EPA-905/2-81-003
    GUIDANCE FOR BAT-EQUIVALENT

CONTROL OF SELECTED TOXIC POLLUTANTS
            Prepared by

     JAMES W. PATTERSON, Ph.D.
     PATTERSON ASSOCIATES, INC,
       1540 N. State Parkway
        Chicago, 111. 60610
               for
      ENFORCEMENT DIVISION
          U.S.  E.P.A.
            REGION V
       CHICAGO, ILL. 60604

-------
                          CONTENTS





CHAPTER                                                 PAGE




  I.  INTRODUCTION 	     1




 II.  REVIEW OF BPT-EQUIVALENT  CONTROL 	     4




III.  TREATMENT TECHNOLOGIES  	    12




 IV.  BAT-EQUIVALENT CONTROL  	    25




  V.  REFERENCES 	    32
              UtS. Environmental Protection Agency
                              0.1

-------
                      LIST OF TABLES


TABLE                                               PAGE

  1.  BPT Effluent Limitations Guidelines for
       Arsenic 	    5
      Range of Thirty-Day Average BPT Values,
      mg/1 	    6

      IESAG Standards for BPT-Equivalent Control
      Technology Proposed to the State of Illinois.    9

      Expected Effluent Values for Application
      of Good Technology (30-day Average) 	   10

      Example Proposed and Promulgated BATEA
      Effluent Limitation Guidelines - Thirty-
      Day Average 	   26

      Comparison of Selected BPT and BAT Effluent
      Limitations Guidelines - Thirty-Day Average .   28

      Summary of BAT-Equivalent Treatment Tech-
      nologies and Effluent Pollutant Levels
      Achievable on a Thirty-Day Averaged Basis ...   29
                           111

-------
                               FOREWORD
As mandated by the Clean Water Act of 1977 and the Great Lakes Water
Quality Agreement of 1978, control of toxicants being discharged to
the Great Lakes Basin and elsewhere in Region V is a continuing con-
cern of the U.S. Environmental Protection Agency and the State pollution
control agencies.  This manual is intended to provide guidance to federal
and state NPDES permit and pretreatment staffs in determining appropriate
limitations for the discharge of selected toxic pollutants in the waste-
water from industrial facilities where applicable Effluent Guidelines
regulations are not available.

Funding for this project was provided by the Great Lakes National
Program Office as authorized under Section 104(b) of the Clean Water Act
and as partial fulfillment of Article VI and Annex 12 of the Great Lakes
Water Quality Agreement.
                                     iv

-------
                           I.  INTRODUCTION

     Regulations for the control of point source industrial pol"
lutants are predicated upon the performance achievable by in-plant
control measures and/or end-of-pipe wastewater treatment techno-
logies.  For the fourteen pollutants considered in this report,
       Arsenic                   Copper         Mercury
       Barium                    Cyanide        Nickel
       Cadmium                   Fluoride       Silver
       Chromium-Hexavalent       Iron           Zinc,
       Chromium-Total
end-of-pipe treatment technology performance is usually concen-
tration limited.
     For example, for precipitation/solids removal treatment of a
metallic pollutant, performance in a well designed and properly
operated treatment plant is constrained to that effluent quality
achievable through the conversion  (by precipitation) of the
soluble metallic pollutant to a solid form, and the subsequent
removal of that solid phase.  Neither complete conversion of the
soluble pollutant to a solid, nor total removal of that solid, is
possible with existing wastewater treatment technologies.  Thus,
an end-of-pipe treatment technology-based effluent limitation
must incorporate factors reflecting both the degree of conversion
possible for soluble to solid phase, and the performance of the
solids separation technology.  Where in-plant control measures
are applied, mass discharges of pollutants may be reduced even
below that level achievable by end-of-pipe treatment alone.
     In making the final BPJ/BAT determinations, consideration
should be given to the reduction of wastewater volumes and/or
raw waste loads that could decrease pollutant mass loadings to
the environment.  Such reductions might be achieved by wastewater
recycling systems,   production process modifications, or individual
process waste stream pretreatment schemes.
     Many different categories of industry discharge common
pollutants, and utilize common treatment technologies in the
control of these pollutants.   The best foundation upon which to

-------
develop technology based effluent limitations is the performance
of well designed and properly operated treatment systems.  In
such systems, among different industries, comparable effluent
concentrations are observed for identical pollutants.  The excep-
tion to this situation occurs in instances of improperly designed
or constructed, or inadequately operated systems, or where plant-
unique characteristics of a wastewater interfere with the
performance of the treatment technology.
     In this latter instance, particular effort on in-plant
control, or specialized treatment methods, may be required in
order to achieve effluent quality comparable to other treatment
systems.  Typically, however, technology based effluent limita-
tion values, in the absence of site-specific wastewater char-
acteristics which interfere with treatment, should be uniform
when expressed on a concentration basis  (1).  In fact, experience
has shown, and the removal data confirm, that even when several
of the cited pollutants are present in the same wastewater the
BPT-equivalent and BAT-equivalent final concentrations for each
still can be achieved by using treatment conditions intermediate
between those optimum for each pollutant when treated alone.
Several states, including California, Delaware, and Illinois, have
successfully applied uniform industrial effluent standards for
many years.  These uniform standards have been enforced equally
for all industrial categories within such states.
     The objective of this report is to identify effluent con-
centrations and associated treatment technologies representing
BPT-equivalent and BAT-equivalent end-of-pipe control of the
fourteen pollutants cited above.  The conclusions presented in
this report are based upon the results of several studies on
available wastewater treatment technologies and their associated
levels of full-scale performance.  The first study was initiated
in 1970, in support of the development by the State of Illinois
Pollution Control Board of uniform industrial effluent standards
(2).  The results of that original study were updated in 1973
(3)   and again in 1974 (4).  A new study was undertaken in 1976-77

-------
on behalf of the State of Illinois, to develop a document on
industrial pollution control which reflected the accomplishments
of industry in complying with the Federal Water Pollution Control
Act Amendments of 1972 (PL 92-500), which required that industry
achieve "Best Practicable Control Technology Currently Available,"
or BPT, by 1977  (5).  Concurrent with that effort, proposed and
promulgated BPT mass-discharge guidelines were reviewed, and
converted to concentrations to provide a common basis for com-
parison (6).  A review of the results of this program was pub-
lished in the professional literature in July, 1977, the date for
BPT compliance set by PL 92-500  (1).  Finally, during 1980-81,
these studies have again been updated and a text is in preparation
which reflects the full range of technical options and performance
capabilities for over twenty industrial pollutants, including
those considered in this report  (7).  Thus, while this report,
by intent, is concise, the literature base underlying it is
extensive and represents almost continuous evaluation of treatment
technology performance data, beginning in 1970.  Reference 5 in
particular, which is available through the National Technical
Information Service, provides a full technical documentation for
the conclusions presented in this  report.
     The achievement of BAT-equivalent effluent quality, as cited
in this report, requires concurrent stringent control of effluent
suspended solids.  For most existing treatment plants, this level
of suspended solids control would  necessitate the addition of a
filtration device.  New plants, if properly designed, constructed
and operated, might achieve an equivalent effluent  suspended
solids level without filtration.

