5859
he Rubber
essing
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, IL 60604-3590
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Tis booklet is about the rubber processing industry and water
pollution. It is intended to help you understand how this indus-
try—and all other industries in the United States—are affected by a law
passed by Congress to reduce and eliminate water pollution.
Because of increasing public concern about this problem, Congress
enacted the Federal Water Pollution Control Amendments in 1972.
To meet the objectives of the law, many industries, including the
rubber processing industry, will have to invest in pollution abatement
equipment or change their processing operations.
The rubber industry employs a third of a million workers and makes
thousands of different products worth a total of $12 billion a year. In
doing so, it also produces 1,380,000 pounds a day of insoluble wastes.
If these wastes are not treated or removed they will cloud the waters
and clog the waterways. Some of these materials decompose in the
water and, in rotting away, use up oxygen that would otherwise sustain
the life of water plants and animals.
The purpose of the law is to clean up the waters of the United States,
but it also requires that economic factors be considered before
standards for waste discharge are set. Additional pollution-control
measures needed by the rubber industry to comply with the new law
total an estimated $78 million initial investment for new equipment
and about $18 million a year in additional operating costs. In many
cases the anticipated cost to individual plants will be insignificant,
and nowhere in the industry are the price rises (predicted on the cost
of pollution control), expected to exceed two percent. Effects on jobs
are also expected to be small; it is estimated that there may be about
a thousand job losses in the entire industry. Most of these can be
taken care of by transfers or normal turnover.
Water-pollution control in the rubber processing industry appears to
present no extreme technical or economic problems, and the industry
is joining with other American industries in the effort to clean up our
waters.
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The Problem
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Without water we could not live;
yet most of us take our water
supply pretty much for granted.
We can get all the water we need
by turning a tap, and when we're
through with it we can pour it
down the drain.
But there are problems. We
have been using our rivers and
lakes as dumps, and as a result,
in most parts of the country
conditions are not too pleasant
down by the riverside. In some
places there may be signs
saying, "Water Polluted. No
Swimming or Fishing." Even
without signs, it may be quite
clear to our eyes and noses that
something is wrong. Population
growth and increased industrial
activity have overloaded the
capacity of the streams to wash
away wastes.
Sources of Pollution
Pollution comes from many
sources—untreated sewage,
storm water runoff, leaks and
spills from pipelines, tanks, and
ships, and factory waste waters.
The effects of pollutants range
from cloudy, muddy water to
offensive smells to conditions
that taint or kill fish and seafood
and sicken humans. Some
pollutants nourish microscopic
organisms that can form scum
or slime or a rapid growth of
algae known as algal blooms,
and these throw the whole
waterlife system out of balance.
Some pollutants, because they
are not easily broken down by
natural processes, build up and
cause slow, long-term poisoning.
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It is impossible to put an
accurate price tag on the cost of
water pollution, but there is no
doubt that it is a large amount. It
is estimated that it costs at least
$13 billion a year for water
purification, damage to fisheries,
and lost recreation.
The Federal
Water Pollution
Control Act
To bring the pollution problem
under control and clean up the
water, the 1972 law provides a
whole new approach to water
pollution control. Under its
provisions, it is illegal for
anyone—a city or town, an
industry, or an individual—to
discharge wastes into the waters
of the United States without a
permit. It is against the law to
use waterways as a dump
To regulate discharges into
the waterways, the Act sets up a
permit-issuing system called the
National Pollutant Discharge
Elimination System (NPDES).
Each State can act as its own
permit-issuing authority if it
wishes; but the NPDES is a
nationwide plan, and States
must have the approval of the
U.S. Environmental Protection
Agency (EPA) for their NPDES
permit plans.
Under the Act, Congress set
up a timetable for reducing
water pollution. The ultimate
goal, to be reached by 1985, is to
eliminate the discharge of any
pollutants into the water. An
interim goal, to be achieved
wherever possible by July 1,
1983, is water that is clean
enough for the protection and
propagation of fish, shellfish,
and wildlife and clean enough
for swimming and other
recreational uses.
To meet these goals, the Act
provides a further timetable for
several other stages of
improved water quality. The first
stage of improvement is to be
reached by July 1, 1977, when
sources of pollution must be
controlled by using the best
practicable control technology
currently available (abbreviated
BPT). By July 1, 1983, the Act
requires further improvement
through the use of the best
available technology
economically achievable
(abbreviated BAT). Because of
this plan for improving pollution
control, the Federal Water
Pollution Control Act has been
called a technology-forcing law.
Industry is being required to use
the best technological means
available to reduce and, if
possible, entirely eliminate
pollution.
