Environmental Pollution Control Alternatives Centralized Waste Treatment Alternatives For The Electroplating Industry

Technology Transfer EPA 625/5-81-01 7
Environmental Pollution
Control Alternatives:

Centralized Waste Treatment
Alternatives for the
Electroplating Industry
June 1981
U.S. Environmental Protection Agency
Region V, Library
230 South Dearborn Street
Chi-~
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This alternatives report was prepared for the Industrial Environmental
Research Laboratory's Nonferrous Metals and Minerals Branch in Cincinnati
OH. The Centec Corporation, Reston VA, prepared the report. The EPA
Project Officer is Alfred B. Craig, Jr.

EPA thanks the following companies and organizations for providing
information and assistance: American Electroplaters' Society, Inc.; JRB
Associates, Inc., McLean VA; and Lang Jewelry Company, Providence Rl.

The contact for further information is:
Nonferrous Metals and Minerals Branch
Industrial Environmental Research Laboratory
U.S. Environmental Protection Agency
Cincinnati OH 45268
This report has been reviewed by the Industrial Environmental Research
Laboratory, U.S. Environmental Protection Agency, Cincinnati OH, and
approved for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the U.S. Environmental
Protection Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use.
COVER PHOTOGRAPH: Centralized waste treatment facility in Iserlohn,
Germany.
U.S. Environmental Protection Agency
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Contents 1 • Overview 1

2. The Need for Compliance Alternatives 2
Regulatory Incentive 2
Centralized Treatment Alternative 4

3. Germany's Centralized Treatment Facilities 7

4. Alternatives for Individual Plating Shops 10

5. Regional Treatment Alternative 13
Selection of Case Study Regions 13
Cleveland 15
Milwaukee 17
Philadelphia 18
Atlanta 21
Seattle 23
Case Study Conclusions 24

6. Group Treatment Alternative 25
Impact of Regulations 25
Group Treatment Analysis 25
Summary -, 29

7. Management and Financing 30
Management and Ownership 31
Financing 31
Considerations for Group Treatment 32
Determining Factors 33
Development Strategies 34

References 36
III
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Illustrations Figures
1. Effect of Centralized Waste Treatment Systems on Capital Cost Per
Plant 5
2. Centralized Treatment Facilities Handling Hydroxide Sludges in
the Catchment of the Ruhr River 7
3. Iserlohn Plant Process 8
4. Centralized Waste Treatment Alternatives for Small Facilities .... 11
5. Centralized Waste Treatment Alternatives for Medium-Sized Fa-
cilities: (a) Without In-Plant Ion Exchange and (b) With In-Plant Ion
Exchange 12
6. Waste Treatment Alternatives: (a) Alternative 1, All Waste to CWT
Facility; (b) Alternative 2, Chromium Waste and All Sludge to CWT
Facility; (c) Alternative 3, Cyanide Waste and All Sludge to CWT
Facility; (d) Alternative 4, Sludge Only to CWT Facility; (e) Alterna-
tive 5, Nothing to CWT Facility; and (f) Alternative 6, Alkali and
Acidic Regenerant to CWT Facility 14
7. Conventional Wastewater Treatment Technology 15
8. Location of Metal Finishing Shops in the Cleveland Area 16
9. Location of Metal Finishing Shops in the Milwaukee Area 19
10. Location of Metal Finishing Shops in the Philadelphia Area. ... 20
11. Location of Metal Finishing Shops in the Atlanta Area 21
12. Location of Metal Finishing Shops in the Seattle Area 22
13. Regional Savings Versus Product of Mean Distance to CWT Facil-
ity and Percentage of Shops Discharging More Than 50,000
gal/d 24
14. Group Treatment Savings Versus: (a) Financing Costs and (b)
Transportation Costs 27

Tables

1. Pretreatment Standards for Existing Sources: Concentration-
Based Standards 3
2. Summary Characteristics of Electroplating Industry Sectors: Indi-
rect Dischargers 3
3. Initial Investment Necessary for Compliance 4
4. Case Study Regions 13
5. In-Plant Processes for Four Waste Streams Under Five Alter-
natives 15
6. Distribution of Water Use Flow Rates by Region 16
7. Annual Costs Summary for the Five Case Study Regions 17
8. Most Economical Waste Treatment Schemes for the Five Case
Study Regions 18
9. Processing Capacities and Costs of Centralized Treatment Facility
Components 18
10. Total Annual Costs of Compliance: Five Regions 23
11. Huntington Industrial Park: Values of Group Treatment Analysis
Parameters 26
12. Regional Summary: Huntington Industrial Park Annual Costs ... 26
13. Processing Capacities and Costs of Group Treatment Facility
Components 28
14. Alternative Chosen by Each Plant and Flows to Each Process at
the GTF 28
15. Investment Required With and Without Group Treatment 29
16. Group Treatment Facility Capital Cost Breakdown 29
17. Financing Alternatives for Centralized Treatment Facilities by
Type of Ownership 31
IV
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1. Overview
The U.S. Environmental Protection
Agency (EPA) has conducted studies
to help the electroplating industry
identify methods of complying with
wastewater pretreatment regula-
tions. This report is a compilation
of the results of recent EPA studies.1
The alternatives described are
categorized by the term "centralized
treatment," which refers to treating
the wastes of many industrial
generators at centralized facilities.
Centralized treatment results
in considerable savings, which are
reflected in reduced costs of
compliance for individual platers.
The findings show that centralized
treatment can be a major economic
benefit to the electroplating
industry as a whole, as well as to
the majority of individual shops.

Centralized treatment schemes may
assume various forms. One alter-
native is regional centralized treat-
ment, in which all platers capable of
economically shipping their
wastes use a facility designed
to serve their region. Another
alternative, group treatment,
involves a facility owned and
operated by a relatively small number
of platers in close proximity. In the
"plating city" centralized treatment
concept, several platers may move
into new facilities incorporating
equipment for joint treatment of
wastewater. Various methods are
available to individual plating shops
for interacting with a centralized
treatment facility. Each method and
its cost benefits are described.
Management and financing alter-
natives also are presented.

A major investigation of centralized
treatment in the United States
was based on case studies of
projected operation of systems in
five municipal regions. The following
regions were chosen as repre-
sentative of a wide variety of U.S.
industrial and demographic factors:
Cleveland, Milwaukee, Philadelphia,
Atlanta, and Seattle. Such charac-
teristics as population, number of
platers, platers per square mile,
and population per plater were
identified for each case study region.
The characteristic data will enable
planners to compare their situations
with one or more of the case
studies presented.

The case studies used actual plant
effluent data within each region
to project savings based on the
existence of a centralized treat-
ment facility. Savings available
within a region depend on the
volumes of wastewater and the
distances it must be shipped from
the shops to the centralized
facility. A close correlation between
these factors was found for the five
case study regions explored.

Groups of platers contemplating
joint ownership and operation
of a treatment facility should
benefit from the case study of
Huntington Industrial Park in
Providence, Rhode Island. Section 6
presents that study and illustrates
the considerable economic benefits
to be derived from consolidating
treatment capacity within an indus-
trial park.

Centralized treatment, in one or
more of its forms, can provide a
feasible alternative to expensive
on-site treatment for a wide
variety of plating shops. This report
is designed for use by regional
planners, industrial associations.
treatment facility operators (present
or potential), and platers in
developing economical compliance
strategies.
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2. The Need for
Compliance Alternatives
Regulatory Incentive

The Clean Water Act amendments of
1977 (Public Law 95-217) directed
EPA to set pretreatment require-
ments for industrial wastewaters
that are found to contain toxic
pollutants in significant amounts.
The requirements were to include
provisions for considering the
amount of pollutants removed by
publicly owned treatment works
(POTW's). Consequently, EPA
issued two sets of regulations that
apply to electroplaters discharging
process wastewater to POTW's:

• General pretreatment regulations
set forth the administrative
requirements for POTW's, States,
and the involved industries.
• Pretreatment standards for
electroplaters set specific
pollutant limitations that electro-
platers must not exceed.

Complying with these regulations by
means of on-site treatment will be
expensive for all industries. New
alternatives are needed that reduce
the cost of environmental
compliance.

General Pretreatment Regulations.
General pretreatment regulations
apply to all industrial pollutants
introduced to a POTW. These
regulations were promulgated on
June 26, 1978, and were modified
and clarified most recently on
January 28, 1981.2 They were
intended to prevent the introduction
to a POTW of pollutants that would
either interfere with its operation
or pass through or otherwise be
incompatible with the treatment
works. Another purpose of the
regulations was to prohibit
discharges that reduce opportuni-
ties to recycle and reclaim
municipal and industrial waste-
waters and sludges. Inhibition or
disruption of a POTW's sewer
system, treatment processes, or
operations constitutes interference
if it contributes to a violation
of any requirement of the POTW's
National Pollutant Discharge
Elimination System permit. Imped-
ing the POTW's use of sewage
sludge for land applications also
constitutes interference.

The general pretreatment regula-
tions outline specific responsibilities
of EPA, States, POTW's, and
industrial dischargers to POTW's.
The regulations also outline sewer
discharge restrictions, removal
credits for pollutants removed by the
POTW, and a framework for
implementing categorical standards.

Specific Pretreatment Standards for
Electroplaters. EPA promulgated
pretreatment standards for electro-
platers in September 1979 and
published revisions in October
1979, March and July 1980, and
January 1981.3 Table 1 gives the
concentration-based limits for
existing electroplating facilities.
More lenient standards were
adopted for plants discharging less
than 10,000 gal/d (38,000 L/d).
Two alternatives are available for
plants that discharge more than
10,000 gal/d (38,000 L/d). Either
set of standards may be adopted on
agreement between the POTW and
the industrial user.

The mass-based limits of the first
alternative relate the allowable
discharge of a pollutant to the quan-
tity of work processed in terms of
surface area and the number of
plating operations performed. A
plating operation is defined as any
step in metal finishing that is fol-
lowed by a rinsing step. An elec-
troplater using this alternative is
eligible for POTW removal credits.
Credit also can be taken for any
significant levels of the regulated
pollutants in the intake water.

The second alternative is designed
to minimize the cost of monitor-
ing the wastewater discharge.
This standard replaces the limits on
the levels of copper, nickel.
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Table 1.

Pretreatment Standards for Existing Sources: Concentration-Based
Standards
Pollutant
Plants discharging <1 0,000 gal/d:
Lead

Plants discharging >1 0,000 gal/d:
Cyanide, total
Copper
Nickel
Chromium
Zinc
Lead

Silver8
All metals

Pretreatment
standard (mg/L)
Daily
maximum
50
06
. . . 1 2
19
45
4.1
70
42
0.6
1 2
1 2
. . . . 105

4-d
average
2.7
0.4
0.7
1.0
2.7
2.6
4.0
2.6
0.4
0.7
0.7
6.8
'Applies only to electroplating of precious metals.