-------
           II.  REVIEW OF BPT-EQUIVALENT CONTROL




     During 1975 and 1976, a study was undertaken on behalf



of the State of Illinois to review and .evaluate the BPT stan-



dards proposed and promulgated by the USEPA  (6).  This evalu-



ation revealed that there were major differences in the levels



of pollution control performance proposed by the USEPA for



like pollutants for different categories of industrial dis-



chargers.  These differences were observed for pollutants com-



mon to many industries, and occurred for pollutants generally



controlled by similar types of treatment technology, irres-



pective of the industrial wastewater source.  Tables 1 and 2



demonstrate these differences among industry categories and



subcategories, for several example pollutants.



     Under the requirements for BPT effluent limitations



guidelines, the inorganic constituent arsenic is regulated for



four industrial categories, two of which include multiple sub-



categories for which arsenic is regulated  (Table 1).  The



minimum arsenic guideline (on a concentration basis) was 0.01



mg/1, for the phosphorus-consuming  (phosphorus trichloride)



subcategory of the Phosphate Manufacturing category.  Highest



effluent arsenic levels, at 10.0 mg/1, were allowed for two



of the three subcategories of the Nonferrous Metals industry.



The third subcategory, however, had an arsenic limitation of



only 0.1 mg/1.  For all categories for which arsenic was regu-



lated, the range of limitations was 0.01 to 10 mg/1, a 1000-



fold span.  Within the Nonferrous Metals category alone, there



was a 100-fold range of arsenic standards.

-------
     Table 1.  BPT Effluent Limitations Guidelines for
       Arsenic (1).
     Industry        Subcategory             Guideline,
                                                mg/1


     Inorganic       Boric Acid-Ore              0.5
      Chemicals       Mined Borax

     Nonferrous      Primary Copper Smelting    10.0
      Metals         Primary Copper Refining    10.0
                     Primary Zinc                0.1

     Ore Mining &    Ferroalloy Ores             0.5
      Dressing        Uranium, Radium, Vanadium  0.5

     Phosphate       Phosphorus Consuming        0.01
     Similar anomalies were observed in the guidelines for

other inorganic pollutants.  Copper was regulated for six

industrial categories encompassing 11 subcategories,  and guide-

line concentrations ranged from 0.03 to 1.1 mg/1, a near 40-

fold span.  Although the guidelines were fairly consistent

among subcategories of each category, one Nonferrous Metal sub-

category had a low copper guideline of 0.03 mg/1, while three

other subcategories had guidelines of 0.3 mg/1, a 10-fold

difference.

     Table 2 summarizes the high and low guideline values for

nine inorganic pollutants.  Arsenic and copper have been dis-

cussed.  The data for the remaining seven pollutants demon-

strate that BPT guideline variability was typical, for all

pollutants listed in Table 2.  The range of guideline values

for total chromium is 100-fold, total cyanide and zinc are 50-

fold, and others range down to 10-fold.

-------
Table 2.  Range of Thirty-Day Average BPT Values, mg/1 (1).
Pollutant
Low Industry
Lowest
 Value
Highest
 Value
High Industry
Arsenic

Cadmium

Chromium(T)

Copper

Cyanide(T)


Fluoride

Lead

Nickel

Zinc
Phosphate              0.01

Ore Mining & Dressing  0.05

Rubber Processing      0.05

Nonferrous Metals      0.03

Ore Mining & Dressing  0.01


Phosphate              0.7

Rubber Processing      0.1

Ore Mining & Dressing  0.1

Ore Mining & Dressing  0.1
             10.0

              0.50

              5.0

              1.1

              0.5


             29.0

              2.1

              2.2

              5.0
             Nonferrous Metals

             Nonferrous Metals

             Leather Tanning

             Inorganic Chemicals

             Organic & Inorganic
              Chemicals

             Glass

             Inorganic Chemicals

             Inorganic Chemicals

             Nonferrous Metals

-------
     Since under PL 92-500 (and subsequent federal legislation,



i.e., the Clean Water Act of 1977), BPT and other effluent li-



mitations are technology-based, the spectrum of effluent limi-



tations proposed by the USEPA was surprising.  In order to



further assess this situation, the State of Illinois established



in late 1975 the Illinois Effluent Standards Advisory Group,



IESAG.  The charge to the IESAG included the following:




     o   To review the technical basis upon which Illinois



         Effluent Standards had been based 	 (and



         such additional information as may be appropriate,



         in order to) ... adequately define the limits and



         economics of state-of-the-art  (industrial) pol-



         lution abatement technology.



     o   To determine, to the extent that the state-of-the-



         art of wastewater treatment had advanced, what



         concentrations of effluent pollutants could be



         technologically achieved  and at what costs.



     o   To assess the applicability of mass discharge



         standards as an alternative to, or in concert with



         Illinois policy of concentration-based standards.



     o   To make such proposals and recommendations as per-



         tained to the consideration by IESAG of  the above



         items for transmittal to  the Illinois Pollution



         Control Board  (IPCB)  and  the Illinois Environmental



         Protection Agency  (IEPA).

