based on a review of these data sources, EPA observed that the pollutants present in raw wastewater from
monofills were not significantly different from those found in Subtitle D municipal landfills, and, in fact,
pollutants present in monofills were a subset of those pollutants found at municipal solid waste landfills. In
addition, concentrations of virtually all pollutants found in ash, sludge, and construction and demolition
waste monofills were significantly lower than those found in raw wastewater from Subtitle D municipal
landfills (see Chapter 5, Tables 5-3 and 5-4). EPA acknowledges that there were no organic pollutants
of interest detected at Subtitle D non-municipal landfills, and that some monofills, such as ash monofills, may
6-22
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have a low organic content and, therefore, may not be able to use the selected BPT/BAT treatment
technology (biological treatment) to treat the wastewater. However, EPA concluded that these Subtitle
D non-municipal facilities can meet the BPT/BAT limitations using available technologies. These treatment
systems may be installed at costs comparable to those for biological treatment. As discussed in Chapter
11, EPA established equivalent effluent limitations for all Subtitle D non-hazardous landfills.
6.3.6.3 Dioxins and Furans in Raw Wastewater at Subtitle D Non-Hazardous Landfills
There are 210 isomers of chlorinated dibenzo-p-dioxins (CDD) and chlorinated dibenzofurans (CDF).
EPA is primarily concerned with the 2,3,7,8-substituted congeners, of which EPA considers 2,3,7,8-
TCDD to be the most toxic and is the only one that is a toxic pollutant. EPA considers non- 2,3,7,8-
substituted congeners to be less toxic, in part, because they are not readily absorbed by living organisms.
Dioxins and furans may be formed as by-products in certain industrial unit operations related to petroleum
refining, pesticide and herbicide production, paper bleaching, and production of materials involving
chlorinated compounds. Dioxins and furans are not water-soluble and are not expected to leach out of
non-hazardous landfills in significant quantities.
As part of EPA sampling episodes at 13 non-hazardous landfills, EPA analyzed raw wastewater samples
for 17 congeners of dioxins and furans. Table 6-14 presents the results of the data analyses. EPA also
used additional raw leachate data from ash monofills from previous EPA studies, as discussed in Chapter
5, Section 5.3.1. EPA found low levels of OCDD, HpCDD, and HxCDD in raw wastewater at several
landfills. The Agency did not detect the most toxic dioxin congener, 2,3,7,8-TCDD, in raw wastewater
at a Subtitle D landfills. All concentrations of dioxins and furans in raw, untreated wastewater were well
below the Universal Treatment Standards for F039 wastes (multi-source leachate) in 40 CFR 268.48,
which establish minimum concentration standards based on based on the Best Demonstrated Available
Treatment Technology (BOAT)1. At the concentrations found in raw landfill wastewater, EPA expects
EPA bases UTS on the BDAT for each listed hazardous waste. BDAT represents the treatment technology that EPA concludes is the most
effective for treating a particular waste that is also readily available to generators and treaters.
6-23
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dioxins and furans to partition to the biological sludge as part of the BPT/BAT treatment technologies. EPA
included the partitioning of dioxins and furans to the sludge in the evaluation of treatment benefits and water
quality impacts. EPA sampling data and calculations conclude that the concentrations of dioxins and furans
present in the wastewater would not prevent the sludge from being redeposited in a non-hazardous landfill.
6.3.7 Raw Wastewater at Subtitle C Hazardous Landfills
The Agency used data from EPA sampling episodes and industry supplied data obtained through the
technical questionnaires to characterize raw wastewater from Subtitle C hazardous landfills. Wastewater
generated at Subtitle C landfills contained a wide range of conventional, toxic, and nonconventional
pollutants at treatable levels. There were a significantly greater number of pollutants found in hazardous
landfill raw wastewater in comparison to non-hazardous landfills. Pollutants which were common to both
untreated non-hazardous and hazardous wastewater were generally an order of magnitude higher in
concentration in hazardous landfill wastewater. The list of pollutants of interest for the Hazardous
subcategory (presented in Table 6-10), which includes 63 parameters, reflects the more toxic nature of
hazardous landfill wastewater and the wide range of industrial waste sources. Chapter 7 discusses the
methodology for determining pollutants of interest. For further discussion on the differences between
hazardous and non-hazardous landfill leachate, see Chapter 5, Section 5.3.1.
Pollutants typical of raw leachate from hazardous facilities and found at higher median concentrations than
at Subtitle D facilities included arsenic, chromium, copper, nickel, and zinc. EPA did not detect cadmium,
lead, and mercury at treatable concentrations in the raw wastewater for any of the hazardous landfills
sampled during EPA sampling episodes.
EPA identified a total of 63 pollutants of interest for Subtitle C hazardous landfills, including the following:
11 convent!onal/nonconventional pollutants, 11 metals, 37 organics and pesticides/herbicides, and 4
dioxins/furans. EPA sampling episodes never detected 250 pollutants, while approximately 157 pollutants
were detected but were not present above the minimum level.
6-24
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6.3.7.1 Dioxins and Furans in Raw Wastewater at Subtitle C Hazardous Landfills
As part of EPA sampling episodes at two in-scope Subtitle C landfills and two in-scope pre-1980 industrial
landfills, EPA analyzed raw leachate samples for 17 congeners of dioxins and furans. Table 6-15 presents
the results of these analyses. As in the Non-Hazardous subcategory, EPA did not detect the most toxic
dioxin congener, 2,3,7,8-TCDD, at any in-scope hazardous/industrial landfill. EPA found low levels of
several congeners in raw wastewater at many of the sampled landfills. Low levels of OCDD, OCDF,
HpCDD, and HpCDF were detected in over half of the landfills sampled. However, all concentrations of
dioxins and furans in raw, untreated wastewater were well below the Universal Treatment Standards (UTS)
for F039 wastes (multi-source leachate) in 40 CFR 268.48, which establish minimum concentration
standards based on BDAT. At the concentrations found in raw landfill wastewater, EPA expects dioxins
and furans to partition to the biological sludge as part of the BPT/BAT treatment technologies.
6-25
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Table 6-1: Wastewater Generated in 1992: Hazardous Subcategory (gallons)
Discharge
Type
Indirect
Zero
Wastewater
Type
Leachate
Gas Condensate
Truck/Equipment
Washwater
Floor Washings
Storm Water
Total Indirect
Leachate
Gas Condensate
Drained Free
Liquids
Truck/Equipment
Washwater
Floor Washings
Contaminated
Ground Water
Storm Water
Total Zero
Subcategory Total
Treated
On-Site
37,600,000
772,000
1,220,000
706,000
0
40,298,000
18,100,000
8,390,000
0
28,400
0
28,700,000
0
55,218,400
95,516,400
Treated
Off-Site
0
0
0
0
0
0
20,600,000
0
0
513,000
0
0
2,300,000
23,413,000
23,413,000
Untreated to
POTW
0
0
101,000
0
4,740,000
4,841,000
0
0
0
0
0
0
30,700,000
30,700,000
35,541,000
Untreated
to Surface Water
0
0
0
0
294,000,000
294,000,000
0
0
0
0
0
0
662,000,000
662,000,000
956,000,000
Recycled
Flow
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Other
0
0
0
0
0
0
169,000,000
0
47,000
50,300,000
35,000,000
0
0
254,347,000
254,347,000
Oi
to
Oi
-------
Table 6-2: Wastewater Generated in 1992: Non-Hazardous Subcategory Municipal Facilities (gallons)
Discharge
Type
Direct
Indirect
Wastewater
Type
Leachate
Gas Condensate
Drained Free Liquids
Truck/Equipment
Washwater
Floor Washings
Contaminated
Ground Water
Storm Water
Total Direct
Leachate
Gas Condensate
Truck/Equipment
Washwater
Floor Washings
Contaminated
Ground Water
Storm Water
Treated
On-Site
565,000,000
1,570,000
715
15,300,000
4,890,000
163,000,000
348,000,000
1,097,760,715
777,000,000
9,700,000
20,700,000
794,000
226,000,000
3,710,000,000
Treated
Off-Site
782,000
0
0
0
0
0
0
782,000
7,640,000
65,900
0
0
0
0
Untreated to
POTW
804,000
0
0
0
0
0
0
804,000
3,640,000,000
793,000
9,060,000
3,320,000
0
677,000,000
Untreated
to Surface Water
167,000,000
0
0
0
0
0
3,430,000,000
3,597,000,000
0
0
594,000
0
0
3,890,000,000
Recycled
Flow
49,000
0
0
0
0
0
0
49,000
29,800,000
0
0
0
0
85,400,000
Other
94,400,000
0
0
0
0
0
0
94,400,000
5,870,000
19,700
0
0
0
1,060,000,000
to
-------
Table 6-2: Wastewater Generated in 1992: Non-Hazardous Subcategory Municipal Facilities (gallons) (cont'd)
Discharge
Type
Indirect
Zero
Wastewater
Type
Total Indirect
Leachate
Gas Condensate
Truck/Equipment
Washwater
Contaminated
Ground Water
Storm Water
Total Zero
Subcategory Total
Treated
On-Site
4,744,194,000
170,000,000
0
425,000
296,000,000
3,930,000
470,355,000
6,312,309,715
Treated
Off-Site
7,705,900
561,000,000
1,610,000
0
0
0
562,610,000
571,097,900
Untreated to
POTW
4,330,173,000
0
0
0
0
0
0
4,330,977,000
Untreated
to Surface Water
3,890,594,000
0
0
0
0
137,000,000
137,000,000
7,624,594,000
Recycled
Flow
115,200,000
233,000,000
0
177,000
0
212,000,000
445,177,000
560,426,000
Other
1,065,889,700
88,600,000
0
2,990,000
0
24,700,000
116,290,000
1,276,579,700
to
oo
-------
Table 6-3: Wastewater Generated in 1992: Non-Hazardous Subcategory Non-Municipal Facilities (gallons)
Discharge
Type
Direct
Indirect
Zero
Wastewater
Type
Leachate
Storm Water
Total Direct
Leachate
Contaminated
Ground Water
Storm Water
Total Indirect
Leachate
Truck/Equipment
Washwater
Total Zero
Subcategory Total
Treated
On-Site
0
0
0
47,400,000
0
19,800,000
67,200,000
56,700
2,000
58,700
67,258,700
Treated
Off-Site
0
0
0
0
0
0
0
129,000,000
0
129,000,000
129,000,000
Untreated to
POTW
0
0
0
57,000,000
4,120,000
0
61,120,000
0
0
0
61,120,000
Untreated
to Surface Water
250,000,000
4,900,000
254,900,000
0
0
0
0
0
0
0
254,900,000
Recycled
Flow
0
0
0
85,100,000
0
0
85,100,000
0
0
0
85,100,000
Other
0
0
0
0
0
43,100,000
43,100,000
0
0
0
43,100,000
to
VO
-------
Table 6-4: Quantity of In-Scope Wastewater Generated in 1992 (gallons)
Discharge
Status
Direct
Indirect
Zero
Total
Sub category
Non-Hazardous
Subtitle D
Municipal
849,679,000
4,509,255,000
1,058,156,000
6,417,090,000
Subtitle D
Non-Municipal
249,659,000
189,511,000
128,633,000
567,803,000
Subtitle D
Facilities
143
756
338
1,237
Hazardous
Subtitle C
0
40,361,000
302,112,000
342,473,000
Subtitle C
Facilities
0
6
139
145
Total
Wastewater
Generated
1,099,338,000
4,739,127,000
1,488,901,000
7,327,366,000
Total
Number of
Facilities
143
762
477
1,382
-------
Table 6-5: Contaminant Concentration Ranges in Municipal Leachate as Reported in Literature Sources
Pollutant
Parameter
Conventional
BOD
pH
TSS
Non-Conventional
Alkalinity
Bicarbonate
Chlorides
COD
Fluorides
Hardness
NH3 -Nitrogen
NO3 -Nitrogen
Organic Nitrogen
Ortho-Phosphorus
Sulfates
Sulfide
TOC
TDS
Total-K -Nitrogen
Total Phosphorus
Total Solids
Metals
Aluminum
Arsenic
Barium
Beryllium
Boron
Cadmium
Calcium
Total Chromium
Copper
Cyanide
Iron
Lead
Magnesium
Manganese
Mercury
Molybendum
Nickel
Potassium
Sodium
Titanium
Vanadium
Zinc
George
(1972)
9 - 54,610
3.7 - 8.5
6 - 2,685
0 - 20,850
34 - 2,800
0 - 89,520
0 - 22,800
0 - 1,106
0 - 1,300
1 - 1,826
0 - 42,276
0 - 1,416
1 - 154
5 - 4,080
0 - 9.9
0.2 - 5,500
0 - 0.5
16.5 - 15,600
0.06 - 1,400
2.8 - 3,770
0 - 7,700
0 - 1,000
Chain/DeWalle
(1977)
81 - 33,360
3.7 - 8.5
10 - 700
0 - 20,850
4.7 - 2,467
40 - 89,520
0 - 22,800
0 - 1,106
0.2 - 1,0.29
6.5 - 85
1 - 1,558
256 - 28,000
584 - 44,900
0 - 130
0 - 59,200
0.03 - 17
60 - 7,200
0 - 9.9
0 - 2,820
<0.10 - 2.0
17 - 15,600
0.09 - 125
28 - 3,770
0 - 7,700
0 - 370
Metry/Cross
(1977)
2,200 - 720,000
3.7 - 8.5
13 - 26,500
310 - 9,500
3,260 - 5,730
47 - 2,350
800 - 750,000
35 - 8,700
0.2 - 845
4.5 - 18
2.4 - 550
0.3 - 136
20 - 1,370
100 - 51,000
240 - 2,570
0.12 - 1,700
64 - 547
13
28 - 3,800
85 - 3,800
0.03 - 135
Cameron
(1978)
9 - 55,000
3.7 - 8.5
0 - 20,900
34 - 2,800
0 - 9,000
0 - 2.13
0 - 22,800
0 - 1,106
0 - 154
0 - 1,826
0 - 0.13
0 - 42,300
0 - 122
0 - 11.6
0 - 5.4
0 - 0.3
0.3 - 73
0 - 0.19
5 - 4,000
0 - 33.4
0 - 10
0 - 0.11
0.2 - 5,500
0 - 5.0
16.5 - 15,600
0.06 - 1,400
0 - 0.064
0 - 0.52
0.01 - 0.8
2.8 - 3,770
0 - 7,700
0 - 5.0
0 - 1.4
0 - 1,000
Wisconsin Report
(20 Sites)
ND - 195,000
5 - 8.9
2 - 140,900
ND - 15,050
2 - 11,375
6.6 - 97,900
0 - 0.74
52 - 225,000
ND - 1,850
ND - 30,500
584 - 50,430
2 - 3,320
ND - 234
ND - 85
ND - 70.2
ND - 12.5
ND - 0.36
0.867 - 13
ND - 0.04
200 - 2,500
ND - 5.6
ND - 4.06
ND - 6
ND - 1,500
0 - 14.2
ND - 780
ND - 31.1
ND - 0.01
0.01 - 1.43
ND - 7.5
ND - 2,800
12 - 6,010
<0.01
0.01
ND - 731
Sobotka Report
(44 Sites)
7 - 21,600
5.4 - 8.0
28 - 2,835
0 - 7,375
120 - 5,475
440 - 50,450
0.12 - 0.790
0.8 - 9,380
11.3 - 1,200
0 - 5,0.95
4.5 - 78.2
8 - 500
5 - 6,884
1,400 - 16,120
47.3 - 938
1,900 - 25,873
0.010 - 5.07
0 - 0.08
0.01 - 10
0.001 - 0.01
0 - 0.1
95.5 - 2,100
0.001 - 1.0
0.003 - 0.32
0 - 4.0
0.22 - 1,400
0.001 - 1.11
76 - 927
0.03 - 43
0 - 0.02
0.01 - 1.25
30 - 1,375
0.01 - 67
All concentrations in mg/L, except pH (std units).
ND = Non-detect
6-31
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Table 6-6: Landfill Gas Condensate (from Detailed Questionnaire)
QID
16012
16015
Pollutant
Conventional
Oil & Grease
Metals
Arsenic
Organics
1,2-Benzenedicarboxylic Acid, Diethyl Ester
1 ,3 -Butadiene, 1 , 1 ,2,3 ,4,4-Hexachloro-
1 ,3 -Dichlorobenzene
1 ,4-Dichlorobenzene
2,4,6-Trichlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,6-Dinitrotoluene
2-Methyl-4,6-Dinitrophenol
2-Nitrophenol
3 ,4-Benzopyrene
3 -Methyl-4-Chlorophenol
Benz(E)Acephenenthrylene
Benzenamine, 4-Nitro-
Benzene, Nitro-
Benzene Hexachloride
Benzene, Ethyl-
Benzene, Methyl-
Benzo(Def)Phenanthrene
Bis(2-Chloroethoxy)Methane
Chloroform
Di-n-propyl Nitrosamine
Ethene, Trichloro
Ethene, Tetrachloro-
0-Chlorophenol
Residue, Non-flammable
Metals
Gold
Lead
Zinc
#0bs
1
1
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
#ND
0
0
1
1
1
1
2
2
2
2
0
2
2
1
2
1
2
1
2
2
1
2
2
0
2
1
2
0
1
2
0
Avg. Cone.
422
570
2.0
2.2
1.2
2.0
15.0
15.0
17.3
5.83
100
17.5
2.0
20.0
2.33
2.2
4.3
2.3
3.4
2.6
2.2
2.8
3.9
3.3
2.5
10.6
8.7
27.2
0.04
0.13
0.14
Unit
mg/L
ug/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
16012: Treated effluent after hydrocarbon/aqueous phase separation and caustic neutralization.
16015: Treated effluent after equalization, caustic neutralization, and carbon adsorption.
QID: Questionnaire ID number
# Obs: Number of observations
# ND : Number of non-detects
6-32
-------
Table 6-7: EPA Sampling Episode Pollutants Analyzed
P O LLUTA N T
CLA SSSICA L WET CHEMISTRY
AM ENABLE CYAN IDE
AMMONIA NITROGEN
B OD
CHLORIDE
COD
FLUORIDE
HEXANEEXTRACTABLE MA TE RIAL
HEXAVALENTCHROMIUM
NITRA TE/NITRITE
PH
RECOVERABLE OILAND GREASE
TD S
TOC
TOTAL CYAN IDE
TOTAL PHENOLS
TOTALPHOSPHORUS
TOTAL SOLID S
TOTAL SULFIDE
TSS
1613: D I OX I N S/FU RA N S
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-HPCDF
1234789-HPCDF
OCDD
OCDF
1657:PESTICIDES/HERBICIDES
A ZINPHOS ETHYL
A ZINPHOS M ETHYL
CHLORFEVINPHOS
CHLORPYRIFOS
COUM A PHOS
CROTOXYPHOS
DBF
DEM ETON A
DEM ETON B
DI AZINON
DICHLORFENTHION
DICHLORVOS
DICROTOPHOS
DIM ETHOA TE
DIOX A THION
DISULFOTON
EPN
ETHION
ETHOPROP
F AMPH UR
FENSULFOTHION
FENTHION
HEXAMETHYLPHOSPHORAM IDE
LEPTOPHO S
M A LA THION
M ERPH OS
CAS NUM POLLUTANT
1657:PESTICIDES/HERBICIDES
C-025 M ETH AM ID OPHO S
7664-41-7 M ETHYL CHLORPYRIFOS
C-002 M ETHYL PA RA THION
16887-00-6 M ETHYL TRITHION
C-004 M EVINPHOS
16984-48-8 M O N O CRO TO P H O S
C-036 NALED
18540-29-9 P ARA THION (ETH YL)
C-005 PHORATE
C-006 PHO SM ET
C-007 PHO SPH AM IDON E
C-010 PHO SPH AM IDON Z
C-012 RONNEL
57-12-5 SULFOTEPP
C-020 SULPROFOS
14265-44-2 TEPP
C-008 TERBUFOS
18496-25-8 TE TR A CH LO R V I NP H O S
C-009 TOKU THION
TRICHLORFON
1746-01-6 TRICHLORON A TE
51207-31-9 TRICRESYLPHOSPH A TE
40321-76-4 TRIM ETH Y LP H O SPH A TE
57117-41-6 1656: PESTICIDES/HERBICIDES
57117-31-4 A CEPH A TE
39227-28-6 ACIFLUORFEN
57653-85-7 ALACHLOR
19408-74-3 ALDRIN
70648-26-9 ATRAZINE
57117-44-9 BENFLURALIN
72918-21-9 ALPHA-BHC
60851-34-5 BETA -B H C
35822-46-9 G A M M A-B H C
67562-39-4 DELTA-BHC
55673-89-7 BROMACIL
3268-87-9 B R O M O X Y N I L O C TA N O A TE
39001-02-0 BUTACHLOR
CA PTA FOL
2642-71-9 CAPTAN
86-50-0 CA RB OPHENOTHION
470-90-6 A LPH A -CHLORD ANE
2921-88-2 G AM M A-CHLORD A NE
56-72-4 CHLOROBENZILA TE
7700-17-6 CHLORONEB
78-48-8 CHLOROPROPYLA TE
8065-48-3A C H LOR O TH A LO N I L
8065-48-3B D I B R O M O C H LOR OP R O P A N E
333-41-5 D A CTH AL (DCP A )
97-17-6 4,4'-DDD
62-73-7 4,4'-DDE
141-66-2 4,4'-DDT
60-51-5 DI ALLA TE A
78-34-2 DI ALLA TE B
298-04-4 DICHLONE
2104-64-5 DICOFOL
563-12-2 DIELDRIN
13194-48-8 ENDOSULFANI
52-85-7 ENDOSULFANII
115-90-2 ENDOSULF AN SULF A TE
55-38-9 ENDRIN
680-31-9 ENDRIN ALDEHYDE
21609-90-5 ENDRINKETONE
121-75-5 ETH ALFLURA LIN
150-50-5 ETRADIAZOLE
CAS NUM
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
732-1 1-6
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
5 12-56-1
30560-19-1
50594-66-6
15972-60-8
309-00-2
19 12-24-9
1861-40-1
3 19-84-6
3 19-85-7
58-89-9
3 19-86-8
314-40-9
1689-99-2
23 184-66-9
2425-06-1
133-06-2
786-19-6
5103-71-9
5103-74-2
510-15-6
2675-77-6
5836-10-2
1897-45-6
96-12-8
1861-32-1
72-54-8
72-55-9
50-29-3
230 3-16-4 A
2303-16-4B
1 17-80-6
1 15-32-2
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
6-33
-------
Table 6-7: EPA Sampling Episode Pollutants Analyzed (continued)
PO LLUTA N T
1656: PESTICIDES/HERBICIDES
FEN ARIM OL
HEPTA CHLOR
HEPTACHLOR EPOXIDE
ISODRIN
ISOPROPA LIN
KEPONE
M ETHOXYCHLOR
M ETRIB UZIN
M IREX
NITROFEN
NORFLUOR AZON
PCB -10 16
PCB -1221
PCB -1232
PCB -1242
PCB -1248
PCB -1254
PCB -1260
PEN TACHLORONITRO BENZENE
PENDAMETHALIN
CIS-PERMETHRIN
TRANS-PERMETHRIN
PERTH A NE
PROP A CHLOR
PROP A NIL
PROP A ZINE
SIM AZINE
STROB A NE
TERB A CIL
TERB UTH YLAZINE
TOX APHENE
TRIA DIM EFON
TRIFLURALIN
1658: PESTICIDES/HERBICIDES
D ALA PON
DIC AM B A
DICHLOROPROP
DINOSEB
M CP A
M CPP
PICLORA M
2,4-D
2,4-DB
2,4 ,5 -T
2,4 ,5 -TP
1 62 0 : M E TA LS
ALUM INUM
ANTIM ON Y
ARSENIC
B ARIUM
BERYLLIUM
B ISM UTH
B ORON
CADMIUM
CALCIUM
CERIUM
CHROM IUM
COB ALT
COPPER
DYSPROSIUM
ERB IUM
EUROPIUM
GAD OLINIUM
GALLIUM
CAS NUM
60 168-88-9
76-44-8
1024-57-3
465-73-6
33820-53-0
143-50-0
72-43-5
21087-64-9
2385-85-5
1836-75-5
27314-13-2
12674-1 1-2
1 1 104-28-2
11141-16-5
53469-21-9
12672-29-6
1 1097-69-1
1 1096-82-5
82-68-8
40487-42-1
61949-76-6
61949-77-7
72-56-0
1918-16-7
709-98-8
139-40-2
122-34-9
800 1-50-1
5902-51-2
5915-41-3
800 1-35-2
43121-43-3
1582-09-8
75-99-0
1918-00-9
120-36-5
88-85-7
94-74-6
7085-19-0
1918-02-1
94-75-7
94-82-6
93-76-5
93-72-1
7429-90-5
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-69-9
7440-42-8
7440-43-9
7440-70-2
7440-45-1
7440-47-3
7440-48-4
7440-50-8
7429-91-6
7440-52-0
7440-53-1
7440-54-2
7440-55-3
PO LLUTA N T
1 62 0 : M E TA LS
GERM ANIUM
GOLD
HAFNIUM
HOLM IUM
INDIUM
IODINE
IRIDIUM
IRON
LAN TH ANUM
LE A D
LITHIUM
LUTETIUM
M A GNESIUM
M ANG ANESE
M ERCURY
M OLYBDENUM
NEOD YM IUM
NICKEL
NIOBIUM
OSM IUM
P ALLAD IUM
PH OSPHORUS
PLA TINUM
POTA SSIUM
PR A SEOD YM IUM
RHENIUM
RHODIUM
RUTHENIUM
SAM ARIUM
SCA NDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TAN TALUM
TELLURIUM
TERB IUM
TH ALLIUM
THORIUM
THULIUM
TIN
TITA NIUM
TUNG STEN
URANIUM
VAN AD IUM
YTTERB IUM
YTTRIUM
ZINC
ZIRCONIUM
1624: VOLA TILE ORGANICS
1,1-DICHLOROE THANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETH ANE
1,1,1,2-TETRA CHLOROETHANE
1,1,2-TRICHLOROETH ANE
1,1,2,2-TETRA CHLOROETHANE
1,2-DIBROMOETHANE
1,2-DICHLOROETHANE
1,2-DICHLOROPROPANE
1,2,3-TRICHLOROPROP ANE
1,3-DICHLOROPROPANE
1, 4 -D I OX ANE
CAS NUM
7440-56-4
7440-57-5
7440-58-6
7440-60-0
7440-74-6
7553-56-2
7439-88-5
7439-89-6
7439-91-0
7439-92-1
7439-93-2
7439-94-3
7439-95-4
7439-96-5
7439-97-6
7439-98-7
7440-00-8
7440-02-0
7440-03-1
7440-04-2
7440-05-3
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-"-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
75-34-3
75-35-4
71-55-6
630-20-6
79-00-5
79-34-5
106-93-4
107-06-2
78-87-5
96-18-4
142-28-9
123-9 1-1
6-34
-------
Table 6-7: EPA Sampling Episode Pollutants Analyzed (continued)
PO LLUTA N T
CAS NUM
P O LLUTA N T
CAS NUM
1624: VOLA TILE ORGANICS
2-B UTANONE (M EK)
2-CHLORO-1.3-BUTADIENE
2-CHLOROETHYLVINYL ETHER
2-HEXANONE
2-METHYL-2-PROPENENITRILE
2-PROPANONE (ACETONE)
2-PROPENAL(ACROLEIN)
2-PROPEN-l-OL(ALLYLALCOHOL)
3-CHLOROPROPENE
4-METHYL-2-PENTANONE
A CRYLONITRILE
BENZENE
BROMODICHLOROMETHANE
BROM OFORM
BROMOMETHANE
CARBON DI SULFIDE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROM ETHA NE
CIS-1.3-DICHLOROPROPENE
CROTONALDEHYDE
DIB ROM O CHLOROM ETHANE
DIB ROM OM ETHANE
DIE THYL ETHER
ETHYLBENZENE
ETHYL CYAN IDE
ETHYLMETHACRYLATE
IODOMETHANE
ISOBUTYLALCOHOL
METHYLENE CHLORIDE
M -XYLENE
O+P XYLENE
TETRACHLOROETHENE
TETRACHLOROM ETHANE
TOLUENE
TRANS-1.2-DICHLOROETHENE
TRANS-1.3-DICHLOROPROPENE
TRANS-1.4-DICHLORO-2-BUTENE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL A CETA TE
VINYL CHLORIDE
1625: SEMIVOLA TILE ORGANICS
1-METHYLFLUORENE
1-METHYLPHENA NTH RENE
1-PHENYLNAPHTHALENE
1.2-DIBROMO-3-CHLOROPROPANE
1,2-DICHLOROBENZENE
1,2-DIPHENYLHYDRAZINE
1,2,3-TR I CHLOROBENZENE
1,2,3-TRIM ETHOXYBENZENE
1,2,4-TR I CHLOROBENZENE
1,2,4 ,5-TETRA CHLOROBENZENE
1,2:3,4-DIEPOXYBUTANE
1,3-BENZENEDIOL (RESORCINOL)
1.3-DICHLORO-2-PROPANOL
1,3-DICHLOROBENZENE
1,3,5-TRITHI ANE
1,4-DICHLOROBENZENE
1,4-DINITROBENZENE
1,4-NAPHTHOQUINONE
1,5-NAPHTHALENEDIAMINE
1730-37-6
832-69-9
605-02-7
96-12-8
95-50-1
122-66-7
87-6 1-6
634-36-6
120-82-1
95-94-3
1464-53-5
108-46-3
96-23-1
54 1-73-1
29 1-21-4
106-46-7
100-25-4
130-15-4
2243-62-1
1625: SEMIVO LA TILE ORGANICS
2-B ROM O CHLOROBENZENE
2-CHLORONAPHTHALENE
2-CHLOROPHENOL
2-ISOPROPYLNAPHTHALENE
2-METHYL-4.6-DINITROPHENOL
2-METHYLBENZOTHIOAZOLE
2-METHYLNAPHTHALENE
2-NITRO AN ILINE
2-NITROPHENOL
2-PHENYLNAPHTHALENE
2-PICOLINE
2-(M ETHYLTHIOJBENZOTHI A ZOLE
2,3-BENZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLORONITROBENZENE
2,3 ,4,6-TETRA CHLOROPHENOL
2,3,6-TRICHLOROPHENOL
2,4-DIAM INOTOLUENE
2,4-DICHLOROPHENOL
2,4-DIM ETH YLPHENOL
2,4-DINITROPHENOL
2,4-DIN I TRO TOLUENE
2,4,5-TRICHLOROPHENOL
2,4 ,5-TRIM ETHYLANILINE
2,4,6-TRICHLOROPHENOL
2.6-DICHLORO-4-NITROANILINE
2,6-DICHLOROPHENOL
2,6-DIN I TRO TOLUENE
2,6-DI-TERT-B UTYL-P-BENZOQUINONE
3-B ROM O CHLOROBENZENE
3-CHLORONITROBENZENE
3-METHYLCHOLANTHRENE
3-NITRO AN ILINE
3,3-DICHLOROBENZIDINE
3,3'-DIMETHOXYBENZIDINE
3.5-DIBROMO-4-HYDROXYBENZONITRILE
3,6-DIMETHYLPHENANTHRENE
4-AM INOBIPHENYL
4-BROMOPHENYLPHENYLETHER
4-CHLORO-2-NITROANILINE
4-CHLORO-3-M ETH YLPHENOL
4-CHLORO ANILINE
4-CHLOROPHENYLPHENYLETHER
4-NITRO AN ILINE
4-NITROB IPHENYL
4-NITROPHENOL
4,4-METHYLENE-BIS(2-CHLOROANILINE)
4,5-M ETH YLENE-PHEN AN THRENE
5-CHLORO-O-TOLUIDINE
5-NITRO-O-TOLUIDINE
7,12-DIM ETH YLBENZfA JANTHRACENE
A CENAPHTHENE
ACENAPHTHYLENE
A CETOPHENONE
ALPHA-NAPHTHYLAM INE
A LPH A -TERPINEOL
A NILINE
A NTHRA CENE
ARAM ITE
BENZANTHRONE
BENZENETHIOL
BENZIDINE
BENZOIC A CID
BENZO(A )A NTHRA CENE
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
6 12-94-2
109-06-8
6 15-22-5
243-17-4
608-27-5
3209-22-1
58-90-2
933-75-5
95-80-
120-83-2
105-67-9
51-28-5
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-
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
208-96-8
98-86-2
134-32-7
98-55-5
62-53-3
120-12-
140-57-8
82-05-3
108-98-5
92-87-5
65-85-0
56-55-3
6-35
-------
Table 6-7: EPA Sampling Episode Pollutants Analyzed (continued)
PO LLUTA N T
CAS NUM
PO LLUTA N T
CAS NUM
1625: SEMIVOLA TILE ORGANICS
BENZO(A )P YRENE
BENZO(B)FLUORANTHENE
BENZO(GHI)PERYLENE
BENZO(K)FLUORANTHENE
BENZYL A LCOHOL
BETA-NAPHTHYLAM INE
BIPHEN YL
BIS(2-CHLOROETHOXY)METHANE
BIS(2-CHLOROETHYL)ETHER
BIS(2-CHLOROISOPROPYL)ETHER
BIS(2-ETHYLHEXYL)PHTHALATE
BUTYLBENZYLPHTHALATE
CARB A ZOLE
CHRYSENE
CROTOXYPH OS
DIBENZOFURA N
DIBENZOTHIOPHENE
DIBENZO(A,H)ANTHRACENE
DIETHYLPHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DI-N-B UTYL PHTH ALA TE
DI-N-OCTYL PHTH ALA TE
DIPHENYLETHER
DIPHENYLAM INE
DIPHENYLDISULFIDE
ETHYLMETHANESULFONATE
ETHYLENETHIOUREA
ETH YNYLESTRA D I OL-3-M ETHYL ETHER
FLUORA NTHENE
FLUORENE
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEX A NOIC A CID
INDENO(1,2,3-CD)PYRENE
ISOPHORONE
ISOSAFROLE
LONGIFOLENE
MALACHITE GREEN
M ETHA PYRILENE
METHYL METHANESULFONATE
NAPHTHALENE
N-C10 (N-DEC ANE)
N-C12 (N-D ODE CANE)
N-C14 (N-TETRADEC A NE)
N-C16 (N-HEXADECANE)
N-C18 (N-OCTADECANE)
N-C20 (N-EICOS ANE)
N-C22(N-DOCOSANE)
N-C24 (N-TETRA COS ANE)
N-C26 (N-HEXACOSANE)
N-C28 (N-OCTACOSANE)
N-C30 (N-TRIA CONTANE)
NITROBENZENE
N-NITROSODIETHYLAMINE
N-NITROSODIMETHYLAMINE
N-NITROSODI-N-BUTYLAMINE
N-NITROSODI-N-PROPYLAMINE
N-NITROSODIPHENYLAM INE
N-NITROSOMETHYL-ETHYLAMINE
N-NITROSOMETHYL-PHENYLAMINE
50-32-8
205-99-2
19 1-24-2
207-08-9
100-5 1-6
91-59-8
92-52-4
111-91-1
111-44-4
108-60-1
1 17-8 1-7
85-68-7
86-74-8
218-0 1-9
7700-17-6
132-64-9
132-65-0
53-70-3
84-66-2
131-11-3
67-71-0
84-74-2
1 17-84-0
10 1-84-8
122-39-4
882-33-7
62-50-0
96-45-7
72-33-3
206-44-0
86-73-7
1 18-74-1
87-68-3
77-47-4
67-72-1
1888-71-7
142-62-1
193-39-5
78-59-1
120-58-1
475-20-7
569-64-2
91-80-5
66-27-3
91-20-3
124-18-5
1 12-40-3
629-59-4
544-76-3
593-45-3
1 12-95-8
629-97-0
646-3 1-1
630-0 1-3
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
1625: SEMIVOLA TILE ORGANICS
N-NITROSOMORPHOLINE
N-NITROSOPIPERIDINE
N.N-DIMETHYLFORMAMIDE
O-AN ISIDINE
O-CRESOL
O-TOLUIDINE
P-CRESOL
P-CYM ENE
P-DIMETHYLAM INO-A ZO BENZENE
PENTACHLOROBENZENE
PENTACHLOROETHANE
PENTACHLOROPHENOL
PENTAMETHYLBENZENE
PERYLENE
PHEN A CETIN
PHENANTHRENE
PHENOL
PHENOTHI A ZINE
PRON AM IDE
PYRENE
PYRIDINE
SA FROLE
SQUA LENE
STYRENE
THI AN APH THENE (2,3-BENZOTHIOPHENE)
THIO A CETAM IDE
THIOXANTHONE
TRIPHENYLENE
TRIPROPYLENEGLYCOLM ETHYL ETHER
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
1 10-86-1
94-59-7
7683-64-9
100-42-5
95-15-8
62-55-5
492-22-8
217-59-4
20324-33-8
6-36
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected
POLLUTANT CAS NUM
1613: DIOXINS/FURANS
2378-TCDD 1746-01-6
2378-TCDF 51207-31-9
12378-PECDD 40321-76-4
12378-PECDF 57117-41-6
23478-PECDF 57117-31-4
123478-HXCDD 39227-28-6
123678-HXCDD 57653-85-7
123789-HXCDD 19408-74-3
123478-HXCDF 70648-26-9
123678-HXCDF 57117-44-9
123789-HXCDF 72918-21-9
234678-HXCDF 60851-34-5
1234678-HPCDD 35822-46-9
1234678-HPCDF 67562-39-4
1234789-HPCDF 55673-89-7
OCDD 3268-87-9
OCDF 39001-02-0
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
HAFNIUM 7440-58-6
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND - - ND ND
ND - - ND ND
ND - - ND ND
ND - - ND ND
ND - - ND ND
ND - - ND ND
ND - - ND
ND - - ND
ND - - ND ND
ND - - ND ND
ND - - ND ND
ND - - ND ND
ND
ND - - ND
ND - - ND ND
ND
ND - - ND ND
ND ND
ND ND ND ND
ND ND ND ND
ND
ND ND ND
ND
ND ND
ND
ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND
ND ND ND ND
ND ND ND
ND ND ND
ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
HOLMIUM 7440-60-0
INDIUM 7440-74-6
IODINE 7553-56-2
IRIDIUM 7439-88-5
IRON 7439-89-6
LANTHANUM 7439-91-0
LEAD 7439-92-1
LITHIUM 7439-93-2
LUTETIUM 7439-94-3
MAGNESIUM 7439-95-4
MANGANESE 7439-96-5
MERCURY 7439-97-6
MOLYBDENUM 7439-98-7
NEODYMIUM 7440-00-8
NICKEL 7440-02-0
NIOBIUM 7440-03-1
OSMIUM 7440-04-2
PALLADIUM 7440-05-3
PHOSPHORUS 7723-14-0
PLATINUM 7440-06-4
POTASSIUM 7440-09-7
PRASEODYMIUM 7440-10-0
RHENIUM 7440-15-5
RHODIUM 7440-16-6
RUTHENIUM 7440-18-8
SAMARIUM 7440-19-9
SCANDIUM 7440-20-2
SELENIUM 7782-49-2
SILICON 7440-21-3
SILVER 7440-22-4
SODIUM 7440-23-5
STRONTIUM 7440-24-6
SULFUR 7704-34-9
TANTALUM 7440-25-7
TELLURIUM 13494-80-9
TERBIUM 7440-27-9
THALLIUM 7440-28-0
THORIUM 7440-29-1
THULIUM 7440-30-4
TIN 7440-31-5
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND
ND ND ND
ND ND ND ND ND
ND
ND ND
ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND
ND ND ND ND
ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND
ND
ND ND ND ND
ND
ND
ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND ND
ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND
oo
oo
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
TITANIUM 7440-32-6
TUNGSTEN 7440-33-7
URANIUM 7440-61-1
VANADIUM 7440-62-2
YTTERBIUM 7440-64-4
YTTRIUM 7440-65-5
ZINC 7440-66-6
ZIRCONIUM 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-1.3-BUTADIENE 126-99-8
2-CHLOROETHYL VINYL 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
2-PROPEN-l-OL(ALLYL ALCOHOL) 107-18-6
3-CHLOROPROPENE 107-05-1
4-METHYL-2-PENTANONE 108-10-1
ACRYLONITRILE 107-13-1
BENZENE 71-43-2
BROMODICHLOROMETHANE 75-27-4
BROMOFORM 75-25-2
BROMOMETHANE 74-83-9
CARBON BISULFIDE 75-15-0
CHLOROACETONITRILE 107-14-2
CHLOROBENZENE 108-90-7
CHLOROETHANE 75-00-3
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND
ND ND ND ND
ND ND ND ND
ND
ND ND ND ND
ND
ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND
ND ND ND ND
ND ND ND ND ND ND
ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND
ND ND ND ND ND ND
ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
oo
vo
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
CHLOROFORM 67-66-3
CHLOROMETHANE 74-87-3
CIS-1.3-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
IODOMETHANE 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-1,2-DICHLOROETHENE 156-60-5
TRANS-1.3-DICHLOROPROPENE 10061-02-6
TRANS-1.4-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
1.2-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
1,2:3,4-DIEPOXYBUTANE 1464-53-5
1,3-BENZENEDIOL (RESORCINOL) 108-46-3
1.3-DICHLORO-2-PROPANOL 96-23-1
1,3-DICHLOROBENZENE 541-73-1
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND
ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND
ND ND
ND ND ND
ND ND ND
ND ND ND ND
ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
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
1,5-NAPHTHALENEDIAMINE 2243-62-1
2-BROMOCHLOROBENZENE 694-80-4
2-CHLORONAPHTHALENE 91-58-7
2-CHLOROPHENOL 95-57-8
2-ISOPROPYLNAPHTHALENE 2027-17-0
2-METHYL-4.6-DINITROPHENOL 534-52-1
2-METHYLBENZOTHIOAZOLE 120-75-2
2-METHYLNAPHTHALENE 91-57-6
2-NITROANILINE 88-74-4
2-NITROPHENOL 88-75-5
2-PHENYLNAPHTHALENE 612-94-2
2-PICOLINE 109-06-8
2-(METHYLTHIO)BENZOTHIAZOLE 615-22-5
2,3-BENZOFLUORENE 243-17-4
2,3-DICHLOROANILINE 608-27-5
2,3-DICHLORONITROBENZENE 3209-22-1
2,3,4,6-TETRACHLOROPHENOL 58-90-2
2,3,6-TRICHLOROPHENOL 933-75-5
2,4-DIAMINOTOLUENE 95-80-7
2,4-DICHLOROPHENOL 120-83-2
2,4-DIMETHYLPHENOL 105-67-9
2,4-DINITROPHENOL 51-28-5
2,4-DINITROTOLUENE 121-14-2
2,4,5-TRICHLOROPHENOL 95-95-4
2,4,5-TRIMETHYLANILINE 137-17-7
2,4,6-TRICHLOROPHENOL 88-06-2
2.6-DICHLORO-4-NITROANILINE 99-30-9
2,6-DICHLOROPHENOL 87-65-0
2,6-DINITROTOLUENE 606-20-2
2,6-DI-TERT-BUTYL-P-BENZOQUINONE 719-22-2
3-BROMOCHLOROBENZENE 108-37-2
3-CHLORONITROBENZENE 121-73-3
3-METHYLCHOLANTHRENE 56-49-5
3-NITROANILINE 99-09-2
3,3-DICHLOROBENZIDINE 91-94-1
3,3'-DIMETHOXYBENZIDINE 119-90-4
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
3.5-DIBROMO-4-HYDROXYBENZONITRILE 1689-84-5
3,6-DIMETHYLPHENANTHRENE 1576-67-6
4-AMINOBIPHENYL 92-67-1
4-BROMOPHENYL PHENYL ETHER 101-55-3
4-CHLORO-2-NITROANILINE 89-63-4
4-CHLORO-3-METHYLPHENOL 59-50-7
4-CHLOROANILINE 106-47-8
4-CHLOROPHENYL PHENYL ETHER 7005-72-3
4-NITROANILINE 100-01-6
4-NITROBIPHENYL 92-93-3
4-NITROPHENOL 100-02-7
4,4-METHYLENE-BIS(2-CHLORO ANILINE) 101-14-4
4,5-METHYLENE-PHENANTHRENE 203-64-5
5-CHLORO-O-TOLUIDINE 95-79-4
5-NITRO-O-TOLUIDINE 99-55-8
7,12-DIMETHYLBENZ(A)ANTHRACENE 57-97-6
ACENAPHTHENE 83-32-9
ACENAPHTHYLENE 208-96-8
ACETOPHENONE 98-86-2
ALPHA-NAPHTHYLAMINE 134-32-7
ALPHA-TERPINEOL 98-55-5
ANILINE 62-53-3
ANTHRACENE 120-12-7
ARAMITE 140-57-8
BENZANTHRONE 82-05-3
BENZENETHIOL 108-98-5
BENZIDINE 92-87-5
BENZOICACID 65-85-0
BENZO(A)ANTHRACENE 56-55-3
BENZO(A)PYRENE 50-32-8
BENZO(B)FLUORANTHENE 205-99-2
BENZO(GHI)PERYLENE 191-24-2
BENZO(K)FLUORANTHENE 207-08-9
BENZYL ALCOHOL 100-51-6
BETA-NAPHTHYLAMINE 91-59-8
BIPHENYL 92-52-4
BIS(2-CHLOROETHOXY) METHANE 111-91-1
BIS(2-CHLOROETHYL) ETHER 1 1 1 -44-4
BIS(2-CHLOROISOPROPYL) ETHER 108-60-1
BIS(2-ETHYLHEXYL) PHTHALATE 117-81-7
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
to
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
BUTYL BENZYL PHTHAL ATE 85-68-7
CARBAZOLE 86-74-8
CHRYSENE 218-01-9
CROTOXYPHOS 7700-17-6
DIBENZOFURAN 132-64-9
DIBENZOTHIOPHENE 132-65-0
DIBENZO(A,H)ANTHRACENE 53-70-3
DIETHYL PHTHALATE 84-66-2
DIMETHYL PHTHALATE 131-11-3
DIMETHYL SULFONE 67-71-0
DI-N-BUTYL PHTHALATE 84-74-2
DI-N-OCTYL PHTHALATE 1 1 7-84-0
DIPHENYL ETHER 101-84-8
DIPHENYLAMINE 122-39-4
DIPHENYLDISULFIDE 882-33-7
ETHYL METHANESULFONATE 62-50-0
ETHYLENETHIOUREA 96-45-7
ETHYNYLESTRADIOL-3-METHYL ETHER 72-33-3
FLUORANTHENE 206-44-0
FLUORENE 86-73-7
HEXACHLOROBENZENE 118-74-1
HEXACHLOROBUTADIENE 87-68-3
HEXACHLOROCYCLOPENTADIENE 77-47-4
HEXACHLOROETHANE 67-72-1
HEXACHLOROPROPENE 1888-71-7
HEXANOICACID 142-62-1
INDENO(1,2,3-CD)PYRENE 193-39-5
ISOPHORONE 78-59-1
ISOSAFROLE 120-58-1
LONGIFOLENE 475-20-7
MALACHITE GREEN 569-64-2
METHAPYRILENE 91-80-5
METHYL METHANESULFONATE 66-27-3
NAPHTHALENE 91-20-3
N-CIO(N-DECANE) 124-18-5
N-C12(N-DODECANE) 112-40-3
N-C14(N-TETRADECANE) 629-59-4
N-C16(N-HEXADECANE) 544-76-3
N-CIS(N-OCTADECANE) 593-45-3
N-C20 (N-EICOSANE) 112-95-8
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
N-C22 (N-DOCOSANE) 629-97-0
N-C24 (N-TETRACOSANE) 646-31-1
N-C26 (N-HEXACOSANE) 630-01-3
N-C28 (N-OCTACOSANE) 630-02-4
N-C30(N-TRIACONTANE) 638-68-6
NITROBENZENE 98-95-3
N-NITROSODIETHYLAMINE 55-18-5
N-NITROSODIMETHYLAMINE 62-75-9
N-NITROSODI-N-BUTYLAMINE 924-16-3
N-NITROSODI-N-PROPYLAMINE 621-64-7
N-NITROSODIPHENYLAMINE 86-30-6
N-NITROSOMETHYL -ETHYLAMINE 10595-95-6
N-NITROSOMETHYL-PHENYLAMINE 614-00-6
N-NITROSOMORPHOLINE 59-89-2
N-NITROSOPIPERIDINE 100-75-4
N.N-DIMETHYLFORMAMIDE 68-12-2
O-ANISIDINE 90-04-0
O-CRESOL 95-48-7
O-TOLUIDINE 95-53-4
P-CRESOL 106-44-5
P-CYMENE 99-87-6
P-DIMETHYLAMINO-AZOBENZENE 60-11-7
PENTACHLOROBENZENE 608-93-5
PENTACHLOROETHANE 76-01-7
PENTACHLOROPHENOL 87-86-5
PENTAMETHYLBENZENE 700-12-9
PERYLENE 198-55-0
PHENACETIN 62-44-2
PHENANTHRENE 85-01-8
PHENOL 108-95-2
PHENOTHIAZINE 92-84-2
PRONAMIDE 23950-58-5
PYRENE 129-00-0
PYRIDINE 110-86-1
SAFROLE 94-59-7
SQUALENE 7683-64-9
STYRENE 100-42-5
THIANAPHTHENE(2,3-BENZOTHIOPHENE) 95-15-8
THIOACETAMIDE 62-55-5
THIOXANTHONE 492-22-8
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND
ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND
ND ND ND ND ND ND
ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
TRIPHENYLENE 217-59-4
TRIPROPYLENEGLYCOLMETHYL ETHER 20324-33-8
1656: PESTICIDES/HERBICIDES
ACEPHATE 30560-19-1
ACIFLUORFEN 50594-66-6
ALACHLOR 15972-60-8
ALDRIN 309-00-2
ATRAZINE 1912-24-9
BENFLURALIN 1861-40-1
ALPHA-BHC 319-84-6
BETA-BHC 319-85-7
GAMMA-BHC 58-89-9
DELTA-BHC 319-86-8
BROMACIL 314-40-9
BROMOXYNIL OCTANOATE 1689-99-2
BUTACHLOR 23184-66-9
CAPTAFOL 2425-06-1
CAPTAN 133-06-2
CARBOPHENOTHION 786-19-6
ALPHA-CHLORDANE 5103-71-9
GAMMA-CHLORDANE 5103-74-2
CHLOROBENZILATE 510-15-6
CHLORONEB 2675-77-6
CHLOROPROPYLATE 5836-10-2
CHLOROTHALONIL 1897-45-6
DIBROMOCHLOROPROPANE (DBCP) 96-12-8
DACTHAL (DCPA) 1861-32-1
4,4'-DDD 72-54-8
4,4'-DDE 72-55-9
4,4'-DDT 50-29-3
DIALLATEA 2303-16-4A
DIALLATEB 2303-16-4B
DICHLONE 117-80-6
DICOFOL 115-32-2
DIELDRIN 60-57-1
ENDOSULFANI 959-98-8
ENDOSULFANII 33213-65-9
ENDOSULFAN SULFATE 1031-07-8
ENDRIN 72-20-8
ENDRIN ALDEHYDE 7421-93-4
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
ENDRINKETONE 53494-70-5
ETHALFLURALIN 55283-68-6
ETRADIAZOLE 2593-15-9
FENARIMOL 60168-88-9
HEPTACHLOR 76-44-8
HEPTACHLOREPOXIDE 1024-57-3
ISODRIN 465-73-6
ISOPROPALIN 33820-53-0
KEPONE 143-50-0
METHOXYCHLOR 72-43-5
METRIBUZIN 21087-64-9
MIREX 2385-85-5
NITROFEN 1836-75-5
NORFLUORAZON 27314-13-2
PCB-1016 12674-11-2
PCB-1221 11104-28-2
PCB-1232 11141-16-5
PCB-1242 53469-21-9
PCB-1248 12672-29-6
PCB-1254 11097-69-1
PCB-1260 11096-82-5
PENTACHLORONITROBENZENE (PCNB) 82-68-8
PENDAMETHALIN 40487-42-1
CIS-PERMETHRIN 61949-76-6
TRANS-PERMETHRIN 61949-77-7
PERTHANE 72-56-0
PROPACHLOR 1918-16-7
PROPANIL 709-98-8
PROPAZINE 139-40-2
SIMAZINE 122-34-9
STROBANE 8001-50-1
TERBAdL 5902-51-2
TERBUTHYLAZINE 5915-41-3
TOXAPHENE 8001-35-2
TRIADIMEFON 43121-43-3
TRIFLURALIN 1582-09-8
1657: PESTICIDES/HERBICIDES
AZINPHOS ETHYL 2642-71-9
AZINPHOS METHYL 86-50-0
CHLORFEVTNPHOS 470-90-6
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
Oi
-k
Oi
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
CHLORPYRIFOS 2921-88-2
COUMAPHOS 56-72-4
CROTOXYPHOS 7700-17-6
DBF 78-48-8
DEMETONA 8065-48-3A
DEMETONB 8065-48-3B
DIAZINON 333-41-5
DICHLORFENTHION 97-17-6
DICHLORVOS 62-73-7
DICROTOPHOS 141-66-2
DIMETHOATE 60-51-5
DIOXATHION 78-34-2
DISULFOTON 298-04-4
EPN 2104-64-5
ETHION 563-12-2
ETHOPROP 13194-48-8
FAMPHUR 52-85-7
FENSULFOTHION 115-90-2
FENTHION 55-38-9
HEXAMETHYLPHOSPHORAMIDE 680-31-9
LEPTOPHOS 21609-90-5
MALATHION 121-75-5
MERPHOS 150-50-5
METHAMIDOPHOS 10265-92-6
METHYL CHLORPYRIFOS 5598-13-0
METHYL PARATHION 298-00-0
METHYL TRITHION 953-17-3
MEVTNPHOS 7786-34-7
MONOCROTOPHOS 6923-22-4
NALED 300-76-5
PARATHION (ETHYL) 56-38-2
PHORATE 298-02-2
PHOSMET 732-11-6
PHOSPHAMIDONE 297-99-4
PHOSPHAMIDONZ 23783-98-4
RONNEL 299-84-3
SULFOTEPP 3689-24-5
SULPROFOS 35400-43-2
TEPP 107-49-3
TERBUFOS 13071-79-9
Non-Hazardous Subcategory
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND
ND ND ND ND
ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND ND
ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
-------
Table 6-8: EPA Sampling Episode List of Analytes Never Detected (continued)
POLLUTANT CAS NUM
TETRACHLORVINPHOS 22248-79-9
TOKUTHION 34643-46-4
TRICHLORFON 52-68-6
TRICHLORONATE 327-98-0
TRICRESYLPHOSPHATE 78-30-8
TRIMETHYLPHOSPHATE 512-56-1
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
CLASSSICAL WET CHEMISTRY
AMENABLE CYANIDE C-025
AMMONIA NITROGEN 7664-41-7
BOD C-002
CHLORIDE 16887-00-6
COD C-004
FLUORIDE 16984-48-8
HEXANE EXTRACTABLE MATERIAL C-036
HEXAVALENT CHROMIUM 18540-29-9
NITRATE/NITRITE C-005
PH C-006
RECOVERABLE OIL AND GREASE C-007
TDS C-010
TOC C-012
TOTAL CYANIDE 57-12-5
TOTAL PHENOLS C-020
TOTAL PHOSPHORUS 14265-44-2
TOTAL SULFIDE 18496-25-8
TSS C-009
Subtitle D Municipal
E4491 E4626 E4667 E4687 E4738
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND
ND ND
ND ND ND ND ND
ND
ND ND ND ND ND
ND ND
ND ND ND
ND ND
ND ND
ND ND ND ND
ND
-
ND
ND ND ND
Non-Hazardous Subcategory
Subtitle D Non-Municipal
E4503 E4630 E4631 E4638 E4639 E4644 E4683 E4690 E4721
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND ND ND ND
ND
ND
ND ND ND ND ND
ND ND ND ND ND ND ND
ND
ND ND ND
ND ND ND ND ND
ND ND
ND ND ND ND
ND ND
ND ND ND
Hazardous Subcategory
E4631 E4659 E4682 E4690 E4721 E4759
ND ND ND ND ND ND
ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND
ND ND
ND ND ND
ND
ND ND
ND ND ND ND
ND
ND ND ND
ND
ND
ND
ND
oo
-------
Table 6-9: Subtitle D Non-Hazardous Subcategory Median Raw Wastewater Concentration File
Subtitle D Non-Hazardous
Pollutant of Interest
Subtitle D Municipal
Median Concentration (ug/L)
Subtitle D Non-Municipal
Median Concentration (ug/L)
Conventional
BOD
TSS
Classical (Non-Conventional)
Ammonia as Nitrogen
COD
Hexavalent Chromium
Nitrate/Nitrite
IDS
TOC
Total Phenols
Organic (Toxic & Non-Conventional)
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzoic Acid
Hexanoic Acid
Methylene Chloride
NN-Dimethylformamide
O-Cresol
P-Cresol
Phenol
Toluene
Tripropyleneglycol Methyl Ether
Metals (Toxic & Non-Conventional)
Barium
Chromium
Strontium
Titanium
Zinc
Pesticides/Herbicides (Non-Conventional)
Dichloroprop
Disulfoton
Dioxins/Furans (Non-Conventional)
1234678-HpCDD
OCDD
240,000
137,000
81,717
994,000
30
651
2,894,289
376,521
571
10.8
1,082
992
101
123
100
5,818
36.8
10
15
75
102
108
197
483
28
1,671
63.8
100
6.1
6.1
67,000
20,500
75,000
1,100,000
950
4,850,000
236,000
251
4,615
0.00014
0.0018
6-49
-------
Table 6-10: Subtitle C Hazardous Subcategory Median Raw Wastewater Concentration File
Subtitle C Hazardous
Pollutant of Interest
Conventional
BOD
Hexane Extractable Material
TSS
Classical (Non-Conventional)
Amenable Cyanide
Ammonia as Nitrogen
COD
Nitrate/Nitrite
IDS
TOC
Total Phenols
Organics (Toxic & Non-Conventional)
1 , 1 -Dichloroethane
1,4-Dioxane
2,4-Dimethylphenol
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Aniline
Benzene
Benzoic Acid
Benzyl Alcohol
Diethyl Ether
Ethylbenzene
Hexanoic Acid
Isobutyl Alcohol
Methylene Chloride
M-Xylene
Naphthalene
O+P Xylene
O-Cresol
Phenol
Pyridine
P-Cresol
Median Cone.
(ug/L)
620,500
29,360
151,000
1,638
268,000
1,308,833
1,580
15,958,333
440,902
25,004
45.7
466
70
1,048
2,889
500
95.7
237
36.9
2,482
43.6
50
44.8
2,703
39.7
118
29.4
48.9
17.1
78.8
4,400
70
144
Subtitle C Hazardous
Pollutant of Interest
Organics (cont.)
Toluene
Trans- 1 ,2-Dichloroethene
Trichloroethene
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Metals (Toxic & Non-Coventional)
Arsenic
Chromium
Copper
Lithium
Molybdenum
Nickel
Selenium
Strontium
Tin
Titanium
Total Cyanide
Zinc
Pesticides/Herbicides (Non-
Coventional)
2,4,5-TP
2,4-D
2,4-DB
Dicamba
Dichloroprop
MCPA
MCPP
Picloram
Terbuthylazine
Dioxins/Furans (Non-Conventional)
1234678-HpCDD
1234678-HpCDF
OCDD
OCDF
Median Cone.
(ug/L)
104
74.3
44.6
853
42.7
214
47.8
36
450
913
240
20
3,044
146
32.6
82.5
100
4.1
5
7.9
4
7.3
209
870
2
14.5
0.00018
0.00013
0.00035
0.0019
6-50
-------
Table 6-11: Range of Conventional and Selected Nonconventional Pollutants Raw Wastewater Average Concentrations (ug/L)
Pollutant Cas No.
Amenable Cyanide C-025
Biochemical Oxygen Demand (BOD) C-002
Total Suspended Solids (TSS) C-009
pH C-006
Hexane Extractable Material C-036
Ammonia as Nitrogen 7664417
Chemical Oxygen Demand (COD) C-004
Nitrate/Nitrite C-005
Total Dissolved Solids (TDS) C-010
Total Organic Carbon (TOC) C-012
Total Phenols C-020
Total Phosphorus 14265442
Non-Hazardous Subcategory
Subtitle D Municipal
Min
-
10,500
6,500
6.7
5,000
1,782
35,000
20
752,000
9,400
50
17
Max
-
7,609,318
14,470,000
9.8
26,000
2,900,000
11,881,700
50,800
17,533,000
3,446,084
2,051,249
6,500
#Obs
31
26
5
4
24
28
17
22
22
15
17
#ND
0
0
0
0
0
0
3
0
0
1
6
Subtitle D Non-Municipal
Min
-
1,000
4,000
6.6
5,000
100
80,000
50
936,000
10,000
50
10
Max
-
3,799,333
16,500,000
9.2
64,000
5,860,000
16,700,000
36,000
33,900,000
4,820,000
39,200
22,700
#Obs
9
8
9
9
9
9
9
9
9
9
7
#ND
1
2
0
4
1
0
1
0
9
1
2
Hazardous Subcategory
Min
0.01
22,000
31,667
5.8
5,000
9,767
270,000
380
4,594,917
2,000
280
10
Max
29,895
2,962,535
568,233
11
64,800
613,620
6,872,579
192,516
31,000,000
3,824,286
192,367
15,900
#Obs
4
8
9
6
5
6
8
6
6
8
5
5
#ND
2
0
0
0
1
0
0
0
0
2
0
1
#Obs: Number of observations
#ND: Number of non-detects
(-): Not detected in any sample
-------
Table 6-12: Range of Metals and Toxic Pollutants Raw Wastewater Average Concentrations (ug/L)
Pollutant CasNo.
Aluminum 7429905
Arsenic 7440382
Barium 7440393
Boron 7440428
Chromium 7440473
Chromium (Hexavalent) 18540299
Copper 7440508
Iron 7439896
Lithium 7439932
Magnesium 7439954
Manganese 7439965
Molybdenum 7439987
Nickel 7440020
Phosphorus 7723140
Selenium 7782492
Silicon 7440213
Strontium 7440246
Sulfur 7704349
Tin 7440315
Titanium 7440326
Total Cyanide 57125
Zinc 7440666
Non-Hazardous Subcategory
Subtitle D Municipal
Min
60.5
-
43
36
2
2
-
2,494
-
24,100
149
-
-
-
-
1,034
787
3,969
-
4
-
11.5
Max
111,100
-
3,500
5,704
240
247
-
1,667,600
-
212,480
78,820
-
-
-
-
91,100
2,146
107,999
-
157
-
31,813
#Obs
7
-
19
7
27
9
-
27
-
14
20
-
-
-
-
4
4
4
-
6
-
27
#ND
0
-
1
0
9
3
-
0
-
0
0
-
-
-
-
0
0
0
-
1
-
1
Subtitle D Non-Municipal
Min
21.5
2
140
76
-
-
-
556
-
8,139
471
4.2
-
-
-
2,498
277
13,700
-
4.4
-
2
Max
712,000
18,300
3,570
16,250
-
-
-
100,000
-
388,000
7,151
69
-
-
-
159,000
30,100
386,573
-
1,740
-
1,240
#Obs
8
10
10
8
-
-
-
9
-
9
9
8
-
-
-
8
8
7
-
8
-
10
#ND
3
3
0
0
-
-
-
0
-
0
0
4
-
-
-
0
0
0
-
2
-
1
Hazardous Subcategory
Min
-
17
-
511
10
-
9
3,585
101
8,307
81
9
60
551
14
2,520
369
10,360
30
3
10
Max
-
1,370
-
8,175
720
-
610
36,758
1,166
440,767
9,045
18,757
2,871
24,650
173
17,911
30,839
786,857
1,118
764
13,317
#Obs
-
9
-
7
9
-
9
7
6
6
6
6
9
7
9
6
6
6
6
6
10
#ND
-
1
-
0
3
-
4
0
0
0
0
1
0
1
3
0
0
0
1
2
1
45.5 846 9 0
#Obs: Number of observations
#ND: Number of non-detects
(-): Not detected in any sample
-------
Table 6-13: Range of Organic Pollutants Raw Wastewater Average Concentrations (ug/L)
Pollutant Cas No.
1,1-Dichloroethane 75343
1,4-Dioxane 123911
1234678-HpCDD 35822469
1234678-HpCDF 67562394
2,4-D 94757
2,4-DB 94826
2,4-Dimethylphenol 105679
2,4,5-TP 93721
2-Butanone 78933
2-Propanone 67641
4-Methyl-2-Pentanone 108101
Alpha Terpineol 98555
Aniline 62533
Benzene 71432
Benzoic Acid 65850
Benzyl Alcohol 100516
Dicamba 1918009
Dichloroprop 120365
Diethyl Ether 60297
Disulfoton 298044
Ethyl Benzene 100414
Hexanoic Acid 142621
I sobutyl Alcohol 78831
MCPA 94746
MCPP 7085190
Methylene Chloride 75092
M-Xylene 108383
Naphthalene 91203
N,N-Dimethylformamide 68122
OCDD 3268879
OCDF 39001020
O-Cresol 95487
O+PXylene 136777612
P-Cresol 106445
Phenol 108952
Picloram 1918021
Pyridine 110861
Terbuthylazine 5915413
Toluene 108883
Trans- 1,2-Dichloroethene 156605
Trichloroethene 79016
Tripropyleneglycol Methyl Ether 20324338
Vinyl Chloride 75014
Non-Hazardous Subcategory
Subtitle D Municipal
Min
-
10
0.00005
-
-
-
-
-
19.3
50
35
10
-
-
0.55
-
-
1
-
2.3
-
10
-
-
-
1.6
-
-
10
0.0001
-
1
-
1
2
-
-
-
3
_
-
99
-
Max
-
323
0.007
-
-
-
-
-
36,544
8,614
46,161
1,061
-
-
33,335
-
-
29
-
20
-
37,256
-
-
-
237
-
-
1,008
0.082
-
2,215
-
998
1,425
-
-
-
598
_
-
1,235
-
#Obs
-
5
3
-
-
-
-
-
14
12
13
5
-
-
7
-
-
5
-
5
-
5
-
-
-
20
-
-
5
3
-
8
-
9
14
-
-
-
23
_
-
5
-
#ND
-
2
1
-
-
-
-
-
3
4
4
1
-
-
3
-
-
2
-
2
-
1
-
-
-
6
-
-
3
1
-
6
-
3
5
-
-
-
5
_
-
2
-
Subtitle D Non-Municipal
Min
-
-
-
-
-
-
-
-
-
50
-
-
-
-
-
-
-
-
-
-
-
-
-
50
50
-
-
-
-
0.0001
-
-
-
-
-
-
-
-
-
_
-
-
-
Max
-
-
-
-
-
-
-
-
-
780
-
-
-
-
-
-
-
-
-
-
-
-
-
4370
1900
-
-
-
-
0.0176
-
-
-
-
-
-
-
-
-
_
-
-
-
#Obs
-
-
-
-
-
-
-
-
-
10
-
-
-
-
-
-
-
-
-
-
-
-
-
8
8
-
-
-
-
8
-
-
-
-
-
-
-
-
-
_
-
-
-
#ND
-
-
-
-
-
-
-
-
-
6
-
-
-
-
-
-
-
-
-
-
-
-
-
2
4
-
-
-
-
5
-
-
-
-
-
-
-
-
-
_
-
-
-
Hazardous Subcategory
Min
0.5
10
0.00005
0.00005
0.5
2.9
10
0.1
50
73
50
10
10
0.3
50
10
0.49
2.2
10
-
0.5
13
10
15
13
1
10
10
-
0.0001
0.0001
10
10
10
10
0.5
10
5
5
0.4
0.5
99
0.2
Max
250
7,611
0.007
0.001
310
120
2,546
13.2
15,252
8,166
3,168
654
2,500
229
306,194
5,690
31
44
159
-
1,072
31,086
10,000
7,071
12,887
19,112
650
7,799
-
0.062
0.012
626
230
17,396
99,947
7.3
10,000
97
2,541
6,237
27,083
3,182
1,429
#Obs
10
9
6
6
9
6
9
9
10
10
9
6
9
10
6
6
6
6
9
-
10
6
9
6
6
10
6
9
-
6
6
9
6
7
9
5
9
5
10
10
10
6
10
#ND
4
5
2
2
4
1
5
4
3
1
3
3
5
5
1
4
0
1
5
-
4
1
6
1
3
4
2
5
-
2
2
2
2
2
1
2
6
2
3
4
4
3
5
#Obs: Number of observations
#ND: Number of non-detects
(-): Not detected in any sample
6-53
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Table 6-14: Dioxins andFurans at Non-Hazardous EPA Sampling Episodes by Episode and Sample Point
Subtitle D
Episode/SP
Municipal
4491 spOl -mf
4626 spOl -mf
4626 sp02 - mf
4626 sp03 - mf
4626 spOS - eff
4626 sp09 - FC
4626 sp09 - FC
4667 spOl -mf
4667 sp06 - eff
4667 sp07 - FC
4667 sp07 - FC
4667 sp07 - FC
4667 sp07 - FC
4667 sp07 - FC
4687 spOl -mf
4687 sp03 - eff
4738 spOl -mf
4738sp02-mf
Non-Municipal
4503 spOl - mf
4630 spOl -mf
4631 sp03 -mf
4638 spOl -mf
4639 spOl -mf
4644 spOl -mf
4721 sp04-mf
Sample
Type
grab
-
grab
grab
-
-
grab
grab
grab
grab
grab
comp
comp
grab
grab
grab
grab
grab
grab
grab
grab
grab
1234678- 1234678-
HpCDD HpCDF OCDD OCDF
140pg/L ND 1800pg/L ND
NS NS NS NS
NS NS NS NS
NS NS NS NS
NS NS NS NS
32.9ng/kgND 803 ng/kg ND
41.2ng/kgND 1100 ng/kg ND
NS NS NS NS
NS NS NS NS
29 ng/kg ND 279 ng/kg ND
32 ng/kg ND 271 ng/kg ND
44 ng/kg ND 308 ng/kg ND
43 ng/kg ND 338 ng/kg ND
39 ng/kg ND 290 ng/kg ND
ND ND ND ND
NS NS NS NS
240pg/L 56pg/L ll,OOOpg/L ND
480 pg/L ND 5, 300 ng/kg ND
ND ND ND ND
103pg/L ND 5380 pg/L ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND 503 pg/L ND
123478-
HxCDD
ND
NS
NS
NS
NS
ND
ND
NS
NS
ND
ND
ND
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
123478-
HxCDF
ND
NS
NS
NS
NS
ND
ND
NS
NS
ND
ND
ND
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
1234789-
HpCDF
ND
NS
NS
NS
NS
ND
ND
NS
NS
ND
ND
ND
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
123678- 123678-
HxCDD HxCDF
ND ND
NS NS
NS NS
NS NS
NS NS
ND ND
ND ND
NS NS
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
NS NS
ND ND
6 ng/kg ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
12378- 12378-
PeCDD PeCDF
ND ND
NS NS
NS NS
NS NS
NS NS
ND ND
ND ND
NS NS
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
123789-
HxCDD
ND
NS
NS
NS
NS
ND
ND
NS
NS
ND
ND
ND
ND
ND
ND
NS
ND
1 6 ng/kg
ND
ND
ND
ND
ND
ND
ND
123789-
HxCDF
ND
NS
NS
NS
NS
ND
ND
NS
NS
ND
ND
ND
ND
ND
ND
NS
ND
ND
ND
ND
ND
ND
ND
ND
ND
234678- 23478-
HxCDF PeCDF
ND ND
NS NS
NS NS
NS NS
NS NS
ND ND
ND ND
NS NS
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
2378- 2378-
TCDD TCDF
ND ND
NS NS
NS NS
NS NS
NS NS
ND ND
ND ND
NS NS
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
NS NS
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
Note: Only filter cake was analyzed for dioxins and furans in Municipal episodes 4626 and 4667
sp: sample point
inf: influent
eff: effluent
comp: composite sample
grab: grab sample
NS: Not sampled mg/L = 1000 ug/L
ND: Non-detect ug/L = 1000 ng/L
FC: Filter cake ng/L = 1000 pg/L
-------
Table 6-15: Dioxins and Furans at Hazardous EPA Sampling Episodes by Episode and Sample Point
Episode
Sample Point
4631 spOl -mf
4631 sp02-inf
4659 spOl - mf
4682 spOl -mf
4682 sp02 - mf
4721 spDOl -in
4721 spOl -mf
4721 spOl -mf
4721 spOl -mf
4721 spOl -mf
4721 sp02 - eff
4721 sp03 - mf
4721 sp05 - mf
4721 sp06 - mf
4759 spOl - mf
4759 sp03 - eff
Sample
Type
grab
grab
grab
grab
grab
comp
comp
comp
comp
comp
-
grab
grab
grab
comp
comp
1234678- 1234678- 123478- 123478- 1234789- 123678- 123678- 12378- 12378- 123789- 123789- 234678- 23478- 2378- 2378-
HpCDD HpCDF OCDD OCDF HxCDD HxCDF HpCDF HxCDD HxCDF PeCDD PeCDF HxCDD HxCDF HxCDF PeCDF TCDD TCDF
13,600pg/Ll,180pg/L116,OOOpg/L6,600pg/LND 95.4pg/L 162pg/L 798 pg/L 202 pg/L ND 79.1 pg/L 196 pg/L ND ND ND ND 31.1pg/I
479pg/L 88 pg/L 7,920 pg/L 573 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
446pg/L ND 4,160pg/L 135pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
752 pg/L 86 pg/L 9,070 pg/L 357 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
593 pg/L 55 pg/L 6,290 pg/L 243 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
576 pg/L ND 5, 040 pg/L 136 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
496 pg/L 62 pg/L 4,630 pg/L 21 2 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS NS
551 pg/L 70 pg/L 5, 080 pg/L 162 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
698 pg/L ND 5, 080 pg/L 290 pg/L ND ND ND ND ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND
ND ND lOOpg/L ND ND ND ND ND ND ND ND ND ND ND ND ND ND
sp: sample point
inf: influent
eff: effluent
comp: composite sample
grab: grab sample
D: Duplicate
ND:Non-detect
NS: Not sampled
mg/L= lOOOug/L
ug/L = lOOOng/L
ng/L = 1000 pg/L
-------
7.0 POLLUTANT PARAMETER SELECTION
7.1 Introduction
EPA reviewed wastewater characterization data presented in Chapter 6 to identify which pollutant
parameters present in landfills wastewater should be considered for regulation. EPA classifies pollutants
into the following three categories: conventional, nonconventional, and toxic pollutants. Conventional
pollutants include BOD5, TSS, oil and grease, and pH. Toxic pollutants - EPA also refers to them as
priority pollutants — include selected metals, pesticides and herbicides, and over 100 organic parameters
that represent a comprehensive list of volatile and semi-volatile compounds. Nonconventional pollutants
are any pollutants that do not fall within the specific conventional and toxic pollutant lists and include, for
example, TOC, COD, chloride, fluoride, ammonia-nitrogen, nitrate/nitrite, total phenol, and total
phosphorous.
