Effluent Guidelines Division
WH-552
Washington DC 20460
EPA 440/1 -84/069
December 1984
ent
ent Limitations
tahdards for the
i .' | i }
Plastics Molding
and Forming
i : ; I
Pdint Source Category
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DEVELOPMENT DOCUMENT
for
EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS
for the
PLASTICS MOLDING AND FORMING POINT SOURCE CATEGORY
William D. Ruckelshaus
Administrator
Jack E. Ravan
Assistant Administrator for Water
Edwin L. Johnson
Director
Office of Water Regulations and Standards
Jeffery D. Denit, Director
Industrial Technology Division
Robert W. Dellinger, Chief
Consumer Commodities Branch
Industrial Technology Division
Robert M. Southworth, P.E.
Technical Project Officer
December 1984
U.S. Environmental Protection Agency
Office of Water
Office of Water Regulations and Standards
Industrial Technology Division
Washington, D.C. 20460
U.S. Environmental Protection Agency,
Region V, Library
230 South Dearborn Street
Chicago, Illinois 60604
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TABLE OF CONTENTS
Sgetion Page
I SUMMARY AND CONCLUSIONS 1
INTRODUCTION 1
TYPE OF EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS 4
CONTACT COOLING AND HEATING WATER SUBCATEGORY. . 5
Best Practicable Technology Currently Available
(BPT) Effluent Limitations Guidelines 5
Best Available Technology Economically
Achievable (BAT) Effluent Limitations
Guidelines 5
Best Conventional Pollutant Control Technology
(BCT) Effluent Limitations Guidelines 6
New Source Performance Standards (NSPS) 6
Pretreatment Standards for Existing Sources
(PSES) 7
Pretreatment Standards for New Sources (PSNS). . 8
CLEANING WATER SUBCATEGORY 8
Best Practicable Technology Currently Available
(BPT) Effluent Limitations Guidelines 8
Best Available Technology Economically
Achievable (BAT) Effluent Limitations
Guidelines 9
Best Conventional Pollutant Control Technology
(BCT) Effluent Limitations Guidelines 9
New Source Performance Standards (NSPS) 9
Pretreatment Standards for Existing Sources
(PSES) 10
Pretreatment Standards for New Sources (PSNS). . 11
FINISHING WATER SUBCATEGORY 12
Best Practicable Technology Currently Available
(BPT) Effluent Limitations Guidelines 12
Best Available Technology Economically
Achievable (BAT) Effluent Limitations
Guidelines
Best Conventional Pollutant Control Technology ^^
(BCT) Effluent Limitations Guidelines. . . ,
New Source Performance Standards (NSPS). .
Pretreatment Standards for Existing Sou1" A<
(PSES) . -jcePJ
Pretreatment Standards for New So\i- *i«\^vYo^
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TABLE OF CONTENTS (Continued)
Section Page
II RECOMMENDATIONS 15
III INTRODUCTION 25
BACKGROUND ..... 25
PURPOSE 27
AUTHORITY 27
STUDY APPROACH 27
IV CATEGORY PROFILE 29
SAMPLING PROGRAM 29
QUESTIONNAIRE SURVEYS 30
1978 and 1979 Questionnaire Surveys 30
1983 Telephone Survey 31
1983 Questionnaire Survey 36
Summary of Questionnaire Data Base 39
LITERATURE REVIEW 42
INDUSTRY DESCRIPTION 42
PLASTICS MOLDING AND FORMING PROCESSESS 45
Extrusion Processes 45
Molding Processes 50
Coating and Laminating Processes 61
Thermoforming Processes. 70
Calendering Processes 72
Casting Processes 74
Foatn Processes 78
Cleaning Processes 79
Finishing Processes. .... 79
V SUBCATEGORIZATION 81
BASIS FOR SUBCATEGORIZATION SCHEME 81
FACTORS CONSIDERED 81
Raw Materials. 81
Production Processes .... 82
Products Produced 83
Size and Age of Plants 84
Geographic Location 85
Types of Water Use . 85
Wastewater Characteristics .... • 86
ii
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TABLE OF CONTENTS (Continued)
Section Page
SELECTED SUBCATEGORIZATION SCHEME 86
APPLICABILITY 87
VI WATER USE AND WASTEWATER CHARACTERISTICS .... 91
QUESTIONNAIRE DATA 91
PM&F Category Data 96
Estimate of Number of Plants and Processes in
PM&F Category That Use Process Water 99
Estimate of PM&F Category Process Water Use. . . 100
Estimate of PM&F Category Process Water
Discharged 102
SAMPLING PROGRAMS 102
Plant Selection - Proposed Regulation 108
Field Sampling Programs - Proposed PM&F
Regulation 108
Plant Selection - Final PM&F Regulation 120
Sample Collection, Preservation, and
Transportation 122
Sample Analysis 130
Field Quality Assurance/Quality Control (QA/QC). 130
Sampling Procedure Protocols .......... 136
Laboratory Quality Assurance/Quality Control
(QA/QC) 139
PROCESS WATER POLLUTANT CONCENTRATIONS 139
Data Editing Rules 139
Pollutant Average Concentration Methodology. . . 153
SAMPLED PLANTS WITH WASTEWATER TREATMENT
SYSTEMS 159
SOLUTION CASTING/SOLVENT RECOVERY SAMPLING
DATA 159
TOTAL PHENOLS VERIFICATION AT PLANT F. ..... 160
VII POLLUTANTS IN PLASTICS MOLDING AND FORMING
PROCESS WATERS 161
CONVENTIONAL POLLUTANTS 161
NONCONVENTIONAL POLLUTANTS 161
iii
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TABLE OF CONTENTS (Continued)
Section
VIII
IX
PRIORITY TOXIC POLLUTANTS 165
List of Pollutants 165
Exclusion of Pollutants and Subcategories. ... 166
POLLUTANTS CONSIDERED FOR REGULATION 176
Conventional Pollutants 176
Nonconventional Pollutants ...... 182
Priority Toxic Pollutants 183
MASS OF POLLUTANTS 209
WASTEWATER CONTROL AND TREATMENT TECHNOLOGIES. . 221
INTRODUCTION 221
IN-PLANT CONTROL TECHNOLOGY 222
Process Water Recycle 222
In-Process Measures 224
END-OF-PIPE TREATMENT TECHNOLOGY 226
Settling 226
pH Adjustment 228
Activated Sludge 230
Activated Carbon Adsorption 236
Filtration (Suspended Solids Removal) 240
Vacuum Filtration (Sludge Dewatering) 243
COSTS, ENERGY, AND NON-WATER QUALITY ASPECTS . . 247
INTRODUCTION 247
COST ESTIMATES FOR TREATMENT TECHNOLOGIES. . . . 247
Sources of Cost Data 247
Cost Components 247
Cost Update Factors 249
Cost Data Correlation 249
DESIGN DATA FOR TREATMENT TECHNOLOGIES 250
Flow Equalization 250
pH Adjustment 253
Settling 254
iv
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TABLE OF CONTENTS (Continued)
Section Page
Package Activated Sludge Plant 255
Activated Carbon Adsorption 257
Vacuum Filters 261
Contract Haul 263
PROCESS-BY-PROCESS COST ESTIMATES 263
Plant-Specific Treatment Technologies. ..... 264
Process Water Characteristics 264
Cost Calculations 265
Consideration of Existing Treatment 265
COST ESTIMATION EXAMPLE 265
ESTIMATION OF ENERGY AND NON-WATER QUALITY
IMPACTS 268
Energy 268
Air Pollution 270
Solid Waste 270
Consumptive Water Loss 275
X BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE 277
BACKGROUND 277
TECHNICAL APPROACH 278
BPT Model Treatment Technologies 281
BPT OPTIONS 283
Contact Cooling and Heating Water Subcategory. . 283
Cleaning Water Subcategory 285
Finishing Water Subcategory 289
REGULATED POLLUTANTS AND POLLUTANT PROPERTIES. . 292
EFFLUENT CONCENTRATION VALUES . . . 292
BPT EFFLUENT LIMITATIONS GUIDELINES 295
EXAMPLE OF THE APPLICATION OF THE BPT EFFLUENT
LIMITATIONS GUIDELINES 295
Example 295
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TABLE OF CONTENTS (Continued)
Section Page
XI BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE 299
INTRODUCTION 299
IDENTIFICATION OF THE BEST AVAILABLE TECH-
NOLOGY ECONOMICALLY ACHIEVABLE 299
Contact Cooling and Heating Water Subcategory. . 299
Cleaning Water Subcategory ...... 302
Finishing Water Subcategory. .......... 303
XII NEW SOURCE PERFORMANCE STANDARDS 307
INTRODUCTION 307
TECHNICAL APPROACH TO NSPS 307
NSPS OPTION SELECTION. 307
Contact Cooling and Heating Water Subcategory. . 308
Cleaning Water Subcategory 308
Finishing Water Subcategory 310
COSTS AND POLLUTANT REMOVALS FOR NSPS 312
REGULATED POLLUTANTS AND POLLUTANT PROPERTIES. . 317
NEW SOURCE PERFORMANCE STANDARDS 317
NON-WATER QUALITY IMPACTS 318
XIII PRETREATMENT STANDARDS 321
TECHNICAL APPROACH 321
PRETREATMENT STANDARDS FOR EXISTING SOURCES. . . 322
Contact Cooling and Heating Water Subcategory. . 322
Cleaning Water Subcategory 322
Finishing Water Subcategory 323
PRETREATMENT STANDARDS FOR NEW SOURCES 323
Contact Cooling and Heating Water Subcategory. . 323
Cleaning Water Subcategory 324
Finishing Water Subcategory 324
XIV BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY . 327
XV ACKNOWLEDGEMENTS 329
XVI REFERENCES 333
vi
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TABLE OF CONTENTS (Continued)
Section Page
XVII GLOSSARY 351
APPENDICES
A SAMPLING DATA A-1
B STATE INDUSTRIAL GUIDES B-1
C POLLUTANT REMOVALS C-1
D POLLUTANT CONCENTRATIONS USED TO CALCULATE THE
BEST PRACTICABLE TECHNOLOGY (BPT) EFFLUENT
LIMITATIONS GUIDELINES D-1
vii
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LIST OF TABLES
Number Page
IV-1 RESULTS OF 1983 PLASTICS MOLDING AND FORMING
TELEPHONE SURVEY FIRST PART 32
IV-2 RESULTS OF 1983 PLASTICS MOLDING AND FORMING
TELEPHONE SURVEY SECOND PART 34
IV-3 DISTRIBUTION OF THE NUMBER OF PLASTICS MOLDING
AND FORMING PROCESSES BY DISCHARGE MODE 35
IV-4 DISTRIBUTION OF THE 330 DETAILED 1983
QUESTIONNAIRES 38
IV-5 WATER-USING PROCESSES IN THE PM&F CATEGORY
DISTRIBUTED BY DISCHARGE MODE 41
IV-6 COMMONLY USED ADDITIVES IN POLYMER FORMULATION
USING THE EXTRUSION PROCESS 48
VI-1 DISCHARGE MODE FOR WET PROCESSES IN
QUESTIONNAIRE DATA BASE 92
VI-2 QUESTIONNAIRE DATA BASE INFORMATION 93
VI-3 DISTRIBUTION OF NUMBER OF PROCESSES IN
QUESTIONNAIRE DATA BASE WITH ZERO DISCHARGE. . . 94
VI-4 PM&F TREATMENT TECHNOLOGIES SUMMARY 95
VI-5 DISCHARGE MODE FOR PROCESSES IN QUESTIONNAIRE
DATA BASE THAT RECYCLE PROCESS WATER 97
VI-6 DISTRIBUTION OF NUMBER OF PROCESSES IN THE
CONTACT COOLING AND HEATING WATER SUBCATEGORY
BY TYPE OF PROCESS AND DISCHARGE MODE 98
VI-7 DISTRIBUTION OF THE NUMBER OF PM&F PROCESSES
THAT USE PROCESS WATER BY TYPE OF PROCESS
WATER AND DISCHARGE MODE 101
VI-8 DISTRIBUTION OF PM&F WATER USE FOR INDIRECT
DISCHARGERS 103
VI-9 DISTRIBUTION OF PM&F WATER USE FOR DIRECT
DISCHARGERS 104
Vlll
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LIST OF TABLES (Continued)
Number Page
VI-10 DISTRIBUTION OF PM&F WATER USE FOR ZERO
DISCHARGERS 105
VI-11 DISTRIBUTION OF PM&F PROCESS WATER DISCHARGED
BY INDIRECT DISCHARGERS 106
VI-12 DISTRIBUTION OF PM&F PROCESS WATER DISCHARGED
BY DIRECT DISCHARGERS 107
VI-13 1980 AND 1983 SAMPLED PROCESSES 121
VI-14 1984 SAMPLED PROCESSES 129
VI-15 POLLUTANTS FOR WHICH PM&F PROCESS WATER
SAMPLES WERE ANALYZED 131
VI-16 ANALYTICAL METHODS SUMMARY 132
VI-17 DETECTION LIMITS FOR PRIORITY TOXIC POLLUTANTS . 134
VI-18 CONTAINER AND GLASSWARE PREPARATION PROCEDURES . 137
VI-19 SUMMARY OF SAMPLE DATA 140
VI-20 DATA FOR POLLUTANT X - CALCULATION OF AVERAGE
CONCENTRATION EXAMPLE 155
VI-21 QUESTIONNAIRE DATA BASE WEIGHTING FACTORS FOR
FLOW-WEIGHTED CONCENTRATION METHODOLOGY 156
VI1-1 CONVENTIONAL POLLUTANT AVERAGE CONCENTRATIONS -
PM&F PROCESS WATERS 162
VI1-2 NONCONVENTIONAL POLLUTANTS FOR WHICH SAMPLES
WERE ANALYZED 163
VI1-3 NONCONVENTIONAL POLLUTANT AVERAGE CONCENTRA-
TIONS - CLEANING WATER SUBCATEGORY 164
VII-4 PRIORITY POLLUTANTS EXCLUDED FROM CONTROL FOR
THE PM&F CATEGORY 169
VI1-5 PRIORITY POLLUTANTS DETECTED IN PM&F PROCESS
WATERS 170
IX
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LIST OF TABLES (Continued)
Number Page
VII-6 EXCLUSION METHODOLOGY EXAMPLE - POLLUTANT X. . . 171
VII-7 PRIORITY POLLUTANTS EXCLUDED FROM CONTROL. ... 172
VII-8 PRIORITY POLLUTANTS IN PM&F PROCESS WATERS ... 174
VII-9 POLLUTANT TREATABILITY LIMITS 177
VII-10 PRIORITY POLLUTANTS PRESENT IN TREATABLE
CONCENTRATIONS 179
VII-11 DATA FOR POLLUTANT X - MASS CALCULATION
EXAMPLE 210
VII-12 QUESTIONNAIRE SURVEY DATA USED TO ESTIMATE
POLLUTANT MASSES 211
VII-13 POLLUTANT MASSES 215
VIII-1 DISTRIBUTION OF PM&F PROCESSES WITH RECYCLE. . . 225
VIII-2 POLLUTANTS AND POLLUTANT PROPERTIES FOUND IN
TREATABLE CONCENTRATIONS IN PM&F PROCESS
WATERS 227
VIII-3 REMOVAL EFFICIENCIES FOR CONVENTIONAL AND
SELECTED NONCONVENTIONAL POLLUTANTS IN A
SETTLING TANK 229
VIII-4 REMOVAL EFFICIENCIES FOR NONCONVENTIONAL
POLLUTANTS AND PRIORITY POLLUTANTS FOR
ACTIVATED SLUDGE PROCESSES 237
IX-1 CAPITAL AND O&M COST EQUATIONS 251
IX-2 ESTIMATED CAPITAL AND O&M COSTS FOR PLANT Y
AT BPT 269
IX-3 DESCRIPTION OF PM&F TREATMENT SYSTEM SOLID
WASTE SAMPLES 273
IX-4 EP TOXICITY TEST RESULTS FOR PM&F WASTEWATER
TREATMENT SOLID WASTES 274
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LIST OF TABLES (Continued)
Number
X-1
X-2
XII-1
XII-2
XII-3
XII-4
XVII-1
EFFLUENT CONCENTRATIONS USED TO CALCULATE THE
FINAL BPT EFFLUENT LIMITATIONS GUIDELINES. . . .
ALLOWABLE DISCHARGE OF REGULATED POLLUTANTS
FOR PLANT X
CHARACTERISTICS OF PM&F "NORMAL" PLANTS
POLLUTANT MASS IN PROCESS WATERS FOR NSPS
"NORMAL" PLANT
ESTIMATED POLLUTANT REMOVALS FOR PM&F NSPS
MODEL TREATMENT TECHNOLOGY
ESTIMATED COSTS OF NSPS MODEL TREATMENT
TECHNOLOGY FOR PM&F "NORMAL" PLANTS
THE GLASS TRANSISTION AND MELTING TEMPERATURES
OF SOME COMMON POLYMERS, AND THEIR MAIN USES . .
Page
294
297
31 3
314
31 5
316
352
XI
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LIST OF FIGURES
Number Page
IV-1 EXTRUSION PROCESS 47
IV-2 INJECTION MOLDING PROCESS 51
IV-3 BLOW MOLDING PROCESS 54
IV-4 COMPRESSION MOLDING PROCESS 55
IV-5 TRANSFER MOLDING PROCESS 57
IV-6 REACTION INJECTION MOLDING PROCESS 59
IV-7 ROTATIONAL MOLDING PROCESS 60
IV-8 EXPANDABLE BEAD FOAM MOLDING PROCESS 62
IV-9 PLASTISOL AND POWDER COATING PROCESSES 63
IV-10 SPREAD COATING PROCESS 64
IV-11 EXTRUSION COATING PROCESS 65
IV-12 LAMINATING PROCESS 68
IV-1 3 CONTINUOUS LAMINATION PROCESS 69
IV-14 THERMOFORMING PROCESS 71
IV-15 CALENDERING PROCESS 73
IV-16 CASTING PROCESSES 75
IV-17 CHILLED FILM CASTING PROCESS 76
VI-1 SAMPLING POINTS AT PLANT A 109
VI-2 SAMPLING POINTS AT PLANT B 110
VI-3 SAMPLING POINTS AT PLANT C 111
VI-4 SAMPLING POINTS AT PLANT D 112
VI-5 SAMPLING POINTS AT PLANT E 113
VI-6 SAMPLING POINTS AT PLANT F 114
xii
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LIST OF FIGURES (Continued)
Number
VI-7 SAMPLING POINTS AT PLANT G 115
VI-8 SAMPLING POINTS AT PLANT H 116
VI-9 SAMPLING POINTS AT PLANT I 117
VI-10 SAMPLING POINTS AT PLANT J 118
VI-11 SAMPLING POINTS AT PLANT K 119
VI-12 SAMPLING POINTS AT PLANT M 123
VI-13 SAMPLING POINTS AT PLANT N 124
VI-14 SAMPLING POINTS AT PLANT 0 125
VI-15 SAMPLING POINTS AT PLANT P 126
VI-16 SAMPLING POINTS AT PLANT Q 127
VI-17 SAMPLING POINTS AT PLANT R 128
VIII-1 ACTIVATED SLUDGE TREATMENT PROCESS 232
VIII-2 EXTENDED AERATION ACTIVATED SLUDGE PACKAGE
PLANTS 235
VIII-3 ACTIVATED CARBON ADSORPTION COLUMN 239
VIII-4 FILTRATION TECHNOLOGIES 241
VIII-5 VACUUM FILTER 244
IX-1 COST ESTIMATE EXAMPLE MODEL TREATMENT
TECHNOLOGIES FOR PLANT Y AT BPT 267
X-1 AVERAGE PROCESS WATER USAGE FLOW RATE 280
X-2 SCHEMATIC OF BPT OPTION 2 - CLEANING WATER
SUBCATEGORY 286
X-3 SCHEMATIC OF BPT OPTION 1 - FINISHING WATER
SUBCATEGORY 290
Kill
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LIST OF FIGURES (Continued)
Number Page
IX-1 BAT OPTION 1 CONTACT COOLING AND HEATING
WATER SUBCATEGORY 301
XI-2 BAT OPTION 1 FINISHING WATER SUBCATEGORY .... 305
XII-1 MODEL TREATMENT TECHNOLOGY FOR NSPS - CLEANING
WATER SUBCATEGORY 309
XI1-2 MODEL TREATMENT TECHNOLOGY FOR NSPS - FINISHING
WATER SUBCATEGORY 311
xiv
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SECTION I
SUMMARY AND CONCLUSIONS
INTRODUCTION
Pursuant to Sections 301, 304, 306, 307, 308, and 501 of the
Clean Water Act and the Settlement Agreement in Natural Resources
Defense Council v. Train 8 ERG 2120 (D.D.C. 1976). modified T7
ERG 1833 (D.D.C. 1979), modified by orders dated October 26,
1982, August 2, 1983; January 6, 1984; and July 5, 1984, the
Environmental Protection Agency (EPA) collected and analyzed data
for plants in the Plastics Molding and Forming Point Source
category. (Throughout this document the Plastics Molding and
Forming category is referred to as the "PM&F" category.) Pro-
posed effluent limitations guidelines and standards for this
category were published in the Federal Register on February 15,
1984 (49 FR 5862). This document and the administrative record
provide the technical basis for the final effluent limitations
guidelines for existing direct dischargers and standards of per-
formance for new source direct dischargers for the PM&F category.
This document also addresses EPA's consideration of pretreatment
standards for new and existing indirect dischargers in the PM&F
category.
In the PM&F category, there are an estimated 10,260 plants of
which 1,898 use process water (i.e., water that contacts the
plastic material during processing). These plants have approxi-
mately 2,587 processes that use process water. Of these pro-
cesses, 810 discharge water directly to rivers and streams; 1,145
discharge to publicly owned treatment works; and 632 do not dis-
charge process water. The other 8,362 plants in the PM&F cate-
gory do not use process water (i.e., they are dry).
To collect information regarding plant size, age and production,
the production processes used, and the quantity, treatment, and
disposal of process water generated, EPA conducted three ques-
tionnaire surveys and a two-part telephone survey. As a result
of these surveys, 382 plants were included in a data base from
which were derived technical, statistical, and economic informa-
tion to evaluate the PM&F category. In addition, EPA sampled
PM&F processes at 18 plants: four plants were sampled in 1980;
seven plants were sampled in 1983; and seven plants were sampled
in 1984. Samples collected were analyzed for conventional,
selected nonconventional, and priority toxic pollutants to
identify and quantify pollutants present in PM&F process waters.
The Agency examined data obtained from the questionnaire surveys
and the wastewater sampling programs to characterize the PM&F
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category. The category is comprised of plants that employ
generic processes that blend, mold, form, or otherwise process
plastic materials. These processes are:
1. extrusion,
2. molding,
3. coating and laminating,
4. thermoforming,
5. calendering,
6. casting,
7. foaming,
8. cleaning, and
9. finishing.
Results of the sampling programs indicate that process water is
generally used to cool or heat plastic products, to clean both
the surfaces of the plastic products and the surfaces of shaping
equipment that contact plastic products, or to finish plastic
products. Waters used in contact cooling and heating processes,
in cleaning processes, and in finishing processes have different
pollutant characteristics. For this reason, the PM&F category
was divided into three subcategories:
1. contact cooling and heating water subcategory;
2. cleaning water subcategory; and
3. finishing water subcategory.
The contact cooling and heating water subcategory includes those
processes where process water contacts raw materials or plastic
products for the purpose of heat transfer during plastics molding
and forming.
The cleaning water subcategory includes those processes that use
process water to clean the surface of plastic products or to
clean shaping equipment surfaces that are or have been in contact
with the formed plastic product. Process water used to clean the
plastic product or shaping equipment includes water used in the
detergent wash cycle and water used in the rinse cycle to remove
detergents and other foreign matter.
The finishing water subcategory includes those processes that use
process water to finish the plastic product. Finishing water
consists of water used to carry away waste plastic material or to
lubricate the product during the finishing operation.
Only process water that contacts the plastic material, plastic
product, or surfaces of shaping equipment used to mold or form
plastic materials is covered by this final regulation. Non-
contact cooling water is not process water and thus is not
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controlled. Permit writers and control authorities will estab-
lish limitations for the discharge of non-contact cooling water
and other non-process wastewater on a case-by-case basis.
Plants in the PM&F category may have processes that use only one
type of water and thus fit within one subcategory. However, many
plants have contact cooling and heating water, cleaning water,
and finishing water processes. In this instance, plants must
comply with the effluent limitations guidelines and standards for
each subcategory.
EPA studied the PM&F category to characterize the pollutants in
the different types of process water. The conventional and non-
conventional pollutants or pollutant properties present in
treatable concentrations are: (1) conventional pollutants
biochemical oxygen demand (6005), oil and grease (O&G), total
suspended solids (TSS), and pH, (2) nonconventional pollutants -
total organic carbon, chemical oxygen demand, and total phenols.
The priority toxic pollutants found in treatable concentrations
in PM&F process waters are: (1) contact cooling and heatin
water - bis(2-ethylhexyl) phthalate,(2) cleaning water - pheno
and zinc, and (3) finishing water - bis(2-ethylhexyl)phthalate,
di-n-butyl phthalate, and dimethyl phthalate.
The control and treatment technologies available for this cate-
gory include various end-of-pipe technologies. These technolo-
gies were considered appropriate for the treatment of plastics
molding and forming process waters and formed the basis for the
model treatment technologies for the final PM&F regulation.
End-of-pipe technologies considered appropriate for PM&F process
waters include equalization, pH adjustment, settling, the acti-
vated sludge process, the activated carbon process and filtra-
tion. Using these technologies, the Agency developed several
treatment options. After consideration of these options, the
Agency selected model treatment technologies as the basis for
this regulation.
Equalization. Equalization involves mixing or holding of
wastewater to provide an influent to a treatment process with
both a relatively constant flow rate and composition.
pH Adjustment. Acidic and basic materials are used to control the
pH of the wastewater. Proper pH adjustment not only controls a
pollutant property but also serves to ensure proper treatment
technology performance.
Settling. Settling is a process that removes solid particles
from illiquid matrix by gravitational force. This is done by
reducing the velocity of the flow in a large volume tank so that
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gravitational settling can occur. Floatable materials such as
oils can also be removed in this process by skimming them from
the surface of the water in the tank.
Biological Treatment (Activated Sludge). The activated sludge
process is a widely used biological treatment process character-
ized by a suspension of microorganisms maintained in a homogene-
ous state by mixing and turbulence induced by aeration. The
microorganisms oxidize soluble and colloidal organic material to
carbon dioxide and water in the presence of molecular oxygen.
This process treats dissolved pollutants such as BOD5, total
organic carbon, and total phenols. The activated sludge process,
which is designed to ensure optimal removal of BOD5, also may
remove organic priority pollutants in the wastewater.
Activated sludge technology can be used with settling technolo-
gies to make a package activated sludge plant. These are self-
contained plants that usually consist of a primary settling unit,
an activated sludge unit, and a final settling unit. Package
activated sludge plants can be used to treat flows from as low as
600 gallons per day to as high as 100,000 gallons per day.
Activated Carbon. The activated carbon process is used to remove
dissolved organic contaminants from wastewater. The activated
carbon removes pollutants from water by the process of adsorp-
tion, the attraction and accumulation of one substance on the
surface of another. Organic compounds are preferentially
adsorbed onto activated carbon; this selectivity results in a
particularly effective method for the removal of soluble organic
compounds from aqueous solutions.
Filtration. Filtration processes are used to remove suspended
solids from process waters. Filtration processes include a wide
range of technologies including screens, granular media filters,
belt filters, and membrane filters. The primary difference
between the various types of filters is the degree of permeabil-
ity of the barrier, ranging from the coarseness of a wire screen
to the selectivity of ultrafiltration membranes.
TYPE OF EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS
The effluent limitations guidelines and standards in the final
PM&F regulation are mass-based. They are calculated using the
following equation:
Effluent Mass = (Concentration) (Average Process
Water Usage Flow Rate)
The pollutant concentrations, which are based on the performance
of the selected model treatment technology, are promulgated in
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the final rule and presented in this document. The average
process water usage flow rate is the process water, including
recycle, that flows through a process and contacts the plastic
product. A permit writer uses the concentration values promul-
gated in this rule and the average process water usage flow rate,
which is obtained from the permittee, to calculate the effluent
pollutant mass that can be discharged.
If a plant has more than one PM&F process in the same subcate-
gory, the average process water usage flow rate for those
processes is the sum of the average process water usage flow rate
for each process. This sum is used to calculate the pollutant
mass for the PM&F processes at a plant in the same subcategory.
CONTACT COOLING AND HEATING WATER SUBCATEGORY
Best Practicable Technology Currently Available (BPT) Effluent
Limitations Guidelines
The BPT effluent limitations guidelines for this subcategory are
based on the application of good housekeeping practices. During
plant visits and various sampling episodes, EPA found that good
housekeeping practices are commonly employed with processes in
this subcategory. Raw materials and lubricating oils are rou-
tinely segregated from the cooling and heating water, which keeps
pollutants not generated during the PM&F operation out of the
cooling and heating water. The final BPT effluent limitations
guidelines ensure continuation of those practices because they
are based on a statistical evaluation of the pollutant concentra-
tions currently discharged by processes at plants employing good
housekeeping techniques. This approach was selected at BPT
because no conventional or nonconventional pollutants were found
in treatable concentrations in contact cooling and heating
waters.
Implementation of the final BPT effluent limitations guidelines
for this subcategory will result in only minimal removals of
conventional, nonconventional, and priority toxic pollutants.
Best Available Technology Economically Achievable (BAT) Effluent
Limitations Guidelines
Except for bis(2-ethylhexyl) phthalate, there are no toxic pollu-
tants present in treatable concentrations in the process water
discharged by contact cooling and heating water processes.
Therefore, except for bis(2-ethylhexyl) phthalate, the BAT
effluent limitations guidelines are the same as the BPT effluent
limitations guidelines for this subcategory.
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The toxic pollutant bis(2-ethylhexyl) phthalate was found in
treatable concentrations (ranging from 0.011 mg/1 to 1.72 mg/1)
in 52.6 percent of the contact cooling and heating water samples
collected and analyzed. However, none of the technologies
considered during the development of the proposed rule for this
subcategory can be used to control this pollutant. Accordingly,
EPA is reserving the BAT effluent limitations guidelines for
bis(2-ethylhexyl) phthalate pending further study. The Agency
has identified one technology (i.e., the activated carbon pro-
cess) that it believes will effectively control bis(2-ethylhexyl)
phthalate, but at this time does not have treatability data for
phthalates for that treatment process. EPA plans to study the
treatment of phthalates by the activated carbon process and,
after reviewing the results of that study, to propose and promul-
gate BAT effluent limitations guidelines for bis(2-ethylhexyl)
phthalate.
Because the BAT effluent limitations guidelines for all pollu-
tants except bis(2-ethylhexyl) phthalate are the same as the BPT
effluent limitations guidelines for those pollutants, there are
no additional pollutant removals achieved by implementation of
the final BAT effluent limitations guidelines.
Best Conventional Pollutant Control Technology (BCT) Effluent
Limitations Guidelines
The Agency was unable to identify a technology that further
reduces the concentrations of conventional pollutants found in
contact cooling and heating waters. For this reason, BCT is
equal to BPT for this subcategory and the BCT effluent limita-
tions guidelines are the same as the BPT effluent limitations
guidelines. Because there are no technologies available to
reduce conventional pollutants in this subcategory, EPA has no
reason to await promulgation of the final BCT methodology before
promulgating BCT effluent limitations guidelines for this
subcategory.
New Source Performance Standards (NSPS)
Except for bis(2-ethylhexyl) phthalate, the Agency is promulgat-
ing NSPS for this subcategory equal to the BPT effluent limita-
tions guidelines. The NSPS control BOD5, O&G, TSS, and pH.
NSPS are being promulated equal to the BPT effluent limitations
guidelines because the Agency believes that the characteristics
of process waters generated by new sources will be substantially
the same as the characteristics of PM&F process waters generated
by existing sources. Accordingly, the Agency considered the same
technologies as the basis for NSPS that were considered for
BPT/BAT. EPA was unable to identify additional technologies that
-------
are capable of reducing the concentrations of pollutants found in
process water discharges from contact cooling and heating water
processes at new sources.
The Agency believes that the concentrations of bis(2-ethylhexyl)
phthalate in contact cooling and heating water discharged by new
sources will be similar to the concentrations of that pollutant
discharged by existing sources. As discussed earlier, the Agency
found treatable concentrations of bis(2-ethylhexyl) phthalate in
52.6 percent of the contact cooling and heating water samples
collected and analyzed. Because no previously-studied technolo-
gies effectively control this pollutant, NSPS for bis(2-ethyl-
hexyl) phthalate are reserved pending completion of the phthalate
treatability study discussed above.
NSPS were derived based on a statistical evaluation of the con-
ventional pollutant concentrations in process waters discharged
by existing contact cooling and heating water processes. They
ensure that the same good housekeeping practices employed at
existing sources will be employed at new sources.
The Agency anticipates that 14 kilograms per year of the toxic
pollutants found in treatable concentrations in contact cooling
and heating waters will be discharged from a "normal" new source
plant for this subcategory. Implementation of NSPS is expected
to result in minimal pollutant removals.
EPA has defined a "normal" new source plant for this subcategory
as a plant that only contains a contact cooling and heating water
process. The average process water usge flow rate for the con-
tact cooling and heating water process at this "normal" plant is
35 gpm and the pollutant concentrations in the process water
discharged from that process are assumed to be equal to the
average pollutant concentrations for this subcategory.
Pretreatment Standards for Existing Sources (PSES)
The Agency is not promulgating PSES at this time for any pollu-
tant; PSES for bis(2-ethylhexyl) phthalate are being reserved.
EPA has determined that the average percentage of toxic pollutant
removals nation-wide by well-operated POTWs meeting secondary
treatment requirements (ranging from 35 to 99 percent) is greater
than the percentage of toxic pollutant removals achieved by BAT
(i.e., zero percent removals). Therefore, the toxic pollutants
do not pass through a POTW. Even though categorical pretreatment
standards are not being promulgated, indirect dischargers in this
subcategory must comply with the General Pretreatment Regulations
- 40 CFR Part 403.
-------
PSES for bis(2-ethylhexyl) phthalate are reserved pending propo-
sal and promulgation of the BAT effluent limitations guidelines
for bis(2-ethylhexyl) phthalate. When BAT is selected, EPA will
determine if that pollutant passes through a. POTW.
Pretreatment Standards for New Sources (PSNS)
The Agency is not promulgating PSNS at this time for any pollu-
tant; PSNS for bis(2-ethylhexyl) phthalate are being reserved.
The Agency believes that new and existing indirect discharge
sources will discharge the same pollutants in similar amounts.
As discussed in the preceding subsection, the average percentage
of toxic pollutants removed nation-wide by well-operated POTWs
meeting secondary treatment requirements (ranging from 35 to 99
percent) is greater than the average percent removal achieved by
BAT/NSPS for this subcategory (i.e., zero percent removal).
Therefore, the toxic pollutants do not pass through a POTW. Even
though the Agency is not promulgating categorical pretreatment
standards, indirect dischargers at new sources in this subcate-
gory must comply with the General Pretreatment Regulations - 40
CFR Part 403.
The Agency believes that the concentrations of bis(2-ethylhexyl)
phthalate in contact cooling and heating water discharged from
new indirect sources will be similar to the concentrations of
that pollutant discharged from existing indirect sources. For
this reason, the Agency is reserving PSNS for bis(2-ethylhexyl)
phthalate until completion of the phthalate treatability study.
When the technology basis for NSPS for that pollutant is
selected, EPA will determine if bis(2-ethylhexyl) phthalate
passes through a POTW.
CLEANING WATER SUBCATEGORY
Best Practicable Technology Currently Available (BPT) Effluent
Limitations Guidelines
The Agency is promulgating BPT effluent limitations guidelines
for this subcategory based on the performance of a package acti-
vated sludge plant with equalization and pH adjustment. The
final BPT effluent limitations guidelines control BOD5, O&G,
TSS, and pH. The activated sludge process removes the toxic
pollutants found in treatable concentrations in cleaning water.
This technology and the effluent values for this technology were
transferred from the organic chemicals, plastics, and synthetic
fibers (OGPSF) point source category.
Implementation of the BPT effluent limitations guidelines for
this subcategory is expected to result in an annual removal of
217,500 kilograms of conventional pollutants, 136,700 kilograms
8
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of nonconventional pollutants, and 155 kilograms of treatable
priority toxic pollutants. EPA believes that the toxic pollu-
tants in cleaning water are effectively controlled when the
effluent limitations guidelines for the conventional pollutants
are met.
Best Available Technology Economically Achievable (BAT) Effluent
Limitations Guideline^
The Agency is not promulgating BAT effluent limitations guide-
lines more stringent than the BPT effluent limitations guidelines
for this subcategory because there are insignificant quantities
of toxic pollutants remaining in cleaning water after compliance
with the applicable BPT effluent limitations guidelines. The
Agency believes that the amount and toxicity of these pollutants
do not justify establishing more stringent BAT effluent limita-
tions guidelines for the toxic pollutants. Therefore, the BAT
effluent limitations guidelines for this subcategory are the same
as the BPT effluent limitations guidelines. No additional toxic
pollutant removals are achieved by the BAT effluent limitations
guidelines for this subcategory.
Best Conventional Pollutant Control Technology (BCT) Effluent
Limitations Guidelines
The Agency has identified at least one technology (i.e., filtra-
tion) that can reduce the concentration of conventional pollu-
tants remaining after the application of BPT for this subcate-
gory. Accordingly, EPA is reserving promulgation of BCT effluent
limitations guidelines for this subcategory pending promulgation
of the final BCT methodology. Once that methodology is promul-
gated, EPA will use it to determine if additional controls for
conventional pollutants are justified for this subcategory.
New Source Performance Standards (NSPS)
The Agency believes that characteristics of process waters
discharged by new sources in the cleaning water subcategory will
be the same as the characteristics of process waters discharged
by existing sources in this subcategory. Thus, the technology
option selected for new sources is the same as the technology
option selected for existing sources in this final rule.
The Agency is promulgating NSPS based on the same model treatment
technologies used as the basis for the promulgated BPT/BAT
effluent limitations guidelines (package activated sludge plant
with equalization and pH adjustment). Although the Agency also
considered filtration as a model treatment technology following
the package activated sludge plant, filtration was not included
in the technology basis at this time for the reasons presented in
-------
Section XII of this document. However, if the Agency finds that
application of filtration is justified based on the final BCT
cost test methodology, EPA may revise the technology basis for
NSPS for this subcategory to include filtration as a polishing
step. At this time, the Agency is not promulgating NSPS more
stringent than the effluent limitations guidelines for existing
sources because the amount and toxicity of the toxic pollutants
remaining after treatment in the BPT/BAT treatment technologies
for this subcategory do not justify more stringent controls.
Pollutants and pollutant properties controlled by NSPS include
biochemical oxygen demand, oil and grease, total suspended
solids, and pH. The Agency believes that the toxic pollutants in
cleaning waters are effectively controlled when the NSPS for the
above pollutants are met.
The Agency anticipates that 2,290 kilograms per year of conven-
tional pollutants, 2,079 kilograms of nonconventional pollutants,
and 2.3 kilograms of priority toxic pollutants will be discharged
by a "normal" new source plant for this subcategory. Implementa-
tion of NSPS is expected to result in removal of 2,100 kilograms
per year of conventional pollutants, 1,300 kilograms of noncon-
ventional pollutants, and 1.5 kilograms of priority toxic
pollutants.
A "normal" plant for the cleaning water subcategory is a model
plant that has one cleaning process whose production, wastewater
characteristics, and financial profile are typical of existing
plants with cleaning processes. The process flow rate for the
cleaning process in this "normal" plant is 13.5 gpm.
Pretreatment Standards for Existing Sources (PSES)
EPA is not promulgating PSES for the cleaning water subcategory
because the priority toxic pollutants (i.e., phenol and zinc)
found in cleaning waters in treatable concentrations do not pass
through a POTW. The Agency compared the percent removal of
phenol and zinc (i.e., 75 percent and 65 percent, respectively)
achieved by application of BAT to the average percentage removal
of those pollutants nation-wide by well-operated POTWs meeting
secondary treatment requirements (99 percent for phenol and 77
percent for zinc) . Because the percent removals in a POTW are
greater than the BAT percent removals, phenol and zinc do not
pass through a POTW. Therefore, pretreatment standards are not
established for phenol and zinc.
Even though no categorical pretreatment standards are being
promulgated for existing sources for this subcategory, indirect
dischargers must comply with the General Pretreatment Regulations
- 40 CFR Part 403.
-------
Pretreatment Standards for New Sources (PSNS)
The Agency is not promulgating PSNS for this subcategory. The
Agency believes that new and existing indirect discharge sources
will discharge the same pollutants in similar amounts. As dis-
cussed in the preceding subsection, the average toxic pollutant
percentage removal by well-operated POTWs meeting secondary
treatment requirements is greater than the percentage of toxic
pollutants removed by the model treatment technology for the BAT
effluent limitations guidelines, which is the technology basis
for NSPS. Therefore, the toxic pollutants do not pass through a
POTW.
Even though new indirect dischargers are not subject to categori-
cal pretreatment standards, they must comply with the General
Pretreatment Reglations - 40 CFR Part 403.
FINISHING WATER SUBCATEGORY
Best Practicable Technology Currently Available (BPT) Effluent
Limitations Guidelines
The Agency is promulgating BPT effluent limitations guidelines
for this subcategory based on the performance of a settling unit.
The BPT effluent limitations guidelines control TSS and pH.
The Agency estimates that the BPT effluent limitations guidelines
for this subcategory will result in a removal of 2,520 kilograms
per year of conventional pollutants from finishing process
waters.
Best Available Technology Economically Achievable (BAT) Effluent
Limitations Guidelines
Except for three phthalates, EPA is promulgating BAT equal to BPT
for this subcategory. The BAT effluent limitations guidelines
are the same as the BPT effluent limitations guidelines. There
are no additional pollutant removals achieved by implementation
of the BAT effluent limitations guidelines for this subcategory.
EPA was only able to identify one technology (i.e., the activated
carbon process) for the removal of the three phthalates found in
treatable concentrations in finishing waters. However, the
Agency does not have treatability data for phthalates for the
activated carbon process. The Agency plans to study the
treatment of phthalates by the activated carbon process. After
reviewing the results of that study, EPA plans to propose and to
promulgate BAT effluent limitations guidelines for the three
phthalates in finishing water. For this reason, the BAT effluent
limitations guidelines for this subcategory for bis(2-ethylhexyl)
11
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phthalate, di-n-butyl phthalate, and dimethyl phthalate are
reserved.
Best Conventional Pollutant Control Technology (BCT) Effluent
Limitations Guidelines
EPA was able to identify at least one technology (i.e., filtra-
tion) that could reduce the concentration of TSS in finishing
waters after the application of BPT. Accordingly, BCT effluent
limitations guidelines for this subcategory are reserved pending
promulgation of the final BCT methodology. That methodology will
be used to determine if additional controls for conventional
pollutants are justified for this subcategory.
New Source Performance Standards (NSPS)
The Agency believes that characteristics of process waters dis-
charged from finishing processes at new sources will be the same
as the characteristics of process waters discharged by those
processes at existing sources. Thus, the technology option
selected for new sources is the same as the one selected for
existing sources.
The Agency is promulgating NSPS based on the same model treatment
technology used as the basis for the BPT effluent limitations
guidelines (i.e., settling). Although the Agency also considered
filtration as a model treatment technology following settling,
filtration was not included in the technology basis for NSPS at
this time for the reasons presented in Section XII of this docu-
ment. However, if the Agency finds that application of filtra-
tion is justified based on the final BCT cost test methodology,
EPA may revise the technology basis for NSPS for this subcategory
to include filtration as a polishing step. At this time, the
Agency is not establishing NSPS more stringent than the effluent
limitations guidelines for existing sources because, except for
three phthalates, there are no toxic pollutants found in finish-
ing waters in treatable concentrations. The Agency believes that
the concentrations of the three phthalates in finishing waters
discharged by new sources will be similar to the concentrations
of those phthalates found in finishing waters discharged by
existing sources. For this reason, the Agency is reserving NSPS
for bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and
dimethyl phthalate for this subcategory.
Pollutants and pollutant properties controlled by new sources
include TSS and pH. NSPS for this subcategory are the same as
the BPT effluent limitations guidelines.
The Agency anticipates that 363 kilograms per year of conven-
tional pollutants will be discharged by a "normal" new source
12
-------
plant for this subcategory. Implementation of NSPS is expected
to result in the removal of 252 kilograms per year of conven-
tional pollutants.
EPA has defined a "normal" new source plant for this subcategory
as a plant that only contains a finishing water process. The
average process water usage flow rate for the finishing water
process at this "normal" plant is 3.15 gpm and the pollutant
concentrations in the process water discharged from that process
are assumed to be equal to the average pollutant concentrations
for this subcategory.
Pretreatment Standards for Existing Sources (PSES)
The Agency is not promulgating PSES for this subcategory at this
time for any pollutant; PSES for bis(2-ethylhexyl) phthalate,
di-n-butyl phthalate, and dimethyl phthalate are reserved. EPA
has determined that the average percentage of the toxic pollu-
tants removed nation-wide by well-operated POTWs meeting second-
ary treatment requirements (ranging from 35 to 99 percent) is
greater than the average percent removal achieved by application
of BAT (i.e., zero percent removal). Therefore, the toxic pollu-
tants do not pass through a POTW. Even though the Agency is not
promulgating categorical pretreatment standards, indirect dis-
chargers at existing sources in this subcategory must comply with
the General Pretreatment Regulations - 40 CFR Part 403.
PSES for bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and
dimethyl phthalate are reserved pending promulgation of the BAT
effluent limitations guidelines for those pollutants. When BAT
is established, EPA will determine if those three phthalates pass
through a POTW.
Pretreatment Standards for New Sources (PSNS)
The Agency is not promulgating PSNS for this subcategory at this
time for any pollutant; PSNS for bis(2-ethylhexyl) phthalate,
di-n-butyl phthalate, and dimethyl phthalate are reserved. The
Agency believes that new and existing indirect discharge sources
will discharge the same pollutants in similar amounts. As dis-
cussed in the preceding subsection, EPA has determined that the
average percentage of toxic pollutants removed nation-wide by
well-operated POTWs meeting secondary treatment requirements is
greater than the average percent of toxic pollutants removed by
the model treatment technology for BAT, which is the technology
basis for NSPS. Therefore, the toxic pollutants do not pass
through a POTW. Even though the Agency is not promulgating
categorical pretreatment standards, indirect discharges at new
sources in this subcategory must comply with the General
Pretreatment Regulations - 40 CFR Part 403.
13
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The Agency believes that the concentrations of the three phthal-
ates in finishing waters discharged from new sources will be
similar to the concentrations of those pollutants discharged from
existing indirect sources. For this reason, the Agency is
reserving PSNS for bis(2-ethylhexyl) phthalate, di-n-butyl
phthalate, and dimethyl phthalate until completion of the phthal-
ate treatability study. When the technology basis for the NSPS
for those pollutants is established, EPA will determine if PSNS
for the three phthalates are warranted.
14
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SECTION II
RECOMMENDATIONS
1. EPA has divided the plastics molding and forming category
into three subcategories for the purpose of final effluent
limitations guidelines and standards. They are:
contact cooling and heating water subcategory;
cleaning water subcategory; and
finishing water subcategory.
2. Best Practicable Technology Currently Available (BPT) efflu-
ent limitations guidelines for the contact cooling and heat-
ing water subcategory are based on a statistical evaluation
of the pollutant concentrations in contact cooling and heat-
ing waters. For the cleaning water subcategory and the
finishing water subcategory, the BPT effluent limitations
guidelines are based on the performance of a package acti-
vated sludge plant with pH adjustment and a settling unit
with pH adjustment, respectively.
A. BPT EFFLUENT LIMITATIONS GUIDELINES FOR THE CONTACT
COOLING AND HEATING WATER SUBCATEGORY
The mass of the pollutants listed below that can be dis-
charged is calculated by multiplying the average process
water usage flow rate for the contact cooling and heating
water processes at a point source times the following pollu-
tant concentrations:
Contact Cooling and Heating Water
Concentration used to calculate BPT effluent limitations
Pollutant or Maximum for any 1 day
Pollutant Property (mg/1)
BOD5 26
Oil & Grease 29
TSS 19
pH (1)
1 Within the range of 6.0 to 9.0 at all times.
15
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The permit authority will obtain the average process water
usage flow rate for the contact cooling and heating water
processes from the permittee.
B. BPT EFFLUENT LIMITATIONS GUIDELINES FOR THE CLEANING
WATER SUBCATEGORY
The mass of the pollutants listed below that can be dis-
charged is calculated by multiplying the average process
water usage flow rate for the cleaning water processes at a
point source times the following pollutant concentrations:
Cleaning Water
Concentration used to calculate BPT effluent limitations
Pollutant or
Pollutant Property
Maximum for any
1 day (mg/1)
Maximum for monthly
average (mg/1)
BOD5
Oil & Grease
TSS
pH
49
71
117
(D
22
17
36
(1)
"'Within the range of 6.0 to 9.0 at all times.
The permit authority will obtain the average process water
usage flow rate for the cleaning water processes from the
permittee.
C. BPT EFFLUENT LIMITATIONS GUIDELINES FOR THE FINISHING
WATER SUBCATEGORY
The mass of the pollutants listed below that can be dis-
charged is calculated by multiplying the average process
water usage flow rate for the finishing water processes at a
point source times the following pollutant concentrations:
16
-------
Finishing Water
Concentration used to calculate BPT effluent limitations
Pollutant or Maximum for any Maximum for monthly
Pollutant Property 1 day (mg/1) average (mg/1)
TSS 130 37
pH (1) (1)
1 Within the range of 6.0 to 9.0 at all times.
The permit authority will obtain the average process water
usage flow rate for the finishing water processes from the
permittee.
3. Except for one phthalate in contact cooling and heating
waters and three phthalates in finishing waters, best avail-
able technology economically achievable (BAT) equals BPT for
each subcategory. The BAT effluent limitations guidelines
are the same as the BPT effluent limitations guidelines for
each subcategory. The BAT effluent limitations guidelines
for phthalates in two subcategories are reserved pending
further study.
A. BAT EFFLUENT LIMITATIONS GUIDELINES FOR THE CONTACT
COOLING AND HEATING WATER SUBCATEGORY
(1) The BAT effluent limitations guidelines for bis(2-ethyl-
hexyl) phthalate are reserved.
(2) The Agency has determined that, with the exception of
bis(2-ethylhexyl) phthalate, there are no toxic pollu-
tants in treatable concentrations in contact cooling and
heating waters. Accordingly, the Agency is promulgating
BAT effluent limitations guidelines equal to the BPT
effluent limitations guidelines.
B. BAT EFFLUENT LIMITATIONS GUIDELINES FOR THE CLEANING
WATER SUBCATEGORY
The Agency has determined that there are insignificant quan-
tities of toxic pollutants in cleaning process waters after
application of BPT. Accordingly, because the BPT level of
treatment provides adequate control, the Agency is establish-
ing BAT effluent limitations guidelines equal to the BPT
effluent limitations guidelines.
17
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C. BAT EFFLUENT LIMITATIONS GUIDELINES FOR THE FINISHING
WATER SUBCATEGORY
(1) The BAT effluent limitations guidelines for bis(2-ethyl-
hexyl) phthalate, di-n-butyl phthalate, and dimethyl
phthalate are reserved.
(2) The Agency has determined that, with the exception of
bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and
dimethyl phthalate, there are no toxic pollutants in
treatable concentrations in finishing waters. Accord-
ingly, the Agency is promulgating BAT effluent limita-
tions guidelines equal to the BPT effluent limitations
guidelines for this subcategory.
4. EPA could not identify a technology that would reduce the
concentrations of conventional pollutants in contact cooling
and heating waters. Therefore, the Agency has no reason to
await promulgation of the final BCT methodology before prom-
ulgating BCT effluent limitations guidelines for the contact
cooling and heating water subcategory. The BCT effluent
limitations guidelines for that subcategory are the same as
the BPT effluent limitations guidelines.
The Agency identified at least one technology, filtration,
that could reduce the concentrations of conventional
pollutants in cleaning waters and in finishing waters after
application of BPT. Accordingly, BCT effluent limitations
guidelines are not being promulgated for those subcategories
until the final BCT methodology is promulgated.
A. BCT EFFLUENT LIMITATIONS GUIDELINES FOR THE CONTACT
COOLING AND HEATING WATER SUBCATEGORY
The mass of the pollutants listed below that can be dis-
charged is calculated by multiplying the average process
water usage flow rate for the contact cooling and heating
water processes at a point source times the following
pollutant concentrations:
18
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Contact Cooling and Heating Water
Concentration used to calculate BCT effluent limitations
Pollutant or Maximum for any 1 day
Pollutant Property (mg/1)
BOD5
Oil & Grease
TSS
PH
26
29
19
(D
Within the range of 6.0 to 9.0 at all times.
The permit authority will obtain the average process water
usage flow rate for the contact cooling and heating water
processes from the permittee.
B. BCT EFFLUENT LIMITATIONS GUIDELINES FOR THE CLEANING
WATER SUBCATEGORY
[Reserved]
C. BCT EFFLUENT LIMITATIONS GUIDELINES FOR THE FINISHING
WATER SUBCATEGORY
[Reserved]
. Except for one phthalate in contact cooling and heating
waters and three phthalates in finishing waters, new source
performance standards (NSPS) are the same as the BAT effluent
limitations guidelines for each subcategory. NSPS for the
phthalates in two subcategories are reserved pending further
study.
A. NEW SOURCE PERFORMANCE STANDARDS FOR THE CONTACT COOLING
AND HEATING WATER SUBCATEGORY
(1) NSPS for bis(2-ethylhexyl) phthalate are reserved.
(2) The mass of the pollutants listed below that can be
discharged is calculated by multiplying the average
process water usage flow rate for the contact cooling
and heating water processes at a new source times the
following pollutant concentrations:
19
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Contact Cooling and Heating Water
Concentration used to calculate NSPS
Pollutant or Maximum for any 1 day
Pollutant Property (mg/1)
BOD5
Oil & Grease
TSS
PH
26
29
19
(D
1 Within the range of 6.0 to 9.0 at all times.
The permit authority will obtain the average process water
usage flow rate for the new source contact cooling and heat-
ing water processes from the permittee.
B. NEW SOURCE PERFORMANCE STANDARDS FOR THE CLEANING WATER
SUBCATEGORY
The mass of the pollutants listed below that can be dis-
charged is calculated by multiplying the average process
water usage flow rate for cleaning processes at a new source
times the following pollutant concentrations:
Cleaning Water
Concentration used to calculate NSPS
Pollutant or Maximum for any Maximum for monthly
Pollutant Property 1 day (mg/1) average (mg/1)
BOD5
Oil & Grease
TSS
pH
49
71
117
(D
22
17
36
(D
1 Within the range of 6.0 to 9.0 at all times.
20
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The permit authority will obtain the average process water
usage flow rate for the contact cooling and heating water
processes from the permittee.
C. NEW SOURCE PERFORMANCE STANDARDS FOR THE FINISHING WATER
SUBCATEGORY
(1) NSPS for bis(2-ethylhexyl) phthalate, di-n-butyl phthal-
ate, and dimethyl phthalate are reserved.
(2) The mass of the pollutants listed below that can be dis-
charged is calculated by multiplying the average process
water usage flow rate for the finishing water processes
at a new source times the following pollutant concentra-
tions:
Finishing Water
Concentration used to calculate NSPS
Pollutant or Maximum for any Maximum for monthly
Pollutant Property 1 day (mg/1) average (mg/1)
TSS
PH
130
(D
37
(D
1 Within the range of 6.0 to 9.0 at all times.
The permit authority will obtain the average process water
usage flow rate for the new source finishing water processes
from the permittee.
6. Except for one phthalate in contact cooling and heating
waters and three phthalates in finishing waters, the Agency
is not promulgating pretreatment standards for existing
sources for the PM&F category because the Agency has deter-
mined that toxic pollutants found in PM&F process waters do
not pass through a well-operated secondary POTW. The PSES
for the phthalates in two subcategories are reserved pending
further study.
21
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A. PRETREATMENT STANDARDS FOR EXISTING SOURCES FOR THE
CONTACT COOLING AND HEATING WATER SUBCATEGORY
(1) PSES for bis(2-ethylhexyl) phthalate are reserved.
(2) Any existing source subject to this subpart that intro-
duces pollutants into a publicly owned treatment works
must comply with 40 CFR Part 403 - General Pretreatment
Regulations.
B. PRETREATMENT STANDARDS FOR EXISTING SOURCES FOR THE
CLEANING WATER SUBCATEGORY
Any existing source subject to this subpart that introduces
pollutants into a publicly owned treatment works must comply
with 40 CFR Part 403 - General Pretreatment Regulations.
C. PRETREATMENT STANDARDS FOR EXISTING SOURCES FOR THE
FINISHING WATER SUBCATEGORY
(1) PSES for bis(2-ethylhexyl) phthalate, di-n-butyl phthal-
ate, and dimethyl phthalate are reserved.
(2) Any existing source subject to this subpart that intro-
duces pollutants into a publicly owned treatment works
must comply with 40 CFR Part 403 - General Pretreatment
Regulations.
7. Except for one phthalate in contact cooling and heating
waters and three phthalates in finishing waters, EPA is not
promulgating pretreatment standards for new sources for the
PM&F category because the Agency has determined that toxic
pollutants found in PM&F process waters do not pass through a
well-operated secondary POTW. PSNS for the phthalates in two
subcategories are reserved pending further study.
A. PRETREATMENT STANDARDS FOR NEW SOURCES FOR THE CONTACT
COOLING AND HEATING WATER SUBCATEGORY
(1) PSNS for bis(2-ethylhexyl) phthalate are reserved.
(2) Any new source subject to this subpart that introduces
pollutants into a publicly owned treatment works must
comply with 40 CFR Part 403 - General Pretreatment
Regulations.
B. PRETREATMENT STANDARDS FOR NEW SOURCES FOR THE CLEANING
WATER SUBCATEGORY
Any new source subject to this subpart that introduces pollu-
tants into a publicly owned treatment works must comply with
40 CFR Part 403 - General Pretreatment Regulations.
22
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C. PRETREATMENT STANDARDS FOR NEW SOURCES FOR THE FINISHING
WATER SUBCATEGORY
(1) PSNS for bis(2-ethylhexyl) phthalate, di-n-butyl phthal-
ate, and dimethyl phthalate are reserved.
(2) Any new source subject to this subpart that introduces
pollutants into a publicly owned treatment works must
comply with 40 CFR Part 403 - General Pretreatment
Regulations.
23
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SECTION III
INTRODUCTION
BACKGROUND
The Federal Water Pollution Control Act Amendments of 1972 estab-
lished a comprehensive program to "restore and maintain the chem-
ical, physical, and biological integrity of the Nation's waters,"
under Section 101(a). By July 1, 1977, existing industrial dis-
chargers were required to achieve "effluent limitations requiring
the application of the best practicable control technology cur-
rently available" (BPT), under Section 301(b)(1)(A); and by July
1, 1984, "effluent limitations requiring the application of the
best available technology economically achievable . . . which
will result in reasonable further progress toward the national
goal of eliminating the discharge of all pollutants" (BAT), under
Section 301(b)(2)(A). New industrial direct dischargers were
required to comply with Section 306 new source performance stan-
dards (NSPS) based on best available demonstrated technology;
existing and new dischargers to publicly owned treatment works
(POTW) were subject to pretreatment standards under Sections
307(b) (PSES) and (c) (PSNS), respectively, of the Act.
The requirements for direct dischargers were to be incorporated
into National Pollutant Discharge Elimination System (NPDES) per-
mits issued under Section 402 of the Act while pretreatment
standards were made enforceable directly against dischargers to a
POTW (indirect dischargers). Although Section 402(a)(1) of the
1972 Act authorized the setting of NPDES permit requirements for
direct dischargers on a case-by-case basis, Congress intended
that, for the most part, effluent limitations guidelines be based
on the degree of effluent reduction attainable by the application
of BPT and BAT. Moreover, Sections 304(c) and 306 of the Act
required promulgation of new source performance standards; and
Sections 304(f), 307(b), and 307(c) required promulgation of
pretreatment standards. In addition to the effluent limitations
guidelines and standards for designated industry categories,
Section 307(a) of the Act required the Administrator to promul-
gate effluent standards for toxic pollutants applicable to all
dischargers of these pollutants. Finally, Section 501(a) of the
Act authorized the Administrator to prescribe any additional
regulations "necessary to carry out his functions" under the Act.
EPA was unable to promulgate many of the toxic pollutant stan-
dards by the dates specified in the Act. In 1976, EPA was sued
by several environmental groups and in settlement of this law-
suit, EPA and the plaintiffs executed a "Settlement Agreement"
that was approved by the Court. This agreement required EPA to
25
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develop a program and adhere to a schedule for promulgating
effluent limitations guidelines, pretreatment standards, and new
source performance standards for 65 "priority" compounds and
classes of compounds for 21 major industries. See, Settlement
Agreement in Natural Resources Defense Council, Inc. v. Train, 8
ERG 2120 (D.D.C. 1976), modified 12 ERG 1833 (D.D.C. 1979),
modified by orders dated October 26, 1982, August 2, 1983;
January 6, 1984; and July 5, 1984.
On December 27, 1977, the President signed into law amendments to
the Federal Water Pollution Control Act (P.L. 95-217). The Act,
as amended, is commonly referred to as the Clean Water Act.
Although this Act makes several important changes in the federal
water pollution control program, its most significant feature is
its incorporation of several of the basic elements of the Settle-
ment Agreement program for toxic pollution control. Sections
301(b)(2)(C) and 301(b)(2)(D) of the Act now require the achieve-
ment by July 1, 1984, of effluent limitations guidelines based on
the application of BAT for toxic pollutants, including the 65
priority compounds and classes of compounds (the same toxic pol-
lutants as listed in Natural Resources Defense Council, Inc. v.