-------
     The documentation upon which the IESAG based its consid-
erations included References 5 and 6 of this report.   In its
report to the State of Illinois, IESAG concluded that for
common pollutants treated by identical technologies,  uniform
concentration-based standards were desirable (8).  Further,
from its evaluation of the capabilities and limitations of
that technology, IESAG recommended that the State of  Illinois
establish the effluent standards listed in Table 3.  In
essence, these recommendations represent BPT-equivalent limi-
tations.  The single exception to the BPT-equivalent  basis of
performance was for mercury.  Recognizing the extreme environ-
mental hazards of mercury, IESAG recommended the imposition of
a mercury standard based upon best available technology,
identified as ion exchange or coagulation treatment.   Thus,
the recommended mercury standard in Table 3 is BAT-equivalent.
Technology associated with the other standards presented in
Table 3 are,
       Arsenic             Precipitation/Clarification
       Barium              Precipitation/Clarification
       Cadmium             Precipitation/Clarification
       Chromium            Chemical Reduction or Ion
        (hexavalent)        Exchange
       Chromium (total)    Precipitation/Clarification
       Copper              Precipitation/Clarification
       Cyanide             Alkaline Chlorination
       Fluoride            Lime Precipitation/
                            Clarification
       Iron                Precipitation/Clarification
       Lead                Precipitation/Clarification

-------
Table 3.  IESAG Standards for BPT-Equivalent Control
  Technology Proposed to the State of Illinois (8).

Pollutant
Arsenic
Barium
Cadmium
Chromium
Chromium
Copper
Cyanide
Fluoride
Iron
Lead
Mercury
Nickel
Silver
Zinc

Concentrati
on, mg/1
Thirty-Day Maximum
Averaged 2 4 -Hour Composite
(total)
(total)
(total)
(hexavalent)
(total)
(total)
(total)
(total)
(total)
(total)
(total)
(total)
(total)
(total)
0.25
2.0
0.15
0.1
1.0
0.5
0.1
15.0
2.0
0.2
0.003
1.0
0.1
1.0
0.5
4.0
0.3
0.2
2.0
1.0
0.2
30.0
4.0
0.4
0.006
2.0
0.2
2.0

-------
                                                           10
       Nickel
       Silver
       Zinc
           Precipitation/Clarification
           Ion Exchange
           Precipitation/Clarification
     Table 4 compares these IESAG recommended BPT-equivalent
limitations with the range of BPT limitations proposed and
promulgated by the USEPA.

     Table 4.  Expected Effluent Values for Application
       of Good Technology  (30-day Average).
     Pollutant
  Type
Treatment
   IESAG      Range of
Recommended BPT Values,
 Standards,    mg/1
    mg/1
     Arsenic     Coprecipitation       0.25     0.01-10.0
     Cadmium     Precipitation         0.15     0.05- 0.5
     Chromium(T) Precipitation         1.0      0.05- 5.0
     Copper      Precipitation         0.5      0.03- 1.1
     Fluoride    Lime Precipitation   15.0      0.7 -29.0
     Lead        Precipitation         0.2      0.1-2.1
     Nickel      Precipitation         1.0      0.1-2.2
     Zinc        Precipitation         1.0      0.1 - 5.0
     In support of the development of BAT-equivalent control
limitations for this report, the BPT-equivalent limitations
recommended by IESAG (Table 3) have been reviewed.  Technical
performance data reported since the period of the IESAG study
(7) has been considered in this review.  There is no data avail-
able at this time to support revision of the IESAG recommenda-
tions as BPT-equivalent limitations.
     Table 3 presents BPT-equivalent standards for 30-day aver-
age and 24-hour maximum discharge.  The ratio of the two values

-------
                                                           11
is 1:2.  This ratio reflects the performance expected for well



designed and properly operated wastewater treatment systems.

-------
                                                           12
                III.  TREATMENT TECHNOLOGIES




     This Chapter provides a brief synopsis of the most effec-



tive treatment technologies established in full-scale practice



for each of the subject pollutants.  Detailed discussions of



these technologies have been published (4,5).




     Arsenic.  In aqueous systems, arsenic exists as either the



arsenite ion  (AsO_ ; As  ) or arsenate ion (AsO ~ ; As  ).



Treatment methods for arsenic include lime' or sulfide precipi-



tation, or coprecipitation (sometimes described as precipitation/



coagulation) with iron or aluminum hydroxide.  The oxidation



state of the arsenic influences the efficiency of each of these



treatment processes.  Sulfide precipitation is partially effec-



tive for arsenate, but ineffective for arsenite.  Lime precipi-



tation is preferred over sulfide precipitation due to higher



treatment efficiency, but has the disadvantage of high required



treatment pH  (pH 12+).  Caustic precipitation is less effective



than lime.  Iron or aluminum coprecipitation is more effective



than is lime precipitation, but has  the disadvantage of yield-



ing greater quantities of sludge, which is often more difficult



to dewater than is the lime precipitate sludge.  Both iron and



aluminum coprecipitation are strongly influenced by treatment



pH, with aluminum treatment efficiency declining at pH above 7,



and iron treatment efficiency declining above pH 9.  Both pro-



cesses perform better on arsenate than arsenite.



     Thus, for all precipitation treatment processes for arsenic,



enhanced performance is observed when the arsenic is present

-------
                                                           13
as arsenate.  Most effective treatment may require a chemical



oxidation step, to convert any arsenite to arsenate.  Chlori-



nation has been used to achieve this oxidation.   Each of the



precipitation processes is, in addition, influenced by the



efficiency of suspended solids removal.  Clarification nor-



mally provides adequate solids removal, due to the quantities



of lime, or iron or aluminum salts required for  precipitation.




     Barium.  Barium is infrequently encountered in industrial



wastewaters, and the treatment literature on barium is scant.



Barium sulfate precipitation has been reported,  with enhanced



gravity clarification of the fine barium sulfate solids achieved



upon addition of a coagulant such as an iron salt.  Barium sul-



fate is relatively soluble, but addition of a salt such as



sodium or iron sulfate in excess will reduce barium solubility



and thereby improve treatment efficiency.  When coagulants are



employed, gravity clarification is effective for solids remo-



val, and little gain in effluent quality is observed through



filtration.  The barium sulfate precipitation reaction appears



to reach equilibrium rather slowly, and adequate reaction  time



in the treatment process is essential.