Clearly, industries will have to
go to some effort and expense in
order to meet the requirements
of the Act. Plants using
outmoded or ineffective
processes and equipment that
do not control the discharge of
pollutants into the water will
have to install additional control
equipment or change their
processes to meet the BPT or
BAT requirements. In some
cases obsolescent plants or
processes may have to be
scrapped.
Because of the cleanup
requirements, when new plants
are built they will have to be
designed for tighter control of
pollutant discharge. The Act
listed a number of industries,
including the rubber processing
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6 industry, for which particular
requirements for new
construction (new source
performance standards) were to
be developed.
Finally, some plants discharge
their waste water to municipal
treatment plants. The Act also
requires that standards be set for
water delivered to municipal
treatment plants (pretreatment
standards) so that waste
products from an industrial plant
will not interfere with the
performance of the municipal
plant. This could happen if there
were an overload of wastes
beyond the purification capacity
of the municipal plant; if there
were corrosive wastes that could
damage piping and equipment;
or if there were wastes that
could poison the bacterial
cultures used in treating sewage.
In summary, the Act sets out
four standards for controlling
wastes: best practicable
technology currently available
(1977 level); best available
technology economically
achievable (1983 level); new
source performance standards,
and pretreatment standards.
Sometimes separate standards
in all four areas will not be
needed. EPA has found that the
best practicable control
technology currently available in
the rubber processing industry
is sufficiently well developed for
adequate pollution control.
Therefore, for the rubber
industry, no stricter standards
will be made for new sources.
Also for the rubber industry,
only general pretreatment
standards are set, except in
limited cases where the
industrial operations utilize lead,
chromium, or zinc. Projections
of the best available technology
required for the rubber industry
by 1983 are in some cases the
same as BPT but are in other
cases stricter.
How the Standards
are Developed
Congress made EPA responsible
for determining standards and
guidelines for industrial effluent
limitations (the amount of waste
that can be discharged by a
plant). These standards are used
by the permit-issuing authorities
in writing an NPDES permit.
EPA goes through a long and
thorough process before it
makes the standards final. EPA
itself, as well as technical
consultants hired by EPA
perform surveys and studies to
find out what kinds of wastes are
produced by an industry. EPA
and its consultants also study
the processes and equipment
that are available for controlling
industrial wastes to determine if
alternate means can be used to
reduce or recycle wastes. The
data gathered on the production
wastes and the description of the
control measures used in each
industry studied are published in
a Development Document. This
reports on the waste-treatment
processes available to an
industry, determines what the
best practicable technology for
control is, and predicts what the
best available control
technology will be by 1983.
Some particular points
considered in the Development
Document are; the kinds of
waste produced by an industry,
methods of treating waste
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waters, manufacturing
processes, the aging of the
plant, the effects of plant size,
the mix of products
manufactured, the raw materials
used, the effects of geographic
location on plant operation, and
the amount of solid or gaseous
waste produced by a process.
The last point is included
because there would be no
advantage in cleaning up a
water pollution problem while
creating an equally bad or worse
air pollution or solid waste
disposal problem.
In the next stage of
determining standards, EPA
circulates the proposed
Development Document among
concerned industries and
technical experts, including a
technical advisory panel called
the Effluent Standards and
Water Quality Information
Advisory Committee established
by the law, whose membership is
drawn from universities and
industry. Based on the findings
of the Development Document
and the comments from these
various experts, EPA prepares
preliminary standards for
limiting the discharge of wastes.
The preliminary standards are
published in the Federal
Register, and anyone can
comment on them or challenge
the facts, figures, and
procedures used to develop the
standards. EPA considers and
analyzes all comments. If an
objection is valid, EPA modifies
the standard before it is
published in final form. Even
after a standard is finally issued,
the law requires that it be
reviewed from time to time and
revised if necessary.
The Development Document
collects the technical
information required to set
standards for pollution control.
EPA, with the help of
consultants and advisors, also
prepares an economic analysis
of the effects of new control
processes in various industries.
The economic analysis is a study
of how much it would cost to
install new control equipment or
to change to a cleaner
manufacturing process, how this
cost would affect operating
costs and prices of goods
produced, and how plant
operating factors and the labor
market would be affected if
proposed control measures were
used.
The findings of the economic
analysis can also be commented
on or challenged by industry or
any other interested party.
The Rubber Industry
The rubber industry is no
single activity, simple business.
It includes many different
processes such as synthetic
rubber production, the
compounding of different kinds
and grades of rubber, curing and
storage, and the fabrication of
thousands of different
manufactured items. Everybody
in the country uses some of
these products—tires, tennis
shoes, rubber boots, hoses,
belting, gaskets, packing and
sealing, balloons, and hot-water
bottles.
