United States
Environmental Protection
Agency
Industrial Technology Division
WH 552
WKhington, DC 20460
EPA 440/1-87/009
October 1987
Development Fine
Document for
Effluent Limitations
Guidelines and
Standards for the
Organic Chemicals/
Plastics and Synthetic
Fibers
Point Source Category
Volume I
-------
DEVELOPMENT DOCUMENT
FOR
EFFLUENT LIMITATIONS GUIDELINES
NEW SOURCE PERFORMANCE STANDARDS
AND
PRETREATMENT STANDARDS
FOR THE
ORGANIC CHEMICALS
AND THE
PLASTICS AND SYNTHETIC FIBERS
POINT SOURCE CATEGORY
Volume I
Lee M. Thomas
Administrator
Lawrence J. Jensen
Assistant Administrator for Water
William A. Whittington
Director
Office of Water Regulations and Standards
Devereaux Barnes, Director
Industrial Technology Division
Marvin B. Rubin
Chief, Chemicals Industry Branch
Elwood H. Forsht
Senior Project Officer
Frank H. Hund
Hugh E. Wise
Janet K. Goodwin
Wendy D. smith U.S. Environmental Protection Agency
Project Team Region 5, Library (pL- 12J)
Octoberl987
Industrial Technology Division
Office of Water Regulations and Standards
U.S. Environmental Protection Agency
Washington, D.C. 20460
-------
ABSTRACT
This document describes the technical development of the U.S.
Environmental Protection Agency's promulgated effluent limitations guidelines
and standards that control the discharge of pollutants into navigable waters
and publicly owned treatment works (POTWs) by existing and new sources in the
organic chemicals, plastics, and synthetic fibers point source category. The
regulation establishes effluent limitations guidelines attainable by the
application of the "best practicable control technology currently available"
(BPT) and the "best available technology economically achievable" (BAT),
Pretreatment standards applicable to existing and new discharges to POTWs
(PSES and PSNS, respectively), and new source performance standards (NSPS)
attainable by the application of the "best available demonstrated control
technology." The regulation was promulgated under the authority of Sections
301, 304, 306, 307, 308, and 501 of the Clean Water Act (the Federal Water
Pollution Control Act Amendments of 1972, 33 U.S.C. 1251 et seq., as amended).
It was also promulgated in response to the Settlement Agreement in Natural
Resources Defense Council, Inc. v. Trian, 8 ERC 2120 (D.D.C. 1976), modified,
12 ERC 1833 (D.D.C.).
-------
TABLE OF CONTENTS
VOLUME I
I. INTRODUCTION
A. LEGAL AUTHORITY 1-1
1. Best Practicable Control Technology Currently
Available (BPT) 1-2
2. Best Available Technology Economically
Achie'vable (BAT) 1-3
3. Best Conventional Pollutant Control
Technology (BCT) 1-3
4. New Source Performance Standards (NSPS) 1-4
5. Pretreatment Standards for Existing
Sources (PSES) 1-4
6. Pretreatment Standards for New Sources (PSNS). . . . 1-4
B. HISTORY OF OCPSF RULEMAKING EFFORTS 1-5
II. SUMMARY AND CONCLUSIONS
A. OVERVIEW OF THE INDUSTRY II-l
B. CONCLUSIONS II-5
1. Applicability of the Promulgated Regulation II-5
2. BPT II-6
3. BCT II-8
4. BAT II-8
5. NSPS 11-11
6. PSES 11-16
7. PSNS 11-17
III. INDUSTRY DESCRIPTION
A. INTRODUCTION III-l
B. DEFINITION OF THE INDUSTRY III-3
1. Standard Industrial Classification System III-3
2. Scope of the Final Regulation III-3
3. Raw Materials and Product Processes 111-20
4. Geographic Distribution 111-32
5. Plant Age 111-32
6. Plant Size 111-35
7. Mode of Discharge 111-41
C. DATA BASE DESCRIPTION. ." 111-41
1. 1983 Section 308 Questionnaire Data Base 111-41
2. Daily Data Base Development 111-46
3. BAT Data Base 111-47
iii
-------
TABLE OF CONTENTS (Continued)
IV. SUBCATEGORIZATION
A. INTRODUCTION IV-1
B. BACKGROUND IV-2
1. March 21, 1983, Proposal IV-2
2. July 17, 1985, Federal Register NOA IV-3
3. December 8, 1986, Federal Register IV-5
C. FINAL ADOPTED BPT AND BAT SUBCATEGORIZATION
METHODOLOGY AND RATIONALE IV-9
1. Performance and Treatment System Shifts IV-12
2. Flow and Total Production Adjustment Factors .... IV-13
b. FINAL ADOPTED BAT SUBCATEGORIZATION APPROACH IV-16
E. SUBCATEGORIZATION FACTORS IV-18
1. Introduction IV-18
2. Manufacturing Product/Process IV-19
3. Raw Materials IV-22
4. Facility Size IV-24
5. Geographical Location IV-24
6. Age of Facility and Equipment IV-26
7. Wastewater Characteristics and Treatability IV-28
V. WATER USE AND WASTEWATER CHARACTERISATION
A. WATER USE AND SOURCES OF WASTEWATER V-l
B. WATER USE BY MODE OF DISCHARGE V-3
C. WATER USE BY SUBCATEGORY '' V-3
D. WATER REUSE AND RECYCLE V-23
1. Water Conservation and Reuse Technologies V-23
2. Current Levels of Reuse and Recycle V-24
E. WASTEWATER CHARACTERIZATION V-29
1. Conventional Pollutants V-29
2. Occurrence and Prediction of Priority Pollutants . . V-49
iv
-------
TABLE OF CONTENTS (Continued)
Page
F. RAW WASTEWATER CHARACTERIZATION DATA V-89
1. General V-89
2. Raw Wastewater Data Collection Studies V-90
3. Screening Phase I V-90
4. Screening Phase II V-94
5. Verification Program V-94
6. EPA/CMA Five-Plant Sampling Program V-101
7. 12-Plant Long-Term Sampling Program V-103
G. WASTEWATER DATA SUMMARY V-105
1. Organic Toxic Pollutants V-105
2. Toxic Pollutant Metals V-112
VI. SELECTION OF POLLUTANT PARAMETERS
A. INTRODUCTION VI-1
B. CONVENTIONAL POLLUTANT PARAMETERS VI-2
1. Five-Day Biochemical Oxygen Demand (BOD ) VI-2
2. Total Suspended Solids (TSS) VI-3
3. pH VI-4
4. Oil and Grease (O&G) VI-5
C. NONCONVENTIONAL POLLUTANT PARAMETERS VI-6
1. Chemical Oxygen Demand (COD) VI-6
2. Total Organic Carbon (TOC) VI-6
D. TOXIC POLLUTANT PARAMETERS VI-7
E. SELECTION CRITERIA VI-9
1. Conventional Pollutants VI-9
2. Nonconventional Pollutants VI-10
3. Toxic Pollutants VI-10
REFERENCES VI-44
VII. CONTROL AND TREATMENT TECHNOLOGIES
A. INTRODUCTION VII-1
B. BEST MANAGEMENT PRACTICES VII-4
1. In-Plant Source Controls VII-4
2. Operation and Maintenance (O&M) Practices VII-9
-------
TABLE OF CONTENTS (Continued)
C. IN-PLANT TREATMENT TECHNOLOGIES VII-11
1. Introduction VII-11
2. Chemical Oxidation (Cyanide Destruction) VII-13
3. Chemical Precipitation VII-18
4. Chemical Reduction (Chromium Reduction) VII-27
5. Gas Stripping (Air and Steam) VII-29
6. Solvent Extraction VII-36
7. Ion Exchange VII-39
8. Carbon Adsorption VII-40
9. Distillation VII-42
10. Reverse Osmosis VII-44
11. Ultrafiltration VII-46
12. Resin Adsorption VII-48
13. In-Plant Biological Treatment VII-48
D. END-OF-PIPE TREATMENT TECHNOLOGIES VII-49
1. Introduction VII-49
2. Primary Treatment Technologies VII-51
3. Secondary Treatment Technologies VII-61
4. Polishing and Tertiary Treatment Technologies. . . . VII-105
E. TOTAL TREATMENT SYSTEM PERFORMANCE VII-125
1. Introduction VII-125
2. BPT Treatment System VII-127
3. Nonbiological Treatment Systems VII-127
4. BAT Treatment System VII-137
F. WASTEWATER DISPOSAL VII-138
1. Introduction VII-138
2. Deep Well Injection VII-138
3. Off-Site Treatment/Contract Hauling VII-147
4. Incineration VII-148
5. Evaporation VII-149
6. Surface Impoundment VII-149
7. Land Application VII-150
G. SLUDGE TREATMENT AND DISPOSAL VII-150
H. LIMITATIONS DEVELOPMENT VII-153
1. BPT Effluent Limitations VII-153
2. BAT Effluent Limitations VII-183
3. BAT and PSES Metals and Cyanide Limitations VII-219
4. BAT Zinc Limitations for Plants Manufacturing
Rayon by the Viscose Process and Acrylic
Fibers by the Zinc Chloride/Solvent Process. . . . VII-227
vi
-------
TABLE OF CONTENTS (Continued)
Page
5. PSES Effluent Limitations VII-228
REFERENCES VII-230
VOLUME II
VIII. ENGINEERING COSTS AND NON-WATER QUALITY ASPECTS
A. INTRODUCTION VIII-1
1. BPT Costing Methodology VIII-2
2. BAT Costing Methodology VIII-7
3. PSES Costing Methodology VIII-24
4. Other Factors VIII-26
B. BPT TECHNOLOGIES VIII-40
1. Activated Sludge VIII-40
2. Biological Treatment Upgrades VIII-56
3. Chemically Assisted Clarification VIII-67
4. Filtration Systems VIII-77
5. Polishing Ponds VIII-78
6. Algae Control VIII-84
C. BAT AND PSES TECHNOLOGIES VIII-95
1. Steam Stripping VIII-95
2. Activated Carbon Systems VIII-119
3. Coagulation/Flocculation/Clarification System. . . VIII-139
4. Cyanide Destruction VIII-180
5. In-Plant Biological Treatment VIII-187
D. ADDITIONAL COSTS VIII-197
1. Contract Hauling VIII-197
2. Monitoring Costs VIII-198
3. Sludge Disposal and Incineration VIII-203
4. RCRA Baseline Costs VIII-222
E. WASTEWATER AND AIR EMISSION LOADINGS VIII-236
1. BPT Conventional Pollutant Wastewater Loadings . . VIII-236
2. BAT and PSES Toxic Pollutant Wastewater
Loadings VIII-236
3. BAT and PSES Toxic Pollutant Air Emission
Loadings VIII-270
vn
-------
TABLE OF CONTENTS (Continued)
IX. EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
A. INTRODUCTION IX-1
1. Regulated Pollutants IX-2
2. BPT Subcategorization IX-2
B. TECHNOLOGY SELECTION IX-2
C. BPT EFFLUENT LIMITATIONS GUIDELINES IX-5
D. COST AND EFFLUENT REDUCTION BENEFITS IX-9
E. IMPLEMENTATION OF THE BPT EFFLUENT LIMITATIONS
GUIDELINES IX-9
F. NON-WATER QUALITY ENVIRONMENTAL IMPACTS IX-12
1. Air Pollution IX-12
2. Solid Waste IX-13
3. Energy Requirement IX-13
X. EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
A. INTRODUCTION X-l
B. BAT SUBCATEGORIZATION X-l
C. TECHNOLOGY SELECTION X-2
1. Option I X-3
2. Option II X-3
3. Option III X-4
D. POLLUTANT SELECTION X-4
E. BAT EFFLUENT LIMITATIONS GUIDELINES X-10
1. Volatiles Limits X-ll
2. Cyanide Limitations X-ll
3. Metals Limitations X-12
4. Other Organic Pollutants X-28
F. COST AND EFFLUENT REDUCTION BENEFITS IMPLEMENTATION
OF THE BAT EFFLUENT X-31
VI11
-------
TABLE OF CONTENTS (Continued)
Page
G. LIMITATIONS GUIDELINES X-31
1. NPDES Permit Limitations X-31
2. NPDES Monitoring Requirements X-32
H. NON-WATER QUALITY ENVIRONMENTAL IMPACTS X-36
1. Air Pollution X-37
2. Solid Waste X-37
3. Energy Requirements X-37
XI. EFFLUENT QUALITY ATTAINABLE THROUGH THE APPLICATION OF
NEW SOURCE PERFORMANCE STANDARDS (NSPS)
A. INTRODUCTION XI-1
B. POLLUTANT AND TECHNOLOGY SELECTION XI-1
XII. EFFLUENT QUALITY ATTAINABLE THROUGH THE PRETREATMENT
STANDARDS FOR EXISTING SOURCES AND PRETREATMENT
STANDARDS FOR NEW SOURCES
A. INTRODUCTION XII-1
B. POLLUTANT SELECTION XII-1
C. TECHNOLOGY SELECTION XII-2
D. PSES AND PSNS XII-3
E. COST AND EFFLUENT REDUCTION BENEFITS XII-6
F. NON-WATER QUALITY ENVIRONMENTAL IMPACTS XII-6
1. Air Pollution XII-7
2. Solid Waste XII-7
3. Energy Requirements XII-7
XIII. BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY XIII-1
XIV. ACKNOWLEDGEMENTS XIV-1
XV. GLOSSARY XV-1
APPENDIX III-A: PRODUCT LISTINGS BY INDUSTRIAL SEGMENT III-A1
APPENDIX IV-A: RATIONALE FOR THE FORM OF THE BPT BOD
REGRESSION MODEL IV-A1
IX
-------
TABLE OF CONTENTS (Continued)
Page
APPENDIX VI-A: LIST OF THE 126 PRIORITY POLLUTANTS VI-Al
APPENDIX VII-A: BPT LONG-TERM AVERAGE BOD AND TSS PLANT-
SPECIFIC TARGETS VII-A1
APPENDIX VII-B: RAW WASTEWATER AND TREATED EFFLUENT BOD , TSS,
COD, AND TOC DATA BEFORE AND AFTER ADJUSTMENT
BY PLANT-SPECIFIC DILUTION FACTORS VII-B1
APPENDIX VII-C: LISTING OF 69 BPT DAILY DATA PLANTS INCLUDED
AND EXCLUDED FROM BPT VARIABILITY
FACTOR CALCULATIONS VII-C1
APPENDIX VII-D: BPT STATISTICAL METHODOLOGY VII-Dl
APPENDIX VII-E: DISTRIBUTIONAL HYPOTHESIS TESTING VII-E1
APPENDIX VII-F:. BAT STATISTICAL METHODOLOGY VII-Fl
APPENDIX VII-G: EVALUATION OF THE VALIDITY OF USING FORM 2C
DATA TO CHARACTERIZE PROCESS AND FINAL
EFFLUENT WASTEWATER JUNE 17, 1985 VII-G1
APPENDIX VIII-A: METHODOLOGY FOR CALCULATING BPT TARGETS AND
IMPUTING MISSING ACTUAL BOD AND TSS
EFFLUENT VALUES VIII-A1
APPENDIX VIII-B: BPT, BAT, AND PSES COMPLIANCE COST ESTIMATES
AND TECHNOLOGY BASIS VIII-B1
APPENDIX VIII-C: BPT PLANT-BY-PLANT BOD5 AND TSS LOADINGS VIII-C1
APPENDIX VIII-D: BAT AND PSES PLANT-BY-PLANT TOXIC POLLUTANT
WASTEWATER LOADINGS VIII-D1
APPENDIX VIII-E: BAT AND PSES PLANT-BY-PLANT AIR EMISSION
LOADINGS VIII-E1
-------
LIST OF FIGURES
VOLUME I
Figure
III-l
IV-1
IV-2
IV-3
IV-4
IV-5
IV-6
IV- 7
V-I
V-2
V-3
V-4
V-5
V-6
V-7
V-8
V-9
V-10
V-ll
V-12
V-13
Relationships Among the SIC Codes Related to the
Production of Organic Chemicals, Plastics, and
Synthetic Fibers
Distribution of Plants by Product and BOD5
(Thermoplastics)
Distribution of Plants by Product and BOD5
(Thermosets)
Distribution of Plants by Product and BOD5 (Rayon) . . .
Distribution of Plants by Product and BOD& (Fibers). . .
Distribution of Plants by Product and BOD5
(Commodity)
Distribution of Plants by Product and BOD5 (Bulk). . . .
Distribution of Plants by Product and BOD5 (Specialty) .
Primary Feedstock Sources
Coal Tar Refining
Methane
Ethylene
Propylene
Butanes/Butenes
Aromatics
Plastics and Fibers
Plastics and Fibers
Nitroaromatics, Nitrophenols, Benzidines, Phenols,
Nitrosamines
Chlorophenols, Chloroaromatics, Haloaryl Ethers, PCBs. .
Chlorinated C2s, C4, Chloroalkyl Ethers
Chlorinated C3s, Chloroalkyl Ethers, Acrolein,
Acrylonitrile, Isophorone
Page
III-6
IV-30
IV-31
IV-32
IV-33
IV-34
IV-35
I V-3 6
V-57
V-58
V-59
V-60
V-61
V-62
V-63
V-64
V-65
V-66
V-67
V-68
V-69
XI
-------
LIST OF FIGURES (Continued)
Figure
V-14
V-15
V-16
VII-1
VII-2
VIII-1
VIII-2
VIII-3
VIII-4
VIII-5
VIII-6
VIII-7
VIII-8
VIII-9
VIII-10
VIII-11
VIII-12
Halogenated Methanes
Priority Pollutant (PRIPOL) Profile of the
OCPSF Industry
A Chemical Process
Solubility of Metal Hydroxides and Sulfides as a
Function of pH
Plot of Average TSS Effluent Versus BOD5 Effluent
for Plants With Biological Only Treatment With
> = 95% BOD5 Removal or BOD5 Effluent < = 40 mg/1. . . .
VOLUME II
Annualized Capital Cost Versus Additional
BOD Removal
Annualized Unit Capital Cost Curve Versus Additional
BOD5 Removal
Total Capital Cost Curve Versus Flow for Chemically
Assisted Clarification Systems
Annual O&M Cost Curve Versus Flow for Chemically
Assisted Clarification Systems
Land Requirements Curve Versus Flow for Chemically
Assisted Clarification Systems
Total Capital Cost Curve Versus Flow for Multi-
media Filter Systems
Annual O&M Cost Curve Versus Flow for Multi-media
Filter Systems
Land Requirements Curve Versus Flow for Multi-
media Filter Systems
Total Capital Cost Curve Versus Flow for Polishing
Pond Systems
Annual O&M Cost Curve Versus Flow for Polishing
Pond Systems
Land Requirements Curve Versus Flow for Polishing
Pond Systems
Annual O&M Cost Curve Versus Flow for Algae
Control in Polishing Ponds Systems
Page
V-70
V-73
V-75
VII-20
VII-167
VIII-64
VIII-65
VIII-72
VIII-73
VIII-74
VIII-81
VIII-82
VIII-83
VIII-86
VIII-87
VIII-88
VIII-91
Xll
-------
LIST OF FIGURES (Continued)
Figure
VIII-13 Capital Cost Curve Versus Flow for Benzene at
Effluent Concentration of 0.01 mg/1 VIII-111
VIII-14 Capital Cost Curve Versus Flow for Benzene at
Effluent Concentration of 1.0 mg/1 VIII-112
VIII-15 Capital Cost Curve Versus Flow for Hexachloro-
benzene at Effluent Concentration of 0.01 mg/1 .... VIII-113
VIII-16 Capital Cost Curve Versus Flow for Hexachloro-
benzene of Effluent Concentration of 1.0 mg/1 VIII-114
VIII-17 Annual O&M Cost Curve Versus Flow for Benzene
and Hexachlorobenzene VIII-115
VIII-18 Total Capital Cost Curve Versus Flow for Large BAT
In-Plant Control Carbon Treatment Systems;
Medium Carbon Adsorption Capacity VIII-143
VIII-19 Total Capital Cost Curve Versus Flow for Large PSES
In-Plant Control Carbon Treatment Systems;
Medium Carbon Adsorption Capacity VIII-144
VIII-20 Annual O&M Cost Curve Versus Flow for Large BAT
In-Plant Control Carbon Treatment Systems;
Medium Carbon Adsorption Capacity VIII-145
VIII-21 Annual O&M Cost Curve Versus Flow for Large PSES
In-Plant Control Carbon Treatment Systems;
Medium Carbon Adsorption Capacity VIII-146
VIII-22 Total Capital Cost Curve Versus Flow for Large BAT
In-Plant Control Carbon Treatment Systems;
Low Carbon Adsorption Capacity VIII-147
VIII-23 Total Capital Cost Curve Versus Flow for Large PSES
In-Plant Control Carbon Treatment Systems;
Low Carbon Adsorption Capacity VIII-148
VIII-24 Annual O&M Cost Curve Versus Flow for Large BAT
In-Plant Control Carbon Treatment Systems;
Low Carbon Adsorption Capacity VIII-149
VIII-25 Annual O&M Cost Curve Versus Flow for Large PSES
In-Plant Control Carbon Treatment Systems;
Low Carbon Adsorption Capacity VIII-150
VIII-26 Total Capital Cost Curves Versus Flow for Large
End-of-Pipe Carbon Treatment Systems (On-site
Carbon Regeneration Systems) VIII-151
Xlll
-------
LIST OF FIGURES (Continued)
VIII-27 Annual O&M Cost Curves Versus Flow for Large
End-of-Pipe Carbon Treatment Systems (On-site
Carbon Regeneration Systems) VIII-152
VIII-28 Total Capital Cost Curve Versus Flow for Small
In-Plant and End-of-Pipe Carbon Treatment
Systems (Low, Medium, High Carbon Adsorption
Capacities) VIII-157
VIII-29 Annual O&M Cost Curve Versus Flow for Small BAT
In-Plant Control Carbon Treatment Systems;
Medium Carbon Adsorption Capacity VIII-158
VIII-30 Annual O&M Cost Curve Versus Flow for Small PSES
In-Plant Control Carbon Treatment Systems;
Medium Carbon Adsorption Capacity VIII-159
VIII-31 Annual O&M Cost Curve Versus Flow for Small BAT
In-Plant Control Carbon Treatment Systems;
Low Carbon Adsorption Capacity VIII-160
VIII-32 Annual O&M Cost Curve Versus Flow for Small PSES
In-Plant Control Carbon Treatment Systems;
Low Carbon Adsorption Capacity VIII-161
VIII-33 Annual O&M Cost Curves Versus Flow for Small
End-of-Pipe Carbon Treatment Systems VIII-162
VIII-34 Land Requirements Curve Versus Flow for Activated
Carbon Treatment Systems VIII-163
VIII-35 Total Capital Cost Curve Versus Flow for
Coagulation/Flocculation/Clarification Systems VIII-166
VIII-36 Land Requirements Curve Versus Flow for
Coagulation/Flocculation/Clarification Systems VIII-168
VIII-37 Annual O&M Cost Curve Versus Flow for
Coagulation/Flocculation/Clarifieation Systems VIII-169
VIII-38 Comparison of Actual Systems Capital Cost and EPA's
Estimates for Coagulation/Flocculation/
Clarification VIII-173
VIII-39 Total Capital Cost Curve Versus Flow for Sulfide
Precipitation Systems VIII-177
VIII-40 Annual O&M Cost Curve Versus Flow for Sulfide
Precipitation Systems VIII-178
xiv
-------
LIST OF FIGURES (Continued)
Figure Page
VIII-41 Total Capital Cost Curve Versus Flow for Cyanide
Destruction Systems VIII-185
VIII-42 Annual O&M Cost Curve Versus Flow for Cyanide
Destruction Systems VIII-186
VIII-43 Total Capital Cost Curve Versus Flow for Small
In-Plant Biological Treatment Systems VIII-190
VIII-44 Total Capital Cost Curve Versus Flow for Large
In-Plant Biological Treatment Systems VIII-191
VIII-45 Annual O&M Cost Curve Versus Flow for Small
In-Plant Biological Treatment Systems VIII-192
VIII-46 Annual O&M Cost Curve Versus Flow for Large
In-Plant Biological Treatment Systems VIII-193
VIII-47 Land Requirements Curve Versus Flow for Small
In-Plant Biological Treatment Systems VIII-195
VIII-48 Land Requirements Curve Versus Flow for Large
In-Plant Biological Treatment Systems VIII-196
VIII-49 Total Capital Cost Curve Versus Flow for Belt
Filter Press Systems VIII-209
VIII-50 Land Requirements Curve Versus Flow for Belt
Filter Press Systems VIII-210
VIII-51 Annual O&M Cost Curve Versus Flow for Belt
Filter Press Systems VIII-212
VIII-52 Total Capital Cost Curve Versus Flow for
Fluidized Bed Incineration Systems VIII-217
VIII-53 Annual O&M Cost Curve Versus Flow for
Fluidized Bed Incineration Systems VIII-219
VIII-54 Overview of Methodology for Identification of
OCPSF Plants Requiring RCRA Baseline Costing VIII-223
VIII-55 Raw Waste Load Calculation Logic Flow VIII-261
VIII-56 BPT, BAT, and Current Waste Load Calculation
Logic Flow VIII-268
VIII-57 PSES Waste Load Calculation VIII-269
XV
-------
LIST OF TABLES
VOLUME I
Table
II-l BPT Effluent Limitations and NSPS by
Subcategory (mg/1) II-9
II-2 BAT Effluent Limitations and NSPS for the End-of-
Pipe Biological Treatment Subcategory 11-12
II-3 BAT Effluent Limitations and NSPS for the Non-End-
of-Pipe Biological Treatment Subcategory 11-14
II-4 Pretreatment Standards for Existing and New Sources
(PSES and PSNS) 11-18
III-l SIC 2865: Cyclic (Coal Tar), Crudes, and Cyclic
Intermediates, Dyes, and Organic Pigments
(Lakes and Toners) 111-10
III-2 SIC 2869: Industrial Organic Chemicals, Not
Elsewhere Classified 111-12
III-3 SIC 2821: Plastic Materials, Synthetic Resins,
and Nonvulcanizable Elastomers 111-15
III-4 SIC 2823: Cellulosic Man-Made Fibers 111-16
III-5 SIC 2824: Synthetic Organic Fibers, Except
Cellulosic 111-17
III-6 OCPSF Chemical Products Also Listed as SIC 29110582
Products 111-18
III-7 OCPSF Chemical Products Also Listed as SIC 29116324
Products 111-19
III-8 Major Generalized Chemical Reactions and Processes
of the Organic Chemicals, Plastics, and
Synthetic Fibers Industry 111-29
III-9 Plant Distribution by State 111-33
111-10 Distribution of Plants by age of Oldest OCPSF
Process Still Operating as of 1984 111-34
III-ll Plant Distribution by Number of Employees 111-36
111-12 Plant Distribution by Number of Product/Processes
and Product/Product Groups for Primary Producers
That are Also Direct and/or Indirect Dischargers . . . 111-37
xvi
-------
LIST OF TABLES (Continued)
Table Page
111-13 Distribution of 1982 Plant Production Quantity by
OCPSF SIC Group 111-39
111-14 Distribution of 1982 Plant Sales Value by OCPSF
SIC Group 111-40
111-15 Mode of Discharge 111-42
111-16 Data Base Designation 111-49
IV-1 BAT Effluent Estimated Long-Term Average Concentration
Comparison Between Plastics and Organics Plants
and Pure BPT Subcategory Plants IV-40
V-l Total OCPSF Plant Process Wastewater Flow
Characteristics by Type of Discharge V-4
V-2 Total OCPSF Plant Nonprocess Wastewater Flow
Characteristics by Type of Discharge V-5
V-3 Process Wastewater Flow for Primary OCPSF Producers by
Subcategory and Disposal Method V-7
V-4 Process Wastewater Flow During 1980 for Secondary
OCPSF Producers by Subcategory and Disposal Method . . V-8
V-5 Process Wastewater Flow for Primary and Secondary
OCPSF Producers That are Zero/Alternative
Dischargers V-9
V-6 Non-Process Wastewater Flow During 1980 for Secondary
OCPSF Producers and Zero/Alternative Dischargers
by Subcategory and Disposal Method V-10
V-7 Total OCPSF Non-Process Wastewater Flow in 1980 for
Primary Producers by Subcategory and Disposal
Method V-ll
V-8 Non-Process Cooling Water Flow for Primary OCPSF
Producers by Subcategory and Disposal Method V-12
V-9 OCPSF Miscellaneous Non-Cooling Non-Process
Wastewater Flow for Primary Producers by Sub-
category and Disposal Method V-13
V-10 Process Wastewater Flow for Primary OCPSF Producers
by Subcategory and Disposal Method V-14
xvn
-------
LIST OF TABLES (Continued)
Table
V-ll Process Wastewater Flow During 1980 for Secondary
OCPSF Producers by Subcategory and Disposal Method . . V-15
V-12 Process Wastewater Flow for Primary and Secondary
OCPSF Producers That are Zero/Alternative
Dischargers V-16
V-13 Non-Process Wastewater Flow During 1980 for Secondary
OCPSF Producers and Zero/Alternative Dischargers
by Subcategory and Disposal Method V-17
V-14 Total OCPSF Non-Process Wastewater Flow in 1980 for
Primary Producers by Subcategory and Disposal
Method V-18
V-15 Non-Process Cooling Water Flow for Primary OCPSF
Producers by Subcategory and Disposal Method V-19
V-16 OCPSF Miscellaneous Non-Cooling Non-Process Waste-
water Flow for Primary Producers by Subcategory
and Disposal Method V-20
V-17 Water Conservation and Reuse Technologies V-25
V-18 Water Recirculated and Reused by Use for the OCPSF
Industries 1978 Census Data (a) V-27
V-19 Summary of OCPSF Process and Nonprocess Wastewater
Recycle Flow for Primary Producers Excluding
Zero Dischargers V-28
V-20 Summary Statistics of Raw Wastewater BOD Concen-
trations by Subcategory Group and Disposal Methods
Producer = Primary V-32
V-21 Summary Statistics of Raw Wastewater BOD Concen-
trations by Subcategory Group and Disposal Method
Producer = Secondary V-33
V-22 Summary Statistics of Raw Wastewater COD Concen-
trations by Subcategory Group and Disposal Method
Producer = Primary V-34
V-23 Summary Statistics of Raw Wastewater COD Concen-
trations by Subcategory Group and Disposal Method
Producer = Secondary V-35
V-24 Summary Statistics of Raw Wastewater TOC Concen-
trations by Subcategory Group and Disposal Method
Producer = Primary V-36
xviii
-------
LIST OF TABLES (Continued)
Table
V-25 Summary Statistics of Raw Wastewater TOC Concen-
trations by Subcategory Group and Disposal Method
Producer = Secondary V-37
V-26 Summary Statistics of Raw Wastewater TSS Concen-
trations by Subcategory Group and Disposal Method
Producer = Primary V-38
V-27 Summary Statistics of Raw Wastewater TSS Concen-
trations by Subcategory Group and Disposal Method
Producer = Secondary V-39
V-28 Summary Statistics of Raw Wastewater BOD Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Primary V-41
V-29 Summary Statistics of Raw Wastewater BOD Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Secondary V-42
V-30 Summary Statistics of Raw Wastewater COD Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Primary V-43
V-31 Summary Statistics of Raw Wastewater COD Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Secondary V-44
V-32 Summary Statistics of Raw Wastewater TOC Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Primary V-45
V-33 Summary Statistics of Raw Wastewater TOC Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Secondary V-46
V-34 Summary Statistics of Raw Wastewater TSS Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Primary V-47
V-35 Summary Statistics of Raw Wastewater TSS Concen-
trations by Subcategory Group and Disposal Method
(with 95% and 70% Rule) Producer = Secondary V-48
V-36 Generic Procceses Used to Manufacture Organic
Chemical Products V-52
V-37 Major Plastics and Synthetic Fibers Products by
Generic Process V-54
xix
-------
LIST OF TABLES (Continued)
Table Page
V-38 Critical Precursor/Generic Process Combinations
That Generate Priority Pollutants V-72
V-39 Organic Chemicals Effluents with Significant
Concentrations (>0.5 ppm) of Priority Pollutants . . . V-77
V-40 Plastics/Synthetic Fibers Effluents with Significant
Concentrations (>0.5 ppm) of Priority Pollutants . . . V-81
V-41 Priority Pollutants in Effluents of Precursor-
Generic Process Combination V-84
V-42 Overview of Wastewater Sampling Programs Included
in BAT Raw Waste Stream Data Base V-91
V-43 Phase II Screening - Product/Process and Other
Waste Streams Sampled at Each Plant V-95
V-44 Selection Criteria for Testing Priority Pollutants
in Verification Samples V-100
V-45 Number of Sampling Days for 12-Plant Long-Term
Sampling Program V-104
V-46 Summary Statistics for Influent Concentrations for
All OCPSF Plants V-106
V-47 Summary Statistics for Influent Concentrations for
Organics-Only OCPSF Plants V-108
V-48 Summary Statistics for Influent Concentrations for
Plastics-Only OCPSF Plants V-109
V-49 Summary Statistics for Influent Concentrations for
Organics and Plastics OCPSF Plants V-110
V-50 Summary of Priority Pollutant Metal-Product/
Process-Plant Validation V-115
VI-1 Twenty-six Toxic Pollutants Proposed for Exclusion . . . VI-8
VI-2 Frequency of Occurrence and Concentration Ranges
for Selected Priority Pollutants in Untreated
Wastewater VI-12
VI-3 ...Toxic Pollutants Excluded from Regulation for BAT
Subcategories One and Two Under Paragraph 8(a)(iii)
of the Settlement Agreement Because they Were VI-16
xx
-------
LIST OF TABLES (Continued)
Table Page
VI-4 Wastewater Loading for Eight Toxic Pollutants
Being Considered for Paragraph Eight Exclusion .... VI-19
VI-5 Four Toxic Pollutants Reserved from Regulation Under
BAT for Subcategory One VI-21
VI-6 Eight Toxic Pollutants Reserved from Regulation
Under BAT for Subcategory Two VI-21
VI-7 Final PSES Pass-Through Analysis Results (Non-
End-of-Pipe Biological Subcategory Data) VI-23
VI-8 Final PSES Pass-Through Analysis Results (End-of-
Pipe Biological Subcategory Data) VI-25
VI-9 Volatile and Semivolatile Toxic Pollutants
Targeted for Control Due to Air Stripping VI-29
VI-10 Estimated POTW Removal Data from Pilot- or Bench-
scale Studies for Selected Toxic Pollutants VI-35
VI-11 Forty-seven Toxic Pollutants Determined to Interfere
With, Inhibit, or Pass-Through POTWs, and Regulated
Under PSES and PSNS Based on Table VII-7 VI-39
VI-12 Six Toxic Pollutants Determined not to Interfere
With, Inhibit, or Pass-Through POTWs, and Excluded
from Regulation Under PSES and PSNS VI-40
VI-13 Six Toxic Pollutants That Do Not Volatilize
Extensively and Do Not Have POTW Percent
Removal Data VI-40
VI-14 Results of PSES Analysis to Determine if Toxic
Pollutant Removals were "...Sufficiently Controlled
by Existing Technologies..." VI-41
VI-15 Three Toxic Pollutants Excluded from PSES and PSNS
Regulation Under Paragraph 8(a)(iii) of the Settle-
ment Agreement because they were "... Sufficiently
Controlled by Existing Technologies..." VI-42
VI-16 Three Pollutants Reserved from Regulation Under
PSES and PSNS Due to Lack of POTW Percent
Removal Data . VI-42
VII-1 Frequency of In-Plant Treatment Technologies in the
OCPSF Industry Listed by Mode of Discharge and
Type of Questionnaire Response VII-12
xxi
-------
LIST OF TABLES (Continued)
Table Page
VII-2 Oxidation of Cyanide Wastes With Ozone VII-15
VII-3 Performance Data for Total Cyanide Oxidation
Using Chlorination VII-16
VII-4 Comparison of OCPSF and Metal Finishing Raw Waste
Metals and Cyanide Concentrations VII-25
VII-5 Raw Waste and Treated Effluent Zinc Concentrations
from Rayon and Acrylic Fibers Manufacturing VII-28
VII-6 Henry's Law Constant (H^ Groupings VII-33
VII-7 Steam Stripping Performance Data VII-35
VII-8 Steam Stripping and Activated Carbon Performance
Data VII-37
VII-9 Daily Activated Carbon Performance Data for
Nitrobenzene, Nitrophenols, and 4,6-Dinitro-
0-Cresol Plant No. 2680T VII-38
VII-10 Typical Ion Exchange Performance Data VII-41
VII-11 Carbon Adsorption Performance Data from Plant
No. 2680T VII-43
VII-12 Performance Data from Hydroxide Precipitation and
Hydroxide Precipitation Plus Filtration for
Metal Finishing Facilities VII-45
VII-13 Ultrafiltration Performance Data for Metals in
Laundry Wastewater-OPA Locka, Florida VII-47
VII-14 Performance Data Basis for In-Plant Biological
Systems VII-50
VII-15 Frequency of Primary Treatment Technologies in the
OCPSF Industry VII-52
VII-16 Frequency of Secondary Treatment Technologies in
the OCPSF Industry VII-53
VII-17 Frequency of Polishing/Tertiary Treatment
Technologies in the OCPSF Industry VII-54
VII-18 Activated Sludge Performance Data for BOD5
and TSS VII-65
xxn
-------
LIST OF TABLES (Continued)
Table
VII-19
VII-20
VII-21
VII-22
VII-23
VII-24
VII-25
VII-26
VII-27
VII-28
VII-29
VII-30
VII-31
VII-32
VII-33
VII-34
VII-35
Lagoon Performance Data for BOD5 and TSS
Attached Growth Treatment Systems Performance
Data for BOD5 and TSS
Typical Design Parameters for Secondary Clarifiers
Treating Domestic Wastewater
Monthly BOD5 Removal Efficiency
Monthly BOD, Efficiency by Region Subset I
(Northern WV, IA, IL, IN, RI)
Monthly BOD5 Efficiency by Region Subset II
(Southern GA, LA, SC, TX)
Monthly BOD Efficiency by Region Subset III
(Middle Latitude VA, NC)
Average Effluent BOD by Month
Average Effluent TSS by Month
Monthly Effluent BOD by Region Subset I
(Northern- WV, IL, RI, IA, IN)
Monthly Effluent BOD5 by Region Subset II
(Southern TX, GA, LA, SC)
Monthly Effluent BOD by Region Subset III
(Middle Latitude VA, NC)
Monthly Effluent TSS by Region Subset I
(Northern- WV, IL, RI, IA, IN)
Monthly Effluent TSS by Region Subset II
(Southern TX, GA, LA, SC)
Monthly Effluent TSS by Region Subset III
(Middle-Latitude— VA, NC)
Monthly Data for Plant #2394
Matrix of 18 Plants With Polishing Ponds Used
as Basis for BPT Option II Limitations
Page
VII-69
VII-72
VII-74
VII-84
VII-85
VII-86
VII-87
VII-91
VII-92
VII-94
VII-95
VII-96
VII-97
VII-98
VII-99
VII-103
VII-106
VII-36 Option III OCPSF Plants With Biological Treatment
Plus Filtration Technology That Pass the BPT
Editing Criteria VII-109
xxi 11
-------
LIST OF TABLES (Continued)
Table Page
VII-37 Summary of Chemically Assisted Clarification
Technology Performance Data VII-114
VII-38 Final Effluent Quality of a Chemically Assisted
Clarification System Treating Bleached
Kraft Wastewater VII-116
VII-39 Classes of Organic Compounds Adsorbed on Carbon .... VII-121
VII-40 Summary of Carbon Adsorption Capacities VII-122
VII-41 End-of-Pipe Carbon Adsorption Performance Data
from Plant No. 3033 VII-126
VII-42 Treatment Technologies for Direct Nonbiological
Plants VII-128
VII-43 Performance of OCPSF Nonbiological Wastewater
Treatment Systems VII-135
VII-44 BOD5 and TSS Reductions by Clarification at
Selected Pulp, Paper, and Paperboard Mills VII-136
VII-45 List of Regulated Toxic Pollutants and the
Technology Basis for BAT Subcategory One and
Two Effluent Limitations VII-139
VII-46 Summary of the Long-Term Weighted Average Effluent
Concentrations for the Final BAT Toxic Pollutant
Data Base for BAT Subcategory One VII-142
VII-46 Summary of the Long-Term Weighted Average Effluent
Concentrations for the Final BAT Toxic Pollutant
Data Base for BAT Subcategory Two VII-144
VII-48 Frequency of Waste Stream Final Discharge and
Disposal Techniques VII-146
VII-49 Frequency of Sludge Handling, Treatment, and
Disposal Techniques VII-151
VII-50 Contaminated and Unconlaminated Miscellaneous
"Nonprocess" Wastewaters Reported in the 1983
Section 308 Questionnaire VII-155
VII-51 Summary Statistics for Determination of BPT BOD5
Editing Criteria by Groups VII-163
VII-52 Rationale for Exclusion of Daily Data Plants
from Data Base VII-173
XXIV
-------
LIST OF TABLES (Continued)
Table Page
VII-53 BPT Subcategory Long-Term Averages (LTAs)
for BOD5 VII-176
VII-54 BPT Subcategory Long-Term Averages (LTAs)
for TSS VII-176
VII-55 Overall Average Versus Production-Proportion-
Weighted Variability Factors VII-178
VII-56 BOD5 Variability Factors for Biological Only
Systems (Effluent BOD < 40 mg/1 or BOD5
Percent Removal > 95%) VII-179
VII-57 TSS Variability Factors for Biological Only
Systems (Effluent BOD5 < 40 mg/1 or BOD
Percent Removal > 95% and TSS < 100 mg/1) VII-181
VII-58 Priority Pollutant (PRIPOL) Data Sources for the
Final OCPSF Rule VII-184
VII-59 Data Retained from Data Sets 3 and 4 Following
BAT Toxic Pollutant Editing Criteria VII-188
VII-60 Explanation of BAT Toxic Pollutant Data Base
Performance Edits VII-189
VII-61 Plant and Pollutant Data Retained in BAT Organic
Toxic Pollutant Data Base for BAT Subcategory
One Limitations VII-191
VII-62 Plant and Pollutant Data Retained in BAT Organic
Toxic Pollutant Data Base for BAT Subcategory
Two Limitations VII-199
VII-63 Treatment Technologies for Plants in the Final BAT
Toxic Pollutant Data Base VII-202
VII-64 BAT Toxic Pollutant Median of Estimated Long-Term
Averages for BAT Subcategory One and Two VII-208
VII-65 Priority Pollutants by Chemical Groups VII-212
VII-66 Individual Toxic Pollutants Variability Factors
for BAT Subcategory One VII-220
VII-67 Individual Toxic Pollutants Variability Factors
for BAT Subcategory Two VII-223
xxv
-------
Table
VII-68
LIST OF TABLES (Continued)
BAT Subcategory One and Two Long-Term Averages and
Variability Factors for Metals and Total Cyanide.
Page
VII-226
VII-69 BAT Zinc Long-Term Averages and Variability Factors
for Rayon (Viscose Process) and Acrylic (Zinc
Chloride/Solvent Process) Fibers Plants VIII-229
VOLUME II
VIII-1 BPT Costing Rules VIII-3
VIII-2 Generic Chemical Processes VIII-8
VIII-3 "Trigger" Values Used as BAT Option II In-Plant
Costing Targets for Plants With End-of-Pipe
Biological Treatment In-Place VIII-10
VIII-4 BAT Long-Term Medians Used as Costing Targets for
Plants Without Biological Treatment In-Place VIII-12
VIII-5 Pollutants to be Controlled Using In-Plant
Biological Treatment VIII-14
VIII-6 High Strippability Priority Pollutants Costed
Steam Stripping for BAT Option IIA and PSES IVA . . . VIII-16
VIII-7 Medium Strippability Priority Pollutants Costed
for Steam Stripping for BAT Option IIA and
PSES Option IVA VIII-17
VIII-8 Medium Adsorpability Priority Costed for Activated
Carbon for BAT Option IIA and PSES Option IVA .... VIII-18
VIII-9 Low Adsorpability Priority Pollutants Costed for
Activated Carbon for BAT Option IIA and PSES
Option IVA VIII-19
VIII-10 High Strippability Priority Pollutants Costed for
Steam Stripping for BAT Option IIB and PSES
Option IIB VIII-20
VIII-11 Medium Strippability Priority Pollutants Costed
for Steam Stripping for BAT Option IIB and
PSES Option IVB VIII-21
VIII-12 Medium Adsorpability Priority Pollutants Costed
for Activated Carbon for BAT Option IIB and
PSES Option IVB VIII-22
xxv i
-------
LIST OF TABLES (Continued)
Table
VIII-13 Low Adsorpability Priority Pollutants Costed
for Steam Stripping for BAT Option IIB and
PSES Option IVB
VIII-14 Overall Averages of the Average Ratio Values
(Process to Total Flow)
VIII-15 Regulated Pollutants and LTMs for PSES Option IV
VIII-16 Temperatures and Temperature Cost Factors Used
to Calculate Activated Sludge Cost and to
Adjust Biological Treatment Upgrade Costs. . .
