Technology Transfer                             EPA 625/10-80-001
Environmental
Regulations
       Technology

The
August 1 980
            U.S.
                 5,
            77 West              12th Ftoqr
                   1L
This report was prepared jointly by
Effluent Guidelines Division
Office of Water Planning and Standards
Office of Water and Waste Management
Washington DC 20460
and
Center for Environmental Research Information
Office of Research Program Management
Office of Research and Development
Cincinnati OH 45268

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Nickel plating bath
                    MrS.

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Contents                   1- Overview	,	    1

                               2. Water Pollution Control Regulations	    2
                                   The Clean Water Act	    3
                                   Applications to Eiectroplaters Discharging Directlyto Waterways	    5
                                   National  Pretreatment Standards for Indirect Dischargers ........    6
                                        General Pretreatment Regulations	    6
                                            Important Aspects for Eiectroplaters .................    7
                                            Variance Application	    7
                                            Removal Allowances	    8
                                        Specific Pretreatment Standards for Eiectroplaters.	    9

                               3. Water Pollution Control Technologies	...,..,,.......,.   11
                                   Selecting a System	   11
                                   Resource Recovery and Pollutant Load Reduction Modifications ....   12
                                   Conventional Wastewater Treatment	   13
                                   Alternative  Methods of Treatment..........,...,,,.,..,.....   14
                                   Cost Implications of Direct Wastewater Discharge. ...,...,,,,..   15

                               4, Water Pollution Control Case Histories .....,..,..,,..	   16
                                   Case History 1.  Economic Evaluation of Evaporator Installation. ..   16
                                   Case History 2.  Automated Direct Drag-out Recovery.	   18
                                   Case History 3. Stream Segregation to Enhance Conventional Treat-
                                      ment System Performance	   19
                                   Case History 4.  Sulfide Precipitation.	   20
                                   Case History 5. Ion Exchange for Selective Heavy Metal Removal...   22

                               5. Solid Waste  Management	   25
                                   Hazardous Waste  Regulations	   25
                                        Identification of Hazardous Wastes	....,....,.,...   25
                                        Requirements for Hazardous Waste Generators	   27
                                        Requirements for Storage and Disposal Facilities	   28
                                   Reduction of Sludge Volume and Disposal Cost	   29
                                        Effects of Pollutant and Wastewater Load Reduction	   30
                                        Effects of Treatment Techniques	   30
                                        Effects of Sludge Dewatering.	   31

                               6, Financing Alternatives ......................................   35
                                   Income Tax Provisions	   35
                                   Small Business Administration Loans	,	   35
                                   SBA-Guaranteed Pollution Control Revenue Bonds	   35
                                   Other Sources	   36

                               7. Consolidated Permit Program ,,....,,............	   37

                               8. Contacts	   38
                                   Regulatory  Information	   38
                                   Financial Assistance Information	   38
                                   EPA Regional Offices			   39

                               References	   41
                                                                                                 HI

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Illustrations                 Figures
                                  1,  Electroplating Industry Conventional Wastewater Treatment, .....    13
                                  2.  Annual Sewer Fee as a Function of Flowrate	,	    15
                                  3.  Evaporative Recovery System: (a) Closed-Loop and (b) Open-Loop. ..    17
                                  4.  Cost Versus Feed Rate for Open-Loop Evaporator System	    18
                                  5.  Automated Direct Drag-out Recovery	    18
                                  6.  Percentage of Drag-out Recovery with Rinse-and-Recycle System. ..    19
                                  7.  Treatment System With Waste Stream Segregation .	    20
                                  8.  Treatment System With Sulfide Precipitation	    21
                                  9.  Continuous Treatment System	    23
                                 10.  Generator Obligations Under the Resource Conservation and Recovery
                                     Act	,	, .    27
                                 11.  Annual Cost for Sludge Disposal	    29
                                 12,  Sludge Generation Rates for Three Treatment Systems.	    30
                                 13.  Sludge Volume Versus Solids Concentration	    31
                                 14.  Recessed Plate  Filter Press and Auxiliary Equipment Needed for
                                     Sludge Dewatering	    32
                                 15.  Annual Sludge Disposal Cost for Filter Press Dewatering System . ,.,    33
                                 16.  Return on Investment from Recessed Plate Filter Installation.....    34


                                 Tables

                                  1.  Summary of Legislative Activities	,	     3
                                  2.  Best  Practicable Control Technology Currently Available  Effluent
                                     Limitations (Suspended Indefinitely): Subparts A and D-F........     4
                                  3.  Best  Practicable Control Technology Currently Available  Effluent
                                     Limitations (Suspended Indefinitely): Subpart B. ..	     5
                                  4.  Best  Practicable Control Technology Currently Available  Effluent
                                     Limitations (Suspended indefinitely): Subparts A, B, and D-F	     6
                                  5.  EPA Classification of Electroplating Industry. . ,	     6
                                  6.  Pretreatrnent Standards  for Existing Sources: Subparts A, B, and
                                     D-H	     8
                                  7,  Pretreatrnent Standards for Existing Sources: Alternative 1—Sub-
                                     parts A, B, and D-H	     9
                                  8.  Pretreatrnent Standards for Existing Sources: Alternative 2—Sub-
                                     parts A, B, and D-H	    10
                                  9.  Economic Evaluation for Evaporator Installation................    16
                                 10.  Permit Requirements and Treated Effluent Quality: Waste Stream
                                     Segregation	    20
                                 11.  State Requirements and Treated Effluent Quality: Sulfide Precipita-
                                     tion	    22
                                 12.  Permit Requirements and Treated Effluent Quality: Ion Exchange....    24
                                 13.  Toxic Waste Limits Set by EPA's Extraction Procedure	    26
 IV

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1.  Overview
The enactment of a series of laws
by the U.S. Congress has confronted
the electroplating industry with
a multitude of pollution control
requirements for wastewater and
solid residues. The Congress
assigned the U.S. Environmental
Protection Agency (EPA) the
responsibility for preparing the
detailed regulations and establishing
the administrative procedures for
carrying out the laws,

Because the water pollution and
solid waste laws were passed  at
different times, EPA's schedule
for implementing pollution
control requirements differs for each
of these areas. Therefore,  electro-
platers must keep informed of
new and changing regulations, as
integrated compliance will reduce
pollution control and treatment costs.
This report is intended to provide
the electroplating industry with
a summary of the laws and EPA
regulatory activities, and of
regulations and technologies that
can affect electroplaters* decisions
for wastewater pollution control
and solid waste handling and
disposal. The regulations recently
promulgated by EPA are presented
and water pollution control
technologies and case histories of
installations are discussed. Processes
are described only to  provide
some guidance for selecting pollution
control systems. The report also
includes information on the current
status of sludge disposal regulations,
technologies and operating
techniques that can reduce
sludge disposal costs, and financial
assistance  available through
federally sponsored programs.
                                    Chrome plating bath

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2.  Water Pollution
Control  Regulations
The regulations to be applied
to electroplaters result from a
complex series of events, involving
an extensive effort by both the
government and the electroplating
industry. Many platers have been
confused by the complexity of
the regulatory process, and their
confusion  is understandable.
It is hoped that this section will
clarify the essential features
of the regulations,

Table 1 summarizes environmental
legislative activities that have
dealt with water pollution control.
With the enactment of the
Federal Water Pollution Control Act
(FWPCA) as amended in 1972
(Public Law 92-500), the Federal
Government became responsible
for a wide range of regulations
related to  water pollution control.
Although the average manufacturer
may not be concerned with the
full scope  of this complex bill, of key
importance are those parts of the
law relating to the discharge
of industrial wastewater to
waterways8 or municipal systems.

For industries discharging waste-
water to waterways (direct dis-
chargers),  the most far-reaching
feature of  the 1972  FWPCA
amendments was the requirement
that all such industries install a
base level of pollution control
technology by July 1, 1977,  and  a
more stringent level by July 1, 1983
(later amended to 1984). The
base level was called Best Practicable
Control Technology Currently
Available (BPCTCA), or simply
BPT. The more stringent level
was termed the Best Available Tech-
nology Economically Achievable
(BATEA), and  is usually referred
to as BAT. In  addition, special
standards  known as New Source
Performance Standards (NSPS)
were to be established for new plants.
                                   "The language of the legislation refers to
                                    "discharge to navigable waters."
Although the BPT and BAT standards
were intended for national com-
pliance, regardless of location,
they are actually minimum standards.
If the BPT pollution control
techniques applied by all sources
discharging to waterways are
inadequate to meet the established
water quality standards for a
stream, both EPA and the State
are required to impose even
stricter pollution control require-
ments. In all cases, the State
is authorized to impose requirements
more stringent than the Federal
guidelines.

The National Resources Defense
Council (NRDC) et al. sued EPA
for not fulfilling its obligation
under the 1972 FWPCA amend-
ments, and in 1976 EPA agreed
to concentrate attention on
potentially toxic substances using
technology-based standards. The
agreement, called the NRDC Consent
Decree or the Settlement Agreement,
required as much control of
toxic pollutants as technologically
feasible by including toxic substances
in  the standards to be issued
for individual industries.

The NRDC  Consent Decree com-
mitted EPA to a schedule for
developing BAT effluent limits for
21 major industries—including
electroplating—covering 65 recog-
nized classes of toxic substances.
EPA has further classified these
65 categories into 129 specific
substances.

In  1977 the provisions of the
NRDC  Consent Decree and other
changes were incorporated
in  further amendments to the
FWPCA. These amendments,
known as the Clean Water Act of
1977  (Public Law 95-217),
included  increased emphasis on the
control of toxic pollutants and
specific provisions for the control
of industrial wastes discharged
to  publicly owned treatment
works (POTW's). (Plants dis-
charging  into  POTW's are often
referred to as indirect dischargers.)

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Table 1.

Summary of  Legislative Activities
    Year
                           Legislation
                                                                                   Effect
1972,
             Federal Water Pollution Control Act (FWPCA)
               Amendments (Public Law 92-500)
1976,
                                                    Required all industries discharging waste into waterways and municipal systems to
                                                      install a base level of pollution control technology (BPT) by July 1, 1977, Required
                                                      BAT by 1 983 (later revised to 1984—see Clean Water Act). Required new source
                                                      performance standards.
                                                    Established National Pollutant Discharge Elimination System  permit  program.
                                                      Required self-monitoring by plants discharging to navigable waters. Established
                                                      Federal control over municipal treatment plants.
                                                    Electroplating regulations were proposed under the act, but were suspended shortly
                                                      thereafter.

                                                    Committed EPA to schedule for developing BAT effluent limitations for 21 major in~
                                                      dustries  covering 65  recognized toxic substance classes (1 29 specific com-
                                                      pounds).
                                                    The Clean Water Act incorporated these parameters.

                                                    Established controls for disposal of all solid wastes. Defined hazardous solid wastes.
                                                      Established tests to determine if waste is hazardous.
                                                    Established standards for solid waste generators, storage facilities, and disposal
                                                      sites.  Required manifest system for transportation of hazardous wastes.
                                                    Regulations under the act were promulgated on May 19, 1980.

                                                    Amended FWPCA. Revised deadlines established under FWPCA.
                                                    Defined  classes of pollutants as toxic, conventional, and nonconventionel. Placed
                                                      major emphasis on the toxic compounds  associated with the NRDC Consent
                                                      Decree.
                                                    Linked pretreatment standards to BAT guidelines for toxics. Authorized publicly
                                                      owned treatment works to relax pretreatment standards under certain conditions.
                                                      Placed 1-year moratorium on industrial cost recovery.
                                                    Most electroplating regulations were promulgated under the act  on September 7,
                                                      1979, The  rest are scheduled for mid-1981,

             Toxic Substances Control Act (Public Law 94-   Can require extensive testing of chemicals by manufacturers. Can require premsrket
               469}                                    notification to  EPA of all new chemicals or mixtures. Can require maintenance of
                                                      records.
                                                    Can delay manufacture or marketing of new chemical products pending generation
                                                      of sufficient environmental information, C0n ban or restrict chemical marketing.

Note.—Earlier legislation included: 1956, Federal Water Pollution Control Act; 1965, Water Quality Act; 1966, Clean Water Restoration Act; 1970,
Water Quality Improvement Act.
1977.
             National Resource Defense Council (NRDC)
               Consent Decree (NRDC et al. vs. Train!
             Resource  Conservation  and  Recovery Act
               (Public Law 94-580}
             Clean Water Act (Public Law 92-217}
The Clean  Water Act

The goals of the Clean Water Act
of 1977 were identical to those
originally defined in the  1972
FWPCA amendments,  which
called for:

•  Eliminating the discharge of
   pollutants to waterways by 1985
•  Providing for fishable,  swim-
   mable waters by 1983
»  Eliminating the hazards of toxic
   compounds

The three levels of control—BPT,
BAT, and NSPS—were retained, but
                                        many changes were made. For
                                        example, the Clean Water Act:

                                        ®  Defined three classes of
                                           pollutants—toxic, conventional,
                                           and nonconventional.
                                        •  Revised deadlines.
                                        »  Required  EPA to address the
                                           65 classes of pollutants (129
                                           specific substances) for both
                                           direct and indirect dischargers,
                                        •  Authorized POTW's to relax
                                           pretreatment standards if it could
                                           be shown that no detrimental
                                           effects  on the POTWs treatment
                                           levels would  result.

                                        The Clean Water Act identifies the
                                        same 65 compounds that were
                                        associated with the NRDC Consent
                                        Decree,  These toxic pollutants
are subject to effluent limits
that result from applying  BAT regu-
lations.  BAT  is to be installed no
later than July 1, 1984, by industries
directly  discharging to waterways.
For all other  toxic substances
subsequently added to the  list,
plants must comply with  BAT limits
no later than 3  years after the limit
is established.  Regulations, or
effluent  limits, for direct dischargers
are expected to be  determined by
EPA during 1980 to allow industries
time to  install the appropriate
technologies; however, it is unlikely
that the BAT regulations for
electroplating will be promulgated
before mid-1981.

