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TABLE XIX
EFFECTS ON RETURNS ON INVESTMENT
WOOL GLASS FIBER (11)
Plant Size
Capacity
(M metric
Waste Water
Operating Cost
as % of
Predicted affect on
return on investment
if currently at
tons/yr) Treatment Type
200 A
B
HI A
B
9 A
B
2 A
B
Selling Price
.64
.68
1.04
1.11
1.79
1.57
3.83
3.10
5%
a. 7
4.7
4.6
4.5
4.3
4.4
3.4
3.7
IPX
9.5
9.5
9.2
9.1
8.5
8.7
6.8
7.4
15%
14.2
14.2
13.7
13.6
12.8
13.0
10.2
11.1
75
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Figures XVI and XVII compare the costs of water treatment for different
sizes of plants as determined from actual industry calculations and the
estimations by the consultant previously mentioned. As seen* actual
costs lie within or below the limits estimated by the consultant report,
and it can be assumed that the conclusions of the consultant study
general hold true for the entire insulation fiberglass industry.
Further analysis reveals that annual operating and investment of
recycle per annual production rating roughly double from the largest
plant, 200,000 metric tons per year, to plants producing 9,000 metric
tons per year. Eighty-five percent of the insulation fiberglass plants
operate within this range and the relatively small cost variance should
not give the large plants a particular advantage. In fact the largest
plants, which seemingly have the greatest cost advantage, are old plants
which require considerable plant modifications not accounted for in the
economic analysis. The costs of recycle systems increase at a much
faster rate for plants smaller than 9,000 metric tons per year.
However, plants in this size range produce specialty products that sell
for a higher price than the standard building insulation that is most
economically produced by medium and large size plants. The average
price of industrial insulation which includes pipe insulation is UO
percent more than for building insulation. This means that the
percentage cost increase relative to market price should vary less over
the entire range of plant sizes than Figures XVI and XVII indicate. In
fact the smallest primary insulation plant has successfully recycled
chain wash waters for 3 1/2 years.
Non-Water Pollution Effects of the Closed Treatment System
Subsurface disposal of process waters by seepage ponds, has caused
ground water contamination at one insulation fiberglass plant
Evaporation ponds should therefore be lined or sealed. Insufficient
information, regarding spray irrigation with process waste waters,
exists to judge this disposal method.
In the progression from no treatment to recycle systems the industry has
had to contend with increasing amounts of sludges consisting of cullet,
glass fiber - resin masses, particulates removed from stack gases, and
wasted product. Since these solids are in an unusable form, they are
hauled to sanitary landfills. Restrictions at some sites prohibits
burial of phenolic wastes because of the fear of ground water
contamination. One company proposes to autoclave its sludges to insure
complete polymerization of the phenols. It should be emphasized that
the amounts of solid wastes generated by total recirculation system is
no greater than if the industry were to employ alternate end of pipe
waste water treatment technologies.
76
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Total process water recirculation systems have no adverse impact on
air emmissions. In only one case has this been the exception (Plant D).
In this case indequately treated water is recycled as air scrubber water
and may actually transfer contaminants to the air. However, this plant
will soon be installing additional water treatment equipment which
should correct the problem.
The use of high pressure spray water pumps does produce
objectionable levels of noise. However, a fiberglass plant is extremely
noisy, especially in the forming area. The small increment of
additional noise introduced by pumps and other miscellaneous recycle
equipment will not affect the hearing protection measures already
practiced by the industry.
This type of treatment system does affect land requirements. The
treatment systems employed at Plants A and B and proposed at Plant D re-
quire considerable space for flocculating and settling tanks, since low
pressure, high volume wash systems are used. Emergency holding ponds
are desirable but not practicable at many existing urban plants.
Estimated energy consumption for existing and proposed treatment
systems are given in Figure XVIII. As seen from the graph power
requirements are nearly directly proportional to plant size. The
industry considers the extra energy needed to operate water treatment
systems to be minor when compared to the energy requirements of the
fiberglass manufacturing equipment and furnaces.
