United States
Environmental Protection
Agency
Permits Division and
Industrial Technology Division
Washington, DC 20460
September 1985
Water
Pretreatment
Guidance Manual
for the Use of
Production-Based
Pretreatment Standards
and the Combined
Wastestream Formula
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
WATER
MEMORANDUM
SUBJECTi Pretreatment Program Guidance
FROM: Rebecca W. Hanmer, Director
Office 'of Water Enforcement and Permits (EN-335)
Jalhes M. Conlon, Acting Director
Office of Water Regulations and Standards (WH-551)
TO: Users of the Guidance Manual for the Use of Production-
Based Categorical Pretreatment Standards and the
Combined Wastestream Formula
This guidance manual has been developed by EPA to explain
how to implement two important elements of the national
pretreatment program: categorical standards and the combined
wastestream formula. The manual is divided into two sections.
The first section explains how to apply production-based
categorical standards in a permit, contract, or similar
mechanism. The second part explains how to use the combined
wastestream formula, providing definitions and examples.
The manual is one of a series of guidance documents intended
to simplify and improve understanding of various aspects of the
pretreatment program. Other documents in this series which have
either been recently issued or will be issued in the near future
will provide guidance on:
1) Removal Credits
2) Total Toxic Organics (TTO) Monitoring
3) RCRA Notification Requirements
4) Local Limits
5) POTW Interference
The need for guidance on the use of categorical standards
and the combined wastestream formula was recognized by the
Pretreatment Implementation Review Task Force (PIRT). PIRT was
set up by the EPA Administrator to make recommendations concerning
the problems faced by POTWs, states, and industry in implementing
the national pretreatment program. This guidance manual is part
of the Agency's response to the PIRT recommendations. It encourages
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active involvement of both the Control Authority and the industrial
user in developing appropriate limits using categorical standards
and the combined wastestream formula. Because the industrial
users are generally the ones most familiar with their processes
and production and flow rates, their participation is needed for
proper development of limits.
There are a few items covered in this document which deserve
special comment because they are related to Agency policy or
anticipated changes in the federal regulations. These are
discussed below.
Production-Based Standards
PIRT asked for guidance on, "the ways in which permits,
contracts, or other enforceable mechanisms may be used legally
to convert production-based standards to equivalent mass or
concentration limits." PIRT asked whether the procedures that
have been developed for direct dischargers under the NPDES*
permit program also apply to indirect dischargers which are not
required to be permitted under the federal regulations. The
approach taken in this guidance manual is to provide a high
degree of consistency between the NPDES program and the pretreat-
ment program regarding application of production-based standards.
The manual emphasizes the usefulness of converting a production-
based standard to an equivalent mass per day limit, as is normally
done when developing NPDES permits. The option of using equivalent
concentration limits is also discussed. The discussion of how
to determine an appropriate production rate is based on section
40 CFR 122.45(b) of the NPDES regulations.
The manual stresses the importance of applying the equivalent
limits using a permit, contract, order, or other official document
that is transmitted to the industrial user. As with NPDES permits,
this document should clearly spell out 1) the equivalent limit,
2) the production and flow rates upon which the limit is based,
and 3) the requirement to notify the Control Authority of changes
in flow and/or production rates which would require the limit to
be revised. Unless there is such a document, it may be difficult
to determine compliance with production-based limits.
Equivalent limits provide a useful tool for determining
compliance with applicable categorical standards. Under the
current provisions of the Clean Water Act and the General
Pretreatment Regulations, however, an industrial user's
compliance with an equivalent limit does not relieve the legal
requirement to be in compliance with the production-based stan-
dard itself. Equivalent limits are enforceable as local limits,
but they do not take the place of the categorical standard.
National Pollutant Discharge Elimination System
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A permit containing an equivalent limit does not shield the
industry from direct enforcement of the production-based standard.
However, EPA will support the proper use of equivalent mass or
concentration limits and will generally defer to the Control
Authority's interpretation of how to apply them provided:
(1) the equivalent limits are correctly calculated using the
guidance provided in this manual and the calculations
are documented;
(2) each individual industrial user's limit is specified in
a permit, contract, order or other official document that
is issued by the Control Authority to the user; and
(3) the permit-type mechanism specifies the production and
flow rates on which the equivalent limits were based and
requires that the user notify the Control Authority if
there is a change in the rates which would require the
limit to be revised.
If EPA finds through its oversight activities that the
three criteria listed above have not been met, we will generally
inform the Control Authority and allow time to correct the problem
before taking an enforcement action. However, the Agency may
choose to take direct enforcement action in any given situation.
The Agency is planning to propose changes to the General
Pretreatment Regulations to provide that equivalent mass per day
or concentration limits contained in a permit, contract, order,
or other official document shall be deemed Pretreatment Standards
for purposes of section 307(d) of the Clean Water Act and shall
be enforceable as such. If this regulation is promulgated,
compliance with the equivalent limits would be deemed compliance
with the production-based standard.
Combined Wastestream Formula
PIRT asked for clarification of the terms "regulated,"
"unregulated," and "dilution" used in the combined wastestream
formula and recommended publication of corrections to Appendix D
of the 1981 General Pretreatment Regulations. At present,
Appendix D incorrectly labels certain wastestreams as dilution
streams. Proposed revisions to Appendix D were published in the
Federal Register on May 9, 1985. The reader should refer to
this revised version of Appendix D instead of the 1981 list
which has significant errors.
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This guidance manual also clarifies how the combined
wastestream formula should be applied when unregulated and
dilution streams are combined with regulated wastestreams after
treatment. The combined wastestream formula was developed to be
used when wastestreams are combined before treatment. Control
Authorities may also use the combined wastestream formula when
these streams are combined after treatment but they are not
required to do so. The manual provides guidance on how to proceed
when Control Authorities do not use the combined wastestream
formula when regulated and unregulated wastestreams are combined
after treatment. It includes examples showing how a formula
should be used to account for the streams added after treatment.
If the streams added after treatment are all acting as dilution
(as shown by actual analysis), the results may be the same as if
the CWF were used. However, if unregulated streams are added
after treatment, the results will depend on the mass of pollutants
actually present in those streams and will probably differ from
a combined wastestream formula calculation.
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GUIDANCE MANUAL FOR THE USE OF
PRODUCTION-BASED PRETREATMENT STANDARDS
AND THE COMBINED WASTESTREAM FORMULA
Prepared by
Industrial Technology Division
Office of Water Regulations and Standards
and
Permits Division
Office of Water Enforcement and Permits
September 1985
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
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TABLE OF CONTENTS
Page
1. INTRODUCTION 1-1
1.1 PURPOSE OF GUIDANCE MANUAL 1-1
1.2 BACKGROUND 1-1
1.2.1 Purpose of Categorical Pretreatment Standards 1-2
1.2.2 Development of Categorical Pretreatment
Standards 1-2
2. USE OF PRODUCTION-BASED CATEGORICAL PRETREATMENT STANDARDS 2-1
2.1 INTRODUCTION 2-1
2.2 USE OF EQUIVALENT MASS LIMITS 2-1
2.3 USE OF EQUIVALENT CONCENTRATION LIMITS 2-3
2.4 OBTAINING AND VERIFYING PRODUCTION AND FLOW INFORMATION... 2-5
2.5 PROHIBITION AGAINST DILUTION TO ACHIEVE COMPLIANCE 2-6
2.6 USE OF PRODUCTION-BASED STANDARDS WITH A PERMIT SYSTEM 2-7
2.7 DETERMINING AN APPROPRIATE PRODUCTION RATE FOR USE IN
DEVELOPING EQUIVALENT LIMITS 2-8
2.7.1 Background 2-8
2.7.2 Use of Historical Data 2-10
2.7.3 Determining a Production Basis Without Historical
Data 2-13
2.8 DETERMINING AN APPROPRIATE FLOW RATE FOR USE IN
DEVELOPING EQUIVALENT LIMITS 2-14
2.8.1 Flow Measurement and Flow Estimation 2-15
2.9 CHANGES IN PRODUCTION AND FLOW RATES 2-17
2.9.1 Changes in Production Rate 2-18
2.9.2 Changes in Flow Rate 2-19
2.9.3 Tiered Permits 2-19
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J. USE OF THE COMBINED WASTESTREAM FORMULA 3-1
3.1 PURPOSE OF THE COMBINED WASTESTREAM FORMULA 3-1
3.2 DEFINITION OF CWF TERMS 3-2
3.3 APPLICABILITY OF THE CWF 3-4
3.4 IMPLEMENTATION OF THE CWF 3-6
3.4.1 Combined Wastestream Formulas 3-6
3.4.1.1 Alternative Concentration Limit
Formula 3-6
3.4.1.2 Alternative Mass Limit Formula 3-7
3.4.1.3 Consistency When Combining Categorical
Standards ,.. 3-8
3.4.2 Conditions for Using the CWF 3-9
3.4.3 Implementation of the CWF 3-11
3.4.3.1 IU Responsibilities 3-13
3.4.4 Example Use of the CWF 3-14
3.4.4.1 Example 1 - Simple Example of Combined
Wastestream Formula Calculations With
Concentration Limits 3-14
3.4.4.2 Example 2 - More Complex Combined
Wastestream Formula Example Calculations
with Concentration and Mass Limits 3-15
3.4.4.3 Example 3 - Above Combined Wastestream
Formula Calculations with Concentration
Limits for Cyanide 3-16
3.4.4.4 Example 4 - Combined Wastestream Formula
Example Calculations Using Concentration
and Mass Limits 3-17
3.4.4.5 Example 5 - Combined Wastestream Formula
for an Integrated Facility 3-20
3.4.5 Comparison of Local Limits and Categorical
Standards 3-28
3.4.5.1 Example - Integrated Facility Calculations
Comparing Categorical Standards and Local
Limits 3-29
4. REFERENCES 4-1
APPENDIX A PUBLICATIONS AVAILABLE FROM THE GOVERNMENT PRINTING OFFICE
(GPO) AND/OR THE NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
APPENDIX B STATUS OF CATEGORICAL PRETREATMENT STANDARDS
APPENDIX C FLOW MEASUREMENT REFERENCES
APPENDIX D COPPER FORMING CATEGORICAL PRETREATMENT STANDARDS - SUBPARTS
UTILIZED IN EXAMPLES
APPENDIX E PORTION OF NPDES PERMIT APPLICATION REQUESTING PRODUCTION AND
FLOW INFORMATION
ii
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LIST OF TABLES
Table
1-1 EPA ESTIMATES OF POLLUTANT DISCHARGE RATES ACHIEVABLE
WITH AND WITHOUT FLOW REDUCTION AS PART OF TREATMENT
TECHNOLOGY 1-4
2-1 COMPARISON OF TYPES OF PRETREATMENT STANDARDS FOR
CATEGORICAL INDUSTRIES 2-2
2-2 APPLICATION OF PRODUCTION-BASED STANDARDS 2-4
2-3 COMPARISON OF PRODUCTION QUANTITIES SPECIFIED IN PRODUCTION-
BASED CATEGORICAL PRETREATMENT STANDARDS 2-9
LIST OF FIGURES
Figure Page
2.1 TIERED APPROACH TO USING EQUIVALENT MASS LIMITS 2-22
3.1 APPLICABILITY OF THE COMBINED WASTESTREAM FORMULA 3-5
3.2 TYPICAL PORCELAIN ENAMELING ON STEEL OPERATION 3-12
3.3 PROCESS FLOW SCHEMATIC FOR EXAMPLE IU 3-21
3.4 EXAMPLE IU WASTEWATER FLOW DIAGRAM 3-22
3.5 EXAMPLE FLOW SCHEMATIC OF EXAMPLE INTEGRATED
FACILITY CATEGORICAL IU 3-30
ill
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1. INTRODUCTION
1.1 PURPOSE OF GUIDANCE MANUAL
The Environmental Protection Agency (EPA), given the responsibility of
ensuring proper pretreatment program oversight and implementation, has begun
developing a series of guidance manuals designed to assist Control Authorities
in implementing and enforcing local, State, and Federal pretreatment requirements
and standards. Industrial users will also find this guidance useful in meeting
their compliance responsiblities with applicable pretreatment standards and
requirements.
One of EPA's major areas of concern involves the proper application and
enforcement of Federal categorical pretreatment standards by Control Authorities.
The purpose of this manual will be to provide guidance on 1) the proper implemen-
tation of production-based categorical pretreatment standards, specifically on
development and use of equivalent mass and concentration limits and interpretation
of industrial user (IU) production and wastestream flow data; and 2) the applica-
tion of the combined wastestream formula (CWF) including clarification of the
definitions of terms used in the formula and clarification of methods for combining
production- and concentration-based standards for regulated wastestreams.
Other manuals being developed by EPA will provide guidance on implementation
of local limits, total toxic organics standards, and removal credits.
This chapter will provide a summary of background information regarding
categorical standards. Other chapters contained in this guidance are
organized as follows:
o Chapter 2 - USE OF PRODUCTION-BASED CATEGORICAL PRETREATMENT STANDARDS
provides guidance on the proper implementation of production-based
standards, including the use of equivalent concentration or mass limits
and determination of production and flow rates. Examples demonstrating
the use of equivalent limits are also provided.
o Chapter 3 - USE OF THE COMBINED WASTESTREAM FORMULA provides guidance on
the purpose of the CWF, definitions of terms utilized, and proper
application and implementation of the formula. Examples demonstrating
the use of the CWF are also provided.
1.2 BACKGROUND
The purpose of this section is to provide a brief overview of the process
by which categorical pretreatment standards are developed. This general overview
provides an understanding of the basic process of categorical standards develop-
ment and the role of categorical standards in the overall National Pretreatment
Program. Categorical standards for specific industries are discussed in more
1-1
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detail in other sources, such as the technical development documents supporting
each standard, and in the preambles to each standard which are published in
the Federal Register.1
1.2.1 Purpose of Categorical Pretreatment Standards
Section 307(b) of the Clean Water Act of 1977 (the Act) requires EPA to
establish:
"pretreatment standards for introduction of pollutants into treatment
works...which are publicly owned for those pollutants which are determined
not to be susceptible to treatment by such treatment works or which would
interfere with the operation of such treatment works."
EPA is implementing this mandate through two major regulatory components.
One component is encompassed in the General Pretreatment Regulations (40 CFR
Part 403), which contain general and specific discharge prohibitions and require
that many of the nation's publicly owned treatment works (POTWs) develop local
limits to protect their individual treatment systems and the local environment
from pass through and interference. These prohibitions and local limits provide
a mechanism for controlling conventional, nonconventional, and toxic pollutants.
The second major regulatory component of the pretreatment program is EPA's
development of categorical pretreatment standards. Categorical pretreatment
standards limit the pollutant discharges of all facilities within an industrial
category which discharge into a POTW. (Appendix B of this guidance provides a
list of the major industries subject to categorical pretreatment standards along
with the effective and compliance dates for existing sources.) The primary focus
of categorical standards is the control of toxic pollutants. Because categorical
standards may differ from locally-developed limits, a categorical facility must
comply with whichever limits are more stringent. Pursuant to 40 CFR Section
403.5(d), it is unlawful to violate either local or categorical standards.
1.2.2 Development of Categorical Pretreatment Standards
Categorical pretreatment standards for a given industry are based on the
capability of a specific wastewater treatment technology or series of technologies
to reduce pollutant discharges to the POTW collection system. Categorical
pretreatment standards are therefore referred to as technology-based. There are
two types of categorical pretreatment standards, Pretreatment Standards for
Existing Sources (PSES) and Pretreatment Standards for New Sources (PSNS).
Each type is based on a specific technology level identified for the industry
category for the control of pollutants. The levels of technology correspond to
similar technology levels applied to industry direct dischargers known as Best
Available Technology Economically Achievable (BAT) for existing facilities and
Best Available Demonstrated Technology (BADT) for new sources. In most cases,
pretreatment standards for industries which discharge to POTWs (indirect
^Copies of development documents can be obtained from the National Technical
Information Services (NTIS), Springfield, VA 22161 (703) 487-4650. A listing
of the development document reference numbers for the industrial categories
discussed in this document is contained in Appendix A.
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dischargers) are based on the regulations for direct dischargers. However, if
POTW treatment plant processes can remove any specific industrial pollutant(s)
as efficiently as the technology applied to direct dischargers, then pretreatment
standards for those pollutants are generally not promulgated for that category.
Categorical standards do not necessarily require that industrial facilities
install the specific treatment technology upon which they were based; however,
the standards do require that industrial facilities achieve discharge limits
that EPA determines are achievable using the model technology.
In sane industries, particularly those with product rinse operations, the
reduction of wastewater flow is one of the major technology options available to
reduce pollutant discharge quantities. For these industries, EPA has identified
process equipment or changes in operating practices that will reduce the wastewater
flow and the mass of pollutants discharged. In those industries where flow
reduction is a major part of the treatment technology defined as the basis for
pretreatment standards, EPA issued production-based pretreatment standards
since concentration-based limitations would not ensure an equal reduction in
the mass of pollutants discharged. Table 1-1 provides the estimates EPA has
made of the pollutant discharge rates achievable in ten industries that have
production-based standards when flow reduction is included as part of the PSES
treatment definition. This table also shows estimates of the expected pollutant
discharge rates if flow reduction is not included in the technology basis.
For some categories, flow reduction may provide a certain amount of pollutant
removal benefit but the difference is not significant. EPA issues both concen-
tration-based and production-based pretreatment standards for these categories.
Control Authorities can require industries in these categories to achieve either
the concentration-based or the production-based standard. The choice may depend
on whether dilution (as a substitute for treatment) is an expected problem.
Dilution is an unacceptable way of achieving compliance with a standard and is
prohibited by the General Pretreatment Regulations, 40 CFR Section 403.6(d).
Application of a production-based standard makes the practice of diluting to
achieve compliance more difficult because pollutant mass is limited.
Finally, for a third group of categorical industries, EPA established only
concentration-based standards. This was done when it was not possible to establish
a correlation between production and achievable pollutant discharge in order to
develop a production-based standard.
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TABIE 1-1
EPA ESTIMATES OF POLLUTANT DISCHARGE RATES ACHIEVABLE
WITH AND WITHOUT FLOW REDUCTION AS PART OF TREATMENT TECHNOLOGY
POLLUTANT DISCHARGE RATES (kg/yr)
CATEGORY
Aliminun Forming
Battery Mfg.