     Cadmium.  Precipitation is the principal treatment process



employed for cadmium.  Most effective  precipitation  treatment



is achieved between pH 9 and  12,  and  close process  control is



required to promote maximum precipitation.  In wastewaters of



moderate to high  carbonate, or  to which supplemental carbonate



has been added, the extremely  insoluble cadmium  carbonate is

-------
                                                           14
formed, with best treatment near pH 10.  Cadmium plating wastes



typically contain cyanide, and pretreatment to completely



destroy the cyanide is necessary for effective cadmium preci-



pitation.  Lime precipitation appears to yield a better settling



precipitate than does caustic, and filtration of caustic treated



wastes may be required to achieve an effluent quality comparable



to that obtained with gravity clarification of a lime treated



waste.  Although it has been reported that ion exchange treat-



ment yields effluent levels equal to or less than good precipi-



tation treatment, there is inadequate full scale data in the



technical literature to support this claim.




     Hexavalent Chromium.  Reduction of hexavalent chromium



from a valence state of plus six to plus three, and subsequent



hydroxide precipitation of the trivalent chromic ion, is the



most common method of hexavalent chromium control.  Some indus-



tries utilize ion exchange for chromic acid control and re-



covery.  The standard reduction treatment technique is to lower



the waste stream pH to 2.0-3.0 with sulfuric acid, and convert



the hexavalent chromium to trivalent chromium with a chemical



reducing agent such as sulfur dioxide, sodium bisulfite or



ferrous sulfate.  One common source of the latter is spent pickle



liquor and, in the subsequent precipitation step the iron will



function as a coagulant at the expense of about four-fold



greater sludge production.  The efficiency of conversion of the



hexavalent to trivalent chromium is interdependent upon the



allowed reaction time, treatment pH, and type and concentration

-------
                                                           15
of reducing agent used.   Close process control is necessary to



achieve effective chromium reduction.



     Ion exchange has been employed successfully for hexavalent



chromium control.  In the ion exchange system wastewater pH is



a critical factor in successful treatment.   At pH below 4,  the



oxidizing power of the chromic acid attacks the resin.   At  pH



above 6, the ratio of dichromate to chromate increases.  Since



most anion exchange resins are less selective for dichromate



than for chromate, ion exchange efficiency decreases.




     Total Chromium.  Total chromium is the sum of the  hexava-



lent plus trivalent chromium.  Where hexavalent chromium is a



precurser form converted to trivalent chromium and the  conver-



sion has been ineffective, the total residual chromium may  be



predominately in the hexavalent form.   Thus, in chromium con-



trol by reduction-precipitation, effective treatment requires



the successful accomplishinent of three sequential steps:



hexavalent chromium reduction to trivalent chromium; precipi-



tation of the trivalent chromium; and removal of the precipitated



chromium.  Treatment performance will deteriorate due to incom-



plete achievement at any one of these three stages.



     Precipitation of trivalent chromium is most effective at



pH 8.5-9.5 although, due to the presence of other metals with



different pH optima in the typical metals-bearing wastewater,



an average waste stream treatment pH of about 8 is often



reported for mixed chromium-metals wastes.  Lime and caustic



are the pH control chemicals of choice, with caustic being most



common in newer or upgraded treatment plants due to  its ease

-------
                                                           16
of handling.  In the gravity clarification stage, lime treated



wastes seem to settle better than do caustic treated wastes,



and filtration of these latter wastes may be necessary to



achieve suspended solids control equal to gravity clarification



of the lime treated wastewater.  Lime sludge may be two to



three fold greater  (dry weight basis) than a caustic sludge,



for treatment of the same wastewater.  Thus, in precipitation



treatment while lime treatment may not necessitate filtration,



the choice may be caustic treatment plus filtration, with the



expense of the filter offset by greater ease of caustic hand-



ling, and reduced volumes of caustic sludge.  These same trade-



offs apply for precipitation treatment of many metals.




     Copper.  The standard treatment method for copper is pre-



cipitation.  Cyanide, or moderate to high concentrations of



carbonate will complex with copper, and prevent its precipita-



tion.  Although most authorities agree that optimum copper



precipitation occurs between pH 9.0 and 10.3, effective treat-



ment has been observed at much lower operating pH values.  Poor



performance in copper treatments seems more often to result



from insufficient solids removal than from inadequate precipita-



tion process pH control.



     Both lime and caustic are widely used to precipitate cop-



per.  In copper sulfate wastewaters, the addition of lime may



result in calcium sulfate formation.  In this instance filtra-



tion should be avoided, since the slowly forming calcium sul-



fate will tend to cement the filter.  With lime treatment,



gravity clarification can provide as effective treatment as,

-------
                                                           17
in contrast for some other metals, can caustic.   The caustic



sludge yield can be significantly less than that from lime



treatment, although the caustic sludge dewatering properties



are poorer than are the lime sludges.  In summary, effective



copper precipitation treatment can be achieved over a fairly



wide pH range, and close pH control is thus not critical.



Gravity clarification is effective in solids removal, and  little



or no benefit is gained by effluent filtration.   The result is



that BAT-equivalent control is comparable to BPT-equivalent



control, being based upon the same wastewater treatment tech-



nology.




     Cyanide.  Cyanide treatment results reported for full-scale



systems are among the most erratic observed for any inorganic



industrial pollutant.  This is primarily due to the variety of



complexes which form with cyanide within different wastewaters,



and the extent to which these cyanide complexes differ in their



response to the standard cyanide destruction techniques.  These



differences are reflected in the higher effluent  limitations



normally promulgated for total cyanide than for cyanide amenable



to chlorination treatment.



     Several methods of treating  cyanide wastes are  in current



use, although the most wide-spread is alkaline chlorination.



Most effective alkaline chlorination  is through two-stage



treatment.  The first stage is designed and operated  to maximize



conversion of cyanide to cyanate, which is destroyed  by addi-



tional chlorination in the second  stage.  There are  reports

-------
                                                           18
that equivalent treatment can be achieved in a single stage



process, although some results suggest that the single stage



approach suffers from a lack of process stability.  Close pro-



cess control, and automated pH and chlorine dosage are neces-



sary to accomplish a high degree of cyanide treatment.  In the



first stage, a pH of 10 or higher, and a reaction period of



up to two hours is necessary.  To avoid formation of solid



cyanide precipitate, the waste must be thoroughly agitated dur-



ing treatment.  In the second stage, an operating pH of 8.0-



8.5 and reaction period of up to one hour is necessary, with



sufficient chlorine addition to force cyanate oxidation.



     Other cyanide treatment processes include ozone oxidation



and electrolytic decomposition.  The former has had limited



field application and the latter process is used primarily for



concentrated cyanide baths, with residual treatment by alkaline



chlorination.