SOURCE: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards; Electro-
plating Point Source Category Pretreatment Standards for Existing Sources," Federal Register
46(18):9462-9473, Jan. 28, 1981.
Table 2.

Summary Characteristics of Electroplating Industry Sectors: Indirect
Dischargers

Electroplating industry sector
Characteristic
Number of plants
Total employment (1 000 persons)
Total production employment (1 000 persons)
Total sales ($1 06/yr)a
Total process water flow (106 gal/d) ...

Job
shops
2,734
62 8
468
. . 1 889
88 3

Printed
circuit board
facilities
327
206
11.9
49.4
6 1

Captive
shops
4722
2 930
87 0
5077
1 163

"1978 dollars.

SOURCE: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards; Electro-
plating Point Source Category: Pretreatment Standards for Existing Sources," Federal Register
44(1 75):52590-52629, Sept. 7, 1979.
chromium, zinc, and total metals
by limits on total suspended solids
and pH. Users of this alternative
must reduce hexavalent chromium
to its trivalent state and must
neutralize the wastewater with lime
[CaO orCa(OH)2]. Plants using strong
chelating agents in processing
are not allowed to use this standard
because control of pH does not
necessarily precipitate heavy metals
in the presence of strong chelates.
The more lenient standards for plants
discharging less than 10,000 gal/d
(38,000 L/d) were adopted to
help reduce electroplaters' compli-
ance costs. Table 2 compares the
characteristics of job shops with
those of the other industry sectors.

Compliance may cause closures
because of the high cost of installing
and operating pretreatment systems.
Table 3 presents an estimate
of the capital costs for the basic
treatment technologies that will
be required to meet the pre-
treatment regulations at various
flow rates. For a 50-gal/min
(190-L/min) waste flow, capital costs
total $112,000 (1978 dollars)
in initial investment. Table 3 shows
that, even at low flow rates, sub-
stantial capital investments will be
required of individual shops.

Hazardous Waste Regulations, In
addition to the pretreatment
regulations issued under the Clean
Water Act amendments, EPA
has published regulations that are
designed to manage and control the
country's hazardous wastes
from generation to final disposal.
These regulations are a result
of legislation in the Resource Con-
servation and Recovery Act (RCRA)
of 1976 (Public Law 94-580.) Con-
gressional concern was prompted
by the large quantities of solid
wastes being generated. Some solid
waste problems result from
meeting requirements of Federal
and State laws, some from processes
themselves, and others from
environmentally unsound practices
used in the disposal or handling
of wastes.

Unlike air and water regulations,
which vary according to the
specific industry to which they
are directed (for example, electro-
plating), the RCRA regulations
apply to all industries that generate,
store, haul, or dispose of hazardous
waste. Some electroplating
facilities will be considered genera-
tors of hazardous waste and may
be considered storage or disposal
facilities.
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Table 3.
Centralized Treatment Alternative
Initial Investment Necessary for Compliance
Treatment process
Investment ($1,000)a by total flow
(gal/min)
20
40
50
60
70

Clarification/floccutation

.... 12
17
22
14
10
22

15
20
23
14
10
22

17
23
24
16
10
22

18
27
25
17
11
22

19
?q
?R
19
1?
??

Total .
97 104
112
120 127
"1978 dollars.

bBased on one-fourth the total wastewater flow.

SOURCE: U.S. Environmental Protection Agency, Environmental Pollution Control Alternatives:
Economics of Wastewater Treatment Alternatives for the Electroplating Industry, EPA 625/5-
79-016, June 1979.
The treatment of electroplating
wastewater, as required by
the national pretreatment standards,
will result in two streams:

• An effluent that must comply with
regulations for acceptable
pollutant discharge
• A residue (sludge) containing a
high concentration of the
substances identified by the pre-
treatment regulations for
removal from the discharge

Because electroplating wastewater
treatment systems commonly
remove many of the metals
regulated, most of these sludges
are considered hazardous. Other
electroplating shop wastes also are
considered hazardous.

EPA estimated recently that 90
percent of the sites accepting
hazardous waste do not comply with
present and proposed regulations
governing hazardous waste
disposal. Upgrading a site to comply
with the regulations will signifi-
cantly increase the cost of operating
the site; this cost increase will
be passed on to the generator of the
waste.

The cost to dispose of waste treat-
ment sludge depends on the sludge
volume, the unit cost to transport the
sludge to a licensed disposal
site, and the fee charged by the dis-
posal site to accept the sludge.
Because the last two factors are
not likely to be under the control
of the sludge generator, reductions
in disposal cost are derived
primarily by reducing the volume of
waste generated.

The cost of sludge disposal in a
particular area depends on the
severity of disposal regulations in
that region. Many States already
have established rigorous control
procedures. In 1978, disposal costs
ranged from $0.10/gal to $0.75/gal
for metal-bearing waste sludge,
with most costs between $0.15/gal
and $0.25/gal. As RCRA regula-
tions are implemented nationally,
inexpensive sludge disposal
will no longer be available. The
economic burden of the increased
charges for sludge disposal,
coupled with the already substantial
burden of compliance with the pre-
treatment regulations, will have a
significant impact on small electro-
plating job shops.
The economic impact of wastewater
and solid waste regulations on
many industrial sectors can be
reduced by identifying and develop-
ing less costly alternatives to
conventional control technologies.
Centralized waste treatment (CWT)
is one such alternative that
shows great promise.

Under the CWT concept, substantial
investment in on-site treatment
facilities would not be necessary
because shops would transport
their wastes in tank trucks to the
treatment location. Wastes can be
accepted at a centralized facility
in various forms. Some plants
may choose to treat liquid wastes on
site and send only sludge to the
CWT facility for dewatering,
recovery, or disposal. Other plants
may choose to send liquid wastes to
the treatment facility. In the
second instance, in-plant waste-
water reduction usually would be
necessary using techniques
such as countercurrent rinsing, ion
exchange, ultrafiltration, or
reverse osmosis. Centralized
treatment allows small plants to
keep investment to a minimum while
obtaining the same desirable
environmental results.

Figure 1 shows the factor by which
costs to an individual plater
could be reduced as a function of
the number of plants (of assumed
identical capacity) subscribing to a
CWT facility. In reality, plants of
different capacities would be sub-
scribing, but Figure 1 illustrates
the magnitude of capital savings.

Although substantial savings in
capital costs occur when as few as 5
to 10 plants participate in a CWT
scheme, even more significant
capital savings are realized with
25 participating plants. The curve
begins to level out beyond 25
subscribers, illustrating the effect of
additional participants on capital
costs. For example, if 20 plants
subscribe to the CWT facility, the
portion of the capital costs to
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LU
5
CC.
I- I-
Z LU
o:5
£d
100
80
DC

LU
u
en
O
10
20 30 40 50 60 70 80

NUMBER OF EQUIVALENT PLANTS SUBSCRIBING TO A CWT FACILITY
100
Note.—CWT = centralized waste treatment.

SOURCE: Minor, Paul S., and Roger J. Batstone, "Applicability of the Federal Republic of Germany's Centralized
Waste Treatment Approach in the United States." In U.S. Environmental Protection Agency and American Electro-
platers' Society, Inc. (cosponsors). Second Conference on Advanced Pollution Control for the Metal Finishing
Industry, EPA 600/8-79-014, NTIS No. PB 297-453, Feb. 1979.
Figure 1.

Effect of Centralized Waste Treatment Systems on Capital Cost Per Plant
be borne by an individual discharger
would be only 20 percent or less
of the plant investment that would be
required if CWT were not available
to treat wastes.

The use of CWT facilities is
becoming common in Japan and
parts of Europe. In Germany, the
first municipal waste treatment
installation devoted entirely to
industrial wastes was built in 1964.
Since that time, the number of
private and public facilities for treat-
ing industrial wastes has increased
to the point where all industrial
wastes can be sent to facilities
specially designed for their treat-
ment or recovery.
With government assistance, elec-
troplaters in Japan have relocated
to parks where they can easily share
waste treatment technology and
facilities. In the past several years, at
least 10 parks for electroplaters
have been planned and constructed
throughout Japan.

In the United States, CWT has been
performed on a small scale,
serving a limited number of indus-
tries through private waste treatment
companies. Because of new, more
stringent wastewater and solid
waste regulations, however, the
need for CWT in the United States is
growing rapidly. Facilities tailored
to the needs of a single industry,
such as electroplating, are the most
efficient means of implementing
CWT, but they are only in the
planning stage in this country.

Opportunities for Resource Recov-
ery. The existence of CWT facil-
ities processing the effluents of the
electroplating industry should
hasten the day when metal recovery
from sludges will be economical.
When operated in conjunction with a
segregated hydroxide retention
facility, a CWT facility will provide an
adequate supply of metal-bearing
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hydroxide sludge to make efficient
recovery possible. Some centralized
facilities that serve a homo-
geneous group of customers (a
substantial number of nickel platers,
for instance) could require segre-
gation of arriving waste streams,
processing them in a way that
produces single-metal hydroxide
sludges.

The technologies to be used in
recovering metals from hydroxide
sludges, mixed or single-metal,
will be similar to existing process
technologies for primary metals.
New technologies will require sub-
stantial investment. Reducing the
recovery cost [per pound (or
kilogram) of metal recovered] to an
economical value will require a
steady supply of substantial quanti-
ties of hydroxide sludge. The CWT
facility, by processing wastewaterto
produce sludge as well as accept-
ing sludges from its customers,
will have the needed quantities of
hydroxide sludge.

Applicability to Other Industries.
The CWT concept is not limited
to any single industry. Certain indus-
trial characteristics favor CWT,
however, and some categories of
industry are best suited to central-
ized treatment. As a rule, the
following six characteristics must
exist for CWT to be an attrac-
tive alternative to on-site treatment:

Environmental regulations
Substantial number of companies
High concentration of companies
Small manufacturing facilities
Small waste volumes
Ability to concentrate wastes

The first point is self-explanatory.
The second characteristic, number of
companies, plays an important role
in determining economies of scale,
as illustrated in Figure 1. The
third item is significant because
a centralized facility site must
be close to potential customers. This
proximity will reduce waste haul-
ing distances and will result in lower
transportation costs.

The fourth factor concerns the sizes
of manufacturing facilities within
a given industry. As a rule, CWT
benefits smaller companies more
than large companies with high
waste volumes because larger com-
panies can achieve economic
operation with their own waste treat-
ment systems. The difference in
the unit treatment costs between on-
site and centralized waste
treatment for large companies
usually is not enough to offset
transportation costs.

The final two characteristics favoring
CWT are small waste volumes and
the ability to concentrate wastes.
Because transportation costs
in a CWT system are a function
of waste volume as well as the dis-
tance to a centralized facility, there
is an economical limit to waste
volume. Important considerations in
the applicability of CWT include
not only current waste volumes
but also the potential for volume
reduction or waste concentration. In
some industries, companies
currently use much more process
water than necessary. These com-
panies could reduce the volume
of waste simply by using less process
water. In addition, new recovery
and recycling technologies are
available to achieve significant
reductions in waste flows.