Coil Coating
Ca making
Copper Forming
Metal Molding
& Casting
Nonferrous Metals
Forming
Nonferrous Metals
Mfg. I
Nonferrous Metals
Mfg. II
Subtotal
Iron 6 Steel
Total
D* I**
59 72
17 129
29 39
3 80
37 45
300 508
37 121
79 85
34 39
595 1118
733 162
1328 1280
TOXIC METALS
PSES PSES
W/O FR WITH FR DIFF. %
14,542 3,201 11,341 78
7,168 908 6,260 87
2,821 1,001 1,820 65
9,241 5,366 3,875 42
39,464 3,277 36,187 92
50,909 7,273 43,636 86
6,112 490 5,622 92
16,702 1,635 15,067 90
228 124 104 46
147,187 22,295 123,912 84
192,272 33,691 158,581 82
339,459 55,986 282,493 83
TOXIC ORGANICS
PSES PSES
W/O FR WITH FR DIFF. %
710 208 502 71
14 3 11 79
307 100 207 67
3,506 382 3,124 89
2,804 133 2,671 72
29,273 3,727 25,546 87
19 5 14 74
NA NA NA
NA NA NA
36,633 4,558 32,075 88
1,401,909 532,454 869,455 62
1,438,542 537,012 901,530 63
NONCONVENTIONAUS
PSES PSES
W/O Fl< WITH FR DIFF. %
21,659 8,885 12,774 S9
5,422 864 4,558 84
20,007 6,525 12,482 62
299,942 99,729 200,213 67
13,950 1,705 12,245 88
NA NA NA
75,465 13,188 62,277 83
33,845 8,219 25,626 76
1,464 479 985 67
471,754 139,594 332,160 70
NA NA NA
471,754 139,594 332,160 70
Notes: * Direct Dischargers
** Indirect Dischargers
PSES w/o FR estimated using raw waste flows
NA - Not Applicable
1-4
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2. USE OF PRODUCTION-BASED CATEGORICAL PRETREATMENT STANDARDS
2.1 INTRODUCTION
EPA has issued categorical pretreatment standards that are: (1) concentration-
based, (2) production-based, and (3) both. Table 2-1 shows which type of standards
have been issued for each of the major industrial pretreatment categories. Eight
categories have only production-based standards; seven have only concentration-based
standards, and seven have both.
EPA has been asked to provide guidance for Control Authorities on how to use
production-based pretreatment standards. Production-based standards are expressed
in terms of allowable pollutant mass discharge rate per unit of production (e.g.,
mgAi2 or lb/1000 Ib). Production-based standards are administratively more
difficult for the Control Authority to implement than concentration-based
standards. To test for compliance with a concentration standard, the Control
Authority need only take a wastewater sample, measure the concentration(s) of
the regulated pollutant(s), and compare this result to the standard. For a
production-based standard, however, the Control Authority must also measure the
flow of the regulated wastestream and determine the corresponding production
rate. The most difficult step in determining whether an industrial user is in
compliance with a production-based standard is sometimes confirming this production
rate.
Rather than measure the production rate each time that compliance monitoring
is performed, Control Authorities may use eguivalent mass or concentration limits
as a tool for routine monitoring and enforcement purposes. Equivalent mass or
concentration limits use an industrial facility's average production and flow
rates to derive a limit that is essentially eguivalent to the production-based
standard but is expressed as mass per day or concentration (e.g., Ib/day or
mg/1). This approach is useful because, by using average production and flow
rates, the Control Authority does not have to rely on day-to-day variations in
the rates. This is the approach which has normally been used in the National
Pollutant Discharge Elimination System (NPDES) program for direct dischargers
for many years.
Equivalent mass or concentration limits are similar to limits derived
using the combined wastestream formula (CWF) since they are usually based on
average production and/or flow rates and are intended to remain constant over a
reasonably long period of time. Sections 2.7 through 2.9 of this chapter provide
guidance and examples which show how to determine appropriate production and
flow rates for use in developing equivalent mass or concentration limits. The
recommendations presented in those sections are applicable to limits developed
using the CWF as well as to equivalent limits developed for a single was test re-jm.
Examples involving the use of the CWF are presented in Chapter 3.
2.2 USE OF EQUIVALENT MASS LIMITS
A production-based standard is applied directly to an industrial user's
manufacturing process unless an equivalent limit is established. Direct applica-
tion would require the Control Authority or the IU to make direct measurements
of the current production and flow rates each time that monitoring was performed.
There are many instances in which this approach is impractical from the stand-
points of cost and technical feasibility. As an alternative, the Control
Authority is encouraged to use an average daily production value based on a
reasonable measure of the actual production rate.
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TABLE 2-1: COMPARISON OF TYPES OF PRETREATMENT
STANDARDS FOR MAJOR CATEGORICAL INDUSTRIES
I. Production-based standards only:
o Aluminum Forming
o Battery Manufacturing
o Coil Coating
o Copper Forming
o Iron and Steel Manufacturing
o Metal Molding and Casting (Foundries)*
o Nonferrous Metals Forming
o Nonferrous Metals Manufacturing
II. Concentration-based standards only:
o Electrical & Electronic Components
o Leather Tanning & Finishing
o Metal Finishing
o Organic Chemicals, Plastics, & Synthetic Fibers*
o Pharmaceuticals
o Steam Electric
o Pesticides
III. Both production-based and concentration-based standards:
o Electroplating
o Inorganic Chemicals
o Petroleum Refining
o Porcelain Enameling
o Pulp, Paper, and Paperboard
o Builders Paper and Board Mills
o Timber Products
Standards are not yet final.
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The averaqe daily production rate is used to develop an equivalent mass
limit according to the relationship:
standard x ave. production rate = equivalent mass limit.
conversion factor
The same average daily production rate is multiplied by both the daily maximum
and maximum monthly average standards. The resulting limits are a daily maximum
mass per day and a maximum monthly average mass per day. (See Table 2-2.) A
long-term average production value should be used — usually a 12-month average.
It is important to select a production level that will be representative during
the life of the permit or other control mechanism. For example, for a five-year
permit the Control Authority should evaluate enough production data to determine
if it is possible to select an average production level that will be representative
for the next five years. Section 2.8 discusses methods for establishing an
appropriate production rate in more detail, including techniques to use when
production is highly variable or historical data is unavailable.
The advantage of using equivalent mass limits, instead of applying the standards
directly, is that it eliminates the need to routinely conduct exhaustive studies
of plant production rates and wastewater detention times. For routine monitoring
purposes, it is necessary for the Control Authority to measure only flow and
concentrations of pollutants.
2.3 USE OF EQUIVALENT CONCENTRATION LIMITS
Direct measurement of flow on a routine basis by either the industrial user
or the Control Authority is often more feasible from a cost and technical standpoint
than is direct measurement of production. However, the Control Authority may decide,
on the basis of cost, technical, or managerial considerations, to develop an equivalent
concentration limit using an average daily flow rate based on a reasonable measure
of the actual flow rate. Equivalent concentration limits eliminate the need to
directly measure flow and production each time that monitoring is performed and
pemit the Control Authority to routinely measure only pollutant concentrations
to assess compliance with production-based standards.
An eguivalent concentration limit is developed using both an average production
rate and an average flow rate. The averaqe daily production rate is multiplied by
the standard and this product is divided by the average daily flow rate, according
to the relationship:
standard x ave. production rate = equivalent concentration
ave. flow rate x conversion factor limit.
It is proper to use the same production and flow values to derive both daily maximum
and monthly average limits. (See Table 2-2.) Long-term average flow and production
rates should be used and they should be based on the same time period. Section 2.8
discusses methods for establishing an appropriate flow rate in more detail. It is
important to select average production and flow rates that will be representative
during the life of the permit.
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TABLE 2-2: APPLICATION OF PRODUCTION-BASED STANDARDS
Equivalent Mass Limits
Standards:
Daily Maximum 004 kg Cu/ton of product
Maximum Monthly
Average 002 kg Cu/ton of product
Conditions;
Production 500 ton of product/day, 12-month average
Flow Not Applicable
Calculations; .004 kg Cu/ton x 500 ton/day = 2 kg Cu/day
.002 kg Cu/ton x 500 ton/day = 1 kg Cu/day
Equivalent Limits;
Daily maximum 2 kg Cu/day
Maximum Monthly
Average 1 kg Cu/day
Equivalent Concentration Limits
Standards;
Daily Maximum 004 kg Cu/ton of product
Maximum Monthly
Average 002 kg Cu/ton of product
Conditions;
Production 500 ton of product/day, 12-month average
Flow 2 million gal/day, 12-month average
Calculations; .004 kg Cu/ton x 500 ton/day
.2 mil gal/day x 3.78* =2.6 mg/1
.002 kg Cu/ton x 500 ton/day
.2 mil gal/day x 3.78* =1.3 mg/1
Eguivalent Limits;
Daily Maximum 2.6 mg/1 Cu
Maximum Monthly
Average 1.3 mg/1 Cu
* This factor converts kg/mil gal to mg/1.
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When using equivalent concentration limits, it is important to ensure that
dilution will not be used to achieve the limits. For example, mixing the regulated
wastewater with additional flow that has not been reported to the Control Authority
would be a form of deliberate dilution. If dilution is an expected problem, it
may be better to use mass per day limits and routinely measure the actual flow
rate.
2.4 OBTAINING AND VERIFYING PRODUCTION AND FLOW INFORMATION
The Control Authority must maintain records on each industrial user to which
equivalent mass or concentration limits have been issued that reveal how the
production and flow levels were established and how the calculations were performed
to derive the limits. These records will be reviewed by EPA or delegated State
officials during their visits to the POTW for pretreatment program inspections
and audits.
The General Pretreatment Regulations, in 40 CFR 403.12, describe the reporting
requirements applicable to categorical lUs. Under the current regulations the IU
must provide production and flow information to the Control Authority when it is
necessary to determine compliance with a standard or if it is necessary to develop
permit limits for the user. The information can be requested under Section 308 of
the Clean Water Act or similar authority in a local program and as a requirement
of the General Pretreatment Regulations. The information must be obtained in the
form of a signed document such as a letter, report, or permit application.
Section 403.14 of the General Pretreatment Regulations discusses the confiden-
tiality of industrial information submitted to the Control Authority. Information
which is considered effluent data cannot be confidential under the Clean Water
Act. In 40 CFR 2.302(a), effluent data is defined to include information on the
manner or rate of operation of a regulated process, to the extent necessary to
determine compliance with a standard. Therefore, industrial users must submit
necessary production and flow rate data to the Control Authority or be liable
for an enforcement action. Information which is determined to be effluent data
is to be made available to the public in accordance with the procedures in 40 CFR
Part 2.
lUs subject to production-based standards are required to submit production
and flow rate information in the baseline monitoring report (BMR) which is to be
submitted within 180 days after the effective date of a categorical pretreatment
standard or 180 days after the final administrative decision on a category deter-
mination request under 40 CFR 403.6(a)(4), whichever is later. This information
should be verified by the Control Authority soon after receipt of the BMR to
determine whether it meets the criteria discussed in sections 2.7 and 2.8 of this
manual for choosing appropriate production and flow rates. The participation
of the IU is important at this stage in setting appropriate levels for use in
developing equivalent limits. lUs will benefit from involvement because they will
become cognizant of any mistakes in data or calculations prior to compliance dead-
lines. The Control Authority will also benefit from the active participation of
the IU because the lUs are generally the ones most familiar with their processes
and production and flow rates.
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SimilarlYr discharge permit applications should ask for production and flow
rate information from lUs subject to production-based standards. When the draft
permit is developed, the IU should be given an opportunity to comment and to detect
any mistakes in the data or calculations before the permit is issued.
After the compliance deadline, the IU is reguired, at a minimum, to continue
to submit production and flow rate information in the 90-day compliance report
which is submitted 90 days after the compliance date and in the periodic reports
on continued compliance which are generally due in June and December each year,
starting after the compliance date for the categorical standards.
When an IU permit or contract is issued with eguivalent limits, the Control Authority
should include a clause reguiring the user to provide the current average production
and flow rates in self-monitoring reports. There should also be a reguirement
that the IU notify the Control Authority immediately of a significant change in
any of the values used in calculating the eguivalent limit. The permit should
advise the permittee that failure to provide the reguired information may subject
the permittee to an enforcement action. The Control Authority should use this
information to reevaluate eguivalent mass or concentration limits and modify them,
if necessary. Examples shown in sections 2.7 through 2.9 give the reader an idea
of what significant changes could warrant modification of the permit limits. As a
general rule, a change in the long-term average production or flow rate of greater
than 20 percent is considered significant.
The Control Authority can and should inspect the facility's production and
flow records and measuring technigues to confirm the accuracy of the reported
values. If the Control Authority desires to verify the production rate first-hand
or to determine the production rate on a particular monitoring day, then the
industrial user may be reguired to perform actual measurements while a Control
Authority representative is present. The proper installation, calibration, and
maintenance of flow monitoring eguipment should also be carefully checked.
2.5 PROHIBITION AGAINST DILUTION TO ACHIEVE COMPLIANCE
Categorical standards apply to the wastewater from the regulated process.
For some categories, the regulated wastestream may include flows from process
rinses, showers, handwashes, laboratories, wet air scrubbers, on-site laundries,
respirator washes, truck washes, etc. To determine what flows are regulated, it
is important to read the published standards, especially the Applicability
section of each standard and the following sections of the preamble to the
standard: Control Treatment Options and Technology Basis for Final Regulation and
Public Participation and Response to Major Comments. It may also be necessary to
read the Technical Development Document to determine which flows are regulated.
Each categorical regulation published in the Federal Register includes an EPA
contact and phone number for further information.
The above-mentioned sources may also provide information on normal flow
rates for the regulated wastestreams. Some industrial users may attempt to
increase water usage beyond normal, necessary levels in order to avoid use of
treatment and control technologies. Such dilution is expressly prohibited by
the General Pretreatment Regulations, Section 403.6(d). Control Authorities
must implement this provision. If an IU is meeting applicable standards without
having installed treatment or instituted other appropriate in-process controls,
the Control Authority should investigate and ensure that unnecessary dilution is
not being practiced.
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When production-based standards are developed, a model flow rate per unit
of production is assumed based on appropriate water consumption levels and flow
reduction methods. If an IU's actual regulated process flow rate is significantly
higher than the model rate, the effluent from the facility could contain concen-
trations of regulated pollutants below the analytical detection levels. An IU
should not be considered to be in compliance with a production-based standard
simply because of below detectable effluent concentrations. The Control Authority
should ensure that compliance is achieved through appropriate treatment and in-
process controls rather than through high water usage. Control Authorities
should not normally develop equivalent mass per day or concentration limits
which would require achieving below detectable effluent concentrations.
2.6 USE OF PRODUCTION-BASED STANDARDS WITH A PERMIT SYSTEM
It is strongly recommended that equivalent limits be applied using a permit,
contract, order, or other official document that is transmitted to the industrial
user. This document should clearly spell out 1) the equivalent limit, 2) the
flow and/or production rates upon which the limit is based, and 3) the requirement
to notify the Control Authority of changes in flow and/or production rates which
would require the limit to be revised. Unless there is such a document, it may
be difficult to determine compliance with production-based standards.
As an example of the type of production- and flow-related data that should
be provided in a permit application, Appendix E contains a portion of the
application form for an NPDES permit. It requests the following information:
I. Outfall Location (For an IU permit, this should be changed to "Sampling
Point Location")
II. Flows, Sources of Pollution, and Treatment Technologies
A. A flow diagram and a water balance for the entire facility.
B. A description of the processes that generate wastewater and the
average flow rates contributing to each sampling point.
C. A description of treatment provided.
D. Flow and frequency data for intermittent discharges.
III. Production Data
A. Determine whether a categorical standard applies to the facility.
B. Determine whether the applicable standard is production-based.
C. If a production-based standard applies, give average daily production.
The permit itself should contain:
(1) Both the daily maximum and monthly average (or 4- or 30-day average)
equivalent limits;
(2) Monitoring frequency;
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(3) Type of monitoring or sampling;
(4) The flow and/or production values used as the basis for the equivalent
limits;
(5) A "reopener clause" stating that the permit may be modified, revoked
and reissued, or terminated if there is a material or significant
change in any of the values used in the calculation to fix the eguivalent
limits.
(6) A requirement that the IU immediately report any material or significant
change in any of the values used in the calculation to fix the equivalent
limits.
(7) A requirement that periodic continued compliance reports which must be
submitted at least semi-annually include the average production and
flow rates that prevailed during the reporting period.
2.7 DETERMINING AN APPROPRIATE PRODUCTION RATE FOR USE IN DEVELOPING EQUIVALENT
LIMITS
When a Control Authority chooses to use an equivalent mass or concentration
limit to implement a production-based categorical standard, it is necessary to
determine an appropriate production rate upon which to base the equivalent limit.
Since the typical IU permit, contract, or other control mechanism is issued for
a period of one to five years, Control Authorities will need to establish a
limitation which will be applicable for that period. A potential problem,
however, is that a plant production rate applicable to a multi-year period can
be calculated in a number of ways, each resulting in a different limitation.
This section provides guidance regarding reasonable and recommended procedures
for determining a production rate upon which to base eguivalent limits.
Production-based categorical standards are expressed in terms of various
units of production depending on the nature of the regulated process. Table 2-3
gives a general comparison of the types of production quantities specified in the
various standards. This table is greatly simplified; it is intended only to give
an idea of the variety in the production bases for different standards.
The material presented in this section on determining an appropriate production
rate is applicable to using the combined wastestream formula (CWF) to develop
alternative mass limits. The CWF is used when one or more regulated wastestreams
are combined with other process or non-process streams.
2.7.1 Background
The proper application of production-based categorical standards is related
to the methodology that EPA uses to develop the standards. Categorical standards
are developed in such a way that they are expected to be achievable in spite of
normal variation in day-to-day production rates and the effect that routine
variation has on effluent quality. When most standards are developed, a long-term
average production value and its relationship to flow are determined for each
industrial facility selected for in-depth study. Variability factors are developed
using effluent concentration or mass data obtained by a field sampling program.
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TABLE 2-3
COMPARISON OF PRODUCTION QUANTITIES SPECIFIED
IN PRODUCTION-BASED CATEGORICAL PRETREATMENT STANDARDS
CATEGORY
Aluminum Forming
Battery Manufacturing
Coil Coating
Copper Forming
Electroplating*
Inorganic Chemicals Man. I*
Inorganic Chemicals Man. II*
Iron and Steel
Metal Molding & Casting
Nonferrous Metals Forming
Nonferrous Metals Man. I
Nonferrous Metals Man. II
Petroleum Refining*
Porcelain Enameling*
Pulp, Paper, & Paperboard*
Timber Products*
PRODUCTION QUANTITY
mg/off-kg (Al or Al alloy removed from
a forming or ancillary process)
mg/kg (processed material or product,
varies w/subcat.)
(area processed), g/10^ cans manfctd,
mg/off-kg (Cu or Cu alloy removed frcm a
forming or ancillary process)
(material plated)
kg/Kkg (product)
kg/Kkg (product)
kg/Kkg (product)
kg/Kkg (metal poured, sand reclaimed, or
air flow in scfm)
mg/kg (product)
(product)
mg/kg (product or raw material, varies
w/subcat . )
kg/Mm3 (feedstock)
mg/nti^ (basis material coated or processed)
kg/Kkg (product)
gr/m3 (production)
* Has both production-based and concentration-based standards
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The variability analysis yields a determination of the achievable maximum daily,
or maximum monthly average, concentration or mass per day. This is then combined
with the long-term average production and flow rates to yield a production-based
standard.