     Fluoride.  Treatment options for fluoride are limited to



two alternative precipitation processes, with significant dif-



ferences in performance and associated sludge yield.  Lime



precipitation to form calcium fluoride has been the dominant



technology for fluoride control.  At the high treatment pH



required (pH 12+), and associated high lime dosage filtration



is risky, due to the tendency of the gravity clarified effluent



to cement the filter.  Thus, within the solubility constraints



associated with calcium fluoride formation, most effective



treatment with lime depends upon highly efficient solids removal



by gravity clarification.  The precipitated solids are reported

-------
                                                           19
to have poor settling characteristics.   This lime precipitation/



clarification technology provided the basis for BPT effluent



limitation guidelines.



     The second treatment alternative is fluoride removal by



alum addition; essentially a coprecipitation process.   Much



lower effluent fluoride levels are achieved with alum copreci-



pitation than with lime precipitation and best removal appears



to result at pH 6-7.  Treatment efficiency in this pH range



reflects the alum dosage (mg/mg fluoride), with enhanced treat-



ment at higher (200+ mg/mg) alum dosages.  A major disadvantage



of the process is the voluminous sludge produced, which even at



moderate alum dosages can represent up to 40% of the original



wastewater volume treated.  This sludge yield represents such



a serious problem that lime precipitation has remained the



treatment technology of choice of both regulatory agencies and



industry.




     Iron.  In aqueous systems, iron exists in the ferric  (Fe  )



or ferrous (Fe  ) form, depending upon conditions of pH and



dissolved oxygen concentration.  In precipitation treatment,



ferrous iron is more soluble than ferric iron.  Therefore, most



effective iron precipitation treatment incorporates conversion



of any ferrous to ferric iron, before precipitation.  At neu-



tral pH and in the presence of oxygen, ferrous iron rapidly



oxidizes to the ferric form, which readily hydrolyzes to the



insoluble precipitate, ferric hydroxide.  Many iron wastewaters



such as pickling rinses are both highly  acidic and contain pre-



dominately the ferrous form of iron.

-------
                                                           20
     The principal treatment process for iron is oxidation-



precipitation-clarification.  The iron wastewater is first



neutralized to pH near 7, where ferrous iron oxidation rapidly



occurs and where the solubility of ferric hydroxide is at its



minimum.  Following or simultaneous with pH adjustment, the



waste is aerated to provide oxygen for the iron oxidation pro-



cess.  Where iron complexing agents are present in the waste,



the rate of oxidation is slowed.  Sufficient aeration time is



therefore essential in order to achieve a high degree of oxida-



tion.  Freshly precipitated ferric hydroxide has a characteris-



tic low specific gravity, which makes settling difficult without



long clarifier detention time or additional treatment such as



filtration.  Lime is frequently used for pH adjustment and,



where sulfuric acid is present as in a pickling waste, large



quantities of calcium sulfate are also precipitated.  In some



industrial wastes, ferrous and ferric iron may exist in the



presence of cyanide.  Extremely stable iron cyanide complexes



result.  Such species present considerable difficulties for both



iron and cyanide treatment.  No truly effective treatment method



has been reported for such wastes.




     Lead.  Precipitation treatment of lead is extremely effec-



tive, except in instances such as the tetraethyl lead industry



where significant concentrations of organic lead occur.  Lead



in the organic form is not amenable to precipitation, and the



organic component must be destroyed by chemical means such as



chlorination, before the lead can be precipitated.  Although

-------
                                                           21
the literature contains conflicting values of pH options for



lead precipitation  (ranging from pH 6 to above pH 10),  there



is strong evidence that best precipitation treatment occurs in



the pH range 9-10.  At this high treatment pH, other metals in



the wastewater with lower pH optima may not be effectively



precipitated, however.  Lead wastewaters precipitated with lime



have good settling properties, while caustic treated wastes may



require filtration to achieve an equivalent effluent lead level.



The expense of caustic plus filtration may be offset by the



lesser sludge volumes produced with caustic treatment.




     Mercury.  Many types of mercury treatment technology have



been described in the technical literature.  Among the most



effective are the ion exchange and coagulation treatment pro-



cesses.  Typically, ion exchange treatment of mercury involves



the formation of a negatively charged mercuric chloride complex



by addition of chlorine or hypochlorite (to oxidize any metallic



mercury present), or chloride salts, and removal of the mer-



curic chloride complex or an anion exchange resin.  Most experi-



ence with ion exchange treatment has been with chlor-alkali wastes



which contain high background chloride levels.



     Control of mercury by coagulation has been reported for



a variety of mercury-containing wastewaters.  The process has



been applied with success to both organic and inorganic mercury. »



Iron and alum coagulants are reported to produce equivalent



mercury removal results, although the alum coagulant may display



poorer settling properties than the iron coagulant.  In both



instances effluent filtration is necessary to achieve best

-------
                                                           22
 treatment results.  A disadvantage of coagulation treatment is



 that  large quantities of mercury-contaminated iron or aluminum



 hydroxide sludge are produced.



      Because of the large sludge quantities generated, activated



 carbon adsorption is sometimes considered as an alternative to



 coagulation.  However, carbon adsorption is less effective than



 ion exchange or coagulation at higher influent mercury levels,



 and it appears that carbon treatment yields effluent mercury



 levels comparable to ion exchange or coagulation only when



 initial mercury levels are below 50 yg/1.




      Nickel.  In waste streams, nickel exists predominately as



 the soluble ion.  In the presence of complexing agents such as



 ammonia, EDTA, or cyanide, nickel can form extremely stable



 soluble complexed species which interfere with conventional



 precipitation treatment.



      Precipitation treatment is the standard practice for con-



 trol  of nickel in industrial wastes, although in specialized



 circumstances such as for recovery in plating plants, reverse



 osmosis has been utilized.  This later technology, although



 effective, is principally utilized for alkaline nickel wastes.



 Best  precipitation treatment is achieved at a pH above 9.5,



which pH level may cause deterioration of the precipitation



 treatment of other metals in the wastewater having significantly



 lower pH options.  Even when lime is employed as the treatment



chemical, nickel hydroxide precipitates have rather poor



settling characteristics.  Poor performance in nickel treatment



more often results through inadequate solids separation than

-------
                                                           23
through incomplete precipitation of the soluble nickel.  Unless



extended clarifier detention time is provided, filtration



appears necessary to achieve good control of total nickel.