The centralized facility concept can
be applied in any of several ways,
alone or in combination:

• Companies with similar processes
and pollution problems located
near one another could group
together and construct a CWT
facility.
• A private entity could construct
CWT facilities and could serve
nearby industry.
• A municipal government could
establish and manage its own
local CWT facility.

The appropriate mechanism will
depend on many factors, including
availability of funds, willingness
of local governments to participate,
and number and density of indus-
trial plants.
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3. Germany's
Centralized Treatment
Facilities
In 1964. the administrative agency
responsible for the water resources
of the Ruhr River catchment basin
instituted a program to provide treat-
ment of hazardous industrial
wastes at a facility adjacent to the
municipal waste treatment works in
Iserlohn, Germany. At the same
time, the agency attempted to gain
control of the disposal of all
hazardous industrial wastes gener-
ated in the region, which is one of the
most highly industrialized areas
in the world. The agency urged and
promoted the establishment of a
waste exchange system and an
acceptable disposal mechanism for
handling any industrial waste.

Since 1964, the number of private
and public facilities in the Ruhr
catchment that treat concentrated
industrial wastes has increased
to the point where all major industrial
wastes can be sent to facilities
specially designed for treatment or
resource recovery (Figure 2).4 A
regular waste pickup service is
maintained and is similar to those
used for municipal wastes.

Participating companies themselves
perform minimal pretreatment.
The quantity of rinse water first must
be reduced using one of two
improved rinsing techniques:
• One still rinse after the bath
and two or three countercurrent
rinses
• One still rinse and one flow
rinse in combination with ion
exchange concentration
Legend:
D = CWT facility site

Scale: 1 in = 30 mi
Site
Sludges received at
CWT facilities
(106 gal/yr)
Thin
Dewatered

Neheim-Husten

317
3 17
2 65
15.87
6 88

079
0 53
0 79
053
MA

Note.—CWT = centralized waste treatment. NA = not applicable.

SOURCE: Roesler. Norman, "Organization and Operation of Centralized Plants for the
Treatment of Special Wastes From the Metal Finishing Industry." In Environmental
Protection Service—Fisheries and Environment Canada, Automotive Parts Manufacturers'
Association (Canada), and American Electroplaters' Society (cosponsors). Waste Handling,
Disposal and Recovery in the Metal Finishing Industry, Report No. EPS 3-WP-77-3,
Mar. 1977.
Figure 2.
Centralized Treatment Facilities Handling Hydroxide Sludges in the
Catchment of the Ruhr River
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Acid
waste
storage
Chromium-
containing
wastes
Dilute sludges
from pretreatment
I
Alkaline
wastes
Chromium
reduction
I
Cyanide
oxidation
LJJ
Neutralization
Liquor to recycle
Filter
process
±
Clarification
1
r T
Sludge to landfill
Overflow to municipal plants
Figure 3.

Iserlohn Plant Process
For collecting, storing, and trans-
porting the liquors, containers of
different capacities [15, 50, and
200 gal (60, 190, and 760 L)]
are provided without any additional
payment. With larger quantities,
it has been proven more economical
to build storage tanks in the plant
itself and to transport the liquors in
trucks that hold 1,320, 2,640,
and 5,280 gal (5,000, 10,000, or
20,000 L). This method is used, for
instance, when thin sludges from
on-site treatment facilities have to be
transported once or twice per
month to the CWT facility for
dewatering.

In Heiligenhaus, wastes are trans-
ported from industrial plants to
the central dewatering facility by one
transport company. By agreement
of the members of the cooperative
system, the transport company
charges the same price regardless of
distance. This decision solved the
problem about the location of
the facility and eliminated possible
economic disadvantages in trans-
porting the wastes.

Storage capacity is one of the most
important components of a CWT
plant. Adequate storage capacity
saves on time, on expense for
neutralization chemicals, and there-
fore on operating costs.
8
-------
The Iserlohn plant accepts concen-
trated plating baths as well as
neutralized and detoxified plating
baths and sufficiently concentrated
rinse waters. Figure 3 is a flow
diagram of the Iserlohn plant
process. Acid and alkaline wastes
are transported in color-coded
containers. No distinction in treat-
ment is made for cyanide-free
alkaline wastes; all alkaline
wastes are treated as if they contain
cyanide. Certain pickle liquors
and baths containing nickel and
copper are kept separate because
they occasionally are sold to a
nearby plant that recovers the metals
through electrodeposition. Where
possible, pickle liquors are trans-
ferred to municipal plants for use as
flocculating agents.

The overflow from the clarifiers at
the Iserlohn plant, as at most public
or private CWT facilities, is pumped
to the municipal treatment sys-
tem. The sludge underflow, at about
2 to 3 percent solids by weight,
passes to a filter press where it is
dewatered to about 35 to 45 percent
solids by weight.

One of the keys to the environmental
success of the CWT concept in
Germany was the establishment of a
segregated area for hydroxide
sludges. The Ruhr River district has
established a secure sludge disposal
site for handling hydroxide
sludges from any type of metal work-
ing plant, but the facility is not
limited to metal finishers. Only
dewatered sludges are accepted,
and single-metal sludges are kept
separate for possible future metal
recovery. Any leachate drains to the
bottom of the area and is returned
to the treatment plant by gravity.
Runoff also is collected and is sent to
the CWT plant.
-------
4. Alternatives for
Individual Plating Shops
Centralized treatment of industrial
wastewater enables a wide
spectrum of shops to enjoy the
benefits of economies of scale, but
CWT does not eliminate the need
for in-plant action and investment
by the individual shop. As a minimal
requirement, storage facilities must
be installed for each type of waste
to be shipped. Because transpor-
tation of wastewater is expensive,
nearly all plants will find it economi-
cal to install rinse-concentrating
equipment, such as additional
rinse tanks for still and counter-
current rinsing. Rinses that can go
directly to a POTW without treat-
ment, such as those following some
alkali cleaning baths, should be
segregated from rinses that need
treatment.

In any region that considers sub-
scribing to a CWT facility, the
plants would vary considerably by
size and extent of current treatment.
Larger plants and those operating
at some distance from the CWT
facility probably would choose to
take steps to reduce the volume
of wastewater to be shipped, thereby
reducing transportation costs.
Some German manufacturers have
installed systems for ion exchange
treatment, both for purification and
reuse of rinse water and as a waste-
concentrating measure. If one is not
already in place, installing a treat-
ment system capable of producing
a dilute slurry for shipment to a
CWT facility would prove economical
for some plants.

Even small plants using centralized
treatment would find it economi-
cal to take simple steps to reduce
wastewater flows. The most
common action might be to install
a still rinse tank on each plating
bath. The still rinses—along with
concentrated cleaning, pickling,
bright dip, activator, and other com-
monly dumped baths—would
then be stored for pickup and
transport to the CWT facility.
All plants would benefit from stricter
housekeeping practices and steps
to reduce drag-out. Storage facilities
will be needed at each plant loca-
tion for wastewater or dilute sludges
awaiting transport to the CWT
facility.

One of the striking aspects of
applying centralized treatment to the
mix of shops in any industrial
region is the large number of possi-
ble configurations. A thorough
examination of the economics
necessitates a specific study for the
local situation. Section 5 presents
results of five case studies intended
as a guide in determining whether
centralized treatment is likely
to offer the most favorable
economics.

Figure 4 shows the in-plant changes
required of the plater who finds
it economical to ship all waste-
water requiring treatment to the
CWT facility. The plater must:

• Identify rinses that can
go to the POTW without treat-
ment.
• Provide pH adjustment, if needed,
and segregate the wastewater
resulting from rinses that must be
treated.
• Install rinse reduction measures,
such as still rinse tanks or
countercurrent rinse systems.
• Install storage tanks to hold
the accumulated wastewater for
pickup.

The analyses presented later in this
report assume that each shop will
provide sufficient storage, in the form
of 5,000-gal (19,000-L) tanks, to
hold at least 1 day's wastewater
of each type (chromium, cyanide,
and acid/alkali).
10
-------
Dilute rinses to publicly owned
treatment works after equalization
Cyanide still rinses
Acid/alkali still rinses 1.
[
Concentrated cyanide bath dumps 1
Concentrated acid bath dumps
Cleaning acids and bases ___
To
centralized
treatment
TypicaJ in-plant changes required:
• Install still rinse tanks
• Minimize drag-out
• Store for pickup
Figure 4.
Centralized Waste Treatment Alternatives for Small Facilities
Container storage at Iserlohn centralized waste treatment plant
Storage implies provision for
spill containment, pumps and
valves, truck access, and possibly
lighting and fences. The addition
of still rinse tanks requires air agita-
tion for good mixing as well as
drag-out minimization measures
(for example, proper racking, drip
bar, or drain boards and drip
tanks) to avoid frequent dumping of
the tanks. A means must be provided
for emptying each still rinse tank
into the appropriate storage tank to
await pickup.

Some plants may be unable to
reduce their waste stream flows
sufficiently to make shipment of
raw wastewater to the CWT
facility attractive. Many of these
plants will choose the actions shown
in Figure 5a. In addition to the
cyanide oxidation treatment indi-
cated, chromium reduction will be
required for those shops having a
hexavalent chromium waste
stream. Costs and other information
concerning available packaged
treatment systems of the type
envisioned herein may be found in
the EPA report. Economics of
Wastewater Treatment Alternatives
for the Electroplating Industry*

Simplifying waste treatment through
ion exchange (Figure 5b) has
proven popular in Europe, where
centralized treatment is available.
Under this alternative, all rinses
needing treatment are run together
to a common storage tank, from
which the wastewater passes
through a two-stage ion exchange
unit. The cationic section captures
the heavy metal ions; the anionic
section picks up the cyanides and
chromates. The resulting de-ionized
water is then recycled to the plating
operations.

The existence of some form of CWT
facility will greatly increase the
choices available to platers as
11
-------
(a)
Typical in-plant changes required:
• Install still rinses
• Minimize drag-out
• Install treatment for rinses
Underflow (3% solids
by weight) to
centralized
treatment
Cyanide
still
rinses
Neutralizing agent
Concentrated baths to
centralized treatment
Overflow
to publicly
owned
treatment
works
Pickle liquors and alkaline
to centralized treatment
(b)

Chromium rinses
Cyanide rinses
Acid/alkali rinses
Acid ion exchange backwash
Alkali ion exchange backwash
Concentrated dumps
To rinses
Recycle
water
storage
they plan their compliance strat-
egies. Some shops will need to do
nothing more than provide a storage
tank for concentrated batch dumps
awaiting pickup; others will need
to invest in flow reduction and
treatment equipment. For all plating
shops, the existence of a facility
capable of accepting concen-
trated rinses, contaminated baths,
dilute sludges, ion exchange
regenerant solutions, and the like
increases the available alternatives
and the feasibility of compliance.
Figure 5.
Centralized Waste Treatment Alternatives for Medium-Sized Facilities:
(a) Without In-Plant Ion Exchange and (b) With In-Plant Ion Exchange
12
-------
5. Regional Treatment
Alternative
A regional approach is one way
of implementing the centralized
treatment concept. Under some
circumstances, a CWT facility
can economically serve waste
generators 100 mi (160 km) or more
away. Wastewater may be trucked
in 5,000-gal (19,000-L) loads to the
facility, where the cyanide,
chromium, and general acid/alkali
wastewater may be stored separately
to await treatment. The Ruhr
district in Germany has taken a
regional approach to centralized
treatment.