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Table 2,

Best Practicable Control Technology Currently Available Effluent Limitations3 (Suspended Indefinitely11): Subparts A
and D-F

Effluent

Pollutant jib/106 ft2/operation):
Nickel 	 	
Chromium:
Total 	
Cr+6 . , .....

Cyanide:
Total , ....
Amenable ..,.,.,..,.,,,...

Cadmium ....... ,,,.»..

Iron 	 	 ....
Tin


pH


Subpart
Daily
maximum
32 7
32.7
32 7
3 3
32 7
32.7
	 3.3
1 308
. . . 1 9.2
32 7
65 4
65 4
654
1,308
60-9 5


A
30- d
average
16 4
164
164
1 6
16 4
164
1 6
654
9 6
164
32 7
32 7
32 7
654
8 0-9 5


Subpart
Daily
maximum
18 4
18 4
184
1 8
184
184
1 8
738
8 8
(«)
36 8
36 8
36 8
738
6 0-9 5

Effluen
D
30-d
average
9 2
9 2
9 2
9 2
92
9 2
9 2
369
44
,d.
184
184
18 4
369
6 0-9 5

t limits
Subpart
Daily
maximum
164
16 4
164
1 6
164
164
1 6
646
9 8
(d)
32 8
32 8
32 8
646
6 0-9 5


£
30-d
average
3 2
8 2
8 2
0 82
8 2
8 2
0 82
323
4 9
rt
164
164
164
323
6 0-9 5


Subpart
Daily
maximum
24 6
24 6
24 6
2 4
24 6
24 6
3 8
984
14 8
rt
49 2
49 2
49 2
984
B 0-9 5


F
30-d
average
12 3
12 3
12 3
1 2
123
12 3
1 9
492
7 4
,d>
24 6
24 6
24 6
492
6 0-9 5

"Plants employing more than 11 persons, discharging more than 2.061 gal/hfrom metal finishing processes, or having a production rate greater than
 52.7 ft2/h per employee.

 Although these regulations were suspended and are not in effect, they may be used by permit writers as guidance.

cDescribed in Table 5.

dNot applicable.

SOURCES: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards; Electroplating Point Source Category; Pretreatment Standards
for Existing Sources," Federal Register 44(1 75):52590-52629, Sept. 7, 1979. U.S. Environmental Protection Agency, "Effluent Guidelines and
Standards, Electroplating Point Source Category, Pretreatment Standards for Existing Sources," Federal Register 44{191 ):56330-56333, Oct. 1, 1979,
U.S. Environmental Protection Agency, "Effluent Guidelines and Standards, Electroplating Point Source Category, Pretreatment Standards for Existing
Sources; Correction," Federal Register 45f59):19245-19246, Mar. 25, 1980.
The control of pollutants defined as
conventional beyond BPT was
made subject to a cost-to-benefit
analysis to determine if any
additional reduction was warranted.
The conventional pollutants
are biochemical oxygen demand
(BOD), total suspended solids
fTSS), oil and grease, and pH.
This part of the !aw reflected
Congress' feeling that BPT might be
sufficient for these pollutants.

Nonconventional pollutants  are all
pollutants that are neither con-
ventional nor toxic.

Another change from the 1972
FWPCA amendments is the
innovative technology  extension
covered in Section 301 (k) of the
Clean Water Act. Congress,
wishing to encourage wastewater
reuse and recycling as well as
other innovations, provided an
opportunity for temporary relief from
some guidelines to facilities
interested in pursuing innovative
control techniques. Thus, Section
301 (k) permits an extension
of the BAT  requirements for both
direct and indirect discharging
industrial sources using innovative
technologies. The extension
can be granted until July 1, 1987,
if the technology will achieve
significantly greater effluent
reduction than BAT at a similar cost,
or if it will allow compliance
with existing requirements at
significantly reduced costs. In either
case, the system must have potential
for industrywide application.
Guidelines governing the extension,
although not yet established,
will include the application
mechanism and general require-
ments for identifying when a
technology is considered innovative.

The National Pollutant Discharge
Elimination System (NPDES)
permit has  been the heart of the
regulation and enforcement system
since the passage of the 1972
FWPCA amendments, and it
continues  in that role under the
Clean Water Act.  Under NPDES
provisions,  each point source dis-
charging into a waterway must

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apply for a permit either through
the State (if the State has an
EPA-approved permit program) or
through EPA, A manufacturer or
municipality must obtain  a permit
detailing the pollutants that
may be discharged, a schedule
for compliance, monitoring
and reporting requirements, and the
period (not to exceed 5 years)
for which the permit applies,

The Federal Government has authority
to ensure compliance with the
conditions of the permit, if viola-
tions of State-issued permits are
not followed by appropriate
enforcement action, EPA can initiate
its own action  after 30 days' notice,
The  law further states that any
person who willfully or negligently
violates any permit condition
shall be punished by a fine of not
more than $25,000, by imprisonment
for not more than 8 months,  or
by both. In this case, "person" is
interpreted to mean any responsible
corporate officer.

To provide regulatory officials
with sufficient  information for
establishing effluent standards, and
to maintain information on the
amounts of pollutants being
discharged, the law allows EPA to
require that a manufacturing facility
monitor its own wastes in a  manner
to be specified by EPA, The
manufacturer must keep adequate
records, to be  provided to EPA
on request or on an established
schedule.  Self-monitoring plays
an important part in the implementa-
tion of controls on manufacturers.

EPA also has the right, on presenta-
tion of appropriate credentials,
to visit any manufacturing site,
to examine records, to check
sampling and monitoring equipment,
and  to take any samples required
for checking the results sub-
mitted by  the manufacturer.  The
information gathered becomes
public, unless trade secrets
or proprietary information would
be revealed in the process, In
cases of this kind, provisions are
made to allow access only to regula-
Table 3,

Best Practicable Control Technology Currently Available Effluent Limitations8
(Suspended Indefinitely15):  Subpart Bc

Effluent characteristic
Pollutant (lb/1 Oe ft2/operat!on):
Silver, 	 	
Gold 	 	
Cyanide:
Tata! 	 . , . , , , , , .

Chromium;
Total 	 	
Cr+s ... 	 	 	 	
indium. ,»,.,,..»-....»,,.»...,,.»».,*,*,.„.*.....







pH 	 	 , 	 	

Effluent
Daily
3.3
. . 	 ... 3.3
	 	 3.3
	 	 32.7
	 32.7
	 	 3,3
3,3
3.3
3.3
	 ..... 3.3
3.3
3.3
	 	 65,4
	 1 ,308
6.0-9.5

limits
30-d
average
1.6
1.6
1.6
16.4
16.4
1.6
1.6
1.6
1.6
1.8
1.6
1.6
32.7
654
6.0-9.5

aPlants employing more than 11 persons, discharging more than 2,081 gal/h from metal finishing
 processes, or having a production rate greater than 52,.7 ft2/h per employee,

bAlthough these regulations were suspended and are not in effect, they may be used by permit
 writers as guidance.

eDescribed in Table 5.

SOURCES: U.S.  Environmental Protection Agency, "Effluent Guidelines and Standards; Electro-
plating Point Source Category; Pretreatment Standards for Existing Sources," Federal fisgister
44f175):52590-52629, Sept. 7, 1979. U.S. Environmental Protection Agency, "Effluent Guidelines
and Standards, Electroplating Paint Source Category, Pretreatment Standards for Existing
Sources," Federal Register 44(191 ):56330-56333,  Oct. 1, 1979. U.S. Environmental Protection
Agency, "Effluent Guidelines and  Standards, Electroplating Point Source Category, Pretreatment
Standards for Existing Sources; Correction," federal Register 45(59): 19245-19246, Mar. 25,1980,
tory officials, (By law, however,
effluent data cannot be considered
proprietary.) Several State and
local governments also have
many of the foregoing authorities,


Applications to  Electro-
          Discharging
Directly  to Waterways

The pretreatment regulations
published on September 7, 1979,1
included effluent guidelines
representing EPA's best estimate
of BPT for direct dischargers, but
footnotes to the relevant sections
indicated that these regulations
have been suspended indefinitely.
The published BPT values (Tables 2
through 4), therefore, are not
enforceable until EPA repromulgates
the direct discharge sections.

Lacking national regulations
for direct dischargers, permit writers
will use their own best judgment
in issuing permits to plants in
the industry subparts1 shown in
Table 5.  Many permit writers,
however, will use one of the
following as guidance:

•  The national  pretreatment
   standards for indirect dischargers
   (discussed in the next subsection)
•  The suspended BPT regulations
   (Tables 2 through 4)

BAT regulations are in  preparation,
but are not expected to be pro-
mulgated until 1981,

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Tal>ie 4,                                                                       National  Pretreatment
Best Practicable Control Technology Currently Available Effluent Limitations8   Standards for Indirect
(Suspended Indefinitely"): Subparts A, B, and D-FC                            Dischargers

                                                                               The Clean Water Act directed
                                                                               EPA to set pretreatment requirements
                                                                               for untreated industry wastewaters
                                                                               suspected of containing toxic
                                                                               pollutants in significant amounts.
                                                                               EPA was also directed to  include
                                                                               provisions for considering the
                                                                               amount  of pollutants removed by
                                                                               POTW's. In  response to this
                                                                               directive, EPA has issued  two sets
                                                                               of regulations that apply to elec-
                                                                               troplaters:

                                                                               «  General pretreatment regula-
                                                                                  tions2'3 set forth the general
                                                                                  administrative requirements for
                                                                                  POTW's,  States, and the
                                                                                  involved industries. They outline
                                                                                  how the regulations will  take
                                                                                  into account (through removal
                                                                                  allowances) pollutants  removed
                                                                                  by the POTW.
                                                                               •  Pretreatment standards for
                                                                                  electroplated -4~6 set specific
                                                                                  levels that electroplaters
                                                                                  must  meet,

Effluent
characteristic


Cyanide (lb/106 ft2/
operation):
Amenable. . . .
Total 	

pH , ....


Subparts
A and B
Daily 30-d
maximum average


3.3 1.6
327 164

6 0-9 0 6 0-9 0

Effluent limits
Subparts
D and F
Daily 30-d
maximum average


1.8 0,92
184 92

6 0-9 0 6 0-9 0


Subpart E
Daily 30-d
maximum average


1 .6 0.82
164 82

6 0-9 0 6 0-9 0

"Plants employing less than 11 persons, discharging less than 2,061 gal/h from metal finishing
 processes, or having a production rate less than 52.7 ft^/h per employee.

bAlthough these regulations were suspended and are not in effect, they may be used by permit writers
 as guidance.

"Described in Table 5.

SOURCES: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards; Electro-
plating Point Source Category; Pretreatment Standards for Existing Sources," Federal Register
44(175):52590-52629, Sept. 7, 1979. U.S. Environmental Protection Agency, "Effluent Guidelines
and Standards, Electroplating Point Source Category, Pretreatment Standards for Existing
Sources," Federal Register 44C\9t):5633Q-$6333, Oct. 1, 1979. U.S. Environmental Protection
Agency, "Effluent Guidelines and Standards, Electroplating Point Source Category, Pretreatment
Standards for Existing Sources; Corrections," Federal Register 45(59):! 9245-19246, Mar. 25,1980.
Table B.
EPA Classification of Electroplating industry
  Subpart
                                        Description
            Electroplating of common metals (Al, Cd, Cu, Cr, Fe, Ni, Sn, Pb, Zn, and any combina-
             tion}
            Electroplating of precious metals (Au, In,  Pt, Rh, and Agj
            Electroplating of specialty metals
            Anodizing (anodizing, acid cleaning, and  alkaline cleaning)
            Coatings (coloring, chromating, phosphating, stripping, immersion plating, acid
             cleaning, and alkaline cleaning)
            Chemical etching and milling (chemical milling, etching, bright dipping, acid clean-
             ing, and alkaline cleaning)
            Electroless plating
            Printed circuit board manufacturing
B	
C	
D	
E	
 Note.—Subparts A, B, and C may involve stripping, coloring, phosphating, acid cleaning, and
 alkaline cleaning.

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

General pretreatment regulations
apply to all industrial pollutants
introduced in any way into a POTW.
These regulations were promulgated
on June 26, 197S,2 went into
effect 60 days later, and were modi-
fied and clarified on October 29,
1979.3 They were  intended to:

• Prevent the  introduction into
   a POTW of pollutants that will
   interfere with  its operation,
» Prevent the  introduction into
   a POTW of pollutants that will
   pass through or otherwise
   be incompatible with the
   treatment works.
» Improve opportunities to recycle
   and reclaim municipal and
   industrial wastewaters and
   sludges.
6

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In this context, inhibition or dis-
ruption of a POTW's sewer system,
treatment processes, or operations
constitutes "interference" if it
contributes to a violation of any
requirements of the POTW's
NPDES permit. The term includes
interference with the POTW's ability
to dispose of its sewage sludge.

The general pretreatment regu-
lations specify responsibilities
to EPA, the States,  POTW's,
and industrial dischargers to
POTW's;  they also detail require-
ments for obtaining removal
allowances,

Important Aspects for Electroplaters.
Industries discharging to munici-
palities are required to do one of
the following:

•  Meet the specific pretreatment
   limits set by EPA for the industry,
»  Obtain a more lenient requirement
   through a removal allowance,
   which  must be obtained  for
   the industry by the municipality,
•  In special cases, where qualified,
   obtain a "fundamentally
   different" variance,

The plater who meets the specific
pretreatment guidelines for
electroplaters need not be concerned
with the second or  third items.

Variance Application, In some cases,
information that may affect an
industry's pretreatment standards
will not have been considered
when the standards were developed.
If it is believed that a particular
situation  is fundamentally different
from that considered in devel-
oping the standards, a variance may
be requested. Requests will
be approved only if:

•  Factors relating to the industrial
   user are fundamentally different
   from those considered by EPA
   in establishing  the standard,
   and these factors greatly
   increase cost.
»  The factors existed before
   EPA promulgated the standard.
Rinse for nonbrass metals
A request for a variance and
supporting evidence must be sub-
mitted in writing to the NPDES
State director or to EPA's Enforce-
ment Division Director within 90
days after promulgation.  If the
request for variance is rejected,
there are provisions for appeal to
the EPA Administrator; if it is
approved, a new discharge limit
will be imposed. General pretreat-
ment regulations are expected
to be amended by August 1980,
after which time the 90-day
time limit will apply.