This chapter presents the criteria used for the selection of pollutant parameters EPA evaluated for regulation
and the selection of pollutants for which EPA has established effluent limitations and standards.
7.2 Pollutants Considered for Regulation
To characterize landfill wastewater and to determine the pollutants that it should evaluate for potential
limitations and standards, EPA collected wastewater characterization samples at 15 landfill facilities, in
addition to influent data collected at six, week-long sampling episodes. EPA analyzed wastewater samples
for 470 conventional, toxic, and nonconventional pollutants including metals, organics, pesticides,
herbicides, and dioxins and furans. Chapter 6 presents this wastewater characterization data.
From the original list of 470 analytes, EPA developed a list of "pollutants of interest" for each subcategory
that it would further evaluate for possible regulation. This list reflects the types of pollutants typically found
in landfill wastewater. From this list of pollutants, EPA calculated the current pollutant mass loadings for
7-1
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the industry and estimated the pollutant loading associated with compliance with the final limitations and
standards. The list of pollutants of interest also served as the basis for selecting pollutants for regulation.
7.3 Selection of Pollutants of Interest
EPA determined pollutants of interest for each subcategory using the raw wastewater data collected during
the EPA sampling program. Chapter 6 presents the landfill facilities sampled in each subcategory in Table
6-8 and whether EPA detected the pollutants analyzed in the facility' s raw wastewater. EPA only included
the sampled facilities that were within the scope of the rule to determine the pollutants of interest.
Therefore, EPA did not include sampling data from captive exempt facilities nor contaminated ground water
data in the analysis. Figure 7-1 presents a diagram of the procedures used to select pollutants of interest.
EPA applied the following criteria to develop a list of pollutants for further evaluation for each subcategory:
1. EPA determined any pollutant detected three or more times in the influent at a concentration at or
above 5 times the minimum level at more than one facility to be a pollutant of interest.
2. For dioxins/furans, EPA determined any dioxin or furan detected three or more times in the influent
at a concentration above the minimum level at more than one facility to be a pollutant of interest.
3. EPA excluded pollutants that are naturally occurring compounds in soil or ground water at landfill
facilities or pollutants that are used as treatment chemicals in this industry from the pollutants of
interest list. These compounds include aluminum, boron, calcium, chloride, fluoride, iron,
manganese, magnesium, potassium, silicon, sodium, sulfur, total phosphorus, and total sulfide.
Tables 7-1 and 7-2 list the final pollutants of interest for the Non-Hazardous and Hazardous subcategories
that EPA has selected for further evaluation after applying these criteria. As shown in Table 7-1, EPA
identified separate lists of pollutants of interest for Subtitle D municipal solid waste landfills and Subtitle
D non-municipal solid waste landfills. However, EPA combined these two lists for the entire Non-
Hazardous landfill subcategory. At proposal, one Non-Hazardous subcategory pollutant of interest,
MCPA, was present at non-municipal solid waste landfills and was not present at municipal solid waste
landfills. However, after proposal, EPA re-evaluated the status of several facilities in the landfills database
7-2
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and now classifies an additional nine facilities as captive landfills not included within the scope of this
guideline. With the removal of pollutants associated with these facilities from the analysis, EPA determined
that, after application of the criteria, MCPA was no longer a pollutant of interest for non-municipal facilities
because it was detected only twice in the influent at a concentration at or above 5 times the minimum level
at two non-captive facilities. Therefore, EPA did not include MCPA as a pollutant of interest for the Non-
Hazardous subcategory for the final rule. Pollutants of interest in both subcategories include conventional,
nonconventional, and toxic pollutants and include metals, organics, pesticides, herbicides, and dioxins and
furans.
7.4 Development of Pollutant Discharge Loadings
EPA estimated mass loadings of pollutant discharges for the pollutants of interest on a facility-by-facility
basis. The Agency calculated pollutant loadings for current discharges and estimated projected discharges
based on each of the regulatory options using the procedures described below.
7.4.1 Development of Current Discharge Concentrations
The current discharge concentration database contains the discharge concentration for each pollutant of
interest at each facility in each subcategory. The Agency determined mass loadings by multiplying the
pollutant concentration by the facility-specific regulated wastewater flow. EPA used all available data
including Detailed Questionnaire and Detailed Monitoring Questionnaire data and EPA sampling data to
determine mass loadings.
In the Detailed Questionnaire and Detailed Monitoring Questionnaires, EPA requested facilities to provide
information on wastewater treatment-in-place and to provide concentration data on treated wastewater
effluent. The Agency compiled all effluent wastewater data for each facility after screening the data using
the conventions discussed in Chapter 4 for raw wastewater. For facilities with multiple effluent sample
points, EPA determined the final effluent concentration by taking a flow weighted average of the samples.
From the effluent wastewater data from each facility, the Agency created a data file that contained one
7-3
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average concentration value for each pollutant of interest at each facility. The amount of data in the file
varied significantly from facility to facility. EPA based several of the current discharge concentrations on
hundreds of sampling data points obtained through the Detailed Monitoring Questionnaire, while it based
others on as few as one sampling data point. The Detailed Monitoring Questionnaire data reflect up to
three years of data and are unique to each facility in terms of numbers of parameters analyzed and
monitoring frequency. Additionally, monitoring may have been performed weekly, monthly, or quarterly.
For facilities sampled by EPA, there was information available for all 470 analytes, and sampling typically
reflected the daily performance of a system over a five-day period.
For facilities with wastewater treatment-in-place, but with either no available effluent data or incomplete
effluent data, EPA generated a treated effluent average concentration. To develop the treated effluent
average concentration, EPA grouped facilities by subcategory and then placed them in treatment-in-place
groups, depending on the type of treatment employed on site. Within a treatment-in-place group, the
Agency calculated the treated effluent average concentration for a pollutant of interest by taking the median
of all weighted source averages for all facilities within the treatment-in-place group. If there were no data
for a particular pollutant within a treatment-in-place group, EPA calculated the treated effluent average
concentration for a pollutant of interest in a subcategory by taking the median of all weighted source
averages for all facilities within the entire subcategory.
For facilities with no treatment-in-place, the Agency used raw wastewater concentrations to represent
current effluent discharge values. EPA calculated facility averages using all available data sources and using
the procedures outlined above. For facilities with no treatment-in-place and with either no influent data or
incomplete influent data, the Agency used the subcategory median raw wastewater concentration (see
Section 6.3.3 for details on developing the Median Raw Wastewater Concentration File) to represent the
current discharge for each pollutant of interest.
7-4
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For the Hazardous subcategory and for Subtitle D non-municipal solid waste facilities in the Non-
Hazardous subcategory, there were insufficient effluent data to calculate a representative treatment-in-place
or subcategory treated effluent average concentration result for several pollutants of interest. The alternate
methodologies developed to calculate representative current discharge concentration values for both the
Hazardous subcategory and for Subtitle D non-municipal facilities in the Non-Hazardous subcategory are
discussed below.
7.4.1.1 Alternate Methodology for Non-Hazardous Subcategory: Subtitle D Non-
Municipal
For Subtitle D non-municipal solid waste facilities in the Non-Hazardous subcategory, EPA used the
effluent data from municipal solid waste landfills to supplement insufficient non-municipal data. EPA
concluded this was appropriate in the circumstances because of the similarities in the median raw
wastewater concentrations from Subtitle D municipal and non-municipal facilities. Table 6-7 in Chapter
6 presents the Subtitle D municipal and non-municipal median raw wastewater concentration data.
EPA employed the following procedure to calculate current discharge concentrations for Subtitle D non-
municipal solid waste facilities. First, EPA used all available non-municipal landfill effluent data. Next, EPA
placed non-municipal facilities in municipal facility treatment-in-place groups according to treatment
employed on site. Then, EPA used municipal landfills treatment-in-place treated effluent average
concentrations for each non-municipal facility with insufficient data.
7.4.1.2 Alternate Methodology for the Hazardous Subcategory
EPA estimated current discharge concentrations for the facilities in the Hazardous subcategory using the
long-term averages developed for the subcategory (see Chapter 11: Development of Effluent Limitations
and Standards). EPA's data collection efforts did not identify any direct discharging hazardous landfills,
and EPA obtained detailed information from only three indirect discharging landfills. Therefore, the Agency
modeled the current discharge concentrations on the small number of indirect discharging facilities in the
7-5
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EPA database as a function of the expected discharge concentrations after treatment using the long-term
averages. EPA used industry-provided effluent data whenever available.
The Agency developed an approach based upon the installed treatment system at the facility. EPA
estimated the current discharge concentration as twice the long-term average (LTA) for a facility without
any biological or chemical treatment-in-place. The modeling approach used to develop the current
discharge concentration (CDC) for the indirect dischargers in the Hazardous subcategory is presented
below.
QID
16017
16041
16087
Treatment-In-Place
Separation and neutralization
Sequencing batch reactors
Equalization, chemical precipitation, primary sedimentation,
activated sludge, and secondary sedimentation
Modeling Scheme
2 x LTAmed
LTA
LTA
For facility 16017, the current discharge concentration value was based upon a function of the LTAmed.
The LTAmed is the median of the long-term averages in the Hazardous subcategory. The long-term
averages used in this subcategory are from BAT facilities 16041 and 16087. Therefore, the corresponding
long-term averages were used for both of these BAT facilities.
7.4.2 Development of Pollutant Mass Loadings
Using the current discharge concentrations discussed above, EPA generated mass loading estimates for
each pollutant of interest at each facility by multiplying the current discharge concentration value by the
facility's average daily discharge flow rate. This resulted in mass loadings, reported in pounds per day, for
each facility in the database. EPA calculated mass loadings to determine the amount of pollution discharged
directly or indirectly to surface waters by landfill facilities and to estimate the amount of pollutant reduction
after implementation of each regulatory technology option. Summaries of pollutant mass loadings for the
selected regulatory options are presented in Chapter 11.
7-6
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7.5 Assessment of Pollutants of Interest
As indicated above, EPA developed extensive lists of pollutants of interest for this industry. EPA used the
full list of pollutants of interest to develop pollutant loadings and pollutant reductions as a result of treatment.
However, the Agency only selected certain pollutants for regulation, since specific regulation of every
pollutant is not always the most cost-effective approach to developing effluent limitations guidelines.
The treatment technologies evaluated as the basis of the regulation remove classes of compounds with
similar treatability characteristics. Several of the pollutants of interest in the Landfills industry are similar
in terms of their chemical structure and treatability. As a result, the regulation of a set of pollutants within
a chemical class ensures that the treatment technologies will provide adequate control of other pollutants
of interest within that class of compounds.
Based upon this analysis, EPA decided not to regulate certain pollutants of interest in the Non-Hazardous
and Hazardous subcategories because their removals are represented adequately by another regulated
pollutant, as discussed in the sections below. In addition, the Agency did not select several other pollutants
of interest for regulation because EPA found these pollutants at concentrations below treatable levels in the
Landfills industry. EPA also did not select pollutants for regulation if the Agency determined that these
pollutants were found at only trace amounts in the industry, and therefore were not likely to cause toxic
effects. The Agency also excluded several pollutants of interest from regulation because the selected BPT
treatment technology would not remove these pollutants.
7.6 Selection of Pollutants To Be Regulated for Direct Dischargers
Based upon the data analyses outlined above, EPA developed a list of pollutants to be regulated for the
Hazardous and Non-Hazardous subcategories. Figure 7-2 presents a diagram that illustrates the
procedures used to select the regulated pollutants. EPA is not establishing effluent limitations and standards
for all conventional, toxic, and nonconventional pollutants. There may be pollutants present in a specific
landfill or type of landfill for which EPA did not establish limitations under this guideline but which may be
7-7
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of concern to a receiving stream or POTW. Due to the specific nature of landfill waste at various sites,
permit writers and local authorities may need to consider case-by-case limitations or standards for these
pollutants. EPA's regulations require the permit writer or local authority to include technology-based limits
for any toxic pollutant which is or may be discharged at a level greater than the level which can be achieved
by treatment requirements appropriate to the permittee or which may pass through or interfere with POTW
operations. (40 CFR § 122.44(e), 125.3. See also 40 CFR § 403.5(c) which requires the establishment
of local limits in a POTW pretreatment program for any pollutant which may cause pass through or
interference). The following sections discuss EPA's reasons for not establishing effluent limitations for
selected pollutants.
7.6.1 Non-Hazardous Subcategory Pollutants to be Regulated for Direct Dischargers
EPA developed the list of pollutants to be regulated for the Non-Hazardous subcategory from the pollutants
of interest list for the Non-Hazardous subcategory. The non-hazardous pollutants of interest list combines
the pollutants of interest from Subtitle D municipal and non-municipal solid waste facilities for a total of 32
pollutants of interest. The BPT/BAT facilities selected by EPA demonstrate removal of the regulated
pollutants. These facilities employed equalization, biological treatment, and for some, multimedia filtration.
Initially, EPA considered regulating all 32 pollutants of interest. After a thorough analysis, EPA, however,
chose not to set limitations for 24 pollutants of interest under BPT/BAT/NSPS for one of the following
reasons:
The pollutant (or pollutant parameter) is controlled through the regulation of other pollutants (or
pollutant parameters).
The pollutant (or pollutant parameter) is present in only trace amounts in the subcategory and/or
is not likely to cause toxic effects.
The pollutant (or pollutant parameter) is not controlled by the selected BPT technology.
7-S
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The following seven Non-Hazardous subcategory pollutants of interest are pollutants that are controlled
through the regulation of other pollutants:
Seven Pollutants Not Selected for Regulation in the Non-Hazardous Subcategory Because They Are
Controlled Through the Regulation of Other Pollutants
COD
TOC
Total Phenols
Hexanoic Acid
O-Cresol
Tripropyleneglycol Methyl Ether
Titanium
COD is an alternative method of estimating the oxygen demand of the wastewater. However, EPA
selected BOD5 for regulation because it is more appropriately controlled by a biological treatment system.
TOC measures all oxidizable organic material in a waste stream, including the organic chemicals not
oxidized (and, therefore, not detected) in BOD5 and COD tests. TOC is a rapid test for estimating the total
organic carbon in a waste stream. For reasons similar to those used for not selecting COD for regulation,
EPA did not select TOC for regulation. Total phenols is a general wet chemistry indicator measurement
for phenolic compounds. Regulation of phenol will control other phenolic compounds. Similarly, hexanoic
acid is relatively biodegradable and should be controlled by regulating benzoic acid. O-cresol is structurally
similar to p-cresol and should be controlled by regulating p-cresol. Tripropyleneglycol methyl ether has
treatability characteristics similar to alpha terpineol in a biological treatment system and should be controlled
by regulating alpha terpineol. EPA determined that titanium will be removed incidentally by biological
treatment in the same manner as zinc, through sorption into the biomass. Therefore, titanium should be
controlled by regulating zinc.
In the proposal, EPA chose not to regulate 2-butanone, 2-propanone, and 4-methyl-2-pentanone because
they were controlled through the regulation of toluene. After proposal EPA decided not to regulate toluene.
The reasons these pollutants were not selected for regulation in the final rule are discussed below.
7-9
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The following thirteen Non-Hazardous subcategory pollutants of interest are present in only trace amounts
and/or are not likely to cause toxic effects:
Thirteen Pollutants Not Selected for Regulation in the Non-Hazardous Subcategory Because They
Are Present in Only Trace Amounts and/or Are Not Likely to Cause Toxic Effects
Nitrate/Nitrite
TDS
1,4-Dioxane
4-Methyl-2-Pentanone
Methylene Chloride
N,N-Dimethylformamide
Toluene
Barium
Chromium
Dichloroprop
Disulfoton
1,2,3,4,6,7,8-HpCDD
OCDD
EPA presents the Non-Hazardous subcategory median raw wastewater concentration data for the
pollutants of interest in Chapter 6, Table 6-9, and the minimum and maximum concentrations for
conventional and nonconventional pollutants, metals, organic pollutants, and dioxins/furans in Tables 6-11
through 6-14.
For this industry, nitrate/nitrite is used primarily as a measure of the extent of nitrification that occurs during
the biodegradation process. Typically, levels of nitrate/nitrite found in landfill wastewater do not require
removal. Removal of nitrate/nitrite can be obtained by specially designed biological treatment systems
(such as nitrification/denitrification systems) that are able to complete the conversion of nitrate/nitrite to
nitrogen gas. Often, removal of nitrate/nitrite is required to address specific water quality concerns for an
individual receiving water (i.e., nutrient problems in the Great Lakes). EPA has determined that the levels
of nitrate/nitrite in landfill wastewater do not justify regulation on a national level and individual permit
writers can address specific water quality considerations.
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TDS is used primarily as a water quality measurement and not as a pollutant that can be controlled through
biological treatment. It often is used as a measurement of the salinity of an ambient water or a wastewater
and often indicates the presence of naturally occurring salts of metals such as sodium, iron, and magnesium.
While it can inhibit biological treatment processes at levels above 10,000 mg/L, acclimated biological
treatment systems can operate successfully with influent TDS concentrations as high as 76,000 mg/L
(reference 55). The median concentration of total dissolved solids in the Non-Hazardous subcategory was
only 4,850 mg/L for non-municipal solid waste landfills and 2,890 mg/L for municipal solid waste landfills.
Therefore, EPA has determined that concentrations of total dissolved solids found in landfills in the Non-
Hazardous subcategory do not justify regulation. EPA's sampling data showed levels of n,n-
dimelhylformamide in landfill wastewater generally near the analytical detection limit (median concentration
for non-hazardous municipal solid waste landfills was 10 ug/L) and, because of this low concentration
throughout the subcategory, regulation was not warranted.
EPA classifies four pollutants, 1,4-dioxane, 4-m ethyl-2-pentanone, methylene chloride, and toluene as
"volatile organics" under analytical test method 1624. In the proposed rule, EPA established direct
discharge limitations fortoluene for landfills in the Non-Hazardous subcategory. However, after proposal,
EPA decided not to regulate toluene because it is not treated by the biological treatment technology
selected as the basis for the landfills effluent limitations. Furthermore, based on the concentration of toluene
in untreated municipal leachate (108 ug/L), the Agency concluded that the loading of toluene to the
atmosphere will not cause toxic effects.
While EPA acknowledges that a small portion of the removal of these pollutants is due to biological
degradation, these pollutants are highly volatile and the primary mechanism for their removal from
wastewater is through volatilization to the atmosphere. EPA based these final regulations on the
performance of an aerated biological system. Wastewater aeration may increase the volatilization of certain
organic compounds, a potential environmental concern. While EPA does not recognize the transfer of
pollutants from one media to another as effective treatment, based on the concentrations of these pollutants
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in untreated wastewater (below treatable levels (10 times the method detection limit)), indications are that
the potential increase in air emissions due to this regulation will be minimal.
Volatile organic compound (VOC) levels in historic landfill leachate (from both hazardous and non-
hazardous waste landfills dating from the 1930s to the mid-1990s) are also at levels which are low enough
as not to call into question EPA's determination to base these rules on the performance of aerated
biological systems. Tables 6-9, 6-10, and 6-13 show the concentrations of VOCs found in landfill
wastewater.
Furthermore, EPA's Office of Air and Radiation is currently evaluating the air emissions from wastewater
generated at municipal solid waste landfills, and intends to take the landfills effluent limitations guidelines into
account in determining whether further controls under Section 112 of the Clean Air Act (which requires
technology-based standards for hazardous air pollutants emitted by major sources of emissions of those
pollutants) are justified. (Preliminary indications are that hazardous air pollutant emissions from aeration
would be a minor fraction of those from other landfill emission sources such as landfill gas emissions.)
EPA's sampling detected two metals, barium and chromium, below treatable levels at non-hazardous
landfills in the EPA database. The median raw wastewater concentrations of barium and chromium found
at municipal landfills is 0.48 mg/L and 0.03 mg/L, respectively, less than 5 times the method detection limit.
EPA is excluding these two metals from regulation because, at the concentrations found at non-hazardous
landfills, these pollutants are not likely to cause toxic effects.
EPA found low levels of dichloroprop, disulfoton, 1,2,3,4,6,7,8-HpCDD, and OCDD in raw wastewater
at several Non-Hazardous subcategory landfills. At the concentrations found, EPA expects these pollutants
to partition to the biological sludge created as a result of the use of the BPT/B AT treatment technologies.
EPA sampling data and calculations conclude that the concentrations of these pollutants present in the
wastewater will not prevent the sludge from being redeposited in a non-hazardous landfill.
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The following four pollutants were not selected for regulation in the Non-Hazardous subcategory because
they are not controlled by the selected BPT/BAT technology:
Four Pollutants Not Selected for Regulation in the Non-Hazardous Subcategory Because They Are
Not Controlled by the Selected BPT/BAT Technology
2-Butanone
2-Propanone
Hexavalent Chromium
Strontium
EPA classifies 2-butanone and 2-propanone as "volatile organics" under analytical test method 1624.
Because the selected BPT/BAT technology for the Non-Hazardous subcategory is aerated equalization
followed by biological treatment and then multimedia filtration, EPA determined that the majority of the
removal of volatile organic compounds is due to volatilization to the atmosphere in either the aerated
equalization tanks or in the activated sludge aeration basin. Therefore, EPA did not regulate volatile organic
pollutants because the BPT/BAT technology does not provide controls for the removal of these pollutants.
EPA detected hexavalent chromium and strontium in wastewater at the facilities selected as the basis for
BPT/BAT/NSPS, but EPA did not have adequate removal data at the BPT/BAT/NSPS facilities employing
biological treatment and, therefore, these pollutants could not be regulated. For both pollutants, EPA had
removal data from one BPT/BAT facility. In both cases, the BPT facilities demonstrated negative percent
removals of these pollutants. In addition to the lack of adequate data, EPA determined that for this
subcategory, these metals are not present in concentrations that are likely to cause toxic effects. Therefore,
these two metals were excluded from regulation in the Non-Hazardous subcategory.
In conclusion, the following eight pollutants of interest are regulated under BPT/BAT/NSPS in the Non-
Hazardous subcategory:
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Eight Pollutants Selected for Regulation in the Non-Hazardous Subcategory
Ammonia as Nitrogen
BOD5
TSS
Alpha Terpineol
Benzoic Acid
P-Cresol
Phenol
Zinc
The Agency wishes to note that zinc was selected for regulation in spite of the fact that exclusion criteria
used to eliminate other pollutants of interest apply, at least partially. Zinc has been selected for regulation
in spite of its relatively low untreated wastewater concentration. The median concentration of zinc found
in raw wastewater at municipal solid waste landfills and at non-municipal solid waste landfills is 0.10 mg/L
and 0.09 mg/L, respectively. EPA selected zinc for regulation because EPA observed incidental removals
ranging from 58 percent to 90 percent at the treatment systems selected for BPT. Additionally, EPA's
sampling did not find raw wastewater concentrations of zinc at levels that would inhibit biological treatment
systems (see Chapter 11, Section 11.2.1).
Chapter 11 describes in detail the development of the effluent limitations for each of these pollutants.
7.6.2 Hazardous Subcategory Pollutants to be Regulated for Direct Dischargers
EPA developed the list of pollutants to be regulated for the Hazardous Subcategory from the Hazardous
Subcategory pollutants of interest list. The two BPT/BAT facilities selected by EPA demonstrate removal
of the regulated pollutants through the use of chemical precipitation and biological treatment. Initially, EPA
considered regulating all 63 pollutants of interest; EPA chose, however, not to set limitations for 50
pollutants of interest under BPT/BAT/NSPS for one of the following reasons:
The pollutant (or pollutant parameter) is controlled through the regulation of other pollutants (or
pollutant parameters).
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The pollutant (or pollutant parameter) is present in only trace amounts in the subcategory and/or
is not likely to cause toxic effects.
The pollutant (or pollutant parameter) is not controlled by the selected BPT technology.
As discussed in Chapter 6, after proposal, EPA analyzed the raw wastewater characterization data for
hazardous landfills without CERCLA ground water data. As a result, raw wastewater concentrations for
several pollutants of interest have changed since proposal and, therefore, in some cases, EP A's reasons
for not selecting these pollutants for regulation also have changed.
EPA did not select the following thirteen Hazardous subcategory pollutants of interest for regulation
because they are controlled through the regulation of other pollutants:
Thirteen Pollutants Not Selected for Regulation in the Hazardous Subcategory Because They Are
Controlled Through the Regulation of Other Pollutants
COD
TOC
Total Phenols
2,4-Dimethylphenol
Benzyl Alcohol
Diethyl Ether
Isobutyl Alcohol
Hexanoic Acid
O-Cresol
Tripropyleneglycol Methyl Ether
Molybdenum
Nickel
Strontium
COD is an alternative method of estimating the oxygen demand of the wastewater. EPA, however,
selected BOD5 for regulation because it is more appropriately controlled by a biological treatment system.
TOC measures all oxidizable organic material in a waste stream, including the organic chemicals not
oxidized (and, therefore, not detected) in BOD5 and COD tests. TOC is a rapid test for estimating the total
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organic carbon in a waste stream. For similar reasons to the rationale for not selecting COD for regulation,
EPA did not select TOC for regulation.
While present in treatable concentrations, EPA did not have adequate removal data for molybdenum,
nickel, and strontium at the Hazardous subcategory BPT/B AT facilities. However, these metals should be
controlled adequately through the regulation of both chromium and zinc. Total phenols is a general, wet
chemistry indicator measurement for phenolic compounds and should be controlled by regulating phenol.
Similarly, 2,4-dimethylphenol has chemical andtreatability characteristics similar to phenol and, therefore,
should also be controlled through the regulation of phenol. Hexanoic acid, benzyl alcohol, and isobutyl
alcohol are relatively biodegradable and should be controlled by regulating benzoic acid. O-cresol is
structurally similar to p-cresol and should be controlled by regulating p-cresol. Tripropyleneglycol methyl
ether and diethyl ether have treatability characteristics similar to alpha terpineol in a biological treatment
system and should be controlled by regulating alpha terpineol.
In the proposal, EPA chose not to regulate 2-butanone, 2-propanone, 4-methyl-2-pentanone,
ethylbenzene, m-xylene, and o+p xylene because they were controlled through the regulation of toluene.
After proposal EPA decided not to regulate toluene. The reasons these pollutants were not selected for
regulation in the final rule are discussed below.
EPA did not select the following sixteen pollutants of interest for regulation in the Hazardous subcategory
because they are present in only trace amounts and/or are not likely to cause toxic effects:
Sixteen Pollutants Not Selected for Regulation in the Hazardous Subcategory Because They Are
Present in Only Trace Amounts and/or Are Not Likely to Cause Toxic Effects
Hexane Extractable Material
Nitrate/Nitrite
TDS
2,4-D
2,4-DB
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2,4,5-TP
Dicamba
Dichloroprop
MCPA
MCPP
Picloram
Terbutylazine
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8-HpCDF
OCDD
OCDF
EPA presents the Hazardous subcategory median raw wastewater concentration data for the pollutants of
interest in Chapter 6, Table 6-10, and the minimum and maximum concentrations for conventional and
nonconventional pollutants, metals, organic pollutants, and dioxins/furans in Tables 6-11 through 6-13, and
Table 6-15.
For this industry, nitrate/nitrite is used primarily as a measure of the extent of nitrification that occurs during
the biodegradation process. Typically, levels of nitrate/nitrite found in landfill wastewater do not require
removal. Removal of nitrate/nitrite can be obtained by specially designed biological treatment systems
(such as nitrification/denitrification systems) that are able to complete the conversion of nitrate/nitrite to
nitrogen gas. Often, removal of nitrate/nitrite is required to address specific water quality concerns for an
individual receiving water (i.e., nutrient problems in the Great Lakes). EPA has, however, determined that
the levels of nitrate/nitrite in landfill wastewater do not justify regulation on a national level and individual
permit writers can address specific water quality considerations.
TDS is used primarily as a water quality measurement and not as a pollutant that can be controlled through
biological treatment. It often is used as a measurement of the salinity of an ambient water or a wastewater
and often indicates the presence of naturally occurring salts of metals such as sodium, iron, and magnesium.
While it can inhibit biological treatment processes at levels above 10,000 mg/L, acclimated biological
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treatment systems can operate successfully with influent IDS concentrations as high as 76,000 mg/L
(reference 55). The median concentration of total dissolved solids was 16,000 mg/L for landfills in the
Hazardous subcategory. Therefore, EPA has determined that concentrations of total dissolved solids found
in landfills in the Hazardous subcategory do not justify regulation. Similarly, hexane extractable material
is a general, wet chemistry indicator measurement for oil and grease compounds that generally can be
controlled through source reduction and good housekeeping. Therefore, EPA did not select hexane
extractable material for regulation.
EPA detected low levels of 2,4-D, 2,4-DB, 2,4,5-TP, dicamba, dichloroprop, MCPA, MCPP, picloram,
terbutylazine, 1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, OCDD, and OCDF in three out of five of
the Hazardous subcategory landfills sampled during EPA's sampling program. At the concentrations found
in raw landfill wastewater, EPA expects these pollutants to partition to the biological sludge created as a
result of the use of the BPT/B AT treatment technologies. EPA sampling data and calculations conclude
that the concentrations of these pollutants present in the untreated wastewater will not prevent the sludge
from being redeposited in a hazardous landfill.
EPA did not select the following twenty-one pollutants for regulation in the Hazardous subcategory because
they are not controlled by the selected BPT/B AT technology:
Twenty-One Pollutants Not Selected for Regulation in the Hazardous Subcategory Because They
Are Not Controlled by the Selected BPT/B AT Technology
Amenable Cyanide
Total Cyanide
1,1 -Dichloroethane
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Benzene
Ethylbenzene
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M-Xylene
Methylene Chloride
O+P Xylene
Toluene
Trans- 1,2-Dichloroethene
Trichloroethene
Vinyl Chloride
Copper
Lithium
Selenium
Tin
Titanium
EPA classifies 1,1-dichloroethane, 1,4-dioxane, 2-butanone, 2-propanone, 4-methyl-2-pentanone,
benzene, ethylbenzene, m-xylene, methylene chloride, o+p xylene, toluene, trans-1,2-dichloroethene,
trichloroethene, and vinyl chloride as "volatile organics" under analytical test method 1624. Because the
selected BPT/BAT technology for the Hazardous subcategory is aerated equalization followed by chemical
precipitation, biological treatment, and multimedia filtration, EPA determined that the majority of the
removal of volatile organic compounds is due to volatilization to the atmosphere in either the aerated
equalization tanks or in the activated sludge aeration basin. Therefore, EPA did not regulate volatile organic
pollutants because the BPT/BAT technology does not provide controls for removal of these pollutants.
While EPA does not recognize the transfer of pollutants from one media to another as effective treatment,
based on the concentrations of these pollutants in untreated wastewater (below treatable levels (10 times
the method detection limit)), indications are that the potential increase in air emissions due to this regulation
will be minimal.
Volatile organic compounds (VOCs) in hazardous waste landfill leachate are being steadily minimized due
to the Resource Conservation and Recovery Act (RCRA) land disposal restriction rules, which typically
require aggressive destructive treatment of organics in hazardous wastes before the waste can be landfilled
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(see 40 CFR 268.40 and 268.48).l VOC levels in historic landfill leachate (from both hazardous and non-
hazardous waste landfills dating from the 1930s to the mid-1990s) are also at levels which are low enough
as not to call into question EPA's determination to base these rules on the performance of aerated
biological systems. Tables 6-9, 6-10, and 6-13 show the concentrations of VOCs found in landfill
wastewater.
For the proposed rule, EPA established direct discharge limitations for benzene and toluene for landfills in
the Hazardous subcategory. However, after proposal, EPA decided not to regulate benzene and toluene
because they are not treated by the chemical or biological treatment technology selected as the basis for
the landfills effluent limitations. Furthermore, based on the concentration of benzene (3 7 ug/L) and toluene
(104 ug/L) in untreated leachate, the Agency concluded that the loading of benzene and toluene to the
atmosphere will not cause toxic effects.
The Hazardous subcategory median untreated wastewater concentrations for copper, lithium, selenium, tin,
and titanium were well below treatable concentrations (10 times the method detection limit). Median
untreated wastewater concentrations ranged from 0.02 mg/L to 0.03 mg/L for selenium, copper, and
titanium, 0.15 mg/L for tin, and 0.45 mg/L for lithium. While the metals are incidentally removed by the
BPT/B AT technology, these concentrations are well below treatable concentrations for conventional metals
precipitation technologies.
For total cyanide, the median untreated wastewater concentration for the Hazardous subcategory is 0.08
mg/L, which is well below treatable concentrations for conventional cyanide destruction technologies.
While the median raw wastewater concentration of amenable cyanide at hazardous landfills is 1.6 mg/L,
EPA concluded that the median untreated wastewater concentration data for total cyanide is more
1 There are certain exceptions to these treatment requirements for hazardous wastewater which is disposed in surface
impoundments. RCRA section 3005 (j) (11). However, if this wastewater contains VOCs above a designated
concentration level, then the impoundments are subject to rules requiring control of the resulting air emissions. 40
CFR 264.1085 and 263.1086.
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representative than amenable cyanide data of cyanide concentrations in hazardous landfill wastewater
because the Agency collected data from ten facilities on total cyanide (one of which was non-detect) and
only four facilities (two of which were non-detect) on amenable cyanide.
Based on these factors, the Agency concluded that the five metals plus amenable and total cyanide were
present in untreated landfill wastewater at concentrations that were too low to be treated effectively by
conventional metals and cyanide treatment technologies (chemical precipitation and chemical oxidation,
respectively). Because EPA's BPT/BAT technology does not control these small concentrations of
pollutants, the Agency has decided to exclude them from regulation.
In conclusion, the following 13 pollutants of interest will be regulated under BPT/BAT/NSPS in the
Hazardous subcategory:
Thirteen Pollutants Selected for Regulation in the Hazardous Subcategory
Ammonia as Nitrogen
BOD5
TSS
Alpha Terpineol
Aniline
Benzoic Acid
Naphthalene
P-Cresol
Phenol
Pyridine
Arsenic
Chromium
Zinc
Chapter 11 describes in detail the development of the effluent limitations for each of these pollutants.
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7.7 Selection of Pollutants to be Regulated for Indirect Dischargers
Section 307(b) of the Clean Water Act (CWA) requires the Agency to promulgate pretreatment standards
for existing sources (PSES) and new sources (PSNS). To establish pretreatment standards, EPA must
first determine whether each BAT pollutant under consideration is not susceptible to treatment by a POTW,
or interferes with the POTW's operation or sludge disposal practices.
7.7.1 Pass-Through Analysis for Indirect Dischargers
The Agency evaluated whether a pollutant is susceptible to treatment at a POTW by comparing removals
between direct dischargers and well-operated POTWs for pollutants of interest for both subcategories,
listed in Tables 7-1 and 7-2. In comparing removals, the Agency compares the percentage of a pollutant
removed by POTWs with the percentage of the pollutant removed by direct discharging facilities applying
BAT.
EPA compares removal s for two reasons: 1) to ensure that wastewater treatment performance for indirect
dischargers is equivalent to that for direct dischargers, and 2) to recognize and take into account the
treatment capability and performance of the POTW in regulating the discharge of pollutants from indirect
dischargers. Rather than compare the mass or concentration of pollutants discharged by the POTW with
the mass or concentration of pollutants discharged by a BAT facility, EPA compares the percentage of the
pollutants removed by the BAT treatment system with the POTW removal. EPA takes this approach
because a comparison of mass or concentration of pollutants in a POTW effluent to pollutants in a BAT
facility's effluent would not take into account the mass of pollutants discharged to the POTW from non-
industrial sources, nor the dilution of the pollutants in the POTW effluent to lower concentrations from the
addition of large amounts of non-industrial wastewater.
To establish the performance of well-operated POTWs, EPA used the information provided from "Fate
of Priority Pollutants in Publicly Owned Treatment Works" (commonly referred to as the 50-POTW
Study), supplemented by EPA's National Risk Management Research Laboratory's (NRMRL) treatability
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database. EPA used NRMRL's database for those pollutants not found in the 50-POTW study. Chapter
4 discusses these studies in detail.
The 50-POTW Study presents data on 50 well-operated POTWs achieving secondary treatment. For this
rulemaking, EPA edited the data in the 50-POTW Study and the data collected for this rule. Because the
50-POTW Study data included influent levels that were close to the detection limit, EPA eliminated these
values, thereby minimizing the possibility that low POTW removals might simply reflect low influent
concentrations instead of being a true measure of treatment effectiveness. EPA applied the following
hierarchal data editing rules to the 50-POTW Study data:
1) Include only detected pollutants having at least three pairs (influent/effluent) of data points.
2) Eliminate average pollutant influent values less than 10 times the minimum analytical detection limit,
along with the corresponding effluent values.
3) For analytes where no average influent concentrations were greater than 10 times the minimum
level2, eliminate all average influent values less than five times the minimum level, along with the
corresponding effluent values;
4) For analytes where no average influent concentration was greater than five times the minimum level,
eliminate all average influent concentrations less than 20 ug/L, along with the corresponding effluent
values.
After editing the database, EPA then calculated POTW-specific percent removals for each pollutant based
on its average influent and average effluent values. The POTW percent removal used for each pollutant
in the pass-through test is the median value of all the POTW specific percent removals for that pollutant.
EPA then compared the median POTW percent removal to the median percent removal for the BAT
option treatment technology to determine pass through.
In applying the data editing rules for the 50-POTW Study for the final rule, the minimum level assigned to the
non-detect values was the minimum level at the time of the 50-POTW Study (circa 1978-1980). For the proposal,
the minimum level assigned to the non-detect values for 50-POTW removals was the Landfills study minimum
levels (circa 1994).
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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 NRMRL Treatability Database . The
database provides the user with the specific source and the industry from which the wastewater was
generated. EPA used the NRMRL database to augment the POTW database for the pollutants for which
the 50-POTW Study did not cover. EPA applied the following data editing rules to the data in the
NRMRL database:
1) Only use treatment technologies representative of typical POTW secondary treatment operations
(aerobic lagoons, activated sludge, activated sludge with sedimentation and/or filtration).
2) Only use domestic or industrial wastewater data.
3) Use pilot-scale and full-scale data; eliminate bench-scale data.
4) Use data from a paper in a peer-reviewed j ournal or government report; edit out lesser quality
references.
5) Eliminate zero or negative percent removals.
6) For each of the NRMRL sources, EPA first selected data having at least three pairs
(influent/effluent) of data points. If no data source contained three pairs of data points, then EPA
selected only those facilities having at least two pairs of data points. If none of the data sources
contained two pairs of data points, then EPA selected those with one pair (influent/effluent) of data
points. EPA applied the paired data editing criteria explained above to the following hierarchy of
NRMRL data sources:
a. NRMRL Treatability data at > lOxMDL - Domestic wastewater.
b. NRMRL Treatability data at > SxMDL - Domestic wastewater.
c. NRMRL Treatability data at >20 ug/L - Domestic wastewater.
d. NRMRL Treatability data at > lOxMDL - Industrial wastewater.
e. NRMRL Treatability data at > SxMDL - Industrial wastewater.
f. NRMRL Treatability data at >20 ug/L - Industrial wastewater.
g. NRMRL Treatability data - any available Domestic and/or Industrial data.
h. Generic pollutant group removal data.
From the NRMRL facilities remaining after applying the above editing criteria, EPA determined the median
percent removal for a particular pollutant. The Agency used this median percent removal to represent
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POTW removal and compared it to the median percent removal for the BAT option treatment technology
in order to determine pass through.
Tables 7-3 and 7-4 present the POTW percent removals for each regulated pollutant in the Non-
Hazardous and Hazardous subcategory, respectively. These tables indicate the source of the percent
removal and which editing criteria applied.
7.7.2 Non-Hazardous Subcategory Pollutants to be Regulated for Indirect Dischargers
EPA conducted a removal comparison on the priority and nonconventional pollutants regulated under BAT
for non-hazardous landfills. EPA did not perform this assessment for the regulated conventional pollutants,
namely BOD5 and TSS, since the conventional pollutants are generally not regulated under PSES and
PSNS. For the proposal, EPA evaluated the seven nonconventional and toxic pollutants proposed for
regulation under BAT for the Non-Hazardous subcategory, and concluded that ammonia removals were
greater at the BAT facilities. Following the proposal, EPA reviewed the data used for the BAT percent
removal calculations. In the proposal, EPA calculated the BAT percent removals using data from
well-operated biological treatment facilities in EPA's database. However, some of these facilities did not
pass the editing criteria for selection as a BPT/B AT facility. In the revised analysis, EPA calculated percent
removals using data from only those seven facilities that passed the BPT/B AT editing criteria. In addition,
in the proposal, EPA inadvertently failed to use selected BAT facilities in the calculation of percent
removals for several pollutants even though the data that met the editing criteria for the facility were
available. As a result of this review, the BAT facility removals for the analysis have changed for the Non-
Hazardous subcategory since the proposal. Finally, after proposal, EPA decided not to set BPT limits for
toluene. Therefore, this pollutant is not considered in the analysis, see Section 7.6.1.
In determining BAT percent removals, EPA used data from selected BAT facilities only if they met the
following criteria:
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1) The influent concentration for a particular pollutant was greater than lOxMDL,
2) The facility had demonstrated removal of the pollutant (EPA did not use facilities showing zero or
negative percent removal), and
3) The facility did not employ treatment technologies in addition to the selected BAT that may
contribute to further reduction of the pollutant.
Applying the editing criteria outlined above to those facilities selected as BAT resulted in a different set of
facilities being used in the calculation of the percent removals than in proposal for each of the pollutants to
be regulated. Table 7-5 lists the BAT facilities used in the calculation of percent removals for the non-
hazardous regulated pollutants.
The Agency used EPA sampling episode data, Detailed Questionnaire Section C data and Detailed
Monitoring Questionnaire data to calculate the non-hazardous BAT facility percent removals. However,
if a particular facility had applicable Detailed Questionnaire Section C and Detailed Monitoring
Questionnaire data, EPA used only the Detailed Monitoring Questionnaire data in calculating the BAT
percent removals because of a potential overlap of the concentration data submitted for these two
questionnaires. EPA used only data with matching influent and effluent data points. The Agency calculated
a percent removal for each data source, and then determined an overall median percent removal for each
regulated pollutant. Table 7-5 presents the summary of BAT performance data used in calculating the
percent removals for the Non-Hazardous subcategory. Table 7-6 presents the results of the removal
comparison for the Non-Hazardous subcategory. This table shows the median BAT percent removal and
the median POTW percent removal. Although the removal comparison suggests that, at the time of
proposal, only ammonia would pass through, as a result of further review of the applicable data contained
in the Public Record, the comparison for the final rule suggests that three other pollutants (benzoic acid,
p-cresol, and phenol) would pass through in the Non-Hazardous subcategory. However, for the reasons
discussed in Chapter 11, EPA is not establishing pretreatment limits for any pollutant in the Non-Hazardous
subcategory because it concluded the pollutants which might pass through were, in fact, in most cases
susceptible to treatment and that national regulation was not required.
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7.7.3 Hazardous Subcategory Pollutants to be Regulated for Indirect Dischargers
EPA conducted removal comparisons for the priority and nonconventional pollutants regulated under BAT
for hazardous landfills. EPA did not perform the analysis for the regulated conventional pollutants, namely
BOD5 and TSS, since the conventional pollutants are generally not regulated under PSES and PSNS. For
the proposal, EPA performed the analysis on the thirteen nonconventional and toxic pollutants proposed
for regulation under BAT for the Hazardous subcategory and determined that seven pollutants appeared
to pass through. EPA proposed pretreatment standards for the following six of these pollutants: ammonia
as nitrogen, benzoic acid, toluene, alpha terpineol, p-cresol, and aniline. For the proposed rule, EPA used
both of the BAT facilities in the calculation of percent removals. However, upon review of the data editing
procedures, EPA determined that some of the facility data should not have been used in the calculation of
percent removals. As a result of this review, the BAT facility removals for the removal comparison have
changed for the Hazardous subcategory since the proposal. Finally, after proposal, EPA decided not to
set BPT limits for toluene and benzene; therefore, these pollutants are not considered in the comparison
(see Section 7.6.2).
In determining BAT percent removals, EPA used data from selected BAT facilities only if they met the
following criteria:
1) The influent concentration for a particular pollutant was greater than lOxMDL,
2) The facility had demonstrated removal of the pollutant (EPA did not use facilities showing zero or
negative percent removal), and
3) The facility did not employ treatment technologies in addition to the selected BAT that may
contribute to further reduction of the pollutant.
Applying the editing criteria outlined above to those facilities selected as BAT resulted in a different set of
facilities being used in the calculation of the percent removals for each of the pollutants to be regulated.
Table 7-7 lists the BAT facilities used in the calculation of percent removals for the hazardous regulated
pollutants.
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The Agency used EPA sampling episode data Detailed Questionnaire Section C data and Detailed
Monitoring Questionnaire data to calculate the hazardous BAT facility percent removals. However, if a
particular facility had applicable Detailed Questionnaire Section C and Detailed Monitoring Questionnaire
data, EPA used only the Detailed Monitoring Questionnaire data in calculating the BAT percent removals
because of a potential overlap of the concentration data submitted for these two questionnaires. EPA used
only data with matching influent and effluent data points. The Agency calculated a percent removal for each
data source, and then determined an overall median percent removal for each regulated pollutant. Table
7-7 presents the summary of BAT performance data used in calculating the percent removals for the
Hazardous subcategory. Table 7-8 presents the results of the removal comparison for the Hazardous
subcategory. This table shows the median BAT percent removal and the median POTW percent removal.
At the time of proposal, the removal comparison suggested better removals at BAT facilities than at
POTWs for seven pollutants (ammonia, alpha terpineol, aniline, benzoic acid, p-cresol, phenol, and
toluene). As a result of EPA's assessment, the comparison now suggests greater BAT removals for the
following eight pollutants: ammonia, alpha terpineol, aniline, benzoic acid, naphthalene, p-cresol, phenol,
and pyridine. However, for the reasons discussed in Chapter 11, EPA is not establishing pretreatment
limits for any pollutant in the Hazardous subcategory.
7-28
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Table 7-1: Non-Hazardous Subcategory Pollutants of Interest
Non-Hazardous
Pollutant of Interest
Conventional
BOD
TSS
Nonconventional
Ammonia as Nitrogen
COD
Nitrate/Nitrite
IDS
TOC
Total Phenols
Organic
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzoic Acid
Hexanoic Acid
Methylene Chloride
N,N-Dimethylformamide
0-Cresol
P-Cresol
Phenol
Toluene
Tripropyleneglycol Methyl Ether
Metals
Barium
Chromium
Hexavalent Chromium
Strontium
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
Disulfoton
Dioxins/Furans
1234678-HpCDD
OCDD
Cas#
C-002
C-009
7664417
C-004
C-005
C-010
C-012
C-020
123911
78933
67641
108101
98555
65850
142621
75092
68122
95487
106445
108952
108883
20324338
7440393
7440473
18540299
7440246
7440326
7440666
120365
298044
35822469
3268879
Subtitle D Municipal
Pollutant of Interest
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Subtitle D Non-Municipal
Pollutant of Interest
X
X
X
X
X
X
X
X
X
7-29
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Table 7-2: Hazardous Subcategory Pollutants of Interest
Pollutant of Interest
Conventional
BOD
Hexane Extractable Material
TSS
Nonconventional
Amenable Cyanide
Ammonia as Nitrogen
COD
Nitrate/Nitrite
IDS
TOC
Total Phenols
Organics
1 , 1 -Dichloroethane
1,4-Dioxane
2,4-Dimethylphenol
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Aniline
Benzene
Benzoic Acid
Benzyl Alcohol
Diethyl Ether
Ethylbenzene
Hexanoic Acid
Isobutyl Alcohol
Methylene Chloride
M-Xylene
Naphthalene
0+P Xylene
0-Cresol
Phenol
Pyridine
Cas#
C-002
C-036
C-009
C-025
7664417
C-004
C-005
C-010
C-012
C-020
75343
123911
105679
78933
67641
108101
98555
62533
71432
65850
100516
60297
100414
142621
78831
75092
108383
91203
136777612
95487
108952
110861
Pollutant of Interest
Organics (cont.)
P-Cresol
Toluene
Trans- 1 ,2-Dichloroethene
Trichloroethene
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Metals
Arsenic
Chromium
Copper
Lithium
Molybdenum
Nickel
Selenium
Strontium
Tin
Titanium
Total Cyanide
Zinc
Pesticides/Herbicides
2,4,5-TP
2,4-D
2,4-DB
Dicamba
Dichloroprop
MCPA
MCPP
Picloram
Terbuthylazine
Dioxins/Furans
1234678-HpCDD
1234678-HpCDF
OCDD
OCDF
Cas#
106445
108883
156605
79016
20324338
75014
7440382
7440473
7440508
7439932
7439987
7440020
7782492
7440246
7440315
7440326
57125
7440666
93721
94757
94826
1918009
120365
94746
7085190
1918021
5915413
35822469
67562394
3268879
39001020
7-30
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Table 7-3: Non-Hazardous Subcategory - POTW Percent Removals
Pollutant
Ammonia as Nitrogen
Alpha-Terpineol
Benzoic Acid
P-Cresol
Phenol
Zinc
MDL
(uafL)
10
10
50
10
10
20
Median
% Removal
39
95
81
68
95
81
POTW Percent Removal Source
50 POTW lOxMDL
NRMRL lOxMDL - Industrial
NRMRL lOxMDL - Industnal
NRMRL lOxMDL - Domestic & Industrial Sources
50 POTW lOxMDL
50 POTW lOxMDL
Table 7-4: Hazardous Subcategory - POTW Percent Removals
Pollutant
Ammonia as Nitrogen
Alpha-Terpineol
Aniline
Benzoic Acid
Napthalene
Phenol
Pyridine
P-Cresol
Arsenic
Chromium
Zinc
MDL
(ugfL)
10
10
10
50
10
10
10
10
10
10
20
Median
% Removal
39
95
98
81
95
95
95
75
66
82
81
POTW Percent Removal Source
50 POTW lOxMDL
NRMRL lOxMDL - Industrial
NRMRL lOxMDL - Industrial
NRMRL lOxMDL - Industrial
SOPOTWIOxMDL
SOPOTWIOxMDL
NRMRL lOxMDL - Industnal
NRMRL lOxMDL - Domestic & Industrial Sources
50 POTW >20 ppb
50 POTW lOxMDL
SOPOTWIOxMDL
7-31
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Table 7-5: Non-Hazardous Subcategory - BAT Performance Data
Pollutants of Interest
Ammonia
Alpha Terpineol
Benzole Acid
P-Cresol
Phenol
Zinc
Facility
/Episode
16041 (DMQ)
16041 (ANL)
16122 (ANL)
16132 (DMQ)
16041 (ANL)
16122 (ANL)
16041 (ANL)
16122 (ANL)
16041 (ANL)
16041 (ANL)
16118(DET)
16122 (ANL)
16041 (DMQ)
16041 (ANL)
16132 (DMQ)
Avg Inf
679
475
181
206
653
123
15400
9300
1360
5120
350
395
505
310
490
AvgEff
5.39
1.4
1.14
5.9
10
10
50
50
10
10
10
10
214
87
50
% Removal
99.21
99.71
99.37
97.14
99.29 Median
98.47
91.87
95.17 Median
99.68
99.46
99.57 Median
99.26 Median
99.80
97.14
97.47
97.47 Median
57.62
71.94
89.80
71.94 Median
All units in ug/L, except ammonia in mg/L.
DMQ: Detailed Monitoring Questionnaire data
ANL: EPA sampling episode data
DET: Detailed Questionnaire data
7-32
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Table 7-6: Pass-Through Analysis for the Non-Hazardous Subcategory
Pollutant
Ammonia
Alpha Terpineol
Benzoic Acid
P-Cresol
Phenol
Zinc
Average BAT
Percent Removal
99%
95%
99%
99%
97%
72%
Average POTW Percent
Removal
39%
95%
81%
68%
95%
81%
7-33
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Table 7-7: Hazardous Subcategory - BAT Performance Data
Pollutants of Interest
Ammonia
Alpha-Terpineol
Aniline
Benzoic Acid
Naphthalene
P-Cresol
Phenol
Pyridine
Arsenic
Chromium
Zinc
Facility
/Episode
16041 (DMQ)
16041 (ANL)
16122 (ANL)
16132 (DMQ)
16041 (ANL)
16041 (ANL)
16087 (ANL)
16041 (ANL)
16087 (ANL)
16041 (ANL)
16041 (ANL)
16087 (ANL)
16041 (ANL)
16087 (DET)
16087 (ANL)
16087 (ANL)
16087 (DMQ)
16087 (ANL)
16041 (DET)
16087 (DMQ)
16087 (ANL)
16041 (DMQ)
16041 (ANL)
16087 (DMQ)
Avg Inf
679
475
181
206
653
1060
533
15400
64957
645
1360
5022
5120
98500
65417
301
1400
584
210
730
415
505
310
550
Avg Eff
5.39
1.4
1.14
5.9
10
10
10
50
50
10
10
10
10
814
31
10
325
308
120
312
82
214
87
380
% Removal
99.21
99.71
99.37
97.14
99.29 Median
98.47 Median
99.06
98.12
98.59 Median
99.68
99.92
99.80 Median
98.45 Median
99.26
99.80
99.53 Median
99.80
99.17
99.95
99.80 Median
96.68 Median
76.79
47.26
62.02 Median
42.86
57.26
80.24
57.26 Median
57.62
71.94
30.91
57.62 Median
All units in ug/L, except ammonia in mg/L.
DMQ: Detailed Monitoring Questionnaire data
ANL: EPA sampling episode data
DET: Detailed Questionnaire data
7-34
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Table 7-8: Pass-Through Analysis for the Hazardous Subcategory
Pollutant
Ammonia
Alpha Terpineol
Aniline
Benzoic Acid
Naphthalene
P-Cresol
Phenol
Pyridine
Arsenic
Chromium
Zinc
Average BAT
Percent Removal
99%
98%
99%
99%
98%
99%
99%
97%
62%
57%
58%
Average POTW Percent
Removal
39%
95%
98%
81%
95%
68%
95%
95%
66%
82%
81%
7-35
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Figure 7-1: Development of Pollutants of Interest
Start with 470 pollutant parameters \
analyzed in each episode I
/^ Was the
pollutant parameter ever"
detected in any
^\ sample?
-No-
Pollutants removed from consideration
because they were never detected in
any sample:
Non-Hazardous Municipal-316
Non-Hazardous Non-Municipal-324
Hazardous-250
List of pollutants detected at least once in any sample:
Non-Hazardous Municipal-154
Non-Hazardous Non-Municipal-146
Hazardous-220
^^--"'Is the pollutant detected three^~~--^^
or more times at a concentration equal to or
greater than five times the minimum level (for
dioxins/furans at a concentration above the
^~~^-\^ minimum level)? ^^-^""^
Yes
Is the pollutant detected at more than one
in-scope facility (excluding captives)?
-No-
Is the pollutant a treatment chemical or a naturally
occurring compound in soil or groundwater?
-Yes-
Remaining pollutants considered pollutants
of interest:
Non-Hazardous Municipal-32
Non-Hazardous Non-Municipal-9
Hazardous-63
Go to
Figure 7-2
Pollutants removed from consideration
since not detected three or more times at a
concentration equal to or greater than five
times the minimum level:
Non-Hazardous Municipal-102
Non-Hazardous Non-Municipal-124
Hazardous-138
Pollutants removed from consideration
since not detected at more than one facility:
Non-Hazardous Municipal-6
Non-Hazardous Non-Municipal-0
Hazardous-5
Pollutants removed from consideration
since they were considered treatment
chemicals or naturally occurring
compounds:
Non-Hazardous Municipal-14
Non-Hazardous Non-Municipal-13
Hazardous-14
7-36
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Figure 7-2: Selection of Pollutants to be Regulated
Remaining pollutants considered
pollutants of interest:
Non-Hazardous Municipal-32
Non-Hazardous Non-Municipal-9
Combined Non-Hazardous-32
Hazardous-63
Will the pollutant be
controlled through the regulation
of other pollutants?
Yes
Is the pollutant controlled by
the selected BPT technology?
No
Yes
Pollutants removed from consideration because they were
controlled through the regulation of other pollutants:
Non-Hazardous-COD, TOC, total phenols, hexanoic acid,
o-cresol, tripropyleneglycol methyl ether, titanium
Hazardous-COD, TOC, total phenols, 2,4-dimethylphenol,
benzyl alcohol, diethyl ether, isobutyl alcohol, hexanoic acid,
o-cresol, tripropyleneglycol methyl ether, molybdenum, nickel,
strontium
Pollutants removed from consideration because they were
present in only trace amounts and/or were not likely
to cause toxic effects:
Non-Hazardous-nitrate/nitrite, TDS, 1,4-dioxane, 4-methyl-2-
pentanone, methylene chloride, n,n-dimethylformamide, toluene,
barium, chromium, dichloroprop, disulfoton, 1234678-HpCDD,
OCDD
Hazardous-hexane extractable material, nitrate/nitrite, TDS, 2,4-
D, 2,4-DB, 2,4,5-TP, dicamba, dichloroprop, MCPA, MCPP,
picloram, terbutylazine, 1234678-HpCDD, 1234678-HpCDF,
OCDD, OCDF
Pollutants selected for regulation:
Non-Hazardous-ammonia as nitrogen, BOD5, TSS, alpha-
terpineol, benzoic acid, p-cresol, phenol, zinc
Hazardous-ammonia as nitrogen, BOD , TSS, alpha-
terpineol, aniline, benzoic acid, naphthalene, p-cresol,
phenol, pyridine, arsenic, chromium, zinc
Pollutants removed from consideration because they were not
controlled by the selected BPT technology:
Non-Hazardous-2-butanone, 2-propanone, hexavalent chromium,
strontium
Hazardous-amenable cyanide, total cyanide, 1,1-dichloroethane,
1,4-dioxane, 2-butanone, 2-propanone, 4-methyl-2-pentanone,
benzene, ethylbenzene, m-xylene, methylene chloride, o+p
xylene, toluene, trans-l,2-dichloroethene, trichloroethene, vinyl
chloride, copper, lithium, selenium, tin, titanium
7-37
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8.0 WASTEWATER TREATMENT TECHNOLOGY DESCRIPTION
This chapter consists of the following two main parts: Section 8.1, describing the wastewater treatment and
sludge handling methods currently in use in the Landfills industry and Section 8.2, presenting a discussion
on the performance of treatment systems evaluated by EPA using data collected during engineering site
visits and field sampling programs.
8.1 Available BAT and PSES Technologies
The Landfills industry uses a wide variety of technologies for treating wastewater discharges. These
technologies can be classified into the following five areas:
Section
• Best Management Practices 8.1.1
• Physical/Chemical Treatment 8.1.2
• Biological Treatment 8.1.3
Sludge Handling 8.1.4
• Zero Discharge options 8.1.5
The EPA's Detailed Questionnaire obtained information on 14 treatment technologies currently in use in
the Landfills industry. Table 8-1 presents the technologies most commonly used by in-scope Subtitle D
non-hazardous and Subtitle C hazardous landfill facilities by discharge type. The table reports the percent
of landfill facilities which use each treatment technology. In addition, EPA collected detailed information
on available technologies from engineering site visits to a number of landfill facilities. The data presented
below are based on these data collection efforts.
8.1.1 Best Management Practices
Best management practices with regard to wastewater generation at landfills can be designed to do one of
8-1
-------
two things: reduce the volume of leachate produced by the landfill or reduce the toxicity of the leachate
produced by the landfill. The volume of leachate generated by a landfill is largely dependent on the annual
precipitation that falls within the landfill area, percolates through the landfilled waste, and collects in the
leachate collection system. State and Resource Conservation and Recovery Act (RCRA) regulations
require closed landfills to install an impermeable cap over the landfill to prevent infiltration of rainwater,
which will eventually reduce the volume of wastewater produced by the landfill. Open landfills, however,
can similarly use methods to reduce rainwater infiltration to the landfill and, hence, reduce wastewater
generation. The open face of the landfill is the active area where solid waste is deposited, compacted, and
covered with daily fill. This area can act as a collection point for rainwater. By maintaining a small open
face on the landfill, along with using impermeable materials on the closed or inactive sections, a landfill
operator can reduce the volume of wastewater collected and produced by an open landfill.
The criteria outlined by the Office of Solid Waste and Emergency Response in 40 CFR § 257, 258, 264,
and 265 provide additional controls to reduce the volume and/or toxicity of landfill leachate. 40 CFR Part
257 ("Criteria for Classification of Solid Waste Disposal Facilities and Practices") establishes disposal
practices for non-municipal, non-hazardous waste di sposal units (including waste disposal units that receive
conditionally-exempt small quantity generator waste). InPart257.3-3(c),theregulationsstatethatafacility
shall not cause non-point source pollution of waters of the United States that violates the applicable legal
requirements implementing an area or Statewide water quality management plan. 40 CFR Part 258
("Criteria for Municipal Solid Waste Landfills") requires municipal solid wastelandfillsto design, construct
and maintain run-on/run-off control systems (40 CFR 258.26), cover the disposed solid waste with six
inches of earthen material at the end of each operating day (40 CFR 258.21), and subject these facilities
to closure criteria, which require a final cover to be applied to cover the wastes (40 CFR 258.60). These
requirements greatly reduce the risk of storm water becoming contaminated as a result of direct contact
with the deposited solid waste. Subpart N of 40 CFR Part 264 ("Standards for Owners and Operators
of Hazardous Waste Treatment, Storage, and Disposal Facilities") establishes design and operating
requirements for hazardous waste landfills. Hazardous waste landfills must design, construct, operate, and
8-2
-------
maintain run-on/run-off control systems (264.301(g)) and, if the landfill contains parti culate matter which
maybe subject to wind dispersal, the operator must cover or otherwise manage the landfill to control wind
dispersal (264.301Q)). Subpart N of 40 CFR Part 265, "Interim Status Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities," defines similar controls to
those identified above for Part 264 for the control of storm water contamination.
In addition, many municipal solid wastelandfillsandcommunitieshavedevelopedprogramstopreventtoxic
materials from being deposited in landfills. Solid waste generated by households may contain many types
of waste which may present an environmental hazard, including paints, pesticides, and batteries. Many
communities have developed household hazardous waste collection programs which collect and dispose
of these hazardous wastes in an appropriate manner, thus avoiding deposition of hazardous wastes in the
municipal landfill and reducing the risks associated with the leachate produced by the landfill.
8.1.2 Physical/Chemical Treatment
8.1.2.1 Equalization
Wastewater and leachate generation rates at landfills vary due to their direct relationship to rainfall, storm
water run-on and run-off, ground water entering the waste-containing zone, and the moisture content and
absorption capability of the wastes. To allow for the equalization of pollutant loadings and flow rates,
leachate and other landfill generated wastewater is often collected prior to treatment in tanks or ponds with
sufficient capacity to hold the peak flows generated at the facility. A constant flow is delivered to the
treatment system from these holding tanks in order to dampen the variation in hydraulic and pollutant
loadings to the wastewater treatment system. This reduction in hydraulicand pollutant variability increases
the performance and reliability of down stream treatment systems and can reduce the size of subsequent
treatment tanks and chemical or polymer feed rates by reducing the maximum flow rates and concentrations
of pollutants. Equalization also lowers the operating costs associated with treatment units by reducing
instantaneous treatment capacity demand and by optimizing the amount oftreatment chemicals required for
a less erratic set oftreatment variables. National estimates based on EP A's Detailed Questionnaire data
8-3
-------
show that 21 percent of direct and 12 percent of indirect non-hazardous landfill facilities use some form
of equalization as part of wastewater treatment systems.
Equalization systems consist of steel or fiberglass holding tanks or lined ponds that provide sufficient
capacity to contain peak flow conditions. Detention times are determined using a mass balance equation
and are dependent on site-specific generation rates and treatment design criteria. According to data
collected by EPA's Detailed Questionnaire, detention times can range from less than a day to 90 days, with
a median value of about two days. Equalization systems contain either mechanical mixing systems or
aeration systems to enhance the equalization process by keeping the tank contents well mixed and
prohibiting the settling of solids.
A breakdown of equalization systems used in the Landfills industry based on the responses to the Detailed
Questionnaire is as follows:
Equalization Type % Non-Hazardous Facilities % Hazardous Facilities
Direct Indirect Indirect
Unstirred 13 7 0
Mechanically Stirred >1 <1 0
Aerated 11 6 0
A typical equalization system is shown in Figure 8-1.