Train, supra) Congress declared toxic under Section 307(a)of the
Act. Likewise, EPA1s program for new source performance stan-
dards is now aimed principally at control of these toxic pollu-
tants. Pretreatment standards control the toxic pollutants and
other pollutants that are incompatible with a POTW. Moreover, to
strengthen the toxics control program, Congress added Section
304(e) to the Act, authorizing the Administrator to prescribe
"best management practices" (BMP) to prevent the release of toxic
and hazardous pollutants from plant site runoff, spillage or
leaks, sludge or waste disposal, and drainage from raw material
storage associated with, or ancillary to, the manufacturing or
treatment process.
In keeping with its emphasis on toxic pollutants, the Clean Water
Act also revised the control program for other types of pollu-
tants. Instead of BAT for "conventional" pollutants identified
under Section 304(a)(4) (including biochemical oxygen demand, oil
and grease, total suspended solids, fecal coliform, and pH), the
new Section 301(b)(2)(E) requires achievement, by July 1, 1984,
of "effluent limitations requiring the application of the best
conventional pollutant control technology" (BCT). The factors
considered in assessing BCT for an industry include a two-part
"cost-resonableness" test (Section 304(b)(4)(B)). See, American
Paper Institute v. EPA, 660 F.2d 954 (4th Cir. 1981). The first
part compares the cost for private industry to reduce its conven-
tional pollutant concentrations with the costs for publicly owned
treatment works for similar levels of reduction of those pollu-
tants. The second part examines the cost effectiveness of
additional industrial treatment beyond BPT.
26
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For nonconventional pollutants, Sections 301(b)(2)(A) and
(b)(2)(F) require achievement of BAT effluent limitations guide-
lines within three years after their establishment, or not later
than July 1, 1984, whichever is later, but in no case later than
July 1 , 1987.
PURPOSE
This document presents the information and data used to develop
the final effluent limitations guidelines and standards for the
plastics molding and forming (PM&F) point source catetgory.
AUTHORITY
Effluent limitations guidelines and standards for the PM&F cate-
gory are promulgated under authority of Sections 301, 304, 306,
307, 308, and 501 of the Clean Water Act (the Federal Water Pol-
lution Control Act Amendments of 1972, 33 U.S.C. 1251 et seq.. as
amended by the Clean Water Act of 1972, Pub. L. 95^T7) (the
"Act"). The PM&F regulation is also promulgated in response to
the Settlement Agreement in Natural Resources Defense Council,
Inc. v. Train, 8 ERG 2120 (D.D.C. 1976), modified 12 ERG 1833
(D.D.C. 1979), modified by orders dated October 26, 1982; August
2, 1983; January 6, 1984; and July 5, 1984.
STUDY APPROACH
The approach used to develop the final PM&F effluent limi-
tations guidelines and standards included the following:
1. The Agency conducted three questionnaire surveys, a two
part telephone survey, and three process water sampling
programs to gather information on production, manufac-
turing processes, water use and dischargepractices,
wastewater treatment, and process water characteristics.
2. EPA sampled 18 PM&F plants to characterize PM&F process
waters. Samples were analyzed for conventional,
selected nonconventional, and priority toxic pollutants.
3. A PM&F category profile was developed using information
from both the questionnaire surveys and literature
sources.
4. The PM&F category was subcategorized based on informa-
tion from the questionnaire surveys and information from
the process water sampling programs.
27
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5. Results of the sampling programs were used to determine
the pollutants in PM&F process water in treatable
concentrations.
6. Control and treatment technologies that effectively
control the pollutants in PM&F process waters were
evaluated.
7. Costs, pollutant removals, energy, and non-water qual-
ity aspects were evaluated for the various treatment
technologies.
8. A model treatment technology was selected for BPT, BAT,
BCT, and NSPS.
9. Effluent concentration data for the model treatment
technologies were obtained.
10. Effluent concentrations for each type of effluent limi-
tations guidelines and standard were then established.
Permit writers use those concentrations and the average
process water usage flow rate for a process, which is
obtained from the permittee, to calculate the mass of a
pollutant that can be discharged.
EPA also evaluated the need for pretreatment standards to control
discharges of pollutants that may pass through a well-operated
secondary POTW. Results of that evaluation are presented in this
document.
28
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SECTION IV
CATEGORY PROFILE
The plastics molding and forming (PM&F) category covers a large,
diverse industry that uses plastic materials to produce a wide
variety of consumer and industrial products. Since shortly after
the discovery of plastic materials, nearly 60 years ago, molding
and forming processes have been used to turn those plastic mate-
rials into usable items. Originally, plastic products were typi-
cally considered to be inexpensive substitutes for wood, leather,
and metal items. However, in many cases, plastic products have
virtually replaced other products due to their superior charac-
teristics, such as light weight, durability, and resistance to
corrosion. New product uses for plastics as well as new plastic
formulations are continually being developed. The products pro-
duced by the plastics molding and forming category are used in a
wide variety of consumer and industrial markets including: auto-
mobiles, appliances and business machines, construction materi-
als, disposables, household furnishings, housewares, and medical
products.
The PM&F category is defined by both molding and forming pro-
cesses and the type of material processed. Plants included in
this category are generally classified by Standard Industrial
Classification (SIC) 3079 (Miscellaneous Plastics Products),
either as the primary or secondary SIC code. Standard Industrial
Classifications are established by the Department of Commerce,
Bureau of the Census. Plants in the PM&F category with a second-
ary SIC code of 3079 include plants in the textiles, lumber and
wood products, printing and publishing, machinery, and transpor-
tation equipment industries. Classification of plants covered by
the PM&F category is further discussed in Section V.
In the course of developing the effluent limitations guidelines
and standards for the plastics molding and forming category,
several data gathering efforts were undertaken to characterize
the category. They included:
sampling at PM&F plants,
conducting questionnaire and telephone surveys, and
reviewing various literature sources.
SAMPLING PROGRAM
Information on the PM&F category was gathered during three waste-
water sampling programs for this regulation. Eighteen PM&F
plants were sampled: seven in 1984, seven in 1983, and four in
1980. Flow measurements taken at the sampled plants provided
29
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information on water use and discharge practices. Wastewater
samples were collected and analyzed for conventional, selected
nonconventional, and priority toxic pollutants. A discussion of
the sampling programs including analytical results is presented
in Section VI and Appendix A.
QUESTIONNAIRE SURVEYS
The plastics molding and forming category was surveyed to gather
information on plant size and age, production, production pro-
cesses used, and the quantity, treatment, and disposal of waste-
water generated at PM&F plants. This information was requested
in three questionnaires mailed under authority of Section 308 of
the Act to companies known or believed to be involved in plastics
molding or forming. A two-part telephone survey was used to
develop the sample population for the third questionnaire survey.
1978 and 1979 Questionnaire Surveys
In 1978, 8,450 firms were sent a one-page questionnaire. The
names and addresses of the plants on the mailing list for this
questionnaire were compiled from the following sources:
1. Dun & Bradstreet, Inc. and
2. Fortune 500.
The questionnaire asked if the company was a plastics molder and
former; if process water was used, (i.e., water that contacts the
plastic product); the type of discharge mode; what plastic mate-
rials were used; and what products were produced at the plant.
When firms had plastics molding and forming processes at more
than one location, a questionnaire was completed for each plant.
A total of 5,138 questionnaires were returned: 1,114 indicated
the plant uses process water in a PM&F process and 4,024
indicated the plant did not use process water.
From the 1,114 respondents to the 1978 survey that indicated they
use process water, 750 plants were mailed a more detailed ques-
tionnaire in 1979. Approximately 59 percent of the companies
responded to the survey. Of the 440 respondents to the survey,
407 returned completed questionnaires and 33 indicated they had
responded incorrectly to the one page questionnaire and had only
dry processes (i.e., process water did not contact the formed
plastic product). Seventy-five of the 407 returned question-
naires contained unclear data. Therefore, only data from the
other 332 questionnaires were included in the data base for this
regulation.
30
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1983 Telephone Survey
In 1983, a two-part telephone survey was conducted to screen the
target population for the third questionnaire survey. The first
part of the telephone survey consisted of calling:
1. Two hundred thirty-two plants that returned a completed
1979 questionnaire;
2. One hundred ninety-three randomly selected plants that
received a questionnaire in 1979 but did not return it;
and
3. Seven hundred thirty-four plants, which is one-half of
the PM&F plants (i.e., "new plants") that entered the
market between January 1, 1978, and December 31, 1981,
according to Dun and Bradstreet's list of plants with a
primary SIC Code 3079.
The first part of the telephone survey was designed so that the
ratio of plants that returned a completed questionnaire in 1979
to those that did not return a completed 1979 questionnaire
(232:193) was the same as the actual ratio of plants that
returned a completed 1979 questionnaire to those that did not
return a completed questionnaire (407:343). All plants called in
the telephone survey were asked whether they were plastics
molders and formers and if they use process water in their PM&F
processes.
Table IV-1 contains the results of the first part of the tele-
phone survey. As shown in the table, 50 percent of the new
plants indicated they use process water. This number was viewed
with caution because the Agency believes that many of the respon-
dents did not completely understand the difference between
contact and non-contact cooling water.
In the second part of the 1983 telephone survey, the other por-
tion of the new PM&F plants that entered the market between
January 1, 1978, and December 31, 1981, (according to Dun and
Bradstreet's listing of plants with a primary SIC 3079) were
contacted. They were also asked if they were plastics molders
and formers and if they use process water. However, they were
asked more specific questions, such as what kind of PM&F pro-
cesses they employ. Because more time was spent asking detailed
questions, information from this part of the survey concerning
the number of processes that use process water (i.e., wet) and
that do not use process water (i.e., dry) is more reliable than
similar information from the first part of the telephone survey.
31
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In the second part of the telephone survey, 741 PM&F plants were
contacted. Out of that number, 535 plants were plastic molders
and formers, while the remaining 206 plants were not. Eighty-
four (16 percent) of the 535 PM&F plants had wet processes and
451 (84 percent) had dry processes.
Table IV-2 contains a distribution of the wet and dry processes
from the second part of the telephone survey by the type of pro-
cess. The number of wet processes and the number of dry proces-
ses are larger than the number of PM&F plants because some plants
had more than one PM&F process. Types of processes with the
largest number of wet processes were extrusion, molding, and
finishing.
Results of the second part of the telephone survey are distrib-
uted by type of wet process and discharge mode in Table IV-3.
Most PM&F processes in the second part of the telephone survey
discharged process water to a POTW or did not discharge process
water (i.e., zero discharge).
Statistics from the 1978 single page questionnaire and the second
part of the 1983 telephone survey were used to estimate the per-
centages of wet and dry plants in the PM&F category. These were
the only two surveys not directed solely at plants believed to
use process water. Of the 5,138 PM&F plants that returned the
single page questionnaire in 1978, 21 percent indicated they had
wet PM&F processes. This percentage was averaged with the 16
percent of the PM&F plants from the second part of the 1983 tele-
phone survey that had wet processes to obtain an estimate of 18.5
percent of the plants in the PM&F industry that are wet (i.e.,
use process water). Multiplying that percentage times the esti-
mated 10,260 plants in the PM&F category provides an estimate of
1,898 wet plants in the category.
The total number of 10,260 PM&F plants in the United States was
estimated from the State Industrial Guides (Appendix B lists the
guides used to develop this estimate) . For the purpose of the
analysis to determine the economic impact of the PM&F regulation,
a sample of PM&F plants was selected from the State Industrial
Guides. The sample, created by extracting every 20th plant
listed as a producer of SIC 3079 products, formed a data base
with 513 entries. Because one of every 20 plants was included,
the 513 entries represent five percent of the category. It fol-
lows that the PM&F category is comprised of approximately 10,260
plants. (20 x 513 = 10,260). Approximately 77 percent of the
513 randomly selected plants had a primary SIC of 3079 and
approximately 23 percent had a secondary SIC of 3079. Applying
these percentages to the total number of plants in the PM&F
industry yields 7,900 plants that are primary plastics molders
and formers and 2,360 that mold and form plastics as a secondary
33
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Table IV-2
RESULTS OF 1983 PLASTICS MOLDING AND FORMING TELEPHONE SURVEY
SECOND PART
Type of
Process
Extrusion
Molding
Coating and
Laminating
Thermoforming
Calendering
Casting
Foaming
Cleaning
Finishing
Wet
Processes
52
18
1
0
0
1
0
3
11
(%)*
(48)
(5)
(3)
(0)
(0)
(14)
(0)
(60)
(13)
Dry
Processes
57
329
34
61
2
6
11
2
72
(%)*
(52)
(95)
(97)
(100)
(100)
(86)
(100)
(40)
(87)
Total
109
347
35
61
2
7
11
5
83
(%)
(100)
(100)
(100)
(100)
(100)
(100)
(100)
(100)
(100)
TOTAL
86
574
660
Wet Processes
Dry Processes
Total
86
574
660
13
87
100
*Percent of type of process
34
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Table IV-3
DISTRIBUTION OF THE NUMBER OF PLASTICS MOLDING AND FORMING
PROCESSES BY DISCHARGE MODE*
Type of Wet
% of Total
Discharge Mode
Process
Extrusion
Molding
Coating and
Laminating
Casting
Cleaning
Finishing
Wet Processes
60.4
20.9
1 .2
1 .2
3.5
12.8
Direct
1
1
0
0
0
0
Indirect
15
7
0
1
3
1
Zero
31
10
1
0
0
10
Unknown
5
0
0
0
0
0
Total
52
18
1
1
3
11
TOTAL
100.0
27
52
86
*Based on information from second part of 1983 telephone survey.
35
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operation. The types of plants with a secondary plastics molding
and forming operation include: textiles, lumber and wood prod-
ucts, printing and publishing, machinery, and transportation
equipment.
1983 Questionnaire Survey
To further update the questionnaire data collected in 1978 and
1979 and the telephone survey data collected in 1983, 330 ques-
tionnaires were mailed in June 1983 to PM&F plants believed to
use process water. The questionnaire sample was developed based
on the following criteria:
1 . The sample was selected to obtain current information
for plants in the category that used process water (wet
plants).
2. The sample consisted of "new" PM&F plants (those enter-
ing the market between January 1, 1978, and December 31,
1981) and "old" PM&F plants that use process water.
3. The number of "new" wet plants was based on data
obtained through the two-part 1983 telephone survey.
4. The number of "old" wet plants was based on data
obtained from the 1978 and 1979 questionnaire surveys
and from the first part of the 1983 telephone survey.
All plants entering the market between January 1, 1978, and
December 31, 1981, were called during the 1983 two-part telephone
survey. Results of that telephone survey indicate that there are
317 new plants that have wet processes.
As previously mentioned, a one-page questionnaire was mailed to
8,450 plants in 1978. There were 1,114 respondents to that ques-
tionnaire that indicated they had wet PM&F processes. A more
detailed questionnaire was mailed to 750 of the 1,114 respondents
in 1979.
Four hundred seven of the plants that received the 1979 detailed
questionnaire returned a completed questionnaire and 343 did not
return a completed questionnaire. Applying the percentage of the
plants that returned completed questionnaires and the percentage
of those that did not return completed questionnaires to the
1,114 wet plants reported in the 1978 one-page questionnaire
provides an estimate of the 1,114 plants that would have returned
a completed questionnaire and that would not have returned a
completed questionnaire if all 1,114 wet plants were mailed a
detailed questionnaire. Using those percentages, the Agency
36
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estimated that 605 of 1,114 wet plants would have returned a com-
pleted questionnaire and 509 would not have returned a completed
questionnaire.
To determine the current status of the 750 plants that received
the 1979 questionnaire, 425 of those plants were called in 1983.
Two hundred thirty-two of the 425 plants returned a questionnaire
in 1979 and 193 did not return the questionnaire. As previously
mentioned, this telephone survey was designed so that the ratio
of the plants that were called (i.e., 232:193) was the same ratio
of the plants that returned and did not return completed 1979
detailed questionnaires (i.e., 407:343).
Results of this telephone survey indicated that 182 of the 232
plants that returned completed 1979 questionnaires were still in
business and had wet PM&F processes. Twenty-nine of the 193
plants that did not return a completed 1979 questionnaire were
still in business and had wet PM&F processes.
The estimated number of the 1,114 wet plants from the 1978 ques-
tionnaire survey that would have returned a detailed question-
naire (i.e., 605) and the estimated number that would not have
returned the questionnaire (i.e., 509) if all 1,114 plants had
been mailed a questionnaire in 1979 were adjusted using the
results of the above telephone survey. Based on those results,
the Agency estimates 475 (605 x 182/232) of the 1,114 wet plants
would have returned the questionnaire and 76 (509 x 29/193) would
not have returned the questionnaire. Therefore, the target popu-
lation for the 1983 questionnaire survey was:
317 new PM&F plants
475 old PM&F plants that would have returned the
1979 questionnaire
76 old PM&F plants that would not have returned
the 1979 questionnaire
868 total
The numbers in each of these strata were used to determine the
distribution of the 330 detailed questionnaires that were mailed
in 1983. That distribution is presented in Table IV-4.
In the 1983 questionnaire survey, companies were requested to
return a questionnaire for each plastics molding and forming
plant they operated. A total of 346 questionnaires were
returned. Of the 346 questionnaires, 324 indicated the plant
molds and forms plastic materials. One hundred sixty-four of
those plants use process water (i.e., they were wet) and 160 do
37
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Table IV-4
DISTRIBUTION OF THE 330 DETAILED 1983 QUESTIONNAIRES
Stratum
Target Number of 1983
Population Questionnaires
New plants
317*
119
Old plants that would have
returned 1979 questionnaire
475**
182
Old plants that would not have
returned the 1979 questionnaire
76**
29
*Based on results of 1983 telephone survey of new plants.
**Based on results of 1983 telephone survey of plants that did
and did not return a completed questionnaire in 1979.
38
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not use process water (i.e., they are dry), meaning 49 percent of
the plants do not use process water even though the survey was
directed at plants who said they did use process water in the
first part of the 1983 telephone survey. This supports the
Agency's contention that plants did not understand the difference
between contact arid non-contact cooling water during the first
part of the telephone survey.
Most of the plants that received the 1979 and 1983 questionnaires
have a primary SIC of 3079, which means that a plant molds and
forms plastics as a primary operation. During a meeting with
representatives from the Society of Plastics Industries (SPI),
they indicated that additional information could be obtained from
plants with a secondary SIC of 3079 (i.e., the plant molds and
forms plastics as a secondary operation) by sending a question-
naire to a sample of companies on the mailing list for the maga-
zine "Plastic World." Therefore, in August 1983, 170 question-
naires were mailed to companies on that list. As with the other
questionnaire surveys, companies were requested to return a ques-
tionnaire for each plastics molding and forming plant that they
operated, so that a total of 173 questionnaires were returned.
Of these, 106 questionnaires indicated the plant molds and forms
plastics with 56 plants using process water and 50 plants having
dry processes. Because the mailing list included many subscrib-
ers not believed to mold or form plastics, such as libraries and
chambers of commerce, statistical information from these ques-
tionnaires was not used to characterize the PM&F category. How-
ever, information from the questionnaires regarding water use
practices at plants with wet processes was included in the data
base for this regulation.
Summary of Questionnaire Data Base
The questionnaire data base for this project consists of ques-
tionnaires from both the 1979 and 1983 surveys. When a plant
returned a questionnaire in 1979 and again in 1983, only the
updated questionnaire from the 1983 survey was included in the
data base. Thus, only 175 of the original 332 questionnaires
from the 1979 questionnaire survey remain in the updated data
base. The data base also contains 207 of the 220 1983 question-
naires returned by wet plants during the 1983 questionnaire
survey. The other 13 questionnaires were incomplete or not
applicable to these effluent limitations guidelines. For the
incomplete questionnaires, it was not possible to obtain addi-
tional data through further contact with the plants. Thus, the
questionnaire data base consists of 175 questionnaires from the
1979 survey and 207 questionnaires from the 1983 survey for a
total of 382 questionnaires.
39
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Table IV-5 contains a distribution of the types of processes by
discharge mode reported on the 1979 and 1983 questionnaires that
make up the data base. These processes use water that contacts
the plastic product. Extrusion processes are the most prevalent
water-users followed by cleaning processes and molding processes.
Calendering processes comprise the smallest percentage of pro-
cesses that use process water (0.8 percent) because most of the
cooling water is contained within the calender roll and never
touches the plastic product.
Each of the questionnaires in the data base for this regulation
were reviewed and the following data were documented for future
reference and evaluation:
company name, plant address, and name of the contact
listed in the questionnaire.
plant discharge status (i.e., direct, indirect, or zero
discharge).
production processes present at the plant; associated
wastewater flow rates; production rates; operating hours;
process water treatment, reuse, or disposal methods; and
the plastic materials processed.
capital and annual treatment costs.
any available pollutant monitoring data provided by the
plant.
The summaries provided a consistent, systematic method of evalu-
ating the information. In addition, procedures were developed to
simplify subsequent analyses. Using those procedures, informa-
tion in the data base was used to:
select and list the plants containing specific production
processes and associated types of process waters and
treatment technologies;
sum the number of plants containing specific processes
and associated types of process waters and treatment
technology combinations;
calculate annual production associated with each process;
and
calculate water use and process water discharge rates for
individual processes.
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41
-------
The survey information was used to develop the PM&F category pro-
file, to develop a subcategorization scheme, to analyze treatment
and control technologies, to determine the water use and dis-
charge practices, and to estimate statistics for the estimated
1,898 plants in the PM&F category that use process water. A more
detailed description of the PM&F data base is presented in
Section VI.
LITERATURE REVIEW
The literature was examined for information on plastics molding
and forming processes and wastewater treatment technologies.
Treatment technology effectiveness and investment and annual
operation and maintenance costs were also obtained from the
literature.
Many sources were reviewed for information on wastewater treat-
ment technologies. EPA's Innovative and Alternative Technology
Assessment Manual provided mostoftheinformationontreatment
technologies.Treatment technology performance data were
obtained from EPA's Treatability Manual, Volume III, Technolo-
gies for Control/Removal of PollutantsT Additional data were
obtainedfromdocumentssupportingthe proposed organic chemi-
cals, plastics, and synthetic fibers category effluent limita-
tions guidelines and standards. Treatment technology information
obtained from these sources is presented in Section VIII. Cost-
ing information was obtained primarily from EPA's Estimating
Water Treatment Costs and vendor contacts. Details on investment
and operation and maintenance costs are presented in Section IX.
A great variety of general references, texts, and articles were
used as sources of information on plastics molding and forming
processes. The process descriptions derived from these sources
are presented later in this chapter. Process information was
supplemented by trip reports for numerous site visits to PM&F
plants. A complete list of references used to obtain both process
information and information on other aspects of the PM&F category
is presented in Section XVI.
INDUSTRY DESCRIPTION
The following description of the PM&F category and the processes
used to mold and form plastic products is based on information
from the sources of information listed above. The literature
provided the foundation on which the descriptions are based.
Literature information has been augmented and updated where
appropriate by data gathered during the sampling episodes and
questionnaire surveys.
42
-------
Plastic materials are a group of synthetic* organic materials
composed of high molecular weight, long chain molecules. The
molecular composition along with the degree of crosslinking and
the pattern and amount of branching in the molecule determines
the material's characteristics. The generic category of plastic
materials includes many types of resins, resinoids, organic poly-
mers, cellulose derivatives, casein derivatives, and proteins.
Except for some specialty applications, the majority of plastic
materials used in consumer and industrial products are syntheti-
cally produced organic polymers and copolymers. The PM&F efflu-
ent limitations guidelines and standards only apply to synthetic
organic polymers (i.e., thermoset polymers, thermoplastic poly-
mers, or combinations of natural polymers and thermoset or ther-
moplastic polymers) that are solid in their final forms and that
were shaped by flow. The materials can be either homogeneous
polymers or polymers combined with fillers, plasticizers, pig-
ments, stabilizers, or other additives. Accordingly, the PM&F
regulation does not apply to natural organic materials.
Plastic materials can be generally classified into two basic
groups: thermoplastics and thermosets. Thermoplastics become
soft when exposed to a sufficient amount of heat and they harden
when cooled. The heating and cooling process can be repeated
several times. Thermoplastic materials can be processed by a
large number of forming processes, the most common being injec-
tion molding and extrusion. They include: acrylonitrile-
butadiene-styrene, polyethylene, polypropylene, polystyrene, and
polyvinyl chloride.
Thermosetting plastics are set into their permanent shape when
heat and pressure are applied during molding or forming. Unlike
thermoplastics, once set into shape, thermoset products cannot be
softened and reformed. Thermoset plastic products are usually
formed by processes such as compression molding, transfer mold-
ing, and casting. Thermoset plastic materials include alkyd
resins, epoxy resins, phenolic resins, and silicone.
Some plastics can be formulated into either thermoplastics or
thermosetting products depending on the extent of crosslinking
permitted during their manufacture. Once produced, these mate-
rials exhibit the properties of the particular type of plastic
and are processed accordingly. Polyurethene and polyester are
two such plastic materials.
* The definition of plastic materials in the PM&F regulation also
includes natural polymers that are combined with synthetic
organic materials, such as cellulose acetate. Wholly natural
organic materials, such as regenerated cellulose, are not
included in this definition.
-------
For the purpose of regulation, the plastics industry is covered
by two industrial point source categories. These categories are:
(1) the organic chemicals, plastics, and synthetic fibers cate-
gory which includes manufacturers who produce and formulate all
the basic plastic resins and who process certain natural organic
materials; and (2) the plastics molding and forming category
comprised of the processors that convert the plastic materials
into usable shapes.
Overlap of the organic chemicals, plastics, and synthetic fibers
category and the plastics molding and forming category occurs
during the production of crude intermediate plastic material,
such as pelletized plastic resin. Plastics molding and forming
processes (e.g., extrusion and pelletizing) used by plastics
resin manufacturers to process crude intermediate plastic mate-
rial for shipment off-site are excluded from the PM&F regulation
and are regulated under the organic chemicals, plastics, and syn-
thetic fibers category. Plastics molding and forming processes
used by plastic resin manufacturers to process crude intermediate
plastic materials that are further processed on-site into inter-
mediate or final plastics products in molding and forming pro-
cesses are controlled by the effluent limitations guidelines and
standards for the plastics molding and forming category.
For example, consider a manufacturer of polyurethane who uses
contact cooling water in a pelletizing operation; the pelletizing
operation is the last step in the polyurethane manufacturing pro-
cess. If those polyurethane pellets (crude intermediate plastic
material) are shipped off-site without further molding and form-
ing, the contact cooling water used in the pelletizing operation
is regulated under the organic chemicals, plastics, and synthetic
fibers category. If, however, the extruded polyurethane pellets
are further extruded on-site into polyurethane tubing (intermedi-
ate or final plastic product), the contact cooling water used in
both the pelletizing operation and the extrusion operation would
be regulated under the plastics molding and forming category.
PM&F plants produce a wide variety of products and range from
small plants with a single process and a few employees to large
plants with several hundred employees. Plastics molding and
forming plants tend to be located near the sales centers of the
United States so that finished consumer products need not be
transported over long distances. Sixty-five percent of the
plants are located in one of the following four clusters:
1. New York, New Jersey, and Pennsylvania;
2. Illinois, Indiana, Michigan, and Ohio;
3. Louisiana, Oklahoma, and Texas; and
4. California and Washington.
44
-------
PLASTICS MOLDING AND FORMING PROCESSES
The plastics molding and forming category consists of plants that
blend, mold, form, or otherwise process a wide variety of plastic
materials into intermediate or final plastic products. There are
nine generic processes used to process plastic materials. They
are:
1. extrusion,
2. molding,
3. coating and laminating,
4. thermoforming,
5. calendering,
6. casting,
7. foaming,
8. cleaning, and
9. finishing.
Each of these processes is described below including discussion
of which PM&F processes use process water and the purpose of the
water. For this regulation, process water is defined as any raw,
service, recycled, or reused water that contacts the plastic
product or contacts shaping equipment surfaces, such as molds and
mandrels, that are or have been in contact with the plastic prod-
uct. Non-contact cooling water is not process water and thus is
not controlled by the final PM&F regulation. Permitting and con-
trol authorities will establish limitations for the discharge of
non-contact cooling water and other non-process wastewater on a
case-by-case basis.
Extrusion Processes
Extrusion processes force molten polymer under pressure through a
shaping die to produce products of uniform cross-sectional area
such as pipe, tubing, sheet, film, and profile. This process has
a number of different applications including the compounding of
polymers, the production of pellets and parisons (blow molding
preforms) for later use, the production of finished and semi-
finished products, and the coating of substrate materials.
A wide range of polymers are extruded. Thermoplastic polymers
are most commonly used and include acrylic resins, acrylonitrile-
butadiene-styrene (ABS), polyacetal, fluoroplastics, nylon,
polyphenylene oxide, polybutylene, polyethylene, polypropylene,
polystyrene, polyvinyl chloride, styrene-acrylonitrile, and
thermoplastic polyesters.
Extruded thermoplastic foams are produced by incorporating a
gas-forming expanding agent in the thermoplastic and extruding
the mixture under carefully controlled conditions. This is an
45
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extrusion process with the addition of a blowing agent at the
extrusion die. Packaging and building products are the major
applications for extruded foam products. The primary raw mate-
rials used to produce extruded foam products are acrylonitrile-
butadiene-styrene, high density polyethylene, polypropylene,
polystyrene, and polyvinyl chloride.
A schematic of the extrusion process is shown in Figure IV-1 .
Polymer granules, pellets, powder, or beads are fed into the
hopper of the extruder. The polymer is picked up by a rotating
screw within the extruder cylinder and is forced toward the die.
Heat provided to the cylinder walls begins the softening of the
polymer pellets. As the material moves along the cylinder, fric-
tion becomes the primary source of heat. During this heating and
compression period, the plastic material is transformed into a
homogeneous melt and is thoroughly mixed.
Prior to leaving the extruder cylinder, the melted polymer passes
through a screen pack that removes dirt and provides back pres-
sure control. The melt enters the die at high pressure. The
extrusion die is a streamlined orifice that reduces the melt to
the desired shape. As the extrudate leaves the extruder, it is
transported over some type of roller or conveyor cooling system
that cools the hot extrudate by use of air or water.
Approximately 50 percent of extrusion processes use contact
cooling water. Contact cooling water is used when a high heat
transfer rate is required such as for the extrusion of
thick-walled products or during pelletizing operations.
Extrusion processes are often used to blend, color, and pelletize
polymers. Additives required for special applications and colors
desired by the processor are added to the resin and are fed to
the extruder to become a homogeneous melt. A brief description
of the most commonly used classes of additives and specialty
chemicals is presented in Table IV-6. The melt is extruded
through a multi-opening die and taken off as strands that are cut
into pellets of the desired size after cooling. In many cases,
the pellets are cut at the face of the die, which is submerged in
water for rapid cooling. Pelletized polymers can be in the form
of round, cylindrical, or cube-shaped particles and can be used
as feed material for extrusion, molding, casting, foaming, and
other processes. Commonly pelletized theromoplastics are ABS,
polyethylene, polypropylene, and polyvinyl chloride.
Extrusion processes can use both contact and non-contact cooling
water. Non-contact cooling water is used to remove excess heat
from the extrusion machinery caused by friction. Direct contact
cooling water is used for product quenching. Extruded profile,
pipe, and tube are often cooled by direct contact cooling water.
46
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Polymer
Feed
Extruder
Cooling
Conveyor
System
Non-contact
Cooling
Water
Contact
Cooling
Water
tExtruded
Product
Polymer Feed
Feed
Hopper
Strainer
Die
Extruded
Plastic
Blowing Agent for Foams
Mechanical Screw
Source: Adpated from Masson, D. (ed) . The Study of the Plastics Industry. 1973.
Figure IV-1
EXTRUSION PROCESS
47
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Table IV-6
COMMONLY USED ADDITIVES IN POLYMER FORMULATION
USING THE EXTRUSION PROCESS
Additive
Antiblocking Agent
Antioxidants
Antisatic Agents
Catalysts
Chemical Resistant
Additives
Colorants
Coupling Agents
Cure Retardants
Curing Agents
Fibrous Reinforcements
Fillers and Extenders
Flame Retardants
Foaming (blowing) Agents
Heat Stabilizers
Function
Prevents self-adhesion of films
Retard oxidative degradation of
plastic material during process-
ing and use
Reduce the accumulation of elec-
tronic charge on the surface of
polymers
Affect the rate of chemical reac-
tions without themselves being
consumed or undergoing chemical
change
crease polymer susceptibility
chemical degradation
Descrease
to
Impart hue (shade), volume
(brightness), and chroma
(strength of color) to plastics
Enhance polymer-mineral surface
bonds and increase the ability of
composites to retain properties
during prolonged exposure to
moisture
Reduce the cure rate for amino
resins
Improve the curing of thermo-
setting resins upon exposure to
heat
Impart tensile, flexural, and
compressive strength to plastics
Increase the bulkiness and
decrease the total cost of
plastic formulations
Act chemically or physically as
insulators by creating endother-
mic cooling reactions, by coating
the plastic to exclude oxygen or
by influencing combustion through
reaction with materials that have
different physical properties
Produce large quantities of gases
upon heating that form cellular
plastics
Prevent the degradation of the
plastic material during process
heating and during its useful
life
Silicate minerals
High melting point waxes
Alkylated phenols
Amines
Phosphates
Thio compounds
Amine
Quaternary ammonium
Anionic surface active
agents
Peroxides
Organo-tin compounds
Amines
Glass
Synthetic fibers
Graphite
Dyes
Organic and inorganic
pigments
Silane compounds
Titanate compounds
Amines
Peroxides
Amines
Azo compounds
Synthetic fibers
Carbon fibers
Glass fibers
Calcium carbonate
Silica
Nutshell flours
Antimony oxide
Chlorinated parafins
Halogenated organics
Nitrogen
Pentane
Azo bis formamide
Barium-cadmium compounds
Tin compounds
48
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Table IV-6 (Continued)
COMMONLY USED ADDITIVES IN POLYMER FORMULATION
USING THE EXTRUSION PROCESS
Additive
Impact Resistant
Additives
Insulators
Lubricants
Mold Release Agents
Plasticizers
Preservatives and
Biocides
Casting Promoters
Sizing Agents
UV Stabilizers
Function
Decrease a plastic materials
tendency to break or crack upon
impact
Improve the thermal or electrical
insulating properties of polymers
Enhance resin processibility and
the appearance of the end product
Prevent sticking of newly formed
parts to a noId
Impart flexibility, resiliency
and increasing melt flow to poly-
mers by reducing the Intramolecu-
lar forces between polymer chains
Inhibit biological degradation of
polymers
Improve the cure of cast parts
Coatings that protect the polymer
surface
Absorb ultraviolet radiation and
reradiate it at a harmless wave-
length or consume the free radi-
cals generated by UV light
Example
Acrylics
ABS
Silaceous minerals
Ceramic oxides
Fatty acid esters
Hydrocarbon oils
Paraffin wax
Amides
Silicon
Mineral oil
Wax
Fatty acids
Mica
Talc
Phthalates
Adipates
Trimellltates
Glycolates
Fatty acid esters
Organic phosphates
Fungicides
Bacteriostats
Cobalt octoate
Dimethyl aniline
Tin salts
Waxes
Benzotrlazoles
Benzophenones
49
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Plastic jacketed wire and cable is also passed through a water
bath for direct contact cooling. The use of contact cooling
water in extrusion processes is the major source of process water
in the plastics molding and forming category.
Molding Processes
Molding is the most common process used to produce finished or
semi-finished products from plastic materials. Molded parts can
be solid, hollow, or foamed.. Plastic objects of almost any
desired shape can be produced commercially by one of seven
different types of molding processes:
1. injection molding,
2. blow molding,
3. compression molding,
4. transfer molding,
5. reaction injection molding,
6. rotational molding, and
7. expandable bead foam molding.
Injection Molding. Injection molding is used to form intricate
plasticpartswith excellent dimensional accuracy at very high
production rates. Injection molding involves the plasticating of
pelletized plastic materials with heat and the subsequent
injection of the melt into a mold.
Both thermoplastic and thermoset polymers are injection molded.
The majority of injection molded products are produced from
polyethylene, polypropylene, polystyrene, and acrylonitrile-
butadiene-styrene (ABS). Other polymers that are commercially
injection molded are acrylic resins, fluoroplastics, nylons,
phenolic resins, polyacetal, polycarbonate, polyesters, poly-
phenylene sulfide, and styrene-acrylonitrile. Typical injection
molded products include appliance parts, furniture parts, machine
parts, office and household items, and toys and novelties.
Fillers can be added during the injection molding process to
produce reinforced plastic products such as appliance components
and sporting goods.
A schematic of the injection molding process is shown in Figure
IV-2 . The resin and additives are fed into the heating portion
of the injection molding machine where the polymer is heated to
the temperature at which it becomes soft enough to flow. An
injection system forces the melt through a nozzle, then through
sprues and runners, and finally into the cavities of the mold
where high pressure is held briefly to allow the plastic to set.
As thermoplastics cool in the mold, they retain the desired
product shape. Thermosets require that heat be applied to the
mold to complete polymerization.
50
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Non-contact Cooling Water
1 —
Polvmer j_ to
Feed
Heating/
Injection
System
V "7
~"
— -J
Removal
Mold
Injection
Molded Part
Mold
Polymer
Feed
Blowing Agent
For Foams
Plunger or
Screw
Source: Adpated from Masson, D. (ed). The Study of the Plastics Industry. 1973.
Figure IV-2
INJECTION MOLDING PROCESS
51
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Structural foam molding is an injection molding process where a
blowing agent is added to either the polymer input materials or
the polymer melt. Polystyrene is the major material used in
structural foam molding. The following polymers are also used:
acrylonitrile-butadiene-styrene, polyphenylene oxide, polycar-
bonate, high density polyethylene, polypropylene, and polysty-
rene. Uses for structural foam include furniture, business
machines, and construction products.
There are four basic types of heating/injection systems used for
commercial injection molding. They are: (1) conventional injec-
tion molding machines, (2) piston-type preplasticating machines,
(3) screw type preplasticating machines, and (4) reciprocating-
screw injection machines. The reciprocating screw injection
machine is the most common machine for modern plastics processing
due to its faster cycles, lower melting temperature requirements,
and better mixing.
In conventional injection molding machines the plastic granules
or pellets feed from a hopper into the chamber of the heating
cylinder. A plunger compresses the material forcing it through
progressively hotter zones of the heating cylinder. The material
flows from the heating cylinder through a nozzle and into the
mold. In piston-type preplasticating machines a heater is used
to preplasticate the plastic granules after which the plastic is
held in a holding chamber until it is molten enough to be forced
into the die. A piston rams the plastic through the nozzle into
the mold. In screw-type preplasticating machines, an extruder is
used to plasticize the plastic material. A rotating screw feeds
the pellets forward into the heated interior surface of the
extruder barrel. The molten plastic is extruded into a holding
chamber and is forced into the die by an injection plunger. In
reciprocating screw injection machines, a rotating screw moves
the plastic material forward through a heated extruder barrel.
As the molten plastic material moves forward, the screw backs up
to a limit switch that determines the volume of material collect-
ing in the front of the barrel. The screw then acts as a ram and
injects the plastic material into the die.
The majority of all injection molding operations use non-contact
cooling water circulated through channels in both the injection
equipment and the product mold. Direct contact cooling may be
used, however, when molded parts require rapid cooling.
Blow Molding. Blow molding is used to produce hollow, thin wall
objects from thermoplastic resins; it has become one of the major
processing methods for the plastics industry for hollow articles.
Blow molding involves extruding or injection molding a preformed
shape that is then blown into its final form by compressed air.
52
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Most thermoplastic materials can be blow molded; however, high
density polyethylene has traditionally been the workhorse of the
blow molding industry. Other thermoplastic polymers commercially
used for blow molding include acrylic resins, acrylonitrile-buta-
diene-styrene, polyacetal, polycarbonate, polyester, polyethyl-
enes, polypropylene, polystyrene, and polyvinyl chloride. Blow
molding processes are used to produce a wide range of hollow bot-
tles and containers. Approximately 80 percent of the blow mold-
ing processes produce packaging items. These include household
bottles and containers for cosmetics, toiletries, pharmaceuti-
cals, chemicals, and foods, as well as industrial containers.
The remaining 20 percent produce industrial products such as
automobile fuel tanks, lighting fixture globes, ornaments, and
toys.
A schematic of a blow molding process is shown in Figure IV-3.
Blow molding processes can be divided into two major types:
extrusion blow molding and injection blow molding. These two
processes are similar in that they both use a parison, or pre-
shaped sleeve, of plastic that is expanded by air pressure to
fill the inside of a concave mold. The difference between the
processes lies in the formation of the parison. Extrusion blow
molding uses an extruder to preform parisons whereas in injection
blow molding the parisons are formed in an injection mold. Blow
molding processes use non-contact cooling water to cool the mold.
Compression Molding. Compression molding is one of the earliest
forms of molding; it requires only one major piece of equipment:
the compression press. Compression molding involves shaping a
measured quantity of plastic within a mold by applying pressure
and heat. This molding process is ideal for the production of
parts with large areas and relatively simple shapes.
Compression molding is primarily used for processing thermoset
resins, although it is used to mold thermoplastics for special
applications. Polymers most commonly used in compression molding
include alkyd resins, amino resins, diallyl phthalate, epoxy
resins, phenolic resins, and polyester resins. Other less fre-
quently used polymers include polytetrafluorethylene, polyure-
thane, silicone, and polyvinyl chloride. Fillers such as glass
fibers, wood, cotton, and cellulose are often used during com-
pression molding to produce reinforced plastic products. Typical
compression molded products include novelties, knobs, handles,
dinnerware, buttons, electrical and electronic components, and
appliance parts. Reinforced products include large automotive
and appliance parts.
A schematic of the compression molding process is shown in Figure
IV-4. The plastic material is fed to the compression mold either
in granular form or as a preform. The mold halves are then
53
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Non-contact Cooling Water
Polymer
and ~*
Additives
Polymer
and ~
Additives
Extrusion
of
Injection
Molding of
Paris on
i. -.
A t
i\L/
Molding
^
|
_J
Blow
Molded
Part
Mold
Gripper
Arm
Parison
Air Injection
Pin
Source: Adapted from Seymour, W.B. Modern Plastics Technology. 1975.
Figure IV-3
BLOW MOLDING PROCESS
54
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Non-contact Cooling Water
Premeasured
Polymer or
Preform
\^/
Compression
Mold Within
Hydraulic Press
Compression
Molded Part
Guide Pin
Premeasured
Polymer Charge
Mold Cavity
Source: Adapted from Masson, D. (ed). The Study of the Plastics Industry. 1973.
Figure IV-4
COMPRESSION MOLDING PROCESS
55
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closed by a hydraulic press. Pressure is maintained and heat is
applied, causing the plastic to spread to the shape of the mold.
Compression molding processes generally use non-contact cooling
water to cool the mold halves. Some compression molding pro-
cesses may use contact cooling water sprays to rapidly cool newly
formed products.
Transfer Molding. Transfer molding is much like compression
moldingwiththe difference being that in transfer molding the
resin is preheated in a separate chamber and is then forced into
the mold cavity for curing.
Thermoset resins are most commonly transfer molded. These
include alkyd resins, amino resins, diallyl phthalate resins,
epoxy resins, phenolic resins, and polyester resins. Fillers
such as cellulose, clay, glass fiber, minerals, and synthetic
fibers are often used during transfer molding to produce rein-
forced plastic products. Transfer molding is especially well
suited for the production of small intricate thermoset parts and
is used extensively in the production of electrical insulating
parts and connectors. Reinforced products include appliance
housings and decorative parts.
A schematic of the transfer molding process is shown in Figure
IV-5. Plastic preforms are preheated by heat lamps, hot air
ovens, or dielectric heaters. That material is put into a
chamber or "transfer pot" where it is plasticized by heat and
pressure into a viscous mass. The plastic is then forced through
sprues and runners into the mold cavity. The pot, sprues,
runners, and cavity surfaces are maintained at a temperature
suitable for rapid curing of the material. The plastic is held
in the mold at its cure temperature until the part is capable of
maintaining its shape. Transfer molding processes generally do
not use contact water to cool the product.
Reaction Injection Molding. Reaction injection molding (RIM)
involvesthe simultaneous high pressure injection of two or more
reactive liquids into a mixing chamber followed by low pressure
injection into a mold cavity. Most commercial reaction injection
molding is performed with various urethane formulations. The
majority of urethane formulations are comprised of two liquid
intermediate feeds: the resin and isocyanate. When blowing
agents are incorporated in the isocyanate feed, foam products are
formed. Fillers are added during reaction injection molding to
produce reinforced plastic products for the automotive industry.
Reaction injection molded polyurethane products include bumper
systems, panelling, automotive trim, sporting goods, and
machinery housing.
56
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Non-contact Cooling Water
Polymer
Preforms
Preform
Preheater
I
Transfer
Chamber
"V7
Mnl A
_ j
Removal
Trimming
Transfer
Molded
Part
Transfer Ram
Guide Pins
Mold Cavity
Figure IV-5
TRANSFER MOLDING PROCESS
57
-------
A schematic of a reaction injection molding process is shown in
Figure IV-6. A reaction injection molding process consists of
four integrally related units: feed tanks, a metering system, a
mixer, and the mold. The feed tanks are where the raw material
components are stored and heated. Agitators, heat exchangers,
low-pressure pumps, and recirculation equipment are used to main-
tain liquid temperature and uniformity. Liquid material from the
feed tanks are metered to the mixing head where they are mixed
under high-pressure. The liquids are then injected into the mold
where polymerization occurs. Once the part has sufficiently
cured to hold its shape, the mold is opened and the part is
ejected. Contact water is not used during the reaction injection
molding process. The molded parts can be sufficiently cooled by
air. Non-contact water may be used to cool the mold.
Rotational Molding. Rotational molding, sometimes termed roto-
molding or rotocasting, is used to make rigid or flexible thin-
walled hollow objects from thermoplastic materials. Rotational
molding involves rotating polymer powder or liquid in a heated
hollow irold.
Rotational molding is performed almost exclusively with thermo-
plastic resins such as polyamide resins, polyacetal, polycar-
bonate, low density polyethylene, and polyvinyl chloride. The
rotational molding process is used to produce a wide range of
industrial and consumer goods including arm rests, toys and
novelties, sporting goods, and tanks and storage bins.
A schematic of the rotational molding process is shown in Figure
IV-7. Premeasured amounts of the polymer powder or liquid are
put into the preheated hollow mold at the mold loading station.
The mold is then put in the circulating hot air oven where it is
simultaneously rotated around two perpendicular axes. The heat
forces the thermoplastic to melt and the rotation uniformly
distributes the polymer over the entire mold surface. The mold
is then removed from the heating oven and is cooled. After the
part has cooled sufficiently to hold the desired shape, the mold
is opened and the part is removed.
Most rotational molding processes use non-contact cooling water
to cool the outside surface of the mold. Some rotational molding
processes may use direct contact water sprays when rapid cooling
of the part is necessary.
Expandable Bead Foam Molding. Expandable bead foam molding
processes produce a closed-cell, rigid plastic foam material
characterized by fused polymer spheres. The fused polymer prod-
uct is produced by expanding beads impregnated with hydrocarbon
in a mold cavity. The beads puff and fuse together filling the
mold cavity when heated.
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Most bead foam molding processes use polystyrene or polyvinyl
chloride as raw materials. Typical end products are packaging
materials, flotation devices, insulation, and hot and cold
containers.
A schematic of an expandable bead foam process is shown in Figure
IV-8. Polystyrene beads are usually pre-expanded to a bulk den-
sity close to the desired product bulk density prior to further
processing. Pre-expansion equipment commonly consists of a steam
chamber with baffles and mechanical agitation. Condensate is
discharged from the steam chamber.
The pre-expanded beads are fed to a preheated split cavity mold.
Steam is supplied to the mold cavity through small holes in the
mold. The heat supplied by the steam causes the impregnated
beads to expand to fill the confines of the mold. The soft and
molten bead skins fuse together to form a single polymer mass.
Condensed steam (contact heating water) is discharged from the
mold cavity.
Water is generally not used for the direct contact cooling of
foam products. Non-contact cooling water is used to cool
extruder and mold assemblies. However, the steam that heats the
product becomes a source of contact heating process water when
condensed.
Coating and Laminating Processes
Coating and laminating processes combine polymeric materials with
other materials to produce products with special properties such
as chemical resistance, toughness, humidity resistance, corrosion
resistance, and electrical insulation. Heat is used in both
processes. Lamination also requires high pressures.
Coating. Polymer coatings are applied in the form of a melt,
liquid" or finely divided powder onto numerous substrates includ-
ing other plastic objects, metal, wood, paper, fabric, leather,
glass, concrete, and ceramics. Both thermoplastic and thermoset
resins can be coated. The most common resins used are: acrylic
resins, epoxy resins, fluoroplastics, amino resins, polyesters,
low density polyethylene, polypropylene, and polyvinyl chloride.
Typical products from coating processes include automotive parts,
appliance parts, electrical supplies, furniture, and housewares.
There are four types of coating processes: plastisol coating,
powder coating, spread coating, and extrusion coating. A flow
diagram representing plastisol and powder coating is presented in
Figure IV-9. Spread coating is illustrated in Figure IV-10. A
flow diagram of the extrusion coating process is presented in
Figure IV-11.
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Plastisol Coating. Plastisol coating involves the use of a
liquid plastisol that consists of fine particles of polyvinyl
chloride (PVC) dispersed in plasticizers. Typical plastisol
coated products include housewares and outdoor furniture. The
plastisol is contained in a vat into which the object to be
coated is dipped. The objects are sometimes preheated to assure
sufficient polymer fusion. The dipped parts then pass through an
oven to complete fusion. Some product applications require that
the plastisol be applied to the object surface with a spray gun
or a brush. Whether sprayed or brushed, the coated object must
subsequently be heated in an oven to fuse the polymer coat. The
dip coating process is very similar to a dip casting process.
The difference lies in the nature of the mold. In dip casting,
the plastic part, such" as a glove, is stripped from the mold and
the mold is used to form another part. In dip coating, the mold
is actually part of the finished product, such as a metal patio
chair that is dip coated with plastic.
Powder Coating. Powder coating involves the use of a homogeneous
blend of thermoset or thermoplastic resin, pigments, fillers, and
additives in the form of a dry, fine, flour-like substance.
Three basic powder coating methods exist: fluidized bed, elec-
trostatic spray, and electrostatic bed. Fluidized bed coating
involves creating a fluidized bed of thermoplastic or thermoset
resin powder by the flow of air through a porous plate at the
bottom of a tank. Objects to be coated are preheated and are
then dipped into the fluidized bed. When the resin particles
touch the surface of the hot object they melt and fuse. Electro-
static spraying is performed by charging the polymer powder
either positively or negatively so that it is attracted to a
grounded or oppositely charged object. The electrostatic bed
process is a combination of the fluidized bed and electrostatic
spray methods. Electrodes located in the porous plate at the
bottom of the fluidized bed tank transfer a charge to the powder
particles which are then attracted to the grounded object to be
coated.
Spread Coating. Knife or spread coating uses a long blade or
knifetospread the molten thermoplastic polymer coating on a
moving substrate. Thermoplastics such as low density polyethyl-
ene, polyvinyl chloride, and polypropylene are used to coat
flexible materials such as fabric.
Extrusion Coating. Extrusion coating involves the extrusion of a
thinfilmor"polymer onto a moving substrate, which is usually
either a paper web, plastic sheet, or paper sheet. Polymers such
as low density polyethylene, polypropylene, and polyethylene
terephthalate are used in extrusion coating processes to produce
the coatings.
66
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Laminating. Laminate structures are formed from layers of resins
aridfillers bonded together. Thermosetting resins are the only
resin types commercially used for laminating. Typical laminating
resins include alkyd resins, epoxy resins, melamine formaldehyde,
and phenolic resins. Paper, cloth, glass fiber, and glass cloth
are typically used as the reinforcing substrate. Lamination pro-
cesses are used to produce decorative panels and items requiring
good electrical insulating properties. Process water is
typically not used in lamination processes.
Laminating processes can be classified into three types: lamina-
tion of flat sheets, lamination of rods and tubes, and continuous
lamination. A schematic of the laminating process is shown in
Figure IV-12.
Flat Sheet Lamination. Flat laminate sheets are produced by
impregnatingthebase sheets with liquid thermosetting resin.
Phenolics, melamines, alkyd, polyester, and epoxies are all
commonly used. The correct number of sheets for the specific
application are placed together with the resin between two
platens of a hydraulic laminating press. The hydraulic press
closes and pressure and heat are applied to the layers. The
thermoset resin flows through the filler sheets and cures. After
the sheets have sufficiently cured, the platens are allowed to
cool, the press is opened, and the sheets removed.
Rod and Tube Lamination. Laminate rods and tubes are produced
Fromfillerwebsimpregnated with thermoset resin. Solid rods
are made by winding the impregnated filler web around a very thin
rod (mandrel) which is then withdrawn. The preform rods are then
placed in a compression mold where heat and pressure are applied.
In some operations the rods are placed in an oven and allowed to
cure without pressure over a long period of time, typically 12 to
24 hours. In making a tube, the mandrel is left in during the
compression molding step.
Continuous Lamination. Continuous lamination processes are used
Toproducelargevolumes of structural grade sheets for use as
residential and industrial panels. Polyester resins are most
commonly used in the continuous lamination process along with
chopped glass fibers. Continuous lamination is performed by
combining the resins and reinforcements between two moving
carrier films. The films are pulled through a set of squeeze
rolls to eliminate entrapped air. The laminate cures in an oven
after which the carrier film is stripped from the newly formed
laminate. Figure IV-13 depicts the continuous lamination
process.
67
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Thermoforming Processes
Thermoforming processes involve the heating of thermoplastic
sheet or film to a pliable state and forcing it around the con-
tours of a mold. Vacuum, air pressure, or mechanical force are
employed to aid in the sheet forming. The input for thermoform-
ing processes is foam sheet or film produced by extrusion,
calendering, or casting processes. Sheet and film can be
laminated or printed prior to thermoforming.
A wide variety of sheet and film plastic is suitable for thermo-
forming. Sheet and film for thermoforming is typically made from
acrylic, acrylonitrile-butadiene-styrene, polycarbonate, poly-
ethylenes, polypropylene, polystyrene, and polyvinyl chloride.
Typical thermoformed products include appliance parts, automotive
parts, lighting fixtures, packaging, and signs and displays.
A schematic of the thermoforming processes is shown in Figure
IV-14. Plastic sheet is clamped into a frame prior to thermo-
forming to provide support for the plastic material throughout
the entire process. The plastic sheet is uniformly heated before
being formed to be certain of uniform stretch during forming.
One of three heating methods are usually used: radiant heating,
convection heating, and conduction heating, with radiant heating
being the most commonly used method. When sufficiently heated,
the sheet is formed into the desired shape by one of three form-
ing processes: (1) vacuum forming, (2) pressure forming, and
(3) matched mold forming.
Vacuum Forming. Vacuum forming is the most versatile and most
commonlyused process for thermoforming. The heated sheet is
placed directly above a concave mold and pressure is used to seal
the plastic material to the upper mold edge. Vacuum is applied
from beneath the mold through small holes in the mold cavity
forcing the sheet against the mold contours. Although many vari-
ations of vacuum forming exist, they all employ a vacuum applied
from below the mold surface. Common variations are termed drape
forming, snap-back forming, and plug assist vacuum forming.
Pressure Forming. Pressure forming involves the use of air pres-
suretoforce the softened plastic sheet against the mold. A
sheet of plastic is clamped over a pressure box containing a
concave mold and is heated. The sheet is then covered and com-
pressed air is blown through openings in the cover. The air
pressure forces the sheet against the mold contours. A variation
of pressure forming termed free blowing is used to produce
bubble-like forms.
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Matched Mold Forming. Matched mold forming is used to produce
productsrequiring excellent reproduction detail. The heated
sheet material is placed between convex and concave mold halves.
The halves are brought together, thereby forming the sheet into
the mold shape.
Most thermoforming processes use non-contact cooling water.
However, in some instances, the thermoformed product may be spray
cooled with water.
Calendering Processes
Calendering is widely used in the plastics molding and forming
category to produce uniform thickness film and sheet at high
production rates. Calendering processes squeeze pliable thermo-
plastic between a series of rotating rolls to produce the polymer
film and sheet, to emboss sheet and film, to perform compounding
and to coat textiles and papers.
Flexible and rigid polyvinyl chloride compounds are the most com-
monly used input materials for the manufacture of calendered
products. Typical products include building and construction
supplies, packaging supplies, and consumer and institutional
goods such as toys, seats, and coverings. Acrylonitrile-buta-
diene-styrene, polyethylene, and polystyrene are also used to
produce various films.
A schematic of a calendering process is shown in Figure IV-15.
Calendering processes generally consist of five units: mixing,
calendering, cooling, take-off, and trimming. The thermoplastic
resin and the appropriate additives are transferred from storage
facilities through a sieve to a high shear mixer or mill where
heat is supplied to soften and blend the polymer mix. The poly-
mer is then fed to the calendering unit, which usually consists
of three to five heated cast iron rolls that squeeze the softened
polymer into a sheet or film of desired width and thickness. The
arrangement of the calender rolls is determined by the product
requirements as are the number of rolls and the roll spacings.
The clearance between rolls is progressively decreased to slowly
reduce the thickness and increase the width of the sheet or film.
Most roll arrangements are adjustable to allow versatility in
production methods. Newly calendered sheet is cooled by feeding
the sheet or film through a series of two to ten cooling rolls
cooled with non-contact cooling water. The take-off rolls feed
the sheet and film to edge trimming operations, further finishing
operations, or roll-up.
Calendering is also used to coat materials such as paper and
fabric with a polymer. The process is similar to that described
above except that fabric or paper is fed into the calendering
72
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Non-contact Cooling Water
Polymers
and
Additives
Mixing
r~
i
i
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i
i
Calendering
Rolls
^
_vr_
Embossing
Rolls
Take-Off
Rolls
1
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Trimming
Film
r * or
Sheet
Plastic
Calendered Plastic
Sheet or Film
Guide Roll
Calender
Rolls
Take-Off Rolls
Cooling or
Embossing
Rolls
Source: Adapted from Jlasson, D. (ed). The Study of the Plastics Industry. 1973.
Figure IV-1-5
CALENDERING PROCESS
73
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rolls as the plastic film is formed. The plastic and fabric are
tightly bonded together by the heat and force of the rolls and
emerge from the cooling rolls as a single composite sheet.
Most calendering processes use non-contact water to cool the
cooling rolls. Contact cooling water may be sprayed on both the
plastic sheet and the rubber contact roller as the plastic sheet
passes through the embossing rollers. Some calendering processes
may also use contact cooling water to cool the newly formed sheet
or film.
Casting Processes
In the plastics molding and forming industry, the term casting is
used rather loosely to describe a wide variety of processes.
Casting involves liquid plastic materials allowed to cure at
atmospheric pressure in a mold or on a mold surface.
Both thermoplastic and thermoset resins can be used in casting
processes. Commonly cast thermoplastics include acrylics,
nylons, and polyvinyl chlorides. Commonly cast thermosets
include epoxy resins, polyesters, phenolics, and polyurethanes.
Fillers are often used in casting processes to produce reinforced
plastic products such as boats and recreational vehicles,
troughs, ducts, bins and tubs, as well as preforms for use in the
compression molding of reinforced products.
There are seven types of casting processes: pot casting, slush
casting, dip casting, cell casting, chilled film casting, solvent
casting, and continuous casting. A schematic of pot, slush and
dip, cell, solvent, and continuous casting processes is shown in
Figure IV-16. The chilled film casting process is illustrated in
Figure IV-17.
Pot Casting. Pot casting is the simplest form of casting and is
used to produce a wide variety of products. Polymers used in pot
casting include acrylic, alkyl resins, diallyl phthalate, epoxy,
nylon, phenolic, polyester, polyurethane, and silicone elastomer.
During pot casting a liquid polymer or a monomer solution is
poured into an open mold where is it allowed to cure. The pot
cast part is cured by the addition of heat in an oven, exother-
mically by means of a catalyst, or by a combination of both
methods. Typical pot cast products include novelties, plaques,
knobs, embedments, electrical encapsulations, optical products,
bearings, gears, jewelry, billiard balls, seals and gaskets,
housewares, and furniture parts.
74
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Pot, Cell, Dip, and Slush Casting
Resins and
Additives
Pot Casting
and Cell
Casting:
Dip Casting:
Resins and _j
Additives
Slush Casting:
Cast
Item
Resins and
Additives
Resins
and ""*"
Additives
Solvent
Recovery
__ Solvent
1
^ Belt
Oven
),
Trimming
Solvent
Cast
Sheet
Continuous Casting
Resins
and
Additives
Mixing and
Dispensing
f^ Stainless
T^ Beit
Oven
Station
Cooling
Station
J
Trimming
and
Cutting
Continuous
Cast Sheet
Figure IV-16
CASTING PROCESSES
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Slush Casting and Dip Casting. Slush casting involves the use of
liquidplast!sol(tineparticle polyvinyl chloride dispersed in
plasticizers such as dioctyl phthalate). These plastisols are
viscous at room temperature. A measured amount of plastisol is
poured into a hollow mold that has been preheated. The mold is
rotated quickly to cover all inside surfaces and after a specific
period of time, excess plastisol is poured out into a storage vat
for future reuse. The thickness of the hollow part is determined
by the amount of time the plastisol remains in the mold. The
mold is then placed in an oven and is heated for several minutes
to complete fusion. Typical slush cast products include house-
wares, novelties, doll heads, fish lures, and toys.
In dip casting, a mold is preheated and dipped into a liquid
plastisol. A polymer coating fuses around the mold during immer-
sion. The coated mold is then placed in an oven to complete
fusion. Typical dip cast products include novelties, boots,
gloves, coin purses, and eye glass cases.
Cell Casting. Cell casting is used to produce sheet, tubes, and
rods.Acrylic sheet is most commonly cell cast. A premeasured
amount of liquid acrylic, consisting of a small amount of polymer
in a monomer and additive solution, is poured between two sheets
of polished or tempered plate glass that are slightly larger than
the desired acrylic sheet product. The glass cell, which is held
together by tubing and spring clips, is then placed horizontally
in an oven for curing.