When using eguivalent limits to implement production-based standards, the
objective is to determine a production rate that approximates the long-term
average rate that can reasonably be expected to occur during the term of the
permit, contract, or other control mechanism. By long-term average, we mean an
average based on the production over an extended period of time that captures a
normal range of variation in production. Because of the way the standards are
developed, using just the data for a short period of high production is likely to
result in equivalent limits that are unnecessarily high, resulting in more pounds
of pollutant being discharged than is allowed by the standards. Therefore,
basing an egivalent limit on the production rate for a high day, week, or month
should be avoided.
2.7.2 Use of Historical Data
Equivalent limits should be based on an industrial user's actual production
rate, not on designed production capacity. Historical information, if available,
generally provides the best basis and should be given more weight than projections
of future production, which are often unreliable. To determine a long-term average
production rate, several years of production data should be examined, if possible.
It is important to ask the industrial user to explain any trends or outstanding
features of the historical data, especially what the causes were and if they are
likely to be repeated in the future. If some of the data are not representative of
normal operation and are due to specific events which are not expected to recur,
the data should be disregarded.
The following example illustrates how a production level could be determined
for use in conjunction with a five-year permit. In brief, the industrial user
has five years of historical production data. After discarding the data for one
of the years which was determined to be nonrepresehtative, the daily average
production rate for the highest of the other four years was selected as the basis
for the alternative limit. Using the data for the highest year is meant to
provide an allowance for large-scale variations affecting production, such as
economic cycles, which may be repeated during the term of the permit. Such
large-scale variations are not likely to have been taken into account when the
standards were developed.
EXAMPLE 2.1
Industrial user A has recorded the following annual production figures for
each of the past five years:
Year Total Production
(Tons/Yr)
1980 375,000
1981 284,000
1982 304,000
1983 292,000
1984 301,500
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The Control Authority wishes to develop equivalent mass limits for the
industrial user which will be applied in a five-year permit. Therefore, a
reasonable measure of the expected production level for the next five years is
needed. A reasonable measure might be based on the production for the highest of
the five years, provided it was not an atypical year. In this example, the 1980
figure (375,000 tons/year) would be used, except that it appears to be substan-
tially out of line with the other years, as shown by the calculation below.
Average Annual Production = 1,556,500 tons = 311,300 tons/yr
5 years
Year Percent Difference
from the Average
1980 + 20.4 %
1981 - 8.8 %
1982 - 2.3 %
1983 - 6.2 %
1984 - 3.1 %
By checking with the industrial user it is found that between 1980 and 1981, the
facility moved part of its manufacturing process to a new plant. Thus the 1980
data should be excluded from further consideration. Looking at the other four
years, the production level for 1982, the highest year, would provide a reasonable
basis for the equivalent limit.
The average daily production rate is computed using the 1982 production
figure (304,000 tons/yr) and the number of production days per year. Since the
industrial user has 255 production days per year, the average daily production
rate is 1,192 tons per day. If pollutant X has a categorical standard of
.001 lb/1000 Ib for the monthly average and .0015 lb/1000 Ib for the maximum
daily average, the equivalent mass limits would be calculated as follows:
Monthly Average Limit (Pollutant X):
1,192 ton x 2000 Ib x .001 Ib = 2.38 Ib/day
day ton 1000 Ib
Daily Maximum Limit (Pollutant X):
1,192 ton 2000 Ib x .0015 Ib = 3.58 Ib/day
day x ton 1000 Ib
In this example, the average production rate was calculated using the number
of production days per year. If the number of wastewater discharge days is
different from the number of production days, then the average rate should be
calculated using the number of discharge days, instead (See Example 2.4).
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In sane cases, historical data are available but the measured quantity
differs from that specified in the standard. (See Table 2-3.) For example, the
standards for sane of the metal forming categories are expressed as milligrams
per off-kilogram (mg/off-kg), where an off-kilogram is the mass of metal removed
from one processing operation for transfer to another. Most facilities have not
measured off-kilograms in the past. It may be possible, however, to relate the
amount of final product, which is likely to have been measured in the past, to
off-kg by developing a conversion factor. This will not always be possible,
particularly at facilities where a number of alternate processing schemes are
used depending on individual customer specifications and daily variations in
product mix. Example 2.2 illustrates how the conversion could be made in a
relatively simple situation. First, it is necessary for several corresponding
measurements to be made of both the specified quantity (off-kg, in this case) and
the quantity which was historically measured (amount of final product). After a
few weeks of data have been collected and analyzed, a relationship between the
two quantities may be found. It may be a simple multiplication factor that
relates the two quantities. This factor is then applied to the historical data
so that a reasonable long-term average production rate can be determined fron the
historical data.
Once a reasonable production basis has been selected and an equivalent limit
has been established, the industry must continue to measure the production rate
for the quantity specified in the standard. The equivalent limit should be
reevaluated using the additional data. This should be done within six months.
EXAMPLE 2.2
A nonferrous metal forming facility produces precious metal wire for several
end uses. Wire is drawn and annealed, then cleaned. All wire products are
produced in a similar manner, but wire destined for the jewelry industry may go
through additional cleaning. Each batch of wire is inspected to determine whether
or not it requires additional cleaning. The process diagram looks like this:
[Drawn and| (Alkaline | |
(annealed | >|cleaning j >j Inspection
wire and rinse
The facility must comply with production-based categorical pretreatment
standards for the alkaline cleaning and rinse processes in mg/off-kg of metal
cleaned. In the past, the facility has kept track only of the amount of finished
wire. They have not measured off-kilograms from intermediate steps such as
alkaline cleaning and rinse and do not know how much wire is normally returned
for additional cleaning. They estimate that the amount returned is between 10
and 40 percent of the amount of finished wire.
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The facility therefore assigns an individual to monitor the alkaline cleaning
and rinse process and record the production rate in off-kilograms each day for a
two-week period. This data is compared to the amount of final product below.
Day Kg of Finished Off-kg of Metal Ratio of Metal Cleaned
Wire Cleaned to Finished Wire
1 36,000 43,000 1.19
2 37,600 47,000 1.25
3 38,000 52,000 1.37
4 39,500 55,000 1.39
5 38,900 53,000 1.36
Week 1 190,000 250,000 1.32
6 43,500 56,100 1.29
7 39,500 52,500 1.33
8 38,000 54,000 1.42
9 36,000 43,200 1.20
10 40,000 49,600 1.24
Week 2 197,000 255,400 1.30
The data show that, on the average, the ratio of the mass of metal cleaned
to the mass of finished wire is 1.31. Based on this, the Control Authority
develops a relationship that converts kg of final product to off-kg of metal
cleaned:
off-kg of metal cleaned = 1.31 x kg of finished wire.
The Control Authority then applies the conversion factor to the past several
years of historical data to develop an appropriate average production rate
expressed in off-kg of metal cleaned. The production rate is used in developing
equivalent limits.
Once the equivalent limits are established, the industrial user should
continue to monitor the production rate for the cleaning process, at least once
every 6 months, by recording actual production for several days. This information
should be included in the semi-annual continued compliance reports submitted to
the Control Authority. The Control Authority should use the additional data to
reevaluate the equivalent limits.
2.7.3 Determining a Production Basis without Historical Data
New industrial facilities or existing facilities that have changed to new
processes will not have historical production information that can be used to
develop equivalent limits. Furthermore, sane facilities have historical data,
but the quantity that was measured is not the same as the one specified in the
standards and the two cannot be related by deriving a correlation. Without
useable historical data, the Control Authority will have to rely on the industrial
user's projections of what the actual production rate is expected to be in the
future.
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Projections are often unreliable indicators of actual future production
recjardless of the method used in making them and the earnestness of the effort
to make reasonable assumptions. Therefore, although the Control Authority may
issue an interim equivalent limit based on the estimated future production, the
industrial user should be required to begin to measure the production rate of
the quantity specified in the standards and supply the data to the Control
Authority. The Authority will then be able to reevaluate the original production
rate estimate and, if necessary, revise the equivalent limit. This should be
done within six months.
2.8 DETERMINING AN APPROPRIATE FLOW RATE FOR USE IN DEVELOPING EQUIVALENT LIMITS
When a Control Authority chooses to use equivalent concentration limits to
implement a production-based standard, it is necessary to determine an appropriate
average flow rate on which to base the equivalent limits. The considerations
for determining an appropriate flow rate are very similar to those described
in Section 2.7 for determining a production rate. For instance, in both cases
it is important to:
o Determine a reasonable estimate of the actual long-term average rate; for
example, the normal daily average during a representative year.
o Use the actual rate rather than the design rate; emphasize historical data
rather than future projections.
o Use the same average rate to calculate both daily maximum and maximum monthly
average alternative limits.
o Establish a rate that is expected to be representative during the entire
term of the permit or other control mechanism.
o Avoid the use of data for too short a time period. In particular, estimating
the average rate based on data for a few high days, weeks, or months is not
appropriate.
o Reevaluate equivalent limits every six months using additional monitoring
data. If the actual average rate changes by more than 20 percent from the
estimated rate used as the basis of the equivalent limits, then the limits
should be revised.
o If an average flow rate is determined based on historical data, it should
be based on the same time period as the production rate. In Example 2.1,
for instance, the average flow rate would have been based on 1982 data.
As discussed previously in Section 1.2.2, production-based standards are
developed using a model treatment technology that includes wastewater flow reduc-
tion as a major component. Control Authorities and industrial users should be
aware of these model technologies. One source of information concerning model
flow rates and process equipment to reduce water discharge rates is the technical
development document for each of the industry categories (See Appendix A). Some
specific problems and examples pertaining to determining an appropriate flow
rate are discussed in the remainder of this section.
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2.8.1 Flow Measurement and Flow Estimation
Because of the importance of accurate flow measurements to determining
compliance with categorical standards and equivalent limits, the Control Authority
should usually require categorical industrial users to install flow measurement
equipment. Monitoring equipment can be permanently installed that will both
(1) continuously record the instantaneous rate of flow of a fluid passing by a
primary measuring device and (2) calculate and record the cumulative volume that
passes during a 24-hour or longer period. If the equipment is properly installed,
operated, and maintained, it is possible to obtain complete and accurate information
on instantaneous flows, cumulative 24-hour flows, and cumulative or average flows
for a longer period.
If such flow measuring data are available, the Control Authority should
assess compliance using either the cumulative 24-hour flow for a particular
monitoring day or the daily average flow based on the data for a longer period.
The cumulative 24-hour flow corresponding to the day on which sampling is
performed, when combined with concentration data from 24-hour flow-proportional
composite sampling, often gives the best indication of the actual mass of
pollutants discharged on a given day.
Thus, a permanent device that continuously records the flow rate is recommended.
A device that allows only visual observation of instantaneous flows is usually
inadequate for at least three reasons:
1) Production-based standards limit the amount of pollutants that can be discharged
for any one day (daily maximum) or for the average of several days (maximum
monthly average). Compliance with such standards should be determined
based on the total flow during a sampling day, not on the flow at a single
instant.
2) Flow records are needed to determine average flows for developing alternative
concentration limits.
3) A complete flow record enables the Control Authority to determine if wastewater
is discharged on weekends, evenings, or other unexpected times.
There may be cases where an IU can justify other methods of flow determination.
Sections 403.12(b)(4) and (e) of the General Pretreatment Regulations state
that, where justified by cost or feasibility considerations, the Control Authority
may allow verifiable estimates of flow as opposed to actual measurements. Guidance
on methods for accurately measuring and estimating flow rates can be found in
the references listed in Appendix C.
At a minimum, it is always necessary to determine the average daily flow for
the regulated process wastestreams. In addition, when the combined wastestream
formula is used, not only are the flow rates for the regulated waste streams
required, but the flow rates of unregulated and/or dilution streams are sometimes
required as well. It is often necessary to conduct a water balance of the entire
plant which accounts for all water entering and leaving. For example, incoming
water may be determined from meter readings or water bills; measuring equipment
may be installed at accessible points; flow volumes for batch processes may be
estimated from a knowledge of tank sizes and number of batches; and so on. A
water balance is useful to verify that flow rates have been accurately determined
for using the CWF or to enable estimation of certain flows which are difficult
to measure.
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EXAMPLE 2.3
The Copper Forming categorical standards regulate the discharges from specific
copper forming processes. The pretreatment standard for a given facility is
determined by adding the allowable discharges for each copper forming process
conducted at the facility using the CWF. For the purpose of this example, "drawing
spent lubricant" is the only copper forming wastewater generated at the facility.
Drawing is defined as:
"a process in which wire or tubing is pulled through a die to reduce the
cross-sectional area. Wire is drawn (pulled) cold through a series of
tungsten carbide dies, decreasing the diameter in each draw. Diamond dies
are used for fine wire. Temperature rise is important because of its
relation to die life and lubrication. Water-based lubricants or neat oils
are used to control and to lubricate the copper as it is drawn through
the die. The lubricant solution eventually becomes degraded and must be
discharged and replaced."
The categorical pretreatment standards are:
Daily Maximum
Pollutant Maximum Monthly Average
(mg/off-kg of copper or copper alloy drawn)
Chromium 0.037 0.015
Copper 0.161 0.085
Lead 0.012 0.011
Nickel 0.163 0.107
Zinc 0.124 0.051
TTO 0.055 0.028
Oil and Grease* 1.700 1.020
*Alternative "indicator pollutant" in lieu of TTO monitoring and compliance.
Compliance with the copper forming categorical standards is required by
August 15, 1986.
Historical data for a copper forming facility shows that its production
averages 25,000 off-kg/day and its wastewater discharges from the drawing spent
lubricant process average 2,000 gallons per day. The facility does not meter
wastewater flow from the drawing process. It meters the total wastewater
discharge from the plant to the POTW collection system and the municipal water
authority meters flow entering the plant. The estimated wastewater flow for the
drawing process of 2,000 gallons per day was derived by balancing known water
consumption and discharge and known or reliably estimated water requirements
elsewhere in the plant. The estimated flow is considered relatively accurate.
The Control Authority is considering equivalent concentration limits. Although
compliance is not required until August 1986, the industrial user seeks establish-
ment of equivalent concentration limits as soon as possible to determine the
course of its compliance plan.
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The daily maximum alternative concentration limit (C) for copper for this
facility may be calculated as follows:
_ (0.161 mg/off-kilogram) (25,000 off-kilogram/day)
(2,000 gpd) (3.78 1/gal)
C = 0.53 mg/1
Similarly, the other equivalent concentration limits applicable to this
copper forming facility are:
Daily Maximum
Pollutant Maximum Monthly Average
mg/1 mg/1
Chromium 0.12 0.05
Copper 0.53 0.28
Lead 0.04 0.04
Nickel 0.54 0.35
Zinc 0.41 0.17
TTO 0.18 0.09
Oil and Grease* 5.63 3.38
*Alternative "indicator pollutant" in lieu of TTO monitoring and compliance.
These equivalent concentration limits are based on the estimated wastewater
flow of 2,000 gallons per day. Although the estimate is considered a good estimate,
it should be verified, both to determine the accuracy of the equivalent concentra-
tion limits and to ensure future compliance with the production-based requirements.
Therefore, as a condition of establishing equivalent concentration standards, the
Control Authority should require that flow monitoring equipment be installed and
maintained to measure wastewater flow from the drawing spent lubricant discharge.
As a part of the final compliance report from the IU, the Control Authority should
require that a historical data base of actual flow measurements be submitted to
permit verification that the established equivalent concentrations are accurate.
If the actual flows differ significantly from the estimated value of 2,000 gallons
per day, revised equivalent concentration limits should be calculated. The
production basis should also be periodically reevaluted, based on more recent
production data.
2.9 CHANGES IN PRODUCTION AND FLOW RATES
The use of long-term average flow and production rates eliminates the need
for the Control Authority to rely on day-to-day variations in these rates.
However, it is possible that the long-term average rate may change over time in
response to large-scale factors. At a minimum, Control Authorities will have an
opportunity to detect changes in the long-term average rate by reviewing the
semi-annual compliance reports that must be submitted by categorical IDs every 6
months.
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These reports should contain average production and flow rate data applicable to
the 6 month reporting period. IDs are also required to notify the Control Authority
immediately of significant changes in these rates. As a general rule, the
average rate is considered to have changed significantly if the change is
greater than 20 percent. EPA expects that significant changes will be rare
unless due to a deliberate change in the normal method of operations on the part
of the IU or to a substantial change in demand. When a significant change in
the long-term average production rate has taken place or is expected, then the
equivalent limits should be reevaluated. For purposes of determining compliance,
until new limits are finalized, the old limits remain in force.
2.9.1 Changes in Production Rate
In rare cases, daily variations in production may be high enough to warrant
consideration of direct implementation of the production-based standard. However,
even if the day-to-day variability is large (exceeding 50 to 100 percent), in
most cases it will still be appropriate to use an average production rate. The
following example illustrates this point.
Example 2.4
A battery reclaimer, covered by the secondary lead smelting subcategory of
the nonferrous metals manufacturing category, must comply with production-based
pretreatment standards which are expressed as milligrams per kilogram of lead
scrap produced. The number of batteries cracked and the amount of lead scrap
produced vary widely from day to day. One day 50 batteries may be cracked; 150
the next. The amount of lead scrap produced varies accordingly. The Control
Authority would like to issue an equivalent mass or concentration limit to
simplify implementation of the productionbased standard. At first glance,
because of the large daily variation, it appears that an average production
rate (based on more than a single day of production) might be inappropriate for
establishing an alternative limit. But, after looking at the wastewater flow
characteristics, the picture is altered.
Even though the production rate varies greatly from day to day, the wastewater
discharge flow rate, as measured at the sampling point after pretreatment, is
essentially constant. There is approximately a 16-hour wastewater detention
time in the system, which exceeds the 8 to 10 hours per day that the facility
produces lead. Furthermore, the wastewater is discharged seven days per week,
although the number of production days per week is only five. Seme of the treated
wastewater is recycled back to the process or is used elsewhere in the plant.
Occasionally, when the treated wastewater pollutant concentrations exceed the
local concentration limits, the wastewater is pumped back through the treatment
system.
The long detention time and the recycling practices have the effect of
"averaging out" the wastewater pollutant concentrations and the flow rate over
time. The sampling method used by the Control Authority, composite sampling,
increases this effect. The result is that the measured pollutant concentrations
and the flow rate on a particular monitoring day are not directly related to the
production for that day. In this case, the Control Authority could elect to use
the average production rate to develop an equivalent limit. If an equivalent
concentration limit were desired, then the average flow rate for the same period
would be used in the calculation.
2-18
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When determining the averaqe production rate in this example, the question
arises whether to divide the total production rate by the number of production
days or the number of flow days, since these two numbers differ. If an equivalent
concentration limit is sought, then it does not matter which number is used, as
long as both the average flow rate and average production rate are computed
using the same divisor. Care should be taken to avoid mixing discharge days and
production days in the calculations. If a mass limit is preferred, then the
number of flow days should be the divisor. Because the number of production
days is less than the number of flow days, dividing by the number of production
days would overestimate the daily allowable mass discharge. For example, let us
assume the battery reclaimer produced 50,000 Kkg of lead scrap during a 255-day
production year. There are 5 production days per week but 7 discharge days.