     Silver.  Treatment technology for silver is influenced



more by the value of the recovered metal than by the limitations



of discharge permits.  Many treatment/recovery techniques are



employed, although the final polishing step is often ion ex-



change.  Other processes include evaporation recovery, copre-



cipitation with ferric chloride, and silver chloride precipita-



tion.  This latter process is least efficient.  Coprecipitation



and ion exchange yield comparable results,  and evaporative



treatment results in complete recovery.  Evaporation is rarely



economical for dilute silver wastewaters.




     Zinc.  Precipitation is the standard of practice in treat-



ment of zinc wastewaters.  There is a great deal of confusion



in the technical literature regarding the optimum pH for zinc



precipitation.  Optimum performance has been cited at pH values



as low as 9.0 to 9.5, and as high as pH 11 and above.  Zince



is an amphoteric metal, with increasing solubility at both higher



and lower pH.  It is possible that constituents (such as com-



plexing agents) other than zinc in the various wastewaters may



influence zinc precipitation efficiency as a function of pH.



As with other metal wastewaters, both lime and caustic are used  „



as the precipitating chemical.  The effluent quality of full-



scale zinc treatment systems appears to be influenced most by



the efficiency of precipitate suspended solids removal and many



such systems employing only gravity clarification for solids

-------
                                                           24
control exhibit high effluent solids and associated high ef-



fluent zinc.  Therefore, for zinc wastes, best available tech-



nology requires determination of and treatment at the best pH



value for that specific wastewater, plus efficient suspended



solids removal by gravity clarification and/or filtration.

-------
                                                           25
                IV.  BAT-EQUIVALENT CONTROL




     Under the authority of the Clean Water Act of  1977,  the



USEPA is developing BAT effluent limitations guidelines  for



industrial point source dischargers.  Guidelines for only a few



industrial categories have been published to date.   Example



guidelines are presented in Table 5.  As was the case for BPT



guidelines, a range of concentration values is observed  for



each pollutant regulated.  The range of guidelines  for copper



is most extreme, at 200-fold.



     Table 6 compares BPT guidelines for several pollutants with



the BAT values listed in Table 5, for three industry categories.



Although it might be expected that BAT performance  should be



equal to or more restrictive than BPT, such is not  consistently



the case,  (see total chromium, fluoride).  For several of the



cases presented in Table 6, BPT and BAT values are  equal.  For



most instances where BAT is below BPT, the reduction is fairly



modest.  The exception in Table 6 is nickel, with a BPT guide-



line of 2.20 mg/1 versus a BAT guideline of 0.10 mg/1.



     On the basis of the BAT information available  to date, it



appears that a pattern of varying concentration based values



will result through the USEPA efforts.  This Chapter of this



report presents single BAT-equivalent values for each subject



pollutant, developed through a technology performance evalua-



tion.  These BAT-equivalent effluent values are summarized in



Table 7, for 30-day average performance.  Based upon performance



data of full-scale systems, a 24-hour maximum discharge value



of 1.5 to  2.0 times the 30-day average  (Table 7) is recommended.

-------
Table 5.  Example Proposed and Promulgated BATEA Effluent Limitation Guidelines - Thirty-
  Day Average.
Industry Category Document As
Inorganic Chemicals13 1*1*0/1-79/007
Chlor-Alkali Mercury Cells 0.10
Chlor-Alkali Daiphragm Cells
Hydrofluoric Acid
Sodium Bichromate
Titanium Dioxide-Sulfate
Process 0.50
Titanium Dioxide-Chloride
Process
Titanium Dioxide-Chloride
Ilmenite Process 0.50
Aluminum Fluoride
Chrome Pigments
Copper Sulfate 0.50
Hydrogen Cyanide
Free
Total
Nickel Sulfate
Sodium Hydrosulfite
Sodium Bisulfite
Cd Cr-H Cr-T

0.05
0.05
O.OU
0.05 0.32
0.15 O.lU
O.lU
0.10 0.10
o.oU
0.19 1.10
0.05 0.05



0.05
0.10
0.11
Cu CN

0.05
o.Uo
0.009

0.50

0.50

o.Uo
o.Uo

0.27
U.OO
o.Uo

0.50
F Fe Pb

0.16
0.22
33 0.06

2.50 0.30
2.1*0
2.50 0.30
30
1.1*0
0.05



0.05
0.30
0.30
Hg Ni

O.OU8 0.10
0.10
0.15
0.17
0.20

0.20
0.17
0.17
0.10



0.20
0.20
0.20
Ap; Zn

0.07 0.15
0.1*0
0.52
0.1*7
0.50

0.50

1.10
0.1+0



o.Uo
0.50
0.50
                                                                                                 K)

-------
Table 5.    (Continued).
Industry Category
Textile Mills
(all subcategories)
Gum & Wood Chemicals
Rosin Based Derivatives
Document As
l*UO/l-79/022b
UUo/l-79/078b
Cd Cr-H Cr-T Cu CN F Fe Pb Hg Ni Ag Zn
0.50 0.50 1.00
1.80
Sulfate Turpentine
Leather Tanning &
 Finishing
Steam Electric Power
Pulp, Paper & Paperboarda
Range - Minimum
      - Maximum
Median Value
UUO/1-79/016
Ul»0/l-80/029b
1.80
                                      1.80
      1.00
1.00
                                      1.80
                                                                                 3.00
             0.10    0.05   0.05   O.OU   0.009  0.50   30   1.00  0.05  O.OUB  0.10 0.07   0.15
             0.50    0.19         1.80   1.80   It.00   33   2.50  l.Uo        1.80        3.00
             0.50    0.10    -     0.10   0.1*0    -     -    2.50  0.30  -     0.17  -     0.50
  Daily maximum values reported.  No standards proposed for 30-day consecutive  average  performance.
  BAT and PSES mass discharge limitations are equal.   PSES  limitations  were  proposed  on both  a  concentration and
  a mass discharge basis.  The PSES limitation values  are presented in  this  Table.
                                                                                                                   to
                                                                                                                   -j