Chilled Film Casting. Chilled film casting is a casting process
used to produce non-oriented, thin, polymer films. Thermoplastic
materials such as polypropylene homopolymer, propylene-ethylene
copolymer, and low density polyethylene are most commonly used to
produce film. The most common form of chilled film casting is
termed chill roll casting. In chill roll casting, the formulated
polymer is extruded through a slot die onto a rotating, chilled,
polished roll. The movement of the roll draws the molten resin
away from the die without significantly stretching or orienting
the film. The extrudate solidifies into a film as it passes over
the chilled roll surface. The film is trimmed as necessary and
wound onto rolls. Chill casting processes produce high clarity
film products. Process water is not used during chill roll
casting.
A less commonly used film casting process is termed tubular water
bath casting. A thin-walled vertical tube of formulated polymer
is extruded downward from a rotating circular die over a water
cooled mandrel. The tube is quenched in contact cooling water
and split open to form a film. The film is then trimmed and
wound on rolls.
77
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Solvent Casting. Solvent casting, often referred to as solution
casting, is used for the production of film and sheet. Polyvinyl
chloride (PVC) organosols are the most commonly used polymers for
this process. Organosols are formed by dispersing finely pow-
dered PVC in plasticizer and organic solvents. The solution is
poured onto a rotating drum or an endless belt that passes
through an oven. The solvent is evaporated in the oven in
carefully programmed heat zones and a relatively solvent free
polymer film leaves the oven.
Continuous Casting. Continuous casting processes produce thin
continuousacrylic sheet. They are very similar to cell casting
processes except that the liquid acrylic is cured between two
highly polished moving stainless steel belts. The acrylic,
trapped between the stainless belts, travels through the oven and
air cooling stations.
Water may be used for the direct contact cooling of cast prod-
ucts. Direct contact cooling water sprays can be used in slush
casting and in dip casting processes and in some pot casting
processes. During tubular water bath casting, direct contact
cooling water is used during the product quenching step.
Foam Processes
Foamed plastics (often called cellular or expanded plastics) are
made by adding a blowing agent to thermoplastics or thermosets
to form a spongelike material. Blowing agents are either added
to the input material and vaporize due to heat or are generated
as a by-product of a cure reaction. Plastic foam products have
wide commercial use for flotation devices, packaging, cushioning,
and insulation. Plastic foams can be either rigid or flexible.
Foamed plastic products can be classified into one of three
types: extruded thermoplastic foam, structural foam, and multi-
component thermoset foam. The production of extruded thermoplas-
tic foams is a variation of the extrusion process where either
dry chemicals that foam when heated are included in the resin
feed or a solvent blowing agent is injected into the polymer melt
at the extrusion die. Structural foam molding is a variation of
the injection molding process where chemical blowing agents or
injected gases form bubbles in the molded product. Multicompo-
nent thermoset foams are formed in a carefully controlled reac-
tion injection molding (RIM) process where blowing agents are
either generated as a by-product of the chemical reaction that
takes place in the mold of a RIM process or added with the input
materials and vaporized by the heat of reaction. Contact cooling
water is generally not used during the molding and forming of
these foamed products.
78
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Cleaning Processes
Parts produced by the various molding and forming processes may
require cleaning to become useful end products.
Cleaning. Cleaning processes wash the surfaces of plastic prod-
ucts to remove residual mold release agents, processing chemi-
cals, and other matter prior to finishing, shipping, or further
processing. Cleaning is generally divided into two segments; a
detergent wash cycle and a rinse cycle for the removal of deter-
gents and other foreign matter. Generally, the level of sophis-
tication of washing processes varies with the type of product
being formed and the manufacturing steps that follow. Small
novelty items requiring cleaning may simply be dunked and agi-
tated in a bucket with the bucket dumped periodically. Larger
items can be cleaned in the same manner in a tank. At the large
manufacturing facilities, custom designed washing equipment may
be employed. Two types of automated cleaning processes are used.
In the first type, a batch of plastic products is loaded into a
washing machine that operates cyclically. In the first cycle,
plastic products are washed with detergent water; in subsequent
cycles, the plastic products are rinsed. When the wash-rinse
cycle is complete, the plastic products are removed from the
machine and the whole process is repeated with a new batch of
products. The other type of automated washing process is a con-
tinuous staged process. The products to be cleaned are conveyed
through a detergent wash stage and then through a rinse stage.
Depending on the degree of cleaning required for a final applica-
tion or further processing, the cleaning process may actually
employ several rinse cycles or stages. For instance, cleaning
processes used to prepare surfaces for painting generally include
a deionized water rinse as a final step.
Shaping equipment surfaces that contact the plastic product, such
as molds and mandrels, may also be washed in a cleaning process.
Finishing Processes
Products produced by the various molding and forming processes
may also require finishing to render the final product useful.
Finishing. There are three general finishing processes:
machining, decorating, and assembling. Machining is used to
drill, cut, mill, and otherwise shape products to match final
product specifications. Decorative finishes are applied to
plastic parts by a variety of methods including painting, print-
ing, hot stamping, and vacuum metallizing. Assembling involves
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joining two or more plastic parts by methods such as solvent
welding, ultrasonic welding, and electronic heat sealing. Pro-
cess water is often used in finishing processes as a lubricant
and carrier of waste particulates generated by machining
processes. Decorating and assembling are dry operations.
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SECTION V
SUBCATEGORIZATION
BASIS FOR SUBCATEGORIZATION SCHEME
In developing the final regulation for the plastics molding and
forming category, the Agency considered whether different efflu-
ent limitations guidelines and standards are appropriate for dif-
ferent segments of the industry. The Act allows EPA to consider
a number of factors to determine if subcategorization is needed.
These factors are:
1 . raw materials;
2. production processes;
3. products;
4. size and age of plants;
5. geographic location;
6. type of water use; and
7. wastewater characteristics.
The Agency determined whether any of these individual factors
identified a need to subcategorize the PM&F category. The Agency
also evaluated the relationship between different factors to
identify a need for subcategorization. A discussion of each
factor is presented below. After considering all these factors,
the Agency determined that the plastics molding and forming cate-
gory is most appropriately regulated using three subcategories.
FACTORS CONSIDERED
Raw Materials
The raw materials used in the plastics molding and forming
category can be classified as:
plastics and resins;
chemical additives; and
processing aids.
The type and combination of raw materials used in plastics mold-
ing and forming are highly dependent on the production process
used and the end products desired. Plastics molders and formers
can use many different raw material combinations to produce dif-
ferent end products at one production plant over a given period
of time. Many different raw materials may also be used in any
one type of PM&F process.
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The concentration of pollutants in PM&F process waters varies
because of the raw materials used. However, the types of pollu-
tants in these process waters are similar regardless of the mate-
rial processed. This is illustrated by reviewing the sampling
data base presented in Appendix A. For cleaning process waters,
the priority pollutant phenol was found in concentrations ranging
from 0.002 mg/1 to 6.0 mg/1 in eight of the 13 cleaning water
processes sampled. The 6.0 mg/1 concentration was found in pro-
cess water used to clean the surfaces of equipment that process
phenolic resin. The 0.002 mg/1 was found in process water used
to wash and rinse a polyurethane product. The range in phenol
concentrations for those two processes can be explained by the
raw material processed. However, the range in pollutant concen-
tration does not prevent both process waters from being treated
in the same type of treatment technology. This situtation is
also illustrated in the data bases for the contact cooling and
heating water processes and for the finishing water processes.
Therefore, a subcategorization scheme based on raw materials is
not needed to ensure equitable effluent limitations guidelines
and standards for the PM&F category. Further, due to the propri-
etary nature of the raw material combinations and the varying
requirements for product quality, particularly when different raw
materials are processed in the same PM&F process, the Agency
believes that a subcategorization scheme based on raw materials
is not feasible for the PM&F category.
Production Processes
There are nine different generic production processes used in the
plastics molding and forming category. They are:
1. extrusion;
2. molding;
3. coating and laminating;
4. thermoforming;
5. calendering;
6. casting;
7. foaming;
8. cleaning; and
9. finishing.
Each of the above processes may use process water (i.e., water
that contacts the plastic product). Process water is used in the
first seven processes to cool or heat plastic materials and plas-
tic products. Process water is used in cleaning processes to
clean surfaces of plastic products and to clean shaping equipment
surfaces; it is used in finishing processes to finish plastic
products.
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As Indicated in the section on raw materials, sampling data
presented in Appendix A indicate that the pollutants found in
process waters for PM&F processes that cool or heat a plastic
product (i.e., the first seven processes listed above) are
similar even though the pollutant concentrations may vary.
Therefore, the Agency believes that there is nothing about the
different contact cooling and heating processes that signifi-
cantly affects the development of equitable effluent limitations
guidelines for those processes. For this reason, PM&F contact
cooling and heating water processes can be addressed as a group
with respect to effluent limitations guidelines and standards.
Sampling data for cleaning water processes and finishing water
processes indicate that the pollutants in those two process
waters are different. Those data also indicate that the pollu-
tants in contact cooling and heating waters are different from
the pollutants in either cleaning process waters or finishing
process waters. For these reasons, the Agency considered three
types of PM&F processes (i.e., contact cooling and heating water
processes, cleaning water processes, and finishing water proces-
ses) further as the basis to subcategorize the PM&F category so
that equitable effluent limitations guidelines and standards
could be developed.
Products Produced
An extremely wide range of products are produced in the plastics
molding and forming category. The products can be classified
according to the following types:
1 . packaging materials;
2. building and construction components;
3. consumer and institutional products;
4. electrical and electronics products;
5. appliances;
6. transportation products;
7. furniture;
8. industrial equipment; and
9. intermediate products.
Products within any given product type can generally be manufac-
tured from several different plastic materials and in several
different production processes. In addition, any given plant may
produce a wide range of products falling into many of the above
product types. The amount and type of pollutants discharged by
those processes are not directly related to the type of product
produced. Thus, a subcategorization scheme based on product type
is not needed to ensure the development of equitable effluent
limitations guidelines and standards for the PM&F category.
83
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Size and Age of Plants
The number of employees and amount of production can be used to
measure relative sizes of PM&F plants. However, neither factor
provides an adequate basis for subcategorization.
The amount of wastewater discharged and the types of pollutants
in the wastewater are largely independent of the number of plant
employees. Variations in staff occur for many reasons including
shift differences, the need for clerical and administrative
support, the need for maintenance support, efficiency of plant
operations, and market fluctuations. Due to these and other
factors, the number of employees is constantly fluctuating. The
Agency found no correlation between the number of employees at a
PM&F plant and the number and range of concentrations of pollu-
tants in wastewater discharged from PM&F processes at a plant.
Therefore, a subcategorization scheme based on the number of
employees at a plant is not appropriate for the PM&F category.
While plant production can be used to approximate the mass of
pollutants generated, the Agency has determined that it should
not be used to establish different effluent limitations guide-
lines and standards for the plastics molding and forming category
for the following reasons:
1, The types of PM&F processes used and the characteristics
of the wastewater discharged from those processes are
not dependent on the total plant production.
2. While the amount of production affects the total mass of
pollutants discharged, it has little effect on the types
and range of concentrations of pollutants found in the
wastewater. Therefore, there is little, if any, differ-
ence between the type of treatment technology required
at small and large PM&F plants where process water is
treated and discharged.
The plastics molding and forming industry is a relatively new
industry that developed following the development of the polymer
and resins formulating industry. To remain competitive in an
industry that has steadily made technological improvements over
the past 30 years, PM&F plants have been continually modernized.
Thus, because most PM&F plants were built in the same general
time frame and are continually modernized, neither plant age nor
equipment age is a significant factor that requires subcategori-
zation to ensure equitable effluent limitations guidelines and
standards.
84
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Geographic Location
Plastics molding and forming plants are not limited to any one
geographical location and are generally located near distribution
and sales centers so that the finished products need not be
transported over long distances. A large percentage of molding
and forming plants are located in the four geographical clusters
of (1) New Jersey, New York, and Pennsylvania; (2) Illinois,
Indiana, Michigan, and Ohio; (3) Louisiana, Oklahoma, and Texas;
and (4) California and Washington.
There are no specific geographical factors that significantly
affect water use at PM&F plants or characteristics of PM&F
process waters. The physical space required for the treatment
systems evaluated for the PM&F regulation is small compared to
the overall plant size. Therefore, there are no consequences
from the construction and operation of a wastewater treatment
system peculiar to the different geographical areas. For these
reasons, the Agency believes there is no need to subcategorize
the PM&F category based on geographic location.
Types of Water Use
Results of the questionnaire surveys and the sampling programs
for the PM&F regulation indicate that there are basically three
types of process water used by processes in the PM&F category.
They are:
1. contact cooling and heating water,
2. cleaning water, and
3. finishing water.
Contact cooling and heating water is used to either cool or heat
plastic materials or plastic products. Water can be sprayed onto
a product or the product can be drawn through a water bath. In
either case, the water is used for heat transfer.
Cleaning water is used to clean the surfaces of plastic products
or to clean shaping equipment surfaces that are or have been in
contact with the plastic product. It includes water used in the
washing and rinsing cycles of a cleaning process.
Finishing water is used to finish plastic products. It includes
water used either to carry away waste plastic materials during a
finishing operation or to lubricate a plastic product during
finishing.
Sampling data indicate that the type and concentration of pollu-
tants in PM&F process waters vary depending on how process water
is used. Therefore, the development of equitable effluent
85
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limitations guidelines and standards for the PM&F category may be
influenced by how the process water is used. For this reason,
the Agency gave further consideration to type of water used as
the basis for the PM&F subcategorization scheme.
Wastewater Characteristics
Results of the sampling programs for this regulation indicate
that contact cooling and heating waters, cleaning waters, and
finishing waters have different pollutant characteristics. Only
one pollutant (i.e., bis(2-ethylhexyl) phthalate) was found in a
treatable concentration in contact cooling and heating waters.
Cleaning waters have treatable concentrations of three conven-
tional pollutants, three nonconventional pollutants, and two
priority toxic pollutants. Finishing waters have treatable con-
centrations of one conventional pollutant (i.e., TSS) and three
priority pollutants. These different pollutants severely impact
the development of equitable effluent limitations guidelines and
standards for the PM&F category. Therefore, wastewater charac-
teristics were considered further as the basis for the PM&F
subcategorization scheme.
SELECTED SUBCATEGORIZATION SCHEME
The subcategorization scheme for the PM&F category is based on
three types of production processes, water use, and wastewater
characteristics. The three types of production processes are
contact cooling and heating water processes, cleaning water pro-
cesses, and finishing water processes. The water use (i.e., heat
transfer, cleaning, or finishing) for those three types of pro-
cesses influence the wastewater characteristics of the process
water. All three factors influence the development of equitable
effluent limitations guidelines and standards for the PM&F cate-
gory.
The three subcategories for the PM&F category are:
1. contact cooling and heating water subcategory,
2. cleaning water subcategory, and
3. finishing water subcategory.
The contact cooling and heating water subcategory includes PM&F
processes in which process water contacts plastic materials for
the purpose of heat transfer. Processes that use process water
to clean the surfaces of plastic products or to clean shaping
equipment surfaces that are or have been in contact with the
plastic product are included in the cleaning water subcategory.
The finishing water subcategory includes PM&F processes that use
process water during the finishing operation.
86
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One advantage of this subcategorization scheme is that plants can
easily identify the type of water used in their PM&F processes.
Having only three subcategories should also make it less compli-
cated for the permit writer to write permits for PM&F plants.
APPLICABILITY
The PM&F effluent limitations guidelines and standards apply to
processes that blend, mold, form, or otherwise process interme-
diate or final plastic products and that discharge process water.
Some molding and forming processes (e.g., extrusion and pelletiz-
ing) are used by plastic resin manufacturers to process crude
intermediate plastic material. For the purpose of the PM&F regu-
lation, plastic molding and forming processes used by plastic
resin manufacturers to process crude intermediate plastic materi-
als for shipment off-site are excluded from the PM&F regulation
and regulated under the organic chemicals, plastics, and synthet-
ic fibers category. Plastic molding and forming processes used
by plastic resin manufacturers to process crude intermediate
plastic materials that are processed on-site into intermediate or
final plastic products by molding and forming are controlled by
the effluent limitations guidelines and standards for the PM&F
category. For example, a plant may manufacture a polyurethane
resin. To prepare the resin for shipment, the manufacturer may
extrude the resin and then pelletize it. If the polyurethane
pellet is shipped off-site, the extrusion process is subject to
the effluent limitations guidelines and standards for the organic
chemicals, plastics, and synthetic fibers category. If the poly-
urethane pellet is further processed on-site in a molding and
forming process, that process and the extrusion process used to
obtain the pellet are subject to the PM&F effluent limitations
guidelines and standards.
In several instances, particular PM&F processes and the waste-
water generated by these processes may fall within this and other
industrial categories for which the Agency has established efflu-
ent limitations guidelines and standards. Thus, for the purpose
of regulatory coverage, the Agency has separated each process to
ensure that it is clearly subject to one set of effluent limita-
tions guidelines and standards. Processes that coat a plastic
material onto a substrate may fall within the definition of elec-
troplating and metal finishing as defined in 40 CFR Parts 413 and
433 (see 48 FR 32485; July 15, 1983). These coating operations
are excluded from the effluent limitations guidelines and stan-
dards for the electroplating and metal finishing point source
category and are subject to the PM&F effluent limitations
guidelines and standards.
Coating of plastic material onto a formed metal substrate is also
covered by the PM&F effluent limitations guidelines and standards
87
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and is not covered by the specific metal forming effluent limita-
tions guidelines such as those for aluminum forming (40 CFR Part
467 (48 FR 49126; October 24, 1983), copper forming (40 CFR Part
468 (48 FR 36942; August 15, 1983), and nonferrous metals forming
(40 CFR Part 471 (proposed 49 FR 8112, March 5, 1984)). However,
the PM&F regulation applies only to the coating process; the
prior forming operations are subject to the specific metal
forming regulation.
Some research and development (R&D) laboratories and technical
centers produce low quantities of plastic products in PM&F pro-
cesses. PM&F processes at R&D laboratories are subject to the
PM&F effluent limitations guidelines and standards if they
discharge process water. The PM&F regulation applies to PM&F
processes that discharge process waters regardless of the mass of
plastic products produced by a process. The Agency considered
low production PM&F processes during the development of the final
PM&F regulation because there are 24 processes in the Agency's
data base with very low production rates (i.e., less than 10,000
pounds per year). Information from those processes was used with
information from high production processes to characterize the
PM&F category.
The PM&F regulation does not apply to wastewater generated during
the reticulation of polyurethane foam. Reticulation can be done
by either a chemical process or a thermal process. In the chemi-
cal process, the foam is passed through a bath of sodium hydrox-
ide and then is quenched in a series of water baths to stop the
chemical reaction. In thermal reticulation, the foam is reticu-
lated by controlled explosions inside the foam structure. Prod-
ucts of combustion are removed from the foam by a vacuum pump and
are absorbed in the water inside the pump. Process water used in
chemical and thermal reticulation is not cooling water because it
is not used for heat transfer; it is not cleaning water because
it does not clean the surface of either the plastic product or
the equipment that contacts the plastic product; and it is not
finishing water because the process water is not used to finish a
plastic product. For these reasons, the PM&F effluent limita-
tions guidelines and standards do not apply to the processes that
reticulate polyurethane foam. Those processes are addressed in
the effluent limitations guidelines and standards for the organic
chemicals, plastics, and synthetic fibers category. If the
reticulated foam is further processed in a molding and forming
process, that process is subject to the PM&F regulation.
The final regulation does not apply to processes used to produce
regenerated cellulose for two reasons. First, cellulose is a
natural organic material, not a "plastic material" as defined by
EPA. In the final PM&F regulation, a plastic material is defined
as "a synthetic organic polymer . . ." [emphasis added]. Second,
88
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the final step in the xanthate process used to regenerate cellu-
lose is to wash the regenerated cellulose to remove dissolved
salts and sulfur compounds from within the cellulose. Process
water used in this final step is not cleaning water as defined in
the final PM&F regulation because it cleans more than just the
surface of the regenerated cellulose. For these reasons, the
manufacturing process for regenerated cellulose is not subject to
the PM&F regulation. It is subject to the effluent limitations
guidelines and standards for the organic chemicals, plastics, and
synthetic fibers category.
Similarly, the final PM&F regulation also does not apply to mold-
ing and forming operations that process regenerated cellulose
because regenerated cellulose is not a plastic material as
defined in the final PM&F regulation. The regulation does apply,
however, to molding and forming processes that use cellulose
derivatives (e.g., cellulose acetate), which are plastic
materials as defined in the final PM&F regulation.
Wastewater is generated by the solvent recovery operation in the
solution or solvent casting process. However, this wastewater
does not result from the blending, molding, forming, or any pro-
cessing of the plastic material and is not a process water. It
is generated when steam condensate from the solvent casting pro-
cess is distilled to recover acetone. Data from the analysis of
samples of this wastewater indicate that its pollutant character-
istics are different from the characteristics of PM&F process
waters. In addition, the Agency estimates that only eight plants
in the category generate solvent recovery wastewater. For these
reasons, the Agency believes that solvent recovery wastewater is
best controlled on a case-by-case basis by the permit writer or
control authority. Analytical data for this type of wastewater
are presented in Appendix A of this technical development
document and may be used as a guide by the permit writer or
control authority.
Plants in the PM&F category may have processes generating only
one type of wastewater and thus fit within one subcategory. How-
ever, many plants generate contact cooling and heating water,
cleaning water, and finishing water. In this instance, plants
must comply with the effluent limitations guidelines and
standards for each subcategory.
89
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SECTION VI
WATER USE AND WASTEWATER CHARACTERISTICS
This section discusses the water use and wastewater discharge
practices for the PM&F category and presents the wastewater
treatment technologies currently used by PM&F plants. Data used
to characterize PM&F process waters are also presented in this
section. The data were obtained from two sources:
1. questionnaires and
2. sampling and analysis programs.
QUESTIONNAIRE DATA
From the survey data base for this project described in Section
IV, statistics were developed to apply to the plastics molding
and forming plants that use process water. The data base con-
tains questionnaires from 382 plants: 175 questionnaires are
from the 1979 survey and 207 questionnaires are from the 1983
survey.
The 382 questionnaires were reviewed and summarized to determine
the discharge mode (i.e., direct, indirect, or zero discharge)
for PM&F processes. Table VI-1 contains a distribution of the
521 wet processes reported in the questionnaires by discharge
mode for the types of process waters generated. As shown in the
table, 31 percent of these processes are direct dischargers, 44
percent are indirect dischargers, and 25 percent have no
discharge.
Table VI-2 presents the average operating hours, average produc-
tion, and the average water use and discharge rates by subcate-
gory for the different types of dischargers. The averages were
calculated by summing the data for processes within a subcategory
by discharge mode and dividing by the number of processes with
the discharge mode. Average water use and discharge rates are
given in both liters per hour and liters per year.
Table VI-3 contains a distribution of the number of wet processes
in the questionnaire data base that have no discharge by the
method used to obtain no discharge.
The 382 questionnaires were also reviewed to determine the treat-
ment technologies currently used by plants in the PM&F category.
A summary of those treatment technologies is presented in Table
VI-4. The 17 plants listed in the table are plants where a sig-
nificant portion (i.e., 50 percent or more) of the wastewater
treated is from PM&F processes. Only 10 of those plants have
91
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Table VI-4
PM&F TREATMENT TECHNOLOGIES SUMMARY*
Treatment Technologies
Plant ID
640
602195C
564076A
1400
1420
1946
29640A
362544S
580294E
1330
583
1500
2722
10290
10650
2500
480
Discharge
Mode
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Indirect
Indirect
Indirect
Indirect
Indirect
Indirect
Zero
%
PM&F
Process
Water
100
100
100
99
88
86
81
80
61
50
100
100
100
100
100
100
100
u
B B tic
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co co E
3 N 14
S1 3 &
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re cr --I
a w o
X
X
X
X
X X
X
X
X
X X
X
Skimming
ion
n
u o
to eg 1-1
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X X
X
X X
X X
X
X X
X
X
X
0)
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n o
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X
X
X
X
X
X
X
X
X
X X
X
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Adsorption
nt Addition
or Solids Removal
co
B r-t V
0 3 00
,0 oc -o
Ti CO 3
CO O •-*
O O 03
X
X X
X
X
X
TOTAL
7412741291111
*Based on information reported in 1979 and 1983 questionnaire surveys.
95
-------
treatment technologies that treat only PM&F process water. The
other plants have treatment technologies that treat process water
from PM&F processes with wastewater from other industrial proces-
ses. The 17 plants where a significant portion of the wastewater
treated is from PM&F processes are only four percent of the
plants in the data base. The other 96 percent of the plants are
zero dischargers, had no treatment technology, or are plants
where more than 50 percent of the wastewater treated was
discharged by processes other than PM&F processes.
Of the 521 wet PM&F processes in the combined data base, 201
recycle process water. Table VI-5 contains a distribution of the
number of processes that recycle process water by discharge mode.
As shown in the table, 48 percent of those processes do not dis-
charge process water, 23 percent are direct dischargers, and 28
percent are indirect dischargers.
The contact cooling and heating water subcategory was analyzed to
determine the types of plastics molding and forming processes in
the subcategory. Table VI-6 presents results of this analysis.
As shown in the table, extrusion processes comprise the majority
of processes in the subcategory with 85.0 percent. The next pre-
dominate type of process is molding with 7.5 percent. These two
types of processes are 92.5 percent of the processes in this sub-
category. The remaining four types of processes (i.e., calender-
ing, casting, coating and laminating, and thermoforming) make up
the remaining 7.5 percent.
PM&F Category Data
The 382 plants in the questionnaire data are distributed with
respect to the processes that use a specific type of process
water in the following manner:
1. Three hundred fifteen plants (82.5 percent) have pro-
cesses using only contact cooling and heating water;
2. Twenty-six plants (6.8 percent) have processes using
only cleaning water;
3. Nine plants (2.3 percent) have processes using only
finishing water;
4. Twenty plants (5.2 percent) have processes that use con-
tact cooling and heating water and processes that use
cleaning water;
5. Five plants (1.3 percent) have processes that use con-
tact cooling and heating water and processes that use
finishing water;
96
-------
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98
-------
6. Six plants (1.6 percent) have processes that use clean-
ing water and processes that use finishing water; and
7. One plant (0.3 percent) has a process that uses contact
cooling and heating water, a process that uses cleaning
water, and a process that uses finishing water.
Based on that information, 341 plants (315 + 20 + 5 + 1) have
processes that use contact cooling and heating water, 53 plants
have processes that use cleaning water (26 + 20 + 6+1), and 21
plants (9+5+6+1) have processes that use finishing water.
Estimate of Number of Plants and Processes in PM&F Category That
Use Process Water
The process and plant information listed above from the question-
naire data base was applied to the estimated 1,898 wet plants in
the PM&F category to obtain an estimate of the number of wet
plants and processes in each subcategory. The means of arriving
at the estimate of 1,898 wet plants is presented in Section IV.
The calculations for the category plant estimate are:
(1,898 category wet plants) (0.825)
(1,898 category wet plants) (0.068)
(1,898 category wet plants) (0.023)
(1,898 category wet plants) (0.052)
(1,898 category wet plants) (0.013)
(1,898 category wet plants) (0.016)
1,569 plants with processes
that use only contact cool-
ing and heating water
129 plants with processes
that use only cleaning
water
43 plants with processes
that use only finishing
water
98 plants with processes
that use contact cooling
and heating water and pro-
cesses that use cleaning
water
24 plants with processes
that use contact cooling
and heating water and pro-
cesses that use finishing
water
30 plants with processes
that use cleaning water and
processes that use finish-
ing water
99
-------
(1,898 category wet plants) (0.003) = 5 plants with processes
that use contact cooling
and heating water, proces-
ses that use cleaning
water, and processes that
use finishing water
This equates to 1 ,696 plants (1 ,569 + 98 + 24 + 5) in the PM&F
category with processes that use contact cooling and heating
water, 262 plants (129 +98+30+5) that use cleaning water,
and 102 plants (43 +24+30+5) that use finishing water. The
total category wet process estimate is:
(1,696 category plants (428 data base
with processes x processes)
that use contact (341 data base
cooling and heat- plants)
ing water)
2,129 processes that
use contact
cooling and
heating water
(262 category plants
with processes x
that use cleaning
water)
(102 category plants
with processes x
that use finish-
ing water)
(71 data base
processes)
(53 data base
plants)
(22 data base =
processes)
(21data base
plants)
351 category pro-
cesses that use
cleaning water
107 category pro-
cesses that use
finishing water
Applying the percentages for direct, indirect, and zero discharg-
ers from Table VI-1 to the number of estimated processes gives an
estimate number of processes by discharge mode. See Table VI-7
for this presentation.
Estimate of PM&F Category Process Water Use
The amount of process water use was estimated for each type of
discharge mode (i.e., direct, indirect, and zero) in the PM&F
category. The PM&F category uses approximately 308 billion
liters (81 billion gallons) annually of process water. The
following example for indirect dischargers illustrates the
procedure used to estimate water use for the PM&F category.
To estimate the water use by indirect dischargers, the average
amount of water used per year for each subcategory from the
questionnaire data base was multiplied by the estimated number of
indirect processes. These data are listed in Tables VI-2 and
VI-7, respectively. The subcategory total amount of indirect
water used was further divided into amounts discharged by plants
with processes in only one subcategory, in two subcategories, and
100
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in three subcategories. For example, in the contact cooling and
heating water subcategory questionnaire data base, indirect dis-
charging processes are distributed as follows:
1 ,_ 90.0 percent of the contact cooling and heating water
processes are at plants with only contact cooling and
heating processes,
2. 7.1 percent of the contact cooling and heating water
processes are at plants with contact cooling and heating
water processes and cleaning processes,
3. 2.3 percent of contact cooling and heating water pro-
cesses are at plants with contact cooling and heating
water processes and finishing processes, and
4. 0.6 percent of contact cooling and heating water pro-
cesses are at plants that have processes in the three
subcategories.
These percentages were multiplied by the total amount of contact
cooling and heating water used by indirect dischargers to calcu-
late the amount of contact cooling and heating water used by
indirect dischargers at the above listed combinations of pro-
cesses. The same calculations were done for the cleaning water
subcategory and for the finishing water subcategory. Table VI-8
summarizes the water use for the possible combinations. Like-
wise, water use was calculated for both the direct and zero
dischargers. Tables VI-9 and VI-10 present the water use
information for those discharge modes.
Estimate of PM&F Category Process Water Discharged
The amount of water discharged by PM&F processes was estimated
for direct and indirect dischargers. The PM&F category dis-
charges approximately 44 billion liters (12 billion gallons)
annually of process water. The water discharge estimate was
calculated in the same manner as the water use estimate, except
that the average amount of water discharged from the question-
naire data base (presented in Table VI-2) was multiplied by the
estimated number of processes. The distribution of process water
discharged by plants with processes in one or more subcategories
was calculated using the same percentages used to calculate the
water use estimates. Tables VI-11 and VI-12, respectively,
present the process water discharge information for direct and
indirect dischargers.
SAMPLING PROGRAMS
This section discusses the sampling programs conducted during
1980, 1983, and 1984, and presents the results of the sample
102
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analyses. The results from the 1980 and 1983 sampling programs
were used in developing the proposed PM&F effluent limitations
guidelines and standards. The 1984 sampling effort results were
incorporated with the results from the other efforts to evaluate
comments and to develop the final PM&F effluent limitations
guidelines and standards.
Plant Selection - Proposed Regulation
The sampling programs for the proposed PM&F regulation were
undertaken to identify pollutants in the PM&F process waters.
Samples were collected at plastics molding and forming plants and
analyzed for conventional, selected nonconventional, and priority
toxic pollutants.
Criteria used to select PM&F plants for sampling included the
number and types of PM&F processes, water use and wastewater dis-
charge practices, and differences in production processes and
plastics materials used. The primary sources of this information
were the questionnaire surveys. The Agency selected plants for
sampling that represented a full range of PM&F processes and raw
materials. Those plants usually had more than one PM&F process.
Field Sampling Programs - Proposed PM&F Regulation
After selection of candidate plants, each plant was contacted by
telephone to verify their operations and to inform them that EPA
had included them in the sampling program. Presampling site
visits were conducted to identify sample locations, sampling
conditions, and plant operations.
Eleven plants were sampled during the 1980 and 1983 episodes.
Plants C, E, F, and I were sampled in 1980 and the remaining
seven plants, A, B, D, G, H, J, and K, were sampled in 1983.
Figures VI-1 through VI-11 present process water flow diagrams
for the 11 plants indicating the location of the sample points.
The sampling data base for the proposed regulation contained data
from 18 contact cooling and heating processes that were sampled
at eight PM&F plants. Four different types of contact cooling
and heating water processes were sampled at those plants (i.e.,
extrusion, molding, calendering, and thermoforming). Twelve
cleaning processes were sampled at eight PM&F plants and one
finishing process was sampled. These 13 processes were in the
cleaning and finishing water subcategory for the proposed
regulation.
Several changes were made to the pre-proposal sampling data base
between proposal and promulgation. These changes include the
following:
108
-------
Source Water-
Product
Cleaning
A-l**
To POTW
Source Water-
Product
Cleaning
A-2**
To POTW
Source Water-
Equipment
Cleaning
A-3*
To POTW
LEGEND:
- Sample Point
- PM&F Process
*Data from this point were not used in data analysis because production
data were not available for. this process.
**This is a batch process.
Figure VI-1
SAMPLING POINTS AT PLANT A
109
-------
Source
Water
Source
Water
Source
Water
Source
Water
To
POTW
Other Plant
Wastewatcr
Direct
Discharge
LEGEND:
- Sample Point
- PM&F Process
- Treatment System
Figure VI-2
SAMPLING POINTS AT PLANT B
110
-------
Source
Water
Source
Water
C-l
X> fc Direct
1 \&> ~ Discharge
Direct
Discharge
LEGEND:
Wastewater From
Paint Spraying
Operation and
Glove Washings
- Sample Point
- PMfieF Process
- Treatment System
*Data from this point were not used in data analyses because
process is no longer in operation.
Figure VI-3
SAMPLING POINTS AT PLANT C
111
-------
Source
Water
Equipment
Cleaninng
D-l*
Qy *" POTW
Source
Water
Equipment
Cleaning
D-2*
To
POTW
Source
Water
Water Chiller
LEGEND:
To POTW
- Sample Point
- PM&F Process
*Batch process was sampled when process water was
discharged.
Figure VI-4
SAMPLING POINTS AT PLANT D
112
-------
Source
Mater
Source
Water
Source
Water
Sourc
Water
Direct
Discharge
Mon-Contact
Cooling Water and
Treated Electroplating
Water
LEGEND:
- Sample Point
- PM&F Process
- Treatment System
*Data from this point were
not used in data analyses,
because the material pro-
cessed is a synthetic
rubber.
Figure VI-5
SAMPLING POINTS AT PLANT E
113
-------
Source »
Water
Source fc
Water
Source fc
Water
Product
Cleaning
Calendering
Thermo-
forming
F-3
— (^)-*t To POTW
F-l
__A?\_^
F-2
Source »
Water
Product
Cleaning
F-4
-®-
Source »
Water
Extrusion
F-6
— <9v-»
F-8' f >v F-9
0 J Lagoon \_/rx_^ Direct
"1TV>*1 System r~xy~^ Discharge
V^^y
Non-Contact Cooling
Water, Rain Water Run-Off,
Boiler Slowdown , and Com-
pression Cooling Water
V^/ ^
LEGEND:
O
- Sample Point
~ PM&F Process
- Treatment System
Figure VI-6
SAMPLING POINTS AT PLANT F
114
-------
Source ^
Water
Extrusion
and
Pelletizing
G-l
/0\ ^ Direct
\& ^ Discharge
Steam
Solution
Casting
Solvent
Recovery
G-2*
Condensed Steam
Direct Discharge
LEGEND:
- Sample Point
- PM&F Process
*Solvent recovery wastewater is not regulated by the
PM&F effluent limitations guidelines and standards.
Figure VI-7
SAMPLING POINTS AT PLANT G
115
-------
Source
Water
Product
Cleaning
H-l
Source.
Water
Equipment
Cleaning
H-2*
<7\
— Qy — ^
To
LEGEND:
- Sample Point
- PM&F Process
*Data from this point were not used in data analyses
because production data were not available for this
process.
Figure VI-8
SAMPLING POINTS AT PLANT H
116
-------
To POTW
Source
Water
Coating and
Laminating
Melamine
Resin
Laminating
Source.
Water
Coating and
Laminating
Phenolic
Resin
Laminating
Filter Aid
1-2
Equipment
Cleaning
i
Sump
1-3
LEGEND:
- Sample Point
- PM&F Process
Treatment System
*Discharge from this process
can be recycled back to
the process or discharge
can be sent to the POTW
depending on water storage
availability at the plant.
1-5
To POTW
Figure VI-9
SAMPLING POINTS AT PLANT I
117
-------
Cooling Water
Expandable
Bead Foam
Molding
J-2
Mold
Release
Water
J-l
Con-
densed
Steam
Sump
Source
Water
Steam
Cooling
Tower
Boiler
Boiler
Slowdown
Cooling
Tower
Slowdown
,
., Direct
^Discharge
LEGEND:
Sample Point
PM&F Process
Figure VI-10
SAMPLING POINTS AT PLANT J
118
-------
Source
Water t
To POTW
Source.
Water
LEGEND:
Cooling Tower
~* Slowdown to POTW
Cooling
Tower
i
P
Extrusion
Extrusion
Extrusion
K-2
K-3
K-4
- Sariple Point
- PM&F Process
Figure VI-11
SAMPLING POINTS AT PLANT K
119
-------
1 . Process H-1 was moved to the cleaning water subcategory.
Originally, this process was classified as a casting
process in the contact cooling and heating water subcat-
egory. The Agency determined that water was used in
this process to rinse the mold release agent (glycerol)
from the product after the product was stripped off a
mandrel. Because this is a cleaning operation instead
of a heat transfer operation, data from that process
were transferred from the contact cooling and heating
water data base to the cleaning water data base.
2. Process B-2 was moved to the contact cooling and heating
water subcategory. At proposal, process B-2 was classi-
fied as a finishing operation because two calender rolls
formed the product into its final shape. This process
was subsequently moved to the contact cooling and heat-
ing water subcategory because the Agency now believes
water is used to cool instead of finish the product.
3. Processes E-1 and E-4 were eliminated from the contact
cooling and heating water subcategory. The material
used in those processes is a synthetic rubber and not a
plastic material.
4. The cleaning and finishing water subcategory was sepa-
rated into the cleaning water subcategory and the
finishing water subcategory.
5. Production data were calculated for process 1-4 and the
process was included in the finishing water subcategory.
Table VI-13 lists the processes sampled in each subcategory and
the process water flow rate for each process for which data were
used to develop the final PM&F regulation.
Plant Selection - Final FM&F Regulation
Effluent limitations guidelines and standards were proposed on
February 15, 1984, for the PM&F point source category. At the
time of the proposal, the Agency identified three areas of the
industry where the collection of additional sampling data was
necessary. The three areas were (1) conventional and nonconven-
tional pollutant data for contact cooling and heating waters;
(2) conventional, nonconventional, and priority pollutant data
for finishing waters; and (3) characteristics of solid waste
generated by PM&F wastewater treatment operations. In addition,
EPA determined that some additional data were needed to fully
evaluate and respond to comments on the proposed PM&F regulation.
120
-------
Table VI-13
1980 AND 1983 SAMPLED PROCESSES
CONTACT COOLING AND HEATING WATER SUBCATEGORY
Process
Code Type of Process
B-1 extrusion
B-2 extrusion
B-4 injection molding
C-1 slush molding
D-3 pelletizing (extrusion)
E-2 calendering
E-3 wire coating (extrusion)
F-1 calendering
F-2 vacuum forming
F-6 extrusion
G-1 pelletizing (extrusion)
J-1 foam injection molding
J-2 molding
K-2 extrusion
K-3 extrusion
K-4 extrusion
Process Water
Flow Rate
(gpm)
0.8
1 .8
0.025
0.28
50 gal/batch
14.0
35.0
2.3
1 .8
2.0
1 .45
120.0
11 .0
4.0
2.0
146.0
CLEANING WATER SUBCATEGORY
A-1 parts washing
A-2 oxalic acid parts washing
B-3 lens cleaning
C-2 parts washing
D-1 tank cleaning
D-2 tank cleaning
F-3 parts washing and rinsing
F-4 parts washing and rinsing
H-1 product rinsing
1-1 resin application equipment cleanup
1-2 resin application equipment cleanup
1-3 resin application equipment cleanup
K-1 parts washing
10 gal/batch
40 gal/batch
20
2.0
15 gal/batch
15 gal/batch
3.4
7.4
0.07
1 .4
0.7
1 .6
0.5
1-4
FINISHING WATER SUBCATEGORY
product surface dulling
5.4
121
-------
As for the sampling programs for the proposed regulation, types
of processes, water use and wastewater discharge practices, and
differences in production processes and plastic materials used
were considered when selecting plants for the post-proposal sam-
pling program. The questionnaire survey forms were the primary
source of this information. Plants M, N, 0, P, Q, and R were
sampled in 1984. Figures VI-12 through VI-17 present process
water flow diagrams for these six plants indicating the location
of the sample points.
The 1984 sampling data base contains data from nine contact cool-
ing and heating processes sampled at five plants. These proces-
ses, which include extrusion, thermoforming, and casting, were
sampled and the samples were analyzed for conventional and
selected nonconventional pollutants. Two finishing water proces-
ses were also sampled at two plants. Samples from those proces-
ses were analyzed for conventional, selected nonconventional, and
priority pollutants. Table VI-14 presents the processes sampled
in each subcategory and the process water flow rate for each pro-
cess. Additionally, four solid waste samples from PM&F waste-
water treatment operations were collected at three plants and
analyzed to determine whether those wastes were hazardous. Refer
to the energy and non-water quality impacts in Section IX for the
extraction procedure (EP) toxicity test results for those
samples.
Plant F was sampled in 1980 and was re-sampled in 1984 for veri-
fication of the total phenols concentrations found in the process
water. The 1980 sampling episode showed total phenols levels
that were magnitudes higher than levels found at the other sam-
pled plants. Because personnel at Plant F could not explain what
was contributing to the total phenols concentration, Plant F was
selected for total phenols verification sampling. The results of
this verification sampling are discussed at the end of this
section.
Sample Collection, Preservation, and Transportation
Collection, preservation, and transportation of samples were
performed in accordance with procedures outlined both in Appendix
III of "Sampling and Analysis Procedures for Screening of Indus-
trial Effluents for Priority Pollutants" (published by the Envi-
ronmental Monitoring and Support Laboratory, Cincinnati, Ohio,
March 1977, revised, April 1977) and in "Sampling Screening
Procedure for the Measurement of Priority Pollutants" (published
by the EPA Industrial Technology Division (formerly Effluent
Guidelines Division), Washington, D.C., October 1976). Proce-
dures for collection, preservation, and transportation of samples
tested for conventional and nonconventional pollutants are
described in the appropriate test methods (see Table VI-16).
122
-------
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Table VI-14
1984 SAMPLED PROCESSES
CONTACT COOLING AND HEATING WATER SUBCATEGORY
Process Water
Flow Rate
Process Code Type of Process (gpm)
M-1 pipe extrusion 3.6
M-2 thermoforming 5.0
N-2 extrusion 0.03
N-3 extrusion 0.94
0-1 extrusion 2.5
0-2 extrusion 1.8
P-1 casting 4.8
R-1 extrusion 3.9
R-2 extrusion 55.0
FINISHING WATER SUBCATEGORY
N-1 product grinding 12.0
Q-1 product finishing 18.0
129
-------
Sample Analysis
Once collected in the field, samples were prepared and shipped
via overnight air express to EPA contract laboratories for analy-
sis. Pollutants for which analyses were conducted are presented
in Table VI-15. The analytical methods used are listed in Table
VI-16. The analytical detection limits for the priority toxic
pollutants are listed in Table VI-17.
Field Quality Assurance/Quality Control (QA/QC)
Field QA/QC procedures for the sampling programs included taking
duplicate, blank, preservative blank, and source water samples.
Field Duplicates. Duplicate samples were collected at one sam-
pling point at iome of the sampled plants and were analyzed for
the same pollutants that the other samples collected at that
point were analyzed for. The identity of the duplicate samples
was not made known to the laboratories. Oil and grease and
volatile organic (VOA) samples were collected in duplicate each
time samples were collected and shipped to the laboratory.
Field Blanks. As required by sampling protocol, organic-free
waterwasFlushed through each automatic sampler prior to the
start of sampling at each plant. One gallon of that water was
collected and shipped to the contract laboratory. This sample
was the non-volatile organic pollutant blank sample.
Duplicate VOA blanks for each sampling point were supplied in 40
milliliter vials by the laboratory. Both preserved and unpre-
served VOA field blanks were supplied. The VOA blanks were
prepared in the laboratory, transported to the sampling site,
placed at selected locations at the sampling site, and then
returned to the laboratory after conclusion of the sampling
period.
Preservative/Container Blanks. To verify that there was no con-
taminationfromthevariouschemicals used as preservatives or
from the sample containers, organic-free water supplied by the
laboratory was poured into the appropriate sample containers.
These samples were preserved and shipped to appropriate
laboratories for analysis.
Source Water Samples. To assess potential presence of conven-
tional, nonconventional, and toxic pollutants in the source water
for each plant, samples of the source water were collected,
preserved, shipped to the laboratory, and analyzed for the
pollutants listed in Table VI-15.
130
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Table VI-16
ANALYTICAL METHODS SUMMARY
USEPA Methodst
405.1
410.1 , 410.2
415.1
160.2
340.1
350.1
351.3
353.2
365.1
405
375.2
376.2
425.1
150.1
335.3
420.2
503C
404B
51 2A
Conventional and Nonconventional Standard
Pollutants USEPA Methodst Methodstt
BOD5
COD
TOG
TSS
Bromide
Fluoride
Ammonia
Total Kjeldahl Nitrogen (TKN)
Nitrate-Nitrite Nitrogen (as N)
Oil and Grease
Phosphorus (total)
Boron
Sulfate (as S04=)
Sulfide (as S)
Surfactants (MBAS)
PH
Cyanide (total)
Phenols (total)
Metals
Calcium
Magnesium
Sodium
Aluminum
Manganese
Vanadium
Boron
Barium
Molybdenum
Tin
Yttrium
Cobalt
Iron
Titanium
tUSEPA Methods for Chemical Analysis of Water and Wastes,
USEPA, Environmental Monitoring and Support Laboratory,
Cincinnati, Ohio, March 1979, EPA-600/4-79-020.
ttStandard Methods for the Examination of Water and Wastewater,
15 Edition, 1981.
tttProcedures are described in "Guidelines Establishing Test Pro-
cedures for Analysis of Pollutants; Proposed Regulations,
Appendix IV," Federal Register, December 3, 1979, p. 69559.
Inductively Coupled Plasma
(ICP) Opticals - Emission
Spectrometer Method
(Task 1)ttt
132
-------
Table VI-16 (Continued)
ANALYTICAL METHODS SUMMARY
Priority Toxic Pollutants
Acid Extraction
Base/Neutral Extraction
Volatile Organics
Pesticides and PCB's
Metals
Lead
Beryllium
Cadmium
Chromium
Copper
Nickel
Zinc
Metals
Selenium
Thallium
Silver
Arsenic
Antimony
Mercury
Metals
Lead
Beryllium
Cadmium
Chromium
Copper
Nickel
Zinc
USEPA Methodt
1625*
1625*
1624*
608
Inductively Coupled Plasma (ICP)
Optical - Emission Spectrometer
Method (Task 1)tt
Flameless Atomic Absorption
Spectrometer Method (Task 2)t
Flame Atomic Absorption
Spectrometer Method (Task 2)t
*In cases where isotopes were not available USEPA Methods 624
and 625 were used.
tUSEPA Methods for Chemical Analysis of Water and Wastes,
USEPA, Environmental Monitoring and Support Laboratory,
Cincinnati, Ohio, March 1979, EPA-600/4-79-020.
ttProcedures are described in "Guidelines Establishing Test Pro-
cedures for Analysis of Pollutants; Proposed Regulations,
Appendix IV," Federal Register, December 3, 1979, p. 69559.
133
-------
Table VI-17
DETECTION LIMITS FOR PRIORITY TOXIC POLLUTANTS
Analytical*
Detection Limit
Pollutant (ug/1)
Base/Neutral Extractable Compounds
N-nitrosodimethylamine 250
isophorone 50
hexachlorocyclopentadiene 250
benzidine 50
3,3'-dichlorobenzidene 50
indeno(1,2,3-cd)pyrene 25
dibenzo(ah)anthracene 25
benzo(ghi)perylene 25
all other base/neutral compounds 10
Acid Extractable Compounds
2,4-dimethylphenol 250
2,4-dinitrophenol 250
2-methyl-4,6-dinitrophenol 250
pentachlorophenol 125
all other acid compounds 25
Volatile Compounds
acrolein 100
acrylonitrile 100
all other volatile compounds 10
Pesticides
aldrin 0.003
dieldrin 0.006
chlordane 0.04
4,4'-DDT 0.016
4,4'-DDE 0.006
4,4'-DDD 0.012
alpha-endosulfan 0.005
beta-endosulfan 0.010
endosulfan sulfate 0.03
endrin 0.009
endrin aldehyde 0.023
heptachlor 0.002
heptachlor epoxide 0.004
134
-------
Table VI-17 (Continued)
DETECTION LIMITS FOR PRIORITY TOXIC POLLUTANTS
Analytical*
Detection Limit
Pollutant (ug/1)
Pesticides (Continued)
alpha-BHC 0.002
beta-BHC 0.004
gamma-BHC 0.004
delta-BHC 0.002
PCB-1242 0.05
PCB-1254 0.06
PCB-1221 0.10
PCB-1232 0.10
PCB-1248 0.06
PCB-1260 0.15
PCB-1016 0.04
toxaphene 0.40
Metals
antimony 100
arsenic 53
beryllium 0.3
cadmium 4
chromium 7
copper 6
lead 42
mercury 0.1
nickel 15
selenium 75
silver 7
thallium 100
zinc 2
Others
cyanide 20
*These analytical detection limits are from the USEPA test method
for the organic acid, base neutral, and volatile pollutants.
The limits for the pesticides and metals are from the Federal
Register, Monday, December 3, 1979, "Guidelines Establishing
Test Procedures for the Analysis of Pollutants; Proposed
Regulations."
135
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Sampling Procedure Protocols
The following procedures were used during the sampling episodes.
These procedures comply with sampling method protocols.
Bottle/Glassware Preparation. Sample containers and glassware
that came in contact with the process water samples were prepared
according to the procedures outlined in Table VI-18. With the
exceptions of grease and oil jars, volatile organic analysis
vials, field blank and preservative blank containers, and the
non-volatile (NVO) composite jug, sample containers were rinsed
with process water prior to use.
Composite Samples. Composite samples were collected using an
ISCO Model 1580 Sampler equipped with new silastic pump tubing
and new teflon sample lines. An aluminum rod was used to anchor
the sample line in place if necessary. The equipment was pro-
grammed to collect a minimum of nine quarts (8,516 milliliters)
of process water over the duration of each sampling day. The
minimum aliquot size was 100 milliliters and the maximum interval
between aliquot collection was 30 minutes.
The operation of each sampler was checked periodically throughout
the sampling day. Batteries used with the samplers were changed
on a daily basis to avoid problems.
At the conclusion of collection of each composite sample period,
contents of the jug were thoroughly mixed by shaking before being
transferred to individual containers. Graduated cylinders were
used to transfer the sample from the sample jug to the container
to avoid spillage.
Free Chlorine Determination. A free chlorine determination was
made with potassium iodide paper at each sampling point at the
beginning of each sampling day. The appropriate samples were
preserved if free chlorine was present in excess of 1 ppm.
Sample Preservation. All samples were maintained at 4°C during
the sampling period. All preservatives were purchased fresh and
placed in new containers. Cyanide and phenol samples were col-
lected via grab samples and preserved with appropriate chemicals
as soon as they were collected. Oil and grease samples were
single grab samples preserved with sulfuric acid. VGA samples
were individual grab samples collected four times per day and
preserved with sodium metabisulfate, if necessary. Individual
pipets were used for each preservative and discarded after use to
avoid cross-contamination.
pH Measurement. pH was monitored at each sampling location using
pH meters. The meter was buffered before use with pH 4, 7, and
136
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10 buffering agents. If pH meters were not available, pH paper
was used.
Temperature Measurement. Temperature was measured with metal
dial thermometers. Mercury thermometers were not used because of
potential contamination of the process water in case the
thermometer broke.
Laboratory Quality Assurance/Quality Control (QA/QC)
Quality control measures used in the laboratory are presented in
"Handbook for Analytical Quality Control in Water and Wastewater
Laboratories" (published by EPA Environmental Monitoring and Sup-
port Laboratory, Cincinnati, Ohio, 1976). As part of the analyt-
ical quality control program, duplicates and blanks (including
sealed VGA samples of blank water carried to each sampling site
and returned unopened and samples of preserved and unpreserved
equipment blank water) were analyzed. Standards and spiked
samples were also analyzed. As part of the analytical QA/QC, all
instruments (such as balances, spectrophotometers, and recorders)
were routinely maintained and calibrated.
PROCESS WATER POLLUTANT CONCENTRATIONS
Analytical data for each type of process water were summarized
and are presented in this section. The tables that present the
data contain the following information for each pollutant:
1. Number of samples analyzed,
2. Number of times pollutant was detected,
3. Subcategory pollutant concentration range, and
4. Subcategory average pollutant concentration.
Table VI-19 presents these data for the three subcategories.
Only pollutants that were detected one or more times are included
in Table VI-19. The daily data used to calculate the summaries
are presented in Appendix A.
Certain data editing rules were applied to the daily data; the
data were then averaged by a flow-weighted averaging methodology
to calculate the subcategory average concentrations listed in
Table VI-19. The editing rules and averaging methodology are
described below.
Data Editing Rules
The following editing rules were used to calculate the subcate-
gory pollutant average concentrations:
139
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1. All non-detected results were averaged as zero.
2. The source water concentration was subtracted from the
process water concentration. If a negative number
resulted, zero was used in the average.
3. Laboratory values below the method detection limit were
averaged as the reported value.
4. Laboratory values reported as less than values for
organic compounds were averaged as the values without
the less than sign.
5. Duplicate data were treated as data for an additional
sampling day.
6. For the priority toxic pollutant metals, when both the
Task 1 (Inductively Coupled Plasma Optical) and Task 2
(Flame Atomic Absorption) analyses were performed, only
the Task 1 test results were used in the averaging
process. A metal laboratory result reported as a less
than value was treated as a non-detected result in the
averaging methodology.
These editing rules vary from the editing rules used to develop
pollutant averages for the proposed PM&F regulation. At propo-
sal, the following editing rules were used:
1. Non-detected values were excluded from the data base.
2. Source water concentrations were not subtracted from the
process water concentration.
3. Laboratory values equal to or below the method detection
limit were excluded from the data base.
4. Laboratory values reported as less than values for
organic compounds were excluded from the data base.
These less than values were usually equal to the method
detection limit.
5. Duplicate data were treated as data for an additional
sampling day.
6. For the priority metal pollutants, when both the Task 1
(Inductively Coupled Plasma Optical) and Task 2 (Flame
Atomic Absorption) analyses were performed, only the
Task 1 test results were used in the data base. A metal
laboratory result reported as a less than value was
treated as a non-detected result in the averaging
methodology.
151
-------
EPA1 s pre-proposal editing rules that excluded values in the
averaging methodology lead to examination of the process water
characteristics on a worse-case basis. By not considering non-
detected values, the concentration average was skewed conserva-
tively high. The post-proposal editing rule that includes all
non-detected data points as zeros in the averaging of data recog-
nizes that even though certain pollutants were not detected, the
resulting data (i.e., that indicating non-detection) are valid
data. These values were included in subcategory average pollu-
tant concentration calculations to ensure proper characterization
of subcategory process water instead of only characterizing a
segment of the subcategory process water where pollutants were
found above their detection limits.
At proposal, EPA did not subtract the source water concentration
from the process water concentration prior to averaging the
process water concentration because the plant's source water
pollutant concentrations contribute to the overall effluent
concentrations. However, EPA decided to subtract the source
water concentration from the process water concentration before
averaging the data for development of the final regulation. This
allowed the Agency to determine the pollutants that were added to
process water from the PM&F processes.
EPA used laboratory results equal to or below the method detec-
tion limit in developing the final PM&F regulation because the
Agency believes that all reported values should be used to calcu-
late average concentrations even though a value may be below a
method detection limit. In addition, EPA had no reason to
believe such data were not valid. Therefore, the data were used
to calculate the subcategory average concentrations.
To develop the final regulation, laboratory results for organic
compounds that were reported as less than values, were averaged
as the value without the less than sign. As discussed above, EPA
believes that all data should be used to calculate the pollutant
averages for the PM&F subcategories. By using the value without
the less than sign, the Agency was conservative in assuming that
the pollutant was present.
The treatment of duplicate data did not change between proposal
and promulgation. EPA considered duplicate data as data for an
additional sampling day.
Likewise, the use of Task 1 metal analyses, instead of Task 2
metal analyses when results from both analyses were available,
did not change between proposal and promulgation. EPA used Task
1 analyses results because only those results were available for
all sampled processes. The use of reported less than values did
152
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not change between the proposed and promulgated regulation. A
reported metal less than value was treated as a non-detected
result.
Pollutant Average Concentration Methodology
For the proposed PM&F rule, EPA used subcategory average pollu-
tant concentrations to characterize PM&F process waters and then
to determine which pollutants warranted control by the effluent
limitations guidelines and standards for a subcategory. The
Agency estimated subcategory average pollutant concentrations by
obtaining an arithmetic average of the pollutant concentrations
found in PM&F process waters during several sampling episodes.
Based on these estimates, EPA identified pollutants present in
treatable concentrations and then selected various technology
options to control those pollutants.
Several commenters on the proposal stated that the subcategory
average pollutant concentrations should be estimated by flow-
weighting the sampling data because arithmetic averages over-
estimate the concentrations of the pollutants in PM&F process
waters. They claimed that flow-weighted averages should be used
to account for the wide variation in the amount of process water
discharged by the processes that were sampled. Commenters also
stated that different average pollutant concentrations should be
calculated for extrusion processes in the contact cooling and
heating water subcategory and for other processes in that sub-
category. According to the commenters, extrusion processes have
the highest water use in that subcategory and process water from
those processes does not contain pollutants in high concentra-
tions.
EPA reviewed the variation in the amount of water discharged by
processes sampled during the development of the PM&F regulation.
The Agency determined that there is wide variation in the dis-
charge rates and that the variation should be considered when
subcategory average pollutant concentrations are estimated. EPA
also determined that flow-weighted average pollutant concentra-
tions provide a better estimate of the pollutant concentrations
found in PM&F process waters because that type of average
addresses the impact of the wide variation in discharge rates.
More weight is given to high flow rate processes than to low flow
rate processes when flow-weighted concentrations are calculated.
When arithmetic averages are calculated, all processes are given
the same weight regardless of their discharge rate. In develop-
ing the final PM&F regulation, EPA relied on flow-weighted pol-
lutant averages to estimate the pollutant concentrations found in
process water discharged from processes in each subcategory.
153
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In response to the comment concerning separate average concentra-
tions for the extrusion processes, the Agency proportioned the
flow-weighted concentrations for the contact cooling and heating
water subcategory by the number of processes for each type of
contact cooling and heating water process in the questionnaire
data base. This gave more weight to extrusion processes because
the largest number of processes in the data base for the contact
cooling and heating water subcategory are extrusion processes.
Presented below is the methodology that the Agency used to flow-
weight the pollutant concentration data. This methodology uses
analytical results and flow data from the sampling episode; it
also uses weighting factors from the questionnaire data base to
determine the predominance of a type of process in the contact
cooling and heating water subcategory. Table VI-20 presents the
sampling data used in the example presented below. Table VI-21
presents the questionnaire data base weighting factors that were
used in the concentration averaging methodology. The methodology
steps described below were applied to the data in Tables VI-20
and VI-21 in the following example:
1. The processes contributing to each type of process water
are separated into similar types of processes (i.e.,
extrusion, molding, calendering, thermoforming, and
casting processes are separated within the contact
cooling and heating water subcategory).
There are two extrusion processes and one molding
process in the example. The extrusion processes are
denoted as EX-1 and EX-2, and the molding process is
denoted as MD-1 in Table VI-20.
2. The daily concentrations for each process are flow-
weighted to obtain an average daily flow-weighted con-
centration. The process water usage flow rates measured
on the sampling days are used to flow-weight the
concentrations.
Average Daily
Process Flow-Weighted Concentration (mg/1)
EX-1 (10 mg/1) (100 1/hr) + (30 mg/1) (140 1/hr) +
(15 mg/1) (100 1/hr) = 19.7 mg/1
(100 1/hr + 140 1/hr + 100 1/hr)
EX-2 (50 mg/1) (300 1/hr) + (10 mg/1) (400 1/hr) = 27 mg/1
(300 1/hr + 400 1/hr)
MD-1 (100 mg/1)(50 1/hr) + (110 mg/1)(60 1/hr) +
(120 mg/1) (60 1/hr) =111 mg/1
(50 1/hr + 60 1/hr + 60 1/hr)
154
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Table VI-21
QUESTIONNAIRE DATA BASE WEIGHTING FACTORS FOR
FLOW-WEIGHTED CONCENTRATION METHODOLOGY
CONTACT COOLING WATER SUBCATEGORY
Percentage of Processes*
Type of Process in Questionnaire Data Base
Extrusion 85.05
Molding 7.48
Coating and Laminating 3.04
Thermofortning 2.33
Casting 1.40
Calendering 0.70
100.00
*See Table VI-6.
156
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3. For each process, the water usage flow rates measured on
the sampling days are averaged. This is the average
process water usage rate.