Three aspects of the variance
application approach should be
stressed:

»  Some control will still be required,
•  The variance will be given
   only for a set period of time and
   must be renewed. Renewal
   will not be automatic.
•  If the variance is denied,
   the original 3-year time limit
   for compliance still holds.

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Removal Allowances. The removal
allowance offers the most likely
approach to obtaining relief
from the pretreatment requirements.
By this mechanism EPA exercises
its authority under the Clean Water
Act to consider the removal of
pollutants by the PQTW.

The removal allowance plan
states that, under specified condi-
tions, a POTW may revise a plant's
discharge limits for a pollutant
if it can be shown that the POTW
is removing an amount of pollutant
equal to the amount of the revision.
The revision must be applied for
by the municipality and basically
requires a demonstration, through
actual data, that the pollutant
is being removed. The concentration
limit would be revised by:
       v
Y =
Table 6.

Pretreatment Standards for Existing Sources: Subparts A, B, and D-Ha
     1 -r

where

Y= revised discharge limit
x — concentration required by
     specific standards for electro-
     platers
 r= demonstrated removal fraction

For example, if the data show
60 percent POTW removal of a
specific pollutant (by the EPA-
specified sampling methods), a pol-
lutant with an initial requirement of
2 mg/l would be revised to:
1 -0.6
        = 5 mg/l
EPA specifies that the influent and
effluent data taken over the municipal
treatment system shall be derived
from a minimum of  12 samples
taken at approximately equal
intervals throughout the year. Where
composite sampling is appropriate,
the time intervals between samples
for the composite cannot exceed
2 hours, and the minimum sampling
period must be 24 hours. Flow
proportioning is required, and
the effluent samples must be taken
over a time span equal to the
time the influent was retained in
the  municipal system after it
was sampled.
Pollutant
Plants discharging <10,000 gal/d:
Lead 	 , ... , . . .

Plants discharging >10,OOO gal/d (Alternative 1bJ;
Cyanide total 	 ........ , . „ ,

Nickel
Chromium . , 	 , , , . . ,
Zinc 	 .,,.,,,,,,..»,,,,,.,,,,..,,,„.,,,,,.,,,
Lead .... . , , , 	 ...
Cadmium , 	 , , , . , . ....
Silver0
All metals ,.,«.,... 	

Pretreatment
standard (mg/l)
Daily
maximum
	 50
	 0.6
1 2
	 1,9
4 5
4 1
	 7,0
	 4.2
0 6
	 12
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
"Described in Table 5.

bMass-based standards,

'Applies only to Subpart B.

SOURCES: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards; Electro-
plating Point Source Category; Pretreatment Standards for Existing Sources," Federal Register
44(175):52590-52629, Sept. 7, 1979. U.S. Environmental Protection Agency, "Effluent
Guidelines and Standards, Electroplating Point Source Category, Pretreatment Standards for
Existing Sources," Federal Register 44{191):56330-56333, Oct.1, 1979, U.S.  Environmental
Protection Agency, "Effluent Guidelines and Standards, Electroplating Point Source Category, Pre-
treatment Standards for Existing Sources; Correction," Federal Register 45(59):19245-19246,
Mar. 25, 1980. U.S. Environmental Protection Agency, "Electroplating Point Source Category,
Effluent Guidelines and Standards, Pretreatment Standards for Existing Sources," federal Register,
in preparation, 1980.
 When sampling is for pollutants,
 such as cyanide, that cannot be
 held for long periods before
 analysis, grab samples can be used.

 Consistent removal (r in the
 foregoing  equation) is to be that
 level of removal demonstrated by
 averaging  the lowest 50 percent
 of the removals measured by
 12 or more samples. (This require-
 ment is a  change from the initial
 regulations.)

 To prevent dischargers from meeting
 required concentrations by
 dilution with nonregulated water,
 the regulations require that the
concentration at which the dis-
charger is regulated be corrected
for this dilution. Thus,
Y =
                                                                               X-F
where
 X = the specified requirement for
     the pollutant
 F = the flow of regulated waste-
     water
F, = the combined flow of un-
     regulated and regulated water

Similarly, the regulated value based
on a consistent removal will be
reduced for a facility that bypasses
its treatment system when dis-
charging to a municipality, to account

-------
for the bypassing. The value
is reduced by multiplying by:

8,760 - Z
  8,760
where

8,760 = number of hours in a year
     Z = number of hours treatment
         system bypassed per year

Certain conditions must be met
before a municipality can receive a
removal allowance for its industrial
users. Of major importance, the
removal allowance must not cause
the municipality to violate its
NPDES permit,  or the disposal
of the municipal sludge must
not be  impaired.

Before the general pretreatment
regulations were revised (on
October 29, 1979), it was also
specified that the municipality apply-
ing for a removal allowance must
have an approved pretreatment
program. It is likely,  however,
that many municipalities will be
unable to comply with this require-
ment in time for industries to
meet their deadlines; therefore,
the revised regulations provide for
a conditional removal allowance
for plants discharging to municipali-
ties that intend to have pretreatment
programs.
Specific Pretreatment Standards
for Electroplaters

EPA promulgated pretreatment
standards for electroplaters
on September 7, 1979.1 Corrections
were printed on  October 1, 1979,4
and March 25, 1980,5 and further
corrections will be in print shortly,6
The industry was categorized to
determine whether any of the
categories (subpatts) should have
pretreatment standards different
from the others. The regulations apply
to all subparts (listed in Table 5).
Table 7.

Pretreatment Standards for Existing Sources:3 Alternative 1b—Subparts A, B,
and D-HG
Pretreatment standard*1 (lb/106 ftz/operation)
Pollutant
Silver


Nickel






Subparts
A and D-G
Daiiy 4-d
maximum average
(") (1
1S.2 8
36 21 .5
32,8 20.5
55.9 32
33.6 20.9
4.7 3.3
9,6 5,9
84 54 7

Subpart
Daily
maximum
9.6
15.2
36
32.8
55,9
33.6
4.7
9.8
84
B
4-d
average
5.9
8
21.5
20.5
32
20.9
3.3
5.9
54.7
Subpart
Daily
maximum
rt
13.7
82.1
74.8
127.6
76.6
10.8
21.9
191,5
H
4-d
average
(1
18.2
49.4
46.9
73.1
47.5
7,4
13.3
124.7
"Plants discharging more than 10,000 gal/d.

bMass-based standards. Equivalent to and may apply in place of standards shown in Table 6 on
 agreement between source and receiving POTW.

Described in Table 5.

dNot applicable.

SOURCES: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards, Electro-
plating Point Source Category, Pretreatment Standards for Existing Sources," Federal Register
44(191 );56330-56333, Oct. 1, 1979. U.S. Environmental Protection Agency, "Effluent Guidelines
and Standards, Electroplating Point Source Category, Pretreatment Standards for Existing
Sources; Correction," Federal Register 45(59):19245-19246, Mar. 25, 1980. U.S. Environmental
Protection Agency, "Electroplating Point Source Category, Effluent Guidelines and Standards.
Pretreatment Standards for Existing Sources," Federal Register, in preparation, 1980,
Table 6 gives the concentration-
based limits for existing electroplat-
ing facilities,*5 More lenient
standards were adopted for plants
discharging  less than 10,000 gal/d
(38,000 l/d). For plants discharging
more than 10,000 gal/d (38,000
l/d), two alternative sets of
standards can be adopted on
agreement between the POTW
and the industrial user.
Alternative 1 is mass-based
limits (Table 7} that relate the
allowable discharge of a pollutant
to the quantity of work processed
in terms of surface area and the
number of plating operations per-
formed. A plating operation is defined
as any step in  metal finishing that
is followed by a rinsing step.
An electroplater using Alternative 1
is eligible for POTW removal
credits. Credit  also can be taken
for any significant levels of  the
regulated pollutants in the intake
water.
                                       Although EPA may specify more stringent
                                       pretreatment requirements in future, the new
                                       level is not directly tied to BAT for direct
                                       dischargers because other conditions (such as
                                       lack of space) will be part of the pretreat-
                                       ment evaluation.

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Table 8.

Pretreatment Standards for Existing Sources:8 Alternative 2b—Subparts A, B,
and D-HC
                                                             Pretreatment standard
                          Effluent
                        characteristic
                                                               Daily
                                                             maximum
             4-d
           average
Pollutant (mg/l):
    Cyanide, total	
    Lead	
    Cadmium	
    Total suspended solids.
pH.
    1.9        1.0
    0.6        0.4
    1,2        0.7
   20.0       13.4
7.5-10.0    7.5-10.0
"Plants discharging more than 10,000 gal/d.

 Simplified standards. An optional control program that may be selected by the source with
 concurrence of the control authority. Requires the absence of strong chelating agents, reduction of
 hexavalent chromium, and neutralization with CaO or Ca(OH)2.

"Described in Table 5,

SOURCES: U.S. Environmental Protection Agency, "Effluent Guidelines and Standards, Electro-
plating Point Source Category, Pretreatment Standards for Existing Sources," Federal Register
44(191):56330-56333, Oct. 1, 1979. U.S. Environmental Protection Agency, "Effluent Guidelines
and Standards, Electroplating Point Source Category, Pretreatment Standards for Existing Sources;
Correction," Federal Register 45(59):1 9245-1 9246, Mar. 25, 1980. U.S. Environmental Pro-
tection Agency, "Electroplating Point Source Category, Effluent Guidelines and Standards,
Pretreatment Standards for Existing Sources," Federal Register, in preparation, 1980.
Alternative 2 (Table 8) is designed
to minimize the cost of monitoring
the wastewater discharge. This
standard replaces the limits
on the level of copper, nickel,
chromium, zinc, and total metals
by limits on TSS and pH, Users
of this alternative must reduce
hexavalent chromium to its trivalent
state and must neutralize the
wastewater with  lime [CaO or
CajOH)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.
 10

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3.  Water Pollution
Control Technologies
Selecting a System

To select a wastewater treatment
system for compliance with water
pollution control regulations,
the following factors should be
considered:

» The system's reliability to
  remove pollutants to the levels
  specified in the discharge permit
• The initial cost to install the
  system
• The day-to-day costs of operating
  the system (labor, utility,
  treatment reagents, and sludge
  disposal costs)

An  additional factor is whether
the system can be modified to
comply with any future regulations
calling for increased pollutant
removal efficiencies.

The procedure for selecting a
treatment process entails the follow-
ing general tasks:

•  Performing field investigations
  to define the waste stream
  parameters (flow rate, pollutant
  types, wastewater variability)
• Developing conceptual models of
  proposed treatment processes
  based on the field investigation
» Conducting bench-scale
  treatability studies on wastewater
  samples to simulate the pro-
  posed processes
» Using results of the treatability
  studies to assess the ability
  of the proposed systems to
  meet discharge requirements
» Using data from the treatability
  study assessment to determine
  design parameters needed
  to specify a full-size system
»  Estimating the cost to install
  and operate the proposed system,
  based on the design parameters
  needed for adequate pollutant
  removal and on vendor quotations
  for the equipment specified
The major influences on the
investment needed for a wastewater
treatment system are:
•  Unit operations required,
   for example, chromium reduction,
   cyanide oxidation, and neu-
   tralization
•  Volumetric flow of wastewater,
   which determines the size
   requirements of the different
   processing units

Most waste streams generated in
the electroplating industry  can
be treated by simple alkali neutraliza-
tion to adjust the wastewater pH
and thereby reduce  the solubility of
the dissolved metals. This  step
must be followed by solids separation
to remove the suspended solids
and precipitated metals. Additional
treatment steps are  typically
required for plants employing
chromium or cyanide plating
processes or plating solutions con-
taining strong chelating compounds,
Waste  streams from these  oper-
ations must be treated  before they
are mixed with the combined
wastewater streams that feed the
central alkali precipitation  process.

Once a specified treatment
system is installed,  many of the
operating costs, such as labor
requirements and electrical
consumption, are fixed. Costs for
treatment chemicals and solid
waste disposal vary, however, and
depend primarily on the mass
flow of pollutants and the  flow
rate of wastewater.  Consequently,
before  a treatment system  is
selected, it is important to evaluate
options available for reducing
the volume of wastewater  and for
reducing or eliminating the entry
of pollutants into the wastewater.
Incorporating waste-reduction
modifications in the plating
process can significantly reduce the
investment for treatment system
installation and can reduce
operating cost after installation. If
installing a recovery process
reduces the investment needed for
treatment hardware, in some cases
the saving  will make the invest-
ment in the recovery process
cost effective.
                                                                                                    11

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Resource Recovery and
Pollutant Load Reduction
Modifications

Pollution control legislation has
affected industry by increasing
the economic penalty associated
with inefficient use of raw materials.
In the plating industry, for example,
loss of a raw material in the
wastewater can result in three
distinct cost items: replacement
of the material, removal of the
material from the wastewater before
discharge,  and disposal of the
residue. Similar cost items exist
for process water: replacement
of water (no longer inexpensive
to purchase) used in processing,
processing the water in the waste-
water treatment system, and
processing the water by the POTW
after discharge into a sewer system.

In response to the increased
cost of raw material  losses, plating
shops are modifying their processes
to reduce these losses as well
as water consumption. Recent years
also have seen the cost-effective
application of various separation
processes  that reclaim plating
chemicals  from rinse waters,
enabling both the raw material and
the water to be reused.

The impact of resource recovery
and pollutant load reduction
modifications on  waste treatment
and solid waste disposal costs must
be measured if these modifications
are to be evaluated. Cost of
sophisticated treatment necessary
for electroplating wastewater and of
residue disposal often provides
a significant economic incentive
for resource recovery.

Case History 1  in Section 4 high-
lights the  significance of the
foregoing  cost factors. If the
evaporator installation were justified
only by the value of the chromium
recovered, the investment would
appear to  result in a significant
loss. If reduced pollution control
costs were included, a net profit
would result, but the investment
still would not be very lucrative.
Use of rapid write-off techniques
allowed for pollution control
equipment, however, would result in
a payback of just under 3 years,
a rate acceptable for most companies.
Section 6 describes in detail
some tax benefits and Federal
programs that facilitate pollution-
control-oriented capital projects.