-------
Table 6.  Comparison of Selected BPT and BAT Effluent Limitations Guidelines  -  Thirty-
  Day Average.
Pollutant
Chromium (Hexavalent )
Chromium( Total )
Copper
Fluoride
Iron
Lead
Nickel
Zinc
Industry Category
Inorganic Chemicals
Inorganic Chemicals
Leather Tanning &
Finishing
Inorganic Chemicals
Steam Electric Power
Inorganic Chemicals
i
t
Inorganic Chemicals
Steam Electric Power
Inorganic Chemicals
Inorganic Chemicals
Inorganic Chemicals
Subcategory
Sodium Bichromate
Chrome Pigments
Sodium Dichromate
Copper Sulfate
Metal Cleaning
Aluminium Fluoride
Hydrofluoric Acid
Titanium Dioxide
Metal Cleaning
Chrome Pigments
Copper Sulfate
Chrome Pigments
BPT(Ref.6)
0.05
0.50
O.UU
1.00-
3.60
1.10
1.00
20.0
15-0
U.OO
1.00
2.10
2.20
I*. 00
BAT (Tab. )
0.05
1.10
0.32
1.80
o.Uo
1.00
30.0
33-0
2.50
1.00
1.UO
0.10
1.10
                                                                                               ro
                                                                                               oo

-------
Table 7.   Summary of BAT-Equivalent Treatment Technologies and Effluent  Pollutant Levels

  Achievable on a Thirty-Day Averaged Basis.
Pollutant
Arsenic
Barium
Cadmium
Chromium,
Hexavalent
Chromium,
Total
Copper
Cyanide
Fluoride
Iron
BAT-Equivalent
Concentration, mg/1
0.20
1.00
0.10
0.05
0.50
o.uo
0.10
10.0
1.50
Treatment Technology
Arsenite Oxidation; Lime Precipitation, or Iron or
Alum Co-Precipitation; Gravity Clarification
Sulfate Precipitation; Coagulation; Gravity
Clarification
High pH Precipitation; Gravity Clarification, or
Filtration Where Caustic is Substituted For Lime
Acidic Reduction To Trivalent Chromium or Ion
Exchange at pH Below 6.0
Precipitation; Gravity Clarification, except
Filtration may be Required for Caustic Tr'-ated
Wastewaters
Precipitation; Gravity Clarification
Two-Stage Alkaline Chlorination
High pH Lime Precipitation; Gravity Clarification
Oxidation at Neutral pH of Ferrous to Ferric Iron;
                                                 Precipitation; Gravity Clarification or

                                                 Filtration
                                                                                                   to
                                                                                                   vo

-------
Table 7.   (Continued).

Pollutant
Lead
Mercury
Nickel
Silver
BAT-Equivalent
Concentration, mg/1
0.15
0.003
0.75
0.10
Treatment Technology
High pH Precipitation; Gravity Clarification, or_
Filtration where Caustic is Substituted for Lime
Ion Exchange or Coagulation plus Filtration
High pH Precipitation; Gravity Clarification and/or
Filtration
Ion Exchange or FErric Chloride Coprecipitation
plus Filtration
Zinc
0.50
Optimized  Precipitation pH;  Gravity Clarification
and/or Filtration

-------
                                                            31
      BAT-equivalent effluent quality requires both in-plant



water conservation, and maximum efficiency of operation of



well designed and properly constructed and maintained treatment



systems.  In some instances, for precipitated solids removal,



clarification alone can yield an effluent quality equal to



final effluent filtration.  However, these are rather rare



instances, and filtration would normally be required to achieve



the BAT-equivalent effluent pollutant levels cited in this



Chapter.  An advantage of filtration is that it normally pro-



vides more consistent effluent quality than does clarification



alone, since clarifiers are prone to upset.




      Arsenic.  BAT-equivalent treatment technology for arsenic



can be achieved by oxidative conversion of arsenite to arsenate,



followed by either lime precipitation at pH 12 or iron copreci-



pitation at pH below 9, and gravity clarification.  In a well



designed and properly operated treatment system, an effluent



arsenic level of 0.20 mg/1 is obtainable.  Filtration would pro-



vide only marginal enhancement of the effluent quality.




      Barium.  Sulfate precipitation of barium is the only well



established treatment technology available.  BAT-equivalent



treatment requires sufficient detention time to  achieve equili-



brium formation of the barium sulfate solids, and the use of



a coagulant such as iron  or aluminum sulfate  to  control suspended'



solids removal by gravity clarification.   A BAT-equivalent  bar-



ium effluent quality of 1.0 mg/1 is  achievable.

-------
                                                            32
      Cadmium.  BAT-equivalent control of cadmium results through



complete destruction of cyanide where present, followed by lime



precipitation plus gravity clarification or caustic precipita-



tion plus filtration.  In a closely controlled treatment plant



with highly efficient solids removal, an effluent cadmium level



of 0.10 mg/1 is achievable.




      Hexavalent Chromium.  Chemical reduction of hexavalent to



trivalent chromium followed by precipitation of the trivalent



chromic hydroxide is a well established technology.  The pro-



cess, with adequate reaction time, and close process control of



pH and reducing agent dosage, can achieve a BAT-equivalent



hexavalent chromium concentration of 0.05 mg/1.  Ion exchange



treatment, when wastewater pH is controlled to minimize forma-



tion of dichromate, can achieve an effluent hexavalent chromium



concentration equal to the chemical reduction process.




      Total Chromium.  BAT-equivalent control for total chrom-



ium will yield an effluent chromium level of 0.5 mg/1.  This



treatment is precipitation and clarification.  Where caustic is



used as the treatment chemical, effluent filtration may be



required to achieve the cited concentration.




      Copper.  Treatment by precipitation and gravity clarifica-



tion will yield BAT-equivalent control of copper to an effluent



level of 0.4 mg/1.  Although close process pH control does not



appear to be critical, effective solids separation is necessary



to achieve this effluent quality.

-------
                                                           33
     Cyanide.  Alkaline chlorination treatment represents BAT-



equivalent control of cyanide, and in the absence of extremely



strong metal-cyanide complexes, can achieve an effluent cyanide



concentration of 0.10 mg/1.  In recognition of the differences



in chemical forms and their associated treatability of cyanide



in different process streams, cyanide treatment must often be



evaluated for individual dischargers where BAT-equivalent con-



trol technology cannot achieve 0.1 mg/1.




     Fluoride.  Lime precipitation plus gravity clarification



represents BAT-equivalent control technology for fluoride.



Effective treatment requires high treatment pH and lime dosage,



as well as efficient solids removal, and can achieve an effluent



fluoride concentration of 10 mg/1.