8.1.2.2 Neutralization
Wastewater generated by landfills may have a wide range of pH depending on the types of waste deposited
in the landfill. In many instances, raw wastewater may require neutralization to eliminate either high or low
pH values that may upset a treatment system, such as activated sludge biological treatment. However,
landfill facilities also use neutralization systems in conjunction with certain chemical treatment processes,
such as chemical precipitation, to adjust the pH of the wastewater to optimize process control. Acids,
such as sulfuric acid or hydrochloric acid, are added to reduce pH, and alkalies, such as sodium hydroxide,
8-4
-------
are added to raise pH values. Neutralization may be performed in a holding tank, rapid mix tank, or an
equalization tank. Typically, neutralization systems at the end of atreatment system are designed to control
the pH of the discharge to between 6 and 9. National estimates based on EPA's Detailed Questionnaire
data show that 33 percent of indirect hazardous landfills, 6 percent of indirect non-hazardous landfills, and
7 percent of direct non-hazardous landfill facilities employ neutralization as part of wastewater treatment
systems using a variety of chemical additives to control pH.
Figure 8-2 presents a flow diagram for a typical neutralization system.
8.1.2.3 Flocculation
Flocculation is a treatment technology used to enhance sedimentation or filtration treatment system
performance. Flocculation precedes these 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 flocculation chemical is added.
Flocculants adhere readily to suspended solids and each other to facilitate gravity sedimentation or filtration.
Coagulants canbe added to reduce the electrostatic surface charges and enhance the formation of complex
hydrous oxides. Coagulation allows for the formation of larger, heavier particles, or flocculants (which
usually form in a flocculation chamber), that can settle faster. There are three different types of flocculants
commonly used: 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. A rapid mix tank is usually designed for a detention time from 15 seconds
to several minutes (see reference 3). After mixing, the coagulated wastewater flows to a flocculation basin
where slow mixing of the waste occurs. The slow mixing allows for the particles to agglomerate into
heavier, more settieable solids. Mixing is provided either by mechanical paddle mixers or by diffused air.
Flocculation basins are typically designed for a detention time of 15 to 60 minutes (see reference 3). Since
many landfill facilities employ gravity-assisted separation and chemical precipitation as part of wastewater
treatment systems, EPA assumes that many of these facilities employ flocculation to enhance system
performance.
8-5
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8.1.2.4 Gravity Assisted Separation
Gravity-assisted separation or sedimentation is a simple, economical, and widely used method for the
treatment of landfill wastewater. Clarification systems remove suspended matter, flocculated impurities,
and precipitates from wastewater. By allowing the wastewater to become quiescent, the suspended matter,
which is heavier than water, can settle to the bottom of the clarifier, forming a sludge blanket which can be
removed. This process can occur in specially designed tanks, or in earthen ponds and basins. Clarification
systems can also be equipped to allow for the removal of materials lighter than water, such as oils, which
are skimmed from the surface and collected for disposal. Sedimentation units at landfills are used as either
primary treatment options to remove suspended solids or as a secondary treatment option following a
biological or chemical precipitation process. Sedimentation processes are highly sensitive to flow
fluctuations and, therefore, usually require equalization at facilities with large flow variations.
Clarifiers can be rectangular, square, or circular in shape. In rectangular or square tanks, wastewater flows
from one end of the tank to the other with settled sludge collected into a hopper located at one end of the
tank. In circular tanks, flow enters from the center and flows towards the outside edge with sludge
collected in a center hopper. Treated wastewater exits the clarifier by flowing over a weir located at the
top of the clarifier. Sludge which accumulates at the bottom of the clarifier is periodically removed and is
typically stabilized and/or dewatered prior to disposal. National estimates based on EPA's Detailed
Questionnaire data suggest that 67 percent of indirect hazardous landfills, 9 percent of indirect non-
hazardous landfills, and27 percent of direct non-hazardous landfill facilities employ some form of gravity-
assisted separation as part of wastewater treatment systems.
Flocculation systems are commonly used in conjunction with gravity-assisted clarification systems to
improve their solids removal efficiency. Some clarifiers are designed with a center well to introduce
flocculants and allow for coagulation in order to improve removal efficiencies. A schematic of a typical
clarification system using coagulation and flocculation is shownin Figure 8-3. The main design parameters
used in designing a clarifier are the overflow rate, detention time, and the side water depth. Overflow rate
8-6
-------
is the measure of the flow as a function of the surface area of the clarifier. Typical design parameters used
for both primary and secondary clarifiers are presented below (see reference 7):
Design Parameter Primary Secondary
Overflow rate, gpd/sq ft 600-1,000 500-700
Detention time, min 90-150 90-150
Minimum Side water depth, ft 8 10
A variation of conventional clarification process is the chemically-assisted clarification process. Coagulants
are added to clarifiers to enhance liquid-solid separation, permitting solids denser than water to settle to
the bottom and materials less dense than water (including oil and grease) to flow to the surface. Settled
solids form a sludge at the bottom of the clarifier which can be pumped out continuously or intermittently.
Oil and grease and other floating materials may be skimmed.
Chemically assisted clarification may be used alone or as part of amore complex treatment process. It also
may be used in the following capacities:
• The first process applied to wastewater containing high levels of settleable suspended
solids.
• The second stage of most biological treatment processes to remove the settleable
materials, includingmicroorganisms, from the wastewater; the microorganisms then can be
either recycled to the biological reactor or sent to the facility's sludge handling system.
• The final stage of most chemical precipitation (coagulation/flocculation) processes to
remove the inorganic floes from the wastewater.
As discussed in Chapter 9, chemically-assisted clarification was a component of the model wastewater
treatment technology for estimatingthe BPT engineering costs of compliance and applied in certain cases.
In developing regulatory compliance costs, EPA used chemically-assisted clarification processes as an
additional polishing process after biological treatment. Chemically- assisted clarification processes consist
ofboth a clarifier and apolymer feed system. For facilities currently with sedimentation following biological
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treatment, EPA provided additional costs only for a polymer feed system. EPA included chemically-
assisted clarification systems in the BPT option to aidin the settling process following biological treatment
to enhance both TSS and BOD5 removals through the wastewater treatment process. Higher BOD5
removals can be obtained by the additional removal of microbial floe in the clarifier. EPA costed facilities
for a chemically-assisted clarification system when their current performance for TSS and/or BOD5 was
slightly out of compliance with regulatory levels (up to 10 mg/L for BOD5 and 50 mg/L for TSS). For
instance, if a facility had an aerobic lagoon treatment system and exceeded the regulatory level for TSS by
20 mg/L, EPA costed the facility for a chemically-assisted clarification system.
Although no landfill facilities in EPA's database reported using chemical addition, chemically-assisted
clarification is a proven technology for the removal of BOD5 and TSS in a variety of industrial categories
(see reference 19).
National estimates indicate that less than one percent of direct and indirect non-hazardous landfills use an
alternative clarification system design based on corrugated plate interceptor (CPI) technology. These
systems include a series of small (approximately two inch square) inclined tubes in the clarification settling
zone. The suspended matter must only travel a short distance, when settling or floating, before they reach
a surface of the tube. At the tubes' surface, the suspended matter further coagulate. Because of the
increased surface area provided by the inclined tubes, CPI units can have much smaller settling chambers
than standard clarifiers.
8.1.2.5 Chemical Precipitation
Chemical precipitation is used for the removal of metal compounds from wastewater. In the chemical
precipitation process, soluble metallic ions and certain anions found in landfill wastewater are converted
to insoluble forms, which precipitate from solution. Most metals are relatively insoluble as hydroxides,
sulfides, or carbonates. Coagulation processes are used in conjunction with precipitation to facilitate
removal by agglomeration of suspended and colloidal materials. The precipitated metals are subsequently
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removed from the wastewater stream by liquid filtration or clarification (or some other form of gravity
assisted separation). Other treatment processes such as equalization, chemical oxidation, or reduction (e.g.,
hexavalent chromium reduction) usually precede the chemical precipitation process. The performance of
the chemical precipitation process is affected by chemical interactions, temperature, pH, solubility of waste
contaminants, and mixing effects.
Common precipitates used at landfills facilities include lime, sodium hydroxide, soda ash, sodium sulfide,
and alum. Other chemicalsused in the precipitation process for pH adjustment and/or coagulation include
sulfuric and phosphoric acid, ferric chloride, and poly electrolytes. Often, facilities use a combination of
these chemicals. Precipitation using sodium hydroxide or lime is the conventional method of removing
metals from wastewater at landfill facilities. Hydroxide precipitation is effective in removing metals such
as antimony, arsenic, chromium, copper, lead, mercury, nickel, and zinc. However, sulfide precipitation
is used, instead of hydroxide precipitation, to remove specific metal ions such as mercury, lead, and silver.
Carbonate precipitation is another method of chemical precipitation and is used primarily to remove
antimony and lead. Use of alum as a precipitant/coagulant agent results in the formation of aluminum
hydroxides in wastewater containing calcium or magnesium bicarbonate. Aluminum hydroxide is an
insoluble gelatinous floe which settles slowly and entraps suspended materials. It is effective for removing
metals such as arsenic and cadmium.
Since lime is less expensive than caustic (sodium hydroxide), it is more frequently used at landfill facilities
employing hydroxide precipitation. However, lime is more difficult to handle and feed, as it must be slaked,
slurried, and mixed and can often plug feed system lines. Lime precipitation also produces a larger volume
of sludge. The reaction mechanism for precipitation of a divalent metal using lime is shown below:
M++ + Ca(OH)2 - M(OH)2 + Ca++
And, the reaction mechanism for precipitation of a divalent metal using sodium hydroxide is:
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M++ + 2NaOH - M(OH)2 + 2Na++
In addition to the type of treatment chemical chosen, an important design factor in the chemical precipitation
operation 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 precipitation for each metal, which corresponds to its point of minimum solubility. Figure 8-4
presents calculated solubilities of metal hydroxides. For example, as demonstrated on this figure, the
optimum pH range where zinc is least soluble is 8 to 10.
Another key consideration in a chemical precipitation application is the detention time in the sedimentation
phase of the process. The optimal detention time is dependent on the wastewater being treated and the
desired effluent quality.
The first step of a chemical precipitation process is pH adjustment and the addition of coagulants. This
process usually takes place in separate mixing and flocculation tanks. After mixing the wastewater with
treatment chemicals, the resultant mixture agglomerates in the flocculation tank, and is mixed slowly by
either mechanical means, such as mixers or recirculation pumping. The wastewater then undergoes a
separation/dewatering process, such as clarification or filtration, where the precipitated metals are removed
from solution. In a clarification system, a flocculant, such as a polymer, is sometimes added to aid in the
settling process. The resulting sludge from the clarifier or filter must be further treated, disposed, or
recycled.
National estimates based on EPA's database indicate that 33 percent of indirect hazardous landfills, 5
percent of indirect non-hazardous landfills, and 9 percent of direct non-hazardous landfill facilities employ
chemical precipitation as part of wastewater treatment systems. A typical chemical precipitation system
is presented in Figure 8-5.
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8.1.2.5.1 Iron (Fe) Coprecipitation
One cost-effective approach to remove metals is the iron adsorption and coprecipitation process. This
process involves adding an iron salt, such as ferric chloride or ferric sulfate, to wastewater (unless it already
contains sufficient quantities of dissolved iron) to form iron hydroxide precipitate [Fe(OH)3(s)]. Above a
pH of 4, the formation of this amorphous precipitate occurs rapidly, causing entrapment of many dissolved
and suspended forms of various metals. This "sweep floe" results in the formation of a large quantity of
solids (sludge) that can be gravity separated in a conventional clarifier (see reference 57).
8.1.2.6 Chemical Oxidation/Reduction
Chemical oxidation treatment processes can be used to remove ammonia, to oxidize cyanide, to reduce
the concentration of residual organics, and to reduce the bacterial and viral content of wastewater. Both
chlorine and ozone are two chemicals that are commonly used to destroy residual organics in wastewater.
When these chemicals are used for this purpose, disinfection of the wastewater is usually an added benefit.
A further benefit of using ozone is the removal of color. Ozone can also be combined with hydrogen
peroxide to remove organic compounds in contaminated ground water. Another use of oxidation is for the
conversion of pollutants to end products or to intermediate products that are more readily biodegradable
or removed more readily by adsorption. National estimates based on the Detailed Questionnaire data show
that 33 percent of indirect hazardous landfills, 11 percent of direct non-hazardous landfills, and less than
one percent of indirect non-hazardous landfill facilities use chemical oxidation units as part of wastewater
treatment systems.
Chemical oxidation is a chemical reaction process in which one or more electrons are transferred from the
chemical being oxidized to the chemical initiating the transfer (the oxidizing agent). The electron acceptor
may be another element, including an oxygen molecule, or it may be a chemical species containing oxygen,
such as hydrogen peroxide, chlorine dioxide (see Section 8.1.2.6.1), permanganate, or ozone. This
process is also effective in destroying cyanide and toxic organic compounds. Figure 8-6 presents a process
schematic for a chemical oxidation system that uses an alkaline chlorination process.
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Chemical oxidation is apotential treatment optionforthe removal of certain organic pollutants from leachate
or ground water. The amount of oxidant required in practice is generally greater than the theoretical mass
calculated. The reasons for this are numerous and include incomplete oxidant consumption and oxidant
demand caused by other species in solution. Oxidation reactions are catalysts and pH dependent; hence,
pH control is an important design variable. For many facilities utilizing chemical oxidation, partial oxidation
of organics, followed by additional treatment options, may be more efficient and cost effective than using
a complete oxidation treatment scheme alone.
According to the Detailed Questionnaire data, landfill facilities use chemical oxidation processes to treat
cyanide-bearing wastes and organic pollutants and as a disinfectant. When treating cyanide or organic
wastes, these processes use strong oxidizing chemicals, such as chlorine in elemental or hypochlorite salt
form. As a disinfection process, an oxidant (usually chlorine) is added to the wastewater in the form of
either chlorine dioxide or sodium hypochlorite (see Section 8.1.2.6.1). Other disinfectant chemicals include
ozone, hydrogen peroxide, sulfur dioxide, and calcium hypochlorite. Once the oxidant is mixed with the
wastewater, sufficient detention time (usually 30 minutes) is allowed for the disinfecting reactions to occur
(see reference 7).
Chemical reduction processes involve a chemical reaction in which electrons are transferred from one
chemical to another to reduce the chemical state of a contaminant. The main application of chemical
reduction in leachate treatment is the reduction of hexavalent chromium to trivalent chromium. Chromium
reduction is necessary due to the inability of hexavalent chromium to form a hydroxide, and enables the
trivalent chromium to be precipitated from solution in conjunction with other metallic salts. Figure 8-7
presents a flow diagram of a chromium reduction system. Sulfur dioxide, sodium bisulfate, sodium
metabisulfate, and ferrous sulfate are typical reducing agents used at landfill facilities.
8.1.2.6.1 Breakpoint Chlorination
Breakpoint chlorination, in wide use as a wastewater treatment technology, is a physical-chemical means
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of removing ammonia from wastewater. Chlorine is added to process waters until the chlorine demand of
the wastewater has been satisfied. At this point, the total dissolved residual chlorine has reached a
minimum (the breakpoint) and the ammonia has been oxidized to form nitrogen gas and hydrochloric acid.
EPA evaluated breakpoint chlorination as an alternative to biological treatment for removing ammonia at
landfill facilities with low BOD concentrations. EPA concluded that these facilities may have difficulty
operating biological treatment systems due to the low organic content of the wastewater.
The most common chlorine compounds used in wastewater treatment plants arechlorine gas (C12), calcium
hypochlorite [Ca(OCl)2], sodium hypochlorite (NaOCl), and chlorine dioxide(C!O2). Calcium and sodium
hypochlorite are most often used in very small treatment plants, such as package plants, where simplicity
and safety are far more important than cost. Sodium hypochlorite is often used at large facilities, primarily
for reasons of safety as influenced by local conditions. Because chlorine dioxide does not react with
ammonia, it is also used in a number of treatment facilities where interferences with ammonia are a concern.
The maintenance of a chlorine residual for the purpose of wastewater disinfectionis complicated by the fact
that free chlorine not only reacts with ammonia, but is also a strong oxidizing agent. As chlorine is added,
readily oxidizable substances, such as Fe+2, Mn+2, H2S, and organic matter, react with the chlorine and
reduce most of it to the chloride ion. After meeting this immediate demand, the chlorine continues to react
with the ammonia to form chloramines. Additional chlorine will cause some of the chloramines to be
converted to nitrogen trichloride (NC13), the remaining will be oxidized to nitrous oxide (N2O) and nitrogen
(N2), and the chlorine will be reduced to the chloride ion. With continued addition of chlorine, most of the
chloramines will be oxidized at the breakpoint. Continued addition of chlorine past the breakpoint will
result in a directly proportional increase in the free available chlorine (unreacted hypochlorite). The main
reason for adding enough chlorine to obtain a free chlorine residual is that usually disinfection can then be
ensured (see reference 56).
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8.1.2.7 Air Stripping
Stripping is an effective treatment method for removing dissolved volatile organic compounds from
wastewater. The removal is accomplished by passing air or steam through the agitated waste stream. The
process results in a contaminated off-gas stream which, depending upon the air emissions standards, usually
requires air pollution control equipment. National estimates based on EPA' sDetailed Questionnaire data
indicate that 4 percent of direct and approximately one percent of indirect non-hazardous landfill facilities
use air stripping as part of wastewater treatment systems.
The driving force of air stripping mass-transfer operation is the difference in concentrations between the
air and liquid streams. Pollutants are transferred from the more concentrated wastewater stream to the less
concentrated air stream until equilibrium is reached. This equilibrium relationship is defined by Henry's
Law. The strippability of a pollutant is expressed as its Henry's Law Constant, which is a function of its
volatility and solubility.
Air stripping (or steam 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 length
of the packing. The countercurrent tower draws its entire air flowfrom the bottom. The cross-flow towers
have been found to be more susceptible to scaling problems and are less efficient than countercurrent
towers.
Figure 8-8 presents a flow diagram of a countercurrent air stripper.
8.1.2.8 Filtration
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, or a vacuum. Filtration
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treatment processes can be used at landfills to remove solids from wastewater after physical/chemical or
biological treatment or as the primary source of leachate treatment. Filtration processes include a broad
range of media and membrane separation technologies from ultrafiltration to reverse osmosis. To aid in
removal, the filter medium may be precoated with a filtration aid such as ground cellulose or diatomaceous
earth.
National estimates based on the Detailed Questionnaire data indicate that 11 percent of direct and two
percent of indirect non-hazardous landfill facilities have some form of filtration as part of wastewater
treatment systems, including the following:
Type of Filtration System % Non-Hazardous Facilities
Direct Indirect
Sand 6 <1
Diatomaceous earth 0 <1
Granular multimedia 6 <1
Membrane 0 1
Fabric 0 <1
Dissolved compounds in landfill wastewater are sometimes pretreated to convert the compound to an
insoluble solid particle prior to filtration. Polymers are sometimes injected into the filter feed piping
downstream of feed pumps to enhance flocculation of smaller floes that may escape an upstream clarifier.
Pretreatment for iron and calcium is sometimes necessary to prevent fouling and scaling.
The following sections discuss the various types of filtration in use at landfills facilities.
8.1.2.8.1 Sand Filtration
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
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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 for sand filters are
typically between 2 to 6 gpm/sq ft (see reference 7).
All fixed mediafilters have influent and effluent distribution systems consisting of pipes and fittings. Strainers
in the tank bottom are usually stainless steel screens. Layers of uniformly sized gravel also serve as bottom
strainers and as a support for the sand. For both types of filters, the bed builds 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. Filters are backwashed by
reversing the flow so that the solids in the media are dislodged and can exit the filter; sometimes air is
dispersed into the sand bed to scour the media.
Fixed-bed filters can be automatically backwashed when the differential pressure exceeds a preset limit or
when a timer starts the backwash cycle. Powered valves and a backwash pump are activated and
controlled by adjustable cam timers or electronic programmable-logiccontrollers to perform the backwash
function. 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 primary
clarifier or screen for removal.
Moving bed filters use an air lift pump and draft tube to recirculate sand from the filter 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 at the top of the
filter or in a remote location. The heavier sand falls back into the filter, while the lighter particles flow over
a weir to waste. Moving bed filters are continuously backwashed and have a constant rate of effluent flow.
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8.1.2.8.2 Diatomaceous Earth
These filtration systems use diatomaceous earth, a natural substance, as a precoat on either a vacuum or
pressure filter arrangement to enhance removal efficiencies. In these instances, the diatomaceous earth is
placed as a thin layer over a screen. The wastewater then is passed through the layer of earth and screen,
with the suspended particles being filtered. A vacuum can be drawn across the screen, or pressure applied
to the wastewater to help the liquid pass through the filter medium.
8.1.2.8.3 Multimedia Filtration
Multimedia, or granular bed, filtration is used for achieving supplemental removal of residual suspended
solids from the effluent of chemical or biological treatment processes. These filters can be operated either
by gravity or under pressure in a vessel. In granular-bed filtration, the wastewater stream is sent through
a bed containing one or more layers of different granular materials. The solids are retained in the voids
between the media particles while the wastewater passes through the bed. Typical media used in granular-
bed filters include anthracite coal, sand, and garnet. These media can be used alone, such as in sand
filtration, or in a multimedia combination. Multimedia filters are designed such that the individual layers of
media remain fairly discrete. This is accomplished by selecting appropriate filter loading rates, media grain
size, and bed density. Hydraulic loading rates for a multimedia filter are between 4 to 10 gpm/sq ft (see
reference 7).
A multimedia filter operates with the finer, denser media at the bottom and the coarser, less dense media
at the top. A common arrangement is garnet at the bottom of the bed, sand in the middle, and anthracite
coal at the top. Some mixing of these layers occurs. During filtration, the removal of the suspended solids
is accomplished by a complex process involving one or more mechanisms, suchas 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.
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The flow pattern of multimedia filters is usually top-to-bottom. Upflow filters, horizontal filters, and biflow
filters are also used. A top-to-bottom multimedia filter is represented in Figure 8-9.
8.1.2.8.4 Membrane Filtration
Membrane filtration systems employ a semi-permeable membrane and a pressure differential. Both
ultrafiltration and reverse osmosis are commonly used membrane filtration processes.
8.1.2.8.4.1 Ultrafiltration
Ultrafiltrationusesasemipermeablemicroporous membrane, through which the wastewaterispassed under
pressure. Water and low molecular weight solutes, such as salts and surfactants, pass through the
membrane and are removed as permeate. Emulsified oils and suspended solids are rejected by the
membrane and removed with some of the wastewater as a concentrated liquid. 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. Several types of ultrafiltration membranes configurations are available: tubular, spiral
wound, hollow fiber, and plate-and-frame. A typical ultrafiltration system is presented in Figure 8-10.
Ultrafiltration is commonly used for the treatment of metal-bearing and oily wastewater. It can remove
substances with molecular weights greater than 500, including suspended solids, oil and grease, large
organic molecules, and complexed heavy metals (see reference 8). Ultrafiltration is used when the solute
molecules are greater than ten times the size of the solvent molecules and less than one-half micron. The
primary design consideration in ultrafiltration is the membrane selection. A membrane pore size is chosen
based on the size of the contaminant particles targeted for removal. Other design parameters to be
considered are the solids concentration, viscosity, and temperature of the feed stream, and the membrane
permeability and thickness.
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8.1.2.8.4.2 Reverse Osmosis
Reverse osmosis is a separation process that uses selective semipermeablemembranes to remove dissolved
solids, such as metal salts, from water. The membranes are more permeable to water than to contaminants
or impurities. The wastewater is forced through the membrane at an applied pressure that exceeds the
osmotic pressure caused by the dissolved solids. Molecules of water pass through the membrane as
permeate while contaminants are flushed along the surface of the membrane and exit as concentrate. The
concentrate flow from a reverse osmosis system ranges from 10 to 50 percent of the feed flow, with
concentrations of dissolved solids and contaminants approaching 10 times that of the feed water (see
reference 6). The percentage of permeate that passes through the membranes is a function of operating
pressure, membrane type, and concentration of the contaminants in the feed.
Cellulose acetate, aromatic polyamide, and thin-film composites are commonly used membrane materials.
Reverse osmosis membranes are configured into tubular, spiral wound, hollow fiber, or plate-and-frame
modules. Modules are inserted into long pressure vessels that can hold one or more modules. Reverse
osmosis systems consist of a pretreatment pump, a high pressure feed pump, one or more pressure vessels,
controls, and instrumentation. A tubular reverse osmosis module is shown in Figure 8-11.
Membranes have a limited life depending upon application and are replaced when cleaning is no longer
effective. Membranes can be cleaned manually or chemically by recirculating the cleaning solution through
the membranes to restore performance. Membranes can also be removed from the reverse osmosis system
and sent off site for flushing and rejuvenation. Membranes are replaced when cleaning is no longer
effective.
Membrane pore sizes for a typical reverse osmosis system range from 0.0005 to 0.002 microns, while
pressures of 300 to 400 psi are usually required (see reference 39). Therefore, reverse osmosis feed-water
needs to be very low in turbidity. Pretreatment of landfill wastewater prior to reverse osmosis treatment
maybe necessary, including chemical addition and clarification, or cartridge filtration using 5 micron filters
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to remove suspended particulates from the influent in order to protect pumps and membranes. Carbon
adsorption is recommended as pretreatment for membranes sensitive to chlorine. Biofouling can be
prevented by chlorination and dechlorination of the feed water. To maintain the solubility of metals such
as calcium, magnesium, and iron, the pH can be adjusted with acid. Aside from pH adjustment, chemical
requirements include the following: bactericide, dechlorination, and chelating agents.
One variation of conventional reverse osmosis technology used at landfill facilities is an innovative
membrane separation technology using disc tube modules. This innovative process is designed to treat
liquid waste that is higher in dissolved solids content, turbidity, and contaminant levels than waste treated
by conventional membrane separation processes. This process also reduces the potential for membrane
fouling and scaling, allowing it to be the primary treatment for waste streams such as landfill leachate.
The disc tube membrane module features larger feed-flow channels and a higher feed-flow velocity than
typical membrane separation systems (see reference 48). These characteristics allow the disc tube module
greater tolerance for dissolved solids and turbidity and a greater resistance to membrane fouling and scaling.
The high flow velocity, short feed-water path across each membrane, and the circuitous flow path create
turbulent mixing reducing boundary layer effects, and minimizing membrane fouling and scaling.
Membrane material for the disc tube module is formed into a cushion with a porous spacer material on the
inside. The membrane cushions are alternately stacked with hydraulic discs on atension rod. The hydraulic
disks support the membranes and provide the flow channels for the feed liquid to pass over the membranes.
After passing through the membrane material, permeate flows through collection channels to a product
recovery tank. A stack of cushions and disks is housed in a pressure vessel. The number of disks per
module, number of modules, and the membrane materials can be varied to suit the application. Modules
are typically combined in a treatment unit or stage. Disc tube module units can be connected in series to
improve permeate water quality or in parallel to increase system treatment capacity (see reference 48).
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Like all membrane separation processes, reverse osmosis technology reduces the volume of the waste.
The degree of volume reduction is dependent on the waste characteristics and the system design. Reverse
osmosis technology can treat liquidwastestreamscontaininglowmolecularweightvolatileandsemivolatile
organics, metals, and other inorganic compounds.
8.1.2.8.5 Fabric Filters
Fabric filters consist of a vessel that contains a cloth or paper barrier through which the wastewater must
pass. The suspended matter is screened by the fabric and the effectiveness of the filter depends on the
mesh size of the fabric. Fabric filters can either be backwashed or built as disposable units.
For waters having less than 10 mg/L suspended solids, cartridge fabric filters may be cost effective.
Cartridge filters have very low capital cost and can remove particles of 1 micron or larger (see reference
39). Using two-stage cartridge filters (coarse and fine) in series extends the life of the fine cartridge.
Disposable or backwashable bag filters also are available and may be quite cost effective for certain
applications. Typically, these fabric filters are used to remove suspended solids prior to other filtration
systems to protect membranes and equipment and reduce solids fouling.
8.1.2.9 Carbon Adsorption
Activated-carbon adsorption is a physical separation process in which organic and inorganic materials are
removed from wastewater by sorption, or attraction, and accumulation of the compounds on the surface
of the carbon granules. This process is commonly referred to as granular activated carbon adsorption.
While the primary removal mechanism is adsorption, biological degradation and filtration are additional
pollutant removal mechanisms provided by the activated- carbon filter. Adsorption capacities of 0.5 to 10
percent by weight are typical in industrial applications (see reference 5). Spent carbon can either be
regenerated on site, by processes such as wet-air oxidation or steam stripping, or, for smaller operations,
be regenerated off site or sent directly for disposal. Vendors of carbon can exchange spent carbon with
fresh carbon under contract.
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Activated-carbon systems consist of a vessel containing a bed of carbon (usually 4 to 12 feet in depth),
whereby the wastewater is either passed upflow or downflow through the filter bed (see reference 6).
Carbon vessels are typically operated under pressure, though some designs use gravity beds. For smaller
applications, granular activated carbon systems also are available in canister systems, which can be readily
changed-out and sent for off-site regeneration.
Often more than one carbon vessel is used in series, such that the first column can be used until the carbon
is "exhausted" before it is regenerated. The partially-exhausted second column is then used as the first
column and another column is rotated behind it to provide polishing. Up to three columns are typically used
in a rotating fashion. When all of the available adsorption sites on the granular activated carbon are
occupied, a rise in organic concentrations is observed in the effluent leaving the vessel. At this point the
granular activated carbon in the vessel is saturated and is said to have reached break-through.
The key design parameter is the adsorption capacity of the granular activated carbon. This is a measure
of the mass of contaminant adsorbed per unit mass of carbon and is a function of the chemical compounds
being removed, type of carbon used, and process and operating conditions. The volume of carbon
required is based upon the COD and/or pollutant-specific concentrations in the wastewater to be treated
and desired frequency of carbon change-outs. The vessel is typically designed for an empty bed contact
time of 15 to 60 minutes (see reference 5). Non-polar, high molecular weight organics with low solubility
are readily adsorbed using GAC. Certain organic compounds have a competitive advantage for adsorption
onto GAC, which results in compounds being preferentially adsorbed or causing other less competitive
compounds to be desorbed from the GAC. Most organic compounds and some metals typically found
in landfill leachate are effectively removed using GAC.
National estimates based on EPA's Detailed Questionnaire data indicate that greater than one percent of
indirect and greater than one percent of direct non-hazardous landfill facilities employ carbon adsorption
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as part of wastewater treatment systems. Figure 8-12 presents a flow diagram of a typical carbon
adsorption vessel.
8.1.2.10 Ion Exchange
Ion exchange is an adsorption process that uses a resin media to remove contaminants from wastewater.
Ion exchange is commonly used for the removal of heavy metals from relatively low-concentration waste
streams. A key advantage of the ion exchange process is that it allows for the recovery and reuse of the
metals in a wastewater. Ion exchange also can be designed to be selective to certain metals and can
provide effective removal from wastewater having high concentrations of background compounds such a s
iron, magnesium, and calcium. A disadvantage is that the resins can be fouled by oils and heavy polymers.
Pretreatment for ground water or leachate treated by an ion exchange system typically includes a cartridge
filtration unit. Additional tanks and pumps are required for regeneration, chemical feed, and collection of
spent solution.
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 of a resin is dependent
upon the wastewater contaminant to be removed. Cation resins adsorb metals, while anion resins adsorb
such contaminants as nitrate and sulfate. A commonly-used resin is polystyrene copolymerized with
divinylbenzene. Key parameters for designing an ion-exchange system include a resin bed loading rate of
2 to 4 gallons per minute per cubic foot, and a pressure vessel diameter providing for a cross-sectional area
loading rate of 5 to 8 gallons per minute per square foot (see reference 5).
The ion exchange process involves the following four steps: treatment, backwash, regeneration, and rinse.
During the treatment step, wastewater is passed through the resin bed. The ion exchange process continues
until pollutant breakthrough occurs. The resin is then backwashed to clean the bed and to remove
suspended solids. During the regeneration step, the resin is contacted with either an acidic or alkaline
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solution containing the ion originally present in the resin. This "reverses" the ion exchange process and
removes the ions that were originally present in the wastewater and were retained by 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. A commonindustrial setup is fixed-bed resin in a vertical column,
where the resin is regenerated in-place. Other operating modes include batch and fluidized bed. These
systems can be designed so that the regenerant flow is concurrent or countercurrent to the treatment flow.
A countercurrent design, although more complex to operate, provides a higher treatment efficiency. The
beds can contain a single type of resin for selective treatment, or the beds can be mixed to provide for more
complete deionization of the waste stream. Often, individual beds containing different resins are arranged
in series, which makes regeneration easier than in the mixed bed system.
National estimates based on the Detailed Questionnaire data show that less than one percent of indirect
non-hazardous landfills employ some form of ion exchange as part of wastewater treatment systems. Figure
8-13 presents a flow diagram of a typical ion exchange setup, fixed-bed resin in a vertical column.
8.1.3 Biological Treatment
Biological treatment uses microbes which consume, and thereby destroy, organic compounds as a food
source. Leachate from landfills can contain large quantities of organic materials that can be readily
stabilized using biological treatment processes. In addition to the carbon food source supplied by the
organic pollutants, the microbes also require energy and supplemental nutrients for growth, such as nitrogen
and phosphorus. There are several different classes of microbes that are commonly used in the biological
treatment of organic bearing wastes. Aerobic microbes require oxygen to grow, whereas anaerobic
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microbes grow in the absence of oxygen. An adaptive type of anaerobic microbe, called a facultative
anaerobe, can grow with or without oxygen.
The success of biological treatment in treating wastewater is dependent on several factors, such as the pH
and temperature of the wastewater, the nature of the pollutants, the nutrient requirements of the microbes,
the presence of other inhibiting pollutants (such as toxic heavy metals), and variations in the feed stream
loading.
Aerobic biological treatment systems utilize an acclimated community of microorganisms to degrade,
coagulate, and remove organic and other contaminants from wastewater. Organic contaminants in the
wastewater are used by the treatment organisms for biological synthesis and growth, with a small portion
for cellular maintenance. Resulting products from biological treatment include cellular biomass, carbon
dioxide, water and, sometimes, the nondegradable fraction of the organic material.
In the biological treatment process, wastewater is mixed orintroduced to the biomass. The microorganisms
responsible for stabilization can be maintained in suspended form or can be attached to a solid media.
Examples of the suspended growth biological treatment systems include various activated sludge treatment
processes and aerobic lagoons. Biological treatment processes which employ the use of fixed film media
include trickling filtration, biotowers, and rotating biological contactors.
Anaerobic biological treatment systems can degrade organic matter in wastewater and ultimately convert
carbonaceous material into methane and carbon dioxide. Anaerobic systems have been shown to be most
effective for high strength leachate (COD over 4,000 mg/L) and for wastewater containing refractory
contaminantsbecauseofeffectivenessofmethanotropicmicroorganismsinmetabolizingthese compounds.
A disadvantage to anaerobic treatment systems is the sensitivity of the methanotropic microorganisms to
certain toxic substances.
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Initially, in an anaerobic treatment process, the complex organic matter in the raw waste stream is
converted to soluble organicsby extra-cellular enzymes. This step facilitatesthe later conversion of soluble
organic matter into simple organic acids. The final step involves the conversion of organic acids into
methane and carbon dioxide. The bacteria responsible for the conversions have very slow growth rates.
In addition, methanotropic bacteria are very sensitive to environmental conditions, require the complete
absence of oxygen, a narrow pH range (6.5 to 7.5), and can be readily inhibited by the presence of toxic
compounds such as certain heavy metals.
The table below presents EPA's estimated number of landfill facilities that use variations of biological
treatment as part of landfill wastewater treatment systems:
Type of Biological Treatment % Non-Hazardous Facilities % Hazardous Facilities
Direct Indirect Indirect
Activated Sludge 81 33
Aerobic Lagoon Systems 73 0
Facultative Lagoons 7 <1 0
Trickling Filters 00 0
Anaerobic Systems 2 <1 0
Powdered Activated Carbon Treatment (PACT)* >1 <1 0
* with Activated Sludge
Nitrification Systems 2 <1 0
Rotating Biological Contactors (RBCs) 00 0
Sequencing Batch Reactors (SBRs) >1 0 33
Denitrification Systems >1 0 0
Other+ 13 0 0
+ includes aerated submerged fixed film and wetlands
The following sections present a discussion of biological treatment systems in use at landfill facilities.
8.1.3.1 Lagoon Systems
A lagoon, stabilization pond, or oxidation pond is a body of water contained in an earthen dike and
designed for biological treatment. While in the lagoon, wastewater is treated to reduce degradable organics
throughbiodegradation and reduce suspended solids through sedimentation. The biological process taking
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place in the lagoon can be aerobic, anaerobic, or both (facultative), depending on the design. Because of
the low construction and operating costs, lagoons offer a financial advantage over other treatment methods
and are popular where sufficient land is available at reasonable cost.
Lagoons are used in wastewater treatment for stabilization of suspended, dissolved, and colloidal organics
either as a mainbiological treatment process or as a polishing treatment process following other biological
treatment systems. Aerobic, facultative, and aerated lagoons are generally used forwastewater of low and
medium organic strength. High-strength wastewater and wastewater of variable strength often are treated
by a series of lagoons. A common configuration is an anaerobic lagoon, followed by a facultative lagoon
and an aerobic lagoon.
The performance of lagoons in removing degradable organics depends on detention time, temperature, and
the nature of the waste. Aerated lagoons generally provide a high degree of BOD5 reduction more
consistently than aerobic or facultative lagoons. Typical problems associated with lagoons are excessive
algae growth, offensive odors from anaerobic lagoons if sulfates are present and the lagoon is not covered,
and seasonal variations in effluent quality. The major classes of lagoons that are based on the nature of
biological activities are discussed below.
Aerobic lagoons depend on algae photosynthesis and natural aeration to assist in the biological activity.
These shallow lagoons (3 to 4 feet in depth) rely on both the natural oxygen transfer occurring through the
surface area of the lagoon and the production of oxygen from photosynthetic algae. Aerobic lagoons are
generally suitable for treating low-to medium-strength landfill leachates due to the recommended smaller
food to mass ratios. Because of this design limitation, aerobic lagoons are used in combination with other
lagoons to treat higher-strength landfill leachates to achieve additional organic removal following
conventional wastewater treatment processes. The typical hydraulic detention time for an aerobic lagoon
is 10 to 40 days, with an organic loading of 60 to 120 pounds of BOD5 per day per acre (see reference
7).
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A variation of the aerobic lagoon is the aerated lagoon. These lagoons do not depend on algae and
sunlight to furnish dissolved oxygen, but require additional oxygen to be introduced to prevent anaerobic
conditions. In these systems, mechanical or diffused aeration devices are used in the lagoons for oxygen
transfer and to create some degree of mixing (see Figure 8-14). Due to this mixing, additional suspended
solids removal in the effluent from the lagoon may be required. The recommended hydraulic detention time
is 3 to 20 days, with an organic loading of 20 to 400 pounds of BOD5 per day per acre (see reference 7).
Based on these higher design loading rates, aerated lagoons are well suited for treatment of medium-
strength landfill leachates.
Aerated lagoons are relatively simple to operate. The influent is fed into the basin where it is mixed and
aerated with the lagoon contents. Settled sludge is not routinely withdrawn from the lagoon. Lagoons
require only periodic cleanings when the settled solids significantly reduce lagoon volume. Since operation
requires no sludge recycle, the hydraulic detention time is equal to the sludge retention time. Contaminant
reduction in a lagoon system is typically less than other biological treatment systems. As a result, aerobic
lagoons are commonly used together with other physical/chemical treatment processes, such as lime
addition and settling, to ensure sufficient pollutant removal efficiencies.
Anaerobic lagoons are relatively deep ponds (up to 6 meters) with steep sidewalls in which anaerobic
conditions are maintained by keeping organic loading so high that complete deoxygenation is prevalent.
Some oxygenation is possible in a shallow surface zone. If floating materials in the waste form an
impervious surface layer, complete anaerobic conditions will develop. Treatment or stabilization results
from anaerobic digestion of organic wastes by acid-forming bacteria that break down organics. The
resultant acids are then converted to carbon dioxide, methane, and other end products. Anaerobic lagoons
are capable of providing treatment of high-strength wastewater and are resistant to shock loads.
In the typical anaerobic lagoon, raw wastewater enters near the bottom of the pond (often at the center)
and mixes with the active microbial mass in the sludge blanket, which can be as much as 2 meters (6 feet)
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deep. The discharge is located near one of the sides of the pond, submerged below the liquid surface.
Excess sludge is washed out with the effluent and recirculation of waste sludge is not required.
Anaerobic lagoons are customarily contained within earthen dikes. Depending on soil and wastewater
characteristics, lining with various impervious materials, such as rubber, plastic, or clay may be necessary.
Pond geometry may vary, but surface area-to-volume ratios are minimized to enhance heat retention.
Waste stabilization in a facultative lagoon treatment system is accomplished by a combination of anaerobic
microorganisms, aerobic microorganisms, and a preponderance of facultative microorganisms that thrive
under anaerobic as well as aerobic conditions. Facultative systemsconsist of lagoons of intermediate depth
(3 to 8 feet) in which the wastewater is stratified into three zones (see Figure 8-15). These zones consist
of an anaerobic bottom layer, an aerobic surface layer, and an intermediate zone dominated by the
facultative microorganisms. Stratification is a result of solids settling and temperature-water density
variations. Oxygen in the surface zone is provided by natural oxygen transfer and photosynthesis or, as in
the case of an aerated facultative lagoon, by mechanical aerators or diffusers. Facultative lagoons usually
consist of earthen dikes, but some are lined with various impervious materials, such as synthetic
geomembranes or clay.
A facultative lagoon is designed to permit the accumulation of settleable solids on the basin bottom. This
sludge at the bottom of the facultative lagoon will undergo anaerobic digestion, producing carbon dioxide
and methane. The liquid and gaseous intermediate products from the accumulated solids, together with the
dissolved solids furnished in the influent, provide the food for the aerobic and facultative bacteria in the
upper layers of the liquid in the lagoon. Recommended hydraulic detention time for a facultative lagoon
without aeration is 7 to 30 days, with an organic loading of 15 to 50 pounds of BOD5 per day per acre (see
reference 7).
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8.1.3.2 Anaerobic Systems
Types of anaerobic biological treatment systems include complex mix anaerobic digesters (see Figure 8-
16), contact reactors with sludge recycle, and anaerobic filters. A digestor uses an air tight reactor where
wastes are mixed with digestor contents that contain the suspended anaerobic microorganisms. A digestor
operated in a complete mix mode without sludge recycling has a hydraulic detention time equal to the solid s
retention time. Anaerobic digestion in a reactor can also occurwith sludge recycling. This permits a much
larger solids retention time (SRT) than the hydraulic detention time. System stability is greater at increased
SRTs, and since the hydraulic detention time can be decreased, the reactor volume can also be reduced.
The anaerobic filter or biotower microbes are maintained in a film on packed solid media within an air-tight
column. A variation of the anaerobic fixed-film process is a fluidized bed process. The basic tower design
is similar to that of an aerobic reactor in that the influent is fed into the reactor at countercurrent flow. This
process provides for very high SRTs and variable hydraulic detention times.
Stabilization of leachate in an anaerobic treatment unit requires the maintenance of a viable community of
anaerobic microbes. Treatment efficiency is dependent on many interrelated factors such as hydraulic
detention time, SRT, temperature, and, to a lesser extent, organic loading, nutrients, and toxics.
Microorganisms responsible for degrading the organic waste must remain in the reactor long enough to
reproduce. When the microbes spend less time in the system than they require to reproduce, the solids are
eventually washed out of the system. Anaerobic treatment facilities are typically designed with an SRT of
2 to 10 times the washout time (typical washout time reported for organic acids is about 3.5 days). For
degradation of organic acids in leachate, this washout time would yield an SRT of 7 to 35 days (see
reference 7). The most common temperature regime for an anaerobic reactor is in the range of 25 to 38
degrees C (see reference 7). Typical loadings for anaerobic systems are from 30 to 100 pounds of COD
per 1,000 cubic feet of reactor volume (see reference 7). Since the synthesis of new cellular material is
slow in anaerobic systems, nutrient requirements are not as large as in aerobic systems. Nutrient addition
needs to be evaluated and, in the case of leachate with low phosphorus concentrations, will require
phosphorus addition.
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8.1.3.3 Attached-Growth Biological Treatment Systems
Attached-growth biological treatment systems are used to biodegrade the organic components of a
wastewater. 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 applicableto industrial wastewater amenable to aerobic biological
treatment in conjunction with suitable pre- and post-treatment units. These systems are effective for the
removal of suspended or colloidal materials.
The three major types of attached-growth systems used at landfills facilities are rotating biological
contactors, trickling filters, and fluidized-bed biological reactors. These processes are described below.
Rotating biological contactors are a form of aerobic attached-growth biological treatment system where
the biomass adheres to the surface of a rigid media. In a rotating biological contactor, the rigid media
usually consists of a plastic disk or corrugated plastic medium mounted on a horizontal shaft (see Figure
8-17). The medium slowly rotates in wastewater (with 40 to 50 percent of its surface immersed) as the
wastewater flows past. During the rotation, the medium picks up a thin layer of wastewater, which flows
over its surface absorbing oxygen from the air. The biological mass growing on the medium surface
absorbs organic pollutants, which then are biodegraded. Excess microorganisms and other solids are
continuously removed from the film on the disk by shearing forces created by the rotation of the disk in the
wastewater. The sloughed solids are carried with the effluentto a clarifier, where they are separated from
the treated effluent.
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Rotating biological contactors provide a greater degree of flexibility for landfills with changing leachate
characteristics. Modular construction of rotatingbiological contactors permit their multiple staging to meet
increases or decreases in treatment demand. Staging, which employs a number of rotating biological
contactors operated in series, enhances biological treatment efficiency, improves shock-handling ability,
and also may aid in achieving nitrification.
Typical rotating biological contactor design parameters include a hydraulic loading of 2.0 to 4.0 gallons per
square feet per day and an organic loading of 2.0 to 3.5 pounds BOD5 per 1,000 square feet per day (see
reference 12).
Factors which affect the efficiency of rotating biological contactor systems include the type and
concentration of organic matter, hydraulic detention time, rotational speed, media surface area
submergence, and pre- and post-treatment activities. Variations of the basic rotating biological contactor
process design include the addition of airto the tanks, chemicals for pH control, use of molded covers or
housing for temperature control, and sludge recycle to enhance nitrification. Rotating biological contactors
are typically well suited for the treatment of soluble organics and adequate for nitrification. They are
low-rate systems capable of handling limited loadings capacity and are not efficient for degrading refractory
compounds or removing metals (see reference 7).
Trickling filtration is another aerobic fixed-film biological treatment process that consists of a suitable
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 (see
Figure 8-18). 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.
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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 (see reference 11). 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 can have a bed depth from 1 to
9 meters and recirculates a portion of the effluent for further treatment (see reference 7).
A variation of a trickling filtration process is the aerobic biotower which can be operated in a continuous
or semi-continuous manner. Influent is pumped to the top of a tower, where it flows by gravity through the
tower. The tower is packed with media, plastic or redwood, containing the microbial growth. Biological
degradation occurs as the wastewater passes over the media. Treated wastewater collects into the bottom
of the tower. If needed, additional oxygen is provided via air blowers countercurrent to the wastewater
flow. Alternative variations of this treatment process involve the inoculation of the raw influent with
bacteria, adding nutrients, and using upflow biotowers. Wastewater collected in the biotowers is delivered
to a clarifier to separate the biological solids from the treated effluent.
An aerobic fluidized-bed biological reactor is a variation of a fixed-film biological treatment process.
Microorganisms are grown on either granular activated carbon or sand media. Influent wastewater enters
the reactor through a distributor which is designed to provide for fluidization of the media (see Figure 8-19).
As the biofilm grows, the media bed expands, thereby reducing the density of the media. The rising bed
is intercepted at a given height with the bulk of the biomass removed from the media. The media then is
returned to the reactor. Additional oxygen can be predissolved in the influent to enhance performance.
The use of granular activated carbon as a medium integrates biological treatment and carbon adsorption
processes, which has the advantage of handling loading fluctuations, as well as greater removals of organic
contaminants.
Due to a short hydraulic detention time, this process is favorable for low to moderate levels of
contamination. The vertical installation of the reactor and high loading capability reduces conventional land
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requirements. The maximum design loading is 400 pounds of BOD per 1,000 square feet of reactor area
per day with a minimum hydraulic detention time of 5 to 10 minutes (see reference 7).
8.1.3.4 Activated Sludge
The activated sludge process is a specific continuous-flow, aerobic biological treatment process that
employs suspended-growth aerobic microorganisms to biodegrade organic contaminants. In this process
(shown in Figure 8-20), a suspension of aerobic microorganisms is maintained in a relatively homogeneous
state by mechanical mixing or turbulence induced by diffused aerators in an aeration basin. This suspension
of microorganisms is called the mixed liquor.
Wastewater is introduced into the basin and mixed with the tank contents. The biological process often
is preceded by gravity settling to remove larger and heavier suspended solids. A series of biochemical
reactions take place in the aeration tank. These reactions degrade organics and generate 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 where the
microorganisms are separated from the treated water. A portion of the settled solids in the clarifier is
recycledbacktothe 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.
Toensurebiological stabilization oforganiccompoundsin activated sludge systems, adequate nutrientlevels
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 leachates can 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 landfill facilities.
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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, oxygen
requirements, and the biokinetic rate constant (K). 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 ofthebiomass. The sludge (or solids) retention time
(SRT) or sludge age is a measure of the average retention time of solids in the activated sludge system.
Sludge retention time is important in the operating of an activated sludge system because it must be
maintained at a level that is greater than the maximum generation time of microorganisms in the system. If
adequate sludge retention time is not maintained, the bacteria are washed from the system faster than they
can reproduce and the process fails. The SRT also affects the degree of treatment and production of waste
sludge. A high SRT results in carrying a high quantity of solids in the system, obtaining a higher degree of
treatment, and producing less waste sludge. The hydraulic detention time is used to determine the size of
the aeration tank and should be determined by use of F/M ratio, SRT, and MLSS. The biokinetic rate
constant (or K-rate) determines the speed of the biochemical oxygen demand reaction and generally ranges
from 0.1 to 0.5 days"1 for municipal wastewater (see reference 11). The value of K for any given organic
compound is temperature-dependent. Because microorganisms are more active at higher temperatures,
the value of K increases with increasing temperature. Oxygen requirements are based on the amount of
oxygen required for BOD5 synthesis and the amount required for endogenous respiration. The design
parameters will also vary with the type of wastewater to be treated. The oxygen requirement to satisfy
BOD5 synthesis is established by the characteristics of the wastewater. The oxygen requirement to satisfy
endogenous respiration is determined by the total solids maintained in the system and their characteristics.
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 wastewater. The typical modification may
represent a variation in one or more of the key design parameters, including the F/M loading, aeration
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location and type, sludge return, and contact basin configuration. The modifications in practice have been
identified by the maj or 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 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 BOD5 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 wastewater 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 stage,
wastewater i s aerated with the return sludge in the contact tank for 3 0 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 (see reference 11).
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.
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Activated sludge systems are effective in the removal of soluble (dissolved) organics by biosorption as well
as suspended and colloidal matter typically found in landfill leachate. Suspended matter is removed by
entrapment in the biological floe while colloidal matter is removed by physiochemical adsorption to the
biological floe. For example, inorganic contaminants, such as heavy metals, that are common in low
concentrations in landfill wastewater are often precipitated and concentrated in the biological sludges
generated from activated sludge systems at landfill facilities. Halogenated organic compounds may be
driven off to a certain extent in the aeration process while other less volatile compounds are removed by
a combination of biodegradation and air stripping in the aeration basin. Finally, activated sludge systems
treating landfill leachates with an excess loading of certain nutrients (i.e. amounts of nitrogen that exceed
the requirements of the biomass in the activated sludge system) can be operated so that nitrification of
ammonia can occur in the activated sludge system. For higher concentrations, stand-alone nitrification
systems may be required; these systems are discussed later in this chapter.
Conventional, plug-flow activated sludge systems can adequately treat the organic loadings found in low-
to medium-strength landfill leachates. Higher-strength leachates often are treated at landfill facilities using
extended aerationmode of activated sludge treatment. This process allows for a large hydraulic detention
time of up to 29 hours and for a sludge detention time of 20 to 30 days (see reference 7). Aerator loading
for the complete-mix extended-aeration process is between 10 to 15 pounds of BOD5 per 1,000 cubic
feet of aerator tank volume (see reference 7). Extended aeration also provides for minimal operator
supervision in comparison to other activated sludge processes and occasional sludge wasting. EPA
sampled a facility (EPA sampling episode 4759) in the Hazardous subcategory that employed a complete-
mix extended-aeration treatment process for high-strength leachate. Design parameters for this system
include influent BOD5 loading of 3520 mg/L with a hydraulic detention time of 28 hours. Higher-strength
leachates are also occasionally treated with a combination of biological processes, sometimes using a
lagoon or attached growth system prior to the activated sludge system to reduce organic loading. Since
activated sludge systems are sensitive to the loading and flow variations typically found at landfill facilities,
equalization is often required prior to treatment using activated sludge systems. Also, activated sludge
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systems treating landfill leachates typically generate excess amounts of secondary sludge that may require
additional stabilization, dewatering, and disposal.
8.1.3.5 Powdered Activated Carbon Biological Treatment
In this biophysical treatment process, powdered activated carbon is added to a biological treatment system
(usually an activated sludge system). The adsorbent qualities of the powdered carbon aid in the removal
of organic compounds, particularly those that may be difficult to biodegrade. Powdered activated carbon
also enhances color removal and the settling characteristics of the biological floe.
The mixture of influent, activated sludge biomass, and powdered activated carbon is held in the aeration
basin for a sufficient detention time adequate for the desired treatment efficiencies (see Figure 8-21). After
contact in the aeration basin, the mixture flows to a clarifier, where settled solids are fed back to the
aeration basin to maintain adequate concentrations of microorganisms and carbon. Clear overflow from
the clarifiers is either further processed or discharged. Fresh carbon is periodically added to the aeration
basin as required and is dependent on desired removal efficiencies. Excess solids are removed directly
from the recycled sludge stream. Wasted solids can be processed by conventional dewatering means or
by wet-air oxidation for the destruction of organics and regeneration of activated carbon. Regeneration
also can be handled off site for smaller applications.
Powdered activated carbon activated sludge treatment combines physical adsorption properties of carbon
with biological treatment, achieving a higher degree of treatment than possible by either mode alone.
Powdered activated carbon removes the more difficult to degrade refractory organics, enhances solids
removal, and buffers the system against loading fluctuations and shock loads. Variations of the powdered
activated carbon biological process includes operation in a batch fill and draw mode (similar to a
sequencing batch reactor), multiple-stage powdered activated carbon units, and combinations of aerobic
and anaerobic powdered activated carbon biological systems. Operation in a batch mode provides for
flexibility in the system, by readily allowing for adjustments to the time and aeration mode in each process
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stage. This mode of operation is particularly applicable to the treatment of leachate with variable
composition and strength. The powdered activated carbon biological treatment process is well suited for
the treatment of leachate containing high concentrations of soluble organics (particularly with low BOD5
to COD ratios). It can obtain better color and refractive organics removal than conventional biological
processes and can provide for treatment of leachates contaminated with various trace organic compounds.
8.1.3.6 Sequencing Batch Reactors (SBRs)
A sequencing batch reactor is a suspended-growth biological system in which the 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 (see Figure 8-22). A 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 then are allowed to settle and the liquid (or supernatant) is decanted. The batch operation of a
sequencing batch reactor makes it applicable to wastewater that is highly variable because each batch can
be treated differently, depending on its waste characteristics.
A sequencing batch reactor system has four cycles: fill, react, settle, and decant. The fill cycle has three
phases. The first phase, called static fill, introduces the wastewater to the system under static conditions.
During this phase, anaerobic conditions can exist. During the second phase, the wastewater is mixed to
eliminate the scum layer and to initiate the oxygenation process. The third phase consists of aeration and
biological degradation. The react cycle is a time-dependent process that continually mixes and aerates the
wastewater while allowing the biological degradation process to complete. Because the reaction is a batch
process, the period of time of aeration can vary to match the characteristics and loadings of the wastewater.
The settling cycle utilizes a large surface area (entire reactor area) and a lower settling rate than used in
conventional sedimentation processes, to allow for settling under quiescent conditions. Next, during the
decant cycle, approximately one-third of the tank volume is removed by subsurface withdrawal. This
treated effluent then can be further treated or disposed. The period of time that the reactor waits prior to
the commencement of another batch processing is the idle period. Excess biomass is periodically removed
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from the sequencing batch reactor when the quantity exceeds that needed for operation and is usually
dewatered prior to disposal.
A sequencing batch reactor 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
loadings in the raw wastewater at that time. Typically, a sequencing batch reactor operates with a hydraulic
detention time of 1 to 10 days with an SRT of 10 to 30 days. The MLSS is maintained at 3,500 to 10,000
mg/L (see reference?). The overall control of the system can 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, a sequencing batch reactor saves on land requirements. It also provides for greater
operation flexibility for treating leachate with viable waste characteristics by being able to readily vary
detention time and mode of aeration in each stage. Sequencing batch reactors also can be used to achieve
complete nitrification/denitrification and phosphorus removal.
8.1.3.7 Nitrification Systems
In this process, nitrifying bacteria are used in an aerobic biological treatment system to convert ammonia
compounds to nitrate compounds. Nitrification is usually followed by denitrification (see next section)
which converts nitrates to nitrogen gas. Nitrifying bacteria, such as nitrosomonas and nitrobacter, derive
their energy for growth from the oxidation of inorganic nitrogen compounds. Nitrosomonas converts
ammonia to nitrites, and nitrobacter converts nitrites to nitrates.
The nitrification process usually follows a standard biological process that has already greatly reduced the
organic content of the wastewater; however, there are some biological systems that can provide organic
(BOD5) removal concurrently with ammonia destruction. The nitrification process can be oriented as either
a suspended growth process (e.g. activated sludge system) or an attached-growth process (e.g. trickling
filter).
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8.1.3.8 Denitrification Systems
Denitrification is an anoxic process whereby nitrate nitrogenis converted to gaseous nitrogen, and possibly
nitrous oxide and nitric oxide. Denitrification is a two step process in which the first step converts nitrates
to nitrites, and the second step converts nitrite to nitrogen gas. The bacteria use nitrogen as an electron
source rather than oxygen in digesting a carbon food source. Since the waste stream reaching the
denitrification process has low levels of organic material, a carbon source (usually methanol) must be
added.
The denitrification process can occur as a suspended-growth process or as an attached-growth process.
Attached growth systems can be designed as either fixed-bed or fluidized-bed reactor systems. Effluents
from denitrification processes may need to be re-aerated to meet dissolved oxygen discharge requirements.
8.1.3.9 Wetlands Treatment
An alternative and innovative biological treatment technology for treating landfill wastewater is wetland
treatment. Wetlands can either be natural or man-made (artificial) systems and contain vegetation that
allow for the natural attenuation of contaminants. Wetlands are designed to provide for a contact time of
usually 10 to 30 days. Vegetation in the wetlands transforms nutrients and naturally degrades organics.
Certain metals also can be absorbed by vegetation through root systems. Key design variables include
loading rates, climatic constraints, and site characteristics. Wetland systems are still mainly experimental
and are not a widely accepted or proven treatment technology for the treatment of landfill leachate.
8.1.4 Sludge Handling
Sludges are generated by a number of treatment technologies, including equalization, gravity-assisted
separation, chemical precipitation, and biological treatment. These sludges are further processed at landfill
sites using various methods. The following sections describe each type of sludge-handling system used
within the Landfills industry.
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8.1.4.1 Sludge Slurrying
Sludge slurrying is the process of transporting sludge from one treatment process to another. It only can
be applied to liquid sludges that can be pumped through a pipe under pressure. National estimates based
on EPA's Detailed Questionnaire data indicate that 33 percent of indirect hazardous landfills and less than
one percent of indirect non-hazardous landfills use sludge-slurrying systems as part of their wastewater
treatment systems.
8.1.4.2 Gravity Thickening
Gravity thickening, as shown in Figure 8-23, consists of placing the sludge in a unit similar to a gravity-
assisted separator, where the sludge is allowed to settle, with the liquid supernatant remaining at the top.
The thickened sludge is then removed, and the separated liquid is returned to the wastewater treatment
system for further treatment. Usually sludges that contain two to three percent solids can be thickened to
approximately five to ten percent solids using gravity thickening. National estimatesbased on the Detailed
Questionnaire responses show that 67 percent of indirect hazardous landfills, 4 percent of indirect non-
hazardous landfills, and 7 percent of direct non-hazardous landfill facilities employ gravity thickening as part
of their wastewater treatment systems.
8.1.4.3 Pressure Filtration
Plate-and-frame pressure-filtration systems are used at landfill facilities to dewater sludges from
physical/chemical and biological treatment processes. Sludges generated at a total solids concentration of
two to five percent by weight are dewatered to a 30 to 50 percent solids mass using plate-and-frame
filtration (see reference 3). Sludges from treatment systems can be thickened by gravity or stabilized prior
to dewatering by pressure filtration or may be processed directly with the plate-and-frame filtration unit.
A pressure filter consists of a series of screens (see Figure 8-24) upon which the sludge is applied under
pressure. A precoat material may be applied to the screens to aid in solids removal. The applied pressure
8-42
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forces the liquid through the screen, leaving the solids to accumulate behind the screen. Filtrate which
passes through the screen media is recirculated back to the head of the on-site wastewater treatment plant.
Screens (also referred to as plates) are held by frames placed side-by-side and held together with a vice-
type mechanism. The unit processes sludge until all of the plates are filled with dry sludge as indicated by
a marked rise in the application pressure. Afterwards, the vice holding the plates is loosened and the
frames separated. Dried sludge is manually scraped from the plates and collected in a hopper for final
disposal. The size of the filter and the number of plates utilized depends not only on the amount of solids
produced by treatment processes, but also is highly dependent on the desired operational requirements for
the filter. A plate-and-frame filter can produce a drier sludge than possible with most other methods of
sludge dewatering. It is usually not operated continuously, but offers operational flexibility since it can be
operated in a batch mode.
Pressure filtration is the most common method of sludge dewatering used at landfill facilities. National
estimates indicate that 67 percent of indirect hazardous landfills, 5 percent of indirect non-hazardous
landfills, and 8 percent of direct non-hazardous landfill facilities use pressure filtration systems as part of
their wastewater treatment systems.
8.1.4.4 Sludge Drying Beds
Sludge-drying beds are an economical and effective means of dewatering sludge when land is available.
Sludge may be conditioned by thickening or stabilization prior to application on the drying beds, which are
typically made up of sand and gravel. Sludge is placed on the beds in an 8 to 12 inch layer and allowed
to dry. The drying area is partitioned into individual beds, approximately 20 feet wide by 20 to 100 foot
long (see reference 13), or a convenient size so that one or two beds will be filled by the sludge discharge
from other sludge-handling units or sludge- storage facilities. The outer boundaries may be constructed
with concrete or earthen embankments for open beds. Open beds are used where adequate area is
available and sufficiently isolated to avoid complaints caused by odors. Covered beds with greenhouse-
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type enclosures are used when it is necessary to dewater sludge continuously throughout the year,
regardless of the weather, and where sufficient isolation does not exist for the installation of open beds.
Sludge is dried by drainage through the sludge mass and supporting sand and by evaporation from the
surface exposed to the air. Most of the water leaves the sludge by drainage; thus, the provision of an
adequate underdrainage system is essential. Drying beds are equipped with lateral drainage tiles that should
be adequately supported and covered with coarse gravel or crushed stone. The sand layer should be from
9 to 12 inches deep (see reference 13) with an allowance for some loss from cleaning operations. Water
drained from the sludge is collected and typically recirculated back to the on-site wastewater treatment
system. Sludge can be removed from the drying bed after it has drained and dried sufficiently. The
moisture content is approximately 60 percent after 10 to 15 days underfavorable conditions (see reference
13). Dried sludge is manually removed from the beds and sent for on-site or off-site disposal. Figure 8-25
depicts the cross section of a typical drying bed.
8.1.5 Zero Discharge Treatment Options
In this section, additional treatment processes and disposal methods associated with zero or alternative
discharge at landfill facilities are described. Based on the responses to theDetailed Questionnaire, national
estimates indicate that 27 percent of all non-hazardous landfill facilities and 96 percent of all hazardous
landfill facilities use zero-discharge treatment options. The most commonly used zero-discharge treatment
method employed by these facilities is land application and recirculation. This section describes land
application, recirculation, deep-well disposal, evaporation, solidification, and off-site disposal.
Land application involves the spreading of the wastewater over an area of land that is capped, closed, or
an unused portion of a landfill. The land generally has sufficient percolation characteristics to allow the
water to drain adequately into the soil. The area is assessed to insure that the soil can provide adequate
biological activity to cause the degradation of organic pollutants and also to provide sufficient binding of
any metals present.
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Recirculation involves the spraying of recycled landfill leachate over areas of a landfill. Although this
process promotes biodegradation and evaporation of the leachate volume, recirculation is primarily used
as a means of dust control.
Deep well disposal consists of pumping the wastewater into a disposal well, which then 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.
Traditionally used as a method of sludge dewatering, evaporation, or solar evaporation, can also involve
the discharge and ultimate storage of wastewater into a shallow, lined, on-site ditch. Since the system is
open to the atmosphere, the degree of evaporation is greatly dependent upon climatic conditions.
Solidification is a process in which materials, such as fly ash, cements, 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.
Some facilities that have a low leachate generation rate (either because of arid conditions or capping),
transport their wastewater off site to either another landfill facility' s wastewater treatment system or to a
Centralized Wastewater Treatment (CWT) facility for ultimate disposal.
8.2 Treatment Performance and Development of Regulatory Options
This section presents an evaluation of performance data on treatment systems collected by EPA during
field sampling programs. The results of these EPA sampling episodes assisted the Agency in evaluating the
various types of treatment technologies. For those facilities employing the selected technologies, the
sampling data were used to develop the effluent limitations. A more detailed discussion of the development
of effluent limitations can be found in Chapter 11.
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8.2.1 Performance of EPA Sampled Treatment Processes
To collect data on potential BAT treatment technologies, EPA reviewed responses to the Detailed
Questionnaire to identify candidate facilities that had well-operated and designed wastewater treatment
systems. EPA conducted 19 site visits to 18 facilities to evaluate treatment systems. Based on these site
visits, EPA selected a total of six facilities for sampling which consisted of five consecutive days of sampling
raw influent wastewater and intermediate and effluent points in the wastewater treatment system. EPA
conducted one of these 5-day sampling episodes (4690) at a facility that was eventually excluded from the
regulation because it is a captive landfill. In addition, the only technology sampled at this facility primarily
treated contaminated ground water. For the reasons discussed in Chapter 2, EPA decided to exclude
contaminated ground water flows from this regulation. EPA did not use the data collected during this
sampling episode in selection of pollutants of interest or in the calculation of effluent limitations. Therefore,
EPA does not discuss this facility further in this section. For the remaining five sampling facilities, EPA
collected data on a variety of biological and chemical treatment processes. Technologies evaluated at the
selected sampling facilities include hydroxide precipitation, activated sludge, sequencing batch reactors,
multimedia filtration, and reverse osmosis. Table 4-2 in Chapter 4, presents a summary of the treatment
technologies sampled during each EPA sampling episode. Presented below are the summaries of the
treatment system performance data for each of the sampling episodes that EPA evaluated in the
development of the effluent limitations guidelines and standards.
8.2.1.1 Treatment Performance for Episode 4626
EPA performed a 5-day sampling program during episode 4626 to obtain performance data on several
treatment technologies including hydroxide precipitation, biological treatment using anaerobic and aerobic
biotowers, and multimedia filtration. A flow diagram of the landfill wastewater treatment system sampled
during episode 4626 is presented in Figure 8-26. The wastewater treatment system used at this Subtitle
D municipal facility treats predominately landfill generated wastewater, including leachate and gas
condensate. Table 8-2 presents a summary of percent removal data collected at episode 4626 for the
performance ofthebiological treatment system and for the entire treatment system, excludingthe multimedia
8-46
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filtration system used to polish thedischarge from theeffluentholdingtank. EPA calculated percent removal
efficiencies for the processes by first obtaining an average concentration based upon the daily sampling
results for each sample collection location (influent and effluent point to the treatment process). EPA
calculated the percent removal efficiency of the system using the following equation:
Percent Removal = [Influent Concentration - Effluent Concentration] xlOO
Influent Concentration
EPA reported negative and zero percent removals for a treatment process on the table as 0.0 percent.
EPA determined the treatment efficiency of the biological treatment unit operation using the data obtained
from sampling points 04 and 07 (see Figure 8-26). As demonstrated on the Table 8-2, the biological
treatment unit experienced good overall removals for TOC (93.0 percent), COD (90.85 percent), and
ammonia as nitrogen (99.14 percent). The biological unit operation alone did not demonstrate high
removals for BOD5 (10.2 percent), TSS (9.32 percent), or for various metals (generally less than 10
percent removals) because the pollutants were generally not present in the biological treatment unit influent
at treatable levels. The unit's influent BOD5 was 39.2 mg/L, TSS was 11.8 mg/L, and most metals were
not at detectable levels even though the raw wastewater at this facility exhibited a BOD5 concentration of
991 mg/L, TSS of 532 mg/L, and several metals at treatable levels. The biological treatment unit influent
was low because this facility employed large aerated equalization tanks and a chemical precipitation system
prior to biological treatment. The equalization tanks had a retention time of approximately 15 days and
were followed by a chemical precipitation system using sodium hydroxide. Due to the long retention time
and wastewater aeration, significant biological activity occurred in these tanks. The resulting insoluble
pollutants were removed in the primary clarifier prior to entering the biological towers. EPA did not detect
organic pollutant parameters in the effluent from the biological treatment process with the exception of 1,4-
dioxane at a concentration of 13.8 ug/L.