The following calculation would be performed:
50,000 Kkg lead scrap x 5 production days/wk
255 production days 7 discharge days/wk
= 196.1 Kkg lead scrap x .714 production days
production day discharge day
= 140 Kkg lead scrap = average production rate for use in
discharge day developing equivalent mass limit.
2.9.2 Changes in Flow Rate
In most cases, the use of equivalent concentration limits based on a long-term
average flow rate is still appropriate even though day-to-day flow is highly
variable. The flow from an individual regulated process may vary substantially
from one day to the next, but the flow rate at the sampling point may be equalized
because of the retention time in the system and mixing with other wastestreams.
At facilities where the combined wastestream formula is used, flow variability
seldom becomes an issue for this reason. In fact, the General Pretreatment
Regulations specify that at least a 30-day average flow rate is to be used in
the formula.
There are also many cases where both the flow rate and the production rate
are highly variable, but the ratio of the two is relatively constant. An alter-
native concentration limit can then be calculated using the average value of the
flow-to-production ratio using the relation:
production-based _._ average wastewater conversion equivalent
standard • volume per unit x factor = concentration
of production limit.
2.9.3 Tiered Permits
In most cases, equivalent mass or concentration limits should be developed
using a historical measure of the actual long-term average production rate.
However, in some cases, the Control Authority may determine that historical
production levels are not indicative of expected future production. When a
significant change in average production is expected during the term of an IU's
permit, the Control Authority may choose to issue a tiered permit.
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A tiered permit is structured so that the IU is given one set of equivalent
limits for the current average production rate and another set of equivalent
limits is specified to take effect when there is a significant change in the
average production rate. The alternate limits* would either became effective at
a specific time or they would be triggered whenever production exceeded a threshold
value. Definitive guidance is not available with regard to the threshold value
which should trigger alternate limits. However, it is generally agreed that a
10 to 20 percent fluctuation is within the range of normal variability while
changes higher than this could warrant consideration of alternate limits.
Tiered permits should be used only after careful consideration and only
when a substantial change in the average rate of production is likely to occur.
The IU should first be required to demonstrate that its actual average production
rate is currently substantially below maximum production capability and that
there is a reasonable potential for an increase above the actual rate during the
term of the permit. A tiered permit may also be appropriate where a significant
decrease in the average production rate is expected during the term of the permit.
Since tiered permits generally require increased technical and administrative
efforts on the part of the Control Authority to ensure that permit conditions
are not violated, the number of tiers in the permit should not exceed the number
necessary to address the reliably anticipated range of production.
A relatively simple type of tiered permit that has been used frequently in
the NPDES program applies to cases where an IU is expanding its production facility
to a significantly higher capacity. The permit might contain two alternate sets
of limits labelled, for instance:
First Tier: From 9/01/85 until Expansion
Second Tier: Fran Expansion until 8/31/90.
Seasonal effluent limits have also been used successfully in
NPDES permits. In most cases they are for fixed periods of time
such as:
First Tier: November 1 to April 30
Second Tier: May 1 to October 31.
Another type of tiered permit contains alternate limits which become effective
when actual average production exceeds a threshold value. This type is useful
for industries, such as the automotive industry, in which demand is extremely
volatile and the permit modification process might not be fast enough to respond
to the need for higher or lower equivalent limits. A permit might be written
with, for example, two or three tiers which apply to ranges of production. For
example, a hypothetical automotive plant with a historical production rate of
50% of capacity might have a total capacity = 2000 ton/day and a production-based
standard for pollutant X = 1 Ib/million Ib (daily maximum). If average production
is expected to vary between 40 and 100% of capacity, alternate permit limits
might be set as follows:
* This usage of the term "alternate limits" should not be confused with the
usage referring to limits derived using the combined wastestream formula
(See Section 3).
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First Tier: Basis of calculation = 50% of capacity, or 1000 ton/day
Limit for pollutant X = 2.0 Ib/day
Applicable production range = 40% to 60% of capacity, or 800 to
1200 ton/day
Second Tier: Basis of calculation = 70% of capacity, or 1400 ton/day
Limit for pollutant X = 2.8 Ib/day (daily maximum)
Applicable production range = 61% to 80% of capacity,
or 1200+ to 1600 ton/day
Third Tier: Basis of calculation = 90% of capacity, or 1800 ton/day
Limit for pollutant X = 3.6 Ib/day (daily maximum)
Applicable production range = 81% to 100% of capacity,
or 1600+ to 2000 ton/day.
A graphical illustration of this approach is presented in Figure 2.1. The
first tier has an applicable production range that covers plus or minus 20 percent
of the basis of the calculation for that tier. This can be seen by noting that
the basis of calculation for the first tier is 1000 ton/day and the threshold
level that would trigger the next tier is set at 1200 ton/day, or 20 percent
higher. Similarly, the second and third tiers have applicable production ranges
of +_ 14 percent and +_ 11 percent, respectively. This is consistent with the
general rule that a 10 to 20 percent change in average production rate is within
the range of normal variability while a greater change could warrant alternate
limits.
Tiered permits generally require increased technical and administrative
supervision on the part of the Control Authority to verify compliance with permit
limits. Special IU reporting requirements are usually necessary and should be
detailed in the IU permit. The permit should specify one set of alternate limits
as the primary limits. The primary limits would be based on the actual or recent
historical level of production. For Control Authority monitoring, the Control
Authority should evaluate compliance based on the primary limits unless notifi-
cation was received in advance that the production rate had changed. IU continued
compliance reports, which must be submitted every six months unless requested
more often by the Control Authority, should contain measurements or estimates of
the actual production rate which prevailed during the reporting period and the
anticipated production rate for the next reporting period.
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Daily Maximum
Effluent Limit
for Pollutant X
(Ib/day)
3.6
2.8
2.0
i i
il
i I
l'
' I
/ i
\ ! I ' '
.'lift
/ / /
L * / ' /
/ / / /
i i i i
* i i i i
' > , *
, / i , '
i ' i
' i ' i
/ i / i
f ' I •
,' I I/ ' \
20
400
40
800
I
60
1,200
80
1,600
100
2,000
% of Capacity
Average
Production
(ton/day)
Figure 2.1
Tiered Approach to Using Equivalent Mass Limits
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3. USE OF THE COMBINED WASTESTREAM FORMULA
3.1 PURPOSE OF THE COMBINED WASTESTREAM FORMULA
The purpose of this chapter will be to provide guidance to Control
Authorities and industrial users (lUs) on proper application and utilization
of the Combined Wastestream Formula (CWF).
Federal categorical pretreatment standards regulate the indirect dis-
charge of certain pollutants from a particular industry or industrial process.
An important consideration for Control Authorities as well as industrial users
when applying or complying with categorical standards, is that the pollutant
limitations specified in the standards apply to the discharge of wastewater
from the regulated process only, prior to mixing with any other wastestreams.
The CWF (40 CFR 403.6 (e)) is a method for calculating alternative
pollutant limits at industrial facilities where regulated process effluent is
mixed with other wastewaters (either regulated or non-regulated) prior to
treatment. As stated in the preamble to the 1981 amendments to the general
pretreatment regulations (46 FR 9419), the formula is of primary importance
to large, diversified industrial users with multiple processes.
These industrial users of POTWs frequently have a number of individual
processes producing different wastestreams that are not regulated by the same
categorical Pretreatment Standard or are not regulated by any categorical
standard. Many of these integrated facilities have combined process sewers
and a number have already constructed combined waste treatment plants. In
these situations, the industrial user often prefers to install a pretreatment
system on the combined stream rather than installing separate parallel systems
on each individual stream. The CWF permits a facility to mix wastestreams
prior to treatment by providing it with an alternative effluent limit for
this combined discharge.
EPA wishes to minimize the need for separation of wastestreams and for
treatment by parallel systems when comparable levels of treatment can be
attained in combined treatment plants. Separate treatment of wastes at an
integrated plant can be costly, wasteful of energy, inefficient and
environmentally counterproductive. In addition, such an approach reduces the
environmental gains resulting frcm the voluntary treatment of unregulated
streams prior to the imposition of regulatory reguirements. However, the
Agency also recognizes that the countervailing concerns of avoiding the
attainment of limits through dilution and ensuring that adeguate treatment is
provided may sometimes lead to the conclusion that segregation of streams is
the only appropriate way to meet applicable pretreatment limits. The CWF
attempts to strike a proper balance between these considerations. It is the
industrial user's choice whether to combine or segregate its wastestreams.
However, if the user decides to combine wastestreams prior to treatment, and
at least one of these wastestreams is covered by a categorical pretreatment
standard, then alternative limits for all regulated pollutants in the combined
wastestream must be calculated using the CWF. If the calculated CWF limit is
below the detectable level, then the alternative limit cannot be applied
because it would not be possible to demonstrate compliance with such a limit.
The Control Authority must reguire the regulated stream to be segregated
from the other relatively dilute streams or appropriate flow reductions must
be implemented to allow detection.
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3.2 DEFINITION OF CWF TERMS
Prior to a discussion on the use of the CWF, it is important that Control
Authority and industry personnel fully understand the terms for the three
types of wastestreams that can exist at an industrial facility: regulated,
unregulated and dilute. The terms are best understood by considering a
particular pollutant, such as "pollutant X." A regulated wastestream is a
wastestream from an industrial process that is regulated by a categorical
standard for pollutant X. An unregulated wastestream is a wastestream that
is not regulated by a categorical standard for pollutant X and not considered
a dilute wastestream as defined below. A dilute wastestream is defined in
40 CFR Part 403 (as amended on May 17, 1984) to include:
o Sanitary wastewater (considered dilute for all pollutants unless stated
otherwise in the published categorical pretreatment standard)
o Noncontact cooling water and boiler blowdown (considered
dilute for all pollutants except in certain cases as described below)
o Wastestreams listed in Appendix D to 40 CFR Part 403 (considered
dilute for all pollutants).
In addition, a non-regulated wastestream is a general term which will
be used in this guidance manual for any wastestream which is not regulated
(it could be either unregulated or dilute).
A wastestream is considered regulated for purposes of calculating a CWF
limit for pollutant X only if (1) the wastestream is produced by a categorical
industrial process that has a standard for pollutant X, and (2) the compliance
date for that standard has been reached. For example, since the aluminum
forming industry has a categorical standard for zinc but not for copper,
wastewater from aluminum forming would be considered regulated for zinc but
unregulated for copper. Before October 24, 1986, the compliance date for
the standards, the wastewater would be considered unregulated for all pollu-
tants including both zinc and copper.
Unregulated wastestreams are those wastestreams that are not covered by
categorical pretreatment standards and not classified as dilute wastestreams.
An unregulated wastestream could be one for which a categorical standard has
been promulgated but for which the compliance deadline has not been reached,
one that currently is not subject to a categorical pretreatment standard
(whether or not it will be in the future), or one that is not regulated for
the pollutant in question although it is regulated for others.
Unregulated streams are presumed, for purposes of using the CWF, to
contain pollutants of concern at a significant level. In effect, the CWF
"gives credit" for pollutants which might be present in the unregulated
wastestream. Rather than treating the unregulated flow as dilution,
which would result in lowering the allowable concentration of a pollutant,
the CWF allows the pollutant to be discharged in the unregulated wastestream
at the same concentration as the standard for the regulated wastestream that
is being discharged. This is based on the assumption that if pollutants are
present in the unregulated wastestream, they will be treated to the same
3-2
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level as in the regulated wastestream. In sane cases, unregulated wastestreams
may not actually contain pollutants of concern at a significant level. Even
if this is the case, they are still considered unregulated when applying the
formula. However, if the Control Authority is concerned that an unregulated
stream is actually acting as dilution, a local or state Control Authority can
use its own legal authority to establish a limit more stringent than would be
derived using the formula in the manner prescribed by the Federal Regulations.
The definition of a dilute wastestream was revised in the May 17, 1984,
Federal Register. The current definition defines dilution flow (Fp) as:
"FD = the average daily flow (at least a 30-day average) from (a)
boiler blowdown streams and noncontact cooling streams; provided,
however, that where such streams contain a significant amount of a
pollutant, and the combination of such streams, prior to treatment,
with an Industrial Users regulated process wastestream(s) will
result in a substantial reduction of that pollutant, the Control
Authority, upon application of the Industrial User, may exercise
its discretion to determine whether such stream(s) should be classi-
fied as diluted or unregulated. In its application to the Control
Authority, the Industrial User must provide engineering, production,
sampling and analysis and such other information so that the Control
Authority can make its determination, or (b) sanitary wastestreams
where such streams are not regulated by a categorical Pretreatment
Standard, or (c) from any process wastestreams which were or could
have been entirely exempted from categorical Pretreatment Standards
pursuant to paragraph 8 of the NRDC v. Costle Consent Decree (12
ERC 1833) for one or more of the following reasons (see Appendix
D):
(1) the pollutants of concern are not detectable in the
effluent from the Industrial User (paragraph (8)(a)(iii);
(2) the pollutants of concern are present only in trace
amounts and are neither causing nor likely to cause toxic
effects (paragraph (8)(a)(iii);
(3) the pollutants of concern are present in amounts too small
to be effectively reduced by technologies known to the Administrator
(paragraph (8)(a)(iii); or
(4) the wastestream contains only pollutants which are
compatible with the PCTW (paragraph (8)(b)(i))."
The industry subcategories listed in Appendix D of 40 CFR Part 403
include several subcategories that fall under: Auto and Other Laundries,
Electrical and Electronic Components, Foundries, Gum and Wood Chemicals,
Inorganic Chemicals, Leather, Pulp and Paper, Rubber Manufacturing, Soap and
Detergent, Textiles, and Timber Products. These subcategories are those
which either EPA exempted from national categorical standards based upon a
3-3
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finding that they do not generally contain significant levels of pollutants
of concern across the industry or EPA exempted them for another reason but
could have exempted them for this reason.
Wastestreams from the processes listed in Appendix D are always considered
dilution for all pollutant parameters. Sanitary wastewater is almost always
considered dilute, except in a very few categories for which the regulations
state otherwise. Boiler blowdown and noncontact cooling water are also most
always classified as dilute. However, if requested by the industrial user, the
Control Authority may determine (supported by required analytical, engineering,
and other data) that they should be considered unregulated process streams.
The Control Authority should ensure that characterizing such wastestreams as
unregulated and combining them with regulated wastestreams prior to treatment
is not used by the industrial user as a partial or complete substitute for
adequate treatment to achieve compliance with a categorical Pretreatment
Standard. Dilution is prohibited in 403.6(d) as a substitute for treatment.
3.3 APPLICABILITY OF THE CWF
A categorical standard applies to the wastestream from a regulated
process (See Figure 3.1(a)). The standard applies to the entire regulated
flow, including the contributions from all operations defined as part of the
regulated process. As indicated by the dashed line in Figures 3.1(a) and
(b), an IU may choose not to treat the entire regulated flow, but the standard
applies to the total flow.
When a regulated wastestream is combined prior to treatment with other
wastestreams-either regulated or non-regulated — the CWF must be used to
calculate an alternate discharge limit that applies to the combined stream
(see Figure 3.1(b)). When non-regulated streams are added after treatment,
however, the Control Authority may apply the CWF but it is not a requirement
that it must be applied (See Figure 3.1(c).
In the situation illustrated in Figure 3.1(c), the CWF must apply when
monitoring occurs at Point A, which is located before the treated flow is
mixed with other non-regulated streams. The Control Authority may apply the
CWF at Point B but the Control Authority is not required to do so. Rather,
the Control Authority may require analytical, engineering and other data to
determine the adjusted standard(s) to reflect the actual amount of a particular
regulated pollutant in the non-regulated wastestream. The Control Authority
should ensure that combining wastestreams after treatment is not used by the
industrial user as a partial or complete substitute for adequate treatment
to achieve compliance with a categorical pretreatment standard. The General
Pretreatment Regulations, Section 403.6(d) prohibits dilution as a substi-
tute for treatment. Therefore, if monitoring occurs at Point B and the
Control Authority does not apply the CWF, then the non-regulated wastewaters
added after treatment must be accounted for in determining compliance with
the applicable categorical standard(s) by adjustment to reflect the actual
amount of a particular regulated pollutant in the non-regulated wastestream.
If the standard is expressed in terms of mass per day, the levels of the
regulated pollutant in the individual wastestreams are simply added together
to determine the applicability limit on that pollutant in the combined waste-
stream. For concentration-based standards, a flow-proportioning calculation
must be performed in order to properly account for the level of the regulated
pollutant in the non-regulated wastestream(s).
3-4
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Figure
3.1 (a)
Regulated
Wastestream
I
Categorical
Standard Applies
Here
Figure
3.1
(b)
Regulated Unregulated Dilute
Wastestream(s) Wastestream(s) Wastestream(s)
I
1
1
1 ^
*
[
r
Combined Wastestream Formula Alternative
Limit Applies Here
Figure
3.1 (c)
Regulated Unregulated Dilute
Wastestream(s) Wastestream(s) Wastestream(s)
+ ! +
TI
i \
\ 1
t A
c
r
r
r
!A Other
Wastestream(s)
J D
Point A: Combined Wastestream Formula Alternative
Limit Applies
Point B: Control Authority May Apply the CWF, But
If It Is Not Applied...Calculate Adjusted
Limit as Follows:
1} Adjusted Mass Limit
(CWF Mass Limit
for Point A)
(CWF Concentration
Limit for Point A)
2) Adjusted Concentration Limit =
(Flow at
x Point A) +
(Actual Mass of Pollutant
in Nonregulated Wastestreams
Added After Treatment)
(Actual Mass of Pollutant
in Nonregulated
Wastestreams Added After
Treatment)
[(Flow at Point B)]
Note: T = Treatment Facility
Figure 3.1
Applicability of the Combined Wastestream Formula
3-5
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The formulas that are used to calculate the adjusted mass or concentration
limits in the example at Point B are given in Figure 3.1(c). These are simple
mass summation and flow proportioning formulas. If the resulting adjusted
standard is below the detectable limit, then a monitoring point must be located
at Point A and limitations applied at that point
Whenever feasible, it is recommended that monitoring be performed at
Point A. This will eliminate the possibility of errors which could occur in
adjusting the limit to be applicable at Point B. Control Authorities may
prefer to monitor at Point B, however, if that is where local limits apply.
Section 3.4.5 of this Chapter presents an example of how to adjust categorical
standards to compare them with local limits in a situation where non-regulated
wastestreams are added after treatment. In this example, it is assumed the
Control Authority is not applying the CWF but rather adjusting the standard(s)
to reflect the actual amount of a particular regulated pollutant in the non-
regulated wastestream.
3.4 IMPLEMENTATION OF THE CWF
This section will provide Control Authority and IU personnel with
information that will be necessary to ensure the proper application and
implementation of the CWF.