77
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o
CM
o
H
H
w
,J
o
LLJ
Z
O
g
H
Pn
§
I
w
H
O
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u
Of
N
Z
<
J I
(HV3A/SHnOH iiVMOUX OOO'OOO'l)
78
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SECTION IX
EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION
OF THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE — EFFLUENT LIMITATIONS GUIDELINES
Introduction
The effluent limitations which must be achieved July 1, 1977 are to
'specify the degree of effluent reduction attainable through the
application of the best practicable control technology currently avail-
able. This technology is generally based upon the average of the best
existing performance by plants of various sizes, ages and unit processes
within the industrial category and/or subcategory industry. This
average is not based upon a broad range of plants within the insulation
fiberglass manufacturing industry, but based upon performance levels
achieved by exemplary plants. Consideration must also be given to:
a. The total cost of application of technology in relation to the
effluent reduction benefits to be achieved from such application;
b. the size and age of equipment and facilities involved;
c. the processes employed;
d. the engineering aspects of the application of various types of
control techniques;
e. process changes;
f. non-water quality environmental impact (including energy require-
ments) .
Best practicable control technology currently available emphasizes
treatment facilities at the end of a manufacturing process but includes
the control technology within the process itself when the latter are
considered to be normal practice within an industry.
A further consideration is the degree of economic and engineering
reliability which must be established for the technology to be
"currently available." As a result of demonstration projects, pilot
plants and general use, there must exist a high degree of confidence in
the engineering and economic practicability of the technology at the
time of commencement of construction or installation of the control
facilities.
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Effluent Reduction Attainable Through The Application of Best:
Practicable Control Technology Currently Available
Based upon the information contained in Sections III through VIII of
this report, a determination has been made that the degree of effluent
reduction attainable through the application of the best practicable
control technology currently available is no discharge of process waste
water pollutants.
Identification of Best Practicable Control Technology Currently Available
Best practicable control technology currently available for the
insulation fiberglass manufacturing subcategory is recycle and reuse of
process waters within the operation. To implement this will require:
1. Replacement of caustic baths with pressurized water sprays in
order to clean forming chains of glass fiber and resin. This
has already been accomplished by the industry.
2. The higher the pressures are, the better the cleaning results.
This results in minimizing the use of other cleaning methods
and in the design of smaller treatment systems, since less water
is used.
3. Reuse of chain wash water after suitable treatment.
4. Slowdown from the chain wash system to control dissolved solids
disposed of in the process as overspray, binder dilution water,
or extra - process by evaporation.
5. Incorporation of hood wash water into the chain wash system.
6. Incorporation of other miscellaneous process waters, such as
mandrel cleaning caustic, into the chain wash system.
7. Recirculation of cullet cooling water with blowdown to the chain
wash recirculation system.
This treatment technology is currently being implemented by the
industry with completion expected before the July 1, 1977 deadline.
Rationale for the Selection of Best Practicable Control Technology
Currently Available
Age and Size of Equipment and Facilities
80
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As set forth in this report, industry competition and general
improvements in production concepts have hastened modernization of plant
facilities throughout the industry. This coupled with the similarities
of waste water characteristics for plants of varying size substantiate
that total recycle is practicable.
Total Cost of Application in Relation to Effluent Reduction Benefits
Based upon the information contained in Section VIII of this report,
the industry as a whole would have to invest up to an estimated maximum
of $10,000,000 to achieve the effluent limitations prescribed herein.
This amounts to approximately a 1.2 to 3.8 percent increase in projected
total capital investment, and an anticipated increase of 0.6 to 3.8
percent in the operating cost.
Table XI lists the annual raw waste loads for this industry. About
fifty percent is discharged to publicly owned treatment works. Another
thirty-two percent is retained by existing recycle operations. The
proposed standards would prevent direct discharge of the remaining
amounts of pollutants to navigable streams. In conjunction with the
Pretreatment Standards for existing sources, the standards would
eliminate that portion of pollutants not receiving treatment at publicly
owned treatment works. In addition the proposed regulations would
prevent discharge of pollutants at future plants.