Average Process Water
Process Usage Rate (1/hr)
EX-1 100 + 140 + 100 =113 1/hr
3
EX-2 300 + 400 = 350 1/hr
2
MD-1 50 + 60 + 60 = 85 1/hr
2
4. The average daily flow-weighted concentrations (calcu-
lated in step 2) for all similar processes in a subcate-
gory are flow-weighted using the average process water
usage rates (calculated in step 3). For example, the
average daily flow-weighted concentrations of extrusion
processes within the contact cooling and heating water
subcategory are flow-weighted together. This resulting
concentration is the type-of-process flow-weighted
concentration.
Type Type-of-Process
of Process Flow-Weighted Concentration (mg/1)
Extrusion (19.7 mg/1) (113 1/hr) + (27 mg/1) (350 1/hr)
(113 1/hr + 350 1/hr)
- 25.2 mg/1
Molding (111 me/1) (85 1/hr) =111 mg/1
(85 1/hr)
5. The average process water usage rates (calculated in
step 3) are averaged together for all similar processes
to calculate a type-of-process average water usage flow
rate.
Type-of-Process
Average Water
Type of Process Usage Flow Rate (1/hr)
Extrusion (113 1/hr + 350 l/hr)/2 = 232 1/hr
Molding 85 1/hr
157
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6. The average pollutant mass for a type of process is cal-
culated by multiplying the type-of-process flow-weighted
concentration (calculated in step 4) by the type-of-
process average water usage flow rate (calculated in
step 5).
Type of Process Average Pollutant Mass (mg/hr)
Extrusion (25.2 mg/1) (232 1/hr) = 5,850 mg/hr
Molding (111 mg/1) (85 1/hr) - 9,440 mg/hr
7. For each type of process, the average pollutant mass
(calculated in step 6) is weighted by the predominance
of that type of process in the questionnaire data base.
The weighted average pollutant masses for the different
types of processes are then summed together. Extrusion
processes comprise 85.05 percent and molding processes
comprise 7.48 percent of the questionnaire data base
contact cooling and heating water processes (from Table
VI-21).
Type of Process Weighted Pollutant Mass (mg/hr)
Extrusion (0.8505) (5,850 mg/hr) = 4,970
Molding (0.0748) (9,440 mg/hr) = 706
TOTAL 5,676 mg/hr
8. For each type of process, the type-of-process average
water usage flow rate (calculated in step 5) is also
weighted by the predominance of that type of process in
the questionnaire data base. The weighted type-of-
process average flows for the different types of
processes in the contact cooling and heating water
subcategory are summed together.
Weighted Type-of-Process Average
Type of Process Water Usage Flow Rate (1/hr)
Extrusion (0.8505) (232 1/hr) = 197
Molding (0.0748) (85 1/hr) = 6.4
TOTAL 203.4 1/hr
158
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9. The subcategory average concentration is calculated by
dividing the total weighted pollutant mass (calculated
in step 7) by the total weighted flow (calculated in
step 8).
Subcategory Average Concentration (mg/1)
Pollutant X (5,676 mg/hr)/(203.4 1/hr) = 27.9 mg/1
The calculation procedure is more simplified for the cleaning
water subcategory and the finishing water subcategory because
these subcategories have only one type of process (i.e., cleaning
or finishing processes). The same methodology is used except for
proportioning the average by type of process.
SAMPLED PLANTS WITH WASTEWATER TREATMENT SYSTEMS
Wastewater treatment technologies exist at four of the plants
(i.e., plants C, E, F, and I) that were sampled in 1980, at one
plant (i.e., Plant B) that was sampled in 1983, and at three
plants that were sampled in 1984 (i.e., plants M, N, and R). Of
the sampled treatment systems, plants I, M, N, and R had a waste-
water treatment system primarily for PM&F process waters.
The treatment at Plant I consists of equalization, pH adjustment,
and filtration (see Figure VI-9). Treatment at Plant M consists
of filtration and settling of contact cooling water. Figure
VI-12 illustrates this treatment. Process water from the grind-
ing operation at Plant N is filtered before discharge (see Figure
VI-13). Treatment for recycled contact cooling water at Plant R
consists of solids skimmings from a collection sump and filtra-
tion through a bag filter (see Figure VI-17). Effluent data for
these treatment processes are presented in Appendix A.
The treatment process at Plants B, C, E, and F is a lagoon that
treats a combined wastewater. Effluents from the lagoons at
Plants E and F were sampled during this project. These effluent
data were not used in the data analyses for the PM&F regulation
because they treat more than just PM&F process waters. Those
data are contained in the administrative record for the
regulation.
SOLUTION CASTING/SOLVENT RECOVERY SAMPLING DATA
Wastewater is also generated by the solvent recovery operation in
the solution or solvent casting process. However, this waste-
water does not result from the blending, molding, forming, or any
processing of the plastic material and is not a process water.
Samples of this wastewater indicate that its pollutant character-
istics are different from the characteristics of PM&F process
159
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waters. In addition, the Agency estimates that only eight plants
in the category generate solvent recovery wastewater. For these
reasons, the Agency believes that solvent recovery wastewater is
best controlled on a case-by-case basis by the permit writer or
control authority. Analytical data for this type of wastewater
from the Agency's study of the plastics molding and forming
category may be used as a guide by the permit writer. Appendix A
presents wastewater pollutant characteristics for a solution
casting process at Plant G. See Figure VI-7 for a process
diagram.
TOTAL PHENOLS VERIFICATION AT PLANT F
The sample points shown in Figure VI-6 were resampled in 1984 to
verify the process water total phenols concentrations at Plant F.
All samples had total phenols samples of less than 0.01 mg/1.
Because the concentrations from the 1980 sampling episode,
ranging from <5 to 1 ,670 mg/1, could not be explained by plant
personnel and because the 1984 sampling data do not verify the
1980 analytical results, the total phenols data from Plant F were
not used to obtain a subcategory average concentration for total
phenols.
160
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SECTION VII
POLLUTANTS IN PLASTICS MOLDING AND FORMING PROCESS WATERS
The Agency studied the plastics molding and forming category to
determine the presence of conventional, selected nonconventional,
and priority toxic pollutants in PM&F process waters.
CONVENTIONAL POLLUTANTS
As previously mentioned, conventional pollutants are those
defined in Section 304(a)(4) of the Act and any other pollutants
defined by the Administrator as conventional pollutants. The
list of conventional pollutants currently includes: biochemical
oxygen demand (BOD), total suspended solids (TSS), fecal coli-
form, pH, and oil and grease.
Samples collected during the 1980, 1983, and 1984 sampling epi-
sodes for the PM&F regulation were analyzed for 6005, TSS, oil
and grease, and pH. All of these pollutants warrant further con-
sideration for control in the cleaning water subcategory because
they were found in treatable concentrations in the cleaning pro-
cess waters. In the finishing water subcategory, total suspended
solids (TSS) were found in concentrations that warrant control.
The contact cooling and heating water subcategory does not have
treatable concentrations of 6005, oil and grease, or TSS.
Refer to Table VI1-1 for the average concentrations of the
conventional pollutants that are controlled in each subcategory.
NONCONVENTIONAL POLLUTANTS
Samples collected during the 1980, 1983, and 1984 sampling epi-
sodes were also analyzed for the nonconventional pollutants
listed in Table VII-2. These pollutants were selected for analy-
sis based on knowledge of the raw materials used in the PM&F
category and on the potential for those pollutants to be dis-
charged in PM&F process waters.
Results of the sample analyses indicate that only three noncon-
ventional pollutants were found in treatable concentrations in
cleaning process waters. They are: chemical oxygen demand
(COD), total organic carbon (TOG), and total phenols. Refer to
Table VI1-3 for the average concentrations of the nonconventional
pollutants in cleaning water.
Nonconventional pollutants were not found in treatable concentra-
tions in contact cooling and heating waters or in finishing
waters.
161
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Table VII-2
NONCONVENTIONAL POLLUTANTS FOR WHICH SAMPLES WERE ANALYZED
Nonconventional Pollutant
Ammonia
Boron
Bromide
Chemical oxygen
demand (COD)
Cyanide (amenable)
Fluoride
Free chlorine
Nitrates
Sulfate
Sulfide
Surfactants
Total dissolved solids
Total Kjehdahl nitrogen
Total organic carbon (TOG)
Total phenols
Total phosphorus
Sampling Episode Year
1980
X
X
X
X
X
X
X
X
X
1983
X
X
X
X
X
X
X
X
X
X
X
X
X
X
1984
X
X
X
X
163
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Table VII-3
NONCONVENTIONAL POLLUTANT AVERAGE CONCENTRATIONS -
CLEANING WATER SUBCATEGORY
Nonconventional Pollutant Average Concentration (mg/1)*
COD 115
TOG 634
Total Phenols 36
*Average concentrations are from Table VI-19
164
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In the proposed PM&F regulation, the Agency indicated that
although approximately 79 percent of the mass of nonconventional
pollutants in contact cooling and heating waters would be removed
by the proposed BPT, EPA was going to investigate the nonconven-
tional pollutants, particularly COD and TOG, to determine the
constituents of those pollutants. Subsequent to proposal, the
Agency conducted a study to determine what contributes to those
pollutants.
EPA reviewed the analytical data for the contact cooling and
heating water samples to determine which of the pollutants that
the samples were analyzed for would contribute to the COD and
TOG. By doing this, the Agency determined whether the concentra-
tions of COD and TOC in contact cooling and heating waters were
solely attributed to the organic pollutants for which analyses
were conducted. Results of that work indicated that other pollu-
tants contributed to the COD and TOC because the concentrations
of COD and TOC were higher than the total of the concentrations
of the organic pollutants in the contact cooling and heating
waters.
The Agency believes that many different non-priority organic pol-
lutants could have contributed to the COD and TOC concentration
estimates at proposal. However, EPA could not identify those
pollutants because the contact cooling and heating water samples
were only analyzed for conventional, selected nonconventional,
and priority toxic pollutants.
As discussed in Section VI of this development document, the
Agency revised its pollutant averaging methodology for the final
PM&F regulation. Flow-weighted averages were calculated for the
final rule to account for the different flow rates of the sampled
processes. EPA believes that flow-weighted averages provide a
better estimate of the pollutant concentrations than the
arithmetic averages used for the proposal.
Based on the flow-weighted subcategory average concentrations for
the COD and TOC, those pollutants are not present in treatable
concentrations in contact cooling and heating waters. The Agency
does not believe that the masses of COD and TOC in contact cool-
ing and heating waters calculated using the flow-weighted
subcategory averages are significant.
PRIORITY TOXIC POLLUTANTS
List of Pollutants
One hundred and twenty-nine priority toxic pollutants were
studied for the PM&F regulation pursuant to the requirements of
the Clean Water Act of 1977. These pollutants, which are listed
165
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in Table VI-15, are members of the 65 compounds and classes of
compounds referred to in Section 307(a)(1) of the Act.
From the original list of 129 priority pollutants, three pollu-
tants were deleted in two separate amendments to 40 CFR Subchap-
ter N, Part 401. Dichlorodifluoromethane and trichlorofluoro-
methane were deleted first (46 FR 79692; January 8, 1981)
followed by the deletion of bis(chloromethyl) ether (46 FR 10723;
February 4, 1981). The Agency concluded that deleting tHese com-
pounds does not compromise adequate control over their discharge
into the aquatic environment and that no adverse effects on the
aquatic environment or on human health will occur as a result of
deleting them from the list of priority toxic pollutants. Con-
centration data were obtained for these pollutants during the
sampling episodes for this regulation because some of the PM&F
samples were collected and analyzed prior to the deletion of
these pollutants from the list of priority pollutants. These
pollutants were not considered, however, for the final PM&F
regulation.
Data on the concentration of asbestos in PM&F process waters are
available from a small number of samples taken during the 1980
sampling program. Those data indicate that asbestos was not
present or could not be interpreted because of the limited number
of fibers counted. EPA did not analyze for asbestos in the 1983
and the 1984 sampling programs.
Exclusion of Pollutants and Subcategories
The modified Settlement Agreement in NRDC v. Train, supra, con-
tains provisions that authorize the exclusion ofpriority toxic
pollutants and industry subcategories from regulation in certain
instances. These provisions are presented in Paragraph 8 of the
modified Settlement Agreement. They are:
"1. For a specific pollutant or a subcategory or category,
equally or more stringent protection is already pro-
vided by an effluent, new source performance standard,
or pretreatment standard or by an effluent limitation
and guideline promulgated pursuant to Section(s) 301 ,
304, 306, 307(a), 307(b), and 307(c) of the Act.
2. For a specific pollutant, except for pretreatment stan-
dards, the specific pollutant is present in the effluent
discharge solely as a result of its presence in intake
waters taken from the same body of water into which it
is discharged and, for pretreatment standards, the
specific pollutant is present in the effluent which is
introduced into treatment works (as defined in Section
212 of the Act) which are publicly owned solely as a
166
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result of its presence in the point source's intake
waters, provided however, that such point source may be
subject to an appropriate effluent limitation for such
pollutant pursuant to the requirements of Section 307.
3. For a specific pollutant, the pollutant is not detecta-
ble (with the use of analytical methods approved pursu-
ant to 304(h) of the Act, or in instances where approved
methods do not exist, with the use of analytical methods
which represent state-of-the-art capability) in the
direct discharges or in the effluents which are intro-
duced into publicly-owned treatment works from sources
within the subcategory or category; or is detectable in
the effluent from only a small number of sources within
the subcategory and the pollutant is uniquely related to
only those sources; or the pollutant is present only in
trace amounts and is neither causing nor likely to cause
toxic effects; or is present in amounts too small to be
effectively reduced by technologies known to the Admin-
istrator; or the pollutant will be effectively con-
trolled by the technologies upon which are based other
effluent limitations and guidelines, standards of
performance, or pretreatment standards.
4. For a category or subcategory, the amount and the toxic-
ity of each pollutant in the discharge does not justify
developing national regulations in accordance with the
schedule contained in Paragraph 7(b)."
The basis for exclusion in subparagraph 2 above for the PM&F
regulation is that if a pollutant was found in a higher concen-
tration in the plant intake water (i.e., source water) than in
the process water generated by the PM&F process, that pollutant
would be excluded from control. Data obtained from the sampling
episodes were reviewed, therefore, to determine which, if any, of
the priority pollutants were excluded from control because of
this reason.
With respect to subparagraph 3 for the PM&F regulation, a pollu-
tant was considered not detected if the laboratory reported that
it was not detected or if the laboratory reported that it was
detected at or below the analytical detection limit. Pollutants
were excluded from control if they were not detected or detected
at or below their detection limit. Refer to Table VI-17 for
analytical detection limits for the priority toxic pollutants.
Also for the PM&F regulation, "detected in a small number of
sources" was defined as detected in two or less samples when 20
or more samples were analyzed. If a pollutant was found in two
or less samples when 20 or more samples were analyzed for that
pollutant, it was excluded from further consideration. Another
167
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basis for exclusion in subparagraph 3 is that a pollutant is
present in amounts too small to be effectively reduced by
technologies known by the Administrator.
The PM&F category was reviewed to determine if any of the prior-
ity pollutants could be excluded based on Paragraph 8 of the
Settlement Agreement. Each subcategory was also reviewed to
determine if any priority pollutants could be excluded by sub-
category. Results of those reviews are presented below.
PM&F Category. The Agency first applied the exclusion criterion
that a pollutant was not detected or was detected at or below the
analytical detection limit to exclude pollutants for the entire
PM&F category. Table VII-4 lists 73 priority toxic pollutants
that were not detected in any of the process water samples
analyzed or were detected at or below the pollutant analytical
detection limit. These pollutants are excluded from regulation
for the PM&F category and were not considered further. Table
VII-5 lists the priority pollutants that were considered further
because they were detected above their analytical detection
limit.
PM&F Subcategories. Priority pollutants listed in Table VII-5
were reviewed by subcategory to determine whether:
1. A pollutant was never detected in process water samples
for this subcategory or was detected at or below the
analytical detection limit;
2. A pollutant was found in a higher concentration in the
plant intake water (i.e., source water) than in the
process water generated by the PM&F process; and
3. A pollutant was detected in two or less samples when 20
or more samples were analyzed for that pollutant.
A pollutant was first reviewed to determine if it was found above
the detection limit. If it was, the data were reviewed to deter-
mine if the pollutant was present in a higher concentration in
the source water than in the process water. If the concentration
was higher in the effluent, the pollutant was examined for occur-
rence in more than two samples if 20 or more samples were ana-
lyzed. If the pollutant passed all of these criteria, it was
considered further for regulation. Table VII-6 presents an
example of this exclusion methodology. Table VII-7 presents
priority pollutants excluded from control for the PM&F subcate-
gories using this methodology. Table VII-8 lists the priority
pollutants that remain after the above mentioned exclusions and
their subcategory average concentration (from Table VI-19).
168
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Table VII-5
PRIORITY POLLUTANTS DETECTED IN PM&F PROCESS WATERS
Priority Pollutant
4. benzene
8. 1,2,4-trichlorobenzene
11. 1,1,1-trichloroethane
12. hexachloroethane
22. parachlorotneta cresol
23. chloroform (trichloro-
methane)
28. 3,3'-dichlorobenzidine
30. 1,2-trans-dichloro-
ethylene
38. ethylbenzene
44. methylene chloride
(dichloromethane)
47. bromoform (tribromo-
methane)
48. dichlorobromomethane
55. naphthalene
62. N-nitrosodiphenylamine
65. phenol
66. bis(2-ethylhexyl)
phthalate
68. di-n-butyl phthalate
69. di-n-octyl phthalate
70. diethyl phthalate
71. dimethyl phthalate
73. benzo (a)pyrene
(3 ,4-benzopyrene)
85. tetrachloroethylene
86. toluene
87. trichloroethylene
89. aldrin
90. dieldrin
92. 4,4'-DDT
93. 4,4'-DDE(p>p'DDX)
94. 4,4'-DDD(p,p'TDE)
96. beta-endosulfan
97. endosulfan sulfate
98. endrin
99. endrin aldehyde
100. heptachlor
101. heptachlor epoxide
102. alpha-BHC
103. beta-BHC
104. gamma-BHC
105. delta-BHC
114. antimony
115. arsenic
117. beryllium
118. cadmium
119. chromium (Total)
120. copper
121. cyanide (Total)
122. lead
123. mercury
124. nickel
125. selenium
126. silver
127. thallium
128. zinc
170
-------
Table VII-6
EXCLUSION METHODOLOGY EXAMPLE - POLLUTANT X
Process
Method
Detection
Limit
(mg/1)
Pollutant X
Concentration (mg/1)
Source Day 1 Day 2 Day 3 Day 4 Day 5
4 NB (3) NB NB (4)
2
3
4
ND
(5)
4-
Nfi
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Nfi
Exclusion Methodology
1. Data are first eliminated because the pollutant was never
detected or detected at or below the analytical detection
limit. See sample data that have a straight line through
them.
2. Data are next eliminated if the source water concentrations
are equal to or greater than the effluent concentrations.
See sampled data enclosed by parentheses.
3. Data are finally eliminated if only analytical results remain
for two or less samples when 20 or more samples were
analyzed. See sample data that are circled.
Pollutant X was excluded because it was found in two or less
samples after the other data were eliminated.
171
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The subcategory average concentrations for the priority pollu-
tants were compared with treatability limits for treatment tech-
nologies most capable of effectively removing the pollutants.
These treatability limits are presented in Table VII-9.
Because the treatability limits are based on "best-case"
treatment technologies, priority pollutants with a concentration
greater than the treatability limit were considered further for
control. The priority pollutants that were present at concentra-
tions higher than the treatable limits and their average concen-
trations are presented in Table VII-10. Priority pollutants with
a subcategory average below the treatability limit were consid-
ered present in amounts too small to be effectively reduced by
technologies known to the Administrator.
POLLUTANTS CONSIDERED FOR REGULATION
The following discussions address the pollutants listed in Tables
VII-1, VII-3, and VII-8. The discussions include the source of
the pollutant; whether it is a naturally occurring element, pro-
cessed metal, or a manufactured product; general physical proper-
ties and the form of the pollutant; and toxic effects of the
pollutant on humans and other animals.
Conventional Pollutants
Biochemical Oxygen Demand (BODQ. Biochemical oxygen demand is
not a specific pollutant, but a measure of the relative oxygen
requirements of wastewaters. The BOD5 test measures the oxygen
required for the biochemical degradation of organic material
(carbonaceous demand) and the oxygen used to oxidize inorganic
material such as sulfides and ferrous iron. It also may measure
the oxygen used to oxidize reduced forms of nitrogen (nitrogenous
demand) unless their oxidation is prevented by the use of an
inhibitor.
Many wastewaters contain more oxygen-demanding materials than the
amount of dissolved oxygen available in air-saturated water.
Therefore, it is necessary to dilute the sample, add nutrients,
and maintain the pH in a range suitable for bacterial growth.
When analyzing those wastewaters, complete stabilization of a
sample may require a period of incubation too long for practical
purposes. For this reason, a five day period was selected as the
standard incubation period.
Oil and Grease. Oil and grease are taken together as one pollu-
tant. Some of its components are:
1 . Light Hydrocarbons - These include light fuels such as
gasoline, kerosene, and jet fuel, and miscellaneous solvents used
176
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Table VII-9
POLLUTANT TREATABILITY LIMITS*
Treatability Limit
Priority Pollutant (mg/1)
4. benzene 0.050
8. 1 ,2,4-trichlorobenzene 0.010
11. 1 ,1 ,1-trichloroethane 0.100
22. parachlorometa cresol 0.050
23. chloroform 0.100
28. 3,3'-dichlorobenzidine 0.010
38. ethylbenzene 0.050
44. methylene chloride 0.100
62. N-nitrosodiphenylamine 0.001 to 0.010
65. phenol 0.050
66. bis(2-ethylhexyl) phthalate 0.010
68. di-n-butyl phthalate 0.025
71. dimethyl phthalate 0.001 to 0.010
86. toluene 0.050
87. trichloroethylene 0.100
89. aldrin 0.001
90. dieldrin 0.001
99. endrin aldehyde <0.001
100. heptachlor <0.001
102. alpha-BHC 0.001
103. beta-Erc 0.001
104. gamma-BHC 0.001
105. delta-BHC 0.001
114. antimony 0.47
115. arsenic 0.34
117. beryllium 0.200
118. cadmium 0.049
119. chromium 0.07
177
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Table VII-9 (Continued)
POLLUTANT TREATABILITY LIMITS*
Treatability Limit
Priority Pollutant (mg/1)
120. copper 0.39
121. cyanide 0.047
122. lead - 0.080
123. mercury 0.036
124. nickel 0.22
125. selenium 0.20
126. silver 0.070
127. thallium 0.200
128. zinc 0.23
*Treatability limits for organic priority pollutants (excluding
pesticides) are from U.S. EPA, Treatability of Organic Priority
Pollutants - Part C - Their Estimated (30-Day Ave.) Treated
Effluent Concentrations - A Molecular Engineering Approach,
Murray P. Strier, 11 July 1978.
Treatability limits for priority pollutant pesticides are from
U.S. EPA, Treatability of Organic Priority Pollutants - Part D •
The Pesticides - Their Estimated (30-Day Ave.) Treated Effluent
Concentrations, Murray P. Strier, 26 December 1978.
Treatability limits for the priority metal pollutants are from
the U.S. EPA, Development Document for Effluent Guidelines and
Standards for the Nonferrous Metals Manufacturing Point Source
Category Phase II. July 1984.
178
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for industrial processing, degreasing, or cleaning purposes. The
presence of these light hydrocarbons may make the removal of
other heavier oil wastes more difficult.
2. Heavy Hydrocarbons, Fuels, and Tars - These include the
crude oils, diesel oils, #6 fuel oil, residual oils, slop oils,
and in some cases, asphalt and road tar.
3. Lubricants and Cutting Fluids - These generally fall
into two classes: non-emulsifiable oils such as lubricating oils
and greases and emulsifiable oils such as water soluble oils,
rolling oils, cutting oils, and drawing compounds. Emulsifiable
oils may contain fat, soap, or various other additives.
4. Vegetable and Animal Fats and Oils - These originate
primarily from processing of foods and natural products.
Oil and grease can settle or float and may exist as solids or
liquids depending on factors such as method of use, production
process, and temperature of water.
Even in small quantities, oil and grease cause troublesome taste
and odor problems. Scum lines from these pollutants are produced
on treatment basin walls and on other containers. Fish and water
fowl are adversely affected by oils in their habitat. Oil
emulsions may adhere to the gills of fish causing suffocation,
and the flesh of fish is tainted when microorganisms that were
exposed to waste oil are eaten. Deposition of oil in the bottom
sediments of water can inhibit normal benthic growth and oil and
grease exhibit an oxygen demand.
Many of the toxic organic pollutants may be distributed between
the oil phase and the aqueous phase in industrial wastewaters.
The presence of phenols, PCB's, PAH's, and almost any other
organic pollutant in the oil and grease make characterization of
this pollutant almost impossible. The other organics add to the
objectionable nature of the oil and grease.
Levels of oil and grease that are toxic to aquatic organisms vary
greatly, depending on the type and the species susceptibility.
Crude oil in concentrations as low as 0.3 mg/1 has been reported
as extremely toxic to freshwater fish. It has been recommended
that public water supply sources be essentially free from oil and
grease.
Oil and grease in quantities of 100 liters per square kilometer
cause a sheen on the surface of a body of water. The presence of
oil slicks decreases the aesthetic value of a waterway.
180
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pH. Although not a specific pollutant, pH is related to the
acidity or alkalinity of a wastewater. It is not, however, a
measure of either. The term pH is used to describe the hydrogen
ion concentration (or activity) present in a given solution.
Values for pH range from 0 to 14; these numbers are the negative
logarithms of the hydrogen ion concentrations. A pH of 7 indi-
cates neutrality. Solutions with a pH above 7 are alkaline,
while those solutions with a pH below 7 are acidic. The rela-
tionship of pH and acidity and alkalinity is not necessarily
linear or direct. Knowledge of the water pH is useful in deter-
mining necessary measures for corrosion control, sanitation, and
disinfection. Its value is also necessary in the treatment of
industrial wastewaters to determine amounts of chemicals required
to remove pollutants and to measure their effectiveness. Removal
of pollutants, especially dissolved solids is affected by the pH
of the wastewater.
Waters with a pH below 6.0 are corrosive to treatment facilities,
distribution lines, and household plumbing fixtures and can thus
add constituents to drinking water such as iron, copper, zinc,
cadmium, and lead. The hydrogen ion concentration can affect the
taste of the water; at a low pH water tastes sour. The bacteri-
cidal effect of chlorine is weakened as the pH increases.
Extremes of pH or rapid pH changes can exert stress conditions on
or kill aquatic life. Even moderate changes from acceptable
criteria limits of pH are deleterious to some aquatic species.
The relative toxicity to aquatic life of many materials is
increased by changes in the water pH. For example, metallocya-
nide complexes can increase a thousand-fold in toxicity with a
drop of 1.5 pH units.
Because of the universal nature of pH and its effect on water
quality and treatment, it is controlled by the effluent limita-
tions guidelines and standards for many industry categories. A
neutral pH range (approximately 6 to 9) is generally desired
because either extreme beyond this range has a deleterious effect
on receiving waters and on other wastewater constituents.
Total Suspended Solids (TSS). Suspended solids include both
organic and inorganic materials. The inorganic compounds include
sand, silt, and clay. The organic fraction includes such materi-
als as grease, oil, tar, and animal and vegetable waste products.
These solids may settle out rapidly; bottom deposits are often a
mixture of both organic and inorganic solids. Solids may be
suspended in water for a time and then settle to the bed of the
stream or lake. Solids discharged with domestic wastes may be
inert, slowly biodegradable materials, or rapidly decomposable
substances. While in suspension, suspended solids increase the
181
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turbidity of the water, reduce light penetration, and impair the
photosynthetic activity of aquatic plants.
Suspended solids in water interfere with many industrial proces-
ses and cause foaming in boilers and incrustations on equipment
exposed to such water, especially as the temperature rises. They
are undesirable in process water used in many manufacturing
processes and in cooling water systems.
Solids in suspension are aesthetically displeasing. When they
settle to form sludge deposits on the stream or lake bed, they
often cause damage to aquatic life. Solids, when transformed to
sludge deposits, may do a variety of damaging things, including
blanketing the stream or lake bed and thereby destroying the
living spaces for those benthic organisms that would otherwise
occupy the habitat. Organic solids use a portion or all of the
dissolved oxygen available in the area and also serve as a food
source for sludgeworms and associated organisms.
Suspended solids may kill fish and shellfish by causing abrasive
injuries and by clogging the gills and respiratory passages of
various aquatic fauna. Indirectly, suspended solids are inimical
to aquatic life because they screen out light, and they promote
and maintain the development of noxious conditions through oxygen
depletion. This results in the killing of fish and fish food
organisms. Suspended solids also reduce the recreational value
of the water.
Nonconventional Pollutants
Chemical Oxygen Demand (COD). COD is a test that measures the
organic matter in wastewater by chemical oxidation. It is not a
measure of one particular pollutant. The oxygen equivalent
(i.e., carbon dioxide, C02) of the organic matter that can be
oxidized is measured by using a strong chemical oxidizing agent
in an acidic medium. Potassium dichromate is an excellent
oxidizing agent for this test. The principal reaction using
dichromate as the oxidizing agent may be generally represented by
the following unbalanced equation:
Organic Matter (CaH]-,Oc) + Cr20y= + H+
Cr3+ + C02 + H20
The COD of wastewater is usually higher than the BOD5 because
more compounds can be chemically oxidized than can be biologi-
cally oxidized. COD can be correlated with BOD5 for many kinds
of wastewater. This can be quite useful because COD test results
can be obtained in three hours versus the five days needed to
obtain 6005 test results.
182
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Total Organic Carbon (TOG). TOC is another test to determine the
organic matter present in wastewater; it is especially applicable
to small concentrations of organic matter. The test is performed
by injecting a known quantity of sample into a high-temperature
furnace. The organic carbon is oxidized to carbon dioxide in the
presence of a catalyst and the carbon dixoide is quantitatively
measured with an infrared analyzer. TOC also measures more than
one pollutant.
Phenols (Total). Total phenols are measured using the 4-AAP
(4-aminoantipyrene) method. This analytical procedure measures
the color development of reaction products between 4-AAP and some
phenols. The results are reported as phenol. Thus, "total
phenols" is not actually total phenols because many phenols
(notably nitrophenols) do not react. Also, because each reacting
phenol contributes to the color development to a different degree
and because each phenol has a molecular weight different from
others and from phenol itself, analyses of several mixtures con-
taining the same total concentration of several phenols will give
different numbers depending on the proportions of the phenols in
the particular mixture. Despite these limitations, the total
phenols method is useful when the mix of phenols is relatively
constant and an inexpensive monitoring method is desired.
Priority Toxic Pollutants
4. Benzene. Benzene (C6H5) is a clear, colorless liquid
obtained mainly from petroleum feedstocks using several different
processes. Some is recovered from light oils obtained from coal
carbonization gases. Benzene boils at 80°C and has a vapor
pressure of 100 mm of mercury at 26°C. It is slightly soluble in
water (1.8 g/1 at 25°C) and it dissolves in hydrocarbon solvents.
Annual production in the United States is three to four million
tons.
Most of the benzene used in the United States goes into chemical
manufacture. About half of that is converted to ethylbenzene
which is used to make styrene. Some benzene is used in motor
fuels.
According to numerous published studies, benzene is harmful to
human health. Most studies relate effects of inhaled benzene
vapors. These effects include nausea, loss of muscle coordina-
tion, and excitement followed by depression and coma. Death is
usually the result of respiratory or cardiac failure. Two spe-
cific blood disorders are related to benzene exposure. One of
these, acute myelogenous leukemia, represents a carcinogenic
effect of benzene. However, most human exposure data are based
on exposure in occupational settings and benzene carcinogenesis
is not firmly established.
183
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Oral administration of benzene to laboratory animals produced
leukopenia, a reduction in the number of leukocytes in the blood.
Subcutaneous injection of benzene-oil solutions has produced sug-
gestive, but not conclusive, evidence of benzene carcinogenesis.
Benzene demonstrated teratogenic effects in laboratory animals,
and mutagenic effects in humans and other animals.
For maximum protection of human health from the potential carcin-
ogenic effects of exposure co benzene through ingestion of water
and contaminated aquatic organisms, the ambient water concentra-
tion is zero. Concentrations of benzene estimated to result in
additional lifetime cancer risk at levels of 10~7, 10"^, and
10~5 are 0.000066 mg/1, 0.00066 mg/1, and 0.0066 mg/1, respec-
tively.
8. 1,2,4-Tri chloroben z ene. 1,2,4-Trichlorobenzene
(65113613, 1 ,2,4-TCB)is a liquid at room temperature,
solidifying to a crystalline solid at 17°C and boiling at 214°C.
It is produced by liquid phase chlorination of benzene in the
presence of a catalyst. Its vapor pressure is 4 mm Hg at 25°C.
1,2,4-TCB is insoluble in water and soluble in organic solvents.
Annual United States production is in the range of 15,000 tons.
1,2,4-TCB is used in limited quantities as a solvent and as a dye
carrier in the textile industry. It is also used as a heat
transfer medium and as a transfer fluid. The compound can be
selectively chlorinated to 1,2,4,5-tetrachlorobenzene using
iodine plus antimony trichloride as catalyst.
No reports are available regarding the toxic effects of 1,2,4-TCB
on humans. Limited data from studies on effects in laboratory
animals fed 1,2,4-TCB indicate depression of activity at low
doses and predeath extension convulsions at lethal doses.
Metabolic disturbances and liver changes were also observed.
Studies for the purpose of determining teratogenic or mutagenic
properties of 1,2,4-TCB have not been conducted. No studies have
been made of carcinogenic behavior of 1,2,4-TCB administered
orally.
For the prevention of adverse effects due to the organoleptic
properties of 1 ,2,4-trichlorobenzene in water, the water quality
criterion is 0.013 mg/1.
11. 1,1,1-Trichloroethane. 1,1,1-Trichloroethane is one of the
two possible trichlorethanes. It is manufactured by hydrochlori-
nating vinyl chloride to 1,1-dichloroethane which is then chlori-
nated to the desired product. 1,1,1-Trichloroethane is a liquid
at room temperature with a vapor pressure of 96 mm of mercury at
20°C and a boiling point of 74°C. Its formula is CC^CH^.
It is slightly soluble in water (0.48 g/1) and is very soluble in
184
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organic solvents. The United States annual production is greater
than one-third of a million tons. 1,1,1-Trichloroethane is used
as an industrial solvent and degreasing agent.
Most human toxicity data for 1,1,1-trichloroethane relate to
inhalation and dermal exposure routes. Limited data are avail-
able for determining toxicity of ingested 1,1,1-trichloroethane,
and those data are all for the compound itself, not solutions in
water. No data are available regarding its toxicity to fish and
aquatic organisms. For the protection of human health from the
toxic properties of 1 ,1 ,1-trichloroethane ingested through the
consumption of water and fish, the ambient water criterion is
18.4 mg/1. The criterion is based on results of bioassays for
possible carcinogenicity.
22. Para-chloro-meta-cresol. Para-chloro-meta-cresol
(ClCyt^OH) is thought to be a 4-chloro-3-methyl-phenol
(4-chloro-meta-cresol, or 2-chloro-5-hydroxy-toluene), but is
also used by some authorities to refer to 6-chloro-3-methyl-
phenol (6-chloro-meta-cresol, or 4-chloro-3-hydroxy-toluene),
depending on whether the chlorine is considered to be para to the
methyl or to the hydroxy group. For the purposes of this docu-
ment, the pollutant is assumed to be 2-chloro-5-hydroxy-toluene.
This pollutant is a colorless crystalline solid melting at 66 to
68°C. It is slightly soluble in water and soluble in organic
solvents. This pollutant reacts with 4-aminoantipyrene to give a
colored product and contributes, therefore, to the nonconven-
tional pollutant "total phenols." No information on manufactur-
ing methods or volumes produced was found.
Para-chloro-meta cresol (abbreviated here as PCMC) is marketed as
a microbicide and was proposed as an antiseptic and disinfectant
more than 40 years ago. It is used in glues, gums, paints, inks,
textiles, and leather goods.
Although no human toxicity data are available for PCMC, studies
on laboratory animals have demonstrated that this pollutant is
toxic when administered subcutaneously and intravenously. Death
was preceded by severe muscle tremors. At high dosages kidney
damage occurred. On the other hand, an unspecified isomer of
chlorocresol, presumed to be PCMC, is used at a concentration of
0.15 percent to preserve mucous heparin, a natural product admin-
istered intravenously as an anticoagulant. No information was
found regarding possible teratogenicity or carcinogenicity of
PCMC.
23. Chloroform. Chloroform, also called trichloromethane, is a
colorless liquid manufactured commercially by chlorination of
methane. Careful control of conditions maximizes chloroform
185
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E reduction, but other products must be separated. Chloroform
oils at 61 °C and has a vapor pressure of 200 mm of mercury at
25°C. It is slightly soluble in water (8.22 g/1 at 20°C) and
readily soluble in organic solvents.
Chloroform is used as a solvent and to manufacture refrigerants,
Pharmaceuticals, plastics, and anesthetics. It is seldom used as
an anesthetic.
Toxic effects of chloroform on humans include central nervous
system depression, gastrointestinal irritation, liver and kidney
damage and possible cardiac sensitization to adrenalin. Carcino-
genicity has been demonstrated for chloroform using laboratory
animals.
For the maximum protection of human health from the potential
carcinogenic effects of exposure to chloroform through ingestion
of water and contaminated aquatic organisms, the ambient water
concentration is zero. Concentrations of chloroform estimated to
result in additional lifetime cancer risks at the levels of
10-7, 10'6, and 10'5 are O.OQ0019 mg/1, 0.00019 mg/1, and
0.0019 mg/1, respectively.
28. 3,3'-Dichlorpbenzidine. 3,3'-Dichlorobenzidine (DCB) or
dichlorobenzidine(4,4'-diamino-3,3'-dichlorobiphenyl) is used in
the production of dyes and pigments and as a curing agent for
polyurethanes. The molecular formula of dichlorobenzidine is
C-| 2^10^-12^2 and the molecular weight is 253.13.
DCB forms brownish needles with a melting point of 132 to 133°C.
It is readily soluble in alcohol, benzene, and glacial acetic
acid, slightly soluble in HC1, and sparingly soluble in water
(0.7 g/1 at 15°C). When combined with ferric chloride or bleach-
ing powder, a green color is produced.
The affinity of DCB for suspended particulates in water is not
clear; its basic nature suggests that it may be fairly tightly
bound to humic materials in soils. Soils may be moderate to long
term reservoirs for DCB.
Pyrolysis of DCB will most likely lead to the release of HC1.
Because of the halogen substitution, DCB compounds probably bio-
degrade at a slower rate than benzidine alone. The photochemis-
try of DCB is not completely known. DCB may photodegrade to
benzidine.
Assuming the clean air concentrations of ozone (2 x 10~°) and
an average atmospheric concentration of hydroxyl radicals (3 x
10~15 M) , the half-life for oxidation of DCB by either of these
chemical compounds is on the order of one and one to 10 days,
186
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respectivelyv. Furthermore, assuming a representative concentra-
tion of 10"'" M for peroxy radicals in sunlit oxygenated water,
the half-life for oxidation by these compounds is approximately
100 days, given the variability of environmental conditions.
The data base available for dichlorobenzidines and freshwater
organisms is limited to one test on bioconcentration of
3,3*-dichlorobenzidine. No statement can be made concerning
acute or chronic toxicity of this pollutant.
No saltwater organisms have been tested with any dichlorobenzi-
dine; no statement can be made concerning acute or chronic
toxicity for that pollutant on saltwater organisms.
For the maximum protection of human health from the potential
carcinogenic effects due to exposure of dichlorobenzidine through
ingestion of contaminated water and contaminated aquatic organ-
isms, the ambient water concentration should be zero based on the
non-threshold assumption for this chemical. However, zero level
may not be attainable at the present time. Therefore, the levels
that may result in incremental increase of cancer risk over the
lifetime were estimated at 10'5, 10'6, and 10~7. The
corresponding recommended criteria are 0.103 ug/1, 0.010 ug/1,
and 0.001 ug/1, respectively. If the above estimates are made
for consumption of aquatic organisms only, excluding consumption
of water, the levels are 0.204 ug/1, 0.020 ug/1, and 0.002 ug/1,
respectively.
38. Ethylbenzene. Ethylbenzene is a colorless, flammable liquid
manufacturedcommercially from benzene and ethylene. Approxi-
mately half of the benzene used in the United States goes into
the manufacture of more than three million tons of ethylbenzene
annually. Ethylbenzene boils at 136°C and has a vapor pressure of
7 mm Hg at 20°C. It is slightly soluble in water (0.14 g/1 at
15°C) and is very soluble in organic solvents.
About 98 percent of the ethylbenzene produced in the United
States goes into the production of styrene, much of which is used
in the plastics and synthetic rubber industries. Ethylbenzene is
a constituent of xylene mixtures used as diluents in the paint
industry, agricultural insecticide sprays, and gasoline blends.
Although humans are exposed to ethylbenzene from a variety of
sources in the environment, little information on effects of
ethylbenzene in man or animals is available. Inhalation can
irritate eyes, affect the respiratory tract, or cause vertigo.
In laboratory animals, ethylbenzene exhibited low toxicity.
There are no data available on teratogenicity, mutagenicity, or
carcinogenicity of ethylbenzene.
187
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Criteria are based on data derived from inhalation exposure
limits. For the protection of human health from the toxic pro-
perties of ethylbenzene ingested through water and contaminated
aquatic organisms, the ambient water quality criterion is 1.4
mg/1.
44. Methylene Chloride. Methylene chloride, also called dichlo-
roroethane(CH2C12),is a colorless liquid manufactured by
chlorination of methane or methyl chloride followed by separation
from the higher chlorinated methanes formed as coproducts.
Methylene chloride boils at 40°C and has a vapor pressure of 362
mm of mercury at 20°C. It is slightly soluble in water (20 g/1
at 20°C) and very soluble in organic solvents. The United States
annual production is about 250,000 tons.
Methylene chloride is a common industrial solvent found in insec-
ticides, metal cleaners, paint, and paint and varnish removers.
Methylene chloride is not generally regarded as highly toxic to
humans. Most human toxicity data are for exposure by inhalation.
Inhaled methylene chloride acts as a central nervous system
depressant. There is also evidence that the pollutant causes
heart failure when large amounts are inhaled.
Methylene chloride did produce mutation in tests for this effect.
In addition, a bioassay recognized for its extremely high sensi-
tivity to strong and weak carcinogens produced results that were
marginally significant. Thus, potential carcinogenic effects of
methylene chloride are not confirmed or denied, but are under
continuous study. These studies are difficult to conduct for two
reasons. First, the low boiling point (40°C) of methylene chlo-
ride makes it difficult to maintain the compound at 37°C during
incubation. Secondly, all impurities must be removed because the
impurities themselves may be carcinogenic. These complications
also make the test results difficult to interpret.
62. N-nitrosodiphenylamine. N-nitrosodiphenylamine
[(C5H5)2NNC-n also called nitrous diphenylamide, is a
yellow crystalline solid manufactured by nitrosation of diphenyl-
amine. It melts at 66°C and is insoluble in water, but soluble
in several organic solvents other than hydrocarbons. Production
in the United States has approached 1 ,500 tons per year. The
compound is used as a retarder for rubber vulcanization and as a
pesticide for control of scorch (a fungus disease of plants).
N-nitroso compounds are acutely toxic to every animal species
tested and are also poisonous to humans. N-nitrosodiphenylamine
toxicity in adult rats lies in the mid range of the values for 60
N-nitroso compounds tested. Liver damage is the principal toxic
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effect. N-nitrosodiphenylamine, unlike many other N-nitroso-
amines, does not show mutagenic activity. N-nitrosodiphenylamine
has been reported by several investigations to be non-carcino-
genic. However, the pollutant is capable of trans-nitrosation
and could thereby convert other amines to carcinogenic N-nitroso-
amines. Sixty-seven of 87 N-nitrosoamines studied were reported
to have carcinogenic activity. No water quality criteria have
been proposed for N-nitrosodiphenylamine.
65. Phenol. Phenol, also called hydroxybenzene and carbolic
acid, is a clear, colorless, hygroscopic, deliquescent, crystal-
line solid at room temperature. Its melting point is 43 C and
its vapor pressure at room temperature is 0.35 mm Hg. It is very
soluble in water (67 gm/1 at 16°C) and can be dissolved in ben-
zene, oils, and petroleum solids. Its formula is C6H50H.
Although a small percent of the annual production of phenol is
derived from coal tar as a naturally occurring product, most of
the phenol is synthesized. Two of the methods are fusion of ben-
zene sulfonate with sodium hydroxide and oxidation of cumene
followed by cleavage with a catalyst. Annual production in the
United States is in excess of one million tons. Phenol is
generated during distillation of wood and the microbiological
decomposition of organic matter in the mammalian intestinal
tract.
Phenol is used as a disinfectant, in the manufacture of resins,
dyestuffs, and Pharmaceuticals, and in the photo processing
industry. In this discussion, phenol is the specific compound
that is separated by methylene chloride extraction of an acidi-
fied sample and identified and quantified by GC/MS. Phenol also
contributes to the "Total Phenols," discussed elsewhere, which
are determined by the 4-AAP colorimetric method.
Phenol exhibits acute and sub-acute toxicity in humans and
laboratory animals. Acute oral doses of phenol in humans cause
sudden collapse and unconsciousness by its action on the central
nervous system. Death occurs by respiratory arrest. Sub-acute
oral doses in mammals are rapidly absorbed then quickly distrib-
uted to various organs, then cleared from the body by urinary
excretion and metabolism. Long term exposure by drinking phenol
contaminated water has resulted in statistically significant
increase in reported cases of diarrhea, mouth sores, and burning
of the mouth. In laboratory animals, long term oral administra-
tion at low levels produced slight liver and kidney damage. No
reports were found regarding carcinogenicity of phenol adminis-
tered orally - all carcinogenicity studies were skin tests.
For the protection of human health from phenol ingested through
water and through contaminated aquatic organisms the concentra-
tion in water should not exceed 3.4 mg/1.
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Fish and other aquatic organisms demonstrated a wide range of
sensitivities to phenol concentration. However, acute toxicity
values were at moderate levels when compared to other organic
priority pollutants.
66-71. Phthalate Esters. Phthalic acid, or 1,2-benzenedicar-
boxylic acid,isoneof three isomeric benzenedicarboxylic acids
produced by the chemical industry. The other two isomeric forms
are called isophthalic and terephthalic acids. The formula for
all three acids is CgH^COOH^. Some esters of phthalic
acid are designated as toxic pollutants. They are discussed as a
group here and specific properties of individual phthalate esters
in PM&F process waters are then discussed.
Phthalic acid esters are manufactured in the United States at an
annual rate in excess of one billion pounds. They are used as
plasticizers - primarily in the production of polyvinyl chloride
(PVC) resins. The most widely used phthalate plasticizer is bis
(2-ethylhexyl) phthalate which accounts for nearly one-third of
the phthalate esters produced. This particular ester is commonly
referred to as dioctyl phthalate (DOP) and should not be confused
with one of the less used esters, di-n-octyl phthalate, which is
also used as a plasticizer. In addition to these two isomeric
dioctyl phthalates, four other esters, also used primarily as
plasticizers, are designated as toxic pollutants. They are:
butyl benzyl phthalate, di-n-butyl phthalate, diethyl phthalate,
and dimethyl phthalate.
Industrially, phthalate esters are prepared from phthalic anhy-
dride and the specific alcohol to form the ester. Some evidence
is available suggesting that phthalic acid esters also may be
synthesized by certain plant and animal tissues. The extent to
which this occurs in nature is not known.
Phthalate esters used as plasticizers can be present in concen-
trations up to 60 percent of the total weight of the plastic.
The plasticizer is not linked by primary chemical bonds to the
resin. Rather, it is locked into the structure of intermeshing
polymer molecules and held by van der Waals forces. The result
is that the plasticizer is easily extracted. Plasticizers are
responsible for the odor associated with new plastic toys or
flexible sheet that has been contained in a sealed package.
Although the phthalate esters are not soluble or are only very
slightly soluble in water, they do migrate into aqueous solutions
placed in contact with the plastic. Thus, industrial facilities
with tank linings, wire and cable coverings, tubing, and sheet
flooring of PVC are expected to discharge some phthalate esters
in their raw waste. In addition to their use as plasticizers,
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phthalate esters are used in lubricating oils and pesticide car-
riers. These also can contribute to industrial discharge of
phthalate esters.
From the accumulated data on acute toxicity in animals, phthal-
ate esters may be considered as having a rather low order of
toxicity. Human toxicity data are limited. The toxic effect of
the esters is most likely due to one of the metabolic products,
in particular the monoester. Oral acute toxicity in animals is
greater for the lower molecular weight esters than for the higher
molecular weight esters.
Orally administered phthalate esters generally produced enlarging
of liver and kidney and atrophy of testes in laboratory animals.
Specific esters produced enlargement of heart and brain, spleen-
itis, and degeneration of central nervous system tissue.
Subacute doses administered orally to laboratory animals produced
some decrease in growth and degeneration of the testes. Chronic
studies in animals showed similar effects to those found in acute
and subacute studies, but to a much lower degree. The same
organs were enlarged, but pathological changes were not usually
detected.
A recent study of several phthalic esters produced suggestive but
not conclusive evidence that dimethyl, diethyl, and bis(2-ethyl-
hexyl) phthalates have a cancer liability. Phthalate esters do
bioconcentrate in fish. The factors, weighted for relative con-
sumption of various aquatic and marine food groups, are used to
calculate ambient water quality criteria for phthalate esters.
The values are included in the discussion of the specific esters.
Studies of toxicity of phthalate esters in freshwater and salt
water organisms are scarce. A chronic toxicity test with bis(2-
ethylhexyl) phthalate showed that significant reproductive
impairment occurred at 0.003 mg/1 in the freshwater crustacean,
Daphnia magna. In acute toxicity studies, saltwater fish and
organismsshowed sensitivity differences of up to eight-fold to
butyl benzyl, diethyl, and dimethyl phthalates. This suggests
that each ester must be evaluated individually for toxic effects.
In addition to the general remarks and discussion on phthalate
esters, specific information on bis(2-ethylhexyl) phthalate,
di-n-butyl phthalate, and dimethyl phthalate is presented below.
66. Bis(2-ethylhexyl) phthalate. Little information is avail-
able about the physical properties of bis(2-ethylhexyl) phthal-
ate. It is a liquid boiling at 387°C at 5mm of mercury and is
insoluble in water. Its formula is CfcH^COOCgHi7)2-
This toxic pollutant constitutes about one-third of the phthalate
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ester production in the U.S. It is commonly referred to as
dioctyl phthalate, or DOP, in the plastics industry where it is
the most extensively used compound for the plasticization of
polyvinyl chloride (PVC).
Bis(2-ethylhexyl) phthalate has been shown to induce liver tumors
in both sexes of Fisher 344 rats and 6503?^ mice. The most
sensitive animals were the male B5C3F-| mice. Carcinogenic-
ity bioassays, conducted for the Carcinogenesis Testing Program,
National Cancer Institute (NCI)/National Toxicology Program,
showed that liver tumors were associated with the administration
of bis(2-ethylhexyl) phthalate (judged at least 99.5 percent pure
by thin layer chromatography) in both mice and rats of either
sex. In rats, the incidence of hepatocellular carcinomas and
neoplastic nodules of the liver were both significantly increased
(p=0.05) in females on the 12,000 ppm diet. Combining these two
categories led to a significant increase (p=0.01) in males at
12,000 ppm and in females at 6,000 (p=0.012) and 12,000 ppm
(p=0.001). Among mice, there was a statistically significant
increase in hepatocellular carcinomas in females at 3,000 ppm
(p=0.006) and in both sexes at -6,000 ppm (p=0.03). There was
also evidence of an increase in hepatocellular adenomas, although
not significant at p<0.05.
Two previous studies on Sherman rats fed diets containing 4,000
ppm DEHP and Wistar rats fed diets containing 5,000 ppm bis(2-
ethylhexyl) phthalate did not show any carcinogenic effects.
However, mortality was high in both studies and too few animals
were maintained longer than one year to permit conclusions
concerning near lifetime exposure.
For the maximum protection of human health from the potential
carcinogenic effects due to exposure of bis(2-ethylhexyl) phthal-
ate through ingestion of contaminated water and contaminated
aquatic organisms, the ambient water concentrations should be
zero based on the non-threshold assumption for this chemical.
However, zero level may not be attainable at the present time.
Therefore, levels are estimated that may result in incremental
increase of cancer risk over the lifetime of 10~5f 10~", and
10~7. The corresponding recommended criteria are 17.5 ug/1,
1.75 ug/1, and 0.175 ug/1, respectively. If the above estimates
are made for consumption of aquatic organisms only, excluding
consumption of water, the levels are 58.8 ug/1, 5.88 ug/1, and
0.588 ug/1, respectively.
68. Di-n-butyl Phthalate (DBP). DBP is a colorless, oily
liquid', boiling at 340"C. Its water solubility at room tempera-
ture is reported to be 0.4 g/1 and 4.5 g/1 in two different chem-
istry handbooks. The formula for DBP,
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is the same as for its isomer, di-isobutyl phthalate. DBF pro-
duction is one to two percent of total United States phthalate
ester production.
DBF is used to a limited extent as a plasticizer for polyvinyl
chloride (PVC). It is not approved for contact with food. It is
used in liquid lipsticks and as a diluent for polysulfide dental
impression materials. DBF is used as a plasticizer for nitrocel-
lulose in making gun powder and as a fuel in solid propellants
for rockets. Further uses are insecticides, safety glass
manufacture, textile lubricating agents, printing inks,
adhesives, paper coatings, and resin solvents.
For protection of human health from the toxic properties of DBF
ingested through water and through contaminated aquatic organ-
isms, the ambient water quality criterion is 34 mg/1. If
contaminated aquatic organisms alone are consumed, excluding the
consumption of water, the ambient water criterion is 154 mg/1.
71. Dimethyl Phthalate (DMP). DMP has the lowest molecular
weight of the phthalate esters - M.W. = 194 compared to M.W. of
391 for bis(2-ethylhexyl) phthalate. DMP has a boiling point of
282°C. It is a colorless liquid, soluble in water to the extent
of 5 mg/1. Its molecular formula is C^fi^(C)(CH3)2*
Dimethyl phthalate production in the United States is just under
one percent of total phthalate ester production. DMP is used to
some extent as a plasticizer in cellulosics; however, its prin-
cipal specific use is for dispersion of polyvinylidene fluoride
(PVDF). PVDF is resistant to most chemicals and finds use as
electrical insulation, chemical process equipment (particularly
pipe), and as a case for long-life finishes for exterior metal
siding. Coil coating techniques are used to apply PVDF
dispersions to aluminum or galvanized steel siding.
For the protection of human health from the toxic properties of
dimethyl phthalate ingested through water and through contami-
nated aquatic organisms, the ambient water criterion is 313 mg/1.
If contaminated aquatic organisms alone are consumed, excluding
the consumption of water, the ambient water criterion is 2,900
mg/1.
86. Toluene. Toluene is a clear, colorless liquid with a
benzene-like odor. It is a naturally occuring compound derived
primarily from petroleum or petrochemical processes. Some
toluene is obtained from the manufacture of metallurgical coke.
Toluene is also referred to as totuol, methylbenzene, methacide,
and phenylmethane. It is an aromatic hydrocarbon with the for-
mula C5H5CH3. It boils at 111°C and has a vapor pressure
of 30 mm Hg at room temperature. The water solubility of toluene
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is 535 mg/1 and it is miscible with a variety of organic sol-
vents. Annual production of toluene in the United States is
greater than two million metric tons. Approximately two-thirds
of the toluene is converted to benzene and the remaining 33
percent is used approximately equally for the manufacture of
chemicals and for use as a paint solvent and aviation gasoline
additive. An estimated 5,000 metric tons are discharged to the
environment annually as a constituent in wastewaters.
Most data on the effects of toluene in human and other mammals
are based on inhalation exposure or dermal contact studies. There
appear to be no reports of oral administration of toluene to
human subjects. A long term toxicity study on female rats
revealed no adverse effects on growth, mortality, appearance and
behavior, organ to body weight ratios, blood-urea nitrogen
levels, bone marrow counts, peripheral blood counts, or morphol-
ogy of major organs. The effects of inhaled toluene on the cen-
tral nervous system, both at high and low concentrations, have
been studied in humans and animals. However, ingested toluene is
expected to be handled differently by the body because it is
absorbed more slowly and must first pass through the liver before
reaching the nervous system. Toluene is extensively and rapidly
metabolized in the liver. One of the principal metabolic prod-
ucts of toluene is benzoic acid, which itself seems to have
little potential to produce tissue injury.
Toluene does not appear to be teratogenic in laboratory animals
or man. Nor is there any conclusive evidence that toluene is
mutagenic. Toluene has not been demonstrated to be positive in
any in vitro mutagenicity or carcinogenicity bioassay system or
to be carcinogenic in animals or man.
Toluene has been found in fish caught in harbor waters in the
vicinity of petroleum and petrochemical plants. Bioconcentration
studies have not been conducted, but bioconcentration factors
have been calculated on the basis of the octanol-water partition
coefficient.
For the protection of human health from the toxic properties of
toluene ingested through water and through contaminated aquatic
organisms, the ambient water criterion is 14.3 mg/1. If contami-
nated aquatic organisms alone are consumed excluding the consump-
tion of water, the ambient water criterion is 424 mg/1. Availa-
ble data show that the adverse effects on aquatic life occur at
concentrations as low as 5 mg/1.
Acute toxicity tests have been conducted with toluene and a vari-
ety of freshwater fish and Daphnia magna. The latter appears to
be significantly more resistant than fish. No test results have
been reported for the chronic effects of toluene on freshwater
fish or invertebrate species.
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87. Trichloroethylene. Trichloroethylene (1,1,2-trichloro-
ethyleneor TCE)Isaclear, colorless liquid boiling at 87°C.
It has a vapor pressure of 77 mm Hg at room temperature and is
slightly soluble in water (1 gm/1). United States production is
greater than 0.25 million metric tons annually. It is produced
from tetrachloroethane by treatment with lime in the presence of
water.
TCE is used for vapor phase degreasing of metal parts; cleaning
and drying electronic components, as a solvent for paints; as a
refrigerant; for extraction of oils, fats, and waxes; and for dry
cleaning. Its widespread use and relatively high volatility
result in detectable levels in many parts of the environment.
Data on the effects produced by ingested TCE are limited. Most
studies have been directed at inhalation exposure. Nervous sys-
tem disorders and liver damage are frequent results of inhalation
exposure. In the short term exposures, TCE acts as a central
nervous system depressant. It was used as an anesthetic before
its other long term effects were defined.
TCE has been shown to induce transformation in a highly sensitive
in vitro Fischer rat embryo cell system (F1706) that is used for
identifying carcinogens. Severe and persistent toxicity to the
liver was recently demonstrated when TCE was shown to produce
carcinoma of the liver in mouse strain B6C3F1. One systematic
study of TCE exposure and the incidence of human cancer was based
on 518 men exposed to TCE. The authors of that study concluded
that although the cancer risk to man cannot be ruled out, expo-
sure to low levels of TCE probably does not present a very seri-
ous and general cancer hazard.
TCE is bioconcentrated in aquatic species, making the consumption
of such species by humans a significant source of TCE. For the
protection of human health from the potential carcinogenic
effects of exposure to trichloroethylene through ingestion of
water and contaminated aquatic organisms, the ambient water con-
centration should be zero based on the non-threshold assumption
of this chemical. However, zero level may not be attainable at
the present time. Therefore, the levels that may result in
incremental increase of cancer risk over the lifetime are esti-
mated at 10~5, 10~6, and 10~7. The corresponding recom-
mended criteria are 0.027 mg/1, 0.0027 mg/1, and 0.00027 mg/1.
Only a very limited amount of data on the effects of TCE on
freshwater aquatic life are available. One species of fish (fat-
head minnows) showed a loss of equilibrium at concentrations
below those resulting in lethal effects.
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89. Aldrin. Aldrin is highly toxic by ingestion and inhalation
and is absorbed through the skin. It has been found to be car-
cinogenic to the liver of mice. For the protection of human
health against the carcinogenic properties of aldrin, EPA has
proposed a limit of 4.6 x 10~3 ng/1 at a risk factor of 10~6
for the ingestion of water and contaminated aquatic organisms.
Aldrin is banned from manufacture and use by EPA.
90. Dieldrin. Dieldrin is highly toxic by ingestion, inhala-
tion, and skin absorption. Dieldrin has been found to cause can-
cer in the liver of mice. Dieldrin is banned from manufacture
and use by EPA.
99. Endrin Aldehyde. Endrin aldehyde is likely to be present in
one pesticide process as a reaction by-product. It is toxic and
has no known commercial uses.
100. Heptachlor. Heptachlor is a nonsystemic stomach and con-
tact insecticide that has fumigant action. It is a soft waxy
solid with a melting range of 46 to 75°C and is practically
insoluble in water. Heptachlor is very toxic to mammals with an
acute oral LD50 of 100 mg/kg for male rats and an acute dermal
LD50 for male rats of 195 mg/kg. Heptachlor and its epoxide
bioaccumulate in fatty tissue and persist for lengthy periods of
time. Several uses of hepatachlor have been discontinued to
avoid contamination of milk and animal products. Heptachlor is a
suspected carcinogen. The total number of tumors in both male
and female rats increased in one long-term study after heptachlor
exposure. It has been recommended that human daily intake of
heptachlor should not exceed 0.005 mg/kg of body weight. A ban
was placed on heptachlor in Canada in 1969 because of concern for
residues in milk and deleterious effects on birds.
102. Alpha-BHC. Alpha-BHC is toxic by ingestion and skin
absorption; is an eye and skin irritant; and is a central nervous
system depressant.
103. Beta-BHC. Beta-BHC is moderately toxic by inhalation,
highly toxic by ingestion, and is a strong irritant by skin
absorption. It acts as a central nervous system depressant.