VIII-17 Land Cost for Suburban Areas
VIII-18 Summary of Land Cost in the United States. . . .
VIII-19 Activated Sludge Default and Replacement Data
for Unit Cost Items Used in Costing Exercise
CAPDET Model (1979)
VIII-20 Activated Sludge K-Values and MLVSS Values
from 308 Questionnaires
VIII-21 Activated Sludge Table of Reported 308
Questionnaire Data
VIII-22 Activated Sludge Table of Reported Capital Cost
Per Gallon and O&M Cost per 1,000 Gallon . . .
VIII-23 Activated Sludge Comparison of CAPDET and
Reported Capital and O&M Costs (1982 Dollars).
VIII-24 Activated Sludge Comparison of Reported and
CAPDET Detention Times (Td)
VIII-25 Activated Sludge Comparison of Reported and
and CAPDET O&M Costs (1982 Dollars)
VIII-26 Activated Sludge Comparison of Operation and
Maintenance Man-Hours
VIII-27 Activated Sludge Table of Reported Operating
and Maintenance Labor Rates (1982 Dollars) . .
VIII-28 Activated Sludge Revised Land Requirements . . .
VIII-29 Capital and Annual Costs of Biological
Treatment Modifications for Activated Sludge
System Upgrades
VIII-23
VIII-25
VIII-27
VIII-30
VIII-33
VIII-37
VIII-42
VIII-43
VIII-45
VIII-46
VIII-48
VIII-49
VIII-50
VIII-52
VIII-54
VIII-55
VIII-58
XXV11
-------
LIST OF TABLES (Continued)
Table
VIII-30 Product Mix of the Five Facilities Used in the
Development of the Capital Cost Curve for
Activated Sludge System Upgrades ,
VIII-31 Current Influent and Effluent BOD5 Concen-
trations at the Five Facilities Used in the
Development of Capital Cost Curves for
Activated Sludge System Upgrades ,
VIII-32 Project Capital and Operation and Maintenance (O&M)
Costs Associated with Activated Sludge
System Upgrades ,
VIII-33 Summary of Chemically Assisted Clarification
Specifications ,
VIII-34 Itemized Capital Costs for Chemically Assisted
Clarifiers ,
VIII-35 Itemized Annual Operating Costs for Chemically
Assisted Clarifiers ,
VIII-36 Benchmark Comparison ,
VIII-37 Summary of Filtration System Specifications. . . . ,
VIII-38 Summary of Capital and O&M Costs for Filtration
Systems 1982 Dollars (March) ,
VIII-39 Summary of Capital and O&M Costs for Polishing
Ponds
VTII-40 Annual Operating Cost for Algae Control in
Polishing Ponds (1982 Dollars)
VIII-41 Ten Treatment Systems With Polishing Ponds
In-Place (At Nine Plants) That Were Costed
Only for Copper Sulfate Addition ,
VIII-42 Summary of Capital and O&M Costs for Polymer
Addition Systems for Upgrading Secondary
Clarifiers
VIII-43 Summary of Polymer Addition Costs for Six
Treatment Systems Selected for Secondary
Clarifier Upgrades
VIII-59
VIII-62
VIII-66
VIII-68
VIII-69
VIII-71
VIII-75
VIII-79
VIII-80
VIII-85
VIII-90
VIII-92
VIII-93
VIII-94
xxviii
-------
LIST OF TABLES (Continued)
Table
VIII-44 Comparison of Predicted and Reported Capital
and O&M Costs for Steam Stripping
VIII-45 Priority Pollutants Divided Into Groups
According to Henry's Constant Values
VIII-46 Reported Steam Stripping Average Influent and
Effluent BAT from the 1983 Supplemental
Questionnaire
VIII-47 Steam Stripping Design Parameters for High
Henry's Law Constant Pollutants
VIII-48 Steam Stripping Design Parameters for Medium
Henry's Law Constant Pollutants
VIII-49 Steam Stripping Design Parameters for Low
Henry's Law Constant Pollutants
VIII-50 Steam Stripping Results for Removal of
Benzene (1982 Dollars)
VIII-51 Steam Stripping Results for Removal of
Hexachlorobenzene (1982 Dollars)
VIII-52 Equations for Determining Computerized Cost
Curves from Steam Stripping Results
(1982 Dollars)
VIII-53 Steam Stripping ($$) Overhead Disposal Cost
Estimates
VIII-54 Steam Stripping Upgrade Costs
VIII-55 Adjustments to CAPDET Default Data and Results
for Activated Carbon Systems
VIII-56 Influent/Effluent Levels of Total Organic
Priority Pollutants of Biological Treatment
Systems for Typical Organic Chemical Plants. .
VIII-57 Summary of In-Plant Carbon Adsorption Capacities
(Ibs of Pollutants Adsorbed/lb Carbon) ....
VIII-58 Carbon Usage Rate for Priority Pollutants
(In-Plant BAT Treatment) (Ibs of Pollutants
Adsorbed/lb Carbon)
VIII-59 Summary of In-Plant Carbon Adsorption Capacities
(Ibs of Pollutants Adsorbed/lb Carbon) ....
VIII-96
VIII-99
VIII-100
VIII-102
VIII-104
VIII-106
VIII-108
VIII-109
VIII-110
VIII-117
VIII-120
VIII-122
VIII-125
VIII-127
VIII-130
VIII-131
XXIX
-------
LIST OF TABLES (Continued)
Table
VIII-60 Carbon Usage Rate for Priority Pollutants
(In-Plant PSES Treatment) (Ibs of Pollutants
Adsorbed/lb Carbon)
VIII-61 Summary of Carbon Adsorption Capacities (End-
of-Pipe) (Ibs of Pollutants Adsorbed/lb
Carbon)
VIII-62 Carbon Usage Rate for Priority Pollutants
(End-of-Pipe Treatment) (Ibs of Pollutants
Adsorbed/lb Carbon)
VIII-63 Granular Activated Carbon Equipment Cost Basis
In-Plant Carbon Treatment System Low Carbon
Adsorption Capacity
VIII-64 Granular Activated Carbon Equipment Cost Basis
In-Plant Carbon Treatment System Low Carbon
Adsorption Capacity
VIII-65 Granular Activated Carbon Equipment Cost Basis
(Erd-of-Pipe Treatment)
VIII-66 Total Capital and O&M Costs for Large In-Plant
Medium Carbon Adsorption Treatment Systems
(1982 Dollars)
VIII-67 Total Capital and O&M Costs for Large In-Plant
Low Carbon Adsorption Treatment: Systems
(1982 Dollars)
VIII-68 Cost Estimate for Large End-of-Pipe Carbon
Treatment Systems (1982 Dollars)
VIII-69 Itemized Capital Cost for Small In-Plant and
End-of-Pipe Carbon Treatment Systems
(1982 Dollars)
VIII-70 Itemized O&M Cost for Small In-Plant Medium
Carbon Treatment Systems (1982 Dollars). . .
VIII-71 Itemized O&M Cost for Small In-Plant Low
Carbon Treatment Systems (1982 Dollars). . .
VIII-72 Itemized O&M Cost for Small End-of-Pipe
Carbon Treatment Systems (1982 Dollars). . .
VIII-73 Itemized Capital Costs for Coagulation/
Flocculation/Clarification Systems
VIII-133
VIII-134
VIII-135
VIII-136
VIII-137
VIII-138
VIII-1AO
VIII-141
VIII-142
VIII-153
VIII-154
VIII-155
VIII-156
VIII-165
XXX
-------
LIST OF TABLES (Continued)
Table
VIII-74
VIII-75
VIII-76
VIII-78
VIII-79
VIII-80
VIII-82
VIII-83
VIII-84
VIII-85
VIII-86
VIII-87
VIII-88
VIII-89
VIII-90
Itemized Annual Operating Costs for Coagulation/
Flocculation/Clarification Systems
Benchmark Comparison
Flocculation/Clarif
Itemized Capital Costs
Systems.
VIII-77 Annual Operating Cost
Systems.
A Comparison of Annual Operating Cost for Lime
Precipitation Systens and Sulfide Precipitation
Systems.
Chemical Precipitatioi
Design Specifications
System
VIII-81 Total Capital and O&M
Destruction Systems
Comparison of Technol
Total Capital and O&M
Biological Treatmen
In-Plant Biological T:
Monitoring Frequencies
Number of Parameters <
Dollars) for Organii
Using Analysis Meth
With Either a More !
Monitoring Frequenc;
or Coagulation/
cation Systems .
for Sulfide Precipitation
for Sulfide Precipitation
Upgrade Costs
for Cyanide Destruction
Cost for Cyanide
gy Costs for PSES Plants
Cost for the In-Plant
Control Systems ....
eatment Land Requirements.
nd Fractions to be Analyzed.
Comparison of Annual Monitoring Cost (1982
and Plastics Facilities
ds 624/625 or 1624/1625
tringent or Less Stringent
Summary of Design Specifications for Belt Filter
Press Systems
Itemized Capital Costs for Belt Filter Press
Systems
Itemized Annual Operating Cost for Belt Filter
Press Systems
Page
VIII-170
VIII-171
VIII-175
VIII-176
VIII-179
VIII-181
VIII-183
VIII-184
VIII-188
VIII-189
VIII-194
VIII-200
VIII-201
VIII-204
VIII-207
VIII-208
VIII-211
XXXI
-------
LIST OF TABLES (Continued)
Table
VIII-91 Summary of Fluidized Bed Incinerator System
Design Specifications
VIII-92 Itemized Capital Costs for Fluidized Bed
Incinerator Systems
VIII-93 Itemized Annual Operating Cost for Fluidized
Bed Incineration Systems
VIII-94 Capital and O&M Costs for the Belt Filter Press
and Fluidized Bed Incineration Systems
VIII-95 Annualized Cost for Sludge Handling Systems. . . .
VIII-96 Parameters Used to Design and Cost Liners and
Monitoring
VIII-97 Liner and Monitoring Well Equipment and
Installation Costs for Selected OCPSF Facilities
VIII-98 Summary of Liner, Monitoring, and Administrative
RCRA Baseline Costs
VIII-99 Summary of BPT, BAT, and PSES Compliance Costs
For Final Regulatory Options (1982 Dollars). . .
VIII-100 Plants With No Cost
VIII-101 Major Products by Process of the Organic
Chemicals Industry
VIII-102 Major Products by Process of the Plastics/
Synthetic Fibers Industry
VIII-103 Generic Chemical Processes
VIII-104 Overview of Wastewater Studies Included in Raw
Wastewater Toxic Pollutant Loadings Calculations
VIII-105 Phase II Screening - Product/Process and Other
Waste Streams Sampled at Each Plant
VIII-106 BPT, BAT Option II, BAT Option III, and PSES
Toxic Pollutant Concentrations Used in Loadings.
VIII-107 BAT Wastewater Toxic Pollutant Loadings
VIII-108 PSES Wastewater Toxic Pollutant Loadings
Page
VIII-214
VIII-215
VIII-218
VIII-220
VIII-221
VIII-226
VIII-228
VIII-232
VIII-233
VIII-234
VIII-239
VIII-247
VIII-250
VIII-251
VIII-255
VIII-263
VIII-271
VIII-273
XXXI1
-------
LIST OF TABLES (Continued)
Table
VIII-109 Priority Pollutants Considered for Estimating
a Portion of the OCPSF Industry Air Emissions
from Wastewater Treatment Systems for 32
Selected VOCs
VIII-110 Volatilization from Pre-Biological Unit Operations
for Selected VOCs
VIII-111 BAT Toxic Pollutants Air Emission Loadings
(Ibs/year)
VIII-112 PSES Toxic Pollutant Air Emission Loadings
(Ibs/year)
IX-1 BPT Effluent Limitations and NSPS by Subcategory
(mg/1)
IX-2 Derivation of BPT Limitations for a Hypothetical
Plant
X-l BAT Effluent Limitations and NSPS for the End-of-
Pipe Biological Treatment Subcategory
X-2 BAT Effluent Limitations and NSPS for the Non-
End-pf-Pipe Biological Treatment Subcategory . .
X-3 Cyanide-Bearing Waste Streams (by product/
process)
X-4 Noncomplexed Metal-Bearing Waste Streams for
Chromium, Copper, Lead, Nickel, and Zinc
(by product/process)
X-5 Complexed Metal Bearing Waste Streams for
Chromium, Copper, Lead, Nickel, and Zinc
(by product/process)
XII-1 Pretreatment Standards for Existing and New
Sources (PSES and PSNS)
Page
VIII-277
VIII-281
VIII-284
VIII-285
IX-8
IX-11
X-6
X-8
X-13
X-15
X-26
XII-4
xxxiii
-------
SECTION I
INTRODUCTION
This document describes the technical development of the U.S.
Environmental Protection Agency's (EPA's) promulgated effluent limitations
guidelines and standards that limit the discharge of pollutants into navigable
waters and publicly owned treatment works (POTWs) by existing and new sources
in the organic chemicals, plastics, and synthetic fibers (OCPSF) point source
category. The regulation establishes effluent limitations guidelines
attainable by the application of the "best practicable control technology
currently available" (BPT) and the "best available technology economically
achievable" (BAT), pretreatment standards applicable to existing and new
discharges to POTWs (PSES and PSNS, respectively), and new source performance
standards (NSPS) attainable by the application of the "best available
demonstrated technology."
A. LEGAL AUTHORITY
This regulation was promulgated under the authority of Sections 301, 304,
306, 307, 308, and 501 of the Clean Water Act (the Federal Water Pollution
Control Act Amendments of 1972, 33 U.S.C. 1251 et seq., as amended) also
referred to as "the Act" or "CWA." It was also promulgated in response to the
Settlement Agreement in Natural Resources Defense Council, Inc. v. Train,
8 ERC 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; July 5, 1984;
January 7, 1985; April 24, 1986; and January 8, 1987.
The Federal Water Pollution Control Act Amendments of 1972 established a
comprehensive program to "restore and maintain the chemical, physical, and
biological integrity of the Nation's waters" (Section 101(a)). To implement
the Act, EPA was required to issue effluent limitations guidelines, pretreat-
ment standards, and NSPS for industrial dischargers.
1-1
-------
In addition to these regulations for designated industrial categories,
EPA was required to promulgate effluent limitations guidelines and standards
applicable to all discharges of toxic pollutants. The Act included a time-
table for issuing these standards. However, EPA was unable to meet many of
the deadlines and, as a result, in 1976, it was sued by several environmental
groups. In settling this lawsuit, EPA and the plaintiffs executed a "Settle-
ment Agreement" that was approved by the Court. This agreement required EPA
to develop a program and adhere to a schedule for controlling 65 "priority"
toxic pollutants and classes of pollutants. In carrying out this program, EPA
was required to promulgate BAT effluent limitations guidelines, pretreatment
standards, and NSPS for a variety of major industries, including the OCPSF
industry.
Many of the basic elements of the Settlement Agreement were incorporated
into the Clean Water Act of 1977. Like the Agreement, the Act stressed con-
trol of toxic pollutants, including the 65 priority toxic pollutants and
classes of pollutants.
Under the Act, the EPA is required to establish several different kinds
of effluent limitations guidelines and standards. These are summarized
briefly below.
1. Best Practicable Control Technology Currently Available (BPT)
BPT effluent limitations guidelines are generally based on the average of
the best existing performance by plants of various sizes, ages, and unit pro-
cesses within the category or subcategory for control of familiar (e.g., con-
ventional) pollutants, such as BODg, TSS, and pH.
In establishing BPT effluent limitations guidelines, EPA considers the
total cost in relation to the effluent reduction benefits, age of equipment
and facilities involved, processes employed, process changes required,
engineering aspects of the control technologies, and nonwater quality
environmental impacts (including energy requirements). The Agency balances
the category-wide or subcategory-wide cost of applying the technology against
the effluent reduction benefits.
1-2
-------
2. Best Available Technology Economically Achievable (BAT)
BAT effluent limitations guidelines, in general, represent the best
existing performance in the category or subcategory. The Act establishes BAT
as the principal national means of controlling the direct discharge of toxic
and nonconventional pollutants to navigable waters.
In establishing BAT, the Agency considers the age of equipment and facil-
ities involved, processes employed, engineering aspects of the control
technologies, process changes, cost of achieving such effluent reduction, and
nonwater quality environmental impacts.
3. Best Conventional Pollutant Control Technology (BCT)
The 1977 Amendments to the Clean Water Act added Section 301(b)(2)(E),
establishing "best conventional pollutant control technology" (BCT) for the
discharge of conventional pollutants from existing industrial point sources.
Section 304(a)(4) designated the following as conventional pollutants: BOD5,
TSS, fecal coliform, pH, and any additional pollutants defined by the Admin-
istrator as conventional. The Administrator designated oil and grease a con-
ventional pollutant on July 30, 1979 (44 FR 44501).
BCT is not an additional limitation, but replaces BAT for the control of
conventional pollutants. In addition to other factors specified in Section
304(b)(4)(B), the Act requires that the BCT effluent limitations guidelines be
assessed in light of a two part "cost-reasonableness" test [American Paper
Institute v. EPA, 660 F.2d 954 (4th Cir. 1981)]. The first test compares the
cost for private industry to reduce its discharge of conventional pollutants
with the costs to POTWs for similar levels of reduction in their discharge of
these pollutants. The second test examines the cost-effectiveness of
additional industrial treatment beyond BPT. EPA must find that limitations
are "reasonable" under both tests before establishing them as BCT. In no case
may BCT be less stringent than BPT.
EPA has promulgated a methodology for establishing BCT effluent limita-
tions guidelines (51 FR 24974, July 8, 1986).
1-3
-------
4. New Source Performance Standards (NSPS)
NSPS are based on the performance of the best available demonstrated
technology. New plants have the opportunity to install the best and most
efficient production processes and wastewater treatment technologies. As a
result, NSPS should represent the most stringent numerical values attainable
through the application of best available demonstrated control technology for
all pollutants (i.e., toxic, conventional, and nonconventional).
5. Pretreatment Standards for Existing Sources (PSES)
PSES are designed to prevent the discharge of pollutants that pass
through, interfere with, or are otherwise incompatible with the operation of
POTWs. The Clean Water Act requires pretreatment standards for pollutants
that pass through POTWs or interfere with either the POTW's treatment process
or chosen sludge disposal method. The legislative history of the 1977 Act
indicates that pretreatment standards are to be technology-based and analogous
to the BAT effluent limitations guidelines for removal of toxic pollutants.
For the purpose of determining whether to promulgate national category-wide
PSES and PSNS, EPA generally determines that there is pass through of pollu-
tants, and thus a need for categorical standards if the nationwide average
percentage of pollutants removed by well-operated POTWs achieving secondary
treatment is less than the percent removed by the BAT model treatment system.
The General Pretreatment Regulations, which serve as the framework for
categorical pretreatment standards, are found at 40 CFR Part 403. (Those
regulations contain a definition of pass through that addresses localized
rather that national instances of pass through and does not use the percent
removal comparison test described above (52 FR 1586, January 14, 1987).)
6. Pretreatment Standards for New Sources (PSNS)
Like PSES, PSNS are designed to prevent the discharge of pollutants that
pass through, interfere with, or are otherwise incompatible with the operation
of a POTW. PSNS are to be issued at the same time as NSPS. New indirect
dischargers, like new direct dischargers, have the opportunity to incorporate
in their plant the best available demonstrated technologies. The Agency con-
siders the same factors in promulgating PSNS as it considers in promulgating
NSPS.
1-4
-------
B. HISTORY OF OCPSF RULEMAKING EFFORTS
EPA originally promulgated effluent limitations guidelines and standards
for the organic chemicals manufacturing industry in two phases. Phase I,
covering 40 product/processes (a product that is manufactured by the use of a
particular process — some products may be produced by any of several proces-
ses), was promulgated on April 25, 1974 (39 FR 14676). Phase II, covering 27
additional product/processes, was promulgated on January 5, 1976 (41 FR 902).
The Agency also promulgated effluent limitations guidelines and standards for
the plastics and synthetic fibers industry in two phases. Phase I, covering
13 product/processes, was promulgated on April 5, 1974 (39 FR 12502). Phase
II, covering eight additional product/processes, was promulgated on January
23, 1975 (40 FR 3716).
These regulations were challenged, and on February 10, 1976, the Court in
Union Carbide v. Train, 541 F.2d 1171 (4th Cir. 1976), remanded the Phase I
organic chemicals regulation. EPA also withdrew the Phase II organic chem-
icals regulation on April 1, 1976 (41 FR 13936). However, pursuant to an
agreement with the industry petitioners, the regulations for butadiene manu-
facture were left in place. The Court also remanded the Phase I plastics and
synthetic fibers regulations in FMC Corp. v. Train, 539 F.2d 973 (4th Cir.
1976) and in response EPA withdrew both the Phase I and II plastics and
synthetic fibers regulations on August 4, 1976 (41 FR 32587) except for the pH
limitations, which had not been addressed in the lawsuit. Consequently, only
the regulations covering butadiene manufacture for the organic chemicals
industry and the pH regulations for the plastics and synthetic fibers industry
have been in effect to date. These regulations were superseded by the regula-
tions described in this report.
In the absence of promulgated, effective effluent limitations guidelines
and standards, OCPSF direct dischargers have been issued National Pollutant
Discharge Elimination System (NPDES) permits on a case-by-case basis using
best professional judgment (BPJ), as provided in Section 402(a)(l) of the CWA.
Subsequent to the withdrawal/suspension of the national regulations cited
above, studies and data-gathering were initiated in order to provide a basis
1-5
-------
for issuing effluent limitations guidelines and standards for this industry.
These efforts provided a basis for the March 21, 1983 proposal (48 FR 11828);
the July 17, 1985 (50 FR 29071), October 11, 1985 (50 FR 41528), and December
8, 1986 (51 FR 44082) post-proposal notices of availability of information;
and the final regulation.
This report presents a summary of the data collected by the Agency since
1976, the data submitted by the OCPSF industry in response to the Federal
Register notices cited above, and the analyses used to support the promulgated
regulations. Section II presents a summary of the findings and conclusions
developed in this document as well as the promulgated regulations. Sections
III through VIII present the technical data and the supporting analyses used
as the basis for the promulgated regulations, and Sections IX through XIII
include the rationale and derivation of the national effluent limitations and
standards. Detailed data displays and analyses are included in the
appendices.
1-6
-------
SECTION II
SUMMARY AND CONCLUSIONS
A. OVERVIEW OF THE INDUSTRY
The organic chemicals, plastics, and synthetic fibers (OCPSF) industry is
large and diverse, and many plants in the industry are highly complex. The
industry includes approximately 750 facilities whose principal or primary
production activities are covered under the OCPSF regulations. There are
approximately 250 other plants that are secondary producers of OCPSF products
(i.e., OCPSF production is ancillary to their primary production activities).
Thus, the total number of plants to be regulated totally or in part by the
OCPSF industry regulation is approximately 1,000. Secondary OCPSF plants may
be part of the other chemical producing industries such as the petroleum
refining, inorganic chemicals, Pharmaceuticals, and pesticides industries as
well as the chemical formulation industries such as the adhesives and
sealants, paint and ink, and the plastics molding and forming industries.
Although over 25,000 different organic chemicals, plastics, and synthetic
fibers are manufactured, less than half of these products are produced in
excess of 1,000 pounds per year.
Some plants produce chemicals in large volumes while others produce only
small volumes of "specialty" chemicals. Large volume production tends to
utilize continuous processes. Continuous processes are generally more effi-
cient than batch processes in minimizing water use and optimizing the consump-
tion of raw materials.
Different products are made by varying the raw materials, the chemical
reaction conditions, and the chemical engineering unit processes. The
products being manufactured at a single large chemical plant can vary on a
weekly or even daily basis. Thus, a single plant may simultaneously produce
many different products using a variety of continuous and batch operations,
and the product mix may change on a weekly or daily basis.
II-l
-------
A total of 940 facilities (based on 1982 production) are included in the
technical and economic studies used as a basis for this regulation. Approxi-
mately 76 percent of these facilities are primary OCPSF manufacturers (over
50 percent of their total plant production involves OCPSF products), and
approximately 24 percent of the facilities are secondary OCPSF manufacturers
that produce mainly other types of products. An estimated 32 percent of the
plants are direct dischargers; about 42 percent discharge indirectly to
publicly owned treatment works (POTWS); and the remaining facilities
(26 percent) are either zero or alternative dischargers, or their discharge
status is unknown. The estimated average daily process wastewater discharge
per plant is 1.31 millions of gallons per day (MGD) for direct dischargers and
0.25 MGD for indirect dischargers. The non-discharging plants use dry
processes, reuse their wastewater, or dispose of their wastewater by deep well
injection, incineration, contract hauling, or by means of evaporation and
percolation ponds.
As a result of the wide variety and complexity of raw materials and
processes used and of products manufactured in the OCPSF industry, an excep-
tionally wide variety of pollutants are found in the wastewaters of this
industry. This includes conventional pollutants (pH, BOD5, TSS, and oil and
grease); an unusually wide variety of toxic priority pollutants (both metals
and organic compounds); and a large number of nonconventional pollutants.
Many of the toxic and nonconventional pollutants are organic compounds
produced by the industry for sale. Others are created by the industry as
by-products of their production operations. This study focused on the
conventional pollutants and on the 126 priority pollutants.
To control the wide variety of pollutants discharged by the OCPSF
industry, OCPSF plants use a broad range of in-plant controls, process
modifications, and end-of-pipe treatment techniques. Most plants have
implemented programs that combine elements of both in-plant control and
end-of-pipe wastewater treatment. The configuration of controls and
technologies differs from plant to plant, corresponding to the differing mixes
of products manufactured by different facilities. In general, direct
dischargers treat their wastes more extensively than indirect dischargers.
II-2
-------
The predominant end-of-pipe control technology for direct dischargers in
the OCPSF industry is biological treatment. The chief forms of biological
treatment are activated sludge and aerated lagoons. Other systems, such as
extended aeration and trickling filters, are also used, but less extensively.
All of these systems reduce biochemical oxygen demand (BOD ) and total
suspended solids (TSS) loadings, and in many instances, incidentally remove
toxic and nonconventional pollutants. Biological systems biodegrade some of
the organic pollutants, remove bio-refractory organics and metals by sorption
into the sludge, and strip some volatile organic compounds (VOCs) into the
air. Well-designed biological treatment systems generally incorporate
secondary clarification unit operations to ensure adequate control of solids.
Other end-of-pipe treatment technologies used in the OCPSF industry
include neutralization, equalization, polishing ponds, filtration, and carbon
adsorption. While most direct dischargers use these physical/chemical
technologies in conjunction with end-of-pipe biological treatment, at least
71 direct dischargers use only physical/chemical treatment.
In-plant control measures employed at OCPSF plants include water
reduction and reuse techniques, chemical substitution, and process changes.
Techniques to reduce water use include the elimination of water use where
practicable, and the reuse and recycling of certain streams, such as reactor
and floor washwater, surface runoff, scrubber effluent, and vacuum seal
discharges. Chemical substitution is utilized to replace process chemicals
possessing highly toxic or refractory properties with others that are less
toxic or more amenable to treatment. Process changes include various measures
that reduce water use, waste discharges, and/or waste loadings while improving
process efficiency. Replacement of barometric condensers with surface
condensers, replacement of steam jet ejectors with vacuum pumps, recovery of
product or by-product by steam stripping, distillation, solvent extraction or
recycle, oil-water separation, and carbon adsorption, and the addition of
spill control systems are examples of process changes that have been
successfully employed in the OCPSF industry to reduce pollutant loadings while
improving process efficiencies.
II-3
-------
Another type of control widely used in the OCPSF industry is physical/
chemical in-plant control. This treatment technology is generally used
selectively on certain process wastewaters to recover products or process
solvents, to reduce loadings that may impair the operation of the biological
system, or to remove certain pollutants that are not treated sufficiently by
the biological system. In-plant technologies widely used in the OCPSF
industry include sedimentation/clarification, coagulation, flocculation,
equalization, neutralization, oil-water separation, steam stripping, distil-
lation, and dissolved air flotation.
Some OCPSF plants also use physical/chemical treatment after biological
treatment. Such treatment is usually intended to reduce solids loadings that
are discharged from biological treatment systems. The most common post-
biological treatment unit operations are polishing ponds and multimedia
filtration. These unit operations are sometimes used in lieu of secondary
clarification or to improve upon substandard biological treatment systems. A
few plants also use activated carbon after biological treatment as a final
"polishing" step.
At approximately 9 percent of the direct discharging plants surveyed,
either no treatment is provided or no treatment beyond equalization and/or
neutralization is provided. At another 19 percent, only physical/chemical
treatment is provided. The remaining 72 percent utilize biological treatment.
Approximately 41 percent of biologically treated effluents are further treated
by polishing ponds, filtration, or other forms of physical/chemical control.
At approximately 39 percent of the indirect discharging plants surveyed,
either no treatment is provided or no treatment beyond equalization and/or
neutralization is provided. At another 47 percent, some physical/chemical
treatment is provided. The remaining 14 percent utilize biological treatment.
Approximately 22 percent of biologically treated effluents are further treated
by polishing ponds, filtration, or other forms of physical/chemical control.
Economic data provided in response to questionnaires completed pursuant
to Section 308 of the CWA indicate that OCPSF production in 1982 totaled 185
billion pounds and that the quantity shipped was 151 billion pounds. The
II-4
-------
corresponding value of shipments equaled $59 billion, while employment in the
industry totaled 187,000 in 1982. In that same, year a total of 455 firms
operated the 940 facilities referenced above.
B. CONCLUSIONS
1. Applicability of the Promulgated Regulation
The OCPSF regulation applies to process wastewater discharges from
existing and new organic chemicals, plastics, and synthetic fibers (OCPSF)
manufacturing facilities. OCPSF process wastewater discharges are defined as
discharges from all establishments or portions of establishments that manufac-
ture products or product groups listed in the applicability sections of the
promulgated regulation (see Appendix III-A of this report), and are included
within the following U.S. Department of Commerce, Bureau of the Census,
Standard Industrial Classification (SIC) major groups:
• SIC 2865 - Cyclic Crudes and Intermediates, Dyes, and Organic Pigments
• SIC 2869 - Industrial Organic Chemicals, not Elsewhere Classified
• SIC 2821 - Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
• SIC 2823 - Cellulosic Man-Made Fibers
• SIC 2824 - Synthetic Organic Fibers, Except Cellulosic.
The regulations apply to plastics molding and forming processes only when
plastic resin manufacturers mold or form (e.g., extrude and pelletize) crude
intermediate plastic material for shipment off-site. This regulation also
applies to the extrusion of fibers. Plastic molding and forming processes
other than those described above are regulated by the plastics molding and
forming effluent guidelines and standards found in 40 CFR Part 463.
The regulations also apply to wastewater discharges from OCPSF research
and development, pilot plant, technical service, and laboratory bench-scale
operations if such operations are conducted in conjunction with and related to
existing OCPSF manufacturing activities at the plant site.
II-5
-------
The regulations do not apply to discharges resulting from the manufacture
of OCPSF products if the products are included in the following SIC subgroups,
and have in the past been reported by the establishment under these subgroups
and not under the OCPSF SIC groups listed above:
• SIC 2843085 - Bulk Surface Active Agents
• SIC 28914 - Synthetic Resin and Rubber Adhesives
• Chemicals and Chemical Preparations, not Elsewhere Classified
- SIC 2899568 - sizes, all types
- SIC 2899597 - other industrial chemical specialties, including
fluxes, plastic wood preparations, and embalming fluids
• SIC 2911058 - Aromatic Hydrocarbons Manufactured from Purchased
Refinery Products
• SIC 2911632 - Aliphatic Hydrocarbons Manufactured from Purchased
Refinery Products.
The regulations are not applicable to any discharges for which a
different set of previously promulgated effluent limitations guidelines and
standards in 40 CFR Parts 405 through 699 apply, unless the facility reports
OCPSF production under SIC codes 2865, 2869, or 2821, and the facility's OCPSF
wastewater is treated in a separate treatment system or discharged separately
to a POTW. They also do not apply to any process wastewater discharges from
the manufacture of organic chemical compounds solely by extraction from plant
and animal raw materials or by fermentation processes.
2. BPT
The technology basis for the promulgated effluent limitations for each
BPT subcategory consists of biological treatment, which usually involves
either activated sludge or aerated lagoons, followed by clarification (and
preceded by appropriate process controls and in-plant treatment to ensure that
the biological system may be operated optimally). Many of the direct dis-
charge facilities have installed this level of treatment.
II-6
-------
The Agency designated seven subcategory classifications for the OCPSF
category to be used for establishing BPT limitations. These subcategory
classifications are 1) rayon fibers (viscose process only); 2) other fibers
(SIC 2823, except rayon, and 2824); 3) thermoplastics (SIC 28213); 4 thermo-
sets (SIC 28214); 5) commodity organic chemicals (SIC 2865 and 2869); 6) bulk
organic chemicals (SIC 2865 and 2869); and 7) specialty organic chemicals
(SIC 2865 and 2869). The specific products and product groups within each
subcategory are listed in Appendix III-A.
While some plants may have production that falls entirely within one of
the seven subcategory classifications, most plants have production that is
divided among two or more subcategories. In applying the subcategory
limitations set forth in the regulation, the permit writer will use what is
essentially a building-block approach that takes into consideration applicable
subcategory characteristics based upon the proportion of production quantities
within each subcategory at the plant. Production characteristics are
reflected explicitly in the plant's limitations through the use of this
approach.
The long-term median effluent BOD& concentrations were calculated for
each subcategory through the use of a mathematical equation that estimates
effluent BOD5 as a function of the proportion of the production of each
subcategory at each facility. The coefficients of this equation were
estimated from reported plant data using standard statistical regression
methods. Plants were selected for developing BPT BOD limitations only if
they achieved at least 95 percent removal for BOD or a long-term average
effluent BOD5 concentration at or below 40 mg/1. The long-term median
effluent TSS concentrations were calculated for each subcategory through the
use of a mathematical equation that estimates effluent TSS as a function of
effluent BOD5. The coefficients of this equation were also estimated from
reported plant data using standard statistical regression methods. Plants
were selected for developing BPT TSS limitations if they passed the BOD5 edit
and also achieved a long-term average effluent TSS concentration at or below
100 mg/1. This statistical analysis is described in detail in Sections IV and
VII.
II-7
-------
"Maximum for monthly average" and "maximum for any one day" effluent
limitations were determined by multiplying long-term median effluent concen-
trations by appropriate variability factors that were calculated through
statistical analysis of long-term BOD5 and TSS daily data. This statistical
analysis is described in detail in Section VII.
The BPT subcategory BOD5 and TSS effluent limitations are presented in
Table II-l; pH, also a regulated parameter, must remain within the range of
6.0 to 9.0 at all times. EPA has determined that the BPT effluent limitations
shall apply to all direct discharge point sources.
3. BCT
The Agency did not promulgate BCT effluent limitations as part of this
regulation. BCT is reserved until a future BCT analysis is completed.
4. BAT
The Agency promulgated BAT limitations for two subcategories. These
subcategories are largely determined by conventional pollutant raw waste
characteristics. The end-of-pipe biological treatment subcategory (BAT Sub-
category One) includes plants that have or will install biological treatment
to comply with BPT limits. The non-end-of-pipe biological treatment sub-
category (BAT Subcategory Two) includes plants that either generate such low
levels of BOD that they do not need to utilize biological treatment, or that
choose to use physical/chemical treatment to comply with the BPT limitations.
The Agency has concluded that, within each subcategory, all plants can treat
priority pollutants to the levels established for that subcategory.
Different limits are being established for these two subcategories.
Biological treatment is an integral part of the model BAT treatment technology
for the end-of-pipe biological treatment subcategory; it achieves incremental
removals of some priority pollutants beyond the removals achieved by in-plant
treatment without end-of-pipe biological treatment. In addition, the Agency
is establishing two different limitations for zinc. One is based on data
collected from rayon manufacturers and acrylic fibers manufacturers using the
zinc chloride/solvent process. This limitation applies only to those plants
II-8
-------
TABLE II-1.
BPT EFFLUENT LIMITATIONS AND NSPS BY SUBCATEGORY (mg/1)
Effluent Limitations1
Maximum for
Subcategory
Rayon Fibers
Other Fibers
Thermoplastic Resins
Thermosetting Resins
Commodity Organic Chemicals
Bulk Organic Chemicals
Specialty Organic Chemicals
Monthly
BOD5
24
18
24
61
30
34
45
Average
TSS
40
36
40
67
46
49
57
Maximum
Any One
BOD5
64
48
64
163
80
92
120
for
Day
TSS
130
115
130
216
149
159
183
pH, also a regulated parameter, shall remain within the range of 6.0 to 9.0
at all times.
Product and product group listings for each subcategory are contained in
Appendix III-A.
II-9
-------
that use the viscose process to manufacture rayon and the zinc chloride/
solvent process to manufacture acrylic fibers. The other zinc limitation is
based on the performance of chemical precipitation technology used in the
metal finishing point source category, and applies to all plants other than
those described above.
The concentration-based BAT effluent limitations hinge on the performance
of the end-of-pipe treatment component (biological treatment for the end-of-
pipe biological treatment subcategory and physical/chemical treatment for the
non-end-of-pipe biological treatment subcategory) plus in-plant control
technologies that remove priority pollutants prior to discharge to the
end-of-pipe treatment system.
The in-plant technologies include steeim stripping to remove selected
volatile and semivolatile priority pollutants, such as toluene, benzene,
carbon tetrachloride, and the dichlorobenzenes; activated carbon for selected
base/neutral priority pollutants, such as 4-nitrophenol and 4,6-dinitro-
o-cresol; hydroxide precipitation for metals; alkaline chlorination for
cyanide; and in-plant biological treatment for selected acid and base/neutral
priority pollutants, such as phenol, the phthalate esters, and the polynuclear
aromatics.
The limits are based on priority pollutant data from both OCPSF and other
industry plants with well-designed and well-operated BAT model treatment
technologies in place. The organic priority pollutant limits are derived from
selected data within the Agency's verification study, cooperative EPA/CMA
study, the 12-Plant Study, and the industry-supplied data base. Except as
noted above, the cyanide and metal priority pollutant limits are derived from
the metal finishing industry data base. The organic priority pollutant limits
apply at the end-of-pipe process wastewater discharge point. There are no
in-plant limitations established for volatile organic priority pollutants.
However, the cyanide and metal limitations apply only to the process waste-
water flow from cyanide-bearing and metal-bearing waste streams. Compliance
for cyanide and metals could be monitored in the plant or, after accounting
for dilution by noncyanide- and nonmetal-bearing process wastewater and
nonprocess wastewater, at the outfall.
11-10
-------
Derivation of the limitations is detailed in Section VII. "Maximum for
Monthly Average" and "Maximum for Any One Day" limitations have been
calculated for each regulated pollutant. Effluent limitations have been
established for 63 pollutants for the end-of-pipe biological treatment
subcategory and 59 pollutants for the non-end-of-pipe biological treatment
subcategory; these limitations are listed in Tables II-2 and II-3,
respectively.
In the final rule, EPA has decided that each discharger in a subcategory
will be subject to the effluent limitations for all pollutants regulated for
that subcategory. Once a pollutant is regulated in the OCPSF regulation, it
must also be limited in the NPDES permit issued to direct dischargers (see
Sections 301 and 304 of the Act; see also 40 CFR Part 122.44(a)). EPA
recognizes that guidance on appropriate monitoring requirements for OCPSF
plants would be useful, particularly to assure that monitoring will not be
needlessly required for pollutants that are not likely to be discharged at a
plant. EPA intends to publish guidance on OCPSF monitoring in the near
future. This guidance will address the issues of compliance monitoring in
general, of initially determining which pollutants should be subject only to
infrequent monitoring based on a conclusion that they are unlikely to be
discharged, and of determining the appropriate flow upon which to derive
mass-based permit requirements.
EPA has determined that this technology basis is the best available
technology economically achievable for all plants except for a subset of small
facilities. For plants whose annual OCPSF production is less than or equal to
5 million pounds, EPA has concluded that the BAT effluent limitations are not
economically achievable. For these plants, EPA has set BAT equal to BPT.
5. NSPS
EPA promulgated new source performance standards (NSPS) on the basis of
the best available demonstrated technology. NSPS are established for conven-
tional pollutants (BOD5, TSS, and pH) on the basis of BPT model treatment
technology. Priority pollutant limits are based on BAT model treatment
technology.
11-11
-------
TABLE II-2.
BAT EFFLUENT LIMITATIONS AND NSPS FOR THE
END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY
Pollutant
Number
1
3
4
6
7
8
9
10
11
12
13
14
16
23
24
25
26
27
29
30
31
32
33
34
35
36
38
39
42
44
45
52
55
56
57
58
59
60
65
66
68
70
Pollutant Name
Acenaphthene
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Trichlorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1,1, 1-Trichloroethane
Hexachloroe thane
1-1-Dichloroe thane
1,1, 2-Trichloroethane
Chloroethane
Chloroform
2-Chlorophenol
1 , 2-Dichlorobenzene
1 , 3-Dichlorobenzene
1 , 4-Dichlorobenzene
1 , l-Dichloro§thylene
1 , 2-Trans-dichloroethylene
2 , 4-Dichlorophenol
1 , 2-Dichloropropane
1 , 3-Dichloropropene
2 , 4-Dimethylphenol
2 , 4-Dini tro toluene
2 , 6-Dini tro toluene
Ethylbenzene
Fluoranthene
Bis (2-Chloroisopropyl) ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
4 , 6-Dini tro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
BAT Effluent
Maximum for
Any One Day
59
242
136
38
28
140
28
211
54
54
59
54
268
46
98
163
44
28
25
54
112
230
44
36
285
641
108
68
757
89
190
49
59
68
69
124
123
277
26
279
57
203
Limitations and NSPS
Maximum for
Monthly Average
22
96
37
18
15
68
15
68
21
21
22
21
104
21
31
77
31
15
16
21
39
153
29
18
113
255
32
25
301
40
86
20
22
27
41
72
71
78
15
103
27
81
11-12
-------
TABLE II-2.
BAT EFFLUENT LIMITATIONS AND NSPS FOR THE
END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY (Continued)
BAT Effluent Limitations and NSPS1
Pollutant
Number
71
72
73
74
75
76
77
78
80
81
84
85
86
87
88
119
120
121
122
124
128
Pollutant Name
Dimethyl phthalate
Benzo( a) anthracene
Benzo(a)pyrene
3 , 4-Benzof luoranthene
Benzo(k)f luoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Total Chromium
Total Copper2
Total Cyanide3
Total Lead2
Total Nickel2
Total Zinc2'4
Maximum for
Any One Day
47
59
61
61
59
59
59
59
59
59
67
56
80
54
268
2,770
3,380
1,200
690
3,980
2,610
Maximum for
Monthly Average
19
22
23
23
22
22
22
22
22
22
25
22
26
21
104
1,110
1,450
420
320
1,690
1,050
All units are micrograms per litsr.
Metals limitations apply only to noncomplexed metal-bearing waste streams,
including those listed in Table X-4. Discharges of chromium, copper, lead,
nickel, and zinc from "complexed metal-bearing process wastewater," listed in
Table X-5, are not subject to these limitations.
Cyanide limitations apply only to cyanide-bearing waste streams, including
those listed in Table X-3.
Total zinc limitations and standards for rayon fiber manufacture by the
viscose process and acrylic fiber manufacture by the zinc chloride/solvent
process are 6,796 yg/1 and 3,325 yg/1 for (Maximum for Any One Day and Maximum
for Monthly Average, respectively. '
11-13
-------
TABLE II-3.