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To determine the treatment efficiency of the entire treatment system, EPA determined the influent
concentration by taking a flow-weighted average of the two influent sampling points, sampling points 01
and 02. EPA represented the effluent from the treatment system by sample point 07. The entire treatment
system experienced good removals for the following conventional and nonconventional pollutants
parameters: BOD5, TSS, ammonia as nitrogen, COD, TOC, and total phenols. Each of the organic
pollutant parameters identified in the influent to the treatment system was removed to non-detectable level s,
with the exception of 1,4-dioxane, which still experienced a high percent removal (94.2 percent). Most
metals had good percent removals or were removed to non-detectable levels.
8.2.1.2 Treatment Performance for Episode 4667
EPA performed a 5-day sampling program during episode 4667 to obtain performance data on various
treatmentunits,includingammoniaremoval,hydroxideprecipitation,biologicaltreatmentusingasequencing
batchreactor, granular activated-carbon adsorption, and multimedia filtration. A flow diagram ofthe landfill
wastewater treatment system sampled during episode 4667 is presented in Figure 8-27. The wastewater
treatment process used at this Subtitle D non-hazardous facility primarily treats landfill generated
wastewater and a small amount of sanitary wastewater flow from the on-site maintenance facility. Table
8-3 presents asummary of percent removal data collected during episode 4667 for the biological treatment
unit operation (SBR) and for the entire treatment system.
EPA determined the treatment efficiency of the biological treatment unit using the data obtained from
sampling points 03 and 04 (see Figure 8-27). As demonstrated on Table 8-3, the SBR treatment unit
experienced moderate overall removals for TOC (43.4 percent), COD (24.7 percent), and BOD5 (48.7
percent). The Agency observed improved removal efficiencies for TSS (82.9 percent), total phenols (74.2
percent), and ammonia as nitrogen (80.7 percent). Metals, such as barium, chromium, and zinc, had low
removal efficiencies. However, as also noted for facility 4626, the Agency observed these metals in the
influent to the biological system at low concentrations, often close to the detection limit. Other metals also
8-48
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had poor removal efficiencies including boron and silicon. EPA did not detect organic parameters in the
effluent from the SBR treatment unit.
EPA determined the treatment efficiency of the entire treatment system at the facility using the data obtained
from sampling points 01 and 06 (see Figure 8-27). Overall the treatment system experienced good
removals for BOD5, TSS, ammonia as nitrogen, COD, TOC and total phenols. Each of the organic
pollutants detected in the influent was removed to non-detect levels in the effluent. Also, each of the metal
parameters experienced a good removal rate through the treatment system.
8.2.1.3 Treatment Performance for Episode 4721
EPA performed a 5-day sampling program during episode 4721 to obtain performance data on the
sequencing batch reactor (SBR) treatment unit operation installed at this Subtitle C hazardous facility. A
flow diagram of the landfill wastewater treatment system sampled during episode 4721 is presented in
Figure 8-28. The wastewater treatment process used at this facility treats predominately landfill generated
wastewater. The majority of the landfill wastewaterwas generated by Subtitle D non-hazardous landfills.
However, the facility also commingled wastewater generated by an on-site hazardous waste landfill for
treatment. The facility also treats limited amounts of off-site generated wastewater at the on-site treatment
plant, primarily from another landfill facility operated by the same entity. Table 8-4 presents a summary
of percent removal data collected during episode 4721 for the SBR treatment unit.
EPA determined the treatment efficiency of the biological treatment unit using the data obtained from
sampling points 01 and 02 (see Figure 8-28). As demonstrated on the Table 8-4, the SBR treatment unit
experienced good overall removals for a number of convention/nonconventional and organic parameters,
including total phenols, BOD5, aniline, benzoic acid, 2-propanone, 2-butanone, naphthalene, alpha
terpineol, ethylbenzene, p-cresol, m-xylene, 4-methyl-2-pentanone, toluene, phenol, hexanoic acid, and
ammonia as nitrogen. EPA observed removal of all of the organic parameters detected in the influent to
non-detect levels in the effluent. COD and TOC percent removals were observed at 72.2 and 66.3
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percent, respectively. The percent removal for TSS was 72.1 percent. Metals with quantitative percent
removals include arsenic (61.9 percent), chromium (46.3 percent), copper (61.2 percent), and zinc (66.3
percent).
8.2.1.4 Treatment Performance for Episode 4759
EPA performed a 5-day sampling program during episode 4759 to obtain performance data on various
treatment processesinstalledatthisSubtitleChazardousfacility,includingchemicalprecipitationusingferric
chloride and sodium hydroxide and biological treatment using an activated sludge process. A flow diagram
of the landfill wastewater treatment system sampled during episode4759 is presented in Figure 8-29. The
wastewater treatment process used at this facility treats predominately landfill generated wastewater, but
also handles limited amounts of contaminated storm water from storage containment systems. Table 8-5
presents a summary of percent removal data collected at episode 4759 for the biological treatment units
only and for the entire treatment system (combined chemical precipitation and biological treatment
processes).
EPA determined the treatment efficiency of the biological treatment unit operations using the data obtained
from sampling points 02 and 03 (see Figure 8-29). As demonstrated on the Table 8-5, the biological
treatment units experienced good overall removals for a number of conventional/nonconventional and
organic parameters, including BOD5, COD, TOC, total phenols, aniline, benzoic acid, 2,4-dimethylphenol,
2-propanone, methylene chloride, 2-butanone, benzyl alcohol, isobutyl alcohol, o-cresol, p-cresol, 4-
methyl-2-pentanone, phenol, pyridine, toluene, and hexanoic acid. Most of the organic parameters
detected in the influent were removed to non-detect levels in the effluent from the biological treatment units.
Most of the metal parameters, such as chromium, copper, selenium, titanium, and zinc, were observed at
low concentrations in the influent to the biological treatment units and, therefore, did not demonstrate good
removal rates.
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EPA determined the treatment efficiency of the entire treatment system at the facility using the data obtained
from sampling points 01 and 03 (see Figure 8-29). As demonstrated on Table 8-5, the entire treatment
system experienced good overall removals for a number of convention/nonconventional and organic
parameters, including total phenols, BOD5, 2,4-dimethylphenol, aniline, benzene, benzoic acid, 2-
propanone, methylene chloride, 2-butanone, benzyl alcohol, isobutyl alcohol, o-cresol, p-cresol, 4-methyl-
2-pentanone, phenol, pyridine, toluene, tripropyleneglycol methyl ether, and hexanoic acid. Most of the
organic parameters detected in the influent were removed to non-detectable levels in the effluent. COD
and TOC percent removals were observed at 76.4 percent and 84.2 percent, respectively. Ammonia as
nitrogen and TSS had poor removal rates of 25.7 percent and 26.6 percent, respectively. Metals with
quantitative percent removals include arsenic (46.6 percent), chromium (80.2 percent), copper (45.2
percent), strontium (66.8 percent), titanium (89.6 percent), and zinc (62.5 percent). Pesticide/herbicide
parameters such as 2,4-DB, dicamba and dichloroprop had good removal efficiencies through the treatment
system. Dioxin/furan parameters were not detected in either the influent or effluent samples.
8.2.1.5 Treatment Performance for Episode 4687
EPA performed a 5-day sampling program during episode 4687 to obtain performance data on the reverse
osmosis treatment process installed at this Non-Hazardous Subtitle D facility. Aflow diagram of the landfill
wastewater treatment system sampled during episode 4687 is presented in Figure 8-30. The wastewater
treatment process used at this facility treats on-site landfill generated wastewater. Table 8-6 presents a
summary of percent removal data collected at episode 4687 for a single-pass reverse osmosis unit including
the multimedia filtration unit and the entire treatment system consisting of a second pass reverse osmosis
unit.
EPA determined the treatment efficiency of the single-pass reverse osmosis treatment system at the facility
using the data obtained from sampling points 01 and 02 (see Figure 8-30). As demonstrated on Table 8-
6, the single-pass reverse osmosis treatment system demonstrated good overall removals for a number of
conventional/nonconventional and organic parameters, including TSS, TOC, BOD5, TDS, COD, 4-methyl-
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2-pentanone, alpha terpineol, benzole acid, tripropyleneglycol methyl ether, and hexanoic acid. A number
of other organic parameters also were observed to have been removed by the treatment process at various
levels lower than 95 percent. Total phenols and ammonia as nitrogen percent removals were observed at
75.1 and 76.7 percent, respectively. Metals with quantitative percent removals include arsenic (87.4
percent), boron (54.1 percent), silicon (88.3 percent), and strontium (92.9 percent). All of the
pesticide/herbicide parameters detected in the influent, including 2,4,5-TP, 2,4-D, 2,4-DB, dicamba,
dichlorprop, MCPA and MCPP, were removed to non-detect levels.
EPA determined the treatment efficiency of the entire treatment system at the facility using the data obtained
from sampling points 01 and 03 (see Figure 8-30). The additional polishing reverse osmosis unit caused
the removal efficiency of most of the conventional and nonconventional parameters to increase. These
parameters include BOD5, ammonia as nitrogen, COD, TDS, TOC, and total phenols. The removal
efficiency of several organic parameters were observed to increase from the single-pass treatment system
including 2-butanone, 2-propanone, phenol, p-cresol, and toluene. The percent removal for boron also
increased from 54.1 percent in the single-pass reverse osmosis system to 94.4 percent in the two-stage
reverse osmosis treatment system.
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Table 8-1: Wastewater Treatment Technologies Employed at In-Scope Landfill Facilities
(Percent of Landfills Industry)
Treatment Technology
Equalization
Neutralization
Chemical oxidation
Chemical precipitation
Adsorption
Filtration
Stripping
Biological treatment
Gravity assisted separation
Sludge preparation
Sludge dewatering
Subtitle D Non-Hazardous
Direct
Discharge
21.0
6.3
11.2
9.1
1.4
10.5
4.2
32.2
27.3
3.5
12.6
Indirect
Discharge
11.2
6.7
0.5
5.4
1.3
1.5
1.3
3.8
9.0
0.5
5.2
Subtitle C
Hazardous
Indirect
Discharge
0.0
33.3
33.3
33.3
0.0
0.0
0.0
66.7
66.7
33.3
66.7
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Table 8-2: Treatment Technology Performance for Facility 4626 - Subtitle D Municipal
Pollutant of Interest
Subtitle D Municipal
Conventional
BOD
TSS
Nonconventional
Ammonia as Nitrogen
COD
Hexavalent Chromium
Nitrate/Nitrite
IDS
TOC
Total Phenols
Organics
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzoic Acid
Hexanoic Acid
Methylene Chloride
N,N-Dimethylformamide
O-Cresol
P-Cresol
Phenol
Toluene
Tripropyleneglycol Methyl Ether
Metals
Barium
Boron
Chromium
Silicon
Strontium
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
Disulfoton
Dioxins/Furans
1234678-HpCDD
OCDD
CAS
#
C-002
C-009
7664417
C-004
18540299
C-005
C-010
C-012
C-020
123911
78933
67641
108101
98555
65850
142621
75092
68122
95487
106445
108952
108883
20324338
7440393
7440428
7440473
7440213
7440246
7440326
7440666
120365
298044
35822469
3268879
DL
2,000
4,000
10.0
5,000
10.0
50.0
1,000
50.0
10.0
50.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
200
100
10.9
100
80.3
4.2
10.6
1.0
2.0
50.0
pg/L
100
DQ/L
Biological Treatment Unit Operation Only:
Sample Points 4 to 7
Influent
SP
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
Cone. (ug/L)
39,200
11,800
135,000
1,742,600
ND
1,535
5,960,000
758,000
182
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
10.3
3,211
11.6
784
ND
4.2
ND
NS
NS
NS
NS
Effluent
SP
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
Cone. (ug/L)
35,200
10,700
1,156
159,400
ND
130,500
5,181,000
52,800
50.0
13.8
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
21.8
2,925
ND
648
82.5
ND
12.0
NS
NS
NS
NS
%
Removal
10.2
9.3
99.1
90.9
0.0
13.1
93.0
72.5
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.0
8.9
6.5
17.4
0.0
1.0
0.0
NS
NS
NS
NS
Entire Treatment System:
Sample Points 1 & 2 (flow weighted) to 7
DL
2,000
4,000
10.0
5,000
10.0
50.0
1,000
50.0
10.0
50.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.6
/10.0
10.0
10.0
105
/99.0
200
100
10.9
100
100
4.2
20.0
1.0
2.0
50.0
Pg/L
100
ne/L
Influent
SP
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
1+2
Cone. (ug/L)
991,067
532,800
193,333
4,028,000
68.7
693
5,012,667
1,316,200
1,204
240
227,893
27,655
598
134
14,657
36,256
50.3
39.3
86.4
ND
685
1,095
ND
2427
4330
36.6
768
2,912
13.0
144
NS
NS
NS
NS
Effluent
SP
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
07
Cone. (ug/L)
35,200
10,700
1,156
159,400
ND
130,500
5,181,000
52,800
50.0
13.8
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
21.8
2,925
ND
648
82.5
ND
12.0
NS
NS
NS
NS
%
Removal
96.5
98.0
99.4
96.0
85.4
0.0
0.0
96.0
95.9
94.2
100
99.8
91.6
92.6
99.7
100
80.1
74.5
88.4
98.5
99.1
99.1
32.5
70.3
15.7
97.2
67.9
91.6
NS
NS
NS
NS
Negative percent removal are recorded as 0.0.
NS: Not Sampled SP: Sample point.
ND: Non-detect DL: Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
-------
Table 8-3: Treatment Technology Performance for Facility 4667 - Subtitle D Municipal
Pollutant of Interest
Subtitle D Municipal
Conventional
BOD
TSS
Noncon vention al
Ammonia as Nitrogen
COD
Hexavalent Chromium
Nitrate/Nitrite
IDS
TOC
Total Phenols
Organics
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzoic Acid
Hexanoic Acid
Methylene Chloride
N,N-Dimethylformamide
O-Cresol
P-Cresol
Phenol
Toluene
Tripropyleneglycol Methyl Ether
Metals
Barium
Boron
Chromium
Silicon
Strontium
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
Disulfoton
Dioxins/Furans
1234678-HpCDD
OCDD
CAS
#
C-002
C-009
7664417
C-004
18540299
C-005
C-010
C-012
C-020
123911
78933
67641
108101
98555
65850
142621
75092
68122
95487
106445
108952
108883
20324338
7440393
7440428
7440473
7440213
7440246
7440326
7440666
120365
298044
35822469
3268879
Biological Treatment Unit Operation Only:
Sample Points 3 to 4
DL
2,000
4,000
10.0
5,000
10.0
50.0
1,000
50.0
10.0
50.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
200
100
10.0
100
100
2.5
20.0
1.0
2.0
50.0
Pg/L
100
os/L
SP
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
Influent
Cone. (us/L)
232,600
59,600
134,800
635,000
ND
14,400
4,024,000
212,600
204
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
19.4
2,842
10.5
5,284
193
4.8
25.2
NS
NS
NS
NS
SP
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
Effluent
Cone. (ue/L)
119,300
10,200
26,040
478,200
ND
87,800
3,987,000
120,400
52.6
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
32.4
2,483
11.3
6,766
237
ND
58.6
ND
ND
NS
NS
%
Removal
48.7
82.9
80.7
24.7
0.0
0.9
43.4
74.2
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.0
12.6
0.0
0.0
0.0
48.1
0.0
NS
NS
NS
NS
Entire Treatment System:
Sample Points 1 to 6
DL
2,000
4,000
10.0
5,000
10.0
50.0
1,000
50.0
10.0
50.0
50.0
50.0
10.0
50.0
10.0
208
/10.0
10.0
10.0
10.0
10.0
10.0
99.0
200
100
11.1
100
100
2.5
20.0
11.8
/l.O
2.0
50.0
Pg/L
100
BS/L
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Influent
Cone. (ue/L)
1,088,000
93,400
295,900
2,932,000
26.0
494
6,232,000
1,098,600
940
323
8,767
13,021
1,239
430
33,335
37,256
ND
1,008
2,215
ND
387
668
ND
283
6,700
90.6
27,158
1,935
69.9
494
ND
6.1
NS
NS
SP
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
Effluent
Cone. (us/L)
201,000
ND
12,060
251,000
ND
87,000
3,834,000
82,000
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
42.6
2,334
ND
6,859
249
ND
27.1
ND
ND
NS
NS
%
Removal
81.5
95.7
95.9
91.4
61.5
0.0
38.5
92.5
94.7
96.9
99.4
99.6
96.0
97.7
99.9
100
99.0
99.6
97.4
98.5
85.0
65.2
87.7
74.7
87.1
96.4
94.5
67.2
NS
NS
Negative percent removal are recorded as 0.0.
NS: Not Sampled DL: Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
ND: Non-detect SP: Sample point
-------
Table 8-4: Treatment Technology Performance for Facility 4721 - Subtitle C Hazardous
oo
Pollutant of Interest
Subtitle C Hazardous
Conventional
BOD
Oil and Grease
TSS
Nonconventional
Amenable Cyanide
Ammonia as Nitrogen
COD
Nitrate/Nitrite
IDS
TOC
Total Cyanide
Total Phenols
Organics
1, 1-Dichloroethane
1,4-Dioxane
2-Butanone
2-Propanone
2,4-Dimethylphenol
4- Methyl- 2-Pentanone
Alpha Terpineol
Aniline
Benzene
Benzoic Acid
Benzyl Alcohol
Diethyl Ether
Ethylbenzene
Hexanoic Acid
Isobutyl Alcohol
M-Xylene
Methylene Chloride
Naphthalene
O+P Xylene
O-Cresol
P-Cresol
Phenol
Pyridine
Toluene
Trans- 1,2-Dichloroethene
Trichloroethene
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Metals
Arsenic
Boron
Chromium
Copper
Lithium
Metals (Cont'd)
Molybdenum
Nickel
CAS
#
C-002
C-036
C-009
C-025
7664417
C-004
C-005
C-010
C-012
57125
C-020
75343
123911
78933
67641
105679
108101
98555
62533
71432
65850
100516
60297
100414
142621
78831
108383
75092
91203
136777612
95487
106445
108952
110861
108883
156605
79016
20324338
75014
7440382
7440428
7440473
7440508
7439932
7439987
7440020
Biological Treatment Unit:
Sample Points 1 to 2
DL
2,000
5,000
4,000
10.0
10.0
5,000
50.0
1,000
20.0
50.0
10.0
10.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
10.0
10.0
100
10.0
8.0
100
10.0
40.0
Influent
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Cone. (us/L)
877,875
45,442
191,375
ND
382,250
2,033,750
1,770
12,275,000
562,250
54.1
3,195
31.5
ND
6,398
4,398
79.0
2,175
691
685
127
5,294
23.7
104
545
1,632
ND
412
49.2
486
155
ND
218
1,553
12.0
1,468
52.7
ND
1,756
15.6
1,492
8,839
86.7
20.6
277
227
131
Effluent
SP
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cone. (us/L)
47,000
6,792
53,375
ND
1,433
565,750
333,375
12,075,000
189,625
46.1
67.6
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
569
8,449
46.5
ND
316
266
125
%
Removal
94.7
85.1
72.1
99.6
72.2
0.0
1.6
66.3
14.8
97.9
68.2
99.2
98.9
87.4
97.7
98.6
98.5
92.2
99.1
57.9
51.8
98.2
99.4
97.6
79.7
97.9
93.6
95.4
99.4
16.5
99.3
81.0
94.4
36.0
61.9
4.4
46.4
61.2
0.0
0.0
4.1
-------
Table 8-4: Treatment Technology Performance for Facility 4721 - Subtitle C Hazardous (continued)
oo
Pollutant of Interest
Subtitle C Hazardous
Selenium
Silicon
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
2,4-D
2,4-DB
2,4,5-TP
Dicamba
Dichloroprop
MCPA
MCPP
Picloram
Terbuthylazine
Dioxins/Furans
1234678-HpCDD
1234678-HpCDF
OCDD
OCDF
CAS
#
7782492
7440213
7440246
7440315
7440326
7440666
94757
94826
93721
1918009
120365
94746
7085190
1918021
5915413
35822469
67562394
3268879
39001020
Biological Treatment Unit:
Sample Points 1 to 2
DL
15.5
100
100
30.0
5.0
20.0
1.0
2.0
0.2
0.2
1.0
50.0
50.0
0.5
5.0
50.0
Pg/L
50.0
Pg/L
100.0
Pg/L
100.0
D2/L
Influent
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Cone. (us/L)
20.0
5,518
2,846
30.7
64.5
253
1.2
3.9
0.5
1.1
2.1
59.1
153
0.5
6.0
588
Pg/L
63.3
pg/L
6,148
Pg/L
237
r>2/L
Effluent
SP
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cone. (us/L)
ND
5,024
2,494
ND
5.3
85.3
ND
ND
ND
0.4
1.3
ND
51.9
ND
ND
NS
NS
NS
NS
%
Removal
22.5
9.0
12.4
2.4
91.7
66.3
14.0
48.4
55.1
64.2
37.7
15.3
66.1
2.0
16.8
NS
NS
NS
NS
Negative percent removal are recorded as 0.0.
NS: Not Sampled
ND: Non-detect
DL: Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
SP: Sample point.
-------
Table 8-5: Treatment Technology Performance for Facility 4759 - Subtitle C Hazardous
Pollutant of Interest
Subtitle C Hazardous
Conventional
BOD
Oil and Grease
TSS
Nonconventional
Amenable Cyanide
Ammonia as Nitrogen
COD
Nitrate/Nitrite
IDS
TOC
Total Cyanide
Total Phenols
Organics
1, 1-Dichloroethane
1,4-Dioxane
2-Butanone
2-Propanone
2,4-Dimethylphenol
4-Methyl-2-Pentanone
Alpha Terpineol
Aniline
Benzene
Benzoic Acid
Benzyl Alcohol
Diethyl Ether
Ethylbenzene
Hexanoic Acid
Isobutyl Alcohol
M-Xylene
Methylene Chloride
Naphthalene
O+P Xylene
O-Cresol
P-Cresol
Phenol
Pyridine
Toluene
Trans- 1,2-Dichloroethene
Trichloroethene
Tripropyleneglycol Methyl Ether
Vinyl Chloride
Metals
Arsenic
Boron
Chromium
CAS
#
C-002
C-036
C-009
C-025
7664417
C-004
C-005
C-010
C-012
57125
C-020
75343
123911
78933
67641
105679
108101
98555
62533
71432
65850
100516
60297
100414
142621
78831
108383
75092
91203
136777612
95487
106445
108952
110861
108883
156605
79016
20324338
75014
7440382
7440428
7440473
Bioliogical Treatment Unit Only:
Sample Points 2 to 3
DL
2,000
5,000
4,000
20.0
10.0
5,000
50.0
1,000
20.0
50.0
10.0
10.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
10.0
10.0
100
10.0
Influent
SP
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cone. (ug/L)
2,650,000
30,167
47,300
NS
194,400
5,200,000
263,196
17,230,000
1,800,000
869
97,340
23.8
1,935
1,633
3,254
1,798
1,009
ND
577
32.0
70,690
859
ND
13.8
5,266
127
10.6
604
22.0
ND
61.2
5,119
54,808
309
120
ND
ND
ND
ND
389
2,706
158
Effluent
SP
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
Cone. (ug/L)
62,800
9,333
90,000
271
155,500
1,180,000
240,423
15,680,000
284,700
796
155
ND
702
ND
65.0
201
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10.3
ND
ND
ND
ND
29.7
ND
ND
ND
ND
ND
ND
312
2,486
82.4
%
Removal
97.6
69.1
0.0
NS
20.0
77.3
8.7
9.0
84.2
8.5
99.8
58.0
63.7
96.9
98.0
88.8
95.1
98.3
68.7
99.9
98.8
27.3
99.8
92.1
5.3
98.3
54.6
83.7
99.8
100
96.8
91.7
19.9
8.1
47.8
Entire Treatment System
Sample Points 1 to 3
DL
2,000
5,000
4,000
20.0
10.0
5,000
50.0
1,000
20.0
50.0
10.0
10.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
10.0
10.0
100
10.0
Influent
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Cone. (ug/L)
2,664,000
37,333
122,600
3,990
209,400
5,006,000
259,242
16,360,000
1,804,000
9,756
97,860
26.7
2,003
1,724
3,634
1,550
1,027
ND
533
36.2
64,957
878
ND
15.8
3,640
138
10.7
661
24.8
ND
188
5,022
65,417
301
136
ND
ND
1,021
ND
584
2,918
415
Effluent
SP
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
Cone. (ug/L)
62,800
9,333
90,000
271
155,500
1,180,000
240,423
15,680,000
284,700
796
155
ND
702
ND
65.0
201
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10.3
ND
ND
ND
ND
29.7
ND
ND
ND
ND
ND
ND
312
2,486
82.4
%
Removal
97.6
75.0
26.6
93.2
25.7
76.4
7.3
4.2
84.2
91.9
99.8
62.5
65.0
97.1
98.2
87.0
95.1
98.1
72.4
99.9
98.9
36.5
99.7
92.8
6.2
98.4
59.6
94.7
99.8
100
96.7
92.6
90.3
46.6
14.8
80.2
-------
Table 8-5: Treatment Technology Performance for Facility 4759- Subtitle C Hazardous (continued)
Pollutant of Interest
Subtitle C Hazardous
Metals (cont.)
Copper
Lithium
Molybdenum
Nickel
Selenium
Silicon
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
2,4-D
2,4-DB
2,4,5-TP
Dicamba
Dichloroprop
MCPA
MCPP
Picloram
Terbuthylazine
Dioxins/Furans
1234678-HpCDD
1234678-HpCDF
OCDD
OCDF
CAS
#
7440508
7439932
7439987
7440020
7782492
7440213
7440246
7440315
7440326
7440666
94757
94826
93721
1918009
120365
94746
7085190
1918021
5915413
35822469
67562394
3268879
39001020
Bioliogical Treatment Unit Only:
Sample Points 2 to 3
DL
25.0
100
10.0
40.0
5.0
100
100
30.0
5.0
20.0
1.0
2.0
0.2
0.2
1.0
50.0
50.0
0.5
5.0
50.0
pg/L
50.0
Pg/L
100
pg/L
100
oe/L
Influent
SP
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cone. (ug/L)
61.1
253
13,710
2,014
191
6,924
105
800
5.1
26.7
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Effluent
SP
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
Cone. (ug/L)
76.4
239
13,130
1,878
190
6,153
94.4
723
2.4
47.2
11.8
4.3
0.4
0.9
4.7
182
288
2.5
28.4
ND
ND
ND
ND
%
Removal
0.0
5.5
4.2
6.8
0.2
11.1
9.9
9.5
52.1
0.0
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Entire Treatment System
Sample Points 1 to 3
DL
25.0
100
10.0
40.0
5.0
100
100
30.0
5.0
20.0
1.0
2.0
0.2
0.2
1.0
50.0
50.0
0.5
5.0
50.0
Pg/L
50.0
Pg/L
100
Pg/L
100
DS/L
Influent
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Cone. (ug/L)
139
266
13,260
2,060
178
6,036
284
908
23.3
126
11.2
43.8
0.5
41.6
18.3
332
662
4.5
97.6
ND
ND
ND
ND
Effluent
SP
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
Cone. (ug/L)
76.4
239
13,130
1,878
190
6,153
94.4
723
2.4
47.2
11.8
4.3
0.4
0.9
4.7
182
288
2.5
28.4
ND
ND
100
Pg/L
ND
%
Removal
45.2
10.2
1.0
8.8
0.0
0.0
66.8
20.4
89.6
62.5
0.0
90.2
18.3
97.9
74.3
45.3
56.5
45.2
70.9
oo
Negative percent removal are recorded as 0.0.
NS: Not Sampled
ND: Non-detect
DL: Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
SP: Sample point.
-------
Table 8-6: Treatment Technology Performance for Facility 4687 - Subtitle D Municipal
Pollutant of Interest
Subtitle D Municipal
Conventional
BOD
TSS
Noconventional
Ammonia as Nitrogen
COD
Hexavalent Chromium
Nitrate/Nitrite
TDS
TOC
Total Phenols
Organics
1,4-Dioxane
2-Butanone
2-Propanone
4-Methyl-2-Pentanone
Alpha Terpineol
Benzoic Acid
Hexanoic Acid
Methylene Chloride
N,N-Dimethylformamide
O-Cresol
P-Cresol
Phenol
Toluene
Tripropyleneglycol Methyl Ether
Metals
Barium
Boron
Chromium
Silicon
Strontium
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
Disulfoton
Dioxins/Furans
1234678-HpCDD
OCDD
CAS
#
C-002
C-009
7664417
C-004
18540299
C-005
C-010
C-012
C-020
123911
78933
67641
108101
98555
65850
142621
75092
68122
95487
106445
108952
108883
20324338
7440393
7440428
7440473
7440213
7440246
7440326
7440666
120365
298044
35822469
3268879
Single-Stage Reverse Osmosis Treatment System Only:
Sample Point 1 to 2
DL
2,000
4,000
10.0
5,000
10.0
50.0
1,000
50.0
10.8
/14.9
50.0
50.0
50.5
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
200
100
9.0
100
100
4.0
10.9
/9.0
1.0
2.0
49.8
Pg/L
99.5
os/L
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Influent
Cone. (ug/L)
1,182,000
171,800
58,480
1,526,000
28.0
1,300
2,478,000
642,600
1,262
ND
3,250
1,580
382
44.5
7,685
5,818
ND
ND
ND
797
702
376
1,207
280
1,808
ND
4,362
1,406
ND
ND
6.1
14.3
ND
ND
SP
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Effluent
Cone. (ug/L)
54,000
ND
13,600
72,200
ND
666
116,600
25,000
316
ND
1,774
1,842
ND
ND
96.3
118
ND
ND
ND
253
185
112
ND
5.6
830
ND
511
ND
ND
ND
ND
ND
NS
NS
%
Removal
95.4
97.7
76.7
95.3
64.3
48.8
95.3
96.1
75.0
45.4
0.0
86.8
77.5
98.8
98.0
68.3
73.6
70.2
91.8
98.0
54.1
88.3
92.9
83.6
86.1
NS
NS
Entire Treatment System:
Sample Point 1 to 3
DL
2,000
4,000
10.0
5,000
10.0
50.0
10,000
10,000
50.0
10.8
/10.0
50.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
99.0
200
100
9.0
100
100
4.0
10.9
/10.0
1.0
2.0
49.8
Pg/L
99.5
os/L
SP
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Influent
Cone. (ug/L)
1,182,000
171,800
58,480
1,526,000
28.0
1,300
2,478,000
642,600
1,262
ND
3,250
1,580
382
44.5
7,685
5,818
ND
ND
ND
797
702
376
1,207
280
1,808
ND
4,362
1,406
ND
ND
6.1
14.3
ND
ND
SP
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
Effluent
Cone. (ug/L)
5,400
ND
608
11,400
ND
502
ND
ND
62.8
ND
372
470
ND
ND
ND
ND
ND
ND
ND
22.3
29.3
15.1
ND
1.4
101
ND
355
ND
ND
ND
ND
ND
NS
NS
%
Removal
99.5
97.7
99.0
99.3
64.3
61.4
99.6
98.4
95.0
88.6
70.3
86.9
77.5
99.4
99.8
97.2
95.8
96.0
91.8
99.5
94.4
91.9
92.9
83.6
86.1
NS
NS
Negative percent removal are
NS: Not Sampled DL:
ND: Non-detect SP:
recorded as 0.0.
Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
Sample point.
-------
Wastewater
Influent
II
Equalization Tank
Equalized
Wastewater
Effluent
Figure 8-1: Equalization
Wastewater
Influent
11
V V
Neutralization Tank
Acid
Caustic
pH monitor/control
Neutralized
Wastewater
Effluent
Fiaure 8-2: Neutralization
8-61
-------
Coagulant
Influent -
Clarifier
Rapid Mix
Tank
Flocculating
Tank
Effluent
Sludge
Figure 8-3: Clarification System Incorporating Coagulation and Flocculation
8-62
-------
100
10
"Sfc
a
o
1
S
o
o
U
—
3
0.1
3 0.01
0.001
0.0001
(
\
A
\\
-4\-
\\
:u(OH)2 \
\ 0
.\-. .-
V
\
\
Pb
\
\
V. . . . L .
\ /
\\ y
\ \ /L-
\ 7\
i \y \
\
\
\ \
\ \
\\
\ \
\ \
\\
\ \
\
\
\
/
OH)2 /
/
/
/
^^_^/
'/ C
/ /
/
\
\
\^
Ni(O
/ /
//
'
i /
\ /
:r(OH)3
Zn(C
/ C(
/
/
/
/
/
/
/
/
H)2
)H)2
i(OH)2
8
PH
10
12
14
16
Figure 8-4: Calculated Solubilities of Metal Hydroxides
8-63
-------
Wastewater
Influent
/ Chemical
\ Controller
\
Chemical Precipitation Tank
Liquid
Effluent
Sludge
Clarifier
Sludge Handling
and/or Treatment
Figure 8-5: Chemical Precipitation System Design
8-64
-------
Caustic Feed
Hypochlorite or Chlorine Feed
Waste water
Influent •
Acid Feed
Treated
Effluent
First Stage
Second Stage
Figure 8-6: Cyanide Destruction
8-65
-------
Su If uric
Acid
Treatment
Chemical
pH Controller
Waste water
Influent
Chemical Controller
•Treated
Effluent
Reaction Tank
Figure 8-7: Chromium Reduction
8-66
-------
Wastewater
Influent
Air
Blower
*—LJ—LJ—LJ—LJ—LJ—'
Packing
Off-gas
Distributor
Treated
Effluent
Figure 8-8: Typical Air Stripping System
8-67
-------
Waste water Influent
Coarse Media
Finer Media
Finest Media
Support
Underdrain Chamber
Treated Effluent
Backwash
Backwash
Figure 8-9: Multimedia Filtration
8-68
-------
Permeate (Treated Effluent)
Waste water
Feed
Concentrate
Membrane Cross-section
Figure 8-10: Ultrafiltration System Diagram
8-69
-------
Concentrate
Membrane
Feed
Figure 8-11: Tubular Reverse Osmosis Module
8-70
-------
Wastewater
Influent
Fresh
Carbon
Fill
Collector/
Distributor
Spent
Carbon
Discharge
Backwash
iiijHjjjijijiii
iiiiiiiiiiiiiii
Backwash
Treated
Effluent
Figure 8-12: Granular Activated Carbon Adsorption
8-71
-------
Wastewater -I^^L Regenerant
Influent
Used
I/
>
i
^\
Resin
^
l^ss
Solution
^xi Treated
Regenerant 1^^ " Effluent
Figure 8-13: Ion Exchange
8-72
-------
Surface Aerators
Figure 8-14: Aerated Lagoon
8-73
-------
Gas Exchange
Figure 8-15: Facultative Pond
8-74
-------
oo
Gas Outlet
Floating Cover
Sludge
Heater
First Stage
(completely mixed)
Second Stage
(stratified)
Supernatant
Outlet
Sludge
Outlet
Figure 8-16: Completely Mixed Digester System
-------
Figure 8-17: Rotating Biological Contactor Cross-Section
8-76
-------
Figure 8-18: Trickling Filter
8-77
-------
Inoculum '
Nutrient Solution '
Wastewater Influent '
Packing
Treated
Effluent
Blower
Figure 8-19: Fluidized Bed Reactor
8-78
-------
Wastewater
Influent
Secondary Clarifier
(side view)
Recycle Sludge
Waste
Excess Sludge
Figure 8-20: Activated Sludge System
8-79
-------
Virgin
PAC
Primary
Effluent
Contact - Aeration
Tank
Clarification
Tank
Filtration
(optional)
Effluent
Carbon / Microorganism
Recycle
Overflow
Division
Box
Figure 8-21: Powder Activated Carbon Treatment System
8-80
-------
Process
Cycle
Fill
React
Settle
Decant
Figure 8-22: Sequencing Batch Reactor Process Diagram
8-81
-------
Sludge from
Chemical Precipitation
(-3% solids)
Supernatant
Settling
Zone
Supernatant
Thickened Sludge to Contract Haul
or to Sludge Dewatering
(-5% solids)
Figure 8-23: Gravity Thickening
8-82
-------
Fixed End
Sludge
Influent
Filtrate
Filter Cloth
Filter Cake
Plate Assembly
Figure 8-24: Plate-and-Frame Pressure Filtration System Diagram
8-83
-------
Fine Sand
Coarse Sand
Fine Gravel
Medium Gravel
Coarse Gravel
Drying Sludge
vijping wi««gv
Underdrain
Figure 8-25: Drying Bed
8-84
-------
Leachate
Leachate and
Gas Condensate
OO
OO
Sodium
Hydroxide
Anionic
Polymer
Weak Hydrochloric
Acid and Phosphate Addition
Effluent Discharge
to Surface Water
Sampling Location
Ferric Chloride, Sodium
Hypochlorite, and Weak
Hydrochloric Acid
Figure 8-26: EPA Sampling Episode 4626 - Landfill Waste Treatment System Block Flow Diagram with Sampling Locations
-------
Leachate and
Maintenance Faclility
Sanitary Wastewater
NaOH
OO
oo
Polymer and
Lime Coagulant
L i
Mix
Tank
Flocculator
Primary
Clarifier
Sludge
Sequencing
Batch Reactor (SBR)
Overflow, Filtrate, and Supernate
Sodium
Hypochlorite
) Sampling Location
Sulfuric
Acid
Phosphoric
Acid
Effluent Dicharge to
Surface Water
i
Surge
Tank
Sludge
Thickeners
Perlite
Sludge
Holding Tank
Plate and Frame
Press
T
Sludge Disposal
in Landfill
Figure 8-27: EPA Sampling Episode 4667 - Landfill Waste Treatment System Block Flow Diagram with Sampling Locations
-------
Leachate and
Off-Site
Waste
Influent
Equalization
Feed Tanks
(10)
oo
I
oo
Sequencing
Batch Reactor
(SBR) (3)
To
POTW
Sludge
Sludge
Thickening
Filter
Press
To Hazardous
Waste Incinerator
Filtrate
) Sampling Location
Figure 8-28: EPA Sampling Episode 4721 - Landfill Waste Treatment System Block Flow Diagram with Sampling Locations
-------
oo
oo
oo
Ferric Sulfuric
Chloride Acid
Ferrous Sodium
Sulfate Hydroxide
Equalization
Tank
(feed tank)
Leachate
Contaminated Water
Storm Water
from Paved Areas
Chemical
Precipitation
Waste
Sludge
Cationic
Polymer
Sulfuric Phosphoric
Acid Acid
Flocculation
Primary
Clarifier
Sludge
Neutralization
Return Sludge
Aeration
Secondary
Clarifier
Sludge
Hold
Tank
Sanitary
Wastewater
Waste
Sludge
Sludge
Thickener
Conditioner
Supernate
Filtrate
Contact Water
Tank No. 1
Clean Water
Contact
Tank No. 2
To
POTW
Sodium Air
Hypochlorite
Filter
Press
Solids to
Landfill
Sampling Location
Figure 8-29: EPA Sampling Episode 4759 - Landfill Waste Treatment System Block Flow Diagram with Sampling Locations
-------
HCL (in-line addition)
Raw
Leachate
Equalization
Tank
f n
^
Multimedia
Filter
T
r „
Cartridge
Filter
oo
oo
VO
Feed
Pump
Equalization
Tank
i
r
A
Double Pass
Permeate
Second Reverse
Osmosis
Unit
0
Single Pass
Permeate
First Reverse
Osmosis
Unit
Concentrate to
Landfill
toPOTW
( j Sampling Location
Figure 8-30: EPA Sampling Episode 4687 - Landfill Waste Treatment System Block Flow Diagram with Sampling Locations
-------
9.0 ENGINEERING COSTS
This chapter presents the costs estimated for compliance with the effluent limitations guidelines and
standards for the Landfills industry. Section 9.1 provides a discussion of the cost-estimation methodologies
considered by EPA including evaluation of two cost-estimation models. Section 9.2 presents a discussion
of the types of cost estimates developed, while in Section 9.3, the development of capital costs, operating
and maintenance (O&M) costs, and other related costs is described in detail. Section 9.4 summarizes the
compliance costs for each regulatory option considered by EPA.
9.1 Evaluation of Cost-Estimation Techniques
This section presents a discussion of the cost-estimation techniques considered by EPA, including
evaluation of two cost-estimation models. In this section, the Agency presents the criteria used to evaluate
these techniques as well as the results of a benchmark analysis to compare the accuracy of these
techniques. This section also presents the selected cost-estimation techniques.
9.1.1 Cost Models
EPA developed compliance-cost estimates for leachate treatment systems to determine the economic
impact of the regulation. EPA has identified existing cost-estimation models to facilitate the development
of compliance-cost estimates. In a mathematical cost model, various design and vendor data on a variety
of treatment technologies are combined and cost equations that describe costs as a function of system
parameters, such as flow, are developed for each treatment technology. Using these types of models
allows for the generation of compliance-cost estimates for several regulatory options that are based on the
iterative addition of treatment technologies and can assist EPA in the selection of options as the basis for
the regulations.
EPA evaluated the following two well-known cost models for use in developing costs:
9-1
-------
Computer-Assisted Procedure for the Design and Evaluation of Wastewater Treatment
Systems (CAPDET), developed by the U.S. Army Corps of Engineers.
• WAV Costs Program (WWC), Version 2.0, developed by CWC Engineering Software.
CAPDET is intended to provide planning level cost estimates to analyze alternatives in the design of
wastewater treatment systems. Modules are used to develop cost estimates for a variety of physical,
chemical, and biological treatment unit processes and can be linked together to represent entire treatment
trains. Equations in each of these modules are based upon common engineering principles used for
wastewater treatment system design. The CAPDET algorithm generates a design based on input
parameters selected by the user, calculates cost estimates for various treatment trains, and ranks them
based on present worth, capital, operating, or energy costs.
The WWC cost model was developed by Culp/Wesner/Culp from a variety of engineering sources,
including vendor supplied data, actual plant construction data, unit takeoffs from actual and conceptual
designs, and published data. The model calculates cost estimates for a variety of individual treatment
technology units that can be combined together to develop compliance-cost estimates for the complete
treatment systems. The WWC model does not design each treatment technology unit but rather prompts
the user to provide design-input parameters that form the basis for the cost estimate. The WWC model
includes a separate spreadsheet program that provides design criteria guidelines to assist in developing the
input parameters to the cost-estimating program. The spreadsheet includes treatment component design
equations and is supplied with default parameters that are based upon accepted design criteria used in
wastewater treatment, to assist in the design of particular treatment units. The spreadsheet also is flexible
enough to allow selected design parameters to be modified to estimate industry-specific factors accurately.
Once design inputs are entered into the program, the WWC model calculates both construction and
operation and maintenance (O&M) costs for the selected wastewater treatment system.
9.1.2 Vendor Data
For certain wastewater treatment technology units, the cost model was not considered the most accurate
9-2
-------
estimate of costs. For these instances, EPA determined that reported equipment and operation and
maintenance costs obtained directly from equipment vendors often can provide accurate cost estimates.
EPA provided information on landfill wastewater characteristics to vendors to determine the appropriate
treatment unit and accurate sizing. Quotes obtained from vendors included equipment costs that EPA
factored up to total capital costs to account for site preparation, mobilization costs, and engineering
contingencies. EPA also obtained vendor quotes for operation and maintenance costs, including utility usage
and cost. The Agency used vendor quotes to determine cost curves for equalization, multi-media filtration,
granular activated carbon, breakpoint chlorination, and reverse osmosis. EPA based the cost curves used
for these treatment technologies on direct vendor quotes, commercial costing guides, or cost information
developed from vendor quotes as part of the Centralized Waste Treatment (CWT) effluent guidelines effort.
9.1.3 Other EPA Effluent Guideline Studies
EPA reviewed other EPA effluent studies, such as the Organic Chemicals and Plastics and Synthetic Fibers
(OCPSF) industry effluent guidelines, to obtain additional costing background and supportive information.
However, EPA did not use costs developed as part of other industrial effluent guidelines in costing for this
industry, with the exception of the CWT effluent guideline data referenced in Section 9.1.2.
9.1.4 Benchmark Analysis and Evaluation Criteria
EPA performed benchmark analyses to evaluate the accuracy of each cost-estimation technique. This
benchmark analysis used reported costs provided in the 308 Questionnaires and compared them to costs
generated using each cost-estimation technique. EPA selected four landfill facilities (Questionnaire
Identification numbers (QIDs) 16122,16125,16041, and 16087) with wastewater treatment systems for
the benchmark analysis. The agency developed cost estimates for wastewater treatment units that make
up the treatment systems at these landfill facilities using the WWC and CAPDET models and vendor
quotes. Next, EPA compared these cost estimates to the reported component costs provided in the 308
Questionnaires to evaluate the accuracy of each methodology in estimating capital and operation and
9-3
-------
maintenance costs. This cost comparison is presented in Table 9-1. Treatment technologies that EPA used
in this benchmark analysis include the following:
equalization,
chemical precipitation,
• activated sludge,
• sedimentation, and
multi-media filtration.
EPA also benchmarked cost estimates developed using these techniques against reported costs for
wastewater treatment systems that included equalization, chemical precipitation, and multimedia filtration
and were obtained from industrial waste combustor facilities as part of that effluent guidelines effort. EPA
believes that the wastewater characteristics being treated by these treatment systems, i.e., inorganic
contaminants and solids in an uncomplexed matrix, are similar for both landfills and industrial waste
combustor facilities and that this additional comparison provides a more thorough evaluation of the
Agency's cost-estimation methodologies. Table 9-2 presents a comparison of the capital and O&M costs
obtained for the wastewater treatment systems at four industrial waste combustor facilities to the cost
estimates obtained using each technique, i.e., the WWC and CAPDET models, and vendor quotes.
As shown in Tables 9-1 and 9-2, EPA has determined that, based on the results of the benchmark analyses
for both data sources, the WWC model generated cost estimates that are considered more accurate than
the CAPDET model when compared to reported treatment technology costs as provided in 308
Questionnaire responses. In all instances, the WWC model estimated the more accurate treatment system
capital and O&M costs as compared to CAPDET and vendor costs. For several facilities, such as QIDs
16087, 16122, and 16125, the WWC model generated capital costs to within 32 percent of costs
provided in the questionnaires. EPA estimated O&M costs for several facilities, including QIDs 16041,
16087, and 16122, to within 18 percent of costs provided in the 308 Questionnaires.
EPA used the following criteria to evaluate each cost-estimation technique and to select the appropriate
option for developing a methodology for estimating compliance costs for the Landfills industry:
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Does the model contain costing modules representative of the various wastewater
technologies in use or planned for use in the Landfills industry?
• Can the model produce costs in the expected flow range experienced in this industry?
Can the model be adapted to cost entire treatment trains used in the Landfills industry?
• Is sufficient documentation available regarding the assumptions and sources of data so that
costs are credible and defensible?
• Is the model capable of providing detailed capital and operation and maintenance costs
with unit-costing breakdowns?
Is the model capable of altering the default design criteria in order to accurately represent
reported design criteria indicative of the Landfills industry?
9.1.5 Selection of Final Cost-Estimation Techniques
Based upon the results of the benchmark analysis, EPA selected the WWC model for estimating costs for
the majority of the treatment technologies that form the basis for BPT/BAT/NSPS effluent limitations and
standards. The Agency determined that the WWC model is capable of producing accurate capital and
O&M costs for a wide range of treatment technologies. EPA found that the CAPDET model was not
capable of generating cost estimates for many of the technologies that form the basis for BPT/BAT/NSPS
effluent limitations and standards for the Landfills industry, and the Agency determined that it was not
accurate in estimating technology costs for landfill facilities. Therefore, EPA decided not to use the
CAPDET model for estimating compliance costs.
EPA has determined that the WWC model best satisfies the selection criteria. The program can estimate
costs for a wide range of typical and innovative treatment technologies and can combine these costs of each
technology to develop system costs. Since the WWC model is a computer based program, it readily
allows for the iterative development of costs for a number of facilities and regulatory options. The program
utilizes cost modules that can accommodate the range of flows and design-input parameters needed to
develop cost estimates for landfill facilities. Cost estimates generated by this model are based upon a
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number of sources, including actual construction and operation costs, along with published data, and are
presented in a breakdown summary table that contains unit costs and totals. Finally, the WWC model can
be adapted to estimate costs based upon specified design criteria and wastewater flow rates.
EPA notes that there were particular technologies for which the WWC model did not produce accurate
cost estimates. These technologies included equalization, multimedia filtration, granular activated carbon,
breakpoint chlorination, and reverse osmosis. In some low-flow situations, costs developed for these
treatment technologies were excessively high as compared to industry provided costs in 308 Questionnaire
responses. For these technologies, EPA determined that vendor quotes provided a more accurate estimate
of compliance costs and would be used in the final engineering costing methodology for these technologies.
In addition, in a select few cases, EPA determined that it would be more economically feasible for some
facilities to truck/pipe their wastewater off-site for treatment than to construct and maintain their own
wastewater treatment system. These facilities had extremely low average daily flow rates (50 gallons or
less); therefore, EPA substituted an off-site disposal cost for CWT treatment for BPT/B AT capital and O
& M costs (see also 9.2.6).
9.2 Engineering Costing Methodology
This section presents the costing methodology used to develop treatment costs for BPT, BCT, and BAT
options for the Landfills industry. This section also presents a description of additional costs, such as
monitoring costs, that EPA developed. The following discussion presents a detailed summary of the
technical approach used to estimate the compliance costs for each landfill facility. The Agency developed
total capital and annual operation and maintenance costs for each facility in its database to upgrade its
existing wastewater treatment system, or to install new treatment technologies, to comply with the long term
averages for each regulatory option. Development of the long-term averages is discussed in Chapter 11
of this document and in the Statistical Support documents. EPA costed facilities primarily using the WWC
model and, on occasion, from cost curves developed from vendor quotes. Table 9-3 presents a breakdown
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of the cost-estimation method used for each treatment technology. EPA developed additional costs for
monitoring, Resource Conservation and Recovery Act (RCRA) permit modifications, and residual disposal.
The Agency developed total facility compliance costs under each BPT, BCT, and BAT option by adding
treatment costs with these additional costs. EPA did not develop cost estimates for zero or alternative
discharge facilities for any of the regulatory options (with the exception of some low flow facilities, see
9.2.5).
9.2.1 Treatment Costing Methodology
The methodology used to develop facility-specific BPT, BCT, and BAT option-compliance costs is
presented graphically on the flow diagram in Figure 9-1. EPA costed facilities for an entire new treatment
system, whether or not they had existing treatment at the facility, if the collected flow subject to this
guideline was less than 85 percent of the total facility flow rate.
For each regulatory option, EPA evaluated each landfill facility in the Detailed Questionnaire database to
determine if the facility would incur costs in order to comply with the regulations. EPA compared the
current discharge concentrations of the facility's effluent with the long-term averages from each regulatory
option. If the facility's current discharge concentration was less than the long-term average, EPA
considered it to be in compliance. A facility considered to be in compliance was projected to incur costs
only for additional monitoring requirements. If a facility was not in compliance but had treatment unit
operations in-place capable of complying with the long-term averages, EPA costed the facility for system
upgrades that would bring the facility into compliance.
For facilities that did not have BPT/BCT/BAT treatment systems or the equivalent, the Agency developed
cost estimates for the additional unit operations and/or system upgrades necessary to meet each long term
average. Facilities that were already close to compliance with the long-term averages only required an
upgrade to achieve compliance with limitations for a regulatory option. EPA developed upgrade costs
using the WWC model whenever possible and included either additional equipment to be installed as part
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of an existing wastewater treatment system, expansion of existing equipment, or operational changes.
Examples of upgrade costs include such items as new or expanded chemical feed systems and improved
or expanded aeration systems. If a facility had no treatment system (or one that could not achieve desired
levels with upgrades or minor additions) the Agency developed cost estimates for an entire BPT/BCT/B AT
treatment system for that facility.
The first step in using the WWC model was to use the design-criteria guidelines spreadsheet to develop
input parameters for the computer program. EPA used reported pollutant loadings from the facility
whenever possible. If pollutant loadings were not available for a particular parameter, EPA used the
estimates of pollutant concentrations in untreated landfill wastewater (see Chapter 6). The Agency also
used the facility's baseline flow rate and the regulatory option long-term averages in the design of the unit
operation. Certain parameters such as BOD5, TSS, and ammonia are used directly in the WWC model
and the design-criteria guideline spreadsheet to design the various treatment unit operations. EPA selected
metals that were included as pollutants of interest to assist in the design of chemical precipitation systems.
The metals to be treated typically control the type and amount of precipitating agents, which govern the
chemical feed system design. A more detailed discussion of the design parameters and costs associated
with individual treatment technologies is presented in Section 9.3.
The design parameters from the design-criteria spreadsheet then were input in the WWC model to
generate installed capital and O&M costs. O&M costs for treatment chemicals, labor, materials, electricity,
and fuel are included in the WWC model O&M costs. Treatment costs developed using the WWC model
were corrected to 1992 dollars using the Engineering News Record published indexes. After EPA
developed the installed capital and annual O&M costs for each facility, it applied selected cost factors, as
shown in Table 9-4, to the results to develop total capital and O&M costs.
To complete the estimation of compliance costs for each regulatory option, EPA developed cost estimates
for other than treatment component costs. The assessment must take into account other costs associated
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with compliance with the effluent limitations guidelines and standards, including the following:
land,
residual disposal,
• RCRA permit modifications, and
• monitoring.
Each of these additional costs are further discussed and defined in the following sections.
The Agency developed final capital costs for each facility and then amortized them using a seven percent
interest rate over 15 years. EPA the added this annualized capital cost to the annual O&M cost to develop
a total annual cost for each regulatory option.
9.2.1.1 Retrofit Costs
EPA applied a retrofit cost factor when additional equipment or processes were required for existing
systems. Retrofit costs cover the need for system modifications and components, such as piping, valves,
controls, etc., that are necessary to connect new treatment units and processes to an existing treatment
facility. EPA estimated retrofit costs at 20 percent of the installed capital cost of the equipment.
9.2.2 Land Costs
EPA did not include land costs in this analysis because it determined that landfills have adequate land to
accommodate additional treatment systems. Typically, the size of the required treatment system is small
when compared to the land area occupied by landfills. Landfills, as required by regulation and permit, have
buffer zones around the fill areas. New treatment systems, or upgrades to an existing system, can be
installed readily in this buffer zone or elsewhere at the landfill without the need to acquire new land.
9.2.3 Residual Disposal Costs
For each of the proposed treatment system additions or upgrades, EPA estimated a cost for residual
disposal. The Agency used two approaches: the first addressed facilities with current sludge-handling
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capabilities, while the second addressed facilities without current sludge handling capabilities. EPA
prepared residual disposal costs on an annualized basis and added to the total O&M costs.
For facilities with sludge-handling capabilities, EPA evaluated the present solids treatment/dewatering
system to determine if it was capable of handling the additional sludge expected to be produced under a
particular regulatory option. For facilities with insufficient capacity to handle the additional solids loadings,
EPA developed upgrade costs for sludge conditioning and dewatering to account for the additional solids.
For facilities with sufficient solids treatment capability, the Agency did not provide additional sludge-
treatment costs. For facilities without installed sludge conditioning and dewatering facilities, EPA developed
cost estimates for a sludge conditioning and dewatering systems.
Dewatered sludge is assumed to be disposed of on-site in the landfill. EPA's cost estimate also includes
the costs associated with the handling and transportation of the sludge to the on-site landfill.
9.2.4 Monitoring Costs
EPA developed costs for the monitoring of treatment system effluent for direct dischargers. The Agency
based the costs upon the following assumptions:
Monitoring costs are based on the number of outfalls through which leachate/ground water
is discharged. The costs associated with a single outfall is multiplied by the total number
of outfalls to arrive at the total cost for a facility. Monitoring costs estimated by EPA are
incremental to the costs already incurred by the facility.
The capital costs for flow-monitoring equipment are included in EPA's estimates.
Sample-collection costs (equipment and labor) and sample shipment costs are not included
in EPA's estimates because EPA assumes that the facility is already conducting these
activities as part of its current permit requirements.
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Based upon a review of current monitoring practices at landfills, many conventional and nonconventional
parameters, as well as several metals, are already being monitored on a routine basis. EPA developed
monitoring costs based upon BOD5 and TSS monitoring 20 times per month and weekly monitoring of
ammonia and other toxic and nonconventional pollutants. In general, these frequencies are higher than
currently required. Table 9-5 presents the monitoring cost per sample for the landfill facilities.
9.2.5 Off-Site Disposal Costs
EPA evaluated whether it would be more cost effective for small-flow facilities to have their landfill
wastewater hauled off site and treated at a centralized waste treatment facility, as opposed to on-site
treatment. EPA compared total annual costs for new or upgraded wastewater treatment facilities to the
costs for off-site treatment at a centralized waste treatment facility. Off-site disposal costs were estimated
at $0.25 per gallon of wastewater treated. EPA added transportation costs to the off-site treatment costs
at a rate of $3.00 per loaded mile using an average distance of 250 miles to the treatment facility. The
Agency based transportation costs upon the use of a 5,000-gallon tanker truck load. Facilities that treat
their wastewater off site are considered zero or alternative dischargers and, hence, do not incur ancillary
costs such as residual disposal, monitoring and permit modifications. EPA then used the lower of the two
costs for either on-site or off-site treatment. Table 9-6 presents the facilities that EPA costed using off-site
treatment.
9.3 Development of Cost Estimates for Individual Treatment Technologies
In Chapter 8, EPA identified and described the wastewater control and treatment technologies used in the
Landfills industry. The following sections describe how EPA developed cost estimates for each of the
treatment technologies used in the regulatory options. Specific assumptions regarding the equipment used,
flow ranges, input and design parameters, design, and cost calculations are discussed for each treatment
technology. Table 9-3, previously referenced, presented the method used to estimate costs for each of
treatment technologies used in the BPT, BCT, and BAT options. Table 9-7 presents a summary of the
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cost-estimation techniques for each treatment technology for the BPT, BCT, and BAT regulatory options,
including the WWC treatment module numbers.
To facilitate the costing of many facilities, EPA developed capital and O&M cost curves for specific
technologies and system components. The Agency developed these curves, which represent cost as a
function of flow rate or other system design parameters, using a commercial statistical software package
(Slidewrite Plus Version 2.1). First, EPA developed costs using the WWC model for each technology or
component using, as a design basis, five different flow rates or other system design parameters (depending
upon the governing design-parameter). For instance, a technology costed on the basis of flow would have
costs estimated using the WWC model at 0.01 million gallons per day (MOD), 0.05 MOD, 0.1 MOD, 0.5
MGD, and 1.0 MGD. EPA based the ranges for the five selected points upon a review of the flow- or
technology-design parameters for landfill facilities and selected them to represent the range from low to
high. Next, EPA entered these five data points (flow/design parameter and associated cost) into a
commercial statistical software program. EPA developed cost curves to model the total capital and O&M
costs by the program using curve fitting routines. EPA used a second-order natural-log equation format
to develop all curves. All cost curves yielded total capital and O&M costs, unless otherwise noted.
9.3.1 Equalization
EPA conducted a review of questionnaire responses to determine the typical hydraulic detention time for
equalization. Based upon of review of industry-furnished data, EPA selected a detention time of 48 hours.
EPA based equalization costs developed for each regulatory option on published price quotes for storage
tanks. These costs were taken from the 1996 Environmental Restoration Unit Cost Book published by
R. S. Means, Inc. EPA developed a cost curve as a function of flow from these tank quotes. The Agency
based construction costs upon published data for an above-ground circular steel tank. EPA also included
additional costs associated with a wastewater pumping system and diffused aeration to provide sufficient
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mixing of tank contents to prohibit settling. The capital cost curve developed for equalization is presented
as Equation 9-1 and is graphically presented in Figure 9-2.
Capital Costs
ln(Y) = 15.177382 + 1.9815471n(X) + 0.157681n(X)2 (9-1)
where:
X = Flow Rate (MOD), and
Y = Capital Cost (1992$)
The O&M cost for the equation was taken as a function of the capital cost and is based upon 10 percent
of the total capital cost per year.
9.3.2 Flocculation
EPA developed a cost curve for flocculation using WWC unit process 72. Costs for flocculation were
a function of flow at a hydraulic detention time of 20 minutes. The capital and O&M cost curves developed
for flocculation are presented below as Equations 9-2 and 9-3:
Capital Costs
ln(Y) = 11.744579 + 0.6331781n(X) - 0.0155851n(X)2 (9-2)
O&M Costs
ln(Y) = 8.817304 + 0.5333821n(X) + 0.0024271n(X)2 (9-3)
where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
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Figures 9-3 and 9-4 graphically present the flocculation capital and O&M cost curves, respectively.
EPA based cost estimates for flocculation basins on rectangular-shaped, reinforced concrete structures with
a depth of 12 feet and length-to-width ratio of 4:1. The Agency used common wall construction where the
total basin volume exceeded 12,500 cubic feet. Vertical-turbine flocculators have higher structural costs
than horizontal paddle flocculators because they require structural support above the basin. Horizontal
paddles are less expensive and more efficient for use in larger basins, particularly when tapered flocculation
is practiced. EPA based manufactured equipment costs on a G value 80 (G is the mean temporal velocity
gradient that describes the degree of mixing; i. e., the greater the value of G the greater the degree of
mixing). EPA based cost estimates for drive units on variable speed drives for maximum flexibility and,
although common drives for two or more parallel basins are often utilized, EPA based the costs on
individual drives for each basin.
Energy requirements are based on a G value 80 and an overall motor/mechanism efficiency of 60 percent.
The Agency based labor requirements on routine operation and maintenance of 15 minutes/day/basin
(maximum basin volume 12,500 cubic ft.) and a 4-hour oil change every 6 months.
9.3.3 Chemical Feed Systems
The following section presents the methodology used to calculate the chemical-addition feed rates used with
each applicable regulatory option. Table 9-8 is a breakdown of the design process used for each type of
chemical feed. Chemical costs were taken from the September 1992 Chemical Marketing Reporter and
are presented in Table 9-9.
For facilities with existing chemical precipitation systems, EPA evaluated the system to determine if it was
achieving the regulatory option long-term averages. If the existing system was achieving long-term
averages, no additional chemical costs were necessary. However, if the facility was not achieving the long-
term averages for an option, EPA estimated costs for an upgrade to the chemical precipitation system.
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First, EPA determined the stoichiometric requirements to remove each metal pollutant of interest to the
long-term average level. If the current feed rates were within the calculated feed rates, no additional costs
were calculated. For facilities currently feeding less than the calculated amounts, EPA estimated costs for
an upgrade to add additional precipitation chemicals, such as a coagulant, or expand their existing chemical
feed system to accommodate larger dosage rates.
EPA costed facilities without an installed chemical precipitation system for an entire metals precipitation
system. The Agency based the chemical feed rates used at a particular facility for either an upgrade or a
new system upon stoichiometric requirements, pH adjustments, and the buffering ability of the raw influent.
In the CWT industry guideline, EPA determined that the stoichiometric requirements for chemical addition
far outweighed the pH and buffer requirements. EPA determined that 150 percent of the stoichiometric
requirement would sufficiently account for pH adjustment and buffering of the solution. The Agency
included an additional 50 percent of the stoichiometric requirement to react with metals not on the pollutant
of interest list. Finally, EPA added an additional 10 percent increase from the stoichiometric amount as
excess. Atotal of 210 percent of the stoichiometric requirement was estimated when calculating costs for
chemical addition systems.
Sodium Hydroxide Feed Systems
The stoichiometric requirement for either lime or hydroxide to remove a particular metal is based upon the
following generic equation:
Bib i, ,\( valence..\l MW
M removed JP M OD treatment chemical
treatment chemical
year )[ MWM ]\ valenceN,
where, M is the target metal and MW is the molecular weight.
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The calculated amounts of sodium hydroxide to remove a pound of each of the selected metal pollutants
of concern are presented in Table 9-10.
EPA developed sodium hydroxide chemical feed system costs for many facilities using the WWC model.
The Agency used reported facility loadings to establish the sodium hydroxide dosage requirement. WWC
unit process 45 was used to develop capital and O&M costs for sodium hydroxide feed systems. The
capital and O&M cost curves developed for sodium hydroxide feed systems based upon the calculated
dosage are presented as Equations 9-4 and 9-5, respectively.
Capital Costs
ln(Y) = 10.653 - 0.1841n(X) + 0.0401n(X)2 (9-4)
O&M Costs
ln(Y) = 8.508 - 0.04641n(X) + 0.0141n(X)2 (9-5)
where:
X = Dosage Rate (Ib/day), and
Y = Cost (1992$)
Figures 9-5 and 9-6 graphically present the sodium hydroxide feed system capital and O&M cost curves,
respectively.
EPA based cost estimates for a sodium hydroxide feed system on WWC unit process 45 for a sodium
hydroxide feed rate of between 10 to 10,000 Ib/day. EPA based costs on dry sodium hydroxide addition
when rates were less than 200 Ib/day and on liquid sodium hydroxide when feed rates were higher.
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The WWC model assumes that dry sodium hydroxide (98.9 percent pure) is delivered in drums and mixed
to a 10 percent solution on site. A volumetric feeder is used to feed sodium hydroxide to one of two tanks:
one for mixing the 10 percent solution and one for feeding. Two tanks are necessary for this process
because of the slow rate of sodium hydroxide addition due to the high heat of solution. Each tank is
equipped with a mixer and a dual-head metering pump, used to convey the 10 percent solution to the point
of application. Pipe and valving is required to convey water to the dry sodium hydroxide solution mixing
tanks and between the metering pumps and the point of application.
A 50 percent sodium hydroxide solution is purchased premixed and delivered by bulk transport for feed
rates greater than 200 Ib/day. The 50 percent solution contains 6.38 pounds of sodium hydroxide per
gallon and is stored for 15 days in fiberglass reinforced polyester (FRP) tanks. Dual-head metering pumps
are used to convey the liquid solution to the point of application, and a standby metering pump is provided
in all systems. The storage tanks are located indoors, since 50 percent sodium hydroxide begins to
crystallize at temperatures below 54°F.
Phosphoric Acid Feed Systems
In the Subtitle C Hazardous subcategory, phosphoric acid is necessary to neutralize the waste stream and
to provide phosphorus to biological treatment systems.
EPA costed the phosphoric acid feed system using the WWC unit process 46. EPA determined that the
amount of phosphoric acid necessary to provide nutrient phosphorus was the controlling factor over the
amount required for pH adjustment. EPA used a ratio of BOD5 removed to the amount of phosphorus
present in the influent waste stream (100 pounds BOD5 removed to one pound phosphorus) to determine
the amount of phosphoric acid to be added as a nutrient feed to a biological treatment system. To allow
for solution buffering, 10 percent excess phosphoric acid was added. The capital and O&M cost curves
developed for phosphoric acid feed systems based upon the calculated dosage are presented as Equations
9-6 and 9-7, respectively.
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Capital Costs
ln(Y) = 10.042 - 0.1551n(X) + 0.0491n(X)2 (9-6)
O&M Costs
ln(Y) = 7.772 - 0.0861n(X) + 0.0411n(X)2 (9-7)
where:
X = Dosage Rate (gpd), and
Y = Cost (1992$)
Figures 9-7 and 9-8 graphically present the phosphoric acid feed system capital and O&M cost curves,
respectively.
EPA based costs on systems capable of metering 93 percent concentrated acid from a storage tank directly
to the point of application. For feed rates up to 200 gpd, the concentrated acid is delivered in drums and
stored indoors. At higher flow rates, the acid is delivered in bulk and stored outdoors in FRP tanks.
Phosphoric acid is stored for 15 days and a standby metering pump is included for all installations.
Polymer Feed Systems
EPA used WWC unit process 34 to cost for polymer feed systems based upon a dosage rate of 2 mg/L.
Although this module estimates costs for a liquid alum feed system, EPA determined that the costs
generated by this module were more reasonable and accurate in developing polymer system costs than the
WWC unit process 43 for polymer feed systems. The capital and O&M unloaded cost curves developed
for polymer feed systems are presented as Equations 9-8 and 9-9, respectively.
Capital Costs
ln(Y) = 10.539595 - 0.137711n(X) + 0.0524031n(X)2 (9-8)
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O&M Costs
ln(Y) = 9.900596 + 0.997031n(X) + 0.000191n(X)2 (9-9)
where:
X = Dosage Rate (Ib/hr), and
Y = Cost (1992$)
Figures 9-9 and 9-10 graphically present the polymer feed system capital and O&M cost curves,
respectively.
Polymer is stored for 15 days in fiberglass-reinforced polyester tanks. For smaller installations, the tanks
are located indoors and left uncovered and, for larger installations, the tanks are covered and vented, with
insulation and heating provided. Dual-head metering pumps deliver the polymer from the storage tank and
meters the flow to the point of application. Feed costs include 150 feet of 316 stainless steel pipe, along
with fittings and valves for each metering pump. A standby metering pump is included for each installation.
9.3.4 Primary Clarification
EPA developed cost curves for primary clarification using WWC unit process 118 for a rectangular basin
with a 12 foot side wall depth. EPA based costs for primary clarification upon a function of flow at an
overflow rate of 900 gallons per day per square feet tank size. The capital and O&M cost curves
developed for primary clarification are presented as Equations 9-10 and 9-11, respectively.
Capital Costs
ln(Y) = 12.517967 + 0.5756521n(X) + 0.0093961n(X)2 (9-10)
O&M Costs
ln(Y) = 10.011664 + 0.2682721n(X) + 0.002411n(X)2 (9-11)
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where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 9-11 and 9-12 graphically present the primary clarification capital and O&M cost curves,
respectively.
EPA based estimated costs on rectangular basins with a 12 feet side water depth (SWD) and chain-and-
flight sludge collectors. Costs for the structure assumed multiple units with common wall construction and
include the chain-and-flight collector, collector drive mechanism, weirs, the reinforced concrete structure
complete with inlet and outlet troughs, a sludge sump, and sludge-withdrawal piping. Yard piping to and
from the clarifier is not included in the cost estimates.
9.3.5 Activated Sludge Biological Treatment
EPA based costs for biological treatment systems using the activated sludge process using the WWC unit
process 18 for a rectangular aeration basin with an 10 foot SWD. EPA determined basin size using a 24
hour hydraulic detention time using Equation 9-12.