Modifications for reducing the
pollutant or wastewater  loading
on a treatment  facility range
from using flow restrictors to
eliminate excess dilution in rinse
tanks to installing  recovery units,
such as reverse osmosis and
evaporation, to  separate plating
chemicals from rinse water for
recycle to the plating bath. Actions
that can minimize  wastewater
volume include:

• Implementing rigorous house-
   keeping practices to locate
   and repair water leaks quickly
• Employing multiple counterflow
   rinse tanks to reduce rinse
   water use substantially
• Employing spray rinses to
   minimize rinse water use
« Using conductivity cells to avoid
   excess dilution  in the rinse tanks
• Installing flow regulators
   to minimize  water use
• Reusing contaminated rinse water
   and treated wastewater where
   feasible

Steps to minimize pollutant
loading include:

• Implementing a rigorous house-
   keeping program to locate
   and repair leaks around process
   baths, replacing faulty insula-
   tion on  plating  racks to prevent
   excessive solution drag-out,
   installing drip trays where needed,
   and so forth
 • Using spray  rinses or air knives
   to minimize  solution  drag-out
   from plating baths
•  Recycling rinse water to
   plating bath to compensate for
   surface evaporation losses (see
   Section 4, Case History 2)
•  Using spent process solutions
   as wastewater treatment
   reagents (acid and alkaline
   cleaning baths are obvious ex-
   amples)
•  Using minimum process bath
   chemical concentrations
•  Installing recovery processes to
   reclaim plating chemicals from
   rinse waters for recycle to the
   plating bath
•  Using process bath purification
   to control the level of impurities
   and prolong the bath's service life

Closed-loop chemical recovery
from a rinse stream (as shown in
Case History 1) can often provide the
solution to handling wastes that
are difficult or expensive to
treat. Applying a closed-loop recovery
system to a plating operation
eliminates the need to treat the
rinse water normally associated with
that step.

In the case of rinse streams
requiring pretreatment (for example,
cyanide or chromium) or rinses
containing pollutants  not effectively
removed by conventional end-of-pipe
technology (for example,  some
types of complexed metals),
installing a closed-loop system
to recycle the rinse may reduce the
investment needed to comply
with the effluent quality limitations.
A small-volume purge stream will
result from closed-loop operation,
but treatment or disposal  of this
stream should not be a major
expense.

EPA has funded research  into
assessing the effectiveness of
methods for recovering plating
materials for reuse in the  plating
process. Reports from this research
are available in the following
subject areas:

® General7"12
• Evaporation13-14
• Reverse osmosis15-19
• Electrodialysis20'21
 12

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   Chrome wasle
        ALIC)
        SO
                                                     Wastewater
                                                     discharge
                                                                                    CLARIFICATION
                                                                                             Solid waste
                                                                                             disposal
                       CYANIDE
                       OXIDATION
                    S = sulfonator
                    C = chlorinator
                  ORP = oxidation reduction potential
Figure 1,

Electroplating Industry Conventional Wastewater Treatment
Conventional Wastewater
Treatment

The pollutant discharge levels called
for in the pretreatment regulations
were  based on the performance
of numerous electroplating
wastewater treatment systems
observed by EPA contractors. Most
plating shops employ a conventional
wastewater treatment process
to remove pollutants from the
discharge.

Conventional wastewater treatment
in the electroplating  industry
consists of the following unit
processes (Figure 1):

» Chromium reduction (if needed)
  of segregated chromium waste
  streams to reduce the chromium
  from its hexavalent form
  to the trivalent state, which then
  can be precipitated as chromium
hydroxide by alkali neutrali-
zation
Cyanide oxidation (if needed)
of segregated cyanide-bearing
waste streams to oxidize the
toxic cyanides to harmless carbon
and nitrogen compounds
Neutralization of the combined
metal-bearing wastewaters, acid/
alkali wastewaters, strong
chemical dumps, and the effluent
from the cyanide and chromium
treatment systems to adjust
the pH within acceptable
discharge limits and precipitate
the dissolved heavy metals
as metal hydroxides
Clarification where flocculating/
coagulating chemicals are added
to promote the initial settling
of the precipitated metal
hydroxides
• Gravity thickening over extended
  time to increase solids content
  of sludge before disposal

These unit processes provide
effective, reliable treatment for many
electroplating waste streams. That
is not to say, however, that such
treatment is suitable for all appli-
cations  or that the "normal"  design
parameters (retention time, reagent
dosage, and so forth) will provide
effective pollutant removal from
every individual plater's waste-
water discharge, Treatabiltty
studies  are needed to assess the
applicability of a treatment
process to a specific wastewater.
Case History 3, in Section 4,
discusses a system  that employs
conventional treatment, but
uses stream segregation to achieve
the pollutant levels  called for
in the discharge permit.
                                                                                                     13

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Alternative  Methods of
Treatment

Several alternative treatment
processes have been developed to
overcome the problems encountered
in treating many waste streams
in the conventional manner.
The most attention has been  given
the frequent inability of the
hydroxide neutralization/metal
precipitation process to reduce
the solubility of dissolved metals to
the low levels required for discharge
of the waste stream. The problem
arises because  many plating
wastewaters contain compounds
that interact with dissolved metals
and interfere with their precipitation
as metal hydroxides. Such com-
pounds as ammonia, phosphates,
tartrates, and EDTAC are commonly
used in plating operations and
consequently find their way
into the wastewater. These com-
pounds, called  chelates, combine
with the dissolved metal ion to form
a complexed ion that is relatively
soluble in neutral or slightly
alkaline solutions.

The means of overcoming the
solubilizing effects of chelating
agents can be grouped under two
categories:

« Precipitation/removal of the
   metal from solution by a method
   that, unlike hydroxide pre-
   cipitation,  is relatively immune
   to the chelating effects of  these
   compounds
• Pretreatment of the wastewater
   to free the metal ion from  the
   chelating agents

The first category  includes such
processes as sulfide precipitation,
water-insoluble starch xanthate
(ISX) precipitation, and ion exchange.
Sulfide precipitation, which
precipitates metals as sulfides
instead of hydroxides, has been
found capable of achieving low
levels of metal solubility in
highly chelated waste streams. The
process has been proven as an
alternative to hydroxide precipitation
or as a method for further reducing
the dissolved metal concentra-
tion in the effluent from a hydroxide
precipitation system. (See Section 4,
Case History 4.)

ISX precipitation can remove
heavy metal cations  from waste-
waters. The ISX acts as an ion
exchange material that removes
heavy metal ions  and replaces
them with sodium or magnesium
ions. Currently it is applied as an
alternative to hydroxide precipitation
or to "polish"  treated wastewater
to lower the residual metal con-
centration.  Because  it is insoluble
in water and its precipitation
reaction  rate is rapid, ISX is
used either as a slurry with the
stream to be treated or as a precoat
on a filter. The waste stream is then
passed through the filter cake.

Ion exchange, using resins that
have a strong selectivity for heavy
metal ions  (as opposed to the
calcium and sodium ions normally
present in the wastewater),  has
been proven effective in lowering the
metal concentration in the waste-
water discharge. (See Section 4,
Case History 5.)

Pretreatment of complexed
waste streams usually involves
segregating the waste streams and
either raising the pH to a highly
alkaline level (high pH lime treat-
ment) or lowering it to an acidic
condition. At these extreme
pH conditions, the metal complex
often dissociates, freeing the metal
ion, A suitable nontoxic soluble
cation (e.g., calcium) then can
be used to tie up the complex so
that it does not recombine with
the metal when the pH is readjusted.
This type of treatment will require
high reagent dosage, but has
been proven effective for treating
many complexed wastewaters.

In some cases, segregating a
difficult-to-treat waste stream,
precipitating the dissolved
metal at the ideal pH, separating the
precipitated solids, then diluting
this stream with the rest of the
wastewater before discharge
will reduce the concentration of the
metal to a level acceptable for
discharge. Lowering the volume
of the segregated waste stream can
keep costs at a minimum and
improve effectiveness.

Another frequent problem in waste-
water treatment is that metal
discharge requirements are not
being met, even though the level of
dissolved metals in the effluent
is low. In cases of this kind, the
solids separation component of the
process is allowing too much
suspended matter, including
precipitated metals, to pass into
the discharge. This condition can
result from overloading the clarifiers,
ineffective conditioning (coagulation
or flocculation) of the clarifier
feed, or poor pH control. Modifica-
tions that can correct the problem
include;

• Improved effectiveness of
   the conditioning system to
   produce a more settleable particle
• More reliable pH control
* Reduced volumetric load on
   the clarifier
« Use of a solids removal polishing
   device, such as a sand or mixed
   media filter, to lower the
   clarifier overflow turbidity level

Other wastewater treatment devel-
opments have included substitute
processes for chromium  reduction
(electrochemical reduction  is
an example), cyanide oxidation
(ozonation has been used, for
example), and others.
 cEthyienediaminetetraacetic acid.

 14

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Several treatment choices are
available to the plater, and proper
process selection and design will
ensure that the system can
meet the current discharge require-
ments, EPA has funded research
into assessing the cost and effective-
ness of many applicable wastewater
treatment techniques. Reports
are available as follows:

   General7'12-22'24
   Integrated  treatment25-26
   Sulfide precipitation27-28
   Cyanide waste treatment29"31
   Other32'35


Cost Implications of
Direct Wastewater
Discharge

Satisfying the pretreatment
requirements  for discharge to a
POTW often can result in a waste
stream suitable for direct discharge
to receiving waters. The advent
of POTW's using advanced
treatment processes has brought
significant increases in the sewer
fees charged to industrial firms
using the public system. If an outfall
is available, it might be possible
to reduce cost by avoiding the
system. Assuming the wastewater
BOD level is acceptable for
discharge,  it is not likely that any
of the residual pollutants will be
removed in the POTW,
   i-
   w
   o
   u
   z
      20
      15
10
                 Legend:
                        $2/1,000 gal sewei fee
                        $1/1,000 gal sewer Fee
                        $0.50/1,000 gal sewer fee
         0         600        1,200       1,800      2,400       3,000

                            DISCHARGE RATE (gal/h)

          Note.-—Based on operating time of 3,000 h/yr. Costs in 1979 dollars.
Figure 2.

Annual Sewer Fee as a Function of Flow Rate
Figure 2 presents the annual sewer
fee levied against a firm as a function
of its discharge rate over a range
of typical rate structures. This
                             fee represents the incentive to
                             consider direct discharge despite
                             the more stringent sampling
                             and reporting requirements
                             associated with the practice,
                                                                                                      15

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4. Water  Pollution
Control Case  Histories
Case History 1,  Economic
Evaluation of Evaporator
Installation

The Phillips Plating Company,
Phillips, Wisconsin,  installed a
75-gal/h (280-l/h) rising film
evaporator to concentrate the
chromium plating bath drag-out in
the rinse stream for recycle to the
plating bath. Installation of the
closed-loop recovery system reduced
the addition of anhydrous chromic
acid (Cr03) to the plating solution
by approximately 4 ib/h  (1.8 kg/h).
The total cost to  install the recovery
system was approximately $60,000.
(All costs are in  1979 dollars.)
Table 9 breaks down the operating
costs associated with the system
and the savings  achieved by
installing the unit.

Considering only the saving in
plating chemicals, the investment
would appear to  lose approximately
$9,000/yr.  If the analysis includes
the savings in treatment chemicals
(Phillips uses a Sulfex1* insoluble
sulfide treatment system) and
solid waste disposal charges
(based on disposal at 25 percent
solids by weight at a cost of
$0.19/gal of sludge), the saving is
an additional $28,400/yr. With
this added saving, the system
would pay for itself in just under
4 years. Taking advantage of
the investment tax credit and the
rapid write-off depreciation
allowance for pollution control
equipment, it was possible to reduce
the investment payback to under
3 years, a  most acceptable in-
vestment rate of return. The situation
at Phillips  Plating highlights
the need to consider these three
factors in evaluating chemical
recovery modifications.

The major operating cost for the
recovery system  is the cost of
energy used to supply steam to the
unit. In a closed-loop system of
the kind shown in Figure 3a, the rinse
                                     Table 9.

                                     Economic Evaluation for Evaporator Installation
                                                                  Item
                                                                                                     Amount
                                     Installed cost for 75-gal/h evaporator ($/yr)


                                     Annual costs at 6,000 h/yr ($/yr):
                                         Depreciation (10-yr life)	,	
                                         Taxes and insurance	
                                         Maintenance .	,...,....,..,.
                                         Labor (J4 h/shift at $6/h)	
                                         Utilities:
                                            Steam (at $3.50/106 Btu)	
                                            Electricity.	
                                         Genera! plant overhead	
                                           Total annual cost	

                                     Annual savings ($/yr):
                                         Replacement Cr03	
                                         Waste treatment reagents .
                                         Sludge disposal	
                                           Total annual savings, ,
                                     Net savings after tax ($)	,	
                                     Payback after tax (yr)	.»...„.,...,,,.....,,....
                                     Payback if 5% investment tax credit and 5-yr rapid write-off are used (yr)
                                                                60,000
                                                                 6,000
                                                                   600
                                                                 3,600
                                                                 2,250

                                                                15,000
                                                                   600
                                                                 2,600

                                                                30,650
                                                                21,600
                                                                23,000
                                                                 5,400

                                                                50,000

                                                                10,000
                                                                     3.8
                                                                     2.6
                                      Note.—Costs in 1979 dollars.
 16

-------
   (a)
           Drag-in
                 Drag-out (2 gal/h)
                                                                                             To process
   (b)
         Drag-in
Product flow
and drag-out
                                                                             To waste
                                                                             treatment
              Concentrate to
              plating baths
Figure 3.
Evaporative  Recovery Systems; (a) Closed Loop and (b) Open Loop
                                                                                                                  17

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rate, which equals the evaporative
duty,  must be sufficient to provide
adequate rinsing. If Phillips
were  to use an open-loop recovery
system in the first two rinse
tanks (Figure 3b) and were to use
the final rinse tank to ensure adequate
rinsing, the plant could still
achieve significant drag-out recovery.
This approach would significantly
reduce the steam costs and
also would require a smaller, less
expensive evaporator. Figure 4
combines the annual fixed and
variable operating costs for
different evaporator feed rates
and compares the resulting annual
costs with the saving the plant
would realize from recovered
chromium and lower pollution
control costs.
Case History 2. Automated
Direct Drag-out Recovery

The Gillette Company, Safety
Razor Division, in Boston, installed
an automated direct drag-out
   i—
   en
   o
   u
   (X
   O
   (3
   >
   <
   If)
       50
       40
       30
       20
       10
                                         Legpnd:
I  gross annual saving from
  resource recovery and
  reduced pollution control
  costs
I  annual costs (fixed plus
  variable operating costs}

L                  I
                           25                 50

                          EVAPORATOR FEED RATES (gal/h)

                           Note.—Costs in 1979 dollars.
                                                                                                      75
Figure 4.
Cost Versus Feed Rate for Open-Loop Evaporator System
   Workpiece
                                             Reverse osmosis
                                             water makeup
   Note.—UC— level indicator control
                                     Concentrated
                                     rinse sump
Figure i.
Automated Direct Drag-out Recovery
18

-------
recovery system that recovered
85 percent of the nickel drag-out
from three barrel-plating tanks.
The system (Figure 5) employs
four countercurrent tanks to provide
both rinsing of the parts and a
source of solution makeup in the
plating tanks. The drag-out recovery
system allows closed-loop
operation of the nickel plating
bath; all rinse water is recycled to
the plating bath with no flows to
waste treatment.