BAT EFFLUENT LIMITATIONS AND NSPS FOR THE
NON-END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY
Pollutant
Number
1
3
4
6
7
8
9
10
11
12
13
14
16
23
25
26
27
29
30
32
33
34
38
39
42
44
45
52
55
56
57
58
59
60
65
66
68
70
Pollutant Name
Acenaphthene
Acrylonitrile
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Tri chlorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1, 1,1-Trichloroethane
Hexachloroe thane
1-1-Dichloroe thane
1,1, 2-Trichloroethane
Chloroethane
Chloroform
1 , 2-Dichlorobenzene
1 , 3-Dichlorobenzene
1 , 4-Dichlorobenzene
1, 1-Dichloroethylene
1 , 2-Trans-dichloroethylene
1 , 2-Dichloropropane
1 , 3-Dichloropropene
2 , 4-Dimethylphenol
Ethylbenzene
Fluoranthene
Bis(2-Chloroisopropyl) ether
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
2 , 4-Dini trophenol
4,6-Dinitro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
BAT Effluent
Maximum for
Any One Day
47
232
134
380
380
794
794
574
59
794
59
127
295
325
794
380
380
60
66
794
794
47
380
54
794
170
295
380
47
6,402
231
576
4,291
211
47
258
43
113
Limitations and NSPS1
Maximum for
Monthly Average
19
94
57
142
142
196
196
180
22
196
22
32
110
111
196
142
142
22
25
196
196
19
142
22
196
36
110
142
19
2,237
65
162
1,207
78
19
95
20
46
11-14
-------
TABLE II-3.
BAT EFFLUENT LIMITATIONS AND NSPS FOR THE
NON-END-OF-PIPE BIOLOGICAL TREATMENT SUBCATEGORY (Continued)
BAT Effluent Limitations and NSPS1
Pollutant
Number
71
72
73
74
75
76
77
78
80
81
84
85
86
87
88
119
120
121
122
124
128
Pollutant Name
Dimethyl phthalate
Benzo( a) anthracene
Benzo(a)pyrene
3 , 4-Benzof luoranthene
Benzo(k)fluoranthene
Chrysene
Acenaphthylene
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Vinyl Chloride
Total Chromium
Total Copper2
Total Cyanide3
Total Lead2
Total Nickel2
Total Zinc2'4
Maximum for
Any One Day
47
47
48
48
47
47
47
47
47
47
48
164
74
69
172
2,770
3,380
1,200
690
3,980
2,610
Maximum for
Monthly Average
19
19
20
20
19
19
19
19
19
19
20
52
28
26
97
1,110
1,450
420
320
1,690
1,050
All units are micrograms per liter.
Metals limitations apply only to noncomplexed metal-bearing waste streams,
including those listed in Table X-4. Discharges of chromium, copper, lead,
nickel, and zinc from "complexed metal-bearing process wastewater," listed in
Table X-5, are not subject to these limitations.
Cyanide limitations apply only to cyanide-bearing waste streams, including
those listed in Table X-3.
^
Total zinc limitations and standards for rayon fiber manufacture by the
viscose process and acrylic fiber manufacture by the zinc chloride/solvent
process are 6,796 ug/1 and 3,325 ug/1 for Maximum for Any One Day and Maximum
for Monthly Average, respectively.
11-15
-------
The Agency issued conventional pollutant new source standards for the
same seven subcategories for which BPT limits were established. These
standards are equivalent to the limits established for BPT shown in
Table II-l. Priority pollutant new source standards are applied to new sources
according to the same subcategorization scheme applicable under BAT. The set
of 63 standards listed in Table II-2 for the end-of-pipe biological treatment
subcategory will apply to new sources that use biological treatment in order
to comply with BOD5 and TSS limitations. The standards in the subcategory for
sources that do not use end-of-pipe biological treatment apply to new sources
that will either generate such low levels of BOD5 that they do not need to use
end-of-pipe biological treatment, or that choose to use physical/chemical
treatment to comply with the BOD5 standard. These facilities will have to
meet the 59 priority pollutant standards listed in Table II-3, which are based
on the application of in-plant control technologies with or without end-of-
pipe physical/chemical treatment.
EPA has determined that NSPS will not cause a barrier to entry for new
source OCPSF plants.
6. PSES
Pretreatment standards for existing sources applicable to indirect
dischargers are generally analogous to BAT limitations applicable to direct
dischargers. The Agency promulgated PSES for 47 priority pollutants which
were determined to pass through POTWs. The standards apply to all existing
indirect discharging OCPSF plants. EPA determines which pollutants to
regulate in PSES on the basis of whether or not they pass through, cause an
upset, or otherwise interfere with operation of a POTW (including interference
with sludge practices). A detailed discussdon of the pass-through analysis is
presented in Section VI.
Indirect dischargers generate wastewater with the same pollutant
characteristics as the direct discharge plants; therefore, the same tech-
nologies that were discussed for BAT are appropriate for application at PSES.
The Agency established PSES for all indirect dischargers on the same
technology basis as the BAT non-end-of-pipe biological treatment subcategory.
11-16
-------
Therefore, the pretreatment standards for existing sources,- shown in Table
II-4, are equivalent to the BAT limitations for the non-end-of-pipe biological
treatment subcategory for the pollutants deemed to pass through.
EPA is not including end-of-pipe biological treatment in the final PSES
model technology in part, because, as a matter of treatment theory, biological
pretreatment may be largely redundant to the biological treatment provided by
the POTW.
Although EPA has rejected the option of adding end-of-pipe biological
treatment, EPA sometimes uses biological treatment as part of its model
technology for the in-plant treatment of certain semivolatile pollutants such
as phenol, the phthalate esters, and the polynuclear aromatics. Specifically,
for such pollutants, EPA has in some cases used in-plant biological treatment
systems as an alternative to in-plant activated carbon adsorption for these
organic pollutants. Thus, EPA actually has used biological treatment as part
of PSES model treatment technology where appropriate.
7. PSNS
Like PSES and BAT, PSNS is generally analogous to NSPS. However, as for
PSES, EPA is not establishing PSNS limits for conventional pollutants or
including end-of-pipe biological treatment in its PSNS model treatment tech-
nology, for the same reasons discussed above with respect to PSES. The Agency
promulgated PSNS on the same technology basis as PSES, and issued standards
for the 47 priority pollutants in Table II-4 that have been determined to pass
through or otherwise interfere with the operation of POTWs. The Agency has
determined that PSNS will not cause a barrier to entry for new source OCPSF
plants.
11-17
-------
TABLE II-4.
PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES (PSES AND PSNS)
Pollutant
Number
1
4
6
7
8
9
10
11
12
13
14
16
23
25
26
27
29
30
32
33
34
38
39
44
45
52
55
56
57
58
60
65
66
68
70
71
78
80
81
84
85
86
87
Pollutant Name
Acenaphthene
Benzene
Carbon Tetrachloride
Chlorobenzene
1,2, 4-Trichlorobenzene
Hexachlorobenzene
1 , 2-Dichloroethane
1 , 1, 1-Trichloroe thane
Hexachloroe thane
1-1 -Dichloroe thane
1,1, 2-Trichloroethane
Chloroethane
Chloroform
1 , 2-Dichlorobenzene
1 , 3-Dichlorobenzene
1 , 4-Dichlorobenzene
1 , 1-Dichloroethylene
1 , 2-Trans-dichloroethylene
1 , 2-Dichloropropane
1 , 3-Dichloropropene
2,4-Dimethylphenol
Ethylbenzene
Fluoranthene
Methylene Chloride
Methyl Chloride
Hexachlorobutadiene
Naphthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
4,6-Dinitro-o-cresol
Phenol
Bis(2-ethylhexyl)phthalate
Di-n-butyl phthalate
Diethyl phthalate
Dimethyl phthalate
Anthracene
Fluorene
Phenanthrene
Pyrene
Tetrachloroethylene
Toluene
Trichloroethylene
Pretreatment
Maximum for
Any One Day
47
134
380
380
794
794
574
59
794
59
127
295
325
794
380
380
60
66
794
794
47
380
54
170
295
380
47
6,402
231
576
277
47
258
43
113
47
47
47
47
48
164
74
69
Standards
Maximum for
Monthly Average
19
57
142
142
196
196
180
22
196
22
32
110
111
196
142
142
22
25
196
196
19
142
22
36
110
142
19
2,237
65
162
78
19
95
20
46
19
19
19
19
20
52
28
26
11-18
-------
TABLE II-4.
PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES (PSES AND PSNS)
(Continued)
Pretreatment Standards
Pollutant
Number
88
121
122
128
Pollutant Name
Vinyl Chloride
Total Cyanide2
Total Lead3
Total Zinc3'4
Maximum for
Any One Day
172
1,200
690
2,610
Maximum for
Monthly Average
97
420
320
1,050
All units are micrograms per liter.
Cyanide limitations apply only to cyanide-bearing waste streams, including
those listed in Table X-3.
Metals limitations apply only to noncomplexed metal-bearing waste streams,
including those listed in Table X-4. Discharges of lead and zinc from
"complexed metal-bearing process wastewater," listed in Table X-5, are not
subject to these limitations.
Total zinc limitations and standards for rayon fiber manufacture by the
viscose process and acrylic fiber manufacture by the zinc chloride/solvent
process are 6,796 ug/1 and 3,325 yg/1 for Maximum for Any One Day and Maximum
for Monthly Average, respectively.
11-19
-------
SECTION III
INDUSTRY DESCRIPTION
A. INTRODUCTION
The organic chemicals industry began modestly in the middle of the 19th
century. The production of coke, used both as a fuel and reductant in blast
furnaces for steel production, generated coal tar as a by-product. These tars
were initially regarded as wastes. However, with the synthesis of the first
coal tar dye by Perkin in 1856, chemists and engineers began to recover the
waste tar and use it to manufacture additional products.
The organic chemicals industry began with the isolation and commercial
production of aromatic hydrocarbons (e.g., benzene and toluene and phenolics
from coal tar). As more organic compounds possessing valuable properties were
identified, commercial production methods for these compounds became desir-
able. The early products of the chemical industry were dyes, explosives, and
Pharmaceuticals.
The economic incentive to recover and use by-products was a driving force
behind the growing synthetic chemicals industry. For example, the manufacture
of chlorinated aromatics was prompted by: 1) the availability of large
quantities of chlorine formed as a by-product from caustic soda production
(already a commodity chemical), 2) the availability of benzene derived from
coal tar, and 3) the discovery that compounds could serve as intermediates for
the production of other valuable derivatives, such as phenol and picric acid.
Specialty products such as surfactants, pesticides, and aerosol propellants
were developed later to satisfy particular commercial needs.
The plastics and synthetic fibers industry began later as an outgrowth of
the organic chemicals industry. The first commercial polymers, rayon and
bakelite, were produced in the early 1900's from feedstocks manufactured by
the organic chemicals industry. In the last seve-ral decades, the development
of a variety of plastic and synthetic fiber products and the diversity of
III-l
-------
markets and applications of these products have made the plastic and synthetic
fibers industry the largest (measured by volume) consumer of organic
chemicals.
Chemicals derived from coal were the principal feedstocks of the early
industry, although ethanol, derived from fermentation, was the source of some
aliphatic compounds. Changing the source of industry feedstocks to less ex-
pensive petroleum derivatives lowered prices and opened new markets for
organic chemicals, plastics, and synthetic fibers during the 1920's and
1930's. By World War II, the modern organic chemicals and plastics and syn-
thetic fiber industries based on petro-chemicals were firmly established in
the United States.
Today, the organic chemicals, plastics and synthetic fibers (OCPSF)
industry includes production facilities of two distinct types: those whose
primary function is chemical synthesis, and those that recover organic chemi-
cals as by-products from unrelated manufacturing operations such as coke
plants (steel production) and pulp mills (paper production). The majority of
the plants in this industry are plants that process chemical precursors (raw
materials) into a wide variety of products for virtually every industrial and
consumer market.
Approximately 90 percent (by weight) of the precursors, the primary
feedstocks for all of the industry's thousands of products, are derived from
petroleum and natural gas. The remaining 10 percent is supplied by plants
that recover organic chemicals from coal tar condensates generated by coke
production.
There are numerous ways to describe the OCPSF industry; however, tradi-
tional profiles such as number of product lines or volume of product sales
mask the industry's complexity and diversity. The industry is even more
difficult to describe in terms that make distinctions among plants according
to wastewater characteristics. Subsequent parts of this section discuss the
OCPSF industry from several different perspectives, including product line,
product sales, geographic distribution, facility size, facility age, and
wastewater treatment and disposal methods as practiced by the industry. OCPSF
III-2
-------
wastewater treatment practices are summarized in Section II and described in
detail in Section VII of this document. The subcategorization of plants
within the OCPSF industry by process chemistry, raw and treated wastewater
characteristics, and other plant-specific factors, is discussed in Section IV.
B. DEFINITION OF THE INDUSTRY
A single definition of the OCPSF industry is difficult to derive because
of the complexity and diversity of the products and the manufacturing proces-
ses used in the industry. However, some traditional profiles can provide
general descriptions of the industry, and these are discussed briefly in the
following subsections:
• Standard Industrial Classification (SIC) system
• Scope of the final regulation
• Raw materials and product processes
• Geographic location
• Age of plant
• Size of plant
• Mode of discharge.
1. Standard Industrial Classification System
Standard Industrial Classification (SIC) codes, established by the U.S.
Department of Commerce, are classifications of commercial and industrial es-
tablishments by type of activity in which they are engaged. The primary pur-
pose of the SIC code is to classify the manufacturing industries for the col-
lection of economic data. For this reason, the product descriptions in SIC
codes are arbitrary, often technically ambiguous, and in some cases inaccur-
ately representative of the products that are purported to be classified. SIC
codes also list archaic products that are no longer relevant to the OCPSF
industry. In some industries the SIC Code(s) match the activities covered by
the issuance of effluent guidelines and standards regulations. For the OCPSF
industry, product descriptions under the following SIC codes are nominal at
best:
2865 Cyclic (Coal Tar) Crudes, and Cyclic Intermediates, Dyes, and
Organic Pigments (Lakes and Toners)
III-3
-------
2869 Industrial Organic Chemicals, Not Elsewhere Classified
2821 Plastics Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
2823 Cellulosic Man-Made Fibers
2824 Synthetic Organic Fibers, Except Cellulosic.
In addition, as a result of 1976 litigation and agreement, the organic chemi-
cals manufacturing, and the plastics and synthetic materials manufacturing
industries (since combined into the industry category addressed by this devel-
opment document) was defined to include all facilities manufacturing products
that could be construed to fall within these specific SIC codes. The U.S.
Environmental Protection Agency (EPA) considered two of these SIC codes: SIC
2865, cyclic (coal tar) crudes, and cyclic intermediates, dyes, and organic
pigments (lakes and toners); and SIC 2869, industrial organic chemicals, not
elsewhere classified, to be applicable to the organic chemicals manufacturing
industry.
The products that the SIC Manual includes in the industrial organic chem-
ical industry (SIC 286) are natural products such as gum and wood chemicals
(SIC 2861), aromatic and other organic chemicals from the processing of coal
tar and petroleum (SIC 2865), and aliphatic or acyclic organic chemicals (SIC
2869).
These chemicals are the raw materials for deriving products such as plas-
tics, rubbers, fibers, protective coatings, and detergents, but have few
direct consumer uses. Gum and wood chemicals (SIC 2861) are regulated under a
separate consent decree industrial category, gum and wood chemicals manufac-
turing (40 CFR 454).
The plastics and synthetic materials manufacturing category as defined by
the 1976 agreement, comprises SIC 282, plastic materials and synthetic resins,
synthetic rubber, and synthetic and other manmade fibers, except glass. SIC
282 includes the following SIC codes:
2821 Plastics Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
III-4
-------
2822 Synthetic Rubber (Vulcanizable Elastomers)
2823 Cellulosic Man-Made Fibers
2824 Synthetic Organic Fibers, Except Cellulosic.
Of these codes, SIC 2822 is covered specifically in the 1976 agreement by
another industrial category, rubber manufacturing (40 CFR 428). Similarly,
miscellaneous plastic products (SIC 3079), which is related to the plastics
industry, is covered by the specific industrial category, plastics molding and
forming (40 CFR 463). EPA considers a plant that merely processes a polymeric
material for any end use other than as a fiber to be in SIC 3079. In con-
trast, if the plant manufactures that polymeric material from monomeric raw
materials, then that portion of its production is in SIC 2821.
The relationship of all the industries listed in the SIC Manual as being
related to production of organic chemicals, plastics, or synthetic fibers is
shown in Figure III-l.
a. Additional SIC Codes Could Be Considered as Part of the OCPSF
Industry
A review of SIC product code data supplied by OCPSF industry facilities
in the 1983 Section 308 Questionnaire identified 11 SIC product categories
that are classified under SIC codes different from those in the Settlement
Agreement discussed above that could be considered as part of the OCPSF
industry because they include the manufacture of OCPSF products or utilize
OCPSF process chemistry. These additional SIC code product categories are
also shown in Figure III-l and listed below.
SIC Code Description
2891400 Synthetic Resin (and Rubber)
Adhesives
2891423 Phenolics and Modified Phenolics
Adhesives
2891433 Urea and Modified Urea Adhesives
2891453 Acrylic Adhesives
III-5
-------
Petrochemical Inter-Industry Relationship
Feedstock Industries
Petrochemical Industries
Petrochemical-Dependent
Chemical Industries
2821
Plastic
Materials
2822
Synthetic
Rubbers
2824
Synthetic
Fibers
2843
Surfactants
3079
Misc. Plastics
Products
—+* 1321 -^, r—*- 2865 — »i
1311
Crude fc
Petroleum
and Natural Gas
Natural
Gas Liquids
-*• 2911— »•
Petroleum
Refining
Cyclics and
Aromatics
— »• 2869 — »
Acyclics and
Aliphatics
Nitrogenous
Fertilizers
_ OOQC ^
>— i^^- — >*•* ^— »••
Carbon
Black
*•
r~*~
_»-
-»-
»
_».
-*•
•^^to.
rr
LL
2823 Cellulosic Fibers
2831 Biologicals
2833 Medicinals and Botanicals
2834 Pharmaceuticals
2841 Detergents
2842 Polishes
2844 Toiletries
2851 Paints
2879 Pesticides
2891 Adhesives
2874 Phosphatic Fertilizers
2875 Mixed Fertilizers
2892 Explosives
2893 Printing Inks
Source: U.S. Department of Commerce, 1981. " 1981 U.S. Industrial Outlook."
Bureau of Industrial Econo'mics, Washington, D.C.
Figure 111-1.
Relationships Among the SIC Codes Related to the Production
of Organic Chemicals, Plastics, and Synthetic Fibers
III-6
-------
2843085 Bulk Surface Active Agents
2899568 Sizes, All Types
2899597 Other Industrial Chemical Specialties,
Including Fluxes, Plastic Wood Prep-
arations and Embalming Chemicals
2899598 Other Industrial Chemical Specialties,
Including Fluxes and Plastic Wood
Preparations
2911058 Aromatics, Made from Purchased
Refinery Products
2911632 Liquified Refinery Gases (Including
Other Aliphatics), Made from Purchased
Refinery Products
3079000 Miscellaneous Plastics Products (Including
Only Cellophane Manufacture From the
Viscose Process)
b. Primary, Secondary, and Tertiary SIC Codes
SIC codes, established by the U.S. Department of Commerce, are classifi-
cations of commercial and industrial establishments by type of activity in
which they are engaged. The SIC code system is commonly employed for collec-
tion and organization of data (e.g., gross production, sales, number of em-
ployees, and geographic location) for U.S. industries. An establishment is
an economic unit that produces goods or services (e.g., a chemical plant, a
mine, a factory, or a store). The establishment is a single physical loca-
tion and is typically engaged in a single or dominant type of economic activ-
ity for which an industry code is applicable.
Where a single physical location encompasses two or more distinct and
separate economic activities for which different industrial classification
codes seem applicable (e.g., a steel plant that produces organic chemicals as
a result of its coking operations), such activities are treated as separate
establishments under separate SIC codes, provided that: 1) no one industry
description in the SIC includes such combined activities; 2) the employment in
each such economic activity is significant; 3) such activities are not
ordinarily associated with one another at common physical locations; and
III-7
-------
4) reports can be prepared on the number of employees, their wages and
salaries, and other establishment type data. A single plant may include more
than one establishment and more than one SIC code.
A plant is assigned a primary SIC code corresponding to its primary
activity, which is the activity producing its primary product or group of
products. The primary product is the product having the highest total annual
shipment value. The secondary products of a plant are all products other
than the primary products. Frequently in the chemical industry a plant may
produce large amounts of a low-cost chemical, but be assigned another SIC code
because of lower-volume production of a high-priced specialty chemical. Many
plants are also assigned secondary, tertiary, or lower order SIC codes corres-
ponding to plant activities beyond their primary activities. The inclusion
of plants with a secondary or lower order SIC code produces a list of plants
manufacturing a given class of industrial products, but also includes plants
that produce only minor (or in some cases insignificant) amounts of those
products. While the latter plants are part of an industry economically, their
inclusion may distort the description of the industry's wastewater production
and treatment, unless the wastewaters can be segregated by SIC codes.
c. Products of Various SIC Categories
Important classes of chemicals of the organic chemicals industry within
SIC 2865 include: 1) derivatives of benzene, toluene, naphthalene, anthra-
cene, pyridine, carbazole, and other cyclic chemical products; 2) synthetic
organic dyes; 3) synthetic organic pigments; and 4) cyclic (coal tar) crudes,
such as light oils and light oil products; coal tar acids; and products of
medium and heavy oil such as creosote oil, naphthalene, anthracene and their
high homologues, and tar.
Important classes of chemicals of the organic chemicals industry within
SIC 2869 include: 1) non-cyclic organic chemicals such as acetic, chloro-
acetic, adipic, formic, oxalic acids and their metallic salts, chloral, for-
maldehyde, and methylamine; 2) solvents such as amyl, butyl, and ethyl alco-
hols; methanol; amyl, butyl, and ethyl acetates; ethyl ether, ethylene glycol
ether, and diethylene glycol ether; acetone, carbon disulfide, and chlorinated
III-8
-------
solvents such as carbon tetrachloride, tetrachloroethene, 'and trichloroethene;
3) polyhydric alcohols such as ethylene glycol, sorbitol, pentaerythritol, and
synthetic glycerin; 4) synthetic perfume and flavoring materials such as
coumarin, methyl salicylate, saccharin, citral, citronellal, synthetic
geraniol, ionone, terpineol, and synthetic vanillin; 5) rubber processing
chemicals such as accelerators and antioxidants, both cyclic and acyclic; 6)
plasticizers, both cyclic and acyclic, such as esters of phosphoric acid,
phthalic anhydride, adipic acid, lauric acid, oleic acid, sebacic acid, and
stearic acid; 7) synthetic tanning agents such as sulfonic acid condensates;
and 8) esters, amines, etc. of polyhydric alcohols and fatty and other acids.
Tables III-l and III-2 list specific products of SIC 2865 and SIC 2869,
respectively.
Important products produced by the plastics and synthetic fibers industry
within SIC 2821 include: cellulose acetate, phenolic, and other tar acid
resins; urea and melamine resins; vinyl acetate resins; polyethylene resins;
polypropylene resins; rosin modified resins; coumarone-indene resins;
petroleum resins; polyamide resins, silicones, polyisobutylenes, polyesters,
polycarbonate resins, acetal resins, fluorohydrocarbon resins. Table III-3
lists important products of SIC 2821.
Important cellulosic man-made fibers (SIC 2823) include: cellulose
acetate, cellulose triacetate and rayon, triacetate fibers. Important non-
cellulosic synthetic organic fibers (SIC 2824) include: acrylic, modacrylic,
fluorocarbon, nylon, olefin, polyester, and polyvinyl. Tables III-4 and III-5
list specific products of SIC 2823 and SIC 2824, respectively.
Certain products of SIC groups other than 2865, 2969, 2821, 2823, and
2824 are identical to OCPSF industry products. Benzene, toluene, and mixed
xylenes manufactured from purchased refinery products in SIC 29110582 (in
contrast to benzene, toluene, and mixed xylenes manufactured in refineries—
SIC 29110558) are manufactured ¥ith the same reaction chemistry and unit
operations as OCPSF products (see Table III-6). Similar considerations apply
to aliphatic hydrocarbons manufactured from purchased refinery products—
SIC 29116324 (see Table III-7).
III-9
-------
TABLE III-l.
SIC 2865: CYCLIC (COAL TAR), CRUDES, AND CYCLIC INTERMEDIATES,
DYES, AND ORGANIC PIGMENTS (LAKES AND TONERS)
Acid dyes, synthetic
Acids, coal tar: derived from coal tar
distillation
Alkylated diphenylamines, mixed
Alkylated phenol, mixed
Aminoanthraquinone
Aminoazobenzene
Aminoazotoluene
Aminophenol
Aniline
Aniline oil
Anthracene
Anthraquinone dyes
Azine dyes
Azo dyes
Azobenzene
Azoic dyes
Benzaldehyde
Benzene hexachloride (BHC)
Benzene, product of coal tar
distillation
Benzoic acid
Benzol, product of coal tar distillation
Biological stains
Chemical indicators
Chlorobenzene
Chloronaphthalene
Chlorophenol
Chlorotoluene
Coal tar crudes, derived from coal
tar distillation
Coal tar distillates
Coal tar intermediates
Color lakes and toners
Color pigments, organic: except animal
black and bone black
Colors, dry: lakes, toners, or full
strength organic colors
Colors, extended (color lakes)
Cosmetic dyes, synthetic
Creosote oil, product of coal tar
distillation
Cresols, product of coal tar
distillation
Cresylic acid, product of coal tar
distillation
Cyclic crudes, coal tar: product of
coal tar distillation
Hydroquinone
Isocyanates
Lake red C toners
Leather dyes and stains, synthetic
Lithol rubine lakes and toners
Maleic anhydride
Methyl violet toners
Naphtha, solvent: product of coal
tar distillation
Naphthalene chips and flakes
Naphthalene, product of coal tar
distillation
Naphthol, alpha and beta
Nitro dyes
Nitroaniline
Nitrobenzene
Nitrophenol
Nitroso dyes
Oil, aniline
Oils: light, medium, and heavy—pro-
duct of coal tar distillation
Organic pigments (lakes and toners)
Orthodichlorobenzene
Paint pigments, organic
Peacock blue lake
Pentachlorophenol
Persian orange lake
Phenol
Phloxine toners
Phosphomolybdic acid lakes and toners
Phosphotungstic acid lakes and toners
Phthalic anhydride
Phthalocyanine toners
Pigment scarlet lake
Pitch, product of coal tar
distillation
Pulp colors, organic
Quinoline dyes
Resorcinol
Scarlet 2 R lake
Stains for leather
Stilbene dyes
Styrene
Styrene monomer
Tar, product of coal tar distillation
Toluene, product of coal tar
distillation
111-10
-------
TABLE III-l.
SIC 2865: CYCLIC (COAL TAR), CRUDES, AND CYCLIC INTERMEDIATES,
DYES, AND ORGANIC PIGMENTS (LAKES AND TONERS)
(Continued)
Cyclic intermediates
Cyclohexane
Diphenylamine
Drug dyes, synthetic
Dye (cyclic) intermediates
Dyes, food: synthetic
Dyes, synthetic organic
Eosine toners
Ethylbenzene
Toluidines
Toluol, product of coal tar distilla-
tion
Vat dyes, synthetic
Xylene, product of coal tar distilla-
tion
Xylol, product of coal tar distilla-
tion
Source: OMB 1972. Standard Industrial Classification Manual 1972.
Statistical Policy Division, Washington, D.C.
III-ll
-------
TABLE III-2.
SIC 2869: INDUSTRIAL ORGANIC CHEMICALS, NOT ELSEWHERE
CLASSIFIED
Accelerators, rubber processing:
cyclic and acyclic
Acetaldehyde
Acetates, except natural acetate of
lime
Acetic acid, synthetic
Acetic anhydride
Acetin
Acetone, synthetic
Acid esters, amines, etc.
Acids, organic
Acrolein
Acrylonitrile
Adipic acid
Adipic acid esters
Adiponitrile
Alcohol, aromatic
Alcohol, fatty: powdered
Alcohol, methyl: synthetic
(methanol)
Alcohols, industrial: denatured
(nonbeverage)
Algin products
Amyl acetate and alcohol
Antioxidants, rubber processing:
cyclic and acyclic
Bromochloromethane
Butadiene, from alcohol
Butyl acetate, alcohol, and
proprionate
Butyl ester solution of 2, 4-D
Calcium oxalate
Camphor, synthetic
Carbon bisulfide (disulfide)
Carbon tetrachloride
Casing fluids, for curing fruits,
spices, tobacco, etc.
Cellulose acetate, unplasticized
Chemical warfare gases
Chloral
Chlorinated solvents
Chloroacetic acid and metallic
salts
Chloroform
Chloropicrin
Citral
Citrates
Citric acid
Citronellal
Coumarin
Cream of tartar
Cyclopropane
DDT, technical
Decahydronaphthalene
Dichlorod i fluorome thane
Diethylcyclohexane (mixed isomers)
Diethylene glycol ether
Dimethyl divinyl acetylene
(di-isopropenyl acetylene)
Dimethylhydrazine, unsymmetrical
Embalming fluids
Enzymes
Esters of phosphoric, adipic,
lauric, oleic, sebacic, and
stearic acids
Esters of phthalic anhydride
Ethanol, industrial
Ethei-
Ethyl acetate, synthetic
Ethyl alcohol, industrial
(non-beverage)
Ethyl butyrate
Ethyl cellulose, unplasticized
Ethyl chloride
Ethyl ether
Ethyl formate
Ethyl nitrite
Ethyl perhydrophenanthrene
Ethylene
Ethylene glycol
Ethylene glycol ether
Ethylene glycol, inhibited
Ethylene oxide
Fatty acid esters, amines, etc.
Ferric ammonium oxalate
Flavors and flavoring materials,
synthetic
Fluorinated hydrocarbon gases
Formaldehyde (formalin)
Formic acid and metallic salts
Freon
Fuel propellants, solid: organic
Fuels, high energy: organic
Geraniol, synthetic
Glycerin, except from fats
(synthetic)
Grain alcohol, industrial
(non-beverage)
111-12
-------
TABLE III-2.
SIC 2869: INDUSTRIAL ORGANIC CHEMICALS, NOT ELSEWHERE
CLASSIFIED (Continued)
Hexamethylenediamine
Hexamethylenetetramine
High purity grade chemicals,
organic: refined from technical
grades
Hydraulic fluids, synthetic base
Hydrazine
Industrial organic cycle compounds
lonone
Isopropyl alcohol
Ketone, methyl ethyl
Ketone, methyl isobutyl
Laboratory chemicals, organic
Laurie acid esters
Lime citrate
Malononitrile, technical grade
Metallic salts of acyclic organic
chemicals
Metallic stearate
Methanol, synthetic (methyl
alcohol)
Methyl chloride
Methyl perhydrofluorine
Methyl salicylate
Methylamine
Methylene chloride
Monochlorodifluoromethane
Monomethylparaminophenol sulfate
Monosodium glutamate
Mustard gas
Napthalene sulfonic acid
condensates
Naphthenic acid soaps
Normal hexyl decalin
Nuclear fuels, organic
Oleic acid esters
Organic acid esters
Organic chemicals, acyclic
Oxalates
Oxalic acid and metallic salts
Pentaerythritol
Perchloroethylene
Perfume materials, synthetic
Phosgene
Phthalates
Plasticizers, organic: cyclic and
acyclic
Polyhydric alcohol esters, amines,
etc.
Polyhydric alcohols
Potassiium bitartrate
Propellants for missiles, solid:
organic
Propylene
Propylene glycol
Quinuclidinol ester of benzylic
acid
Reagent grade chemicals, organic:
refined from technical grades
Rocket engine fuel, organic
Rubber processing chemicals,
organic: accelerators and
antioxidants
Saccharin
Sebacic acid
Silicones
Soaps, naphthenic acid
Sodium acetate
Sodium alginate
Sodium benzoate
Sodium glutamate
Sodium pentachlorophenate
Sodium sulfoxalate formaldehyde
Solvents, organic
Sorbitol
Stearic acid salts
Sulfonated naphthalene
Tackifiers, organic
Tannic acid
Tanning agents, synthetic organic
Tartaric acid and metallic salts
Tartrates
Tear gas
Terpineol
Tert-butylated bis
(p-phenoxyphenyl) ether fluid
Tetrachloroethylene
Tetraethyl lead
Thioglycolic acid, for permanent
wave lotions
Trichloroethylene
Trichloroethylene stabilized,
degreasing
Trichlorophenoxyacetic acid
Trichlorotrifluoroethane
tetrachlorodi fluoroethane
isopropyl alcohol
Tricresyl phosphate
111-13
-------
TABLE III-2.
SIC 2869: INDUSTRIAL ORGANIC CHEMICALS, NOT ELSEWHERE
CLASSIFIED (Continued)
Tridecyl alcohol
Trimethyltrithiophosphite (rocket
propellants)
Triphenyl phosphate
Vanillin, synthetic
Vinyl acetate
Source: OMB 1972. Standard Industrial Classification Manual 1972.
Statistical Policy Division, Washington, D.C.
111-14
-------
TABLE III-3.
SIC 2821: PLASTIC MATERIALS, SYNTHETIC RESINS,
AND NONVULCANIZABLE ELASTOMERS
Acetal resins
Acetate, cellulose (plastics)
Acrylic resins
Acrylonitrile-butadiene-styrene resins
Alcohol resins, polyvinyl
Alkyd resins
Allyl resins
Butadiene copolymers, containing less
than 50% butadiene
Carbohydrate plastics
Casein plastics
Cellulose nitrate resins
Cellulose propionate (plastics)
Coal tar resins
Condensation plastics
Coumarone-indene resins
Cresol-furfural resins
Cresol resins
Dicyandiamine resins
Diisocyanate resins
Elastomers, nonvulcanizable (plastics)
Epichlorohydrin bisphenol
Epichlorohydrin diphenol
Epoxy resins
Ester gum
Ethyl cellulose plastics
Ethylene-vinyl acetate resins
Fluorohydrocarbon resins
Ion exchange resins
lonomer resins
Isobutylene polymers
Lignin plastics
Melamine resins
Methyl acrylate resins
Methyl cellulose plastics
Methyl methacrylate resins
Molding compounds, plastics
Nitrocellulose plastics (pyroxylin)
Nylon resins
Petroleum polymer resins
Phenol-furfural resins
Phenolic resins
Phenoxy resins
Phthalic alkyd resins
Phthalic anhydride resins
Polyacrylonitrile resins
Polyamide resins
Polycarbonate resins
Polyesters
Polyethylene resins
Polyhexamethylenediamine adipamide
resins
Polyisobutylenes
Polymerization plastics, except
fibers
Polypropylene resins
Polystyrene resins
Polyurethane resins
Polyvinyl chloride resins
Polyvinyl halide resins
Polyvinyl resins
Protein plastics
Pyroxylin
Resins, phenolic
Resins, synthetic: coal tar and
non-coal tar
Rosin modified resins
Silicone fluid solution (fluid for
sonar transducers)
Silicone resins
Soybean plastics
Styrene resins
Styrene-acrylonitrile resins
Tar acid resins
Urea resins
Vinyl resins
Source: OMB 1972. Standard Industrial Classification Manual 1972.
Statistical Policy Division, Washington, D.C.
111-15
-------
TABLE III-4.
SIC 2823: CELLULOSIC MAN-MADE FIBERS
Acetate fibers Rayon primary products: fibers,
Cellulose acetate monofilament, yarn, straw, strips, and yarn
staple, or tov Rayon yarn, made in chemical
Cellulose fibers, man-made plants (primary products)
Cigarette tow, cellulosic fiber Regenerated cellulose fibers
Cuprammonium fibers Triacetate fibers
Fibers, cellulose man-made Viscose fibers, bands, strips,
Fibers, rayon and yarn
Horsehair, artifical: rayon Yarn, cellulosic: made in chemical
Nitrocellulose fibers plants (primary products)
Source: OMB, 1972. Standard Industrial Classification Manual 1972.
Statistical Policy Division, Washington, D.C.
111-16
-------
TABLE III-5
SIC 2824: SYNTHETIC ORGANIC FIBERS, EXCEPT CELLULOSIC
Acrylic fibers
Acrylonitrile fibers
Anidex fibers
Casein fibers
Elastomeric fibers
Fibers, man-made: except cellulosic
Fluorocarbon fibers
Horsehair, artificial: nylon
Linear esters fibers
Modacrylic fibers
Nylon fibers and bristles
Olefin fibers
Organic fibers, synthetic: except
cellulosic
Polyester fibers
Polyvinyl ester fibers
Polyvinylidene chloride fibers
Protein fibers
Saran fibers
Soybean fibers (man-made textile
materials)
Vinyl fibers
Vinylidene chloride fibers
Yarn, organic man-made fiber
except cellulosic
Zein fibers
Source: OMB 1972. Standard Industrial Classification Manual 1972.
Statistical Policy Division, Washington, D.C.
111-17
-------
TABLE III-6.
OCPSF CHEMICAL PRODUCTS ALSO LISTED AS SIC 29110582 PRODUCTS
Benzene
Cresylic acid
Cyclopentane
Naphthalene
Naphthenic Acid
Toluene
Xylenes, Mixed
C9 Aromatics
Source: 1982 Census of Manufacturers and Census of Mineral Industries.
Numerical List of Manufactured and Mineral Products. U.S. Department
of Commerce, Bureau of the Census, 1982.
111-18
-------
TABLE III-7.
OCPSF CHEMICAL PRODUCTS ALSO LISTED AS SIC 29116324 PRODUCTS
C2 Hydrocarbons
Acetylene
Ethane
Ethylene
C3 Hydrocarbons
Propane
Propylene
C4 Hydrocarbons
Butadiene and butylene fractions
1,3-Butadiene, grade for rubber
n-Butane
Butanes, mixed
1-Butene
2-Butene
1-Butane and 2-butene, mixed
Hydrocarbons, C4, fraction
Hydrocarbons, C4, mixtures
Isobutane (2-Methylpropane)
Isobutylene (2-Methylpropene)
C4 Hydrocarbons, all other
amylenes
Dibutanized aromatic concentrate
C5 Hydrocarbon, mixtures
Isopentane (2-Methylbutane)
Isoprene (2-Methyl-l,3-butadiene)
n-Pentane
1-Pentene
Pentenes, mixed
Piperylene (1,3-Pentadiene)
C5 Hydrocarbons, all other
C6 Hydrocarbons
Diisopropane
Hexane
Hexanes, mixed
Hydrocarbons, C5-C6, mixtures
Hydrocarbons, C5-C7, mixtures
Isohexane
Methylcyclopentadiene
Neohexane (2,2-Dimethylbutane)
C6 Hydrocarbons, C6, all other
n-Heptane
Heptenes, mixed
Isoheptanes
C7 Hydrocarbons
C8 Hydrocarbons
C10-C16
C12-C18
C15-C17
other
, C5-C9, mixtures
Diisobutylene (Diisobutene)
n-Octane
Octenes, mixed
2,2,4-Trimethylpentane (Isooctane)
C8 Hydrocarbons, all other
C9 and above Hydrocarbons
Dodecene
Eicosane
Nonene (Tripropylene)
Alpha olefins
Alpha olefins, C6-C10
Alpha olefins, Cll and higher
n-Paraffins
n-Paraffins, C6-C9
n-Paraffins, C9-C15
n-Paraffins, C10-C14
n-Paraffins,
n-Paraffins,
n-Paraffins,
n-Paraffins,
Hydrocarbons,
Polybutene
Hydrocarbon derivatives
n-Butyl mercaptan (1-Butanethiol)
sec-Butyl mercaptan (2-Butanethiol)
tert-Butyl mercaptan (2-Methyl-
2-propanethiol)
Di-tert-butyl disulfide
Diethyl sulfide (Ethyl sulfide)
Dimethyl sulfide
Ethyl mercaptan (Ethanethiol)
Ethylthioethanol
n-Hexyl mercaptan (1-Hexanethiol)
Isopropyl mercaptan (2-Propanethiol)
Methyl ethyl sulfide
Methyl mercaptan (Methanethiol)
tert-Octyl mercaptan (2,4,4-Trimethyl-
2-pentanethiol)
Octyl mercaptans
Thiophane (Tetrahydrothiophene)
Hydrocarbon derivatives: all other
hydrocarbon derivatives
Hydrocarbons, C9 and above, all other,
including mixtures
Source: 1982 Census of Manufacturers and Census of Mineral Industries.
Numerical List of Manufactured and Mineral Products. U.S. Department
of Commerce, Bureau of the Census, 1982.
111-19
-------
2. Scope of the Final Regulation
The promulgated regulation establishes effluent limitations guidelines
and standards for existing and new organic chemicals, plastics, and synthetic
fibers manufacturing facilities (BPT, BAT, NSPS, PSES, and PSNS). The final
regulations apply to process wastewater discharges from these facilities.
For the purposes of this regulation, OCPSF process wastewater discharges
are defined as discharges from all establishments or portions of establish-
ments that manufacture the products or product groups listed in the applica-
bility sections of the regulation and also in Appendix III-A of this document,
and are included within the following U.S. Department of Commerce Bureau of
the Census SIC major groups:
• SIC 2865 - Cyclic Crudes and Intermediates, Dyes, and Organic Pigments
• SIC 2869 - Industrial Organic Chemicals, Not Elsewhere Classified
• SIC 2821 - Plastic Materials, Synthetic Resins, and Nonvulcanizable
Elastomers
• SIC 2823 - Cellulosic Man-Made Fibers
• SIC 2824 - Synthetic Organic Fibers, Except Cellulosic.
The OCPSF regulation does not apply to process wastewater discharges from
the manufacture of organic chemical compounds solely by extraction from plant
and animal raw materials or by fermentation processes. Thus, ethanol derived
from natural sources (SIC 28095112) is not considered to be an OCPSF industry
product; however, ethanol produced synthetically (hydration of ethene) is an
OCPSF industry product.
The OCPSF regulation covers all OCPSF products or processes whether or
not they are located at facilities where the OCPSF covered operations are a
minor portion of and ancillary to the primary production activities or a major
portion of the activities.
The OCPSF regulation does not apply to discharges from OCPSF product/
process operations that are covered by the provisions of other categorical
111-20
-------
industry effluent limitations guidelines and standards if the wastewater is
treated in combination with the non-OCPSF industrial category regulated waste-
water. (Some products or product groups are manufactured by different pro-
cesses and some processes with slight operating condition variations give dif-
ferent products; EPA uses the term "product/process" to define all different
variations within this category of the same basic process to manufacture dif-
ferent products as well as to manufacture the same product using different
processes.) However, the OCPSF regulation applies to the product/processes
covered by this regulation if the facility reports OCPSF products under SIC
codes 2865, 2869, or 2821, and its OCPSF wastewaters are treated in a separate
treatment system at the facility or discharged separately to a publicly owned
treatment works (POTW).
For example, some vertically integrated petroleum refineries and pharma-
ceutical manufacturers discharge wastewaters from the production of synthetic
organic chemical products that are specifically regulated under the petrochem-
ical and integrated subcategories of the petroleum refining point source cate-
gory (40 CFR Part 419, Subparts C and E) or the chemical synthesis products
subcategory of the Pharmaceuticals manufacturing point source category (40 CFR
Part 439, Subpart C). Thus, the principles discussed in the preceding para-
graph apply as follows: the process wastewater discharges by petroleum refin-
eries and pharmaceutical manufacturers from production of organic chemical
products specifically covered by 40 CFR Part 419 Subparts C and E and Part 439
Subpart C, respectively, that are treated in combination with other petroleum
refinery or pharmaceutical manufacturing wastewater, respectively, are not
subject to regulation no matter what SIC they use to report their products.
However, if the wastewaters from their OCPSF production is separately dis-
charged to a POTW or treated in a separate treatment system, and they report
their products (from these processes) under SIC codes 2865, 2869, or 2821,
then these manufacturing operations are subject to regulation under the OCPSF
regulation, regardless of whether the OCPSF products are covered by 40 CFR
Part 419, Subparts C and E and Part 439, Subpart C.
The promulgated OCPSF category regulation applies to plastics molding and
forming processes when plastic resin manufacturers mold or form (e.g., extrude
and pelletize) crude intermediate plastic material for shipment off-site.
111-21
-------
This regulation also applies to the extrusion of fibers. Plastics molding and
forming processes other than those described above are regulated by the plas-
tics molding and forming effluent guidelines and standards (40 CFR Part 463).
Public comments requested guidance relating to the coverage of OCPSF
research and development facilities. Stand-alone OCPSF research and develop-
ment, pilot-plant, technical service, and laboratory bench-scale operations
are not covered by the OCPSF regulation. However, wastewater from such opera-
tions conducted in conjunction with and related to existing OCPSF manufactur-
ing operations at OCPSF facilities is covered by the OCPSF regulation because
these operations would most likely generate wastewater with characteristics
similar to the commercial manufacturing facility. Research and development,
pilot-plant, technical service, and laboratory operations that are unrelated
to existing OCPSF plant operations, even though conducted on-site, are not
covered by the OCPSF regulation because they may generate wastewater with
characteristics dissimilar to that from the commercial OCPSF manufacturing
facility.