3.4.1 Combined Wastestream Formulas
Section 403.6(e) of the General Pretreatment Regulations provides two
formulas to develop alternative categorical limits. One formula is used to
develop an alternative concentration limit for standards that are concentration
based. The other formula is used to develop an alternative mass limit for
those categorical standards that are production based. Both alternative
concentration and alternative mass limits will be developed in examples
contained in this Chapter.
3.4.1.1 Alternative Concentration Limit Formula
N
Fr - Fo
N F. V FT
I
Op = Alternative concentration limit for the pollutant in the combined
wastestream
Ci = Concentration-based categorical pretreatment standard for the pollutant
in regulated stream i
Fi = Average daily flow (at least 30 day average) of regulated stream i
FD = Average daily flow (at least 30 day average) of dilute wastestream(s)
(see previous complete definition, page 3-2)
FT = Average daily flow (at least 30 day average) through the combined
treatment facility (including regulated, unregulated and dilute
wastestreams)
N = Total number of regulated streams
3-6
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The CWF develops an alternative concentration limit for each pollutant by
multiplying the categorical standard for each regulated pollutant of each
regulated stream (Ci) by the flow of that regulated stream (F^) and then
adding the resultant product for all the regulated wastestreams that are
combined. This amount is then divided by the sum of the flows (FjJ of all
the wastestreams in which that pollutant is regulated. If no dilution waste-
streams are being combined, only the first part of the formula would be
needed to compute an alternative concentration limit. If dilute wastestreams
are combined with the regulated wastestreams, the number resulting fron the
first part of the formula is multiplied by a fraction. This fraction is
derived by taking the total flow through the wastewater treatment system
(FT) minus the total flow from all dilute wastestreams (F^) and dividing by
the total flow (FT).
It should be noted that when the formula is applied properly, it has
the effect of allowing any unregulated streams combined with the regulated
streams to be discharged at the same pollutant concentrations as allowed by
the standards for the regulated streams.
3.4.1.2 Alternative Mass Limit Formula
N
MT -
Mp = Alternative mass limit for the pollutant in the combined wastestream
(mass per day)
MI = Production-based categorical pretreatment standard for the pollutant in
regulated stream i (or the standard multiplied by the appropriate measure
of production if the standards being combined contain different units of
measurement)
FJ[ = Average daily flow (at least 30 day average) of regulated stream i
FD = Average daily flow (at least 30 day average) of dilute wastestream(s)
FT = Average daily flow (at least 30 day average) through the combined
treatment facility (including regulated, unregulated and dilute
wastestreams)
N = Total number of regulated streams
Alternative mass limits are developed by adding together the calculated
mass values from a production-based categorical standard for a pollutant (Mi)
in each regulated process wastestream that is combined. If the production bases
for the production-based standards being combined were different (see Table 2-3),
then each of the production-based standards would have to be multiplied by
the appropriate daily production basis for each regulated process, before
the standards were added together. If only regulated wastestreams were
3-7
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combined, only this sun of the production-based categorical standards
is needed to establish an alternative mass limit (Wp)- In the case of the
addition of dilute or unregulated wastewaters, the sum of production-based
categorical standards mass values would need to be multiplied by a fraction.
This fraction is calculated by taking the total flow through the wastewater
treatment system (F-j-) minus the total of dilute wastestreams (Fp) combined
with the regulated process wastestreams and dividing by the total flow of
regulated process wastestreams (F^). (Note: This is eguivalent to the
regulated flow plus the unregulated flow divided by the regulated flow.)
As with the concentration limit formula, when applied properly the mass
limit formula has the effect of allowing any unregulated streams combined
with the regulated streams to be discharged at the same pollutant concentra-
tions as allowed by the standards for the regulated streams.
3.4.1.3 Consistency When Combining Categorical Standards
When a Control Authority or IU utilizes the CWF to develop alternative
limits for two different process wastestreams which are both regulated by a
concentration-based categorical standard or a production-based standard,
the CWF is simply applied as described in the previous sections. However,
Control Authorities and TUs may be faced with the task of establishing an
alternative limit when one process wastestream, regulated by concentration-
based categorical standards, is combined with another process wastestream,
regulated by production-based categorical standards. They also may face the
situation where two different process wastestreams are combined but each is
regulated by a production-based categorical standard based on different
production units. (See Table 2.3 for a list of the type of standard by
industry category.)
When a situation arises where -a process wastestream, regulated by
concentration-based standards (e.g., electronic components, metal finishing)
is combined with another process wastestream regulated by production-based
standards (e.g., copper forming, coil coating), then preliminary calculations
are needed before the CWF can be applied. These preliminary calculations
would involve either converting the production-based categorical standard to
an equivalent concentration limit, or converting the concentration-based
categorical standard to an eguivalent mass limit.
To convert a production-based categorical standard to an eguivalent
concentration limit, the procedure outlined in the previous Chapter should be
utilized. This would involve multiplying the production-based standard by
the average production basis and dividing by the flow. Consider an industrial
facility that combines wastewaters from a coil coating process (with discharge
limit units of mg/fai^) an<3 a metal finishing process (with discharge limit
units of mg/1).
If the Control Authority desires to regulate using the concentration
units of the metal finishing standards (mg/1), the Control Authority must first
convert the coil coating standards to eguivalent concentration limits.
Assuming an average daily coil coating production rate of 30,000 sguare
3-8
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meters of area processed and an average process flow rate of 10,000 gallons
per day, an equivalent concentration limit (daily maximum) for zinc is calcu-
lated as follows:
(1.56 mg/m2) (30,000 m2/day) = 1.24 mg/1
(10,000 gal/day) (3.78 1/gal)
Where 1.56 mg/m2 is the categorical standard daily
maximum limitation for zinc and 3.78 1/gal is a
unit conversion factor.
For this example, therefore, 1.24 mg/1 would be used in conjunction with
the daily maximum metal finishing zinc standard (2.61 mg/1) as C^ in the CWF
to develop an alternative concentration limit for the combined wastestream.
If the Control Authority desires to regulate using equivalent mass
limits, the concentration-based standard for metal finishing is multiplied
by the average or other appropriate flow of that regulated wastestream.
Assuming a metal finishing process wastewater average flow rate of 15,000
gallons per day, an equivalent mass limit (daily maximum) for zinc is calcu-
lated as follows:
(1.24 mg/1) (15,000 gal/day) (3.785 1/gal) = 70,401 rog/day
The coil coating standard (with units of mg/m2) has to be converted
to a mass per day limit so it can be combined in the CWF with the equivalent
mass limit for the metal finishing standards (with units of mg/day). As
described in Chapter 2, Section 2.2, a mass per day limit is derived by
multiplying the production-based standard by the production basis. Thus
assuming an average coil coating production rate of 30,000 square meters per
day, the mass per day limit (daily maximum) for zinc would be calculated as
follows:
(1.56 mg/m2) (30,000 m2/day) = 46,800 mg/day
For this example, the 70,401 mg/day and 46,800 mg/day would be used as
MI and M2 in the CWF to develop an alternative mass limit ( Mi)
for the combined wastestreams of 117,201 mg/day.
Finally, a situation could occur where two process wastestreams, each
regulated by different production-based categorical standards with different
production units, are combined and the CWF is needed to establish alternative
discharge limits. If this situation does occur, then the Control Authority
or IU must convert each production-based standard to an equivalent mass
per day limit prior to their use as values for M^ in the CWF for alternative
mass limits. To assist Control Authorities and IDs evaluate the compatibility
of production units for production-based categorical standards, Table 2.3
presents all of the major industrial categories and the production units
associated with the standards.
3.4.2 Conditions For Using The CWF
To ensure proper application and implementation of the CWF, the following
conditions (as described in Section 403.6(e) of, and the preamble to, the
3-9
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General Pretreatment Regulations) must be followed by the Control Authority
and IU:
o Alternative discharge limits that are calculated in place of the
promulgated categorical pretreatment standards must be enforced as
categorical standards.
o Calculations of alternative limits must be performed by the Control
Authority or by the IU with review and approval by the Control
Authority.
o Alternative limits must be established for each regulated pollutant in
each of the processes regulated by a categorical standard.
o When both production- and concentration-based standards apply, the
Control Authority may use mass-based limitations or concentration-based
limitations.
o Both daily maximum and long-term average (usually monthly)
alternative limits must be calculated for each regulated pollutant,
unless the categorical standards only include limits for the daily
maximum.
o A calculated alternative limit cannot be used if it is below the
analytical detection limit for that pollutant. If a calculated limit
is below the detection limit, the control authority must reguire
the regulated process wastestream to be segregated or appropriate
flow reductions to be implemented to allow detection.
o A mixture of wastestreams where one of the streams is subject to a
categorical standard requirement stating "zero discharge of process
wastewater pollutants" (e.g., porcelain enameling) reguires zero
flow for the stream. The zero flow discharge requirement must be
placed as a condition in the permit (or other control mechanism).
If the standard says "no discharge allowance for process wastewater
pollutants", (e.g., battery manufacturing), a discharge is allowed
but any flow measured would be considered dilution when using the
CWF.
Additionally, special considerations are needed if an industry combines
an electroplating process wastewater with other wastewaters, and the CWF will
need to be utilized to calculate an alternative discharge limit. Specifically,
the Electroplating Point Source Category Pretreatment Standards have 4-day
average limits. However, according to 40 CFR 413.04, as amended on January
28, 1981, if a nonelectroplating wastestream is regulated by a 30-day average
standard, and it is combined with an electroplating wastestream, 30-day
average standards rather than 4-day average standards are to be used in
calculating an alternative limit with the CWF. Section 40 CFR 413.04
provides a table to convert a 4-day average standard to a 30-day average
standard.
It is also important that Control Authority and IU personnel properly evaluate
the applicability of each categorical standard as it relates to using the
CWF when combining regulated process wastestreams. If there is any
3-10
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question of the proper category for which a facility is to be regulated, 40
CFR Part 403.6(a) gives procedures for a formal request for review and
certification from EPA or the delegated State as to the proper category.
There may also be instances when a categorical standard for one industry
(e.g., Porcelain Enameling) regulates wastewater discharges from a process
typically part of a more general industry category (e.g., Electroplating/
Metal Finishing). In these situations, the categorical standard for the
more specific industry category may take precedence and apply to the process
wastewater discharges. The Applicability Section of the regulation
for each of the categorical standards should be checked carefully.
For example, refer to Figure 3.2 which provides a process flow diagram
for a typical porcelain enameling on steel operation. Typically, alkaline
cleaning, acid etching and nickel deposition operations would be regulated
by the Electroplating/foetal Finishing Categorical Pretreatment Standards,
and when wastewaters from these process operations are combined with certain
other regulated process wastestreams, the CWF would need to be used.
However, according to 40 CFR 433.10(b) (Metal Finishing Point Source Category)
and 40 CFR Part 466 (Porcelain Enameling Point Source Category), these opera-
tions, when used immediately prior to a procelain enameling operation for
surface preparation, are regulated by the porcelain enameling regulations and
not the electroplating/metal finishing regulations.
Specifically, the Applicability Section of 40 CFR Part 466 states
that the Porcelain Enameling categorical standards apply to any porcelain
enameling facility which discharges into a POTW. Porcelain enameling is
defined in 40 CFR 466.02(a) as follows:
"Porcelain enameling means the entire process of applying a fused
vitreous enamel coating to a metal basis material. Usually this
includes metal preparation and coating operations."
Further metal preparation is defined in 40 CFR 466.02(f) as follows:
"Metal preparation means any and all of the metal processing steps
preparatory to applying the enamel slip. Usually this includes cleaning,
pickling and applying a nickel flash or chemical coating."
Therefore, the process wastewaters from all the operations shown in Figure 3.2
are regulated under the same category, Porcelain Enameling.
3.4.3 Implementation of the CWF
The previous sections of this chapter have provided guidance for
Control Authorities and lUs on how to properly calculate or establish alter-
native categorical discharge limits when IU wastestreams are combined prior to
treatment. However, it is equally important that lUs be aware of their
responsibility to the Control Authority while being regulated by these alter-
native categorical discharge limits, and that Control Authorities provide
proper oversight and ensure compliance with these alternative categorical
discharge limits derived from the CWF.
3-11
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Parts •
H20
I
1
*
Alkaline
Clean
HO
*
Rinse
H0
*<*
Etch
H0
*
H20
1
I
T
„ Nickel
Deposition
Rinse
Fusion
H20
1
Enamel
Application
Slip
Milling
H2°
H20
I
1
*
Rjnse
H20
i
1
Y
Neutralization
From: Development Document for Effluent Limitations Guidelines and Standards
for the Porcelain Enameling Point Source Category; EPA 440/1-82/072,
Final, November 1982
Figure 3.2
Typical Porcelain Enameling on Steel Operation
3-12
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3.4.3.1 IU Responsibilities
Section 403.6(e) of the General Pretreatment Regulations states in part:
"The Industrial User shall comply with the alternative daily
maximum and long-term average limits fixed by the Control
Authority until the Control Authority modifies the limits or
approves an Industrial User modification request. Modification
is authorized whenever there is a material or significant change
in the values used in the calculation to fix alternative limits
for the regulated pollutant. An Industrial User must immediately
report any such material or significant change to the Control
Authority. Where appropriate, new alternative categorical limits
shall be calculated with 30 days."
Therefore, the IU is responsible to notify the Control Authority
immediately of any changes that would significantly affect the values used in
the CWF to calculate their alternative categorical discharge limits. These
types of changes could include, but are not limited to, the following:
o An increase or decrease in production or flow related to the use of
production based standards to determine mass or equivalent concentration
limits such that the mass (M^) or equivalent concentrations (C^)
would change
o An increase or decrease in regulated process wastestream(s) flow such
that the values F-p and F-[ would change
o An increase or decrease in unregulated process and dilute waste-
stream(s) flow such that values FT and FQ would change
o A change in the regulated process(es) such that it will be regulated
by another categorical standard or subcategory thus changing C^
o A change in manufacturing process such that dilute wastestreams become
unregulated, or unregulated process wastestreams became dilute
wastestreams (this would apply to boiler blowdown and noncontact
cooling water discharges as the Control Authority determines the
definition of each as described previously)
o The addition of other regulated, unregulated and/or dilute wastestreams
which would affect all the CWF values.
It is the responsibility of the Control Authority to determine if new
alternative categorical discharge limits should be calculated based on the
changes submitted by the IU. Guidance on the use of production and flow
information to calculate or modify alternative limits is presented in Chapter
2. If new alternative limits are warranted, then they must be calculated
within 30 days.
Therefore, depending on the type of wastestreams combined, and the types
of categorical standards applicable to the regulated wastestreams (i.e.,
3-13
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concentration- or production-based), the following data may need to be included
in IU baseline monitoring reports, 90-day compliance reports, and semi-annual
self-monitoring reports:
o Flow measurements from each regulated process wastewater stream
o Flow measurements from each unregulated and dilute wastestream combined
with any regulated process wastestreams before treatment of the
combined wastestream. (The unregulated flow could be computed as the
difference between total flow and dilution flow.)
o Regulated pollutant concentrations in the effluent frcm the waste
treatment system (both daily maximum and long-term average)
o Production data for each regulated process (if production-based
standards are used)
o Regulated pollutant concentrations in boiler blowdown and noncontact
cooling water wastestreams if the IU requests reclassif ication fron
dilute to unregulated
The Control Authority may request other data as necessary to evaluate the
need for more stringent limits not associated with categorical standards.
3.4.4. Example Use of the CWF
This section provides Control Authorities and lUs with several examples
on how to properly utilize the CWF. These examples consider possible
combination of categorical industrial processes, ranging frcm simple to more
complex application of the CWF.
3.4.4.1 Example 1 - Simple Example of Combined Wastestream Formula
Calculations with Concentration Limits
The following example provides the calculations for determining alternate
discharge limits for zinc using the CWF. The example involving a job shop
electroplater with >10,000 gpd process wastewater flow and a sanitary waste-
stream:
Industrial
Category
Electroplating
Sanitary Waste
Wastestream
Type
Regulated
Dilution
Flow
(mgd)
0.08
0.01
Daily Max.
Zn Limit
(mg/1)
4.2
N/A
Compliance
Date
April 27, 1984
N/A
3-14
-------
Electroplating
Q = 0.08 mgd
Zn = 4.2 mg/1
Sanitary
Waste
Q
Zn
0.01 mgd
N/A
1
Zn
Zn
4.2 mg/1 (0.08 mgd)
'cwf 0.08 mgd
= 4.2 mg/1 (0.08 mgd)
'cwf (0.09 mgd)
(0.08 mgd 4- 0.01 mgd) - 0.01 mgd
(0.08 mgd + 0.01 mgd)
Zn
cwf
3.7 mg/1
3.3.4.2 Example 2 - More Complex Combined Wastestream Formula Example Calcu-
lations with Concentration Limits
The following example provides the calculations for determining alternate
CWF discharge limits for zinc. The example assumes a combination of various
industries with the following wastestreams:
Industrial
Category)
Metal Finishing
(Electroplating)*
(Coating and Painting)1
Porcelain Enameling
Sanitary Waste
Wastestream
Type
Regulated
Flow
(mgd)
0.4
Daily Max.
Zn Limit
(mg/1)
2.61
Regulated
Regulated
Dilution
0.1
0.075
0.05
2.61
1.332
N/A
Compliance
Date
February 15, 1986
November 25, 1985
N/A
llhese are not subcategories; they are metal finishing processes. These
operations are not associated with the porcelain enameling operations or
materials.
Alternative Production-based limits of 53.3 mg/fo2 for preparation and 0.85
mg>2 for coating were contained in 40 CFR 466.14 as of July 1985. Final
amendments based upon litigation settlement agreement revises the 0.85 mg/fci'S
to 1.68 mg/m2; thus for the mass-based examples the revised limit will be used.
3-15
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The calculation of alternate CWF limits (Zo^f) in this example is
based on compliance dates for Porcelain Enameling and Metal
Finishing.
Alternate CWF discharge limit for integrated electroplater/porcelain
enameler after February 15, 1986 (compliance date for metal finishing).
Q
Zn
Metal Finishing
(Electroplating
Common Metals)
= 0.4 mgd
• 2.61 mg/l,
Q =
Zn =
0.1 n
2.61
Metal Finishing
(Coating and Painting)
"igd
mg/l
Porcelain
Enameling (Steel)
Q = 0.075 mgd
, Zn = 1.33 mg/l ,
Sanitary
Waste
Q = 0.05 mgd
Zn = N/A ,
i
Zn,
'cwf
2.61 mg/l (0.4 mgd + 0.1 mgd) + 1.33 mg/l (0.075 mgd)
(0.5 mgd + 0.075 mgd)
(0.5 mgd + 0.075 mgd + 0.05 mgd - 0.05 mgd)
0.625 mgd
2.25 mg/l
Note: The electroplating and coating/painting processes are covered by
Metal Finishing in this example, and subject to a Zn limit of 2.61
mg/l. Thus, the alternate discharge limit is based on Metal Finishing
and Porcelain Enameling categorical standards and proportioned by the
flow of the three regulated wastestreams. Due to dilution from sanitary
waste, the alternate discharge limit is reduced to 2.25 mg/l.