Level control probes in the three
plating tanks control the addition of
concentrated rinse to make up
for surface evaporation losses
from that tank, A level control in the
concentrated rinse water sump
controls the addition of fresh
makeup water in the last rinse tank.
To minimize the buildup of
impurities in the system, the makeup
water is purified by a compact
reverse osmosis water purification
unit. The system installed at
Gillette included the reverse osmosis
unit, the three chemical transfer
pumps, the concentrated rinse
sump (operating on the U-tube
principle}, a control panel, and the
necessary control loops. The total
cost was $8,500.

Three factors determine the
percentage of drag-out that can be
recovered when this approach
is used;

® The surface evaporation rate
  from the plating tank, which deter-
  mines the amount of rinse
  water that can be recycled
• The ratio of the  drag-out
  volume to the volume  of rinse
  water recycled to the plating bath
» The number of countercurrent
  rinses used for recovery

Figure 6 shows the percentage of
drag-out that can be reclaimed
in terms of these factors.
   O
   IE
   Q
   O
   O
   Ul
      100
      80
      60
      40
       20
                                        Legend:
           2 counterflow rinse tanks
           Jn recovery use
          [ 1 counterflow rinse tank
           in recovery use
                                          _L
                               4          6

                             RECYCLE RINSE RATIO'
                                                                10
   3gal/h recycle rinse •*• gai/h drag-out Recycle rinse flow = surface evaporation from bath.
Figure 6,

Percentage of Drag-out Recovery With Rinse-arid-Recycle System
       History 3.
                To
Conventional Treatment
System Performance

The Medford Plastics Company,
Medford, Wisconsin, is engaged
in plating copper, nickel, and
chromium on plastic components.
The plant recently installed
the wastewater treatment system
shown in Figure 7.

During the treatability studies
conducted before a  system was
selected, it became  obvious that the
nickel concentration could not be
reduced in a common treatment
system to the level  required
by the discharge permit  It was
proposed to segregate the
electroless nickel plating rinse flow
from the rest of the wastewater.
A system was evaluated for
precipitating the nickel at a high pH,
clarifying the suspended solids, then
mixing the nickel  rinse effluent
with the balance of the wastewater
before discharge.  Testing indi-
cated that this approach should
provide a total effluent nickel
concentration below the permit
specifications.

Table 10 shows that the treated
discharge achieves the removal levels
called for in the discharge permit
When the system was first installed,
however, the discharge consistently
exceeded the nickel level  re-
quirement. To correct this problem,
the plant cut the flow to the
                                                                                                     19

-------
   Copper/chrome rinses

   (15 gal/min
   Nickel rinses
               Collection     Chrome     pH
               tank         reduction    adjustment
                                      (pH = 8)
                           pH
                           adjustment
                           (pH=11)
                                                                    Dumpster

                                                                 Sludge filter press
                                                                                   Underflow
                                                                                   sump
Figure 7.
Treatment System With Waste Stream Segregation
Table 10.

Permit Requirements and Treated Effluent Quality: Waste Stream Segregation
Effluent
characteristic

Chromium (Ib/d):
Total . . , 	 - , ,
Hexavalerst 	 . . . . , 	 .......
Nickel (ppm), ...... ...... .......
Copper {pprn} 	 . 	 	 	 	 ...
pH 	 	 	

Permit
requirements3
8 8
. . . 0 22
0 02
, . . . 13
	 017
60-9 5

Treated
effluent
<0 1
0 13
0004
0 16
0.06
9 3

"Monthly average of daily values.
 nickel treatment system in half
 by further counterflowing  the
 rinses. The increased retention time
 in the treatment system and the
 greater dilution achieved when the
 nickel wastewater was  mixed
 with the copper-chrome wastewater
 eliminated the problem.
       History 4,  Sulfide
Precipitation

Holly Carburetor, a Division of
Colt Industries, in Paris, Tennessee,
manufactures carburetors for major
auto makers and as replacement
parts. Part of the wastewater
from the plant results from surface
treatment of parts used in assembling
the carburetors. This waste
stream contains varying concen-
trations of iron, zinc, and chromium
(hexavalent and trivalent); it is
treated by The Permutit Company's
Sulfex™ treatment system. The
system was installed as an EPA
demonstration project funded under
a grant made to the National
Association of Metal Finishers.
Figure 8 shows the  equipment com-
ponents of a treatment system
using sulfide precipitation,

The Sulfex™ system precipitates
metals as sulfides instead of
hydroxides.  Because metal
sulfides are considerably less soluble
than hydroxides, lower metal
concentrations can  be achieved
20

-------
                          JL       _______
                        p—F""""-""    "™"  •
                                                                                                               Signal
                                                                                                               to start
                                                                                                               polymer
                                                                                                               and FeS
                                                                                                               pumps
               Dump
               sump
     Legend:
     pHC= pH controller
     pHA = low-pH aiarm
       RC = recycle control
     MFM= magnetic flow meter
       FC= flow counter
       Vs = surge volume in
           second-stage neutraiizer
      N/C= normally closed
   Filtrate to
   second-stage
   neutralizer
               Sludge filter
               press
Figure 8.
Treatment Process With Sulfide  Precipitation
                                                                                                                        21

-------
in the effluent Table 11  compares
Holly Carburetor's effluent quality
with the city treatment system
discharge requirements,  showing
the system to be effective in removing
the metals to the required levels.

Two distinct sulfide precipitation
processes (insoluble and soluble)
are being  used to treat waste-
waters containing heavy metals.
The system at Holly Carburetor is
known as insoluble sulfide pre-
cipitation  (ISP),  in which ferrous
sulfide is the  sulfide source.
Ferrous suifide is relatively insoluble
in water; consequently, the level
of dissolved sulfide in the waste-
water is kept at a minimum. The
main advantage of ISP over the
soluble sulfide approach is that there
is no detectable H2S odor associated
with the process.

Soluble sulfide precipitation (SSP)
uses a water-soluble reagent,
such as sodium hydrosulfide (NaHS)
or sodium sulfide |Na2S). SSP
has been applied to treat complexed
metal finishing wastewaters and
has achieved lower metal con-
centrations compared with treatment
by hydroxide  precipitation.

Most of the equipment components
of both ISP and SSP systems
are common to hydroxide systems.
Consequently, these processes
offer a means of modifying an
existing hydroxide  system to
improve metal removal capability.


Case History 5.  Ion
Exchange for  Selective
Heavy Metal Removal

The Hurd  Lock and Manufacturing
Company, Greensville, Tennessee,
employs a combination treatment
system using batch treatment
of wastewater collected in four
different treatment sumps. The
wastewater collected in  each  sump
is processed  separately through
the system shown in Figure 9.
The continuous treatment system for
Table 11,

State Requirements and Treated Effluent Quality: Sulfide Precipitation
                Pollutant (mg/l)
         Tennessee guidelines
             for indirect
             discharge
Treated
effluent
Zinc	.........
Hexavalent chromium ,
Total chromium	
Copper	
               5.0
               0.05
               5.0
               5.0
 0.015
 0.02
 0.10
"Below detectable limits.
Cyanide process bath, with double-effect evaporators at left
each batch employs the following
steps:

• Chromium reduction (not
   always required)
• Neutralization (the pH set-point
   adjusted to achieve maximum
   metal removal for each waste
   processed)
• Flocculation (with polymer
   addition)
• Pressure filtration (with diato-
   maceous  earth precoat)
• Ion exchange polishing
The ion exchange polishing step
reduces the concentration of
metals to the level required for
discharge. Table 12 presents the
discharge quality and the require-
ments set forth in the permit.
The system was required to meet the
same level  of metal concentration
as that called for in the effluent
discharged  from the city's treatment
system. The plant was allowed
to exceed the chemical oxygen
demand (COD) level allowed
22

-------
                                                                                                City water
                   Chromium reduction
                   (1,000 gal)
                        I       1                    Es€3^si?ISi;|

                      1}   f  J                     Neutralization     F
                      £p   isi                     (660 gal)         (!
                        fi       M   ^mmmam^mm&mmmmmmmi^mmmammmmmmm
                        I       I  /ft.	                     I
      Chrome      Nickel     Chrome      Zinc
      rinse        tank       floor        pit
      Landfill
                                                        ION EXCHANGE POLISHING

                   "Waste from each sump is processed separately from that of the others.
              City sewer

24-h holding tank
Figure 9,
Continuous Treatment System
                                                                                                                     23

-------
Table 12.
Permit Requirements and Treated Effluent Quality: Ion Exchange
                                                 Treated effluent
        Effluent
      characteristic
  Permit
requirements
                                      Chrome
                                       floor
         Chrome
          rinses
          Nickel
          rinses
pH	
Color units	
Pollutant (mg/l):
    Total suspended solids,
    COD	
    Cadmium	
    Chromium	
    Copper	,
    Iron	,	
    Lead	
    Nickel	
    Zinc	,	
  6.5-8.5
    12

    15
    20
     0.01
     0.05
     0,05
     0.50
     0.05
     0.10
     0.10
 11.0
  0
928
 <0.005
 <0.02
 <0.05
 <0.05
 <0.05
 <0.05
 <0.02
 11.0
  0
210
 <0.005
 <0.02
 <0.05
 <0.05
 <0.05
 <0,05
 <0.02
  6.9
  0
217
 <0.005
 <0.02
 <0.05
 <0.05
 <0.05
 <0.05
 <0.02
           Zinc
            pit
 11.6
  0
500
 <0.005
 <0.02
 <0.05
 <0.05
 <0.05
 <0.05
 <0.02
for discharge because this pollutant
could be effectively reduced
by subsequent treatment. Table 12
shows that all metal level require-
ments were met.

The  resin used in the ion-exchange
columns selectively removes
heavy metals from the waste, but
allows alkali and alkaline earth
cations to pass through, A two-stage
ion exchange treatment achieved
best results. The first stage
uses a hydrogen ion resin; the
second stage uses a sodium ion
resin. The  plant shifted from  caustic
soda to lime for neutralization,
because the resin proved more
selective for heavy metal in the
presence of calcium ions.
 24

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5,  Solid Waste
Management
Hazardous Waste
Regulations

EPA has promulgated regulations
designed to manage and control
the country's hazardous wastes
from generation to final disposal,
These regulations are a result
of a directive to EPA by Congress
in the Resource Conservation and
Recovery Act (RCRA) of 1976
(Public Law 94-580), Congressional
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 generally
inadequate and environmentally
unsound practices used in the
disposal or handling of wastes.

The RCRA regulations differ from
those concerned with air and water
pollution in that air and water
regulations vary according  to the
specific industry (for example,
electroplating) to which they are
directed, whereas all industries
that generate, store, haul, or
dispose of hazardous waste must
comply with the same set of rules.
Most electroplating facilities will
be considered generators of
hazardous waste and may be con-
sidered storage or disposal
facilities. The procedures to deter-
mine if wastes are  hazardous
and the requirements for generators,
storers, and disposers of hazardous
wastes follow.


Identification of Hazardous Wastes

Under the regulations,  promulgated
in May 198G,36 solid wastes
include all substances destined for
disposal and not already regulated
by the Clean Water Act or the
Atomic Energy Act of 1954.

EPA has developed the following
list of characteristics as criteria
for determining which solid
wastes must be classified as
hazardous:

   Ignitability
   Corrosivity
   Reactivity
   Toxicity of leachates
   Radioactivity
   Infectiousness
   Phytotoxicity (toxicity to plants)
   Teratogenicity and mutagenicity
   (ability to cause mutations)

A waste possessing one or more
of these traits will be declared
hazardous. The following electro-
plating wastes are assumed to
be hazardous unless proved
otherwise:

• Wastewater treatment sludges
   (toxic)
• Spent plating bath solutions
   (reactive and toxic)
• Sludges from the bottom  of
   plating baths (reactive and toxic)
• Spent stripping and cleaning
   bath solutions (reactive and toxic)

The corrosivity criterion is used
to determine if these materials can
extract toxic contaminants from
other wastes or make them soluble.
A material is corrosive if it has
a pH  below 2 or above 12.5, or if it
corrodes steel (following a test
developed by the National Associa-
tion of Corrosion Engineers).