It is concluded that the ultimate reduction to zero discharge of
pollutants outweighs the costs. Presently 32 percent of plants are
achieving no discharge of pollutants.
Processes Employed
All plants in the industry use the same or similar production
methods, the discharges from which are also similar. There is no
evidence that operation of any current process or subprocess will
substantially affect capabilities to implement best practicable control
technology currently available.
Engineering Aspects of Control Technique Applications
This level of technology is practicable because 32 percent of the
plants in the industry are now achieving the effluent reductions set
forth herein. The concepts are proved, they are available for
implementation, they enhance production, and waste management methods
may be readily adopted Lhrough adaptation or modification of existing
production units.
8]
-------
Process Changes
This technology is as an integral part of the whole waste management
program now being implemented within the industry. While it does
require inprocess changes, they are practiced by many plants in the
industry.
Non-Water Quality Environmental Impact
There is one essential impact upon major non-water elements of the
environment: a potential effect on soil systems due to strong reliance
upon the land for ultimate disposition of solid wastes. With respect to
this, it is addressed only in a precautionary context since no evidence
has been discovered which even intimates a direct impact. However,
subsurface disposal of process waste waters from seepage, percolation or
infiltration is not recommended due to possible contamination of ground
waters.
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SECTION X
EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF THE BEST
AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE — EFFLUENT LIMITATIONS
GUIDELINES
The effluents limitations reflecting this technology is no discharge
of process waste water pollutants to navigable waters as developed
in Section IX.
83
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SECTION XI
NEW SOURCE PERFORMANCE STANDARDS
The effluents limitations for new sources is no discharge of process
waste water pollutants to navigable waters as developed in Section IX.
85
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SECTION XII
ACKNOWLEDGMENTS
The author wishes to express his appreciation to various personnel
with the insulation fiberglass industry for their willing cooperation in
providing analytical data, flow diagrams, related information, and
assistance with respect on-site plant visits. In this regard those
persons so cited are: Mr. S.H. Thomas, Director of Environmental
Control, and Mr. George w. Fletcher, Environmental control Specialist,
Owens-Corning Fiberglas; Mr. E.M. Fenner, Director of Technical
Relations, and Mr. G.A. Ensign, Manager of Environmental Control
Engineering, Johns-Manville; Mr. E.B. Norwicki, Manager of Environmental
Control, Certain-Teed Saint Gobain; and Mr. L.T. Powell, Manager of
Process Engineering, Pittsburgh Plate Glass Industries. In addition to
these men and their immediate staff the author also wishes to express
his appreciation to the plant managers and staff at those plants
inspected by EPA for their more than cooperative assistance.
Acknowledgment is given to the Office of Research and Monitoring for
providing contacts in the fiberglass industry through existing and past
Technology Research Projects. Previous Interim Guidance Documents by
the Office Permit Programs have formed a basis upon which this document
was written.
Thanks is given to Ernst Hall, Walter Hunt and Ronald McSwiney of
the Effluent Guidelines Division who spent many extra hours revising the
document. The working group/steering committee members who reviewed
this document in order to coordinate intragency environmental efforts
are Ernst Hall, Effluent Guidelines Division; Taylor Miller, Office of
Enforcement and General Council; Arthur Mallon and Charles Ris III,
Office of Research and Monitoring; James Santroch, National
Environmental Research Center, Corvallis; John Savage, Office of
Planning and Evaluation; J. William Jordan and James Grafton. Office of
Permit Programs; and Robert Atherton, Office of Air Quality Planning and
Standards. Last but not least, appreciation is given to the secretarial
staff of the Effluent Guidelines Division in particular Ms. Kay Starr,
in the typing of drafts, revisions, and final preparation of the
effluent guidelines document.
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Section XIII
BIBLIOGRAPHY
1. Encyclopedia Britannica, "Glass Fibers," Volume 10, William Ben-ton,
Publisher, Chicago, PP. 475-476.