X = ((24 Hours x 3600) x (Z))/l,000 (9-12)
where:
X = Basin Volume (1,000 cu ft)
Z = Flow Rate (cfs)
The WWC model assumes zero O&M costs for the aeration basins only. The unloaded (without
engineering cost factors applied) capital cost curve developed for aeration basins with an 10 foot SWD
is presented as Equation 9-13.
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ln(Y) = -1.033901 + 3.7226931n(X) - 0.1970161n(X)2 (9-13)
where:
X = Basin Volume (in thousands of cubic feet), and
Y = Capital Cost (1992$)
Figure 9-13 graphically presents the aeration basin capital cost curve.
Aeration using diffused air was costed for the basin using WWC unit process 26 and reported facility
loading conditions. EPA calculated aeration requirements using the facility BOD5 and ammonia loadings
using Equation 9-14.
X = ((A + B)/0.075 x C x 0.232 x 1440)71,000 (9-14)
where:
X = Air Requirement (1,000 standard cubic feet per minute [scfm])
A = BOD5 to Aeration Basin (Ib/day) based on 1.8 Ib O2/lb BOD5 influent
B = Ammonia to Aeration Basin (Ib/day) based on 4.6 Ib O2/lb ammonia influent
C = Transfer Efficiency at 9 percent
The unloaded capital and O&M cost curves developed for air diffusion systems are presented as Equations
9-15 and 9-16, respectively.
Capital Costs
ln(Y) = 11.034417 + 0.9929851n(X) - 0.0025211n(X)2 (9-15)
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O&M Costs
ln(Y) = 9.497546 + 0.5497151n(X) - 0.0042161n(X)2 (9-16)
where:
X = Air Requirement (1,000 scfm), and
Y = Cost (1992$)
Figures 9-14 and 9-15 graphically present the air diffusion system capital and O&M cost curves,
respectively.
The costs for aeration basins include all equipment, piping, electrical, and labor for installation. The air-
supply system costs include piping from air source to aeration basin, blowers, controls, and housing.
Aeration-basin cost estimates include excavation, concrete walkways, in-basin process piping, and
handrails and attendant costs, but excludes the cost of aeration equipment, electrical and instrumentation
work. EPA considered providing for heated aeration basins for facilities located in cold-weather climates.
Based upon data collected by EPA, biological treatment of landfill generated wastewater was not adversely
affected by climate conditions.
9.3.6 Secondary Clarification
EPA developed cost curves for secondary clarification using WWC unit process 118 for a rectangular
basin with a 12 foot side wall depth with chain-and-flight collectors. EPA based costs for secondary
clarification upon a function of flow, at an overflow rate of 900 gallons per day per square feet tank size.
The capital and O&M cost curves developed for secondary clarification are presented as Equations 9-17
and 9-18, respectively.
Capital Costs
ln(Y) = 12.834601 + 0.6886751n(X) + 0.0354321n(X)2 (9-17)
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O&M Costs
ln(Y) = 10.197762 + 0.3399521n(X) + 0.0158221n(X)2 (9-18)
where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 9-16 and 9-17 graphically present the secondary clarification capital and O&M cost curves,
respectively.
Costs for the structure assumed multiple units with common wall construction, and include the chain-and-
flight collector, collector drive mechanism, weirs, the reinforced concrete structure, complete with inlet and
outlet troughs, a sludge sump, and sludge-withdrawal piping. Yard piping to and from the clarifier is not
included in the cost estimates.
9.3.7 Multimedia Filtration
EPA developed cost curves as a function of flow rate for a multimedia filtration system using vendor-
supplied quotes. The Agency developed cost curves as part of the CWT effluent guidelines effort. The
capital and O&M cost curves developed for multimedia filtration are presented as Equations 9-19 and 9-
20, respectively.
Capital Costs
ln(Y) = 12.265 + 0.6581n(X) + 0.0361n(X)2 (9-19)
O&M Costs
ln(Y) = 10.851 + 0.1681n(X) + 0.0181n(X)2 (9-20)
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where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 9-18 and 9-19 graphically present the multimedia filtration capital and O&M cost curves,
respectively.
The total capital costs for the multimedia filtration systems represent equipment and installation costs. The
total construction cost includes the costs of the filter, instrumentation and controls, pumps, piping, and
installation. The operation and maintenance costs include energy usage, maintenance, labor, and taxes and
insurance. Energy costs include electricity to run the pumps, lighting, and instrumentation and controls. The
labor requirement for the multimedia filtration system was four hours per day.
9.3.8 Reverse Osmosis
EPA developed capital and O&M cost curves as a function of flow rate for reverse osmosis treatment using
vendor supplied quotes. EPA based costs on one single-pass system using disk tube module technology.
The capital cost curve developed for reverse osmosis is presented as Equation 9-21.
ln(Y) = 14.904 - 0.01421n(X) - 0.06871n(X)2 (9-21)
where:
X = Flow Rate (MOD), and
Y = Capital Cost (1992$)
Figure 9-20 graphically presents the reverse osmosis capital-cost curves. Based upon vendor supplied
costs, O&M costs were taken at $0.02/gallon.
9-24
-------
Costs for a standard reverse osmosis system generally include the following components: filter booster
pump, sand or carbon filter, cartridge filter, high-pressure pump and control system, reverse osmosis
module permeators, pure water deacidification filter, in-built closed circuit cleaning system, automatic pure
water membrane flushing system, power and control system with microprocessor, full instrumentation and
measurement equipment, comprehensive fail-safe system, fault indication, and modular skid frame
construction. The costs did not take into account the following optional equipment: main raw-water supply
pump, pure water tank and distribution pump, chlorine dosing system, ultra-violet disinfection system,
containerized/mobile systems, self-contained power supply, and anti-magnetic systems.
9.3.9 Sludge Dewatering
EPA based costs estimated for sludge dewatering upon sludge-drying beds. EPA costed each facility
separately using the WWC unit process 128. EPA based the required bed area upon influent
characteristics at a loading of 15 gallons per day of sludge per square foot bed area. EPA calculated
drying bed area using Equation 9-22.
X = (Ax365)/B (9-22)
where:
X = Area (sq ft)
A = Total Dry Solids (Ib/day) based on 0.8 Ib solids/lb BOD5 influent
B = 15 Ib per year sludge/sq ft
The unloaded capital and O&M cost curves developed for sludge-drying beds are presented as Equations
9-23 and 9-24, respectively.
Capital Costs
ln(Y) = 4.488639 + 0.7164711n(X) + 0.00000531 lln(X)2 (9-23)
9-25
-------
O&M Costs
ln(Y) = 6.95049 + 0.331551n(X) + 0.0028821n(X)2 (9-24)
where:
X = Area (sq ft), and
Y = Cost (1992$)
Figures 9-21 and 9-22 graphically present the sludge-drying bed capital and O&M cost curves,
respectively.
Included in the costs are sludge-distribution piping, nine inches of sand media overlying nine inches of gravel
media, two foot concrete dividers between beds, and an underdrain system to remove percolating water.
EPA excluded land costs from the cost estimates.
Energy requirements are based on the following: a front-end loader to remove dried sludge from the beds
and prepare the bed for the next sludge application, cleaning and preparation time of 3 hours for a 4,000
square foot bed, diesel fuel consumption of 4 gallons per hour, and 20 cleanings^ed/year.
9.3.10 Granular Activated Carbon
EPA developed cost curves as a function of flow rate for a granular activated carbon (GAC) system using
vendor-supplied quotes. EPA estimated the capital and O&M costs for GAC using the "Power Plant
Wastewater Treatment Technology Review Report", Electric Power Research Institute (EPRI), November
1996, Exhibits A3-1 and D3-1, respectively, and supplemented using "Technologies and Costs for
Removal of Arsenic from Drinking Water", Office of Ground Water and Drinking Water, EPA, Draft July
1998. The capital and O&M cost curves developed for GAC adsorption are presented as Equations 9-25
and 9-26, respectively.
9-26
-------
Capital Costs
ln(Y) = 12.772 + 0.4571n(X) - 0.0251n(X)2 (9-25)
O&M Costs
ln(Y) = 9.691 - 0.2241n(X) - 0.0411n(X)2 (9-26)
where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 9-23 and 9-24 graphically present the GAC adsorption capital and O&M cost curves,
respectively.
The total capital costs for the GAC systems represent equipment and installation costs. The total
construction cost includes the costs of the GAC, instrumentation and controls, pumps, piping, and
installation. The operation and maintenance costs include carbon replacement/disposal, energy usage,
maintenance, labor, and taxes and insurance. Energy costs include electricity to run the pumps, lighting,
and instrumentation and controls. The labor requirement for the GAC system was four hours per day.
9.3.11 Breakpoint Chlorination
EPA developed cost curves as a function of flow rate for a breakpoint chlorination system using vendor-
supplied quotes. EPA extrapolated cost estimates for breakpoint chlorination from data supplied by the
EPA Office of Ground Water and Drinking Water report. The capital and O&M cost curves developed
for a breakpoint chlorination system are presented as Equations 9-27 and 9-28, respectively.
Capital Costs
ln(Y) = 12.219 + 0.0511n(X) - 0.0451n(X)2 (9-27)
9-27
-------
O&M Costs
ln(Y) = 12.881 + 0.9231n(X) + 0.0531n(X)2 (9-28)
where:
X = Flow Rate (MOD), and
Y = Cost (1992$)
Figures 9-25 and 9-26 graphically present the breakpoint chlorination capital and O&M cost curves,
respectively.
The total capital costs for the breakpoint chlorination systems represent equipment and installation costs.
The total construction cost includes the costs of the chlorine addition unit, instrumentation and controls,
pumps, piping, and installation. The operation and maintenance costs include chemical usage, energy usage,
maintenance, labor, and taxes and insurance. Energy costs include electricity to run the pumps, lighting,
and instrumentation and controls. The labor requirement for the breakpoint chlorination system was four
hours per day.
9.4 Costs for Regulatory Options
The following sections present the costs estimated for compliance with the BPT/ BCT/B AT and NSPS
effluent limitations guidelines and standards for the Subtitle D Non-Hazardous and Subtitle C Hazardous
subcategories. Costs for each of the regulatory options are presented below for only the facilities in the
308 Questionnaire database, as well as for all of the facilities in the Landfills industry based on national
estimates (see Chapter 3, Section 3.2.1 for an explanation of national estimates). All costs estimates in this
section are expressed in terms of 1992 dollars, unless otherwise noted.
9.4.1 Facility Selection
EPA evaluated each of the 220 Detailed Questionnaires that were returned with sufficient technical and
9-28
-------
economic data to determine if the facility would be subj ect to the final limitations and standards and would,
therefore, incur costs as a result of the regulation. EPA determined that 94 of the 220 facilities would not
incur costs because of the following reasons:
• 49 facilities indicated that they were zero or alternative discharge
• 40 facilities were operated in conjunction with other industrial or commercial operations
and EPA determined that the rule was not applicable to these facilities
5 respondents did not generate in-scope wastewater.
EPA calculated costs for each of the remaining 126 facilities and then modeled the national population by
using statistically-calculated survey weights. EPA proj ected the landfill industry costs (presented below)
for several technology options based on costs developed for 123 Subtitle D and 3 Subtitle C facilities.
9.4.2 BPT Regulatory Costs
EPA developed preliminary cost-effectiveness analyses using interim costing-rounds to select BPT
regulatory options. The BPT costs for each subcategory are presented below.
9.4.2.1 Subtitle D Non-Hazardous Subcategory BPT Costs
Once EPA developed current discharge and untreated landfill wastewater pollutant concentrations for
facilities in the Subtitle D Non-Hazardous subcategory, EPA evaluated two options,BPT Options I and n.
BPT Option I: Equalization and activated sludge biological treatment with secondary clarification, and
sludge-dewatering. For the facilities in the 308 Questionnaire database, Table 9-11 presents the total
capital ($2,737,104) and annual O&M costs ($838,579) for this option, as well as the total amortized
annual cost for each facility. Based on national estimates, BPT Option I for the Subtitle D Non-Hazardous
subcategory is estimated to have total annualized pre-tax costs of $7.30 million (based on 1998 dollars).
9-29
-------
BPT Option II: Equalization, activated sludge biological treatment with secondary clarification, multimedia
filtration, and sludge-dewatering. For the facilities in the 308 Questionnaire database, Table 9-12 presents
the total capital ($3,252,453) and annual O&M ($1,027,788) costs for this option, as well as the total
amortized annual cost for each facility. Based on national estimates, BPT Option II for the Subtitle D
Non-Hazardous subcategory is estimated to have total annualized pre-tax and post-tax costs of $8.57 and
$7.64 million (based on 1998 dollars), respectively.
9.4.2.2 Subtitle C Hazardous Subcategory BPT Costs
Once EPA developed current discharge and untreated landfill wastewater pollutant concentrations for
facilities in the Subtitle C Hazardous subcategory, EPA evaluated one BPT option, BPT Option I.
BPT Option I: Equalization, chemical precipitation, activated sludge biological treatment with secondary
clarification, multimedia filtration, and sludge-dewatering. Since EPA did not identify any direct discharge
facilities in the Subtitle C Hazardous subcategory database, there are no costs associated with this option.
9.4.3 BCT Regulatory Costs
EPA developed preliminary cost-effectiveness analyses using interim costing-rounds to select BCT
regulatory options. The BCT costs for each subcategory are presented below.
9.4.3.1 Subtitle D Non-Hazardous Subcategory BCT Costs
Once EPA developed current discharge and untreated landfill wastewater pollutant concentrations for
facilities in the Subtitle D Non-Hazardous subcategory, EPA evaluated two options, BCT Option I and n.
BCT Option I: Equalization and activated sludge biological treatment with secondary clarification, and
sludge-dewatering. This option is equivalent to BPT Option I for the Non-Hazardous subcategory with
costs previously provided in Section 9.4.2.1 above.
9-30
-------
BCT Option II: Equalization, activated sludge biological treatment with secondary clarification, multimedia
filtration, and sludge-dewatering. This option is equivalent to BPT Option II for the Non-Hazardous
subcategory with costs previously provided in Section 9.4.2.1 above.
9.4.3.2 Subtitle C Hazardous Subcategory BCT Costs
Once EPA developed current discharge and untreated landfill wastewater pollutant concentrations for
facilities in the Subtitle C Hazardous subcategory, EPA evaluated one option, BCT Option I.
BCT Option I: Equalization, chemical precipitation, activated sludge biological treatment with secondary
clarification, multimedia filtration, and sludge-dewatering. This option is equivalent to BPT Option I for the
Subtitle C Hazardous subcategory and, therefore, has no associated costs.
9.4.4 BAT Regulatory Costs
EPA developed preliminary cost-effectiveness analyses using interim costing-rounds to select BAT
regulatory options. The BAT costs for each subcategory are presented below.
9.4.4.1 Subtitle D Non-Hazardous Subcategory BAT Costs
EPA costed three BAT options for the Subtitle D Non-Hazardous subcategory: BAT Options I, n and m.
BAT Option I: Equalization and activated sludge biological treatment with secondary clarification, and
sludge-dewatering. This option is equivalent to BPT Option I for the Non-Hazardous subcategory with
costs previously provided in Section 9.4.2.1 above.
BAT Option II: Equalization, activated sludge biological treatment with secondary clarification, multimedia
filtration, and sludge-dewatering. This option is equivalent to BPT Option II for the Non-Hazardous
subcategory with costs previously provided in Section 9.4.2.1 above.
9-31
-------
BAT Option HI: Equalization, activated sludge biological treatment, multimedia filtration, and reverse
osmosis with sludge-dewatering. For facilities in the 308 Questionnaire database, Table 9-13 presents the
total capital ($34,518,089) and annual O&M ($5,896,531) costs for this option as well as the total
amortized annual cost for each facility. Based on national estimates, BAT Option HI for the Subtitle D
Non-Hazardous subcategory is estimated to have a total annualized pre-tax cost of $45.95 million (based
on 1998 dollars).
9.4.4.2 Subtitle C Hazardous Subcategory BAT Costs
Once EPA developed current discharge and untreated landfill wastewater pollutant concentrations for
facilities in the Subtitle C Hazardous subcategory, EPA evaluated one BAT option, BPT Option I.
BAT Option I: Equalization, chemical precipitation, activated sludge biological treatment with secondary
clarification, multimedia filtration, and sludge-dewatering. This option is equivalent to BPT Option I for the
Hazardous subcategory and, therefore, has no associated costs.
9.4.5 NSPS Regulatory Costs
EPA developed preliminary cost-effectiveness analyses using interim costing-rounds to select NSPS
regulatory options. The NSPS costs for each subcategory are presented below.
9.4.5.1 Subtitle D Non-Hazardous Subcategory NSPS Costs
EPA is establishing NSPS for the Subtitle D Non-Hazardous subcategory to be equivalent to the limitations
established for BPT Option II for this subcategory, which also is the basis for BCT and BAT.
NSPS: Equalization, activated sludge biological treatment with secondary clarification, multimedia filtration,
and sludge-dewatering. The total NSPS annual cost for the Non-Hazardous subcategory is $52,755
assuming an average facility flow of 10,000 gpd.
9-32
-------
9.4.5.2 Subtitle C Hazardous Subcategory NSPS Costs
EPA is establishing NSPS for the Subtitle C Hazardous subcategory to be equivalent to the limitations
established for BPT Option I for this subcategory, which also is the basis for BCT and BAT.
NSPS: Equalization, chemical precipitation, activated sludge biological treatment with secondary
clarification, multimedia filtration, and sludge-dewatering. The total NSPS annual cost for the Hazardous
subcategory is $132,031 assuming an average facility flow of 10,000 gpd.
9-33
-------
Table 9-1: Cost Comparison
Facility
QID
16122
16125
16087
16041
Treatment Train
Chemical Precipitation
Above+Anaerobic&Aerobic Bio
Above+2nd Chemical Precipitation
Above+Equalization+Multimedia Filter
Equalization
Entire Treatment Train
Equalization+Air Stripping
Chemical Precipitation+SBR
Above+Carbon+Multimedia Filter
Entire Treatment Train
SBR+Sludge Equipment
CAPDET Computer Run
Capital Cost
1992
$232,366
$1,217,370
$1,449,732
$1,517,811
$58,478
$1,576,289
$57,717
$282,073
$478,266
NA
$159,908
O&M
Costs
$178,773
$353,181
$587,637
$715,088
$69,475
$784,563
$61,556
$255,294
$460,622
NA
$115,066
WWC Engineering
Software
Capital Cost
1992
$190,308
$836,433
$908,201
$1,573,621
$692,252
$2,782,188
$394,570
$1,928,245
$2,492,431
$2,519,307
$2,378,898
O&M
Costs
$41,883
$79,898
$91,295
$91,295
$1,997
$317,747
$20,718
$103,100
$145,949
$816,351
$436,879
Vendor Quotes
Capital Cost
1992
$177,504
$794,343
$971,847
$1,553,010
$526,532
$2,154,117
$243,800
(a)
(b)
(c)
NA
O&M
Costs
$163,397
$305,669
$469,066
$543,840
$36,442
$586,240
$54,147
(a)
(b)
(c)
NA
Questionnaire Responses
Capital Cost
1992
NA
NA
NA
NA
NA
$4,113,628
$588,714
$2,067,188
$2,534,242
$2,423,057
$6,293,919
O&M
Costs
$22,858
$133,314
$133,872
$133,872
$3,388
$311,400
$8,247
$31,534
$34,883
$992,578
$460,050
co
i
CO
NA: Not Available
(a): Capital O&M costs without the SBR are $82,675 and $56,972, respectively
(b): Capital O&M costs without the SBR are $140,078 and $106,642, respectively
(c): Capital O&M costs without the activated sludge system and chlorine addition are $189,120 and $100,849, respectively
-------
Table 9-2: Costing Source Comparison
- =
1 I
& 2
O
Capital Costs
1992 Dollars
I Questionnaire
IWWC
ICAPDET
1 Vendor Quotes
Questionnaire
wwc
CAPDET
Vendor Quotes
Chem Precip
2,206,980
3,543,264
4,948,779
399,878
Chem Precip and Filtration
2,751,204
2,950,035
1,475,480
3,314,930
Chem Precip
1,214,563
2,144,446
942,216
319,206
2-stage Chem Precip
2,265,009
1,476,821
3,072,253
670,158
o
O
08
O
1000 -
500 -
O&M Costs
1992 Dollars
d Questionnaire
(•WWC
IB CAPDET
l Vendor Quotes
Questionnaire
WWC
CAPDET
Vendor Quotes
Chem Precip
910,000
1,355,505
585,855
860,867
Chem Precip and Filtration
315,000
231,728
99,036
222,135
Chem Precip
1,837,000
1,864,219
515,859
361,623
2-stage Chem Precip
363,000
686,360
466,848
151,889
9-35
-------
Table 9-3: Breakdown of Costing Method by Treatment Technology
Treatment Technology
Equalization
Flocculation
Chemical Feed System
Primary & Secondary
Clarification
Activated Sludge
Reverse Osmosis
Multimedia Filtration
Activated Carbon
Breakpoint Chlor.
Sludge-Drying Beds
Cost Using
WWC Program
X
X
X
X
X
Cost Using Vendor
Quotes
X(a)
X
X(b)
X(c)
X(d)
Key Design
Parameter(s)
Flow rate
Flow rate
Flow rate & Pollutant
of Interest Metals
Flow rate
Flow rate, BOD5, &
Ammonia
Flow rate
Flow rate
Flow rate
Flow rate
Flow rate, TSS &
BOD5
(a) Based upon costs provided in Environmental Restoration Unit Cost Book
(b) Cost curves developed using vendor quotes in the CWT guideline effort
(c) Based upon costs provided in "Power Plant Wastewater Treatment Technology Review Report",
Electric Power Research Institute (EPRI), November 1996, Exhibits A3-1 and D3-1, respectively,
and supplemented using "Technologies and Costs for Removal of Arsenic from Drinking Water",
Office of Ground Water and Drinking Water, EPA, Draft July 1998
(d) Costs were extrapolated from data supplied by the EPA Office of Ground Water and Drinking
Water report
9-36
-------
Table 9-4: Additional Cost Factors
Type
Capital
O&M
Factor
Site Work & Interface Piping
General Contractor Overhead
Engineering
Instrumentation & Controls
Buildings
Site Improvements
Legal, Fiscal, & Administrative
Interest During Construction
Contingency
Retrofit (if necessary)
Taxes & Insurance
Percent of Capital Cost
18
10
12
13
6
10
2
9
8
20
21
(1) 2 percent of total capital costs, which includes WWC costs and capital costs listed above.
9-37
-------
Table 9-5: Analytical Monitoring Costs
Pollutants
Cost/Sample (S)1
Subtitle D Non-Hazardous
Ammonia as N
BOD5
TSS
Metals & Organics
18.00
15.00
6.00
105.00
Subtitle C Hazardous
Ammonia as N
BOD5
TSS
Metals & Volatile/Semi-Volatile
Organics
18.00
15.00
6.00
1600.00
(1) Cost based on 1995 analytical laboratory costs adjusted to 1992 dollars.
9-38
-------
Table 9-6: Subtitle D Non-Hazardous Facilities Costed for Off-Site Disposal
Facility QID
16048
16055
16062
16139
16148
16160
16250
Flow (gpd)
5
8
50
50
77
137
200
Off- Site Disposal Cost
730
1168
7300
7300
11242
20002
29200
($/yr)
9-39
-------
Table 9-7: Unit Process Breakdown by Regulatory Option
Treatment Technology
Description
Equalization & activated sludge
Equalization, activated sludge
& multimedia filtration
Equalization, activated sludge,
multimedia filtration & single-stage
reverse osmosis
Equalization, chemical precipitation,
activated sludge & multimedia
filtration
Subcategory
Non-Hazardous
BPT/BCT/BAT
Option I
BPT/BCT/BAT
Option II
NSPS
BAT
Option III
Hazardous
BPT/BCT/BAT
Option I
NSPS
WWC Unit
Process #*
NA
18
26
118
128
NA
18
26
118
NA
128
NA
18
26
118
NA
NA
128
NA
72
45
34
118
46
18
26
118
NA
128
WWC Unit Process #
Description
equalization
aeration basin
aeration system
secondary clarification
sludge dewatering
equalization
aeration basin
aeration system
secondary clarification
multimedia filtration
sludge dewatering
equalization
aeration basin
aeration system
secondary clarification
multimedia filtration
single-stage reverse osmosis
sludge dewatering
equalization
flocculation tank
sodium hydroxide feed system
polymer feed system
primary clarification
phosphoric acid feed system
aeration basin
aeration system
secondary clarification
multimedia filtration
sludge dewatering
*NA=Not Applicable-Vendor Quotes Used
-------
Table 9-8: Chemical Addition Design Method
Chemical
Basis for Design
Stoichiometry
Reference1 (mg/L)
Sodium Hydroxide
Polymer
Phosphoric Acid
X
X
2.0
(1) From: Industrial Water Pollution Control, 2nd Edition.
9-41
-------
Table 9-9: Treatment Chemical Costs
Treatment Chemical
Sodium Hydroxide
Polymer
Phosphoric Acid
Cost
$350/ton
$2.25/lb
$300/ton
9-42
-------
Table 9-10: Sodium Hydroxide Requirements for Chemical Precipitation
Pollutant
Cadmium
Chromium, total
Iron
Nickel
Zinc
Phosphorus
Dosage Rate
Sodium Hydroxide
(Ib/lb metal removed)
0.71
2.31
2.15
2.04
1.22
6.46
9-43
-------
Table 9-11: BPT/BCT/BAT Option I Subtitle D Non-Hazardous Subcategory
ID#
16001
16003
16008
16009
16011
16012
16013
16014
16015
16016
16020
16023
16024
16025
16026
16027
16028
16029
16033
16035
16038
16039
16043
16044
16046
16047
16048
16049
16050
16052
16053
16054
16055
16056
16058
16059
16060
Flow
(MOD)
0.0793
0.00472
0
0.01613
0
0.00221
0.015
0
0.0005
0.0023
0.04581
0.05734
0.00592
0
0
0
0.01985
0.025
0.0091
0
0.00822
0.00178
0.00218
0
0
0.00115
5E-06
0.0017
0.01
0.0546
0.00124
0.00075
8E-06
0.00137
0.003
0.0011
0.0018
CAPITALCOSTS($)
Equipment
153,015
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
38,175
0
35,037
58,533
217,678
39,625
16,544
0
40,636
44,348
38,017
43,919
Sludge
Handling
2,004
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
2,004
2,004
5,563
2,004
2,004
0
2,004
2,004
2,004
2,004
Retrofit
31,004
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
7,408
0
44,648
0
3,710
0
0
9,270
0
0
Permit
Modification
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
Land
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
Total
Capital
186,023
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
40,179
0
44,449
60,537
267,889
41,629
22,258
0
42,640
55,622
40,021
45,923
AMORTIZED
TOTALCAPITAL(a)
($/YR)
20,424
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4,411
0
4,880
6,647
29,413
4,571
2,444
0
4,682
6,107
4,394
5,042
O &M COSTS($/YR)
Equipment
19,637
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8,760
0
8,302
11,672
17,799
9,002
5,276
0
8,921
8,936
8,730
9,178
Solids
Handling
4,078
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,917
0
2,208
1,917
6,897
1,917
1,917
0
1,917
1,917
1,917
2,208
Monitoring
11,540
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,540
0
11,540
11,540
11,072
11,540
11,357
0
11,540
0
11,540
11,540
Total
O &M
35,255
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
22,217
0
22,050
25,129
35,768
22,459
18,550
0
22,378
10,853
22,187
22,926
TOTAL
ANNUAL
COST($/YR)(b)
55,679
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
26,628
730
26,930
31,776
65,180
27,030
20,994
1,168
27,060
16,960
26,581
27,968
VO
-------
Table 9-11: BPT/BCT/BAT Option I Subtitle D Non-Hazardous Subcategory (continued)
ID#
16061
16062
16063
16064
16065
16068
16070
16071
16072
16073
16074
16075
16076
16077
16078
16079
16083
16084
16085
16088
16090
16091
16092
16093
16097
16098
16099
16102
16103
16107
16109
16111
16113
16114
16115
16116
16117
Flow
(MOD)
0
0.00005
0.0067
0.01197
0.008
0
0.00133
0.006
0
0.0182
0
0.01021
0
0.00816
0.00499
0.11247
0.001
0.00643
0.03
0.03621
0.00393
0.2321
0.00668
0.08158
0.019
0
0.01533
0.01394
0.03756
0.00129
0.05056
0.0072
0
0.00864
0.00407
0.0042
0.04
CAPITAL COSTS ($)
Equipment
0
0
75,309
62,083
71,448
0
0
0
0
0
0
0
0
0
0
344,770
29,000
0
0
0
0
0
0
222,598
0
0
0
110,824
0
0
0
0
0
0
0
0
0
Sludge
Handling
0
0
2,004
2,004
2,004
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Retrofit
0
0
0
0
14,690
0
0
0
0
0
0
0
0
0
0
68,954
6,201
0
0
0
0
0
0
44,520
0
0
0
22,165
0
0
0
0
0
0
0
0
0
Permit
Modification
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
Land
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
Total
Capital
0
0
77,313
64,087
88,143
0
0
0
0
0
0
0
0
0
0
413,724
37,205
0
0
0
0
0
0
267,118
0
0
0
132,989
0
0
0
0
0
0
0
0
0
AMORTIZED
TOTALCAPITAL(a)
($/YR)
0
0
8,489
7,036
9,678
0
0
0
0
0
0
0
0
0
0
45,425
4,085
0
0
0
0
0
0
29,328
0
0
0
14,602
0
0
0
0
0
0
0
0
0
O&M COSTS ($/YR)
Equipment
0
0
11,152
12,127
10,481
0
0
0
0
0
0
0
0
0
0
23,219
7,835
0
0
0
0
0
0
30,361
0
0
0
13,163
0
0
0
0
0
0
0
0
0
Solids
Handling
0
0
3,562
3,931
3,231
0
0
0
0
0
0
0
0
0
0
0
1,735
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Monitoring
0
0
11,540
11,540
11,090
0
0
0
0
0
0
0
0
0
0
11,180
11,540
0
0
0
0
0
0
11,180
10,520
0
0
11,540
0
0
0
0
0
0
0
0
9,908
Total
O&M
0
0
26,254
27,598
24,802
0
0
0
0
0
0
0
0
0
0
34,399
21,110
0
0
0
0
0
0
41,541
10,520
0
0
24,703
0
0
0
0
0
0
0
0
9,908
TOTAL
ANNUAL
COST($/YR)(b)
0
7,300
34,742
34,634
34,480
0
0
0
0
0
0
0
0
0
0
79,824
25,195
0
0
0
0
0
0
70,869
10,520
0
0
39,304
0
0
0
0
0
0
0
0
9,908
VO
-------
Table 9-11: BPT/BCT/BAT Option I Subtitle D Non-Hazardous Subcategory (continued)
ID#
16118
16119
16120
16121
16122
16123
16124
16125
16127
16128
16129
16130
16131
16132
16135
16137
16139
16140
16143
16144
16146
16148
16149
16150
16151
16152
16153
16154
16155
16156
16158
16159
16160
16161
16162
16163
16164
Flow
(MOD)
0.0288
0.00729
0.04278
0.08028
0.0255
0.04608
0.01666
0.01419
0.00363
0.00396
0.00469
0.0003
0.03
0.03
0.01149
0
0.00005
0
0
0
0
0.00008
0
0.04578
0.00205
0
0.008
0.01022
0.00831
0.173
0.01428
0.225
0.00014
0.053
0.0009
0
0.01
CAPITAL COSTS ($)
Equipment
0
13,151
0
0
0
206,903
0
0
48,545
0
0
4,400
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
Sludge
Handling
0
2,004
0
0
0
8,080
0
0
2,004
0
0
2,004
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
Retrofit
0
3,031
0
0
0
42,997
0
0
10,110
0
0
1,281
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
Permit
Modification
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
Land
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
Total
Capital
0
18,186
0
0
0
257,980
0
0
60,659
0
0
7,685
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
AMORTIZED
TOTALCAPITAL(a)
($/YR)
0
1,997
0
0
0
28,325
0
0
6,660
0
0
844
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
O&M COSTS ($/YR)
Equipment
0
2,577
0
0
0
19,430
0
0
9,190
0
0
10,400
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
Solids
Handling
0
1,948
0
0
0
8,365
0
0
2,756
0
0
4,078
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
Monitoring
0
11,117
9,200
0
9,948
11,540
0
10,712
11,540
0
11,540
11,540
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
Total
O&M
0
15,642
9,200
0
9,948
39,335
0
10,712
23,486
0
11,540
26,018
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
TOTAL
ANNUAL
COST($/YR)(b)
0
17,639
9,200
0
9,948
67,660
0
10,712
30,146
0
11,540
26,862
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
VO
-------
Table 9-11: BPT/BCT/BAT Option I Subtitle D Non-Hazardous Subcategory (continued)
ID#
16165
16166
16169
16170
16171
16173
16174
16175
16176
16177
16180
16184
16185
16186
16187
16189
16190
16191
16193
16196
16197
16199
16200
16201
16202
16203
16204
16204
16205
16206
16208
16211
16212
16215
16217
16219
16220
Flow
(MOD)
0.03022
0.00342
0
0.0048
0.024
0.025
0.0072
0
0.03727
0
0
0
0
0.00304
0.003
0
0
0
0.0023
0.01223
0
0.0008
0.01142
0.00188
0.01301
0.02
0
0
0
0.05739
0.00334
0.15
0.0007
0
0
0.02544
0.03041
CAPITAL COSTS ($)
Equipment
0
0
0
55,201
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
108,110
0
0
0
0
0
0
0
0
0
0
0
0
15,300
0
0
0
0
Sludge
Handling
0
0
0
2,004
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,645
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
0
Retrofit
0
0
0
11,441
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
Permit
Modification
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
Land
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
Total
Capital
0
0
0
68,647
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
119,755
0
0
0
0
0
0
0
0
0
0
0
0
17,304
0
0
0
0
AMORTIZED
TOTALCAPITAL(a)
($/YR)
0
0
0
7,537
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
13,148
0
0
0
0
0
0
0
0
0
0
0
0
1,900
0
0
0
0
O&M COSTS ($/YR)
Equipment
0
0
0
9,594
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
14,487
0
0
0
0
0
0
0
0
0
0
0
0
18,800
0
0
0
0
Solids
Handling
0
0
0
4,078
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10,115
0
0
0
0
0
0
0
0
0
0
0
0
1,516
0
0
0
0
Monitoring
0
0
0
11,235
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,540
0
0
0
0
0
0
0
0
0
0
0
0
10,500
0
0
0
0
Total
O&M
0
0
0
24,907
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
36,142
0
0
0
0
0
0
0
0
0
0
0
0
30,816
0
0
0
0
TOTAL
ANNUAL
COST($/YR)(b)
0
0
0
32,444
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
49,290
0
0
0
0
0
0
0
0
0
0
0
0
32,716
0
0
0
0
VO
-------
Table 9-11: BPT/BCT/BAT Option I Subtitle D Non-Hazardous Subcategory (continued)
ID#
162 1
162 2
162 2
162 3
162 4
162 5
162 8
16230
16231
16232
16233
16234
16236
16239
16240
16240
16241
16242
16243
16245
16246
16248
16249
16250
16251
16252
16253
TOTALS
Flow
(MOD)
0.00662
0.01548
0
0.02904
0
0.031
0.00072
0
0
0
0.0097
0.03083
0.00595
0
0
0.0056
0
0.0005
0
0
0.00135
0.01
0
0.0002
0.0007
0.005
0.01776
2.694
CAPITAL COSTS ($)
Equipment
0
0
0
153,000
0
0
0
0
0
0
94,269
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,340,439
Sludge
Handling
0
0
0
2,004
0
0
0
0
0
0
9,868
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
75,236
Retrofit
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
321,429
Permit
Modification
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
Land
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
Total
Capital
0
0
0
155,004
0
0
0
0
0
0
104,137
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,737,104
AMORTIZED
TOTAL CAPITAL(a)
($/YR)
0
0
0
17,019
0
0
0
0
0
0
11,434
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
300,519
O &M COSTS ($/YR)
Equipment
0
0
0
51,200
0
0
0
0
0
0
13,366
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
373,594
Solids
Handling
0
0
0
4,078
0
0
0
0
0
0
9,277
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
87,480
Monitoring
0
0
0
10,500
0
0
0
0
0
0
11,540
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,068
368,307
Total
O &M
0
0
0
65,778
0
0
0
0
0
0
34,183
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,068
829,381
TOTAL
ANNUAL
COST($/YR)(b)
0
0
0
82,797
0
0
0
0
0
0
45,617
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,068
1,139,098
VO
-k
oo
(a) Amortization assuming 7%interest over 15 year period.
(b) Off-site disposal costs used for low flow facilities 16048, 16055, and 1 6062
-------
Table 9-12: BPT/BCT/BAT Option II Subtitle D Non-Hazardous Subcategory
ID#
16001
16003
16008
16009
16011
16012
16013
16014
16015
16016
16020
16023
16024
16025
16026
16027
16028
16029
16033
16035
16038
16039
16043
16044
16046
16047
16048
16049
16050
16052
16053
16054
16055
16056
16058
16059
16060
16061
16062
16063
16064
Flow
(MOD)
0.0793
0.00472
0
0.01613
0
0.00221
0.015
0
0.0005
0.0023
0.04581
0.05734
0.00592
0
0
0
0.01985
0.025
0.0091
0
0.00822
0.00178
0.00218
0
0
0.00115
5E-06
0.0017
0.01
0.0546
0.00124
0.00075
8E-06
0.00137
0.003
0.0011
0.0018
0
0.00005
0.0067
0.01197
CAPITALCOSTS($)
Equipment
203,456
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
51,650
0
48,843
58,533
217,678
39,625
30,019
0
54,111
44,348
51,492
57,885
0
0
94,714
62,083
Sludge
Handling
2,004
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
2,004
2,004
5,563
2,004
2,004
0
2,004
2,004
2,004
2,004
0
0
2,004
2,004
Retrofit
41,092
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
10,169
0
44,648
0
6,405
0
0
9,270
0
0
0
0
0
0
Permit
M edification
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
Land
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
Total
Capital
246,552
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
53,654
0
61,017
60,537
267,889
41,629
38,427
0
56,115
55,622
53,496
59,889
0
0
96,718
64,087
AMORTIZED
TOTALCAPITAL(a)
($/YR)
27,070
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5,891
0
6,699
6,647
29,413
4,571
4,219
0
6,161
6,107
5,874
6,575
0
0
10,619
7,036
O &M COSTS ($/YR)
Equipment
44,857
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
15,497
0
15,205
11,672
17,799
9,002
12,013
0
15,659
8,936
15,468
16,161
0
0
20,855
12,127
Solids
Handling
4,078
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,917
0
2,208
1,917
6,897
1,917
1,917
0
1,917
1,917
1,917
2,208
0
0
3,562
3,931
M onitoring
11,540
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,540
0
11,540
11,540
11,072
11,540
11,357
0
11,540
0
11,540
11,540
0
0
11,540
11,540
Total
O &M
60,475
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
28,954
0
28,953
25,129
35,768
22,459
25,287
0
29,116
10,853
28,925
29,909
0
0
35,957
27,598
TOTAL
ANNUAL
COST($/YR)(b)
87,545
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
34,845
730
35,653
31,776
65,180
27,030
29,506
1,168
35,277
16,960
34,798
36,484
0
7,300
46,576
34,634
VO
-k
VO
-------
Table 9-12: BPT/BCT/BAT Option II Subtitle D Non-Hazardous Subcategory (continued)
ID#
16065
16068
16070
16071
16072
16073
16074
16075
16076
16077
16078
16079
16083
16084
16085
16088
16090
16091
16092
16093
16097
16098
16099
16102
16103
16107
16109
16111
16113
16114
16115
16116
16117
16118
16119
16120
16121
16122
16123
16124
16125
Flow
(MOD)
0.008
0
0.00133
0.006
0
0.0182
0
0.01021
0
0.00816
0.00499
0.11247
0.001
0.00643
0.03
0.03621
0.00393
0.2321
0.00668
0.08158
0.019
0
0.01533
0.01394
0.03756
0.00129
0.05056
0.0072
0
0.00864
0.00407
0.0042
0.04
0.0288
0.00729
0.04278
0.08028
0.0255
0.04608
0.01666
0.01419
CAPITALCOSTS($)
Equipment
91,929
0
0
0
0
0
0
0
0
0
0
356,066
42,475
0
0
0
0
0
0
222,598
72,380
0
0
135,429
0
0
0
0
0
0
0
0
37,048
0
13,151
0
0
0
246,283
0
0
Sludge
Handling
2,004
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
8,080
0
0
Retrofit
18,787
0
0
0
0
0
0
0
0
0
0
71,213
8,896
0
0
0
0
0
0
44,520
14,476
0
0
27,086
0
0
0
0
0
0
0
0
7,410
0
3,031
0
0
0
50,873
0
0
Permit
M edification
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
Land
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
Total
Capital
112,719
0
0
0
0
0
0
0
0
0
0
427,279
53,374
0
0
0
0
0
0
267,118
86,856
0
0
162,514
0
0
0
0
0
0
0
0
44,458
0
18,186
0
0
0
305,236
0
0
AMORTIZED
TOTALCAPITAL(a)
($/YR)
12,376
0
0
0
0
0
0
0
0
0
0
46,913
5,860
0
0
0
0
0
0
29,328
9,536
0
0
17,843
0
0
0
0
0
0
0
0
4,881
0
1,997
0
0
0
33,513
0
0
O &M COSTS ($/YR)
Equipment
20,721
0
0
0
0
0
0
0
0
0
0
27,018
14,573
0
0
0
0
0
0
30,361
3,597
0
0
25,465
0
0
0
0
0
0
0
0
18,524
0
2,577
0
0
0
39,120
0
0
Solids
Handling
3,231
0
0
0
0
0
0
0
0
0
0
0
1,735
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,948
0
0
0
8,365
0
0
M onitoring
11,090
0
0
0
0
0
0
0
0
0
0
11,180
11,540
0
0
0
0
0
0
11,180
10,520
0
0
11,540
0
0
0
0
0
0
0
0
9,908
0
11,117
9,200
0
9,948
11,540
0
10,712
Total
O &M
35,042
0
0
0
0
0
0
0
0
0
0
38,198
27,848
0
0
0
0
0
0
41,541
14,117
0
0
37,005
0
0
0
0
0
0
0
0
28,432
0
15,642
9,200
0
9,948
59,025
0
10,712
TOTAL
ANNUAL
COST($/YR)(b)
47,418
0
0
0
0
0
0
0
0
0
0
85,111
33,708
0
0
0
0
0
0
70,869
23,653
0
0
54,848
0
0
0
0
0
0
0
0
33,313
0
17,639
9,200
0
9,948
92,538
0
10,712
VO
I
-------
Table 9-12: BPT/BCT/BAT Option II Subtitle D Non-Hazardous Subcategory (continued)
ID#
16127
16128
16129
16130
16131
16132
16135
16137
16139
16140
16143
16144
16146
16148
16149
16150
16151
16152
16153
16154
16155
16156
16158
16159
16160
16161
16162
16163
16164
16165
16166
16169
16170
16171
16173
16174
16175
16176
16177
16180
16184
Flow
(MOD)
0.00363
0.00396
0.00469
0.0003
0.03
0.03
0.01149
0
0.00005
0
0
0
0
0.00008
0
0.04578
0.00205
0
0.008
0.01022
0.00831
0.173
0.01428
0.225
0.00014
0.053
0.0009
0
0.01
0.03022
0.00342
0
0.0048
0.024
0.025
0.0072
0
0.03727
0
0
0
CAPITALCOSTS($)
Equipment
55,540
0
0
4,400
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
55,201
0
0
0
0
0
0
0
0
Sludge
Handling
2,004
0
0
2,004
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
2,004
0
0
0
0
0
0
0
0
Retrofit
11,509
0
0
1,281
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
11,441
0
0
0
0
0
0
0
0
Permit
M edification
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
Land
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
Total
Capital
69,053
0
0
7,685
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
68,647
0
0
0
0
0
0
0
0
AMORTIZED
TOTALCAPITAL(a)
($/YR)
7,582
0
0
844
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
7,537
0
0
0
0
0
0
0
0
O &M COSTS ($/YR)
Equipment
11,684
0
0
10,400
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
9,594
0
0
0
0
0
0
0
0
Solids
Handling
2,756
0
0
4,078
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
4,078
0
0
0
0
0
0
0
0
M onitoring
11,540
0
11,540
11,540
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
11,235
0
0
0
0
0
0
0
0
Total
O &M
25,980
0
11,540
26,018
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
24,907
0
0
0
0
0
0
0
0
TOTAL
ANNUAL
COST($/YR)(b)
33,562
0
11,540
26,862
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
32,444
0
0
0
0
0
0
0
0
-------
Table 9-12: BCT/BPT/BAT Option II Subtitle D Non-Hazardous Subcategory (continued)
ID#
16185
16186
16187
16189
16190
16191
16193
16196
16197
16199
16200
16201
16202
16203
16204
16204
16205
16206
16208
16211
16212
16215
16217
16219
16220
16221
16222
16222
16223
16224
16225
16228
16230
16231
16232
16233
16234
16236
16239
16240
16240
Flow
(MOD)
0
0.00304
0.003
0
0
0
0.0023
0.01223
0
0.0008
0.01142
0.00188
0.01301
0.02
0
0
0
0.05739
0.00334
0.15
0.0007
0
0
0.02544
0.03041
0.00662
0.01548
0
0.02904
0
0.031
0.00072
0
0
0
0.0097
0.03083
0.00595
0
0
0.0056
CAPITALCOSTS($)
Equipment
0
0
0
0
0
0
0
131,628
0
0
0
0
0
0
0
0
0
0
0
0
15,300
0
0
0
0
0
0
0
153,000
0
0
0
0
0
0
116,040
0
0
0
0
0
Sludge
Handling
0
0
0
0
0
0
0
11,645
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
0
0
0
0
2,004
0
0
0
0
0
0
9,868
0
0
0
0
0
Retrofit
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
Permit
Modification
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
Land
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
Total
Capital
0
0
0
0
0
0
0
143,273
0
0
0
0
0
0
0
0
0
0
0
0
17,304
0
0
0
0
0
0
0
155,004
0
0
0
0
0
0
125,908
0
0
0
0
0
AMORTIZED
TOTALCAPITAL(a)
($/YR)
0
0
0
0
0
0
0
15,731
0
0
0
0
0
0
0
0
0
0
0
0
1,900
0
0
0
0
0
0
0
17,019
0
0
0
0
0
0
13,824
0
0
0
0
0
O &M COSTS ($/YR)
Equipment
0
0
0
0
0
0
0
26,246
0
0
0
0
0
0
0
0
0
0
0
0
18,800
0
0
0
0
0
0
0
51,200
0
0
0
0
0
0
24,252
0
0
0
0
0
Solids
Handling
0
0
0
0
0
0
0
10,115
0
0
0
0
0
0
0
0
0
0
0
0
1,516
0
0
0
0
0
0
0
4,078
0
0
0
0
0
0
9,277
0
0
0
0
0
M onitoring
0
0
0
0
0
0
0
11,540
0
0
0
0
0
0
0
0
0
0
0
0
10,500
0
0
0
0
0
0
0
10,500
0
0
0
0
0
0
11,540
0
0
0
0
0
Total
O &M
0
0
0
0
0
0
0
47,901
0
0
0
0
0
0
0
0
0
0
0
0
30,816
0
0
0
0
0
0
0
65,778
0
0
0
0
0
0
45,069
0
0
0
0
0
TOTAL
ANNUAL
COST($/YR)(b)
0
0
0
0
0
0
0
63,632
0
0
0
0
0
0
0
0
0
0
0
0
32,716
0
0
0
0
0
0
0
82,797
0
0
0
0
0
0
58,893
0
0
0
0
0
VO
(^
to
-------
Table 9-12: BCT/BPT/BAT Option II Subtitle D Non-Hazardous Subcategory (continued)
ID#
16241
16242
16243
16245
16246
16248
16249
16250
16251
16252
16253
TOTALS
Flow
(MOD)
0
0.0005
0
0
0.00135
0.01
0
0.0002
0.0007
0.005
0.01776
2.694
CAPITAL COSTS ($)
Equipment
0
0
0
0
0
0
0
0
0
0
26,840
2,789,743
Sludge
Handling
0
0
0
0
0
0
0
0
0
0
0
75,236
Retrofit
0
0
0
0
0
0
0
0
0
0
5,368
387,473
Permit
Modification
0
0
0
0
0
0
0
0
0
0
0
0
Land
0
0
0
0
0
0
0
0
0
0
0
0
Total
Capital
0
0
0
0
0
0
0
0
0
0
32,208
3,252,453
AMORTIZED
TOTALCAPITAL(a)
($/YR)
0
0
0
0
0
0
0
0
0
0
3,536
357,102
O&M COSTS ($/YR)
Equipment
0
0
0
0
0
0
0
0
0
0
13,420
562,803
Solids
Handling
0
0
0
0
0
0
0
0
0
0
0
87,480
Monitoring
0
0
0
0
0
0
0
0
0
0
11,068
368,307
Total
O&M
0
0
0
0
0
0
0
0
0
0
24,488
1,018,590
TOTAL
ANNUAL
COST($/YR)(b)
0
0
0
0
0
0
0
0
0
0
28,024
1,384,890
(a) Amortization assuming 7%interest over 15 year period.
(b)Off-site disposal costs used for lowflow facilities 16048, 16055,and 16062
-------
Table 9-13: BAT Option III Subtitle D Non-Hazardous Subcategory
ID#
16001
16003
16008
16009
16011
16012
16013
16014
16015
16016
16020
16023
16024
16025
16026
16027
16028
16029
16033
16035
16038
16039
16043
16044
16046
16047
16048
16049
16050
16052
16053
16054
16055
16056
16058
16059
16060
16061
16062
16063
Flow
(MOD)
0.0793
0.00472
0
0.01613
0
0.00221
0.015
0
0.0005
0.0023
0.04581
0.05734
0.00592
0
0
0
0.01985
0.025
0.0091
0
0.00822
0.00178
0.00218
0
0
0.00115
5E-06
0.0017
0.01
0.0546
0.00124
0.00075
8E-06
0.00137
0.003
0.0011
0.0018
0
0.00005
0.0067
CAPITALCOSTS(S)
Equipment
2,183,593
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
191,967
46,193
247,768
797,074
1,949,079
190,146
123,852
32,864
218,417
361,815
186,408
266,809
0
36,642
664,889
Sludge
Handling
2,004
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
2,004
2,004
5,563
2,004
2,004
0
2,004
2,004
2,004
2,004
0
0
2,004
Retrofit
437,119
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
49,954
0
390,928
0
25,171
0
0
72,764
0
0
0
0
0
Permit
Modification
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
Land
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
Capital
2,622,716
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
193,971
46,193
299,726
799,078
2,345,571
192,150
151,028
32,864
220,421
436,583
188,412
268,813
0
36,642
666,893
AMORTIZED
TOTALCAPITAL(a)
($ /YR)
287,960
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21,297
5,072
32,908
87,734
257,531
21,097
16,582
3,608
24,201
47,934
20,687
29,514
0
4,023
73,221
O&M COSTS ($/YR)
Equipment
623,747
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
23,878
14,452
27,615
84,672
416,379
18,054
17,488
7,737
25,638
30,836
23,498
29,301
0
8,043
69,765
Solids
Handling
4,078
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,917
0
2,208
1,917
6,897
1,917
1,917
0
1,917
1,917
1,917
2,208
0
0
3,562
Monitoring
11,540
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,540
0
11,540
11,540
11,072
11,540
11,357
0
11,540
0
11,540
11,540
0
0
11,540
Total
O &M
639,365
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
o
0
0
0
0
o
0
0
37,335
14,452
41,363
98,129
434,348
31,511
30,762
7,737
39,095
32,753
36,955
43,049
0
8,043
84,867
TOTAL
ANNUAL
COST($/YR)(b)
927,325
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
58,632
20,254
74,272
185,864
691,879
52,609
47,344
12,513
63,296
80,688
57,641
72,563
0
19,366
158,088
VO
-------
Table 9-13: BAT Option III Subtitle D Non-Hazardous Subcategory (continued)
ID#
16064
16065
16068
16070
16071
16072
16073
16074
16075
16076
16077
16078
16079
16083
16084
16085
16088
16090
16091
16092
16093
16097
16098
16099
16102
16103
16107
16109
16111
16113
16114
16115
16116
16117
16118
16119
16120
16121
16122
16123
Flow
(MOD)
0.01197
0.008
0
0.00133
0.006
0
0.0182
0
0.01021
0
0.00816
0.00499
0.11247
0.001
0.00643
0.03
0.03621
0.00393
0.2321
0.00668
0.08158
0.019
0
0.01533
0.01394
0.03756
0.00129
0.05056
0.0072
0
0.00864
0.00407
0.0042
0.04
0.0288
0.00729
0.04278
0.08028
0.0255
0.04608
CAPITALCOSTS(S)
Equipment
885,558
733,057
0
0
0
0
0
0
0
0
0
0
2,562,809
165,966
0
0
0
0
0
0
2,221,423
1,067,839
0
0
1,035,581
0
0
0
0
0
0
0
0
1,562,645
0
603,122
1,569,551
0
1,240,783
1,864,917
Sludge
Handling
2,004
2,004
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
8,080
Retrofit
0
147,012
0
0
0
0
0
0
0
0
0
0
512,562
33,594
0
0
0
0
0
0
444,285
213,568
0
0
207,116
0
0
0
0
0
0
0
0
312,529
0
120,624
313,910
0
248,157
374,599
Permit
Modification
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
Land
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
Total
Capital
887,562
882,073
0
0
0
0
0
0
0
0
0
0
3,075,371
201,564
0
0
0
0
0
0
2,665,708
1,281,407
0
0
1,242,698
0
0
0
0
0
0
0
0
1,875,174
0
723,746
1,883,461
0
1,488,939
2,247,596
AMORTIZED
TOTALCAPITAL(a)
($ /YR)
97,450
96,847
0
0
0
0
0
0
0
0
0
0
337,659
22,131
0
0
0
0
0
0
292,680
140,692
0
0
136,442
0
0
0
0
0
0
0
0
205,884
0
79,463
206,794
0
163,478
246,774
O &M COSTS ($/YR)
Equipment
99,486
79,121
0
0
0
0
0
0
0
0
0
0
848,079
21,873
0
0
0
0
0
0
625,858
138,700
0
0
127,227
0
0
0
0
0
0
0
0
310,524
0
53,202
312,258
0
186,150
375,504
Solids
Handling
3,931
3,231
0
0
0
0
0
0
0
0
0
0
0
1,735
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
8,365
Monitoring
11,540
11,090
0
0
0
0
0
0
0
0
0
0
11,180
11,540
0
0
0
0
0
0
11,180
10,520
0
0
11,540
0
0
0
0
0
0
0
0
9,908
0
11,117
9,200
0
9,948
11,540
Total
O&M
114,957
93,442
0
0
0
0
0
0
0
0
0
0
859,259
35,148
0
0
0
0
0
0
637,038
149,220
0
0
138,767
0
0
0
0
0
0
0
0
320,432
0
64,319
321,458
0
196,098
395,409
TOTAL
ANNUAL
COST($/YR)(b)
212,406
190,289
0
0
0
0
0
0
0
0
0
0
1,196,918
57,279
0
0
0
0
0
0
929,719
289,912
0
0
275,208
0
0
0
0
0
0
0
0
526,316
0
143,783
528,251
0
359,576
642,183
VO
-------
Table 9-13: BAT Option III Subtitle D Non-Hazardous Subcategory (continued)
ID#
16124
16125
16127
16128
16129
16130
16131
16132
16135
16137
16139
16140
16143
16144
16146
16148
16149
16150
16151
16152
16153
16154
16155
16156
16158
16159
16160
16161
16162
16163
16164
16165
16166
16169
16170
16171
16173
16174
16175
16176
Flow
(MOD)
0.01666
0.01419
0.00363
0.00396
0.00469
0.0003
0.03
0.03
0.01149
0
0.00005
0
0
0
0
0.00008
0
0.04578
0.00205
0
0.008
0.01022
0.00831
0.173
0.01428
0.225
0.00014
0.053
0.0009
0
0.01
0.03022
0.00342
0
0.0048
0.024
0.025
0.0072
0
0.03727
CAPITALCOSTS(S)
Equipment
0
909,456
423,029
0
444,502
36,269
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
507,196
0
0
0
0
0
Sludge
Handling
0
0
2,004
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
2,004
0
0
0
0
0
Retrofit
0
181,891
85,007
0
88,900
7,254
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
101,840
0
0
0
0
0
Permit
Modification
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
o
0
0
0
0
0
0
0
0
0
0
0
Land
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
Total
Capital
0
1,091,347
510,040
0
533,403
43,523
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
611,040
0
0
0
0
0
AMORTIZED
TOTALCAPITAL(a)
($ /YR)
0
119,824
56,000
0
58,565
4,779
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
67,089
0
0
0
0
0
O&M COSTS ($/YR)
Equipment
0
103,609
38,161
0
34,237
2,190
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
44,634
0
0
0
0
0
Solids
Handling
0
0
2,756
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
4,078
0
0
0
0
0
Monitoring
0
10,712
11,540
0
11,540
11,540
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,235
0
0
0
0
0
Total
O&M
0
114,321
52,457
0
45,777
13,730
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
0
0
0
0
0
59,947
0
0
0
0
0
TOTAL
ANNUAL
COST($/YR)(b)
0
234,145
108,457
0
104,342
18,509
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0
0
o
0
0
o
0
o
0
0
0
127,036
0
0
0
0
0
VO
-------
Table 9-13: BAT Option III Subtitle D Non-Hazardous Subcategory (continued)
ID#
16177
16180
16184
16185
16186
16187
16189
16190
16191
16193
16196
16197
16199
16200
16201
16202
16203
16204
16204
16205
16206
16208
16211
16212
16215
16217
16219
16220
16221
16222
16222
16223
16224
16225
16228
16230
16231
16232
16233
16234
Flow
(MOD)
0
0
0
0
0.00304
0.003
0
0
0
0.0023
0.01223
0
0.0008
0.01142
0.00188
0.01301
0.02
0
0
0
0.05739
0.00334
0.15
0.0007
0
0
0.02544
0.03041
0.00662
0.01548
0
0.02904
0
0.031
0.00072
0
0
0
0.0097
0.03083
CAPITALCOSTS(S)
Equipment
0
0
0
0
0
0
0
0
0
0
965,897
0
0
0
0
0
0
0
0
0
0
0
0
134,753
0
0
0
0
0
0
0
1,531,517
0
0
0
0
0
0
840,751
0
Sludge
Handling
0
0
0
0
0
0
0
0
0
0
11,645
0
0
0
0
0
0
0
0
0
0
0
0
2,004
0
0
0
0
0
0
0
7,768
0
0
0
0
0
0
9,868
0
Retrofit
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
Permit
Modification
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
o
0
0
0
0
0
0
0
0
0
0
0
0
Land
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
Total
Capital
0
0
0
0
0
0
0
0
0
0
977,542
0
0
0
0
0
0
0
0
0
0
0
0
136,757
0
0
0
0
0
0
0
1,539,285
0
0
0
0
0
0
850,619
0
AMORTIZED
TOTALCAPITAL(a)
($ /YR)
0
0
0
0
0
0
0
0
0
0
107,329
0
0
0
0
0
0
0
0
0
0
0
0
15,015
0
0
0
0
0
0
0
169,005
0
0
0
0
0
0
93,393
0
O &M COSTS ($/YR)
Equipment
0
0
0
0
0
0
0
0
0
0
115,547
0
0
0
0
0
0
0
0
0
0
0
0
20,233
0
0
0
0
0
0
0
246,811
0
0
0
0
0
0
95,062
0
Solids
Handling
0
0
0
0
0
0
0
0
0
0
10,115
0
0
0
0
0
0
0
0
0
0
0
0
1,516
0
0
0
0
0
0
0
8,212
0
0
0
0
0
0
9,277
0
Monitoring
0
0
0
0
0
0
0
0
0
0
11,540
0
0
0
0
0
0
0
0
0
0
0
0
10,500
0
0
0
0
0
0
0
10,500
0
0
0
0
0
0
11,540
0
Total
O &M
0
0
0
0
0
0
0
0
0
0
137,202
0
0
0
0
0
0
0
0
0
0
0
0
32,249
0
0
0
0
0
0
0
265,523
0
0
0
0
0
0
115,879
0
TOTAL
ANNUAL
COST($/YR)(b)
0
0
0
0
0
0
0
0
0
0
244,531
0
0
0
0
0
0
0
0
0
0
0
0
47,264
0
0
0
0
0
0
0
434,528
0
0
0
0
0
0
209,272
0
VO
-------
Table 9-13: BAT Option III Subtitle D Non-Hazardous Subcategory (continued)
ID#
16236
16239
16240
16240
16241
16242
16243
16245
16246
16248
16249
16250
16251
16252
16253
TOTALS
Flow
(MGD)
0.00595
0
0
0.0056
0
0.0005
0
0
0.00135
0.01
0
0.0002
0.0007
0.005
0.01776
2.694
CAPITAL COSTS ($)
Equipment
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,056,810
29,860,948
Sludge
Handling
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
76,992
Retrofit
0
0
0
0
0
0
0
0
0
0
0
0
0
0
211,362
4,580,148
Permit
Modification
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total
Capital
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,268,173
34,518,089
AMORTIZED
TOTALCAPITAL(a)
($/YR)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
139,239
3,789,901
O&M COSTS ($/YR)
Equipment
0
0
0
0
0
0
0
0
0
0
0
0
0
0
143,068
5,442,636
Solids
Handling
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
85,588
Monitoring
0
0
0
0
0
0
0
0
0
0
0
0
0
0
11,068
368,307
Total
O&M
0
0
0
0
0
0
0
0
0
0
0
0
0
0
154,136
5,896,531
TOTAL
ANNUAL
COST($/YR)(b)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
293,374
9,695,630
VO
I
-------
// Are regulated ^^
wastewaters less than
85% of total facility
\, flow? /
// Is the facility
/^ complying with LTAs
\for this BAT/BPT/PSES/
^x option? //
/Does the facility have all
of the treatment components for
this BAT/BPT/PSES option
\x installed? /
Do not cost facility. Cost
for BAT/BPT/PSES
compliance is zero
/Does the facility have
some of the treatment
components for this BAT/
BPT/PSES option or
equivalent treatment?/
Provide entire treatment
system for this BAT/BPT/
PSES option
Provide additional treatment
components necessary to
achieve LTAs for this BAT/
BPT/PSES option. In some
cases upgrades to existing
treatment components or other
incremental treatment processes
may only be necessary to
achieve LTAs for this BAT/
BPT/PSES option
/ Cost facility for entire treatment ^
' system under this BAT/BPT/PSES
option; including land, residual, RCRA
i permit modifications (if hazardous),
\ and monitoring costs /
\ /
/ Cost facility only for additional
treatment process(es) and upgrades
necessary to achieve LTAs for this BAT/
BPT/PSES option; including retrofit,
land, residual, RCRA permit
modifications (if hazardous), and
\ monitoring costs /
Upgrade existing process
equipment or operation to
ensure compliance with LTAs
for this BAT/BPT/PSES
option
Cost upgrade to existing treatment system
to achieve LTAs for this BAT/BPT/PSES
option; including retrofit, land, residual,
RCRA permit modifications (if hazardous)
and monitoring costs
Figure 9-1: Option-Specific Costing Logic Flow Diagram
-------
Figure 9-2
Equalization Capital Cost Curve
A WWC Cost
1e+008 ET
1e+007
1000000
w
O
U 100000
10000
1000
1204
0.001
0.01
0.1
10
Flow (MOD)
-------
Figure 9-3
Flocculation Capital Cost Curve
A WWC Cost
1000000 E
100000
W
O
U
10000
1000
100
0.001
0.01
12630J
7999<
0.1
10
Flow (MOD)
-------
Figure 9-4
Flocculation O&M Cost Curve
A WWC Cost
100000 F
10000
w
O
U
1000
100
0.001
638
0.01
195
139
0.1
6735
470(
I I I I I
10
Flow (MOD)
-------
Figure 9-5
Sodium Hydroxide Capital Cost Curve
A WWC Cost
1000000 c
W
O
U
100000
10000
0.5 1
10
4725^0613
A A
1631
100
1000
10000
Dosage Rate (Ib/day)
-------
Figure 9-6
Sodium Hydroxide O&M Cost Curve
A WWC Cost
50000
10000
W
O
U
1000
4948
0.5 1
10
51915297
100
1000
9148.
10000
Dosage Rate (Ib/day)
-------
Figure 9-7
Phosphoric Acid Feed Capital Cost Curve
A WWC Cost
500000
100000
W
O
U
10000
0.5 1
10
100
1000
10000
Dosage Rate (gpd)
-------
Figure 9-8
Phosphoric Acid Feed O&M Cost Curve
A WWC Cost
50000
10000
W
O
U
1000
0.5 1
10
100
1000
10000
Dosage Rate (gpd)
-------
Figure 9-9
Polymer Feed Capital Cost Curve
A WWC Cost
1000000 c
w
o
u
100000
10000
5 10
5238;
100
1000
10000
Dosage Rate (Ib/hr)
-------
Figure 9-10
Polymer Feed O&M Cost Curve
A WWC Cost
1e+009
1e+008
10+007
W
O
U 1000000
100000
10000
98572:
19714?
98623J
10
100
1000
10000
Dosage Rate (Ib/hr)
-------
Figure 9-11
Primary Clarifier Capital Cost Curve
A WWC Cost
1e+007 E
1000000
W
O
U
100000
10000
1000
0.001
0.01
18075
27457J
0.1
10
Flow (MOD)
-------
Figure 9-12
Primary Clarifier O&M Cost Curve
A WWC Cost
100000 c
W
O
U
10000
1000
0.001
0.01
1809:
2250(
12445,
1027L
0.1
10
Flow (MOD)
-------
Figure 9-13
Aeration Basin Capital Cost Curve
A WWC Cost
1e+008 F
1e+007
W
O
U
1000000
100000
10
311661
A
544139
A
100
45610<
1000
12991143
10000
Basin Volume (1000 eft)
-------
Figure 9-14
Air Diffusion System Capital Cost Curve
A WWC Cost
5e+007
1e+007
1000000
100000
50000
11119!
571
2859<
1469
6355
10
100
1000
Flow (1000 scfm)
-------
Figure 9-15
Air Diffusion System O&M Cost Curve
A WWC Cost
1000000 r
100000
o
u
10000
1
2174'
15401
1087;
71
4836
10
100
1000
Flow (1000 scfm)
-------
Figure 9-16
Secondary Clarifier Capital Cost Curve
A WWC Cost
1e+007 F
1000000
W
O
U
100000
10000
0.001
0.01
0.1
10
Flow (MOD)
-------
Figure 9-17
Secondary Clarifier O&M Cost Curve
A WWC Cost
100000 r
ts 10000
o
u
1000
0.001
0.01
0.1
10
Flow (MOD)
-------
Figure 9-18
Multimedia Filtration Capital Cost Curve
A WWC Cost
1000000 c
W
O
U
100000
10000
0.001
0.01
0.1
10
Flow (MOD)
-------
Figure 9-19
Multimedia Filtration O&M Cost Curve
A WWC Cost
100000
W
O
U
10000
0.001
0.01
0.1
10
Flow (MOD)
-------
Figure 9-20
Reverse Osmosis Capital Cost Curve
5000000
1000000
W
O
U
100000
Vendor Cost
0.001
368491
A
111757]
13262]
815093
0.01
0.1
Flow (MOD)
-------
Figure 9-21
Sludge Drying Beds Capital Cost Curve
A WWC Cost
100000 c
W
O
U
10000
1000
10
100
653*
397!
125
76
1000
10000
100000
Area (sqft)
-------
Figure 9-22
Sludge Drying Beds O&M Cost Curve
A WWC Cost
100000 r
ts 10000
o
u
1000
10
508
100
2826'
216;
1185
918
1000
10000
100000
Area (sqft)
-------
Figure 9-23
GAC Capital Cost Curve
A WWC Cost
100000
tz 10000
o
u
1000
0.0001
522(
331
157(
0.001
0.01
0.1
Flow (MOD)
-------
Figure 9-24
GAC O&M Cost Curve
A WWC Cost
100000 r
co
O
U
10000
1000
0.0001
17400
21800
1040
0.001
0.01
0.1
Flow (MOD)
-------
Figure 9-25
Brkpnt Chlorination Capital Cost Curve
A WWC Cost
1000000 F
100000
co
o
u
10000
1000
0.0001
0.001
100800
53800
A
0.01
0.1
Flow (MOD)
-------
Figure 9-26
Breakpoint Chlorination O&M Cost Curve
A WWC Cost
100000 r
co
O
U
10000
1000
0.0001
0.001
0.01
0.1
Flow (MOD)
-------
10.0 NON-WATER QUALITY IMPACTS
The operation of wastewater treatment systems may have ancillary environmental effects by generating solid
and hazardous residuals and air emissions, and by consuming energy in treatment.
The elimination or reduction of one form of pollution may create or aggravate other environmental
problems. Therefore, Sections 304(b) and 306 of the Clean Water Act (CWA) require EPA to consider
the non-water quality environmental impacts and energy requirements of effluent limitations guidelines and
standards. In fulfillment of these requirements, EPA has considered the effect of promulgating the BPT,
BCT, BAT, and NSPS regulations for the Landfills industry on the creation of additional air pollution, solid
and hazardous waste, and energy consumption.
While it is difficult to balance environmental impacts across all media and energy use, the Agency
determined that the impacts identified below do not outweigh the benefits associated with compliance with
the limitations and standards.