The economics of the regional
approach may be summarized by
comparing the total capital and
operating expenses for the region
with and without centralized treat-
ment. The comparison assumes that
compliance is achieved entirely by
on-site treatment facilities. The
regional savings result from a favora-
ble trade-off of the transportation
costs and the benefits achieved
through economy of scale.

The results of a number of regional
case studies follow.6'7 The regions
were defined to include all platers
within a 20-mi (30-km) radius
from the center of each industrial
concentration. Five regions were
chosen to represent widely dif-
ferent regional parameters. The aim
was to determine the benefits
of centralized treatment for some
typical situations in the United
States. To determine the feasibility of
CWT in each case study area, data
were gathered from municipal,
regional, and industrial sources,
and an analysis was performed.
Selection of Case Study Regions

Most electroplating shops are
located in large industrial com-
munities in and around municipali-
ties. The municipalities may be
characterized by a variety of
measures that may affect the feasi-
bility of centralized treatment.
The selection of case study regions
was based on:
• Municipal demography
• Number of metal finishing
facilities
• Regional location
The case study regions chosen are
shown in Table 4, along with values
of the factors used to categorize
each region.

Each region has a relatively high
concentration of electroplaters and
displays a variety of values of the
different parameters chosen. The
regions represent a geographical
distribution that includes the
Northeast, South, Midwest, and
West. Populations range from
440,000 in Atlanta to almost 2 mil-
lion in Philadelphia. Geographical
concentration of platers—an
obvious measure of transportation
efficiency—ranges from a high of
3.2 platers per square mile in Cleve-
land to a low of less than 0.5
per square mile in Atlanta. Popula-
tion per plater, a simplified measure
of the economic dependence of an
area on its metal finishing industry,
varies from less than 3,000 in Cleve-
land to over 10,000 in Philadelphia.

The analysis was formulated to con-
sider six waste treatment alterna-
Table 4.

Case Study Regions
Platers
Case study region
Cleveland
Milwaukee
Philadelphia
Atlanta
Seattle
Population
638,793
665,796
1 ,81 6,000
440,300
531.000
Number
244
87
176
58
104
Per square
mile
3.215
0.908
1.354
0.426
1.135
Population
per plater
2,618
7,653
10,318
7,591
4,808
13
-------
(a)
Untreated
Wastes
POTW
(b)
Treated
Wastes
POTW
Untreated •
Wastes • I Dilute"
1
CWT
facility
De watered
(c)
Untreated
Wastes
Treated
Wastes
POTW
(d)
Treated
Wastes
Dilute5
Untreated
Waste
(e)
Treated
Wastes
(f)
POTW
Acidic r * Alkali
f f
CWT
facility
Dewatered
'20% solids by weight.

b4% solids by weight.

Note.—CWT = centralized waste treatment. POTW = publicly owned treatment works.
Legend:

•I •§ Chromium
BB mm Acid/alkali

• •• • Regenerant
Figure 6.

Waste Treatment Alternatives: (a) Alternative 1, All Waste to CWT Facility; (b) Alternative 2, Chromium Waste
and All Sludge to CWT Facility; (c) Alternative 3, Cyanide Waste and All Sludge to CWT Facility; (d) Alternative 4,
Sludge Only to CWT Facility; (e) Alternative 5, Nothing to CWT Facility; and (f) Alternative 6, Alkali and Acidic Regen-
erant to CWT Facility
14
-------

Hexavalent ^1 Reduction 1 |
chromium ^| I I
t
1 Precipita
4
Cyanide m^^- Oxidation •^•^••J

Water to
city sewer
f

Sludge
(1% solids
by weight) i
r
1 Thickening I
Sludge
(4% solids !
by weight) \

1 Mechanical 1
dewatering 1
Sludge I
(20% to 30%
solids by J
weight) *

1 Landfill I

Figure 7.
Conventional Wastewater Treatment Technology
tives (Figure 6) that involve on-site
treatment, off-site treatment at a
CWT facility, or both. Figure 7
is a flow diagram of the typical
treatment system used by the shops
in the analysis. A summary of
in-plant processes that would
be performed by individual com-
panies under each alternative
is shown in Table 5.

Cleveland
Data were collected from various
sources for approximately 140
metal finishing shops in the Cleve-
land metropolitan area. It was
concluded that 103 of these shops
were not currently meeting 1983
pretreatment standards. The current
water use statistics for these 103
shops are summarized in Table 6.
Table 5.

In-Plant Processes for Four Waste Streams Under Five Alternatives
In-plant process for waste stream of

1
2.

Alternative
Chromium
All waste to CWT facility . Storage
Chromium waste and all sludge to
CWT facility Storage

Cyanide

Cyanide oxidation
Physical-chemical treatment
Acid/alkali

Physical-chemical treatment

Dilute
sludge
NA
Storage

3. Cyanide waste and all sludge to CWT
facility
4. Sludge only to CWT facility.

5. Nothing to CWT facility....
Chromium reduction
Physical-chemical treatment
Chromium reduction
Physical-chemical treatment
Chromium reduction
Physical-chemical treatment
Sludge dewatering
Storage
Physical-chemical treatment Storage

Physical-chemical treatment Storage
Cyanide oxidation
Physical-chemical treatment
Cyanide oxidation Physical-chemical treatment
Physical-chemical treatment Sludge dewatering
Sludge dewatering
NA
Note.—CWT = centralized waste treatment. NA = not applicable.
15
-------
Table 6.

Distribution of Water Use Flow Rates by Region
Percentage of shops
i-iow rate per snop igai/d)
0 to 1 0 000 .
10,001 to 25,000 . . .
25,001 to 50,000
50,001 to 100,000
100001 to 500000
500 001 to 1 000 000
>1 000000

Cleveland
36
24
13
9
15
1
2

Milwaukee
26
14
12
17
19
5
7

Philadelphia
28
17
4
26
21
2
2

Atlanta
35
4
18
22
17
4
0

Seattle
33
19
24
9
15
0
0

As shown in Figure 8, most of the
103 shops are clustered in a 50-mi2
(130-km2) area, and approximately
15 shops are located to the north-
east in a second cluster. The
potential CWT site is in the southeast
sector of the larger cluster. The
mean distance between all shops
and the potential site is 7.8 mi
(12.6 km). The nearest potential
customer is located 0.5 mi (0.8 km)
from the centralized facility, and
the farthest company is located
29.9 mi (48.1 km) from the site.
Legend:
• Metal finishing shop
Potential site of
centralized facility
Scale: Each square of the grid is a square mile.
Figure 8.

Location of Metal Finishing Shops in the Cleveland Area
16
-------
Table 7.

Annual Costs" Summary for the Five Case Study Regions
Component
Cleveland
The initial analysis omitted Alterna-
tive 6—in-plant ion exchange—
to allow direct comparison with
the other study regions. Table 7 pre-
sents the annual costs associated
with the most economical waste
treatment scheme determined by the
analysis considering on-site
treatment and CWT. Table 8 shows
the most economical treatment "
, . -.-. Plant:
alternative. The necessary process- Amortized investment 1,926
ing capacities of the CWT facility operation 1,745
components are shown in Table 9. chemicals 528
Transport 0
The results of the Cleveland analysis CWT facility fees °_
show a very high percentage of Regional total 4,199
participation in the CWT system. • —-
Only 1 of the 103 shops has not Milwaukee
chosen to use the centralized facility.
That particular Shop is located 1 9.5 "" Amortized investment 898
mi (31.4 km) from the site and has Operation 710
a waste stream flow of 43,200 gal/d Chemicals 249
(163,500 L/d) after flow reduction. "Lrans?orV'; °
v ' CWT facility fees 0

For the vast majority of the small Regional total 1,857
fless than 10,000 gal/d (38,000
L/d) before flow reduction] and Philadelphia
medium-sized shops [10,000 to p|ant
50,000 gal/d (38,000 to 190,000 "n Amortized investment 1,189
U/d) before flow reduction], the Operation 961
analysis selected Alternative 1, Chemicals 1,020
regardless of distance from the T,ta"s?ort-'': °
a ,. , ... T, .. CWT facility fees 0
centralized facility. The distance,
however, was a factor in the degree Regional total 3,170
of flow reduction used. As a rule, —•
as the distance increased from Atlanta
the CWT facility to the shops, the p|ant.
Shops were more likely to install Amortized investment 404
countercurrent rinses. The average Operation 341
distance to the facility for shops Chemicals 81
that decided to add countercurrent c^ityfees;;;;;;;;;;;;;;;;;;;;;;;;;;;;;;; °
rinses on all single overflow rinses
(with potential for countercurrent Regional total 826
rinsing) was 9.3 mi (15.0 km). The •
average distance for shops that Seattle
decided not to install counter- p|ant.
current rinses for all potential rinses Amortized investment 367
was 3.7 mi (6.0 km). Operation 319
Chemicals 22
Transport 0
Milwaukee cwr facilltv tees o

_ .. , . . Regional total 708
Data were collected for approxi-
mately 60 metal finishing shops in a1980 dollars.
the Milwaukee metropolitan area.
_. , . , . .. , ., Note.—CWT = centralized waste treatment.
The data show that 41 of these
shops were not meeting 1983
pretreatment standards and, thus,
were included in the CWT analysis.
Cost ($1,000)
Without With
CWT facility CWT facility
Saving
345
297
247
1,129
486
2,504
432
323
220
342
120
1,437
661
560
995
478
84
2,778
80
61
51
217
92
501
1,581
1,448
281
-1,129
-486
1,695
466
387
29
-342
-120
420
528
401
25
-478
-84
392
324
280
30
-217
-92
325
156
133
17
154
65
211
186
5
-154
-65
525
183
17
-------
Table 8.

Most Economical Waste Treatment Schemes forthe Five Case Study Regions
Number of shops
Alternative
Cleveland Milwaukee Philadelphia Atlanta Seattle
1.
2.