Reactive wastes have one or more
of the following tendencies:

•  To autopolymerize
•  To create a vigorous reaction
   with air or water
«  To exhibit thermal instability
   with regard to shock or to the
   generation of toxic gases
•  To explode

The final characteristic, toxicity,
is the one of most importance
to electroplaters. If disposed
of improperly, toxic wastes may
                                                                                                    25

-------
Small centrifuge
release toxic materials in sufficient
amounts to pose a substantial hazard
to human health or to the environ-
ment.  EPA has designed a leaching
test (called the  Extraction Pro-
cedure) to measure the amount
of toxic materials that can be
extracted from the waste at a pH of 5,
during a 24-hour period, with
constant stirring. If the  extract
obtained from the  test exceeds set
limits for certain contaminants, the
waste  will  be considered hazardous.
Eight metals are among the 14
materials selected as toxic;  several
of these metals are commonly
used in electroplating. Table 13
lists the specific metals with the
standard for  each. Other materials
may be added to the list in the future.
Table 13.

Toxic Waste Limits Set by EPA's Extraction Procedure
                           Pollutant
Extract level
  (mg/l)
Arsenic. , .
Barium . ..
Cadmium .
Chromium
Lead	
Mercury ,.
Selenium .
Silver ....
    5.0
  100.0
    1.0
    5.0
    5.0
    0.2
    1.0
    5.0
SOURCE: U.S. Environmental Protection Agency, "Hazardous Waste Management System:
Identification and Listing of Hazardous Waste," Pt, 3, Federal Register 45(98):33084-33133,
May 19, 1980.
26

-------
       Does the
       waste pass
       the EPA
       hazard tests
       or is it known
       to be non-
       hazardous?
           I
YES
        Common
        disposal
                    YESd
       NO
                                               s< 2,220 Ib
                                               of waste
                                               produced
                                               a month?
                                                                           RCRA
                                                                           ieensed
                                                                           disposal;
                                                                            Site selection
                                                                            Security
                                                                            Inspection
                                                                            Records
                                                                            Financing
                                                                            Monitoring
                                                                            Closure requirements
                                                                            Training
                                                                            Emergency
                                                                            Process standards
         "An appeal is available (see U.S. Environmental Protection Agency, Hazardous Waste System: Identification and Listing of
          Hazardous Waste, Pt. 3, Federal Register 45(98):33084-33133, May 19, 1980),
Figure 10.

Generator Obligations Under the  Resources Conservation and Recovery Act
Requirements for Hazardous
Waste Generators

Producers of hazardous waste are
considered generators  under the
regulations. It is a generator's
responsibility to determine if the
waste is hazardous by  conducting
EPA-specified tests, or the generator
may simply declare the waste
hazardous. If the waste is known  to
be nonhazardous, testing  is not
                        necessary; however, the generator is
                        responsible for the accuracy of
                        that determination.

                        Generators of hazardous wastes
                        are responsible for notifying EPA
                        of their activities, using appro-
                        priate containers, labeling the
containers,  and ensuring proper
disposal (Figure 10). The law also
requires generators who produce and
dispose of more than 2,200 Ib
(1,000  kg) of hazardous waste per
month,  with certain exceptions, to
use a manifest system to ensure
proper transport and disposal.

The manifest records the movement
of hazardous wastes from the
                                                                                                          27

-------

Recessed plate filter press
generator's premises to an
authorized off-site treatment,
storage, or disposal facility. The
manifest, signed by the generator,
transporter, and disposer, is an
official record that all Department
of Transportation (DOT) and EPA
requirements have been met.
The generator must maintain original
copies for 3 years,  and must
report to EPA if the manifest is
not returned in 45 days.

Exception reports are required,
listing  any unreturned manifests.
Annual reports, documenting
shipments of all hazardous
wastes originating  during the
report year, also are required.
In general, all information submitted
by a generator is available to
the public to the extent authorized
by the Freedom of Information
Act and EPA regulations associated
with that act,


Requirements for Storage and
Disposal Facilities

When wastes are stored on site
for 90 days or longer, the generator
falls under an additional set
of regulations designed to control
owners and operators of hazardous
waste storage and disposal
facilities. The standards for storage,
promulgated in May 1980,37
are intended to prevent the re-
lease of hazardous waste from
storage areas into the environment.
Hazardous wastes must be stored
in tanks and containers that meet
specifications established  by
EPA for the storage of flammable
and combustible liquids. Beyond
these specifications,  materials
compatible with the hazardous waste
must be used to construct or to
line the containers.

Storage areas must have a continuous
base impervious to the material
being stored and must be designed
for spill containment with either
dikes or trenches, which require
daily visual inspection. Throughout
the storage period, records
must be maintained showing the
 28

-------
identity and location of all stored
hazardous wastes. Site selection
requirements apply, and leachate
monitoring may be required.
Obviously, it is an economic
advantage not to  be classified
as a storage facility.

As stated earlier, these standards
only apply to those who store
hazardous wastes for 90 days or
more. For shorter  durations,
no recordkeeping  is required,


Reduction  of Slydge
Volume and Disposal Cost

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
  pretreatment regulations for
  removal from the discharge

Because electroplating wastewater
treatment systems commonly
remove many of the metals regulated,
most of these  sludges will be
considered hazardous, Many other
electroplating  shop wastes will
also be  considered hazardous.

EPA estimated recently that
90 percent of  the sites accepting
hazardous waste do not comply
with present and  proposed regula-
tions governing hazardous
waste disposal. Upgrading a site
to comply with the regulations will
significantly increase the cost of
operating the site, and this cost
increase will be passed on to the
generator of the waste.
      100
       75
   O
   o
   O
   a.
   <
   <
       50
       25
                    Legend:
                          disposal cost at $0.30/gal
                         I disposal cost at $0.10/gal
                      J_
 _L
_L
         0            25            50            75

                            SLUDGE VOLUME (gai/h)

         Note.—Based on operating time of 3,000 h/yr. Costs in 1979 dollars.
                            100
Figure 11,

Annual Cost for Sludge Disposal
The cost to dispose of waste
treatment sludge depends on the
volume of sludge to be disposed of,
the unit cost to transport the
sludge to a licensed disposal site,
and the fee charged by the disposal
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 derive primarily from
reduction of the volume of waste
generated.

Sludge  disposal cost in a particular
area is determined by the  level
of controls governing  disposal
in that region. Many States
already have established rigorous
control procedures, and disposal
costs range from $0.10/gal
to $0.75/ga! for metal-bearing
waste sludge; most costs are between
$0.15/gal and $0.25/gal. As
RCRA is implemented nationally,
inexpensive sludge disposal will
become a thing of the past.
Figure 11 shows the annual disposal
cost in terms of sludge disposal
rate (volume) and cost per gallon.
                                                                                                    29

-------
Sludge generation rates and disposal
costs can be reduced by:

*  Reducing the mass of pollutant
   entering the waste treatment
   system
»  Reducing the wastewater
   volume entering the treatment
   system
»  Using wastewater treatment
   techniques that generate
   minimum quantities of sludge
•  Reducing sludge volume by
   mechanical dewatering

To evaluate sludge volume
reduction alternatives, the plant
must first define its present
and future disposal  cost factors.
Typically, disposal sites accepting
metal hydroxide sludge base
their charges on the volume of
sludge.  In some cases, the site will
have one rate structure for liquid
sludges and one for nonflowing
sludges. As a rule, the hauling
cost is directly related to the
sludge volume or weight


Effects of Pollutant and
Wastewater Load Reduction

Reduction of pollutant and waste-
water loading on the waste
treatment system will have the
added benefit of reducing sludge
volume. This reduction is  part
of the three-pronged benefit
of implementing recovery and
recycle  techniques. For plants in
areas where sludge disposal is
expensive, the cost effectiveness
of modifications to reduce water  use
or pollutant loading will be enhanced.

Although the effect of reducing
wastewater flow is  not usually as
great as the effect of reducing
the level of heavy metal pollutants in
the wastewater, the volume of
wastewater processed does
influence sludge generation. The
water volume treated, because of
the high pH of most wastewater
discharges, affects the consumption
rate of the alkali neutralizing
agent (caustic, lime) and water
       40
   1   30
   03
   in
   a
   _j
   °   20
   §
   (9
   a
       10
                Legend
                T ~ pH insoluble sulfide precipitation
                IHBBI hydroxide neutralization/
                      clarification with insoluble
                      sulfide polishing
                      hydroxide neutralization/
                      clarification
                   500       1,000       1,500       2,000

                        WASTEWATER FLOW RATE (gsl/h)
                                                              2.500
Note.—"Wastewater contains 30 ppm Fe
demand equals 3 times the stoichiometric requirements.
                                   40 ppm Ni+2, 30 ppm Zn"*"2. Sulfide reagent
Figure 12.

Sludge Generation Rates for Three Treatment Systems
conditioning agents (ferric chloride,
aluminum chloride), which
are frequently fed at a rate dependent
on the wastewater flow rate.
These chemicals frequently
contribute to the quantity of sludge
generated. In the case of lime,
some part normally remains
insoluble and adds to the sludge
volume. Conditioners such as
ferric and aluminum chloride
are converted to insoluble hydroxides
during treatment and end up in
the sludge.

The effect on sludge volume
attributed to reducing plating
chemical loss is  easier to determine
than the effect of wastewater
flow. As an example, discharges
of 1  Ib (0,45 kg) of chromic acid
anhydride to the wastewater will
result in the precipitation of
                                 approximately 1 Ib (0.45 kg) of
                                 chromium hydroxide in the pH
                                 adjustment operations. This amount
                                 of chromium hydroxide will add
                                 approximately 6 gal (23 I)  of
                                 volume to the clarifier underflow,
                                 based on an underflow solids
                                 concentration of 2 percent by weight.
                                 Similar relationships exist  for
                                 the other metals used in plating
                                 operations.


                                 Effects of Treatment Techniques

                                 Because of the high cost of
                                 electroplating sludge disposal, the
                                 treatability studies  conducted
                                 during the evaluation of the
                                 different treatment alternatives
                                 should address sludge generation
                                 factors and the dewatering
                                 properties of the resultant sludge.

                                 Many of the newly developed
                                 treatment techniques marketed
                                 today offer improved pollutant
30

-------
removal capabilities compared with
the capabilities of conventional
treatment, but they also result in
significantly more sludge for
disposal. For example, insoluble
sylfide precipitation can reduce
the metal concentration in many
waste streams to lower levels
than can hydroxide precipitation,
ISP uses ferrous sulfide as the
source of the sulfide ion. The ferrous
ions liberated as a result of
precipitating the metals  as sulfides
are then converted to ferrous
hydroxide and add to the sludge
volume,

Figure 12 compares the sludge
generation rates of an insoluble
sulfide precipitation system
and an insoluble sulfide polishing
system with a conventional hydrox-
ide system using sodium hydroxide
as the neutralizing agent, over a
range of flow rates. Using the
sulfide process as a polishing
system to reduce the concentration
of metals in the effluent after
a conventional hydroxide precipita-
tion/clarification sequence will
achieve the same degree of metal
removal as sulfide precipitation,
but compared with the hydroxide
process, will increase the volume of
sludge generated only slightly,
The trade-off, however,  is that
a polishing  system will require
additional hardware and  have a
higher initial cost. The saving in
sludge disposal fees and reagent
cost must justify the added
expense if the  polishing  system
is to be chosen.

Within an existing treatment
process, the choice of reagents
can affect sludge quantities
generated. Lime and caustic  soda
are the two alkali neutralizing
agents used most frequently,
The advantages of lime include lower
cost per unit of neutralizing
capacity, sludge that settles and
dewaters more readily, and the
ability to reduce metals to lower
levels in some applications
(primarily because of the complex-
    o
       1,000
         500

         400


         300



         200
         100
         50
         40
          30
          20
          10
                    1
                                         _L
             J_
_L
                    5       10      15     20      25     30

                    SLUDGE SOLIDS CONCENTRATION (% by Weight)
                                                               35
Figure 13.

Sludge Volume Versus Solids Concentration
breaking capabilities of the
calcium ions). Lime has disadvan-
tages, however, in that it requires
a higher investment in the reagent
feed system,  takes longer to
react in the wastewater, and (accord-
ing to one study)  produces three
to six times the bulk of sludge
produced by caustic soda neutraliza-
tion. An effective  analysis will
identify the relative merits of
the different  reagents to be used.
Effects of Sludge .Dewatering

Although sludge generation rates
can be reduced significantly
by the methods outlined earlier,
some residue will always result
from wastewater treatment The cost
to dispose  of this residue will
primarily depend on the sludge
volume. The volume of dilute
sludge withdrawn from the clarifier
underflow can be reduced signifi-
cantly through mechanical
dewatering techniques.  Figure 13
                                                                                                      31

-------
shows the volume reduction that can
be achieved by dewatering clarifier
underflows to different concen-
tration levels.

Mechanical dewatering devices
that have been used successfully
to concentrate metal hydroxide
sludge include vacuum, pressure,
and compression filters and
centrifuges.

Vacuum filters dewater sludge
by applying a vacuum on one side
of a water-permeable membrane,
which  has a sludge layer or
suspension on the other side.
In response to the pressure gradient,
the water passes through  the
membrane. Rotary-drum and
vacuum-belt filter methods employ
this principle. Vacuum  filters
perform best with feed solids
concentrations above 3 percent
by weight; sludge containing lower
feed solids concentrations
should be thickened before
vacuum filtration. Good filtration
rates and trouble-free cake
release from the filter media usually
are realized with a sludge that is
not too sticky or too compressible,
Precoat rotary vacuum  filtration
can be used for dilute or otherwise
hard-to-filter  sludges. The precoat
material  represents an  additional
cost and adds to the quantity
of solids for disposal, but precoat
filtration often yields a higher
solids  concentration than  conven-
tional vacuum filtration.

Pressure filters pressurize  the
sludge and bring it in contact with a
water-permeable membrane. Re-
cessed plate  filter presses use
this method to dewater sludge. They
can achieve high solids content
because  of the large pressure
gradient  they can apply across the
sludge cake.  Commercial units are
designed that have operating
pressure limits as high  as 225 Ib/in2
gauge  (1,654 kPa).  As  do vacuum
filters,  filter presses work  best
with sludges that have good
filtration characteristics and are not
too sticky or  too compressible.
Filter presses are effective in
                                                  Filter press
           Filtrate to clarifier
  Air supply (100 Ib/in2 g)
                X.
  Clarifier underflow 1
                         Diaphragm
                         pump
                                                    Dumpster
                                    Filter
                                    feed
                                    sump
Figure 14.