10.1 Air Pollution
The primary source of air pollution from landfills results from the microbial breakdown of organic wastes
from within the landfill. Landfills are known to be maj or sources of greenhouse gas emissions such as
methane and carbon dioxide. These emissions are now regulated under the Clean Air Act (CAA) as a
result of the municipal solid waste landfill Standards of Performance for New Stationary Sources and
Guidelines for Control of Existing Sources, promulgated by the EPA on March 12, 1996 (Federal
Register: Volume 61, Number 49) and codified in 40 CFR 60 Subpart CC-Emission Guidelines and
Compliance Times for Municipal Solid Waste Landfills and Subpart WWW-Standards of Performance
for Municipal Solid Waste Landfills. Many non-hazardous solid waste landfills are required to collect and
combust the gases generated in the landfill. Wastewater collected from within the landfill contains organic
compounds which include volatile organic compounds (VOC) and hazardous air pollutants (HAP). This
10-1
-------
wastewater must be collected, treated and stored in units which are often open to the atmosphere and may
result in the volatilization of certain compounds. Organic pollutants volatilize in reaching an equilibrium with
the vapor phase above the wastewater. These volatile organic compounds are emitted to the ambient air
surrounding the collection and treatment units. The magnitude of volatile organic compound emissions is
dependent on factors such as the physical properties of the pollutants, the temperature of the wastewater,
and the design of the individual collection and treatment units.
The landfill effluent guidelines limitations are based on the performance of an aerated biological system.
Wastewater aeration may increase the volatilization of certain organic compounds, a potential environmental
concern. However, indications are that the potential increase in air emissions due to the final landfill effluent
guideline will be minimal. VOCs in hazardous waste landfill leachate are being steadily minimized due to
the Resource Conservation and Recovery Act (RCRA) land disposal restriction rules, which typically
require aggressive destructive treatment of organics in hazardous wastes before the waste can be landfilled
(see 40 CFR 268.40 and 268.48).' VOC levels in historic landfill leachate (from both hazardous and non-
hazardous waste landfills dating from the 1930s to the mid-1990s) are also at levels which are low enough
as not to call into question EPA's determination to base these rules on the performance of aerated
biological systems. Tables 6-9, 6-10, and 6-13 in Chapter 6 show the concentrations of VOCs found in
landfill wastewater.
Furthermore, EPA's Office of Air and Radiation is currently evaluating the air emissions from wastewater
generated at municipal solid waste landfills, and intends to take this rule into account in determining whether
further controls under section 112 of the Clean Air Act (which requires technology-based standards for
hazardous air pollutants emitted by major sources of emissions of those pollutants) are justified.
1 There are certain exceptions to these treatment requirements for hazardous wastewater which is
disposed in surface impoundments. RCRA section 3005 (j) (11). However, if this wastewater contains
VOCs above a designated concentration level, then the impoundments are subject to rules requiring
control of the resulting air emissions. 40 CFR 264.1085 and 263.1086.
10-2
-------
(Preliminary indications are that hazardous air pollutant emissions from aeration would be a minor fraction
of those from other landfill emission sources such as landfill gas emissions.)
In addition, EPA is addressing emissions of volatile organic compounds from industrial wastewater through
a Control Techniques Guideline (CTG) under Section 110 of the CAA. CAA amendments require that
State implementation plans for certain ozone nonattainment areas be revised to require the implementation
of reasonably available control technology (RACT) for control of volatile organic compound emissions from
sources for which EPA has prepared CTGs. In September, 1992, EPA published a draft CTG document
entitled "Control of Volatile Organic Compound Emissions from Industrial Wastewater."
(EPA-453/0-93-056). This document addresses various industries, including the hazardous waste
treatment, storage, and disposal facilities (TSDF) industry, and outlines volatile organic compound
emissions expected from their wastewater treatment systems and methods for controlling them. For CTG
guideline purposes, EPA has included Subtitle C and D landfills with leachate collection systems in the
TSDF industry. EPA estimates that nearly all landfills affected by the Landfills effluent guideline will be
subject to this CTG for volatile emissions from their wastewater treatment systems. It was estimated in the
CTG draft document that 43 percent of the facilities in the TSDF industry are located in areas of ozone
nonattainment. In 1994, the draft CTGs were revised to reflect changes that were made in the wastewater
provisions of the Hazardous Organic National Emission Standards for Hazardous Air Pollutants
promulgated by the EPA on April 22,1994 (Federal Register: Volume 59, Number 19). EPA published
these changes to the CTGs in a document entitled "Industrial Wastewater Alternative Control Technology".
10.2 Solid and Other Aqueous Waste
Several of the wastewater treatment technologies available to comply with the landfills regulation will
generate solid and other aqueous waste. The costs for the disposal of these other waste residuals were
included in the compliance cost estimates prepared for the regulatory options. Solid wastes generated by
a number of the BPT, BCT, and BAT wastewater treatment technologies include sludge from clarifiers
10-3
-------
associated with biological treatment and chemical precipitation systems and backwash waters from
filtration systems.
In surveying both subcategories of this industry, EPA determined that it is common practice to dispose of
the sludges generated by the on-site wastewater treatment systems directly back into the landfills. This
practice eliminates the need for, and the costs associated with, off-site disposal. Analysis of sludge data
collected as part of this study also indicates that sludges generated by wastewater treatment systems at
landfills in the Subtitle D Non-Hazardous subcategory are non-hazardous, allowing them to be disposed
of at the landfill sites from which they are generated.
Waste sludge generated by wastewater treatment facilities at landfills in the Subtitle C Hazardous
subcategory may be a hazardous waste, depending upon factors such as the characteristics of the waste
deposited in the landfill and the design and operation of the wastewater treatment system. If listed
hazardous wastes, as per 40 CFR 261 Subpart D, are disposed of into the landfill, the resultant sludges
from the treatment of landfill generated wastewater will be considered a hazardous waste. Based upon the
"derived-from" rule found in 40 CFR 261.3(c)(2), the sludge will have the same RCRA waste code as the
waste in the landfill for monofills. For hazardous waste landfills which dispose of more than one type of
listed hazardous waste and generate a multi-source leachate, the sludge from treatment of the leachate will
have the F039 RCRA waste code. Sludges from a treated leachate at a landfill which handles only
characteristic wastes, as per 40 CFR 261 Subpart C, will need to be analyzed to determine whether it
exhibits any of the characteristics of a hazardous waste as per 40 CFR 261 Subpart C. EPA has
developed land disposal restrictions as found in 40 CFR 268. This regulation places restrictions on the land
disposal of wastes and specifies treatment standards that must be met before wastes can be land disposed.
For purposes of this regulation, EPA has assumed that dried sludges from facilities in the Subtitle C
Hazardous subcategory will be returned to the on-site landfill for disposal. Similarly, EPA has assumed
dried sludges from Subtitle D non-hazardous facilities will be returned to the on-site landfill for disposal.
10-4
-------
Listed or characteristically hazardous waste sludges are to meet applicable treatment standards prior to
disposal.
The increased amount of sludge created due to this regulation will be negligible in comparison to the daily
volumes of waste processed and disposed in a typical landfill, whether non-hazardous or hazardous. As
a result, the practice of on-site disposal has a minimal impact on landfill capacity. For example, based on
national estimates, the Subtitle D Non-Hazardous subcategory processed approximately 5,300 million tons
of waste in 1992. The BPT/BCT/B AT wastewater treatment options will generate approximately 0.0044
million tons per year of waste solids or only 8.3 x 10"5 percent of the volume of waste disposed into the
landfill. For the Subtitle C Hazardous subcategory, the BPT/BCT/B AT option will generate approximately
194 tons per year of solids, as compared to the national estimate of 550 million tons of waste processed,
which equates to 3.5 x 10"5 percent.
Filtration backwash waters are generally recycled to the beginning of the wastewater treatment system for
reprocessing. This practice eliminates the generation of a waste stream needing disposal.
10.3 Energy Requirements
The operation of wastewater treatment equipment results in the consumption of energy. EPA estimates that
the attainment of the BPT, BCT, and BAT standards will increase energy consumption by a very small
increment over present industry use. The treatment technologies that are the basis for the limitations and
standards are not energy-intensive, and the projected increase in energy consumption is primarily due to
the incorporation of components such as power pumps, mixers, blowers, power lighting and controls, and
heating devices. The associated energy costs are included in EPA's estimated operating costs for
compliance with the guideline presented in Chapter 9. For example, the BPT/BCT/B AT Option 2 for the
Subtitle D Non-Hazardous subcategory is estimated to consume 3,300 megawatt-hour per year
(Mwhr/year). This is equivalent to approximately 1,800 barrels per year of No.2 fuel oil, as compared to
the 1992 rate of consumption in the United States of 40.6 million barrels per year. The additional energy
10-5
-------
demand imposed by this regulatory option will represent an insignificant increase in the production or
importation of fuel oil. For the Subtitle C Hazardous subcategory, the regulatory option is estimated to
consume 37.3 Mwhr/yr or an equivalent 21 barrels per year of No.2 fuel oil.
10-6
-------
11.0 DEVELOPMENT OF EFFLUENT LIMITATIONS AND STANDARDS
This chapter presents the final effluent limitations guidelines and standards for the landfills point source
category. EPA bases the final effluent limitations upon the performance of selected wastewater treatment
systems at landfill facilities and develops limitations expressed as monthly-average and daily-maximum
concentrations. The following sections discuss the development of the numerical, technology-based
limitations:
• Development of Long-Term Averages, Variability Factors, and Effluent Limitations
• 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)
• Pretreatment Standards for New Sources (PSNS)
11.1 Development of Long-Term Averages, Variability Factors, and Effluent
Limitations
The section below presents a summary of the statistical methodology used in the calculation of effluent
limitations. (As explained in section 11.6, et.seq.. EPA decided not to establish pretreatment standards
for landfills). A more detailed explanation can be found in the "Statistical Support Document for the Final
Effluent Limitations Guidelines and Standards for the Landfills Point Source Category" (EPA-821-B-99-
007).
EPA bases effluent limitations for each subcategory on a combination of long-term average effluent
concentrations and variability factors that account for variation in treatment performance within a treatment
system overtime. The Agency developed variability factors and long-term averages from a database
11-1
-------
composed of individual daily measurements of treated effluent at landfills. EPA collected technology
performance data from field sampling efforts and from industry-supplied data provided in the Detailed
Monitoring Questionnaire. In Chapter 4, EPA presents a detailed description of each data source. While
EPA sampling data typically reflects the daily performance of a system over a 5-day period, industry-
supplied data for this guideline (collected through the Detailed Monitoring Questionnaire) reflected up to
three years of data. The monitoring data obtained through the Detailed Monitoring Questionnaire is unique
to each facility in terms of the number of parameters analyzed and the monitoring frequency. Several
facilities provided information for dozens of pollutants, while others provided data for only a few
parameters. Additionally, monitoring may have been performed weekly, monthly, or quarterly. Wherever
possible, when calculating effluent limitations, EPA used a combination of industry-supplied data and EPA
sampling data to better account for the variability of the treatment of landfill leachate over time.
EPA used these data to develop long-term average concentrations and variability factors, by pollutant and
technology option, for each subcategory. The Agency calculated the final limitations by multiplying long-
term average concentrations by the appropriate variability factors. The following paragraphs briefly
describe how EPA determined each of these values. As mentioned above, EPA presents the detailed
methodology and data in the Statistical Support Document.
11.1.1 Calculation of Long-Term Averages
For each pollutant selected for regulation (see Chapter 7), EPA calculated long-term average effluent
concentrations for each regulatory option and subcategory. The first step was to select representative
facilities from the EPA database for each option. In Section 11.2, EPA explains the criteria used in facility
selection. After selecting the facilities that best represented a technology option, EPA reviewed the influent
and effluent data supplied for each of the regulated pollutants. In calculating limitations, the Agency used
effluent data from EPA sampling episodes and Detailed Monitoring Questionnaires, but it did not use
effluent data from the Detailed Questionnaire. The pollutant data submitted in the Detailed Questionnaire
contained the average concentration, the minimum and maximum concentrations, and the number of
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samples, whereas EPA sampling data and the Detailed Monitoring Questionnaire consisted of individual
daily data. In developing limits, EPA calculated the long-term averages and variability factors using
individual daily data. Furthermore, summary data (like the data submitted in the Detailed Questionnaire)
may obscure the minimum detection levels used in the sampling data. The use of daily data (like the
Detailed Monitoring Questionnaire and EPA sampling data) in developing limitations allows EPA to account
for concentration values reported at or below the detection limits. EPA set observations below the sample-
specific detection level equal to the detection level for the purposes of calculating a facility-level long-term
average. In addition, in many cases, EPA considered reported averages from the Detailed Questionnaires
redundant because many facilities also reported the daily data from the Detailed Monitoring Questionnaire
for the same time period in 1992 and, therefore, EPA would not have used the data in the calculation of
limits. However, in determining whether a pollutant was present at treatable levels, EPA relied on data
from any of the three pollutant data sources: Detailed Questionnaire, Detailed Monitoring Questionnaire,
and EPA analytical sampling episodes. EPA used effluent data from a facility only if sufficient influent data
were available to establish the presence of treatable levels of pollutants. In addition, for each of the
regulated pollutants, the Agency analyzed all of the selected facilities to determine if the facility was utilizing
treatment technologies, apart from those selected as the technology option, that may provide significant
removals of that particular pollutant. For example, the data from a facility that employed carbon adsorption
(a treatment technology that was not part of a selected technology option) would not be used in the
calculation of the limit for a pollutant that may be treated by carbon adsorption. However, if an
intermediate data point that preceded carbon adsorption treatment were available for this facility, then EPA
did consider the use of that data point to characterize the performance of the treatment system up to that
point. Furthermore, EPA edited EPA sampling data according to the criteria outlined in Chapter 4, Section
4.9.
Once EPA selected the facilities and effluent data points, the Agency calculated the average effluent
concentration for each regulated pollutant at each facility. For facilities that EPA had data for both five-day
EPA sampling and industry-supplied Detailed Monitoring Questionnaires (representing data collected over
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the course of at least a year), EPA calculated long-term averages separately as long as the dates for the
two data sets did not overlap. Therefore, by using both data sets, the long-term average accounted for the
variability of leachate over a longer period of time.
The Agency estimated the long-term average for each regulated pollutant for each BPT/B AT facility by
fitting a modified delta-lognormal distribution to the daily concentration data. The modified delta-lognormal
distribution models the data as a mixture of non-detect observations and measured values that follow a
lognormal distribution. The Agency selected this distribution because of the following reasons: (l)thedata
for many analytes consisted of a mixture of non-detects and measured values that were approximately
lognormal, and (2) in cases where there are no non-detects, the distribution is equivalent to the usual two-
parameter lognormal. This is the same basic distributional model used by EPA in the final rulemakings for
the Organic Chemicals, Plastics and Synthetic Fibers (OCPSF; 40 CFRPart 414) and the Pulp and Paper
category (40 CFR Part 430) and for the proposed rulemaking for the Centralized Waste Treatment
industrial category (proposed 40 CFRPart 437, 64 FR 2280 January 13,1999). In the Pulp and Paper
and the Centralized Waste Treatment studies, the modified delta-lognormal distribution assumes that all
non-detects have a value equal to the reported sample-specific detection levels and that the detected values
follow a lognormal distribution. EPA again used this model as the basis of estimates of the long-term
average at a landfill facility. In the case of the OCPSF rule, EPA used the same basic model but the
reported non-detect values were set equal to the pollutant analytical minimum level. A more detailed
discussion of the modified delta-lognormal distribution can be found in the "Statistical Support Document
for the Final Effluent Limitations Guidelines and Standards for the Landfills Point Source Category" (EP A-
821-B-99-007).
After EPA developed the facility-level long-term averages for each regulated pollutant using the criteria
outlined above, the Agency determined the median of the facility-level long-term averages for each
regulated pollutant in each subcategory. The median of the facility-level long-term averages for each
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regulated pollutant was the long-term average used in the calculation of the effluent limitation as described
later in this section.
11.1.2 Calculation of Variability Factors
EPA calculated variability factors using the same data sets used to derive the long-term average values.
As with the calculation of the long-term averages, EPA fit the daily concentration data to a modified
delta-lognormal distribution. The Agency calculated separate variability factors for different averaging
periods (either 1 -day, 4-day, or 20-day averages). Thus, EPA applied different variability factors to daily
data (single measurements without averaging) and to monthly-average data based on four measurements
taken once per week ("4-day averages") or 20 measurements taken once each day, five days a week
throughout a month ("20-day average").
For those facility data sets that had at least four observations for a given regulated pollutant, including two
detected values, EPA used the modified delta-lognormal model to estimate daily and 4-day or 20-day
average variability factors. There were several instances where EPA could not calculate variability factors
from the landfills database because EPA measured fewer than two samples above the detection limit. In
these cases, the Agency transferred variability factors from biological treatment systems used in the final
rulemaking of the OCPSF guideline (40 CFR Part 414).
As stated above, in calculating the variability factors, EPA assumed a log-normal distribution of the data.
In addition, the Agency used the following:
• The 95th percentile to establish the maximum monthly average.
• The 99th percentile to establish the maximum for any one day.
EPA defines the daily variability factor as the ratio of the estimated 99th percentile of the distribution of
daily values to the estimated mean of the distribution. Similarly, the Agency defines the monthly variability
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factor as the estimated 95th percentile of the distribution of 4-day or 20-day averages divided by the
estimated mean of the monthly averages. EPA derived a monthly-average and daily-maximum variability
factor for each pollutant and for each regulatory option. For each subcategory, the Agency defined the
daily variability factor for each pollutant as the average of the facility-level daily variability factor. Likewise,
EPA defines the 4-day average variability factor for each pollutant as the average of the facility-level 4-day
average variability factors and the 20-day average variability factor for each pollutant as the average of the
facility-level 20-day average variability factors.
11.1.3 Calculation of Effluent Limitations
The Agency used the median long-term average and the average variability factor for each pollutant in the
calculation of the effluent limitations. For each subcategory, EPA calculated the daily-maximum limitations
by multiplying the median of the long-term average for a given pollutant by the average daily variability
factor for that pollutant. EPA calculated the monthly-maximum limitations by multiplying the median long-
term average for a given pollutant by the average 4-day or 20-day variability factors for that pollutant. The
Agency used twenty-day average limitations for the conventional pollutants, BOD5 and TSS, and four-day
average limitations for other nonconventional and toxic pollutants.
11.2 Best Practicable Control Technology Currently Available (BPT)
EPA promulgated BPT effluent limitations for the Subtitle D Non-Hazardous and Subtitle C Hazardous
subcategories. BPT effluent limitations control identified conventional, toxic, and nonconventional pollutants
when discharged from landfill facilities to surface waters of the U. S. Generally, EPA determines BPT
effluent levels based on the average of the best existing performance by facilities of various sizes, ages, and
unit processes within an industrial category or subcategory. In industrial categories where present practices
are uniformly inadequate, however, EPA may determine thatBPT requires higher levels of control than any
currently in place if the technology to achieve those levels can be practicably applied. BPT may be
transferred from a different category or subcategory. BPT normally focuses on end-of-process treatment
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rather than process changes or internal controls, except when these technologies are common industry
practice.
In addition, the Clean Water Act (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. This inquiry does not limit EPA's broad
discretion to adopt BPT limitations that are achievable with available technology unless the required
additional reductions are "wholly out of proportion to the costs of achieving such marginal level of
reduction." A Legislative History of the Water Pollution Control Act Amendments of 1972. p. 170.
Moreover, the inquiry does not require the Agency to quantify benefits in monetary terms. See e.g.
American Iron and Steel Institute v. EPA, 526 F. 2d 1027 (3rd Cir., 1975).
In assessing the costs relative to 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 developing guidelines, the Act does
not require or permit consideration of water quality problems attributable to particular point sources, or
water quality improvements in particular bodies of water. Therefore, EPA has not considered these factors
in developing the final limitations. See Weyerhaeuser Company v. Costle, 590 F. 2d 1011 (D.C. Cir.
1978).
In setting BPT limitations based on a treatment technology, EPA does not require the use of that technology
to treat landfill wastewater. Rather, to establish the limits, EPA has demonstrated that the concentration
limits are achievable based on a well-operated system using selected technologies. The technologies that
may be used to treat wastewater are left entirely to the discretion of the individual landfill operator, as long
as the numerical discharge limits are achieved.
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11.2.1 BPT Technology Options for the Subtitle D Non-Hazardous Subcategory
In the Agency' s engineering assessment of the best practicable control technology currently available for
treatment of wastewater from landfills, EPA first considered three technologies commonly in use by landfills
and other industries as options for BPT: chemical precipitation, biological treatment, and multimedia
filtration.
For its evaluation of chemical precipitation, EPA collected raw wastewater and treated effluent data from
several non-hazardous landfills employing this technology. Based on these data, EPA removed chemical
precipitation from further consideration as a BPT treatment option. While chemical precipitation is an
effective treatment technology for the removal of metals, non-hazardous landfills typically have low
concentrations of metals in treatment system influent wastewater. Observed metals concentrations were
typically not found at levels that would inhibit biological treatment or that would be effectively removed by
a chemical precipitation unit.
EPA sampling data collected at facilities in the Non-Hazardous subcategory showed relatively low levels
(less than 1 mg/L) of pollutant of interest metals in untreated landfill generated wastewater. Furthermore,
Table 11-1 presents several sources of performance data for metals removals in activated sludge systems
along with published biological treatment inhibition ranges and raw wastewater characteristics from the non-
hazardous facilities in the EPA database. Performance data for metals from biological treatment systems
were obtained from the National Risk Management Research Laboratory (NRMRL) Treatability Database
(formerly called the Risk Reduction Engineering Laboratory (RREL) Treatability Database), the 50-POTW
Study, and a sampling program conducted at twelve OCPSF facilities that have biological treatment
systems. Metal concentrations in the raw wastewater for this subcategory are below, or close to, the
published inhibition levels for biological treatment systems. A review of performance data indicates that
certain pollutant of interest metals, such as chromium and zinc, are removed by well-operated biological
treatment processes at relatively high rates. See Table 11-1.
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Based on this analysis, EPA concluded that pollutant of interest metals observed in the Non-Hazardous
subcategory generally are present in landfill generated wastewater at levels that should not effect the
operation and performance of a biological treatment system. Under these circumstances, biological
treatment removes the metals identified as pollutants of interest in the Non-Hazardous subcategory.
Therefore, EPA concluded that biological treatment is an adequate BPT control technology for pollutant
of interest metals in the Non-Hazardous subcategory.
Based on the above assessment, EPA developed the following BPT regulatory options. Chapter 8
discusses these two technology options in detail and Chapter 9 discusses the cost estimates developed for
these options.
Non-Hazardous Subcategory Option I: Biological Treatment
EPA first assessed the pollutant removal performance of equalization and biological treatment. EPA
evaluated this as Option I due to its effectiveness in removing the large organic loads commonly associated
with leachate. BPT Option I consists of aerated equalization followed by biological treatment. EPA
included various types of biological treatment such as activated sludge, aerated lagoons, and anaerobic and
aerobic biological towers or fixed film reactors in calculating limits for this option. The Agency based the
costs for Option I on the cost of aerated equalization followed by an extended aeration activated sludge
system and clarification, including sludge dewatering. Figure 11-1 presents a flow diagram of the treatment
system costed for Option I. Approximately thirty percent of the direct-discharging municipal solid waste
landfills employed some form of biological treatment, and fifteen percent had a combination of equalization
and biological treatment.
Non-Hazardous Subcategory Option II: Biological Treatment and Multimedia Filtration
The second technology option considered for BPT treatment of non-hazardous landfill wastewater was
equalization prior to biological treatment, followed by secondary clarification and multimedia filtration. EPA
evaluated this as Option II due to its effectiveness in removing the large organic loads and suspended solids
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commonly associated with leachate. Approximately nine percent of the direct discharging non-hazardous
facilities used the technologies described in Option n. EPA based cost estimates for Option n on the cost
of Option I plus a multimedia filtration system. Figure 11-2 presents a flow diagram of the treatment system
costed for this option.
Selected BPT Technology Option
EPA selected Option n, equalization prior to biological treatment followed by secondary clarification and
multimedia filtration, as the technology basis for BPT limitations for the Non-Hazardous landfills
subcategory. EPA selected Option n for the basis of BPT limitations because of the demonstrated ability
of biological treatment systems in controlling organics and the effectiveness of multimedia filtration in
removing TSS. EPA's decision to base BPT limitations on Option II treatment primarily reflects two
factors: the degree of effluent reductions attainable and the total cost of the treatment technologies in
relation to the effluent reductions achieved. In assessing BPT, EPA considered the age, size, process, other
engineering factors, and non-water quality impacts pertinent to the facilities treating wastes in this
subcategory. No basis could be found for identifying different BPT limitations based on age, size, process
or other engineering factors. Neither the age nor the size of the landfill facility will directly affect the
treatability of the landfill wastewater, as discussed in Chapter 5. For the non-hazardous landfills, the most
pertinent factors for establishing the limitations are costs of treatment and the level of effluent reductions
obtainable.
EPA has selected Option n based on the comparison of the two options in terms of total costs of achieving
the effluent reductions, pounds of pollutant removals, economic impacts, and general environmental effects
of the reduced pollutant discharges. BPT Option II removed significantly more pounds of conventional
pollutants than Option I with only a moderate associated cost increase. EPA estimated that BPT Option
E will cost $340,000 (1998 dollars) more annually than BPT Option I for an additional removal of 142,000
pounds of conventional pollutants (mainly TSS).
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Finally, EPA analyzed the costs of both options to determine the economic impact that this rule would have
on the Landfills industry. EPA's assessment showed that, under either option, only two facilities would
incur significant economic impacts. For this assessment, EPA defined significant economic impacts in two
different ways, depending on the ownership of the facility. For privately-owned facilities, significant
economic impacts exist when the facility's after-tax cash flow is negative following the addition of
compliance costs. For municipally-owned facilities, significant economic impacts occur when the ratio of
compliance costs to median household income are greater than one percent. The economic assessment
for the final rule is described in the "Economic Analysis for the Final Effluent Limitations Guidelines and
Standards for the Landfills Point Source Category." (EPA-821-B-99-005).
11.2.2 BPT Limits for the Subtitle D Non-Hazardous Subcategory
Selection of BPT Facilities
EPA based the final BPT effluent limitations for the Non-Hazardous subcategory on the average of the best
existing wastewater treatment systems. The first criterion used in the selection of the average of the best
facilities was effective treatment of BOD5. In selecting BPT facilities, EPA identified facilities that employed
either Option I or Option n technologies. Even though EPA selected Option II technologies as the basis
for developing the BPT effluent limitations, EPA assumed that very little additional BOD5 removal would
occur because of the multimedia filter employed in Option n and, therefore, facilities employing biological
treatment only (Option I) could achieve good removal of BOD5 and be considered BPT. However, in
determining the BPT effluent limitations for TS S, EPA only used the data from the best performers using
the entire BPT Option n technology (biological treatment plus a filter) because of the multimedia filtration
system's effectiveness in removing suspended solids.
There were 45 municipal solid waste landfill facilities (see Table 11-2) in the EPA database in the Non-
Hazardous subcategory that utilized a biological treatment system that was considered for BPT. Even
though both Subtitle D municipal solid waste landfills and non-municipal solid waste landfills make up the
Non-Hazardous subcategory, EPA only considered municipal solid waste facilities for selection as BPT
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for the Non-Hazardous subcategory because the wastewater at these landfills tends to contain a wider
array of pollutants than that found at Subtitle D non-municipal facilities. The pollutants found at the non-
municipal facilities tended to be a subset of the pollutants found at the municipal facilities. In fact, all nine
pollutants of interest for non-municipal facilities were also pollutants of interest for the municipal facilities
(see Chapter 7). In addition, EPA's data showed that the pollutants of interest present at non-municipal
facilities were present at concentrations similar to, or less than, the concentrations typically found at
municipal facilities. Therefore, EPA determined that a treatment system that can adequately control
pollutant discharges from a municipal solid waste landfill should also be able to control discharges at
Subtitle D non-municipal landfills. EPA discusses its reasons for establishing only one subcategory for non-
hazardous landfills in Chapter 5 and discusses alternative technology options and costs of these options in
Chapters 8 and 9, respectively.
In addition to the 45 non-hazardous municipal solid waste facilities identified as potential BPT, EPA also
evaluated one hazardous facility (16041) in the EPA database. This facility used biological treatment in the
form of a sequential batch reactor (SBR) to treat its landfill generated wastewater. The facility commingled
leachate from both non-hazardous and hazardous landfills prior to treatment by the SBR. In determining
whether it was reasonable to include a facility from the Hazardous subcategory as a potential BPT facility
in the Non-Hazardous subcategory, EPA evaluated two different factors. First, because the facility
accepted leachate from both hazardous and non-hazardous landfills, EPA sampling data showed that the
waste stream contained almost all of the pollutants of interest for the Non-Hazardous subcategory at similar
concentrations to those found in the non-hazardous landfill raw wastewater database (see Table 11-3).
At this facility, EPA sampling detected all but one of the 32 pollutants of interest for the Non-Hazardous
subcategory in the influent concentration (1,4-dioxane) and EPA did not include four others (barium,
disulfoton, hexavalent chromium, and n,n-dimethylformamide) in the analytical effort. Therefore, the
Agency determined that the raw wastewater concentrations for the non-hazardous pollutants of interest
from this hazardous facility were similar to those concentrations found at the non-hazardous facilities.
Second, the facility achieved good BOD5 removal using biological treatment equivalent to BPT Option I.
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Therefore, EPA concluded that a treatment system that can adequately control pollutant discharges from
a hazardous landfill should also be able to control discharges at non-hazardous landfills.
Based on the assessment above, there were 46 in-scope landfill facilities in the EPA database that
employed various forms of biological treatment considered for BPT for the Non-Hazardous subcategory.
EPA evaluated these 46 landfill facilities selected as potential BPT candidates to determine the performance
across the various types of biological treatment systems. To determine the best performers for biological
treatment EPA established a number of criteria. The first criterion used in the selection of the best facilities
was effective treatment of BOD5. Under this criterion, there were several reasons why a facility might be
eliminated from the selection of BPT facilities.
Of the 46 landfill facilities treating their wastewater with some form of biological treatment, only 26 facilities
provided BOD5 effluent data in their Detailed Questionnaire or Detailed Monitoring Questionnaire
submitted to EPA or in the data that EPA collected during a sampling episode performed at the facility.
EPA evaluated these data to assess the performance across the various biological systems. Two facilities,
16119 and 16123, provided carbonaceous BOD (CBOD) data rather than BOD5 data and, therefore,
EPA removed these facilities from further consideration. EPA eliminated the facilities reporting CBOD data
because the analytical results of the CBOD tests can differ from the BOD5 results, especially in cases where
ammonia is present in the wastewater. Table 11-4 lists the 20 facilities that EPA eliminated from further
consideration as BPT facilities since they did not supply BOD5 effluent data. Table 11-5 lists the treatment
in place at the 26 candidate BPT facilities in the Non-Hazardous subcategory that provided BOD5 effluent
data. Table 11-6 shows, for the 26 candidate BPT facilities, the baseline flow, the facility-average raw
wastewater BOD5 concentration, the facility-average effluent BOD5 concentration, the influent and effluent
BOD5 concentrations from Section C of the Detailed Questionnaire (DET) data, Detailed Monitoring
Questionnaire (DMQ) data, and EPA sampling episodes (ANL) data, and the reason (if any) why EPA
eliminated the facility as a BPT facility. EPA determined the average raw wastewater BOD5 concentration
and average effluent BOD5 concentration at a facility by calculating the flow-weighted average of the facility
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data available in Section C of the Detailed Questionnaire, the Detailed Monitoring Questionnaire, and the
data collected during the EPA sampling episode.
Because EPA based BPT limitations on the effectiveness of biological treatment, the Agency eliminated
facilities that used additional forms of treatment for BOD5 (other than biological treatment). EPA, therefore,
removed two sites (16099, 16125) using carbon treatment in addition to biological treatment from the list
of candidate BPT facilities. EPA eliminated another facility from consideration (16117) because it used
two separate treatment trains in treating its wastewater, one with biological treatment and the other with
chemical precipitation, before commingling the streams at the effluent sample point. After the elimination
of these three facilities, 23 potential BPT facilities remained in the EPA non-hazardous landfill database.
To ensure that the facilities were operating effective biological treatment systems, EPA evaluated the influent
concentrations of BOD5 entering the wastewater treatment systems to determine which facilities had influent
BOD5 concentrations that most closely resembled typical non-hazardous landfills. The median
concentration of BOD5 for non-hazardous landfills was 240 mg/L and the average concentration was 1,229
mg/L. EPA determined that facilities with BOD5 influent concentrations significantly lower than these values
would not be representative of typical wastewater concentrations found in the Non-Hazardous
subcategory. Therefore, EPA eliminated facilities where the influent BOD5 was below 100 mg/L. EPA
acknowledges that it is possible to operate a biological treatment system with influent BOD5 concentrations
lower than 100 mg/L. In fact, as can be seen in Table 11-6, four of the remaining candidate BPT facilities
had influent BOD5 concentrations much less than 100 mg/L (16077, 16093, 16097, and 16170) and
operated biological treatment systems. Three of these four (16077, 16093, 16097) achieved BOD5
effluent concentrations below the BPT effluent limit despite low influent BOD5 concentrations. However,
EPA did receive a significant number of comments on the proposal stating that the biological treatment
option selected as BPT was infeasible for treatment of particular types of landfill leachate (ash monofill
wastewater in particular) due to its low organic content. The BOD5 raw wastewater data submitted by
some of these commenters was below 10 mg/L. The Agency acknowledges that in many of these cases
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(such as where BOD5 is less than 10 mg/L), the concentration of organic material in the raw wastewater
is too low to support biological treatment. Because the guidelines do not require the installation of any
particular technology to meet the limitations, facilities remain free to use whatever technology they choose
as long as these technologies can meet the limitations. In response to comments concerning the feasibility
of biological treatment for certain types of monofills with very low BOD5in their raw leachate, the Agency
developed costs for low BOD5 facilities in the database for alternative, non-biological treatment such as
breakpoint chlorination, granular activated carbon, and iron co-precipitation. These alternate forms of non-
biological treatment are discussed in Chapter 8 and their associated costs presented in Chapter 9. EPA's
decision not to further subcategorize the Non-Hazardous landfill subcategory is discussed in Chapter 5.
Therefore, as a result of the influent BOD5 greater than 100 mg/L edit, EPA did not consider four facilities
(16077, 16093, 16097, and 16170) for BPT.
EPA eliminated eight other facilities (16048,16049,16052, 16065, 16161, 16164, 16171, and 16176)
from BPT consideration because they did not supply BOD5 influent data (from any data source). EPA did
not select two facilities (16127 and 16129) because their raw wastewater streams consisted primarily of
non-contaminated storm water or contaminated ground water, which are flows that this regulation does not
cover. As discussed in Chapter 6, the Agency did not use monitoring data to characterize landfill generated
wastewater from facilities where out-of-scope wastewater contributed greater than 15 percent of the total
wastewater flow. Facility 16129 treated a combined raw wastewater influent stream consisting of 92
percent ground water and 7 percent leachate, and facility 16127 treated a combined raw wastewater
influent stream consisting of 70 percent storm water and 30 percent leachate. After elimination of these
facilities, a total of 9 candidate BPT facilities remained.
The final requirement for BPT selection in the Non-Hazardous landfill subcategory was that the biological
treatment system at the facility had to achieve a BOD5 effluent concentration less than 50 mg/L. EPA
determined that facilities not able to maintain an effluent concentration below 50 mg/L were not operating
their biological system effectively. Two of the remaining 9 facilities (16088 and 16165) did not achieve
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BOD5 effluent concentrations of less than 50 mg/L, leaving seven facilities in the database. The site-
identification numbers for the seven facilities selected as BPT are 16041, 16058, 16118, 16120, 16122,
16132, and 16253.
The seven facilities that met all of the BPT criteria employed various types of biological treatment systems,
including activated sludge, a sequential batch reactor, aerobic and anaerobic biological towers or fixed film,
and aerated ponds or lagoons. Most of the facilities employed equalization tanks in addition to the
biological treatment, while several facilities also employed chemical precipitation and neutralization in their
treatment systems. Clarification or sedimentation stages followed the biological treatment systems. Table
11-7 shows the treatment technologies in-place at the facilities selected as BPT for the Non-Hazardous
subcategory. EPA used all seven facilities employing well-operated biological treatment systems to
calculate the effluent limitations for BOD5. The average influent BOD5 concentrations to these seven
treatment systems ranged from 150 mg/L to 7,600 mg/L and, as mentioned above, all of the average
effluent concentrations for these seven facilities were below 50 mg/L.
While the BOD5 edits discussed above ensure good biological treatment and a basic level of TSS removal,
treatment facilities meeting this level may not necessarily be operated for optimal control of TSS. To
ensure that the effluent limitation developed for TSS reflects proper control, EPA established additional
editing criteria for TSS.
EPA developed two criteria for editing TSS performance data. In addition to achieving the BOD5 criteria
cited above, EPA required that the facility employ technology sufficient to ensure adequate control of TSS,
that is, a sand or multimedia filtration system. Three of the seven well-operated biological systems (16120,
16122,16253) used sand or multimedia filters as a polishing step for additional control of suspended solids
prior to discharge.
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The second factor EPA considered was whether the treatment system achieved an effluent TSS
concentration less than or equal to 100 mg/L. EPA selected treatment facilities meeting these criteria as
the average of the best existing performers for TSS. Table 11-8 lists the baseline flow, the facility-average
raw wastewater TSS concentration, the facility-average effluent TSS concentration, the influent and effluent
TSS concentrations from Section C of the Detailed Questionnaire (DET) data, the Detailed Monitoring
Questionnaire (DMQ) data, and the EPA sampling episode (ANL) data for the seven facilities selected as
BPT in the Non-Hazardous subcategory. EPA determined the average raw wastewater TSS concentration
and average effluent TSS concentration at a facility by calculating the flow-weighted average of the facility
data available in Section C of the Detailed Questionnaire, the Detailed Monitoring Questionnaire, and the
data collected during the EPA sampling episode. All three facilities that employed a sand or multimedia
filtration system (16120, 16122, and 16253) achieved an effluent TSS concentration far less than 100
mg/L, and therefore EPA included these among the best existing performers for TSS. Although facility
16122 meets the TSS editing criteria, EPA eliminated it from further consideration as BPT for TSS because
of potential settling of TSS in aerated tanks immediately prior to the filters that are not part of the selected
BPT option. Therefore, EPA selected the remaining two facilities (16120 and 16253) as "average of the
best" existing performers for TSS and based the TSS limitations on these two facilities.
EPA determined that the use of a multimedia filter after biological treatment with secondary clarification
achieved significantly lower long-term average effluent concentrations of TSS than the other BPT facilities
that did not employ multimedia filters after secondary clarification. As shown in Table 11-8, the two
facilities (16120 and 16253) that employed multimedia filters after biological treatment with clarification
achieved an average effluent TSS concentration of 19.5 mg/L whereas the other BOD5 BPT facilities
without multimedia filters achieved an average effluent concentration of 69.1 mg/L.
Development of BPT Limitations
EPA based the effluent limitations for BOD5 on all seven non-hazardous BPT facilities; however, the BPT
facilities often did not supply data for all of the regulated pollutants. Therefore, EPA used the data available
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from the seven non-hazardous BPT facilities to develop the BPT limitations for ammonia, TSS, alpha
terpineol, benzoic acid, p-cresol, phenol, and zinc. EPA applied additional editing criteria to the seven BPT
facilities to select the "average of the best" existing performers for each of the regulated pollutants. The
editing criteria applied to the available data were as follows:
• EPA only used data from the seven facilities which passed the BOD5 criteria in the calculation of
limits (16041, 16058, 16118, 16120, 16122, 16132, and 16253).
• EPA only used data from facilities that passed the TSS criteria in the calculation of TSS limits
(16120 and 16253).
• EPA did not use effluent data from the Detailed Questionnaire (16000 series data) in the calculation
of effluent limits. The pollutant data submitted in the Detailed Questionnaire contained the average
concentration, the minimum and maximum concentrations, and the number of samples, whereas
EPA sampling data and the Detailed Monitoring Questionnaire consisted of individual daily data.
In developing limits, EPA calculated the long-term averages and variability factors using individual
daily data. Furthermore, summary data (like the data submitted in the Detailed Questionnaire) may
obscure the minimum detection levels used in the sampling data. The use of daily data (like the
Detailed Monitoring Questionnaire and EPA sampling data) in developing limitations allows EPA
to account for concentration values reported at or below the detection limits. In addition, in many
cases, EPA considered reported averages from Detailed Questionnaires redundant because many
facilities also reported the daily data from the Detailed Monitoring Questionnaire for the same time
period in 1992 and, therefore, EPA would not have used the data in the calculation of limits.
However, EPA did use, in cases where no other influent data were available, influent data from
the Detailed Questionnaire to show that a landfill had treatable levels of a pollutant in the
wastewater.
Since chemical precipitation was not part of the selected BPT Option for the Non-Hazardous
subcategory, EPA did not use data from BPT facilities employing chemical precipitation when
developing limitations for metals. Therefore, since zinc was the only metal regulated, EPA did not
include zinc effluent data from four of the seven facilities that employed chemical precipitation in
the calculation of zinc limitations (16118, 16120, 16122, and 16253). In the Non-Hazardous
subcategory, EPA determined that the levels of zinc found in raw wastewater were at low enough
concentrations that chemical precipitation was not a necessary treatment technology. In the Non-
Hazardous landfill subcategory, EPA's sampling, for the most part, did not find zinc raw
wastewater concentrations that would inhibit biological treatment. In addition, raw wastewater
concentrations of zinc were typically less than 1 mg/L, a level that would not be effectively removed
by a chemical precipitation system.
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• EPA did not use facility data demonstrating zero or negative percent removals in the calculation of
limits. No facility data in the Non-Hazardous subcategory met this criterion.
• EPA did not include data from facility 16120 in the calculation of ammonia limitations because the
treatment system included air stripping.
• EPA only used effluent data if sufficient influent data were available to establish the presence of
treatable levels of pollutants. The Agency only used effluent data in calculating limits if influent data
for a given pollutant were available for a facility. In cases where a facility supplied effluent data for
a particular pollutant but did not supply influent data in the Detailed Monitoring Questionnaire (or
supplied influent data below a treatable level), EPA used the effluent data so long as influent data
were available from the EPA sampling episode or the Detailed Questionnaire at a concentration
above a treatable level. However, EPA did not use effluent data from EPA sampling episodes to
calculate limits unless matching influent data from the EPA sampling episode were at concentrations
above treatable levels.
For the EPA sampling episode at facility 16122, EPA did not use the effluent data collected from
sample point 08 in the calculation of the limits because this sample point was located after two
aerated holding tanks operated in parallel just prior to the multimedia filter (which was not part of
the selected treatment option after biological treatment). Instead, EPA used data from sample
point 07 (after biological treatment but before aeration in the holding tanks) in the calculation of
limits for the final rule. In addition, EPA did not use effluent data from the Detailed Questionnaire
and Detailed Monitoring Questionnaire from facility 16122 in the calculation of limits because the
data were from sample point 03, which is located after the aeration tanks.
In Table 11-9, EPA presents the non-hazardous BPT facilities and sample points used to calculate the non-
hazardous BPT limitations for conventional, nonconventional, and toxic pollutants. Table 11-10 presents
the non-hazardous BPT facilities and sample points that EPA did not use to calculate the BPT limitations
and the reason for their exclusion. Table 11-11 presents EPA's final BPT limitations for the Non-
Hazardous subcategory.
Tables 11-12 and 11-13 present the national estimates of the pollutant of interest reductions for the
BPT/BAT options for the municipal solid waste Subtitle D landfills and non-municipal Subtitle D landfills,
respectively. Table 11-14 and Table 11-15 summarize the estimated amount of pollutants discharged
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annually from direct discharging municipal landfills and direct-discharging non-municipal landfills,
respectively, before and after the implementation of BAT for the Non-Hazardous subcategory.
EPA based all of the estimated costs on a facility installing aerated equalization tanks followed by an
activated sludge biological system with clarification and a multimedia filter and included a sludge dewatering
system. On a national scale, EPA estimates that the implementation of the BAT effluent limitations will
require a capital cost of $18.87 million and annual operating cost of $6.50 million resulting in a total
annualized cost of $7.64 million (post-tax) for the Subtitle D Non-Hazardous subcategory (1998 dollars).
11.2.3 BPT Technology Options for the Subtitle C Hazardous Subcategory
EPA's survey of the hazardous landfills industry identified no in-scope respondents that were classified as
direct dischargers. All of the hazardous landfills within the scope of the rule are either indirect or
zero/alternative dischargers. Consequently, EPA could not evaluate any treatment systems in-place at
direct-discharging hazardous landfills for establishing BPT effluent limitations. Therefore, EPA relied on
information and data from widely available treatment technologies in use at hazardous landfill facilities
dischargingindirectlyandatnon-hazardouslandfills discharging directly and indirectly, termed "technology
transfer." EPA concluded that the technology in-place at some indirect hazardous landfills is appropriate
to use as the basis for regulation of direct dischargers because the wastewater generated at hazardous
waste landfills discharging directly would be similar in character to the wastewater from indirect-discharge
hazardous waste landfills.
Based on this assessment, EPA developed the following BPT regulatory options for establishing BPT
effluent limitations for the Hazardous landfill subcategory: 1) aerated equalization followed by chemical
precipitation with clarification and multimedia filtration, 2) aerated equalization followed by chemical
precipitation with clarification, biological treatment with secondary clarification, and multimedia filtration,
and 3) zero or alternative discharge. Chapter 8 discusses these options in detail and Chapter 9 discusses
the cost estimates developed for these options.
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Hazardous Subcategory Option I: Chemical Precipitation and Multimedia Filtration
EPA first assessed the pollutant removal performance of equalization, chemical precipitation, and
multimedia filtration. EPA evaluated chemical precipitation as a treatment technology because of the metals
concentrations typically found in hazardous landfill leachate and the efficient metals removals achieved
through chemical precipitation. EPA also evaluated multimedia filtration as an appropriate technology to
remove additional levels of metals and TSS following chemical precipitation.
Hazardous Subcategory Option IT: Chemical Precipitation. Biological Treatment, and Multimedia Filtration
The second technology option considered for BPT treatment of hazardous landfill wastewater was aerated
equalization, chemical precipitation, and biological treatment with secondary clarification, followed by
multimedia filtration. EPA evaluated these technologies as Option II because of the effectiveness of
chemical precipitation in removing metals and the effectiveness of biological treatment in removing the high
organic loads present in the leachate. The Agency considered multimedia filtration to be an appropriate
technology for consideration because of its effectiveness in removing TSS and metals remaining after
primary or secondary clarification.
Hazardous Subcategory Option III: Zero or Alternative Discharge
Finally, EPA considered a zero or alternative discharge option as BPT Option III because a significant
segment of the industry is currently not discharging wastewater to surface waters or to POTWs. The zero
or alternative disposal option would require facilities to dispose of their wastewater in a manner that would
not result in wastewater discharge to a surface water or a POTW.
Methods of achieving zero or alternative discharge currently in use by hazardous landfills are deep well
injection, solidification, and contract hauling of wastewater to a Centralized Waste Treatment (CWT)
facility or to a landfill wastewater treatment facility. Thirty seven facilities are estimated to inj ect landfill
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wastewater underground on site, 103 facilities send their wastewater to a CWT or landfill treatment system,
and one facility solidifies wastewater.
Selected BPT Technology Option
EPA selected Option II, aerated equalization and chemical precipitation followed by biological treatment
with secondary clarification and multimedia filtration, as the technology basis for BPT limitations for the
Hazardous landfills subcategory. EPA selected Option n because of the demonstrated ability of biological
treatment and multimedia filtration in removing the large organic loads and suspended solids associated
with hazardous leachate. Metals in the raw wastewater will be removed prior to the biological treatment
system using chemical precipitation. Figure 11-3 presents a flow diagram of the treatment system for this
option.
EPA eliminated Option I from consideration because it did not control organic pollutants effectively. In
addition, based on consideration of comments submitted on the proposal, EPA decided not to establish
BPT limitations based on zero or alternative discharge. EPA concluded that, for the industry as a whole,
zero or alternative discharge options are either not viable or the cost is wholly disproportionate to the
pollutant reduction benefits and, thus, not "practicable." Furthermore, the commenters' submissions
support EPA's decision to reject zero or alternative discharge as the technology basis for BPT (or BAT)
limitations for hazardous landfills. While EPA supports the use of zero or alternative discharges particularly
where it does not result in media transfer of pollutants, many of the available zero discharge options have
identifiable shortcomings, such as transfer of waste residuals to another media (e.g., ground water, soil) or
the availability of an alternative disposal option only in certain geographic locations.
For example, one demonstrated alternative disposal option for large wastewater flows is underground
injection. However, this is not considered a practically available option on a nationwide basis because it
is not allowed in many geographic regions of the country where landfills may be located. These restrictions
may preclude underground injection at a given landfill. In such circumstances, landfills would need to resort
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to contract hauling to a CWT facility. Unless the CWT itself were a zero discharge facility, the ultimate
result would be treatment and discharge to surface waters or a POTW following waste treatment that may
be no more effective than that provided on site. This might result in substantial transportation costs for the
landfill and associated non-water quality environmental impacts (e.g., truck emissions) resulting in no net
reduction in the discharge of pollutants. EPA's survey demonstrated that only landfills with relatively low
flows (under 500 gpd) currently contract haul their wastewater to a CWT. The costs of contract hauling
are directly proportional to the volume and distance over which the wastewater must be transported,
generally making it excessively costly to send large wastewater flows to a CWT, particularly if it is not
located nearby.
EPA evaluated the cost of requiring all hazardous landfills to achieve zero or alternative discharge status.
For the purposes of costing, EPA assumed that a facility would have to contract haul wastewater off site
because it may be impossible to pursue other zero or alternative discharge options. EPA concluded that
the cost of contract hauling off site for high flow facilities was unreasonably high and disproportionate to
the removals potentially achieved. In addition, EPA concluded that the wastewater shipped to a CWT will
typically receive treatment equivalent to that promulgated, and that zero/alternative discharge requirements
would result in additional costs to discharge without greater removals for hazardous landfill wastewater.
To calculate costs for this option, EPA estimated that all facilities currently discharging to a POTW would
have to contract haul wastewater approximately 500 miles to a CWT facility. EPA based cost estimates
on a $0.35 per gallon disposal cost at a CWT facility, and $3.00 per loaded mile for transport. EPA
estimated the total cost to the industry at approximately $30 million dollars.
11.2.4 BPT Limits for the Subtitle C Hazardous Subcategory
Selection of BPT Facilities
EPA based the BPT effluent limitations for the Hazardous subcategory upon the average of the best exi sting
landfill facilities. Based on the characteristics of hazardous landfill leachate and on an evaluation of
appropriate technology options, the Agency selected aerated equalization, chemical precipitation, and
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biological treatment followed by secondary clarification and multimedia filtration as BPT technology for the
Hazardous subcategory. As previously noted, EPA relied on data from both hazardous and non-hazardous
facilities to develop the limitations for this subcategory. Because there are currently no hazardous landfills
discharging directly, EPA used data from indirectly discharging facilities to develop the limitations.
Apart from the 139 hazardous, zero, or alternative discharge facilities estimated to be in the U.S. based
on the responses to the Detailed Questionnaire, EPA identified only three other hazardous respondents
(16017,16041, and 16087) to the Detailed Questionnaire, all of which discharged indirectly to POTWs.
Facility 16017 only collected and treated landfill gas collection condensate which was very dilute, had low
flows, and required only minimal treatment (neutralization using ammonia) prior to discharge.
Consequently, EPA did not consider this facility as appropriate for establishing BPT limitations. The two
remaining facilities (16041 and 16087) both had treatment systems in-place that achieved very good
pollutant reductions. The treatment at facility 16087 consisted of equalization and a chemical precipitation
unit followed by an activated sludge system with secondary clarification; the other facility (16041) utilized
equalization tanks and a sequential batch reactor. The treatment systems in-place at these indirect-
discharging hazardous facilities achieved low effluent concentrations with average removals of 88 to 98
percent of organic toxic pollutants, and 55 to 80 percent of metal pollutants. Thus, EPA concluded that
both facilities should be used in the development of the Hazardous subcategory BPT limitations for
nonconventional and toxic pollutants. Table 11-16 presents the treatment technologies in-place at the
facilities selected as BPT for the Hazardous subcategory.
Development of BPT Effluent Limitations
As discussed above, because there were no direct-discharging hazardous facilities in EPA's database, the
Agency relied on technology transfer to establish BPT effluent limitations, using performance data from
treatment technologies at hazardous landfill facilities discharging indirectly and non-hazardous facilities
discharging directly and indirectly. EPA used the data from the two hazardous indirect-discharging facilities
(16041 and 16087) to calculate the BPT effluent limitations for the following toxic pollutant parameters:
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alpha terpineol, aniline, arsenic (total), benzoic acid, chromium (total), naphthalene, p-cresol, phenol,
pyridine, and zinc (total). Chapter 7 discusses the methodology used to select toxic pollutants for
regulation.
EPA concluded that establishing BPT effluent limitations for ammonia, BOD5, and TSS based only on
performance data from these two hazardous indirect-discharging facilities was not appropriate. In general,
removal of classical pollutant parameters such as ammonia, BOD5, and TSS in treatment systems at
indirect-discharging facilities is incidental to toxic pollutant removals, since these pollutants are a major
component of domestic sewage and are adequately treated at POTWs. Since removals of ammonia,
BOD5, and TSS at these two hazardous indirect-discharging facilities ranged from poor to adequate, EPA
concluded that the use of performance data from BPT facilities in both the Hazardous and Non-Hazardous
subcategories that employed variations of biological treatment would result in more representative
hazardous BPT effluent limitations for these pollutants.
EPA supplemented the Hazardous subcategory data for these three pollutants with data from non-
hazardous landfill facilities. For calculation of BPT effluent limitations for BOD5, EPA supplemented the
performance data from the two hazardous indirect-discharging facilities (16041 and 16087), with
performance data from direct- and indirect-discharging non-hazardous facilities (16058, 16118, 16120,
16122,16132 and 16253) to obtain a more representative mix of facilities. For calculation of BPT effluent
limitations for TSS, because neither of the treatment systems for the two hazardous indirect-discharging
facilities included multimedia filtration to control TSS discharges, EPA used technology transfer to establish
TSS limitations, using performance data from two non-hazardous facilities (16120 and 16253) that passed
the TSS effluent editing criteria for the BPT effluent limitations for Non-Hazardous subcategory.
For calculation of BPT effluent limitations for ammonia, since the treatment system for only one of the two
hazardous indirect-discharging facilities was considered a good performer (16041), EPA supplemented
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these data with performance data from two non-hazardous BPT facilities (16122 and 16132) that were
considered good performers in the Non-Hazardous subcategory.
In addition, EPA applied editing criteria to the data to determine the final list of BPT facilities and sample
points used to develop the BPT limits for the Hazardous subcategory. The editing criteria applied to the
available data were as follows:
EPA only used data from the two hazardous facilities selected as BPT (16041 and 16087) in the
calculation of limits for toxic pollutants (except ammonia).
EPA used technology transfer from the Non-Hazardous subcategory in establishing limits for
BOD5, TSS, and ammonia.
EPA only used data from facilities that passed the TSS criteria in the calculation of TSS limits
(16120 and 16253).
EPA did not use effluent data from the Detailed Questionnaire (16000 series data) in the calculation
of effluent limits. The pollutant data submitted in the Detailed Questionnaire contained the average
concentration, the minimum and maximum concentrations, and the number of samples, whereas
EPA sampling data and the Detailed Monitoring Questionnaire consisted of individual daily data.
In developing limits, EPA calculated the long-term averages and variability factors using individual
daily data. Furthermore, summary data (like the data submitted in the Detailed Questionnaire) may
obscure the minimum detection levels used in the sampling data. The use of daily data (like the
Detailed Monitoring Questionnaire and EPA sampling data) in developing limitations allows EPA
to account for concentration values reported at or below the detection limits. In addition, in many
cases, EPA considered reported averages from Detailed Questionnaires redundant because many
facilities also reported the daily data from the Detailed Monitoring Questionnaire for the same time
period in 1992 and, therefore, EPA would not have used the data in the calculation of limits.
However, EPA did use, in cases where no other influent data were available, influent data from the
Detailed Questionnaire to show that a landfill had treatable levels of a pollutant in the wastewater.
EPA did not use facility data demonstrating zero or negative percent removals in the calculation of
limits.
EPA did not include data from facility 16120 in the calculation of ammonia limitations because the
treatment system included air stripping.
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EPA only used effluent data if sufficient influent data were available to establish the presence of
treatable levels of pollutants. The Agency only used effluent data in calculating limits if influent data
for a given pollutant were available for a facility. In cases where a facility supplied effluent data for
a particular pollutant but did not supply influent data in the Detailed Monitoring Questionnaire (or
supplied influent data below a treatable level), EPA used the effluent data so long as influent data
were available from the EPA sampling episode or the Detailed Questionnaire at a concentration
above a treatable level. However, EPA did not use effluent data from EPA sampling episodes to
calculate limits unless matching influent data from the EPA sampling episode are at concentrations
above treatable levels.
Table 11-17 presents the hazardous BPT facilities and sample points used to calculate the hazardous BPT
limitations for conventional, nonconventional, and toxic pollutants. Table 11-18 presents the hazardous
BPT facilities and sample points EPA did not use to calculate the BPT limitations and the reason for their
exclusion. In Table 11-19, EPA presents the final BPT limitations for the Hazardous subcategory.
Since there are no direct discharging hazardous landfills in the EPA database, EPA could not estimate
pollutant reductions as a result of the regulation and the average facility costs for implementation of the
regulation.
11.3 Best Conventional Pollutant Control Technology (BCT)
BCT limitations control the discharge of conventional pollutants from direct dischargers. Conventional
pollutants include BOD, TSS, oil and grease, and pH. BCT is not an additional limitation, but rather
replaces BAT for the control of conventional pollutants. To develop BCT limitations, EPA conducts a
cost-reasonableness evaluation, which consists of a two-part cost test: 1) the POTW test and 2) the
industry cost-effectiveness test.
In the POTW test, EPA calculates the cost per pound of conventional pollutants removed by industrial
dischargers in upgrading from BPT to a BCT candidate technology and then compares this to the cost per
pound of conventional pollutants removed in upgrading POTWs from secondary to tertiary treatment. The
upgrade cost to industry, which is represented in dollars per pound of conventional pollutants removed,
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must be less than the POTW benchmark of $0.25 per pound (in 1976 dollars). In the industry cost-
effectiveness test, the ratio of the incremental BPT to BCT cost, divided by the BPT cost for the industry,
must be less than 1.29 (i.e. the cost increase must be less than 29 percent).
For the final rule, EPA established effluent limitations guidelines and standards equivalent to the BPT
guidelines for the conventional pollutants covered under BPT for both subcategories. In developing BCT
limits, EPA considered whether there are technologies that achieve greater removals of conventional
pollutants than for BPT and whether those technologies are cost-reasonable according to the BCT cost-
reasonableness evaluation. In each subcategory, EPA identified no technologies that can achieve greater
removals of conventional pollutants than those promulgated for BPT that are also cost-reasonable under
the BCT cost-reasonableness evaluation, and, accordingly, EPA established BCT effluent limitations equal
to the BPT effluent limitations guidelines and standards.
11.4 Best Available Technology Economically Achievable (BAT)
The factors considered in establishing a BAT level of control include the following: the age of process
equipment and facilities, the processes employed, process changes, the engineering aspects of applying
various types of control techniques to the costs of applying the control technology, non-water quality
environmental impacts such as energy requirements, air pollution and solid waste generation, and such other
factors as the Administrator deems appropriate (Section 304(b)(2)(B) of the Act). In general, the BAT
technology level represents the best existing economically achievable performance among facilities with
shared characteristics. BAT may include process changes or internal plant controls which are not common
in the industry. BAT may also be transferred from a different subcategory or industrial category.
EPA promulgated BAT effluent limitations for both landfill subcategories based upon the same technologies
evaluated and selected for BPT. The BAT effluent limitations control identified toxic and nonconventional
pollutants discharged from facilities. EPA did not identify any additional technologies beyond BPT that
could provide additional toxic pollutant removals and that are economically achievable.
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11.4.1 BAT Limits for the Subtitle D Non-Hazardous Subcategory
EPA evaluated reverse osmosis technology as a potential option for establishing BAT effluent limits more
stringent than BPT for the control of toxic pollutants for the Non-Hazardous subcategory. EPA considered
reverse osmosis for evaluation because of its effective control of a wide variety of toxic pollutants in
addition to controlling conventional and nonconventional parameters.
EPA evaluated BAT treatment options as an increment to the baseline treatment technology used to
develop BPT limits. Therefore, the BAT Option III consisted of BPT Option II (biological treatment
followed by multimedia filtration) followed by a single-stage reverse osmosis unit. Figure 11-4 presents
a flow diagram of the treatment system costed for BAT Option III. EPA acknowledges that reverse
osmosis treatment of landfill wastewater does not require biological pretreatment. However, in evaluating
potential BAT options, EPA considers the removal and costs of BAT in addition to the selected BPT
option. Therefore, to analyze the incremental removals and incremental costs, EPA evaluated the reverse
osmosis system after the selected BPT option (biological treatment and multimedia filtration).
EPA promulgated limits based on a BAT technology that is equivalent to the BPT technology. After an
assessment of costs and pollutant reductions associated with reverse osmosis, EPA concluded that limits
should not be established based on more advanced treatment technology than the BPT technology. EPA
concluded that a biological system followed by multimedia filtration would remove the maj ority of toxic
pollutants, leaving the single-stage reverse osmosis to treat the very low levels of pollutants that remained.
In the Agency's analysis, BPT Option n removed 170,000 pounds of toxic pollutants per year, whereas
BAT Option in removed 172,000 pounds of toxic pollutants per year. The small incremental removal of
pounds of toxic pollutants achieved by BAT Option in was not justified by the large cost for the reverse
osmosis treatment system. According to EPA's costing analysis, the BAT Option HI, consisting of BPT
Option n plus reverse osmosis, was estimated to cost the Landfills industry $130.3 million in capital costs
(1998 dollars) and $45.95 million in annualized costs (pre-tax, 1998 dollars). By contrast, the selected
option, BPT Option II, had capital costs of $18.87 million (1998 dollars) and annualized costs of $7.64
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million (post-tax, 1998 dollars). It should be noted that reverse osmosis was much more effective than the
BPT Option n at removing the often-high quantities of dissolved metals such as iron, manganese, and
aluminum. However, these parameters were not included in the calculation of pound-equivalent reductions
due to their use as treatment chemicals.
Table 11-20 compares the long-term averages achieved by BPT Option II, consisting of equalization,
biological treatment, and multimedia filtration, to the long-term averages achieved by the reverse osmosis
treatment system. For the long-term average comparison, the effluent concentrations are from the reverse
osmosis treatment system sampled by EPA and described in Section 8.2.1.5, including the flow diagram
in Figure 8-30. Table 11-20 shows BPT Option II achieves very low effluent concentrations that are
similar to the effluent concentrations achieved by the reverse osmosis system.
Several commenters on the proposal supported EPA's decision to reject reverse osmosis as the selected
technology option. While EPA rej ected reverse osmosis as the basis for BAT limitations because it was
very expensive and achieved very little additional removal of pollutant, other technical factors also
supported this decision. EPA agrees with the commenters that there may be additional site-specific costs
associated with the operation of reverse osmosis systems at landfills that it could not directly factor into its
cost analysis. EPA found that it was difficult to evaluate potential operating and concentrate-disposal
problems and the associated potential increase in the cost of operating a reverse osmosis system at a
landfill. The fact that reverse osmosis is a technology that concentrates rather than destroys pollutants i s
an important consideration. These concentrates still need to be treated and disposed and, as noted by one
commenter, some states may not allow them to be recycled back into the landfill. Further, recirculation
may inhibit rather than stimulate anaerobic decomposition of the landfilled wastes. While the sludges
generated by chemical precipitation and biological treatment require minimal treatment prior to disposal,
reverse osmosis concentrates may require additional costly treatment steps prior to final disposal.
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11.4.2 BAT Limits for the Subtitle C Hazardous Subcategory
As stated in the BPT analysis, EPA's survey of the hazardous landfills industry identified no in-scope
respondents which were classified as direct dischargers. All of the hazardous landfills in the EPA survey
were indirect or zero or alternative dischargers. Therefore, the Agency based BPT limitations on
technology transfer and treatment systems in place for indirect dischargers in the Hazardous subcategory
and on treatment systems in-place for BPT facilities in the Non-Hazardous subcategory. In EPA's
engineering assessment of the possible BAT technology for direct-discharging hazardous facilities, EPA
evaluated the same three potential technology options as those evaluated for BPT for the Hazardous landfill
subcategory. These technology options were 1) aerated equalization followed by chemical precipitation
with clarification and multimedia filtration, 2) aerated equalization followed by chemical precipitation with
clarification, biological treatment with secondary clarification, and multimedia filtration, and 3) zero or
alternative discharge, as explained above. EPA has identified no other technologies that would represent
BAT level of control for this industry.
EPA determined that BAT limits should be established based on the same technology evaluated for BPT
limits. As explained above at Section 11.2.3, zero or alternative discharge is not an available alternative
treatment technology for this industry. Therefore, EPA promulgated BAT effluent limitations for the
Hazardous landfill subcategory based upon the same treatment technology selected for BPT: equalization
prior to chemical precipitation with clarification, followed by biological treatment with secondary
clarification, and multimedia filtration.
11.5 New Source Performance Standards (NSPS)
New Source Performance Standards under Section 306 of the Clean Water Act represent the greatest
degree of effluent reduction achievable through the application of the best available demonstrated control
technology for all pollutants (i.e. conventional, nonconventional, and toxic pollutants). NSPS are applicable
to new industrial direct-discharging facilities, for which construction has commenced after the publication
of final regulations. Congress envisioned that new treatment systems could meet tighter controls than
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existing sources because of the opportunity to incorporate the most efficient processes and treatment
systems into plant design. Therefore, Congress directed EPA, in establishing NSPS, to consider the best
demonstrated process changes, in-plant controls, operating methods, and end-of-pipe treatment
technologies that reduce pollution to the maximum extent feasible.
EPA established New Source Performance Standards (NSPS) that would control the same conventional,
toxic, and nonconventional pollutants promulgated for control by the BAT effluent limitations for both
subcategories. The treatment technologies used to control pollutants at existing facilities are fully applicable
to new facilities. Furthermore, EPA has not identified any other 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 established NSPS limitations that are identical to
those promulgated in both subcategories for BPT/BCT/BAT.
In the proposed rule, EPA solicited comments and data on other technologies that may be appropriate for
the treatment of landfill leachate from new sources. One commenter urged EPA to consider reverse
osmosis as an appropriate technology for the treatment of leachate. While EPA acknowledges that reverse
osmosis can treat landfill leachate to levels equivalent to, and even lower than, the final BAT limitations,
EPA concluded that the reverse osmosis treatment system did not remove significantly more pounds of
toxic pollutants than the treatment option selected as BAT. Therefore, EPA concluded that the large costs
associated with the installation, operation, and maintenance of a reverse osmosis system would not justify
the small incremental removal of pounds of toxic pollutants achieved. Therefore, EPA is promulgating
NSPS limitations that are identical to those in each subcategory for BPT/BCT/BAT.
11.6 Pretreatment Standards for Existing Sources (PSES)
Section 307(b) of the Act requires EPA to promulgate pretreatment standards for pollutants that are not
susceptible to treatment by POTWs or which would interfere with the operation of POTWs. After a
thorough analysis of indirect-discharging landfills in the EPA database, EPA has decided not to establish
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PSES for either subcategory in the Landfills Point Source Category. For the proposal, EPA proposed not
to establish pretreatment standards for indirectly discharging landfills in the Non-Hazardous subcategory.
However, for the Hazardous subcategory, EPA proposed effluent limitations and pretreatment standards
for six pollutants. In response to its proposal, EPA received a number of comments supporting the decision
not to propose pretreatment standards for Subtitle D landfills. In addition, a number of commenters
suggested that EPA should also reconsider whether Subtitle C landfills require national categorical
pretreatment standards. As a result of these comments, EPA took a second look at its data and
determined that pretreatment standards were not necessary for the Landfills Point Source Category.
For both subcategories, EPA looked at a number of factors in deciding whether a pollutant was not
susceptible to treatment at a POTW or would interfere with POTW operations - the predicate to
establishment of pretreatment standards. First, EPA assessed the pollutant removals achieved at POTWs
relative to those achieved by landfills using BAT treatment systems. Second, EPA estimated the quantity
of pollutants likely to be discharged to receiving waters after POTW removals. Third, EPA studied
whether any of the pollutants introduced to POTWs by landfills interfered with or were otherwise
incompatible with POTW operations. EPA, in some cases, also looked at the costs and other economic
impacts of pretreatment standards and the effluent reduction benefits in light of treatment systems currently
in-place at POTWs. The result of EPA's evaluation showed that POTWs could adequately treat
discharges of landfill pollutants. Therefore, EPA is not establishing pretreatment standards for either
subcategory in this point source category.
As noted above, among the factors EPA considers before establishing pretreatment standards is whether
the pollutants discharged by an industry pass through a POTW or interfere with the POTW operation or
sludge disposal practices. One of the tools traditionally used by EPA in evaluating whether pollutants pass
through a POTW, is a comparison of the percentage of a pollutant removed by POTWs with the
percentage of the pollutant removed by discharging facilities applying BAT. In most cases, EPA has
concluded that a pollutant passes through the POTW when the median percentage removed nationwide
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by representative POTWs (those meeting secondary treatment requirements) is less than the median
percentage removed by facilities complying with BAT effluent limitations guidelines for that pollutant. For
a full explanation of how EPA performs its removal analysis, see Chapter 7.