5.
All waste to CWT facility . . .
Chromium waste and all
sludge to CWT facility . . .
Cyanide waste and all sludge
to CWT facility
Sludge only to CWT facil-
ity
Nothing to CWT facility . . .
86

15
1
23

13
0
22

20
0
19

4
0
11

11
0
Note.—CWT = centralized waste treatment.
Figure 9 shows the locations of the
41 metal finishing shops. Most of
the shops are located in a 4-mi-
(6-km-) wide vertical strip along
the eastern shore of Lake Michigan.
The potential CWT facility site
is approximately at the center of
this strip. The other metal finishing
shops are scattered over a 100-mi2
(260-km2) area. The mean distance
between all shops and the poten-
tial site is 7.8 mi (12.6 km). The
nearest and farthest shops are
located 0.10 and 30.2 mi (0.16 and
48.6 km), respectively, from the
CWT facility site. The distribution
of water use flow rates for the 41
shops is shown in Table 6.

The most economical waste treat-
ment alternative is shown in Table 8.
The annual costs associated with
this configuration are presented
in Table 7.
The Milwaukee analysis revealed
a high percentage of large and
medium-sized shops. Only 40
percent of the shops use 25,000
gal/d (95,000 L/d) or less of water,
and 48 percent use more than
50,000 gal/d (190,000 L/d). In
Cleveland, the percentage was 60
percent for less than 25,000 gal/d
(95,000 L/d) and 27 pecent for
more than 50,000 gal/d (190,000
L/d). The effect is that 32 percent of
the Milwaukee shops selected Alter-
native 4—sludge only to CWT
facility—as the most economical
waste treatment alternative,
whereas only 14 percent made that
choice in the Cleveland area.
Philadelphia

Data were collected for approxi-
mately 90 metal finishing shops in
the Philadelphia metropolitan area.
Fifty-one of these shops were not
meeting 1983 pretreatment stand-
ards and were used in the CWT
analysis.

Figure 10 shows the location of the
51 metal finishing shops. A major
portion of this metal finishing popu-
lation is located in southeastern
Philadelphia, in an area bordered by
the Schuylkill and Delaware Rivers.
The potential CWT facility site is
in the extreme southeast corner of
the city near Philadelphia Inter-
national Airport. The mean distance
between the shops used in the
analysis and the potential site is
10.1 mi (16.3 km). The nearest
potential customer is 2.4 mi (3.9 km)
from the centralized site, and
the farthest company is 26.7 mi
(43.0 km) away. The distribution of
water use rates for the 51 shops
used in the analysis is shown in
Table 6. The most economical waste
treatment scheme is shown in
Table 8, and the annual costs
associated with this configuration
are presented in Table 7.

The results of the Philadelphia
analysis bear a strong resemblance
to the Milwaukee results. Thirty-nine
of the Philadelphia shops selected
Alternative 4. Again, this effect
is primarily a result of having a
relatively high percentage of large
and medium-sized water users [51
percent of shops in Philadelphia
use more than 50,000 gal/d
(19,000 L/d)].
Table 9.

Processing Capacities and Costs3 of Centralized Treatment Facility Components
Process

Storage

Required
capacity
40,700 gal/d
41 ,000 gal/d
1 90,000 gal/d
3,646 lb/db
190,1 00 gal

Annual cost ($)
Amortized
investment
7,200
17,800
36,100
19,000
58,200
Operation
1 5,200
246,700
79,900
6,500
0
Total
22,400
264,500
1 1 6,000
25,500
58,200
Fee
rate ($)
0.001 8/gal
0.0215/gal
0.0020/gal
0.0233/lb
0.001 /gal
"1980 dollars.
bDry solids.
18
-------
Legend:
• Metal finishing shop
Potential site of
centralized facility
Scale: Each square of the grid is a square mile.
Figure 9.

Location of Metal Finishing Shops in_the Milwaukee Area
Philadelphia showed a relatively
high percentage of shops selecting
Alternatives 2 and 3 (18 percent,
compared with 1 percent for Cleve-
land and 12 percent for Milwaukee).
The effect is primarily caused by the
relatively larger mean distance 2 or 3 was 10.0 mi (16.1 km).
between tne shops and the CWT Because of the longer distances, it
facility site. The average distance was cost effective to treat some
between the site and the nine Phila- waste streams (usually acid/alkali)
delphia shops selecting Alternatives on site and to haul other streams
(usually chromium) to the CWT
facility for treatment.
19
-------
Potential site of
centralized facility
Scale: Each square of the grid is a square mile.
Figure 10.

Location of Metal Finishing Shops in the Philadelphia Area
20
-------
Legend:
• Metal finishing shop
Potential site of
centralized facility
Scale: Each square of the grid is a square mile.
Figure 11.

Location of Metal Finishing Shops in the Atlanta Area
Atlanta

Data were collected for 54 metal
finishing shops in the Atlanta
metropolitan area. The available
information indicated that 23 of
these shops were not meeting 1983 20-mi2 (52-km2) area around down-
pretreatment standards; therefore, town Atlanta (Figure 11). The
those shops were considered in the potential CWT facility is 5 mi (8 km)
CWT analysis. southeast of the center of the city.
The mean distance between the
Most of the 23 metal finishing shops
analyzed are well distributed in a
21
-------
Potential site of
centralized facility
Scale'. Each square of the grid is a square mile.
Figure 12.

Location of Metal Finishing Shops in the Seattle Area

22
-------
Table 10.

Total Annual Costs8 of Compliance: Five Regions
Cost ($1,000)
Region
Cleveland .

Philadelphia
Atlanta
Seattle

Without
CWT facility
4,199
1,857
3,170
826
708

With
CWT facility
2,504
1,437
2,778
501
525
Saving
$1,000
1,695
420
392
325
183
% of cost
40.4
22.6
12.4
39.3
25.8
Average
distance to
CWT facility
(mi)
7.8
7.8
10.1
5.6
16.6
Shops with
wastewater flow
>50,000 gal/d
(%)
27
48
51
43
24
•1980 dollars.

Note.—CWT = centralized waste treatment.
shops and the potential site is 5.6
mi (9.0 km). The nearest and farthest
shops are located 2.2 and 11.6 mi
(3.5 and 18.7 km), respectively,
from the potential CWT facility. The
distribution of water use flow rates
is shown in Table 6.

Atlanta's most economical waste
treatment scheme considering
on-site treatment and CWT is
shown in Table 8. The annual costs
associated with this configuration
arg presented in Table 7.

The Atlanta results show a relatively
high level of participation in the
CWT system, which is primarily the
result of the proximity of the shops
to the CWT facility site [mean
distance of 5.6 mi (9.0 km)]. The
four shops selecting Alternative 4 in
the analysis are large shops [that
is, greater than 50,000 gal/d
(190,000 L/d)], most of which are
located 10 mi (16 km) or more from
the site of the CWT facility.

Seattle

Data were collected for approxi-
mately 60 metal finishing shops in
the Seattle metropolitan area.
Twenty-two of these shops were
included in the CWT analysis
because they were not meeting
1983 pretreatment standards.

Figure 12 shows the location of the
22 metal finishing shops analyzed.
Most of the shops are located
between Puget Sound and Lake
Washington; the rest are in the
northern portion of King County and
in the Kent area. The potential
CWT facility site is near the two
southern shops in Kent. The mean
distance between the shops and the
potential site is 16.6 mi (26.7 km).
The nearest and farthest shops are
located 2.1 and 33.2 mi (3.4 and
53.4 km), respectively, from the
centralized treatment facility. The
distribution of water use flow rates is
shown in Table 6.

The most economical waste treat-
ment scheme for the Seattle region
is shown in Table 8. The annual
costs associated with this configura-
tion are presented in Table 7.

For Seattle, the factor having the
greatest effect on cost was the
hauling distance. Although 76 per-
cent of the metal finishing popula-
tion that was analyzed used less than
50,000 gal/d (190,000 L/d) of
water, only half the total number of
shops sent raw waste streams to the
CWT facility. The mean distance to
the treatment facility for the
plants selecting Alternative 4 was
19.5 mi (31.4 km); for the remainder
of the shops, the mean distance
was 12.8 mi (20.6 km).
Trucks unloading at Iserlohn centralized waste treatment facility
23
-------
Case Study Conclusions

Table 10 shows the annual regional
costs of compliance, with and
without the existence of a regional
CWT facility, for each case study
region. The primary determinants of
the feasibility of centralized treat-
ment for a region are apparently
the mean distance of the partici-
pating shops to the CWT facility
and the distribution of wastewater
flows in the region. In fact, the
product of the mean distance and
the percentage of shops with a
wastewater flow greater than 50,000
gal/d (190,000 I7d) shows a very
strong negative correlation with
the regional savings achieved
by CWT as a percentage of the
annual cost of compliance in the
absence of CWT (Figure 13).

The regional approach to central-
ized treatment for electroplating
wastes has been shown to be
of great economic benefit in regions
as diverse as Cleveland and
Atlanta. The greatest success will be
achieved when a region's partici-
pating shops are close to the
planned CWT site and reduce their
flows to levels that make transport
of wastewater feasible. These
conclusions apply to a large number
of participating shops.
70
60
50
40
o
<*
I
o
o
UJ
50,000 gal/d (mi)

Note.—CWT = centralized waste treatment. Data from Table 10.
Figure 13.
Regional Savings Versus Product of Mean Distance to CWT Facility and
Percentage of Shops Discharging More Than 50,000 gal/d
24
-------
6. Group Treatment
Alternative
The preceding section described
regional centralized treatment as one
means of reducing the anticipated
economic impact on electroplaters
of compliance with pending waste-
water and solid waste regulations.
To be cost effective, a relatively large
number of electroplating shops must
participate in regional CWT, but
Figure 1 shows that the major
portion of the economy-of-scale
benefit of CWT could be realized
when as few as 10 shops participate.

Group treatment, as the term is used
here, refers to the joint establish-
ment of a waste treatment facility
by a group of shops in close proxim-
ity and having similar wastes.8
Ownership, management, and
operation usually would involve the
participating companies themselves,
although a number of variants are
possible. The group treatment facility
(GTF) would be primarily for the
benefit of its members, but it could
offer to treat the wastes of other
small shops having similar waste
constituents.
Impact of Regulations

The compliance date of the pre-
treatment standards3 for the electro-
plating point source category is
May 12, 1983. The regulations
identify eight subcategories to
which modified effluent limitations
apply. Of primary concern to the
plants in Huntington Industrial
Park, in Providence, Rhode Island,
are the Common Metals Subcategory
and the Precious Metals Subcate-
gory. The major difference between
these subcategories is the addition
of a limitation on the discharge of
silver in the case of precious metals.
The City of Providence intends to
enforce standards that are identical
to the Federal requirements. The
May 12, 1983, compliance date
means that methods of complying
with the pretreatment regulations
must be considered early. Thus,
EPA's Office of Research and
Development sponsored the
investigation of group treatment
at Huntington Industrial Park as a
case study that might be useful as a
guide for similar industrial groups.