2. Phillips, C. J., "Fiber Glass," The Encyclopedia Americana, Volume
6, Americana corporation. New York, PP. 170-170b.
3. Shreve, R. Norris, Chemical Process Industries, 3rd edition, McGraw-
Hill Book Company, New York, PP. 700-702, (1967).
4. Shand, E. B., Glass Engineering Handbook, 2nd edition, McGraw-Hill
Book Company, New York, PP. 375-410, (1958).
5. Phenolic T_ Waste Reuse by Diatgmite Filtration, Johns-Manville
Products Corporation, Water Pollution Control Research Report,
federal grant number 12080 EZF (September, 1970).
6. Baloga, J.M., Hutto, F.B., Jr., and Merrill, E.I., "A Solution To
The Phenolic Pollution Problem In Fiber Glass Plants: A Progress
Report," chemical Engineering Progress Symposium Series, American
Institute of Chemical Engineers, Number 97, Volume 65, PP. 124-127.
(1968) .
7. Angelbeck, Donald L., Reed, Walter B., and Thomas, Samuel H.,
"Development and Operation of a Closed Industrial Waste Water
System," Owens-Corning Fiberglass Corporation Paper Presented at the
Purdue Industrial Waste Conference, Purdue University, West
Laffayette, Indiana, (May 4, 1971).
8. Fletcher, George W., Thomas, Samuel H. and cross, Donald E.,
"Development and Operation of a Closed Wastewater System For The
Fiberglas Industry," Owens-Corning Fiberglas corporation. Paper
Presented at the 45th Annual Conference, Water Pollution Control
Federation, Atlanta, Georgia, (October 9, 1972).
9. "Welcome to Owens-corning Fiberglas.. .A citizen of Newark., Ohio,"
Owens-Corning Fiberglas Corporation.
10. Helbring, Clarence H., et al, "Plant Effluent - Recycle and Reuse,
PPG Industries, Works t50, Shelbyville, Indiana, "PPG Industries, A
Paper Presented at the Purdue Industrial Waste conference, Purdue
University, West Laffayette, Indiana, (1971).
89
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11. "Initial Economic Impact Analysis of Water Pollution Control Costs
Upon The Fiber Glass Industry," report to Environmental Protection
Agency by Arthur D. Little, Inc., Cambridge, Massachusetts, Contract
No. 68-01-0767, (1973).
12. StandarcLMethods for the Examination of Water and Wastewater, 13th
edition, American Public Health Association, Washington, D. C.
(1971).
13. "Methods for Chemical Analysis of Water and Wastes," Environmental
Protection Agency, National Environmental Research Center,
Analytical Quality Control Laboratory, Cincinnati, Ohio (1971).
1U. "Sewage Treatment Plant and Sewer construction cost Indexes,"
Environmental Protection Agency, Office of water Programs
Operations, Municipal Waste Water Systems Division, Evaluation and
Resource Control Branch.
15. Screening Study for Background Information from Fiber Glass
Manufacturing, Vulcan-Cincinnati, Inc,. Cincinnati, Ohio, prepared
for EPA, Contract number 68-02-0299, (December U, 1972).
16. Water Quality Criteria, 2nd edition, The Resources Agency of
California, State Water Quality Control Board, publication No. 3-A
(1963) .
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SECTION XIV
GLOSSARY
Act
The Federal Water Pollution Control Act Amendments of 1972.
Annual Operating Costs
Those annual costs attributed to the manufacture of a product or
operation of equipment. They include capital costs, depreciation,
operating and maintenance costs, and energy and power costs.
Atmosphere
Unit of pressure. One atmosphere is normal atmosphere pressure, 11.70
pounds per square inch.
Batt
Standard wool mat used for residential insulation.
Best Available Technology Economically Achievable (BATEAL
Treatment required by July 1, 1983 for industrial discharges to surface
waters as defined by Section 301 (b)(2)(A) of the Act.