Recessed Plate Filter Press and Auxiliary Equipment Needed for Sludge
Dewatering
dewatering feed streams that are
very dilute or subject to wide
variations in feed solid concentra-
tion. For small applications, filter
presses usually represent the
least capital investment for sludge
dewatering.

Compression filters dewater the
sludge by squeezing it between
water-permeable membranes. They
have been proven  effective mainly
for dewatering highly compressible
sludges characterized by large,
delicate particle floes typically
associated with polyelectrolyte con-
ditioning. The compression filterwas
developed to provide a device
that overcomes the difficulty of
applying filtration techniques
to dewater this type of sludge.
The filters are produced by a number
of manufacturers and consist of a
series of belts and rollers that
gradually increase  the compressive
force applied to the sludge cake.
Compression filters consume
less energy than vacuum filters or
centrifuges, but are more sophisti-
cated mechanically. Consequently,
the relatively high cost of the
smaller units makes them unattractive
for concentrating the  lower
sludge volumes typical of the
plating industry.

Centrifuges dewater sludge in
a manner similar to gravity thick-
eners,  but they create an apparent
gravity thousands of times more
powerful than normal by rapidly
rotating the sludge. The increased
gravity greatly accelerates the
settling process and magnifies the
compaction effect. This dewatering
mechanism makes centrifuges
most suitable for compressible
sludges, which settle well. Use of the
units usually necessitates condi-
tioning of the feed stream with
a polyelectrolyte  to increase
32

-------
settling ability. Basket centrifuges
are used most frequently for
electroplating sludge dewatering,
They are attractive because of
their compact size and automated
operation.

Plants  use dewatering devices
for one of two reasons:

•  To make sludge suitable for
   disposal at a  local site that
   will  only accept nonflowing
   sludges
«  To achieve a net reduction in
   sludge disposal costs despite the
   operating cost  associated with
   the  dewatering equipment

The  high cost of sludge disposal
will  justify dewatering equipment
for all  but generators of very  small
sludge volumes.

Consider, for example, the installation
of a recessed plate filter (Figure 14)
to dewater a dilute clarifier under-
flow from 3  percent solids by
weight to 20 percent solids by
weight. Figure 15 compares the
    05
    o
    u
    if)
    o
    0-
    w
    C3
    Q
    3
3
Z

<
       100 r-
        80
        60
        40
        20
                                    legend:
                                    •+:-?-  3% solids (disposal only)
                                    l^BBB 20% solids (disposal plus
                                           filter press annual costs)
                                           20% solids (disposal only)
                   100      200      300       400

                           CLARIFIER UNDERFLOW (gal/h)
                                                        500
                                                                 600
           4,800 h/yr operation, $0.10/gal sludge disposal. 3% solids by weight clarifier
     underflow. Costs in 1979 dollars.
Figure 15.

Annual Sludge Disposal Cost for Filter Press Dewatering System
 Single-stage cyanide oxidation, neutralization-fiocculation, and settling tank with automatic sludge collector
                                                                                                          33

-------
  X
  <
  <
  (_
  z
     100
      75
      50
      25
                                               sludge disposal at $0,20/ga!
                                               sludye disposal at $0.10/gal
                                               sludge disposal at $0,05/gal
                                                       _L
                    50         100         150

                           CLARIFIES UNDERFLOW (gal/h)
                                                       200
                                                                  250
   "Assumes 48% income tax rate.

   Note,—4,800 h/yr operation. Sludge dewatered from 3% to 20% solids by weight. Costs
   in 1979 dollars.
Figure 16.

Return on Investment From Recessed Plate Filter Installation
                                    disposal alone.  Even with its costs
                                    included, the filter press  reduces
                                    annual disposal costs at underflow
                                    rates exceeding 15 gal/h (57 l/h).
                                    Figure 16 shows the return on
                                    investment resulting from  installation
                                    of a filter press  as  a function
                                    of clarifier underflow rate over a
                                    range of sludge disposal  costs.
                                    For a plant disposing of its sludge at
                                    $0.10/gal, the investment has
                                    a reasonable rate of return at 50 gal/h
                                    (190 l/h). For a  plant incurring
                                    a disposal cost  of $0.25/gal, the
                                    installation of a filter press would
                                    be favorable  above 25 gal/h (95 l/h).

                                    Thus, mechanical dewatering is
                                    usually cost  effective, except
                                    for plants generating very small
                                    siudge volumes—less than 50 gal/h
                                    (190 l/h}. RCRA will probably
                                    require that sludges be dewatered
                                    before land application. The
                                    facility that accepts the wastes,
                                    therefore, will be likely to have some
                                    means of dewatering dilute
                                    sludge. Plants generating small
                                    sludge volumes may find it most
                                    cost effective to use the dewatering
                                    capabilities of a  central disposal site.
annual costs of sludge disposal,
at $0.10/gal of sludge, for the
two concentrations. The figure
shows two curves for sludge
disposal at 20 percent solids by
weight: cost  including filter press
operation plus dewatered sludge
disposal and cost for sludge
34

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6.  Financing
Alternatives
The Federal Government has
established tax incentives and has
made financing alternatives
available to ease the burden of
compliance with  environmental
regulations.


income Tax  Provisions

Two available tax treatments
permit a company to pay lower
income taxes. The first alternative
is the investment tax credit (ITC),
a direct  credit against current
income taxes. Under this alternative,
the company is allowed to take an
ITC of 10 percent but cannot
exceed the total tax liability,
or $25,000 plus 50 percent of the
tax liability in excess of $25,000,
whichever is less. Any depreciation
schedule approved by the Internal
Revenue Service can be used
in  conjunction with the ITC;
however, the equipment must be
depreciable and have a life
expectancy of at least 3 years,
Questions on other applicable
restrictions can be directed to the
contacts listed in Section 8,

The second tax alternative involves
special rapid amortization of
pollution control  facilities. It
applies to facilities for water or
atmospheric pollution control or
abatement that were in operation
before January 1, 1969, and that
conform to applicable State
and Federal regulations. Relatively
new plants in operation before
1976 can rapidly amortize only
a part of the investment. The rapid
amortization provision allows
a company to depreciate the total
investment costs over a 60-month
period; however, the useful life
of the equipment cannot be
greater than  15 years. With this
tax alternative, half of the ITC, or
5 percent, also can be claimed
against taxes, if the equipment
has a useful  life of at least 5 years.
Smal!
Administration Loans

Various Federal financial assistance
programs exist to help small
businesses with pollution control
costs. These loans come under the
Small Business Administration
(S8A) Economic Injury Loan Program
and are intended for companies
likely to suffer economic injuries
without them. Loans have averaged
$125,000; roughly 25 percent
have gone to electroplaters to date,
The loans offer an attractive
interest rate of 7% percent and may
extend for up to 30 years. Participat-
ing arid guaranteed loans are
available with SBA and  commercial
lending institutions, but higher
interest rates apply.

To be eligible for an SBA loan, a
company must be an existing small
business and meet several other
requirements, For example, the
firm must have been turned down
by a bank. The rejection may be
made in any of a number of ways,
for example, setting too high an
interest rate or too short a payback
period. The firm also must receive
certification from EPA that the
equipment  is necessary and
adequate, and it must demonstrate
that regulatory requirements
will cause serious economic injury.


SBA-Guaranteed Pollution
Control Revenue Bonds

Revenue bond financing is used
extensively by large businesses to
supply funds for pollution control
facilities. SBA-guaranteed bonds
are issued to obtain the most
advantageous interest rate and
repayment terms possible for small
businesses. The small business
using this alternative applies
                                                                                                 35

-------
for a loan from a State or local
authority having the right to issue
bonds. SBA guarantees payment
and the State then issues the bonds
through an underwriter. The State
or local authority becomes the
nominal owner of the property,
which can be conveyed to the
business under a lease or under a
lease-purchase agreement Many
of the requirements for this
form of funding are similar to
those for SBA loans.


Other Sources

Other, less direct forms of funding
are  available for financing pollution
control facilities.
The Economic Development
Administration (EDA) finances
the growth of business in redevelop-
ment areas. EDA loans, however,
are typically large (they averaged
$1.5 million in 1977) and are
oriented toward large businesses
not covered by SBA programs.
Although not specifically covered
by EDA, pollution control equipment
may be eligible for this financing
in certain circumstances.

EDA also has funding available
to assist States and local areas
threatened with economic displace-
ment because of such matters
as environmental requirements
placed on local industry. With this
EDA funding, the State or local
municipality owns the treatment
facility and  leases it to a group of
industrial users. This centralized
treatment concept is expected
to be heavily funded in the near
future and is particularly applicable
to electroplaters.

The Farmers Home Administration
(FmHA) is authorized to provide
business and industry  loans to  rural
areas; however, the financing
of pollution control equipment
represents only a small part of  the
loan program. As a rule, FmHA
encourages borrowers of less than
$400,000 to use the SBA.
36

-------
7,  Consolidated Permit
Program
EPA has consolidated its permit
programs, wherever feasible, to
eliminate gaps and overlaps
among the programs, to ensure
consistency of regulatory approaches,
and to provide uniform procedures
to the regulated community. The
permit application procedures
were published in May 1980,38 and
include the following five programs:

® The Hazardous Waste Manage-
  ment programs under RCRA
• The Underground Injection
  Control program under the Safe
  Drinking Water Act
» The National Pollutant Discharge
  Elimination System under the
  Clean Water Act
» The Dredge or Fill program
  under the Clean  Water Act,  as
  this program Is operated by
  States with  approval by EPA
« The Prevention of Significant
  Deterioration (PSD) program
  under the Clean  Air Act, where
  this program is operated by
  EPA (procedures not applicable
  to State-issued PSD permits)
The first and third programs are of
most interest to electroplaters;
however, the same basic application
form can be used for permits
under any of the programs. The
consolidated form collects gen-
eral information that applies
to all programs; this form is
supplemented by a form unique
to the specific program. Although
there are exclusions under each
program, heavy  penalties  are
imposed for failure to apply for a
permit when one is required. The
appropriate EPA Regional Office
can determine whether a  permit
is required in a given situation.
The consolidation effort is limited
because some programs are operated
by the State rather than by the
EPA Regional Offices. One permit
may be required by the State
and another by EPA. The appropriate
Regional Office  can supply
information about where to apply.
                                   Cationic rinse tanks
                                                                                                  37

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8.  Contacts
A number of local and Federal
representatives may be consulted
on matters related to regulations or
financial assistance. These contacts
are listed in the paragraphs that
follow, with details of how they can
be reached. It should be borne
in  mind that names of persons are
current and subject to change.
Addresses and telephone numbers,
however, will remain valid.


Regulatory Information

All contacts for regulatory infor-
mation should be addressed at:

U.S.  Environmental  Protection
   Agency
401  M Street, S.W.
Washington  DC 20460

Names of persons to be consulted
on a given subject area appear with
the appropriate office numbers
and are followed by the telephone
numbers  at which they can be
reached.


Water

Requests for information on
water regulations should be
addressed to:

Jeffrey D. Denit (WH-552)
(202) 426-2576


Solid Wastes

The  appropriate contact for solid
waste regulatory information
will depend  on the subject area.

Hazardous Waste Criteria—
   Identification and Listing
Alan Corson (WH-565)
(202) 755-9187

Standards for Generators of
   Hazardous Wastes
Harry Trask (WH-563)
(202) 755-9150

Standards for Transporters of
   Hazardous Wastes
Harry Trask (WH-563)
(202) 755-9150
Standards for Treatment of
  Hazardous Wastes
Steve tingle (WH-565)
(202) 755-9200

Permit Regulations for Hazardous
  Waste Treatment,  Storage, and
  Disposal
Arthur Glazer (WH-563)
(202) 755-9150

Guidelines for State Hazardous
  Waste Programs
Dan  Derkics (WH-563)
(202) 755-9150


Financial Assistance
Information


EPA Headquarters

For general information on financial
assistance, the contact is:

Frances  Desselle
Financial Assistance  Coordinator
Office of Analysis and Evaluation
Environmental  Protection Agency
Room 745  E.T. (WH-586)
401  M Street, S.W.
Washington DC 20460

The telephone number for this
contact  is: (202) 426-7874,


Farmers Home Administration

Questions relating to  FmHA business
and  industry loans for rural areas
should be directed to:

U.S. Department of Agriculture
Room 5314
14th St.  and Independence Ave., S.W.
Washington DC 20250
 38

-------
Small Business Administration
Region
 Region IV
information on SBA-guaranteed
bonds can be obtained from:

Earl L Chambers
Director
Office of Special Guarantees
Small Business Administration
1441  L Street, N.W.
Washington DC 20416

This office can be  reached by
telephone at:  (202) 235-2900.


Economic Development Admin-
  istration

Information on the various kinds
of EDA funding can be obtained from:

Daryl Bladen
Deputy Director of Public Works
or
Joseph Rosenblum
(202)  377-5265


EPA Regional  Offices

Addresses are given in the following
paragraphs for the 10 EPA regions.
Hours of operation are also included,
as well as the names and tele-
phone numbers of regional
administrators and financial assist-
ance officers.
Region I

The region is composed of
Connecticut, Maine, Massachusetts,
New Hampshire, Rhode Island,
and Vermont,

Administrator
William R. Adams, Jr.
(617) 223-7210

Financial Assistance Coordinator
Ted Landry
Enforcement Division
{617) 223-5061

Address
Room 2203
J.F.K, Federal Building
Boston MA 02203

Hours
8 a.m. to 5 p.m.
The region is composed of
New Jersey, New York, Puerto Rico,
and the Virgin Islands,

Administrator
Charles S. Warren
(212) 264-2525

Financial Assistance Coordinator
Gerald DeGaetano
Permits Administration Branch
Enforcement Division
(212) 264-4711

Address
Room 1009
26 Federal Plaza
New York NY 10007

Hours
8 a.m. to 4:30 p.m.