The Providence region is unique with
regard to electroplating concentra-
tion. The proportion of electro-
plating firms to the general
population is higher than in any
other part of the country. The
Providence POTW currently receives
large concentrations of metals
in its influent and calculates that it
discharges as much as $30,000°
worth of silver each week into
Narragansett Bay. The jewelry indus-
try is heavily represented. It has
been estimated that compliance
with pretreatment regulations
may force about 20 percent of firms
in the job shop sector out of
business nationally.9 Thus, a GTF at
Huntington Industrial Park, in
addition to serving its founding
firms, would have the potential to
provide economical waste treatment
to nearby small job shops that
might otherwise be severely affected.
Group Treatment Analysis

The goal of the analysis was to
determine the most economical of
the following four allowed alter-
natives:

• Send all wastewater to the GTF
• Send all cyanide-bearing waste-
water to the GTF; treat other flows
on site and send dilute sludge
to the GTF
• Treat all flows on site; send
dilute sludge to the GTF
• Perform all treatment processes,
including sludge dewatering, at
the individual plant

Treatment processes considered
were conventional cyanide oxida-
tion, physical/chemical treatment
(neutralization, precipitation,
flocculation, clarification, and
thickening), and dewatering by filter
'Personal communication. James F. Lembo,
Providence City Engineer, Rhode Island.
Mar. 20, 1980.
25
-------
press or vacuum filter. Dewatering
to 20 to 30 percent solids content
by weight is considered essential,
whether performed on site or at
the GIF, because future disposal
regulations may not allow dilute
sludges to be placed in landfill
and because sludge volume minimi-
zation reduces transportation
costs.

Plants that decide to ship waste-
water to the GTF must install
sufficient 5,000-gal (19,000-L) tanks
to hold separately 1 day's production
of cyanide and noncyanide waste-
water. If the savings from installing
countercurrent rinsing (where
space permits) are significant,
the plant is charged with the cost of
such investment and installation,
and the appropriate waste stream
flows are reduced accordingly.

The 1980 cost for the conversion of a
single-running rinse to a two-stage
countercurrent rinse is $866.b This
amount is considerably less than
the $3,000 figure used in the
general regional case studies
because of the small size of rinse
tanks used in the jewelry industry.

Transportation to the GTF was
assumed initially to be bv 5.000-gal
(19,000-L) tank trucks. The alterna-
tive of piping all wastes to the
GTF was also considered. The cost
of shipping 5,000 gal (19,000 L) by
truck to the GTF varied from $20
to $40. (A typical charge for waste-
water hauling is $40/h.) The interest
rate on borrowed funds varied
from 6 percent to 18 percent. Each
plant was assumed to require a
20-percent return on investment
before committing capital to
in-house treatment technology.

Electric utility costs, a component
of operating costs, were calculated
by using the $0.07/kWh rate
prevailing in the Providence area.
In addition, operating labor, main-
tenance, and chemical costs are
bUnless otherwise noted, all costs in this
section are in 1980 dollars.
computed for each process. The
capital cost of the GTF is computed
(as it was in the regional analyses)
as the sum of the investment in each
treatment process, multiplied by a
factor of 1.65 to account for ancillary
costs of GTF construction.10 These
costs include site work, excavation,
shelter, laboratory, electrical
installation, controls, and piping.
in addition to such nonconstruction
costs as architectural/engineering
fees, legal fees, and contingency.
Such a factor is not applied to the
cost of treatment processes installed
within an existing plant, because
it is assumed that necessary shelter,
utilities, and the like already exist.
No allowance for the cost of land
acquisition, if any, is included.
Table 11.

Huntington Industrial Park: Values of Group Treatment Analysis Parameters
Parameter
Value
Financial data:
Interest rate 12%
Return on investment 20%
Equipment life 15 yr
Transportation cost $30/5.000 gal
Electric power cost $0.07/kWh
Chemical Engineering manpower cost in-
dex 198.00
Chemical plant cost index 246.90
Chemical wholesale price index 287.20
Group treatment facility characteristics:
Identification:
Region name ...
Number of plants
Operational time
Providence
10
16h/d, 300d/yr
Processes considered Cyanide oxidation, physical-chemical treat-
ment, sludge dewatering, and storage
capacity

Note.—1980 cost basis.
Table 12.

Regional Summary: Huntington Industrial Park Annual Costs8

Cost |$)
Component
Plant:

Without
CWT facility
180,640
1 83 490
29 730

With
CWT facility
31 700
29 150
4,300

Saving
148,940
1 54 340
25430

Total.
393,860
65,150
328,710
Transport0
CWT facility fees.
0
0
124,540
84,430
-124,540
-84,430
Regional total .
393,860
274,120
119,740
"1980 dollars.

blnterest rate = 12%.

cHauling cost = $30/5,000 gal.

Note.—CWT = centralized waste treatment.
26
-------
Table 11 shows the values of the
financial parameters and the GTF
constants used in the analysis. The
calculated annual operating results
for the region, consisting of the
10 participating firms, are sum-
marized in Table 12. The annualized
investment costs shown represent
the amortization of the initial capital
investment at 12 percent over 15 yr.
Table 12 shows that, although
the total waste hauling charges in
the park fora yearcome to $124,540
(this total includes amortized
in-plant storage costs as well), an
overall annual savings of $119,735
is realized when compared with the
costs of treatment without a GTF.

Figure 14 shows the effect of the
financing cost and the transportation
charge on the overall savings
achieved. (It has been assumed that
the same financing cost applies to
the construction of an individual
treatment plant or a GTF.) Figure 14a
shows that the annual savings
increase rapidly as the interest rate
increases. The reason for this
effect is that the greater the cost of
financing, the more significant
the economy-of-scale factor
becomes. Of course, the cost of
servicing the debt increases as
financing charges increase, but the
savings make group treatment even
more attractive as interest rates rise.

Figure 14b shows the same informa-
tion plotted as annual savings
versus transportation charge. As
the cost of hauling every 5,000
gal (19,000 L) of wastewater from
each plant to the GTF doubles
from $20 to $40, the savings
decrease by 12 to 20 percent,
depending on the interest rate. GTF
subscribers, therefore, should be
careful to find the most efficient
hauling means available.

The capacity of each treatment
process at the GTF required to
service the needs of the members
is shown in Table 13. No provision
is made for hexavalent chromium
(a)
180
170
_ 160
se. 150
Z
> 140
(/)
§ 13°
<
z
z
120
110
100
90
$40-'
6 12 18

INTEREST RATE (%)
24
Legend:
(b)
• Transportation charge per 5.000 gal
Interest rate
18%
90
0 15 20 25 30 35 40
TRANSPORTATION COST ($/5,000 gal)

Note.—Facility operates 24 h/d. Cost data in 1 980 dollars.
Figure 14.

Group Treatment Savings Versus: (a) Financing Costs and (b) Transportation
Costs
27
-------
Table 13.

Processing Capacities and Costs3 of Group Treatment Facility Components
Process
Chromium reduction
Cyanide oxidation
Physical-chemical treatment , ,
Sludge dewatering
Storage

Required
capacity
0 gal/d
. . 20 535 gal/d
27 501 gal/d
85 Ib/d"
27 501 gal

Annual cost ($)
Amortized
investment
0
5,752
1 7,974
6,287
6,561
Operation
0
31,828
13.703
2,324
0
Total
0
37,580
31,677
8,611
6,561
Fee
rate ($)
0/gal
0.0080/gal
0.0050/gal
0.4402/lb
0.001 0/gal
*1 980 dollars.
"Dry solids.
treatment because the participating
plants have virtually no chromium in
their wastewater. The total flow to
the GTF is little more than 25,000
gal/d (95,000 L/d), which is sub-
stantially less than the present
wastewater flow of 300,000 gal/d
(1,100,000 L/d) from the 10 plants.
Two reasons for the decreased
flow to the GTF are:

• The model found that it would
be cost effective for all plants to
reduce flow by installing counter-
current and still rinses at rinse
stations, as feasible.
• Based on the analysis, two plants
(with two of the largest flows)
elected not to send all their
raw wastewater to the GTF.

Table 13 also summarizes all
costs associated with operating each
treatment process at the GTF,
including the amortized investment
cost. A fee for the use of each
process is then established (break-
even operation for the GTF is
assumed), so that each participant
is charged according to the volume
of wastes sent to each process.

Table 14 lists the plants by code and
shows the alternatives chosen
and the flows to each GTF process
from each plant. Transportation of
the raw wastewater was so expen-
sive that Plant 1 determined its
most cost-effective solution was to
provide on-site treatment through
the clarification step and to send
the dilute sludge only to the GTF.
Another alternative could be
selected because of segregation of
certain running rinses that do not
require treatment and the accom-
plishment of more flow reduction
than the model assumptions
allowed. Plant 5, with a small
cyanide stream flow but a large acid/
alkali flow, chose to send the
cyanide wastes to the GTF rather
than to treat cyanide on site.
Nevertheless, the large acid/alkali
flow was found to be treated more
economically on site, sending only
the dilute sludge to the GTF. Again,
other waste concentration measures
could change that selection.

Table 15 compares the capital
investment in treatment equipment
required with and without the GTF.
Table 14.

Alternative Chosen by Each Plant and Flows to Each Process at the GTF
Average flows to GTF
Plant number
Alternative chosen
Cyanide . . Sludge
. , . Physical-chemical
oxidation . dewatering
(gal/d) «••»•••« (gal/d) (,b/d)
1

5 . . . .

9 . . . .

Alternative 4 — sludge only to
GTF
Alternative 1 — all waste to
GTF
Alternative 1 — all waste to
GTF
Alternative 1 — all waste to
GTF
Alternative 3 — cyanide waste
and all sludge to GTF
Alternative 1 — all waste to
GTF
Alternative 1 — all waste to
GTF
Alternative 1 — all waste to
GTF
Alternative 1 — all waste to
GTF
Alternative 1 — all waste to
GTF
0

7,797.5

549.5

639.0

646.5

904.2

1,476.8

970.5

1,235.0

6,316.0

9,493.6

1,693.6

818.5

646.5

2,562.0

2,216.1

1,389.1

1,553.3

7,126.7

2.2

21.1

10.2

1.7

8.9

6.8

0.5

4.1

1.6

27.5

Note.—GTF = group treatment facility.
28
-------
The capital cost of the GTF itself is
only 23 percent of the total in-plant
investment required without group
treatment. This percentage corre-
sponds closely to the estimate
shown in Figure 1 for 10 subscribing
plants.11 Table 16 shows the capital
cost breakdown for the GTF. The
total is the amount that would
have to be financed jointly by the
participants. In addition, each
plant would have to bear the costs
of stream segregation, storage
provision, and wastewater flow
reduction (included as part of
transportation costs in Table 12).
The two plants that elected to
install some on-site treatment (under
this set of assumptions) would have
that capital cost in addition.