Best Practicable control Technology Currently Available (BPCTCA)
Treatment required by July 1, 1977 for industrial discharges to surface
waters as defined by Section 301 (b) (1) (A) of the Act.
Best Available Demonstrated control Technology (BADCT)
Treatment required for new sources as defined by Section 306 of the Act.
Binder
Chemical substance sprayed on the glass fibers in order to bond them
together. Synonymous with the terms resin and phenolic resin.
Blowing Wool
Insulation that is either poured or blown into walls. It is produced by
shredding standard insulation mats and is also referred to as pouring
wool.
91
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BOP 5
Biochemical Oxygen Demand, 5 day, 20°C.
Bore-silicate
A type of glass containing approximately five percent boric oxide.
Capital Costs
Financial charges which are computed as the cost of capital times the
capital expenditures for pollution control. The cost of capital is
based upon a weighed average of the separate costs of debt and equity.
Category and Subcategory
Divisions of a particular industry which possess different traits which
affect water quality and treatability.
Caustic
Any strongly alkaline material. Usually sodium hydroxide.
Chain
A revolving metal belt upon which the newly formed glass fibers fall to
form a thick mat. There are two general types of chains: wire mesh
chains and flight conveyors. The latter are hinged metal plates with
several holes to facilitate the passage of air.
cm
Centimeter
COD
Chemical Oxygen Demand
Gullet
Chunks of solid glass formed when molten glass bled from a furnace comes
into contact with water.
Curing
The act of thermally polymerizing the resin onto the glass fibers in a
controlled manner.
92
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Depreciation
Accounting charges reflating the deterioration of a capital asset over
its useful life.
Diatomaceous Earth
A filter media used in this case to remove fine glass-resin particles.
The process of filtration is referred to as diatomite filtration.
Dry,Air Pollution Control
The technique of air pollution abatement without the use of water.
Fiberglass
Extremely fine fibers of corrosion resistant glass of diameters
typically less than 0.015 mm. Also fiber glass.
Flame Attenuation
The glass fiber forming process in which thick threads of glass are
forced through perforated bushings and then reduced in diameter by
burning gases or steam.
Forming Area
The physical area in which glass fibers are formed, sprayed with
lubricant and/or binder, and fall to the chain. A downward forced air
draft is maintained to insure proper binder dispersal and to force the
fibers to the chain.
Glass Wool
The cured fiberglass - resin product. Also referred to as insulation
fiberglass.
gpm
Gallons per minute
Investment Costs
The capital expenditures required to bring the treatment or control
technology into operation. These include the traditional expenditures
such as design; purchase of land and materials; site preparation; con-
struction and installation; etc.; plus any additional expenses required
93
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obring the technology into operation including expenditures to establish
related necessary solid waste disposal.
1
Liter
Lubricant
Usually a mineral oil added to the binder to inhibit abrasion from the
fibers,
Thousand (e.g. thousand metric tons) .
Mandrel
A pipe-line metal form with numerous holes. Serves as a form about
which insulation is shaped to make pipe insulation.
Mat
The newly formed layer of fiberglass on the chain.
mg/1
Milligrams per liter. Nearly equivalent to parts per million
concentration.
MM
Million (e.g. million pounds)
Navigable Waters
The waters of the United States including the territorial seas.
New Source
Any building, structure, facility, or installation from which there is
or may be a discharge of pollutants and whose construction is commenced
after the publication of the proposed regulations.
Operations and Maintenance
Costs required to operate and maintain pollution abatement equipment.
They include labor, material, insurance, taxes, solid waste disposal
etc.
94
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Overspray
Water spray applied to the newly formed glass fivers, the purpose of
which is to both cool the hot glass and to decrease the rate of resin
volatilization and polymerization.
Pack
A fiberglass product made from relatively thick fibers, as compared to
glass wool insulation, that is used for special application (e.g. air
filters and distillation column packing).
ES
A measure in the hydrogen ion concentration in water. A pH of 7.0
indicates a neutral condition. A greater pH indicated alkalinity and a
lower pH indicates acidity. A one unit change in pH indicates a 10 fold
change in acidity and alkalinity.