Finally, as described in the following paragraphs, this regulation does
not cover certain production that has historically been reported to the Bureau
of Census under a non-OCPSF SIC subgroup heading, even if such production
could be reported under one of the five SIC code groups covered by the final
regulation.
The Settlement Agreement required the Agency to establish regulations for
the organic chemicals manufacturing SIC codes 2864 and 2869 and for the plas-
tics and synthetic materials manufacturing SIC Code 282. SIC 282 includes the
three codes covered by this regulation, 2821, 2823, and 2824, as well as SIC
2822, synthetic rubber (vulcanizable elastomers), which is covered specific-
ally in the Settlement Agreement by another industrial category, rubber manu-
facturing (40 CFR 428). The Agency therefore directed its data collection
efforts to those facilities that report manufacturing activities under SIC
codes 2821, 2823, 2824, 2865, and 2869. Based on an assessment of this infor-
mation and the integrated nature of the synthetic OCPSF industry, the Agency
also defined the applicability of the OCPSF regulation by listing the specific
products and product groups that provide the technical basis for the regula-
tion (see Appendix II1-A).
111-22
-------
Since many of these products may be reported under more than one SIC code
even though they are often manufactured with the same reaction chemistry or
unit operations, the Agency proposed to extend the applicability of the OCPSF
regulation (50 FR 29068; July 17, 1985 or 51 FR 44082; December 8, 1986) to
include OCPSF production reported under the following SIC subgroups:
• SIC 2911058 - aromatic hydrocarbons manufactured from purchased
refinery products
• SIC 2911632 - aliphatic hydrocarbons manufactured from purchased
refinery products
• SIC 28914 - synthetic resin and rubber adhesives (including only those
synthetic resins listed under both SIC 28914 and SIC 2821 that are
polymerized for use or sale by adhesive manufacturers)
• Chemicals and chemical preparations, not elsewhere classified:
- SIC 2899568 - sizes, all types
SIC 2899597 - other industrial chemical specialties, including
fluxes, plastic wood preparations, and embalming fluids
• SIC 2843085 - bulk surface active agents
• SIC 3079 - miscellaneous plastics products (including only cellophane
manufacture from the viscose process).
However, for the reasons discussed below, the Agency has decided not to extend
the applicability of the OCPSF regulation to discharges from establishments
that manufacture OCPSF products and have, in the past, reported such produc-
tion under these non-OCPSF SIC subgroups.
As noted earlier, the SIC codes are classifications of commercial and
industrial establishments by type of activity in which they are engaged. The
predominant purpose of the SIC code is to classify the manufacturing indus-
tries for the collection of economic data. The product descriptions in SIC
codes are often technically ambiguous and also list products that are no
longer produced in commercial quantities. For this reason, the Agency pro-
posed to define the applicability of the OCPSF regulation in terms of both SIC
codes and specific products and product groups (50 FR 29073, July 17, 1985).
Many chemical products may appear under more than one SIC code depending on
111-23
-------
the manufacturing raw material sources, use in the next st,age of the manufac-
turing process, or type of sale or end use. For example, phenolic, urea, and
acrylic resin manufacture may be reported under SIC 28914, synthetic resin
adhesives, as well as under SIC 2821, plastics materials and resins. Benzene,
toluene, and xylene manufacture may be reported under SIC 2911, petroleum
refining, or under SIC 2911058, aromatics, made from purchased refinery pro-
ducts, as well as SIC 2865, cyclic crudes and intermediates. Likewise, alkyl-
benzene sulfonic acids and salts manufacture may be reported under SIC
2843085, bulk surface active agents, which include all amphoteric, anionic,
cationic, and nonionic bulk surface active agents excluding surface active
agents produced or purchased and sold as active incredients in formulated
products, as well as SIC 286, industrial organic chemicals.
Many commenters stated that the Agency's OCPSF technical and economic
studies do not contain sufficient information to extend coverage to all
facilities reporting OCPSF manufacturing under all of the above SIC subgroups.
The Agency agrees in part with these commenters. The OCPSF technical, cost,
and economic impact data-gathering efforts focused only on those primary and
secondary manufacturers that report OCPSF manufacturing activities under SIC
codes 2821, 2823, 2824, 2865, and 2869. Specific efforts were not directed
toward gathering technical and financial data from facilities that report
OCPSF manufacturing under SIC subgroups 2911058, 2911632, 28914, 2843085,
2899568, 2899597, and 3079. As a result, EPA lacks cost and economic informa-
tion from a significant number of plants that report OCPSF manufacturing
activities to the Bureau of the Census under these latter SIC subgroups. Con-
sequently, the applicability section of the final regulation (§414.11) clari-
fies that the OCPSF regulation does not apply to a plant's OCPSF production
that has been reported by the plant in the past under SIC groups 2911058,
2911632, 28914, 2843085, 2899568, 2899597, and 3079.
Approximately 140 of the 940 OCPSF plants that provide the technical
basis for the final regulation reported parts of their OCPSF production under
SIC codes 2911058, 2911632, 28914, 2843085, 2899568, and 2899597, as well as
SIC codes 2821, 2823, 2824,.2865, and 2869. As a result of the definition of
applicability, a smaller portion of plant production than was reported as
OCPSF production for these plants is covered by the final regulation.
111-24
-------
The Agency does note, however, that the OCPSF manufacturing processes are
essentially identical regardless of how manufacturing facilities may report
OCPSF production to the Bureau of the Census. Therefore, the OCPSF technical
.data base and effluent limitations and standards provide permit issuing
authorities with technical guidance for establishing "Best Professional Judg-
ment" (BPJ) permits for OCPSF production activities to which this regulation
does not apply.
Some of the non-OCPSF SIC subgroups were the subject of prior EPA deci-
sions not to establish national regulations for priority pollutants under the
terms of Paragraph 8 of the Settlement Agreement. Such action was taken for
adhesive and sealant manufacturing (SIC 2891), as well as plastics molding and
forming (SIC 3079), paint and ink formulation and printing (which industries
were within SIC 2851, 2893, 2711, 2721, 2731 and 10 other SIC 27 groups) and
soap and detergent manufacturing (SIC 2841). However, it should be noted that
in specific instances where a plant in these categories has OCPSF production
activities, toxic pollutants may be present in the discharge in amounts that
warrant BPJ regulatory control. Moreover, the adhesives and sealants, plas-
tics molding and forming, and paint and ink formulation and printing Paragraph
8 exclusions do not include process wastewater from the secondary manufacture
of synthetic resins. Similarly, the soaps and detergents Paragraph 8 exclu-
sion does not include process wastewater from the manufacture of surface
active agents (SIC 2843). In these cases, and even in cases where priority
pollutants from OCPSF production covered by other categorical standards (e.g.,
petroleum refining and Pharmaceuticals) have been excluded from those regula-
tions under the terms of Paragraph 8 of the Settlement Agreement, BPJ priority
pollutant regulation for individual plants having OCPSF production may be
appropriate.
3. Raw Materials and Product Processes
a. Raw Materials
Synthetic organic chemicals are derivatives of naturally occurring mater-
ials (petroleum, natural gas, and coal) that have undergone at least one chem-
ical reaction. Given the large number of potential starting materials and
111-25
-------
chemical reactions available to the industry, many thousands of organic chemi-
cals are produced by a potentially large number of basic processes having many
variations. Similar considerations also apply to the plastics and synthetic
fibers industry, although both the number of starting materials and processes
are more limited. Both organic chemicals and plastics are commercially pro-
duced from six major raw material classifications: methane, ethane, propene,
butanes/butenes, and higher aliphatic and aromatic compounds. This list can
be expanded to eight by further defining the aromatic compounds to include
benzene, toluene, and xylene. These raw materials are derived from natural
gas and petroleum, although a small portion of the aromatic compounds is
derived from coal.
Using these eight basic raw materials (feedstocks) derived from the
petroleum refining industry, process technologies used by the OCPSF industry
lead to the formation of a wide variety of products and intermediates, many of
which are produced from more than one basic raw material either as a primary
reaction product or as a co-product. Furthermore, the reaction product of one
process is frequently used as the raw material for a subsequent process. The
primary products of the organic chemicals industry, for example, are the raw
materials of the plastics and synthetic fibers industry. Furthermore, the
reaction products of one process at a plant are frequently the reactants for
other processes at the same plant, leading to the categorization of a chemical
as a product in one process and a reactant in another. This ambiguity con-
tinues until the manufacture of the ultimate end product, normally at the
fabrication or consumer stage. Many products/intermediates can be made from
more than one raw material. Frequently, there are alternate processes by
which a product can be made from the same basic raw material.
A second characteristic of the OCPSF industry that adds to the complexity
of the industry is the high degree of integration in manufacturing units.
Most plants in this industry use several of the eight basic raw materials
derived from petroleum or natural gas- to produce a single product.
In addition, many plants do not use the eight basic raw materials, but
rather use products produced at other plants as their raw materials. Rela-
tively few manufacturing facilities are single product/process plants unless
111-26
-------
the final product is near the fabrication or consumer product stage. Any
attempt to define or subcategorize the industry- on the basis of the 8 raw
materials would require the establishment of over 256 definitions or subcate-
gories. Schematic diagrams illustrating some of these relationships are shown
in Section V of this document (see Figures V-l to V-16).
b. Process Chemistry
Chemical and plastics manufacturing plants share an important character-
istic: chemical processes never convert 100 percent of the feedstocks to the
desired products, since the chemical reactions/processes never proceed to
total completion.
Moreover, because there is generally a variety of reaction pathways
available to reactants, undesirable by-products are often generated. This
produces a mixture of unreacted raw materials, products, and by-products that
must be separated and recovered by operations that generate residues with
little or no commercial value. These losses appear in process wastewater, in
air emissions, or directly as chemical wastes. The specific chemicals that
appear as losses are determined by the feedstock and the process chemistry
imposed upon it. The different combinations of products and production
processes distinguish the wastewater characteristics of one plant from those
of another.
Manufacture of a chemical product necessarily consists of three steps:
1) combination of reactants under suitable conditions to yield the desired
product; 2) separation of the product from the reaction matrix (e.g., by-
products, co-products, reaction solvents); and 3) final purification and/or
disposal of the wastewaters. Pollutants arise from the first step as a
result of alternate reaction pathways; separation of reactants and products
from a reaction mixture is imperfect and both raw materials and products are
typically found in process wastewaters.
Although there is strong economic incentive to recover both raw materials
and products, there is little incentive to recover the myriad of by-products
formed as the result of alternate reaction pathways. An extremely wide
111-27
-------
variety of compounds can form within a given process. Typically, chemical
species do not react via a single reaction pathway; depending on the nature of
the reactive intermediate, there is a variety of pathways that lead to a
series of reaction products. Often, and certainly the case for reactions of
industrial significance, one pathway may be greatly favored over all others,
but never to total exclusion. The direction of reactions in a process
sequence is controlled through careful adjustment and maintenance of condi-
tions in the reaction vessel. The physical condition of species present
(liquid, solid, or gaseous phase), conditions of temperature and pressure, the
presence of solvents and catalysts, and the configuration of process equipment
dictate the kinetic pathway by which a particular reaction will proceed.
Therefore, despite the differences between individual chemical production
plants, all transform one chemical to another by chemical reactions and physi-
cal processes. Although each transformation represents at least one chemical
reaction, production of most of the industry's products can be described by
one or more of the 41 major generalized chemical reactions/processes listed in
Table III-8. Subjecting the basic feedstocks to sequences of these 41 generic
processes produces most commercial organic chemicals and plastics.
Pollutant formation is dependent upon both the raw material and process
chemistry, and broad generalizations regarding raw wastewater loads based
solely on process chemistry are difficult at best. Additionally, OCPSF manu-
facturing processes typically employ unique combinations of the major generic
processes shown in Table III-8 to produce organic chemicals, plastics, and
synthetic fibers that tend to blur any distinctions possible.
c. Product/Processes
Each chemical product may be made by one or more combinations of raw
feedstock and generic process sequences. Specification of the sequence of
product synthesis by identification of the product and the generic process by
which it is produced is called a "product/process." There are, however,
thousands of product/processes within the OCPSF industries. Data gathered on
the nature and quantity of pollutants associated with the manufacture of
specific products within the organic chemicals and plastic/synthetic fibers
111-28
-------
TABLE III-8.
MAJOR GENERALIZED CHEMICAL REACTIONS AND PROCESSES
OF THE ORGANIC CHEMICALS, PLASTICS, AND SYNTHETIC FIBERS INDUSTRY
Acid cleavage
Alkoxylation
Alkylation
Amination
Ammonolysis
Ammoxidation
Carbonylation
Chlorohydrination
Condensation
Cracking
Crystallization/Distillation
Cyanation/Hydrocyanation
Dehydration
Dehydrogenation
Dehydrohalogenation
Distillation
Electrohydrodimerization
Epoxidation
Esterification
Etherification
Extractive distillation
Extraction
Fiber production
Halogenation
Hydration
Hydroacetylation
Hydrodealkylation
Hydrogenation
Hydrohalogenation
Hydrolysis
Isomerization
Neutralization
Nitration
Oxidation
Oxyhalogenation
Oxymation
Peroxidation
Phosgenation
Polymerization
Pyrolysis
Sulfonation
111-29
-------
industries have been indexed for 176 product/processes. These data are dis-
cussed in Section V of this document.
Organic chemical plants vary greatly as to the number of products manu-
factured and processes employed, and may be either vertically or horizontally
integrated. One representative plant, which is both vertically and horizon-
tally integrated, may produce a total of 45 high-volume products with an
additional 300 lower-volume products. In contrast, a specialty chemicals
plant may produce a total of 1,000 different products with 70 to 100 of these
being produced on any given day.
On the other hand, specialty chemicals may involve several chemical
reactions and require a more detailed description. For example, preparation
of toluene diisocyanate involves three synthesis steps — nitration, hydro-
genation, and phosgenation. This example., in fact, is relatively simple;
manufacture of other specialty chemicals is more complex. Thus, as individual
chemicals become further removed from the feedstock of the industry, more
processes are required to produce them.
In contrast to organic chemicals, plastics and synthetic fibers are
polymeric products. Their manufacture directly utilizes only a small subset
of either the chemicals manufactured or processes used within the OCPSF indus-
try. Such products are manufactured by polymerization processes in which
organic chemicals (monomers) react to form macromolecules or polymers, com-
posed of thousands of monomer units. Reaction conditions are designed to
drive the polymerization as far to completion as practical and to recover
unreacted monomer.
Unless a solvent is used in the polymerization, by-products of polymeric
product manufacturers are usually restricted to the monomer(s) or to oliomers
(a polymer consisting of only a few monomer units). Because the mild reaction
conditions generate few by-products, there is economic incentive to recover
the monomer(s) and oliomers for recycle; the principal yield loss is typically
scrap polymer. Thus, smaller amounts of fewer organic chemical co-products
(pollutants) are generated by the production of polymeric plastics and syn-
thetic fibers than are generated by the manufacture of the monomers and other
organic chemicals.
111-30
-------
For the purposes of characterizing the OCPSF industry in this section,
the manufacturing facilities are assigned to one of the following three groups
based on SIC codes reported in the 1983 Section 308 Questionnaire.
Plant Group Associated SIC Codes Reported
Organics Plants 2865, 2869
Plastics Plants 2821, 2823, 2824
Organics and Plastics One or more from each of
Plants (Mixed) the two groups above
d. Industry Structure by Product/Process
A portion of the branched product structure of the OCPSF industry is
illustrated in Figures V-l to V-16 of Section V, which include key OCPSF pro-
ducts and organic priority pollutants. The total product line of the industry
is considerably more complex, but Figures V-l to V-16 illustrate the ability
of the organic chemicals industry to produce a product by different synthesis
routes. For each of the products that are produced in excess of 1,000 pounds
per year (approximately 1,500 to 2,500 products), there is an average of two
synthetic routes. The more than 20,000 compounds that are produced in smaller
quantities by the industry tend to be more complex molecules that can be syn-
thesized by multiple routes. Because many products are often produced by more
than one manufacturer, using the same or different synthetic routes, few
plants have exactly the same product/process combinations as other plants.
An important characteristic of the OCPSF industry is the degree of verti-
cal integration among manufacturing units at individual plants. Since a
majority of the basic raw materials is derived from petroleum or natural gas,
many of the commodity organic chemical manufacturing plants are either part of
or contiguous to petroleum refineries; most of these plants have the flexi-
bility to produce a wide variety of products.
Relatively few organic chemical manufacturing facilities are single
product/process plants, unless the final product is near the fabrication or
consumer product stage.
111-31
-------
Additionally, many process units are integrated in such a way that pro-
duction levels of related products can be varied as desired over wide ranges.
There can be a wide variation in the size (production capacity) of the manu-
facturing complex, as well as diversity of product/processes. In addition to
variations based on the design capacity and design product mix, economic and
market conditions of both the products and raw materials can greatly influence
the production rate and the processes that are employed even on a relatively
short-term basis.
4. Geographic Distribution
Plant distribution by state is presented in Table III-9. Most organic
chemical plants are located in coastal regions or on waterways near either
sources of raw materials (especially petrochemicals) or transportation
centers. Plastics and synthetic fibers plants are generally located near
organic chemicals plants to minimize costs of monomer feedstock transporta-
tion. However, a significant number of plastics plants are situated near
product markets (i.e., large population centers) to minimize costs of trans-
porting the products to market.
5. Plant Age
The ages of plants within the OCPSF industry are difficult to define,
since the plants are generally made up of more than one process unit, each
designed to produce different products. As the industry introduces new pro-
ducts and product demand grows, process units are added to a plant. It is not
clear which process should be chosen to define plant age. Typically, the
oldest process in current operation is used to define plant age. Information
concerning plant age was requested in the 1983 "308" Questionnaire.
Respondents were asked to report the year plant operation began and the
year the oldest OCPSF process line still operating went into operation. Table
111-10 presents the plant distribution of the age of the oldest OCPSF process
line still operating. Table 111-10 indicates that a few plants are currently
operating processes that are over 100 years old. However, over two-thirds of
the plants began operating the oldest process within the past 35 years. In
addition, the startup o^ new plants has been declining since the early 1970's.
111-32
-------
TABLE III-9.
PLANT DISTRIBUTION BY STATE
State*
AL
AR
CA
CO
CT
DE
FL
GA
IA
IL
IN
KS
KY
LA
MA
MD
MI
MN
MO
MS
MT
NC
NE
NH
NJ
NY
OH
OK
OR
PA
PR
RI
SC
TN
TX
UT
VA
WA
WI
WV
Total
Organics
Plants
14
4
19
2
6
5
2
7
2
16
7
3
7
27
4
4
9
1
8
4
-
13
1
2
70
23
27
-
1
22
-
4
17
8
57
2
7
3
4
13
425
Plastics
Plants
4
2
40
1
8
2
6
9
4
24
3
-
9
12
13
5
8
1
6
5
-
18
-
2
23
15
30
2
5
13
1
2
12
6
20
-
15
4
5
3
338
Organics and
Plastics Plants
5
2
4
-
2
2
3
2
-
15
2
1
5
8
3
1
4
1
1
3
1
10
-
-
16
5
12
-
4
8
1
3
8
4
29
-
2
1
3
6
177
Total
23
8
63
3
16
9
11
18
6
55
12
4
21
47
20
10
21
3
15
12
1
41
1
4
109
43
69
2
10
43
2
9
37
18
106
2
24
8
12
22
940
*0nly states that contain at least one facility are listed.
Source: EPA CWA Section 308 Survey, October 1983.
111-33
-------
TABLE 111-10.
DISTRIBUTION OF PLANTS BY AGE OF OLDEST
OCPSF PROCESS STILL OPERATING AS OF 1984
Plant Age
1-5
6-10
11-15
16-20
21-25
26-30
31-35
36-40
41-50
51-60
61-70
71-80
81-90
91-100
101-120
>120
Data not
Available
Total
Organics
Plants
24
37
40
55
44
50
42
24
30
23
28
16
3
3
5
-
1
425
Plastics
Plants
14
29
41
54
46
41
24
17
23
19
16
4
5
1
1
-
3
338
Organics and
Plastics Plants
2
2
20
17
19
28
20
21
16
8
10
5
4
3
_
1*
1
177
Total
40
68
101
126
109
119
86
62
69
50
54
25
12
7
6
1*
5
940
*Note: The one plant whose age is >120 is 137 years old.
Source: EPA CWA Section 308 Survey, 1983.
111-34
-------
This major decline in startup of combined organics and plastics plants in
the past 10 years may indicate a trend toward construction of plants that
produce fewer products or many specialty products geared toward specific mar-
kets, since the combined plants tend to be the larger, multi-product, verti-
cally integrated plants.
6. Plant Size
Although plant size may be defined in many ways, including number of
employees, number of product/processes, plant capacity, production volume, and
sales volume, none of these factors alone is sufficient to define plant size;
each is discussed in this subsection.
a. Number of Employees
Perhaps the most obvious definition of plant size would be the number of
workers employed. However, continuous process plants producing high-volume
commodity chemicals typically employ fewer workers per unit of production than
do plants producing specialty (relatively low-volume) chemicals. Table III-ll
presents the plant distribution by the average number of employees engaged in
OCPSF operations during 1982. These data were obtained from the 1983 Section
308 Questionnaire.
b. Number of Product/Processes
Plant size may also be expressed in terms of the number of product/
processes that are operated at a plant. Analysis of the number of product/
processes for 546 primary producers in the edited 1983 Section 308 Question-
naire data base is presented in Table 111-12. The table generally includes
only direct and indirect discharge facilities whose total plant production is
greater than 50 percent OCPSF products. Detailed product/process information
was not collected from zero discharge or secondary OCPSF manufacturing
facilities.
The data presented in Table 111-12 may understate the number of distinct
product/processes because plants were requested to group certain products that
were listed in the questionnaire instructions or that individually constituted
less than 1 percent of the total plant production. For example, many dye
111-35
-------
TABLE III-ll.
PLANT DISTRIBUTION BY NUMBER OF EMPLOYEES
Number of
Employees
1-105
11-20
21-30
31-40
41-50
51-100
101-200
201-500
501-1000
1001-2000
2001-5000
>5000
Data not
Available
Total
Organics
Plants
70
55
41
39
34
64
53
36
7
5
-
-
11
425
Plastics
Plants
73
58
32
26
23
45
27
23
9
9
7
-
6
338
Organics and
Plastics Plants
19
16
11
10
4
21
14
30
19
17
8
*1
7
177
Total
162
129
94
75
61
130
94
89
35
31
15
*1
24
940
*Note: The only plasnt with >5,000 employees hasd 11,262 employees,
Source: EPA CWA Section 308 Survey, 1983.
111-36
-------
TABLE 111-12.
PLANT DISTRIBUTION BY NUMBER OF PRODUCT/PROCESSES AND
PRODUCT GROUPS FOR PRIMARY PRODUCERS THAT ARE ALSO
DIRECT AND/OR INDIRECT DISCHARGERS*
Number of
Product /Processes
1
2
3
4
5
6
7
8
9
10
11-12
13-15
16-20
21-30
31-40
41-50
Organics
Plants
41
23
30
24
15
34
18
11
6
16
12
9
4
7
_
-
Plastics
Plants
72
30
27
17
8
10
6
2
2
_
1
_
~
-
-
_
Organics and
Plastics Plants
5
15
16
13
11
13
_
3
5
13
6
7
12
1
1 (50)
Total
113
58
72
57
36
55
37
13
11
21
26
15
11
19
1
1
Total
250
175
121
546
*Table consists of plants that completed Part B of the 1983 Section 308
Questionnaire.
111-37
-------
plants reported individual dye products, while others reported types of dyes
such as Azo- or Vat-dyes as one product. A review of Table 111-12 shows that:
plastics plants tend to have fewer product/processes with 88 percent reporting
5 or fewer; organics plants have a wider range of number of product/processes
with 87 percent reporting 10 or fewer; and that plants manufacturing both
organics and plastics, although fewer in number, tend to have more product/
processes with 88 percent reporting 20 or fewer.
c. Plant Capacity and Production Volume
For the purposes of this report, plant size cannot be sufficiently de-
fined based on design capacity due to the often broad differences between a
plant's design capacity or rate and its average production rate per year.
Plants continuously producing high-volume chemicals (generally employing
relatively few workers), may be physically smaller than plants producing
lower-volume specialty chemicals by batch processes. Table 111-13 presents
the distribution of plant OCPSF production and total production for the year
1982 with plants sorted by their primary SIC code. The rates given are total
(all products) production for the plant, not just the product SIC group under
which they are listed. All data are from the 1983 Section 308 Questionnaire.
Additional production information is available in the Economic Impact Analysis
Report. Even though the table includes 38 plants that have been determined to
be non-scope facilities, the general trends reflected in the table should
apply to the final list of 940 scope facilities.
d. Plant Sales Volume
Sales volume alone is not necessarily an accurate indicator of plant
size. High-volume commodity chemicals are typically less expensive than
specialty chemicals. However, sales volume or production volume in terms of
dollars is very useful in describing plant size in economic terms. This
definition of size has been used in the economic analysis for this OCPSF rule.
Table 111-14 presents the distribution of plants by OCPSF total 1982 sales
value with plants sorted by their major SIC code. These 1983 Section 308
Questionnaire data are presented in the same format as production volumes
above. Additional sales data are available in the Economic Impact Analysis
Report. Like Table 111-13, Table 111-14 includes 38 facilities that have been
determined to be non-scope facilities.
111-38
-------
TABLE 111-13.
DISTRIBUTION OF 1982 PLANT PRODUCTION QUANTITY BY OCPSF SIC GROUP
No SIC
No. of
Plants
OCPSF Production
(Million Ibs.)
No data 39
0-.2
.2-1
1-2
2-10
10-20
20-100
100 Plus
All 39
Total Production
(Million Ibs.)
No data 12
0-.2 2
.2-1 2
1-2 1
2-10 12
10-20 5
20-100 3
100 Plus 2
All 39
2821 2823 2824
No. of No. of No. of
Plants Plants Plants
3
10
22
18
67
60
120
83
383
3
6
12
12
40
50
151
109
383
2
-
1
-
1 6
2
1 12
4 18
6 41
2
-
1
-
1 6
2
1 11
4 19
6 41
2865
No. of
Plants
6
17
5
25
10
14
34
111
3
14
7
23
11
14
39
111
2869
No. of
Plants
3
29
22
19
75
37
109
104
398
3
22
12
11
65
33
107
145
398
All
No. of
Plants
47
45
62
42
174
109
256
243
9781
20
33
41
31
147
101
287
318
9781
All
Percent
4.8
4.6
6.3
4.3
17.8
11.1
26.2
24.8
100.0
2.0
3.4
4.2
3.2
15.0
10.3
29.3
32.5
100.0
1Includes 38 plants that have been determined to be non-scope facilities.
Source: OCPSF Economic Impact Analysis.
111-39
-------
TABLE III-14.
DISTRIBUTION OF 1982 PLANT SALES VALUE BY OCPSF SIC GROUP
No SIC
No. of
Plants
OCPSF Production
(Million $)
No data 39
0-1
1-5
5-10
10-50
50-100
100-500
500 Plus
All 39
Total Sales
Value (Million $)
No data 13
0-1 2
1-5 9
5-10 3
10-50 9
50-100 2
100-500 1
500 Plus
All 39
2821 2823 2824
No. of No. of No. of
Plants Plants Plants
11
34
76
61
128
33
38
"2
383
5
15
32
56
157
58
50
10
383
2
-
2
1 3
1 8
5
4 20
1
6 41
2
-
1
1 3
1 9
5
4 20
1
6 41
2865
No. of
Plants
-
5
23
11
45
10
17
-
Ill
-
5
15
13
47
13
18
-
Ill
2869
No. of
Plants
8
39
56
47
132
43
57
16
398
6
26
45
33
143
46
82
17
398
All
No. of
Plants
60
78
157
123
314
91
136
19
9781
26.
48
102
109
366
124
175
28
9781
All
Percent
6.1
8.0
16.1
12.6
32.1
9.3
13.9
1.9
100.0
2.6
4.9
10.4
11.1
37.4
12.7
17.9
2.9
100.0
1Includes 38 plants that have been determined to be non-scope facilities.
Source: OCPSF Economic Impact Analysis.
111-40
-------
7. Mode of Discharge
There are three basic discharge modes utilized by the industry: direct,
indirect, and zero or alternative disposal/discharge. Direct dischargers are
plants that produce a contaminated process wastewater, treated or untreated,
that is discharged directly into a surface water. Plants that produce only
noncontact cooling water and/or sanitary sewage effluents (non-process waste-
water) are not considered to be direct dischargers of OCPSF process wastewater
for purposes of this report. Indirect dischargers are plants that route their
OCPSF process wastewater effluents to POTWs. Zero or alternative disposal/
dischargers are plants that discharge no OCPSF process wastewater to surface
streams or to POTWs. For the purposes of this report, these include plants
that generate no process wastewaters, plants that recycle all contaminated
waters, and plants that use some kind of alternative disposal technology
(e.g., deep well injection, incineration, contractor removal, etc).
The discharge of process wastewaters into the system of an adjoining
manufacturing facility or to a treatment system not owned by a government
entity is not considered indirect discharge, but is termed off-site treatment
and is considered an alternative disposal method. Table 111-15 shows the
plant distribution based on mode of discharge. The table also shows the
distribution between primary producers (i.e., plants whose OCPSF production
exceeds 50 percent of the plant total) and secondary producers.
Fifteen plants discharge treated and/or untreated wastewater both di-
rectly and indirectly. In general, these plants discharge high-strength or
"difficult to treat" wastewater to POTWs and direct discharge more easily
treated low-strength wastewater.
C. DATA BASE DESCRIPTION
1. 1983 Section 308 Questionnaire Data Base
In the preamble to the March 21, 1983 proposed regulation, the Agency
recognized the need to gather additional data to ensure that the final regula-
tion is based upon information that represents the entire industry and to
assess wastewater treatment installed since 1977. Therefore, the Agency
III-A1
-------
TABLE 111-15.
MODE OF DISCHARGE
Direct Indirect
Primary Producers
Organics Plants 96 146
Plastics Plants 72 96
Organics & Plastics
Plants 70 45
Total Primary
Producers 238 287
Secondary Producers
and/or Zero Dischargers
Organics Plants 30 48
Plastics Plants 13 41
Organics & Plastics
Plants 8 17
Total Secondary
Producers/Zero
Dischargers 51 106
Total All Plants 289 393
Direct and
Indirect Zero Unknown Total
5 3-250
2 5-175
5 1-121
12 9 - 546
1 92 4 175
1 104 4 163
1 29 1 56
3 225 9 393
15 234 9 940
Source: EPA CWA Section 308 Survey, 1983.
111-42
-------
conducted an extensive data-gathering program to improve the coverage of all
types of OCPSF manufacturers. A comprehensive Clean Water Act Section 308
Questionnaire was developed and distributed in 1983. The mailing list was
compiled from the following references that identify manufacturers of OCPSF
products:
• Economic Information Service
• SRI Directory of Chemical Manufacturers
• Dun and Bradstreet Middle Market Directory
• Moody's Industrial Manual
• Standard and Poor's Index
• Thomas Register
• Red Book of Plastics Manufacturers
• 1976 and 1977 308 Questionnaire Data Bases
• Plastics Manufacturers Telephone Survey of 301 Plants.
In October 1983, the Agency sent a General Questionnaire to 2,840 facili-
ties and corporate headquarters to obtain information regarding individual
plant characteristics, wastewater treatment efficiency, and the statutory
factors expected to vary from plant to plant. The General Questionnnaire
consisted of three parts: Part I (General Profile), Part II (Detailed Produc-
tion Information), and Part III (Vastewater Treatment Technology, Disposal
Techniques, and Analytical Data Summaries).
Some plants that received the Section 308 Questionnaire had OCPSF
operations that were a minor portion of their principal production activities
and related wastewater streams. The data collected from these facilities
allow the Agency to characterize properly the impacts of ancillary (secondary)
OCPSF production. Generally, if a plant's 1982 OCPSF production was less than
50 percent of the total facility production (secondary manufacturer), then
only Part I of the questionnaire was completed.
Part I identified the plant, determined whether the plant conducted
activities relevant to the survey, and solicited general data (plant age,
ownership, operating status, permit numbers, etc.). General OCPSF and non-
OCPSF production and flow information was collected for all plant manufactur-
ing activities. This part also requested economic information, including data
111-43
-------
on shipments and sales by product groups, as well as data on plant employment
and capital expenditures.
Part I determined whether a respondent needed to complete Parts II and
III (i.e., whether the plant is a primary or secondary producer of OCPSF pro-
ducts, whether the plant discharges wastewater, and for secondary producers,
whether the plant segregates OCPSF process wastewaters). For those plants
returning only the General Profile, Part I identified the amounts of process
wastewater generated, in-place wastewater treatment technologies, wastewater
characteristics, and disposal techniques.
Part II requested detailed 1980 production information for 249 specific
OCPSF products, 99 specific OCPSF product groups, and OCPSF products that
constituted more than 1 percent of total plant production. Less detailed
information was requested for the facility's remaining OCPSF and non-OCPSF
production. Part II also requested information on the use or known presence
of the priority pollutants for each OCPSF product/process or product group.
Part III requested detailed information on plant wastewater sources and flows,
technology installed, treatment system performance, and disposal techniques.
Responses to economic and sales items in Part I pertained to calendar
year 1982, which were readily available, since the plants were required to
submit detailed 1982 information to the Bureau of the Census. This reduced
the paperwork burden for responding plants.
The remainder of the Section 308 Questionnaire, however, requested data
for 1980, a more representative production year. The Agency believed that
treatment performance in 1982 would be unrepresentative of treatment during
more typical production periods. This is because decreased production nor-
mally results in decreased wastewater generation. With lower volumes of
wastewater being treated, plants in the industry might be achieving levels of
effluent quality that they could not attain during periods of higher produc-
tion. The year 1980 was selected in consultation with industry as representa-
tive of operations during more normal production periods, but recent enough to
identify most new treatment installed by the industry since 1977. The indus-
try representatives did not assert that significant new treatment had been
installed since 1980.
111-44
-------
The Section 308 Questionnaires were designed to be encoded into a
computer data base directly from the questionnaires. To ensure that the ques-
tionnaires were filled out completely and correctly a copy of each question-
naire was reviewed by engineers. Due to the diversity and complexity of the
OCPSF industry, a number of problems were encountered in reviewing the ques-
tionnaires. Some of the problems encountered included incorrect units of
measure, incomplete responses, misinterpretation of data requested, conflict-
ing data for different questions, pooling of data for separate questions, and
unusual circumstances at the plant.
Solutions to these problem included recalculation of the data, followup
contacts for clarification, or in some cases rejection of the data. Some of
these problems may be explained in part by the fact that some companies simply
did not keep records of the information that was requested by the question-
naire, and consequently could not respond fully on all items of interest.
The data were encoded onto computer tapes from the corrected copies of
the questionnaires. Each questionnaire was double entered by separate indi-
viduals to help eliminate keypunch errors. The data were then sorted into
separate computer files for each question.
The data in each question-file were then verified by various means.
Verification methods included but were not limited to: visual inspection of
the file printout, checks for missing data, checks for conflicting data, and
checks for unusually high or low values. In addition, many of the engineering
analyses required a more detailed review of the data, plus the execution of
the analyses often exposed faulty data through erroneous results or the in-
ability of a program to run. Wherever suspect data were identified, they were
referred to the review engineers who then took appropriate action to resolve
the problem. The economic study assessments also determined that some plants
that responded as a scope facility should be considered non-scope. A separate
data file called the Master Analysis File has been created from the 308
Questionnaire data. This data file contains only data that are useful in the
engineering analyses and are used for that purpose.
111-45
-------
The Section 308 Questionnaires were mailed in October 1983. In February
1984, Section 308 followup letters were sent to 914 nonrespondents. A total
of 940 questionnaire responses provide the basis for the final technical and
.economic studies. A total of 1,574 responses were from facilities that were
determined to be outside of the scope of the final regulations (e.g., sales
offices, warehouses, chemical formulators, non-scope production, etc.); 166
were returned by the Post Office; and 160 did not respond. A followup
telephone survey of 52 randomly selected nonrespondents concluded that over 90
percent of the nonrespondents were not manufacturers of OCPSF products.
In addition, a Supplemental Questionnaire was sent to 84 facilities known
to have installed selected wastewater treatment unit operations. Detailed
design and cost information was requested for four major treatment components
commonly used to treat OCPSF wastewaters (i.e., biological treatment, steam
stripping, solvent extraction, and granular activated carbon) and summary
design and cost information for other wastewater and sludge treatment compon-
ents. The questionnaires also collected available treatment system perform-
ance data for in-plant wastewater control or treatment unit operations, in-
fluent to the main wastewater treatment system, intermediate waste stream
sampling locations, and final effluent from the main wastewater treatment
system. Unlike the General Questionnaire, it asked for individual daily data
rather than summary data. After a followup effort 64 plants responded with
useful data and information.
2. Daily Data Base Development
One of the major purposes of this study is the development of long-term
daily pollutant data. These data are required to derive variability factors
that characterize wastewater treatment performance and provide the basis for
derivation of proposed effluent limitations guidelines and standards. Hun-
dreds of thousands of data points have been collected, analyzed, and entered
into the computer.
The first effort at gathering daily data involved the BPT and BAT mail-
ings in 1976 and 1977. These questionnaires asked each plant for backup
information to support the long-term pollutant values reported. Many plants
111-46
-------
submitted influent and effluent daily observations convering the time period
of interest in the BPT questionnaire (January 1, 1976 to September 30, 1976).
Additionally, there were other conventional and nonconventional pollutant
daily data in the files from the period of verification sampling. Some plants
also submitted additional data with their public comments for the 1983 pro-
posed requlations. Additional data were collected through the supplemental
1983 Section 308 Supplemental Questionnaires.
3. BAT Data Base
The BAT Data Base contains long- and short-term priority pollutant data
used in the development of effluent limits. The data base consists primarily
of end-of-pipe wastewater treatment system influent and effluent data, but
also includes other types of samples. These other samples include individual
process streams, intermediate samples within the end-of-pipe system, and in-
fluent and effluent samples of individual treatment units, especially those
under consideration as BAT technology.
Data sources include both EPA sampling programs and data supplied by
OCPSF plants. In all cases, the analytical data have been considered accept-
able for limitations development only if the QA/QC procedures were documented
and in the case of organic pollutants the analyses were confirmed by GC/MS or
known to be present based on process chemistry. The major sources of data are
listed below:
• EPA Screening Sampling Program (1977 to 1979)
• EPA Verification Sampling Program (1978 to 1980)
• EPA/CMA Five-Plant Study (1980 to 1981)
• EPA 12-Plant Sampling Program (1983 to 1984)
• Plant Submissions Accompanying Comments to the March 1983 Proposed
Regulations
• Plant Submissions Accompanying Comments to the July and October 1985
and December 1986 Notices of New Information
• Supplemental Sections to the 1983 Section 308 Questionnaire.
111-47
-------
The data base designations used throughout this report are listed in
Table 111-16. The four EPA sampling programs are discussed in greater detail
in Sections V and VII of this report.
111-48
-------
TABLE 111-16.
DATA BASE DESIGNATION
Data Base File Name
Description
308 Data Base
Data base containing all data
extracted from 1983 Section 308
Questionnaires
Master Analysis File (MAP)
Contains data excerpted from the
1983 Section 308 Data Base
(includes conventional pollutant
parameter long-term average data)
Daily Data Base
Contains long-term conventional
pollutant effluent daily data from
69 plants
BAT Data Base
Contains long- and short-term
treatment system influent and
effluent daily data for priority
pollutants
Master Process File (MPF)
Contains priority pollutant raw
wastewater characterization data
for 176 OCPSF product/processes
III-A9
-------
SECTION IV
SUBCATEGORIZATION
A. INTRODUCTION
Sections 304(b)(l)(B) and 304(b)(A)(B) of the Clean Water Act (CWA) re-
quire the U.S. Environmental Protection Agency (EPA) to assess certain factors
in establishing effluent limitations guidelines based on the best practicable
control technology (BPT) and best available technology economically achievable
(BAT). These factors include the age of equipment and facilities involved;
the manufacturing process employed; the engineering aspects of the application
of recommended control technologies, including process changes and in-plant
controls; nonwater quality environmental impacts, including energy require-
ments; and such other factors as deemed appropriate by the Administrator.
To accommodate these factors, it may be necessary to divide a major
industry into a number of subcategories of plants sharing some common charac-
teristics. This allows the establishment of uniform national effluent limita-
tions guidelines and standards, while at the same time accounting for the
particular characteristics of different groups of facilities.
The factors considered for technical significance in the subcategoriza-
tion of the Organic Chemicals and Plastics and Synthetics Fibers (OCPSF) point
source categories include:
• Manufacturing product/processes
• Raw materials
• Wastewater characteristics
• Facility size
• Geographical location
• Age of facility and equipment
• Treatability
• Nonwater quality environmental impacts
• Energy requirements.
IV-1
-------
The impacts of these factors have been evaluated to determine if sub-
categorization is necessary or feasible. These evaluations, which are dis-
cussed in detail in the following sections, result in the following final
subcategories:
o BPT: Rayon, other fibers, thermoplastic resins, thermosetting resins,
commodity organics, bulk organics, and specialty organics
o BAT: Subcategory One (end-of-pipe biological treatment) and Subcate-
gory Two (non-end-of-pipe biological treatment).
B. BACKGROUND
In the March 21, 1983, Federal Register, EPA proposed a subcategorization
approach for regulation of the OCPSF industry. A Notice of Availability (NOA)
appeared in the July 17, 1985, Federal Register, which addressed a number of
concerns raised by industry relating to the March 1983 proposal. Another NOA
appeared in the December 8, 1986, Federal Register, which presented an altern-
ative subcategorization approach. This section discusses the subcategoriza-
tion methodologies for the proposal and the two NOAs and presents the concerns
and issues raised during the public comment periods for each.
1. March 21, 1983 Proposal
The March 21, 1983, proposal established four subcategories (Plastics
Only, Oxidation, Type I, and Other Discharges) for BPT effluent limitations,
which were based on generic chemical reactions such as oxidation, peroxida-
tion, acid cleavage, and esterfication and whether a plant produced plastics
or organics. This approach was found to be too cumbersome to implement be-
cause the process information necessary to place a plant in a subcategory was
not readily available. Also, a major problem raised by both industry and
regulatory agencies in public comments on the proposal was that a plant could
shift from one subcategory to another simply by changing a single product/
process.
The March 21, 1983, proposal also established two subcategories (Plastics
Only and Not Plastics Only) for BAT effluent limitations. The rationale for
this two-subcategory approach was that plants in the Plastics Only subcategory
tended to have fewer toxic pollutants present and less significant levels than
IV-2
-------
the remaining discharges, all of which result from the manufacture of at least
some organic chemicals which were contained in the Not Plastics Only subcat-
egory. The Agency also announced its intention to establish a separate BAT
subcategory with different zinc limitations for those plants manufacturing
rayon and utilizing the viscose process.
After reviewing public comments and evaluating its proposed subcategori-
zation methodology, the Agency decided to revise its approach and developed
another subcategorization approach, which was published for public comment in
the July 17, 1985, Federal Register NOA. This revised methodology is dis-
cussed in the following section.
2. July 17, 1985, Federal Register NOA
The July 17, 1985, Federal Register NOA sought to correct some of the
difficulties described above by categorizing plants according to the products
accounting for most of their production. Under this subcategorization strat-
egy, every plant was to be put into a single categoric grouping. The subcate-
gories in this approach were as follows:
1. Thermoplastics Only (SIC 28213)
2. Thermosets (SIC 28214 plus Organics)
3. Rayon (Viscose)
4. Other Fibers (SIC 2824 and 2823 plus Organics)
5. Thermoplastics and Organics (SIC 28213 and 2865 or 2869)
6. Commodity Organics
7. Bulk Organics
8.• Specialty Organics.
These eight subcategories were defined as follows:
• Subcategories 1 and 3 were defined as facilities that produced at
least 95 percent thermoplastics and rayon, respectively.
• Subcategories 2 and 4 were for facilities whose production was at
least 95 percent of the subcategory heading or facilities whose combi-
nation of organic chemicals and the subcategory heading represented at
least 95 percent of the plant production.
IV-3
-------
• Subcategory 5 represented plants with a production that vas at least
95 percent thermoplastic and organic products with neither product
group representing 95 percent production. This group was interpreted
to be vertically integrated plants producing organics, which were then
used primarily for the production of thermoplastics.
• Subcategories 6 through 8 identified the relatively pure organics
plants that had a production that was at least 95 percent organics.
Organics production was further subdivided according to volume.
/
- Commodity: Those chemicals produced nationally in amounts greater
than or equal to 1 billion pounds per year.