Summary

The proposed GTF has been shown
to be feasible for Huntington
Industrial Park and to provide con-
siderable cost savings for the
participants when compared with
their costs of complying with the
Table 15.
Investment Required With and Without Group Treatment
Cost or saving

With group treatment:
In-plant investment , . .
Capital cost of group treatment facility

Total cost with group treatment . .

Capital saving

Note.— Cost data in 1980 dollars.
Amount ($)
1 229 864

215,673
287,991

. . 503 664

726,200

Table 16.

Group Treatment Facility Capital
Cost Breakdown
Capital cost
Amount ($)
Cyanide oxidation
Physical-chemical treatment.. .
Sludge dewatermg
Storage
Laboratory or shelter
Total
23,059
72,496
42,772
36,066
113,598

287,991
pretreatment regulations individ-
ually. Although installation of an
industrial sewer system within the
park would more than double the
demands for initial capital, it would
be cost effective in the long run.
The analysis performed has con-
sidered only conventional treatment
processes, and further study is
warranted to investigate the benefits
of recovery technology for copper
and nickel at the GTF.
Note.—Cost data in 1980 dollars.
29
-------
7. Management and
Financing
In spite of demonstrated economic
feasibility, the potential of the
CWT concept will not be fully
realized unless creative and ambi-
tious management plans and
financing packages are prepared.
Private enterprise may undertake
much of this endeavor, but local
industry and local government
will need to become involved as
coordinators, recruiters, and possibly
investors. If electroplaters and other
similar industries hope to see
the development of adequate CWT
capacity to process their particular
aqueous and semisolid wastes,
they probably cannot afford to wait
for adequate capacity to appear in
response to market influences
alone.

Complete reliance on private sector
development of CWT facilities may
produce too little capacity, or too
slow a schedule, to meet more than a
portion of the treatment needs of
electroplaters as they strive to
comply with the current EPA regula-
tions.2 As in all industries, a shortage
in CWT capacity will likely lead
to higher prices and greater
customer selectivity on the part
of the centralized facilities—both of
which would have a detrimental
effect on electroplaters.

Private management and financing
of CWT facilities already exist
and probably will play a significant
role in providing treatment capacity
for electroplaters. Other manage-
ment and financing alternatives,
however, should be considered to
ensure the availability of adequate
facilities designed to serve the
interests of all platers equally
and at low costs.

Management choices focus on such
questions as who will own the
facility, who will make the decisions
about facility operations, and who
will assume the liability or risk
associated with the operation
of a centralized treatment facility.
Methods of financing involve plans
for raising the capital needed to plan,
design, and construct the facility
and to cover operating losses that
are likely to occur during the startup
phase. Whereas these concepts are
fairly simple and straightforward,
the decision process of selecting
specific approaches and the simul-
taneous way in which management
and financing issues must be
addressed complicate the matter
considerably.

It is uncertain whether management
and financing selections are
separate decisions. One cannot
expect, for example, to exercise a
significant degree of management
control over a CWT facility unless
a comparable financing contribution
is made. In addition, the type of
management ownership chosen will
dictate to a large extent the choice
of financing. Table 17 lists the
financing alternatives that are
available for each of the three major
management ownership plans—
private, public, and cooperative.
The table shows that privately owned
CWT facilities have the largest
number of possible financing
choices. Limitations, eligibility
requirements, and various other
restrictions that apply to these
financing alternatives may make the
alternatives available to publicly
owned facilities more attractive.
Most cooperative CWT facilities
probably will be new ventures
that will need to establish a credit
rating. This lack of an adequate
credit record and the joint owner-
ship nature of cooperatives will
reduce the availability of financing
alternatives more for cooperatives
than for the other forms ot manage-
ment ownership.

In addition to these three manage-
ment ownership plans, hybrid or
combination alternatives are possi-
ble. For example, an industrial
cooperative or local government
could make the necessary land
30
-------
Table 17.

Financing Alternatives for Centralized Treatment Facilities by
Type of Ownership
Financing alternative
Ownership
Private single Public Cooperative
Conventional bank loan A
Corporate debentures A
Industrial development bonds A
Pollution control revenue bonds A
Municipal bonds:
General obligation
Revenue
Small Business Administration programs:
Direct loans A
Participation loans A
Guaranteed loans A
Pollution control revenue bond guarantee A
Economic Development Administration programs:
Grants
Loans A
Guarantees A
Farmers Home Administration programs:
Grants
Loans A
Department of Housing and Urban Development Action
Grant Program A
A
A
A
A
A
A
A
TA
TA
TA
A
A
TA
TA
A
A
A

A
Note.—A = available; TA = technically available but may not be practical because of the joint
ownership nature and limited credit record of cooperatives. Blanks indicate that the financing alter-
native is not suitable for the type of ownership.
available to a private CWT firm for a
token lease payment. Such an
arrangement would provide the
industrial cooperative or local
government with some control over
CWT facility operations while
leaving the facility under private
management. The capacity for
creativity and imagination are the
only limits to the types of hybrid
combinations possible. One basic
trade-off, however, applies to
each hybrid combination: increased
management control requires
increased financing participation
and entails the assumption of
increased legal liability.

Management and Ownership

Management and ownership
alternatives fall into three basic cate-
gories: private, public, or cooperative
ownership. Private ownership
would be by firms that specialize in
waste treatment and disposal,
although it is possible that a single
electroplater could build a CWT
facility to handle his and other
platers' wastes. Public ownership
could be by State, county, municipal,
or quasi-governmental economic
development corporation. Finally,
cooperative ownership implies
either a joint venture or a general-
limited partnership of CWT
facility users.

In addition to full private and
full governmental electroplater
cooperative ownership, the follow-
ing two scenarios represent
variants to the basic management
plans:

• Government or electroplater
ownership of the land with an
outside firm owning and
operating the CWT facility
• Government or industry owner-
ship of the land, buildings,
and equipment used in the CWT
facility with an outside firm
managing the facility

The selection process will be
influenced in large part by the follow-
ing factors:

• Level of management control
desired by government and
industry user groups
• Willingness and capability of
government and industry user
groups to participate in financing
• Level of liability for CWT facility
operations that government and
industry user groups are willing
to accept

Management control over the
pricing of services and the user
access to a centralized facility will
be accompanied by the risk asso-
ciated with the potential dangers of
handling and disposing of hazard-
ous materials. If the potential
customers and local government are
concerned that the CWT facility
should service small business and
should provide the treatment
services at a below-market user fee,
then the potential customers and
local government will need to
assume both a role in the financing
package and the associated risk of
participation. If the potential
customers want to transfer all
the risks, financing considerations,
and management problems to a
third party, they also must delegate
management control and pricing
authority.

Financing

The alternatives available to fund
centralized facilities are numerous
and include traditional private-
source bank loans or corporate
bond issues as well as Federal and
State programs designed to assist
businesses. Hybrids and combina-
tions of these financing approaches
can be considered and tailored to
available programs and local needs.
The success of a potential package
will require resourcefulness and
31
-------
creativity in developing financing
plans responsive to individual
situations.

Conventional Loans, Conventional
loans are available from lending
institutions to finance CWT projects,
assuming existing corporate finan-
cial strength is supported by well-
established ties with the financial
community. The current credit
markets dictate loan availability
and credit rate.

Debentures. Private investment
funds raised by issuing debentures
are direct obligations of the issuing
corporation dependent entirely on
its general credit rating, reputation,
and prestige. Debentures normally
are used by large, financially
successful companies as a means of
raising capital through debt
financing. The amount of funds
raised by this method must be large
enough to justify the underwriting.

Small Business Investment Corpora-
tions. The Small Business Invest-
ment Act of 1958 authorized
the creation of Small Business
Investment Corporations (SBIC's)
to provide long-term capital to small
businesses. Approval by the Small
Business Administration (SBA),
which licenses SBIC's, is required if
the SBIC wishes to invest more
than 20 percent or $500,000 in a
single, small business concern.
Although SBIC's alone may be
unable to underwrite a capitaliza-
tion of this type, they may play a
role in developing an overall
financing package.

Industrial Development Bonds. Tax-
exempt industrial development
bonds can be issued by State
or local government for financing
industrial development. Industrial
development bonds issued for pollu-
tion control financing do not have a
dollar limitation; however, using
these bonds to promote industrial
pollution projects with tax-exempt
status requires strict adherence to
State and Internal Revenue Service
regulations. Until recently, few small
firms were able to use this source
of capital because investment
bankers required minimal credit risks
and guaranteed repayment for
financing this debt on nonproductive
pollution control facilities.

Small Business Administration
Guarantees. In 1976, Congress
authorized the SBA to guarantee 100
percent of a small business's
obligation to finance a pollution
control facility. Public Law 94-305
ensures that smallerfirms can obtain
favorable financing rates and terms
similar to those of major corpora-
tions. Such guarantees are to be
used by credit-worthy businesses,
and no credit denial by a bank is
required. Section 8 of the Federal
Water Pollution Control Act and
Public Law 94-305 provide the
following programs to small
businesses:

• SBA Pollution Control Revenue
Bond Guarantees
• SBA Loan Guarantee
• SBA Participation Loan
• SBA Direct Loan
• SBA Section 502 Programs

Bond guarantees are made to small,
credit-worthy companies to
provide low-interest, long-term
financing for pollution control
needs. Firms must have been in
business for at least 5 yr and must
have been profitable for at least
3 of those 5 yr.

Loan guarantees are provided for
businesses that are unable to obtain
conventional bank loans and
would otherwise suffer substantial
economic injury to comply with
Federal treatment regulations.
Reasonable repayment assurances
are required, but these loan
guarantees provide advantageous
interest rates.
The SBA also may participate
in a loan with a bank. Normally,
the SBA's participation limit is 75
percent of the project cost; however,
if a bank exceeds its lending limit,
the SBA share may be raised 15
percent. Direct loans up to $500,000
are available for acquiring pollu-
tion control equipment.

The SBA can assist local develop-
ment companies in creating facilities
for small businesses. Section 502
of the Small Business Investment
Act of 1958 allows for loans for
facilities that small businesses
may lease or purchase.

Economic Development Administra-
tion. The Federal Government
assumes a major role in restoring
economically depressed areas
through the Public Works and
Economic Development Act of 1965.
Eligible programs in specially
designated areas are:

• Direct grants for government-
owned projects
• Supplementary grants to augment
other grants when applicants
are unable to meet local govern-
ment shares
• Loans in severely distressed
areas for financing public
works—65 percent for industrial
and commercial expansion, 90
percent for working capital and
fixed assessed loans

Other Federal Programs. The
Farmers Home Administration and
the Department of Housing and
Urban Development (HUD) may be
further sources of information on
Federal programs subsidizing
projects that are in the public
interest. Municipal bonds and State
programs likewise should be
investigated when considering a
financing approach.