3.4.4.3 Example 3 - Above Combined Wastestream Formula Calculations with
Concentration Limits for Cyanide
In the metal finishing category and certain others (e.g., Pharmaceuticals),
if cyanide is monitored after all wastestreams are combined, then all non-
cyanide containing wastestreams are considered dilution. Wastestreams that
contain cyanide could either be regulated or unregulated, but any non-cyanide
bearing wastestreams are considered dilution. Therefore, an alternative CWF
discharge limit for the above example with respect to cyanide is based upon
the same wastestream types, flows and compliance dates except for the following:
Daily Maximum Total Cyanide Standard
for Metal Finishing Category
Coating and Painting Wastestream Type
Porcelain Enameling Wastestream Type
Electroplating Wastestream Type
1.20 mg/l (cyanide-bearing streams)
Dilution (non-cyanide bearing)
Dilution (non-cyanide bearing)
Regulated (20%) and Dilution (80%
non-cyanide bearing)
3-16
-------
Note: Metal finishing standards (40 CFR 433.12(c)) require that the alternate
cyanide limit for combined wastestream be based upon the dilution
ratio of the cyanide containing wastestream to the effluent flow.
Since the coating and painting and porcelain enameling wastestreams
do not contain cyanide they are part of the effluent which is considered
dilution. In addition, a portion of the electroplating wastestream
(for this example 80 percent) does not contain cyanide and is considered
dilution.
The calculation of the cyanide daily maximum limit is as follows:
Cyanide Standard 1.20 mg/1 Daily Maximum
Cyanide Wastestream Flow 0.4 mgd (20%) =0.08 mgd
Total Effluent Flow = (0.4 mgd + 0.1 mgd + 0.075 mgd + 0.05 mgd)= 0.625 mgd
Cyanide,^ = 1.20 mg/1 (0.08 mgd)
0.625 mgd
= 0.15 mg/1
3.4.4.4 Example 4 - Combined Wastestream Formula Example Calculations Using
Concentration and Mass Limits
The following example provides the calculations for determining alternate
discharge limits for zinc using the CWF after August 15, 1986 (compliance
date for copper forming). The example assumes combinations of various
industries with the following wastestreams:
Industrial
Category
Metal Finishing
(Coating and Painting)
Porcelain Enameling
(Steel-coating sub-
category only)
Copper Forming
Sanitary Waste
Wastestream
Type
Regulated
Regulated
Flow
(mgd)
0.1
0.075
Zn Limit
(mgA)
2.61
1.332
Compliance
Date
February 15,
November 25,
1986
1985
Regulated
Dilution
0.4
0.05
Production
Based3
N/A
August 15, 1986
N/A
llhese are not subcategories ; they are metal finishing processes.
^Alternate Mass/Production based limits =53.3 mg/m2 for preparation and 1.68
for coating, (revised)
^Production based limits = 0.943 mg/off-kg of copper heat treated for
solution heat treatment.
3-17
-------
The calculated alternate discharge limits (ZHQ^) in the following examples
are based on compliance dates for Porcelain Enameling, Copper Forming and
Metal Finishing.
Copper Forming and several other categorical standards are expressed as
production-based limits. The example below converts production-based limits
to equivalent concentration-based limits. These equivalent concentration
limits can then be used as the standards for Copper Forming.
Copper Forming (Solution Heat Treatment) = 0.943 mg/off-kg of copper heat
Maximum Daily Limit for Zinc treated
Average Daily Production During
Last 12 months
Average Daily Water Usage in
Solution Heating Treating
During Last 12 months
= 30,000 off-kg of copper heat
treated per day
= 400,000 gpd
Note: Off-kg shall mean the mass of copper or copper alloy removed from a
forming or ancillary operation at the end of a process cycle for
transfer to a different machine or process.
EXAMPLE
Step It Convert Production-based Standard to Equivalent Concentration Limit
Concentration
Equivalent = (Production-based Limit)(Avg. Daily Production Rate)
Avg. Daily Flow from Regulated Process) (Conversion Factor)
Zn(equivalent) = 0*943 mq/off-kg (30,000 off-kg/day) = 0.019 mg/1
400,000 gpd (3.785 liters/gallon)
Step 2; Once the concentration equivalent is determined, then the
alternative CWF limit can be calculated as shown below:
Q - (
Zn - (
Copper Forming
(Solution Heat
Treatment)
).4 mgd
).019mg/l ,
Metal Finishing
(Coating and Painting)
Q = 0.1 mgd
Zn = 2.61 ,
Q =
Zn =
0.07
1.33
Porcelain
Enameling (Steel)
5 mgd
!
Sanitary
Waste
Q = 0.05 mgd
Zn =- N/A
r
Zn,
cwf
(0.019 mg/l x 0.4 mgd) + (2.61 mg/l x 0.1 mgd) + (1.33 mg/l x 0.075 mgd)
(0.4 mgd + 0.1 mgd 4- 0.075 mgd)
3-18
-------
(0.4 mgd + 0.1 mgd + 0.075 mgd + 0.05 mgd - 0.05 mgd)
0.625 mgd
1
Zncwf = °-59 mg/1
For the wastestreams shown in the first part of Example 4, permit authori-
ties may wish to utilize mass limits. The example below converts both concen-
tration-based and production-based standards to mass-based limits and
utilizes the CWF to calculate an alternative mass per day limit.
EXAMPLE (Alternative Method)
Copper Forming
Copper Forming (Solution Heat Treatment = 0.943 mg/off-kg of copper heat
Maximum Daily Limit for Zinc treated
Average Daily Production During = 30,000 off-kg of copper heat
Last 12 months treated per day
Average Daily Water Usage in = not required
Solution Heat Treating
During Last 12 months
Allowable Zn Mass = 0.943 (30,000) = 28,290 mg/day
Metal Finishing
Metal Finishing Maximum Daily =2.6 mg/1
Limit for Zinc
Average Daily Production During = not required
Last 12 months
Average Daily Water Usage in = 100,000 gpd
Metal Finishing
Allowable Zn Mass = 2.61 (100,000 x 3.78)= 986,580 mg/day
Porcelain Enameling
Porcelain Enameling (steel basis material) = (53.3 + 1.68) mg/m2 of area
Maximum Daily Limit for Zinc using the processed or coated through metal
alternative mass limits preparation and coating operation,
respectively.
Average Daily Production During = 5570 m2 of preparation
Last 12 months 7250 m2 of coating
Average Daily Water Usage in = not required
Porcelain Enameling
Allowable Zn Mass = 53.3(5570)+!.68(7250)=309,061 mg/day
3-19
-------
Copper Forming
(Solution Heat
Treatment)
\
Metal Finishing
(Coating and Painting)
28,290 mg/day
Porcelain
Enameling (Steel)
, 986,580 mg/day
Sanitary
Waste
, 309,061 mg/day
p
Zncwf = 28,290 -i- 986,580 + 309,061
= 1,323,931 mg/day
Zncwf =1-32 kg/day or (2.9 Ibs/day)
Note: Average daily water usages for the copper forming and porcelain
enameling (production-based) limits are not required for the example
calculations shown above.
3.4.4.5 Example 5 - Combined Wastestream Formula Example Calculations for
an Integrated Facility
The following example provides the rationale and calculations for determining
alternate CWF limits for copper, for a copper forming facility containing
regulated, unregulated and dilution streams. It also provides a summary of
calculated alternative limits for other regulated pollutants.
1. Facility Description; An integrated copper forming facility that
produces 12-gauge copper wire and 22-gauge tin-plated copper wire
that is used for electrical and electronic products.
2. Process Description; Purchased 3/8" annealed and cleaned copper rod
is drawn to produce a 12-gauge copper wire. After being drawn, the
copper wire is annealed and alkaline cleaned to produce th«» finished
copper wire. Sixty percent of the finished 12-gauge copper wire is
then redrawn, annealed, and alkaline cleaned, to produce a 22-gauge
copper wire. The 22-gauge copper wire is then plated with tin to
produce a second finished product. A process flow diagram for this
example IU is shown in Figure 3.3.
3. Production Rates;
Average daily production rate for the
12-gauge copper wire forming process:
Average daily production rate for the
22-gauge copper wire forming process:
50,000 kg/day
30,000 kg/day
3-20
-------
Copper
Rod 13/8")'
Drawing
Process
^
Water
Annealing
Process
•—
Alkaline
Cleaning
Alkaline
Cleaning
Rinse
Finished
12-Gauge
Copper Wire
Finished
12-Gauge •
Copper Wire
Drawing
Process
Water
Annealing
Process
Finished
Tin-Plated
22-Gauge
Copper Wire
Alkaline
Cleaning
Alkaline
Cleaning
Rinse
Rinse
Electroplating
Acid Tin Bath
Figure 3.3
Process Flow Schematic for Example IU
3-21
-------
Drawing
Process
Annealing
Process
Alkaline
Cleaning
Alkaline
Cleaning Rinse
Treatment
Noncontact
Cooling Water
Tin Electroplating
Process
Tin Electroplating
Rinse
Sanitary
To POTW
Figure 3.4
Example IU Wastewater Flow Diagram
3-22
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4. Average Copper Forming Process Wastestrearo Flow Rates:
Process Average Wastewater Flow Rate (gpd)
Drawing 2000 (12-gauge process)
1200 (22-gauge process)
Water Annealing 25,000 (12-gauge process)
17,000 (22-gauge process)
Alkaline Cleaning 7,500 (12-gauge process)
5,000 (22-gauge process)
Alkaline Cleaning Rinse 110,000 (12-gauge process)
70,000 (22-gauge process)
Total 237,700
* Note: Breakdown of process flows developed from model plant data in Copper
Forming Development Document. Only the total flow is necessary for
use in the CWF.
5. Average Electroplating Process Wastestream Flow Rates;
Process Average Wastewater Flow Rate (gpd)
Tin Electroplating and rinse 11,300
6. Wastewater Flow Diagram: Figure 3.4 provides a wastewater flow
diagram for the example facility. Note that two additional waste-
streams, sanitary and noncontact cooling water, are combined with the
process wastewater before treatment.
7. Applicable Categorical Standards; The copper forming and ancillary
processes are regulated by 40 CFR Part 468.14; Copper Forming
Categorical Pretreatment Standards; Copper Forming Category. The
wastewater from the major copper forming process (drawing in this
example) and each ancillary process (annealing, alkaline cleaning and
rinse) are individually regulated by the copper forming categorical
standard. For this example IU, the standards which apply and are
utilized are shown in Appendix D. For the calculation determining
the copper limit, the applicable standard is sutmarized in the
results summary table later in this example.
8. Classification of Noncontact Cooling Water; In order to determine
whether the noncontact cooling water discharged at this example
IU would be classified as dilute or unregulated, the Control
Authority required analysis of grab samples of the wastewater for
all the regulated pollutants. Results of the analyses are as follows:
3-23
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Noncontact Cooling Water
Parameter Concentration (mg/1)
Cadmium ND*
Chronium ND
Copper 1.89
Lead ND
Nickel ND
Silver ND
Zinc ND
Cyanide (total) ND
*ND = not detected, below analytical detection limits
Based en the above analyses, the Control Authority may classify the
noncontact cooling water as a dilute wastestream for all the regulated pol
lutants. In the case of copper, which was the only pollutant detected, the
measured value was not substantially above the treatability level as reflected
by the maximum daily limit and maximum average monthly (4-day) limit in the
electroplating regulations. In fact the measured level was substantially
below these limits.
9. Example Calculation for Alternative Mass Limit for Copper after
August 15, 1986
The following will illustrate how to calculate an alternative mass
limit for copper, for the example IU described above after August 15, 1986
(compliance date for Copper Forming Categorical Pretreatment Standards).
a). Calculation of Mass Per Day Eguivalent for Copper Forming Processes
In order to utilize one categorical standard for the entire copper
forming process, the standards (or allowance) for the major forming and
ancillary processes can be summed together based on the production rate of
each process. For this example IU, the following table presents the
applicable copper standard for each process and the total allowance for the
entire copper forming process:
3-24
-------
Daily Maximum Standard
Daily
Applicable Production
Regulated Copper Standard Rate
Process (mg/off-kg) (off -kg/day)
Drawing:
12-Gauge
22-Gauge
Annealing:
12-Gauge
22-Gauge
Alkaline Cleaning:
12-Gauge
22-Gauge
Alkaline Cleaning Rinse:
12-Gauge
22-Gauge
Total Allowance
Maximum
Drawing:
12-Gauge
22-Gauge
Annealing:
12-Gauge
22-Gauge
Alkaline Cleaning:
12-Gauge
22-Gauge
Alkaline Cleaning Rinse:
12-Gauge
22-Gauge
0.161
0.161
2.356
2.356
0.088
0.088
8.006
8.006
Monthly Average
0.085
0.085
1.240
1.240
0.046
0.046
4.214
4.214
50,000
30,000
50,000
30,000
50,000
30,000
50,000
30,000
Standard
50,000
30,000
50,000
30,000
50,000
30,000
50,000
30,000
Copper
Allowance
(ing/day)
8,050
4,830
117,800
70,680
4,400
2,640
400,300
240,180
848,880 ing/day
4,250
2,550
62,000
37,200
2,300
1,380
210,700
126,420
Total Allowance
446,800
3-25
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b). Adjustment of Metal Finishing Standards; The metal finishing categorical
standards regulate only the concentration (in mg/1) of wastewaters discharged
fron electroplating processes. Therefore, the Control Authority has to con-
vert the concentration-based metal finishing standard for copper to an equivalent
mass limit. For this example, the equivalent daily maximum mass limit
for copper is calculated as follows:
Daily Maximum
Equivalent Mass =3.38 mg/1 x 11,300 gpd x 3.785 liters/gal.
Limit for Copper
144,564 mg/day
The monthly average mass limit for metal finishing standards is based directly
on the maximum monthly concentration limit for copper in the regulation and
can be calculated as follows:
Monthly Maximum
Equivalent Mass = 2.07 mg/1 x 11,300 gpd x 3.785 1 liter/gal. = 88,535 mq/day
Limit for Copper
b). Data Summary Table; The following table summarizes the data necessary to
calculate an alternative discharge limit for copper when metal finishing and copper
forming standards apply:
Wastestream
Description
Copper Forming
Processes
Electroplating
(Tin)
Non-Contact
Cooling Water
Sanitary
Wastestream
Type
Regulated
Fequlated
Dilute
Dilute
Average
Flow
(gpd)
237,000
11,300
6,400
4,000
Daily Max.
Copper Limit
848,880 mg/day
144,564 mg/day
N/A
N/A
Max. Monthly
Avg. Copper Limit
446,800mg/day
88,535mg/day
N/A
N/A
c). Alternate Daily Maximum Copper Limit Calculation; Using the data found
in b) above, an alternate daily maximum copper limit can be calculated again
using the alternative mass limit formula given in Section 3.3.1.2:
MT = (848,880 mg/day 4- 144,564 mg/day)
I" (259,400 gpd - 10,400 gpdf]
[(237,700 gpd + 11,300 gpdlj
MT = 993,444 mg/day
MT - 993,444 mg/day
f 249,000 gpdl
L249,000 gpdj
3-26
-------
d). Alternate Monthly Copper Limit Calculation; Again using the data in b)
above and the alternative mass limit formula, an alternative maximum monthly
average copper limit can be calculated. The calculation is the same as in
c) above, however the values for M^ change to reflect the maximum monthly
average limits:
MT = (446,800 mg/day + 88,535 mg/day)
MT = 535,335 mg/day
[(259,400 gpd - 10,400 gpd)~|
[(237,700 gpd + 11,300gpd)J
10. Example calculations for copper before August 15, 1986 (compliance
date for copper forming) and after February 15, 1986 (compliance
date for metal finishing)
a). Calculation of alternative concentration limit for Copper
Metal Finishing = 3.38 mg/1 categorical limit
Daily Maximum
Concentration for Copper
Copper Forming = Unregulated Process Wastestream for Purposes of CWF
Daily Maximum
Concentration for Copper
Using the appropriate flow information for all wastestreams and whether the
wastestream is dilution the following CWF calculation results:
Cu
!cwf
Ci Fi x FT - FD
3.38 mg/l (11,300 gpd)]
11,300 gpd
(259,400 gpd - 10,400 gpd)
259,400 gpd
Cucwf = 3.38 mg/l x 0.9599
Cu,.^ = 3.24 mg/l
b). Calculation of alternative mass limit for Copper
Metal Finishing = 3.38 mg/l x 3.785 liters/gal x 11,300 gpd
Daily Maximum
Mass for Copper = 144,564 mg/l
Mcwf = Mi x FT - FD
Fi
Cumass cwf =144,564 mg/day x
(259,400 gpd - 10,400 gpd)
11,300 gpd
3.186 x 106 mg/day
3-27
-------
11. Calculation of Alternate Discharge Limits for the Remaining Regulated
Pollutant Parameters (After August 15, 1986)
The remaining pollutant parameters that are regulated by both the copper
forming and electroplating/metal finishing categorical standards include
chromium (Cr), lead (Pb), nickel (Ni), zinc (Zn) and total toxic organics
(TTO). In addition, cadmiun (Gd), silver (Ag), total cyanide (CM), and total
metals are regulated only by the electroplating/metal finishing standards.
For those regulated pollutants common to both categorical standards,
the calculations would be similar to those described in this example, Parts 9
and 10. The only differences in the calculations would be utilization of the
applicable standard for each pollutant.
12. Calculation of Alternative Discharge Limits for TTO
In order for this example facility to comply with the TTO standards in
both the copper forming and electroplating/metal finishing categorical stan-
dards, an alternative TTO mass limit must be developed using the CWF or the
TTO monitoring alternative provided in each regulation may be used indepen-
dently or together. The copper forming regulation provides an oil and grease
standard as an alternative to TTO monitoring and compliance; the electroplating/
metal finishing provides a TTO monitoring alternative comprising a certification
procedure and the development and implementation of a toxic organic management.
An example dealing with this type of occurrance is contained in the
"Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreatment
Standards". The reader should refer to this manual for guidance on the
implementation of the TTO standards.
13. Calculations of Remaining Pollutant Parameters Regulated by
Electroplating and Metal Finishing Only
The remaining pollutant parameters regulated by the electroplating/metal
finishing standards for the tin plating process (Gd, Ag, CN, total metals)
would also need to be adjusted using the CWF. To do this, the copper forming
process wastestreams would be classified as unregulated except in the case of
cyanide and used as such in the CWF. For cyanide only the cyanide bearing
wastestreams are considered regulated flows; the other flows are considered
dilution (see previous example in Section 3.4.4.3).
3.4.5 Comparison of local Limits and Categorical Standards
Control Authorities are required during pretreatment program development
to establish local discharge limits to:
o Prevent the introduction of pollutants into the POTW which could
interfere with its operations
o Prevent the pass through of untreated pollutants which could violate a
POTW's NPDES permit limitations and applicable water quality standards
o Prevent the contamination of a POTW's sludge which would limit
selected sludge uses or disposal practices.