- Bulk: Those chemicals produced nationally in amounts less than 1
billion but more than 40 million pounds per year.
Specialty: Those chemicals produced nationally in amounts less
than or equal to 40 million pounds per year.
Plants were assigned to these categories based on their mix of produc-
tion; plants having at least 75 percent commodity or specialty were assigned
to these respective subcategories. Remaining plants were assigned to the bulk
subcategory. Thus, a plant might be assigned to the bulk subcategory, but it
could also manufacture both commodity and specialty chemicals.
The July 17, 1985, Federal Register NOA also announced the Agency's in-
tentions to establish a single set of BAT effluent limitations that would be
applicable to all OCPSF facilities rather than the two subcategory approach
presented in the March 21, 1983, proposal. The rationale for this "one BAT
subcategory" approach was that the available data for BAT show that plants in
differing BPT subcategories can achieve similar low toxic pollutant effluent
concentrations by installing the best available treatment components. The
Agency also again announced its intention to establish a separate BAT subcate-
gory with different zinc limitations for those plants manufacturing rayon and
utilizing the viscose process.
While the subcategories developed for the July 17, 1985, Federal Register
NOA were more useful than those established for the March 21, 1983, proposal,
the revised subcategorization approach was still criticized by OCPSF trade
associations and companies for the reasons summarized below.
IV-4
-------
a. Multiple Subcategory Plants
A significant number of the plants cannot be classified according to the
July 17, 1985, Federal Register NOA subcategorization approach for the follow-
ing reasons:
• No single subcategory accounts for the majority of the production at a
number of plants.
1
• No allowance was made in the thermoplastics and organics subcategory
for variations in the types of organic products produced. From analy-
sis of the data, plants with high specialty volume can be expected to
have higher BOD effluent concentrations when compared to plants with
high commodity production.
• Plants could change their subcategory classifications by making small
changes in the proportion of products produced.
b. Low Flow/High Flow Plants
In the March 21, 1983, Proposal, the Agency incorporated a low flow/high
flow cutoff in one of its proposed subcategories, because flow was found to be
a statistically significant subcategorization factor. This adjustment was not
made in the July 17, 1985, Federal Register NOA because flow was not found to
be a statistically significant factor for the revised subcategorization
approach. However, the Agency received numerous public comments requesting
that consideration be given to plants that conserve water and are low water
users.
All the above considerations led the Agency to modify the July 17, 1985,
subcategorization approach to accommodate these issues while trying to pre-
serve a workable subcategorization and guideline structure.
3. December 8, 1986, Federal Register
The Agency again revised its subcategorization methodology and presented
it in the December 8, 1986, Federal Register NOA. Initially, a regulatory
approach that would have created plant specific long-term averages based on a
flow proportioning of individual product subcategory long-term averages was
attempted. This would have eliminated a number of difficulties associated
with multiple subcategory plants and was consistent with current permit writ-
ing "building block" practices.
IV-5
-------
Production/flow information had been requested from industry in the 1983
308 Questionnaire Survey in anticipation of implementing such an approach.
Unfortunately, much of the production/flow information (when supplied) was
either estimated or grouped with other product/process flows and was con-
sidered too inaccurate or nebulous for subcategorization purposes. However,
since relatively accurate production volume information by product/process or
product groups was available, a regulatory approach that proportions the vari
ous subcategory long-term averages for each plant based on the reported pro-
portion of production by product group was developed. This revised subcate-
gorization approach incorporated essentially the same product-based subcate-
gories as presented in the July 17, 1985, Federal Register NOA:
1. Thermoplastics (SIC 28213)
2. Thermosets (SIC 28214)
3. Rayon (Viscose Process)
4. Other Fibers (SIC 2823 and 2824)
5. Commodity Organics (SIC 2865 and 2869)
6. Bulk Organics (SIC 2865 and 2869)
7. Specialty Organics (SIC 2865 and 2869).
While the prior subcategorization approaches incorporated subcategories that
included both a major production group and other secondary production, these
seven subcategories represented only single production groups, while plants
that have production that falls into more than one production group. were
handled by a regression model that emulates the production proportioning used
by permit writers. This regression model was as follows:
7
ln(BODi) = a + I vi.-1 . + B- [ln(flowi ) ] + D-I5i + ei
13 3
where ln(BOD.), w. ., ln(flow.), and 15. are plant-specific data
available in the data base (for plant i), and the parameters a, T.,
and D are values, estimated from the data base using standard
statistical regression methods. Definitions of the terms in this
regression equation (and also used in subsequent equations) are as
follows:
ln(BODi) = natural logarithm (In) of the 1980 annual arithmetic average
BOD effluent in mg/1, which has been adjusted for dilution
with uncontaminated miscellaneous wastewaters (as described
in Section VII), for plant i.
IV-6
-------
ln(flow.) = ln(total flow (MGD)), corrected for non-process waste
streams) for plant i, with associated coefficient B.
15. = indicator variable for plant i
=1, if plant i meets 95 percent BOD5 removal or at most 50
mg/1 BOD5 effluent editing criteria (95/50), for plants with
biological treatment and polishing ponds,
= 0, otherwise
w.. = proportion of OCPSF 1980 production from plant i from sub-
category j
e. = statistical error term associated with plant i
The seven subcategories, represented by the subscript j, are as follows:
j=l: Thermoplastics
j=2: Thermosets
j=3: Rayon
j=4: Other Fibers
j=5: Commodity Organics
j=6: Bulk Organics
j=7: Specialty Organics.
The coefficients T. and D are related to the intercept of this equation
(denoted by "a"). The T. coefficients are subcategorical deviations from the
7
overall intercept "a." The restriction Z T.=0 is placed on the regression
3=1 '
equation, as discussed in Appendix IV-A, to allow for estimation of these
values by standard multiple regression methods. The coefficient D represents
the difference between the intercept of this equation (based on all full-
response, direct discharge OCPSF plants that have at least biological treat-
ment in place and have provided BOD5 effluent, subcategorical production, and
flow data) and the intercept based on the subset of these plants that have
biological treatment and polishing ponds and meet the 95/50 editing criteria
used by EPA at the time of the 1986 NOA.
IV-7
-------
In addition to its production proportioning approach, the Agency also
included a flow adjustment factor in its regression model in an attempt to
respond to public comments criticizing its elimination in the July 17, 1985,
subcategorization approach. When included in the regression model and tested
statistically, the flow adjustment coefficient, B, was found to be statistic-
ally significant in explaining plant-to-plant variation of reported average
BOD5 effluent.
A regression model relating effluent TSS to effluent BOD was also devel-
oped to calculate estimated TSS effluent long-term averages for individual
plants, as follows:
ln(TSS.) = a + b-[ln(BOD., ) ] + ei
where:
InCTSS^ = ln(1980 annual arithmetic average TSS effluent in mg/1,
which has been adjusted for dilution with uncontaminated
miscellaneous wastewaters, as described in Section VII),
for plant i
e. = statistical error term associated with plant i.
The data base used to determine these long-term averages included all
full-response, direct discharge OCPSF plants with biological treatment and
polishing ponds that met the 95/50 editing criteria for BOD5 described pre-
viously and that had TSS effluent concentrations of at most 100 mg/1. The
variables ln(BODi) [defined previously] and ln(TSS.) are plant-specific data
available in this data base, and the intercept and slope parameters a and b,
respectively, are values estimated from the data base using standard statis-
tical regression methods.
The December 8, 1986, Federal Register NOA retained the "one BAT subcate-
gory" approach along with the separate subcategory and different zinc limita-
tions for rayon manufacturers utilizing the viscose process.
While the revised subcategorization approach was yet another improvement
on previous subcategorizations, a number of major issues were raised during
the public comment period for the December 8, 1986, Federal Register NOA,
which are detailed below.
IV-8
-------
a. Flow Adjustment Factor
Many comments were received which stated that the flow adjustment factor
was not the equitable flow correction that the Agency intended, since it util-
ized total wastewater flow in its adjustment that would penalize high-
production facilities with high flows and plants with certain product/
processes that typically utilize and discharge large volumes of wastewater
(e.g., rayon and fibers plants). Commenters suggested that the flow adjust-
ment factor be changed to account for production volume at each facility;
i.e., use a gallon of wastewater/pound production adjustment factor.
A related issue raised by commenters also concerned the flow adjustment
factor: a flow adjustment coefficient based on the use of all OCPSF plants
with biological treatment, regardless of effluent BOD5 , causes a small group
of plants exhibiting high effluent BOD5 and low wastewater flow to dispropor-
tionately influence the estimated long-term averages for other plants, based
on the regression model. The commenters stated that if approximately 16
plants with effluent BOD values greater than 200 mg/1 were removed from the
regression, the flow adjustment coefficient, B, was no longer significant.
b. Total Production
Commenters stated that a total production factor should be included in
the regression model even though production was evaluated in the December 8,
1986, subcategorization approach and was found not to be significant.
C. FINAL ADOPTED BPT AND BAT SUBCATEGORIZATION METHODOLOGY AND RATIONALE
Based on an assessment of the comments on the subcategorization method-
ology presented in the December 8, 1986, Federal Register NOA, the Agency
revised its regression model and the methodology for using the model to estab-
lish effluent BOD5 long-term averages. The final revised regression model is
as follows:
= a + I wi . -T. + B-I4i + C-Ibi + ei
1D :
IV-9
-------
where:
I4i = performance indicator variable for plant i
1, if plant i meets the 95 percent BOD5 removal or at most
40 mg/1 BOD5 effluent editing criteria (the final BOD,, perform-
ance editing criteria)
0, otherwise
Ibi = treatment indicator variable for plant i
1, if plant i has only biological treatment
0, if plant i has treatment in addition to biological treatment
e, = statistical error term associated with plant i.
The other terms have been defined previously.
The values for a, T., B and C are regression coefficients that are esti-
mated from the 157 full-response, direct discharge OCPSF plants that have at
least biological treatment in place and provided BOD effluent and subcategor-
ical production data.
Procedures used to estimate the model coefficients and the estimates are
presented in Appendix IV-A, Exhibit 1. The data base employed to obtain the
estimates is presented in Appendix IV-A, Exhibit 8.
This regression model differs from the model presented in the December 8,
1986, Federal Register NOA in several major respects:
• BPT Treatment System: The revised regression model is designed to
estimate BOD effluent long-term averages for biological treatment
only (the selected BPT regulatory option) rather than for biological
treatment and polishing ponds (see Section IX for rationale of options
selection).
• BOD Performance Edit: The indicator variable I5A in the December 8,
1986 subcategorization specified at least 95 percent BOD5 removal or
at most 50 mg/1 BOD5 in the treated wastewater (95/50), while the
revised regression model has indicator variable Ui , which specifies
95/40 (see Section VII for discussion on change of performance editing
rules).
IV-10
-------
• Performance and Treatment System Shifts: The regression model pre-
sented in the December 8, 1986 Federal Register NOA included a single
parameter to account for differences in the logarithm of BOD due to
treatment systems other than biological treatment and polishing ponds
and less than adequate performance (defined as 95/50). The revised
regression model includes separate parameters to account for differ-
ences: one parameter to distinguish between BPT treatment systems
(now biological only) and other treatment systems; and another para-
meter to account for performance (now defined as 95/40). Discussion
of these changes in parameters is included in this section.
• Adjustment for OCPSF flow: The model published in the December 8,
1986, subcategorization included an OCPSF flow adjustment, but the
current model includes no such adjustment for flow. Discussion of
this change is included in this section.
• Individual Plant Versus Subcategory Long-Term Averages: While the
subcategorization methodology published in the December 8, 1986, NOA
yielded individual plant-specific long-term averages, the revised
subcategorization methodology yields pure subcategory BOD and TSS
effluent long-term averages that will be applied by the NPDES permit
writers.
The procedures used to calculate the pure subcategory long-term averages are
presented in Appendix IV-A. (See Section VII for discussion of rationale for
choosing between pure subcategory and individual plant-specific long-term
averages.)
The Agency retained the same methodology presented in the December 8,
1986, Federal Register NOA for calculating TSS effluent long-term averages. A
discussion of the relationship of TSS to BOD5 effluent concentrations is pre-
sented in Section VII, along with a discussion of the final TSS performance
criterion. The regression model for estimating TSS effluent long-term
averages is as follows:
ln(TSS.) = a + b-[ln(BODi)] + ei
The coefficients a and b are estimated from the 61 OCPSF plants that have
only biological treatment in place, meet the 95/40 editing criteria for BODg
described previously, and have TSS effluent concentrations of at most
100 mg/1.
IV-11
-------
Estimates of the TSS-model coefficients are given in Appendix IV-A,
Exhibit 2. The data base employed to generate the estimates is presented in
Appendix IV-A, Exhibit 8.
The following sections discuss the rationale behind some of the changes
made to the subcategorization methodology.
1. Performance and Treatment System Shifts
One change in the form of the BOD long-term average model is a revision
of the indicator functions. The regression model published in the December 8,
1986, Federal Register NOA had a single shift indicator. This indicator was
the sole explanatory variable to account for adjusted differences in average
treatment performance between biological plants having polishing ponds and
satisfying the proposed 95/50 performance criterion and all other plants.
If this kind of single indicator function was applied to the revised BPT
treatment and performance standards of biological only and 95/40, then this
single shift indicator would account for adjusted differences between biologi-
cal only, 95/40 plants and all other plants. The set of all other facilities
can be divided into three distinct subsets: plants with treatment other than
biological only which satisfy the performance criterion; plants with treatment
other than biological only which do not satisfy the performance criterion; and
plants with only biological treatment which do not satisfy the performance
criterion. Clearly, plants with more than biological treatment are expected
to perform at least as well as biological-only facilities, and biological-only
plants that fail to satisfy the 95/40 edit will perform below the BPT "average
of the best" performance. A single shift indicator alone, similar to that
included in the regression model published in the December 8, 1986, NOA,
cannot separately account for the adjusted differences due to treatment and
performance between the biological-only, 95/40 plants and all other plants.
In an effort to reformulate the revised BOD5 long-term average model to better
reflect the separate effects of the treatment and performance characteristics
of the data base, EPA redefined the single indicator shift in the form of two
indicator variables for the model: one indicator accounts for adjusted dif-
ferences between biological only treatment and treatment other than biological
IV-12
-------
only, and the other indicator accounts for adjusted differences between plants
meeting the 95/40 performance criteria and those that do not.
2. Flow and Total Production Adjustment Factors
The regression model published in the December 8, 1986, Federal Register
NOA contained a flow adjustment term in the form of the natural logarithm of
the plant OCPSF flow in MGD. EPA included this term in an effort to account
for plants that practice water conservation. The regression coefficient for
that term was negative, which resulted in a decreasing BOD5 long-term average
concentration for increasing flow. Although this result is reasonable and may
account for water conservation, it could impose unreasonably low limitations
on plants with a high proportion of fibers production that already achieve low
effluent BOD5 levels (i.e., 12 mg/1). Industry commenters claimed that flow
rate alone cannot distinguish between plants that practice water conservation
and those plants that use excessive amounts of water. Certain product/pro-
cesses (e.g., rayon manufacture) must use large amounts of water in relation
to other plants and are then unjustly penalized with lower limits. Further-
more, commenters stated the inclusion of the flow adjustment term does not
reflect total production, which should be incorporated into the subcategorical
regression model. According to the commenters, increased production should
result in larger flows and higher BOD concentrations, which is contrary to
the results obtained from the regression model EPA published in the December
8, 1986, NOA. An examination of these issues is summarized below.
EPA reexamined the inclusion of the flow adjustment factor. Based on
that examination, EPA agrees that flow rate alone does not indicate whether a
plant practices water conservation. Moreover, the 1986 published model, in
EPA's assessment, did result in excessively low BOD5 long-term average con-
centrations for some plants with large flows.
Commenters further argued that the statistical significance of the flow
adjustment factor for the regression model presented in the December 8, 1986,
NOA was due entirely to a small number of plants with small flows and large
BOD5 effluents. EPA's examination of the data base revealed that facilities
IV-13
-------
with relatively high BOD and low flows are mostly facilities that have bio-
logical treatment but failed the 95/40 performance criteria. To formalize
this analysis, EPA considered models in the context of the data base used for
determining BOD5 effluent long-term averages to explore the effects of these
plants on flow adjustments. In particular, the model
7
InCBOD^ = a + Z w^-T.. + F-[ln(flowi) J + e._
was examined separately for the following four subsets of the data base:
(1) Biological only and 95/40
(2) Biological only and not 95/40
(3) Not biological only and 95/40
(4) Not biological only and not 95/40
These four mutually exclusive subsets partition completely the 153 full-
response, direct discharger OCPSF plants that have at least biological treat-
ment in place and provided BOD5 effluent, flow, and subcategorical production
data. The computer analysis for these regression models and plots of ln(BOD5
effluent) versus In(flow) are presented in Appendix IV-A, Exhibit 3. Note
that the set of plants in (1) above has information regarding all subcate-
gories. Rayon plants are not present in the set of plants in subsets (2),
(3), and (4), however, and the term corresponding to rayon has been excluded
from the model for these sets of plants. Also, fibers plants are not present
in the set of plants in subset (4), and the term corresponding to fibers has
also been excluded from the model when examining the set of plants in (4).
These models were examined for the significance of the coefficient F, corres-
ponding to the natural logarithm of flow.
Based on this analysis, the Agency agrees with the commenters that the
significance of the flow adjustment term in the December model is largely
influenced by the poorly performing plants (plants that do not meet the 95/40
BPT performance edit) with only biological treatment. Because this pattern is
exhibited only by a subset of plants that are not well-designed and operated,
IV-14
-------
the Agency concludes that this pattern should not be reflected in the esti-
mation of long-term BOD5 averages as a construct of the model. Therefore, EPA
has deleted the flow adjustment factor from the model.
EPA has also examined the inclusion of a production adjustment factor
using the following model:
7
ln(BOD.) = a + I W...-T.. + G-lln(prodi)] + e.
J =-*-
where:
ln(prod..) = In (OCPSF 1980 total production) from plant i, in
millions of pounds per year, with associated
coefficient G.
As described in the analysis of flow, this model was examined separately
for the four subsets of the 157 full-response, direct discharge OCPSF plants
that have at least biological treatment in place and provided BOD5 effluent
and subcategorical production data. The computer analysis for these regres-
sion models and plots of In(BOD) are presented in Appendix IV-A, Exhibit 4.
These models were examined for the coefficient of G, corresponding to the
natural logarithm of production. The same pattern emerges with this factor as
was present when the natural logarithm of flow was examined; namely, the sig-
nificance of this term is largely due to the poorly performing plants with
biological only treatment (plants that do not meet the 95/40 BPT performance
edit). Consequently, EPA has decided not to add a production adjustment
factor to the model.
Commenters have asserted that increased production should result in
higher BOD effluent concentrations. As seen by the regressions involving
total production, the data do not support a positive association between BOD5
effluent concentration and total production (higher BOD effluent concentra-
tions associated with higher production levels), after adjustment for propor-
tion of production in a subcategory.
IV-15
-------
EPA has also considered the effect of flow per unit of production, using
the following model, applied separately to the 4 subsets of 153 full-response,
direct discharge OCPSF plants that have at least biological treatment in place
and provided BOD5 effluent, flow, and subcategorical production data (4 of the
157 full-response plants did not report flow):
7
ln(BOD.) = a + E W...-T.. + H-[ln(365*flowi/prod.) ] + eA
where:
flow./prod. = annual total flow (MGD), corrected for non-process
waste streams, for plant i, divided by OCPSF 1980
production (in millions of pounds per year), for
plant i.
The units for ln(365*flowi/prod.) are gallons/pound—the significance of
the coefficient H, associated with this quantity, was examined. Results simi-
lar to those found for flow and production were observed, in the sense that
this flow per unit production variable is only marginally significant for
plants with biological only treatment that do not meet the 95/40 BPT perform-
ance edit (see Appendix IV-A, Exhibit 5). The Agency concluded that a flow
per unit production adjustment factor was not appropriate for the same reasons
described for flow and production; that is, the model should not reflect a
pattern exhibited only by a subset of plants that are not well-designed and
operated.
D. FINAL ADOPTED BAT SUBCATEGORIZATION APPROACH
Based on comments received during public comment periods for the proposal
and the NOAs, the Agency noted that a certain subset of OCPSF plants existed
that either generate such low raw waste BOD5 levels that they do not require
end-of-pipe biological treatment or choose to use physical/chemical treatment
alone to comply with BPT effluent limitations. The Agency has decided to
establish two BAT subcategories that are largely determined by raw waste BOD5
characteristics, as follows:
• Subcategory One - all plants that have or will install biological
treatment to comply with BAT effluent limitations.
IV-16
-------
• Subcategory Two - all plants which, based on raw waste characteris-
tics, will not utilize biological treatment to comply with BPT
effluent limitations.
In addition, the Agency is also establishing a different BAT effluent
limitation for zinc, including manufacturers of rayon by the viscose process
and plants manufacturing acrylic fibers utilizing the zinc chloride/solvent
process.
BAT effluent limitations for Subcategory One will be based on the per-
formance of biological treatment and in-plant controls. Biological treatment
is an integral part of this subcategory's model BAT treatment technology; it
achieves incremental removals of some toxic pollutants beyond the removals
achieved by in-plant treatment without end-of-pipe biological treatment. BAT
effluent limitations for Subcategory Two will be based on the performance of
only in-plant treatment technologies such as steam stripping, activated
carbon, chemical precipitation, cyanide destruction, and in-plant biological
treatment of selected waste streams. The Agency has concluded that, within
each subcategory, all plants can treat priority pollutants to the levels
established. (The Agency determined that further BPT subcategorization for
plants without end-of-pipe biological treatment is unnecessary. As described
in the Section VII assessment of nonbiological end-of-pipe treatment systems,
the Agency concluded that plants that do not need biological treatment to
comply with the BPT BODg limitations can meet the TSS limitations with physi-
cal/chemical controls alone. As also shown, some plants achieve sufficient
control of BOD5 through the use of only physical/chemical treatment unit
operations.)
The Agency also received comments (supported by submitted data) during
public comment periods stating that plants manufacturing acrylic fibers by the
zinc chloride/solvent process produced raw waste and treated effuent levels of
zinc similar to those levels produced by rayon manufacturers utilizing the
viscose process. After examining these data, the Agency agreed with the
commenters that it was appropriate to include these plants along with rayon
manufacturers. Based on this decision, the Agency is establishing two dif-
ferent limitations for the pollutant zinc. One is based on data collected
IV-17
-------
from rayon manufacturers and acrylic fibers manufacturers using the zinc
chloride/solvent process. This limitation applies only to those plants that
use the viscose process to manufacture rayon and the zinc chloride/solvent
process to manufacture acrylic fibers. The other zinc limitation is based on
the performance of chemical precipitation technology used in the metal fin-
ishing point source category, and applies to all plants other than described
above.
E. SUBCATEGORIZATION FACTORS
1. Introduction
All nine factors listed in the beginning of this section were examined
for technical significance in the development of the proposed subcategoriza-
tion scheme. However, in general, the proposed subcategorization reflected
primarily differences in waste characteristics, since many of the other eight
factors, while considered, could not be examined in appropriate technical and
statistical depth due to the intricacies of the plants in this industry.
Therefore, variations in waste characteristics were utilized to evaluate the
impact of the other eight factors on subcategorization. For example, the
ideal data base for evaluating the need for subcategorization and the develop-
ment of individual subcategories would include raw wastewater and final efflu-
ent pollutant data for facilities which segregate and treat each process raw
waste stream separately. In this manner, each factor could be evaluated
independently. However, the available information consists of historical data
collected by individual companies, primarily for the purpose of monitoring the
performance of end-of-pipe wastewater treatment technology and compliance with
NPDES permit limitations. The OCPSF industry is primarily composed of multi-
product/process, integrated facilities. Vastewaters generated from each
product/process are typically collected in combined plant sewer systems and
treated in one main treatment facility.
Therefore, each plant's overall raw wastewater characteristics are
affected by all of the production processes occurring at the site at one time.
The effects of each production operation on the raw wastewater characteristics
cannot be isolated accurately from all of the other site-specific factors.
Therefore, a combination of both technical and statistical methodologies had
IV-18
-------
to be used to evaluate the significance of each of the subcategorization fac-
tors. The methodologies and analyses necessarily are limited to indicating
trends rather than yielding definitive quantitative significance of the fac-
tors considered.
In the methodology that was employed, the results of the technical analy-
sis were compared to the results of the statistical efforts to determine the
usefulness of each factor as a basis for subcategorization. The combined
technical/statistical evaluations of the nine factors are presented below.
2. Manufacturing Product/Processes
Comments have been received that state that the choice of the final seven
subcategories based on production is arbitrary, since the Agency did not per-
form a statistical analysis to group plants in optimal subcategories. Product
groups are based on both the marketing structure of the industry and technical
factors affecting the generation of contaminants.
By choosing subcategories based on SIC codes, the marketing character-
istics by which the industry is organized are emphasized; facilities can be
easily classified since the SIC codes are readily available to the plant.
Furthermore, from a technical point of view, based on engineering judgment and
analysis of the data supplied by the industry, most of these subcategories
represent different waste streams.
The purpose of subcategorization is the division of the OCPSF industry
into smaller groups that account for the particular common characteristics of
different facilities. The OCPSF industry (as defined by EPA) is recognized to
comprise several product groups:
• Organic Chemicals (SIC 2865/2869)
• Plastic Materials and Synthetic Resins (SIC 2821)
• Cellulosic Manmade Fibers (SIC 2823)
• Synthetic Organic Fibers (SIC 2824).
IV-19
-------
Vertical integration of plants within these industries is common, however,
blurring distinctions between organic chemical plants and plastics/synthetic
fibers plants. As a practical matter, the OCPSF industry is divided among
three types of plants:
• Plants manufacturing only organic chemicals (SIC 2865/2869)
• Plants manufacturing only plastics and synthetic materials (SIC 2821/
2823/2824)
• Integrated plants manufacturing both organic chemicals and plastics/
synthetic materials (SIC 2865/2869/2821/2823/2824).
Each type of plant is unique not only in terms of product type (e.g., plas-
tics) but also in terms of process chemistry and engineering. Using raw
materials provided by organic chemical plants, plastic plants employ only a
small subset of the chemistry practiced by the OCPSF industry to produce a
limited number of products (approximately 200). Additionally, product re-
covery from process wastewaters in plastic plants generally is possible, thus
lowering raw waste BOD5 concentrations. Plants producing organic chemicals,
on the other hand, utilize a much larger set of process chemistry and engi-
neering to produce approximately 25,000 products; process wastewaters from
these plants are in general not as amenable to product recovery and are gen-
erally higher in raw waste BOD5 concentration and priority pollutant loadings.
Further divisions are possible within these broad groupings. Plastic
materials and synthetic resins manufacturers can be subdivided into thermo-
plastic materials (SIC 28213) producers and thermosetting resin (SIC 28214)
producers. Rayon manufacturers and synthetic organic fiber manufacturers are
also both unique. Again, process chemistry and engineering are broadly con-
sistent within these groupings in terms of BOD5.
The organic chemicals industry produces many more products that does the
plastics/synthetic fibers industry and is correspondingly more complex. While
it is indeed possible to separate this industry into product groups, the num-
ber of such product groups is large. Moreover, with few exceptions, plants
produce organic chemicals from several product groups and thus limit the
utility of such an approach.
IV-20
-------
An alternative to a product-based approach is an approach based on the
type of manufacturing conducted at a plant. Large plants producing primarily
commodity chemicals (the basic chemicals of the industry, e.g., ethylene,
propylene, benzene) comprise the first group of plants. A second tier of
plants includes plants that produce high-volume intermediates (bulk chemi-
cals). Plants within this tier typically utilize the products of the com-
modity chemical plants (first tier plants) to produce more structurally com-
plex chemicals. Bulk chemical plants are generally smaller than those in the
first group, but still may produce several hundred million pounds of chemicals
per year (e.g., aniline, methylene dianiline, toluene diisocyanate). The
third group includes those plants that are devoted primarily to manufacture of
specialty chemicals — chemicals intended for a particular end use (e.g., dyes
and pigments). Generally, specialty chemicals are more complex structurally
than either commodity or bulk chemicals.
Chemicals within the three groups — commodity, bulk, and specialty —
are defined on the basis of national production. Commodity chemicals are
those chemicals produced nationally in amounts greater than or equal to 1
billion pounds per year. Bulk chemicals are defined to be those chemicals
produced nationally in amounts less than 1 billion but more than 40 million
pounds per year. Specialty chemicals are those chemicals produced nationally
in amounts less than or equal to 40 million pounds per year. Using these
definitions, there are 35 commodity chemicals, 229 bulk chemicals or bulk
chemical groups, and more than 786 specialty chemicals or specialty chemical
groups.
In general, the rate of biodegradation decreases with increasing molecu-
lar complexity. Because commodity chemical plants produce the least complex
chemicals, a general trend of lower BOD5 effluent concentrations for commodity
chemical plants to higher BOD5 effluent concentrations for specialty chemical
plants is observed.
With regard to subcategorization for BAT, the Agency considered whether
the industry should be subcategorized by evaluating the same subcategorization
approach developed for BPT, which is based primarily on manufacturing product/
processes. The available data for BAT show that plants in differing BPT sub-
categories can achieve similar low toxic pollutant effluent concentrations by
IV-21
-------
installing the best available treatment components. Since all plants within
the two BAT technology-based subcategories can achieve compliance with the
same BAT effluent limitations through some combination of demonstrated tech-
nology, the predominant issue relates to the cost of the required treatment
technology. EPA has analyzed these costs and their associated impacts and has
determined them to be reasonable. Therefore, the Agency believes that BAT
subcategorization based on manufacturing product/processes is not necessary
for effective, equitable regulation.
3. Raw Materials
Synthetic organic chemicals can be defined as derivative products of
naturally occurring materials (e.g., petroleum, natural gas, and coal) that
have undergone at least one chemical reaction, such as oxidation, hydrogena-
tion, halogenation, or alkylation. This definition, when applied to the
larger number of potential starting materials and the host of chemical reac-
tions that can be applied, leads to the possibility of many thousands of
organic chemical compounds being produced by a potentially large number of
basic processes having many variations. There are more than 25,000 commercial
organic chemical products derived principally from petrochemical sources.
These are produced from five major raw material classifications: methane,
ethylene, propylene, C4 hydrocarbons and higher aliphatics, and aromatics.
This major raw materials list can be expanded by further defining the aro-
matics to include benzene, toluene, and xylene. These raw materials are
derived from natural gas and petroleum, although a small portion of the
aromatics are derived from coal.
Currently, approximately 90 percent (by weight) of the organic chemicals
used in the world are derived from petroleum or natural gas. Other sources of
raw materials are coal and some naturally occurring renewable material of
which fats, oils, and carbohydrates are the most important.
Regardless of the relatively limited number of basic raw materials util-
ized by the organic chemicals industry, process technologies lead to the for-
mation of a wide variety of products and intermediates, many of which can be
produced from more than one basic raw material either as a primary reaction
IV-22
-------
product or as a byproduct. Furthermore, primary reaction products are fre-
quently processed to other chemicals that categorize the primary product from
one process as the raw material for a subsequent process.
Delineation between raw materials and products is nebulous at best, since
the product from one manufacturer can be the raw material for another manufac-
turer. This lack of distinction is more pronounced as the process approaches
the ultimate end product, which is normally the fabrication or consumer stage.
Also, many products/intermediates can be made from more than one raw material.
Frequently, there are alternate processes by which a product can be made from
the same basic raw material.
Another characteristic of the OCPSF industry that makes subcategorization
by raw material difficult is the high degree of integration in manufacturing
units. Since the majority of basic raw materials derive from petroleum and
natural gas, many of the organic chemical manufacturing plants are either
incorporated into or contiguous to petroleum refineries, and may formulate a
product at almost any point in a process from any or all of the basic raw
materials. Normally, relatively few organic chemical manufacturing facilities
are single product/process plants unless the final product is near the fabri-
cation or consumer product stage.
Because of the integrated complexity of the largest (by weight) single
segment of the organics industry (petrochemicals), it may be concluded that
BPT and BAT subcategorization by raw materials is not feasible for the fol-
lowing reasons:
• The organic chemicals industry is made up primarily of chemical
complexes of various sizes and complexity.
• Very little, if any, of the total production is represented by single
raw material plants.
• The raw materials used by a plant can be varied widely over short time
spans.
• The toxic, conventional, and nonconventional wastewater pollutant
parameter data gathered for this study were not collected and are not
available on a raw material orientation basis, but rather represent
the mixed end-of-pipe plant wastewaters.
IV-23
-------
4. Facility Size
Although sales volume, number of employees, area of a plant site, plant
capacity, and production rate might logically be considered to define facility
size, none of these factors alone describes facility size in a satisfactory
manner. Recognizing these limitations, the Agency has chosen total OCPSF
production to define facility size.
The regression model approach allows the Agency to easily test for BPT
subcategorization factors such as facility size as measured by total OCPSF
production. EPA has analyzed total OCPSF production, as discussed previously
in this section, to determine its appropriateness as a subcategorization fac-
tor, and determined that the significance of production is due largely to
plants with only biological treatment that do not meet the 95/40 BPT perform-
ance edit. Consequently, an adjustment factor for production is not incorpo-
rated into the model.
In terms of a BAT subcategorization factor, although facility sizes (as
measured by total OCPSF production) of the waste streams with the OCPSF indus-
try vary widely, ranging from less than 10,000 pounds/day to more than
5 million pounds/day, this definition fails to embody fundamental character-
istics such as continuous or batch manufacturing processes. While equivalent
production rates may be accomplished by either production method, the charac-
teristics of these waste streams in terms of toxic pollutants may vary sub-
stantially because of different yield losses inherent in each process. There-
fore, the Agency has determined that no adequate method exists for defining
facility size and that there is no technical basis for the use of facility
size as a BAT subcategorization factor.
5. Geographical Location
Companies in the OCPSF industry usually locate their plants based on a
number of factors. These include:
• Sources of raw materials
• Proximity of markets for products
• Availability of an adequate water supply
IV-24
-------
• Cheap sources of energy
• Proximity to proper modes of transportation
• Reasonably priced labor markets
In addition, a particular product/process may be located in an existing facil-
ity based on availability of certain types of equipment or land for expansion.
Companies also locate their facilities based on the type of production
involved. For example, specialty producers may be located closer to their
major markets, whereas bulk producers may be centrally located to service a
wide variety of markets. Also, a company that has committed itself to zero
discharge as its method of wastewater disposal has the ability to locate any-
where, while direct dischargers must locate near receiving waters, and in-
direct dischargers must locate in a city or town that has an adequate POTW
capacity to treat OCPSF wastewaters.
Because of the complexity and inter-relationships of the factors affect-
ing plant locations outlined above, no clear basis for either BPT or BAT sub-
categorization according to plant location could be found. Therefore, loca-
tion is not a basis for BPT and BAT subcategorization of the OCPSF industry.
Since biological treatment installed to meet BPT effluent limitations is
an important part of both BPT and BAT subcategorization approaches, the Agency
decided to perform an analysis to confirm that temperature (as defined by the
heating-degree day variable to measure winter/summer effects), instead of
location, is not a subcategorization factor. The Agency used a regression
model approach similiar to the analysis for facility size. Analysis on the
following regression model was performed to test for the significance of this
factor:
ln(BODi) = a + E w^.'T. + J-(degree daysi) + e..
where:
degree days.^ = the number of degrees that the mean daily outdoor
temperature is below 65°F for a given day, accumu-
lated over the number of days in the year that the
IV-25
-------
mean temperature is below 65°F, at plant i (with
associated coefficient J).
This analysis was performed separately for the four subsets described
previously which partition the 157 full-response, direct discharge OCPSF
plants that have at least biological treatment in place and provided BODg
effluent and subcategorical production data. The computer analysis for these
regression models is presented in Appendix IV-A, Exhibit 6. In none of these
four subsets was temperature significant, and consequently a temperature
factor is determined to be inappropriate.
6. Age of Facility and Equipment
The age of an OCPSF plant is difficult to define accurately. This is
because production facilities are continually modified to meet production
goals and to accommodate new product lines. Therefore, actual process equip-
ment is generally modern (i.e., 0-15 years old). However, major building
structures and plant sewers are not generally upgraded unless the plant
expands significantly. Older plants may use open sewers and drainage ditches
to collect process wastewater. In addition, cooling waters, steam conden-
sates, wash waters, and tank drainage waters are sometimes collected in these
drains due to their convenience and lack of other collection alternatives.
These ditches may run inside the process buildings as well as between manu-
facturing centers. Therefore, older facilities are likely to exhibit higher
wastewater discharge flow rates than newer facilities. In addition, since the
higher flows may result from the inclusion of relatively clean noncontact
cooling waters and steam condensates as well as infiltration/inflow, raw
wastewater concentrations may be lower due to dilution effects. Furthermore,
recycle techniques and wastewater segregation efforts normally cannot be
accomplished with existing piping systems, and would require the installation
of new collection lines as well as the isolation of the existing collection
ditches. However, due to water conservation measures as well as ground con-
tamination control, many older plants are upgrading their collection systems.
In addition, the energy crisis of recent years has caused many plants to
upgrade their steam and cooling systems to make them more efficient. Based on
the factors mentioned above, the Agency has determined its only accurate age
IV-26
-------
measurement to be the age of the oldest process at each OCPSF facility.
Analysis on the following regression model was performed to test for the
significance of age:
= a + £ W....-T + K-Cage^) + ei
3=1
where:
aget = the age of the oldest process at plant i (with associated
coefficient K.) .
This analysis was performed separately for the four subsets described
previously that partition the 157 full-response, direct discharge OCPSF plants
that have at least biological treatment in place and provided BOD5 effluent
and subcategorical production data. The computer analysis for these regres-
sion models is presented in Appendix IV-A, Exhibit 7. Results of this
analysis are similar to results seen for production, flow, and flow per unit
of production; that is, the only group of plants that exhibit a relationship
between age and effluent BOD5 concentration is the subset of poorly performing
biological-only plants (plants that do not meet the 95/40 BPT editing cri-
teria). Consequently, the Agency has determined that an age factor is not
appropriate.
The extent to which process wastewaters are contaminated with toxic pol-
lutants depends mainly upon the degree of contact that process water has with
reactants/products, the effectiveness of the separation train, and the
physical-chemical properties of those priority pollutants formed in the reac-
tion. Raw wastewater quality is determined by the specific process design and
chemistry. For example, water formed during a reaction, used to quench a
reaction mixture, or used to wash reaction products will contain greater
amounts of pollutants than does water that does not come into direct contact
with reactants or products. The effectiveness of a separation train is deter-
mined by the process design and the physical-chemical properties of those
pollutants present. While improvements are continually made in the design and
construction of process equipment, the basic design of such equipment may be
IV-27
-------
quite old. Process equipment does, however, deteriorate during use and re-
quires maintenance to ensure optimal performance. When process losses can no
longer be effectively controlled by maintenance, process equipment is re-
placed. The maintenance schedule and useful life associated with each piece
of equipment are in part determined by equipment age and process conditions.
Equipment age, however, does not directly aEfect either pollutant concentra-
tions in influent or effluent wastewaters and is therefore inappropriate as a
basis for BAT subcategorization.
7. Uastewater Characteristics and Treatability
a. BPT Subcategorization
The treatability of OCPSF wastewaters is discussed in detail in Section
VII. The treatability of a given wastewater is affected by the presence of
inhibitory materials (toxics), availability of alternative disposal methods,
and pollutant concentrations in, and variability of, the raw wastewater con-
centrations. However, all of these factors can be controlled by sound waste
management, treatment technology design, and operating practices. Examples of
these are:
• The presence of toxic materials in the wastewater can be controlled by
in-plant treatment methods. Technologies such as steam stripping,
metals precipitation, activated carbon, and reverse osmosis can elimi-
nate the presence of materials in a plant's wastewater that may
inhibit or upset biological treatment systems.
• Although some plants utilize deep well injection for disposal of high-
ly toxic wastes to avoid treatment system upsets, other alternative
disposal techniques such as contract hauling and incineration are
available to facilities that cannot utilize deep well disposal. In
addition, stricter groundwater regulations may eliminate the option of
deep well disposal for some plants and make it uneconomical for
others, forcing facilities to look more closely at these other
options.
• Raw waste concentration variability can easily be controlled by the
use of equalization basins. In some plants, "at-process" storage and
equalization is used to meter specific process wastewaters, on a con-
trolled basis, into the plant's wastewater treatment system.
• Raw waste concentrations can be reduced with roughing biological
filters or with the use of two-stage biological treatment systems.
These techniques are discussed in detail in Section VII.
IV-28
-------
OCPSF wastewaters can be treated by either physical-chemical or biologi-
cal methods, depending on the pollutant to be removed. Also, depending on the
specific composition of the wastewater, any pollutant may be removed to a
greater or lesser degree by technology not designed for removal of this pol-
lutant. For example, a physical-chemical treatment system designed to remove
suspended solids will also remove a portion of the BOD of a wastewater if the
solids removed are organic and biodegradable. It is common in the OCPSF in-
dustry to use a combination of technologies adapted to the individual waste-
water stream to achieve desired results. These concepts are discussed in
detail in Section VII. In general, the percent removals of BOD5 and TSS are
consistent across the seven final subcategories. It is also possible for
plants in these subcategories to achieve high percent removals (greater than
95%) for both BOD5 and TSS (data supporting these removals are presented and
discussed in Section VII). Also, OCPSF plants producing the same products and
generating similiar raw waste BOD5 concentrations are, in general, equally
distributed above and below the pure subcategory long-term averages for BOD5
effluent as determined by the BPT regression equation. Figures IV-1 through
IV-7 present the distribution of plants within each pure subcategory (defined
as full-response direct discharge plants that have at least 80 percent of
their total OCPSF production in one of the seven final subcategories) by
effluent BOD5 and the product(s) each plant produces. Also included with each
plant's BOD5 effluent is its associated raw waste BOD5 concentration (when
available); in addition, if a plant produces more than one product within a
subcategory, its effluent and raw waste BOD values are repeated and noted on
each figure, as multiple effluent and influent, respectively.
In reviewing these figures, it should be noted that for most of the pro-
ducts within a pure subcategory, plants with fairly high raw waste BOD con-
centrations are equally distributed above and below the subcategory long-term
average BOD5 effluent and that even for plants producing the same products
that did not have raw waste BOD concentration data, BOD effluents are fairly
well-distributed above and below the subcategory median BOD effluent for
certain products within selected subcategories. Situations in which there are
a disproportionate number of plants either above or below the subcateogry
long-term average maybe explained by a number of factors, including the con-
tribution of remaining 20 percent of each plant's product mix to its BOD5
IV-29
-------
i
a
i*
i . , . . rn i^
D u
H Q §
n fc
•X <
* <
4- Q
+ r**i
— T • TU
<
+ ...-...,_, in
' CJ
ra-
D
n
~n "^
n
n
n
V _. _, __, r. _^, ,_ „ I ^
n
,J£
JudtujJJ_j£z
3>Eoooooo3
-n.(jxQ.Q.n.a.-2Ǥ
"• =-0 «
^It
v°-
IV-30
-------
Q
-1-
eg
U.
UJ
U
a
CD
in
m
cu
1/9H NI S008
dO OT 3SVQ 901
l-
UJ •
D U.
_1 U.
LL UJ
U_
UJ UJ
uj a.
_J M
13 t-
(f> Z
n <
a <
•3 u.
_J Z
UJ D.
_1 M
CD 1-
H 3
in 3:
+ •)«•
UJ
a.
•imoauju-coi
IV-31
-------
I
n
* <
* <
+ P
u
H
Z
U •
13 U.
_l U-
H. HI
H.
UJ UJ
_l
UJ Q.
1 | i
CD H
Z -J
W"^
—J
U) X.
a <
n <
in n <3
h-
o
D
§ z
n iii •
D U.
_J Z
ll 1— t
Z
M UJ
_J
HI 0.
CD 1-
Z -J
M D
cn s.
+ *
•f *
HI
< 0.
II
lit L_ *»
>.
^
0) IA
? Q
re O
< E m _
•l H_ -a c
„, o c o
£ w >
3 C ., flj
ro ° o tt
K]M~
~ 2
•M a!
OT
O
in
m
cu
1/9W NI 9008
JO
IV-32
-------
s
01
V _^^
n ^^^^ ~ — i..' ^^
v 1 ^1
vT^ ""• " — — --— •%
* 0
* <
* h
n
H 1 Q
* ,
n
n
ji si
^v~ ~—~ ^J
-1 H
# fl
H _^
in ^ tn c\j tn o
n/9w NI saoe
dO OT 3SVO 901
CD
ll I
UJ .
ID U.
_1 U.