104. Gamma-BHC. Gamma-BHC, also known as lindane, is highly
toxic by ingestion and moderately toxic by inhalation.
105. Delta-BHC. Delta-BHC is moderately toxic by inhalation and
highly toxic by ingestion. It is a strong irritant to the skin
and eyes; is absorbed by the skin; and is a central nervous
system depressant.
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114. Antimony. Antimony (chemical name - stibium, symbol Sb) ,
classified as a non-metal or metalloid, is a silvery white, brit-
tle crystalline solid. Antimony is found in small ore bodies
throughout the world. Principal ores are oxides of mixed anti-
mony valences and an oxysulfide ore. Complex ores with metals
are important because the antimony is recovered as a by-product.
Antimony melts at 631°C and is a poor conductor of electricity
and heat.
Annual United States consumption of primary antimony ranges from
10,000 to 20,000 tons. About half is used in metal products,
mostly antimonial lead for lead acid storage batteries, and about
half in non-metal products. A principal compound is antimony
trioxide which is used as a flame retardant in fabrics and as an
opacifier in glass, ceramics, and enamels. Several antimony
compounds are used as catalysts in organic chemicals synthesis,
as fluorinating agents (the antimony fluoride), as pigments, and
in fireworks.
Essentially no information on antimony-induced human health
effects has been derived from community epidemiology studies.
The available data are in literature relating effects observed
with therapeutic or medicinal uses of antimony compounds and
industrial exposure studies. Large therapeutic doses of anti-
monial compounds, usually used to treat schistisomiasis, have
caused severe nausea, vomiting, convulsions, irregular heart
action, liver damage, and skin rashes. Studies of acute indus-
trial antimony poisoning have revealed loss of appetite, diar-
rhea, headache, and dizziness in addition to the symptoms found
in studies of therapeutic doses of antimony.
For the protection of human health from the toxic properties of
antimony ingested through water and through contaminated aquatic
organisms, the ambient water criterion is 0.146 mg/1. If contam-
inated aquatic organisms are consumed, excluding the consumption
of water, the ambient water criterion is 45 mg/1. Available data
show that adverse effects on aquatic life occur at concentrations
higher than those cited for human health risks.
115. Arsenic. Arsenic (chemical symbol As) is classified as a
non-metal or metalloid. Elemental arsenic normally exists in the
alpha-crystalline metallic form, which is steel gray and brittle,
and in the beta form, which is dark gray and amorphous. Arsenic
sublimes at 615°C. Arsenic is widely distributed throughout the
world in a large number of minerals. The most important commer-
cial source of arsenic is as a by-product from treatment of cop-
per, lead, cobalt, and gold ores. Arsenic is usually marketed as
the trioxide (AS203). Annual United States production of the
trioxide approaches 40,000 tons.
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The principal use of arsenic is in agricultural chemicals (herbi-
cides) for controlling weeds in cotton fields. Arsenicals have
various applications in medicinal and vetrinary use, as wood pre-
servatives, and in semiconductors.
The effects of arsenic in humans were known by the ancient Greeks
and Romans. The principal toxic effects are gastrointestinal
disturbances. Breakdown of red blood cells occurs. Symptoms of
acute poisoning include vomiting, diarrhea, abdominal pain, las-
situde, dizziness, and headache. Longer exposure produced dry,
falling hair, brittle, loose nails, eczema, and exfoliation.
Arsenicals also exhibit teratogenic and mutagenic effects in
humans. Oral administration of arsenic compounds has been asso-
ciated clinically with skin cancer for nearly one-hundred years.
Since 1888, numerous studies have linked occupational exposure
and therapeutic administration of arsenic compounds to increased
incidence of respiratory and skin cancer.
For the maximum protection of human health from the potential
carcinogenic effects of exposure to arsenic through ingestion of
water and contaminated aquatic organisms, the ambient water con-
centration is zero. Concentrations of arsenic estimated to
result in additional lifetime cancer risk levels of 10~7,
10-6, and 10'5 are 0.00000022 mg/1, 0.0000022 mg/1, and
0.000022 mg/1, respectively. If contaminated aquatic organisms
alone are consumed, excluding the consumption of water, the water
concentration should be less than 1.75 x 1Q~4 to keep the
increased lifetime cancer risk below 10~5. Available data show
that adverse effects on aquatic life occur at concentrations
higher than those cited for human health risks.
117. Beryllium. Beryllium is a dark gray metal of the alkaline
earth family. It is relatively rare, but because of its unique
properties finds widespread use as an alloying element, espe-
cially for hardening copper used in springs, electrical contacts,
and non-sparking tools. World production is reported to be in
the range of 250 tons annually. However, much more reaches the
environment as emissions from coal burning operations. Analysis
of coal indicates an average beryllium content of 3 ppm and 0.1
to 1.0 percent in coal ash or fly ash.
The principle ores are beryl (3BeO.Al203.68102) and
bertrandite [665810207(OH2)]. Only two industrial
facilities produce beryllium in the United States because of
limited demand and the highly toxic character. About two-thirds
of the annual production goes into alloys, 20 percent into heat
sinks, and 10 percent into beryllium oxide (BeO) ceramic
products.
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Beryllium has a specific gravity of 1.846, making it the lightest
metal with a high melting point (1,350°G). Beryllium alloys are
corrosion resistant, but the metal corrodes in aqueous environ-
ments. Most common beryllium compounds are soluble in water, at
least to the extent necessary to produce a toxic concentration of
beryllium ions.
Most data on toxicity of beryllium are for inhalation of beryl-
lium oxide dust. Some studies on orally administered beryllium
in laboratory animals have been reported. Despite the large num-
ber of studies implicating beryllium as a carcinogen, there is no
recorded instance of cancer being produced by ingestion. How-
ever, a recently convened panel of uninvolved experts concluded
that epidemiologic evidence suggests that beryllium is a
carcinogen in man.
In the aquatic environment, beryllium is chronically toxic to
aquatic organisms at 0.0053 mg/1. Water softness has a large
effect on beryllium toxicity to fish. In soft water, beryllium
is reportedly 100 times as toxic as in hard water.
For the maximum protection of human health from the potential
carcinogenic effects of exposure to beryllium through ingestion
of water and contaminated aquatic organisms, the ambient water
concentration is zero. Concentrations of beryllium estimated to
result in additional lifetime cancer risk levels of 10"?,
10~6, and TO'5 are 0.00000037 mg/1, 0.0000037 mg/1, and
0.000037 mg/1, respectively. If contaminated aquatic organisms
alone are consumed, excluding the consumption of water, the
concentration should be less than 0.00117 mg/1 to keep the
increased lifetime cancer risk below 10~5.
118. Cadmium. Cadmium is a relatively rare metallic element
that is seldom found in sufficient quantities in a pure state to
warrant mining or extraction from the earth's surface. It is
found in trace amounts of about one ppm throughout the earth's
crust. Cadmium is, however, a valuable by-product of zinc pro-
duction.
Cadmium is used primarily as an electroplated metal and is found
as an impurity in the secondary refining of zinc, lead, and
copper.
Cadmium is an extremely dangerous cumulative toxicant, causing
progressive chronic poisoning in mammals, fish, and probably
other organisms. The metal is not excreted.
Toxic effects of cadmium on man have been reported from through-
out the world. Cadmium may be a factor in the development of
such human pathological conditions as kidney disease, testicular
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tumors, hypertension, arteriosclerosis, growth inhibition,
chronic disease of old age, and cancer. Cadmium is normally
ingested by humans through food and water as well as by breathing
air contaminated by cadmium dust. Cadmium is cumulative in the
liver, kidney, pancreas, and thyroid of humans and other animals.
A severe bone and kidney syndrome known as itai-itai disease has
been documented in Japan as caused by cadmium ingestion via
drinking water and contaminated irrigation water. Ingestion of
as little as 0.6 mg/day has produced the disease. Cadmium acts
synergistically with other metals. Copper and zinc substantially
increase its toxicity.
Cadmium is concentrated by marine organisms, particularly
molluscs, that accumulate cadmium in calcareous tissues and in
the viscera. A concentration factor of 1,000 for cadmium in fish
muscle has been reported, as have concentration factors of 3,000
in marine plants and up to 29,600 in certain marine animals. The
eggs and larvae of fish are apparently more sensitive than adult
fish to poisoning by cadmium and crustaceans appear to be more
sensitive than fish eggs and larvae.
For the protection of human health from the toxic properties of
cadmium ingested through water and through contaminated aquatic
organisms, the ambient water criterion is 0.010 mg/1. Available
data show that adverse effects on aquatic life occur at concen-
trations in the same range as those cited for human health and
they are highly dependent on water hardness.
119. Chromium. Chromium is an elemental metal usually found as
a chromite (FeO.Cr2C>3). The metal is normally produced by
reducing the oxide with aluminum. A significant proportion of
the chromium used is in the form of compounds such as sodium
dichromate (Na2CrC>4) and chromic acid (CrC>3) , both are
hexavalent chromium compounds.
Chromium is found as an alloying component of many steels and its
compounds are used in electroplating baths and as corrosion
inhibitors for closed water circulation systems.
The two chromium forms most frequently found in industry waste-
waters are hexavalent and trivalent chromium. Hexavalent chro-
mium is the form used for metal treatments. Some of it is
reduced to trivalent chromium as part of the process reaction.
The raw wastewater containing both valence states is usually
treated first to reduce remaining hexavalent to trivalent chro-
mium and second to precipitate the trivalent form as the hydrox-
ide. The hexavalent form is not removed by lime treatment.
Chromium, in its various valence states, is hazardous to man. It
can produce lung tumors when inhaled and induces skin sensitiza-
tions. Large doses of chromates have corrosive effects on the
200
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intestinal tract and can cause inflammation of the kidneys.
Hexavalent chromium is a known human carcinogen. Levels of chro-
mate ions that show no effect in man appear to be so low as to
prohibit determination, to date.
The toxicity of chromium salts to fish and other aquatic life
varies widely with the species, temperature, pH, valence of the
chromium, and synergistic or antagonistic effects, especially the
effect of water hardness. Studies have shown that trivalent
chromium is more toxic to fish of some types than is hexavalent
chromium. Hexavalent chromium retards growth of one fish species
at 0.0002 mg/1. Fish food organisms and other lower forms of
aquatic life are extremely sensitive to chromium. Therefore,
both hexavalent and trivalent chromium must be considered harmful
to particular fish or organisms.
For the protection of human health from the toxic properties of
chromium (except hexavalent chromium) ingested through water and
contaminated aquatic organisms, the ambient water quality crite-
rion is 170 mg/1. If contaminated aquatic organisms alone are
consumed, excluding the consumption of water, the ambient water
criterion for trivalent chromium is 3,443 mg/1. The recommended
ambient water quality criterion for hexavalent chromium is
identical to the existing drinking water standard for total
chromium, which is 0.050 mg/1.
120. Copper. Copper is a metallic element that sometimes is
found free, as the native metal, and is also found in minerals
such as cuprite (Cu20), malechite [CuG03.Cu(OH)2], azurite
[2CuC03.Cu(OH)2], chalcopyrite (CuFeS2), and bornite
(Cu5FeS4). Copper is obtained from these ores by smelting,
leaching, and electrolysis. It is used in the plating, electri-
cal, plumbing, and heating equipment industries, as well as in
insecticides and fungicides.
Traces of copper are found in all forms of plant and animal life
and the metal is an essential trace element for nutrition.
Copper is not considered to be a cumulative systemic poison for
humans as it is readily excreted by the body, but it can cause
symptoms of gastroenteritis, with nausea and intestinal irrita-
tions, at relatively low dosages. The limiting factor in domes-
tic water supplies is taste. To prevent this adverse organolep-
tic effect of copper in water, a criterion of one mg/1 has been
established.
The toxicity of copper to aquatic organisms varies significantly,
not only with the species, but also with the physical and chemi-
cal characteristics of the water, including temperature, hard-
ness, turbidity, and carbon dioxide content. In hard water, the
toxicity of copper salts may be reduced by the precipitation of
201
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copper carbonate or other insoluble compounds. The sulfates of
copper and zinc and of copper and calcium are synergistic in
their toxic effect on fish.
Relatively high concentrations of copper may be tolerated by
adult fish for short periods of time; the critical effect of
copper appears to be its higher toxicity to young or juvenile
fish. Concentrations of 0.02 to 0.03 mg/1 have proved fatal to
some common fish species. In general, the salmonoids are very
sensitive and the sunfishes are less sensitive to copper.
The recommended criterion to protect freshwater aquatic life is
0.0056 mg/1 as a 24-hour average, and 0.012 mg/1 maximum concen-
tration at a hardness of 50 mg/1 CaCC>3. For total recoverable
copper, the criterion to protect freshwater aquatic life is
0.0056 mg/1 as a 24-hour average.
Copper salts cause undesirable color reactions in the food indus-
try and cause pitting when deposited on some other metals such as
aluminum and galvanized steel. To control undesirable taste and
odor quality of ambient water due to the organoleptic properties
of copper, the estimated level is one mg/1 for total recoverable
copper.
Irrigation water containing more than minute quantities of copper
can be detrimental to certain crops. Copper appears in all
soils; its concentration ranges from 10 to 80 ppm. In soils,
copper occurs in association with hydrous oxides of manganese and
iron and also as soluble and insoluble complexes with organic
matter. Copper is essential to the life of plants and the normal
range of concentration in plant tissue is from 5 to 20 ppm.
Copper concentrations in plants normally do not build up to high
levels when toxicity occurs. For example, the concentrations of
copper in snapbean leaves and pods was less than 50 and 20 mg/kg,
respectively, under conditions of severe copper toxicity. Even
under conditions of copper toxicity, most of the excess copper
accumulates in the roots; very little is moved to the aerial part
of the plant.
121. Cyanide. Cyanides are among the most toxic of pollutants
commonlyobserved in industrial wastewaters. Introduction of
cyanide into industrial processes is usually by dissolution of
potassium cyanide (KCN) or sodium cyanide (NaCN) in process
waters. However, hydrogen cyanide (HCN) formed when the above
salts are dissolved in water, is probably the most acutely lethal
compound.
The relationship of pH to hydrogen cyanide formation is very
important. As pH is lowered to below 7, more than 99 percent of
the cyanide is present as HCN and less than 1 percent as cyanide
202
-------
i. Thus, at neutral pH, the pH of most living organisms
i toxic form of cyanide prevails.
Cyanide ions combine with numerous heavy metal ions to form com-
plexes. The complexes are in equilibrium with HCN. Thus, the
stability of the metal-cyanide complex and the pH determine the
concentration of HCN. Stability of the metal-cyanide anion com-
plexes is extremely variable. Those formed with zinc, copper,
and cadmium are not stable. They rapidly dissociate, with pro-
duction of HCN, in near neutral or acid waters. Some of the com-
plexes are extremely stable. Cobaltocyanide is very resistant to
acid distillation in the laboratory. Iron cyanide complexes are
also stable, but undergo photodecomposition to give HCN upon
exposure to sunlight. Synergistic effects have been demonstrated
for the metal cyanide complexes making zinc, copper, and cadmium
cyanides more toxic than an equal concentration of sodium
cyanide.
The toxic mechanism of cyanide is essentially an inhibition of
oxygen metabolism (i.e., rendering the tissues incapable of
exchanging oxygen). The cyanogen compounds are true noncumula-
tive protoplasmic poisons. They arrest the activity of all forms
of animal life. Cyanide shows a very specific type of toxic
action. It inhibits the cytochrome oxidase system. This system
is the one that facilitates electron transfer from reduced metab-
olites to molecular oxygen. The human body can convert cyanide
to a non-toxic thiocyanate and eliminate it. However, if the
quantity of cyanide ingested is too great at one time, the
inhibition of oxygen utilization proves fatal before the detoxi-
fying reaction reduces the cyanide concentration to a safe level.
Cyanides are more toxic to fish than to lower forms of aquatic
organisms such as midge larvae, crustaceans, and mussels. Toxic-
ity to fish is a function of chemical form and concentration, and
is influenced by the rate of metabolism (temperature), the level
of dissolved oxygen, and pH. In laboratory studies, free cyanide
concentrations ranging from 0.05 to 0.14 mg/1 have been proven to
be fatal to sensitive fish species including trout, bluegill, and
fathead minnows. Levels above 0.2 mg/1 are rapidly fatal to most
fish species. Long term sublethal concentrations of cyanide as
low as 0.01 mg/1 have been shown to affect the ability of fish to
function normally (e.g., reproduce, grow, and swim).
For the protection of human health from the toxic properties of
cyanide ingested through water and through contaminated aquatic
organisms, the ambient water quality criterion is 0.200 mg/1.
Persistence of cyanide in water is highly variable and depends
upon the chemical form of cyanide in the water, the concentration
of cyanide, and the nature of other constituents. Cyanide may be
203
-------
destroyed by strong oxidizing agents such as permanganate and
chlorine. Chlorine is commonly used to oxidize strong cyanide
solutions. Carbon dioxide and nitrogen are the products of com-
plete oxidation. But if the reaction is not complete, the very
toxic compound, cyanogen chloride, may remain in the treatment
system and subsequently be released to the environment. Partial
chlorination may occur either as part of a POTW treatment or
during the disinfection treatment of. surface water for drinking
water preparation.
122. Lead. Lead is a soft, malleable, ductile, blueish-gray,
metallic element, usually obtained from the mineral galena (lead
sulfide, PbS), anglesite (lead sulfate, PbS04), or cerussite
(lead carbonate, PbC03). Because it is usually associated with
minerals of zinc, silver, copper, gold, cadmium, antimony, and
arsenic, special purification methods are frequently used before
and after extraction of the metal from the ore concentrate by
smelting.
Lead is widely used for its corrosion resistance, sound and
vibration absorption, low melting point (solders), and relatively
high imperviousness to various forms of radiation. Small amounts
of copper, antimony and other metals can be alloyed with lead to
achieve greater hardness, stiffness, or corrosion resistance than
is afforded by the pure metal. Lead compounds are used in glazes
and paints. About one third of United States lead consumption
goes into storage batteries. About half of United States lead
consumption is from secondary lead recovery. United States
consumption of lead is in the range of one million tons annually.
Lead ingested by humans produces a variety of toxic effects
including impaired reproductive ability, disturbances in blood
chemistry, neurological disorders, kidney damage, and adverse
cardiovas.cular effects. Exposure to lead in the diet results in
permanent increase in lead levels in the body. Most of the lead
entering the body eventually becomes localized in the bones where
it accumulates. Lead is a carcinogen or cocarcinogen in some
species of experimental animals. Lead is teratogenic in experi-
mental animals. Mutagenicity data are not available for lead.
The recommended ambient water quality criterion for lead is
identical to the existing drinking water standard for lead which
is 0.050 mg/1. Available data show that adverse effects on
aquatic life occur at concentrations as low as 7.5 x 10~^ mg/1
of total recoverable lead as a 24-hour average with a water
hardness of 50 mg/1 as CaCC>3.
123. Mercury. Mercury is an elemental metal rarely found in
nature as the free metal. Mercury is unique among metals as it
remains a liquid down to about 39 degrees below zero. It is
204
-------
relatively inert chemically and is insoluble in water. The prin-
cipal ore is cinnabar (HgS).
Mercury is used industrially as the metal and as mercurous and
mercuric salts and compounds. Mercury is used in several types
of batteries. Mercury released to the aqueous environment is
subject to biomethylation, conversion to the extremely toxic
methyl mercury.
Mercury can be introduced into the body through the skin and the
respiratory system as the elemental vapor. Mercuric salts are
highly toxic to humans and can be absorbed through the gastro-
intestinal tract. Fatal doses can vary from 1 to 30 grams.
Chronic toxicity of methyl mercury is evidenced primarily by
neurological symptoms. Some mercuric salts cause death by kidney
failure.
Mercuric salts are extremely toxic to fish and other aquatic
life. Mercuric chloride is more lethal than copper, hexavalent
chromium, zinc, nickel, and lead towards fish and aquatic life.
In the food cycle, algae containing mercury up to 100 times the
concentration in the surrounding sea water are eaten by fish that
further concentrate the mercury. Predators that eat the fish in
turn concentrate the mercury even further.
For the protection of human health from the toxic properties of
mercury ingested through water and through contaminated aquatic
organisms, the ambient water criterion is 0.00014 mg/1.
124. Nickel. Nickel is seldom found in nature as the pure ele-
mental metal. It is a relatively plentiful element and is widely
distributed throughout the earth's crust. It occurs in marine
organisms and is found in the oceans. The chief commercial ores
for nickel are pentlandite [(Fe,Ni)983], and a lateritic ore
consisting of hydrated nickel-iron-magnesium silicate.
Nickel has many and varied uses. It is used in alloys and as the
pure metal. Nickel salts are used for electroplating baths.
The toxicity of nickel to man is thought to be very low and sys-
temic poisoning of human beings by nickel or nickel salts is
almost unknown. In non-human mammals nickel acts to inhibit
insulin release, depress growth, and reduce cholesterol. A high
incidence of cancer of the lung and nose has been reported in
humans engaged in the refining of nickel.
Nickel salts can kill fish at very low concentrations. However,
nickel has been found to be less toxic to some fish than copper,
zinc, and iron. Nickel is present in coastal and open ocean
waters at concentrations in the range of 0.0001 to 0.006 mg/1
205
-------
although the most common values are 0.002 to 0.003 mg/1. Marine
animals contain up to 0.4 mg/1 and marine plants contain up to 3
mg/1. Higher nickel concentrations have been reported to cause
reduction in photosynthetic activity of the giant kelp. A low
concentration was found to kill oyster eggs.
For the protection of human health based on the toxic properties
of nickel ingested through water and through contaminated aquatic
organisms, the ambient water criterion is 0.0134 mg/1. If con-
taminated aquatic organisms are consumed, excluding consumption
of water, the ambient water criterion is 0.100 mg/1. Available
data show that adverse effects on aquatic life occur for total
recoverable nickel concentrations as low as 0.0071 mg/1 as a
24-hour average.
125. Selenium. Selenium (chemical symbol Se) is a non-metallic
element existing in several allotropic forms. Gray selenium,
which has a metallic appearance, is the stable form at ordinary
temperatures and melts at 220°C. Selenium is a major component
of 38 minerals and a minor component of 37 others found in
various parts of the world. Most selenium is obtained as a
by-product of precious metals recovery from electrolytic copper
refinery slimes. United States annual production at one time
reached one million pounds.
Principal uses of selenium are in semi-conductors, pigments,
decoloring of glass, zerography, and metallurgy. It also is used
to produce ruby glass used in signal lights. Several selenium
compounds are important oxidizing agents in the synthesis of
organic chemicals and drug products.
While results of some studies suggest that selenium may be an
essential element in human nutrition, the toxic effects of
selenium in humans are well established. Lassitude, loss of
hair, discoloration and loss of fingernails are symptoms of
selenium poisoning. In a fatal case of ingestion of a larger
dose of selenium acid, peripheral vascular collapse, pulmonary
edema, and coma occurred. Selenium produces mutagenic and tera-
togenic effects, but it has not been established as exhibiting
carcinogenic activity.
For the protection of human health from the toxic properties of
selenium ingested through water and through contaminated aquatic
organisms, the ambient water criterion is 0.010 mg/1 (i.e., the
same as the drinking water standard). Available data show that
adverse effects on aquatic life occur at concentrations higher
than that cited for human toxicity.
126. Silver. Silver is a soft, lustrous, white metal that is
insoluble in water and alkali. In nature, silver is found in the
206
-------
elemental state (native silver) and combined in ores such as
argentite (Ag2S), horn silver (AgCl), and procisite
(Ag3AsS3), and pyrangyrite (Ag3SbS3). Silver is used
extensively in several industries, among them electroplating.
Metallic silver is not considered to be toxic, but most of its
salts are toxic to a large number of organisms. Upon ingestion
by humans, many silver salts are absorbed in the circulatory sys-
tem and deposited in various body tissues, resulting in general-
ized or sometimes localized gray pigmentation of the skin and
mucous membranes known as argyria. There is no known method for
removing silver from the tissues once it is deposited and the
effect is cumulative.
Silver is recognized as a bactericide and doses from 0.000001 to
0.0005 mg/1 have been reported as sufficient to sterilize water.
The criterion for ambient water to protect human health from the
toxic properties of silver ingested through water and through
contaminated aquatic organisms is 0.050 mg/1.
The chronic toxic effects of silver on the aquatic environment
have not been given as much attention as many other heavy metals.
Data from existing literature support the fact that silver is
very toxic to aquatic organisms. Despite the fact that silver is
nearly the most toxic of the heavy metals, there are insufficient
data to adequately evaluate even the effects of hardness on
silver toxicity. There are no data available on the toxicity of
different forms of silver.
Bioaccumulation and concentration of silver from sewage sludge
has not been studied to any great degree. There is some indica-
tion that silver could be bioaccumulated in mushrooms to the
extent that there could be adverse physiological effects on
humans if they consumed large quantities of mushrooms grown in
silver enriched soil. The effect, however, would tend to be
unpleasant rather than fatal.
127. Thallium. Thallium is a soft, silver-white, dense,
malleable metal. Five major minerals contain 15 to 85 percent
thallium, but they are not of commercial importance because the
metal is produced in sufficient quantity as a by-product of
lead-zinc smelting of sulfide ores. Thallium melts at 304°C.
United States annual production of thallium and its compounds is
estimated to be 1,500 pounds.
Industrial uses of thallium include the manufacture of alloys,
electronic devices, and special glass. Thallium catalysts are
used for industrial organic syntheses.
207
-------
Acute thallium poisoning in humans has been widely described.
Gastrointestinal pains and diarrhea are followed by abnormal
sensation in the legs and arms, dizziness, and, later, loss of
hair. The central nervous system is also affected. Somnolence,
delerium or coma may occur. Studies on the teratogenicity of
thallium appear inconclusive; no studies on mutagenicity were
found; and no published reports on carcinogenicity of thallium
were found.
For the protection of human health from the toxic properties of
thallium ingested through water and contaminated aquatic
organisms, the ambient water criterion is 0.013 mg/1.
128. Zinc. Zinc occurs abundantly in the earth's crust, con-
centrated in ores. It is readily refined into the pure, stable,
silver-white metal. In addition to its use in alloys, zinc is
used as a protective coating on steel. It is applied by hot dip-
ing (i.e., dipping the steel in molten zinc) or by electroplat-
ing.
Zinc can have an adverse effect on man and animals at high con-
centrations. Zinc at concentrations in excess of five mg/1
causes an undesirable taste that persists after wastewater
treatment. For the prevention of adverse effects due to these
organoleptic properties of zinc, five mg/1 was adopted for the
ambient water criterion. Available data show that adverse
effects on aquatic life occur at concentrations as low as 0.047
mg/1 as a 24-hour average.
Toxic concentrations of zinc compounds cause adverse changes in
the morphology and physiology of fish. Lethal concentrations in
the range of 0.1 mg/1 have been reported. Acutely toxic concen-
trations induce cellular breakdown of the gills and possibly the
clogging of the gills with mucous. Chronically toxic concentra-
tions of zinc compounds cause general enfeeblement and widespread
histological changes to many organs, but not to gills. Abnormal
swimming behavior has been reported at 0.04 mg/1. Growth and
maturation are retarded by zinc. Effects of zinc poisoning may
not become apparent immediately, so that fish removed from
zinc-contaminated water may die as long as 48 hours after
removal.
In general, salmonoids are most sensitive to elemental zinc in
soft water; the rainbow trout is the most sensitive in hard
waters. A complex relationship exists between zinc concentra-
tion, dissolved zinc concentration, pH, temperature, and calcium
and magnesium concentration. Prediction of harmful effects has
been less than reliable and controlled studies have not been
extensively documented.
208
-------
The major concern with zinc compounds in marine waters is not
with acute lethal effects, but rather with the long-term sub-
lethal effects of the metallic compounds and complexes. Zinc
accumulates in some marine species; marine animals contain zinc
in the range of 6 to 1,500 mg/kg. From the point of view of
acute lethal effects, invertebrate marine animals seem to be the
most sensitive organism tested.
MASS OF POLLUTANTS
Pollutant average concentrations in the PM&F process waters were
presented for the PM&F subcategories in Table VI-19. Of equal
importance is the mass of pollutants in the process waters.
Estimated pollutant masses generated per year are presented in
this section.
Pollutant masses were estimated with a statistical methodology
that combines information from both the sampling episodes and the
questionnaire data base. This methodology is illustrated below.
Refer to Table VII-11 for sampling data used in this example.
The questionnaire survey data used in the example are presented
in Table VII-12.
1. The example has two extrusion processes and one molding
process in the contact cooling and heating water
subcategory.
2. Calculate the average mass of pollutant discharged for
each process. Use the water usage flow rates and the
concentrations measured on the sampling days (see Table
VII-11).
Process Average Mass of Pollutant (mg/hr)
EX-1 (10 mg/l)(100 l/hr) + (30 mg/l)(140 l/hr) + (15 mg/l)(10Q 1/hr)
3
= 2,230 mg/hr
EX-2 (:>0 mg/l)(300 1/hr) + (10 mg/l)(400 1/hr) = 9,500 mg/hr
MD-1 (100 mg/l)(50 l/hr)+(110 mg/l)(60 l/hr)+(120 mg/l)(60 1/hr)
3
= 6,270 mg/hr
209
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3. For the processes that belong to a type of process, sum
the average mass of pollutants (calculated in step 2).
Type of Process
Extrusion
Molding
Summed Average Mass (mg/hr)
2,230 mg/hr + 9,500 mg/hr = 11,730 mg/hr
6,270 mg/hr
4. For each process, calculate an average plastic produc-
tion rate with measurements taken on the sampling day
(see Table VII-11).
Process
EX-1
EX-2
MD-1
Average Plastic Production Rate (kg/hr)
50+100+50 « 67 kg/hr
1,000+900
2
- 950 kg/hr
100+130+130 = 12o kg/hr
5. For the processes that belong to a type of process, sum
the average plastic production rates calculated in step
4.
Type of Process
Extrusion
Molding
Summed Average Plastic
Production Rate (kg/hr)
67 kg/hr + 950 kg/hr = 1,117 kg/hr
120 kg/hr
For each type of process, divide the summed average
pollutant mass (calculated in step 3) by the summed
average plastic production rate (calculated in step 5)
to calculate a pollutant mass per unit of production.
Type of Process
Extrusion
Molding
Pollutant Mass Per Unit of
Production
(mg Pollutant/kg Plastic)
11 ,730 mg/hr = 10.5
1,117 kg/hr
6,270 mg/hr = 52.3
120 kg/hr
kg
212
-------
7. For each type of process, multiply the pollutant mass
per unit of production (calculated in step 6) by the
estimated number of processes and by the average plastic
production from the questionnaire data base. This cal-
culation estimates the pollutant mass for each type of
process in the subcategory. The questionnaire data are
presented in Table VII-12 for the different types of
processes for both direct and indirect dischargers.
This example calculation estimates the direct discharge
pollutant mass. An analogous calculation for the
indirect discharge pollutant mass uses the values for
indirect dischargers presented in Table VII-12.
Estimated Direct Discharge
Type of Process Pollutant Mass (kg/yr)
Extrusion (10.5 mg/kg)(631 processes)(6,740 kkg/yr/process)
= 44,700 kg/yr
Molding (52.3 mg/kg)(30 processes)(1,490 kkg/yr/process)
= 2,340 kg/yr
8. In the contact cooling and heating water subcategory, an
estimate of the pollutant mass per unit of production
for the types of processes that have no sampling data
was also calculated. This was calculated by summing the
estimated pollutant masses (calculated in step 7) and
then dividing by the sum of questionnaire survey factors
used in the pollutant mass estimate. For example,
combining the extrusion and molding results from step 7
gives the following:
44,700 kg/yr + 2,340 kg/yr
[(631 processes)(6,740 kkg/yr/process)
+ (30 processes)(1,490 kkg/yr/process)]
= 0.011 kg pollutant
kkg plastic
This pollutant mass per unit of production is an
estimate to use for the types of processes that have no
sampling data (i.e., casting, calendering, coating and
laminating, and thermoforming).
To estimate the pollutant mass discharged for the type
of processes that have no available sampling data,
multiply the pollutant mass per unit of production
(calculated in step 8) by the appropriate factors in
Table VII-12.
213
-------
Type of Process
Calendering
Casting
Coating &
Laminating
Estimated Direct Discharge
Pollutant Mass (kg/yr)
(0.011 kg/kkg)(5 processes)(1,980 kkg/yr/process)
= 109 kg/yr
(0.011 kg/kkg)(5 processes)(7,300 kkg/yr/process)
= 402 kg/yr
(0.011 kg/kkg)(10 processes)(293 kkg/yr/process)
= 32 kg/yr
Thermoforming (0.011 kg/kkg)(15 processes)(2,060 kkg/yr/process)
= 340 kg/yr
10. Sum the estimated pollutant masses for both sampled and
unsampled types of processes (calculated in steps 7 and
9), to obtain an estimate of the total direct discharge
pollutant mass for the subcategory.
Type of Process
Extrusion
Molding
Calendering
Casting
Coating & Laminating
Thermoforming
Estimated Direct Discharge
Pollutant Mass (kg/yr)
44,700
2,340
109
402
32
340
TOTAL
47,923 kg/yr
of Pollutant X
This calculation procedure is more simplified for the cleaning
water subcategory and for the finishing water subcategory because
these subcategories have only one type of process (i.e., cleaning
or finishing processes). Calculation steps one through seven
need only be performed for these subcategories.
This methodology was used to estimate the mass of pollutants
discharged by direct and indirect dischargers in the three PM&F
subcategories. Those estimates are presented in Table VII-13.
Masses were estimated for the conventional and nonconventional
pollutants in all three subcategories, even though not all of
these pollutants were found in treatable concentrations for each
subcategory. This was done to examine the total pollutant mass
in the subcategories. Masses for the priority pollutants were
calculated for the pollutants in Table VI1-8. This was also done
to evaluate the priority pollutant mass discharged by the
industry.
214
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SECTION VIII
WASTEWATER CONTROL AND TREATMENT TECHNOLOGIES
INTRODUCTION
This section discusses the control and treatment technologies
considered in this final rulemaking for the control of pollutants
in process waters generated by PM&F processes. These control and
treatment technologies are unit processes that are used to
develop model treatment technology options. The specific model
technology options considered for BPT, BAT, NSPS, and PSES/PSNS
are discussed in Sections X, XI, XII, and XIII, respectively.
Prior to publication of the proposed PM&F regulation, EPA consid-
ered a wide range of in-process control and end-of-pipe treatment
technologies. These technologies are discussed in detail in the
preamble to the proposed PM&F regulation (see 49 FR 5862) and in
the technical development document supporting the proposed PM&F
regulation. Additional information obtained subsequent to the
proposal to evaluate comments and data submitted by commenters on
the proposed regulation and revisions in EPA's data averaging
methodology (see Section VI of this document) led to changes in
technologies considered in developing model treatment technology
options for the final PM&F regulation. Based on their applica-
bility to PM&F process waters and general technical feasibility,
the following control and treatment technologies, which are
divided into in-plant control technologies and end-of-pipe treat-
ment technologies, were considered for the final PM&F regulation:
o In-plant control technologies
--Process water recycle
--In-process measures
o End-of-pipe treatment technologies
--Settling
--pH adjustment
--Activated sludge
--Activated carbon adsorption
--Filtration (suspended solids removal)
--Vacuum filtration (sludge dewatering)
The remainder of this section describes each of these technolo-
gies. In particular, the following topics are discussed, where
applicable, for each technology:
221
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o Process description,
o Applications,
o Technology status,
o Limitations,
o Reliability,
o Environmental impact, and
o Treatability data.
The primary literature sources relied on during the development
of this section were EPA's Treatability Manual, Volume III, Tech-
nologies for Control/Removal of Pollutants andEPA's Innovative
and Alternative Technology Assessment Manual. Metcalf and Eddy,
Inc.'s Wastewater Engineering, Treatment/Disposal/Reuse served as
a general reference. Refer to Section XVI for reference details.
IN-PLANT CONTROL TECHNOLOGY
The purpose of in-plant control technology for plants in the
plastics molding and forming category is to reduce or eliminate
the amount of process water requiring end-of-pipe treatment and
thereby either reduce the size of the treatment technology or
eliminate the need for the treatment'technology. In-plant tech-
nologies considered for the PM&F category are: (1) process water
recycle; and (2) in-process measures.
Process Water Recycle
Recycling of process water is the practice of recirculating water
to be used again for the same purpose or process. Water recycle
is distinguished from water reuse, which is the recirculation of
process water to be used again for a different purpose or pro-
cess. An example of water recycle would be to use rinse water
more than once in the same rinsing operation; whereas in water
reuse, the rinse water would be used again, but in a different
operation. Both practices result in a reduction in the amount of
process water discharged.
Applications. Two types of recycle are possible - recycle with
no discharge (100 percent recycle) and recycle with a discharge
(or bleed stream). One hundred percent recycle may be prohibited
by the presence of dissolved solids in the process water (e.g.,
sulfates and chlorides). These dissolved solids precipitate if
their solubility limits are exceeded and form scale on pipes and
equipment. A bleed stream, either continuous or periodic, is
necessary to prevent maintenance problems that would be created
by the precipitation of dissolved solids. One hundred percent
recycle is generally applicable to low flow rate processes and to
process waters with low pollutant concentrations.
222
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Process water that requires cooling is recycled through a unit
that lowers the temperature of the water so that it can be recy-
cled. Two types of equipment may be used for 100 percent recycle
of process water that needs to be cooled. The first and simplest
piece of equipment is a holding tank. Process water is held up
in a tank until the temperature drops sufficiently, through pas-
sive heat transfer to the environment, to allow the water to be
recycled. A holding tank is only practical for low flow rates
because tank sizes increase dramatically when the flow rate
increases. One hundred percent recycle of process waters that
needs to be cooled may also be achieved using chillers, which
cool the water by mechanical refrigeration. In a chiller, the
cooling water is passed through a heat exchanger that is cooled
by a low boiling, vaporized refrigerant. Chillers can be used
with processes with medium flow rates because they can be pur-
chased as self-contained units that are easy to install. At
higher flow rates, the chiller's high energy usage per unit of
cooling makes its use less attractive. Recycle systems such as
cooling tanks or chiller units are generally cleaned out once
every one or two years and thus potentially may require the
disposal of some amount of waste.
Recycle with a discharge is generally practiced for processes
with high flow rates. Process waters from those processes that
need to be cooled can be recycled through cooling towers that
lower the water temperature by evaporative cooling. In a typical
cooling tower configuration, water is distributed at the top of
the tower in a manner that provides a large contact area between
air and water. Air circulates countercurrently to the water to
be cooled. Heat is transferred from the water to the air as
water evaporates. Cooling towers can be used with processes with
flow rates from as low as 15 gpm to several hundred gpm.
One hundred percent recycle of process water through cooling tow-
ers is prohibited because the concentration of dissolved solids
in the process waters may cause scale to form on the cooling
tower. A bleed stream is needed to reduce the concentration of
these solids below the concentration where they would precipitate
and cause pipe plugging and scaling on the cooling tower.
Process water that requires the removal of solids and oil and
grease before it can be used again in the process can be recycled
through a settling tank. Generally, process water that requires
removal of suspended solids and oil and grease has to be replaced
after a period of time. jThis can be done either by replacing the
small continuous discharge flow from the unit with fresh water or
by periodically changing all of the process water within the
recycle unit.
223
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Technology Status. Process water recycle is currently practiced
By 57f percent o~F the wet processes in the contact cooling and
heating water subcategory, 13 percent of wet processes in the
cleaning water subcategory, and 18 percent of wet processes in
the finishing water subcategory. When recycle was reported, the
recycle percentage generally ranged from 90 to 100 percent.
Table VIII-1 contains a distribution of the number of processes
with various recycle percentages by PM&F subcategory based on
data from the questionnaire data base.
Limitations. A potential limitation of 100 percent recycle of
process water is the buildup of dissolved solids. The presence
of dissolved solids may result in scale formation on piping and
equipment and may also affect product quality. Dissolved solids
levels can be controlled in cases where a bleed stream is dis-
charged by increasing the bleed flow. For recycle systems that
include settling, solids removed from the settling unit require
disposal. Small quantities of scale and settled solids also have
to be periodically removed from recycle units with a discharge.
The percent of process water that can be recycled depends on
product quality. In some cases, process water may not be
recycled because product quality requires that only "potable"
water be used in the process.
Reliability. Recycle units have few components with moving
parts; most of the routine maintenance is needed to service the
recirculating pump.
Environmental Impact. Recycle is an important water conservation
measure because both the demand for raw water and the amount of
water discharged are reduced when process water is recycled. A
reduction in the amount of process water that requires treatment
results in a reduction in the required treatment unit capacity
and, therefore, the cost of end-of-pipe treatment. In addition,
the performance of the treatment process, in terms of percent
removal, may be improved when recycle is used because pollutants
in the recycle unit discharge are more concentrated. Generally,
end-of-pipe treatment perform more effectively with higher
pollutant concentrations.
In-Process Measures
Two opportunities exist for plants to reduce the quantity of
water used by PM&F processes. One is to decrease the quantity of
water that flows through the process; the other is to modify the
process so that the use of process water is no longer necessary.
224
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Applications. The Agency believes that, based on observations
made during plant visits, some PM&F plants may not pay close
attention to water use. Satisfactory operation may be achieved
with smaller rinse or contact cooling water flows. The practice
of shutting off process water during periods when a production
unit is inoperative and adjusting flow rates during periods of
low activity can reduce the volume of water to be treated or
discharged. Producers with a high water use should be able to
reduce their water use through simple flow reduction procedures
such as more careful adjustment of process water flow rates and
reduction of overflow and dragout from quench tanks.
The Agency considered process modifications for reducing process
water use because approximately 80 percent of the processes in
the PM&F category do not require the use of process water. The
possibility of eliminating the use of process water by the other
20 percent of PM&F processes that use process water, was studied.
Investigation into the specific uses of process water revealed
that the 20 percent of manufacturers who are using process water
need that water for efficient and effective operation of their
processes. The majority of PM&F process water is contact cooling
water used during extrusion processes. This water is necessary
for effective heat transfer, particularly during pelletizing pro-
cesses and for the extrusion of tube, pipe, profiles, or plastic
coverings on wire and cable. Process water is also needed for
contact cooling during other molding and forming process to
maintain product integrity. It is also needed to clean both the
surfaces of the plastic products and surfaces of shaping equip-
ment used to produce those products and to finish plastic prod-
ucts. Water is required in cleaning processes and in finishing
processes as a carrier media. PM&F processes that use process
water need the water for effective operation of the process; they
cannot be converted to dry processes. Therefore, process modifi-
cations to eliminate the use of process water are not appropriate
for wet PM&F processes.
END-OF-PIPE TREATMENT TECHNOLOGY
This section discusses end-of-pipe treatment technologies appli-
cable to treatment of process waters discharged by PM&F proces-
ses. End-of-pipe treatment technologies are used to reduce the
concentrations of pollutants in process waters. The end-of-pipe
treatment technologies that were considered will treat either
some or all of the pollutants listed in Table VIII-2.
Settling
Settling is a process that removes solid particles from a liquid
matrix by gravitational force. This is done by reducing the
velocity of the influent flow so that gravitation settling can
226
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Table VIII-2
POLLUTANTS AND POLLUTANT PROPERTIES FOUND IN TREATABLE
CONCENTRATIONS IN PM&F PROCESS WATERS
Conventional Pollutants
BOD5
Oil and Grease
TSS
pH
Nonconventional Pollutants
COD
TOG
Total Phenols
Priority Pollutants
65. phenol
66. bis(2-ethylhexyl) phthalate
68. di-n-butyl phthalate
71. dimethyl phthalate
128. zinc
227
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occur. Simple settling requires long retention times to achieve
high removal efficiencies. Settling tanks can be designed with
baffles to eliminate the turbulence caused by influent water and
have sloping bottoms to aid in sludge collection. Settling tanks
are often designed so that oil and grease separation also occurs.
Oil and grease and other floatable materials can be removed by
surface skimming.
Applications. Settling can be effectively used to treat waste-
water with high concentrations of oil and grease and suspended
solids. Toxic metals removals have also been achieved in
settling tanks.
Technology Status. Settling has been effectively demonstrated in
the treatment of numerous industrial wastewaters. It is one of
the oldest wastewater treatment technologies in use. Eleven
plants in the questionnaire data base for the PM&F category have
settling/clarification units in place to treat PM&F process
waters.
Limitations. Excessively long retention times may be required
under certain conditions, particularly when the specific gravity
of suspended particles is close to one or the particle sizes are
small. Colloidal particles with diameters less than one micron
may not be effectively settled without the addition of a floccu-
lant or coagulating agent. Additionally, dissolved pollutants
are not removed by settling.
Reliability. The lack of mechanical complexity makes this tech-
nology very reliable.
Environmental Impact. The major environmental impact associated
with settling is the disposal of the solid material removed from
the wastewater.
Treatability Data. Mean removal efficiencies for conventional
and selected nonconventional pollutants in a settling unit are
presented in Table VIII-3.
pH Adjustment
pH adjustment is the process of adjusting an acidic or a basic
wastewater to a pH of an acceptable value. Adjusting the pH of
the wastewater is necessary for various reasons. The pH should
be adjusted to: (1) prevent metal corrosion and/or damage to
equipment and structures; (2) protect aquatic life and human
health; (3) ensure effective operation of a treatment process;
and (4) provide neutral" pH water for recycle. pH adjustment may
also be needed to break emulsions, to insolubilize certain
228
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Table VIII-3
REMOVAL EFFICIENCIES FOR CONVENTIONAL AND SELECTED
NONCONVENTIONAL POLLUTANTS IN A SETTLING TANK
Mean Removal
Pollutant Efficiency (%)
BODS 33
Oil and Grease 47
TSS 82
COD 71
TOC 40
Total Phenols 43
Source: Treatability Manual. Volume III, Technologies for
Control/Removal of Pollutants, July 1980,
EPA 600/8-80-042c.
229
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chemical species, or to control chemical reaction rates (e.g.,
chlorination). Generally, the pH of a wastewater should be
between 6.0 and 9.0.
The actual process of adjustment to a neutral pH is accomplished
by the addition of a basic material to an acidic material or by
adding an acid to an alkaline material. Addition of the neutral-
ization agent must be carefully controlled to avoid large temper-
ature increases due to the exothermic nature of most acid-base
neutralization reactions. Neutralization chemicals can be added
manually or automatically to a mixed tank. Continuous pH moni-
toring is usually included in an automatic chemical addition
system.
Applications. This technology is widely applied in the treatment
of wastewaters.
Technology Status. pH adjustment is widely used in industrial
waste treatment. Seven PM&F plants that treat process waters
from primarily PM&F processes reported that they adjusted the pH
of their process waters (see Table VI-4).
Limitations. The pH adjustment rate may be limited by heat
effects accompanying the neutralization reaction. In most cases,
proper planning of the neutralization process with respect to
concentration of the neutralizing agent, rate of addition, reac-
tion time, and equipment design can alleviate the heat problem.
Reliability. The pH adjustment process is highly reliable if
properly monitored.
Environmental Impact. The environmental impacts associated with
pH adjustment are, in general, minor. However, pH adjustment may
result in precipitation of dissolved pollutants in certain waste-
waters. These precipitated solids may eventually settle and
require disposal. In addition, when acids are added to waste-
waters containing certain salts, such as sulfide, toxic gases may
be produced.
Activated Sludge
The activated sludge process is an aerobic (i.e., in the presence
of oxygen) decomposition process in which organic material is
oxidized by microorganisms. These microorganisms utilize organic
pollutants as a source of food and convert them into carbon diox-
ide, water, energy, and cellular material, which may be removed
by liquid-solids separation. Activated sludge treatment is dis-
tinguished from other types of biological treatment by the return
of settled microorganisms (i.e., the acidvated sludge) to contact
with incoming wastewater. The activated sludge process is used
230
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to remove dissolved and colloidal biodegradable organic pollu-
tants from wastewater.
A flow diagram of a conventional activated sludge process is pre-
sented in Figure VIII-1. There are two basic unit operations
involved: (1) contacting of the influent wastewater and micro-
organisms in the presence of oxygen, and subsequently, (2) sepa-
ration of the liquid/solids mixture that forms. The activated
sludge process was developed as a continuous flow process because
of the underlying concept of recycling activated sludge. In the
first step, or the contacting phase, the microorganisms oxidize
soluble and colloidal organic pollutants to carbon dioxide and
water in the presence of molecular oxygen. The intimate contact
required between the wastewater and microorganisms is achieved by
mixing and turbulence induced by aeration. The mixture of micro-
organisms and wastewater (called mixed liquor) formed in the
contactor or aeration basin is transferred to a gravity settling
unit for liquid/solids separation. A large portion of the micro-
organisms that settle in the settling unit is recycled to the
contactor to be mixed with incoming wastewater; the remaining
excess sludge is transferred to sludge handling processes.
The mechanism of aerobic decomposition in the activated sludge
process can be expressed as:
Microorganisms
Organic Material + 02 + Nutrients ^. C0£
+ H20 + Energy + Microorganisms
Two separate phases actually occur in parallel; one is the syn-
thesis of organic materials into new microorganism cells in the
presence of nutrients, and the other is the oxidation of organic
material to C02, H20, and energy in the presence of oxygen
and microorganisms. Two primary nutrients are required for the
formation of new cells in the former reaction; these are nitrogen
and phosphorus. Most wastewaters contain sufficient quantities
of nutrients; however, nutrients have to be added where this is
not the case.
Oxygen is required in this process to support the oxidation and
synthesis reactions. Various aeration methods are employed to
transfer oxygen to wastewater. They include mechanical aeration
and diffused aeration.
Mechanical Aeration. Mechanical aeration methods include a sub-
merged turbine with compressed air spargers (agitator/sparger
system) and surface mechanical entrainment aerators. The
agitator/sparger system consists of a radial-flow turbine located
below the mid-depth of the basin with compressed air supplied to
the turbine through a sparger. The surface-type aerators entrain
231
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Flow Diagram, Conventional Activated Sludge Process
Primary Settling Unit Effluent
Aeration Tank
To Final Settling Unit
Return Sludge
Sludge from Final Settling Unit
Excess Sludge
Mechanical Surface Aeration
Driv
Diffused Aeration
.—, Compressor
Sparger
Figure VIII-1
ACTIVATED SLUDGE TREATMENT PROCESS
Figures adapted from Innovative and Alternative Technology
Assessment Manual, EPA 430/9-78-009.
23 2
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atmospheric air by producing a region of intense turbulence at
the water surface. They are designed to pump large quantities of
liquid, thus dispersing the entrained air and agitating and
mixing the basin contents. Figure VII1-1 contains a schematic
diagram of a mechanical surface aeration unit.
Diffused Aeration. In a diffused air system, compressors are
used to supply air to a diffusion network. Diffused air systems
may be classified as fine bubble or coarse bubble. Diffusers
commonly used in the activated sludge process include porous
ceramic plates laid in the basin bottom (fine bubble), porous
ceramic domes or ceramic or plastic tubes connected to a pipe
header and lateral system (fine bubble), tubes covered with
synthetic fabric or wound filaments (fine or coarse bubble), and
specifically designed spargers with multiple openings (coarse
bubble). A diffused aeration sparger system is also depicted in
Figure VIII-1.
Two modifications to the activated sludge process are pure oxygen
and extended aeration:
Pure Oxygen. The use of pure oxygen for activated sludge treat-
ment has become competitive with the use of air due to the devel-
opment of efficient oxygen dissolution systems. The benefits of
substituting pure oxygen for air include reduced power require-
ments for dissolving oxygen in the wastewater, reduced aeration
tank volume, and improved biokinetics of the activated sludge.
Lower amounts of excess sludge are generated; the thickening
capability of pure oxygen activated sludge is generally greater
than the thickening capability of the air activated sludge.
Extended Aeration. Extended aeration is a modification of the
activated sludge process in which the fundamental idea is to
minimize the amount of excess sludge, which represents a disposal
problem. Extended aeration is distinguished from the conven-
tional activated sludge process by longer retention times, lower
food to microorganism ratios, higher oxygen consumptions, and
higher concentration of microorganisms in the contactor. All of
these factors lead to a decrease in the amount of sludge that has
to be disposed of.
Excess sludge is formed in the activated sludge process because
there is a net increase in the microoganism formation. However,
there is an additional reaction that occurs in extended aeration
in which the new microorganism cells undergo self-oxidation
because sufficient time is allowed for further completion of the
oxidation process. In the self-oxidation step, the microorgan-
isms consume their own cell material for energy (a step also
referred to as endogenous respiration). However, there is always
a portion of the sludge that is non-biodegradable.
233
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The extended aeration process is generally applicable to rela-
tively small wastewater flows for which the additional retention
time (and aeration basin volume) is less costly compared to costs
of the aeration basin volume for larger flows. The application
of extended aeration for small flows is usually accomplished with
package treatment plants. There are a variety of proprietary
extended aeration package plants available on the market today.
A typical design features three chambers. The influent enters
the first chamber where scum and sludge are separated. The
second chamber is where the aeration occurs. The third and final
compartment is a settling chamber where sludge settles by gravity
and is returned to the aeration portion of the unit. Figure
VIII-2 presents a diagram of an extended aeration activated
sludge package plant.
Applications. The activated sludge process is employed in domes-
ticandindustrial wastewater treatment for the removal of con-
ventional, nonconventional, and priority organic pollutants.
Limited priority pollutant metals removal has also been observed
in activated sludge processes. Activated sludge processes can be
used to treat PM&F process waters to remove dissolved organic
pollutants found in treatable concentrations (see Table VIII-2).
Industrial wastewater that is amenable to biological treatment
and degradation may be jointly treated with domestic wastewater
in an activated sludge process.
Technology Status. Activated sludge has not been demonstrated
for the treatment of process waters generated solely by PM&F
processes. However, it is a widely demonstrated, effective
biological treatment process that has been used to treat waste-
waters with conventional pollutant characteristics similar to the
conventional pollutant characteristics of PM&F process waters.
Limitations/Reliability. Activated sludge treatment processes
can be upset with variations in hydraulic and organic loads. For
example, shock loads of phenolic compounds will kill the micro-
organisms that oxidize the organic materials and make the activ-
ated sludge process work. Under steady state conditions, phenols
can be treated in concentrations up to 500 mg/1 (Metcalf & Eddy,
Inc.). Activated sludge processes are also not designed for an
intermittent wastewater flow. Other disadvantages are high
operating costs, operational complexity, and energy consumption.
The activated sludge process must be well maintained for it to
work properly.
Environmental Impact. The activated sludge process requires
properdisposalof"sludge to avoid solid waste pollution prob-
lems. Excess sludge generation is generally in the range of 0.15
to 0.7 pound per pound BOD5 removed (EPA Treatability Manual).
Energy requirements are approximately 200 kwh/yr per 1,000 gpd
234
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Batch - Extended Aeration
Blower
Influent
High Water
Alarm
Pump Shut-off
Elevation
-0
« I
« /'\
.Effluent
Diffuser
Pump
Flow-Through Extended Aeration
Influent
Mechanical or
Diffused Aeration
f / / ••••—•
/^Sludge
v/ ////////
Effluent
Settling
Chamber
Sludge
Figure Vlll-2
EXTENDED AERATION ACTIVATED SLUDGE PACKAGE PLANTS
235
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treated (Innovative and Alternative Technology Assessment
Manual). Improperly operated systems can cause odor problems.
Treatability Data. Treatability data for activated sludge pro-
cesses treating solely PM&F process waters are not available.
However, treatability data for activated sludge processes are
available from several studies of other industrial categories.
For conventional pollutants (i.e., BOD5, oil and grease, TSS),
the available treatability data most applicable to the PM&F cate-
gory are data from the organic chemicals, plastics, and synthetic
fibers category because wastewaters generated by some processes
in that subcategory and by some PM&F processes are similar with
respect to conventional pollutant concentrations.
Treatability data for nonconventional pollutants (i.e., COD, TOG,
total phenols) were based on percent removal values reported in
EPA1 s Treatability Manual, Volume III, Technologies for Control/
Removal of Pollutants.Thesevaluesrepresentedmeanpercent
removals for COD, TOG, and total phenols calculated using
performance data from various industries for activated sludge
processes.
For priority pollutants found above treatable concentrations,
mean percent removals for the activated sludge process were
obtained from EPA's Fate of Priority Pollutants in Publicly
Owned Treatment Works;" Volume I (440/1-82-303); they are pre-
sentedin Table VIII-4.However, these percent removals are not
generally applicable to the relatively low concentrations of
priority pollutants characteristic of PM&F process waters. In
many cases, application of these percent removals to the average
influent concentrations of priority pollutants found in PM&F
process waters resulted in effluent concentrations less than the
pollutant analytical detection limits.
Activated Carbon Adsorption
Activated carbon removes pollutants from water by the process of
adsorption (i.e., the attraction and accumulation of one sub-
stance on the surface of another). Activated carbon preferenti-
ally adsorbs organic compounds over other compounds and, because
of this selectivity, is effective in removing organic pollutants
from wastewaters. This sorption process occurs when wastewater
is passed over the activated carbon in a packed bed.
The term activated carbon applies to any amorphous form of carbon
specially treated to give high adsorption capacities. The
adsorption of materials onto the active sites in the activated
carbon is a reversible process, allowing the carbon to be regen-
erated for reuse using either heat and steam or solvents.
236
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Table VIII-4
REMOVAL EFFICIENCIES FOR NONCONVENTIONAL POLLUTANTS
AND PRIORITY POLLUTANTS FOR ACTIVATED SLUDGE PROCESSES
Nonconvent ional
_ Pollutants _
COD
TOG
Total Phenols
Priority Pollutants
65. phenol
66. bis(2-ethylhexyl)
phthalate
67. dimethyl phthalate
68. di-n-butyl phthalate
Mean Removal
Efficiency
128.
zinc
63
63
60
99+
72
No Data
51
77
Source
A
A
A
B
B
B
B
Sources:
(A) USEPA, Treatability Manual, Volume III, Technologies for
Control/Removal of Pollutants, July 1980, EPA 600/8-80-
042c.
(B) USEPA, Fate of Priority Pollutants in Publicly Owned
Treatment Works: Volume I, September 1982, EPA 440/
1-82/303.
237
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Carbon adsorption requires preliminary treatment of the waste-
water to remove excess suspended solids, oils, and greases.
Suspended solids in the influent should be less than 50 mg/1 to
minimize backwash requirements; oil and grease should be less
than 10 mg/1.
Activated carbon is available in both powdered and granular form.
An adsorption column packed with granular activated carbon is
depicted in Figure VIII-3. Powdered carbon is less expensive per
unit weight and may have slightly higher adsorption capacity, but
it is more difficult to handle and to regenerate compared with
granular activated carbon.
Applications. Carbon adsorption is used primarily to remove
gaseous contaminants and condensable vapors from gaseous streams.
Carbon adsorption has also been used to remove dissolved organic
pollutants in both municipal and industrial wastewaters. It is
most effective for removing non-polar organic compounds of low
molecular weight and slight solubility in the liquid phase. Many
inorganic pollutants, including cyanide, chromium, mercury, and
chlorine, are also effectively removed in the activated carbon
process.
In general, carbon adsorption is used to treat wastewater when a
high quality effluent is desired. It is used for such things as
purification in industrial processes, pharmaceutical manufacture,
drinking water purification, and secondary and tertiary treatment
of industrial and municipal wastewaters. Typical applications
include removal of phenol from drinking water supplies, sugar
decolorization, and removal of mercury from industrial waste-
waters. Potentially, activated carbon adsorption is almost uni-
versally applicable because trace organics are found in virtually
all industrial wastewaters.
Limitations. Wastewaters treated by carbon adsorption require
pretreatment if there are significant levels of suspended solids
(greater than 50 mg/1) and oil and grease (greater than 10 mg/1)
present. High suspended solids levels tend to quickly clog the
carbon bed and result in frequent backwashings. Oil and grease
tend to coat the activated carbon, interfering with reactivation
and resulting in the loss of activity.
Carbon adsorption is generally least effective for the removal of
organic pollutants exhibiting the following characteristics:
o Low molecular weight,
o High solubility in the liquid phase, and
o High polarity.
238
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FLANGE
WASTE WATER
INFLUENT
DISTRIBUTOR
WASH WATER
SURFACE WASH
MANIFOLD
BACKWASH
BACKWASH
REPLACEMENT CARBON
CARBON REMOVAL PORT
TREATED WATER
SUPPORT PLATE
Figure VIII-3
ACTIVATED CARBON ADSORPTION COLUMN
239
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High operating and maintenance costs are associated with carbon
adsorption due to the relatively sophisticated operation and
materials handling.
Reliability, Treatment of wastewater using activated carbon
adsorption is moderately reliable, depending on the design, con-
struction, and manufactured equipment quality. In addition, high
levels of suspended solids and oil and grease may affect the
performance.
Environmental Impact. Carbon adsorption equipment requires mini-
mal use of land. Spent carbon may present a land disposal prob-
lem if regeneration is not feasible. There may also be an air
pollution problem encountered with regeneration and production of
hydrogen sulfide (leading from favorable conditions found in
carbon beds).
Treatability Data. A U.S. EPA study entitled, Treatability of
Organic Priority Pollutants - Part C - Their Estimated (30-Day
Ave.) Treated Effluent Concentration - AMolecular Engineering
Approach, indicates that bis(2-ethylhexyl) phthalate can be
theoretically removed to 0.010 mg/1 (30-day average) using
activated carbon treatment preceded by oil-water separation and
filtration. Based on consideration of chemical structure and
physical and chemical properties that would affect adsorption,
the treatability level for dimethyl phthalate and di-n-butyl
phthalate were both estimated to be 0.025 mg/1.
Filtration (Suspended Solids Removal)
Filtration processes are used either to remove suspended solids
from the effluent from other treatment technologies or as a
pretreatment process. Filtration processes include a wide range
of technologies including screens, granular media filters, belt
filters, and membrane filters, just to name a few. Figure VIII-4
contains diagrams of different kinds of filters used to remove
suspended solids from wastewater.