Phenol Class of cyclic organic derivatives with the basic formula
C*6*H*5*OH
Pretreatment
Treatment proved prior to discharge to a publicly owned treatment works.
Process Water
(i) Any water which comes into rjntact with any glass, fiberglass,
phenolic binder solutions or any other raw materials, intermediate or
final material or product, used in or resulting from the manufacture or
insulation fiberglass and (ii) Non-contact cooling water.
Resin
Synonymous to Binder
Rotary Spun
The glass fiber forming process in which glass is forced out of holes in
the cylindrical wall of a spinner.
Sec
Second. Unit of time.
Secondary Treatment
Biological treatment provided beyond primary clarification.
95
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Silicates
A chemical compound containing silicon, oxygen, and one or more metals.
Staple Fiber
Glass fibers with used short irregular lengths for insulation products
in contrast to continuous filaments used for textile products.
Wet Air Pollution Control
The technique of air pollution abatement utilizing water as an
absorptive media.
96
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TABLE XX
METRIC UNITS
CONVERSION TABLE
MULTIPLY (ENGLISH UNITS) by TO OBTAIN (METRIC UNITS)
ENGLISH UNIT ABBREVIATION CONVERSION ABBREVIATION METRIC UNIT
acre ac
acre - feet ac ft
British Thermal
Unit BTU
British Thermal
Unit/pound BTU/lb
cubic feet/minute cfm
cubic feet/second cfs
cubic feet cu ft
cubic feet cu ft
cubic inches cu in
degree Fahrenheit F°
feet ft
gallon gal
gallon/minute gpm
horsepower hp
inches in
inches of mercury in Hg
pounds Ib
million gallons/day mgd
mile mi
pound/square
inch (gauge) psig
square feet sq ft
square inches sq in
tons (short) t
yard y
0.405
1233.5
0.252
0.555
0.028
1.7
0.028
28.32
16.39
0.555(°F-32)1
0.3048
3.785
0.0631
0.7457
2.54
0.03342
0.454
3,785
1.609
(0.06805 psig +1)1
0.0929
6.452
0.907
0.9144
ha hectares
cu m cubic meters
kg cal kilogram - calories
kg cal/kg kilogram calories/kilogram
cu m/min cubic meters/minute
cu m/min cubic meters/minute
cu m cubic meters
1 liters
cu cm cubic centimeters
°C degree Centigrade
m meters
1 liters
I/sec liters/second
kw killowatts
cm centimeters
atm atmospheres
kg kilograms
cu m/day cubic meters/day
km kilometer
atm atmospheres (absolute)
sq m square meters
sq cm square centimeters
kkg metric tons (1000 kilograms)
m meters
1 Actual conversion, not a multiplier
97
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SUPPLEMENT A
CONSULTATIONS AND PUBLIC PARTICIPATION
Scope of Consultations
Prior to the publication of the Development Document and the
proposed regulations for the insulation fiberglass manufacturing
industry, the following agencies, groups, and corporations were given
the opportunity for comment:
1. All State and U.S. Territory Pollution Control Agencies
2. Ohio River Valley Sanitation Commission
3. New England Interstate Water Pollution Control Commission
4. Delaware River Basin Commission
5. Hudson River Sloop Restoration, Inc.
6. Conservation Foundation
7. Businessmen for the Public Interest
8. Environmental Defense Fund, Inc.
9. Natural Resources Defense Council
10. The American Society of Civil Engineers
11. Water Pollution Control Federation
12. National Wildlife Federation
13. The American Society of Mechanical Engineers
14. Department of Commerce
15. Water Resources Council
16. Department of the Interior
17. Certain - Teed Saint Gobain
13. Johns-f'anville Corporation
19. Owens-Corning Fiberglas Corporation
Industry Participation
The concept of total recycle of process waters was initiated by a
Federal Water Quality Administration research grant (5) in 1968. Further
documentation by the industry (7, 8, 10) further substantiated that
total recycle could be applied to rotary processes.