U. UJ
UJ UJ
UJ I M
CD H
Z _I
H D
in z:
a
n <
n <
H
CJ "
^^ .
O * r
_J Z
U. M
M U]
_|
UJ Q.
_J M
CD CD H
M D
in "s.
+ *
+ *
^i "A
UJ
a.
i-
<
to
^ BQ \ U 11. (£ ID
tfl U- -1 ? E UI U.
UJ ^ & HI Q
I U U) O H M X
M IE tO Z UI
V U V 0 0 0 2
z < z a. a. a to
i i i i i i i
< m o a uj u. CD
w if
C Q
0)1 «
il 3 3
~ 2
a
IV-33
-------
in
1/9W NI 9008
dO Of 3SV9 901
0)
fow
« O^:
o c o
c a £
S *- c
5 o
IV-34
-------
— •' - - — Tj ""
1
D
+ B
D
n
<
n
*— 0
n
-
«-.
•x— — ,
Q t — M- S
OC if; m O c
n. ^^ £ c «
z M i? '^ 3
M LU 3 "O
Q UJ CL 'C 2
CD h- (0
5^ 5
01 X
+ *
u + *
LU
a.
m H
tn
o
u
10 3
S "> ^ ffl
in
cu
"1/9H NI SQ08
JO OT 3SVQ 901
W M 1-
-i O
UJ -I J
— - to Z Q r
zouiLnujuinx
OZOlSQZNacJ
-JUJUJOMI-IZUJI
zt5J<
-------
*
*
*~ « 3
n t-
n B{
Q C.
^T K
D
D
* <
j ti
T TCJ
D
H E3
<
a
H H
a
H B
a
a
j r-i
T— T— tu
H r~H
H ^--Q
•\ 1 B
D
a
in T d w -rt o
i/9w NI saoe eg
dO OT 3SVG 901 ||
1
1-
UJ •
3 U.
-I U.
U. UJ
* uu uj
_J
at a.
-i _l H
J IS (_
Z _J
M D
M O Z
D41
X D <
-------
effluent, the end-of-pipe treatment systems in place at each plant and the
in-plant controls currently in place at each plant that may cause raw waste
BOD5 concentrations to be reduced or that may remove toxic pollutants that
inhibit biological activity and cause higher BOD effluent concentrations. It
should also be noted in any event that for those plants substantially above
the subcategory long-term average BOD5 effluent value, as well as for other
plants, EPA's costing methodology and resulting cost estimates and economic
impact estimates have fully accounted for any required treatment improvement.
Based on the distribution of raw waste and effluent BOD5 concentrations,
the relative consistency of percent removal data across the final seven sub-
categories, and BOD5 effluent data within subcategories and product groups
within those subcategories, the Agency has concluded that the adopted BPT
subcategorization accounts sufficiently for wastewater characteristics and
treatability.
b. BAT Subcategorization
Typically, the treatability of a waste stream is described in terms of
its biodegradability, as biological treatment usually provides the most cost-
effective means of treating a high volume, high (organic) strength industrial
waste (i.e., minimum capital and operating costs). Furthermore, biodegrad-
ability serves as an important indicator of the toxic nature of the waste load
upon discharge to the environment. Aerobic (oxygen-rich) biological treatment
processes achieve accelerated versions of the same type of biodegradation that
would occur much more slowly in the receiving water. These treatment pro-
cesses accelerate biodegradation by aerating the wastewater to keep the dis-
solved oxygen concentration high and recycling microorganisms to maintain
extremely high concentrations of bacteria, algae, fungi, and protozoa in the
treatment system. Certain compounds that resist biological degradation in
natural waters may be readily oxidized by a microbial population adapted to
the waste. As would occur in the natural environment, organic compounds may
be removed by volatilization (e.g., aeration) and adsorption on solid mater-
ials (e.g., sludge) during biological treatment.
IV-37
-------
One of the primary limitations of biological treatment of wastewaters
from the OCPSF industry is the presence of both refractory (difficult to
treat) compounds as well as compounds that are toxic or inhibitory to biologi-
cal processes. Compounds oxidized slowly by microorganisms can generally be
treated by subjecting the wastewater to biological treatment for a longer
time, thereby increasing the overall conventional and toxic pollutant re-
movals. Lengthening the duration of treatment, however, requires larger
treatment tanks and more aeration, both of which add to the expense of the
treatment. Alternatively, pollutants that are refractory, toxic, or inhibi-
tory to biological processes can be removed prior to biological treatment of
wastewaters. Removal of pollutants prior to biological treatment is known as
pretreatment.
The successful treatment of wastewaters of the OCPSF industries primarily
depends on effective physical-chemical pretreatment of wastewaters, the abil-
ity to acclimate biological organisms to the remaining pollutants in the waste
stream (as in activated sludge processes), the year-round operation of the
treatment system at an efficient removal rate, the resistance of the treatment
system to toxic or inhibitory concentations, and the stability of the treat-
ment system during variations in the waste loading (i.e., changes in product
mixes).
However, as discussed earlier in this section, the Agency determined that
a subset of OCPSF plants, based on their low raw waste BOD5 levels, did not
necessarily require biological treatment to comply with BPT effluent limita-
tions. Some of these plants produced chlorinated hydrocarbons that typically
generate wastewater characterized by low raw waste BOD5 concentrations. In
these cases, biological treatment would not be effective in treating refrac-
tory priority pollutants that would not be amenable to biodegradation. There-
fore, the Agency decided that separate BAT effluent limitations based on the
performance of physical-chemical treatment technologies only were appropriate
and has established a separate subcategory for these plants based on their
unique raw wastewater characteristics and freatability.
The Agency also maintains that similar toxic pollutant effluent concen-
trations can be achieved by plants in differing BPT subcategories, i.e.,
IV-38
-------
plants with different product mixes, by installing the best available treat-
ment technologies. These toxic pollutants are being controlled using a combi-
nation of in-plant and end-of-pipe treatment technologies. The in-plant
controls are based upon specific pollutants or groups of pollutants identified
in waste streams and controlled by technologies for which treatment data are
available or transferred with appropriate basis (see Section VII of this docu-
ment). Thus, subcategory groupings of plants based on product mix for BAT are
not appropriate. Nevertheless, the Agency has attempted to perform a quanti-
tative assessment of treatability of BAT toxic pollutants by BPT subcategory
classification. The capability to perform this assessment is limited because
the frequency of occurrence of BAT toxic pollutants is determined by the pres-
ence of specific product/processes (or reaction chemistry) within plants that
is not totally dependent on BPT subcategory classifications. Table IV-1 pre-
sents a comparison of toxic pollutant mean effluent concentrations achieved by
100 percent plastics and organics plants contained in the final, edited BAT
toxic pollutant data base that were used in the calculation of BAT effluent
limitations. Also included is the same comparison between those 100 percent
"pure" BPT subcategory plants contained in the same data base. The first
comparison shows that, with the exception of two pollutants (#10 and #32),
plastics and organics plants achieve effluent concentrations that approach the
analytical minimum level. The same results are found for the second "pure"
subcategory comparison, even though fewer plants were available for the analy-
sis. For the two pollutants with disparate results, the Agency believes that
these differences are not the result of dissimilar wastewater treatability,
but a lack of effluent concentration data for these pollutants from 100 per-
cent plastics plants. EPA notes that when more than one 100 percent plastics
plant is available for comparison (e.g., pollutant #86), the effluent concen-
trations are similar.
In addition to each OCPSF plant's ability to achieve similar effluent
concentrations, the Agency also believes that its extensive BAT toxic pollu-
tant data base is representative of OCPSF wastewaters, treatment technologies,
processes, and products. In total, 186 plants were sampled in the Agency's
screening, verification, 5-plant, and 12-plant studies. After editing the
data base so that only quality data (i.e., having adequate QA/QC) representing
BAT treatment were used, the edited BAT data base contains sampling data for
IV-39
-------
TABLE IV-1.
BAT EFFLUENT ESTIMATED LONG-TERM AVERAGE CONCENTRATION COMPARISON
BETWEEN PLASTICS AND ORGANICS PLANTS AND
PURE BPT SUBCATEGORY PLANTS
Plant
Numbers 4
Plastics
883
2221
4051 10
1349
1617
2536
Organics
12 10
296 10
444 10
1609 10
1753
2394
2693
3033
Thermoplastics
883
1617
4051 10
2536
1349
Thermosets
2221
Bulk Organics
444 10
Specialty Organics
1753
Concentrations (ppb) by
Pollutant Number
10 32 38
Plastics vs. Organics
10
10
1016 923
_ _
_ _
10
10
12
_
_ _
10
10
_
10 13
Pure Subcategory
10
_ _
1016 923
10
- - -
LO
- - -
10
65
10
-
-
-
10
12
10
-
10
—
59
-
15
—
—
10
-
10
-
-
86
10
103
-
10
-
10
10
10
18
_
10
-
-
10
103
-
-
10
10
-
87
_
16
-
_
-
_
-
10
_
_
-
-
_
16
_
-
-
-
-
IV-40
-------
36 OCPSF plants (including industry supplied data) representing 232 product/
processes. These 36 plants account for approximately 26 percent of production
volume and 24 percent of the process wastewater flow of the entire industry.
The types of product/processes utilized by these 36 plants represent approxi-
mately 13 percent of the types of OCPSF product/processes in use. Since the
products manufactured by these facilities are manufactured at other OCPSF
facilities, the data obtained from these plants represent even greater per-
centages of total industry production and flow. Thus, about 68 percent of
OCPSF industry production (in total pounds) is represented and about 57 per-
cent of the OCPSF industry wastewater is accounted for by the products and
processes utilized by the 36 plants in the limitations data base. Products
that could be manufactured by the 232 product/processes utilized at or manu-
factured by the 36 plants account for 84 percent of industry production and
76 percent of process wastewater.
The OCPSF industry manufactures more than 20,000 individual products;
however, overall production is concentrated in a limited number of high-volume
chemicals. Excluding consideration of plastics, resins, and synthetic fibers,
EPA has identified 36 organic chemicals that are manufactured in quantities
greater than 1 billion pounds per year. These chemicals are referred to as
commodity chemicals. Two hundred eighteen organic chemicals are manufactured
in quantities between 40 million and 1 billion pounds per year. These chemi-
cals are referred to as bulk chemicals. Together, these 254 chemicals account
for approximately 91 percent of total annual production volume of organic
chemicals as reported in the 308 Questionnaire survey data base for the OCPSF
industry. By sampling OCPSF plants that manufacture many of these high-volume
chemicals, as well as other types of OCPSF plants, EPA has, in fact, gathered
sampling data that are representative of production in the entire industry.
Based on the results of its comparison analysis and the adequate coverage
of the OCPSF industry in its sampling programs, the Agency believes that
plants within each of its BAT subcategories can achieve BAT effluent limita-
tions despite differing product/process mix.
The Agency has also determined that because of their unique high raw
wastewater zinc characteristics and treatability noted in Sections V and VII,
IV-41
-------
respectively, producers of rayon by the viscose process and acrylic fibers by
the zinc chloride/solvent process will receiive different BAT effluent limita-
tions for zinc than the remainder of the OCPSF industry, whose BAT limitations
will be based on the performance of chemical precipitation technology used in
the Metal Finishing Point Source Category.
c. Energy and Non-Water Quality Aspects
Energy and non-water quality aspects include the following:
• Sludge production
• Air pollution derived from wastewater generation and treatment
• Energy consumption due to wastewater generation and treatment
• Noise from wastewater treatment.
The basic treatment step, used by virtually all plants in all subcategories
that generate raw wastes containing basically BOD5 and TSS, is biological
treatment. Therefore, the generation of sludges, air pollution, noise, and
the consumption of energy will be homogeneous across the industry,, However,
the levels of these factors will relate to the volume of wastewater treated
and their associated pollutant loads. Since the volumes of wastewater gener-
ated and wastewater characteristics were considered in earlier sections, it is
believed that all energy and nonwater quality aspects have been adequately
addressed in this final subcategorization approach.
IV-42
-------
SECTION V
WATER USE AND WASTEWATER CHARACTERIZATION
A. WATER USE AND SOURCES OF WASTEWATER
The Organic Chemicals, Plastics, and Synthetic Fibers (OCPSF) industry
uses large volumes of water in the manufacture of products. Water use and
wastewater generation occur at a number of points in manufacturing processes
and ancillary operations, including: 1) direct and indirect contact process
water; 2) contact and noncontact cooling water; 3) utilities, maintenance, and
housekeeping waters; and 4) waters from air pollution control systems such as
Venturi scrubbers.
The OCPSF effluent limitations and standards apply to the discharge of
"process wastewater," which is defined as any water that, during manufacturing
or processing, comes into direct contact with or results from the production
or use of any raw material, intermediate product, finished product,
by-product, or waste product (40 CFR 401.11(q)). An example of direct contact
process wastewater is the use of aqueous reaction media. The use of water as
a medium for certain chemical processes becomes a major high-strength process
wastewater source after the primary reaction has been completed and the final
product has been separated from the water media, leaving residual product and
unwanted by-products formed during secondary reactions in solution.
Indirect contact process wastewaters, such as those discharged from
vacuum jets and steam ejectors, involve the recovery of solvents and volatile
organics from the chemical reaction kettle. In using vacuum jets, a stream of
water is Used to create a vacuum, but also draws off volatilized solvents and
organics from the reaction kettle into solution. Later, recoverable solvents
are separated and reused while unwanted volatile organics remain in solution
in the vacuum water, which is discharged as process wastewater. Steam ejector
systems are similar to vacuum jets with steam being substituted for water.
The steam is then drawn off and condensed to form a source of process
wastewater.
V-l
-------
The major volume of water used in the OCPSF industry is cooling water.
Cooling water may be contaminated, such as contact cooling water (considered
process wastewater) from barometric condensers, or uncontaminated noncontact
cooling water. "Noncontact cooling water" is defined as water used for
cooling that does not come into direct contact with any raw material, inter-
mediate product, waste product, or finished product (40 CFR 401.11(n)).
Frequently, large volumes of noncontact cooling water may be used on a once-
through basis and discharged after commingling with process wastewater. Many
of the wastewater characteristics reported by plants in the data bases were
based on flow volumes that included both process wastewater and nonprocess
wastewater such as noncontact cooling water. Other types of nonprocess
wastewater include: boiler blowdown, water treatment wastes, stormwater,
sanitary waste, and steam condensate. An adjustment of the reported volumes
of the effluents was therefore required to arrive at performance of treatment
systems and other effluent characteristics.
This adjustment was made by eliminating the uncontaminated cooling water
volume from the total volume, to arrive at the contaminated wastewater flow at
the sampling site. The concentrations of the conventional pollutants BOD ,
COD, TSS, and TOC were adjusted using the simplifying judgment that the
uncontaminated cooling water did not contribute to the pollutant level.
However, it should be noted that in some cases noncontact cooling water can
contribute pollutant loading, especially to typically low-strength plastics
and synthetic materials wastewaters.
In some cases, effluent priority pollutant and daily conventional
pollutant data submitted by plants were from sample sites that included
nonprocess wastewater. Where this dilution with noncontact cooling water or
other nonprocess wastewater was significant (i.e., >25 percent of total), such
data were considered nonrepresentative of actual treatment systems' daily
performance and were excluded from the data base used for assessing treatment
system performance variability factors.
V-2
-------
B. WATER USE BY MODE OF DISCHARGE
Industry process wastewater flow descriptive statistics are summarized in
Table V-l for 929 OCPSF plants that submitted sufficient information in the
1983 Section 308 Questionnaire. This data base is classified by direct,
indirect, or zero discharge status. "Zero" discharge methods include no
discharge, land application, deep well injection, incineration, contractor
removal, evaporation, off-site treatment by a privately owned treatment
system, and discharge to septic and leachate fields.
Some of the plants in the 308 data base discharge waste streams by more
than one method. However, for purposes of tabulating wastewater data, each
plant was assigned to a single discharge category (i.e., no double counting
appears in the direct, indirect, and zero discharge data columns). A plant
was classified as a zero or alternate discharger only if all of its waste
streams were reported as zero or alternate discharge streams. Plants were
classified as direct dischargers if at least one process wastewater stream was
direct. Plants whose process wastewater streams were discharged to publicly
owned treatment works (POTWs) were classified as indirect dischargers. Many
of the indirect discharge plants discharge noncontact cooling water directly
to surface waters.
Industry nonprocess wastewater flow descriptive statistics are summarized
in Table V-2 for 718 OCPSF plants as classified in Table V-l by process
wastewater discharge status.
C. WATER USE BY SUBCATEGORY
As discussed previously in Section IV, data relating product/process
production information to flow was requested from industry in the 1983 Section
308 Questionnaire to facilitate the flow proportioning of individual product
subcategory limitations for multiple subcategory plants. This information
would have also facilitated the presentation of the wastewater flow data by
subcategory. Unfortunately, much of the production/flow information (when
supplied) was either estimated or grouped with other product/process flows and
was considered too inaccurate or nebulous for use. Since this information
V-3
-------
TABLE V-l.
TOTAL OCPSF PLANT PROCESS WASTEWATER
FLOW CHARACTERISTICS BY TYPE OF DISCHARGE
Frequency Counts (# of Plants)
By Flow Range
Process Wastewater
Discharge Status
Direct
Indirect
*(N) = 929 out of 940 scope facilities
Source: 1983 Section 308 Questionnaire Responses
Zero
Descriptive Statistics
Number of Plants*
Percentage of Plants
Total Flow (MGD)
Average Flow (MGD)
Median Flow (MGD)
304
33%
387
1.31
0.40
393
42*
94
0.25
0.04
232
25%
32
0.24
0.007
<0.005 MGD
0.005 to 0.01 MGD
>0.01 to 0.10 MGD
>0.10 to 0.50 MGD
>0.5 to 1.0 MGD
>1.0 to 5.0. MGD
>5.0 to 10.0 MGD
>10 MGD (up to a maximum of 19.3 MGD)
25
12
54
80
43
75
8
7
106
34
136
77
26
12
1
1
161
11
30
16
4
10
0
0
V-4
-------
TABLE V-2.
TOTAL OCPSF PLANT NONPROCESS VASTEWATER
FLOW CHARACTERISTICS BY TYPE OF DISCHARGE
Nonprocess Wastewater
Discharge Status
Direct
Indirect
Frequency Counts (# of Plants)
By Flow Range
Zero
Descriptive Statistics
Number of Plants*
Percentage of Plants
Total Flow (MGD)
Average Flow (MGD)
Median Flow (MGD)
278
39%
3,973
14.29
0.40
332
46%
353
1.06
0.03
108
15%
103
0.95
0.05
<0.005 MGD
0.005 to 0.01 MGD
>0.01 to 0.10 MGD
>0.10 to 0.50 MGD
>0.5 to 1.0 MGD
>1.0 to 5.0 MGD
>5.0 to 10.0 MGD
>10 MGD (up to a maximum of 1,732 MGD)
11
14
53
77
32
42
12
37
76
36
117
56
22
19
3
3
21
16
34
20
8
5
I
3
*(N) = 718 out of 940 scope facilities reporting discharge of nonprocess
wastewater
Source: 1983 Section 308 Questionnaire Responses
V-5
-------
could not be used to group these flow data, accurately, the Agency has decided
to present these data using two methodologies. The first method utilizes an
approach similar to the regression model used for subcategorization to
proportion these data among subcategories. The second methodology places
individual plants completely in one of the seven final subcategories based on
a prescribed set of rules. These two methodologies are discusssed in more
detail in the following sections.
Tables V-3 through V-16 provide the 1980 process and nonprocess
wastewater flow statistics by subcategory and disposal me'thod. Tables V-3
through V-9 present separate tabulations for primary and secondary producers
and for process and nonprocess wastewater. In each table, the mean and median
flows for multi-subcategory plants have been divided into subcategories using
the regression methodology described in Section IV based on plant: production
volume proportions for each subcategory. Thus, mean and median flows given in
some cases may not represent actual plant subcategory flow since, on a unit of
production basis, different products produce different flow volumes. However,
data constraints preclude direct attribution of process and nonprocess flows
to individual products or product subcategory groups. Production weighted
mean subcategory flow values were calculated using the following formula:
Production Weighted Mean = PiFi + P2'F? + P3F3 + ••• + piFj
pi + ?-, + P3 + ••• + pi
Where:
PI = Decimal subcategory proportion of total OCPSF plant production for
plant #1 (range = 0 to 1.0)
F1 = Total process flow for plant #1.
In determining the median, the wastewater flow of each plant that has at
least one product within a subcategory are ranked from lowest to highest. The
subcategory decimal production proportions are summed starting from the lowest
flow plant until the sum equals or exceeds 50 percent of the total of all the
decimal production proportions. The wastewater flow of the plant whose
proportions when added to the proportion sum causes the total to exceed
V-6
-------
TABLE V-3
PROCESS WASTEWATER FLOW FOR PRIMARY OCPSF PRODUCERS
BY SUBCATEGORY AND DISPOSAL METHOD
DIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
(MGD)
1.00
0.71
8.04
1.14
2.16
1.53
0.84
MEDIAN
(MGD)
0.43
0.08
8.57
0.57
1.00
0.29
0.30
STANDARD
DEVIATION
1.70
1.66
2.98
2.31
3.73
3.43
1.74
NUMBER OF
OBSERVATIONS
60.99
12.10
3.19
13.73
48.85
47.53
41.61
NUMBER OF
PLANTS
104
31
5
22
84
113
103
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
(MGD)
0.25
0.08
0.05
0.57
0.48
0.34
MEDIAN
(MGD)
0.05
0.02
0.02
0.04
0.05
0.06
STANDARD
DEVIATION
0.65
0.28
0.06
1.71
1.15
1.49
NUMBER OF
OBSERVATIONS
68.57
40.97
7.00
18.43
33.71
106.31
NUMBER OF
PLANTS
108
80
8
36
84
154
V-7
-------
TABLE V-4
PROCESS UASTEUATER FLOW DURING 1980 FOR SECONDARY OCPSF
PRODUCERS BY SUBCATEGORY AND DISPOSAL METHOD
DIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS 0.15
THERMOSETS
ORGAN ICS
SUBCATEGORY
THERMOPLASTICS 0.03
THERMOSETS
ORGAN ICS
MEAN
(MGD)
0.15
0.50
0.70
MEAN
(MGD)
0.03
0.03
0.11
MEDIAN
(MGD)
0.08
0.01
0.20
INDIRECT
MEDIAN
(MGD)
0.01
0.00
0.02
STANDARD
DEVIATION
0.26
0.93
1.27
DISCHARGERS
STANDARD
DEVIATION
0.05
0.08
0.18
NUMBER OF
OBSERVATIONS
8.68
4.03
28.29
NUMBER OF
OBSERVATIONS
16.59
20.90
52.51
NUMBER OF
PLANTS
12
5
30
NUMBER OF
PLANTS
27
30
58
V-8
-------
SUBCATEGORY
TABLE V-5
PROCESS WASTEWATER FLOW FOR PRIMARY & SECONDARY
OCPSF PRODUCERS THAT ARE ZERO/ALTERNATIVE DISCHARGERS
MEAN MEDIAN STANDARD NUMBER OF NUMBER OF
(MGD) (MGD) DEVIATION OBSERVATIONS PtANTS
THERMOPLASTICS
THERMOSETS
ORGAN ICS
FIBERS
COMMODITY ORGAN ICS 0.91
BULK ORGAN ICS
SPECIALTY ORGANICS 0.16
0.08
0.01
0.42
0.33
0.91
0.31
0.16
0.01
0.00
0.03
0.08
0.91
0.30
0.11
0.26
0.08
0,93
0.98
•
0.37
0.19
24.92
33.11
60.71
2.31
0.84
1.30
2.81
36
40
69
3
1
3
4
V-9
-------
TABLE V-6
NON-PROCESS WASTEUATER FLOW DURING 1980
FOR SECONDARY OCPSF PRODUCERS
AND ZERO/ALTERNATIVE DISCHARGERS
BY SUBCATEGORY & DISPOSAL METHOD
SECONDARY AND DIRECT DISCHARGE PLANTS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MEAN
(MGD)
0.320
0.242
3.564
MEDIAN
(MGD)
0.190
0.250
0.255
STANDARD
DEVIATION
0.760
0.242
11.546
NUMBER OF
OBSERVATIONS
8.72
1.03
27.25
NUMBER OF
PLANTS
12
2
29
SECONDARY AND INDIRECT DISCHARGE PLANTS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MEAN
(MGD)
0.072
0.458
1.240
MEDIAN
(MGD)
0.005
0.020
0.015
STANDARD
DEVIATION
0.206
1.179
6.470
NUMBER OF
OBSERVATIONS
19.50
17.99
46.51
NUMBER OF
PLANTS
29
27
52
SECONDARY AND OTHER: DISCHARGE PLANTS*
SUBCATEGORY
MEAN
(MGO)
MEDIAN
(MGD)
STANDARD
DEVIATION
NUMBER OF
OBSERVATIONS
NUMBER OF
PLANTS
THERMOPLASTICS 0.242 0.013 1.367
THERMOSETS 0.101 0.019 0.184
ORGANICS 0.658 0.031 2.960
FIBERS 6.455 0.710 20.921
18.00
27.01
47.67
1.31
26
33
57
2
NOTE: THERE ARE 9 PRIMARY PLANTS NOT INCLUDED IN THIS TABLE
THAT ARE ZERO DISCHARGERS.
V-10
-------
TABLE V-7
TOTAL OCPSF NON-PROCESS WASTEUATER FLOW IN 1980
FOR PRIMARY PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
DIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
( MOD )
9.266
5.228
2.295
9.279
55.125
21.990
8.142
MEDIAN
( MGD )
0.280
0.450
2.500
1.910
0.720
0.475
0.200
STANDARD
DEVIATION
67.664
62.392
4.263
17.113
232.600
128.821
42.871
NUMBER OF
OBSERVATIONS
58.905
11.904
2.187
11.851
45.738
46.253
35.162
NUMBER OF
PLANTS
101
33
4
19
78
108
96
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.211
0.141
0.077
3.434
4.808
0.418
DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.027
0.000
0.150
14.560
MEDIAN
( MGD )
0.027
0.020
0.024
0.311
0.064
0.043
OTHER THAN
MEDIAN
( MGD )
0.010
0.000
0.150
0.150
STANDARD
DEVIATION
1.326
0.738
0.090
11.510
21.021
1.765
NUMBER OF
OBSERVATIONS
55.056
29.003
4.002
15.329
27.823
74.786
NUMBER OF
PLANTS
85
62
5
30
67
116
DIRECT OR INDIRECT
STANDARD
DEVIATION
0.026
.
,
24.171
NUMBER OF
OBSERVATIONS
2.122
0.878
0.208
2.792
NUMBER OF
PLANTS
3
1
1
3
V-ll
-------
TABLE V-8
NON-PROCESS COOLING WATER FLOW FOR PRIMARY
OCPSF PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
DIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
( MGD )
0.814
0.259
0.140
0.369
1.097
0.431
0.381
MEDIAN
( MGD )
0.182
0.063
0.120
0.337
0.537
0.100
0.077
STANDARD
DEVIATION
2.058
0.661
0.125
0.321
1.651
0.936
1.042
NUMBER OF
OBSERVATIONS
58.415
11.992
2.187
12.153
42.908
43.148
42.196
NUMBER OF
PLANTS
96
33
4
19
75
107
100
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
COMMODITY ORGAN I CS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.085
0.171
0.068
0.776
0.213
0.097
DISCHARGERS
MEAN
( MGD )
0.065
0.004
0.121
0.039
0.023
MEDIAN
( MGD )
0.012
0.007
0.090
0.118
0.028
0.011
OTHER THAN
MEDIAN
( MGD )
0.043
0.004
0.121
0.003
0.003
STANDARD
DEVIATION
0.204
1.015
0.057
1.781
0.380
0.231
NUMBER OF
OBSERVATIONS
45.578
25.319
4.027
13.479
24.790
68.806
NUMBER OF
PLANTS
73
52
5
25
59
99
DIRECT OR INDIRECT
STANDARD
DEVIATION
0.039
.
.
.
0.036
NUMBER OF
OBSERVATIONS
2.168
0.878
0.83S
0.302
2.815
NUMBER OF
PLANTS
4
1
1
2
4
V-12
-------
TABLE V-9
OCPSF MISCELLANEOUS NON-COOL ING WON-PROCESS WASTEUATER FLOW
FOR PRIMARY PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
DIRECT DISCHARGERS
SUBCATtGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MEAN
( MGD )
9.474
4.956
1.671
9.288
52.918
20.449
6.504
MEDIAN
< MGD )
0.485
0.290
0.240
1.585
1.400
0.660
0.233
STANDARD
DEVIATION
66.066
59.320
3.467
16.800
226.990
123.687
37.616
NUMBER OF
OBSERVATIONS
62.632
13.183
3.187
12.323
48.535
50.649
46.491
NUMBER OF
PLANTS
107
36
5
20
84
118
111
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.242
0.236
0.116
3.727
4.365
0.434
DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MEAN
( MGD )
0.063
0.004
0.121
0.143
14.466
MEDIAN
( MGD )
0.030
0.025
0.063
0.639
0.106
0.069
OTHER THAN
MEDIAN
( MGD )
0.090
0.004
0.121
0.153
0.153
STANDARD
DEVIATION
1.318
1.088
0.130
11.519
19.798
1.708
NUMBER OF
OBSERVATIONS
64.020
35.707
5.002
16.932
31 .855
87.483
NUMBER OF
PLANTS
100
72
6
32
75
131
DIRECT OR INDIRECT
STANDARD
DEVIATION
0.048
.
.
.
24.107
NUMBER OF
OBSERVATIONS
3.168
0.878
0.838
0.302
2.815
NUMBER OF
PLANTS
5
1
1
2
4
V-13
-------
TABLE V-10
PROCESS WASTEWATER FLOW FOR PRIMARY OCPSF PRODUCERS
BY SUBCATEGORY AND DISPOSAL METHOD
DIRECT DISCHARGERS
( 95X & 70X RULES )
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN ICS
BULK ORGAN ICS
SPECIALTY ORGANICS
MIXED
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
TOTAL
FLOW
(MGD)
24.884
3.080
24.639
7.422
25.909
27.146
16.985
194.299
MIN
(MGD)
0.02100
0.00001
5.03000
0.24300
0.00144
0.00020
0.00075
0.00002
MAX
(MGD)
3.450
2.680
11.039
1.482
3.890
18.000
3.450
19.323
MEAN
(MGD)
0.61
0.51
8.21
0.82
0.96
1.04
0.59
2.23
MEDIAN
(MGD)
0.31
0.09
8.57
0.63
0.66
0.11
0.26
0.85
STANDARD
DEVIATION
0.73
1.06
3.02
0.46
1.04
3.49
0.91
3.68
NUMBER OF
PLANTS
41
6
3
9
27
26
29
87
INDIRECT DISCHARGERS
TOTAL
FLOW
(MGD)
8.0439
0.7884
0.3768
11.4154
8.1822
32.4242
22.3383
( 95X
MIN
(MGD)
0.0000070
0.0001000
0.0003000
0.0078000
0.0007000
0.0000100
0.0000343
& 70% RULES )
MAX
(MGD)
1.240
0.350
0.160
7.970
2.963
15.439
4.840
MEAN
(MGD)
0.16
0.05
0.05
1.14
0.48
0.36
0.26
MEDIAN
(MGD)
0.05
0.00
0.02
0.28
0.05
0.07
0.03
STANDARD
DEVIATION
0.27
0.10
0.06
2.46
0.92
1.63
0.74 •,
NUMBER OF
PLANTS
49
16
7
10
17
90
86
V-14
-------
TABLE V-11
PROCESS WASTEUATER FLOW DURING 1980 FOR SECONDARY OCPSF
PRODUCERS BY SUBCATEGORY AND DISPOSAL METHOD
( 95 X RULE )
DIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
MINIMUM
(MGD)
0.00016
0.00369
0.00001
0.75000
MINIMUM
(MGD)
0.000300
0.000054
0.000050
0.000200
MAXIMUM
(MGD)
0.20
1.90
4.70
0.97
( 95
INDIRECT
MAXIMUM
(MGD)
0.0920
0.1400
0.6300
0.5585
MEAN
(MGD)
0.08
0.50
0.69
0,86
X RULE )
DISCHARGERS
MEDIAN
(MGD)
0.05
0.06
0.17
0.86
MEAN MEDIAN
(MGD) (MGD)
0.02
0.02
0.10
0.07
0.01
0.00
0.02
0.01
STANDARD
DEVIATION
0.08
0.93
1.30
0.16
STANDARD
DEVIATION
0.03
0.04
0.17
0.15
NUMBER OF
OBSERVATIONS
8
4
27
2
NUMBER OF
OBSERVATIONS
11
15
48
16
V-15
-------
TABLE V-12
PROCESS WASTEWATER FLOW FOR PRIMARY & SECONDARY
OCPSF PRODUCERS THAT ARE ZERO/ALTERNATIVE DISCHARGERS
( 95% & 70% RULES )
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
OR CAN I CS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
MINIMUM
(MGD)
0.00001
0.00004
0.00000
0.00010
0.90700
0.29700
0.00450
0.00006
MAXIMUM
(MGD)
0.34
0.02
4.40
0.08
0.91
0.30
0.33
2.20
MEAN
(MGD )
0.05
0.00
0.40
0.04
0.91
0.30
O.T5
0.33
MEDIAN
(MGD)
0.01
0.00
0.03
0.04
0.91
0.30
0.11
0.01
STANDARD
DEVIATION
0.09
0.00
0.94
0.06
•
•
0.16
0.70
NUMBER OF
PLANTS
21
27
55
2
1
1
3
16
V-16
-------
TABLE V-13
NON-PROCESS UASTEWATER FLOW DURING 1980
FOR SECONDARY OCPSF PRODUCERS
AND ZERO/ALTERNATIVE DISCHARGERS
BY SUBCATEGORY & DISPOSAL METHOD
( 95X & 70% RULES )
SECONDARY AND DIRECT DISCHARGE PLANTS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN 1CS
MIXED
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
MINIMUM
(MGD)
0.00165
0.25000
0.00200
0.19000
SECONDARY
MINIMUM
(MGD)
0.00010
0.00090
0.00010
0.00050
MAXIMUM
(MGD)
0.710
0.250
59.800
7.600
( 95% & 70%
AND INDIRECT
MAXIMUM
(MGD)
0.250
5.000
44.100
2.100
( 95% & 70%
SECONDARY AND OTHER
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
MINIMUM
(MGD)
0.00050
0.00171
0.00001
0.71000
0.00370
MAXIMUM
(MGD)
1.500
0.590
5.750
0.710
24.700
MEAN
(MGD)
0.234
0.250
3.500
3.510
RULES )
MEDIAN
(MGD)
0.120
0.250
0.125
2.740
STANDARD
DEVIATION
0.289
.
12.038
3.765
NUMBER OF
PLANTS
8
1
25
3
DISCHARGE PLANTS
MEAN
(MGD)
0.037
0.492
1.317
0.341
RULES )
MEDIAN
(MGD)
0.003
0.007
0.012
0.059
STANDARD
DEVIATION
0.072
1.372
6.806
0.590
NUMBER OF
PLANTS
14
13
42
15
DISCHARGE PLANTS*
MEAN
(MGD)
0.136
0.092
0.360
0.710
1.935
MEDIAN
(MGD)
0.010
0.020
0.028
0.710
0.076
STANDARD
DEVIATION
0.381
0.156
0.934
.
6.559
NUMBER OF
PLANTS
15
22
42
1
14
NOTE: THERE ARE 9 PRIMARY PLANTS NOT INCLUDED IN THIS TABLE
THAT ARE ZERO DISCHARGERS.
V-17
-------
TABLE V-14
TOTAL OCPSF NON-PROCESS WASTEUATER FLOW IN 1980
FOR PRIMARY PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
DIRECT DISCHARGERS
( 95% & 70% RULES )
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD )
0.00022
0.00007
0.14000
0.07200
0.00200
0.00521
0.00266
0.00010
MAXIMUM
( MGD )
30.744
15.605
2.500
44.364
648.000
38.400
15.626
1731.700
MEAN
( MGD )
2.106
2.659
1.320
10.727
25.595
3.267
1.842
43.023
MEDIAN
( MGD )
0.212
0.218
1.320
4.526
0.409
0.269
0.179
1.281
STANDARD
DEVIATION
5.603
5.741
1.669
15.621
126.949
8.123
3.613
195.531
NUMBER OF
PLANTS
39
7
2
8
26
25
22
83
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
SUBCATEGORY
THERMOPLASTICS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD )
0.00000
0.00030
0.01770
0.00520
0.00290
0.00020
0.00010
DISCHARGERS
MINIMUM
( MGD )
0.01000
0.05000
0.00010
( 95X & 70%
MAXIMUM
( MGD )
1.490
0.335
0.210
47.146
111.260
8.830
11.157
OTHER THAN
( 95% & 70%
MAXIMUM
( MGD )
0.047
40.480
0.000
RULES )
MEAN
( MGD )
0.154
0.052
0.077
6.859
8.662
0.439
0.469
DIRECT OR
RULES )
MEAN
( MGD )
0.028
13.560
0.000
MEDIAN
< MOD )
0.021
0.012
0.040
1.159
0.060
0.063
0.030
INDIRECT
MEDIAN
( MGD )
0.028
0.150
0.000
STANDARD
DEVIATION
0.306
0.099
0.090
16.310
30.827
1.271
1.648
STANDARD
DEVIATION
0.026
23.313
.
NUMBER OF
PLANTS
40
11
4
8
13
61
69
NUMBER OF
PLANTS
2
3
1
V-18
-------
TABLE V-15
NON-PROCESS COOLING WATER FLOW FOR PRIMARY
OCPSF PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
DIRECT DISCHARGERS
( 95% & 70% RULES )
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD )
0.00414
0.00007
0.10000
0.08300
0.00500
0.00165
0.00001
0.00070
MAXIMUM
( MGD )
10.045
1.072
0.120
1.086
3.167
3.300
2.303
12.400
MEAN
( MGD )
0.736
0.290
0.110
0.411
0.884
0.277
0.229
0.843
MEDIAN
( MGD )
0.177
0.038
0.110
0.325
0.468
0.078
0.041
0.288
STANDARD
DEVIATION
1.969
0.441
0.014
0.351
0.999
0.699
0.456
1.791
NUMBER OF
PLANTS
40
7
2
8
24
22
29
81
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
SUBCATEGORY
THERMOPLASTICS
COMMODITY ORGANICS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD )
0.00009
0.00010
0.00731
0.028U
0.00300
0.00004
0.00001
DISCHARGERS
MINIMUM
( MGD )
0.04300
0.12100
0.00120
0.00400
( 95% & 70%
MAXIMUM
( MGD )
0.890
0.029
0.135
2.758
0.999
1.600
8.000
OTHER THAN
( 95% & 70%
MAXIMUM
( MGD )
0.092
0.121
0.060
0.004
RULES )
MEAN
( MGD )
0.077
0.009
0.067
0.786
0.172
0.096
0.247
DIRECT OR
RULES )
MEAN
( MGO )
0.067
0.121
0.021
0.004
MEDIAN
( MGD )
0.012
0.006
0.063
0.481
0.014
0.011
0.016
INDIRECT
MEDIAN
( MGD )
0.067
0.121
0.003
0.004
STANDARD
DEVIATION
0.194
0.009
0.057
0.931
0.320
0.232
1.074
STANDARD
DEVIATION
0.035
.
0.034
m
NUMBER OF
PLANTS
34
9
4
8
13
58
56
NUMBER OF
PLANTS
2
1
3
1
V-19
-------
TABLE V-16
OCPSF MISCELLANEOUS NOW-COOLING NON-PROCESS UASTEWATER FLOW
FOR PRIMARY PRODUCERS BY SUBCATEGORY & DISPOSAL METHOD
DIRECT DISCHARGERS
( 95% & 70% RULES )
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGANICS
MIXED
MINIMUM
< MGO )
0.00100
0.00015
0.12000
0.32100
0.01200
0.00521
0.00031
0.00080
MAXIMUM
( MGD )
30.896
15.643
2.500
44.447
651.167
41.700
15.703
1739.330
MEAN
( MGD )
2.657
2.949
0.953
11.138
25.432
3.135
1.474
40.435
MEDIAN
( MGO )
0.396
0.290
0.240
4.929
0.884
0.304
0.173
1.410
STANDARD
DEVIATION
6.235
5.687
1.341
15.500
125.062
8.264
3.097
188.898
NUMBER OF
PLANTS
42
7
3
8
27
28
32
90
INDIRECT DISCHARGERS
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
SUBCATEGORY
THERMOPLASTICS
COMMODITY ORGANICS
SPECIALTY ORGANICS
MIXED
MINIMUM
( MGD )
0.00000
0.00010
0.02411
0.04480
0.00300
0.00004
0.00011
DISCHARGERS
MINIMUM
( MGD )
0.01000
0.12100
0.05120
0.00410
( 95% & 70%
MAXIMUM
( MGD )
2.380
0.350
0.345
49.904
111.960
9.367
11.417
OTHER THAN
( 95% & 70%
MAXIMUM
( MGD )
0.092
0.121
40.540
0.004
RULES )
MEAN
( MGD )
0.187
0.047
0.115
6.795
7.178
0.449
0.592
DIRECT OR
RULES )
MEAN
( MGD )
0.064
0.121
13.581
0.004
MEDIAN
C MGD )
0.028
0.018
0.063
0.898
0.081
0.080
0.052
INDIRECT
MEDIAN
( MGD )
0.090
0.121
0.153
0.004
STANDARD
DEVIATION
0.411
0.092
0.131
16.218
27.944
1.286
1.797
STANDARD
DEVIATION
0.047
.
23.347
.
NUMBER OF
PLANTS
47
14
5
9
16
72
78
NUMBER OF
PLANTS
3
1
3
1
V-20
-------
50 percent is then chosen as the median. If, however, the total equals
50 percent exactly, then the median is the average of the wastewater flow of
that plant and the next plant in the sequence. The tables are divided into
primary and secondary producers because legs detailed production data were
collected from secondary producers. Likewise, less detailed data were
collected from both primary and secondary zero discharge plants. Production
data are identified only by Standard Industrial Classification (SIC) code for
secondary or zero discharge producers, and thus the organics subcategories
(i.e., bulk, commodity, specialty) must be grouped together.
In each table, the column for "Number of Plants" represents the total
number of plants for whom at least part of their flow was used to derive the
subcategory statistics. Therefore, double or multiple counting of plants
occurs for multi-subcategory plants. The column for "Number of Observations"
represents the sum of plant subcategory production proportions.
Tables V-10 through V-16 also provide 1980 process and nonprocess
wastewater flow statistics by subcategory and disposal technique, but use a
different method to aggregate plants by subcategory. Plants were placed in
one of five categories (Thermoplastics, Thermosets, Rayon, Organics, Fibers)
if their production was at least 95 percent contained in that category.
Plants having less than 95 percent were placed in a sixth category (Mixed).
The organics category was then further subdivided into three subcategories
(Commodity, Bulk, Specialty) if the plant's organics production was at least
70 percent contained in one of the subcategories. Plants with less than
70 percent production were also placed in the mixed category. As with the
tables generated using the regression methodology, production data are
identified only by SIC code for secondary or zero discharge producers, and
thus the organics subcategories (Commodity, Bulk, Specialty) were grouped
together in the tables for these plants.
Tables V-3 and V-4 provide process wastewater flow statistics for primary
and secondary producers, respectively, with each divided into direct and
indirect dischargers using the regression methodology. Tables V-10 and V-ll
present the same flow statistics using the 95 percent production basis for
assigning plants to subcategories for the four nonorganics subcategories and
V-21
-------
the 70 percent organics production basis for the three organics subcategories
(95/70 methodology). Table V-5 provides process wastewater flow statistics
for the zero or alternate discharge plants using the regression methodology,
while Table V-12 presents the same flow statistics using the 95/70 methodology.
Tables V-6 through V-9 provide 1980 flow statistics for nonprocess wastewaters
using the regression methodology, while Tables V-13 through V-16 present the
same flow statistics using the 95/70 methodology.
The data in each table are grouped by the disposal method of the plants'
process wastewater. In general, plants that discharge process wastewater
directly will also discharge nonprocess wastewater directly. However, in some
cases, plants that discharge process wastewater indirectly or by zero or
alternate discharge methods may discharge their non-process wastewaters
directly due to the generally lower treatment requirements of many nonprocess
waste streams.
Tables V-6 and V-13 provide the nonprocess flow statistics for secondary
producers and zero and alternate dischargers. Tables V-7 and V-14 provide the
total nonprocess flow statistics for primary producers, while Tables V-8
through V-9 and Tables V-15 through V-16 provide the portions of these flows
that are composed of cooling water versus other miscellaneous nonprocess
wastewater.