     Iron.  BAT-equivalent control of iron requires efficient



oxidation of ferrous to ferric iron, followed by precipitation



and solids removal.  In most instances, solids removal by



gravity clarification will yield an effluent iron concentration



of 1.5 mg/1.  Rarely, filtration may be required in order to



achieve this effluent quality.




     Lead.  Effective treatment of lead requires precipitation



at pH near 10, plus effective suspended solids removal.  Where



lime is employed as the treatment chemical and adequate clari-



fier detention time is provided, an effluent lead level of 0.15



mg/1 is achievable.  With caustic used in lieu of lime, a poorer



settling precipitate results and filtration may be necessary to



achieve an effluent lead concentration of 0.15 mg/1.

-------
                                                           34
     Mercury.  BAT-equivalent control of mercury can be achieved



by ion exchange treatment, or by coagulation with effluent fil-



tration.  At raw wastewater mercury levels below about 50 yg/1,



activated carbon adsorption will perform equivalent to the other



two processes.  An effluent mercury level of 3 pg/1 is achiev-



able in well designed and properly operated treatment systems.




     Nickel.  Precipitation treatment of nickel is effective in



converting the soluble ion to a solid nickel hydroxide phase.



However, the precipitate appears to have poor settling charac-



teristics and effective solids removal is accomplished only



with either long clarifier detention time or by filtration.



Either approach can achieve an effluent nickel level of 0.75 mg/1,




     Silver.  BAT-equivalent control of silver can be accom-



plished by either ion exchange or ferric chloride coprecipita-



tion treatment.  Either method will yield an effluent silver



level of 0.10 mg/1.  With coprecipitation, effluent filtration



may be required to achieve this effluent silver level.




     Zinc.  The efficiency of precipitation treatment for  zinc



is influenced by the treatment pH  (with the optimum pH value



apparently varying among different wastewaters) and efficient



suspended solids removal.  A BAT-equivalent effluent  zinc  level



of 0.5 mg/1 is achievable when these conditions are met.

-------
                                                             35
                      V.   REFERENCES


1.  Patterson, J.W.,  "Technical  Inequities  in Effluent
    Limitations Guidelines,"  Journal,  WPCF,  49:7:1586,
    July, 1977.

2.  Patterson, J.W.,  "Wastewater Treatment  Technology,"
    Illinois Institute for Environmental  Quality,  1971.

3.  Patterson, J.W.,  "Wastewater Treatment  Technology, 2nd
    Edition," Illinois Institute for Environmental Quality,
    1973.

4.  Patterson, J.W., Wastevater  Treatment Technology,  Ann
    Arbor Science Publishers,  Inc., Ann Arbor,  MI.,  1975.

5.  Patterson, J.W.,  "Technology and Economics  of  Industrial
    Pollution Abatement,"  Illinois  Institute for Environmental
    Quality Document No. 7622, 1977.   (Available through
    National Technical Information  Service  as NTIS Publication
    PB 279 338/A5).

6.  Patterson, J.W.,  "Directory  of  Federal  and  State Water
    Pollution Standards,"  Illinois  Institute for Environ-
    mental Quality  Report  No.  77/06, October, 1977.

7.  Patterson, J.W., Wastewater  Treatment Technology,  2nd
    Edition;  Industrial Practice (in  preparation),  Ann
    Arbor Science Publishers,  Inc., Ann Arbor,  MI.  (1981).

8.  Illinois Effluent Standards  Advisory  Group,  "Evaluation
    of Effluent Regulations of the  State  of  Illinois,"
    Illinois Institute for Environmental  Quality Report
    No. 76/21, June, 1976.

9.  Additional References:  Development Documents  of the
    Effluent Guidelines Division, USEPA.
            U.S. Environmental Protection Agency  '•
            Region 5, Library (PL-12J)
            77 West Jackson Boulevard, 12th FtoOf
            Chicago, IL 60604-3590

-------
                                   TECHNICAL REPORT DATA "
                            (Please read Instructions on the reverse before completing)
 1. REPORT NO.
    EPA-905/2-81-003
                                                           3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
   Guidance for BAT-Equivalent Control  of Selected
   Toxic  Pollutants
                                                           5 REPORT DATE
                                                              May 1981
                               6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
   James  W.  Patterson
                                                           8 PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
   Patterson  Associates, Incorporated
   1540  North State Parkway, Unit  13-A
   Chicago,  Illinois  60610
                                10 PROGRAM ELEMENT NO.
                                11. CONTRACT/GRANT NO.
                                   Purchase  Order
                                   No. 54239NASX
12. SPONSORING AGENCY NAME AND ADDRESS
   Permit  Branch (5EP)
   U.S.  Environmental Protection Agency
   230 South  Dearborn Street
   Chicago,  Illinois  60604
                                13. TYPE OF REPORT AND PERIOD COVERED
                                   Final
                                14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
   Project  Contact:   Jon Barney  (312) 886-6109      Funding provided by the  Great  Lakes
   National  Program Office under Section  104(b)  of the Clean Water Act.
16. ABSTRACT                                                              ~  ~~~  ~~	
   This manual  is intended to provide guidance  to federal and state NPDES  permit  and
   pretreatment staffs in determining appropriate limitations for the discharge of
   selected  toxic pollutants in the wastewater  from industrial facilities  where appli-
   cable  Effluent Guidelines regulations  are  not available.  From his extensive knowl-
   edge and  comprehensive review of the treatment technology available to  industry,  the
   author has  determined, in his best professional  judgement, the final effluent  con-
   centrations  that can be achieved using his estimate of best available technology
   (BAT)  for the following toxic pollutants:  arsenic, barium, cadmium, hexavalent
   chromium, total  chromium, copper, cyanide, fluoride, iron, mercury, nickel, silver,
   and zinc.   It is concluded that, aside from  a few extraordinary situations  involving
   unusual chemical interferences, the treatability levels provided in the manual  should
   be applicable, independent of industrial category.
 7.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS
                                             c. COS AT I Field/Group
   Best Available  Technology
   BAT
   Toxic pollutants
   Metals
   Cyanide
   Wastewater
   Treatment
Pollution control
NPDES
Permits
Treatability
 8. DISTRIBUTION STATEMENT
                                              19 SECURITY CLASS (This Report)
                                                  Unclassified
                                             21. NO. OF PAGES
                                                40
    Unlimited
                  20 SECURITY CLASS (Tillspage)
                      Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

-------