The performance of filters is based on a physical screening
process in which a barrier* prevents the passage of suspended
solids. The primary difference between the various types of
filters is the degree of permeability of the barrier, ranging
from the coarseness of a wire screen to the selectivity of
ultrafiltration membranes.
* Although processes based on barriers that have no appreciable
thickness in the direction of the liquid flow are typically
referred to as straining, these processes are considered as
filtration processes in this discussion.
240
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Hater Level-
Influent
Rotating Screen
Effluent
Inclined Screen
Influent
+, Filtered Solids
Accumulated
. Solids to
Df aposal
Paper Filter
Influent
»
Spent Backwash to
Headworks
Cperating Level
Backwash _
Anthracite
Sand
Underdrain
Backwash
Storage
Effluent
Granular Media Filter
Figure VIII-4
FILTRATION TECHNOLOGIES
Backwash Pump
241
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Filtration processes operate on either a batch or continuous
basis, depending on the process. For instance, normal practice
is to design certain types of filters (e.g. , granular media,
cartridge, bag) to operate on a batch basis with entire units
taken out of service for cleaning (e.g., backwashing, filter
media replacement) according to a schedule or as required. Some
granular media filter designs, however, provide more or less
continuous cleaning, either externally with media cycled through
the bed, or in-place with techniques such as traveling backwash
or air pulsing of the bed and air mixing of the liquid above it.
Other types of filters, such as inclined screens and paper fil-
ters (see Figure VI1I-4) usually provide continuous removal of
the accumulated solids.
Applications. Filtration can be used for a wide range of appli-
cationsincluding: (1) the removal of coarse solids by screening
in a pretreatment process, (2) the removal of precipitated solids
after chemical coagulation of wastewaters, and (3) treatment of
settled effluent from other treatment technologies (e.g., the
activated sludge process).
Technology Status. Several types of filters are currently used
to treat PM&F process waters. Technologies observed during sam-
pling episodes include a bag filter, a paper filter, and a belt
filter.
Limitations. Economics of filtration processes can be highly
dependenton consistent influent quality and flow variations.
The performance of filtration processes may be limited by the
filterability (e.g., particle size, floe strength, adhesive pro-
perties) of the suspended solids. The f ilterability may be
improved by addition of filter aids such as alum to act as
coagulants and to increase the floe strength.
In addition, dissolved solids are generally not removed by fil-
tration processes, with the exception of certain processes based
on selective membranes that are capable of removing dissolved
solids.
Reliability. Filters typically have a high degree of reliability
when properly maintained. Occasional problems may arise when the
filters are not properly cleaned.
Environmental Impact. The major environmental impact of filters
is the disposal of the suspended solids removed from the waste-
water. Solids have to be disposed of properly to avoid negative
environmental impacts. Filters usually do not contribute to
other types of pollution (e.g., air pollution).
242
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Treatability Data, Filtration is an effective and widely used
technology forremoving total suspended solids from wastewater.
Typical percent removals for suspended solids range from 5 to 95
percent. The median percent removal for suspended solids using
granular media filtration is 75 percent based on treatability
data reported in Treatability Manual, Volume III, Technologies
for Control/Removal of Pollutants;(EPA 600/8-80-042C). Mean
removal efficiencies ranging from 10 to 25 percent for oil and
grease, BOD^, TOG, COD, and total phenols have also been
achieved in filtration units.
Vacuum Filtration (Sludge Dewatering)
In wastewater treatment plants, sludge may be dewatered by vacuum
filters that generally use cylindrical drum filters. These fil-
ters have a medium that may be cloth made of natural or synthetic
fibers or a wire-mesh fabric. The drum is suspended above and
dips into a vat of sludge. As the drum rotates slowly, part of
its circumference is subject to an internal vacuum that draws
sludge to the filter medium. Water is drawn through the porous
filter cake to a discharge port, and the dewatered sludge,
loosened by compressed air, is scraped from the filter mesh.
Because the dewatering of sludge on vacuum filters is relatively
expensive per kilogram of water removed, the liquid sludge is
frequently thickened prior to processing. A vacuum filter is
depicted in Figure VIII-5.
Applications. Vacuum filters are frequently used both in munici-
pal treatment plants and in a wide variety of industries. They
are most commonly used in larger facilities, which may have a
thickener to double the solids content of sludge before vacuum
filtering.
Technology Status. Vacuum filtration is a fully proven technol-
ogy for sludge dewatering. It is used for sludge dewatering in
many industries.
Limitations. Vacuum filters are not practical at low dewatered
sludge outputs due to their high initial cost and area require-
ments. In addition, vacuum filters have high maintenance
requirements, which are characteristic of sludge dewatering
equipment. Maintenance consists of the cleaning or replacement
of the filter media, drainage grids, drainage piping, filter
pans, and other parts of the equipment. Experience in a number
of vacuum filter plants indicates that maintenance consumes
approximately 5 to 15 percent of the time of the maintenance
personnel. If carbonate buildup or other problems are unusually
severe, maintenance time may be as high as 20 percent. For this
reason, one or more spare units should be available. If inter-
mittent operation is used, the filter equipment should be drained
243
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FABRIC OR WIRE
FILTER MEDIA
STRETCHED OVER
REVOLVING DRUM
ROLLER
SOLIDS SCRAPED
OFF FILTER MEDIA
DIRECTION OF ROTATION
CYLINDRICAL
FRAME
LIQUID
THROUGH
MEDIA BY
MEANS
VACUUM
SOLIDS COLLECTION
HOPPER
INLET LIQUID
TO BE
FILTERED
-TROUGH
FILTERED LIQUID
Figure VIII-5
VACUUM FILTER
244
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and washed each time it is taken out of service. An allowance
for this wash time must be made in filtering schedules.
Reliability. Vacuum filters have proven reliable at many indus-
trial and municipal treatment facilities. At present, the larg-
est municipal installation that uses vacuum filters is the West
Southwest wastewater treatment plant in Chicago, Illinois, where
96 large filters were installed in 1925, functioned approximately
25 years, and then were replaced with larger units. Original
vacuum filters at Minneapolis-St. Paul, Minnesota, now have over
28 years of continuous service.
Environmental Impact. The disposal of the solid cake generated
fromvacuumfiltration is the only major environmental impact
associated with this technology. The solid waste is usually dis-
posed in a landfill. The characteristics of the dewatered sludge
depend primarily on the raw waste characteristics of the treated
wastewaters and the particular treatment technology utilized.
245
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SECTION IX
COSTS, ENERGY, AND NON-WATER QUALITY ASPECTS
INTRODUCTION
This section presents the technical data used to develop cost
estimates for the treatment technologies described in Section
VIII. In addition, the methodology for estimating process-by-
process treatment costs is discussed. Cost estimates obtained
using information presented in this section are used to evaluate
the control and treatment options for each type of effluent
limitations guidelines and standards. The cost estimates are
also used as the basis to estimate the economic impact of the
final regulation on the PM&F category.
This section also discusses the technical basis for the Agency's
estimates of (1) the energy used by the treatment technologies,
(2) solid waste generation rates, and (3) other non-water quality
impacts attributable to implementation of the control and
treatment technologies.
COST ESTIMATES FOR TREATMENT TECHNOLOGIES
Sources of Cost Data
Capital and operation and maintenance (O&M) cost data for the
treatment technologies were obtained from two sources:
(1) equipment manufacturers and (2) the literature. The major
sources of capital costs were contacts with equipment vendors.
Most of the O&M cost information was obtained from the litera-
ture.
Cost Components
Capital costs consist of equipment costs and system costs.
Equipment costs include: (1) the purchase price of the manufac-
tured equipment and any accessories; (2) delivery charges, which
account for the cost of shipping the purchased equipment a dis-
tance of 500 miles; and (3) installation charges, which include
charges for labor, excavation, site work, and materials.
System capital costs include engineering, administrative, and
legal costs, contingencies, and the contractor's fee. The
engineering, administrative, and legal costs are expressed as a
percentage of the equipment costs. Contingencies and contrac-
tor's fee are expressed as a percentage of the sum of the equip-
ment costs and the engineering, administrative, and legal costs.
Equipment costs and system costs are added to obtain the total
capital costs. The components of capital costs are listed below:
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Item No. Item Cost
1 Equipment Costs Cost of installed equipment
2 Engineering, 10 percent of Item 1
Administrative,
and Legal
3 Subtotal Item 1 and Item 2
4 Contingency 15 percent of Item 3
5 Contractor's Fee 10 percent of Item 3
6 Total Capital Cost Items 3 through 5
Operation and maintenance costs include the following:
1. Raw materials costs - These costs are for chemicals used
in the treatment processes, which include caustic,
sulfuric acid, corrosion inhibitors, and biocides.
2. Operational labor costs - These costs account for the
labor directly associated with operation of the process
equipment. Labor requirements are estimated in terms of
hours per year. A composite labor rate of $21 per hour
was used to convert the annual hours to an annual cost.
This composite labor rate includes a base labor rate of
$9 per hour for skilled labor, 15 percent of the base
labor rate for supervision, and 100 percent of the base
rate for plant overhead. Nine dollars per hour is the
Bureau of. Labor national wage rate for skilled labor.
3. Maintenance and repair costs - These costs account for
the labor and materials required for repair and routine
maintenance of the equipment. Maintenance and repair
costs were assumed to be five percent of the equipment
costs based on information from literature sources
unless more reliable data were available from vendors.
4. Energy costs - Energy or power costs were calculated
based on total nominal horsepower requirements for the
equipment (in kw-hrs); an electricity charge of $0.049/
kilowatt-hour; and an operating schedule of 24 hours/
day, 250 days/year unless specified otherwise. The
electricity rate is based on the industrial electricity
rate derived from the Department of Energy's Monthly
Energy Review (March 1982).
248
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In addition to O&M costs, total annualized costs include monitor-
ing costs. Monitoring refers to periodic sampling and analysis
to verify that discharge limitations are being met. Monitoring
costs were based on $300 per sample for toxic pollutants (base/
neutral extractables analysis via gas chromatography/mass spec-
trophotometry) and $50 per sample for conventional pollutants
(BOD5, TSS, oil and grease, and pH). These costs were deter-
mined from in-house literature and from a vendor quote. The
costs per analysis were multiplied by the monitoring frequency
(i.e., number of analyses per year) to obtain the annual monitor-
ing costs for a particular plant. Monitoring frequencies and the
annual monitoring costs for each plant are discussed in the
Economic Impact Analysis of Effluent Limitations and Standards
for the Plastics Molding and Forming Industry, EPA 440/2-84-025,
December 1984. Amortized costs, which account for depreciation
and the cost of financing, are also discussed in the economic
analysis document.
Cost Update Factors
All costs were standardized by adjusting them to the first quar-
ter of 1982. The cost indices used for particular components of
costs are described below.
Capital Costs - Capital costs were adjusted using the EPA-Sewage
Treatment Plant Construction Cost Index. The value of this index
for March 1982 is 414.0.
Operation and Maintenance-Labor Costs - The Engineering News-
Record Skilled Labor Wage Index was used to adjust the portion of
operation and maintenance cost attributable to labor. The March
1982 value is 325.0.
Maintenance and Repair Costs - The producer price index published
by the Department of Labor, Bureau of Statistics was used for
these costs. The March 1982 value of this index is 276.5.
Raw Materials Costs - The Chemical Engineering Producer Price
Index for industrial chemicals was used. This index is published
biweekly in Chemical Engineering magazine. The March 1982 value
of this index is362.6.
Cost Data Correlation
To estimate capital and O&M costs for the treatment technologies,
cost data from all available sources were plotted on a graph of
capital or O&M costs versus a design parameter (usually flow
rate). These data were distributed over a range of flows. A
single line was fitted to the data points, thus arriving at a
cost curve that represented an average of all the costs for
249
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either a treatment technology or a component of a treatment tech-
nology. Because the cost estimates presented in this section are
applicable to treatment technologies used in varying circum-
stances and geographic locations, the Agency believes this
statistical approach best estimates costs of the technologies
considered for the final PM&F regulation. For consistency in
estimating costs and accuracy in reading the final cost curves,
equations were developed to represent the final cost curves.
Capital and operation and maintenance cost equations are listed
in Table IX-1.
DESIGN DATA FOR TREATMENT TECHNOLOGIES
Design data and cost information are presented for the following
treatment and control technologies:
- Flow equalization,
- pH adjustment,
- Settling,
- Package activated sludge plant,
- Activated carbon adsorption,
- Vacuum filters, and
- Contract haul.
Flow Equalization
Flow equalization is accomplished using holding tanks sized for a
retention time of eight hours and an excess capacity factor of 20
percent. Equalization costs were based on the following
equipment:
1. Equalization tank (eight hour retention time)
2. Influent pump
Cost correlations are available for equalization tanks with a
volume between 50 and 500,000 gallons based on vendor quotations.
Three separate capital cost equations were developed, one for
fiberglass tanks ranging from 50 to 1,000 gallons, another for
fiberglass tanks from 1,000 to 24,000 gallons, and a third for
24,000 to 500,000 gallon steel tanks. Capital costs for steel
tanks with a volume greater than 24,000 gallons include on-site
fabrication, two coats of epoxy, a prime coat, and a finish coat.
O&M costs for tanks include maintenance costs (e.g., for inspec-
tion, repair) and labor costs for removing settled solids from
the tank. The maintenance costs are estimated as two percent of
the capital cost of the tank and the labor requirements for
settled solids removal range from 1 to 4.5 hours per week,
depending on the tank size.
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Table IX-1
CAPITAL AND O&M COST EQUATIONS*
Equipment
Activated Carbon
Adsorption
Agitators, C-clamp
Agitators, Top Entry
Contract Haul
Lirae Feed System
Package Activated Sludge
Plant
Pumps, Transfer
Tank, Fiberglass
Equation
C - 19,280
C - 16,538.7 + 836.368 Y - 3.40459 Y2
C « -60,242.7 + 1,814.97 Y - 2.79681 Y2
A - 3,140
A - 3,112 + 209.26 Y - 0.3526 Y2
A - 14,214 + 14.668 Y + 0.2696 Y2
C - 19,220
C - 7,847 + 11 ,531 .4 Y - 98.524 Y2
C - 132,579 + 1,738.07 Y
A - 3,400
A - 2,694.5 + 2,787.15 Y - 99.2586 Y2
A - 5,865.5 + 1 ,086.30 Y
C - 417 + 4,030 (HP)
A - 104+351 (HP)
C - 839.1 + 587.5 (HP)
A - 2,739.89 + 403.365 (HP) + 0.7445 (HP)2
C - 1,585.55 + 125.302 (HP) - 3.27437 (HP)2
A - 2,739.89 + 403.365 (HP) + 0.7445 (HP)2
C - 0
A - 0.40 (G)(HPY)
C - exp[9.13051 + 0.114998 In (F) + 0.18767
(InF)2]
A - exp[7,00162 + 0.317975 In F + 0.064336
(InF)2] + 0.022 (F) (HPY)
C - 2,566
A - 910
C - 9,165
A - 3,055
C - 6,500 + 1.71 X
A - 1,600 + 0.96 X
C - exp[1.57977 + 1.22209 (InX)
- 0.028484(lnX)2]
A - 4,538.99 + 0.0737513 (X) - 2.77111
x 10-* (X2)
C - exp[6.31076 + 0.228887 (InY)
+ 0.0206172 (InY)2]
A - exp[6.67588 + 0.031335 (InY)
+ 0.062016 (InY)2]
C - 3,100.44 + 1.19041 (V) - 1.7288x10-5 (V)2
A - 0.02(C) + (21)[4.17 x 10-5(v) + 0.958]
A - 0.05(C)
A - 0.02(C)
Range of Validity
CER - 0.374 0 < Y < 5
5 t Y < 75
75 ? Y ? 310
0 < Y ? 1
1 I Y ^ 75
75 < Y < 310
CER - 3.90
0 < Y < 1
1 ? Y < 15
15 ? Y < 150
0 ? Y ? 0.1 5
0.15? Y ? 15
15 < Y < 150
0 < HP .< 0.25
0.25 < HP < 0.33
0.33 < HP < 5.0
Nonhazardous Wastes
0.01 < F < 10
0.01 < F < 10
X < 600
600 < X < 1,500
1,500 < X < 5,000
5,000 < X < 100,000
3 < Y < 3,500
500 < V < 24,000
Equalization w/settling
Settling
Equalization/holding w/o
settling
251
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Table IX-1 (Continued)
CAPITAL AND O&M COST EQUATIONS*
Equipment
Tank, Steel
Vacuum Filter
Vacuum Filter Housing
Equation
C - 14,759.8 + 0.170817 (V) - 8.44271
x 10-8 (V)2
A - 0.02(C) + (21)[4.17 x 10"5(V) + 0.958]
A = 0.05(C)
A = 0.02(C)
C = 71,083.7 + 442.3(SA) - 0.233807(SA)2
A =• 17,471.4 + 677.408(SA) - 0.484647(SA)2
C - (45)[308.253 + 0.836592(SA) ]
A = (4.96)[308.253 + 0.836592(SA)]
Range of Validity
24,000 < V < 500,000
Equalization w/settling
Settling
Equalization/holding w/o
settling
9.4 < SA < 750
9.4 < SA < 750
A = Operation and maintenance costs (1982 dollars/year)
C - Equipment costs (1982 dollars)
CER - Carbon exhaustion rate (pounds carbon/1,000 gallons)
F - Chemical feed rate (pounds/hour)
G - Sludge disposal rate (gallons/hour)
HP = Power requirement (horsepower)
HPY = Plant operating hours (hours/year)
SA - Filter surface area (square feet)
V - Tank capacity (gallons)
X - Wastewater flow rate (gallons/day)
Y - Wastewater flow rate (gallons/minute)
*Capital cost equations do not include system capital costs (e.g., engineering, contingency, etc.); system
costs must be added to the equipment costs (calculated by the above cost equations) to obtain total
capital costs. O&M cost equations do not include either monitoring or amortization costs.
252
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Capital costs for pumps are based on vendor quotations for posi-
tive displacement pumps with a flow rate between 3 and 27 gpm and
centrifugal pumps, which are more economical at higher flow
rates, with a flow rate between 27 and 3,500 gpm. Pump O&M costs
are based on the following:
energy costs, which were estimated assuming a pump
efficiency of 70 percent; the pump operates for the
reported plant operating hours at the nominal capacity
(horsepower);
operating labor costs, which were based on 0.5 hours
labor/operating day; and
maintenance labor costs, which were based on labor
requirements ranging from 0.005 to 0.03 hours labor/hour
of pump operation (depending on pump capacity).
pH Adjustment
Costs were estimated for adjusting the pH of process waters from
pH 5 to pH 7 by the addition of'lime. An influent pH of 5 was
selected based on a review of pH's from the sampling data.
Adjustment of pH occurs in the equalization tank if such a tank
is included in the treatment technology. If equalization is not
required, pH adjustment occurs in a mix tank with an appropri-
ately sized agitator (based on 0.5 horsepower/1,000 gallons).
Costs for the following equipment were included in pH adjustment
costs:
1. Mix tank (if equalization tank is not available)
2. Lime feed system
- storage tank
- chemical metering pump
- pipe and valves
- instrumentation (pH control)
3. Agitator
Capital costs for the mix tank were obtained using the cost equa-
tions used to calculate equalization tank costs, as described in
the flow equalization discussion in this section. O&M costs for
mix tanks are estimated as five percent of the tank capital cost
and are for maintenance (e.g., periodic clean out and repair).
A capital cost equation for the lime feed system delivering
between 0.01 and 10 Ibs lime/hour on a continuous basis was
developed from vendor quotations. The capital costs include
253
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costs for a pH monitor (flow-through pH analyzer), electrical and
instrumentation (e.g., conduit, indicating controller, trans-
ducer) , piping and valves (e.g., control valve and instrumenta-
tion piping), a C-clamp agitator, and a storage tank (sized to
hold six percent weight lime slurry for one week).
O&M costs for lime feed systems include energy costs for the agi-
tator, operational labor costs for preparation of chemical stock
solutions and calibration of instrumentation, and maintenance
costs for the tank and valving.
Lime feed system costs were included in the pH adjustment costs
because PM&F process waters generally have to be adjusted from
acidic to neutral conditions when pH adjustment is necessary. In
cases when an acid feed system was required, the costs of an acid
feed system were assumed to be equal to the costs of the lime
feed system. This assumption tends to overestimate the pH
adjustment costs because an acid feed system requires a less
sophisticated metering system than a lime feed system.
Capital and O&M cost equations were developed for three types of
agitators: (1) small C-clamp agitators (less than 0.25 hp),
(2) medium-sized C-clamp agitators (between 0.25 and 0.33 hp) ,
and (3) top-entry agitators (between 0.33 and 10 hp). The capi-
tal costs for agitators, which were based on vendor quotations,
include costs of enclosed gear drives, electric motors, and 304
stainless steel shafts and propellers. Agitator O&M costs
include energy costs (based on estimated horsepower requirements
and 8,760 operating hours per year) and maintenance labor and
materials costs (assumed to be five percent of the capital cost).
Settling
Settling tanks are used for gravity separation of suspended
solids in wastewater. The settling unit was sized for eight
hours of retention time. It was assumed that 82 percent influent
solids were removed. This technology includes:
1. Settling tank (eight hour retention time)
2. Pump
Operating and maintenance costs include tank maintenance and
settled solids removal (estimated as five percent of capital cost
of tank) and O&M costs associated with the pump. Refer to previ-
ous discussion on flow equalization for information on tank
capital costs and for information on pump capital and O&M costs.
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Package Activated Sludge Plant
Package activated sludge plants are usually composed of three
tanks (see Figure VIII-2) in which primary settling, activated
sludge treatment (extended aeration), and secondary settling
occur. The influent enters the first chamber where scum and
settleable solids are removed. The second chamber (i.e., the
activated sludge unit) is where dissolved pollutants are treated.
The final chamber is a settling unit where solids settle by
gravity and are either returned to the aeration unit or removed.
Package activated sludge plants can be used for flows as low as
600 gallons per day.
Capital costs for a package activated sludge plant included the
following:
1. Costs for a nutrient addition system
- mix tank (retention time of eight hours for PM&F
plants operating eight hours per day, 10 minutes for
PM&F plants operating 16 to 24 hours per day)
- agitator (sized based on 0.5 hp/1,000 gallons)
- chemical feed pumps (2)
- chemical day tanks (2)
2. Costs for the activated sludge unit
- primary settling tank
- aeration chamber
- secondary settling tank
The following assumptions were made in the design of the package
activated sludge plant:
1. Influent process water characteristics:
BOD5 = 89 mg/1
TSS =714 mg/1
pH = 5
Effluent process water characteristics:
BOD5 = 22 mg/1
TSS = 36 mg/1
pH = 7
2. "Nutrients" are added to the process water to maintain
an active microorganism level. Nitrogen is added at a
dosage level of 8.9 mg/1 (one-tenth of the influent
BOD5 concentration) as ammonia chloride (NH4.C1).
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Phosphorus is fed at a dosage level of 0.89 mg/1 (one-
hundredth of the influent BOD5 concentration) as
phosphoric acid
3. Nutrients (for maintaining the activated sludge) and
lime (for adjusting the pH) are added in a mix tank.
Nutrient and lime addition was accomplished on either a
batchwise or continuous basis depending on which alter-
native was less costly. For addition of the chemicals
to the high flow rate PM&F processes, a rapid mix tank
(10 minute retention time) and continuous feed system
was more economical compared with collection of the
process water generated during the course of an operat-
ing day followed by manual addition of chemicals on a
batchwise basis. For low flow rate processes, however,
the batch addition scheme was more economical than con-
tinuous chemical addition due to the relatively high
capital costs of continuous feed systems.
Because the low flow rate processes were generally asso-
ciated with plants with fewer number of operating hours,
the selection of either batch or continuous chemical
addition was based on the plant operating schedule. For
plants operating eight hours per day, the mix tank is
sized for eight hours of retention (in addition to 20
percent excess capacity) and chemicals are manually
added on a batch basis. For plants operating 16 or 24
hours per day, chemicals are added continuously in a
rapid mix tank sized for 10 minutes of retention. Costs
for lime feed systems are described separately under the
pH adjustment discussion in this section.
4. The design for the activated sludge treatment of indus-
trial wastes is based on three-stage treatment, consist-
ing of primary settling, extended aeration, and second-
ary settling. However, the commercially available
package activated sludge units that are applicable to
low flow rate processes only provide two-stage treatment
(aeration followed by settling). Thus, costs for a pri-
mary settling tank sized for a retention time of eight
hours were added to the costs of the two-stage package
units.
5. The package , activated sludge treatment plant design
includes flow equalization. Flow equalization is pro-
vided in the nutrient addition mix tank for PM&F plants
operating eight hours per day and in the primary settl-
ing tank for PM&F plants operating either 16 or 24 hours
per day. In each case, the tank is sized for an eight
hour retention time based on instantaneous influent flow
rate.
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6. The nominal package activated sludge treatment plant
capacity is based on a continuous influent flow rate.
The smallest capacity package plant for which costs were
obtained is 600 gpd. If the influent flow is greater
than 200 gpd but less than 600 gpd, costs for the 600
gpd package plant were assumed. Treatment costs for
PM&F processes with a flow rate less than 200 gpd were
based on disposal by contract haul, which is more eco-
nomical than treatment in a package activated sludge
plant at these flow rates. It was assumed in these
cases that PM&F plants will use the less costly method
of complying with the PM&F regulation.
7. Sludge production rates are based on removal of TSS from
the influent concentration of 714 mg/1 to a concentra-
tion of 36 mg/1, plus production of 0.6 Ib sludge (dry
weight) per Ib of BOD5 removed. Sludge from the
settling units consists of two percent solids (TSS =
20,000 mg/1).
8. Costs are provided for sludge dewatering based on vacuum
filtration of the sludge to 20 percent solids if such
treatment is economical. Sludge is contract hauled
without dewatering if the influent flow to the vacuum
filter is less than 50 1/hr.
Activated Carbon Adsorption
Activated carbon is used to remove dissolved organic contaminants
from wastewaters. As the wastewater is pumped through the carbon
column, organic contaminants diffuse into the carbon particles
through pores and are adsorbed onto the pore walls. As organic
material accumulates, the carbon loses its effectiveness and must
be replaced or regenerated periodically.
Two downflow carbon columns in series are usually used.* The
leading column loses its effectiveness first because most of the
organic pollutants are adsorbed in it. When breakthrough occurs
(i.e., when the column effluent concentration of a specified
adsorbed pollutant exceeds a specified maximum), the column is
taken off-line and regenerated or replaced and the second column
becomes the leading column. This configuration, known as a
* When it was estimated that breakthrough would occur less than
once every three months, two columns were not deemed necessary.
Thus, costs were based on a single adsorption column in these
cases.
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"merry-go-round," results in a more consistent effluent quality
than a single, larger column or a system where one column is
active and one is on standby. During column operation, solids
accumulate in the interstices of the carbon bed. To prevent the
column from plugging, the bed must be periodically backwashed to
remove these solids. Also, a method for replacing spent carbon
is required. Either replacement with virgin carbon and disposal
of the spent carbon or regeneration of the spent carbon by either
off-site or on-site regeneration may be used, depending on the
carbon usage rate.
Costs of the following equipment were included in the estimate of
capital costs for the activated carbon process:
1. Carbon adsorption unit
- steel adsorption columns (1 or 2 columns depending
on estimated carbon exhaustion rate)
- hydraulic loading = 2.5 gpm/ft^
- initial activated carbon charge
- pump for transfer between surge tank and column
- piping
- instrumentation
2. Backwash facilities
- backwash hold tank - provides 15 gpm/ft^ per
column for 15 minutes (duration length of backwash)
- pump
3. Influent surge tank (one hour retention time)
4. Carbon replacement/regeneration facilities* for:
- replacement (for carbon usage rates less than 1.6
Ibs/hr)
- off-site regeneration (for carbon usage rates between
1.6 and 53 Ibs/hr) or
- on-site regeneration (for carbon usage rates above
53 Ibs/hr)
The capital and O&M cost equations for activated carbon adsorp-
tion systems include the costs of all four components listed
above. As presented in Table IX-1, separate sets of equations
were developed for different flow ranges and carbon exhaustion
*The carbon replacement/regeneration method depends on the carbon
usage rate.
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rates as a function of influent flow rate. Both the carbon
exhaustion rate and the influent flow rate to the activated
carbon unit are dependent on whether process waters are recycled.
For processes in the questionnaire data base for this regulation
that recycled 90 percent or more of the process water, the influ-
ent to the activated carbon adsorption unit was assumed to be the
discharge (at 90 percent recycle) from the recycle unit. For
processes with reported recycle percentages of less than 90 per-
cent, the influent to activated carbon adsorption was assumed to
be the process water usage flow (i.e., once-through process
data).
The carbon exhaustion rate is dependent on the influent and
effluent pollutant concentrations of the process water. Recycled
process waters should have higher pollutant concentrations than
process waters that are not recycled. Specifically, process
water recycled at 90 percent was assumed to have concentrations
10 times higher than non-recycled process waters. Based on this
assumption, the following influent concentrations and carbon
exhaustion rates were used to size the activated carbon unit:
Process Water Concentration/Carbon
Exhaustion Rate
Contact Cooling
and Heating Water
Finishing Water
Pollutant
Bis(2-ethylhexyl)
phthalate (mg/1)
Di-n-butyl phthal-
ate (mg/1)
Dimethyl phthalate
(mg/1)
Carbon Exhaustion
Rate (lb/1,000
gal)
Non-
Recycled
0.235*
**
**
0.374
Recycled!
2.35
**
3.90
Non-
Recycled
0.479
0.031
0.034
0.82
Recycledt
4.79
0.31
0.34
8.6
t Based on 90 percent recycle.
* Only field sampling concentration data above the treatability
level of 0.01 mg/1 were used in calculating the flow-weighted
pollutant average concentration in the influent to activated
carbon adsorption.
** Not found
water.
above treatable concentrations in this process
259
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The carbon exhaustion rates were based on published isotherm data
(Reference: Carbon Adsorption Isotherms for Toxic Organics, EPA
600/8-80-023, April 1980) and an excess capacity factor of 100
percent.
Capital and O&M costs for activated carbon adsorption were based
on achieving the following theoretical treatability limits:
Theoretical Treatability
Limit (mg/1) for
Pollutant Activated Carbon Adsorption
Bis(2-ethylhexyl) phthalate 0.010
Di-n-butyl phthalate 0.025
Dimethyl phthalate 0.025
Source: Treatability of Organic Priority Pollutants - Part C -
Their Estimated (30-Day Ave.) Treated Effluent Concen-
tration - A Molecular Engineering Approach, U.S. EPA
(internal report).
Capital costs of activated carbon adsorption units include costs
based on vendor quotations for pre-assembled steel adsorption
columns having a constant height of 25 feet. The diameter is
based on a constant hydraulic loading of 2.5 gpm/ft^. If the
calculated column diameter is greater than the maximum allow-
able diameter (9 feet) , multiple column trains are designed. If
the predicted diameter is less than the allowable minimum diam-
eter (2 feet) , the minimum diameter is used. O&M costs for the
carbon columns specifically include costs of energy for supply
and backwash pumping, operating labor costs for monitoring column
performance, and routine maintenance (e.g., changing pump seals,
etc.). Costs for the initial activated carbon charge are based
on the cost of Calgon FILTRASORB 300 and are a function of the
amount of carbon purchased. Typical activated carbon costs range
from $0.63 to $0.97 (March 1982) per pound.
The capital and O&M costs for the surge and backwash tanks and
transfer pumps are based on the corresponding cost equations
previously described in the flow equalization discussion, except
that O&M tank costs are only two percent of the capital cost
because solids removal is not necessary.
Selection of the carbon replacement or regeneration method
depends on the carbon usage rate (Ibs carbon exhausted/hr), which
is a function of the influent flow rate and the carbon exhaustion
rate. One of three operating schemes was chosen for each plant.
Below a carbon usage rate of 1.6 Ibs/hr, replacement of spent
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carbon with new carbon and contract haul of the spent carbon was
most economical. Between 1.6 and 53 Ibs/hr, regeneration by
off-site regeneration was more economical. On-site regeneration
facilities were more economical when the carbon usage rate was
above 53 Ibs/hr.
For carbon replacement, no capital investment was required.
Direct annual costs consist of contract hauling the spent carbon
as a hazardous waste and the purchase and installation of new
carbon.
For the off-site regeneration option, direct capital costs
include costs for hoppers for dewatering and storage of spent
carbon. The minimum amount of carbon that can be economically
regenerated off-site is 20,000 Ibs. In cases where the actual
inventory is less than 20,000 Ibs, capital costs for purchasing
additional carbon to reach the minimum level are included. O&M
costs include the charge for regeneration, transportation of the
carbon to and from the regeneration facility, and cost for
placing carbon into the column.
For an on-site regeneration facility, direct capital costs
include costs for a multiple hearth furnace and associated equip-
ment, spent carbon storage, exhaust gas scrubbers, a carbon
slurry system, quench tank, housing, and controls and instrumen-
tation. Direct annual costs include operation and maintenance
labor for the regeneration facility, maintenance materials, and
electricity and natural gas costs for the building, electrical
equipment, and furnace. Also included is the cost of replacing
carbon lost in the regeneration process (10 percent of the spent
carbon passing through the furnace) with virgin carbon.
Vacuum Filters
For the PM&F regulation, sludge from a settling unit and waste
activated sludge is dewatered in a vacuum filter to reduce the
amount of sludge that requires disposal. Vacuum filters can
dewater sludge to a cake with 20 percent solids. Dewatered
sludge is disposed of by contract haul and the filtrate is
recycled to the treatment process.
The capacity of the vacuum filter, expressed as square feet of
filtration area, is based on a yield of 14.6 kg of dry solids/hr
per square meter of filter area (3 Ibs/hr/ft*J, a solids cap-
ture of 95 percent and an excess capacity of 30 percent. The
filter operates eight hours per operating day.
Cost data were compiled for vacuum filters ranging in size from
0.9 to 69.7 m2 (9.4 to 750 ft2) of filter surface area.
Based on the results of a total annualized cost comparison,
261
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contract haul of the sludge is more economical when the sludge
flow rate is 50 1/hr (0.23 gpm) or less. Therefore, when the
sludge flow rate is 50 1/hr or less, costs were estimated to
contract haul all of the sludge.
Costs for the vacuum filtration unit include costs for the
following equipment:
1. Vacuum filter with precoat but no sludge conditioning
2. Housing
3. Influent transfer pump
4. Slurry holding tank
5. Sludge pumps
The vacuum filter is sized based on eight hours of operation per
day. The slurry holding tank and pump are excluded when the
treatment technology operates eight hours per day or less. In
this case, the underflow from the settling unit directly enters
the vacuum filter. For cases, where the treatment technology is
operated for more than eight hours per day, the underflow is
stored during vacuum filter non-operating hours. The filter is
sized accordingly to filter the stored slurry in an eight hour
period each day. The holding tank capacity is based on the
difference between the plant and vacuum filter operating hours
plus an excess capacity of 20 percent. Cost equations for
capital and O&M costs of vacuum filters and a vacuum filter
building are presented in Table IX-1.
The following assumptions were made in developing vacuum filter
capital and O&M costs:
1. O&M costs associated with the vacuum filter were devel-
oped based on continuous operation (24 hrs/day, 365
days/yr). These costs were adjusted for a plant's indi-
vidual operating schedule by assuming that O&M costs are
proportional to the hours the vacuum filter actually
operates. Thus, O&M costs were adjusted by the ratio of
actual vacuum filter operating hours per year (8 hrs/
day x number days/yr) to the number of hours in a year
(8,760 hrs/yr).
2. O&M vacuum filter costs include operating and mainte-
nance labor (ranging from 200 to 3,000 hrs/yr as a func-
tion of filter size), maintenance materials (generally
less than five percent of capital cost), and energy
(mainly for the vacuum pumps).
3. Costs for facilities to house a vacuum filter were based
on rates of $45/ft2 and $5/ft2/yr for capital and
O&M costs, respectively. These rates were applied to
262
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the estimated floor area required by the vacuum filter
system to obtain the costs of the facilities that house
the vacuum filter. The O&M cost rate accounts for elec-
trical energy requirements of the filter housing. Floor
area for the housing is based on equipment dimensions
reported in vendor literature, ranging from 300 ft2
for the minimum size filters (9.4 ftO to 1,400 ft2
for a vacuum filter capacity of 1,320 ft2.
Contract Haul
Concentrated sludge and certain process waters are removed on a
contract basis for off-site disposal. The cost of contract haul
depends on the classification of the waste as being either
hazardous or nonhazardous. For nonhazardous wastes, a rate of
$0.106/liter ($0.40/ gallon) was used to estimate contract
hauling costs. The cost for contract hauling hazardous wastes
(i.e., spent activated carbon) was developed from a survey of
waste disposal services and varies with the amount of waste
hauled (e.g., $0.97/gal for disposal at 1 gal/hr of sludge to
$0.76/gal for disposal at 100 gal/hr of sludge). No capital
costs are associated with contract hauling. The minimum monthly
charge for removal is $75.00, based on information from
nonhazardous sludge haulers.
PROCESS-BY-PROCESS COST ESTIMATES
Prior to estimating treatment costs for each process in the data
base for this regulation, the treatment technologies discussed in
Section VIII were used to develop model treatment technology
options for the various types of effluent limitations guidelines
and standards. These model treatment technology options are
discussed in more detail in Sections X, XI, and XII.
For the model treatment technology options considered by the
Agency, each type of process water (i.e., each subcategory)
requires a different treatment option.* Thus, the Agency assumed
that process waters in different subcategories would not be
combined for treatment. For this reason, capital and O&M costs
for each type of process water were estimated separately (i.e.,
based on segregated treatment of each process water type), as
discussed below.
* Except for the contact cooling and heating category water and
finishing water subcategory, both of which had activated carbon
adsorption as the model treatment technology at BAT. However,
no plant for which process water treatment costs were estimated
had process waters in both of these subcategories.
263
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First, for each of the 112 direct discharging plants in the
questionnaire survey data base for which treatment costs were
estimated, process waters were segregated by subcategory. Next,
for the questionnaire survey plants that had more than one pro-
cess water in a particular subcategory, the flows for these pro-
cess waters were combined to obtain subcategory flows for each
plant. Thus, it was assumed that process waters would be com-
bined if they required the same treatment. Third, costs of the
model treatment technology options were estimated for each
subcategory to obtain capital and O&M costs for each of the 112
questionnaire survey plants. These process-by-process cost
estimates, which are included in the public record for this
regulation, were then used in the economic impact analysis to
develop total capital and total annual cost estimates on a
plant-by-plant basis. These cost estimates are in the Economic
Impact Analysis of Effluent Limitation Guidelines and Standards
for the Plastics Molding and Forming Industry, EPA 440/2-84-025,
December1984.A more detaileddiscussion of this process-by-
process cost methodology for a plant is presented below.
Plant-Specific Treatment Technologies
The first step in the development of process-by-process cost
estimates was to select the appropriate treatment technologies
for a particular plant. This selection is simply based on the
particular processes at a plant. For example, if a plant dis-
charges cleaning water and finishing water, costs at BPT for this
plant were estimated for the model treatment technology options
at BPT for these process waters.
Process Water Characteristics
After establishing the model treatment technology for a. given
plant, the next step was to define the influent process water
characteristics (i.e., flow and pollutant concentrations).
Because the cost equations shown in Table IX-1 are primarily
dependent on flow, either directly or indirectly, the influent
flow is required as an input parameter. The plant-specific flows
for each process water were derived from the questionnaire
surveys. For plants practicing recycle of process water, the
discharge flow was used as the influent flow to end-of-pipe
treatment (see discussion on activated carbon adsorption in this
section for exceptions).
Costs for certain treatment technologies are affected by influent
concentrations. For example, the carbon exhaustion rate is
dependent on the amount of adsorbable organics removed from the
influent. Influent concentration dictates how long it takes for
carbon to be exhausted. Th,ese influent concentrations are also
264
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required for the calculation of pollutant removals. In general,
the influent concentrations used as input to cost estimation are
the flow-weighted average values calculated for each subcategory
and presented in Section VI. The exception is explained in the
description of the activated carbon adsorption process.
Cost Calculations
Once the model treatment technology option and process water
characteristics were defined for each plant in the data base,
appropriate cost equations were used to estimate capital and O&M
costs of the technology. The capital and O&M cost equations are
presented in Table IX-1.
Consideration of Existing Treatment
Cost estimates for the model treatment technology options are for
"greenfield" plants and do not account for equipment that plants
may already have in-place. To estimate the cost incurred by a
plant to meet the effluent limitations guidelines, "credit"
should be given for treatment in-place at that plant. The actual
capital costs of a model treatment technology option were
obtained by subtracting capital costs of treatment in-place (as
calculated by the cost equations) from the total "greenfield"
costs. O&M costs associated with treatment in-place were not
subtracted, however, because these costs recur and must be borne
by the facility each year.
COST ESTIMATION EXAMPLE
An example illustrating the cost estimation procedures for a
single plant is presented here. Capital and O&M costs at BPT are
estimated using the specific cost estimation steps previously
described.
Plant Y in the PM&F category is a direct discharger at which
injection molding, dip coating, plastic product cleaning, and
grinding operations are performed. Both cleaning water and
finishing water are discharged from the plant. Therefore, the
plant has processes in both the cleaning water subcategory and
the finishing water subcategory. The plant also has processes in
the contact cooling and heating water subcategory (i.e., injec-
tion molding and dip coating) , but these processes do not use
process water.
Costs for Plant Y at BPT were estimated using the following
procedure:
265
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1. Define the treatment technology.
The only model treatment technology option considered at
BPT for the cleaning water subcategory consists of
equalization and pH adjustment followed by a package
activated sludge plant; for the finishing water subcate-
gory, only settling was considered. Thus, costs for
Plant Y are estimated based on the model treatment
technologies shown in Figure IX-1 .
2. Define the process water characteristics.
Cleaning water influent characteristics:
Flow = 170 1/hr (0.75 gpm)
pH - 5
BODs = 89 mg/1
TSS =714 mg/1
O&G = 48 mg/1
Finishing water influent characteristics:
Flow = 522 1/hr (2.3 gpm)
TSS = 95 mg/1
Plant operating hours = 5,914 hrs/yr
3. Cost calculation.
The specified model treatment technology and raw waste
data were used as the basis of the cost calculations.
Results of the design and cost calculations are
presented below.
Design Data
Finishing water (settling):
Settling tank volume = 1,324 gal
Contract haul volume (sludge) = 3,125 gal/yr
Cleaning water (equalization, pH adjustment, and package
activated sludge plant):
Equalization tank volume = 432 gal
Equalization agitator size = 0.015 hp
Activated sludge treatment capacity = 864 gal/day
266
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Nutrient Addition:
Phosphoric acid application rate = 0.0012 Ibs/hr
Ammonium chloride application rate = 0.0128
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Lime application rate = 0.0011 Ibs/hr
Contract haul volume (sludge) = 9,830 gal/yr
The estimated costs of these model treatment technolo-
gies are presented in Table IX-2.
4. Consideration of treatment in place.
This step reduces the estimated costs to account for
treatment facilities existing at Plant Y. Based on the
questionnaire survey response, Plant Y has no treatment
in-place. Therefore, the "greenfield costs" shown in
Table IX-2 represent the actual estimated costs for
Plant Y at BPT.
ESTIMATION OF ENERGY AND NON-WATER QUALITY IMPACTS
The remainder of this section discusses the methodologies used to
estimate the energy and non-water quality environmental impacts
associated with the regulation. The estimated energy require-
ments, solid wastes generation, air pollution emissions, and
consumptive water losses based on the following methodologies are
presented in Sections X through XIII.
Energy
The increases in electrical energy consumption attributable to
application of the final PM&F effluent limitations guidelines and
standards were estimated to assess the impact of the final PM&F
regulation with regard to energy consumption. The estimated
electrical energy consumption by the PM&F category (expressed as
kw-hr/year) for the selected model treatment technology options
is presented in Sections X, XI, XII, and XIII for BPT, BAT, NSPS,
and PSES/PSNS, respectively. This part discusses the assumptions
and steps used to derive the energy consumption estimates.
Estimation of the net increase in electrical energy consumption
at BPT and BAT was accomplished as follows:
1. Energy costs for the treatment technologies were esti-
mated using energy factors. These factors represent the
percent of the annual O&M costs attributable to energy
for each technology. The energy costs ($/year) were
converted to energy requirements (kilowatt-hours/year)
using the electricity charge rate of $0.049/kilowatt-
hour.
268
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Table IX-2
ESTIMATED CAPITAL AND O&M COSTS FOR PLANT Y AT BPT
Estimated Costs ($3/82)
Equipment Costs CapitalO&M (1)
Settling $ 5,390 $ 1,120
Equalization 1,980 1,980
Chemical Addition 16,500 4,400
Package Activated Sludge Plant 4,380 4,670
Contract Haul (Sludge)
Cleaning Water 0 3,700
Finishing Water 0 1.270
Subtotal (Equipment Costs) $28,250 $17,140
System Costs
Engineering, Administrative, and Legal 2,825
Contingency 4,661
Contractor's Fee 3,108 -
(1) O&M costs do not include monitoring costs,
Subtotal (System Costs) 10,594
Total Costs $38,844 $17,140
269
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2. Energy requirements for plants in each subcategory were
estimated by applying the energy factors to the corre-
sponding treatment technology O&M costs. This was done
for each of the 112 direct discharging plants in the
questionnaire survey for which costs were estimated.
Estimated energy requirements for these plants were then
totaled by subcategory.
3. The total energy requirement for each PM&F subcategory
was estimated by scaling up the subcategory values
obtained in the previous step. The scale-up was based
on multiplying the subcategory value by the ratio of the
estimated total number of wet PM&F plants to the number
of wet plants in the PM&F questionnaire survey.
4. The energy usage for the PM&F category was estimated by
adding the projected subcategory energy requirements
obtained in the previous step.
At BPT, the estimated total energy requirement determined in the
last step represents the total energy usage by PM&F plants
attributable to the BPT effluent limitations guidelines. The
significance of the energy usage attributable to the PM&F regu-
lation is assessed by comparing it to the total current energy
usage for the PM&F category, which is estimated to be 1 x 10"'
kw-hr/yr. The total energy usage was projected from energy usage
information supplied by plants in the questionnaire survey data
base.
Air Pollution
The Agency does not expect the treatment of PM&F process waters
using the technologies considered as the basis for this final
PM&F regulation to create an air pollution problem. Some vola-
tile organic compounds may be emitted to the air from the biolog-
ical treatment technologies. However, those emissions are not
expected to be significant. Accordingly, air pollution emissions
attributable to the PM&F regulation were not estimated.
Solid Waste
The increase in solid wastes generated from application of the
final effluent limitations guidelines and standards were esti-
mated to assess the potential solid waste disposal impact of the
final PM&F regulation. The estimated amounts of solid wastes
(expressed as metric tons per year) generated by the PM&F cate-
gory for the selected model treatment technologies are presented
in Sections X, XI, XII, and XIII, for BPT, BAT, NSPS, and
PSES/PSNS, respectively. This section discusses the assumptions
and steps used to derive the solid wastes generation estimates.
270
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Solid wastes generated by the control and treatment technologies
considered for the PM&F category include settled solids from
sedimentation processes, treatment process sludges containing
biological solids and skimmed oil, and residues from periodic
cleaning of tanks and other equipment that may accumulate solids.
The annual sludge generation rates resulting from treatment of
PM&F process waters were estimated by material balances performed
around each unit treatment process. These material balances were
based on the average influent pollutant levels and design assump-
tions for the treatment technologies discussed previously in this
section. These sludge generation rates provided the basis for
estimating the total amount of solid wastes generated by the PM&F
category due to the final PM&F regulation:
1. Solid waste generation rates (liters/year) for treatment
of each type of PM&F process water were determined for
each of the 112 direct discharging plants included in
the questionnaire survey data base that have no
treatment in-place.* These generation rates, expressed
in liters/year, were converted to metric tons/year by
assuming that the solid-waste has the density of water.
Estimated solid waste generation rates for these plants
were totaled by subcategory.
2. The total solid waste generation rates for the PM&F
subcategory were estimated by scaling up the subcategory
values obtained in the previous step. The scale-up was
based on multiplying the subcategory values by the ratio
of the estimated total number of wet PM&F plants to the
number of wet plants in the PM&F questionnaire survey
data base.
3. The solid waste generation rate for the PM&F category
was estimated by adding the projected subcategory solid
waste generation rates obtained in the previous step.
Characterization of PM&F Solid Wastes. Based on the analyses of
process water solid wastes generated during treatment of PM&F
process waters, the Agency believes that PM&F process water
treatment residuals are not hazardous under Section 3001 of the
Resource Conservation and Recovery Act (RCRA). Four solid waste
samples were collected at three PM&F plants. The descriptions of
* Only questionnaire survey plants with no treatment-in-place
were included to estimate the additional amount of solid waste
generated from implementation of the selected model treatment
technologies (i.e., the net increase from the current level of
solid waste generation attributable to this regulation).
271
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these samples, including the PM&F subcategory, materials pro-
cessed, wastewater treatment practices, and physical descriptions
of the samples are presented in Table IX-3. These samples were
tested for hazardous characteristics based on the extraction
procedure (EP) toxicity test (see test method 1310, Test Methods
for Evaluating Solid Wastes, SW-846t). This testmethodTs
designed to simufate potential leaching of toxic pollutants from
the solid waste. Pollutants in solid waste samples analyzed were
present in concentrations below the allowable concentration of
those pollutants specified in the EP toxicity test procedures.
As can be seen by the results, presented in Table IX-4, the
pollutant concentrations in all extract samples were well below
the pollutant concentrations considered hazardous.
In addition to passing the EP toxicity test, none of the solid
wastes are specifically listed as hazardous, pursuant to 40 CFR
Part 261.11 (45 FR 33121; May 1980, as amended by 45 FR 76624;
November 19, 1980T7 nor are they likely to exhibit only hazardous
waste characteristics (e.g., reactivity, ignitability).
Also, the Agency expects the solid wastes generated by the
selected model treatment technologies to exhibit similar nonhaz-
ardous characteristics as these sampled wastes. Thus, the
Agency believes that the solid wastes generated as a result of
these guidelines will not be hazardous. Because the PM&F solid
wastes are not believed to be hazardous, no estimates for treat-
ment, storage, or disposal of the solid wastes in accordance with
RCRA hazardous waste requirements were made.
Although it is the Agency's view that solid wastes generated as a
result of the final PM&F regulation are not expected to be clas-
sified as hazardous under the regulations implementing Subtitle C
of the Resource Conservation and Recovery Act (RCRA), generators
of these wastes must test the waste to determine if they meet any
of the characteristics of hazardous waste. See 40 CFR Part
262.11 (45 FR 12732-12733; February 26, 1980). The Agency may
also list tEese sludges as hazardous pursuant to 40 CFR Part 261
(45 FR at 33121; May 19, 1980, as amended at 45 FR 76624;
November 19, 1980).
If these wastes are identified as hazardous, they will come
within the scope of RCRA's "cradle to grave" hazardous waste man-
agement program, requiring regulation from the point of genera-
tion to point of final disposition. EPA's generator standards
require generators of hazardous wastes to meet containerization,
labeling, record keeping, and reporting requirements; if plastics
molders or formers dispose of hazardous wastes off-site, they
tSee also 40 CFR 261.24 (45 FR 33084; May 19, 1980)
272
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would have to prepare a manifest that tracks the movement of the
wastes from the generator's premises to an appropriate off-site
treatment, storage, or disposal facility. See 40 CFR Part 262.20
(45 FR 33142; May 19, 1980, as amended at 45 FR 86973; December
31, T980). The transporter regulations require transporters of
hazardous wastes to comply with the manifest system to ensure
that the wastes are delivered to a permitted facility. See 40
CFR Part 263.20 (45 FR 33142; May 19, 1980, as amended at 45 FR
86973; December 31, T580). Finally, RCRA regulations establish
standards for hazardous waste treatment, storage, and disposal
facilities allowed to receive such wastes. See 40 CFR Part 264
(46 FR 2802; January 12, 1981, 45 FR 32274; July 26, 1982).
Even if these wastes are not identified as hazardous, they still
must be disposed in a manner that will not violate the open dump-
ing prohibition of §4005 of RCRA. The Agency has calculated as
part of the costs for wastewater treatment the cost of hauling
and disposing of these wastes in accordance with this require-
ment.
Consumptive Water Loss
Where evaporative cooling mechanisms are used for recycling
water, water loss may result and contribute to water scarcity
problems - a primary concern in arid and semi-arid regions.
Because recycle of PM&F process waters is not a treatment and
control technology used in development of the PM&F regulation,
consumptive water loss associated with the regulation does not
represent a potential environmental impact. Therefore, consump-
tive water losses were not estimated.
275
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SECTION X
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
BACKGROUND
This section defines the effluent characteristics attainable
through the application of best practicable control technology
currently available (BPT), as required by Section 301(b)(1)(A) of
the Act. Effluent limitations guidelines for the PM&F category
based on BPT reflect either the existing treatment performance by
plants of various sizes, ages, and manufacturing processes within
the plastics molding and forming category or the performance of a
treatment technology transferred from the organic chemicals,
plastics, and synthetic fibers category.
The factors considered in identifying BPT include the total cost
of applying the technology in relation to the effluent reduction
benefits derived, the age of equipment and facilities involved,
the manufacturing processes employed, energy, non-water quality
environmental impacts, and other factors EPA considers appropri-
ate. In general, the BPT level represents the average of the
best existing performance of plants of various ages, sizes,
processes, or other common characteristics. Where existing per-
formance is uniformly inadequate, BPT may be transferred from a
different subcategory or category. Limitations based on transfer
of a technology have to be supported by a conclusion that the
technology will be capable of achieving the prescribed effluent
limitations guidelines (see Tanners' Council of America v. Train,
540 F.2d 1188 (4th Cir. 1976)). BPT focuses on end-of-pipe
treatment rather than process changes or internal controls,
except where such practices are common to the industry.
The cost-benefit inquiry for BPT is a limited balancing, com-
mitted to EPA's discretion, that does not require the Agency to
quantify benefits in monetary terms. See American Iron and Steel
Institute v. EPA, 526 F.2d 1027 (3rd Cir^ 1975). In balancing
costs in relation to effluent reduction benefits, EPA considers
the volume and nature of existing discharges, the volume and
nature of discharges expected after application of BPT, the
general environmental effects of the pollutants, and the cost and
economic impacts of the required level of pollution control. The
Act does not require or permit consideration of water quality
problems attributable to particular point sources or industries,
or water quality improvements in particular water bodies.
Accordingly, water quality considerations were not the basis for
the final BPT effluent limitations guidelines for the PM&F cate-
gory. See Weyerhaeuser Company v. Costle, 590 F.2d 1011 (D.C.
Cir. 1978).
277
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TECHNICAL APPROACH
The plastics molding and forming category was studied to identify
the manufacturing processes used and to determine the character-
istics of PM&F process waters. Results of that study were used
to subcategorize the PM&F category, to determine the appropriate
type of effluent limitations guidelines for the PM&F category,
and to select model BPT treatment technologies.
Subcategorization. The factors reviewed to determine the sub-
categorization scheme for this category are:
1. Raw materials,
2. Production processes,
3. Products,
4. Size and age of plants,
5. Wastewater characteristics,
6. Water use, and
7. Geographic location of plants.
At proposal, the PM&F category was divided into two subcatego-
ries: (1) contact cooling and heating water subcategory and
(2) cleaning and finishing water" subcategory. In response to
comments, the Agency collected additional sampling data for
finishing waters subsequent to proposal. Using those data and
data from previous sampling episodes, EPA determined that clean-
ing waters and finishing waters have different pollutant charac-
teristics. Cleaning waters have treatable concentrations of
6005, O&G, TSS, COD, TOG, total phenols, phenol, and zinc,
whereas finishing waters only have treatable concentrations of
TSS and three phthalates. Because of these different character-
istics, cleaning water processes and finishing water processes
were placed in separate subcategories for the final rule.
For the purpose of the final regulation, the PM&F category is
divided into three subcategories: (1) contact cooling and heat-
ing water subcategory, (2) cleaning water subcategory, and
(3) finishing water subcategory. Additional information on this
subcategorization scheme is presented in Section V of this docu-
ment.
In making technical assessments of data, reviewing manufacturing
processes, and assessing treatment technology options, both
indirect and direct dischargers were considered as a single group
for each subcategory. An examination of PM&F plants and process-
es did not indicate any process differences based on the type of
discharge, whether it be direct or indirect. Therefore, data
from both direct and indirect dischargers were used to make
technical assessments for BPT for each subcategory.
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Type of Effluent Limitations Guidelines and Standards. The
Agency proposedproduction-basedettluentlimitationsguidelines
and standards for the PM&F category. They were calculated by
multiplying the effluent pollutant concentration by a regulatory
production-normalized flow (i.e., liters discharged per 1,000
kilograms of plastic product produced). After further study and
evaluation, the Agency has determined that production-based
effluent limitations guidelines and standards are not appropriate
for the PM&F category. EPA could not establish production
normalized flows for each subcategory primarily because of the
wide variation in water use by PM&F processes. This variation is
caused by the many different types of materials processed and by
product quality requirements. The amount of water required
depends on the type of material processed and the desired product
quality. In some cases, many different materials are processed
in the same process at the same plant thus making the establish-
ment of a regulatory production normalized flow infeasible. This
is particularly true for "custom" plastics molders and formers.
EPA considered subdividing the PM&F category based on either the
plastic material processed or on product quality to account for
the variability in water use caused by the different plastic
materials thus allowing the establishment of subcategory produc-
tion normalized flows. However, such a subcategorization scheme
would be extremely complex because of the large number of plastic
materials and the combination of plastic materials that are used.
Such an approach is also not feasible because of the "custom"
PM&F plants discussed above.
The effluent limitations guidelines and standards in this final
rule for all three subcategories are mass-based. They are
calculated using the following equation:
Effluent Mass = (Concentration) (Average Process Water
Usage Flow Rate)
The pollutant concentrations are established based on the perfor-
mance of the selected treatment technology. The average process
water usage flow rate is obtained from the permittee for each
process to be regulated. It is defined as the volume of process
water (liters) used per year by a process divided by the number
of days per year the process operates. The volume of water used
is the water that flows through a process and comes in contact
with the plastic product over a period of one year. Figure X-1
indicates where the average process water usage flow rate is
measured.
A one year period was selected to determine the volume of water
used by a process to account for any variation in water use
because of seasonal operations. It also accounts for variation
in the number of days that the plant operates during a year.
279
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If a plant has more than one PM&F process in the same subcate-
gory, the average process water usage flow rate for those pro-
cesses is the sum of the average process water usage flow rate
for each process. This sum is used to calculate the pollutant
mass for the PM&F processes at a plant in the same subcategory.
Using the above equation to calculate effluent pollutant mass
ensures that processes with the same average process water usage
flow rate, whether water is recycled or used on a once-through
basis, have the same mass limitations. If only concentration
limitations were employed, processes that recycle process water
may be penalized because their discharges would likely have
higher concentrations than the concentrations in discharges from
processes that use once-through process water.
Additional Steps. Once the subcategorization scheme and the type
ol:effluentlimitations guidelines and standards were estab-
lished, the following steps were taken as part of the technical
study to develop final BPT effluent limitations guidelines:
1. Select pollutants that would be controlled.
2. Select a treatment technology on which to base the BPT
effluent limitations guidelines.
3. Establish effluent concentration values for the con-
trolled pollutants achievable by the selected BPT.
4. Establish maximum concentration for any one day and
maximum for monthly average concentration based on the
effluent concentrations achievable by the selected BPT
technology.
BPT Model Treatment Technologies
The BPT model treatment technologies were developed from the
control and treatment technologies described in Section VIII.
Factors considered in developing the model BPT treatment technol-
ogies included the characteristics of PM&F process waters, PM&F
process water flow rates, and treatment technologies at PM&F
plants.
The BPT options for each subcategory were selected from the group
of model treatment technologies described below.
Technology 1: Settling and pH Adjustment (if necessary)
Settling is effective in removing insoluble pollutants such as
total suspended solids (TSS) and oil and grease (O&G). However,
dissolved pollutants (e.g., 6005) are not removed by this tech-
nology. Settling is a widely demonstrated technology used to
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treat PM&F process waters. If necessary, pH adjustment is used
to maintain the pH of the effluent within prescribed limits.
Technology 2: Equalization, pH Adjustment (if necessary),
and Package Activated Sludge Plant
This treatment technology consists of flow equalization and pH
adjustment (as needed) followed by treatment in a package acti-
vated sludge plant. Flow equalization provides an influent
wastewater with a relatively constant flow rate and composition.
If necessary, pH adjustment is included to maintain the pH of the
effluent within prescribed limits. The activated sludge technol-
ogy treats dissolved and biodegradable organic compounds in the
process waters. In addition, insoluble pollutants such as TSS
and O&G are removed in the liquid/solids separation processes in
a package activated sludge plant.
Activated sludge treatment is used only at integrated facilities
where PM&F process waters and other wastewaters are combined for
treatment. However, the activated sludge technology is widely
demonstrated in other categories for the treatment of wastewaters
with characteristics similar to the characteristics of PM&F pro-
cess waters. In particular, it has been demonstrated in the
treatment of wastewater generated by processes in the plastics
only subcategory of the organic chemicals, plastics, and
synthetic fibers category.
Technology 3: Zero Discharge by Contract Haul of the Discharge
from a Recycle Unit
Disposal of the discharge from a recycle unit by contract haul
eliminates the discharge of pollutants. Two plants in the PM&F
questionnaire data base currently contract haul cleaning water.
At proposal, recycle was included as part of several treatment
technologies. Recycle reduces the amount of process water that
has to be treated and also may improve the performance of the
treatment technology because technologies usually perform better
with a concentrated wastewater.
The Agency considered recycle with the technologies for the final
PM&F regulation, but rejected it because of the variation in
water use by PM&F processes. That variation is caused by the
different types of plastic materials produced and by product
quality requirements. For example, a "custom" plastics molder
and former may produce a polyurethane product and a polyvinyl
chloride product in the same process. Those products may have
different quality requirements that influence the amount of water
needed to produce each product. The amount of water that could
be recycled also depends on the quality requirements of the
plastic product.