The cooling water in Tables V-8 and V-15 include both once-through
noncontact cooling water plus cooling tower blowdown and for some plants may
include other nonprocess wastewater where flows were reported as a combined
total. It is evident from these tables that cooling water comprises the major
portion of nonprocess wastewater for most plants and that direct dischargers
produce greater quantities of nonprocess wastewater than indirect dischargers.
In general, the summary statistics for wastewater flow by subcategory
that were generated by the two methodologies compare favorably; all of the
differences between subcategory medians calculated by the two methodologies
fell within the standard deviations calculated by either methodology. Reasons
for the differences include the inaccurate nature of assigning individual
plants to subcategories, i.e., the arbitrary assignment of plants based on the
V-22
-------
95/70 rule, which was determined to be insufficient for previous sub-
categorization efforts, as well as the relative contribution of the extra 5 or
30 percent of other subcategories' flows depending on if the plant is pre-
dominantly plastics or organics, respectively. Based on the inherent
limitations of the 95/70 methodology, the Agency has much more confidence in
the utility of the regression methodology summary statistics, but has included
the 95/70 summary statistics for comparison purposes.
D. WATER REUSE AND RECYCLE
1. Water Conservation and Reuse Technologies
A variety of water conservation practices and technologies are available
to OCPSF plants. Because of the diversity within the industry, no one set of
conservation practices is appropriate for all plants. Decisions regarding
water reuse and conservation depend on plant-specific characteristics, as well
as site-specific water supply and environmental factors (e.g., water avail-
ability, cost, and quality). Therefore, this section will describe the range
of practices and technologies available for water conservation.
Conventional water conservation practices include (McGovern 1973; Holiday
1982):
• Recovery and reuse of steam condensates and process condensates, where
possible
• Process modifications to recover more product and solvents
• Effective control of cooling-tower treatment and blowdown to optimize
cycles of concentration
• Elimination of contact cooling for off vapors
• Careful monitoring of water uses; maintenance of raw water treatment
systems and prompt attention to faulty equipment, leaks, and other
problems
• Installation of automatic monitoring and alarm systems on in-plant
discharges.
V-23
-------
Table V-17 summarizes water conservation technologies, and their applications,
limitations, and relative costs to industry plants. Some of these technolo-
gies, such as steam stripping, are also considered effluent pollution control
technologies. Water conservation, in fact, can often be a benefit of mandated
pollution control.
2. Current Levels of Reuse and Recycle
Data on the amount of water reused and recycled in the OCPSF industry
from the 1978 Census Bureau survey and the 1983 308 Questionnaires are
presented in Tables V-18 and V-19, respectively.
In Table V-18, the Census Bureau defines "recirculated or reused water"
as the volume of water recirculated multiplied by the number of times the
water was recirculated. Seventy-nine percent of the OCPSF plants surveyed by
the Census Bureau reported some recirculation or reuse of water. Census
Bureau statistics show that the bulk of recirculated water is used for cooling
and condensing operations, such as closed-loop cooling systems for heat
transport. Chemical algaecides and fungicides are routinely added to these
cooling waters to prevent organism growth and suppress corrosion, both of
which can cause exchanger fouling and reduction of heat transfer co-
efficients.
As water evaporates and leaks from such closed systems, the concentration
of minerals in these waters increases, which may lead to scale formation,
reducing heat transfer efficiency. To reduce such scaling, a portion of such
closed system waters is periodically discharged as blowdown and replaced by
clean water.
Table V-19 shows the 1980 recycle flow of process and nonprocess
wastewaters for OCPSF plants that are primary producers, excluding zero and
alternate dischargers as reported in the 1983 Section 308 Questionnaire. The
flow rates shown were for wastewater streams where the final disposal method
was reported as recycle. Thus, the data do not reflect the number of times
the wastewater is recycled (as in Census Bureau data), nor do they include
flow in closed-loop systems such as cooling towers, since water in such
V-24
-------
V}
W
M
8
j
o
o
u
f^
Ed
in
r-~ Ed
I
^> Q
TABLE
ISERVATION AP
g
o
&
H
^
CO
4-1
C
01
B
B
0
O
B
CO -H
4-1 4-1
CO Rl
O l-i
U 0)
o<
cu o
•H
Rl R)
r-H 4-i
0) -rt
cxi a
3
co
B
O
•H
4-1
R)
4-1
•H
B
•rt
CO
O
•H
4-1
Rl
y
• H
a.
a.
cu
3
cr
•H
c
-C
y
cu
E-<
0) O l-i
4-.
•H (0
^J Jj ^
CO -H
T> Ri CO
O *•'
Xt ^» V-4 B
*j 4-1 x> id
!* -rt B
O r-l M -rt
l-l R) CU S
bo 3 rH Rl
0"W «-•
•0 1 B B
a. box: y
RJ -H
05 03.
^*
bo
•H
»
X!
bo
•H
ta
4~>
fi*J Q
CO
10 0)
•rt O i— 1 XI CU
C l-l -rt r-4
bo o CQ co a)
M CU -rt 3 rH
O N T3 B i-H
Rl I O
u B bo M
o s RI B <-•
>4-l M CU -H B
O 4-1 r-l O
o o
Z b
bO
C M
•H B CU
r-l O *-"
§-H id
•M ^
y y
^ B 3 >>
o i-i S -o 4J
O O O -rt
C ^3 M W
O t-i » 0. 3
•rt 0) O O,
RJ (d X) B -C
u > cu bo
B t-> 01 IJ Si
CU CO S 3
B > 4-i B O
0 0
B
o
•H
CO
CO
0)
l-l
a.
s
o
y
i
u
O
(X
R)
>
*o
o
& o
O bo
B
r-l
*^3 fl)
CU -H
CO ***
3 B
>, •"
i-» O
cu a
T3
1^ Ju|
3
4-1 4-1
^£
B
3
•H
CU
B
•H
13
cu
CO
o
4-i rH
y cu *H
•H N 4-i
B Rl CO
M B T3
M lj 1
o o a
U CU
O 4-1 4-1
M-l tO CO
X!
O O
•z.
£?
01
vt-l >
O O
y
B CU
O l-i lJ
•H 0)
4-1 4-1 CU
Rl R) 4-1
Lj > RJ
fi 4-- B
0) CO 01
B > B
0 O
B
O
>r4
4-1 4-1
0] Rl
CU l-i
XI O
o.
0) Rl
*-• >
CO 0)
Rl
O
bO
E >,
O R)
M >
•" B lJ
co o cu
•H *O
i-H w q
•H y
W *r*\ 4-J
Er-IB
0) Q. 01
4-> Q, e
O Rl CX
Q, 0
CU rH
01 co cu
3 CU CU
4-1 4-1 T3
3 B
a
3
•H
0)
as
§
•H
*o
(1)
CO
01
0) B >>
•H 4-* t-i a a
4-J O XI 3
•H B B B i-<
CO
01 CO k-i 1
to 3 01 *-• Xi
1 B t> CO bO
bO (0 -H
B B U *-• XI
r-l 0) 0) CU CU
O 4-1 0?
Cb CO OS
"O >> Rl
0) B >sT3 U
N Rl > -H CU
•rt S RJ O u
B 0) r-l (0
O CO ,£3 rH *W S
•rt 3 O O
*J O. CO O r-l B l-l
o y - R| o 3
•> *H >* CO •H >rt Q4
i— (WBUr-ll4<-'flJ
Ri4-in)o)(dcuyi-i
ScooyBBO3
O) 01 t-i
c
- o
CO -H
•H 4-1
CO Rl
O U
E -i-1
CO rH
O -n
U-l
0) Rl
CO M
l-l 4-1
0) rH
> 3
0)
1— 1
Rt
•H
4-1
rj
01
1
0)
14
3
4^
3
1-1
4-1
CO
CU
O
a
•H
lu
as
i
3 Xi
•rt bO
T3 *rt
CU -C
0)
J3
R)
•rt
B
O
O
4-1
T) CO
CU *->
4J l-l
•rt R)
B CO
•rt
i_]
si
CO
e -rt
0 *
u y
M-l RJ
u
M XI
0>
4-> U
rt o
CU 0)
rH -rt l-l
4-1 co co
0
CO
CO
>>
R}
•rt
T3
O
l-l
4-1
y
cu
r- 1
4-1
Rl
O.
CO CO
(Q 01
CO
XI CO
CU 0)
X! y
CO O
'rH a.
rt) CU
CO O
CU CO
rH '4-4
rH O
CU
t
a
3 XI
•rt bO
0) X!
as
s
>T-j
M
01
CO
Rl CU
B *-•
0) U
tripped cond<
may need fu
processing
C/3
CO CU
CO 4-1
01 -O Rl
y B B
O (0 -rt
l-i S
0) 4-1
o rt o
co y
01 -o cu o)
> B Xj *-•
y u o 5
01
bo
E
o.
a.
«rt
l-l
4-1
CO
s
Rl
0)
M
4->
in
03
4-1
c/T bO
f>rt
4-1 0)
O S CO
o y
£r w -B
cu co rt
> 3 bO
y a* o
£
V-25
-------
•o"
3
C
•rl
±J
o
o
in
a
M
3
o
z
• o
r- W
rH H
1
> W
C/J
CM 3
i-J W
Pp W
-^
f^ O
5
^3
0
M
5
1
C/3
Z
O
o
P4
H
pH
t*
CO
4J
c
Ol
O
o
c
CO -H
4-1 4->
CO rd
0 IH
U
O.
X
D
CO
.e rd
*-> 0)
o rd
a
3
•rH
•y
01
ac
a
3
•H
01
g
•rH 0)
o
U w
IH bo
rd c
O.-H
B r-l
o o
y o
y
^
rH 4H
CO S»
0
o
J^
01 CO
> c
0 -H bO
IH -H
<*H -H bO
O rd bO
0
IH O
ft. -O 3
O
C 4J
o
•n bO
4- a
(d *rH
C fH
r^ O
a y
o
o
i
l-i C
01 O
O.-H
a 4J
•O -r-l
01 IH Ol
s: 01 u
co _e
•H b04->
r-H -r-l fd
J3 J3 01
n) x:
4— ' t4
CO O 01
01 U IH
1 3
r-l T3 *J
rH O 01 4-> >
01 *-l
r-l CO 01 -
i c c o.
U rd O 3
01 IH IH 1
ff j-i f-i. rtl
bO N
•rH 4-» H
IH JS C "4H
O rd
b U
CO
CO
01 CO
y c
0 0
Ul -rH
Q. 4-1
rd
to y
3 -H
O rH
U Q.
01 O,
a n)
3
"Z.
bo
C
•H
r— 1
O
o
y
c
•H
*4H
1
IH
•r4
>» 4J
rH O
at a.
•o
•H 0)
3
4-* 4-1
0 3
a
.,_!
I -0
> 01
o s
s
3
•rH
1 T3
> 0)
5S
JJ
4-» O
W -H
3 *w
S ^W
*iH
CO T3
13
•H 0) 01
rH rH X>
O -0
•o o y
o/ a
> 0) rH
rH IH O
0 IH
CO 0) 4-1
w .a e
•rH O
Q O
bO O
C T3
•H >
rH O
O rH
O A
y
IH
01 01
y >
3 O
•O 4J
01
OS
sc3
rd -H
01 C
4-> 4-1
CO v*-l
Of O
•a to
•H
CO
CM
CO
iH
^^
rd
13
•rH
rH
O
09
••
01
y
3
O
V-26
-------
CO
pa
M
P3
/^
g
Q
55
H
&4
CO
Cu
O
o
PM
M
EH
« -j
r N"^'
&*
<1
W t_,
*-\ *^J
0 O
CO
CQ «
CO
•If O
»
53 CO
r*»-
Q*y
fej <~H
"^J
Q
W
EH
3
3
O
OH
M
O
S
PM
1
o!
/— •*
Xl
^X
CO
B
O
rH
rH
RJ
0
14^
o
co
C
o
•rl
rH
rH
•rl
CQ
\^s
CU
CO
S3
J>^
JO
^3
CU
rt
i— i
3
O
l-l
•H
O
04
J_l
CU
4-1
RJ
bO
B
•H
CO
CU
•o
B
O
o
T3
B
RJ
bo
B
•H
1— 1
O
o
1
XI
CO
•rl
rH
XI
R)
CO
U
O
•
O
z
>,
U
4-1
CO
3
T3
r-l
U
CU T3
r-l CU
•rl CU
o r*i
PQ
l-l CU
RJ O
4-1 •!-!
•H >
B l-l
Ri CU
CO 00
l-l
CU
XI
0
bo
•H
M O
•rt i-l
^ 4->
•H
TJ
E
O
O
U
CU
> B
O O
Rj 4-1
CU O Rl
4-" -rl 14
CO l-l CU
4-» B
O CU
CU O
rH
w
CO
co
cu
o
o
l-l
a.
r—l
R)
O
s~\
T>
CU
CO >>
bO at CU
E -^ >
•H U
4-1 cu 3
l-l CO 00
O 3
a. cu •
CU l-l 4J
05 >•» CO
O f'l
CO 14
4-1 -H 14-1
BOO
cu cu
e « x
^^_
cu
T3
O
O
a.
3 U
0 M
14 CO
"*
^-^
•^ i— I -^ CO ^** CO
* m to * o • t i
CO CO ^-^ CM
y^v /»"N ^^V
to i o t o i i
"^ o *.
CO CO •*^-
CM CO ~^"
• p— r^*. vo o -4" i i
rH x^
O^CO CsJ COCT\COO CM
r*** co ^o ^i oo i^ ^5 *^
CM in co vo -** CM o
•t *. *. X.
ff\ co r-i \n
/~\ ^S **X K"~S X"*k /*X ^«\ X*N
£?S ^ ^S«« S
^^ ^ ^^r^,-^ ^
rHin VO CM^OCMO ^
in vo r-i o co -3" in
r-4 CM r-l rH CO
O
CO iH
r-l »->
Rl CU
O XI
•H 4-1
B B
cu x
XI CO
O rH \ rH
in &* R) CO rH CO -^ t4CMcMCMf-l i-J
V> V <
bo R) X) H
14 r-l -n O
^5 Ou (*^ 6~<
CU
O
S
CO
U CU
0 S T3
•rl 41
W J-l 4J
B I-i
O u-l O
IH o a.
r-l CU
RJ i-l i-l
bO CU
n i_j
B e cu
O 3 M
•H E 3
1— 1 4->
rH CU 0
•H X! RJ
B i * ii--|
•s
O >-> E
CM XI Rj
a
E CU CU
•H -H XI
CO rH 4-i
3 0,
• H »v
CO 4-» CU
4-1 r-l O
C 3 -H
CU B >
XI TJ
CO CU 13
-H 4J CU
rH Rl W
XI • rH Rl
Rj >, 3 rH
4J CU O 3
M > V-l O
01 U -H i-i
3 O -H CO
U CO CU O CU
O IJ CU -H
4J CO l-l B
•rt l-l Rj
cu xi cu cu a.
co 4-1 4-1 M a
o m cu o
E > > 0
14 -rl
CU 1*4 M rH
4-1 -O O CU RJ
RJ CU 4-> 3
D« TS CU RJ 13
3 S > -H
M-l rH 3 >
O 0 rH 4) -rt
X O Jrf T3
J>, CU > Rl B
CU 4-> -rt
> CU 41 B
U U XI -rl H-l
3 4) 4J O
OO > 4-1
CO O CO
CO CO Rt E
r^ u w to o
O\ 0) TJ E B -rt
rH CO CU O O 4-1
3 B i-H rH RJ
rH -rt rH rH IH
R) CU 14-1 RJ RJ CU
•rt S CU bo bO 0.
0 3 -O 0
41 rH BE
CX O co 0 0 bO
CO > RJ -rt -H E
> 1-H rH -rl
RJ 1J rH i— 1 CO
rH CU T) -rl -rt 0
oo B r-i
CO O — TJ> «H 14-1 13
E CU r- E -rt O -H
41 rH r~ R) O
O i-l C^ - 41 >
O rH 13 • CO RJ
41 o 4> bO 3
XI £5 i-1 • CU O
4-* RJ -rt Rj 4) l-l 4->
4-* rH ^v
14-1 RJ U 3 •- E T3
O "O Rl 0 T3 O rH
CU i-i 0) -H 4)
3 CO >v -rt 4-1 4J XI
R) *-i ^ O RJ Rl XI
CU E i-l 4) rH r-l 4J
lj 41 CU OC! 3 3 -rl
3 CO 4-< O O >
oa cu R) i-i i-i i-i
U ? 0) -rt -rt Rl
Q« 4-1 O O 4-'
41 >4H RJ CU CU «t
Cd oa O Dl l-l U O
O
e§ ^ ^ ^
o m -o o
CO ^^ ^^ ^^
V-27
-------
w
g
o
^j ^C
%z
3S
&s
^* w
%%
H 5
og
is
o;iH
rH p t/J
> § §
III
£§
pt, 2
is
sS
£*
is
z ^
Bg
u
>H
O
s
O Cfl
fe §
rH rH
(T) CU
O rH
*" 5
O 4-t
o
> VI
o *•
rH C
1*4 TO
i-H
rH Cu
>
y
0 P5
o
CU
rH
y r-s
y O
(y j^
« ^
rH ^
w o
+•> rH
o a,
H
rH
rH CO
O r-t
a,
X
cu
y
4J U
r^ rtl
2 Si
OH bO
C
O 4-1
*fc O
a
cu
I*
o.
rj
0
u
o
4J
rt
rH
O-
CM O VO O
O CO CM O
co O *^ co
vO P- vO 00
in •* rH CO
• • • •
O -* CM CO
r- rH CO O
CO in rH ON
ON in r** rH
vO CM O ON
CM rH rH
CU
•3 £
>, co rH m^r "
y ^ r-» rH co
« ?{
CU O CM ON tH X
y O O CM -* 0
O O 00 -* CO «
1J O CO rH ON »•
fVj co ""St* r*^ 10 "
• • • • £
vo r** LO vO **•*
r-~ONOvo
rH rH CO
W
y
c
Si
>> I- >N
i-H O rH
c c
O <-8 O W
40
co to w G
y y y (d
C 4-. 4J DM
a) co D)
bO (d (d rH
M rH rH rH
O OH CU ^C
r~ O m r~
^Jt O ON ON
-* O CM -»
§O -* m
O ON rH
• • • •
O O CM O
\O ^^ ON CO
vO O r*- O
m o m ON
m co sr ON
CM O CO O
r-~ r*
o o r- r-
rH rH O CM
f~- O -* »H
CM O rH •*
O O r* r-
O O r~I r-I
VO O ON CM
ON P^- P» CM
•< IH X
rH O rH
e e
O u9 O W
CO CO CO C
u y y (d
°C *•> 4-" OH
rti w to
bo (d (d rH
b i-H rH f-H
O O4 0L4
-------
systems is not considered wastewater until it 'leaves the system as blowdown.
As a result of these differences, Table V-19 shows a much lower number of
plants reporting recycle.
The fact that Table V-19 excludes plants that are considered zero dis-
chargers may account for some of this discrepancy, since any plant that recy-
cles 100 percent of its process wastewater would be excluded.
D. WASTEWATER CHARACTERIZATION
1. Conventional Pollutants
A number of different pollutant parameters are used to characterize
wastewater discharged by OCPSF manufacturing facilities. These include:
• Biochemical Oxygen Demand (BOD5)
t Total Suspended Solids (TSS)
• pH
• Chemical Oxygen Demand (COD)
• Total Organic Carbon (TOC)
• Oil and Grease (O&G).
BOD5 is one of the most important gauges of the pollution potential of a
wastewater and varies with the amount of biodegradable matter that can be
assimilated by biological organisms under aerobic conditions. Large, complex
facilities tend to discharge a higher BOD mass loading, although concentra-
tions are not necessarily different from smaller or less complex plants. The
nature of specific chemicals discharged into wastewater affects the BOD5 due
to the differences in susceptability of different molecular structures to
microbiological degradation. Compounds with lower susceptibility to decom-
position by microorganisms tend to exhibit lower BOD5 values, even though the
total organic loading may be much higher than compounds exhibiting
substantially higher BOD5 values.
V-29
-------
Raw wastewater TSS is a function of the products manufactured and their
processes, as well as the manner in which fine solids that may be removed by a
processing step are handled in the operations. It can also be a function of a
number of other external factors, including stormwater runoff, runoff from
material storage areas, and landfill leachates that may be diverted to the
wastewater treatment system. Solids are frequently washed into the plant
sewer and removed at the wastewater treatment plant. The solids may be
organic, inorganic, or a mixture of both. Settleable portions of the
suspended solids are usually removed in a primary clarifier. Finer materials
are carried through the system, and in the case of an activated sludge system,
become enmeshed with the biomass where they are then removed with the sludge
during secondary clarification. Many of the manufacturing plants show an
increase in TSS in the effluent from the treatment plant. This characteristic
is usually associated with biological systems and indicates an inefficiency of
secondary clarification in removal of secondary solids. Also, treatment
systems that include polishing ponds or lagoons may exhibit this characteristic
due to algae growth. However, in plastics and synthetic materials wastewaters,
formation of biological solids within the treatment plant may cause this
solids increase due to the low strength nature of the influent wastewater.
Raw wastewater pH can be a function of the nature of the processes
contributing to the waste stream. This parameter can vary widely from plant
to plant and can also show extreme variations in a single plant's raw
wastewater, depending on such factors as waste concentration and the portion
of the process cycle discharging at the time of measurement. Fluctuations in
pH are readily reduced by equalization followed by a neutralization system, if
necessary. Control of pH is important regardless of the disposition of the
wastewater stream (i.e., indirect discharge to a POTW or direct discharge) to
maintain favorable conditions for biological treatment system organisms, as
well as receiving streams.
COD is a measure of oxidizable material in a wastewater as determined by
subjecting the waste to a powerful chemical oxidizing agent (such as dichro-
mate) under standardized conditions. Therefore, the COD test can show the
presence of organic materials that are not readily susceptible to attack by
biological microorganisms. As a result of this difference, COD values are
V-30
-------
almost invariably higher than BOD5 values for the same sample. The COD test
cannot be substituted directly for the BOD5 test because the COD/BODg ratio is
a factor that is extremely variable and is dependent on the specific chemical
constituents in the wastewater. However, a COD/BOD5 ratio for the wastewater
from a single manufacturing facility with a constant product mix may be
established. This ratio is applicable only to the wastewater from which it
was derived and cannot be utilized to estimate the BODg of another plant's
wastewater. It is often established by plant personnel to monitor process and
treatment plant performance with a minimum of analytical delay. As production
rate and product mix changes, however, the COD/BOD5 ratio must be reevaluated
for the new conditions. Even if there are no changes in production, the ratio
should be reconfirmed periodically.
TOC measurement is another means of determining the pollution potential
of wastewater. This measurement shows the presence of organic compounds not
necessarily measured by either BOD or COD tests. TOC can also be related to
delay. As production rate and product mix changes, however, the COD/BOD
ratio must be reevaluated for the new conditions. Even if there are no
changes in production, the ratio should be reconfirmed periodically.
Tables V-20 through V-27 provide a statistical analysis of raw wastewater
BOD5, COD, TOC, and TSS by subcategory and disposal method. For
multi-subcategory plants, the plants' pollutant values have been
production-weighted for calculation of mean values and selection of median
values. The following equation illustrates the method for calculating the
production-weighted mean concentrations:
Subcategory:
Production-weighted Mean = PiCi + P2C2 + P3C3 + + piCi
p.Tjip. . n
Where:
P. = Decimal subcategory proportion of total plant production for plant
ttl (Range 0 to 1.0)
C1 = Pollutant concentration for plant #1.
V-31
-------
TABLE V-20
SUMMARY STATISTICS OF RAW WASTEWATER BOD CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD
ALL PLANTS THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
DIR/IND THERMOPLASTICS
THERMOSETS
BULK ORGAN I CS
SPECIALTY ORGANICS
DIRECT THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
INDIRECT THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
ZERO THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
KK
# OF
PLANTS
108
44
4
20
51
95
104
1
1
1
2
62
16
4
18
38
53
46
43
26
2
12
40
55
2
1
1
1
1
UUULCK=KKinftKT
# OF PLANTS
(PRODUCTION
WEIGHTED)
65.7538
15.6468
2.1871
13.1475
29.9702
34.9281
60.3664
1.0000
0.0337
0.2863
1.6800
37.1289
4.0231
2.1871
11.1475
21.6020
16.8416
18.0697
27.4570
10.7119
2.0000
7.5305
17.7067
40.5939
0.1680
0.8781
0.8377
0.0935
0.0228
PRODUCTION
WEIGHTED
MEAN
1328.886
1856.433
169.756
921.281
1724.727
1465.540
1320.423
469.000
577.000
577.000
245.745
725.190
1569.784
169.756
904.556
1504.018
1199.871
1347.053
2182.704
2092.435
1014.500
2518.558
1738.854
1353.627
323.534
340.000
280.000
280.000
280.000
PRODUCTION
WEIGHTED
MEDIAN
351.000
572.000
175.000
986.000
679.000
705.000
715.000
469.000
577.000
577.000
20.500
386.000
668.000
175.000
706.200
694.000
668.000
718.000
198.000
453.800
1014.500
679.000
705.000
715.000
340.000
340.000
280.000
280.000
280.000
PRODUCTION
WEIGHTED
STD. DEV.
4634.526
4824.965
11.139
663.397
2284.493
2120.879
1819.967
.
.
,
429.352
830.834
2119.824
11.139
724.331
2009.651
1399.325
2038.317
7093.989
5779.452
40.305
3042.237
2665.783
1766.617
.
.
,
.
B
V-32
-------
TABLE V-21
SUMMARY STATISTICS OF RAW UASTEUATER BOD CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL
METHOD
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
UNKNOWN
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
THERMOPLASTICS
ORGAN I CS
THERMOPLASTICS
THERMOSETS
ORGAN I CS
THERMOPLASTICS
THERMOSETS
ORGAN I CS
THERMOPLASTICS
ORGAN 1CS
THERMOPLASTICS
r
# OF
PLANTS
30
24
62
2
1
9
3
23
17
21
37
1
1
1
KUUUl.CK=OCLUNUM
# OF PLANTS
(PRODUCTION
WEIGHTED)
17.4317
16.6878
55.8805
1 .0567
0.9433
5.6808
2.0319
21.2874
9.1103
14.6559
33.2337
0.5839
0.4161
1.0000
KT
PRODUCTION
WEIGHTED
MEAN
673.612
796.882
920.621
42.073
621 .500
66.951
39.624
58.193
1194.172
901.867
1492.966
7.000
7.000
434.000
PRODUCTION
WEIGHTED
MEDIAN
117.800
304.000
96.900
9.230
621.500
54.500
24.000
41.000
361.000
360.000
451.000
7.000
7.000
434.000
PRODUCTION
WEIGHTED
STD. DEV.
1698.067
1459.787
2228.595
595.622
.
73.167
22.498
75.010
2276.641
1533.251
2758.663
.
.
m
V-33
-------
TABLE V-22
SUMMARY STATISTICS OF RAW UASTEUATER COD CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD
ALL PLANTS THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
DIR/IND THERMOPLASTICS
THERMOSETS
BULK ORGAN I CS
SPECIALTY ORGANICS
DIRECT THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
INDIRECT THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
ZERO THERMOPLASTICS
THERMOSETS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
....... rK
# OF
PLANTS
95
49
4
17
62
79
93
2
1
2
2
56
18
4
15
43
48
41
35
'.9
2
18
28
49
2
1
1
1
1
UUUUCK=rMnRKT
# OF PLAN1S
(PRODUCTION
WEIGHTED)
53.6896
20.3799
2.1871
11.5417
33.9393
27.2478
46.0146
1.0293
0.0337
1.2533
0.6836
32.0356
6.6961
2.1871
9.5417
24.1352
13.7100
15.6944
20.4567
12.7719
2.0000
8.9665
12.1911
29.6138
0.1680
0.8781
0.8377
0.0935
0.0228
PRODUCTION
WEIGHTED
MEAN
3035.613
7497.533
503.405
1657.671
3457.453
4811.004
3362.890
944.575
6912.000
4794.021
6897.501
2429.787
9414.566
503.405
1632.135
2600.765
3291.938
2354.756
3927.833
4870.899
1779.500
6030.363
6553.362
3817.702
22733.387
31105.000
600.000
600.000
600.000
PRODUCTION
WEIGHTED
MEDIAN
1395.000
2709.000
500.000
1501.000
1645.000
2066.000
1772.500
850.000
6912.000
4167.000
6912.000
1425.000
4094.000
500.000
1217.000
1645.000
3092.000
1756.000
1226.800
2394.000
1779.500
2709.000
1435.000
1772.500
31105.000
31105.000
600.000
600.000
600.000
PRODUCTION
WEIGHTED
STD. DEV.
5851.739
10315.211
83.729
1668.644
5075.267
8651.988
5231.467
3269.370
.
2563.254
„
4783.865
11736.815
83.729
1847.690
2737.533
3011.197
2418.299
7041.918
7574.041
393.858
8614.405
12603.269
6242.976
.
.
.
.
.
V-34
-------
TABLE V-23
SUMMARY STATISTICS OF RAW UASTEUATER COD CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
PRODUCER=SECONDARY
DISPOSAL
METHOD
SUBCATEGORY
# OF
PLANTS
# OF PLANTS
(PRODUCTION
WEIGHTED)
PRODUCTION
WEIGHTED
MEAN
PRODUCTION
WEIGHTED
MEDIAN
PRODUCTION
WEIGHTED
STD. DEV.
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
THERMOPLASTICS
THERMOSETS
ORGANICS
THERMOPLASTICS
ORGANICS
THERMOPLASTICS
THERMOSETS
ORGAN ICS
THERMOPLASTICS
THERMOSETS
ORGANICS
THERMOPLASTICS
ORGANICS
24
19
49
2
1
7
1
19
14
18
28
1
1
11.1848
14.2420
45.5732
1.0567
0.9433
3.7185
1.0000
18.2815
5.8257
13.2420
25.9323
0.5839
0.4161
1825.124
3282.064
3126.985
795.978
14115.333
272.776
274.500
377.963
3157.083
3509.187
4710.872
284.100
284.100
800.000
1808.000
636.700
41.000
14115.333
141.000
274.500
248.000
1995.000
2340.000
1698.000
284.100
284.100
26^0.893
3996.106
6883.309
13691.642
219.334
571.528
2823.567
4059.385
8463.117
V-35
-------
TABLE V-24
SUMMARY STATISTICS OF RAW WASTEWATER TOC CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL
METHOD
ALL PLANTS
DIRECT
INDIRECT
SUBCATEGORY
THERMOPLASTICS
THERHOSETS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY OR CAN I CS
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
THERMOPLASTICS
THERMOSETS
COMMODITY ORGAN I CS
BULK ORGAN I CS
SPECIALTY ORGAN I CS
fK
# OF
PLANTS
42
16
7
39
56
55
31
7
7
37
45
41
11
9
2
11
14
UUULCK=KKinHKT
# OF PLANTS
(PRODUCTION
WEIGHTED)
18.9470
4.8893
3.8143
20.6337
23.5709
22.1449
14.5154
1.2449
3. 8143
19.3261
17.6060
14.4933
4.4316
3.6444
1 .3076
5.9648
7.6516
PRODUCTION
WEIGHTED
MEAN
992.384
426.877
475.170
1096.466
989.221
1247.866
1132.305
351.164
475.170
970.419
897.761
1424.170
534.079
452.741
2959.352
1259.177
913.918
PRODUCTION
WEIGHTED
MEDIAN
486.000
349.000
391.200
418.000
484.000
575.000
522.000
349.000
391.200
418.000
358.000
424.000
50.000
654.000
4660.000
505.000
604.000
PRODUCTION
WEIGHTED
STD. DEV.
1997.567
274.541
173.191
1385.640
1749.485
2463.687
2124.494
182.526
173.191
1199.265
1557.493
2965.838
1654.798
322.723
4594.570
2384.023
1120.472
V-36
-------
TABLE V-25
SUMMARY STATISTICS OF RAW WASTEWATER TOC CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
PRODUCER=SECONDARY
DISPOSAL
METHOD
SUBCATEGORY
# OF # OF PLANTS
PLANTS (PRODUCTION
WEIGHTED)
PRODUCTION
WEIGHTED
MEAN
PRODUCTION
WEIGHTED
MEDIAN
PRODUCTION
WEIGHTED
STD. DEV.
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
THERMOPLASTICS
THERMOSETS
ORGAN ICS
THERMOPLASTICS
ORCAN ICS
THERMOPLASTICS
THERMOSETS
ORGAN ICS
THERMOPLASTICS
THERMOSETS
ORGAN ICS
9
7
27
2
1
5
2
13
2
5
13
5.4525
4.7260
24.8216
1.0567
0.9433
2.6737
1.0319
11.2945
1.7221
3.6941
12.5838
349.877
278.596
1478.439
316.970
5644.333
131.137
68.104
174.445
709.665
337.393
2336.539
215.000
78.000
249.000
15.000
5644.333
118.000
68.000
23.800
500.000
145.500
445.000
698.064
365.633
3094.234
5476.268
87.972
3.298
414.016
381.009
403.957
3957.989
V-37
-------
TABLE V-26
SUMMARY STATISTICS OF RAW WASTEWATER TSS CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL SUBCATEGORY
METHOD
ALL PLANTS THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN I CS
BULK ORGAN ICS
SPECIALTY ORGANICS
DIR/IND THERMOPLASTICS
THERMOSETS
BULK ORGANICS
SPECIALTY ORGANICS
DIRECT THERMOPLASTICS
THERMOETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
INDIRECT THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
ZERO THERMOPLASTICS
THERMOSETS
KK
# OF
PLANTS
113
54
3
15
56
92
109
2
1
2
3
55
15
3
13
36
44
37
55
37
2
20
46
69
1
1
UUUbCK-fKinAKT
# OF PLANTS
(PRODUCTION
WEIGHTED)
69.2105
21.9417
1.9756
9.8263
29.1388
37.3944
60.5127
1.0293
0.0337
1.2533
1.6836
32.7511
5.4898
1.9756
7.8263
19.4999
14.5703
13.8871
35.3082
15.5401
2.0000
9.63<>0
21.5708
44.9420
0.1219
0.8731
PRODUCTION
WEIGHTED
MEAN
639.742
822.065
399.500
135.510
378.424
1026.209
526.438
66.792
6103.000
1545.294
2485.942
729.522
1756.192
399.500
158.895
302.818
603.532
381.469
564.396
347.309
44.000
531.376
1281.553
497.827
3181.000
3181.000
PRODUCTION
WEIGHTED
MEDIAN
263.000
212.000
635.000
72.000
157.000
174.000
154.000
63.000
6103.000
196.000
34.700
302.000
1598.000
635.000
156.000
157.000
234.000
194.000
202.000
129.400
44.000
186.000
129.400
151.800
3181.000
3181.000
PRODUCTION
WEIGHTED
STD. DEV.
971.596
1203.909
339.319
126.695
678.674
2990.516
1236.554
131.090
5515.897
4672.420
1115.037
1358.482
339.319
132.934
433.753
913.698
473.399
824.529
739.290
4.243
1028.767
3832.206
1229.205
.
m
V-38
-------
TABLE V-27
SUMMARY STATISTICS OF RAW WASTEWATER TSS CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
DISPOSAL
METHOD
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
UNKNOWN
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
THERMOPLASTICS
ORGAN I CS
THERMOPLASTICS
THERMOSETS
ORGAN I CS
THERMOPLASTICS
THERMOSETS
ORGAN I CS
THERMOPLASTICS
ORGAN I CS
THERMOPLASTICS
t-
# Of
PLANTS
31
25
64
2
1
9
3
,26
18
22
36
1
1
1
KUUUltK-aClUNUH
# OF PLANTS
(PRODUCTION
WEIGHTED)
18.2239
17.7299
58.0462
1.0567
0.9433
5.6808
2.0319
24.2874
9.9025
15.6980
32.3995
0.5839
0.4161
1.0000
KT
PRODUCTION
WEIGHTED
MEAN
121.241
255.721
800.089
25.286
350.000
32.303
38.924
76.918
164.678
283.782
1365.387
14.600
14.600
360.000
PRODUCTION
WEIGHTED
MEDIAN
64.000
168.000
76.700
6.880
350.000
29.000
26.000
38.900
130.000
168.000
173.000
14.600
14.600
360.000
PRODUCTION
WEIGHTED
STD. DEV.
122.123
262.125
4456.709
333.790
.
20.124
19.618
107.027
112.000
266.163
5943.781
.
.
.
V-39
-------
In determining the median, the actual pollutant concentrations, of each
plant that has at least one product within a subcategory are ranked from
lowest to highest. The subcategory decimal production proportions are summed
starting from the lowest concentration plant until the sum equals or exceeds
50 percent of the total of all the decimal production proportions. The
pollutant concentration of the plant whose proportions when added to the
proportion sum causes the total to exceed 50 percent is then chosen as the
median. If, however, the sum equals 50 percent exactly, then the median is
the average of the pollutant concentrations of that plant and the next plant
in the sequence.
Tables V-28 through V-35 also provide raw wastewater statistics for BOD ,
COD, TOC, and TSS by subcategory and discharge technique, but use the 95/70
methodology discussed earlier in this section to aggregrate plants by subcate-
gory. As in previous tables concerning wastewater volumes, these tables are
separated into primary producers and a few zero/alternate dischargers versus
secondary producers and most zero dischargers. For some indirect and zero
dischargers who pretreat their wastewater, the data used are typically from
the effluent of their pretreatment system rather than strictly raw wastewater.
Most indirect dischargers only sample their wastewater at the point where it
enters the POTW collection system. It should also be noted that, as described
in Section VII, the concentrations of pollutants for raw wastewater of the
primary producers that are direct dischargers have been corrected for dilution
by uncontaminated nonprocess wastewater. This correction was not performed on
secondary producers, nor on indirect and zero dischargers.
As with the summary statistics for wastewater flow by subcategory, the
summary statistics for raw wastewater BOI>5, COD, TOC, and TSS concentrations
by subcategory that were generated by the two methodologies compare favorably;
most of the differences between subcategory medians calculated by the two
methodologies fell within the standard deviations calculated by either
methodology. For the reasons stated earlier in this section when discussing
the summary statistics for wastewater flow by subcategory, the Agency has much
more confidence in the accuracy of the summary statistics calculated by the
regression methodology, but has included the summary statistics calculated by
the 95/70 methodology for comparison purposes.
V-40
-------
TABLE V-28
SUMMARY STATISTICS OF RAW WASTEWATER BOD CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS
SUBCATEGORY
DIR/IND
DIRECT
INDIRECT
ZERO
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGAN1CS
MIXED
THERMOPLASTICS
BULK ORGAN ICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
PRODUCER=PRIMARY
# OF
PLANTS
48
5
2
9
U
18
52
74
1
0
1
1
26
2
2
7
9
8
12
45
21
3
2
4
10
39
27
0
1
0
0
1
IKI
MEAN
1088.883
1191.200
169.000
739.244
2099.000
940.156
1263.161
1814.754
469.000
20.500
577.000
647.205
2415.500
169.000
660.600
2209.944
901.625
1534.810
1079.856
1665.240
375.000
1014.500
2304.125
970.980
1211.440
3140.048
MEDIAN
266.500
250.000
169.000
706.200
629.500
393.500
704.500
737.000
469.000
20.500
577.000
380.500
2415.500
169.000
444.000
694.000
264.000
773.500
785.000
138.000
250.000
1014.500
766.500
430.000
694.000
757.000
STD. DEV.
4312.183
1991 .833
8.48S
531.238
2887.453
1074.395
1623.229
3811.602
•
.
810.973
3239.256
8.485
586.126
2959.328
1051.801
2567.712
920.978
6500.336
436. 14S
40.305
3402.801
1147.855
1249.419
6037.743
280.000
340.000
280.000
340.000
V-41
-------
TABLE V-29
SUMMARY STATISTICS OF RAW WASTEWATER BOO CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS.
SUBCATEGORY
DIR/IND
DIRECT
INDIRECT
ZERO
UNKNOWN
THERMOPLASTICS
THERMOSETS
ORGAN ICS
FIBERS
MIXED
THERMOPLASTICS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN ICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
PRODUCER=SECONDARY
# OF
PLANTS
12
13
51
0
14
1
0
1
5
2
20
2
5
11
31
10
0
0
0
0
1
1
0
0
UHKT
MEAN
441.894
623.608
972.029
964.434
9.230
621.500
70.940
39.950
60.801
24.500
900.960
729.727
1559.918
1232.458
7.000
434.000
MEDIAN
161.900
277.000
82.000
302.000
9.230
621.500
54.500
39.950
43.000
24.500
651.000
360.000
451.000
402.000
7.000
434.000
STD. DEV.
705.702
871.510
2327.405
2239.655
•
77.758
22.557
76.557
30.406
938.746
911.519
2848.442
2611.835
•
m
V-42
-------
TABLE V-30
SUMMARY STATISTICS OF RAW WASTEWATER COO COMCEMTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS
SUBCATEGORY
DIR/IND
DIRECT
INDIRECT
ZERO
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGAN ICS
MIXED
THERMOPLASTICS
BULK ORGAN ICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
PRODUCER=PRIMARY
# OF
PLANTS
34
7
2
8
15
11
37
81
1
1
0
1
19
4
2
6
10
5
12
46
14
3
2
4
5
25
33
0
1
0
0
1
1KI
MEAN
2172.459
5773.143
522.500
1132.000
2914.633
2839.545
2658.803
5450.385
850.000
4167.000
6912.000
1774.974
8865.250
522.500
916.167
2579.200
5020.200
2173.000
3254.714
2806.365
1650.333
1779.500
4331.875
393.400
2891.989
7689.313
MEDIAN
1158.000
1700.000
522.500
1000.000
1943.000
598.000
1692.000
2066.000
850.000
4167.000
6912.000
1286.000
6815.500
522.500
710.000
1971.500
3796.000
1544.500
1689.500
455.500
509.000
1779.500
2229.250
500.000
1692.000
2709.000
STD. DEV.
3478.292
7882.793
31.820
875.063
3401.295
3411.839
2746.715
9051.549
,
•
;
1734.512
9586.722
31.820
904.102
2590.289
3896.203
2220.908
5735.796
5074.226
1984.647
393.858
5387.018
238.931
2980.155
11217.300
600.000
600.000
31105.000 31105.000
V-43
-------
TABLE V-31
SUMMARY STATISTICS OF RAW UASTEUATER COO CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
UNKNOWN
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN I CS
KKUUUl,tK:
# OF
PLANTS
8
12
40
0
11
1
0
1
3
1
17
2
4
11
23
7
0
0
0
0
1
0
0
0
=SECONDARY
MEAN
1509.000
3219.000
3007.794
3513.803
41.000
14115.333
245.333
274.500
393.626
243.200
2823.750
3486.682
4940.004
3393.714
MEDIAN
646.000
1753.500
582.500
1364.000
41.000
14115.332
141.000
274.500
248.000
248.200
2247.500
2340.000
1698.000
1808.000
STD. DEV.
2032.859
4181.376
7111.048
4438.984
214.463
587.223
341.957
2234.261
4276.269
8955.829
2962.999
284.100
284.100
V-44
-------
TABLE V-32
SUMMARY STATISTICS OF RAW WASTEWATER TOC CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL SUBCATEGORY
METHOD
• KKUUULtK=f K1WKT
# OF MEAN MEDIAN STD. DEV.
PLANTS
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN ICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
COMMODITY ORGANICS
BULK ORGAN ICS
SPECIALTY ORGANICS
MIXED
11
0
0
3
10
9
16
45
0
0
0
0
8
0
0
3
9
6
10
35
3
0
0
1
3
6
10
0
0
0
0
0
470.470
.
.
472.733
1811.067
637.000
1252.500
1017.778
.
.
.
.
618.396
.
.
472.733
1494.519
758.667
1472.000
994.250
76.000
.
.
4660.000
393.667
886.667
1100.126
.
.
.
.
166.000
.
,
391.200
1088.000
308.000
516.500
505.000
.
.
.
418.000
.
.
391.200
389.000
238.500
408.000
486.000
35.000
.
.
4660.000
500.000
777.000
579.500
.
.
.
.
770.042
.
.
160.829
1860.990
1013.431
2764.300
1774.971
.
,
.
.
868.222
»
.
160.829
1664.006
1254.864
3514.778
1695.554
74.505
.
.
.
195.541
656.135
2128.878
.
.
.