In developing the final guidelines, EPA has made a number of modifications to its calculations of pollutant
removal used to compare POTW operations with BAT treatment. For example, the primary source of
POTW percent removal data used for removal comparisons is an EPA document, "Fate of Priority
Pollutants in Publicly Owned Treatment Works" (EPA 440/1-82/303) commonly referred to as the "50-
POTW Study". The 50-POTW Study presents data on 50 well-operated POTWs with secondary
treatment in removing toxic pollutants. For its removal comparison for this guideline, EPA eliminated
influent values that were close to the detection limit, thereby minimizing the possibility that low POTW
removals might simply reflect low influent concentrations instead of being a true measure of treatment
effectiveness.
After revising the database, EPA calculated POTW-specific percent removals for each pollutant based on
its average influent and average effluent values. The POTW percent removal used for each pollutant for
the comparison is the median value of all the POTW-specific percent removals for that pollutant. EPA then
compared the median POTW percent removal to the median percent removal for the BAT option treatment
technology in order to determine pass through.
11.6.1 EPA's Decision Not to Establish PSES for the Subtitle D Non-Hazardous
Subcategory
EPA estimates that there are 756 Subtitle D landfill facilities in the U.S. that discharge landfill wastewater
to a POTW. The Agency did not establish pretreatment standards for existing sources (PSES) for the
Non-Hazardous landfill subcategory. The Agency decided not to establish PSES for this subcategory after
an assessment of the effect of landfill leachate on receiving POTWs and the cost of pretreatment standards.
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EPA looked at three measures of effects on POTWs: biological inhibition levels, contamination of POTW
biosolids, and a comparison of BAT and POTW removals. For the proposed rule, following procedures
outlined above, the removal comparison suggested that one pollutant, ammonia, would pass through in the
Non-Hazardous subcategory. However, EPA concluded that ammonia was susceptible to treatment and
did not interfere with POTW operations. Therefore, the Agency did not propose to establish national
pretreatment standards for ammonia.
Following the proposal, EPA reviewed the data available in the proposed Public Record for both the
POTW percent removal calculations and the BAT percent removal calculations and made a number of
adjustments. For the proposal, EPA calculated the BAT percent removals using data from well-operated
biological treatment facilities in EPA's database. However, some of these facilities did not pass the editing
criteria for selection as a BPT/BAT facility. For the revised removal comparison, EPA calculated percent
removals using data from only those seven facilities that passed the BPT/BAT editing criteria. In addition,
in the proposal, EPA inadvertently neglected to use selected BAT facilities in the calculation of percent
removals for several pollutants even though the data for the facility passed the editing criteria.
The result of this revised comparison of removal for the Non-Hazardous subcategory suggested that BAT
removal would be greater than POTW removal for four pollutants: ammonia, benzoic acid, p-cresol, and
phenol. However, as explained below, EPA concluded that these pollutants do not pass through or
interfere with POTW operations on a national basis and therefore has not established national categorical
pretreatment regulations for these pollutants. Moreover, as discussed later in this chapter, EPA notes that
adoption of PSES would result in the removal of only a small quantity of pollutants, approximately 14 toxic
pound equivalents per facility per year. Such a reduction is low relative to that seen in other categorical
pretreatment standards promulgated by EPA. (See 64 FR 45077).
11.6.1.1 EPA's Rationale for Not Establishing PSES for Ammonia
EPA has decided not to establish ammonia pretreatment standards for several reasons. First, while EPA's
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removal comparison suggests that ammonia in landfill leachate is not as amenable to POTW treatment as
to pretreatment, in reality, EPA has concluded that ammonia is susceptible to POTW treatment on a
national basis. Further, landfill discharges will not result in POTW upsets or interfere with POTW
operations. The Public Record indicates that POTWs are not currently experiencing any difficulty in
adequately treating ammonia discharges from Subtitle D landfills. No POTWs commenting on the proposal
cited any persistent POTW upsets associated with landfill leachate discharges. Finally, EPA has
determined that pretreatment standards for ammonia for landfill indirect dischargers would be extremely
costly, given the high levels of removal currently observed. In these circumstances, EPA has concluded
that ammonia is susceptible to treatment by POTWs and national pretreatment standards are not required.
Ammonia Removals
In the case of ammonia, the median BAT percent removal for the landfills industry is 99 percent compared
to the median POTW percent removal which is 39 percent. (For the proposed rule, EPA calculated the
POTW percent removal for ammonia to be 60 percent. However, upon applying the revised data editing
procedures to the 50-POTW Study, EPA has now determined that ammonia POTW percent removal is
39 percent.) This comparison suggests that ammonia is not susceptible to treatment at a POTW and passes
through. However, as discussed below, most subtitle D landfills discharging to POTWs are discharging
small quantities of leachate with an ammonia concentration comparable to that observed in raw sewage.
EPA's data show that over 75 percent of indirectly discharging landfills discharge fewer than 10 pounds
of ammonia per day at a concentration similar to that observed in raw sewage. Because many POTWs
are designed and operated to treat ammonia (and other pollutants) in raw sewage, a POTW will adequately
control landfill discharges of ammonia so long as the ammonia loadings to a POTW did not significantly
differ from that typically observed. In those circumstances, ammonia will not pass through such POTWs.
Moreover, some POTWs have installed additional treatment to control ammonia. The data on POTW
removal used for EPA's comparison does not reflect this fact. POTWs that have installed additional
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ammonia treatment (or modified existing treatment) typically achieve removals in excess of 95 percent -
much higher than the 39 percent removal observed for the POTWs in the comparison analysis. Thus,
ammonia does not pass through POTWs with nitrification even in cases where significant loadings of
ammonia are discharged to a POTW.
In these circumstances, EPA has concluded ammonia at levels discharged by landfills is generally
susceptible to POTW treatment. Therefore, EPA concluded that ammonia limits are best established by
local POTWs based on site-specific conditions in accordance with the POTW's design treatment capacity
and existing mass loadings.
Upset and Interference
EPA also assessed the ammonia concentrations and loads received by POTWs from Subtitle D leachate
discharges to evaluate potential upsets or interference with POTW treatment systems. EPA concluded
that national pretreatment standards were not required to prevent interference with POTW operations.
In terms of landfill leachate ammonia concentrations discharged to POTWs, only one of the Subtitle D
landfill facilities in EPA's database is currently discharging (i.e. after treatment, if treatment is in place)
wastewater to a POTW which contains more than 105 mg/L of ammonia. The remainder of the indirect-
discharging Subtitle D landfills discharged an average concentration of 37 mg/L of ammonia to POTWs,
with one-half of the facilities discharging less than 32 mg/L. Typical ammonia concentrations in raw
domestic sewage range from 12 to 50 mg/L ("Operation of Municipal Wastewater Treatment Plants:
Manual of Practice, Volume II," Water Pollution Control Federation).
The one facility in EPA's database that was discharging more than 105 mg/L of ammonia to a POTW was
discharging 1,018 mg/L of ammonia to a 114 MGD POTW which currently has ammonia control
(nitrification) in place. EPA also received influent ammonia data from several POTWs that commented on
the proposed rule. The average ammonia influent concentration to POTWs ranged from 14 mg/L to 35
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mg/L with an average concentration of 17 mg/L. Therefore, with the exception of the one outlier, the
average concentration of ammonia in leachate discharged to POTWs (37 mg/L) noted in EPA's data
closely parallels POTW experience (35 mg/L). However, it should be noted that the upper ranges of
leachate concentrations were higher than the upper ranges observed in domestic sewage. Nevertheless,
in most instances, observed ammonia discharge levels to POTWs fall within a POTWs treatment
capabilities. Thus, EPA determined that the vast majority of Subtitle D landfills are discharging ammonia
to POTWs at levels comparable to that which POTWs in the ordinary course of operations receive and
treat in raw domestic sewage.
No POTWs commenting on the proposal cited any specific incidents where POTW acceptance of landfill
leachate containing high levels of ammonia caused persistent upsets at the POTW. The data are consistent
with that supplied by commenters and further supported EPA's understanding prior to the proposal of no
documented persistent problems at POTWs due to ammonia concentrations in landfill leachate.
EPA also analyzed the effects that ammonia concentrations found in landfill leachate can have on the
biological treatment systems at POTWs. In this analysis, EPA compared the concentrations of ammonia
found in leachate with the activated sludge biological minimum threshold toxicity value (or inhibition value).
With respect to ammonia, the inhibition value for activated sludge systems is 480 mg/L (Guidance Manual
on the Development and Implementation of Local Discharge Limitations Under the Pretreatment Program,
Volume 1. EPA, November 1987). The average raw wastewater concentration of ammonia found in
Subtitle D landfills in EPA's database was 199 mg/L for direct, indirect and zero dischargers. In addition,
all of the average and median ammonia concentration values observed in the data submitted to EPA in
comments were below the activated sludge inhibition value. EPA has consequently determined that
ammonia does not represent a threat to biological treatment systems that would require establishment of
pretreatment standards.
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Effect on Receiving Streams
Subsequent to the proposal, EPA evaluated total wastewater flows and loads of ammonia to receiving
streams associated with non-hazardous landfill indirect dischargers (an estimated 756 facilities). EPA
estimated that the non-hazardous landfill industry discharges 2.7 million pounds per year of ammonia to
POTWs, which results in 1.6 million pounds per year being discharged to receiving streams, assuming that
the POTWs have secondary treatment achieving 39 percent removal but do not have additional treatment
for ammonia control. However, as mentioned above, EPA is aware that many POTWs have installed
additional treatment specifically for the control of ammonia and typically achieve removals in excess of 95
percent. A review of EPA's 1996 Clean Water Needs Survey and its Permit Compliance System
database indicates that approximately 20 percent of the POTWs in the U.S. employ some sort of ammonia
control. Over 75 percent of the Subtitle D landfills in EPA's database discharge less than 10 pounds per
day to the POTW (3,500 pounds/year), which results in discharging less than six pounds per day (2,100
pounds/year) to receiving streams, again assuming secondary treatment only and no additional POTW
ammonia controls. In light of existing ammonia control in place at POTWs, actual discharges to receiving
streams are likely to be even smaller.
Cost of Pretreatment Standards
EPA has evaluated the economic costs of ammonia pretreatment standards. EPA's economic assessment
of these options demonstrated very high removal costs with low associated pollutant removals. Given the
high cost, EPA concluded that it is not appropriate to establish national pretreatment standards to address
the limited circumstances in which POTW removal might not match BAT removal performance.
EPA evaluated the costs of pretreatment standards in terms of the toxic pound equivalents. Pound-
equivalents is a term used to describe a pound of pollutant weighted by its toxicity relative to copper.
These weights are known as toxic weighting factors. The Agency calculates pound-equivalents by
multiplying the pounds of a pollutant discharged from a landfill by the toxic weighting factor for that
pollutant. The use of pounds-equivalent reflects the fact that some pollutants are more toxic than others.
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The first treatment option that EPA evaluated is biological treatment. EPA evaluated PSES Option I
equivalent to BPT/B AT Option I, which was equalization plus biological treatment. This option had a total
annualized cost of $34.6 million (1998 dollars). Biological treatment removed 10,650 pound-equivalents
annually, or an average of 14 pound equivalents per facility per year. This represents a cost of removal of
$l,900/lb-equivalents (1981 dollars) and represents the cost of removing all of the pound-equivalents
removed, not just ammonia. If EPA took credit only for the pound-equivalents of ammonia removed, the
annual removal cost for this option is $7,100/lb-equivalents (1981 dollars). Moreover, these calculations
are based on the assumption that POTWs will only remove 39 percent of the ammonia discharged to it.
If POTWs remove more ammonia than that assumed, then the cost of each pound of pollutant removed
by the industrial user raises. Given the installation of additional ammonia controls at many POTWs, actual
ammonia removal by POTWs will be greater than assumed.
The second technology option EPA evaluated for the control of ammonia is ammonia stripping with
appropriate air pollution controls. However, according to EPA's survey of the landfills industry, only two
percent of survey respondents use this technology for the treatment of landfill leachate. In addition, air or
steam stripping is more commonly used for treatment of wastewater containing concentrations of ammonia
that are several orders of magnitude greater than those typically found in landfill wastewater. Therefore,
EPA concluded that biological treatment systems are more appropriate for the treatment of the ammonia
concentrations found in landfill leachate. In addition, air stripping for ammonia removal generally requires
warm climates, and therefore this may not be a viable treatment option for all landfills located in the United
States. In these circumstances, effluent levels associated with air stripping may not be attainable in all cases
and thus not broadly available in the landfill industry. In addition, the air stripping option for the treatment
of ammonia has an estimated annualized cost of $ 15.1 million (1998 dollars, pre-tax costs). The cost-
effectiveness for this option is also high, $4,400/lb-equivalents (1981 dollars).
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As explained above, EPA concluded that the vast majority of POTWs experience no difficulty in treating
the ammonia loads received from landfill indirect dischargers, and that as a result, there is generally no pass
through of ammonia from landfill leachate on a national basis. Moreover, the cost of pretreatment is not
warranted by the limited circumstances where pretreatment would result in reduced ammonia to surface
water. But there are POTWs without additional controls for ammonia that may not be equipped to handle
landfill leachate ammonia discharges. Consequently, in the proposal, EPA requested comments on requiring
ammonia pretreatment standards for those landfills discharging to POTWs that do not have ammonia
controls in place. Several commenters supported no pretreatment standard because of their conclusion that
ammonia loads from landfills made up an insignificant amount of the total ammonia loads discharged to
POTWs. Others favored pretreatment standards because of smaller POTWs that do not employ nutrient
removal systems. EPA, however, is not convinced that national ammonia pretreatment standards are
warranted even where landfills are discharging to POTWs without ammonia controls given the high cost of
pretreatment and current ammonia concentrations in landfill leachate discharged to POTWs that are
generally consistent with values observed in raw sewage. Special ammonia situations are best addressed
by the local POTW based on site-specific conditions in accordance with the POTW' s design treatment
capacity and existing mass loadings.
All of these factors discussed above confirm EPA's decision not to establish national ammonia pretreatment
standards. EPA has concluded that landfills typically discharge wastewater to POTWs containing ammonia
concentrations that can be adequately treated by POTWs. Further, in cases where ammonia loading rates
are at levels which may be of concern or where ammonia discharges are a water quality concern, POTWs
retain the ability to establish local limits on ammonia.
11.6.1.2 EPA's Rationale for Not Establishing PSES for Benzoic Acid
Benzole Acid Pass-Through Analysis
As stated above, for the proposal, benzoic acid was not one of the pollutants EPA determined would pass
through. However, after the proposal, EPA reviewed the BAT facilities and the representative POTW
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facilities used for the removal comparison and determined that it had not used the appropriate editing rules.
As a result of these revisions, the comparison showed that the median percent removal for benzoic acid at
the landfills BAT facilities was 99 percent compared to the median POTW percent removal which was
determined to be 81 percent. Because the 50-POTW database does not contain information on the percent
removal of benzoic acid, EPA used the National Risk Management Research Laboratory Treatability
database to estimate the percent removal. (For more information on EPA's use of the NRMRL database,
see Chapter 7.)
Despite the difference in the BAT and POTW percent removals, further analysis of the data showed that
both systems were achieving the same level of treatment of benzoic acid. That is, both the NRMRL
database facilities representing POTWs and the landfills BAT facilities were treating benzoic acid down to
non-detect levels (50 ug/L). Therefore, the smaller percent removal achieved by facilities in the NRMRL
database (used to represent the POTW percent removal) is a function of lower influent concentrations at
those facilities and is not necessarily indicative of inferior treatment at POTWs. EPA concluded that benzoic
acid in these circumstances is susceptible to treatment at the POTW and does not pass through.
Benzoic Acid Loads Discharged to POTWs
In addition, EPA also evaluated the total flows and loads of benzoic acid discharged from non-hazardous
landfills to POTWs. EPA compared the current discharge loads to the loads that would be anticipated after
the implementation of pretreatment standards. As was explained above, EPA selected Option I (biological
treatment) as the appropriate treatment technology and has analyzed the costs and benefits of pretreatment
standards for the Non-Hazardous subcategory for this option. According to EPA's estimates, non-
hazardous landfills currently discharge approximately 4,700 pounds of benzoic acid to POTWs per year
resulting in an annual discharge of 900 pounds to receiving streams. PSES Option I (biological treatment)
would reduce this annual discharge to receiving streams to 400 pounds per year. The average non-
hazardous facility discharges only 6.4 pounds of benzoic acid annually (less than 0.02 pounds per day), and
the median discharge is only 1.9 pounds per year. Furthermore, benzoic acid has a toxic weighting factor
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of only 0.0003. Therefore, for the entire indirect-discharging non-hazardous landfills population
(approximately 756 facilities), Option I would only remove an additional 0.16 pound-equivalents peryear.
As a result of the above analysis, EPA determined that national pretreatment standards for benzoic acid are
not necessary because benzoic acid is susceptible to treatment by POTWs. POTWs and landfill BAT
facilities both treat benzoic acid down to non-detect levels. In addition, EPA determined that the pounds
of benzoic acid currently being discharged by landfills are compatible with POTW treatment and that
pretreatment standards would result in little further reduction of benzoic acid.
11.6.1.3 EPA's Rationale for Not Establishing PSES for P-Cresol
P-Cresol Pass-Through Analysis
Like benzoic acid, p-cresol also did not pass through POTWs according to EPA's pass-through analysis
at proposal. However, the result of its revised removal comparison showed some difference in removal.
The landfills median BAT percent removal for p-cresol is 99 percent, while the estimated median POTW
percent removal is 68 percent. (Again, because the 50-POTW database does not contain percent removal
data for p-cresol, EPA used the NRMRL database to determine POTW removal.)
P-Cresol Concentrations and Loads Discharged to POTWs
EPA also analyzed the flows and loads of p-cresol being discharged from non-hazardous landfills to
POTWs. According to EPA's estimates, non-hazardous landfills currently discharge approximately 2,730
pounds of p-cresol to POTWs per year resulting in an annual discharge of 870 pounds to receiving streams.
PSES Option I (biological treatment) would reduce this discharge to receiving streams to 130 pounds/year.
Furthermore, p-cresol has a toxic weighting factor of only 0.0024. Therefore, the implementation of Option
I results in an additional reduction of only 3.0 pound-equivalents per year across the entire Subtitle D indirect
discharge population. On average, non-hazardous landfill facilities discharge only 3.4 pounds of p-cresol
annually (or 0.01 pounds per day), and the median discharge load is only 0.7 pounds per year.
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Based on the data shown above, EPA concluded that the implementation of pretreatment standards for p-
cresol would result in only minimal reductions in the pounds of p-cresol discharged to surface waters. In
addition, p-cresol is found in non-hazardous landfill leachate at concentrations which will not cause upsets
at POTWs nor should POTWs have difficulty effectively treating such concentrations. The median raw
wastewater concentration for p-cresol at municipal landfills is 75 ug/L. This concentration is well below the
Universal Treatment Standard (UTS) of 770 ug/L established for F039 wastes (multi-source leachate) in
40 CFR 268.48. (EPA bases UTS on the Best Demonstrated Available Treatment Technology (BOAT)
for each listed hazardous waste. BDAT represents the treatment technology that EPA concludes is the
most effective for treating a particular waste that is also readily available to generators and treaters.)
11.6.1.4 EPA's Rationale for Not Establishing PSES for Phenol
Although phenol appeared to pass through, EPA decided not to establish pretreatment standards for phenol
based on the fact that phenol is highly biodegradable and is treated by POTWs to the same degree as the
landfill direct dischargers. Furthermore, the Agency concluded that the differences in influent concentrations
caused the apparent difference in removal performance between landfill direct dischargers and POTWs.
As a result, the performance across the landfills direct dischargers showed higher removals than the
performance at the POTWs.
In EPA's landfills database, raw wastewater concentrations of phenol at the BAT facilities in the Non-
Hazardous subcategory were much higher than the influent concentrations at the POTWs used in the
determination of the POTW percent removal. The average influent concentrations for phenol for the three
non-hazardous BAT facilities used in the pass-through analysis ranged from 350 ug/L to 5,120 ug/L. All
three of the facilities treated phenol down to the analytical minimum level (10 ug/L), corresponding to a
median percent removal of 97.5 percent. For POTW performance, EPA used a total of eight POTWs in
the analysis for POTW percent removal of phenol. The average influent concentration for phenol at these
eight POTWs was 387 ug/L, and six of the eight effluent values were below the analytical minimum level and
therefore assigned values of 10 ug/L. Thus, the average percent removal for the POTWs was 95.3 percent.
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In this case, EPA concluded that the differences in removals for POTWs (95.3 percent) and BAT facilities
(97.5 percent) is an artifact of the differing influent concentrations and does not necessarily reflect a real
difference in treatment performance. Therefore, EPA concluded that phenol is treated to essentially the
same level by direct dischargers and POTWs and, therefore, does not pass through.
Based on the pollutant loadings rationale described above for ammonia, benzoic acid, and p-cresol, and
based on the highly biodegradable nature of phenol, EPA decided not to set pretreatment standards for
landfills in the Non-Hazardous subcategory. In addition, the Agency concluded that in the case of
discharges from Subtitle D landfills, problems that may result from elevated ammonia loads in landfill leachate
are best addressed at the local level. Furthermore, the Agency has determined that as a result of the ability
of POTWs to adequately treat the small quantities of benzoic acid and p-cresol being discharged from
landfills, a pretreatment standard for these two pollutants is also unnecessary. EPA also concluded that the
cost to implement pretreatment standards for this subcategory is not warranted by the environmental benefits
associated with any small additional removals.
11.6.1.5 Public Comments to the Proposed Rule Regarding Non-Hazardous PSES
In support of EPA's proposal not to establish PSES for the Non-Hazardous subcategory, EPA received
comments and data following the proposal concerning the treatment of non-hazardous landfill leachate at
POTWs. A total of seventeen commenters, representing municipalities, POTWs, privately-owned landfills,
trade associations, and engineering consulting firms, stated that in their experience, no POTW upsets or
adverse impacts on sludge quality had occurred as a result of a POTW accepting non-hazardous landfill
leachate. Several of these commenters supported their claim with data or anecdotal evidence from over 20
landfills discharging leachate to POTWs. Most of these commenters felt that local limits are currently
addressing discharges from non-hazardous landfills and that any particular pollutant that may be of concern
should be dealt with on a case-by-case basis. Commenters also stated that the implementation of
pretreatment standards would be extremely costly for very little improvement in water quality. Commenters
stressed that any mandatory pretreatment that did not take into account the ability of receiving POTWs to
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handle the wastewater would inevitably result in unnecessary pretreatment of some waste streams. EPA
found that this comment is particularly applicable to ammonia because of the varying degrees of treatment
that can be achieved by POTWs. Furthermore, several commenters felt that the constituents found in landfill
leachate are similar to those found in the influent to POTWs and that the flow contribution from landfills is
relatively small.
There were also several commenters who supported the establishment of pretreatment standards for non-
hazardous landfill leachate. One municipality was concerned with the effects that landfill leachate can have
on small community POTWs with low flows. Specifically, the commenter was concerned with elevated
levels of three specific pollutants (zinc, chromium, and cyanide) at three landfills that discharge to the city's
POTW. The concentrations cited by the commenter for chromium and zinc were much higher than the
median concentration determined for these metals by EPA's data gathering efforts. In addition, EPA did
not detect cyanide in its analytical sampling at Subtitle D landfills. As a result, EPA determined that the
pollutant concentrations identified by this municipality are not indicative of the concentrations typically
present at Subtitle D landfills. Therefore, in cases where elevated levels of pollutants present in landfill
leachate may cause problems for a POTW, local, site-specific limits are the best way to implement controls
on such discharges. Furthermore, EPA did not receive any comments from POTWs that had experienced
persistent upsets as a result of accepting landfill leachate.
One other municipality felt that EPA should set pretreatment standards for non-hazardous landfills since
close to 70 percent of the wastewater flow discharged from Subtitle D landfills is discharged to POTWs.
EPA establishes pretreatment standards for pollutants that are not susceptible to treatment by POTWs to
prevent pass through and interference based on the ability of POTWs to achieve treatment equivalent to that
of direct dischargers. The percentage of total flow of an industry being discharged to POTWs is not a basis
for establishing pretreatment standards. Furthermore, EPA determined that the total loads of the pollutants
that are discharged to POTWs made up only a very small fraction of what the POTW receives, and that the
concentrations of these pollutants are at levels that are compatible with POTW treatment.
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Other commenters disagreed with EPA's statements that non-hazardous leachate is of the same quality as
the headwaters of a POTW. Three of these commenters were particularly concerned with ammonia
concentrations in landfill leachate (the data from these commenters was discussed in the ammonia discussion
above). EPA reviewed the data submitted by these commenters and, although some pollutants exceeded
EPA's median concentrations, the commenters did not cite any specific instances where the reported
leachate concentrations created a problem for a receiving POTW. EPA acknowledges that elevated levels
of pollutants can exist in landfill wastewater. However, the median concentrations of pollutants determined
by EPA's sampling program indicate that, on a national basis, concentration levels of pollutants are not at
a level to be of concern to POTWs. In addition, in many cases, the loads of pollutants discharged from
landfills to POTWs make up a very small portion of the total pollutant loads received by the POTW.
Another commenter suggested that EPA consider setting pretreatment standards for sulfates and sodium in
landfill discharges. The commenter stated that the levels of sodium found in landfill leachate is generally
greater than the level of 20 mg/L indicated in EPA's Drinking Water Contaminant Candidate List. EPA did
not include limits for sulfates or sodium since these can be found in naturally occurring compounds in landfill
soils and are often constituents in treatment chemicals commonly used for wastewater treatment.
One municipality commented in favor of PSES for ammonia since its regional POTWs had to establish a
local ammonia pretreatment limit of 100 mg/L to protect water quality in ocean outfalls. However, in this
case, the local authority has determined that a 100 mg/L pretreatment standard is adequate for the protection
of water quality in the ocean outfalls. EPA acknowledges that there may be circumstances in which POTWs
may have to establish local limits in order to prevent upsets or pass through. These situations do not
undercut EPA's decision not to establish national pretreatment standards for ammonia. As explained in
Section 11.6.1.1, the removal technologies evaluated for PSES would result in very low ammonia discharge
levels, much lower than that established by the commenter (100 mg/L). This situation further supports EPA's
conclusion that local limits for ammonia provide the most appropriate control and that national pretreatment
requirements for ammonia may result in unnecessary pretreatment of some waste streams. In fact, one of
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the two landfills discharging leachate to the district's POTW has since installed an SBR. As a result, the
leachate ammonia concentration for this landfill has dropped from an average of 393 mg/L to 52 mg/L. The
fact that one of the landfills has installed pretreatment to lower ammonia discharges is a good example that
existing pretreatment programs are effective at requiring landfills to control their discharges.
One of the commenters in support of PSES already employs biological pretreatment at its landfill. This
landfill specifically stated that concentrations of ammonia as nitrogen and total toxic organics should undergo
pretreatment prior to discharge to a POTW unless the leachate is a very small constituent of the total flow
of the POTW. The raw wastewater ammonia concentrations at this landfill were consistent with the median
determined by EPA's sampling efforts and the facility employed biological treatment to achieve an effluent
ammonia concentration that was acceptable to the local POTW. In addition, the concentrations of toxic
organics found in EPA's sampling of Subtitle D landfill leachate were typically not at levels that would cause
inhibition to biological treatment at a POTW. The specific organic pollutants that EPA determined to pass
through were found in very low concentrations, resulting in minimal loadings discharged to POTWs. The fact
that this landfill already employs pretreatment is a good example that existing pretreatment programs are
effective at requiring landfills to control their discharges.
11.6.2 EPA's Decision Not to Establish PSES for the Subtitle C Hazardous Subcategory
In the proposed rule, EPA proposed pretreatment standards for six pollutants that EPA determined to pass
through in the Hazardous subcategory. However, after reviewing the comments received and re-evaluating
the pollutant loads in the Hazardous subcategory, EPA has decided not to establish national pretreatment
standards for Subtitle C landfills.
As previously explained, EPA establishes pretreatment standards for pollutants that are not susceptible to
treatment at a POTW or for pollutants that may interfere with POTW operations. As explained at section
11.2.3, for the Hazardous subcategory, EPA identified only three Subtitle C landfills, all of them indirect
dischargers. EPA used data from these hazardous landfills to develop the BPT/BAT limitations for toxic
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pollutants because these landfills were using the treatment systems for their leachate that EPA determined
was the BPT/BAT treatment technology.
EPA also performed an analysis for this subcategory in order to compare POTW removals with BAT
treatment systems. As was the case for the Non-Hazardous subcategory, EPA revised the pass-through
analysis data editing procedures after the proposal and as a result EPA's removal results have changed. The
result of the revised comparison show BAT removals greater than POTW removals for the following eight
pollutants: ammonia, alpha terpineol, aniline, benzoic acid, naphthalene, p-cresol, phenol, and pyridine.
For its removal comparison for ammonia, EPA compared the nation-wide median percentage of ammonia
removed by well-operated POTWs to the percentage of ammonia removed by BAT treatment systems from
both the Hazardous and Non-Hazardous subcategories. (For the reasons explained in section 11.2.4, in
the case of ammonia, EPA supplemented the Hazardous subcategory data with data from non-hazardous
landfill facilities.) For all other toxic pollutants, in determining whether a pollutant would pass through a
POTW, the Agency compared the nation-wide median percentage of a pollutant removed by well-operated
POTWs with secondary treatment to the percentage of a pollutant removed by BAT treatment systems from
only the Hazardous subcategory. For the proposal, EPA proposed pretreatment standards that were
equivalent to the BPT/BAT limitations for the pollutants that passed through. EPA has reconsidered its
decision that it should promulgate national pretreatment standards for hazardous landfills. The reasons for
this decision are explained in more detail below.
Two of the indirect discharging landfills have treatment technology in place that EPA considers to be BAT,
and currently discharge very low concentrations of pollutants to their local POTWs. The third and only
other indirectly discharging Subtitle C landfill for which EPA has data discharged less than 1,000 gal/day
of landfill gas collection condensate to a POTW. In addition to the low wastewater flow at this landfill, the
facility has relatively low raw wastewater pollutant concentrations and employs neutralization with ammonia
followed by settling prior to discharge to the POTW.
11-49
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Several commenters on the proposal questioned EPA's rationale for developing ammonia pretreatment
standards for the Hazardous subcategory while not establishing ammonia pretreatment standards for the
Non-Hazardous subcategory. EPA's database indicate that the median raw wastewater ammonia
concentration for hazardous landfills is 268 mg/L as compared to the raw wastewater ammonia
concentration for Subtitle D landfills which is 199 mg/L.1 EPA has current information on ammonia
concentration in wastewater discharges for two of the three Subtitle C landfills in EPA's database. One of
the landfills employs biological treatment and discharges an average of 4.9 mg/L of ammonia to the POTW.
The other landfill employs chemical precipitation prior to biological treatment and discharges ammonia at
an average concentration of 156 mg/L. This discharge level presents no apparent problem to the receiving
POTW. According to discussions with this facility and the POTW, the POTW has not set local
pretreatment standards for ammonia for this landfill, and the POTW does not perform nitrification nor is
there an ammonia limit in the POTW's NPDES permit. Since 1995, the POTW has seen the ammonia
concentration at its headworks increase from 13 mg/L to 20 mg/L and has experienced some upsets at the
POTW. However, the POTW explained that it was unsure whether the upsets are a result of the increased
ammonia concentrations or due to some other constituent in the wastewater. In addition, the POTW is not
sure if the landfill leachate discharge is contributing at all to the upsets. As was the case in the Non-
Hazardous subcategory, EPA concluded that national pretreatment standards for ammonia are not
warranted by the small quantity of ammonia being discharged to POTWs from landfills in this subcategory
and due to the site-specific water quality and POTW nitrification issues associated with ammonia.
Although the removal comparison suggests that phenol may pass through, EPA decided not to establish
pretreatment standards for it because it is highly biodegradable and is, in fact, treated by POTWs to the
same degree as the landfill direct dischargers. The Agency concluded that any apparent difference in
In the comments received on the proposal, some commenters referred to the Hazardous subcategory median ammonia raw wastewater
concentration referred to in Table 6-8 on page 6-44 of the Proposed Landfills Development Document (EPA -821-R-97-022). This table
lists the median ammonia raw wastewater concentration of 8.6 mg/L. However, this median concentration included numerous CERCLA
facilities with discharges that consisted primarily of ground water. After proposal, EPA recalculated the median ammonia raw wastewater
concentration for the Hazardous subcategory using only data from Subtitle C landfills in EPA's database. This results in a median raw
wastewater ammonia concentration of 268 mg/L.
11-50
-------
removals in the removal comparison is an artifact of differing influent concentrations rather than any
difference in performance between landfill direct dischargers and POTWs.
In EPA's landfills database, raw wastewater concentrations of phenol at the two BAT facilities in the
Hazardous subcategory were much higher than the influent concentrations at the POTWs used in the
determination of the POTW percent removal. The average influent concentrations for phenol for the two
hazardous BAT facilities used in the pass-through analysis ranged from 5,120 ug/L to 98,500 ug/L, and the
average effluent concentrations ranged from 10 ug/L to 814 ug/L corresponding to an average percent
removal of 99.8 percent. For POTW performance, EPA used a total of eight POTWs in the analysis for
POTW percent removal of phenol. The average influent concentration for phenol at these eight POTWs
was 387 ug/L, and six of the eight effluent values were below the analytical minimum level and therefore
assigned values of 10 ug/L. Thus, the average percent removal for the POTWs was 95.3 percent, and
therefore EPA determined that the pollutant passed through. In this case, EPA concluded that the pass-
through determination is an artifact of the differing influent concentrations and does not necessarily reflect
a real difference in removals. Therefore, EPA concluded that phenol is treated to essentially the same level
by direct dischargers and POTWs and, therefore, does not pass through.
Further review of the comparison for alpha terpineol, aniline, benzoic acid, naphthalene, and pyridine under
the revised analysis showed that all of these pollutants were treated down to non-detect levels in both the
landfill's BAT treatment option and in the NRMRL facilities representing POTWs. That is, both BAT
facilities and POTWs achieve the same level of treatment for these pollutants, and the differences in removal
once again were simply a function of smaller influent concentrations at facilities representing POTWs.
(Alpha terpineol and benzoic acid are compounds for which a high removal efficiency would be expected
at a POTW due to their relatively high biodegradability.) Therefore, the Agency determined that, not only
are the current pollutant loads not a problem for POTWs, but also all of these pollutants are present in
concentrations that are treated down to non-detect levels in a well-operated POTW. Thus, given the small
11-51
-------
loadings and low concentrations of these pollutants, EPA concluded that these five pollutants are susceptible
to treatment at the POTW and do not pass through.
Furthermore, EPA has concluded that while the removal comparison suggests that two pollutants,
naphthalene and aniline, may not be susceptible to POTW treatment, in fact, they will receive equivalent
treatment. First, the median untreated wastewater concentration observed in EPA's data collection effort
for these pollutants is less than the Universal Treatment Standards (UTS) EPA has developed for these
pollutants in F039 wastes (multi-source leachate) in 40 CFR 268.48. The UTS for naphthalene is 0.059
mg/L which is slightly greater than the median concentration found in hazardous landfills (0.049 mg/L). The
UTS standard for aniline is 0.81 mg/L while the median concentration in hazardous landfills is 0.237 mg/L.
Second, aniline and naphthalene (as well as p-cresol and pyridine) will be removed from wastewater through
attachment to the biosolids in the POTW's biological treatment system and then undergo subsequent
biodegradation while entrained in the biosolids.
In addition, as noted above, the revised comparison shows a lower POTW removal for p-cresol than that
achieved by BAT treatment. However, as was the case in the Non-Hazardous subcategory, EPA has
concluded that the concentrations of p-cresol and the associated loadings discharged to POTWs from
landfills in the Hazardous subcategory would be insignificant compared to the total loads received at the
POTW. The median Subtitle C raw wastewater concentration for p-cresol is 144 ug/L (this includes only
Subtitle C landfills and not the CERCLA data included in the median on page 6-44 of the Proposed Landfills
Development Document) which is less than the UTS developed for p-cresol in F039 wastes which is 770
ug/L (40 CFR 268.48).
Therefore, based on the small quantity of pollutants involved and low pollutant concentrations discharged
from landfills in the Hazardous subcategory, EPA concluded that national pretreatment standards for landfills
in the Hazardous subcategory are unnecessary. In addition, EPA concluded that local limits are adequately
controlling wastewater discharges from Subtitle C landfills.
11-52
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11.7 Pretreatment Standards for New Sources (PSNS)
Section 307 of the Clean Water Act requires EPA to promulgate both pretreatment standards for new
sources and new source performance standards. 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.
EPA decided not to establish pretreatment standards for new sources for both subcategories for many of
the same reasons that EPA did not establish PSES limits. As stated in the PSES discussions above, EPA
concluded that the typical concentrations of pollutants in landfill leachate are not at levels that will cause
problems for POTWs. In addition, EPA determined that the relatively small wastewater flows from landfills,
coupled with the concentrations of pollutants typically found, result in small pollutant loading rates discharged
to POTWs from landfills. Finally, in site-specific cases where a particular pollutant may be found at
concentrations that are of concern to the POTW, EPA concluded that local pretreatment standards are the
most appropriate means for controlling such discharges.
11-53
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Table 11-1: Removal of Pollutant of Interest Metals in the Non-Hazardous Subcategory (ug/L)
Non-
Hazardous
POI
Metals
Barium
Chromium
Strontium
Titanium
Zinc
CAS#
7440393
7440473
7440246
7440326
7440666
Landfills Raw
Wastewater Data
Subtitle D
Municipal
Median
Concentration
483
28
1,671
64
100
Subtitle D Non-
Municipal
Median
Concentration
822
NA
4,615
11.8
93
NRMRL Treatability
Data(l)
Biological Treatment
Systems
Influent
Concentration
1,000-10,000
44
1,000-10,000
55
372
Percent
Removal
84.0
45.0
14.0
34.0
56.0
Published
Inhibition
Levels (2)
NA
1,000-100,000
NA
NA
80-5,000
50-POTW Study (3)
Maximum
Influent
Concentration
NA
2,380
NA
NA
9,250
Mean
Influent
Concentration
NA
173
NA
NA
723
Median
Percent
Removal
NA
82
NA
NA
79
OCPSF 12 Plant Sampling
Data (4)
Biological Treatment
Systems
Median
Influent
Concentration
NA
440
NA
NA
322
Percent
Removal
NA
68.5
NA
NA
58.5
NA - Not applicable or not available.
(1) Source: EPA National Risk Management Research Laboratory (NRMRL) Treatability Database.
(2) Source: EPA Guidance Manual on the Development and Implementation of Local Discharge Limitations Under the Pretreatment Program, Volume 1. EPA Nov 1987.
(3) Source: EPA Fate of Priority Pollutants in Publicly Owned Treatment Works. (EPA 440/1 -82/303, September 1982).
(4) Source: EPA Organic Chemicals, Plastics and Synthetic Fibers Public Record.
-------
Table 11-2: List of Subtitle D Municipal Solid Waste Facilities Employing
Biological Treatment Considered for BPT in the Non-Hazardous Subcategory
Facility Questionnaire ID Numbers
16001
16047
16048
16049
16052
16056
16058
16059
16060
16063
16065
16077
16078
16079
16083
16085
16088
16093
16097
16099
16102
16117
16118
16119
16120
16121
16122
16123
16125
16127
16129
16132
16154
16155
16158
16159
16161
16164
16165
16166
16170
16171
16174
16176
16253
11-55
-------
Table 11-3: Comparison of Raw Wastewater Mean Concentrations of Non-Hazardous
Pollutants of Interest for Municipal Solid Waste Landfills and Hazardous Facility 16041
Cas No.
C-002
C-004
C-005
C-009
C-010
C-012
C-020
106445
108101
108883
108952
120365
123911
142621
18540299
20324338
298044
3268879
35822469
65850
67641
68122
7440213
7440246
7440326
7440393
7440428
7440473
7440666
75092
7664417
78933
95487
98555
Pollutant
Biochemical Oxygen Demand
Chemical Oxygen Demand
Nitrate/Nitrite
Total Suspended Solids
Total Dissolved Solids
Total Organic Carbon
Total Phenols
P-Cresol
4-Methyl-2-Pentanone
Toluene
Phenol
Dichloroprop
1,4-Dioxane
Hexanoic Acid
Chromium (Hexavalent)
Tripropyleneglycol Methyl Ether
Disulfoton
OCDD
1234678-HpCDD
Benzoic Acid
2-Propanone
N,N-Dimethylform amide
Silicon
Strontium
Titanium
Barium
Boron
Chromium
Zinc
Methylene Chloride
Ammonia Nitrogen
2-Butanone
0-Cresol
Alpha Terpineol
Mean concentration of
Pollutants of Interest for
All Municipal Landfills in
EPA Database
1,228,534
2,024,932
5,844
735,308
4,195,518
661,478
142,838
246
3,789
166
287
10
118
13,148
77
568
9
0.03
0.002
7,220
2,407
214
30,913
1,569
66
720
3,005
46
1,476
70
238,163
5,119
298
334
Mean Concentration of
Pollutants of Interest for
Hazardous Facility
16041
877,875
2,033,750
1,770
191,375
12,275,000
562,250
3,195
218
2,175
1,468
1,553
2
10
1,632
Not analyzed
1,750
Not analyzed
6
1
5,294
4,398
Not analyzed
5,518
2,846
65
Not analyzed
8,839
87
253
49
382,250
6,398
10
691
11-56
-------
Table 11-4: Candidate BPT Facilities for the Non-Hazardous Subcategory
Eliminated from BPT Consideration Because No BOD5 Effluent Data Was Available
Facility Questionnaire ID Numbers
16001
16047
16056
16059
16060
16063
16078
16079
16083
16085
16102
16119
16121
16123
16154
16155
16158
16159
16166
16174
11-57
-------
Table 11-5: Treatment Systems In Place at Landfill Facilities Considered for BPT Which Supplied BOD5
Effluent Data
Facility
QID
16041
16048
16049
16052
16058
16065
16077
16088
16093
16097
16099
16117
16118
16120
16122
16125
16127
16129
16132
16161
16164
16165
16170
16171
16176
16253
Treatment in Place
Sequencing batch reactor (SBR)
Aerobic (oxidation pond)
Aerobic-anaerobic (facultative pond)
Aerobic-anaerobic (oxidation pond)
Aerated lagoon
Aerobic pond
Aerated lagoon
Equalization, sand filter, carbon adsorption, aerobic
Activated sludge, secondary clarifier, disinfection, multimedia filtration
Activated sludge, secondary clarifier
Equalization, chemical precipitation, flocculation, coalescing, anaerobic, activated sludge with
PACT, nitrification, secondary clarifier
Equalization, chemical precipitation, primary clarifier, aerated fixed film, secondary clarifier,
denitrification
Equalization, chemical precipitation, primary clarifier, anaerobic, aerobic, secondary clarifier
Settling, aeration, chemical precip, primary clarifier, air stripper, neutralization, activated sludge,
secondary clarifier, multimedia filtration, disinfection
Equalization, chemical precipitation, primary clarifier, anaerobic, aerobic, secondary clarifier,
aerobic equalization, multimedia filtration
Aeration, chemical precipitation, primary clarifier, SBR, secondary clarifier, carbon adsorption,
multimedia filtration
Unstirred tank, aeration
Neutralization (lime), chemical precipitation, primary clarifier, activated sludge, secondary clarifier,
sand filter, air stripping
Aerated pond
Aeration, aerobic, settling (aerated pond)
Aeration, chemical precipitation, primary clarifier, neutralization, equalization, aerobic, secondary
clarifier
Aerobic, settling (aerated pond)
Equalization, stabilization pond
Equalization, activated sludge, settling
Aeration, activated sludge, settling
Equalization, chemical precipitation, primary clarifier, anaerobic, activated sludge, secondary clarifier.
nitrification, multimedia filter
11-58
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Table 11-6: Landfill Facilities Considered for BPT in the Non-Hazardous Subcategory which Supplied BOD5 Effluent Data
Facility
QID
16041
16048
16049
16052
16058
16065
16077
16088
16093
16097
16099
16117
16118
16120
16122
16125
16127
16129
16132
16161
16164
16165
16170
16171
16176
16253
Bsl Flow
(MOD)
0.058917
0.000005
0.0017
0.0546
0.003
0.008
0.00816
0.03621
0.081575
0.019
0.01533
0.04
0.0288
0.042775
0.0255
0.014193
0.003627
0.00469
0.03
0.053
0.01
0.030218
0.0048
0.024
0.037272
0.01776
BODS (mg/L)
Facility Avg
Inf
910
NA
NA
NA
153
NA
54
3799
24
23
3600
180
1990
790
1007
1673
NA
214
7609
NA
NA
1812
69
NA
NA
327
Eff
47
41
NA
37
24
35
10
209
8.3
14
11.5
4.8
48
10
6.1
57
40
1.8
15.7
171
487
974
63
213
112
6.4
DET
Inf
_
_
_
_
_
_
54
_
27
_
_
_
2200
_
_
1141
_
_
5581
_
_
1812
_
_
_
1000
Eff
_
_
4.8
37
22
35
10
200
6
20
8
4
49
16
5.3
10
_
_
7
171
487
974
54
213
112
5.2
DMQ
Inf
_
_
_
_
_
_
_
3799
22
23
3600
180
1890
780
_
2394
_
214
4741
_
_
_
69
_
_
159
Eff
_
_
_
_
30
_
_
223
8.3
14.3
11.5
5.5
46
4.6
5.4
_
40
1.8
16
_
_
_
72
_
_
6.4
ANL
Inf
910
_
_
_
153
_
_
_
_
_
_
_
_
1290
1007
379
_
_
_
_
_
_
_
_
_
-
Eff
45
_
_
_
_
_
_
_
_
_
_
_
_
_
30
171
_
_
_
_
_
_
_
_
_
-
Reason Facility Data was not Considered
for BOD Limitations
Data used for calculating BOD limits
No BOD influent data
No BOD influent data
No BOD influent data
Data used for calculating BOD limits
No BOD influent data
Average influent BOD concentration below 100 mg/L
Effluent BOD concentration greater than 50 mg/L
Average influent BOD concentration below 100 mg/L
Average influent BOD concentration below 100 mg/L
Carbon treatment used in addition to biological treatment
Separate treatment trains (BIO/CPR) employed before
Data used for calculating BOD limits
Data used for calculating BOD and TSS limits
Data used for calculating BOD and TSS limits
Carbon treatment used in addition to biological treatment
Wastewater stream consists primarily of storm water
Wastewater stream consists primarily of ground water
Data used for calculating BOD limits
No BOD influent data
No BOD influent data
Effluent BOD concentration greater than 50 mg/L
Average influent BOD concentration below 100 mg/L
No BOD influent data
No BOD influent data
Data used for calculating BOD and TSS limits
Bsl Flow: Baseline flow
Facility Avg: Flow weighted average calculated from all data sources available at the facility (DET, DMQ, ANL)
DET: Detailed Questionnaire data from 1992
DMQ: Detailed Monitoring Questionnaire data from 1992 through 1994
ANL: Analytical data from sampling episodes 1993-1995
NA: Not Available
-------
Table 11-7: Selected BPT Facilities for the Non-Hazardous Subcategory
Detailed
Questionnaire ID
Number
16041
16058
16118
16120
16122
16132
16253
Discharge
Status
Indirect
Direct
Indirect
Direct
Direct
Indirect
Direct
Treatment in Place
sequential batch reactor
equalization, aerated lagoon
aerated equalization, chemical
precipitation, anaerobic fixed film, aerobic
fixed film, clarification
aerated equalization, chemical
precipitation, ammonia strip lagoons,
neutralization, activated sludge, multimedia
filter, chlorination
aerated equalization, chemical
precipitation, flocculation, clarification,
neutralization, anaerobic fixed film,
aerobic fixed film, neutralization,
coagulation, flocculation, clarification,
chlorination, aerated equalization,
multimedia filter
aerated pond
equalization, chemical precipitation,
flocculation, clarification, neutralization,
anaerobic filtration, 2-stage activated
sludge, multimedia filter
11-60
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Table 11-8: TSS Data from Landfill Facilities Selected for BPT in the Non-Hazardous Subcategory
Facility
QID
16041
16058
16118
16120
16122
16132
16253
Baseline
Flow
(MOD)
0.058917
0.003
0.0288
0.042775
0.0255
0.03
0.01776
TSS (mg/L)
Facility Average
Influent
330
14470
NA
1221
267
244
150
Effluent
36
188
NA
14
5.4
47
25
DET
Influent
364
-
-
-
-
244
180
Effluent
36
216
-
14
5.6
39
17.5
DMQ
Influent
307
-
-
1241
-
-
120
Effluent
35
188
-
13.6
5.4
47
25
ANL
Influent
70
14470
-
200
267
-
-
Effluent
46
-
-
-
12.5
-
-
Facility Avg: weighted average calculated from all data sources available at the facility (DET, DMQ, ANL).
DET: Detailed Questionnaire data from 1992
DMQ: Detailed Monitoring Questionnaire data from 1992 through 1994
ANL: Analytical data from sampling episodes 1993-1995
NA: Not Available
-------
Table 11-9: Facilities and Sample Points Used for the Development of BPT/B AT Effluent Limitations
for the Non-Hazardous Subcategory
BPT
Facility
Data
Source
Influent Sample
Point
Avg. Influent
Concentration
Effluent
Sample Point
Avg. Effluent Concentration
Ammonia (mg/L)
16041
16122
16132
DMQ
ANL
ANL
DMQ
02
01,03,05,06
01,02,03
01,02,03
679
475
181
206
04
02
07
04
5.4
1.4
1.2
5.9
BOD5 (mg/L)
16041
16058
16118
16120
16122
16132
16253
ANL
DMQ
ANL
DMQ
DMQ
ANL
DMQ
DMQ
01,03,05,06
01,02
01
01
01,02,03
01,02,03
01
910
153
1,890
780
1,007
4,740
159
02
01
02
02
07
04
02
47
29.7
Only influent cone, used
45.5
4.6
35.2
15.8
6.4
TSS (mg/L)
16120
16253
DMQ
DMQ
01
01
1,240
120
02
02
13.6
24.9
Alpha Terpineol (ug/L)
16041
16122
ANL
ANL
01,03,05,06
01,02,03
653
123
02
07
10
10
Benzoic Acid (ug/L)
16041
16122
ANL
ANL
01,03,05,06
01,02,03
15,400
9,300
02
07
50
50
P-Cresol (ug/L)
16041
ANL
01,03,05,06
1,360
02
10
11-62
-------
Table 11-9: Facilities and Sample Points Used for the Development of BPT/B AT Effluent Limitations
for the Non-Hazardous Subcategory (continued)
BPT
Facility
Data
Source
Influent Sample
Point
Avg. Influent
Concentration
Effluent
Sample Point
Avg. Effluent Concentration
Phenol (ug/L)
16041
16118
16120
16122
ANL
DET
DMQ
DMQ
ANL
ANL
01,03,05,06
01
01
01
01
01,02,03
5,120
350
16
712
395
02
02
02
02
07
10
Only influent cone, used
11
27.7
Only influent cone, used
10
Zinc (ug/L)
16041
16058
16132
DMQ
ANL
DMQ
ANL
DMQ
02
01,03,05,06
01,02
01,02,03
505
310
995
490
04
02
01
04
214
87
59
Only influent cone, used
50
ANL: Analytical data
DET: Detailed Questionnaire data
DMQ: Detailed Monitoring Questionnaire data
11-63
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Table 11-10: BPT Facility Data Excluded from the Calculation of Non-Hazardous BPT/BAT
Limitations
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
BOD5 (mg/L)
16041
DMQ
16058
16118
16120
ANL
16122
DMQ
16132
16253
02
02
-
01
01
01
01
01,02,03
01
-
-
2,200
1,290
_
5,581
1,000
04
04
01
02
02
03
03
04
02
_
22
49
15.9
5.3
5.4
7
5.2
No data
No data
Detailed questionnaire data was not used
Detailed questionnaire data was not used
Detailed questionnaire data was not used
No effluent data
Effluent sample point 03 located after
aerated equalization
Detailed questionnaire data was not used
Detailed questionnaire data was not used
TSS (mg/L)
16041
DMQ
ANL
16058
DMQ
ANL
16118
DMQ
16120
ANL
16122
DMQ
ANL
16132
DMQ
16253
02
02
1,3,5,6
01,02
01
01
01
01
01
01,02,03
01,02,03
01,02,03
01
364
307
70
14,470
_
200
267
244
180
04
04
02
01
01
02
02
02
03
03
07
04
04
02
36
35
46
216
188
-
14
5.6
5.4
12.5
39
47
17.5
Facility wastewater treatment system does
not employ filtration
Facility wastewater treatment system does
not employ filtration
Facility wastewater treatment system does
not employ filtration
Detailed questionnaire data was not used
No effluent data
Facility eliminated due to settling that can
occur in equalization tanks prior to
filtration
Facility wastewater treatment system does
not employ filtration
Detailed questionnaire data was not used
11-64
-------
Table 11-10: BPT Facility Data Excluded from the Calculation of Non-Hazardous BPT/BAT
Limitations (continued)
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
Ammonia (mg/L)
16041
16058
DMQ
ANL
16118
DMQ
16120
DMQ
ANL
16122
DMQ
16132
16253
DMQ
02
01,02
01
01
01
01
01
01
01,02,03
01
01
554
2,900
_
362
245
136
135
-
_
04
01
01
02
02
02
02
03
03
04
02
02
5.0
;
-
1.35
5.98
0.87
0.48
-
0.01
Detailed questionnaire data was not used
No data
No data
No effluent data
No data
No data
Facility wastewater treatment system
employed an air stripper
Effluent sample point 03 located after
aerated equalization
No data
No data
No influent data
Alpha Terpineol (ug/L)
16041
DMQ
16058
DMQ
ANL
16118
DMQ
16120
DMQ
ANL
16122
DMQ
16132
DMQ
16253
DMQ
02
02
01,02
01
01
01
01
01
01
01,02,03
01,02,03
01
01
_
-
_
-
_
_
-
04
04
01
01
02
02
02
02
03
03
04
04
02
02
_
;
-
;
-
_
.
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
11-65
-------
Table 11-10: BPT Facility Data Excluded from the Calculation of Non-Hazardous BPT/BAT
Limitations (continued)
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
Benzoic Acid (ug/L)
16041
DMQ
16058
DMQ
ANL
16118
DMQ
16120
DMQ
ANL
16122
DMQ
16132
DMQ
16253
DMQ
02
02
01,02
01
01
01
01
01
01
01,02,03
01,02,03
01
01
-
50
-
-
-
_
_
04
04
01
01
02
02
02
02
03
03
04
04
02
02
_
50
_
-
_
-
20
No data
No data
No data
No influent data
Influent concentration < lOxMDL
No data
No data
No data
No data
No data
No data
No data
No data
No data
No data
No influent data
P-Cresol (ug/L)
16041
DMQ
16058
DMQ
ANL
16118
DMQ
16120
DMQ
ANL
16122
DMQ
ANL
16132
DMQ
02
02
01,02
01
01
01
01
01
01
01,02,03
01,02,03
01,02,03
_
48
_
30
10
425
10
_
04
04
01
01
02
02
02
02
03
03
07
04
04
-
10
-
10
10
-
No data
No data
No data
No influent data
Influent concentration < lOxMDL
No data
No data
No data
Influent concentration < lOxMDL
Influent concentration < lOxMDL
No data
No effluent data
Influent concentration < lOxMDL
No data
No data
11-66
-------
Table 11-10: BPT Facility Data Excluded from the Calculation of Non-Hazardous BPT/BAT
Limitations (continued)
BPT
Facility
16253
DMQ
Influent
Sample
Point
01
01
Avg.
Influent
Cone.
_
Effluent
Sample
Point
02
02
Avg.
Effluent
Cone.
_
Reason for Exclusion
No data
No data
Phenol (ug/L)
16041
DMQ
16058
DMQ
ANL
16120
16122
DMQ
16132
DMQ
16253
DMQ
02
02
01,02
-
01
01
01,02,03
01,02,03
01
01
_
10
-
3,050
_
-
04
04
01
01
02
03
03
04
04
02
02
_
10
10
-
10
_
-
No data
No data
Detailed questionnaire data was not used
No influent data
Influent concentration < lOxMDL
No data
Effluent sample point 03 located after
aerated equalization
No data
No data
No data
No data
Zinc (ug/L)
16041
16058
16118
DMQ
16120
DMQ
ANL
16122
DMQ
ANL
16132
16253
DMQ
02
-
01
01
01
01
01
01
01,02,03
01,02,03
01
01
1,130
-
380
295
230
85
212,000
805
120
575
20
90
04
01
02
02
02
02
03
03
07
04
02
02
200
10
50
45
40
37
16
22
12
10
38
50
Detailed questionnaire data was not used
Detailed questionnaire data was not used
Facility wastewater treatment system
includes chemical precipitation
Facility wastewater treatment system
includes chemical precipitation
Facility wastewater treatment system
includes chemical precipitation
Detailed questionnaire data was not used
Facility wastewater treatment system
includes chemical precipitation
ANL: Analytical data
DET: Detailed Questionnaire data
DMQ: Detailed Monitoring Questionnaire data
11-67
-------
Table 11-11: BPT/BAT Limitations for the Non-Hazardous Subcategory
Pollutant or
Pollutant Property
BOD5
TSS
Ammonia
Alpha Terpineol
Benzoic Acid
P-Cresol
Phenol
Zinc
pH
Maximum for 1 day
(mg/L)
140
88
10
0.033
0.12
0.025
0.026
0.20
0)
Monthly Average Shall Not
Exceed (mg/L)
37
27
4.9
0.016
0.071
0.014
0.015
0.11
0)
0 pH shall be in the range 6.0 - 9.0 pH units.
11-68
-------
Table 11-12: National Estimates of Pollutant of Interest Reductions for BPT/BAT Options for
Municipal Solid Waste Landfills - Direct Dischargers
Pollutant of
Interest CAS
Number
C-020
C-012
C-010
C-009
C-005
C-004
C-002
98555
95487
78933
7664417
75092
7440666
7440473
7440393
7440326
7440246
68122
67641
65850
298044
20324338
18540299
142621
123911
120365
108952
108883
108101
106445
35822469
3268879
Pollutant of Interest
TOTAL PHENOLS (CHLOROFORM EXTRACTION)
TOTAL ORGANIC CARBON
TOTAL DISSOLVED SOLIDS
TOTAL SUSPENDED SOLIDS
MTRATE/NrrRITE
CHEMICAL OXYGEN DEMAND
BIOCHEMICAL OXYGEN DEMAND
ALPHA-TERPINEOL
O-CRESOL
2-BUTANONE
AMMONIANITROGEN
METHYLENE CHLORIDE
ZINC
CHROMIUM
BARIUM
TITANIUM
STRONTIUM
N,N-DIMETHYLFORMAMIDE
2-PROPANONE
BENZOICAdD
DISULFOTON
TRIPROPYLENEGLYCOL METHYL ETHER
CHROMIUM (HEXAVALENT)
HEXANOICAdD
1,4-DIOXANE
DICHLOROPROP
PHENOL
TOLUENE
4-METHYL-2-PENTANONE
P-CRESOL
1234678-HPCDD
OCDD
National Estimates
Current
Discharge
Loads
(pounds/vr)
1,005
692,275
13,158,362
319,754
109,494
2,364,028
478,004
247
62
2,846
174,382
385
857
110
1,449
123
3,404
69
1,642
350
22
840
117
9,183
55
16
298
191
228
151
6E-04
7E-03
BPT/BAT
Option I
Loads
(pounds/vr)
166
352,957
13,109,304
195,173
109,494
1,597,988
144,915
53
53
2,846
26,279
385
249
103
926
20
1,812
53
1,642
265
22
528
117
53
55
6
56
191
228
48
3E-04
2E-03
BPT/BAT
Option II
Loads
(pounds/vr)
125
231,875
12,086,905
92,491
109,494
1,497,581
105,561
53
53
2,846
16,978
385
249
103
926
20
1,812
53
1,642
265
22
528
117
53
55
6
56
191
228
48
3E-04
1E-03
BAT Option
lE-RO
Loads
(pounds/vr)
125
127,805
621,714
21,328
3,527
373,389
105,561
53
53
2,846
16,978
385
249
103
639
20
533
53
1,642
265
11
528
50
53
55
5
56
191
228
48
3E-04
1E-03
11-69
-------
Table 11-13: National Estimates of Pollutant of Interest Reductions for BPT/BAT Options for
Non-Municipal Solid Waste Landfills - Direct Dischargers
Pollutant of
Interest CAS
Number
C-002
C-004
C-009
C-005
C-020
C-012
C-010
7664417
7440246
Pollutant of Interest
Biochemical Oxygen Demand
Chemical Oxygen Demand
Total Suspended Solids
Nitrate/Nitrite
Total Phenols
Total Organic Carbon
Total Dissolved Solids
Ammonia as Nitrogen
Strontium
National Estimates
Current
Discharge
Loads
(pounds/yr)
24,492
5,633,111
22,451
73,475
241
55,107
69,189,296
153,074
61,229
BPT/BAT
Option I
Loads
(pounds/yr)
24,492
1,033,662
22,451
1,939
78
55,107
13,878,575
11,062
54,494
BPT/BAT
Option II
Loads
(pounds/yr)
24,492
907,417
22,451
1,939
53
55,107
6,385,329
6,994
54,494
BAT Option
III -RO
Loads
(pounds/yr)
24,492
147,359
8,164
1,359
53
51,025
339,723
6,994
204
11-70
-------
Table 11-14: Annual Pollutant Discharge Before and After the Implementation of BPT for
Subtitle D Municipal Solid Waste Landfill Facilities in the Non-Hazardous Subcategory
Pollutant Group
Conventional Pollutants(1)
Nonconventional Pollutants(2)
Metal Pollutants®
Organic Pollutants(4)
Pesticides(5)
Dioxins/ Furans(6)
Current
Annual Pollutant
Discharge
(pounds)
800,000
16,500,000
6,000
16,500
40
0.0075
Annual Pollutant
Discharge
After
Implementation
of BPT
(pounds)
200,000
13,950,000
3,200
6,500
29
0.0013
Annual Amount
of Pollutants
Removed by BPT
(pounds)
600,000
2,550,000
2,800
10,000 (7)
11
0.0062
(1) Includes BOD5 and TSS
(2) Includes ammonia, COD, IDS, TOC, total phenols, and nitrate/nitrite
(3) Includes barium, chromium, hexavalent chromium, strontium, titanium, and zinc
(4) Includes alpha terpineol, benzoic acid, hexanoic acid, N,N-Dimethylformamide, o-cresol, p-cresol, phenol,
tripropyleneglycol methyl ether, methylene chloride, 1,4 dioxane, 2-butanone, 2-propanone, 4-methyl-2-
pentanone, and toluene
(5) Includes dichloroprop and disulfoton
(6) Includes OCDD and 1,2,3,4,6,7,8-HpCDD
(7) EPA did not include the removal of the following volatile organic compounds: methylene chloride, 1,4
dioxane, 2-butanone, 2-propanone, 4-methyl 2-pentanone, and toluene
11-71
-------
Table 11-15: Annual Pollutant Discharge Before and After The Implementation of BPT for Subtitle
D Non-Municipal Solid Waste Landfill Facilities in the Non-Hazardous Subcategory
Pollutant Group
Conventional Pollutants (1)
Nonconventional Pollutants (2)
Metal Pollutants (3)
Current
Annual Pollutant
Discharge
(pounds)
47,000
75,100,000
61,200
Annual Pollutant
Discharge
After
Implementation
of BPT
(pounds)
47,000
7,350,000
54,500
Annual Amount
of Pollutants
Removed by BPT
(pounds)
0
67,750,000
6,700
(1) Includes BOD5 and TSS. Both facilities in the database were already in compliance with the BOD5 and TSS
limits.
(2) Includes ammonia, nitrate/nitrite, IDS, TOC, total phenol, and COD.
(3) Includes strontium - the only metal pollutant of interest for non-municipal solid waste landfills.
11-72
-------
Table 11-16: Selected BPT Facilities for the Hazardous Subcategory
Detailed
Questionnaire
ID Number
16041
16087
Discharge
Status
Indirect
Indirect
Treatment in Place
sequential batch reactor
stirred equalization, chemical
precipitation, flocculation,
neutralization, clarification, activated
sludge, chemical oxidation
11-73
-------
Table 11-17: Facilities and Sample Points Used for the Development of BPT/BAT Effluent Limitations
for the Hazardous Subcategory
BPT
Facility
Data
Source
Influent Sample
Point
Avg. Influent
Concentration
Effluent
Sample Point
Avg. Effluent
Concentration
Ammonia (mg/L)
16041
16122
16132
DMQ
ANL
ANL
DMQ
02
01,03,05,06
01,02,03
01,02,03
679
475
181
206
04
02
07
04
5.4
1.4
1.2
5.9
BOD5 (mg/L)
16041
16058
16087
16118
16120
16122
16132
16253
ANL
DMQ
ANL
DMQ
DMQ
DMQ
ANL
DMQ
DMQ
01,03,05,06
01,02
01
01
01
01,02,03
01,02,03
01
910
153
2,929
1,890
780
1,007
4,740
159
02
01
05
02
02
07
04
02
47
29.7
Only influent cone, used
29
45.5
4.6
35.2
15.8
6.4
TSS (mg/L)
16120
16253
DMQ
DMQ
01
01
1,240
120
02
02
13.6
24.9
Alpha Terpineol (ug/L)
16041
ANL
01,03,05,06
653
02
10
Aniline (ug/L)
16041
16087
ANL
ANL
01,03,05,06
01
1,060
533
02
03
10
10
Benzoic Acid (ug/L)
16041
16087
ANL
ANL
01,03,05,06
01
15,400
64,957
02
03
50
50
11-74
-------
Table 11-17: Facilities and Sample Points Used for the Development of BPT/BAT Effluent
Limitations for the Hazardous Subcategory (continued)
Pollutant
BPT
Facility
Influent Sample
Point
Avg. Influent
Concentration
Effluent
Sample Point
Avg. Effluent
Concentration
Naphthalene (ug/L)
16041
ANL
01,03,05,06
645
02
10
P-Cresol (ug/L)
16041
16087
ANL
ANL
01,03,05,06
01
1,360
5,022
02
03
10
10
Phenol (ug/L)
16041
16087
ANL
ANL
01,03,05,06
01
5,120
65,417
02
03
10
29.7
Pyridine (ug/L)
16087
ANL
01
301
03
10
Arsenic (ug/L)
16087
DMQ
ANL
01
01
1,400
584
05
03
325
312
Chromium (ug/L)
16087
DMQ
ANL
01
01
730
415
05
03
312
82
Zinc (ug/L)
16041
16087
DMQ
ANL
DMQ
02
01,03,05,06
01
505
310
550
04
02
05
214
85
380
ANL: Analytical data
DET: Detailed Questionnaire data
DMQ: Detailed Monitoring Questionnaire data
11-75
-------
Table 11-18: BPT Facility Data Excluded from the Calculation of Hazardous BPT/BAT Limitations
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
BOD5 (Transferred from the Non-Hazardous subcategory) (mg/L)
16041
DMQ
16058
16087
ANL
16118
16120
ANL
16122
DMQ
16132
16253
02
02
-
01
01
01
01
01
01
01,02,03
01
-
-
2,980
3,721
2,200
1,290
-
5,581
1,000
04
04
01
03
03
02
02
03
03
04
02
-
22
258
66
49
15.9
5.3
5.4
7
5.2
No data
No data
Detailed questionnaire data was not used
Effluent concentration above 50 mg/L
Effluent concentration above 50 mg/L
Detailed questionnaire data was not used
Detailed questionnaire data was not used
No effluent data.
Effluent sample point 03 located after
aerated equalization
Detailed questionnaire data was not used
Detailed questionnaire data was not used
TSS (Transferred from the Non-Hazardous subcategory) (mg/L)
16041
DMQ
ANL
16058
DMQ
ANL
16087
DMQ
ANL
16118
DMQ
16120
ANL
16122
DMQ
ANL
16132
DMQ
16253
02
02
1,3,5,6
01,02
01
01
01
01
01
01
01
01
01,02,03
01,02,03
01,02,03
01
364
307
70
14,470
586
579
172
-
200
267
244
180
04
04
02
01
01
03
05
03
02
02
02
03
03
07
04
04
02
36
35
46
216
188
51
114
78
-
14
5.6
5.4
12.5
39
47
17.5
Facility wastewater treatment system does
not employ filtration
Facility wastewater treatment system does
not employ filtration
Facility wastewater treatment system does
not employ filtration
Facility wastewater treatment system does
not employ filtration
Detailed questionnaire data was not used
No effluent data
Facility eliminated due to settling that can
occur in equalization tanks prior to
filtration
Facility wastewater treatment system does
not employ filtration
Detailed questionnaire data was not used
11-76
-------
Table 11-18: BPT Facility Data Excluded from the Calculation of Hazardous BPT/BAT Limitations
(continued)
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
Ammonia (Transferred from the Non-Hazardous subcategory) (mg/L)
16041
16058
DMQ
ANL
16087
DMQ
ANL
16118
DMQ
16120
DMQ
ANL
16122
DMQ
16132
16253
DMQ
02
01,02
01
01
01
01
01
01
01
01
01
01,02,03
01
01
554
2,900
209
_
362
245
136
135
-
_
04
01
01
03
05
03
02
02
02
02
03
03
04
02
02
5.0
;
153
_
1.35
5.98
0.87
0.48
-
0.01
Detailed questionnaire data was not used
No data
No data
No effluent data
No data
No data
Minimal ammonia removal
No data
No data
Facility wastewater treatment system
employed an air stripper
Effluent sample point 03 located after
aerated equalization
No data
No data
No influent data
Alpha Terpineol (ug/L)
16041
DMQ
16087
DMQ
ANL
02
02
01
01
01
-
10
04
04
03
05
03
_
10
No data
No data
No data
No data
Influent concentration < lOxMDL
Aniline (ug/L)
16041
DMQ
16087
DMQ
02
02
01
01
-
-
04
04
03
05
_
_
No data
No data
No data
No data
Benzoic Acid (ug/L)
16041
DMQ
16087
DMQ
02
02
01
01
-
_
04
04
03
05
_
_
No data
No data
No data
No data
11-77
-------
Table 11-18: BPT Facility Data Excluded from the Calculation of Hazardous BPT/BAT Limitations
(continued)
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
Naphthalene (ug/L)
16041
DMQ
16087
DMQ
ANL
02
02
01
01
01
_
25
04
04
03
05
03
_
10
No data
No data
No data
No data
Influent concentration < lOxMDL
P-Cresol (ug/L)
16041
DMQ
16087
DMQ
02
02
01
01
-
_
04
04
03
05
-
_
No data
No data
No data
No data
Phenol (ug/L)
16041
DMQ
16087
DMQ
02
02
01
_
98,500
04
04
03
05
_
814
No data
No data
Detailed questionnaire data was not used
No data
Pyridine (ug/L)
16041
DMQ
ANL
16087
DMQ
02
02
1,3,5,6
01
01
23
_
04
04
02
03
05
10
_
No data
No data
Influent concentration < lOxMDL
No data
No data
11-78
-------
Table 11-18: BPT Facility Data Excluded from the Calculation of Hazardous BPT/BAT Limitations
(continued)
BPT
Facility
Influent
Sample
Point
Avg.