Region HI

The region is composed of
Delaware, Maryland, Pennsylvania,
West Virginia, the District of
Columbia, and Virginia.

Administrator
Jack Schramm
(215) 597-9814

Financial Assistance Coordinator
Bob Gunter
FRC  Liaison Officer
(215) 597-2763

Address
Curtis Building
Sixth  and Walnut Sts,
Philadelphia PA 19106

Hours
8 a.m. to 4:30 p.m.
 The region is composed of
 Alabama, Florida, Georgia, Kentucky,
 Mississippi, North Carolina,  South
 Carolina, and Tennessee.

 Administrator
 Rebecca W. Hanmer
 (404) 881-4727

 Financial Assistance Coordinator
 John Hurlebaus
 Supervisor
 Grants Analysis
 Program Support Branch
 Grants Administrative Support
   Section
 (404) 881-4491

 Address
 345 Courtland St., N.E.
 Atlanta GA 30308

 Hours
 8:15 a.m. to 4:45 p.m.


 Region V

 The region is composed of
 Illinois,  Indiana, Wisconsin,
 Michigan, Minnesota, and Ohio.

 Administrator
 John McGuire
 (312) 353-2000

 Financial Assistance Coordinator
 Arnold Leder
 Chief
 Water Branch
 (312) 353-2904

 Address
 230 S. Dearborn St.
 Chicago  IL 60604

 Hours
 8:15 a.m. to 4:45 p.m.


 Region VI

 The region is composed of
 Arkansas, Louisiana, New Mexico,
 Oklahoma, and Texas.

Administrator
 Adelene  Harrison
 (214) 767-2600
                                                                                                 39

-------
Financial Assistance Coordinator
Jan Horn
Enforcement Division
(214) 729-2760

Address
First International Building
1201  Elm St.
Dallas TX 75270

Hours
8 a.m. to 4:30 p.m.


Region VII

The region is composed of
Kansas, Missouri, Nebraska, and
Iowa.

Administrator
Kathleen Q. Camin
(816) 374-5493

Financial Assistance Coordinator
Paul Walker
Chief
Engineering Branch
Water Division
(816) 374-2725

Address
1735 Baltimore St.
Kansas City MO 64108

Hours
7:15 a.m. to 4 p.m.
Region V11I

The region is composed of
Colorado, Wyoming, Montana,
North Dakota, South Dakota, and
Utah.

Administrator
Roger L Williams
(303) 837-3895

Financial Assistance Coordinator
Gerald Burke
Office of Grants
Water Division
(303) 327-4579

Address
1860 Lincoln St.
Denver CO 80203

Hours
8 a.m. to 4:30 p.m.


Region IX

The region is composed of
Arizona, California, Hawaii, Nevada,
American Samoa, Guam, and the
Trust Territories.

Administrator
Paul de Falco, Jr.
(415) 556-2320
Financial Assistance Coordinator
Linda Powell
Permits Branch
Enforcement Division
(415) 556-3450

Address
215  Fremont St.
San  Francisco CA 94105

Hours
8 a.m. to 4:30 p.m.


Region X

The  region is composed of
Alaska, Idaho, Oregon, and
Washington.

Administrator
Donald P.  Dubois
(206)442-1220

Financial Assistance Coordinator
Dan  Bodien
Special Technical Advisor
Enforcement Division
(206)442-1352

Address
1200 Sixth Ave.
Seattle WA 98101

Hours
8 a.m. to 4:30 p.m.
 40

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

2U.S.  Environmental Protection
 Agency. "General Pretreatment
 Regulations for Existing and
 New Sources of Pollution."
 Federal Register 43f123):27736-
 27773, June 26, 1978.

3 U.S.  Environmental Protection
 Agency. "General Pretreatment
 Regulations for Existing and
 New Sources of Pollution."
 Federal Register 44(210):62260-
 62275, Oct. 29, 1979.

4U.S.  Environmental Protection
 Agency. "Effluent Guidelines and
 Standards; Electroplating Point
 Source Category; Pretreat-
 ment Standards for Existing
 Sources," Federal fteyister
 44(191):56330-56333, Oct. 1,
 1979,

5U.S.  Environmental Protection
 Agency. "Effluent Guidelines and
 Standards; Electroplating Point
 Source Category; Pretreat-
 ment Standards for Existing
 Sources; Correction." Federal
 Register 45(59): 19245-19246,
 Mar.  25, 1980,

6 U.S.  Environmental Protection
 Agency. "Electroplating Point
 Source Category, Effluent Guide-
 lines and Standards, Pretreatment
 Standards for Existing Sources."
 Federal Register, in preparation,
 1980.

7U.S.  Environmental Protection
 Agency and American Electro-
 platers' Society, Inc. (cosponsorsj.
 Annual Conference on Advanced
 Pollution Control for the Metal
 Finishing Industry fist). Held at
 Lake Buena Vista, Florida on Jan-
 uary  17-19, J978, EPA 600/8-78-
 010.  NTIS No. Pb 282-443.
 May  1978.
 8U.S. Environmental Protection
 Agency and American Electro-
 platers' Society, Inc. (cosponsors).
 Proceedings of a Conference
 on Advanced Pollution Control for
 the Metal Finishing Industry (2nd)
 Held at Kissimmee, FL on
 February 5-7,  1979, EPA 600/8-
 79-014. NTIS No.  Pb  297-453.
 June 1979.

 9U.S. Environmental Protection
 Agency, Office of Water and
 Hazardous Materials, Effluent
 Guidelines Division, Development
 Document for Proposed Existing
 Source Pretreatment Standards
 for the Electroplating Point
 Source Category, EPA 440/1 -78-
 085. Feb. 1978.

10U.S. Environmental Protection
 Agency. Environmental Pollution
 Control Alternatives: Economics of
 Wastewater Treatment Alterna-
 tives for the Electroplating
 Industry, EPA 625/5-79-016.
 June 1979. (Prepared by Centec
 Corporation)

11 U.S. Environmental Protection
 Agency, Industrial  Environmental
 Research  Laboratory. Advanced
 Treatment Approaches for Metal
 Finishing  Wastewaters,  Part 1.
 EPA 600/J-77-056a. NTIS
 No. Pb 277-147. Oct. 1977.

12U.S. Environmental Protection
 Agency, Industrial  Environmental
 Research  Laboratory. Advanced
 Treatment Approaches for Metal
 Finishing  Wastewaters,  Part 2.
 EPA 60Q/J-77-056b, NTIS
 No. Pb 277-148. Nov. 1977.

13U,S. Environmental Protection
 Agency. Control Technology
 for the Metal Finishing Industry;
 Evaporators. EPA 625/8-79-002.
 June 1979. (Prepared by Centec
 Corporation)
                                                                                                   41

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14U,S, Environmental Protection
  Agency. "Evaporative Recovery
  of Chromium Plating Rinse
  Waters," Project No, S803781-1.
  Feb. 1977. (Prepared by Advance
  Plating Company and Corning
  Glass Works)

15U.S. Environmental Protection
  Agency, Treatment of Electro-
  plating Wastes by Reverse
  Osmosis. EPA 600/2-76-261.
  NTIS No, Pb 265-393, Sept, 1976,
  (Prepared by American  Electro-
  platers' Society)

16U,S, Environmental Protection
  Agency, FBI Reverse Osmosis
  Membrane for Chromium Plating
  Rinse  Water, EPA 600/2-78-040.
  NTIS No, Pb 280-944. Mar. 1978.
  (Prepared by American  Electro-
  platers' Society)

17U.S. Environmental Protection
  Agency. Reverse Osmosis Field
  Test: Treatment of Watts
  Nickel Rinse Waters. EPA 600/2-
  77-039. NTIS No. Pb 266-919.
  Feb. 1977. (Prepared by Abcor,
  Inc.)

18U.S. Environmental Protection
  Agency. Reverse Osmosis Field
  Test: Treatment of Copper Cyanide
  Rinse  Waters. EPA 600/2-77-1 70.
  NTIS No.  Pb 272-473.  Feb. 1977.
  (Prepared by Abcor, Inc.)

19U.S. Environmental Protection
  Agency. New Membranes for
  Treating Metal Finishing Effluents
  by Reverse Osmosis. EPA 600/
  2-76-197. NTIS No, Pb 265-363,
  Oct. 1976. (Prepared by Midwest
  Research Institute)

20U.S. Environmental Protection
  Agency. Electrodialysis for Closed
  Loop Control of Cyanide Rinse
  Waters. EPA 600/2-77-161.
  NTIS No.  Pb 272-688. Aug. 1977.
  (Prepared by International
  Hydronics Corporation)
21 U.S. Environmental Protection
  Agency. Investigation of Treating
  Electroplaters Cyanide Waste by
  Electrodialysis. EPA R2-73-287.
  NTIS No. Pb 231-263. Dec. 1973.
  (Prepared by RAI Research
  Corporation)

22U.S. Environmental Protection
  Agency, Office of Technology
  Transfer. In-Process Pollution
  Abatement Vol. 1, Upgrading
  Metal-Finishing Facilities to
  Reduce Pollution.  EPA 625/3-73-
  002. NTIS No. Pb 260-546,
  July 1973.

23U.S. Environmental Protection
  Agency. Waste Treatment:
  Upgrading Metal-Finishing
  Facilities To Reduce Pollution.
  NTIS No.  Pb 226-963. July 1973,
  (Prepared by Lancy Laboratories)

24U.S. Environmental Protection
  Agency. Controlling Pollution
  From the Manufacturing and Coat-
  ing of Metal Products: Water
  Pollution Control. EPA 625/3-73-
  009, May 1977. (Prepared by
  Centec  Corporation)

25U.S, Environmental Protection
  Agency. Wastewater Treatment
  and Reuse in a Metal Finishing
  Job Shop.  NTIS No,  Pb 234-476,
  July 1974. (Prepared by S.  K.
  Williams and Company)

26U.S, Environmental Protection
  Agency. Chemical Treatment of
  Plating  Waste for Removal
  of Heavy Metals, EPA R2-73-044.
  NTIS No. Pb 227-363. May 1973.
  (Prepared by Beaton and Corbin
  Manufacturing Company)

27U.S. Environmental Protection
  Agency. Treatment of Metal
  Finishing Wastes by Sulfide Pre-
  cipitation.  Unpublished report,
  (Prepared by Perrnutit Company)

28U,S. Environmental Protection
  Agency, Treatment of Metal
  Finishing Wastes by Sulfide Pre-
  cipitation.  EPA 600/2-77-049,
  NTIS No. Pb 267-284. Feb. 1977,
  (Prepared by Metal Finishers'
  Foundation)
29U.S. Environmental Protection
  Agency. An Investigation of
  Techniques for Removal of Cyanide
  From Electroplating Wastes.
  EPA WQO-12010-EIE-11/71.
  NTIS No, Pb 208-210. Nov. 1971,
  (Prepared by Battelle Columbus
  Laboratories)

30U.S. Environmental Protection
  Agency, Treatment of Complex
  Cyanide Compounds for Reuse
  or Disposal. EPA R2-73-269.
  NTIS No, Pb 222-794, June 1973.
  (Prepared by Berkey Film
  Processing of New England)

31 U.S. Environmental Protection
  Agency. Ozone Treatment of
  Cyanide-Bearing Plating Waste.
  EPA 600/2-77-104. NTIS No.
  Pb 271-015. June 1977. (Prepared
  by Sealectro Corporation)

32U,S. Environmental Protection
  Agency. Removal of Heavy Metals
  From Industrial Wastewater
  Using Insoluble Starch Xanthate.
  EPA 600/2-78-085. NTIS No.
  Pb 283-792. May 1978.  (Prepared
  by U.S. Department of Agriculture,
  Agricultural Research Service)

33U.S, Environmental Protection
  Agency. An Investigation of
  Techniques for Removal of
  Chromium From Electroplating
  Wastes. NTIS No.  Pb 215-614,
  Mar,  1971, (Prepared by Battelle
  Memorial Laboratories)

34U.S, Environmental Protection
  Agency. Electrolytic Treatment of
  Job Shop Metal Finishing
  Wastewater. EPA 600/2-75-028.
  NTIS No, Pb 246-560, Sept. 1975,
  (Prepared by New  England
  Plating Company)

35U.S. Environmental Protection
  Agency. Removal of Chromium
  from Plating Rinse Water Using
  Activated Carbon.  EPA 600/2-75-
  055.  NTIS No. Pb  243-370,
  June 1975. (Prepared by Battelle
  Memorial Institute)
42

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36U.S, Environmental Protection      37U,S. Environmental Protection     38U.S. Environmental Protection
  Agency, "Hazardous Waste          Agency. "Standards Applicable       Agency, "Consolidated Permit
  Management System; Identification     to Owners and Operators of         Application Forms for EPA Pro-
  and Listing of Hazardous Waste,"     Hazardous Waste Treatment,        grams." Federal Register 45(98):
  Pt 3. Federal Register 45(98):        Storage, and Disposal Facilities."     33290-33588, May 19, 1980.
  33084-33133, May 19,  1980,        Federal Register 45(98):33154-
                                    33258, May 19, 1980,
                                                                                                 43

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                                  This industrial awareness report was prepared by the Centec Corporation,
                                  Fort Lauderdale FL and Reston VA, EPA thanks the following organizations
                                  for providing information and technical review: American Electroplaters'
                                  Society; Gillette Company, Safety Razor Division, Boston MA; Holly
                                  Carburetor, a Division of Colt Industries, Paris TN; Hurd Lock and Manufac-
                                  turing Company, Greensviile TN; Medford Plastics Company, Medford Wl;
                                  and Phillips Plating Company, Phillips Wl. Aqualogic* Inc.,  Bethany CT,
                                  provided photographs.


                                  This report has been reviewed by the U.S. Environmental  Protection Agency
                                  and approved for publication.  The process alternatives, trade names, or
                                  commercial products are only examples and are  not endorsed or recom-
                                  mended by the U.S. Environmental Protection Agency. Other alternatives
                                  may exist or may be developed that are applicable to the electroplating
                                  industry.


                                  COVER PHOTOGRAPH: Nickel plating bath.

44

                                                                                      * 660-868  8/80

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