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As mentioned above in the discussion on production-normalized
flows, EPA considered subdividing the PM&F category based on
either the plastic material processed or on product quality to
account for the variability in water use. This approach was
rejected because of its complexity.
Because of the variation in water use by PM&F processes, the
Agency was unable to establish a subcategory recycle percentage
that all processes in a subcategory can meet. For this reason,
recycle was rejected for the final PM&F regulation. Technology 3
was not considered further for this regulation because it was
considered feasible only in conjunction with extensive recycle.
The Agency does not believe it is feasible to contract haul all
of the process water instead of just the discharge from the
recycle unit.
BPT OPTIONS
The BPT options were selected from the model treatment technolo-
gies described above. The applicability of a model treatment
technology to a particular subcategory is based on the character-
istics of process waters generated by processes in the subcate-
gory. The rationale for selection or rejection of each BPT
option is discussed below. In addition, the estimated costs,
pollutant removals, energy requirements, and solid waste genera-
tion rates associated with the selected option for each subcate-
gory are presented.
Contact Cooling and Heating Water Subcategory
There were no conventional pollutants found in treatable concen-
trations in the contact cooling and heating water subcategory
(see Table VI-19). The only pollutant found in treatable con-
centrations in contact cooing and heating waters was bis(2-ethyl-
hexyl) phthalate. Therefore, the Agency did not consider any of
the model treatment technologies as BPT options.
At proposal, Technology 1 (settling and pH adjustment) and Tech-
nology 2 (equalization, pH adjustment, and activated sludge
treatment) were considered as BPT options for this subcategory.
Technology 1 was rejected for the final rule because the sus-
pended solids concentration in the contact cooling and heating
water is very low. Technology 2 was rejected for the final rule
because the BOD5 concentration in contact cooling and heating
water is not high enough to support the activated sludge treat-
ment process.
Contract haul was also included as part of a BPT option consid-
ered at proposal. That option included recycle to reduce the
amount of process water that had to be hauled. As discussed ear-
lier in this section, the Agency has determined that recycle is
283
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no longer appropriate as part of the technology basis for the
effluent limitations guidelines and standards for the PM&F cate-
gory. EPA believes that contract haul of contact cooling and
heating water is not a feasible option unless the amount of pro-
cess water that has to be hauled is reduced through the use of a
recycle unit. For this reason, contract haul of process water
was not considered as a BPT option for the final regulation for
this subcategory.
The Agency considered one BPT option as the basis for the BPT
effluent limitations guidelines for this subcategory. It is:
Option 1: Good Housekeeping Practices
The Agency found during the sampling episodes for this regulation
that good housekeeping practices are employed with contact cool-
ing and heating processes. Lubricating oils and other pollutants
are kept out of the contact cooling and heating water and the
processes that use that type of water are usually used only to
cool or heat plastic materials. For example, in an extrusion
process, the molten plastic material is forced through a dye and
the resulting product is drawn through a water bath for rapid
cooling. The water bath is used 'only to cool the plastic prod-
uct. Consequently, the only opportunity for pollutants to get
into the process water occurs when the plastic material is
cooled.
In this option, the concentration values used to calculate the
final BPT effluent limitations guidelines are based on a statis-
tical evaluation of the pollutant concentrations in the raw pro-
cess waters. This option ensures the continuation of the good
housekeeping practices by limiting the pollutant concentrations
to those that are currently being discharged.
Option Selected. The Agency is promulgating Option 1 as the
modeltechnology basis for BPT effluent limitations guidelines
for the contact cooling and heating water subcategory. The final
BPT effluent limitations guidelines control BOD5, O&G, TSS, and
pH. Appendix D describes how the concentration values promul-
gated in the final regulation for this subcategory were
calculated.
The concentration values in the final rule are multiplied by the
average process water usage flow rate for a contact cooling and
heating water process to obtain the mass of pollutants that can
be discharged. The average process water usage flow rate, dis-
cussed in the previous section, is obtained from the permittee.
There are only minimal pollutant removals for the selected option
and only minimal costs because this option is based on current
284
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practices. The Agency has determined that the effluent reduction
benefits associated with compliance with the BPT effluent limita-
tions guidelines justify the costs.
The Agency has concluded that there will be only a minimal
increase in production of solid wastes caused by the implementa-
tion of the BPT effluent limitations guidelines for this subcate-
gory. There is also little or no increase in electrical energy
usage.
Cleaning Water Subcategory
The conventional pollutants found in treatable concentrations in
cleaning waters are TSS, O&G, 6005, and pH. Therefore, the
Agency only considered model treatment technologies that remove
these pollutants as BPT options for this subcategory.
At proposal, EPA considered BPT options based on recycle and con-
tract haul of the discharge from the recycle unit and recycle
with treatment of the discharge from the recycle unit in a pack-
age activated sludge plant. As discussed earlier, the Agency has
determined that recycle is no longer an appropriate technology
basis for the final effluent limitations guidelines for the PM&F
category. Contract haul of cleaning waters was rejected as a BPT
option for this subcategory for the same reasons it was rejected
for the contact cooling and heating water subcategory.
The Agency identified two options as the basis for the final BPT
effluent limitations guidelines for the cleaning water subcate-
gory. These options are:
Option 1: Settling and pH Adjustment (as needed)
The technology for this option consists of a sedimentation tank
in which the velocity of the process water is reduced so that
solid material can settle by gravitational force. The pH of the
process water is adjusted, if necessary. For the final PM&F
regulation, this option was rejected early because it does not
treat the dissolved pollutants (i.e., 6005) found in treatable
concentrations in cleaning waters.
Option 2: Equalization, pH Adjustment (as needed), and Package
Activated Sludge Plant
The technology for this option consists of an equalization tank
followed by a package activated sludge plant with pH adjustment
(if necessary). This technology treats the 8005, O&G, and TSS
in cleaning waters (see Table VI-19). It also treats the non-
conventional and priority toxic pollutants found in treatable
concentrations in cleaning water. The Option 2 technology is
represented in Figure X-2.
285
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The estimated amounts of pollutants remaining after Option 2 are:
Type of
Pollutant
Conventional
Nonconventional
Priority Toxic
Discharged in
Raw Water -
Direct Dischargers
(kg/yr)
238,800
216,400
237
Remaining After
Option 2 (kg/yr)
21 ,300
79,800
82
The methodology used to calculate the pollutant removals is
presented in Appendix C.
The estimated investment cost and annual pollution control costs
for Option 2 are:
Cost ($ Million, 1984
Dollars)
Option 2
Investment Cost
Annual Pollution Control Costs*
*Includes depreciation and interest.
$6.9
4.4
Detailed information on these costs is presented in Economic
Impact Analysis of Final Effluent Limitations and Standards for
the Plastics Molding and Forming Industry, EPA 440/2-84-025,
December 1984.
Option Selected. The Agency is promulgating Option 2 as the
technology basis for the BPT effluent limitations guidelines for
this subcategory.
Data available to the Agency indicate that where cleaning waters
are treated by biological treatment processes, wastewaters from
other manufacturing processes are commingled with the cleaning
process waters. Therefore, data are not available on the appli-
cation of biological treatment to cleaning waters only. As at
proposal, EPA found that treatment at plants that treat cleaning
waters separately is uniformly inadequate because those plants
indicated on their questionnaires that they use only sedimenta-
tion and oil skimming to treat cleaning water. These technolo-
gies do not remove the dissolved pollutants in the cleaning
waters. Thus, the Agency has determined that the PM&F industry
has uniformly inadequate treatment of process water discharges
resulting from the cleaning processes. Accordingly, the Agency
has relied on the transfer of biological treatment (i.e., the
activated sludge process) from the organic chemicals, plastics,
287
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and synthetic fibers category to establish BPT effluent limita-
tions guidelines for this subcategory. The Agency believes that
such a transfer is appropriate because of the similarities
between the cleaning process waters and the organic chemicals,
plastics, and synthetic fibers category wastewaters.
At proposal, to evaluate the two types of wastewaters, the Agency
conducted a statistical comparison of the raw wastewater conven-
tional pollutant concentrations in PM&F process waters and the
concentrations of those pollutants in raw wastewaters discharged
at plants in the plastics only subcategory in the organic chemi-
cals, plastics, and synthetic fibers category. This comparison
was revised to support the final PM&F rule. After reviewing the
results of the updated analysis, the Agency has concluded that
the raw wastewater conventional pollutant concentrations in PM&F
cleaning waters are neither significantly greater nor more varia-
ble than the raw process water conventional pollutant concentra-
tions in wastewaters discharged by plants in the plastics only
subcategory. This conclusion supports the Agency's determination
that the activated sludge treatment technology can be transferred
from the organic chemicals, plastics, and synthetic fibers
(OCPSF) category and that the technology will treat PM&F cleaning
waters to the same level that it treats OCPSF wastewaters.
Performance data for the activated sludge process were also
transferred from the organic chemicals, plastics, and synthetic
fibers category to the cleaning water subcategory. The trans-
ferred concentration values in the final PM&F regulation are the
same as the concentration values used to calculate the
production-based effluent limitations guidelines for the cleaning
and finishing water subcategory at proposal. Maximum for any one
day and maximum for monthly average concentrations for BOD5,
O&G, and TSS are established by the final PM&F rule. The trans-
fer of both the activated sludge process and performance data for
that process are discussed in more detail in Appendix D. The
Agency believes the toxic pollutants found in treatable concen-
trations in cleaning waters are effectively controlled when the
effluent limitations guidelines for the conventional pollutants
are met.
The Agency estimates that the BPT effluent limitations guidelines
for this subcategory will result in the removal of 217,500 kg/yr
of conventional pollutants, 136,600 kg/yr of nonconventional
pollutants, and 155 kg/yr of priority toxic pollutants from the
process waters. The estimated total investment costs and total
annual costs for the BPT effluent limitations guidelines are $6.9
million and $4.4 million, respectively, in 1984 dollars. The
Agency has determined that the costs are justified by the
effluent reduction benefits.
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The Agency estimates that the implementation of the selected BPT
option for the cleaning water subcategory will result in a net
increase in electrical energy consumption of 4.1 million
kilowatt-hours per year (kw-hr/yr) and a net increase in the
solid waste generation rate of 7,300 metric tons per year
(kkg/yr). The methodologies used to derive these estimates are
discussed in Section IX. The net increase in electrical energy
consumption is significantly less than one percent of the esti-
mated total current energy usage for the PM&F category. The
Agency has concluded that the increased production of solid
wastes (which are not believed to be hazardous) associated with
the selected option for this subcategory will not cause any
significant negative environmental impacts. Therefore, there are
no non-water quality impacts of the BPT effluent limitations
guidelines for this subcategory.
Finishing Water Subcategory
The only conventional pollutant found in treatable concentrations
in finishing waters was TSS. Therefore, the Agency considered
only model treatment technologies that remove that pollutant as
BPT options in this subcategory.
For the proposed PM&F regulation, cleaning water processes and
finishing water processes were in the same subcategory. Subse-
quent to proposal, the Agency established separate subcategories
for cleaning water processes and for finishing water processes.
The activated sludge process on which the proposed BPT effluent
limitations guidelines for the cleaning and finishing water sub-
category were based was not considered for the final BPT effluent
limitations guidelines for the finishing water subcategory
because the BOD5 concentration (i.e., 6 mg/1) in finishing
waters is not high enough to support operation of a biological
process. The Agency identified one BPT option for the final
regulation to treat the pollutants found in treatable concentra-
tions in finishing waters (see Tables VII-2, VII-3, and VII-10).
Option 1: Settling and pH Adjustment (as needed)
The technology for this option consists of a settling tank in
which the velocity of the process water is reduced so that solid
material can settle by gravitational force. The pH of the pro-
cess water is adjusted if necessary. This technology removes
TSS. Refer to Figure X-3 for a schematic of the Option 1
technology.
289
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The estimated amounts of pollutants remaining after Option 1 are:
Discharged in Raw
Process Water - Remaining After
Direct Discharger Option 1
Type of Pollutant (kg/yr)
Conventional 3,630 1,110
Priority Toxic 20 20
The methodology used to calculate the pollutant removals is
presented in Appendix C.
The estimated investment cost and annual pollution controls for
Option 1 are:
Cost (1984 Dollars)
Option 1
Investment Cost $91,000
Annual Pollution Cost* 67,500
* Includes depreciation and interest.
Option Selected. The Agency is promulgating Option 1 as the
technology basis for the BPT effluent limitations guidelines for
this subcategory. This technology is demonstrated for the PM&F
category. Twelve of the plants that treat PM&F process waters
have a settling unit.
The Agency estimates that the BPT effluent limitations guidelines
for this subcategory will result in the removal of 2,520 kg/yr of
conventional pollutants from the process waters. The estimated
total investment cost and total annual cost for the BPT effluent
limitations guidelines are $91,000 and $67,500, respectively, in
1984 dollars. The Agency has determined that the costs are
justified by the effluent reduction benefits.
The Agency estimates that the implementation of the selected BPT
option for the finishing water subcategory will result in a net
increase in electrical energy consumption of 24,000 kw-hr/yr and
a solid waste generation rate of 10 metric tons per year. The
methodologies used to derive these estimates are discussed in
Section IX. The net increase in electrical energy consumption is
significantly less than one percent of the estimated total
current energy usage for the PM&F category. The Agency has con-
cluded that the increased production of solid wastes associated
with the selected option for this subcategory will not cause any
significant negative environmental impacts. As discussed in
Section IX of this document, EPA has determined the solid wastes
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are not expected to be hazardous pursuant to RCRA. There are no
non-water quality impacts of the BPT effluent limitations
guidelines for this subcategory.
REGULATED POLLUTANTS AND POLLUTANT PROPERTIES
Pollutants and pollutant properties selected for control in the
plastics molding and forming category include biochemical oxygen
demand (6005), oil and grease (O&G), total suspended solids
(TSS), and pH.
Biochemical oxygen demand was found in cleaning waters at con-
centrations up to 1 ,000 mg/1. BOD5 is used to estimate the
organic content of wastewater. BODjj is also an important con-
trol parameter for the activated sludge treatment process; the
reduction of BOD5 indicates an overall reduction of organic
pollutants.
Total suspended solids was found in cleaning waters at concentra-
tions up to 16,363 mg/1. It was found in finishing waters at
concentrations up to 1,359 mg/1.
Oil and grease was detected in cleaning waters at concentrations
up to 684 mg/1.
For protection of aquatic life and human welfare, pH of waste-
water should be between 6.0 and 9.0. The pH of PM&F process
waters is regulated because the pH of contact cooling and heating
waters ranged between 5.4 and 8.3 and the pH of cleaning water
ranged from 1.6 to 11.5. The pH of finishing water ranged from
6.4 to 8.4.
The Agency is establishing BPT effluent limitations guidelines
for BOD5, TSS, O&G, and pH in two subcategories and for TSS and
pH in the other subcategory. The Agency estimates that when
these limitations are met, approximately 63 percent of the amount
of treatable nonconventional pollutants discharged by PM&F pro-
cesses and approximately 65 percent of the amount of treatable
priority toxic pollutants discharged will be removed. These
estimates are based on removal percentages reported in the
literature and previous EPA studies for the nonconventional and
priority toxic pollutants. The nonconventional and priority
toxic pollutants in PM&F process waters are listed in Tables
VII-3 and VII-10, respectively.
EFFLUENT CONCENTRATION VALUES
Contact Cooling and Heating Water Subcategory. For the contact
cooling and heating water subcategory,the concentrations used to
calculate the mass of pollutants that can be discharged are based
292
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on a statistical evaluation of the raw waste concentrations in
contact cooling and heating waters. Maximum for any one day con-
centrations were established for 8005, O&G, and TSS. pH is
also controlled for this subcategory. Maximum for monthly aver-
age concentrations were not established for this subcategory
because there is no variability associated with the performance
of a treatment technology. The maximum for any one day values
are based on the concentrations currently discharged and are pre-
sented in Table X-1. A discussion of the statistical evaluation
of the contact cooling and heating water raw waste concentrations
is presented in Appendix D.
Cleaning Water Subcategory. A package activated sludge plant is
theend-of-pipetreatment technology selected as BPT for the
cleaning water subcategory. The activated sludge process and
performance data for that process were transferred from the
organic chemicals, plastics, and synthetic fibers (OCPSF) cate-
gory because wastewater generated by processes in that category
and PM&F cleaning waters have similar conventional pollutant
characteristics.
The transfer of the activated sludge process was evaluated by
comparing the sampling data for cleaning waters obtained during
the sampling program for this regulation to process wastewater
data from the organic chemicals, plastics, and synthetic fibers
category, particularly the plastics only subcategory. That
comparison showed that the wastewaters for the cleaning water
subcategory and for the OCPSF category have similar characteris-
tics. Specifically, data on raw waste concentrations of BOD5,
TSS, and O&G were examined statistically. A detailed report on
the statistical analysis is presented in Appendix D. Results of
that analysis show that the concentrations for these pollutants
in PM&F cleaning waters are neither significantly greater nor
more variable than the concentrations of those pollutants in
wastewaters generated by processes at plants that manufacture
plastics. This supports the Agency's technical judgment that the
activated sludge process will treat PM&F cleaning waters effec-
tively and achieve the conventional pollutant effluent concentra-
tions achieved by activated sludge processes that treat waste-
water generated by processes at plastics manufacturing plants in
the OCPSF category. The Agency's judgment that the activated
sludge process will treat PM&F cleaning waters was based on the
literature and knowledge of the performance of the activated
sludge process.
Thus, the Agency transferred the activated sludge technology and
effluent data for that technology from the OCPSF category to the
PM&F cleaning water subcategory. Effluent concentration values
were transferred for BOD5, TSS, and O&G. These values are
presented in Table X-1.
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Table X-1
EFFLUENT CONCENTRATIONS USED TO CALCULATE THE FINAL
BPT EFFLUENT LIMITATIONS GUIDELINES
Contact Cooling and Heating Water Subcategory
Pollutant
BOD5
Oil and Grease
TSS
pH
Maximum for
Any One Day (mg/1)
26
29
19
(D
Maximum for
Monthly Average (mg/1)
(2)
(2)
(2)
(D
Cleaning Water Subcategory
Pollutant
BOD5
Oil and Grease
TSS
PH
Maximum for
Any One Day (mg/1)*
49
71
117
(D
Maximum for
Monthly Average (mg/1)*
22
17
36
(D
Pollutant
TSS
PH
Finishing Water Subcategory
Maximum for
Any One Day (mg/1)
130
(D
Maximum for
Monthly Average (mg/1)
37
(D
0)Within the range 6.0 to 9.0 at all times.
(2)Not established for this subcategory.
*Transferred from the OCPSF category.
294
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Finishing Water Subcategory. The effluent concentrations for TSS
for the finishing water subcategory were obtained by multiplying
the subcategory average TSS concentration by a percent removal to
obtain a long-term average concentration. Variability factors
were then applied to the long-term average to obtain the maximum
for any one day and maximum for monthly average concentration
values. Calculation of both the variability factors and the
concentration values is discussed in more detail in Appendix D.
The TSS concentrations used to calculate the final BPT effluent
limitations guidelines for the finishing water subcategory are
presented in Table X-1.
BPT EFFLUENT LIMITATIONS GUIDELINES
BPT effluent limitations guidelines are calculated by multiplying
the pollutant concentrations promulgated in the final PM&F regu-
lation by the average process water usage flow rate for a pro-
cess, which is obtained from a permittee. The maximum for any
one day and maximum for monthly average concentrations used to
calculate the final BPT effluent limitations guidelines are
presented in Table X-1.
EXAMPLE OF THE APPLICATION OF THE BPT EFFLUENT LIMITATIONS
GUIDELINES
The purpose of the BPT effluent limitations guidelines is to pro-
vide a uniform basis for regulating process water discharged from
processes in the plastics molding and forming category. For
direct dischargers, this is accomplished through NPDES permits.
The plastics molding and forming category is regulated on an
individual wastewater flow "building block" approach. An example
that illustrates how the effluent limitations guidelines are used
to determine the amount of pollutants that can be discharged from
plastics molding and forming plants is presented below.
Example
Plant X is a hypothetical plastics molder and former that is
classified as a direct discharger. Plant X, which operates for
eight hours a day, 250 days per year, compounds and pelletizes
1,250,000 kg of polyethylene per year. The pelletizing process
uses contact cooling water. A portion of the pelletized product
is extruded in a process that also uses contact cooling water.
The average process water usage flow rates for both these pro-
cesses are 118,100 I/day (65 gpm) and 36,400 I/day (20 gpm) ,
respectively.
In addition, Plant X cleans injection molds; the molds are used
to shape polyethylene products. The average process usage flow
rate for the cleaning water process is 16,350 I/day (3 gpm). The
295
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shaped polyethylene is then trimmed in a finishing operation that
uses an average of 1,900 I/day (0.34 gpm) of finishing water.
Only de minimus levels of BOD5 and oil and grease are present
in the finishing water from this operation.
Based on this information, the allowable masses of pollutants
that can be discharged by Plant X under the final BPT regulation
are determined as follows. Plant X has processes that belong to
each of the three PM&F subcategories. The two contact cooling
processes are regulated under the contact cooling and heating
water subcategory, the injection mold cleaning process is regu-
lated under the cleaning water subcategory, and the trimming
process is regulated under the finishing water subcategory.
The mass of BOD^ that may be discharged from PM&F processes at
Plant X is calculated as follows:
1. The total average process water usage flow rate for the
contact cooling and heating water process is the sum of
the reported average process water usage flow rates.
For Plant X, this is equal to 118,100 I/day plus 36,400
I/day, or a total of 154,500 I/day.
2. From Table X-1, the maximum for any one day concentra-
tion value for BOD5 is 26 mg/1.
3. Multiplying the effluent concentration (26 mg/1) by the
average process water flow rate (154,500 I/day) results
in the maximum for any one day mass of 4,017,000 mg/day
(8.9 Ibs/day) of BOD5 that may be discharged from the
contact cooling and heating water processes.
4. Using these calculation procedures (steps 1-3) for the
cleaning water process results in the corresponding
maximum for any one day BOD5 discharge of 801,500
mg/day (1.8 Ibs/day). The BOD5 discharge from the
finishing water is not considered because BODs is not
regulated in the finishing water subcategory and only de
minimus levels of BOD5 were reported in the finishing
water by the permittee.
5. The total maximum for any one day discharge for BOD5
for Plant X is the sum of 4,017,000 mg/day (from contac
cooling water) and 801,150 mg/day (from cleaning water),
or 4,818,150 mg/day (10.6 Ibs/day).
Table X-2 illustrates the calculation of the maximum for any one
day mass of pollutants that can be discharged for Plant X. Maxi-
mum for monthly average mass discharges are calculated in a
similar manner.
296
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SECTION XI
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
INTRODUCTION
This section defines the effluent limitations guidelines based on
the performance of the best available technology economically
achievable (BAT) pursuant to Section 304(b)(2)(B) of the Clean
Water Act. BAT effluent limitations guidelines are applicable to
process waters that are directly discharged by existing sources.
The factors considered in assessing BAT include the total cost of
applying the technology in relation to the amount of pollutant
removal, age of equipment and facilities involved, the process
employed, process changes, non-water quality environmental
impacts (including energy requirements) and the costs of applying
such technology. At a minimum, the BAT level represents the best
economically achievable performance of plants of various ages,
sizes, processes, or other shared characteristics. As with BPT,
where the Agency has found the existing treatment performance to
be uniformly inadequate, BAT may be transferred from a different
subcategory or category. BAT may include feasible process
changes or internal controls even when not common industry
practice.
The required assessment of BAT "considers" costs, but does not
require a balancing of costs against effluent reduction benefits
(see, Weyerhaeuser v. Costle, supra). In developing BAT, how-
ever, EPA gives substantial weight to the reasonableness of cost.
The Agency considers the volume and nature of discharges expected
after application of BPT, the general environmental effects of
the pollutants, and the costs and economic impacts of the
additional pollution control levels.
Despite this expanded consideration of costs, the primary deter-
minant of BAT is effluent reduction capability. As a result of
the Clean Water Act of 1977, the achievement of BAT effluent
limitations guidelines has become the principal national means of
controlling toxic pollutants. Process waters generated by PM&F
processes contain five priority toxic pollutants in treatable
concentrations including one toxic metal and four toxic organics.
IDENTIFICATION OF THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE
Contact Cooling and Heating Water Subcategory
The only toxic pollutant found in treatable concentrations in
contact cooling and heating waters was bis(2-ethylhexyl) phthal-
ate. It was found in treatable concentrations in 12 out of 16
299
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processes sampled (52.6 percent of the samples analyzed) ranging
from 0.011 to 1.72 mg/1. Therefore, only BAT options that remove
that pollutant were considered for the final PM&F regulation.
At proposal, EPA considered a package activated sludge plant as a
BAT option for this subcategory. This option was not considered
for the final rule because the BOD5 concentrations in contact
cooling and heating waters are not high enough to support the
operation of biological treatment.
Contract haul was also a BAT option for this subcategory at pro-
posal. That option included recycle to reduce the amount of pro-
cess water that had to be hauled. As discussed earlier, the
Agency has determined that recycle is no longer appropriate as
part of the technology basis for the effluent limitations guide-
lines and standards for the PM&F category. EPA believes that
contract haul is not a feasible option unless the amount of pro-
cess water that has to be hauled is reduced through the use of a
recycle unit. For this reason, contract haul was not considered
as a BAT option for the final regulation for this subcategory.
The Agency considered one option as the basis for the BAT
effluent limitations guidelines in this subcategory. It is:
Option 1 : pH Adjustment (as needed) and Activated Carbon
Adsorption
The model treatment technology in Option 1 is the only technology
EPA could identify to remove the bis(2-ethylhexyl) phthalate in
contact cooling and heating water. Enough activated carbon was
included in the design of that process to remove the phthalate to
a level equal to its treatability limit (see Table VII-9). The
technology for this option is shown in Figure XI-1.
The estimated amount of bis(2-ethylhexyl) phthalate discharged in
contact cooling and heating water is 9,470 kg/yr. After appli-
cation of the model treatment technology in Option 1, the Agency
estimates that 8,500 kg/yr of this phthalate will be removed.
The estimated investment costs and annual pollution control costs
for Option 1 are $34,000,000 and $13,000,000, respectively, in
1984 dollars. Detailed information on these costs is presented
in Economic Impact Analysis of Effluent Limitations and Standards
for the Plastics Molding and Forming Industry,EPA 440/2-84-025,
December 1984.
Option Selected. The Agency is not selecting Option 1 as the
basisfor the final BAT effluent limitations guidelines for this
subcategory at this time because EPA has no treatability data for
the activated carbon process. The Agency plans to conduct
further studies to obtain these data.
300
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As part of the treatability study, EPA will collect samples at
contact cooling and heating water processes. The Agency will
then conduct bench-scale studies to select the type of activated
carbon to use to treat contact cooling and heating water and to
determine the carbon exhaustion rates. Once carbon exhaustion
rates are known, EPA can design and cost the activated carbon
processes for the treatment of contact cooling and heating water.
Because of the lack of performance data for the treatment of
phthalates in the activated carbon process, EPA is reserving the
BAT effluent limitations for bis(2-ethylhexyl) phthalate for this
subcategory at this time. When the treatability study discussed
above is completed, the Agency will propose and promulgate the
BAT effluent limitations guidelines for the phthalate.
The Agency is promulgating BAT equal to BPT for the other prior-
ity toxic pollutants because bis(2-ethylhexyl) phthalate is the
only toxic pollutant found in treatable concentrations in contact
cooling and heating waters. Therefore, except for bis(2-ethyl-
hexyl) phthalate, the BAT effluent limitations guidelines are the
same as the BPT effluent limitations guidelines for this subcate-
gory. EPA has determined that the BAT/BPT effluent limitations
guidelines for this subcategory are economically achievable.
There are no net increases in energy usage or solid waste genera-
tion for BAT compared to BPT for the contact cooling and heating
water subcategory because, at this time, the Agency is not prom-
ulgating BAT effluent limitations guidelines more stringent than
the BPT effluent limitations guidelines for this subcategory.
Cleaning Water Subcategory
The Agency only considered one option for BAT for this subcate-
gory. This option, which is the selected BPT, is:
Option 1: Equalization, pH Adjustment, and Package Activated
Sludge Plant
At proposal, the Agency considered recycle and contract haul of
the discharge from the recycle unit as a BAT option. This option
was rejected for this subcategory for the final regulation for
the same reasons it was rejected in the contact cooling and
heating water subcategory.
The Agency is not promulgating BAT effluent limitations guide-
lines more stringent than the BPT effluent limitations guidelines
for this subcategory because there are insignificant quantities
of priority toxic pollutants remaining in cleaning waters after
application of BPT. The Agency estimates that 155 kg/yr of the
302
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toxic pollutants (I.e., phenol and zinc) discharged in cleaning
waters in treatable concentrations will be removed after compli-
ance with the BPT effluent limitations guidelines. Thus, 82
kg/yr would be discharged after application of BPT. This is
equal to less than 0.01 kg/day of toxic pollutants discharged per
direct discharger. Table C-4 in Appendix C lists the estimated
amount of phenol and zinc that would be discharged per year by
direct dischargers in this subcategory after compliance with the
BPT effluent limitations guidelines. Also shown on Table C-3 is
the average concentration of toxic pollutants after application
of BPT. The Agency has determined that the toxic pollutants are
adequately controlled by the BPT effluent limitations guidelines
and the amount and toxicity of those pollutants after application
of BPT do not justify establishing more stringent BAT effluent
limitations guidelines for toxic pollutants for this subcategory.
Accordingly, EPA is excluding the toxic pollutants phenol and
zinc from further national regulation for this subcategory, under
Paragraph 8(a)(i) of the Settlement Agreement in NRDC v. Train,
supra.
There are no net inc. jases in energy usage or solid waste genera-
tion for BAT compared with BPT for the cleaning water subcategory
because the Agency is not promulgating BAT effluent limitations
guidelines more stringent than BPT effluent limitations guide-
lines for this subcategory. EPA has determined that the BAT/BPT
effluent limitations guidelines for this subcategory are
economically achievable.
Finishing Water Subcategory
Three toxic pollutants were found in finishing waters in treata-
ble concentrations. Bis(2-ethylhexyl) phthalate was found in
treatable concentrations in two of three sampled finishing pro-
cesses (55.6 percent of the samples analyzed) ranging from 0.011
mg/1 to 1.488 mg/1. Di-n-butyl phthalate was found in treatable
concentrations in one of three sampled finishing processes (33.3
percent of the samples analyzed) ranging from 0.038 mg/1 to 0.081
mg/1; dimethyl phthalate was found in treatable concentrations in
one of three sampled finishing processes (11.1 percent of the
samples analyzed) at 0.194 mg/1. Therefore, for this final regu-
lation, only BAT options that remove bis(2-ethylhexyl) phthalate,
di-n-butyl phthalate, and dimethyl phthalate were considered.
At proposal, cleaning water processes and finishing water pro-
cesses were in the same subcategory. Subsequent to proposal,
those processes were placed in separate subcategories.
The BAT options considered at proposal for the cleaning and
finishing water subcategory were considered for the finishing
water subcategory in this final regulation. Recycle and contract
303
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haul of the discharge from the recycle unit was rejected for this
subcategory for the same reasons it was rejected for the cleaning
water subcategory. Recycle and treatment of the discharge from
the recycle unit in a package activated sludge plant with pH
adjustment was also rejected for this subcategory because the
BOD5 concentrations in finishing waters are not high enough to
support the operation of a biological process.
The Agency considered one option as the basis for the BAT
effluent limitations guidelines for this subcategory.
Option 1: pH Adjustment (as needed), Settling, and Activated
Carbon Adsorption
The model treatment technology in Option 1 is the only technology
EPA could identify to remove the phthalates in finishing waters.
Enough activated carbon was included in the design of that pro-
cess to remove the phthalates to a level equal to their treata-
bility limits (see Table VII-9). The settling unit, which is the
selected BPT, removes the TSS in the process water prior to
treatment of the process water in the activated carbon process.
The model treatment technology for this option is depicted in
Figure XI-2.
The estimated amounts of pollutant remaining after Option 1 are:
Pollutant Mass
In Raw Removed - Remaining
Wastewater Option 1 After Option 1
Pollutant (kg/yr) (kg/yr) (kg/yr)
Conventional 3,630 2,938 692
Priority Toxic 20 18.5 1.5
The estimated investment costs and annual pollution control cost
for Option 1 are $311,000 and $162,000, respectively, in 1984
dollars.
Option Selected. The Agency is not selecting Option 1 as the
basisfortheFinal BAT effluent limitations for this subcategory
at this time because EPA has no treatability data for phthalates
for the activated carbon process. As mentioned in the discussion
for the contact cooling and heating water subcategory, the Agency
plans to conduct further studies to obtain these data. These
studies will address the phthalates in both contact cooling and
heating waters and in finishing waters.
Because of the lack of performance data for the treatment of
phthalates in the activated carbon process, EPA is reserving the
304
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BAT effluent limitations guidelines for bis(2-ethylhexyl) phthal-
ate, di-n-butyl phthalate, and dimethyl phthalate for this sub-
category at this time. When the treatability study for phthal-
ates is completed, the Agency will propose and promulgate the BAT
effluent limitations guidelines for the phthalates.
The Agency is promulgating BAT equal to BPT for the other toxic
pollutants because, except for the three phthalates, there are no
toxic pollutants found in treatable concentrations in finishing
waters. With the exception of the three phthalates listed above,
the BAT effluent limitations guidelines are the same as the BPT
effluent limitations guidelines for this subcategory. EPA has
determined that the BAT/BPT effluent limitations guidelines for
this subcategory are economically achievable.
There are no net increases in energy usage or solid waste genera-
tion for BAT compared to BPT for the finishing water subcategory
because, at this time, the Agency is not promulgating BAT efflu-
ent limitations guidelines more stringent than the BPT effluent
limitations guidelines for this subcategory.
306
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SECTION XII
NEW SOURCE PERFORMANCE STANDARDS
INTRODUCTION
This section discusses new source performance standards (NSPS)
for PM&F processes at new sources that discharge directly to
navigable waters. New sources are defined as any building,
structure, facility, or installation (including major modifica-
tions to existing sources) for which construction is started
after promulgation of NSPS for the PM&F category.
The basis for NSPS under Section 306 of the Act is the best
available demonstrated technology. New plants have the opportun-
ity to design and use the best and most efficient plastics mold-
ing and forming processes and wastewater treatment technologies
without facing the added costs and restrictions encountered in
retrofitting an existing plant. Therefore, Congress directed EPA
to consider the best demonstrated process changes, in-plant con-
trols, and end-of-pipe treatment technologies that reduce pollu-
tion to the maximum extent feasible when developing NSPS.
TECHNICAL APPROACH TO NSPS
The Agency believes that characteristics of process waters dis-
charged by new PM&F processes in each subcategory will be the
same as the characteristics of process waters discharged by
existing PM&F processes in those subcategories. Thus, the
options considered for NSPS are the same as those considered for
the BPT/BAT effluent limitations guidelines for each subcategory.
These options are discussed in the BPT and BAT sections of this
development document (Sections X and XI, respectively). The
pollutants found in treatable concentrations in the process
waters for each subcategory and their concentrations are
presented in Tables VII-1, VII-3, and VII-10.
NSPS OPTION SELECTION
Except for phthalates in two subcategories, the Agency is promul-
gating NSPS based on the model treatment technologies selected as
the basis for the BPT/BAT effluent limitations guidelines. EPA
is not promulgating NSPS more stringent than the effluent limita-
tions guidelines for existing sources at this time because either
the amount and toxicity of the priority toxic pollutants remain-
ing after application of the BPT/BAT model technologies do not
justify more stringent controls or there are no toxic pollutants
in treatable concentrations in the process waters. The mass of
priority toxic pollutants remaining and their effluent
307
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concentrations after application of BPT/BAT are presented in
Tables C-3 and C-5 for the cleaning water subcategory and Tables
C-7 and C-10 for the finishing water subcategory, respectively.
Except for one phthalate, there are no priority toxic pollutants
in treatable concentrations in contact cooling and heating
process waters.
EPA is reserving NSPS for bis(2-ethylhexyl) phthalate for the
contact cooling and heating water subcategory pending completion
of the phthalate treatability study discussed in Section XI of
this development document. NSPS for bis(2-ethylhexyl) phthalate,
di-n-butyl phthalate, and dimethyl phthalate are also reserved
for the finishing water subcategory until the treatability study
is completed. When that study is completed, EPA will propose and
promulgate NSPS for the phthalates.
The technology basis for NSPS for each subcategory is:
Contact Cooling and Heating Water Subcategory
NSPS for this subcategory are based on good housekeeping
practices. As discussed earlier, EPA found during the sampling
episodes for development of the PM&F regulation that good house-
keeping practices are employed with contact cooling and heating
water processes. Lubricating oils and other pollutants are kept
out of the contact cooling and heating waters and those waters
are used only for plastics molding and forming. Good housekeep-
ing practices are the basis for the NSPS for this subcategory
because, except for one phthalate, there are no pollutants in
contact cooling and heating wasters in treatable concentrations.
NSPS ensure that good housekeeping practices will be employed at
plants using new contact cooling and heating water processes
because they are based on the current concentrations of pollu-
tants discharged at existing sources where good housekeeping is
practiced.
NSPS for this subcategory control BOD5, O&G, TSS, and pH.
Results of the statistical evaluation used to establish concen-
tration values for those pollutants are presented in Appendix D.
NSPS for bis(2-ethylhexyl) phthalate for this subcategory are
reserved pending completion of the phthalate treatability study.
Cleaning Water Subcategory
The model treatment technology for NSPS for this subcategory con-
sists of equalization, pH adjustment (as needed), and a package
activated sludge plant. A schematic of the model treatment tech-
nology for NSPS for the cleaning water subcategory is presented
in Figure XII-1. NSPS for this subcategory control 6005, O&G,
TSS, and pH.
308
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The Agency considered a model treatment technology for NSPS for
this subcategory that included a package activated sludge plant
followed by a filter. However, EPA did not propose NSPS based on
this more stringent technology and the Agency has no performance
data using that technology for the treatment of cleaning water
only. Also, EPA did not receive any comments on the proposed
PM&F regulation suggesting that a filter should be included in
the model technology for NSPS. This may be because, based on the
"normal" plant for this subcategory discussed later in this sec-
tion, the Agency estimates that 2,180 kg/yr of conventional pol-
lutants would be removed by the activated sludge process followed
by a filter (see Appendix C). This is only 80 kg/yr or 0.32
kg/day per direct discharging new source more than would be
removed by a package activated sludge plant without a filter.
There are no additional nonconventional and priority toxic
pollutant removals by filtration, because these pollutants are
dissolved, not suspended. For these reasons, EPA is not includ-
ing a filter in the NSPS model technology for this subcategory at
this time. However, after further study of the filtration tech-
nology for the best conventional pollutant control technology
(BCT) effluent limitations guidelines for this subcategory, if
the Agency finds that additional conventional pollutant removals
based on the application of a filter are justified, EPA may
revise NSPS for this subcategory using a model treatment technol-
ogy that consists of a package activated sludge plant with pH
adjustment and a filter.
Finishing Water Subcategory
The model treatment technology for NSPS for this subcategory
consists of pH adjustment (if necessary) and settling. A
schematic of this model treatment technology for the finishing
water subcategory is presented in Figure XII-2. NSPS for this
subcategory control TSS and pH.
NSPS for bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and
dimethyl phthalate for this subcategory are reserved pending com-
pletion of the phthalate treatability study discussed in Section
XI. The phthalates were the only toxic pollutants found in
treatable concentrations in finishing waters.
The Agency considered a model treatment technology for NSPS for
this subcategory that included pH adjustment, settling, and
filtration. However, EPA did not propose NSPS based on this more
stringent technology and the Agency has only limited performance
data using this model treatment technology to treat finishing
waters only. Also, EPA did not receive any comments on the
proposed PM&F regulation suggesting that a filter should be
included in the model treatment technology for NSPS (cleaning
water processes and finishing water processes were in the same
subcategory at proposal). This may be because, based on the
310
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"normal" plant for this subcategory discussed later in this
section, the Agency estimates that 318 kg/yr of conventional
pollutants would be removed by a settling unit followed by a
filter (see Appendix C). This is only 66 kg/yr or 0.26 kg/day per
direct discharging new source more than would be removed by a
settling unit. For these reasons, EPA is not using a filter as
with the model treatment technology for NSPS for this subcategory
at this time. However, after further study of the filtration
technology for the BCT effluent limitations guidelines for this
subcategory, if the Agency finds that additional conventional
pollutant removals based on the application of a filter are
justified, EPA may revise NSPS for this subcategory using
filtration as part of the model treatment technology.
COSTS AND POLLUTANT REMOVALS FOR NSPS
The Agency conducted an economic analysis of the impact of the
final NSPS on new PM&F plants. The analysis was based on a
"normal" plant for each subcategory. A "normal" plant for a sub-
category is a theoretical model plant that has one molding and
forming process covered by the subcategory whose production,
wastewater characteristics, and financial profile are typical of
existing plants.
The process flow rates for the PM&F process in a "normal" plant
are assumed to be the median values for plants in the question-
naire data base for a subcategory. The pollutant concentrations
in the process waters discharged from the PM&F process at a
"normal" plant are assumed to be equal to the subcategory average
pollutant concentrations. Each "normal" plant is also assumed to
operate 6,000 hours/year (24 hours/day for 250 days/year).
Process flow rates and pollutant concentrations assumed for the
"normal" plant in each subcategory are presented in Table XII-1.
The pollutant masses in the PM&F process waters for the "normal"
plants are shown in Table XI1-2. The pollutant removals for the
NSPS model treatment technology for each "normal" plant are
presented in Table XII-3. Data for the model treatment technolo-
gies used as the basis for the effluent limitations guidelines
for existing sources were used to estimate the removals presented
in Table XII-3.
The estimated investment cost and annual pollution control costs
for the NSPS model treatment technology for each subcategory are
presented in Table XII-4.
Data relied on for the economic analysis of NSPS were primarily
data developed for existing sources, which include costs on a
plant-by-plant basis along with retrofit costs where applicable.
The Agency believes that costs could be lower for new sources
312
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Table XII-2
POLLUTANT MASS IN PROCESS WATERS FOR NSPS "NORMAL" PLANT
(kg/yr)
Contact Cooling Cleaning Finishing
and Heating Water Water
Pollutant Water Subcategory Subcategory Subcategory
Conventional * 2,293 363
Nonconventional * 2,079 *
Priority Toxic 13.6 2.3 2.1
*Pollutants not found in treatable concentrations in process
waters.
314
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Table XII-3
ESTIMATED POLLUTANT REMOVALS FOR PM&F NSPS MODEL
TREATMENT TECHNOLOGY (kg/yr)
Contact Cooling Cleaning Finishing
and Heating Water Water
Pollutant Water Subcategory* Subcategory Subcategory
Conventional 0 2,094 252
Nonconventional 0 1,314 0
Priority Toxic 0 1.50
*Minimal removals for this Subcategory because NSPS are based on
good housekeeping practices instead of performance of a treat-
ment technology.
315
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Table XII-4
ESTIMATED COSTS OF NSPS MODEL TREATMENT TECHNOLOGY
FOR PM&F "NORMAL" PLANTS
($, 1984 Dollars)
Contact Cooling Cleaning Finishing
and Heating Water Water
Water Subcategory Subcategory Subcategory
Investment Cost 0 $267,000 $9,100
Annual Pollution 0 $ 83,000 $6,800
Control Costs
316
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than costs for equivalent existing sources because production
processes could be designed to reduce the amount of process water
discharged and there would be no costs associated with retrofit-
ting a process. The Agency does not believe that applying the
model treatment technology for NSPS to new sources, including
major modifications to existing sources, creates a barrier to
entry into the PM&F category because new sources will expend an
amount equal to, or possibly less than, the amount required by
existing sources to comply with the final PM&F regulation.
REGULATED POLLUTANTS AND POLLUTANT PROPERTIES
The Agency has no"reason to believe that the pollutants found in
treatable concentrations in PM&F process waters from new sources
will be any different than pollutants found in process waters
from existing sources. Consequently, pollutants selected for
regulation under NSPS are the pollutants controlled at BPT for
each subcategory. They are: BODtj, O&G, TSS, and pH in the
contact cooling and heating water subcategory and in the cleaning
water subcategory and TSS and pH in the finishing water subcate-
gory. The effluent concentrations promulgated for NSPS are the
same as those presented in Table X-1 . Those values are multi-
plied by the average process water usage flow rate obtained from
the permittee to obtain the mass of pollutants that can be dis-
charged. The Agency estimates that, except for phthalates, 63
percent of the treatable nonconventional pollutant mass and 65
percent of the treatable priority toxic pollutant mass are
removed when the NSPS for the conventional pollutants are met.
NSPS for phthalates are reserved in two subcategories.
NEW SOURCE PERFORMANCE STANDARDS
The effluent concentration values used by a permit writer or con-
trol authority to calculate the mass of a pollutant that can be
discharged are the same as those used to calculate the BPT efflu-
ent limitations guidelines. These concentration values are dis-
cussed in more detail in Section X of this development document.
The concentration values for NSPS (see Table X-1) are multiplied
by the average process water usage flow rate to obtain the mass
of pollutants discharged. Calculation of the effluent concentra-
tion values presented in Table X-1 is addressed in Appendix D.
The example presented in Section X, which illustrates the appli-
cation of the BPT effluent limitations guidelines, is also rele-
vant to the application of the NSPS for each subcategory for the
final regulation.
317
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NON-WATER QUALITY IMPACTS
A. Air Pollution
Model treatment technologies for NSPS will settle or biologically
oxidize pollutants found in PM&F process waters. Emissions from
these technologies are not expected to cause air pollution prob-
lems. Accordingly, NSPS will not create any substantial air pol-
lution problem.
B. Solid Waste
EPA believes that the amount of solid wastes generated by a new
source will be approximately the same as the amount generated by
an equal-sized existing source at BPT. Therefore, for equal-
sized facilities, the estimated annual average plant production
of solid wastes generated in compliance with NSPS would be about
the same as the annual average plant production for BPT. EPA
projects that this would be about 40 metric tons per year per new
source in the cleaning water subcategory and about 10 metric tons
per year per new source in the finishing water subcategory. EPA
anticipates that only minimal quantities of solid wastes would be
generated at new sources in the contact cooling and heating water
subcategory because of the characteristically low levels of TSS
in process water discharges from existing sources in this sub-
category. The assumptions used for estimating solid waste
generation rates are presented in Section IX.
In addition, it is the Agency's view that solid wastes generated
by new sources as a result of these guidelines are not expected
to be classified as hazardous. This conclusion is based on the
results of extraction procedure (EP) toxicity tests discussed in
Section IX.
C. Consumptive Water Loss
The model treatment technologies for NSPS are not expected to
cause a water loss. Therefore, NSPS are not expected to result
in a consumptive water loss.
D. Energy Requirements
EPA believes that the energy used by a new direct discharging
plant to comply with NSPS will be approximately the same amount
as that used by an equal-sized existing source at BPT. There-
fore, for equal-sized plants, the estimated annual plant energy
use for NSPS would be about the same as the annual average energy
use for BPT. EPA projects that this would be about 83,000
kw-hr/yr per new source in the cleaning water subcategory and
about 2,400 kw-hr/yr per new source in the finishing water
318
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subcategory. EPA anticipates that only minimal quantities of
energy will be required at new sources in the contact cooling and
heating water subcategory because the technology basis of NSPS
(the application of good housekeeping practices) would not
involve the use of significant levels of energy. The assumptions
used for estimating energy requirements are presented in Section
IX.
These uses do not significantly add to the total energy consump-
tion for the PM&F category. The Agency concludes that any
increased energy use to comply with the NSPS is insignificant and
that effluent reduction benefits outweigh the increased energy
use.
319
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SECTION XIII
PRETREATMENT STANDARDS
This section addresses pretreatment standards for existing
sources (PSES) and pretreatment standards for new sources (PSNS).
PSES and PSNS are applicable to PM&F process waters that are
indirectly discharged (i.e., discharged to a POTW), pursuant to
in Sections 307(b) and 307(c) of the Clean Water Act.
The Federal Water Pollution Control Act of 1972 stated that pre-
treatment standards shall prevent the discharge of any pollutant
that may interfere with, pass through, or otherwise be incompat-
ible with a POTW. The Clean Water Act of 1977 further stipulated
that industrial discharges also must not interfere with the use
and disposal of municipal sludges. The General Pretreatment
Regulations for existing and new sources originally were pub-
lished in the Federal Register (Vol. 43, No. 123; June 26, 1978)
and can be found at 40 CFR Part 403. These regulations provide
the general framework for categorical pretreatraent standards.
They describe the Agency's overall policy for establishing and
enforcing categorical pretreatment standards for new and existing
industrial dischargers and delineate the responsibilities and
deadlines applicable to each party involved, including POTWs,
States, and the involved industries. In cases where categorical
pretreatment standards are not established because the Agency has
determined that they are not warranted, indirect dischargers must
still comply with the General Pretreatment Regulations - 40 CFR
Part 403.
The remainder of this section describes the technical approach to
developing PSES/PSNS for the PM&F category.
TECHNICAL APPROACH
The Agency examined the need for pretreatment standards in each
of the PM&F subcategories. Specifically, the Agency considered
whether the toxic pollutants discharged by the PM&F processes
pass through a POTW. A pollutant is considered by the Agency to
pass through a POTW when more of that pollutant can be removed by
the application of BAT than can be removed by a POTW. If, for a
particular pollutant, the average percentage removed nation-wide
in well-operated POTWs meeting secondary treatment requirements
is greater than the percentage removed by BAT, the pollutant does
not pass through a POTW. Thus, a categorical pretreatment
standard for that pollutant is not needed.
321
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PRETREATMENT STANDARDS FOR EXISTING SOURCES
Contact Cooling and Heating Water Subcategory
For all pollutants except bis(2-ethylhexyl) phthalate, the Agency
is not promulgating categorical PSES for this subcategory; PSES
for bis(2-ethylhexyl) phthalate are being reserved pending
further study. EPA has determined that the average percentage of
toxic pollutant removals (ranging from 35 to 99 percent) nation-
wide by well-operated POTWs meeting secondary treatment require-
ments is greater than the percentage of toxic pollutant removals
achieved by BAT (i.e., zero percent removals) in this subcate-
gory. Therefore, the toxic pollutants do not pass through a
POTW. Even though categorical pretreatment standards are not
being promulgated, indirect dischargers in this subcategory must
comply with the General Pretreatment Regulations - 40 CFR Part
403.
PSES for bis(2-ethylhexyl) phthalate are reserved pending propo-
sal and promulgation of the BAT effluent limitations guidelines
for that pollutant. When BAT is selected for that pollutant, EPA
will determine if bis(2-ethylhexyl) phthalate passes through a
POTW.
Cleaning Water Subcategory
EPA is not promulgating PSES for the cleaning water subcategory
because the priority toxic pollutants found in cleaning waters in
treatable concentrations (i.e., phenol and zinc) do not pass
through a POTW. The Agency compared the percent removal of
phenol and zinc (i.e., 75* percent and 62** percent, respec-
tively) achieved by applying BAT to the average percentage
removal of those pollutants nation-wide by well-operated POTWs
*Percent removal was calculated based on the treatability limit
from U.S. EPA's Treatability of Organic Priority Pollutants -
Part C - Their Estimated (30-Day Ave.) Treated Effluent
Concentration - A Molecular Engineering Approach, Murray P.
Strier, July 11, 1978.
**Percent removal was derived from the treatability limit for
zinc for the lime, settle,and filtration technology listed in
the U.S. EPA, Development Document for Effluent Limitations
Guidelines and Standards for the Nonferrous Metals
Manufacturing Point Source Category Phase II,July 1984.
322
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meeting secondary treatment requirements (99t percent for phenol
and 77t percent for zinc). Because the percent removals in a
POTW are greater than the BAT percent removals, phenol and zinc
do not pass through a POTW. Therefore, categorical pretreatment
standards are not required for phenol and zinc. Even though no
categorical pretreatment standards are being promulgated for
existing sources for this subcategory, indirect dischargers must
comply with the General Pretreatment Regulations - 40 CFR Part
403.
Finishing Water Subcategory
Except for three phthalates, the Agency is not promulgating
categorical PSES for this subcategory for any pollutant; PSES for
bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and dimethyl
phthalate are reserved. EPA has determined that the average
percentage of toxic pollutants removed nation-wide by well-
operated POTWs meeting secondary treatment requirements (ranging
from 35 to 99 percent) is greater than the average percent
removal of toxic pollutants by direct dischargers applying BAT
(i.e., zero percent removals). Therefore, the toxic pollutants
do not pass through a POTW. Even though the Agency is not prom-
ulgating categorical pretreatment standards, indirect dischargers
at existing sources in this subcategory must comply with the
General Pretreatment Regulations - 40 CFR Part 403.
PSES for bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and
dimethyl phthalate are reserved pending development of the BAT
effluent limitations guidelines for those pollutants. When BAT
is selected, EPA will determine if those three pollutants pass
through a POTW.
PRETREATMENT STANDARDS FOR NEW SOURCES
Contact Cooling and Heating Water Subcategory
For all pollutants except bis(2-ethylhexyl) phthalate, the Agency
is not promulgating categorical PSNS for the contact cooling and
heating water subcategory; PSNS for bis(2-ethylhexyl) phthalate
are reserved. The Agency believes that new and existing indirect
discharge sources in this subcategory will discharge the same
pollutants in similar amounts. As discussed in the preceding
tPOTW percent removals were obtained from Table 10, Fate of
Priority Pollutants in Publicly Owned Treatment Works, Final
Report, Volume 1, EPA-440/1-82/303, September 1982.
323
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section, the average percentage of toxic pollutants removed
nation-wide by well-operated POTWs meeting secondary treatment
requirements (ranging from 35 to 99 percent) is greater than the
average percent removal of toxic pollutants by direct dischargers
applying BAT/NSPS (i.e., zero percent removals). Therefore, the
toxic pollutants do not pass through a POTW. Even though the
Agency is not promulgating categorical pretreatment standards at
this time, indirect dischargers at new sources in this subcate-
gory must comply with the General Pretreatment Regulations - 40
CFR Part 403.
The Agency believes that the concentrations of bis(2-ethylhexyl)
phthalate in contact cooling and heating waters discharged from
new indirect sources will be similar to the concentrations of
that pollutant discharged from existing indirect sources. For
this reason, the Agency is reserving PSNS for bis(2-ethylhexyl)
phthalate until promulgation of NSPS for that pollutant. When
NSPS are developed, EPA will determine if bis(2-ethylhexyl)
phthalate passes through a POTW.
Cleaning Water Subcategory
The Agency is not promulgating categorical PSNS for this subcate-
gory. The Agency believes that new and existing indirect dis-
charging sources will discharge the same pollutants in similar
amounts. As discussed in the preceding section, the average
toxic pollutant percentage removed nation-wide by well-operated
POTWs meeting secondary treatment requirements is greater than
the percentage of toxic pollutant removals achieved by applying
BAT. Therefore, the toxic pollutants do not pass through a POTW.
Even though new indirect dischargers are not subject to categori-
cal pretreatment standards, they must comply with the General
Pretreatment Regulations - 40 CFR Part 403.
Finishing Water Subcategory
Except for three phthalates, the Agency is not promulgating
categorical PSNS for this subcategory for any pollutant; PSNS for
bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and dimethyl
phthalate are reserved. The Agency believes that new and exist-
ing indirect discharge sources in this subcategory will discharg-
ing the same pollutants in similar amounts. As discussed in the
preceding section, EPA has determined that the average percentage
of toxic pollutants removed nation-wide by well-operated POTWs
meeting secondary treatment requirements (ranging from 35 to 95
percent) is greater than the average percent removals achieved
by applying BAT/NSPS (i.e., zero percent removals). Therefore,
the toxic pollutants do not pass through a POTW. Even though the
Agency is not promulgating categorical pretreatment standards,
324
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new source indirect dischargers in this subcategory must comply
with the General Pretreatment Regulations - 40 CFR Part 403.
The Agency believes that the concentration of the three phthal-
ates in finishing waters discharged from new indirect sources
will be similar to the concentrations of those pollutants dis-
charged from existing indirect sources. For this reason, the
Agency is reserving PSNS for bis(2-ethylhexyl) phthalate,
di-n-butyl phthalate, and dimethyl phthalate until NSPS for those
pollutants are promulgated. When NSPS are developed, EPA will
determine if the pollutants pass through a POTW.
325
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SECTION XIV
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
This section defines the effluent limitations guidelines for the
PM&F category based on the performance of the "best conventional
pollutant control technology" (BCT). BCT effluent limitations
guidelines are applicable to the discharge of conventional pollu-
tants from existing industrial point sources, as established in
Section 301(b)(2)(E) of the 1977 amendments to the Clean Water
Act. Section 304(a)(4) designated the following as conventional
pollutants: biochemical oxygen demand (BOD), total suspended
solids (TSS), fecal coliform, pH, and any additional pollutants
defined by the Administrator as conventional. The Administrator
designated oil and grease a "conventional" pollutant on July 30,
1979 (44 FR 44501).
BCT effluent limitations guidelines are not additional limita-
tions but replace BAT effluent limitations guidelines for the
control of conventional pollutants. In addition to other factors
specified in Section 304(b)(4)(B), the Act requires that BCT
effluent limitations guidelines be assessed in light of a two
part "cost-reasonableness" test. See, American Paper Institute
v. EPA, 660 F.2d 954 (4th Cir. 1981). The first part of the test
compares the cost for private industry to reduce its conventional
pollutant concentrations with the cost publicly owned treatment
works incur for similar levels of reduction. The second part of
the test examines the cost-effectiveness of additional industrial
wastewater treatment beyond BPT. EPA must find that the BCT
effluent limitations guidelines are "reasonable" under both parts
of the test before the BCT effluent limitations guidelines are
established. In no case may the BCT effluent limitations
guidelines be less stringent than the BPT effluent limitations
guidelines.
EPA published its methodology for carrying out the BCT analysis
on August 29, 1979 (44 FR 50732). In the case mentioned above,
the Court of Appeals orcTered EPA to make certain revisions. A
revised methodology for the general development of BCT effluent
limitations guidelines was proposed on October 29, 1982 (47 FR
49176). On September 20, 1984, the Agency issued a major notice
of data availability for the BCT methodology (49 FR 37046). When
the final BCT methodology is promulgated, EPA wilT~use this meth-
odology to determine whether BCT effluent limitations guidelines
should be established for two of the three PM&F subcategories.
The Agency reviewed treatment technologies that could be used to
remove additional conventional pollutants after BPT. For the
contact cooling and heating water subcategory, EPA was unable to
327
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identify a technology that further reduces the concentrations of
conventional pollutants found in contact cooling and heating
waters. For this reason, the Agency is establishing BCT effluent
limitations guidelines equal to the BPT effluent limitations
guidelines for the contact cooling and heating water subcategory
(presented in Table X-2). Because there are no technologies
available to reduce conventional pollutants in contact cooling
and heating waters, EPA has no reason to await promulgation of
the final BCT methodology before promulgating BCT effluent
limitations guidelines for this subcategory.
For both the cleaning water subcategory and the finishing water
subcategory, the Agency has identified at least one technology
(filtration) that can reduce the concentration of conventional
pollutants remaining after the application of BPT. Therefore,
EPA is reserving promulgation of BCT effluent limitations guide-
lines for those subcategories pending promulgation of the final
BCT methodology. Once that methodology is promulgated, EPA will
apply it to the costs and conventional pollutant removals asso-
ciated with the filtration technology to determine if additional
controls for conventional pollutants are justified for those two
subcategories.
328
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SECTION XV
ACKNOWLEDGEMENTS
This project was conducted by the Environmental Protection Agency
(EPA). EPA personnel who contributed to this project are:
Jeffery D. Denit
Devereaux Barnes
Ernst P. Hall
Robert W. Bellinger
Robert M. Southworth, P.E.
Susan E. Lepow
Jill Weller
Louis Dupuis
Ann M. Watkins
Henry D, Kahn
R. Clifton Bailey
Alexander MeBride
Director, Industrial Technol-
ogy Division
Deputy Director, Industrial
Technology Division
Chief, Metals Industry Branch,
Industrial Technology Division
Chief, Consumer Commodities
Branch, Industrial Technology
Division
Senior Project Officer,
Consumer Commodities Branch,
Industrial Technology Division
Assistant General Council,
Water Division
Attorney, Office of General
Counsel
Chief, Economic Analysis
Staff, Office of Analysis and
Evaluation
Economics Project Officer,
Economic Analysis Staff,
Office of Analysis and
Evaluation
Analysis and Evaluation
Division
Statistician, Program Integra-
tion and Environmental Staff
Chief, Water Quality Analysis
Branch, Monitoring and Data
Support Division
329
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Alexandra G. Tarnay
Environmental Project Officer,
Water Quality Analysis Branch,
Monitoring and Data Support
Division
Contractor personnel who contributed to this project are:
Lee C. McCandless
David C. Kennedy
Thomas M. Lachajczyk
Daniel L. Logan
Robert A. Bessent
Albert P. Becker
Cindy L. Dahl
James S. Sherman
Calvin L. Spencer
Roy E. Sieber
Arlene A. Freyman
Robert M. Eng
Laura L. Murphy
Sandra F. Moore
Daphne K. Phillips
Nancy E. Reid
Program Manager, Versar, Inc.
Vice President, Envirodyne
Engineers, Inc.
Senior Environmental Engineer,
Envirodyne Engineers, Inc.
Environmental Engineer,
Envirodyne Engineers, Inc.
Environmental Engineer,
Envirodyne Engineers, Inc.
Chemical Engineer,
Envirodyne Engineers, Inc.
Environmental Engineer,
Envirodyne Engineers, Inc.