3-28
-------
These local limits are normally applicable to lUs at the point where they
discharge into the POTW collection system ("end-of-pipe").
Categorical standards on the other hand, are treatment technology-based
and apply at the point just downstream from the regulated process ("end-of-
process").
To be able to perform a comparison between local limits and categorical
standards to determine which standards are more stringent, it may be necessary
to calculate a CWF alternative limit which applies to the regulated streams
plus any wastestreams combined prior to treatment. This limit may then need
to be further adjusted using the methodology described in Section 3.3 if
non-regulated streams are added to the treated effluent.
The following example illustrates the process for comparing categorical
standards to local limits using a typical integrated facility as shown in
Figure 3.5. In this example, it is assumed that the Control Authority is
not applying the CWF where non-regulated wastestreams are added after
treatment.
3.4.5.1 Example - Integrated Facility Calculations Comparing Categorical
Standards and Local Limits
Facility Data:
1. Description of the example facility:
o The company is an electroplating job shop with a flow >10,000
gpd.
o The electroplating operations consist of cadmium, nickel, and
chrome plating.
o The other manufacturing operations consist of plastic extrusion,
paint stripping and spray painting. Wastewater from the extrusion
operation is noncontact cooling water.
o The facility has sanitary and cafeteria wastewaters.
2. The electroplating pretreatment standards for job shops are promul-
gated in 40 CFR 413. The maximum limits for any one day (in mg/1)
for flows >10,000 gpd are:
CN,T: 1.9 Zn: 4.2
Cu: 4.5 Pb: 0.6
Ni: 4.1 Cd: 1.2
Cr: 7.0 Total Metals: 10.5
Daily maximum values are utilized for the comparison in this example,
because POTW local limits are normally expressed as maximum limits
for any one day. Hence, a Control Authority would apply to the
categorical IU the categorical four-day average limit as adjusted for
the combined flow, and the more stringent maximum standard for any
one day (local or categorical).
3-29
-------
Property Line
f — s. x x— — x x — x--x -
— X-— X— — X — — X X— —X— — X -
I
X
:
t
:
c
t
;
i
:
x
Y,
D D
D D
ngn
ns. n
n ?n
D|D
D n
n n
L»- 1
if-
Sample
Point A
>
Extrusion
(Noncontact Cooling)
Spray
Painting
1
1
i
1
1
«*_!_„
Waste
Treatment
*. , Pain
i Stripp
i
!<-— *
I On-site
1 Sewer
Restrooms •*•
i
i
1
I
Sample '
Point B O
•Ik-
Dry
Assembly
i
_.i
t
ny • "
Cafeteria
Offices
T
•o-
Main Street
Wastewater Flows (Gallons Per Day)
Electroplating
Noncontact Cooling
Spray Painting
Paint Stripping
Sanitary and Cafeteria
Total Flow
\
City
Sewer
50,000 gpd
30,000 gpd
10,000 gpd
5,000 gpd
10,000 gpd
105,000 gpd
Sample Point A — Sump located immediately after treatment
(combined wastestream formula applies)
Sample Point B — On-site manhole, 10 feet NW of Main Street
(local limits apply)
Figure 3.5
Example Flow Schematic of Example Integrated Facility
3-30
-------
3. The POTW has the following maximum local limits (mg/1) which apply
at Point B:
CN,T: 3.0 Zn: 4.0
Cu: 2.0 Pb: 0.1
Ni: 3.0 Cd: 0.5
Cr: 5.0
4. As shown below, it appears that when comparing local limits vs.
categorical standards on paper, six of the local limits are more
stringent than the categorical standards. Since categorical stan-
dards are end-of-process limits and not end-of-pipe limits, this
one-step, simple comparison is not applicable at a point where all
wastewaters are combined.
Federal Standard Local Standard
CN,T 1.9 3.0
Cu 4.5 2.0
Ni 4.1 3.0
Cr 7.0 5.0
Zn 4.2 4.0
Pb 0.6 0.1
Cd 1.2 0.5
Total Metals 10.5
5. Flow Schematic of the Example Facility:
See Figure 3.5.
6. Example facility wastestream flow rates:
Regulated flow (electroplating only): F^ = 50,000 gpd
Flows added before treatment
Dilution flow: FD = 30,000 gpd
(plastic extrusion non-contact cooling waters)
Unregulated process flows: 10,000 gpd (not required)
(spray painting only)
Total Flow at Point A: FT = 90,000 gpd
Flows added after treatment (Not Regulated)
Sanitary and Cafeteria: 10,000 gpd
Paint Stripping: 5,000 gpd
Flow at Point B: 105,000 gpd
The flow from the spray painting operation is considered an unregulated stream
because spray painting is not listed in Appendix D of the General Pretreatment
3-31
-------
Regulations (which would have made it considered dilution) and it is not
regulated under the Electroplating category 40 CFR Part 413 (which would
have made it considered regulated). However, if the facility was not a job
shop, then it would be covered under Metal Finishing, 40 CFR Part 433 after
February 15, 1986, and the spray painting flow would be considered regulated
and covered by the standards issued as part of that category standard. The
flow from paint stripping is also not regulated under the Electroplating
Standards.
B. Adjustment of Categorical Standards
The following illustrates how to calculate an adjusted categorical limit
for cadmium (Cd), to be applied at Sample Point A, using the CWF and then
adjusting the limit for the addition of non-regulated streams after treatment.
These steps are important so that proper comparison of categorical standards
and local limits can be performed.
STEP 1
Combined wastestream formula:
N
(A)
FT - FD
i=l x
N
FT
Cj-/A\ = Alternative concentration limit for combined flow of regulated
wastesteam plus other (unregulated and dilute) was test reams added
prior to treatment. This limit applies at Sample Point A.
Ci = Federal categorical pretreatment standard for the pollutant in the
regulated wastestream (F^)
Fi = Regulated process wastestream flow
FT = Total flow at Sample Point A
FD = Dilution flow at Sample Point A
STEP 2
Calculating for cadmium using flows presented in A. 6 above:
CT(A) = 1*2 mg/1 x 50,000 gpd x 90,000 gpd - 30,000 gpd
50,000 gpd 90,000 gpd
=1.2 mg/1 x 0.667
=0.80 mg/1
3-32
-------
STEP 3
Adjusting CWF limit (Cj.) to determine applicable limit at Point B.
First, determine the actual concentration of cadmium in the non-regulated
streams added after treatment. The sanitary and cafeteria wastestreams
contain no metals. The analysis of the paint stripping wastewater yields the
following:
Actual Concentrations
Pollutant Paint Stripping (mg/1)
CN,T ND
Cu ND
Ni ND
Cr ND
Zn 0.9
Pb 0.3
Cd 1.4
Total Metals 1.4
Adjusted Concentration Limit for Point B
CWF Limit Actual Mass of Pollutant in Non-Regulated
for Point A X Flow at Point A + Streams Added After Treatment
(Flow at Point B)
Adjusted Concentration Limit for Point B for Cd is:
(0.80 mg/1) (90,000 gpd) + (1.4 mg/1) (5,000 gpd)
CT (B) = 105,000 gpd
CT(B)= 0.75 mg/1
Step 4
Perform the above calculations for the other regulated pollutants and make a
comparison and selection of the more stringent limits (i.e., local limits vs.
adjusted categorical limits to apply at Point B. It should be noted that
the requirement contained in the metal finishing (CFR Part 433) categorical
standards that non-cyanide wastestream are considered dilution does not
apply for the electroplating (CFR Part 413) limitations used in the combined
wastestream formula. Thus, the cyanide calculations are conducted in the
same manner as the metals.
3-33
-------
(a)
(b)
(c)
(d)
Categorical
Standard
Daily Max
(mg/l)
1.9
4.5
4.1
7.0
4.2
0.6
1.2
10.5
Adjusted
Categorical
Standard
Daily Max
(mg/l)
1.1
2.6
2.3
4.0
2.4
0.3
0.75
5.8
Local Limit
Daily Max
(mg/l)
3.0
2.0
3.0
5.0
4.0
0.1
0.5
Appli cable Limit
(most stringent)
(mg/D
1.1 (Categorical)
2.0 (Local)
2.5 (Categorical)
4.2 (Categorical)
2.5 (Categorical)
0.1 (Local)
0.5 (Local)
5.8 (Categorical)
CN,T
Cu
Ni
Cr
Zn
Pb
Cd
Total Metals
Examining the table above, the following observations are made:
(1) Local limits are more stringent for Cu, Pb, and Cd.
(2) Without adjusting the categorical standards, comparing column (c) with
column (a), it appears as discussed earlier that local limits for Ni,
Cr, and Zn are more stringent. However, after calculating the adjusted
categorical standards, the adjusted categorical limits for these three
pollutant parameters are more stringent then the local limit at the
point at which local limit apply.
(3) In summary, comparison of the limits without adjusting the categorical
standard shows that six local limits would be more stringent. After the
adjustment, only three limits remain more stringent.
3-34
-------
4. REFERENCES
"Development Document for Effluent Limitations Guidelines and Standards for
the Copper Forming Point Source Category; Final," March 1984, EPA
440/1-84/074.
"Development Document for Effluent Limitations Guidelines and Standards for
the Metal Finishing Point Source Category; Final," June 1983, EPA
440/1-83/091.
"Development Document for Effluent Limitations Guidelines and Standards for
the Porcelain Enameling Point Source Category; Final," November 1982, EPA
440/1-82-072.
"Guidance Manual for Electroplating and Metal Finishing Pretreatment
Standards," February 1984, EPA Effluent Guidelines and Permits Division.
"Guidance Manual for POIW Pretreatment Program Development," October 1983, EPA
Office of Hater Enforcement and Permits.
"Pretreatment Program Implementation Guidance Manual," May 1984, EPA Region X
Permits Branch.
"Guidance Manual for Implementing Total Toxic Organics (TTO) Pretreatment
Standards, "September 1985, U.S. EPA Permits Division.
4-1
-------
APPENDIX A
PUBLICATIONS AVAILABLE FROM THE GOVERNMENT PRINTING OFFICE
AND/OR THE NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
-------
APPENDIX A
PUBLICATIONS ORDERING INFORMATION
Copies of all Development Documents published by the Industrial Technology
Division (formerly Effluent Guidelines Division) are maae available for
review at the following EPA Office's:
ENVIRONMENTAL PROTECTION AGENCY
Public Information Reference Unit
Waterside Mall, Room 2922
401 M Street, SW
Washington, DC 20460
or
Any Environmental Protection Agency
Regional Office Library
Publications can be obtained by purchasing from the following sources
using the document numbers shown in the attached table:
GOVERNMENT PRINTING OFFICE (GPU)
ATTN: Superintendent of Document
North Capitol Street, NW
Washington, DC 20402
Order Desk Phone Number (202) 783-3238
NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
5285 Port Royal Road
Springfield, VA 22151
Order Desk Phone Number (703) 487-4b50
(NTIS Accession Number is required when ordering)
A-1
-------
APPENDIX A (CONT'D)
CATEGORY OF ITD
INDUSTRIAL STUDIES
CFR
PART
NUMBER
PUBLICATIONS AVAILABLE FROM THE GOVERNMENT PRINTING OFFICE (GPO)
AND/OR THE NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
SUBCATEGORY
ITD
DOCUMENT NUMBER
GPO STOCK
NUMBER
NTIS
ACCESSION
NUMBER
Aluminum Forming 467
Battery Manufacting 461
Coil Coating 465
Copper Forming 468
Electroplating 413
Electrical & Elec- 469
tronics Components
Inorganic Chemicals 415
Aluminum (Final)
Battery Mfg. (Final)
a) Coil Coating (Final)
b) Coil Coating Canmaking
(Final)
Copper (Final)
Electroplating
(Pretreatment Final)
a) Phase I (Final)
b Phase II (Final)
a) (Phase I) (Final)
b) (Phase II) (Final)
EPA 440/1-84/073
EPA 440/1-84/067 Vol I
Vol II
EPA 440/1-82/071
EPA 440/1-83/071
EPA 440/1-84/074
EPA 440/1-79/003
EPA 440/1-83/075
EPA 440/1-84/075
EPA 440/1-82/007
EPA 440/1-84/007
PB84-244425
PB85-121507
PB85-121515
PB83-205542
PB84-198647
PB84-192459
PB80-196488
PB82-249673
PB82-265612
PB85-156446
Iron & Steel
Manufacturing
420
Iron & Steel (Final)
Volume I
Volume II
Volume III
Volume IV
Volume V
Volume VI
EPA 440/1-82/024
PB82-240425
PB82-240433
PB82-240441
PB82-240458
PB82-240466
PB82-240474
* Also available from Effluent Guidelines Division
A-2
-------
APPENDIX A (CONT'O)
PUBLICATIONS AVAILABLE FROM THE GOVERNMENT PRINTING OFFICE (GPO)
AND/OR THE NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
CATEGORY ITD
INDUSTRIAL STUDIES
Leather Tanning &
F i n i sh 1 ng
Metal Finishing
CFR
PART
NUMBER
425
433
SUBCATEGORY
Leather (Final )
Metal Finishing
ITD
DOCUMENT NUMBER
EPA 440/1-82/016
EPA 440/1-82/091
NTIS
GPO STOCK ACCESSION
NUMBER NUMBER
Pb83- 172593
PB84- 1 1 1>989
Nonferrous Metal 421
Petroleum Refining 419
Pharmaceuticals 439
Plastics Molding 463
8. Forming
Porcelain 466
Enameli n
(Final)
a) Bauxite Ref in ing
b) Primary Aluminum
Sme11 i ng
c) Secondary Aluminum
SmeIti ng
Petroleum Refining
(Final)
Pharmaceutical (Final)
Form!ng (Fi nal)
Porcelain Enameling
(Final)
EPA 440/1-74/091-c 5501-001tb Pttr284b3/AS
EPA 440/l-74/OI9-d 5501-00817 PB234859/AS
EPA 440/1-74/019-e 5501-00819 PB238464/AS
EPA 440/1-82/014
EPA 440/1-83/084
EPA 440/1-84/069
EPA 440/1-82/072
PB83-I72569
Pb84-I800bb
A-3
-------
APPENDIX A (CONT'D)
PUBLICATIONS AVAILABLE FROM THE GOVERNMENT PRINTING OFFICE (GPO)
AND/OR THE NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
CATEGORY ITD
DUSTRIAL STUDIES
Pulp & Paper &
Paperboard
CFR
PART
NUMBER
430
&
431
Steam Electric 423
Textile Mills 410
Timber Products 429
SUBCATEGORY
Pulp, Paper & Paper-
board and Builders'
Paper & Board Mills
(Final)
Steam Electric (Final)
Textile Mills (Final)
Timber Products (Final)
ITD
DOCUMENT NUMBER
EPA 440/1-82/025
EPA 440/1-82/029
EPA 440/1-82/022
EPA 440/1-81/023
GPO STOCK
NUMBER
NTIS
ACCESSION
NUMBER
PB83-163949
PB83-116871
PB81-227282
A-4
-------
APPENDIX B
STATUS OF CATEGORICAL PRETREATMENT STANDARDS
-------
INDUSTRIES SUBJECT TO CATEGORICAL PRETREATMENT STANDARDS
FINAL REGULATIONS
Industry Category
Timber Products
Electroplating2
Iron & Steel
Inorganic Chemicals (Phase I)
Petroleum Refining
Pulp & Paper Mills
Steam Electric Power Plants
Leather Tanning & Finishing
Porcelain Enameling
Coil Coating
Electric and Electronic
Components (Phase I)
Metal Finishing
Copper Forming
Aluminum Forming
Pharmaceuticals
Coil Coating (Canmaking)
Electrical & Electronic
Components (Phase II)
Nonferrous Metals (Phase I)
Battery Manufacturing
Inorganic Chemicals (Phase II)
Nonferrous Forming
Nonferrous Metals (Phase II)3
Metals Molding and Casting 3
PSES1
Compliance
Date
12-09-79
4-27-84 (Nonintegrated)
6-30-84 (Integrated)
6/15/86 (TTO)
7-10-85
8-12-85
12-01-85
7-01-84
7-01-84
11-25-85
11-25-85
12-01-85
7-01-84 (TTO)
11-08-85(Arsenic)
6/30/84 (TTO)
2-15-86
8-15-86
10-24-86
10-27-86
11-17-86
7-14-87
3-09-87
3-09-87
8-22-87
8-23-88
ipSES - Pretreatment Standards for Existing Sources.
2Existing job shop electroplaters and independent printed circuit board
manufacturers must comply with only the electroplating regulations. All
other electroplating subcategories are now covered by both the electroplating
and metal finishing standards.
3Standards are not yet final.
B-l
-------
INDUSTRIAL TECHNOLOGY DIVISION
PROPOSED AND FINAL RULES - PRIMARY CATEGORIES
FEDERAL REGISTER CITATIONS
(1979 - Present)
9/16/85
Industry 40 CFR PART TYPE RULE SIGNATURE*
0 ALUMINUM FORMING 467 PROPOSED 11/05/82
PROMULGATION 09/30/83
Correction
Notice
(Approval )
0 BATTERY MANUFACTURING 461 PROPOSED 10/29/82
PROMULGATION 02/27/84
Correction
Correction
Notice
(Records)
• COAL MINING 434 PROPOSED 12/30/80
PROMULGATION 09/30/82
Correction
Prop. Amend.
Notice
(Comment Period)
Notice
(Approval)
0 COIL COATING
Phase I 465 PROPOSED 12/30/80
PROMULGATION 11/05/82
Final Amend.
Final Amend.
Correction
Phase II (Canmaklng) 465 PROPOSED 01/31/83
PROMULGATION 11/09/83
Correction
Notice
(Approval )
0 COPPER FORMING 468 PROPOSED 10/29/82
PROMULGATION 08/04/83
Final Amend.
Prop. Amend.
Prop. Amend.
Final Amend.
0 ELECTRICAL/ELECTRONIC COMPONENTS
Phase I 469 PROPOSED 08/11/82
PROMULGATION 03/31/83
Interim Final/
Prop. Amend.
Final Amendment
Notice
(Approval )
Notice
(Approval )
Phase II 469 PROPOSED 02/28/83
PROMULGATION 11/30/83
Correction
FEDERAL REGISTER
47 FR 52626
48 FR 49126
49 FR 11629
50 FR 4513
47 FR 51052
49 FR 9108
49 FR 13879
49 FR 27946
49 FR 47925
46 FR 3136
47 FR 45382
48 FR 58321
49 FR 19240
49 FR 24388
50 FR 4513
46 FR 2934
47 FR 54232
48 FR 31403
48 FR 41409
49 FR 33648
48 FR 6268
48 FR 52380
49 FR 14104
50 FR 4513
47 FR 51278
48 FR 36942
48 FR 41409
50 FR 4872
50 FR 26128
50 FR 34242
47 FR 37048
48 FR 15382
48 FR 45249
49 FR 5922
49 FR 34823
50 FR 4513
48 FR 10012
48 FR 55690
49 FR 1056
CITATION
11/22/82
10/24/83
03/27/84
01/31/85
11/10/82
03/09/84
04/09/84
07/09/84
12/07/84
01/13/81
10/13/82
11/01/83
05/04/84
06/13/84
01/31/85
01/12/81
12/01/82
07/08/83
09/15/83
08/24/84
02/10/83
11/17/83
04/10/84
01/31/85
11 /1 2/82
08/15/83
09/15/83
02/04/85
06/27/85
08/23/85
08/24/82
04/08/83
10/04/83
02/16/84
09/04/84
01/31/85
03/09/83
12/14/83
01/09/84
* Administrator's signature; ( ) 1s the projected schedule approved by the court.