Considerations for Group
Treatment

The group treatment concept
requires that some or all of the
32
-------
companies with wastes to be
treated share in the ownership and
management arrangement. A
group of firms, such as those at
Huntington Industrial Park, has
several alternatives for financing
the proposed facility. Among
these alternatives are conventional
bank loans, industrial revenue
bond financing, and industrial rev-
enue bond financing with special
SBA repayment guarantees.

Conventional bank loan financing of
the GIF is a possibility. The
individual companies involved in the
ownership may each qualify for a
portion of the loan. The loan could
be made either directly to the
firms involved or to a corporation
formed by the firms to own and
operate the facility. In either case,
the bank would look to the assets
and credit-worthiness of the
individual firms.

If applications for a conventional
loan are rejected, it is possible to
qualify for an SBA "economic injury
loan" under the Pollution Control
Loan Program. Rates are at below-
market interest. Roughly one-
quarter of such loans made through
1978 were to electroplaters.12

Perhaps the most attractive finan-
cing for such a GTF venture is
through the issuance of tax-exempt
industrial revenue bonds. Such
bonds are issued by a public
entity. Were such bonds to be
issued to finance the proposed Hunt-
ington Industrial Park GTF, the
likely issuer would be the Rhode
Island Department of Economic
Development.

Until recently, issuance of tax-
exempt industrial revenue bonds was
possible only for large enterprises
in strong financial position because
the investor must rely on the credit
of the firm for repayment. In June
1976, however, the SBA received
authority to guarantee loans to
eligible small businesses for the
acquisition of pollution control
facilities,0 This SBA guarantee
may be for an amount of up to $5
million, the full amount of principal
and interest, and may run for up
to 25 yr. The funds raised by the
public entity (Rhode Island Depart-
ment of Economic Development,
in the case of the example presented
in this report) would be loaned to
the participating firms. The repay-
ment of these funds by the firms
would then be guaranteed by the
SBA. To qualify for the loan guaran-
tee, each firm participating in the
ownership arrangement must meet
the definition of a small business
(for electroplaters, one definition
is a firm with fewer than 250
employees) and must have been in
business for at least 5 yr, at least
3 of them profitable. In addition,
the participating companies must
be financially able to service the
debt. When tax-exempt bond
financing is combined with the SBA
guarantee feature, the resulting
AAA rating provides small busi-
nesses with the most favorable
financing rates possible—rates
previously available only to the
largest concerns.

Preliminary discussions with a
potential underwriter have been
held regarding the financing of a
GTF, such as the one studied at
Huntington Industrial Park. In
practice, the financing package is
compiled by an underwriter, in con-
junction with local bond counsel and
the issuer. Although joint treatment
facilities for electroplaters have
not yet been financed under this
program, similar joint treatment
ventures have been or are being
financed under the program for a
group of cheese processors, a group
of potato cooperatives, and others.

A practical limitation may be that
when more than three or four firms
Further information is available from
the Pollution Control Financing Division of
SBA, Office of Special Guarantees, 1815 North
Lynn Street, Magazine Building, Rosslyn,
Virginia 22209 (703-235-2902).
are involved in the ownership,
the administrative costs of assem-
bling the package may become
excessive. Because fees for bond
counsel, the SBA guarantee,
underwriting costs, and the like
must come out of the loan proceeds,
the advantages of this approach
cannot be realized when the amount
to be financed is less than $100,000.
The $300,000 to $800,000 capital
investment requirement of the
Huntington Industrial Park case
study makes this SBA Pollution Con-
trol Financing Guarantee Program
very attractive. If one to four of the
firms were to propose ownership and
management of the GTF under this
SBA guarantee program, the SBA
would be interested in ensuring
that definite contractual arrange-
ments give a guarantee of future
access and fair charges to those
firms not participating in owner-
ship.

Determining Factors

Private treaters will provide CWT
capacity as the profit potential
develops. The decision of private
enterprise to invest in a CWT
facility depends on the following
three factors, among others:
1. Community commitment to
enforce current and forthcoming
effluent discharge regulations
in a vigorous and timely manner
2. Existence of an affordable
site that is politically and com-
mercially suitable
3. Favorable business environment

Factor 1 is the prerequisite cited
most frequently by potential
CWT facility owners. The firms are
apprehensive about committing
several million dollars toward
the construction of a CWT facility.
They fear that lax local enforcement
will allow potential customers to
continue dumping their wastes into
the sewer system, leaving CWT
firms with little or no market.

Although Factor 2 involves economic
and political issues, economics
33
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Truck unloading dewatered sludge at Iserlohn's disposal site
is usually a more important con-
sideration in CWT development.
CWT firms fear that the cost of
prime urban industrial sites will make
them vulnerable to competition
from other centralized facilities
and remove their cost advantage in
relation to the on-site treatment
alternative.

The third factor concerns local
government and general community
interest in promoting and developing
its industrial base. The most favora-
ble business environment for a CWT
facility would be a municipality
that is expanding its industrial
base.
Development Strategies

To the extent that competition is
fostered between two or more
CWT facilities in an area, the need
for regulation and the apprehen-
sions about the quality of service
and the level of fees should lessen.
Nevertheless, it remains likely
that local government and electro-
platers themselves will have to get
actively involved if they wish to see
their special needs adequately
serviced.
There are several development
strategies for local government
and electroplater cooperative
participation. First, local govern-
ment can serve as a recruiter of
private CWT facility investment to
foster competition. Working through
a local development corporation
or economic development authority,
private ventures can be solicited
and financing assistance can be
provided without direct government
involvement. Many Federal assist-
ance programs such as the HUD
Action Grant and the Economic
Development Administration
loan guarantee program need local
government support. In certain
situations. States can assist in
the financing of private facilities
through the issuance of Pollution
Control Revenue Bonds, which
are tax-exempt bonds issued by
States for the benefit of local
industry.

Second, in addition to the preceding
form of coordination and assist-
ance, local government and the
electroplaters can encourage
development of CWT facilities by
getting involved in site selection
and land purchase/lease arrange-
ments. Selecting the sites of
aqueous waste treatment facilities
has not generated as much public
reaction as the selection of sites
for hazardous waste landfills.
Therefore, only the basic business
considerations should need to be
addressed in the site selection
process. The local government's
planning commission, or economic
development agency, can identify
potential sites to CWT facility
developers. Finally, one of these
government agencies or an
electroplating cooperative could
make a site available to a private
developer at a token lease rate. Such
assistance would greatly reduce the
cost of operating a centralized
facility and would allow for reduced
treatment prices for customers.

The third and final major develop-
ment strategy for local government
and local electroplaters is direct
ownership of the facilities. Unlike
the other development strategies,
direct ownership involves a sub-
stantial financing effort on the
34
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part of either an electroplater service and the direct and hidden responsibility, however, is for the
cooperative or the local government costs of ownership. potential user community to provide
and the assumption of considerably a united effort for the creation
more liability. Direct ownership. Financing and management of a of these facilities. Participation
however, could focus the CWT centralized facility may determine by the industry that requires this
services on the types of services its success or failure. Strong con- treatment capacity will help ensure
and toward the types of firms that sideration should be given to the its succesr.
would benefit most from a central- specific requirements of the user
ized facility. Thus, a trade-off exists community, the financing corn-
between the benefits of this munity, and Federal, State, and
local governments. The major
35
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References
1 Craig, Alfred B., Jr., and George C.
Cushnie. "The Environmental
Protection Agency's Centralized
Waste Treatment Program." In U.S.
Environmental Protection Agency
and American Electroplaters'
Society, Inc. (cosponsors), Third
Conference on Advanced Pollution
Control for the Metal Finishing
Industry. EPA 600/2-81 -028. Feb.
1981.

2U.S. Environmental Protection
Agency. "General Pretreatment
Regulations for Existing and New
Sources." Federal Register
46(18):9439-9460, Jan. 28,
1981.

3U.S. Environmental Protection
Agency. "Effluent Guidelines and
Standards; Electroplating Point
Source Category Pretreatment
Standards for Existing Sources."
Federal Register 46(18):9462-
9473, Jan. 28, 1981.

4Roesler, Norman. "Centralized
Treatment and Disposal of Special
Wastes in the Federal Republic of
Germany." In U.S. Environmental
Protection Agency and American
Electroplaters' Society, Inc.
(cosponsors). Third Conference
on Advanced Pollution Control for
the Metal Finishing Industry.
EPA 600/2-81 -028. Feb. 1981.

5U.S. Environmental Protection
Agency. Environmental Pollution
Control Alternatives: Economics
of Wastewater Treatment Alter-
natives for the Electroplating
Industry. EPA 625/5-79-016.
June 1979.
6Craig, Alfred B., Jr., and George C.
Cushnie. "Centralized and Group
Treatment." Paper read at U.S.
Environmental Protection Agen-
U ° Environment! Protection Agency cy's Seminar on Handling Electro-
'. , ., „ plating Wastes: Financial Means
Region V, UL,,..*/ and Technological Considerations.
230 South Dcaroorn S:reet Fall 1980.
Chicago, Illinois 60604
7U.S. Environmental Protection
Agency. Proceedings: Centralized
Waste Treatment Seminar on
Meeting Metal Finishing Waste-
water Regulations, Cleveland
OH, June 12, 1980. Reston VA,
Centec Corporation and JRB
Associates, Inc., undated.

8Salomon, Erich W., and Edward H.
Comfort. "Group Treatment
Options and Economics." In U.S.
Environmental Protection Agency
and American Electroplaters'
Society, Inc. (cosponsors). Third
Conference on Advanced Pollution
Control for the Metal Finishing
Industry. EPA 600/2-81-028.
Feb. 1981.

9U.S. Environmental Protection
Agency. "Effluent Guidelines and
Standards; Electroplating Point
Source Category: Pretreatment
Standards for Existing Sources."
Federal Register 44(175):52590-
52629, Sept. 7, 1979.

10U.S. Environmental Protection
Agency. Construction Costs for
Municipal Wastewater Treatment
Plants: 1973-1977. EPA 430/9-
77-013. NTIS No. PB 282-436.
Jan. 1978.

11 Minor, Paul S., and Roger J.
Batstone. "Applicability of the
Federal Republic of Germany's
Centralized Waste Treatment
Approach in the United States." In
U.S. Environmental Protection
Agency and American Electro-
platers' Society, Inc. (cosponsors),
Second Conference on Advanced
Pollution Control for the Metal
Finishing Industry. EPA 600/8-79-
014. NTIS No. PB 297-453. Feb.
1979.

12Sacks, Sheldon. "Federal Finan-
cial Assistance for Pollution
Abatement." In U.S. Environmental
Protection Agency and American
Electroplaters' Society, Inc.
(cosponsors). Second Conference
on Advanced Pollution Control for
the Metal Finishing Industry. EPA
600/8-79-014. NTIS No. PB
297-453. Feb. 1979.
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