Program Manager, Radian
Corporation
Project Director, Radian
Corporation
Chemical Engineer, Radian
Corporation
Chemical Engineer, Radian
Corporation
Chemical Engineer, Radian
Corporation
Chemical Engineer, formerly
with Radian Corporation
Secretary, Radian Corporation
Secretary, Radian Corporation
Secretary, Radian Corporation
330
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The cooperation of the Society of Plastics Industry, Inc., the
individual PM&F companies whose plants were sampled, and the com-
panies who submitted detailed information in response to the
questionnaires is gratefully appreciated.
331
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SECTION XVI
REFERENCES
Agranoff, Joan (ed). Modern Plastics Encyclopedia, 1981-1982.
McGraw-Hill, Inc., New York, New York, 1981.
Agranoff, Joan (ed). "Casting of Polypropylene Film." Modern
Plastics Encyclopedia, 1981-1982. McGraw-Hill, Inc., New York,
New York, 1981. p. 248.
Alex, Kurt. "Melt-Processible Structural Foam Molding." Modern
Plastics Encyclopedia, 1981-1982. McGraw-Hill, Inc., New York,
New York, 1981. p. 248.
Allan, R. W. "Closed Mold Processing." Modern Plastics
Encyclopedia, 1981-1982. McGraw-Hill, Inc., New York, New York,
1981.p. 392.
Allbee, Nancy. "Update: Flame Retardants, Part 1: Inorganic
Additives." Plastics Compounding, 4(4):89, 1981.
Allbee, Nancy. "Update: Flame Retardants, Part 2: Organic
Additives." Plastics Compounding, 4(5):95, 1981.
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350
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SECTION XVII
GLOSSARY
This section contains the definitions of the technical terms used
in this document. Table XVII-1 lists some common plastic
polymers and their uses and properties.
Acidity
The acidity of water is its quantitative capacity to react with a
strong base to a designated pH. Various materials may contribute
to the measured acidity depending on the method of determination.
These materials include strong mineral acids, weak acids such as
carbonic and acetic acids, and hydrolyzing salts such as ferrous
or aluminum sulfates.
Alkalinity
Alkalinity of a water is its quantitative capacity to react with
a strong acid to a designated pH. It is an indication of the
concentration of carbonate, bicarbonate, and hydroxide ions
present in the water.
Analytical Quantification Limit
The minimum concentration at which a pollutant can be accurately
measured. It is also known as the method detection limit.
Average Process Water Usage Flow Rate
The average process water usage flow rate of a process in liters
per day is equal to the volume of the process water (liters) used
per year by a process divided by the number of days per year the
process operates. The average process water usage flow rate for
a plant with more than one plastics molding and forming process
in a subcategory is the sum of the average process water usage
flow rates for those plastics molding and forming processes.
Batch Treatment
Batch treatment is a waste treatment method where wastewater is
collected over a period of time and then treated pri>or to dis-
charge. Collection may be continuous even though treatment is
not. Batch treatment may be used because the processes generat-
ing wastewater are operated on a batch operation mode, or the
treatment system may be oversized for the amount of wastewater
generated.
351
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Biological Oxygen Demand (BODs)
The biological oxygen demand test for wastewaters determines the
oxygen required for the biochemical degradation of organic
material (carbonaceous demand) and the oxygen used to oxidize
inorganic material such as sulfides and ferrous iron. The
wastewater sample is incubated for a standard period of five
days, hence the name 6005.
Blowing Agent
A blowing agent is the material injected into a plastic material
that causes the plastic material to expand with the application
of heat. Blowing agents can be gases introduced into the molten
plastic or a gas producing compound that is mixed with the
polymer before processing.
Blow Molding
Blow molding expands a parison into a desired shape with com-
pressed air. Hollow, thin-wall objects from thermoplastic resins
are formed.
Calendering Process
The calendering process squeezes pliable thermoplastic between a
series of rolls to produce uniform quality polymer film and
sheet, to emboss sheet and film, to perform compounding opera-
tions, and to coat textiles and papers.
Casting Process
A casting process forms products by allowing a liquid plastic to
cure at atmospheric pressure in a mold or on a mold surface.
Chemical Oxygen Demand (COD)
The chemical oxygen demand is a measure of the oxygen equivalent
of the organic matter in a wastewater sample that is susceptible
to oxidation by a strong chemical oxidant.
Cleaning Process
A cleaning process is a process in which surfaces of plastic
products and shaping equipment surfaces that contact the plastic
product are washed to remove residual mold release agents and
other matter prior to finishing or further processing. A clean-
ing process contains a detergent wash cycle and a rinse cycle.
354
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Cleaning Water
Cleaning water is process water used to clean the surfaces of an
intermediate or final plastic product or to clean the surfaces of
equipment used in plastic molding and forming that contacts an
intermediate or final product. It includes water used in both
the detergent wash and rinse cycles of a cleaning process.
Coating Process
A coating process covers objects with a polymer layer that is in
the form of a melt, liquid, or finely divided powder. These
objects that are coated include other plastic materials, metal,
wood, paper, fabric, leather, glass, concrete, and ceramics.
Compounding
Compounding is the plastics processing step where a plastic resin
is mixed with additives or fillers.
Compression Molding
Compression molding shapes a measured quantity of plastic within
a mold by applying heat and pressure to form products with large
surface areas and relatively simple shapes.
Contact Cooling and Heating Water
Contact cooling and heating water is process water that contacts
the raw materials or plastic product for the purpose of heat
transfer during plastic molding and forming.
Conventional Pollutants
Conventional pollutants are the pollutants defined in Section
304(a)(4) of the Clean Water Act. They include biological oxygen
demand, oil and grease, suspended solids, fecal coliform, and pH.
Cooling Trough
A cooling trough is a long open box-like container that holds
water to quench a processed plastic product. It is commonly used
to contact cool extruded strands before they are pelletized and
to cool extruded pipe.
Crude Intermediate Plastic Material
Crude intermediate plastic material is plastic material formu-
lated in an on-site polymerization process.
355
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Direct Discharger
A direct discharger is an industrial water user that discharges
wastewater directly to a navigable stream.
Dry Process
A dry process is a process that uses no proces water or uses
only non-contact cooling water.
Effluent
Effluent is the discharge from a point source after treatment.
End-of-Pipe Treatment
End-of-pipe treatment is the treatment given wastewater before
the wastewater is discharged.
Extrusion Process
Extrusion is a process that forces molten polymer under pres-
sure through a shaping die to produce products of uniform cross-
sectional area such as pipe, tubing, sheet, and film.
Filler
A filler is a material that when added to a plastic may reduce
the end product cost by occupying a fraction of the volume of the
plastic product. It may also act as a speciality additive to
improve the final product.
Finishing Process
A finishing process renders the plastic parts useful. There are
three types of finishing processes: machining, decorating, and
assembling.
Finishing Water
Finishing water is process water used to remove waste plastic
material generated during a finishing process or to lubricate a
plastic product during a finishing process. It includes water
used to machine and to assemble intermediate or final plastic
products.
Foaming Agent
A foaming agent is a gas producing compound added to a polymer
that causes the polymer to foam when the gas is liberated by the
addition of heat or a reduction in pressure.
356
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Foaming Process
A foaming process injects a blowing or foaming agent into a
thermoplastic or thermoset to form a sponge-like material.
Glass Transition Temperature
The temperature at which a polymer changes from a brittle glassy
solid to a rubber-like substance.
Indirect Discharger
An indirect discharger is an industrial source that discharges
wastewater to a publicly owned treatment works.
Influent
Influent is water used in a PM&F process. It can be the source
water for a plant or the source water combined with recycled
water.
Injection Molding
Injection molding forms intricate plastic parts by forcing a
heated plastic material into a mold cavity.
In-Process Control Technology
In-process control technology is the conservation of water
throughout the production processes to reduce the amount of
wastewater discharged.
Integrated Plant
An integrated plant is a plant that combines process water from
all sources in the plant for treatment in a central wastewater
treatment system.
Laminating Process
The laminating process combines layers of plastic materials with
other materials through high pressure. These structures are
formed from layers of resins and fillers bonded together as a
unit with the resin used as a reinforcing agent.
Mass of Pollutant That Can Be Discharged
The mass of pollutant that can be discharged is the pollutant
mass calculated by multiplying the allowable pollutant effluent
concentration times the average process water usage flow rate.
357
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Melt Temperature
The temperature at which a polymer becomes fluid.
Monomer
A monomer is a chemical compound that during a polymerization
process becomes a repeating link in the polymer chain.
New Source Performance Standards (NSPS)
NSPS for new industrial direct dischargers as defined by Section
306 of the Clean Water Act are based on the best available
demonstrated technology.
Nonconventional Pollutants
Nonconventional pollutants include pollutants that are not desig-
nated as either conventional pollutants or priority toxic
pollutants.
Oil and Grease
Oil and grease are materials that are soluble in trichlorotri-
fluoroethane. They include nonvolatilized materials usch as
hydrocarbons, fatty acids, soaps, fats, waxes, and oils.
Parison
A parison is a preshaped sleeve usually made by extrusion. This
sleeve is an intermediate product often used as the starting
material for the blow molding process.
Pelletizing
Pelletizing is a process by which long extruded strands are cut
into pellets. These pellets are an intermediate product which
can be the feed material for other plastic molding and forming
processes.
pH
pH is the negative logarithm of the hydronium ion concentration.
Values below seven represent an acid environment; a value of
seven represents a neutral environment; and values greater than
seven are indicative of a basic environment.
Pigments
A pigment is a compound that when well mixed with a polymer
imparts color to the polymer. To impart color, the pigment must
absorb light in the visible wavelength range.
358
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Plastic Material
A plastic material is a synthetic organic polymer (i.e., a therm-
oset polymer, a thermoplastic polymer, or a combination of a
natural polymer and a thermoset or thermoplastic polymer) that is
solid in its final form and that was shaped by flow. The mate-
rial can be either a homogeneous polymer or a polymer combined
with fillers, plasticizers, pigments, stabilizers, or other
additives.
Plasticization - Internal
A copolymerization process by which a chain is made more flexi-
ble. The chain's rigidity is caused by steric factors.
Plasticizer - External
An external plasticizer is usually a monomeric molecule that when
mixed with polar or hydrogen bonded polymer results in increasing
the flexibility of the rigid polymer.
Plastics Molding and Forming (PM&F) Processes
Plastic molding and forming processes are a group of manufactur-
ing processes in which plastic materials are blended, molded,
formed, or otherwise processed into intermediate or final plastic
products.
Plastisol
A plastisol is a low viscosity system of dispersed polyvinyl
chloride (PVC) in a plasticizer.
PM&F Category
Throughout this document, the PM&F abbreviation stands for the
Plastics Molding and Forming category.
Pollutant Concentration
A measure of the mass of pollutant per volume of wastewater.
Commonly used units are milligrams per liter.
Pollutant Effluent Limitations Guidelines
The pollutant effluent limitations guidelines is the mass of
pollutant allowed to be discharged per unit of time. For the
PM&F category, typical units are milligrams of pollutant per day.
The pollutant mass is calculated by multiplying the effluent
concentration times the average process water usage flow rate.
359
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Polymer
A polymer is a macromolecule comprised of linked together repeat-
ing monomers. These macromolecules have molecular weights in the
range of 10^ to 107.
Polymerization
Polymerization is the chemical reaction that produces a polymer.
Priority Toxic Pollutants
Priority toxic pollutants are toxic pollutants selected for study
from 65 compounds and classes of compounds Congress declared
toxic under Section 307(a) of the Clean Water Act.
Process Water
Process water is any raw, service, recycled, or reused water that
contacts the plastic product or contacts shaping equipment sur-
faces such as molds and mandrels that are, or have been, in
contact with the plastic product.
Publicly Owned Treatment Works (POTW)
A POTW is a wastewater treatment facility owned by a state or
municipality.
Reaction Injection Molding (RIM)
A RIM process simultaneously injects two or more reactive liquid
streams at high pressure into a mixing chamber and then injects
the plastic at a lower pressure into the mold cavity.
Recycle
Recycle is a water-saving technology that returns process water
that has been used in a process to that process.
Regrind
Regrind is processed plastic that is scrapped and mixed with pure
plastic and reprocessed.
Reinforcing Agent
A reinforcing agent primarily improves the strength and stiffness
of the base polymer.
360
-------
Resin
A resin is the homogeneous polymer that forms the basis of a
plastic product. The resin does not include fillers, plasti-
cizers, pigments or stabilizers.
Rotational Molding
A rotational molding process rotates a polymer powder or liquid
inside a large, heated mold to form hollow objects from thermo-
plastic materials.
Sprue
The sprue is the entrance into the mold through which the plastic
flows.
Stabilizer
A stabilizer is a compound that when added to a polymer protects
it from heat, light, or oxygen.
Thermoforming Process
A thermoforming process heats a thermoplastic sheet or film to a
pliable state and forces it around the contours of a mold.
Vacuum, air pressure, or mechanical force form the molten sheet
to the mold.
Thermoplastic Polymer
A thermoplastic polymer is a linear molecule that can melt and
flow with the addition of heat and pressure.
Thermoset Polymer
A thermoset polymer has crosslinks throughout the chain making it
stable to heat. The polymer will not melt or flow with heat.
Total Organic Carbon (TOG)
TOG is a measure of the organic material in a wastewater and is
determined by oxidizing the organic material to carbon dioxide.
Total Phenols
Phenols are hydroxy derivatives of benzene.
Total Suspended Solids (TSS)
TSS is a measure of the solids in wastewater.
361
-------
Transfer Molding
Transfer molding uses a preheated plastic material and moves it
into the mold cavity with pressure through a sprue. It is
similar to injection molding.
Treatability Limit
The treatability limit is the lowest concentration of a pollutant
achievable by a wastewater treatment process.
Volume of Process Water Used Per Year
The volume of process water used per year is the volume of pro-
cess water that flows through a process and comes in contact with
the plastic product over a period of one year.
Wastewater Discharged
Wastewater discharged is process water from a PM&F process that
is discharged to a navigable stream or a POTW.
Water Quench
A water quench is a contact water cooling bath used to quickly
cool a material. It is often used in extrusion and injection
molding to cool the products.
Water Used
Water used is water that contacts the plastic material or prod-
uct. This includes any recycle and makeup water.
Wet Process
A wet process is a process in which the plastic product comes
into direct contact with water.
Zero Discharger
A zero discharger is any industrial water user that does not
discharge wastewater.
362
-------
APPENDIX A
SAMPLING DATA
-------
APPENDIX A
SAMPLING DATA
This appendix presents the daily concentration data for the 18
PM&F plants sampled for the final PM&F regulation. Table A-1
lists the data for the contact cooling and heating water
subcategory; Table A-2 lists the data for the cleaning water
subcategory; and Table A-3 presents the data for the finishing
water subcategory. The concentration values for the source water
sample, for process samples collected on days one, two, and three
and for the duplicate samples listed in Tables A-1, A-2, and A-3
were used to develop the average concentrations presented in
Table VI-19.
Processes from Plant K in Tables A-1 and A-2 have two source
water concentrations listed. The first value listed represents
the concentration of a make-up water flow and the second value
represents a recirculated water flow to the process. Some pollu-
tants for process K-4 from Plant K have two concentration values
listed under each sampling day. The first concentration is from
an unpreserved sample and the second listed value is from a
preserved sample.
Wastewater treatment processes that treat primarily PM&F process
waters were sampled at one plant (i.e., Plant I) in 1980. Tables
A-4 and A-5 present influent and effluent data for two treatment
processes at that plant (see Figure VI-9) . Wastewater treatment
processes that treat primarily PM&F process waters were also sam-
pled at three plants in 1984. Refer to Tables A-6, A-7, and A-8
for influent and effluent data for these treatment processes at
plants M, N, and R, respectively (see Figures VI-12, VI-13, and
VI-17).
Table A-9 presents solution casting solvent recovery sampling
data for Plant G. Data presented in Table A-9 may be used as a
guide by the permit writer to write permits for the solvent
recovery wastewater. This wastewater is not regulated by the
plastics molding and forming effluent limitations guidelines and
standards.
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-------
APPENDIX B
STATE INDUSTRIAL GUIDES
-------
APPENDIX B
STATE INDUSTRIAL GUIDES
This appendix lists the State Industrial Guides used to estimate
the size of the PM&F category. This estimate is described in
Section IV.
State
Alabama
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Edition Title and Publisher
1980-81 Alabama Director of Mining and Manu-
facturing,Industrial Research
Department, Alabama Development
Office
1982 Arizona Directory of Manufacturers,
Pheonix Metropolitan Chamber of
Commerce
1982 Arkansas Directory of Manufacturers,
Arkansas Industrial Development
Foundation
1983 California Manufacturer's Register,
California Manufacturer's Association
1982 Directory of Colorado Manufacturers,
University of Colorado,Boulder,
Business Division, College of
Business and Administration
1982 MacRa.e's Connecticut State Industrial
Directory
1981-82 Delaware Directory of Commerce and
Industry^Delaware State Chamber of
Commerce
1982 Directory of Florida Industries, The
Florida Chamber of Commerce c 1981
1980-81 Georgia Manufacturing Directory.
Georgia Department of Industry and
Trade, c. 1980
B-l
-------
State
Edition Title and Publisher
Idaho
Illinois
Indiana
Iowa
Kansas
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
1982 Idaho Manufacturing Directory
University of Idaho Center for Busi-
ness Development and Research
1983 Illinois Manufacturers Directory,
Manufacturer's NewsInc.,Chicago, IL
Editor, Louise M. West
1983 Harris Indiana Marketer's Industrial
Directory, Harris Publishing Company
(1983, Ohio), State Directory
Division
1981-82 Directory of Iowa Manufacturers,
Iowa Development Commission
1981-82 Directory of Kansas Manufacturers and
Products', Kansas Department of
Economic Development
1981-82 Directory of Kansas Manufacturers and
Pro due tV,Kansas Economic Development
Commission
1983 Kentucky Directory of Manufacturers,
Kentucky Department of Economic
Development
1982 Directory of Louisiana Manufacturers,
Louisiana Department of Commerce
1981-82 Directory of New England Manufac-
turers , New England Council,
George D. Hall Company
1981-82 The Directory of Maryland Manufac-
turers , State of Maryland, Department
of Economic and Community Development
1981-82 Directory of Massachusetts Manufac-
turers , George D. Hall's Association
Industires of Mass c. 1981
1982 The Directory of Michigan Manufac-
turers , Pick Publications, Inc.
1981 Minnesota Directory of Manufacturers,
Minnesota Department of Economic
Development
B-2
-------
State
Edition Title and Publisher
Mississippi
Missouri
Nebraska
Nevada
New Hampshire
New Jersey
New York
North Carolina
North Dakota
Ohio
Oklahoma
Pennsylvania
Rhode Island
1980 Mississippi Manufacturers Directory
Mississippi Research and Development
Center, printed 1979
1982 Missouri Directory, Mining and Manu-
facturing Industires Services and
Supplies" Information Data Company
1982-83 A Directory of Nebraska Manufacturers
and Their Products,Nebraska Depart-
ment of Economic Development
1981 Nevada Industrial Directory, Nevada
Department of Economic Development
1982-83 Made in New Hampshire, State of New
Hampshire,Office of Industrial
Development, Division of Economic
Development
1983 New Jersey State Industrial Directory
MacRae"'s Blue Book, Inc.
1983 New York State Industrial Directory,
MacRae1s Blue Book,Inc.
Editor, Barbara Sadie
1981-82 Directory of North Carolina Manufac-
turing Firms, North Carolina Depart-
ment of Commerce
1978-79 Directory of North Dakota Manufactur-
ing, North Dakota Business and
Industrial Development Department
1983 Ohio Marketers Industrial Directory,
Harris Publishing Company
1980 Oklahoma Directory of Manufacturers
and Products^Industrial Development
Department
1982 MacRae's Pennsylvania State Indus-
trial Directory
1981-82 Rhode Island Directory of Manufac-
turers , Rhode Island Directory of
Economic Development
B-3
-------
State
South Carolina
South Dakota
Tennessee
Texas
Virginia
Washington
West Virginia
Wisconsin
Edition Title and Publisher
1983
South Carolina 1983 Industrial Direc-
tory , South Carolina State Develop-
ment Board
1981-82 South Dakota Manufacturers & Proces-
sors Directory, Department of
Economic and Tourism Development
1982 Tennessee Directory of Manufacturers,
Tennessee Department of Economic and
Community Development
1983 Directory of Texas Manufacturers ,
Bureau of Business Research,
University of Texas, Austin
1981-82 Virginia Industrial Directory,
Virginia State Chamber of Commerce
1982-83 Washington Manufacturers Register,
Times Mirror Press, Washington State
Department of Commerce and Economic
Development
1980 West Virginia Manufacturer's Direc-
tory, Governor's Office of Economic
and Community Development Department
1983 Classified Directory of Wisconsin
Manufacturers, Wisconsin Association
of Manufacturers and Commerce
B-4
-------
APPENDIX C
POLLUTANT REMOVALS
-------
APPENDIX C
POLLUTANT REMOVALS
This appendix explains how PM&F subcategory pollutant mass remov-
als were calculated for the model treatment technologies. These
removals apply to the BPT and BAT effluent limitations guidelines
and to NSPS. Table C-1 contains the subcategory pollutant aver-
age concentrations and total estimated direct discharge masses
for pollutants found in treatable concentrations for each
subcategory.
CONTACT COOLING AND HEATING WATER SUBCATEGORY
BPT Effluent Limitations Guidelines Pollutant Mass Removals
No model treatment technology was selected as the basis for the
BPT effluent limitations guidelines for this subcategory. BPT
effluent limitations guidelines were established to ensure that
plants continue the good housekeeping practices observed during
the sampling episodes conducted during development of this regu-
lation. They are based on the results of a statistical evalua-
tion of the pollutant concentrations in contact cooling and
heating process waters. There are only minimal costs associated
with the final BPT effluent limitations guidelines and there are
only minimal pollutant mass removals. See Section X for a
discussion of the BPT effluent limitation guidelines for this
subcategory.
BAT Effluent Limitations Guidelines Pollutant Mass Removals
BAT effluent limitations guidelines for this subcategory are
equal to BPT effluent limitations guidelines except for the
priority pollutant bis(2-ethylhexyl) phthalate. BAT effluent
limitations guidelines are reserved for bis(2-ethylhexyl) phthal-
ate. After further study, EPA will propose and promulgate BAT
effluent limitations guidelines for this pollutant. The technol-
ogy considered to treat bis(2-ethylhexyl) phthalate is activated
carbon adsorption.
To estimate mass removals at BAT for bis(2-ethylhexyl) phthalate,
the theoretical treatability limit for this pollutant presented
in Table VII-9 was used. This limit was based on technology that
includes activated carbon adsorption. Refer to Table C-2 for the
influent and effluent concentrations and the estimated pollutant
mass removals for the activated carbon process.
The influent and effluent concentrations listed on Table C-2 are
from Tables C-1 and VII-9, respectively. The percentage removal
(i.e., 89.8 percent) based on these concentrations was applied to
C-1
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?ollutant mass removals for the BPT effluent limitations guide-
ines. Table C-4 lists the estimated cleaning water subcategory
pollutant mass removals at BPT and the mass of pollutants
remaining after BPT.
BAT Effluent Limitations Guidelines Pollutant Mass Removals
For the cleaning water subcategory, BAT effluent limitations
guidelines are equal to BPT effluent limitations guidelines.
Consequently, the BAT pollutant mass removals are equal to BPT
removals as listed in Table C-4.
NSPS Pollutant Mass Removals
Pollutant mass removals for direct dischargers at a new plant in
the cleaning water subcategory were based on the performance of
the model treatment technology that was selected at BPT. To
estimate the pollutant masses discharged and the pollutant mass
removals for NSPS, the pollutant masses at BPT were divided by
the estimated number of direct discharging cleaning processes
(i.e., 104 cleaning processes). This approach assumes that pro-
cess waters at a new discharging source have the same pollutant
influent and effluent concentrations as listed in Table C-3.
Hence, the pollutant percent removals are the same. Refer to
Table C-5 for the cleaning water subcategory new source pollutant
masses, mass removals, and masses remaining after treatment.
EPA considered NSPS based on the performance of a package acti-
vated sludge plant followed by a filter. Refer to Table C-6 for
the filter pollutant mass removals and for filter influent and
effluent concentrations. The mass of pollutants in the influent
to the filter and the filter influent pollutant concentrations
are equal to the pollutant masses remaining after activated
sludge treatment (see Table C-5) and the effluent concentrations
presented on Table C-3, respectively.
FINISHING WATER SUBCATEGORY
BPT Effluent Limitations Guidelines Pollutant Mass Removals
The model treatment technology (i.e., settling) for BPT for this
subcategory removes total suspended solids (TSS). Table C-7
presents the TSS influent and effluent concentrations, the TSS
percent removal, the pollutant mass removals based on the percent
removal, and the pollutant mass remaining after treatment. The
TSS pollutant mass removal for the BPT effluent limitations
guidelines is 2,520 kg/yr.
The TSS percent removal is 69.5 percent. This removal was calcu-
lated using the influent concentration of 95 mg/1 and the median
C-6
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Table C-5
NSPS POLLUTANT MASS REMOVALS
CLEANING WATER SUBCATEGORY
Conventional
Pollutant
BOD5
Oil and Grease
TSS
TOTAL
Nonconventional
Pollutant
COD
TOG
Total Phenols
TOTAL
Priority
Pollutant
65. phenol
128. zinc
TOTAL
New Source*
Pollutant
Mass (kg/yr)
246
137
1 .910
2,293
308
1 ,700
71
2,079
0.569
1 .71
2.279
Pollutant
Mass Removal
(kg/yr)
186
88.2
1 .820
2,094.2
1,316.7
0.426
1 .06
1 .486
Pollutant
Mass
Remaining
After
Treatment
(kg/yr)
60
48.8
90
198.8
194
1 ,080
42.7
114
620
28.3
762.3
0.143
0.650
0.793
*0btained by dividing the pollutant mass listed in Table C-1 for
the cleaning water subcategories by the estimated number of
direct discharging cleaning water processes.
C-8
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Table C-7
TOTAL SUSPENDED SOLIDS CONCENTRATIONS AND MASS REMOVALS
FINISHING WATER SUBCATEGORY
TSS Influent Concentration 95 mg/1
TSS Effluent Concentration 29 mg/1
TSS Percent Removal* 69.5 %
TSS Mass 3,630 kg/yr
TSS Mass Removal 2,520 kg/yr
TSS Mass Remaining After Treatment 1,110 kg/yr
*Percent removal is based on a median effluent concentration of
29 mg/1 for settling technology. This is the median effluent
concentration for settling technology in the U.S. EPA,
Treatability Manual, Volume III, Technologies for Control/
Removal of Pollutants. July 1980, EPA 600/8-80-842c.
C-10
-------
effluent concentration of 29 mg/1 from the U.S. EPA, Treatabillty
Manual, Volume III, Technologies for Control/Removal of Pollu-
tants , July 1980, EPA 600/8-80-842C for settling technology.
BAT Effluent Limitations Guidelines Pollutant Mass Removals
BAT effluent limitations guidelines for this subcategory are
equal to BPT effluent limitations guidelines for all pollutants
except for bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and
dimethyl phthalate. Therefore, the estimated pollutant removals
are the same as at BPT.
The three phthalates are reserved at BAT. The technology iden-
tified for treatment of the phthalates is settling followed by
activated carbon adsorption. The activated carbon also removes
additional quantities of TSS. The Agency estimated the amounts
of the three phthalates that would be removed by the activated
carbon process so that the technology could be evaluated econom-
ically. Refer to Table C-8 for the activated carbon adsorption
process influent and effluent concentrations and the percent
removals for the three phthalates.
The pollutant removals for the settling unit are equal to the
removals at BPT and the TSS concentration of the process water
entering the activated carbon adsorption process is equal to the
TSS concentration in the settling unit effluent (i.e., 29 mg/1
from Table C-7).
The pollutant mass removals for the finishing water subcategory
are presented in Table C-9. These removals reflect the pollutant
removals for the settling and activated carbon adsorption tech-
nologies. Also presented in Table C-9 are the finishing water
subcategory pollutant masses remaining after treatment.
NSPS Pollutant Mass Removals
NSPS for this subcategory are equal to BPT effluent limitations
guidelines except for bis(2-ethylhexyl) phthalate, di-n-butyl
phthalate, and dimethyl phthalate. NSPS are reserved for the
phthalates pending completion of a phthalate treatability study.
Estimated pollutant mass removals for direct discharge finishing
water processes at a new plant were based on two model treatment
technologies:
1. Settling (the selected technology for BPT and BAT) and
2. Settling followed by filtration.
To estimate the pollutant masses discharged and the pollutant
mass removals for NSPS, the pollutant masses at BPT were divided
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by the estimated number of finishing processes (i.e., 10 finish-
ing processes). This approach assumes that settling units at new
discharging sources have the influent and effluent concentrations
listed on Table C-7. Hence, the pollutant percent removal is the
same for a settling unit at an existing source and at a new
source. Table C-10 presents the mass removals for the settling
technology for the finishing water subcategory.
EPA considered a model treatment technology for NSPS that
included a settling unit followed by filtration. The filter
influent and effluent concentrations and pollutant mass removals
are presented in Table C-11. The filter influent TSS concentra-
tion and influent TSS mass are equal to the effluent TSS concen-
tration and effluent TSS mass from the settling unit at BPT (see
Table C-7).
-------
Table C-10
NSPS MASS REMOVALS - SETTLING UNIT
FINISHING WATER SUBCATEGORY
Pollutant Mass
New Source Pollutant Mass Remaining After
Conventional Pollutant Mass Removal Treatment
Pollutant (kg/yr)* (kg/yr)** (kg/yr)
TSS 363 252 111
*Calculated by dividing the estimated subcategory pollutant mass
for TSS by the estimated number of finishing processes.
**For settling unit, based on percent removal presented in Table
C-7.
C-15
-------
Table C-11
NSPS MASS REMOVALS - FILTER
FINISHING WATER SUBCATEGORY*
TSS Influent Concentration 29 mg/1
TSS Effluent Concentration 12 mg/1
TSS Percent Removal** 59 percent
TSS Pollutant Mass 111 kg/yr
TSS Pollutant Mass Removal 65.5 kg/yr
TSS Mass Remaining After Treatment 45.5 kg/yr
*For a filter following the settling unit.
**Percent removal was calculated using the median effluent
concentration for granular media filtration from U.S. EPA,
Treatability Manual, Volume III, Technologies for Control/
Removal of Pollutants. July 1980, EPA 600/8-80-842c.
C-16
-------
APPENDIX D
POLLUTANT CONCENTRATIONS USED TO
CALCULATE THE BEST PRACTICABLE TECHNOLOGY (BPT)
EFFLUENT LIMITATIONS GUIDELINES
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MEMORANDUM
SUBJECT: Calculation of Final Best Practicable Technology (BPT) Limitations
Guidelines - Plastics Molding and Forming (PM&F)
FROM: R. Clifton Bailey, Statistician
Analysis and Evaluation Division (WH-586)
TO: Robert M. Southworth, PM&F Project Officer
Industrial Technology Division (WH-552)
Purpose
This memorandum describes the development of the final BPT effluent
limitations guidelines for the PM&F category. Pollutants regulated by the
effluent limitations guidelines are biochemical oxygen demand (6005), oil and
grease (O&G), and total suspended solids (TSS).
Background
Proposed BPT effluent limitations guidelines for the PM&F category were
published in the Federal Register on February 15, 1984 (49 FR 5862). They
control 6005, O&G, and TSS in two subcategories. The limitations were based
on concentration values that were transferred from the organic chemicals,
plastics, and synthetic fibers (OCPSF) category and a production normalized
flow calculated using information from two questionnaire surveys of the PM&F
industry.
In response to comments, the Agency collected additional pollutant con-
centration data and calculated flow-weighted subcategory pollutant average
concentrations using both the new sampling data and data from previous sampling
episodes. Based on the flow-weighted average concentrations and information
provided by conmenters, the Agency determined that the PM&F category should be
divided into three subcategories for the final PM&F regulation. They are:
0 contact cooling and heating water subcategory;
0 cleaning water subcategory; and
0 finishing water subcategory.
This memorandum discusses the concentration values used to calculate the
final BPT effluent limitations guidelines for each subcategory. These concen-
trations are multiplied by the average process water usage flow rate for a pro-
cess to determine the mass of pollutants that can be discharged from a process.
-------
—2—
The final BPT effluent limitations guidelines for the contact cooling
and heating water subcategory are based on a statistical evaluation of the
raw waste concentrations of 8005, O&G, and TSS in contact cooling and heating
water. This approach was used because the concentrations of 8005 in contact
cooling and heating water are too low to support the operation of the proposed
technology for BPT (i.e., the activated sludge process) and the Agency could
not identify any other technology that would reduce those concentrations.
Final BPT effluent limitations guidelines for the cleaning water
subcategory are based on the application of a package activated sludge plant
with equalization and pH adjustment because the 6005 concentrations found in
cleaning water are high enough to support biological treatment. However, no
effluent data on activated sludge treatment of cleaning water only were avail-
able. Therefore, as at proposal, we compared the cleaning water untreated
concentration data for 6005, O&G, and TSS to data from those pollutants in
wastewater generated at plastics manufacturing plants (PMP) in the organic
chemicals, plastics, and synthetic fibers category (OCPSF) category. Results
of that comparison are presented in this memorandum. Because wastewaters
fron cleaning processes at PM&F plants and wastewaters generated at PMP plants
have similar 6005, O&G, and TSS characteristics, it is appropriate to use
activated sludge effluent data from those pollutants from the OCPSF category
to determine effluent limitations guidelines for the PM&F cleaning water sub-
category. Those data are presented in Appendices I and IIA to this memorandum.
For the finishing water subcategory, only TSS was present in treatable
concentrations. For this reason, the BPT effluent limitations guidelines for
this subcategory are based on the performance of a settling unit. Calculation
of the maximum TSS concentration for any one-day and the maximum TSS concentra-
tion for the monthly average is discussed in this memorandum.
Data
Plastics Molding and Forming Process Sample Data
Samples of untreated process water were collected at 18 plastics
molding and forming (PM&F) plants. 8005, O&G, and TSS concentrations
found in these samples are presented in Appendix I. Concentration data
are presented for all three subcategories.
Plastics Manufacturing Plant Data
The BPT effluent limitations guidelines for the cleaning water sub-
category are based on data from well-operated activated sludge processes
at six plastics manufacturing plants (Nos. 9, 44, 45, 96, 111, 126).
These well-operated treatment processes were identified through an
engineering analysis of the performance data for those processes (see
page 190 of the OCPSF technical development document-proposal for a
summary). 8005 and TSS data were available from effluent samples col-
lected at five of the six plants (Nbs. 9, 44, 45, 111, 126). These data
are presented in Appendix IIA.
D-2
-------
-3-
Oil and grease (O&G) data were not available for the six well-
operated wastewater treatment processes at the plastics manufacturing
plants in the plastics only subcategory. Therefore, the PM&F effluent
limitations guidelines for O&G were developed based on data from four
plants (Nos. 3, 61, 124, 170) in the OCPSF data base that manufacture
plastics (not necessarily plastics only plants) and that use activated
sludge treatment. Those data are also presented in Appendix IIA.
Subsequent to proposal, we investigated using an expanded data base
for the OCPSF category to see if the transferred effluent concentrations
for the final regulation for the cleaning water subcategory should be
based on the expanded data base. Although additional data had been col-
lected for the OCPSF category, those data had neither been input to the
data base nor been verified. Because the estimated date for completion
of the expanded and verified data base was after the promulgation date for
the final PM&F regulation, we used the same data base for the transfer of
the activated sludge performance data for the final PM&F regulation that
was used for the proposed regulation. This data base is the only verified
data base available for the development of the PM&F regulation. Because
it is a verified data base, the Agency believes it is appropriate to use
that data base for the final PM&F Regulation.
The final BPT effluent limitations guidelines for the cleaning water
subcategory were developed based on a log-normal distribution fit to the
data. The goodness-of-fit of the log-normal model for O&G effluent data
was examined using a graphical procedure described in Appendix III. As
stated, the plots presented in Appendix IIC support the log-normal dis-
tribution as a model for the O&G effluent data. The graphical procedure
used to demonstrate log-normality for O&G was the same procedure used to
demonstrate log-normality for 8005 and TSS for the proposed OCPSF Regula-
tion (see the technical development document for the proposed OCPSF
regulation).
Performance Data Transfer - Cleaning Water Subcategory
Effluent concentration values for 6005, O&G, and TSS for the cleaning
water subcategory were developed in a manner similar to the effluent con-
centrations for those pollutants for the cleaning and finishing water sub-
category at proposal. However, as discussed above, cleaning water processes
and finishing water processes are in separate subcategories for the final
regulation. Therefore, only PM&F cleaning water data were used for the com-
parison with the influent data from PMP in the OCPSF category. The revised
data summary shown in Table 1 presents the plant average pollutant concentra-
tions and log-variances for plants in the cleaning water subcategory and for
the PMP plants used in the comparisons.
As at proposal, the statistical comparisons use a nonparametric test, the
Mann-Whitney U/Wilcoxon Test, for independent samples. The revised comparisons
(summarized in Table 2) were made separately for the plant means and plant log-
variances. In these tests, neither the medians of the PM&F means nor the medians
of the PM&F log-variances were found to be significantly greater than the cor-
responding PMP values. Consequently, the process water for the PM&F cleaning
water subcategory is neither significantly greater nor more variable than the
PMP process wastewater with respect to 8005, TSS, and O&G concentrations.
D-3
-------
-4-
Results of the statistical analysis also support the judgement that 6005,
TSS, and O&G effluent concentrations for activated sludge treatment of cleaning
water should neither be greater nor more variable than effuent concentrations
for those pollutants for an activated sludge process used to treat PMP process
wastewater. We conclude, therefore, that the cleaning water concentration
values shown in Table 6 of this memorandum can be met using the activated
sludge process to treat PM&F wastewater.
D-4
-------
-5-
TABLE 1
RANK COMPARISON OF MEAN POLLUTANT CONCENTRATIONS AND LOG-VARIANCES:
PLASTICS MOLDING AND FORMING (PM&F) PLANTS IN THE
CLEANING WATER SUBCATEGORY AND PLASTICS MANUFACTURING (PMP) PLANTS
PLANT PLANT SAMPLE CONCENTRATION (irg/1)
POLLUTANT TYPE ID SIZE MEAN RANK
BOD5 PMF I 8 5.33 1
PMF K 1 20.00 2
B 3 48.67 3
C 3 62.89 4
PMP 9 23 84.74 5
PMP 111 157 94.82 6
PMF F 6 200.97 7
PMF A 2 361.52 8
PMP 45 148 381.14 9
PMP 44 45 754.00 10
PMF H 2 777.50 11
PMP 126 247 1087.47 12
0&G PMF A 2 4.000 3
PMF R 3 4.000 3
PMF D 2 4.000 3
PMF H 2 4.000 3
PMF K 1 4.000 3
PMF C 3 12.544 6
PMP 61 234 17.393 7
PMP 124 59 22.902 8
PMP 3 157 41.139 9
PMP 1 8 54.215 10
PMP 170 203 79.277 11
F 4 133.321 12
TSS PMF B 3 4.00 1
PMF K 1 6.00 2
PMF C 3 6.24 3
PMF H 2 7.25 4
D 2 10.50 5
9 23 27.25 6
PMF A 2 33.58 7
PMP 111 157 42.84 8
PMF F 6 234.65 9
PMP 45 148 304.32 10
PMP 126 247 557.00 11
44 45 3780.76 12
I 8 7360.98 13
D-5
-------
-6-
TABLE 1 (CONT'D)
LOG-VARIANCE
OF POLLUTANT
PLANT PLANT SAMPLE CONCENTRATION:
POLLUTANT TYPE ID SIZE MEAN RANK
BOD5 PMF K 1 .
PMF B 3 0.00387 1
PMF H 2 0.07376 2
PMF C 3 0.08329 3
PMP 44 45 0.12644 4
PMF I 8 0.12665 5
PMP III 157 0.16975 6
PMP 45 148 0.17588 7
PMP 126 247 0.26334 8
PMP 9 23 0.67626 9
PMF F 6 1.46832 10
PMF A 2 7.65196 11
O&G PMF K 1 .
PMF A 2 0.0000 2.5
PMF B 3 0.0000 2.5
PMF D 2 0.0000 2.5
PMF H 2 0.0000 2.5
PMP 61 234 0.39147 5.0
PMP 170 203 0.39781 6.0
PMP 3 157 0.61599 7.0
PMP 124 59 1.11618 8.0
PMF C 3 1.48186 9.0
PMF I 8 1.69834 10.0
PMF F 4 6.30013 11.0
TSS PMF K 1 .
PMF B 3 0.0000 1
PMF D 2 0.11786 2
PMP 111 157 0.17684 3
PMF H 2 0.46569 4
PMP 126 247 0.55877 5
PMP 9 23 0.56581 6
PMF A 2 0.69461 7
PMF C 3 0.82157 8
PMF F 6 1.18541 9
PMP 45 148 1.47319 10
PMF I 8 2.25857 11
PMP 44 45 2.61015 12
D-6
-------
-7-
TABLE 2
RESULTS OF THE COMPARISON OF POLLUTANT CONCENTRATION IN
PMP PROCESS WASTEWATER AND IN PROCESS WASTEWATER FOR
THE PM&F CLEANING WATER SUBCATEGORY
Using Wilcoxon - T Test for 2 Independent Samples
One-Tailed Test HQ: PMF _< PMP
HA: PMF > PMP
NUMBER OF PLANTS
RANK MEAN
PLANT MEANS
RANKED
PLANT LOG-
VARIANCES RANKED
POLLUTANT
BOD5
O&G
TSS
BOD5
O&G
TSS
PMF
7
8
8
6
7
7
PMP
5
4
5
5
4
5
PMF
5.14
5.38
5.50
5.53
5.71
6.00
PMP
8.40
8.75
9.40
6.80
6.50
7.20
TX!
42
35
47
40
26
36
P
.926 NS2
.923 NS
.953 NS
.959 NS
.606 NS
.681 NS
1 As defined by Gibbons, J.D., "Nonparametric Methods for Quantitative
Analysis," Holt, Rinehard and Winston, 1976, p. 163.
2 NS - Not significant.
[This updates Table 3, page D-ll, technical development document for the
proposed PM&F regulations].
D-7
-------
-8-
Statistical Evaluation of Raw Waste Concentrations - Contact Cooling and
Heating Water Subcategory
The final BPT effluent limitations guidelines for 6005, O&G, and TSS for
the contact cooling and heating water subcategory are based on the raw waste
concentrations of those pollutants in contact cooling and heating waters. This
approach was used because commenters correctly pointed out that the concentra-
tions of BOE>5 in contact cooling and heating water were too low to support the
proposed activated sludge treatment. Furthermore, during the sampling episodes
for this regulation, the Agency found that, for contact cooling and heating
water, the industry employed good housekeeping practices such as keeping lubri-
cating oil and other pollutants out of the process water. A regulation based
on the raw waste concentrations ensures the continuation of the good housekeeping
practices. An evaluation of the raw waste concentrations, shown in Table 3,
was selected as the basis for the final BPT effluent limitations guidelines
for this subcategory because the Agency could not identify a technology that
would reduce the low 801)5, O&G and TSS concentrations in contact cooling and
heating waters.
D-8
-------
-9-
TABLE 3
PM&F DATA FOR THE CONTACT COOLING AND HEATING WATER SUBCATEGORY
FM&F DATA FOR CONTACT COOLING AND HEATING SUBCATEGORY
STREAMS M-l AND M-2 DELETED
POLLUTANT PROCESS STREAM
a 005
CALENIJ 9-2
CALENO E-2
CALEND F-l
CAST
MOLU
HOLD
MOLD
THERM
OAY1
5.0UOU
9.4000
10.0000
OAY2
M.9000
b.onon
OAY3 OF
. o
4.1000 2
10.000U Z
PHOC POOLED SO • U.340h
PWOC EXPECTED VALUE • 7.516654
P-l ?.30nO . .
EXYRUOE
EXTRUDE
EXTRUDE
EXTKUDE
EXTRUDE
EXTRUDE
EXTHUOE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUJE
fl-1
D-3
E-3
r-6
o-l
K-2
K>3
K-4
N-2
N"3
U-l
0"2
R"l
R-2
PROC POOLED SL> • 0*5224
PROC EXPFCTEP VALUE
5,0000 .
2.636193
7.61)00
•
b.nooo
s.oooo
b . 0 0 n 0
in. nooo
,
3.9000
b.OOOO
s.uooo
b.OOOO
5,oo(/o
.
b.OOOO
0.5000
j.ooou
b.OOOO
b.OOOO
b.OOOO
.
.
h.OODO .
4.1/000 .
PHOC POOLtO SU • U.6794
P«OC EXPfcCrEO VALUE
f>.4bi>3*3
8-4
C-l
J-l
J"2
5.0UOO
96.9000
S.OOOCi
54.0000
U4.8000
PHOC POOLtO iU • O.d6o7
PROC EXPECTED VALUE • H.56161B
f-2
p.nyno
7.0000
POOLt" SI/ • 0.0771
EXPECTED VALue. • 7.3<.oj9j
LOGMEAN SUM SQUARE
EIJ
VIJ
AVO FLOw
1.6094
1.9459
2.2262
0.0000
0.4307
0.0332
5.2985
7.4180
9.8374
3*4983 410.0000
6.7667 3157.0000
11.9005 530.0000
FLOW TOT • 4097.00
PROCESS NGTE'j VARIANCE • 7.099109
0.8329
0.0000
2.6362
2.1801 1090.0000
FLOM TOT » 1090.00
PROCESS WGTEU VARIANCE • 2.160112
1.6094
0.8967
1.3S40
1,6094
1.6094
1.6094
2.3026
1.7918
l.lohj
0.0000
0.0000
4.0233
0.130b
o.onoo
o.oooo
0.0000
o.oooo
0.0000
o.oooo
o.oooo
o.oooo
o.cooo
o.oooo
6.2978
t
3.0939
4.6763
*
6.2978
6.2976
6.2976
12.S957
7.5574
•
t
7,5b7*
b,OJ83
23.2623
t
5.6141
13.9574
.
23.2623
23.2623
23.2623
93.0493
33.4978
•
•
33.4978
14.6879
161.0000
23.7600
8040.0000
454.0000
313,bOOO
908.0000
45*. 0000
33154,0000
6.6000
213.0000
559,0000
416.0000
8B1.0000
12400.0000
FLOW TOT • 58003.80
PROCESS w&lEa VAKlHUCt m 16.6277
1.6094 0.0000 5.0111 0.1120 5.6000
4.bO?9 0.0069 90.9343 36.8824 63.6000
1.6094 0.0000 5.0111 0.1120 27260.0000
3.9690 0.0000 54.1203 13.0642 2010.0000
FLON TOT • 29339.20
PROCESS wetku VARIANCE • 1.07906
1.9904
O.OU9
7.3404
0.3212 408.0000
FLO* TOT « 40b.(/0
PROCESS mSTED VARIANCE • 0.3211999
PROCESS STREAMS Ml AND M2 DELETED BECAUSE CONTAMINATED.
D-9
-------
-10-
TABLE 3
PM&F DATA FOR THE CONTACT COOLING AND HEATING WATER SUBCATEGORY
PM&F DATA FOR CONTACT COOLING AND HEATING SUBCATEGORY
STREAMS M-l AND M-2 DELETED
POLLUTANT PROCESS STREAM
U&G
CALENt)
CALEND
CALENO
CAST
MOLD
MOLD
MOLD
tHERM
H-?
E-2
F-l
tXTRUUF.
EXTHUOE
EXTRUDE
EUTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
EXTRUDE
bXTRUOE
EXTRUDE
ExTRUOE
EXTHUDt
H-l
U-3
E-3
F-6
G-l
K-2
K-3
K«4
N-?
N-3
0-1
0-2
P-l
K-OU'jl
4.0000
4.0000
'o.oooo
,
4.0000
4.0000
4.0000
4. Oil 00
5.0000
,
b . 0 U 0 u
3 . n o o o
6. OuOO
« . o o n o
.
.
27.8000
5.0000
4.0000
4,0000
4. OuOO
4. OUOO
,
3.0000
.
.
.
.
,
.
14.4000
4.0000
,
4.0000
4. OOOu
4 . (1 0 0 0
.
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.
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0
0
2
1
1
2
2
2
0
U
0
0
0
0
PROC POOLEH SU » 0.102/?
PkOC txPtCTEU VALUE
H-4
C-l
J-l
J-i!
7.0000
rs,oono
1i.oooo
(,1.0000
24.5>)0n
,
1 .0000
PHOC POOLED SO » 0.5600
PROC EXPECTED VALUt
F-? 1.0000 .
s. o u n o
PHOC POOLED SU * 0.3ft Id
Pknc EXPECTt" VALUE a 4,13'*0b3
LObMEAN SUM SQUARE
VIJ
AVG FLOW
1.3B63
2.UJ97
0.4621
0.0000
0.2461
1.2812
4.8414 10.8985 410.0000
20.3003 191.6133 3157.0000
1.9213 1.7164 S30.0000
FLOW TOT • 4097.00
PHOCtSS *G!ED VARIANCE » 148.9629
0.5493
0.6035
2.3421
4.5444 1090.0000
FLOW TOT • 1090.00
PROCESS wGTEU VARIANCE • 4.544424
1.3B63
1.3b63
3.09S3
1.4979
1.3863
1.3B6J
1.3063
l.JdhJ
1.609*
1,09Mb
1.6094
1.09Bb
1.7V1B
ii07W*
O.OOUU
0.0000
0.0796
O.UZ«9
0.0000
0.0000
0 . 0 0 0 0
0.0000
0.0000
U.OOOG
o.oooo
0.0000
u.OOOO
o.onuo
4.0210
4.0^10
22.2107
4.4956
4.0210
4.0210
4.0210
4.05
O.JU21
0.6793
181.0000
23.7000
B040.0&00
454.0000
313.5UOO
90b.OOOO
454.0000
33154.0000
6.6000
213.0000
559.0000
416.0000
8U1.0000
12400.0000
FLOW TOT • 58003. BO
KGTEU VARIANCE • 0.9771765
1.9459 0.0000 H.lb83 24.69b6 5.6000
3.7432 0.6272 49.4046 699.0445 63.6000
2.3979 0.0000 12.B674 60.9854 27260,0000
4.110V 0. OOOd 71.3554 18Tb.»26«. 2010.0000
FLOw I0| « 29J39.20
PKUCtSb uttlLU VARIANCE » 187.100?
1.3540
0.131(5
4.1341
2.3810 40B.OOOO
TOT « 406.00
PROCESS wUlEU VARIANCE • 2.3S1B21
PROCESS STREAMS Ml AND M2 DELETED BECAUSE CONTAMINATED.
D-10
-------
-11-
TABLE 3
PM&P DATA FDR THE CONTACT COOLING AND HEATING WATER SUBCATEGORY
PM&F DATA FOR CONTACT COOLING AND HEATING SUBCATEGORY
STREAMS M-l AND M-2 DELETED
POLLUTANT PROCESS STREAM
rss
CALEND
CALEND
CALEND
CAST
MOLD
THERM
B-2
E-2
F-l
DAY!
4.0000
3.0000
6.000U
OAY2
4.0000
3.0UOO
PAY3 Of
2.00HO 2
b.OUOu 2
P-l
PROC POOLED SO • 0.3530
PROC EXPECTED VALUE • 3.409589
2.0000 . .
PHfIC POOLED SO • 0.4936
PKOC EXPECTED VALUE • 2.Z5913/
EXTRUDE
EXTRUDE
£xm»n£
tXTRUOE
EXTHUDE
EXTRUDE
EXTrtUDE
tXTRUPE
ExTHunt
tXTRUOE
EXTRUDE
tXTRUOE
EXTRUDE
EXTRUDE
6-1
0-3
£-3
F-6
6-1
K-Z
K.-3
K-4
N-2
N-3
f)-l
0-2
R-l
»-2
4.0000
4.0000
t.OOOi)
.
22.0UOO
6.0000
4.0UOO
4.0000
l.oooo
•
1.0000
l.O&OO
1.0000
1.0000
.
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2.0UOP
l.oooo
4.0noo
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4.0000
4.0000
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1.0000
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2
1
1
2
2
2
0
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POOLED SO • U.4249
PHOC EXPECTED VALUE
H-4 4.0000
C-l 104.COOO
J-l 4. (1006
J-? 36.0000
77.0000
• 3.405251
. 0
1H.OQOO 2
0
PROC POOLt11 SU « 0.93oO
PROC EXPECTED VALUE «
F-2
l.oooo
2.0HOO
PHOC POULED SD • 0.4002
PHOC
i.nuno 2
1.364*59
LO&MtAN S>UM SQUARE
EIJ
VIJ
AVG FLOW
1.3063
1.0594
1.4999
O.OOUO
0.2425
0.2582
4.2584
3.0708
4.7709
2.4183 410.0000
1.2576 3157.0000
3.0355 530.0000
FLOfc TOT • 4097.00
PROCESS NOTED VARIANCE • 1.603742
0.6931 0.0000 2.2591 1.4002 1090.0000
FLOW TOT " 1090.00
PROCESS wGlED VARIANCE • 1.408235
1.3063
1.3d63
1.0594
o.oouo
2.2JH7
1.521*
1.3863
1.3U63
o.ouoo
G.ODOO
o.ouoo
ft. 0000
O.OoOG
U.OoOu
0.0000
U.OQOO
0.2*25
O.OOUO
1.4531
0.1096
0.0000
O.UOOO
O.OOUO
0.0000
0.0001
O.t)0l(0
O.OOUO
0.000"
4.3778
4.3776
3.1570
1.0945
10.2669
5.0114
4.3778
4.377b
1.0945
1.094!>
1.0945
1.0945
l.OSUb
1.0V45
3.7910
3.7910
1.9718
0.2370
20.6546
4.9686
3.T91B
3.7918
0.2370
0.2370
0.2370
0.2370
0.2370
0.2370
181.0000
23.700U
B040.0000
454.0000
313.5000
908.0000
454,0000
33154.0000
6.6000
213. 0000
559.0000
416.0000
Btil.OUOO
12*00,0000
FLO* TOT « 58003.60
PHOCtSb KbltD VARIANCE • 2.735160
1.3bb3 0.0000 6.2105 54.4100 5.6000
J.9b9b 1.7590 81.4080 9346.0067 63.6000
1.346J U.OOUO 6.2105 54.4100 27260.0000
3.bt)35 0.0000 55.0947 4407.2072 2010.0000
FLOW TOT • 29J39.2U
PROCESS wGTEU VARIANCE • 372.7630
0.2310
0.3203
1.3650
0.3236 408.0000
FLON T01 • 406.00
VARIANCE • 0.3236007
PROCESS STREAMS Ml AND M2 DELETED BECAUSE CONTAMINATED.
D-ll
-------
-12-
In basing the effluent limitations guidelines for 6005, O&G, and TSS on
the raw waste concentrations, the Agency developed effluent limitations that
reflect the distribution of the process-types within the contact cooling and
heating water subcategory. To do this, EPA used the PM&F data for the question-
naire surveys of the industry to estimate the relative number of processes by
process-type within the contact cooling and heating water subcategory. The rela-
tive number of processes by process-type establishes a weight for each process-
type which is the ratio of the number of processes of each type to the total
number of processes in the survey data base for this subcategory. The weights
are:
Type of Process Weight
Calendering 0.0093
Casting 0.0140
Extrusion 0.8528
Molding 0.0724
Thermof orming 0.0211
Coating & Laminating 0.0304.
Consequently, the extrusion process type has the most weight because the
largest number of processes for the contact cooling and heating water sub-
category are extrusion processes. Within each process type, process streams
were flow-weighted. As suggested by cortmenters, flow-weighting gives more
weight to sampled process streams where water use was most intense. To obtain
the flow-weight for a process stream within a process type, the average process
stream flow (shown in Table 3) is normalized to sum to one within the process-
type by dividing the process stream flow by the total stream flow within the
process-type. For the limitations computation, each process stream is assigned
a weight that is the product of the weight for the process type (shown above)
and the individual flow-weight within the process-type. For example, to compute
the weight for extrusion process stream, E3, of 0.1182 shown in Table IV.A.I in
Appendix IVA to this memorandum, we use the weight for the extrusion process-type
of 0.8528 shown above, the average stream flow for E3 of 8040 1/hr. (Table 3)
and the total flow for sampled extrusion processes of 58003.8 1/hr. (Table 3).
The weight for process stream E3 is determined by:
Extrusion weight x flow for E3/total flow for extrusion processes
= 0.8528 x 8040/58003.8
= 0.8528 x 0.1386
= 0.1182.
The resulting process stream weights used in the limitations computations are
displayed in Appendix IVA.
The 99th percentile daily limitations for the contact cooling and heating
water subcategory were computed according to the methodology shown in Appen-
dix IVA. This methodology was used to represent the subcategory process-types
and the flow within the process-types. The daily 99th percentile concentration
values for this subcategory are shown in Table 6.
D-12
-------
-13-
Calculation of TSS Concentration - Finishing Water Subcategory
Hie only pollutant regulated in the finishing water subcategory is TSS.
Since proposal, the cleaning and finishing water subcategory was split into two
subcategories. In response to comments, the Agency collected additional data
and found that TSS was the only pollutant present in treatable concentrations
in finishing water. The Agency based the TSS concentration values shown in
Table 6 for the finishing water subcategory on settling technology. The TSS
effluent concentrations were obtained by multiplying the estimated long-term
average TSS effluent concentration for a settling unit by the daily and
monthly variability factors described below.
Long-Term Average TSS Concentration
A long-term average TSS effluent concentration for a settling unit
was calculated by multiplying the flow-weighted TSS concentration in
finishing water (see Table 4) times a percent removal. The percent removal
(i.e., 82 percent) was reported in the technical development document for
the proposed PM&F regulation (pg. 194). It was obtained from the Treat-
ability Manual, Volume III, Technologies for Control/Removal of Pollutants,
July 1980, US EPA 600-8-80-042C. The estimated long-term TSS effluent
concentration for the settling unit is:
91 mg/1 x 0.18 = 16 rag/1.
This concentration was used to calculate the maximum for one day and the
maximum of monthly average concentrations for TSS because effluent data
for the treatment of finishing water alone in a settling unit are not
available.
Variability Factors
In the absence of effluent data for a settling unit that treats only
finishing water, we considered the transfer of variability factors from
other industrial categories. However, we were unable to find an appropriate
data base for the transfer of those factors. For this reason, the vari-
ability factors used to calculate the final BPT effluent limitations guide-
lines for the finishing water subcategory are based on the variability of
the raw TSS concentrations found in finishing waters.
The TSS daily variability factor, VF(1), for the finishing processes
is the ratio of the flow-weighted average of the lognormal 99-th percen-
tile estimates to the flow-weighted average of the lognormal expectations.
In Appendix IVB, we shown that this ratio is
A A
VF(1) = exp(2.326a - a2/2)
when a pooled estimate of o is used. In this case o = 1.216 and
VF(1) = 8.1.
The Central Limit Theorem was used to compute the 95th percentile
variability factor for an average of 30 samples. For this approximation,
D-13
-------
-14-
we used the flow weighted averages of the log-normal expectations and the
variances to compute a subcategory expectation and variance. As shown in
Appendix IVB, the monthly variability factor is
VF(30) = 1 + 1.6449(V/30)-5/E
= 1 + 1.6449(1.89781 x 10^/30)-5/102.4
= 2.3
The maximum for one day and the maximum for average monthly pollutant
concentrations used to calculate the final BPT effluent limitations guide-
lines for TSS for the finishing water subcategory are presented in Table 5.
BPT Effluent Limitations Guidelines
The concentrations used to calculate the final BPT effluent limitations
guidelines for the PM&F category are presented in Table 6. These concentrations
are multiplied by the average process water usage flow rate for a process to
obtain the mass of a pollutant that can be discharged from that process.
D-14
-------
-15-
TABLE 4
SUMMARY OF TSS CONCENTRATION DATA FOR THE FINISHING WATER SUBCATEGORY
TSS (mg/1)* Average
Leg Sum
Flow
Process Day 1
1-4
N-l
0-1
63
4
12.55
Day 2 Day 3
289 1359
1
6.3 -
(mg/1)
570.3
2.5
9.4
Mean (y|) Squares (SSi)
5.675
0.693
2.185
4.717
0.961
0.237
D.F. K
2
1
1
)** (1/hr.)
1220
2760
4160
Pooled standard deviation
Flow-weighted:
Average Concentration
Average log-normal expectation, E
Average of log-normal
99th percentiles
Average log-normal variance, V
1.216
91 mg/1
102.4 mg/1
827.4 mg/1
1.89781 x I05(mg/l)2
* Duplicate concentrations for TSS samples were averaged.
** Degrees of freedom equal to number of samples for the process minus one.
D-15
-------
-16-
TABLE 5
EFFLUENT TSS CONCENTRATIONS - FINISHING WATER SUBCATEGORIES
Variability
Factor Long-Term Average Concentration*
Maximum for One Day 8.1 16 mg/1 130 mg/1
Maximum for Monthly
Average 2.3 16 mg/1 37 mg/1
* Long-term average multiplied by variability factor.
D-16
-------
-17-
TABLE 6
CONCENTRATIONS USED TO CALCULATE THE FINAL BPT EFFLUENT LIMITATIONS GUIDELINES*
Maximum for
Maximum for One Day Monthly Averages
Subcategory Pollutant (mg/1) (mg/1)
Cooling & Heating BODS 26
Water O&G 29
TSS 19
Cleaning Water BODS 49 22
O&G 71 17
TSS 117 36
Finishing Water TSS 130 37
* These values are multiplied by the average process water usage flow rate for
a process to obtain the mass of pollutants that can be discharged from the
process.
D-17
-------
APPENDIX I
8005, O&G and TSS Data for Untreated PM&F Process Water by Subcategory
D-18
-------
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D-24
-------
APPENDIX II
Plastics Manufacturing Plants (PMP)
A) PM&P Data: Influent and Effluent
BODS, O&G and TSS
B) Summary Statistics for PMP Data
C) Probit Plots for PMP Oil and
Grease Data
D-25
-------
APPENDIX IIA
PMP Data: Influent and Effluent BOD, O&G and TSS
D-26
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