On July 27, 1972, members of the Enforcement Office and Office of
Refuse Act Programs of the EPA met with representatives of the then
four firms that manufactured insulation fiberglass. The industry was
presented with a draft interim guidance proposing no waterborne waste
discharge by January 1,^1976 as a permit condition.
The industry representatives concurred with the draft regulations.
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Plant inspections were conducted by the project officer during the
month of March, 1973. During this period, the principal water pollution
officials of each of the four firms were consulted. The now existing
three firms were asked to comment on the development document by
June 22, 1973. Two of the companies replied.
The companies were concerned that the no discharge of pollutants
requirement would be applied to plants where both insulation and textile
products are made. The regulations apply only to insulation fiberglass
manufacturing operations.
The industry also requested that boiler blowdowns, water softener
backwashes and noncontact cooling waters be omitted from the no discharge
requirements. The chemistry of the binder is such that it should not be
exposed to certain contaminants (e.g. magnesium and calcium ions) in
boiler blowdown and water softener backwashes. These two waste streams
have been omitted from the definition of process waste waters.
At present, there is no discharge of these waste waters to navigable
waters. In some instances these wastes are discharged to publicly owned
treatment works, but no treatability problems have been reported. The
constituents in these waste waters include dissolved solids, suspended
solids, pH and heat.
Noncontact cooling water is currently recycled and the blowdown
used for overspray or binder dilution at existing exemplary plants.
Industry still has the option of cooling these waters to meet the no
discharge of pollutants requirement. Industry, under Section 316 of
the Act, can be granted less stringent limitations for noncontact
cooling waters if it can be demonstrated "to the satisfaction of the
Administrator that any effluent limitation proposed for the control
of the thermal component of any discharge from such source will require
effluent limitations more stringent than necessary to assure the pro-
tection and propagation of a balanced, indigenous population of shell-
fish, fish, and wildlife in and on the body of water into which the
discharge is to be made." "The Administrator may impose an effluent
limitation under such sections for such plant, with respect to the
thermal component of such discharge (taking into account the interaction
of such thermal component with other pollutants), that will assure the
protection and propagation of a balanced, indigenous population of
shellfish, fish, and wildlife in and on that body of water."
Industry also commented that at plants in urban locations,
insufficient room is available to construct holding ponds for
system upsets and that such upsets may have to be discharged. Because
of the nature of these wastes, no discharge can be allowed to navigable
waters.
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If in the case of process upsets discharges are sent to a
publicly owned treatment works, sufficient pretreatment must be provided
to prevent upsets in the public system and to meet any applicable
pretreatment requirements. It is possible that manufacturing shut-
downs may result from such actions.
Effluent Standards and Water Quality Information Advisory Committee
Comments
Concern over increased air pollution was raised because the blow-
down is disposed of on the hot fiberglass as either overspray or binder
dilution. When used for binder dilution there has been no measurable
increase in air emissions, because the binder has orders of magnitude
more of the same volatile matter. When used as overspray, one company
has experienced air emission problems. Another has not and is currently
practicing this method. The second company maintains a total solids
concentration in its recycled water 10 times less than the first,
accounting for the difference in air emissions.
The committee also questioned whether requiring no discharge of
pollutants by 1977 as best practicable control technology currently
available was really imposing more stringent a requirement than the
Act states. The Act designates no discharge of pollutants as a national
goal to be achieved by 1935. However, this technology is currently
in practice by the industry and has been shown to be economically and
technologically practicable for over three years. No discharge of
process water pollutants does meet the requirements for best practicable
control technology currently available and can, therefore, be set as a
July 1, 1977 requirement.
Other Federal Agencies
No comments were received from other Federal agencies before
July 2, 1973.
Public Interest Groups
The comments received from public interest groups agreed with the
conclusions and recommendations of the development document.
Period for Additional Comments
Upon signature of the proposed rule-making package by the
Acting Administrator, interested persons will have 21 days in which
to comment on the proposed regulations.
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