Influent
Cone.
Effluent
Sample
Point
Avg.
Effluent
Cone.
Reason for Exclusion
Arsenic (ug/L)
16041
DMQ
ANL
16087
02
02
1,3,5,6
01
535
1,420
04
04
02
03
569
193
No data
No data
Negative percent removal
Detailed questionnaire data was not used
Chromium (ug/L)
16041
DMQ
ANL
16087
02
02
1,3,5,6
01
210
419
82
731
04
04
02
03
120
417
46
501
Detailed Questionnaire data was not used
No removal
Influent concentration < lOxMDL
Detailed questionnaire data was not used
Zinc (ug/L)
16041
16087
ANL
02
01
01
1,130
560
126
04
03
03
200
279
52
Detailed questionnaire data was not used
Detailed questionnaire data was not used
Influent concentration < lOxMDL
ANL: Analytical data
DET: Detailed Questionnaire data
DMQ: Detailed Monitoring Questionnaire data
11-79
-------
Table 11-19: BPT/BAT Limitations for the Hazardous Subcategory
Pollutant or
Pollutant Property
BOD5
TSS
Ammonia
Alpha Terpineol
Aniline
Benzoic Acid
Naphthalene
P-Cresol
Phenol
Pyridine
Arsenic
Chromium
Zinc
PH
Maximum for 1 day
(mg/L)
220
88
10
0.042
0.024
0.119
0.059
0.024
0.048
0.072
1.1
1.1
0.535
0)
Monthly Average Shall Not
Exceed (mg/L)
56
27
4.9
0.019
0.015
0.073
0.022
0.015
0.029
0.025
0.54
0.46
0.296
0)
pH shall be in the range 6.0 - 9.0 pH units.
11-80
-------
Table 11-20: Comparison of Long-Term Averages for Nonconventional and Toxic Pollutants
Regulated Under BAT for the Non-Hazardous Subcategory
Pollutant
Ammonia
Alpha Terpineol
Benzoic Acid
P-Cresol
Phenol
BPT Option II:
Equalization +
Biological +
Multimedia Filter
(mg/L)
5.4
0.010 ND
0.050 ND
0.010 ND
0.010 ND
Reverse Osmosis
single stage effluent
(mg/L)
13
0.010 ND
0.093
0.253
0.185
Reverse Osmosis
second stage
effluent
(mg/L)
0.59
0.010ND
0.050 ND
0.022
0.029
ND: Non-detect
11-81
-------
oo
to
Raw
Wastewater
Aerated
Equalization Tank
Activated SludgeAeration Basin
-Return Activated Sludge -
Air
Aeration System
Clarification
Treated
Effluent
Waste Activated Sludge
Sludge Dewatering
Figure 11-1: BPT/BCT/BAT/PSES/PSNS Non-Hazardous Subcategory Option I Flow Diagram
-------
Raw
Wastewater
oo
Aerated
Equalization Tank
Clarification
Activated SludgeAeration Basin
Multimedia
Filtration
A *
Aeration System
-Return Activated Sludge-
Waste Activated
Sludge
Sludge
Dewatering
Backwash
Return
Treated
Effluent
Figure 11-2: BPT/BCT/BAT Non-Hazardous Subcategory Option II & NSPS Flow Diagram
-------
Raw
Wastewater
oo
Aerated
Equalization Tank
Sodium Hydroxide &
Polymer Feed Systems
^
I
V i
r
c
-\
^
\
3>
Y
>,
"locculation Tank
Primary Clarification
Phosphoric Acid Feed
System
Waste Sludge
Treated
Effluent
Secondary Clarification
Activated SludgeAeration Basin
-Return Activated Sludge -
Aeration System
Waste Activated Sludge
Backwash Return
Figure 11-3: BPT/BCT/BAT Hazardous Subcategory Option II & NSPS Flow Diagram
-------
Treated
Effluent
Raw
Wastewater
oo
Aerated
Equalization Tank
Clarification
Activated SludgeAeration Basin
-Return Activated Sludge-
Aeration System
Waste Activated
Sludge
Sludge
Dewatering
Backwash
Return
Concentrate
Return
Figure 11-4: BAT Non-Hazardous Subcategory Option III Flow Diagram
-------
12.0 REFERENCES
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AWWA, March 1978.
2. Chemical Marketing Reporter, New York: Schnell Publishing, September 7, 1992.
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Characterization of Leachate, EPA-600/2-77-186a.
4. Chian, E. S. and F. B. DeWalle, Evaluation of Leachate Treatment, Volume II, Biological and
Physical-Chemical Processes, EPA-600/2-77-186b.
5. CWC Engineering Software, W/W Costs & Design Criteria Guidelines, 2.0, Software Operation
Manual.
6. Eckenfelder, Wesley, Industrial Pollution Control, New York: McGraw-Hill, 1989.
7. Engineering News Record, New York: McGraw-Hill, September, 1992. (INDEXES)
8. Freeman, Harry., Ed., Standard Handbook of Hazardous Waste Treatment and Disposal, New
York: McGraw-Hill, 1989.
9. George, J. A., Sanitary Landfill-Gas and Leachate Control, the National Perspective, Office
of Solid Waste Management Programs, U.S. EPA, 1972.
10. Howard, Philip H., Environmental Fate and Exposure for Organic Chemicals - Volume I -
Large Production and Priority Pollutants, Chelsea, MI: Lewis Publishers, Inc., 1989.
11. Joint Task Force, Design of Municipal Wastewater Treatment Plants, MOP 8, Alexandria:
Water Environment Federation, 1991.
12. McBean, Edward A., et al., Solid Waste Landfill Engineering and Design, Englewood Cliffs,
NJ: Prentice Hall PTR, 1995.
13. McGinley, Paul M. and Peter Kmet, Formation, Characteristics, Treatment and Disposal of
Leachate from Municipal Solid Waste Landfills, Wisconsin Department of Natural Resources
Special Report, August 1, 1984.
12-1
-------
14. Metry, A. A. and F. L. Cross, Leachate Control and Treatment, Volume 7, Westport, CT:
Environmental Monograph Series, Technomic Publishing Co., 1977.
15. Melendez, Beth, Department of Environmental Engineering Sciences, University of Florida, A
Study of Leachate Generated from Construction and Demolition Landfills., August 2, 1996.
16. Peters, Max S. and Timmerhaus, Klaus D., Plant Design and Economics for Chemical
Engineers, New York: McGraw-Hill, 1980.
17. Rast, Richard, Sr. Ed., Environmental Restoration Unit Cost Book, R.S. Means and Delta
Technologies Group, 1996.
18. Sobotka & Co., Inc., Case History Data Compiled and Reported to the U. S. Environmental
Protection Agency Economic Analysis Branch, Office of Solid Waste, 1986.
19. Stecher, Paul G., et al., Ed., The Merck Index - 8th Edition, Rahway, NJ: Merck & Co., Inc.,
1968.
20. Tchobanoglous, George, Wastewater Engineering, 2nd Ed., New York: McGraw-Hill, 1979.
21. Technical Practice Committee, Sludge Dewatering, MOP 20, Washington, DC: Water Pollution
Control Federation, 1983.
22. Technical Practice Committee, Wastewater Treatment Plant Design, MOP 36, Washington,
DC: Water Pollution Control Federation, 1977.
23. U. S. Army Corps of Engineers, Computer Assisted Procedures for the Design and Evaluation
of Wastewater Treatment Systems, Operation Manual, 1981.
24. U. S. Environmental Protection Agency, Best Demonstrated Available Technology Background
Document for U and P Wastes and Multi-Source Leachate (F039), Volume A, Final, PB90-
234337, 1990.
25. U.S. Environmental Protection Agency, CERCLA Site Discharges to POTWs Treatability
Manual, EPA 540/2-90-007, 1990.
26. U.S. Environmental Protection Agency, Characterization of MWC(Municipal Waste
Combustion) Ashes and Leachates from MSW(Municipal Solid Waste) Landfills, Monofills,
and Co-Disposal Sites, EPA/550-SW-87-028, 1087.
12-2
-------
27. U.S. Environmental Protection Agency, Characterization of Municipal Waste Combustion Ash,
Ash Extracts, andLeachates, EPA 530-SW-90-029A, 1990.
28. U.S. Environmental Protection Agency, Detailed Costing Document for the Centralized Waste
Treatment Industry, EPA 821-R-95-002, 1995.
29. U.S. Environmental Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the
Pesticide Chemical Industry, Proposed, EPA 821-R-92-005, 1992.
30. U.S. Environmental Protection Agency, Development Document for Effluent Limitations
Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers, EPA
440/1-87/009, 1987.
31. U.S. Environmental Protection Agency, Development Document for Proposed Effluent
Limitations Guidelines and Standards for the Centralized Waste Treatment Industry, EPA
821-R-95-006, 1995.
32. U. S. Environmental Protection Agency, Draft Background Document, Case Studies on Ground-
Water and Surface Water Contamination from Municipal Solid Waste Landfills, Criteria for
Municipal Solid Waste Landfills (40 CFR 258), EPA/530-SW-88-040, 1988.
33. U.S. Environmental Protection Agency, Draft Background Document, Summary of Data on
Municipal Solid Waste Landfill Leachate Characteristics, Criteria for Municipal Solid Waste
Landfills (40 CFR 258), EPA/530-SW-88-038, 1988.
34. U.S. Environmental Protection Agency, Evaluation of Flow Equalization in Municipal
Wastewater Treatment, EPA-600/2-79-096, 1979.
35. U.S. Environmental Protection Agency, Fate of Priority Pollutants in Publicly Owned
Treatment Works, Final Report, Volume I, EPA-440/1-82/303, 1982.
36. U.S. Environmental Protection Agency, Fate of Priority Pollutants in Publicly Owned
Treatment Works, Final Report, Volume II, EPA-440/1-82/303, 1982.
37. U.S. Environmental Protection Agency, Federal Water Pollution Control Act Amendments, 3 3
U.S.C. 1251 et seq., 1972 (as amended by Clean Water Act, Pub. L, 95-217, 1977, and Water
Quality Act, Pub. L, 100-4, 1987).
38. U.S. Environmental Protection Agency, 50 POTW Study Database, 1978-80.
12-3
-------
39. U.S. Environmental Protection Agency, Ground-Water Leachate Treatment Systems,
EPA/625/R-94/005, 1995.
40. U.S. Environmental Protection Agency, Guidance Manual on the Development and
Implementation of Local Discharge Limitations Under the Pretreatment Program, December
1987.
41. U.S. Environmental Protection Agency, Guideline Series, Control of Volatile Organic
Compound Emissions from Industrial Wastewater, Draft, EPA 453/D-93-056, 1992.
42. U. S. Environmental Protection Agency, Leachate Baseline Report: Determination ofMunicipal
Landfill Leachate Characteristics, D-33-10-6-17, 1986.
43. U.S. Environmental Protection Agency, Management of Hazardous Waste Leachate, PB 81 -
189359, 1980.
44. U.S. Environmental Protection Agency, Methods for Chemical Analysis of Water and
Wastewater, Cincinnati, 1979.
45. U. S. Environmental Protection Agency, Municipal Landfill Gas Condensate Final Report,
EPA/600/52-87/090, 1987.
46. U.S. Environmental Protection Agency, Process Control Manual for Aerobic Biological
Wastewater Treatment Facilities, Washington, DC, 1977.
47. U.S. Environmental Protection Agency, Performance Evaluation and Troubleshooting at
Municipal Wastewater Treatment Facilities, EPA-43 0/9-78-001, 1978.
48. U.S. Environmental Protection Agency, Resource Conservation and Recovery Act, 1976.
49. U.S. Environmental Protection Agency, Risk Reduction Engineering (RREL) Treatability
Database - Version 5.0 (draft), Cincinnati, 1994.
50. U. S. Environmental Protection Agency, Site Technology Capsule: Rochem Separation Systems,
Inc. Disc Tube Module (DTM) Technology (draft), Cincinnati, 1995.
51. U.S. Federal Register, Volume 58, No. 130, Friday, July 9, 1993, pp. 36885-36888.
52. Weast, Robert C., Ed., Handbook of Chemistry and Physics - 55th Edition, Cleveland, OH:
CRC Press, Inc., 1974.
12-4
-------
53. Yui, Bill, Alan Yi, and James Urek, Treatability Study on the Biological Treatment of Landfill
Leachate and Gas Condensate, Environmental Engineering, 1992.
54. Settlement Agreement, Natural Resources Defense Council, Inc. vs. Train, 8 ERC 2120
(D.D.C. 1976), modified, 12 ERC 1833 (D.D.C. 1979), modified by Orders dated October 26,
1982; August 2, 1983; January 6, 1984; July 5, 1984; January 7, 1985; April 24, 1986; and
January 8, 1987.
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System, Organic Chemicals, Plastics and Synthetic Fibers Point Source Category, Confidential
Record, November 5, 1987.
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New York: McGrawHill, 1991.
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Sons, Inc., 1985.
12-5
-------
APPENDIX A:
SECTION 308 SURVEY FOR LANDFILLS
INDUSTRY POPULATION ANALYSIS
A-l
-------
Appendix A: Section 308 Survey for Landfills-Industry Population Analysis
The list of landfills needed to define the landfill population in the United States was developed from
various sources: state environmental and solid waste departments, and other state contacts; the
National Survey of Hazardous Waste Treatment Storage, Disposal, and Recycling Facilities
respondent list; Environmental Ltd.'s 1991 Directory of Industrial and Hazardous Waste Management
Firms; the Resource Conservation and Recovery Act (RCRA) 1992 list of Municipal Solid Waste
Landfills; and the Resource Conservation and Recovery Information System (RCRIS) National
Oversight Database.
The information provided by state environmental departments was requested during early stages of
the rulemaking process for Centralized Waste Treatment and represented 1987-88 data for both
active and inactive landfills. This information was incomplete to some extent. For 18 of the 50 states
only limited or no information was available. Hence, these states were contacted during the data
gathering effort for the development of effluent guidelines and standards for Landfills and Incinerators
to obtain updated lists of landfills and wastewater collection information.
The duplication of landfill entries among various sources was eliminated as far as possible by cross
checking using computer programs. However, some duplication in Subtitle D landfills is inevitable
as some of the various identifiers were unclear.
Landfill population was divided into two categories: Subtitle C (hazardous waste) and Subtitle D
(non-hazardous waste). In total, mailing addresses were compiled for 595 Subtitle C landfills and
9,882 Subtitle D landfills. In addition, 448 Subtitle D landfills were identified for which addresses
were inadequate for delivery. Thus the population of Subtitle D amounted to 10,330. Table 1
provides a list of the number of landfills with deliverable mailing addresses in each state by category.
A-2
-------
Selection of the landfills to survey
From the identified landfill population of 10,925 Subtitle C and D facilities, screener surveys were
mailed to 4996. Facilities receiving the screener survey included all of the 595 Subtitle C landfills and
a sample of the 9,882 Subtitle D facilities with mailable addresses.
TABLE 1. COUNT OF LANDFILLS WITH MAILABLE ENTRIES IN EACH STATE
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecti-
cut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Subtitle-
D
238
201
90
134
630
216
125
8
91
277
15
112
182
101
118
118
121
73
Subtitle-C
38
1
2
3
16
12
22
14
9
17
1
6
14
29
13
8
33
17
Total
276
202
92
137
646
228
147
22
100
294
16
118
196
130
131
126
154
90
A-3
-------
State
Maine
Maryland
Massachu-
setts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New
Hapmshire
New Jersey
New
Mexico
New York
North
Carolina
North
Dakota
Ohio
Oklahoma
Oregon
Pennsyl-
vania
Rhode
Island
South
Carolina
Subtitle-
D
291
50
722
762
257
97
128
257
41
127
58
467
121
565
244
85
119
189
231
41
12
127
Subtitle-C
2
5
1
9
4
3
7
1
8
3
0
8
7
10
39
1
24
7
10
22
0
9
Total
293
55
723
771
261
100
135
258
49
130
58
475
128
575
283
86
143
196
241
63
12
136
A-4
-------
State
South
Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washing-
ton
West
Virginia
Wisconsin
Wyoming
Puerto
Rico
Guam
Total
Subtitle-
D
193
112
601
92
73
440
72
57
183
218
0
0
9882
Subtitle-C
0
9
70
7
0
8
9
5
3
45
3
1
595
Total
193
121
671
99
73
448
81
62
186
263
3
1
10477
A-5
-------
The remaining 4401 screener surveys were sent to Subtitle D landfills. A statistical approach was
taken to sample the 9882 deliverable Subtitle D facilities. For sampling purposes, the 9882 Subtitle
D landfills were stratified into three categories:
1) landfills with known wastewater collection
2) landfills from states with fewer than 100 landfills and
3) landfills from states with more than 100 landfills.
All landfills with known wastewater collection were included in the landfill survey sample. The
population included 134 landfills with known wastewater collection (1.35%).
Landfills in states with fewer than 100 landfills were stratified from the landfills in states with more
than 100 landfills. This was simply a sampling technique for random sampling and was done to
ensure the inclusion of a representative number of facilities from each stratum.
There were 16 states with under 100 landfills each (after exclusion of known wastewater collectors),
which accounted for 892 landfills. A screener survey was mailed to each of these 892 landfills. The
remaining 24 states, with over 100 landfills each, accounted for 8856 landfills. A random sample of
3375 was taken from this strata, and a screener survey was mailed to each of these randomly selected
landfills. Table 2 summarizes the stratification.
Screener surveys were distributed by both Federal Express and U.S. certified mail: 1916 surveys
were sent via Federal Express, which resulted in 94% receipt confirmation; 3080 surveys were sent
via U.S. certified mail, which resulted in 92% receipt confirmation. Twenty three additional screener
surveys were mailed because of change of ownership, or different mailing address, even though the
physical location of the landfill remained same. A summary of analysis on these additional surveys
is presented in Table 3. Thus, a total of 5020 landfill screener surveys were distributed.
A-6
-------
TABLE 2. SUMMARY OF STRATIFICATION
Strata # Population
1
2
3
4
Subtitle C
Subtitle D -known wastewater
generators
Subtitle D - states with < 100 landfills
Subtitle D - states with >100 landfills
Total
# in frame
595
134
892
8856
10477
# in sample
595
134
892
3375
4996
A completed screener survey was received from 3628 landfills excluding the late arrivals. This
includes response from a pre-test screener survey. The status of remaining screener surveys is:
• 353 surveys were deemed non-deliverables due to incorrect/non-traceable addresses and were
returned to the sender
• 1008 landfills were presumed to be non-respondents
• 4 landfills were found to be out-of-business
• 26 landfills were declared ineligible to participate in the survey for reasons discovered during
the mid-point remainder calls
• 1 respondent refused to respond to the survey.
For statistical analysis purposes, screener surveys in each of the above categories were traced back
to the respective strata. Table 4 presents a breakdown of these remaining screener surveys by strata.
A-7
-------
TABLE 3. SUMMARY OF ADDITIONAL SCREENER SURVEY ANALYSIS
Screener ID
15100
15101
15102
15103
15104
15105
15106
15107
15108
15109
15110
15111
15112
15113
15114
15116
15117
15118
15119
15120
15121
15122
15123
15124
Original ID
13235
14044
13876
11594
14117
13953
13264
10985
14449
12167
12883
14112
11319
12327
11528
13389
13995
14779
11422
13976
12422
11299
10851
Stratum
4
4
4
4
4
4
4
4
4
1
4
4
3
4
4
3
4
4
4
4
1
4
4
Reason for re-assignment
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
additional screener resp. was obtained for a new landfill
additional screener resp. was obtained for a new landfill
additional screener resp. was obtained for a new landfill
additional screener resp. was obtained for a new landfill
response transferred from pre-test screener survey
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
screener sent to former owner or incorrect address
A-8
-------
Among the 3628 survey responses received, a total of 3581 surveys were sent to data entry; 44 were
declared ineligible upon reviewing their response, and were not processed any further; 3 remained
incomplete because of unsuccessful attempts to contact the respondents to complete the review
process. A total of 859 respondents were found collecting some type of wastewater (landfills
collecting only storm water were not included) generated from their landfill operations, and were
considered as in scope population from which a sample of facilities will be selected to receive the
detailed Section 308 landfill questionnaire. The rest of the surveys sent to data entry were considered
out of scope. For statistical analysis purposes, screener surveys not sent to data entry, the out of
scope surveys, and the in scope surveys were traced back to the respective strata, and a count of
these in each strata is presented in Table 4.
A response bias query was conducted on about 5.65% (57 landfills) of the 1008 presumed non-
respondents. Each of these 57 randomly-selected landfills was called to discern the reasons that the
screener survey was not received. The result of this effort is as follows:
- 25 facility contacts said that they over looked/misplaced/forgotten the survey (1 in stratum
2; 1 in stratum 3; and 23 in stratum 4)
- 19 facility contacts said that they did not recall receiving any survey (2 in stratum 1; 3 in
stratum 3; and 14 in stratum 4)
- 7 facility contacts said that they did not feel it was applicable to them (1 in stratum 1; 2
in stratum 3; and 4 in stratum 4)
- 3 facility contacts said that they forgot and would complete the survey and return (2 in
stratum 3; and 1 in stratum 4)
- 2 facility contacts said that they received duplicate surveys, and this was checked and
found correct (these 2 are in stratum 4)
A-9
-------
- 1 facility contact said that they are under bankruptcy proceedings (this is in stratum 1).
A total of 39 landfill screener survey responses were received past the deadline, since these were
received after the close of the screener survey database, they were not considered for any further
analyses. Among these 39 late arrivals, only four landfills collected wastewater generated from
landfill operations (landfill leachate and contaminated groundwater), and none of these four landfills
have any on-site treatment. Additional information on these four landfills is: two were municipal,
non-commercial, and discharged untreated wastewater to a Publicly Owned Treatment Works
(POTW); one was government, commercial, and discharged untreated wastewater to a POTW; one
was private and sent their wastewaters for off-site disposal.
Questionnaire distribution
A total of 859 landfill operators reported that they collect one or more type of wastewater generated
from the landfill operations (landfills collecting only storm water were not included). These landfills
were considered as the sample frame to receive the Section 308 questionnaire for landfills. Facilities
with treatment were targeted most heavily, while some facilities without treatment but collect
wastewater were randomly selected to receive only Section A of the questionnaire. The facilities
selected fall into any of the following eight categories:
1. Commercial private, municipal, or government facilities which have wastewater treatment and
are direct or indirect dischargers. A census was conducted of this part of the industry.
2. Commercial private, municipal, or government facilities which have wastewater treatment and
are zero dischargers (do not discharge to surface water or to a POTW). Approximately 25%
of these were randomly chosen to receive the questionnaire.
A-10
-------
3. Non-commercial private facilities with wastewater treatment. Approximately 40% of these
were randomly chosen to receive the questionnaire.
4. Facilities with no wastewater treatment. Approximately 10% of these were randomly chosen
to receive only Section A of the questionnaire.
5. Commercial facilities who accept PCB wastes. Only one facility was in this category, and was
chosen.
6. Municipal hazardous waste landfills. There were two facilities in this category, and a census
was conducted of this part of the industry.
7. Small business with no wastewater treatment. A census was conducted of this part of the
industry.
8. Pre-test facility which was not in the screener population. Only one facility was in this
category, and was chosen based on knowledge of the industry and professional judgement.
For statistical analysis purposes, the facilities in each of the aforementioned categories were traced
back through their screener surveys to the respective strata, and a count of these in each strata is
presented in Table 5.
Section 308 Questionnaires were sent to a total of 252 mailing addresses that were considered in
scope from their screener responses. The questionnaire response was received from 248 landfills.
The remaining four landfills were presumed to be non-respondents. The questionnaire responses
received included four responses from pre-test questionnaires. Thus a total of 248 responses were
available for further review.
Among the survey responses obtained, 22 were declared out of scope upon reviewing their response
and were not processed any further; 226 were reviewed for completeness and technical accuracy and
A-ll
-------
were entered into the landfill questionnaire database. For statistical analysis purposes, the 252
questionnaires that were sent, including the 226 questionnaires reviewed and placed in the database,
were traced back to the original screener population strata, and a count of these in each strata is
presented in Table 4.
A-12
-------
TABLE 4. COUNT OF SCREENER SURVEYS IN EACH CATEGORY BY STRATA1
Category
Non-respondents
Ineligible2
Incomplete
In scope
Out of scope
Quest, recipients
Quest, in database
Quest, out of scope
Quest, non-
response
Stratum 1
69
79
2
141
305
51
46
4
1
Stratum 2
15
9
0
91
20
35
32
3
0
Stratum 3
170
45
1
222
456
77
71
4
2
Stratum 4
755
294
0
405
1941
88
76
11
1
Total
1009
427
3
859
2722
2523
2263
22
4
each of the category presented below, a list of Survey ID numbers and their respective
strata # is presented in Appendix A.
2This includes all non-deliverables, out-of-business, and duplicate addresses.
3An additional one is the pre-test questionnaire, which is not part of any stratum.
A-13
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TABLE 5. QUESTIONNAIRE SELECTION BY CATEGORY
Category
Pri/com/muni/govt./with treat/D-I
discharge
Pri/non-com/with treatment
Pri/com/muni/govt./with treat/Zero
discharge
No treatment
PCB facilities with treatment
Municipal/hazardous
Small business/no treatment
Pre-test not in Screener population4
Totals
Stratu
m 1
12
30
1
5
0
2
1
-
51
Stratu
m2
27
2
0
6
0
0
0
-
35
Stratu
m3
51
3
7
14
1
0
1
-
77
Stratum
4
38
7
0
38
0
0
5
-
88
Total
128
42
8
63
1
2
7
1
252
4This is a pre-test questionnaire and is not in any stratum because, it was not in the screener
database.
A-14
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TABLE 6. IN SCOPE SCREENERS NOT SELECTED FOR QUESTIONNAIRE BY
CATEGORY
Category
Pri/com/muni/govt./with treat/D-I
discharge
Pri/non-com/with treatment
Pri/com/muni/govt./with treat/Zero
discharge
No treatment
PCB facilities with treatment
Municipal/hazardous
Small business/no treatment
Totals
Stratu
m 1
0
31
7
52
0
0
0
90
Stratu
m2
0
0
2
54
0
0
0
56
Stratu
m3
0
6
9
130
0
0
0
145
Stratum
4
0
27
7
283
0
0
0
317
Total
0
64
25
519
0
0
0
608
A-15
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APPENDIX B:
DEFINITIONS,
ACRONYMS, AND ABBREVIATIONS
B-l
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APPENDIX B: DEFINITIONS, ACRONYMS, AND ABBREVIATIONS
ADMINISTRATOR: The Administrator of the U.S. Environmental Protection Agency.
AGENCY: The U.S. Environmental Protection Agency.
AVERAGE MASTER FILE: A method of calculating the average raw wastewater concentration for each
pollutant of interest in a subcategory. The Average Master File was calculated using all available data
collected in the Landfills industry study.
BASELINE FLOW: Estimated wastewater discharge flow rate for a selected facility in 1992 based on their
Detailed Questionnaire response.
BAT: The best available technology economically achievable, applicable to effluent limitations to be achieved
by July 1, 1984, for industrial discharges to surface waters, as defined by Sec. 304(b)(2)(B) of the CWA.
BCT: The best conventional pollutant control technology, applicable to discharges of conventional pollutants
from existing industrial point sources, as defined by Sec. 304(b)(4) of the CWA.
BOD5: Biochemical oxygen demand - Five Day. A measure of the biochemical decomposition of organic
matter in a water sample. It is determined by measuring the dissolved oxygen consumed by microorganisms
to oxidize the organic contaminants in a water sample under standard laboratory conditions of five days and
70 degrees Celsius. BOD5 is not related to the oxygen requirements in chemical combustion.
BPT: The best practicable control technology currently available, applicable to effluent limitations to be
achieved by July 1,1977, for industrial discharges to surface waters, as defined by Sec. 304(b)(l) of the CWA.
CAPDET: Computer-Assisted Procedure for the Design and Evaluation of Wastewater Treatment Systems.
Developed by the U.S. Army Corp. of Engineers, CAPDET is intended to provide planning level cost estimates
to analyze alternate design technologies for wastewater treatment systems.
CAPTIVE: Used to describe a landfill that is directly associated with an industrial or commercial operation.
See Chapter 2 for the conditions that a captive landfill must meet in order to be excluded from the landfill
effluent guideline.
CELL: An area of a landfill that is separated from other areas by an impervious structure. Each cell has a
separate leachate collection system or would require a separate leachate collection system if one were
installed. Individual leachate collection systems that are combined at the surface are considered separate
systems by this definition.
CLEAN WATER ACT (CWA): The Federal Water Pollution Control Act Amendments of 1972 (33 U.S.C.
Section 1251 et seq.X as amended by the Clean Water Act of 1977 (Pub. L. 95-217), and the Water Quality
Act of 1987 (Pub. L. 100-4).
B-2
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CLEAN WATER ACT (CWA) SECTION 308 QUESTIONNAIRE:
A questionnaire sent to facilities under the authority of Section 308 of the CWA, which requests information
to be used in the development of national effluent guidelines and standards.
CLOSED: A facility or portion thereof that is currently not receiving or accepting wastes and has undergone
final closure.
COMMERCIAL FACILITY: A facility that treats, disposes, or recycles/recovers the wastes of other facilities
not under the same ownership as this facility. Commercial operations are usually made available for a fee or
other remuneration. Commercial waste treatment, disposal, or
recycling/recovery does not have to be the primary activity at a facility for an operation or unit to be considered
"commercial".
CONTAMINATED GROUND WATER: Water below the land surface in the zone of saturation which has
been contaminated by landfill leachate. Contaminated ground water occurs at landfills without liners or at
facilities that have released contaminants from a liner system. Ground water may also become contaminated
if the water table rises to a point where it infiltrates the landfill or the leachate collection system.
CONTAMINATED STORM WATER: Storm water which comes in direct contact with landfill wastes, the
waste handling and treatment areas, or wastewater that is subject to the limitations and standards. Some
specific areas of a landfill that may produce contaminated storm water include (but are not limited to): the
open face of an active landfill with exposed waste (no cover added); the areas around wastewater treatment
operations; trucks, equipment or machinery that has been in direct contact with the waste; and waste
dumping areas.
CONVENTIONAL POLLUTANTS: Constituents of wastewater as determined by Sec. 304(a)(4) of the
CWA, including pollutants classified as biochemical oxygen demand, total suspended solids, oil and grease,
fecal coliform, and pH.
DEEP WELL INJECTION: Disposal of wastewater into a deep well such that a porous, permeable formation
of a larger area and thickness is available at sufficient depth to ensure continued, permanent storage.
DETAILED MONITORING QUESTIONNAIRE (DMQ): Questionnaires sent to collect monitoring data
from 27 selected landfill facilities based on responses to the Section 308 Questionnaire.
DIRECT DISCHARGER: A facility that discharges or may discharge treated or untreated wastewater into
waters of the United States.
DRAINED FREE LIQUIDS: Aqueous wastes drained from waste containers (e.g., drums, etc.) prior to
landfilling. Landfills which accept containerized waste may generate this type of wastewater.
EFFLUENT LIMITATION: Any restriction, including schedules of compliance, established by a State or the
Administrator on quantities, rates, and concentrations of chemical, physical, biological, and other constituents
B-3
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which are discharged from point sources into navigable waters, the waters of the contiguous zone, or the
ocean. (CWA Sections 301 (b) and 304(b)).
EPA: The U.S. Environmental Protection Agency.
EXISTING SOURCE: Any facility from which there is or may be a discharge of pollutants, the construction
of which is commenced before the publication of the proposed regulations prescribing a standard of
performance under Sec. 306 of the CWA.
FACILITY: All contiguous property owned, operated, leased or under the control of the same person or entity.
GAS CONDENSATE: A liquid which has condensed in the landfill gas collection system during the extraction
of gas from within the landfill. Gases such as methane and carbon dioxide are generated due to microbial
activity within the landfill, and must be removed to avoid hazardous conditions.
GROUND WATER: The body of water that is retained in the saturated zone which tends to move by
hydraulic gradient to lower levels.
HAZARDOUS SUBCATEGORY: For the purposes of this guideline, Hazardous subcategory refers to all
landfills regulated under Subtitle C of RCRA.
HAZARDOUS WASTE: Any waste, including wastewater, defined as hazardous under RCRA (40 CFR
261.3).
INACTIVE: A facility or portion thereof that is currently not treating, disposing, or recycling/recovering
wastes.
INDIRECT DISCHARGER: A facility that discharges or may discharge wastewater into a publicly-owned
treatment works (POTW).
INTRA-COMPANY: A facility that treats, disposes, or recycles/recovers wastes generated by off-site
facilities under the same corporate ownership. The facility may also treat on-site generated wastes.
LANDFILL: An area of land or an excavation in which wastes are placed for permanent disposal, that is not
a land application or land treatment unit, surface impoundment, underground injection well, waste pile, salt
dome formation, a salt bed formation, an underground mine or a cave.
LANDFILL GENERATED WASTEWATER: Wastewater generated by landfill activities and collected for
treatment, discharge or reuse, include: leachate, contaminated ground water, storm water runoff, landfill gas
condensate, truck/equipment washwater, drained free liquids, floor washings, and wastewater from recovering
pumping wells.
LEACHATE: Leachate is a liquid that has passed through or emerged from solid waste and contains soluble,
suspended, or miscible materials removed from such waste. Leachate is typically collected from a liner system
B-4
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above which waste is placed for disposal. Leachate may also be collected through the use of slurry walls,
trenches or other containment systems.
LEACHATE COLLECTION SYSTEM: The purpose of aleachate collection system is to collect
leachate for treatment or alternative disposal and to reduce the depths of leachate buildup or level of saturation
over the low permeability liner.
LINER: The liner is a low permeability material or combination of materials placed at the base of a landfill to
reduce the discharge to the underlying or surrounding hydrogeologic environment. The liner is designed as a
barrier to intercept leachate and to direct it to a leachate collection system.
LONG-TERM AVERAGE (LTA): For purposes of the effluent guidelines, average pollutant levels achieved
over a period of time by a facility, subcategory, or technology option. LTAs are used in developing the
limitations and standards in the landfill regulation.
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT:
A permit to discharge wastewater into waters of the United States issued under the National Pollutant
Discharge Elimination System, authorized by Section 402 of the CWA.
NEW SOURCE: As defined in 40 CFR 122.2, 122.29, and 403.3 (k), a new source is any building,
structure, facility, or installation from which there is or may be a discharge of pollutants, the construction of
which commenced (1) for purposes of compliance with New Source Performance Standards (NSPS)
established under CWA section 306, after the promulgation of these standards; or (2) for the purposes of
compliance with Pretreatment Standards for New Sources (PSNS), after the publication of proposed
standards under CWA section 307 (c), if such standards are thereafter promulgated in accordance with that
section.
NONCONVENTIONAL POLLUTANTS: Pollutants that are neither conventional pollutants listed at 40
CFR Part 401.16 nor priority pollutants listed in Appendix A of 40 CFR Part 423.
NON-CONTAMINATED STORM WATER: Storm water which does not come in direct contact with
landfill wastes, the waste handling and treatment areas, or wastewater that is subject to the limitations and
standards. Non-contaminated storm water includes storm water which flows off the cap, cover,
intermediate cover, daily cover, and/or final cover of the landfill.
NON-HAZARDOUS SUBCATEGORY: For the purposes of this report, Non-Hazardous subcategory refers
to all landfills regulated under Subtitle D of RCRA.
NON-WATER QUALITY ENVIRONMENTAL IMPACT: Deleterious aspects of control and treatment
technologies applicable to point source category wastes, including, but not limited to air pollution, noise,
radiation, sludge and solid waste generation, and energy usage.
B-5
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NSPS: New Source Performance Standards, applicable to new sources of direct dischargers whose
construction is begun after the publication of the proposed effluent regulations under CWA section 306.
OCPSF: Organic chemicals, plastics, and synthetic fibers manufacturing point source category.
(40 CFR Part 414).
OFF-SITE: Outside the boundaries of a facility.
ON-SITE: The same or geographically contiguous property, which may be divided by a public or private right-
of-way, provided the entrance and exit between the properties is at a crossroads intersection, and access is
by crossing as opposed to going along the right-of-way. Non-contiguous properties owned by the same
company or locality but connected by a right-of-way, which it controls, and to which the public does not have
access, is also considered on-site property.
PASS THROUGH: A pollutant is determined to "pass through" POTWs when the nationwide median
percentage removed by well-operated POTWs achieving secondary treatment is less than the percentage
removed by the industry's direct dischargers that are using the BAT technology.
POINT SOURCE: Any discernable, confined, and discrete conveyance from which pollutants are or may be
discharged.
POLLUTANTS OF INTEREST (POIs): Pollutants commonly found in landfill generated wastewater. For
the purposes of this report, a pollutant of interest is a pollutant that is detected three or more times above a
treatable level at a landfill, and must be present at more than one facility.
PRIORITY POLLUTANT: One hundred twenty-six compounds that are a subset of the 65 toxic pollutants
and classes of pollutants outlined in Section 307 of the CWA. The priority pollutants are specified in the
NRDC settlement agreement (Natural Resources Defense Council et al v. Train, 8 E.RC. 2120 [D.D.C.
1976], modified 12 E.RC. 1833 [D.D.C. 1979]).
PRODUCT STEWARDSHIP: These activities mean the acceptance for treatment and disposal of
only the following materials: spent, or unused products; shipping and storage containers with
product residue; off-specification products.
PSES: Pretreatment standards for existing sources of indirect discharges, under Sec. 307(b) of the CWA.
PSNS: Pretreatment standards for new sources of indirect discharges, applicable to new sources whose
construction has begun after the publication of proposed standards under CWA section 307 (c), if such
standards are thereafter promulgated in accordance with that section.
PUBLIC SERVICE: The provision of landfill waste disposal services to individual members of the general
public, publicly-owned organizations (schools, universities, government agencies, municipalities) and
not-for-profit organizations for which the landfill does not receive a fee or other remuneration.
B-6
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PUBLICLY OWNED TREATMENT WORKS (POTW): Any device or system, owned by a state or
municipality, used in the treatment (including recycling and reclamation) of municipal sewage or industrial
wastes of a liquid nature that is owned by a state or municipality. This includes sewers, pipes, or other
conveyances only if they convey wastewater to a POTW providing treatment (40 CFR 122.2).
RCRA: The Resource Conservation and Recovery Act of 1976 (RCRA) (42 U.S.C. Section 6901 et seq.i
which regulates the generation, treatment, storage, disposal, or recycling of solid and hazardous wastes.
SUBTITLE C LANDFILL: A landfill permitted to accept hazardous wastes under Sections 3001 and 3019 of
RCRA and the regulations promulgated pursuant to these sections, including 40 CFR Parts 260 through 272.
SUBTITLE D LANDFILL: A landfill permitted to accept only non-hazardous wastes under Sections 4001
through 4010 of RCRA and the regulations promulgated pursuant to these sections, including 40 CFRParts 257
and 258.
SURFACE IMPOUNDMENT: A natural topographic depression, man-made excavation, or diked area formed
primarily of earthen materials (although it may be lined with man-made materials), used to temporarily or
permanently treat, store, or dispose of waste, usually in the liquid form. Surface impoundments do not include
areas constructed to hold containers of wastes. Other common names for surface impoundments include
ponds, pits, lagoons, finishing ponds, settling ponds, surge ponds, seepage ponds, and clarification ponds.
TOXIC POLLUTANTS: Pollutants declared "toxic" under Section 307(a)(l) of the Clean Water Act.
TRUCK/EQUIPMENT WASHWATER: Wastewater generated during either truck or equipment washes at
the landfill. During routine maintenance or repair operations, trucks and/or equipment
used within the landfill (e.g., loaders, compactors, or dump trucks) are washed and the resultant washwaters
are collected for treatment.
VARIABILITY FACTOR: The daily variability factor is the ratio of the estimated 99th percentile of the
distribution of daily values divided by the expected value, median or mean, of the distribution of the daily data.
The monthly variability factor is the estimated 95th percentile of the distribution of the monthly averages of the
data divided by the expected value of the monthly averages.
ZERO DISCHARGE: No discharge of pollutants to waters of the United States or to a POTW. Also included
in this definition are alternative discharge or disposal of pollutants by way of evaporation, deep-well inj ection,
off-site transfer, and land application.
B-7
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INDEX
Activated Sludge
Capital Cost Curves (9-71, 9-72)
Costing (9-20, 9-36)
Evaluated as BAT - Hazardous Subcategory (11-31, 11-84)
Evaluated as BAT - Non-Hazardous Subcategory (11-29, 11-82, 11-83, 11-85)
Evaluated as BPT - Hazardous Subcategory (11-20, 11-84)
Evaluated as BPT - Non-Hazardous Subcategory (11-8, 11-82, 11-83)
O&M Cost Curve (9-73)
Technology Description (8-34, 8-79)
Treatment Performance (8-50, 8-58, 8-88)
Types (8-36)
Age (see Landfills Industry)
Air Pollution Reduction Impacts (10-1)
Air Stripping
Number of Landfills currently using (8-53)
Technology Description (8-14, 8-67)
Ammonia
Limitations - Hazardous Subcategory (2-20, 11-80)
Limitations -Non-Hazardous Subcategory (2-21, 11-68)
National Estimates of Pollutant of Interest Reductions (11-69, 11-70)
Pretreatment Standards - Hazardous Subcategory (2-5, 11-48)
Pretreatment Standards -Non-Hazardous Subcategory (2-5, 11-35)
Raw Wastewater Concentrations-Hazardous Subcategory (5-20, 5-25, 6-50, 6-51, 8-56, 8-58,
11-56, 11-74, 11-77)
Raw Wastewater Concentrations - Non-Hazardous Subcategory (5-20, 5-23, 5-24, 5-27, 5-30,
6-49, 6-51, 8-54, 8-55, 8-60, 11-56, 11-62, 11-65)
Treated Effluent Concentrations - Hazardous Subcategory (8-56, 8-58, 11-56, 11-74, 11-77)
Treated Effluent Concentrations - Non-Hazardous Subcategory (8-54,8-55, 8-60,11-56,11-62,
11-65)
Anaerobic Biological Systems
Technology Description (8-30, 8-75)
Technology Performance (8-46, 8-54, 8-85)
Applicable Waste Streams (2-2, 6-1, 6-8, 6-30)
INDEX-1
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INDEX
Aqueous Waste Disposal Impacts (10-3)
Attached-Growth Biological Systems
Technology Description (8-31, 8-76, 8-77, 8-78)
Types (8-31)
BAT (1-2)
Costs (9-31, 9-32, 9-40, 9-44, 9-49, 9-54)
Limitations - Hazardous Subcategory (2-4, 2-20, 11-31, 11-80)
Limitations - Non-Hazardous Subcategory (2-4, 2-21, 11-29, 11-68)
Technology Description (8-1)
Technology Options - Hazardous Subcategory (11-84)
Technology Options - Non-Hazardous Subcategory (11-81, 11-82, 11-83, 11-85)
BCT (1-2)
Costs (9-30, 9-31, 9-40, 9-44, 9-49)
Limitations (2-4, 11-27)
Technology Options (11-82, 11-83, 11-84)
Best Management Practices (8-1)
Benzoic Acid
Limitations - Hazardous Subcategory (2-20, 11-80)
Limitations -Non-Hazardous Subcategory (2-21, 11-68)
National Estimates of Pollutant of Interest Reductions (11-69)
Pretreatment Standards - Hazardous Subcategory (11-48)
Pretreatment Standards - Non-Hazardous Subcategory (11-41)
Raw Wastewater Concentrations -Hazardous Subcategory (5-20, 5-25, 6-50, 6-53, 8-56, 8-58,
11-56, 11-74, 11-77)
Raw Wastewater Concentrations - Non-Hazardous Subcategory (5-20, 5-22, 5-24, 5-27, 5-30,
6-49, 6-53, 8-54, 8-55, 8-60, 11-56, 11-62, 11-66)
Treated Effluent Concentrations - Hazardous Subcategory (8-56, 8-58, 11-56, 11-74, 11-77)
Treated Effluent Concentrations - Non-Hazardous Subcategory (8-54,8-55, 8-60,11-56,11-62,
11-66)
Biological Treatment
As a selection criteria for BPT facilities (11-8, 11-9, 11-10, 11-20, 11-21, 11-22, 11-55, 11-58,
11-59, 11-60, 11-73, 11-82, 11-83, 11-84)
Number of Landfills currently using (3-37, 8-26, 8-53)
INDEX-2
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INDEX
Technology Description (8-24)
Types (8-26)
BOD5 (4-2,5-13,6-10,6-18)
As a selection criteria for BPT facilities (11-11, 11-55, 11-57, 11-58, 11-59)
Concentration with Age of Landfill (5-11, 5-30, 6-10)
Limitations - Hazardous Subcategory (2-20, 11-80)
Limitations - Non-Hazardous Subcategory (2-21, 11-68)
National Estimates of Pollutant of Interest Reductions (11-69, 11-70)
Raw Wastewater Concentrations - Hazardous Subcategory (5-20, 5-25, 6-50, 6-51, 8-56, 8-58,
11-56, 11-74, 11-76)
Raw Wastewater Concentrations -Non-Hazardous Subcategory (5-20, 5-23, 5-24, 5-27, 5-30,
6-31, 6-49, 6-51, 8-54, 8-55, 8-60, 11-56, 11-59, 11-62, 11-64)
Regulated Pollutant (7-14, 7-21)
Treated Effluent Concentrations - Hazardous Subcategory (8-56, 8-58, 11-74, 11-76)
Treated Effluent Concentrations-Non-Hazardous Subcategory (8-54, 8-55, 8-60,11-62,11-64)
BPT (1-1, 11-6)
Costs (9-29, 9-30, 9-40, 9-44, 9-49)
Limitations - Hazardous Subcategory (2-4, 2-20, 11-23, 11-80)
Limitations - Non-Hazardous Subcategory (2-4, 2-21, 11-11, 11-68)
Selected Facilities (11-60, 11-73)
Technology Options - Hazardous Subcategory (11-20, 11-84)
Technology Options - Non-Hazardous Subcategory (11-8, 11-82, 11-83)
Breakpoint Chlorination
Capital Cost Curve (9-83)
Costs (9-27, 9-36)
O&M Cost Curve (9-84)
Technology Description (8-12)
Captive/Intra-Company Facilities
Definition (3-2)
Exemption from Guideline (2-10, 3-13)
Number in Landfills Population (3-12, 3-25)
Carbon Adsorption
Capital Cost Curve (9-81)
Costs (9-26, 9-36)
INDEX-3
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INDEX
Number of Landfills currently using (8-53)
O&M Cost Curve (9-82)
Technology Description (8-21,8-71)
Treatment Performance (8-48, 8-55)
Chemical Oxidation/Reduction
Number of Landfills currently using (8-53)
Technology Description (8-11, 8-12, 8-65, 8-66)
Chemical Precipitation
Capital Cost Curves (9-63, 9-65, 9-67)
Costs (9-14, 9-36, 9-41, 9-42, 9-43)
Evaluated as BAT (11-28, 11-31, 11-84)
Evaluated as BPT - Hazardous Subcategory (11-20, 11-21, 11-22 11-84)
Evaluated as BPT - Non-Hazardous Subcategory (11-8)
Number of Landfills currently using (3-37, 8-53)
O&M Cost Curves (9-64, 9-66, 9-68)
Technology Description (8-8)
Treatment Performance (8-46, 8-48, 8-50, 8-54, 8-55, 8-58, 8-85, 8-86, 8-88)
Clarification
Capital Cost Curves (9-69, 9-74)
Costs (9-19, 9-22, 9-36)
Evaluated as BAT - Hazardous Subcategory (11-31, 11-84)
Evaluated as BAT - Non-Hazardous Subcategory (11-29, 11-82, 11-83, 11-85)
Evaluated as BPT - Hazardous Subcategory (11-20, 11-84)
Evaluated as BPT - Non-Hazardous Subcategory (11-8, 11-82, 11-83, 11-85)
O&M Cost Curves (9-70, 9-75)
Technology Description (8-6, 8-62)
Contaminated Ground Water
CERCLA Ground Water Data (4-13, 6-7)
Concentration of Pollutants (5-8, 5-25, 5-27)
Definition (3-19, 6-4)
Exclusion from Guideline (2-5, 3-12, 3-19, 5-8, 6-1, 6-4)
Monitoring (3-6, 3-8, 3-9)
Quantity of Flow Generated (3-19, 3-34, 6-26, 6-27, 6-29)
INDEX-4
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INDEX
Costs (9-1)
Additional Cost Factors (9-8, 9-37)
BAT (9-31, 9-40, 9-44, 9-49, 9-54)
BCT (9-30, 9-40, 9-44, 9-49)
BPT (9-29, 9-40, 9-44, 9-49)
Land Costs (9-9)
Methodology (9-6,9-7,9-11)
Models (9-1, 9-3, 9-34, 9-35, 9-40)
Monitoring Costs (9-10, 9-38)
NSPS (9-32, 9-40)
Off-Site Disposal Costs (9-11, 9-39, 11-23)
Option Specific Costing Logic Flow Diagram (9-59)
Residual Disposal Costs (9-9)
Retrofit Costs (9-9)
Treatment Chemicals (9-14, 9-41, 9-42, 9-43)
Treatment Technologies (5-14, 9-11, 9-36, 9-40)
Cost Models (9-1)
Current Discharge Concentrations (7-3)
Alternate Methodology - Hazardous Subcategory (7-5)
Alternate Methodology - Non-Hazardous Subcategory (7-5)
Denitrification Systems
In Removal of Nitrate/Nitrite (7-10, 7-17)
Technology Description (8-41)
Discharge Information
Discharge Types (3-22, 3-42)
Quantity of Flow Discharged (3-34, 6-4, 6-5, 6-6, 6-26, 6-27, 6-29, 6-30)
Raw Wastewater Concentrations - Hazardous Subcategory (5-20, 5-25, 6-17, 6-24, 6-25, 6-50,
6-51, 6-52, 6-53, 6-55, 8-56, 8-58, 11-56, 11-74, 11-76)
Raw Wastewater Concentrations - Non-Hazardous Subcategory (5-20, 5-22, 5-24, 5-27, 5-30,
6-17, 6-21, 6-23, 6-49, 6-51, 6-52, 6-53, 6-54, 8-54, 8-55, 8-60, 11-54, 11-56, 11-59, 11-61,
11-62, 11-64)
Sources of Wastewater (3-16,6-1)
Drained Free Liquids (2-2, 3-1, 3-12, 3-17, 6-1, 6-3)
Quantity of Flow Generated (3-17, 3-34, 6-14, 6-26, 6-27, 6-29, 6-30)
INDEX-5
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INDEX
Energy Requirements (5-15,10-5)
Equalization
Capital Cost Curve (9-60)
Costs (9-12, 9-36)
Evaluated as BAT - Hazardous Subcategory (11-31, 11-84)
Evaluated as BAT - Non-Hazardous Subcategory (11-29, 11-82, 11-83, 11-85)
Evaluated as BPT - Hazardous Subcategory (11-20, 11-84)
Evaluated as BPT - Non-Hazardous Subcategory (11-8, 11-82, 11-83)
Number of Landfills currently using (3-37, 8-53)
Technology Description (8-3,8-61)
Equipment/Truck Washwater (see Truck/Equipment Washwater)
Filtration (8-14)
Diatomaceous Earth (8-17)
Fabric Filters (8-21)
Membrane Filtration (8-18)
Reverse Osmosis (8-19, 8-70, 9-78)
Ultrafiltration (8-18, 8-69)
Multimedia Filtration (8-17, 8-68, 9-76, 9-77)
Number of Landfills currently using (3-37, 8-53)
Sand Filtration (8-15)
Flocculation
Capital Cost Curve (9-61)
Costs (9-13, 9-36)
O&M Cost Curve (9-62)
Technology Description (8-5, 8-62)
Floor Washings (2-2, 3-12, 6-1)
Quantity of Flow Generated (3-18, 3-34, 6-26, 6-27, 6-29, 6-30)
Fluidized Bed Biological Reactor
Technology Description (8-33, 8-78)
Granular Activated Carbon (see Carbon Adsorption)
INDEX-6
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INDEX
Gravity Assisted Separation (also see Clarification)
Number of Landfills currently using (8-53)
Technology Description (8-6, 8-62)
Ground Water (see Contaminated Ground Water)
Hazardous Subcategory (2-1, 5-2)
BAT Options (11-31, 11-84)
BPT Options (11-20, 11-84)
Limitations (2-20, 11-23, 11-31, 11-80)
Pollutants Considered for Regulation - Indirect Dischargers (7-27)
Pollutants of Interest (7-30)
Pollutants Selected for Regulation - Direct Dischargers (7-21)
Pretreatment Standards (2-5, 11-32, 11-48)
Raw Wastewater Concentrations (5-20, 5-25, 6-24, 6-25, 6-50, 6-51, 6-52, 6-53, 6-55, 8-56,
8-58, 11-56, 11-74, 11-76)
Subcategorization Approach (5-1, 5-2)
Wastewater Flow and Discharge (6-6, 6-26, 6-30)
Impacts
Air Pollution (7-11, 7-12, 7-13, 7-19, 10-1)
Energy Requirements (10-5)
Solid and Other Aqueous Waste Disposal (10-3)
Non-Water Quality (5-15,10-1)
Intra-Company/Captive Facilities
Definition (3-2)
Exemption from Guideline (2-10, 3-13)
Number in Landfills Population (3-12, 3-25)
Ion Exchange
Technology Description (8-23, 8-72)
Iron Coprecipitation
Technology Description (8-11)
Laboratory-Derived Wastewater (2-2, 3-1, 3-12, 3-18, 6-1, 6-3, 6-8)
INDEX-7
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INDEX
Lagoon Systems
Aerated (8-28, 8-73)
Aerobic (8-27)
Anaerobic (8-28)
-
Facultative (8-29, 8-74)
Number of Landfills currently using (8-26)
Technology Description (8-26)
Land Costs (9-9)
Landfill Gas Condensate (2-2, 3-1, 3-12, 3-17, 6-1, 6-2, 6-13)
Definition (3-17, 6-2)
Monitoring Data (6-32)
Quantity of Flow Generated (3-17, 3-34, 6-13, 6-26, 6-27, 6-29, 6-30)
Treatment (6-13)
Landfill Leachate (2-2, 3-1, 3-12, 3-16, 6-1, 6-2, 6-8)
Definition (3-16, 6-2)
Literature Data (6-12, 6-31)
Quantity of Flow Generated (3-17, 3-34, 6-11, 6-26, 6-27, 6-29, 6-30, 6-31)
Landfills Industry
Age (5-11, 5-28, 5-30)
Area (3-26, 3-27)
Cells (3-28, 5-6, 5-13)
General Information (3-14)
Industry Description (3-1)
Location of Landfills (3-11, 3-12, 3-24, 5-9)
Number of Facilities (3-11, 3-12, 3-24)
Ownership Types (3-1, 3-25, 5-9)
Population (3-11, 3-24, 3-29, 3-30)
Regulatory History of the Landfills Industry (3-3)
Regulatory Types (3-2)
Waste Received (3-15, 3-31, 3-32, 3-33, 5-3)
Leachate (see Landfill Leachate)
Leachate Collection Systems (3-20, 3-35)
INDEX-8
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INDEX
Limitations
BPT/BAT/NSPS Limitations - Hazardous Subcategory (2-4, 2-20, 11-23, 11-80)
Facilities and Sample Points Selected (11-74)
Facilities and Sample Points Excluded (11-76)
BPT/BAT/NSPS Limitations - Non-Hazardous Subcategory (2-4, 2-21, 11-11, 11-68)
Facilities and Sample Points Selected (11-62)
Facilities and Sample Points Excluded (11-64)
Calculations of Effluent Limitations (11-6)
Long-Term Averages (11-2,11-81)
PSES (11-32, 11-34, 11-48)
Variability Factors (11-5)
Long-Term Averages (11-1, 11-2, 11-81)
Monitoring Costs (9-10)
Monofills (5-5, 5-22, 5-24, 11-14)
Multimedia Filtration
As a selection criteria for BPT facilities (11-9, 11-10, 11-16, 11-20, 11-21, 11-22, 11-60, 11-
61,11-83, 11-84)
Capital Cost Curve (9-76)
Costs (9-23, 9-36)
Evaluation as BAT - Hazardous Subcategory (11-31, 11-84)
Evaluation as BAT - Non-Hazardous Subcategory (11-29, 11-83, 11-85)
Evaluation as BPT - Hazardous Subcategory (11-20, 11-21, 11-22, 11-84)
Evaluation as BPT - Non-Hazardous Subcategory (11-9, 11-10, 11-16, 11-83)
O&M Cost Curve (9-77)
Technology Description (8-17,8-68)
Treatment Performance (8-46, 8-48, 8-54, 8-55, 8-85, 8-86)
National Estimates (3-11, 3-43)
National Risk Management Research Laboratory (NRMRL) Treatability Database (see Pass-Through
Analysis)
Neutralization
Number of Landfills currently using (8-53)
Technology Description (8-4, 8-61)
INDEX-9
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INDEX
Nitrification Systems
In Removal of Nitrate/Nitrite (7-10, 7-17)
Technology Description (8-40)
Non-Hazardous Subcategory (2-1, 5-3)
BAT Options (11-29, 11-82, 11-83, 11-85)
BPT Options (11-8, 11-82, 11-83)
Limitations (2-21, 11-11, 11-29, 11-68)
Pollutants Considered for Regulation - Indirect Dischargers (7-25)
Pollutants of Interest (7-29)
Pollutants Selected for Regulation - Direct Dischargers (7-14)
Pretreatment Standards (2-5, 11-32, 11-34)
Raw Wastewater Concentrations (5-20, 5-22, 5-24, 5-27, 5-30, 6-21, 6-23, 6-31, 6-49, 6-51,
6-52, 6-53, 6-54, 8-54, 8-55, 8-60, 11-54, 11-56, 11-59, 11-61, 11-62, 11-64)
Subcategorization Approach (5-1, 5-3)
Wastewater Flow and Discharge (6-5, 6-27, 6-29, 6-30)
Non-Water Quality Impacts (10-1)
NSPS (1-3,2-5,)
Costs (9-32, 9-40)
Limitations (2-20,2-21, 11-31, 11-68, 11-80, 11-83, 11-84)
Off-Site Disposal Costs (9-11, 9-39, 11-23)
Ownership Status (see Landfills Industry)
P-Cresol
Limitations - Hazardous Subcategory (2-20, 11-80)
Limitations -Non-Hazardous Subcategory (2-21, 11-68)
National Estimates of Pollutant of Interest Reductions (11-69)
Pretreatment Standards - Hazardous Subcategory (11-48)
Pretreatment Standards - Non-Hazardous Subcategory (11-43)
Raw Wastewater Concentrations - Hazardous Subcategory (5-20, 6-50, 6-53, 8-56, 8-58,11-56,
11-75, 11-78)
Raw Wastewater Concentrations -Non-Hazardous Subcategory (5-20, 5-22, 5-24, 5-30, 6-49,
6-53, 8-54, 8-55, 8-60, 11-56, 11-62, 11-66)
Treated Effluent Concentrations - Hazardous Subcategory (8-56, 8-58, 11-75, 11-78)
Treated Effluent Concentrations-Non-Hazardous Subcategory (8-54, 8-55, 8-60,11-62,11-66)
INDEX-10
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INDEX
Pass-Through Analysis
Approach (7-22)
BAT Performance Data (7-22, 7-32, 7-34)
Data Editing (7-23)
NRMRL Treatability Database (4-15, 7-22, 7-31)
50-POTW Study Database (4-14, 7-22, 7-31)
Results - Hazardous Subcategory (7-27, 7-35, 11-48)
Results - Non-Hazardous Subcategory (7-25, 7-33, 11-34)
pH (6-18)
Limitations (2-20,2-21, 11-68, 11-80)
Raw Wastewater Concentrations (6-31, 6-51)
Phenol
Limitations - Hazardous Subcategory (2-20, 11-80)
Limitations -Non-Hazardous Subcategory (2-21, 11-68)
National Estimates of Pollutant of Interest Reductions (11-69)
Pretreatment Standards - Hazardous Subcategory (11-48)
Pretreatment Standards - Non-Hazardous Subcategory (11-44)
Raw Wastewater Concentrations-Hazardous Subcategory (5-20, 5-26, 6-50, 6-53,11-56, 11-
75, 11-78)
Raw Wastewater Concentrations - Non-Hazardous Subcategory (5-20, 5-22, 5-24, 5-27, 5-30,
6-49,6-53, 11-56, 11-63, 11-67)
Treated Effluent Concentrations - Hazardous Subcategory (8-56, 8-58, 11-75, 11-78)
Treated Effluent Concentrations-Non-Hazardous Subcategory (8-54, 8-55, 8-60,11-63,11-67)
Pollutants Considered for Regulation - Indirect Dischargers
Hazardous Subcategory (7-22, 7-27, 7-35)
Non-Hazardous Subcategory (7-22, 7-25, 7-33)
Pollutants Not Selected for Regulation - Direct Dischargers
Hazardous Subcategory (7-15, 7-16, 7-18)
Non-Hazardous Subcategory (7-9, 7-10, 7-13)
Pollutants of Interest
Determination (7-2, 7-7, 7-36)
Hazardous Subcategory List (6-50, 7-30)
Metals (11-54)
Non-Hazardous Subcategory List (6-49, 7-29)
INDEX-11
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INDEX
Pollutant Reductions (7-3, 11-35, 11-41, 11-43, 11-44, 11-48, 11-69, 11-70, 11-71, 11-72)
Pollutants Selected for Regulation - Direct Dischargers
Determination of (7-7, 7-37)
Hazardous Subcategory (2-20, 7-14, 7-21, 11-80)
Non-Hazardous Subcategory (2-21, 7-8, 7-10, 11-68)
Population (see Landfills Industry)
50-POTW Study (see Pass-Through Analysis)
Powdered Activated Carbon
Technology Description (8-38, 8-80)
Preliminary Data Summary (4-1)
Pressure Filtration
Technology Description (8-42, 8-83)
Pretreatment Methods for Wastes Received at Landfills (3-21, 3-36)
Primary Clarification (see Clarification)
PSES (1-3,2-5, 11-32)
Hazardous Subcategory (11-48)
Non-Hazardous Subcategory (11-34, 11-82)
Ammonia (11-35)
Benzoic Acid (11-41)
P-Cresol (11-43)
Phenol (11-44)
Public Comments (11-45)
PSNS (1-4,2-5, 11-53)
Hazardous Subcategory (11-53)
Non-Hazardous Subcategory (11-53, 11-82)
Public Comments
PSES (11-45)
INDEX-12
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INDEX
QA/QC and Other Data Editing Procedures (4-15)
Quantity of Wastes Received (3-15, 3-31, 3-32, 3-33)
Questionnaires (4-3, Appendix A)
Detailed Monitoring Questionnaire (4-9)
Detailed Technical Questionnaire (4-6)
Screener Surveys (4-4)
RCRA
Subtitle C (3-3)
Subtitle D (3-6)
Recovering Pumping Wells (2-3, 3-1, 3-12, 3-20, 6-4)
Definition (3-20, 6-4)
Quantity of Flow Generated (3-20, 3-34)
Residual Disposal Costs (9-9)
Retrofit Costs (9-9)
Reverse Osmosis
Capital Cost Curve (9-78)
Costs (9-24,9-36, 11-29)
Evaluated as BAT-Non-Hazardous Subcategory (11-29, 11-41, 11-69, 11-70, 11-81, 11-85)
Technology Description (8-19,8-70)
Treatment Performance (8-51, 8-60, 8-89, 11-69, 11-70, 11-81)
Rotating Biological Contactors
Technology Description (8-31,8-76)
Sampling Program
Analytical Data (5-24, 5-25, 5-27, 6-37, 6-54, 6-55, 8-54, 8-55, 8-56, 8-58, 8-60, 11-56, 11-
59, 11-61, 11-62, 11-64, 11-74, 11-76)
Pollutants Analyzed in EPA Sampling (6-15, 6-33, 6-37)
Sampling Episodes (4-11, 4-12, 4-23, 4-24, 4-25)
Sampling Results for Performance of Treatment Processes (8-45, 8-54, 8-55, 8-56, 8-58, 8-60)
Site Visits (4-10, 4-11, 4-12, 4-23, 4-25)
INDEX-13
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INDEX
Scope of the Regulation (2-2)
Screener Surveys (see Questionnaires)
Secondary Clarification (see Clarification)
Section304(m)(l-4)
Sequencing Batch Reactors
BPT Facility for Hazardous Subcategory (11-24)
BPT Facility for Non-Hazardous Subcategory (11-12)
Number of Landfills currently using (8-26)
Technology Description (8-39,8-81)
Treatment Performance (8-48, 8-49, 8-55, 8-56, 8-86, 8-87)
Sludge Handling (8-41, 8-53)
Gravity Thickening (8-42, 8-82)
Pressure Filtration (8-42, 8-83)
Sludge Dewatering (8-42, 8-53, 9-25, 11-9)
Sludge Drying Beds (8-43, 8-84, 9-25, 9-36, 9-79, 9-80)
Sludge Slurrying (8-42)
Solid Waste Disposal Impacts (10-3)
Storm Water
Contaminated (2-7, 3-1, 3-12, 3-19, 6-1, 6-3)
Non-Contaminated (non-contact) (2-7, 3-12, 3-19, 6-1, 6-4)
Quantity of Flow Generated (3-19, 3-34, 6-26, 6-27, 6-29)
Stripping (see Air Stripping)
Subcategories (see Hazardous and Non-Hazardous Subcategories)
Landfill Subcategories (2-1, 5-2, 5-3)
Subcategorization (2-1, 5-1)
Age (5-11, 5-28, 5-30)
Approach (5-1)
Factors Considered (5-3)
Landfill Subcategories (2-1, 5-2, 5-16)
INDEX-14
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INDEX
Waste Types (5-3)
Wastewater Characteristics (5-7)
Treatment Performance (8-45)
Episode 4626 (8-46, 8-54, 8-85)
Episode 4667 (8-48, 8-55, 8-86)
Episode 4721 (8-49, 8-56, 8-87)
Episode 4759 (8-50, 8-58, 8-88)
Episode 4687 (8-51, 8-60, 8-89)
Trickling Filters
Technology Description (8-32, 8-77)
Truck/Equipment Washwater (2-2, 3-1, 3-12, 3-18, 6-1, 6-3, 6-14)
Definition (3-18, 6-3, 6-14)
Quantity of Flow Generated (3-18, 3-34, 6-15, 6-26, 6-27, 6-29, 6-30)
TSS (6-18)
As a selection criteria for BPT facilities (11-16, 11-25, 11-61)
Limitations - Hazardous Subcategory (2-20, 11-80)
Limitations - Non-Hazardous Subcategory (2-21, 11-68)
National Estimates of Pollutant of Interest Reductions (11-69, 11-70)
Raw Wastewater Concentrations-Hazardous Subcategory (5-20, 5-26, 6-50, 6-51, 8-56, 8-58,
11-56, 11-74, 11-76)
Raw Wastewater Concentrations - Non-Hazardous Subcategory (5-20, 5-23, 5-24, 5-27, 5-30,
6-31, 6-49, 6-51, 8-54, 8-55, 8-60, 11-56, 11-61, 11-62, 11-64)
Regulated Pollutant (7-14, 7-21)
Treated Effluent Concentrations - Hazardous Subcategory (8-56, 8-58, 11-74, 11-76)
Treated Effluent Concentrations-Non-Hazardous Subcategory (8-54, 8-55, 8-60,11-62,11-64)
Ultrafiltration (also see Filtration)
Technology Description (8-18,8-69)
Variability Factors (11-1, 11-5)
Waste Receipts (3-15, 3-31, 3-32, 3-33, 5-3)
Wastewater (6-1)
CERCLA Ground Water Data (4-13, 6-18)
INDEX-15
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INDEX
Characterization (5-7, 6-7, 6-17, 6-31, 6-32, 6-37, 6-49, 6-50, 6-51, 6-52, 6-53, 6-54, 6-55)
Industry Supplied Data (4-13)
Quantity of Flow Generated (3-16, 3-34, 6-4, 6-5, 6-6, 6-26, 6-27, 6-29, 6-30)
Sources (2-2, 3-16, 6-1)
Technology for Treatment of (3-22, 3-37, 5-14, 8-53)
Treatment Performance (8-45)
Wetlands Treatment
Technology Description (8-41)
Zero/Alternative Discharge Treatment
Cost (9-7, 9-11, 9-39, 11-20, 11-23)
Discharge Types (3-22, 3-42)
Evaluated as BAT - Hazardous subcategory (11-31)
Evaluated as BPT - Hazardous subcategory (11-21)
Number of Landfills currently using (6-7, 11-24)
Technology Description (8-44)
INDEX-16
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