NOTE: THIS LISTING DOES NOT INCLUDE RULEMAKING ACTIVITIES SUBSEQUENTLY PUBLISHED BETWEEN PROPOSAL
AND PROMULGATION UNLESS THE SCHEDULED PROMULGATION HAS NOT YET BEEN COMPLETED. THESE, AND
PUBLICATIONS ISSUED PRIOR TO 1979, ARE IDENTIFIED IN THE PREAMBLES TO EACH PROMULGATED
REGULATION.
B-2
-------
INDUSTRIAL TECHNOLOGY DIVISION
PROPOSED AND FINAL RULES - PRIMARY CATEGORIES
FEDERAL REGISTER CITATIONS
(1979 - Present)
9/16/85
-continued-
Industry 40 CFR PART TYPE RULE SIGNATURE*
• ELECTROPLATING 413 PROPOSED 01/24/78
[Pretreatment - PSES only] PROMULGATION 08/09/79
Correction
Correction
Prop. Amend.
Prop. Amend.
Prop. Amend.
Prop. Amend.
Prop. Amend.
Final Amend.
Correction
Final Amend.
Notice
(Approval )
0 FOUNDRIES (Metal Molding and Casting) 464 PROPOSED 10/29/82
Notice
(Add. Data)
Notice
(Add. Data)
Notice
(Comment Period)
PROMULGATION (09/85)**
0 INORGANIC CHEMICALS
Phase I 415 PROPOSED 07/10/80
PROMULGATION 06/16/82
Correction
Phase II 415 PROPOSED 09/30/83
PROMULGATION 07/26/84
Correction
0 IRON a STEEL MANUFACTURING 420 PROPOSED 12/24/80
PROMULGATION 05/18/82
Correction
Correction
Final Amend.
Correction
Prop. Amend.
Correction
Final Amend.
Correction
Correction
0 LEATHER TANNING a FINISHING 425 PROPOSED 06/13/79
PROMULGATION 11/07/82
Correction/
Notice
(Add. Data)
Final Amend.
Final Ammed.
Correction
Correction
Correction/
Final. Amend.
(PSES)
Notice
(Add. Data)
Notice
(Waiver. Reg. II)
Notice
(Waiver, Reg. II)
FEDERAL REGISTER CITATION
43 FR 6560
44 FR 52590
44 FR 56330
45 FR 19245
45 FR 45322
46 FR 9462
46 FR 43972
47 FR 38462
48 FR 2774
48 FR 32462
48 FR 43680
48 FR 41409
49 FR 34823
47 FR 51512
49 FR 10280
50 FR 6572
50 FR 11187
—
45 FR 49450
47 FR 28260
47 FR 55226
48 FR 49408
49 FR 33402
49 FR 37594
46 FR 1858
47 FR 23258
47 FR 24554
47 FR 41738
48 FR 51773
48 FR 46944
48 FR 51647
49 FR 21024
49 FR 24726
49 FR 25634
44 FR 38746
47 FR 52848
48 FR 30115
48 FR 31404
48 FR 32346
48 FR 35649
48 FR 41409
49 FR 17090
49 FR 42794
49 FR 44143
02/14/78
09/07/79
10/01/79
03/25/80
07/03/80
01/28/81
09/02/81
08/31/82
01/21/83
07/15/83
09/26/83
09/15/83
09/04/84
11/15/82
03/20/84
02/15/85
03/20/85
—
07/24/80
06/29/82
12/08/82
10/25/83
08/22/84
09/25/84
01/07/81
05/27/82
06/07/82
09/22/82
11/14/83
10/14/83
11/10/83
05/17/84
06/15/84
06/22/84
07/02/79
11/23/82
06/30/83
07/08/83
07/15/83
08/05/83
09/15/83
04/23/84
10/24/84
11/02/84
* Administrator's signature; ( ) 1s the projected schedule approved by the court.
** Schedule pending approval by the court.
B-3
-------
INDUSTRIAL TECHNOLOGY DIVISION
PROPOSED AND FINAL RULES - PRIMARY CATEGORIES
FEDERAL REGISTER CITATIONS
(1979 - Present)
9/16/85
- continued -
Industry 40 CFR PART TYPE RULE
8 METAL FINISHING 433
a 413
0 NONFERROUS METALS
Phase I 421
Phase II 421
0 NONFERROUS METALS FORMING 471
0 OIL a GAS (OFFSHORE)
0 ORE MINING 440
0 ORGANIC CHEMICALS AND PLASTICS a 414
SYNTHETIC FIBERS a 416
0 PESTICIDES 455
PROPOSED
PROMULGATION
Final Amend.
Correction
PROPOSED
PROMULGATION
Correction
Correction
Correction
PROPOSED
PROMULGATION
PROPOSED
PROMULGATION
PROPOSED
PROMULGATION
PROPOSED
PROMULGATION
PROPOSED
Notice
(Records)
Notice
(Records)
Notice
(Add. Data)
PROMULGATION
PROPOSED
Proposed
(Analytical
Methods)
Notice
(Add. Data)
Notice
SIGNATURE*
08/11/82
07/05/83
-.
—
01/31/83
02/23/84
..
—
—
05/15/84
08/27/85
02/03/84
07/19/85
08/02/85
(1986)
05/25/82
11/05/82
02/28/83
—
—
--
(03/86)
11/05/82
—
—
—
FEDERAL REGISTER CITATION
47 FR 38462
48 FR 32462
48 FR 41409
48 FR 43680
48 FR 7032
49 FR 8742
49 FR 26738
49 FR 29792
50 FR 12252
49 FR 26352
50 FR ~
49 FR 81 1 2
50 FR 34242
50 FR 34592
47 FR 25682
47 FR 54598
48 FR 11828
49 FR 34295
50 FR 20290
50 FR 29068
---
47 FR 53994
48 FR 6250
49 FR 24492
49 FR 30752
08/31/82
07/15/83
09/15/83
09/26/83
02/17/83
03/08/84
06/29/84
07/24/84
03/28/85
06/27/84
09/— /85
03/05/84
08/23/85
08/26/85
06/14/82
12/03/82
03/21/83
08/29/84
05/15/85
07/17/85
--_
11/30/82
02/10/83
06/13/84
08/01/84
(Comment Period)
Notice
(Add Data)
Notice
(Records)
PROMULGATION
__
__
09/11/85
50 FR 3366
50 FR 20290
50 FR —
01/24/85
05/15/85
10/--/85
* Administrator's signature; ( ) 1s the projected schedule approved by the court.
B-4
-------
INDUSTRIAL TECHNOLOGY DIVISION
PROPOSED AND FINAL RULES - PRIMARY CATEGORIES
FEDERAL REGISTER CITATIONS
(1979 - Present)
9/16/85
- continued -
Industry
PETROLEUM REFINING..
40 CFR PART TYPE RULE
419 PROPOSED
PROMULGATION
Prop. Amend.
Final Amend.
Correction
SIGNATURE*
11/27/79
09/30/82
FEDERAL REGISTER CITATION
44 FR 75926
47 FR 46434
49 FR 34152
50 FR 28516
50 FR 32414
12/21/79
10/18/82
08/28/84
07/12/85
08/12/85
PHARMACEUTICALS.
439
PROPOSED
PROMULGATION
Correction
Notice
(Approval)
Notice
(Approval)
11/07/82
09/30/83
47 FR 53584
48 FR 49808
48 FR 50322
50 FR 4513
11/26/82
10/27/83
11/01/83
01/31/85
50 FR 18486 05/01/85
PROPOSED -
NSPS
Correction
BCT Cost
Extension
Notice
(Add. Data)
Notice
(Add. Data -
Toxic Volatlles)
48 FR 49832
49 FR 1190
49 FR 8967
49 FR 17978
49 FR 27145
10/27/83
01/10/84
03/09/84
04/26/84
07/02/84
50 FR 36638 09/09/85
0 PLASTICS MOLDING a FORMING
463
PROPOSED
PROMULGATION
Correction
02/03/84
12/04/84
49 FR 5862
49 FR 49026
50 FR 18248
02/15/84
12/17/84
04/30/85
0 PORCELAIN ENAMELING.
466
PROPOSED
PROMULGATION
Final Amend.
Final Amend.
Prop. Amend.
Final Amend.
01/19/81
11/05/82
46 FR 8860
47 FR 53172
48 FR 31403
48 FR 41409
49 FR 18226
50 FR 36540
01/27/81
11/24/82
07/08/83
09/15/83
04/27/84
09/06/85
* Administrator's signature; ( ) 1s the projected schedule approved by the court.
B-5
-------
INDUSTRIAL TECHNOLOGY DIVISION
PROPOSED AND FINAL RULES - PRIMARY CATEGORIES
FEDERAL REGISTER CITATIONS
(1979 - Present)
Industry
• PULP a PAPER.
TYPE RULE
430 PROPOSED
a 431 PROMULGATION
Notice
(Add. Data)
Correction
Final Amend.
Notice
(FDF)
Correction
Public Hearing
(NPDES Decision)
Notice
(Petition Denied)
Notice
(Variance Denied)
PROPOSED (PCB)
Notice
(Comment Period)
PROPOSED
(BOO5 - Acetate)
Notice
(Add. Data)
12/11/80
10/29/82
46 FR 1430
47 FR 52006
48 FR 11451
48 FR 13176
48 FR 31414
48 FR 43682
48 FR 45105
48 FR 45841
49 FR 40546
49 FR 40549
47 FR 52066
48 FR 2804
45 FR 15952
50 FR 36444
9/16/85
contlnued
01/06/81
11/18/82
03/18/83
03/30/83
07/08/83
09/16/83
10/06/83
10/07/83
10/16/84
10/16/84
11/18/82
01/21/83
03/12/80
09/06/85
STEAM-ELECTRIC.
423
PROPOSED
PROMULGATION
Final Amend.
10/03/80
11/07/82
45 FR 68328
47 FR 52290
48 FR 31404
10/14/80
11/19/82
07/08/83
0 TEXTILE MILLS.
410
PROPOSED
PROMULGATION
Notice
(Add. Data)
Correction
10/16/79
08/27/82
44 FR 62204
47 FR 38810
48 FR 1722
10/29/79
09/02/82
01/14/83
48 FR 39624 09/01/83
8 TIMBER.
429
PROPOSED
PROMULGATION
Final Amend.
10/16/79
01/07/81
44 FR 62810
46 FR 8260
46 FR 57287
10/31/79
01/26/81
11/23/81
Administrator's signature; ( ) Is the projected schedule approved by the Court.
B-6
-------
APPEND IX C
FLOW MEASUREMENT REFERENCES
-------
American Petroleum Institute. 1969. Manual on Disposal of Refinery Wastes,
Chapter 4.
Associated Water and Air Resources Engineers, INc. 1973. Handbook for
Industrial Wastewater Monitoring, U.S. EPA, Technology Transfer.
Blasso L. 1975. "Flow Measurement Under Any Conditions," Instruments ano
Control Systems, 48, 2, page 45-50.
Biasso, M.G. 1975. "Discharge Measurement Sturctures. Working Group on
Small Hydraulic Structurers International Institute for Land Reclamation
and Improvement, Wageningen, The Netherlands.
ISCO. Open Channel Flow Measurement Handbook. Lincoln, NB
Mauis, F.T. 1949. "How to Calculate Flow Over Submerged Thin-Plate Weirs."
Eng. News-Record, p 65.
Robinson, A.R. 1965. Simplified Flow Corrections for Parshall Flumes Under
Submerged Conditions. Civil Engineering, ASCE.
Shelley, P.E. and G.A. Kirkpatrick. 1975. Sewer Flow Measurement; A State
of the Art Assessment. U.S. EPA, EPA-600/2-75-027.
Simon, A. 1976. Practical Hydraulics, John Wiley 4 Sons, Inc., New YorK.
Smoot, G.F. 1974. A Review of Velocity-Measuring Devices. USDI, U.S.G.S.
OPen File Report, Reston, Virginia.
Stevens. Water Resources Data Book. Beaverton, OR.
Thorsen, T. and R. Oden. 1975. "How to Measure Industrial Wastewater Flow,"
Chemical Engineering, 62, 4, page 95-100.
USDI, Bureau of Reclamation. 1967. Water Measurement Manual, 2nd Ed.
U.S. EPA, Office of Water Enforcement. 1984. NPDES CompIiance Inspect ion
Manua I.
C-1
-------
APPENDIX D
COPPER FORMING CATEGORICAL PRETREATMtNT STANDARDS
SU8PARTS UTLIZIED IN EXAMPLE
-------
APPENDIX D
A. COPPER FORMING PRETREAIMENT STANDARDS
40 CFR Part 468
Subpart C - PSES for Drawing Spent Lubricant
Maximum for Any Maximum For Monthly
1 Day Average
mg/off-kg (Ibs/teillion off-lbs)
of copper or copper alloy drawn
Chromium 0.037 0.015
Copper 0.161 0.085
Lead 0.012 0.011
Nickel 0.163 0.107
Zinc 0.124 0.051
TTO 0.055 0.028
Oil and Grease* 1.700 1.020
*For alternate monitoring
Subpart F - PSES for Annealing With Water
Maximum for Any Maximum For Monthly
1 Day Average
mg/off-kg (Ibs/toillion off-lbs)
of copper or copper alloy annealed
with water
Chromium 0.545 0.223
Copper 2.356 1.240
Lead 0.186 0.161
Nickel 2.380 1.574
Zinc 1.810 0.758
TTO 0.806 0.421
Oil and Grease* 24.800 14.880
*For Alternate Monitoring
D-l
-------
APPENDIX D (CONT'D)
Subpart H - PSES for Alkaline Cleaning Rinse
Chromi urn
Copper
Lead
Nickel
Zinc
TTO
Oi 1 and Grease*
Maximum for Any
1 Day
mg/of f-kg
of copper
c leaned
1.854
8.006
0.632
8.090
6.152
2.739
84.280
Maximum For, Monthly
Average
(Ibs/mi I 1 ion off-lbs)
or copper alloy alkaline
0.758
4.214
0.547
5.351
2.570
1.432
50.588
*For Alternate Monitoring
Subpart J - PSES
Chromium
Copper
Lead
Nickel
Zinc
TTO
Oi 1 and Grease*
for Alkaline Cleaning
Maximum for Any
1 Day
mg/of f-kg
of copper
c leaned
0.020
0.086
0.0070
0.089
0.068
0.030
0.93
Bath
Maximum For Monthly
Average
(Ibs/mi 1 lion off-lbs)
or copper alloy alkaline
0.0084
0.046
0.0060
0.059
0*.028
0.015
0.56
*For Alternate Monitoring
D-2
-------
APPENDIX E
PORTION OF
NPDES PERMIT APPLICATION
REQUESTING PRODUCTION AND FLOW INFORMATION
-------
onnt or type m the unshaded areas oniv.
EPA i.O. NUMe)ER(Copv -rim Hem 1 of Form li
form Approved.
OMB No 2000-0055
Approval «wes 12 -3 US
^EPA
APPLICATION FOR PERMIT TO DISCHARGE WASTEWATER
EXISTING MANUFACTURING, COMMERCIAL, MINING AND SILVICULTURAL OPERATIONS
Consolidtud Permits Program
II. PLOWS. SOURCES OF POLLUTION. AND TREATMENT TECHNOLOGIES^^}
A. Attach a line drawing showing the water flow through the facility. Indicate sources of intake water, operations contributing wactewater to the effluent
and treatment units labeled to correspond to the more detailed descriptions in Item a. Construct a water balance on the line drawing by showing average
flows between intakes, operations, treatment units, and outfalls. If a water balance cannot be determined (».g.. for etrttin mining tetivitntl, provide 3
pictorial deecription of the nature and amount of any sources of water and any collection or treatment ineamiis
cooling water, and storm water runoff; (2) The average flow contributed by each operation; and (3) The treatment received by the wane water. Continue
on additional sheets if necessary.
LOOT-
FAULNO
(lull
tSWMCIJ
Z. OPERATION)*) CONTRIBUTING FLOW
>. OPERATION Hill)
L. US* ONLY (tfflutnt fUtllnt* w*-e«iefoHe»
b. AVERAGE FUOW
tincludt unittf
I. TR«ATM«NT
1. DKSCRIPTION
b. UIST CODES FROM
TABCE 2C 1
EPA Form 3S1O-2C (Rav. 2-88)
PAGE 1 OF 4
CONTINUE On neVcnse
E-l
-------
CONTINUED FROM THE FRONT
C. Eaoapt for itorm runoff. Ma, or apiMa, ara My of tha diacharoai aMcrtbad in Itama II-A or 8 intermittent or ininnal?
Q v«a fcompltM MM ftiHoufcn «aWr> H MO 'f o to Section ///)
t. OUTFALL
NUMBER
«ur;
2. OFCftATtONi'j/
CONTRIBUTING FLOW
(litt)
M. P1IOOUCT1ON j^^^^^^H
mmm
3. FREQUENCY | 4. FLOW
1. OAV»
P«W WCEK
Hptcify
autratf)
.••
6. MONTHm
PER VCAM
dpteify
avtrogtt
mm
>. FUOW MATC
(in mutl
••
mom
tx TOTAL VOLUMC
(tpttify with unittl
mm
mm
c OUP».
ATION
••
A. Does an tfflutnt guidciint limitation promulgitid by €ffi. under Section 304 of th« Cle»n W>tir Act apply to your facility?
~ v«« (eomptttt Il*m Ill-t) ^ NO (to to Section /V)
B. Af» tfw limitation* in ttw applicable «ff luant guidMirw txprcnad in term* of production lor otfMr Tiaaann of ofttnttonll
C3 VB* feompi<»« /wnt I// CJ 31 N0 '»° 'o S««"on 'V;
C. If you antv«nw«d "y««" to lt»m 111-8. list th* quantity which r*pr**«nts an ac
uMd in MM appticatol* •ffluMit gukMina. and indicata tha affaetad outfa*
t
laval of production, axpraatad in tha tarma and unita
1 . AVERAGE DAILY PRODUCTION
C • PUCOUCT H T«
Itptcify)
. KTC.
t. AFF*CTCD
OUTFALLS
(lift out fait numbcm
E-2
' U. S. GOVERNMENT PRINTINC OFFICE : 1935 486-527/32962
-------
xvEPA
EN-336
United States
Environmental Protection
Agency
Washington, DC 20460
Official Business
Penalty for Private Use
S300
------- |