.
a
V-45
-------
TABLE V-33
SUMMARY STATISTICS OF RAW UASTEWATER TOC CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
PRODUCER=SECONDARY
SUBCATEGORY # OF
PLANTS
UNKNOWN
THERMOPLASTICS
THERMOSETS
ORCAN ICS
FIBERS
MIXED
THERMOPLASTICS
OR CAN ICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN ICS
4
22
0
5
1
0
1
2
1
10
2
1
3
12
2
0
0
0
0
0
0
0
0
inunn r — •
MEAN
200.337
259.125
1423. 514
1353.267
15.000
5644.333
143.175
68.000
191.480
61.000
500.000
322.833
2450.208
500.000
MEDIAN
143.175
111.750
259.750
118.000
15.000
5644.332
143.175
68.000
30.400
61.000
500.000
145.500
612.500
500.000
STD. DEV.
216.795
325.740
3144.832
2434.943
•
101.576
m
439.123
80.610
.
367.162
4024.083
707.107
V-46
-------
TABLE V-34
SUMMARY STATISTICS OF RAW WASTEUATER TSS CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS
DIR/IND
DIRECT
INDIRECT
ZERO
SUBCATEGORY
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGAN1CS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
RAYON
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
FIBERS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
THERMOPLASTICS
COMMODITY ORGANICS
BULK ORGANICS
SPECIALTY ORGANICS
MIXED
iULtK=KKJ
# OF
PLANTS
49
7
2
7
10
20
51
84
1
1
1
1
21
3
2
5
6
6
10
43
27
4
2
4
13
40
39
0
0
0
0
1
I»I«K i
MEAN
640.032
1212.000
396.500
117.286
247.658
1358.959
445.072
617.603
63.000
196.000
34.700
6103.000
749.452
2590.333
396.500
146.600
194.222
977.333
404.466
452.398
576.299
178.250
44.000
327.813
1624.552
465.482
593.374
.
.
.
3181.000
MEDIAN
182.000
362.000
396.500
50.000
140.000
124.500
151.800
232.000
63.000
196.000
34.700
6103.000
237.000
2509.000
396.500
72.000
139.000
180.500
193.500
235.000
154.000
155.500
44.000
186.500
83.000
151.400
187.000
.
.
.
.
3181.000
STD. DEV.
1066.040
1425.356
337.290
126.805
251.969
3979.027
1124.192
1020.412
,
.
„
.
1275.399
1035.399
337.290
142.672
143.518
1348.864
528.479
584.672
905.587
154.675
4.243
376.642
4903.910
1245.249
948.802
.
.
.
.
.
V-47
-------
TABLE V-35
SUMMARY STATISTICS OF RAW UASTEWATER TSS CONCENTRATIONS
BY SUBCATEGORY GROUP AND DISPOSAL METHOD
( WITH 95% & 70% RULE )
DISPOSAL
METHOD
ALL PLANTS
SUBCATEGORY
DIR/IND
DIRECT
INDIRECT
ZERO
PRODUCER=SECONDARY
# OF
PLANTS
UNKNOWN
THERMOPLASTICS
THERMOSETS
ORGAN ICS
FIBERS
MIXED
THERMOPLASTICS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANICS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN]CS
MIXED
THERMOPLASTICS
THERMOSETS
ORGAN ICS
FIBERS
MIXED
THERMOPLASTICS
THERMOSETS
ORGANrCS
12
14
53
0
15
1
0
1
5
2
23
2
5
12
30
11
0
0
0
0
1
1
0
0
U AK I
MEAN
98.348
284.270
861.552
157.557
6.880
350.000
29.860
39.450
79.553
36.400
132.800
325.073
1461.083
175.087
U.600
360.000
MEDIAN
49.200
168.000
76.700
130.000
6.880
350.000
29.000
39.450
38.900
36.400
122.000
189.500
165.500
163.000
14.600
360.000
STD. DEV.
112.008
281.031
4663.029
134.590
•
19.646
19.021
109.397
27.719
86.955
283.886
6174.386
127.525
•
f
V-48
-------
2. Occurrence and Prediction of Priority Pollutants
The Clean Water Act required the Agency to develop data characterizing
the presence (or absence) of 129 priority pollutants in raw and treated waste-
waters of the OCPSF industry. These data have been gathered by EPA from
industry sources and extensive sampling and analysis of individual OCPSF
process wastewaters. An adjunct to these data-collection efforts was the
correlation of priority pollutant occurrence with product/process sources by a
consideration of the reactants and process chemistry. This approach offers
the advantage of qualitative prediction of organic priority pollutants likely
to be present in plant wastewaters. A systematic means of anticipating the
occurrence of priority pollutants is beneficial to both the development and
implementation of regulatory guidelines:
• Industry-wide qualitative product/process coverage becomes feasible
without the necessity of sampling and analyzing hundreds of effluents
beyond major product/processes.
• Guidance is provided for discharge permit writers, permit applicants,
or anyone trying to anticipate priority pollutants that are likely to
be found in the combined wastewaters of a chemical plant when the
product/processes operating at the facility are known.
Qualitative prediction of priority pollutants for these industries is possible
because, claims of uniqueness notwithstanding, all plants within the OCPSF
industry are alike in one important sense—all transform feedstocks to
products by chemical reactions and physical processes in a stepwise fashion.
Although each transformation represents at least one chemical reaction,
virtually all can be classified by one or more generalized chemical reactions/
processes. Imposition of these processes upon the eight basic feedstocks lead
to commercially produced organic chemicals and plastics. It is the permuta-
tion of the feedstock/process combinations that permit the industries to
produce such a wide variety of products.
Chemical manufacturing plants share a second important similarity;
chemical processes almost never convert 100 percent of the feedstocks to the
iesired products; that is, the chemical reactions/processes never proceed to
V-49
-------
total completion. Moreover, because there are generally a variety of reaction
pathways available to reactants, undesirable by-products are often unavoidably
generated. This results in a mixture of unreacted raw materials and products
that must be separated and recovered by unit operations that often generate
residues with little or no commercial value. These yield losses appear in
process contact wastewater, in air emissions, or directly as chemical wastes.
The specific chemicals that appear as yield losses are determined by the feed-
stock and the process chemistry imposed upon it, i.e., the feedstock/generic
process combination.
a. General
Potentially, an extremely wide variety of compounds could form within a
given process. The formation of products from reactants depends upon the
relationship of the free enthalpies of products and reactants; more important,
however, is the existence of suitable reaction pathways. The rate at which
such transformations occur cannot (in general) be calculated from first
principles and must be empirically derived. Detailed thermodynamic calcu-
lations, therefore, are of limited value in predicting the entire spectrum of
products produced in a process, since both the identity of true reacting
species and the assumption of equilibrium between reacting species are often
speculative. Although kinetic models can in principle predict the entire
spectrum of products formed in a process, kinetic data concerning minor side
reactions are generally unavailable. Thus, neither thermodynamic nor kinetic
analyses alone can be used for prediction of species formation. What these
analyses do provide, however, is a framework within which pollutant formation
may be considered and generalized.
Prediction of pollutant formation is necessarily of a qualitative rather than
quantitative nature; although reactive intermediates may be identified
without extensive kinetic measurements, their rate of formation (and thus
quantities produced) are difficult to predict without kinetic measurements.
Other quantitative approaches, for example, detailed calculation of an
equilibrium composition by minimization of the free energy of a system,
require complete specification of all species to be considered. Because such
methods necessarily assume equilibrium, the concentrations generated by such
methods represent only trends or, perhaps at best, concentration ratios.
V-50
-------
The reaction chemistry of a process sequence is controlled through
careful adjustment and maintenance of conditions in the reaction vessel. Tfr
physical condition of species present (liquid, solid, or gaseous phase),
condition of temperature and pressure, the presence of solvents and catalyst
and the configuration of process equipment are designed to favor a reaction
pathway by which a particular product is produced. From this knowledge, it
possible to identify reactive intermediates and thus anticipate species
(potential pollutants) formed.
Most chemical transfprmations performed by the OCPSF industry may be
reduced to a small number of basic steps or unit processes. Each step or
process represents a chemical modification of the starting matrials and is
labeled a "generic process." For example, the generic process " nitration"
may represent either the substitution or addition of an "-N02" functional
group to an organic chemical. Generic processes may be quite complex
involving a number of chemical bonds being broken and formed, with the over?
transformation passing through a number of distinct (if transitory) inter-
mediates. Simple stoichiometic equations, therefore, are inadequate
descriptions of chemical reactions and only rarely account for observed
by-products.
Table V-36 lists the major organic chemicals produced by the OCPSF
industry (approximately 250) by process, and Table V-37 gives the same
information for the plastics/synthetic fibers industry. Certain products
shown in Table V-36 are not derived from primary feedstocks, but rather fron
secondary or higher order materials (e.g., aniline is produced by hydrogena-
tion of'nitrobenzene that is produced by nitration of benzene). For such
multistep syntheses, generic processes appropriate to each step must be
evaluated separately. For many commodity and bulk chemicals, it is sufficit
to specify a feedstock and a single generic process, because they are gener-
ally manufactured by a one-step process. Nitration of benzene to produce
nitrobenzene, for example, is a sufficient description to predict constituer
of the process wastewater: benzene, nitrobenzene, phenol, and nitrophenols
will be the principal process wastewater constituents. Similarly, oxidatior
of butane to produce acetic acid results in wastewater containing a wide
variety of oxidized species, including formaldehyde, methanol, acetaldehyde,
n-propanol, acetone, methyl ethyl ketone, etc.
V-51
-------
"wBS
*i*iV^!ln i^'*w
'""iirSciiS
»nt«v I'UKJMI
JSJsi
"SS
.^pr:;':;
apr*° *"'"4ia
I 3PI*''*JV :>l™^^l.p.Jjai
j_ tpluifJlJOJ
*PIHun*j«jo[,o-«
l ";,zs
*u|m"'^T*^'oi
KI | Ul 1 1 uMdU>| ( 141 >• U >1
i4nuK)jn|(iti9rrN I'^^'N'I
*J1U""""l'l"^^'H
I """"J^lS
•^"•I'l *«*|*4>aiO
(auiuriilitiM.) 1)0 *m*f*^?-l ' 1
wwmov
Mqu^Mm^w^rlv'
•wiuiV l*1i¥
^ ^w'"«^J.i«»i-ivn
• |«IO*|O
i «p^p^u^°u
3 ""^I'JS
I«-|'X
'^Ltojd^^i^lu
[Oilio *mH4u.jUi
l**l^l'*!^y^l
leiiAnA^Hl^^d
,«,vo '^j^»j;
l°^OJtw*1
2 *U|»»3i|0
2 Jirujjoio^jjo l*«'l
i°N>*u™p°a
iow'v^^M^S
'""^SSv^SSa
|ow*u»»y-l
'E^s
. i^'"v"
"w™w
„„=,-««.„, »,u
PI3V 3|l|u»llnS
PPV 310vtlu*dt»^
Mni|o i^i'n-r
e ,,,„«, :£Hr£
P(3V 3|WJ«mSH 1^*3-
ppy 3|)X»1Ji»iou!Ui|p>oam]]
PPV 31^J|n"»143
PP 3 "a'^iq
PPV 3||'»
[ ppy HIM
§8
o
o
o
1
•
o
•
o
o
o
0
o
o
0
o
o
o
o
•
o
o
0
o o
o o
o
o
o
o o
o
*
:
o
•
*
0
o
o
o o
*
o o o
0 0
•
• •
o
0
o o
•
0 0
0
9
•
•
o
o
0
o
0 0
o
o
o
o
o
5
1
III L 1? git
§ S \ I : ? 5 5 S I 8 1 i
if u n i I n i n
i § S 3 £ £ £ 5 t i S ; 1
•
•
.
o
o
*
*
' o
o
o
o
o
0
o
o
o
9
•
•
*
o
o
°
o
o
I
*
o
o
•
o
•
o
o
o
f>.
}
I!
, I]
s M § II ij
I i 1 i M H i ! M § !
! E i £ i M H r E -
-------
3
•a
o
.e
O
~i
CO 2
> g
is
.fO O
0)
o
n t
i 3 I
^S
<=
S S
o o
0 O
..
il
Ji
II
II
ti
• o
-------
SNIS3U vaun
SNIS3H U31S3A1Od QSiVaniVSNO
SNIS3U 31V1XU3VH13IAI 1AH13IAI 3N3UA1S
SNIS3H 3QIUQAHNV OI31VW 3N3HAJ.S
Nissu 3N3iavj.na-3N3HAJ.s
SNIS3H NVS
NOAVU
3NOQI10UdAd lANIAAlOd
3QIUO1HO lANIAAlOd
SNIS3H 31VJ.30V lANIAAlOd
SNIS3U OINOdlflSAIOd
3N3HAJ.SA10d
100A19 3N3nAdOHdAXOA1Od
SNIS3H 3N31AdOUdAHOd
31VNVAOOSIia lANiHdlQ 3N31Aai3W OiaSI/VAIOd
SNIS3a 3N31AHi3A1Od
3QIXO 3N31AHJ.3A10d
SNIS3U a31S3AnOd
sasaid asissAiod
SNIS3a 3N3IQVin8A1Od
S3ailftlVA10d
SNIS3U 1V130VA1Od
SNIS3U NOSUVOOUaAH Wn310H13d
NIS3U 99 NO1AN
NIS3U N01AN
11VS NOHAN
SNissa onxaovaoiAi
380101130 1AH13W
SNIS3U 3NIIAIV13lrtl
SNIS3U AXOd3
Sa3iS3 Q3ZiaiXOd3
3DNOdS 3S01im30
aivaiiN 3soimi3o
31V130V 380101130
3NVHdOn30
3SOimn30 1AH13WAXO8HVO
SNIS3U QAX1V
SNIS3U 3ailAI\nAU3V
X31VT OHAUOV
SU38IJ OHAHOV
SNIS3U OIlAaOV
SNIS3U S9V
(fl
(ft
UJ
o
o
cc
0.
0
ffi
Ul
UJ
O
•
•
ADDITION POLYMERIZATION
MASS
•
•
•
•
•
EMULATION
•
•
•
•
•
•
SUSPENSION
•
•
•
SOLVENT
SOLVENT NONSOLVENT
•
•
•
•
4
CC
UJ
I
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
CONDENSATION POLYMERIZATION
£
S.
o
a
in
CO
0)
o
o
0)
c
0)
CO
4-1
U
3
~O
O
S2
UJ 0)
_l ^
QQ IT
0)
J=
•4->
>>
CO
•o
c
CO
o
'^
CO
CO
E.2
>S
o a
a «
I:
s
II
01°
.£ 5
Si
a- a
0 E
O) „,
c «
a. £
V-54
-------
-------
Specialty chemicals, on the other hand, may involve several chemical
reactions and require a fuller description. For example, preparation of
toluene diisocyanate from commodity chemicals involves four synthetic steps
and three generic processes as shown below:
NH.,
This example is relatively simple and manufacture of other specialty chemicals
may be more complex. Thus, as individual chemicals become further removed
from the basic feedstocks of the industry, fuller description is required for
unique specification of process wastewaters. A mechanistic analysis of
individual generic processes permits a spectrum of product classes to be
associated with every generic process provided a feedstock is specified. Each
product class represents compounds that are structurally related to the
feedstock through the chemical modification afforded by the generic process.
b. Product/Process Chemistry Overview
The primary feedstocks of the OCPSF industry include: benzene, toluene,
o,p-xylene, ethene, propene, butane/butene, and methane; secondary feedstocks
include the principal intermediates of the synthetic routes to high-volume
V-55
-------
organic chemicals and plastics/synthetic fibers. Other products that are
extraneous to these routes, but are priority pollutants, are also considered
because of their obvious importance to guidelines development.
Flow charts used to illustrate a profile of the key products of the two
categories were constructed by compositing the synthetic routes from crude oil
fractions, natural gas, and coal tar distillates (three sources of primary
feedstocks) to the major plastics and synthetic fibers. Figures V-l through
V-7 depict the routes through the eight primary feedstocks and various inter-
mediates to commercially produced organic chemicals; Figures V-8 and V-9 show
the combinations of monomers that are polymerized in the manufacture of major
plastics and synthetic fiber products. Also shown in Figures V-l through V-7
are processes in current use within these industries.
These charts illustrate the tree-shaped structure of this industry's
product profile (i.e., several products derived from the same precursor). By
changing the specific conditions of a process, or use of a different process,
several different groups of products can be manufactured from the same feed-
stock. There is an obvious advantage in having to purchase and maintain a
supply of as few precursors (feedstocks) and solvents as possible. It is also
important to integrate the product mix at a plant so that one product provides
feedstock for another. A typical chemical plant is a community of production
areas, each of which may produce a different product group. While the product
mix at a given plant is self-consistently interrelated, a different mix of
products may be manufactured from plant to plant. Thus, a plant's product mix
may be independent of, or may complement the product mix at, other plants
within a corporate system.
The synthetic routes to priority pollutants are illustrated in Figures
V-10 through V-14; these flow charts provide a separate scheme for each of the
following five classes of generic groups of priority pollutants:
1. Nitroaromatic compounds, nitrophenols, phenols, benzidines and
nitrosamines
2. Chlorophenols, chloroaromatic compounds, chloropolyaromatic
compounds, haloaryl ethers and PCBs
V-56
-------
c
J
4
c,
o
C.
1
5
E
C
>
14
C
r
c
_
c
/I O
B 0>
3 0
in
/! T)
H >1 C
/I X C
1) t
3 ^ C
J t
: OT
>iU -
0 — 3
n
d
3
c
c
H
5
>1
H
11
3 M
H IB
H O
D
ei
J
3 rH
3 -H
H O
J
: 6
U 2
31 6
3 i.
3 §
? I
o
o
L
fl
C.
P
I
i
i
q
^
H
J
n
Q
0
3
^
3
I
i
k.
c
c
e
r
r
r
j
4
^
1
1 '
d
B
d
J j
H
^ r
3
J C
r i
^ r
^
H
0 r
J C
i
B
S t.
]
-I
1 *
QJ *
1) C 0) U T
- QJ C 2
TJ N QJ C/i PJ QJ -t
* C rH &] J C
H JD £ U E~i 1 X >H £Q HJ r-
j £ a EH o -J-)
J W 2 CQ M P3 C
I H t
H 00 0
t
i
r-
;
C
f
>i
t t T T
i i i i
* m in w m in
0)
QJ IB rH
H C i-H -H M
H H rH o e e
3 W H >i P O
O > rH 3 P
J 0) (B -rl CQ
| t t t t
.
U
5
H
3
B
J
3
J
a
3
H
J
X
J ^
>
n
H 01
n C
X-H
H i — 1
3 O
H M
u O
11 *
3 6
1) 2
H t
3. i>
3 S
n f
H 0
r-
*,
4
d t
S ',
3 1
j :
5 i-
- S
c
i
r
^
P
'
*
u
J (.
4-
IT
E
d (/) C
5 W >-
d 2 1
D W >
J 1-1 r-
3 >< C
H X O
t
-t
J
J
g
3
-4
j
d
ra
Q)
-P
o
2
(L,
U)
t/] ft — •
A; >iu J
0 M O O
O (1) ft
•P C i-H M
W H IB PH
•O MH U ft
0) ID -H —
(1) >H ft 4->
1H >1 • C
C P W IB
O O> C JJ
-P (D T) O 3
3 C-rlrH
Irt P IB -P rH
0) 0) i
M O H O 4J
H -P -(-I
i-t W (d 4-J i-l
O -H !M C O
n >
•H
4J
O
18
in
P
X
w
c
o
H
4J
iB
C
0)
0>
o
'O
>1
J3
01
Q
C
O
•H
P
HI
rH
>.
X
rH
<
C
0
• H
4->
IB
C
Cl
DI
0
T3
>
r~- co en o T-H
O tJi
>1 -H
o. e
~- 01 >H
DI C O
c •
c -H g
O rH
.. 1)
M rH iH -
o o
IB iw O _
M (U -H (B 18
U in 4J in 0)
•>i O T3
(B IB IB in M
0) (1) 4J T3 -O
P P IB >! >l
W W U X X
(0
V-57
-------
m i IB
0 3
> i-l
O rH
u o
01 ft
o
IB
fc,
x:
ft
•H
O
o
£1
id
u
o
M
0)
M
u
4J
J3
•r-l
ij
•o
111
c
I I I M
It
E-i
a>
4J
(0
c
(U
3 1
3
t
(U
o
u
t
4J 4-1
O -H
3 M
o
"8
o
u
33
ft
o
•H
4J
O
H)
M
4J
X
to
T3
C -H
0 3
iH -H -H
O 4J 3
^ W D1
>4-H -H
d< Q J
D)
C
CM '.£
0
o
O
V-58
-------
melt
Syiv
Gas
Hyd]
Am-<
i — »• chloride
! 5
CO &
:ogen)
->
chloride
•— •> Chloroform*
— •• Carbon*
tetrachloride
Methacrylic acid-
Methyl methacrylate
Generic Processes
1. Chlorination
2. Oxidation
3. Oxo(carbonylation
4. Esterification
5. Hydrochlorination
Notes
Major synthetic route
* Priority pollutant(PRIPOL)
Source: Wise & Fahrenthold, 1981.
Figure V-3
Methane
V-59
-------
* (
U C
O T) 03
C
(
i
•H o 0 x;
^ 0) O 13 4
r
H n
X! M (U
-1 O O 4-1
T3 4-> >< -H 0)
03 rH (Tj
£>i 03 rH W in 0 i
£ 4J 01 Q) O H 4
CO) 4-1 rH O (
0) U (1) OS X! r
H
4
d) 03 c rH o x:
c o oj >i u
QJ -H rH rH X rH (1
^•1 4-1 K*H K** 0 ^1 i
H X! rH
•J U >1
1) -H >H
-> iH O
FH m
rr
SO rH rH
H XI SM
>i
4J U -H 4J 4-1 -H 0)
W < > W W > En
i.
XII _
vU ^
c
0)
i
l*
4-1 T3
0) -H
!*! U
03
CN 4 U
L-rJ
0)— *
U
m
If
Q) QJ
C Tf
(U >i
N X!
* C i 4-1
2 X! QJ
Ed 4-1 U
(0 Ed <
4 1,
i
c
t t
3 CTi
CN
r~
rH
-««
rH
•K
0)
c
03
X!
Q)
O
M
i-
c
rt
rH
o
G
03
x:
4-1
Ed
i
rH
(1) ij
4-> O
O M
04
U — '
H 4J
4J C
Q) 03
rH
00
rH
^
'O
rH
O
XI 4-1 4-1
W
0)
4-1
o
z
4J 3
C rH
M O
ft
X-l
O >i
n 4J
03 -H
S M
0
•H
iH
CU
*
c
(1)
X!
03
Eu
<-3
0
M
•H
^
l(
0)
U
3
O
C
•H
C
o c
•H O
4-1 -H
03 4-1
03
C
in -H
O M
rH O
X! rH
U XI
o u
>H O
T)
X 0)
O Q
0 C
•H O
4-1 -H
03 4-1
C 03
•r-l rJ
0 >1
*> r*H
U 4-1
O U
iH 0)
T) M
>i-H
33 Q
CN
C
O
4-1 C
0) O
O -H
•H 4-1
4H 03
•H T3 rH
iH -H 0
>H
C
o
W -H
H 4-1
W 03
>irH
03
C
>1-H
X M
O O
4-> o -d x:
W ft >i4J X!
W W K W O
EH
W
Ul
0)
W
(/]
OJ
o
o
)H
cu
o
•H
C
O
•H
4J
03
C C
O Q)
•H O> O 4-1
4-1 O -H
03 M
C 0
O -H
C -H 4J
03
03 W
C
03 t)
x: -H x: c
-------
*
"c
c
0
,£
P
r*4
t]
5 I
a c
o a
5 1
3 ;
3 C.
i
*"
r-
<
5
C
5
^
7;
C
n
C
•r
r-
I
H C
) v
: .c
J 4.
J C
: s
*=;
t"
T-
c
I
i
-1
c
c
re
,
ro
tN
u
H
j
3
;
H
c
3
-,
J r-
H C
J C
8 t
r~
j t
H
H 0
X C
-i 0
i 1
J C
D '
: P
(
*
H ^
H
j
5
j —
u
j
(
<
»
!
(
1
C
^
H
3
)
>i
H W
Jl M r-
O C
u x: c
: 4J t
\> 0) I
H >l C
XrH 1
X O (
3 ft C
4 C
U r
3 U
__ _^_ —
)
3
3
H
7
H
3
3
d
J r
3
Q
3 f
~\ C
a
4.
n
*.
I
C
(1
1—
i
X
K
j
4
Ci
r
t
c
r-
j
n
c
3 (
H (
j ;
t) (
i.
j r-
H
H J.
>1 4
-4 t
J
* r
u
r
\ i-
'
.
7
.
C
0
1)
J
3
^
>i
-i
J C
a
i.
H T;
X t
< X
D C
: i.
H C
X r-
: ^
J C
a
£
vl tl
3
H
H
3
d
<
J
H
X
J
d
M
T
M '
H
H
H
J
3
>( 7
S
y
3
H r
a ^
-<
>1
J r
3
Q
r
" f
r
:
H r
-1 i-
f 1
4 C
)
H ^
: o
J C
H J
1, r-
J C.
t
r
r
r*
(
J
(
(
n
f
r-
r-
r
|C
4
U
j
H
-1
D
H +
3
J
H r
>1
H
H
£ «
t
H C
r *
H C
r-
•r
f i
3 T
H C
-1 C
3 ^
x (.
H C
5 <
i
r
H
vl
H
3
5
j
d
H
>1
H
H
<
T >J
H r
H
)
H
D
H
J
£
t
^
C
(
't
u c
H •'
^ 4
J (
J .r
H 4.
3 E
H (.
X
4 1
J (
C T
r
S
W
(1)
0
c
o
•H I
4J T
(0 I
c t
•H i-
0 :
r-l 1
XI
u a
•
rn *s
r~( r
<
C •'
O 4
•H
4J r
o n
CM ffl *
0 >i
•H ,*
U rH
0) < C
C
O rH T
— .
1-3 *•
D O 73
J PL) rH
3 H O
3 Pi X!
-1 CL, 4J
— C
J 4J 0)
H C >H
j re x:
U 4J (d
: 3 fa
J H
3 -H UJ
x O
o ft i
G Pi < L)
• • • •
J1 un vo r~
H rH rH rH
- C
3 O
H -H
J 4J
d cm
H O W
>i --H C
- 4J (1) C
D (0 73 O
a c S c -H
H O -H 0 4J
0 -rH MH O Hi
J 4J -H M
- (0 !H rH 73
73 0) 0 >1
D -H 4-1 73 XI
>< X W rH (U
3 O W < Q
o en o «H CN
rH rH rH
O
•rH
4J
(D C C
2 COO
D C -rH -H -rH
H O ^4 1 ' | '
J -H 73 nj id
D 4J >i C rH
3 (d X! 0) >i
H 73 0 t? X
>< -H IH O O
D X O IH ft
H O rH 73 O
1) ftx; >i -H
i< w u a en
si ro ^* in vo
in o>
^§
£1
3 g-
» 2
LL 0.
V-61
-------
CO
O1
73
- c
(U -H 0)
c E 4J
O (0 (fl
P -H 0) rH
i
* -H T) U
(1) CJ M -r-j Q
-t C C 73 X (fl
t>i i 73 O £
C r-l -H - .C -H 4J
P >i 73 c u a; a)
3) rC (fl (fl (fl C £
4J 4J 0) .
H (U 3 U O rH rH
>1 g X) -H -H >< >1
C ifl >i 0) 4J O, A
P X rH rH 0) O 4J
0)0) O (fl U r-i 0)
5 X &4 S < (US M
(U
O1
0)
•rH
M
4J
•rH
c
&
' -0
Nl CO r~- «:
-1
O
C (U
o ci
P
U
O
(U 14
c a<
U 0) 0) (fl
2 C C 4J U
U (U (fl 3 -H
J 4-> 4-1 « (H
333 I (!)
D CD CQ O C
I (Q 0)
H (N C -H ij
3 O
o .a
M 4J
C
U 0)
•rH ^
4J f-^
(U (fl
.C tl
4-1
C c«
W 0)
I/I
O S
rfl
2 (U
0
3
0
W
C
O C
•H C O
a 4J o -H
O (fl -rH 4-1
•rH N -p (rj
•P -H (0 C
(0 M 73 (U
^H 1) -H D^
T3 E X 0
>1 S O >H
£ rH JH T)
i
Q CM fl4 S3
• • * •
VD f^- CO ^
o a
"H O
4J -H
10 4J C
C (fl 0
C 0) C C -H
O tJi (fl O -P
H O >1-H (fl
1 1 J 1 fj 1 t fy^
(0 73 O (fl *»H
M N M 73 X
T3 43 73 -H O
>i Q) >i x a
B Q a O W
rH (N PO *J* IT)
V)
0)
si
CO
V-62
-------
(U
tJ
TJ
3 i
>* •!•
o t
0 "
I/I
H C
H -r
0 i-
r
41 ^
G 4
4) 4
H [
> <•
H I
o c
H E
t 1
•o
1
U
rH
=
a
•3
01
c
u
H
2
N
c
41
G •=
41
H
O
U
0 C
IH i
V> C
H r-
C r
H >
a
f c
H
i]
5
i]
3
J
3
•H
01
4J
iH
3 (fl
H xi t
J 4-J -r
a si c
d i
J 01
•H U (
H 41
8 4J r-
2 rH f
-> >1 ^
2 XI 4
l4-> S.
I) 41 C
H £ C
U -H t
H Q r
t I
tn
r "=
t
u c
2 C
J C
H f—
x t
<: >
i £
1
•
[
I
w
z,
,J
^
X
i
3
H >
J T
a :
j.
J !
H (
H
8 t
2
J r-
2 (
I 4
3 4
0 4
H C
' ^
J C
5 C
J C
H r~
* r
< >
= C
I)
•4.
-1
3
X
a
j
H
H
0
J
M
r ^
I)
J
>1
*
3
l
i
0
(l
f.
4
^
C
n
Z
1
'
,
O
•H
^_t
4) H
i a
>iE
rH r
O
t
ro
O
•rH
J_j
0) <
£g
o
Oj
•V
1
ro
4)
•H 73
H ^i
•rH XI
G 01
< 73
rH
Iffl
g
0
\_Q tt4
r-j
«
f 01
C
01
N
G
41
O
rH
•H
2
-H T
1
])
a
H
t
j
i
3
;
H
H
3
x i
2
2 4
fl
(
J 1-
H (
1)
H
0
s t
0
(
!
f
i
(
4
(
'
1
1
C
(l
>
fl
i
C
r-
S
(.
\
f O
*
b
2
b
IN
2
b
d
5 tf
a -H
J U
j (fl
fl
H U
3 -H
H Q.
1 -rH
fl T3
J <
IN
1 |_
1
) t
)
2 H
3 0
a (8
< X
) QJ
2 XI
3 0
H rH
X >,
J O
1
5
<
i)
5
H
J
>i
;
j
5
5
I
i
J
41
C
•H
(fl
•r-t
T3
41
C
41 f
rH
>1 r
XI
4J (
— — n 41
H r
(fl
41
ac D
r
1 1
o ;
< C.
I
C"
U
C
H
3
2
U
2
1 -1
fl
H
Q f
^
}
r\
H
3
-UJ-1^—
ij
r t
H rH
1
1
U
I
;
f,
'
i
i
c
'
i
<
V i
5 !
U (
1) >
j e
i/
^^^«
<
u
3 (
-1
< :
3 4
i
u
2 i-
1)
H 4
X 4
1 <
3 S
H
U (
1
r
r
_J
•)
H
1
C
fl
(—
i
c
r
Q
U
u
-1
X
J
n
H
X
2
J
1)
: 4
a c
si
-i
c
4)
D !
3
U 4
H r-
H :
i1 i
j •
1 (J
•4
1
T-
*
r
J
11
3
U
•H
J r
>1 J
0 C
> V
)
B
vj
-4
J c
3 t
^ c
>1 r-
-i i
-J J
J 4
b
f
•)
H
H
fl
H
3
2 (
IJ
2 (
1 4
3 (
H
3 <
H r-
2 ^
J C.
> V
H .-
y
i
H
X
J
J
•
~~ iH
ij 00
g S
M
/l 0) o;
U +J a, T3
2 3 ^ rH
1) O 4J O
•j IH c x;
2 (fl 4J
1) O 4J C
3 -H 3 41
3 4J rH i-l
-l 4) -H XI
3 XI 0 (fl
H 4J Q. b.
2 C
J rX tX »^J
in 4J
•H 01
rJ M Ifl
0 O -H
•r-v-rH S
(fl H
S CM ••
0)
W O
OJ M
0 0
2 * W
O C G
•H G O G O
4J O (2 -rH O -H
Ifl -rH O 4-> -H 4J
O 4J -H (8 4J (0
•H (fl 4J T3 Ifl G
IH >-i (fl 'H 73 -H
•H 73 rH X -H rH
•OJXrXOXO •». IK
•H X! -^ iH O -i C -H
0 fC -H (0
^4 G QJ -M c*3
H O Di (ti -H
--* -H -^ C M
C 4J C 41 41
o m o DI e
•H Ul -H O -H
4-> C 4J S-l 73
U 0> (fl 73 O
3 73 E >t >H
73 G -H x: T)
41 O X 41 >i
D3 U O Q 35
^o r^~ oo CTI o
rH
Ul C
41 G O
W O C -H
Ifl -HO 4-1
41 4_) -H (fl
O O C (0 O -H
>-i -H 01 C -H in
CM 4J D> 01 4J -H
(fl 0 0* (fl iH
U r4 1-1 01 73 0)
•H 4J 73 O -H 4J
i-l -H >iXI X Ifl
01 Z 33 fti O W
G
0)
O rH OJ PO ^* iTt
V-63
-------
Monomer(s)
Plastics
(Resins)
Synthetic
Fibers
styrene • • — ?— —
_
MMM
'
Acrylonitrile* — -
— zacc
-2d-
2cd-
-2d—
i
: •• foiystyrene Kesins
*• Styrene-Butadiene Resins
(Latex)
•» SAJi Resins
»• ABS Resins
Polyvinyl alcohol Resins
+Methyl methacrylate —
;
— 2c— •
— ~M «
Formaldehyde-
Melamine-
Urea-
Epichlorohydrin—1-
Bisphenol A —
Phosgene 1-
Generic Processes
Plastics Polymerization
1. Condensation
2. Addition
a. Mass c. Suspension
b. Solution d. Emulsion
Hydrolysis
-* Polyvinyl acetate Resins '
(Latex)
2c—*• Copolymer 3—4 —
(85% Acrylonitrile)
Acrylic Fibers
-*- Acrylic Resins (Latex)
Acrylic Resins
•*• Phenolic Resins
Melamine Resins
Urea Resins
Epoxy Resins
Polycarbonate Resins
Fibers Spinning
3. Wet
4. Dry
5. Melt
Notes
Synthetic route
* Priority pollutant
+ Variable comonomer
Source: Wise & Fahrenthold, 1981.
Figure V-8
Plastics and Fibers
V-64
-------
Monomer(s)
Terephthalic acid —
Dimethyl terephthalate
Ethylene glycol
Glycerin-
Isophthalic acid-
Phthalic anhydride—
Maleic anhydride
Propylene glycol
Styrene
Acetic anhydride—
i
i
Coumarone-Indene—
Dicyclopentadiene-
•2b-
•2b-
Plastics
(Resins)
•1—» Polyester-
Resins
Alkyd Resins
Unsaturated
Polyester Resin
Cellulose xanthate-
Cellulose acetate-
Petroleum
hydrocarbon Resins
Synthetic
Fibers
Polyester
Fiber
•3-*- Rayon Fiber
•4-*1 Cellulose
acetate
Fiber
ETHYLENE-
PROPYLENE-
•2a—»• LD Polyethylene Resins
•2b—*• ED Polyethylene Resins
•2c—*• Polypropylene Resins — 5—» Polypropylene
Fiber
Vinyl chloride*
•2bcd—•• Polyvinyl chloride Resins
Hexamethylene—*—*• Nylon—1—*• Nylon 66 Resins-
diamine
Adipic acid
salt
Caprolactam-
Tolylene diisocyanate-
Polymeric MBI
Propylene glycol
polyethers
Nylon 6 Resins-
Nylon 66 Fiber
Nylon 6 Fiber
Polyurethane Resins
and Foams
Generic Processes
Plastics Polymerization Fiber Spinning
1. Condensation 3. Wet
2. Addition 4. Dry
a. Mass c. Suspension 5. Melt
b. Solution d. Emulsion
Notes
Synthetic route
Priority pollutant
Source: Wise & Fahrenthold, 1981.
Figure V-9
Plastics and Fibers
V-65
-------
— 01
01 C
C H
g 1
3 4->
O O
:»
c
.
.c
j=
o
,
O.
O
1
m
C)
evo
,-t
M
(fl
•o
£ H
H
c
4)
5,
H
D J
H r
O
H
C
U i
H C
a
i i
N r
N r
iB
01
2
J
a
Q
0
k
rJ
H
)
D
C
J
0
J
u
•g
i
D
D
H
3
H 4J T3 T3
M -H O O
C Z W M
0) 1 O O
B Z Ll Ll
4J 4J
•H -H
Z Z
1 1
Z Z
*3*
H
g Q
ntJ un r—
^ -r
S 01 W
H C Li
>1 -H 01
3 E J-i
U IB W
3 rH Cd
^ < • ^^i
H C rH r
3 0 >,
x: c
H J3
H Q CU C
1
rH
>1 -H
c o e
01 1
r? ^J" «
ft
rM r
r^ *r •«•
01
•o
O
O
? Ir-
C * 0)
O -H ct
N OH
IB C rH
•H dJ -H
. T3 ^= C
P. IB
01 O O
H C H >H
3 01 4-> 4J
3 N -H -H
1) C Z Z
2 O) II
1< ffi cN rg
U-T [
01
C
H
C
1"
01
c
01
N
C
a
0
M
4J
H
Z
-,
«
u
z
Csl
z
u
m
H -H
3 C
•H
T Q
^ E
01 *
•H 'D
rH d
•H 111
d a
IB a
o o
rH IH
•H -H
i T
J"
•K
Q)
c
a>
3
0
O
JJ
•H
c
•H
G
i
4.
fN
L
T
«
u
z
§
J
g
o) o tj
coo
•p Ll
N fl 0
W ft U
•H J
Li o Li o
o e o ft
r-i H d H
IB Ll -H CC
E ft E ft
o
W
tf)
0)
c
(0
(A
o
J2
o
c
0)
(0
0)
ei
u —
H — • 4J
Ll T? .Q W
-u 0) N
Z >i O IB
rH -H 4J
• IB 4J IB
a 4-1 w o
IB 3
•• 0 "B rH
C U 01
01 -O ^~ .*
Cfl H U O
>| U C -H
^ "C "H Z
• -U • C
^ Q) ~ -H
g -U
C 01 C iB
O W O C
•H C H 0)
4-> IB 4-1 Oi
IB Ll O O
T3 Li 3 Ll
•H IB Tl T3
X 01 01 >,
O B! Oi X
in u? r~ oo
0)
J=
a
o
(0
O
CO
O
>i
XI
m
01
fc.
W —
0) C
ui O •*-*
0) -H JJ W
S4-) ITJ -H C
(0 N W O
^( C H >-H
&i H 4-1 i-1 4J
i-j O O tj
O 0 N J-i J-i
S-l X H >l-r-t
Q) U Q I 2
C
V-66
-------
^*
1 — 1
o
O
C.
ft
O
O
rH
t~]
O
CO
4J
c
-
o
rH X
X! C
U ci
CO 4-
x c
c c
E I
0 C
14 t
0 C
J3 X
0 t_
•H -r
EH E-
0)
C
O
N
C
0)
o
J 14
: o
J rH
a x:
: u
i 2
) 4-1
4 CD
) EH
1
-
J CO
»
: CN
j
4 rH
| |
O O
XI .W
CN CN
j CD
: c
> CD
a N
s c
J I
) O
4 X4
O
i x:
) O
4 -H
^ EH
o
CD
O
E
0
IH
O
rH
x;
o
14 OJ
o) x;
x; 4J
>i C
c D
0) X3
x: ft
ft
C ft
ft O
O IH
X!
U
1
rr
* <
rH C
O
C •-
0)
x: c
ft T
o c
IH >-
O C
rH r~
x: x
u c.
X)
CN
*
£
<
4
(
p ;
(
r-
I
c
c
••5
r
jC
r
|
*
i
i
i
i
XI X!
H C *
3 -r4 C]
= rH C
) -.H C
3 C u
1 CO c
3 O 1
^ n i
3 0 C
H rH L
x x; c
JO
H -H JC.
a Q •:
1 -r
r ^ c
*J CN C
I FH jo
3 1 CM
0 II
1 1 cu
i-H C
O -H
C rH
CD H
x; c
ft CO
o o
o o
I— 1 rH
A x;
u u
f
XI
CN
*
J
3
U
4
S
11
3 1
3
4
J (
4 r
: j
j
4 -r
) C
\
rN
C
C
C
c
E
1
c
i
c
*
1
*
u CD
3 C
) (U
3 C
U in cD
3 X)
D--O
-1 14
3 O
H rH
' JC
J O
H -H
3 Q
1
3 e
11
!1
_J
c
4-
CI
I)
: c
D C
j a
3 X
i :
4 '
)
J -5
j
^
c
j
j
3
H
) 0
: c
j a
3 t
1. C
= J
1 c
< E
' ?
f«
Ji
i
i
;
D
•i
J
3
2
5
H
3
H
3
1
•K
C
CD
rH
CO
x:
4J
1 jC
5 co
J C
3 O
S S
3 rH
= x:
) U
CD
4J
3
O
M
U
•H
4J
ID
4J
C
C/}
^4
O
CO
S
J
2
Qi
04
4J ^-
U . 4J
3 ( C
O 4-> 4->
M U 3
0 Tl r-l
U O O
cO O ><
ft O 4->
0 14 14
coo
•H C.-H
",
*'
r-l
00
a\
..
T3
rH
O
X,
c
X!
CO
18
CD
3
CD
U
H
3
0
4J
Ul
i
4J
CrH
-H U
id <
< 4J
. rj
0)
ui e
•H CD
W Dl
> c
rH CO
O M
•d co
>i CD
X Oi
T3
CU
N
><
O
Ul
0)
>H
u
a
o
o
rH
U
CN
1
CO
O
IH
0
£
U
CN
1
ft co c a f> a fl
o o ID ft c o S
14 14 • f-a CD 14 5
o o o e j
Q 0 m
i-l r-l 14 3 O rH S
x: x; o -H e x; S
U U rH T) 5 U ^
II X O L4 1
.t
CN 1 CN
* 1
rH C
O -
C
0)
x: c
"* f U U] (
IJ
J s
.
i
fc-l
J 2
: u
H tS]
4 Z
4 U
: o
04 <
0
-------
3|
-
4.J a 3 1-1
O O T3 •-*
^ a o o
o c o o H
S2
a>
.c
•«->
UJ
(D
O
£ *
30
O) .
TJ rH n-t
o
•a
2
ca
_c
*c
_o
^
u
^ -r -- >
a; >
c s:
a o
i o o — H -
H W M ,;
: H o ,
_ j w ^H •:
i C O >.£ ,.
-I •—I U T
V-68
-------
Q>
•c
£
rtl C
UJ pi-
C C
j 1
Of
s, '
XI -r
ft 4J
O (1)
u) o
M <
3 >i o
J XI <
1
rH
ft
O
iH
ft
O
Ul
H -H
H O
iH «
O iH
i-H Q)
XI XI
U 4J
U U
M IN
JJ —
= W
3 -H
J 43
1
S|
q
1
si
5
d
Q
4J
U
5
rd
1^
m
•d
rH
•K ^
o w
C H
Q) 0)
43 -H
C A Q
' A
'd i *
43 1C
o Q
>H C * rH
o -H (U id
x; • cd »o) 0) 4-1
O CTN O N 42 4->
•H >i C ft O
ft H , -rH x;
oo x; u o
J1 >1
O O -rH iH rH
SH iH 73 O rH
fU Oj < <
K
J, t t
* * 1 n)
0) in a) 1 rsi C
(3 C 1 rH -H
id id I | g
ft ft 1 I id
id 0 o o 1 4J
CTliHtUiH rHl C *
ft -d ft | H— i o a)
O -H O II 1 O H 0)
M tH iH 1 1 rH -H rH
O O O O 0) SH -H
(UrHf-HrH *CC 4-liH
CXiXlXl Ctdd) -H4-J*
(1) CJ U O -H 4-> -H C -H 0)
rH-rH -rH (US-d OCT3
>lQrHQ rHCQld rHO-H
ft 1 >1 1 O 1 4-1 >i 4-1 C
Or^rHro inO3 M UQJIB OU>(
CMrHi |