Processes used in synthetic
rubber plants, which are actually
just particular kinds of chemical
factories, are completely
different from those used in tire
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fabrication plants. In its study of
waste production and
processing, EPA found that the
rubber industry was so diverse
that no single set of standards
could be applied fairly
throughout the industry. EPA's
solution to this problem was to
subdivide the rubber industry
into different classes:
Tire and inner tube
Synthetic rubber
Emulsion crumb-rubber
Solution crumb-rubber
Latex-rubber
General molded, extruded, and
fabricated rubber
Small (using less than 8,200
Ibs/day of raw materials)
Medium (using from 8,200 to
23,000 Ibs/day of raw materials)
Large (using more than 23,000
Ibs/day of raw materials)
Reclaimed-rubber
Wet-digestion process
Pan, dry-digestion, and
mechanical processes
Latex-dipped, latex-extruded,
and latex-molded rubber
Latex foam
The classes take into account
differences in the nature of the
plant (such as synthetic rubber
production or manufacturing),
processes used, and, in the case
of fabricated rubber plants,
differences in plant size (smaller
plants are allowed a greater
waste discharge per unit of
production than larger plants).
In the tire and inner tube
subcategory, the age of the plant
is also taken into account, with
plants built before 1959 having
less stringent standards.
Wastes in the
Rubber Industry
Because of the great variety of
processes and operations that
are used in the rubber industry,
it might be expected that the
pollution control problem would
be equally varied and complex.
However, the great variety of
finished rubber, products is
achieved through using different
formulations of the same basic
ingredients, so that the actual
waste products produced are
pretty much the same
throughout the industry,
although different processes
produce different amounts and
therefore require different
standards. Finished rubber is
made from raw rubber—natural
or synthetic—with the addition
of fillers, extenders, and
reinforcers, and a small amount
of curing and accelerator agents,
antioxidants, and pigments. The
most common fillers and
extenders are carbon black and
oils, and they amount to about
one-third the final weight. Most
of these materials get
incorporated into the finished
rubber and are very effectively
locked in, but there are always
some leaks and spills.
In the production of synthetic
rubber there are additional
process steps that complicate
the situation somewhat. These
include processes to recover
unused raw materials, mostly
styrene and butadiene, so that
they can be recycled.
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10 Water is used extensively, in
both synthetic rubber plants and
in manufacturing plants, for
cooling and heating in drums,
rollers, and molds. It is used in
chemical processes in various
treatment, rinse, and wash baths.
It is used to make soapstone
slurries that keep tacky rubber
surfaces from sticking to each
other. And it is used for washing
down work areas.
Some non-water-soluble
wastes are also produced by the
rubber industry. These are
mainly oil and grease from
machinery, spills and leaks of
filler oils, and some organic
solvents.
Pollutants to be Controlled
EPA has decided that the
effluent standards for the rubber
industry should be set in terms
of common pollutants that affect
general water quality rather than
restricting particular chemical
substances. There are three
exceptions to this for toxic
wastes that are produced in
certain subcategories of the
industry. Limits have been put
on lead, used in the manufacture
of lead-sheathed hosing; on
zinc, used in the form of zinc
oxide as a gelling agent for foam
rubber; and on chromium, used
in the form of chromic acid
cleaning baths for forms and
molds.
Other quantities regulated by the
standards are:
Total suspended solids (TSS).
This is the amount of solid
material, from any source, in
waste water. It includes inert,
inorganic materials, such as
sand and clay, and organic
materials like fibers, which
eventually rot away. Fine
particles in water make it cloudy
and muddy and can interfere
with the growth of water plant
organisms by blocking their light
supply. This material eventually
settles to the stream bed, where
it can blanket and kill off bottom
life. Organic wastes can form a
sludge that feeds undesirable
organisms.
Oil and grease. This is a
measure of insoluble
hydrocarbons and oils in waste
water. These pollutants can form
unwanted and harmful coatings
and surface scums, and interfere
with the proper transfer of
oxygen to water life.
pH. This is a chemical measure
of the alkalinity or acidity of
solutions. A pH value of 7
indicates neutrality. Values
below 7 indicate acidity and
those above 7 indicate alkalinity.
A change of one pH unit means
a tenfold change in acid or alkali
concentration. Extremes of pH
or rapid changes in pH can be
very harmful to aquatic life.
Water with a pH below 6 is
sufficiently acid to corrode
pipes, which means not only
damage to waterworks systems
but the introduction of dissolved
metal into the water.
Chemical oxygen demand
(COD). This is a measure of the
ability of a waste material to
react chemically with the
dissolved oxygen in water,
resulting in competition with
aquatic plants and animals for
the air supply.
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12 Biochemical oxygen demand
(BOD). This is another measure
of the ability of wastewater to
use up dissolved oxygen in
receiving waters. It differs from
chemical oxygen demand
because it is a measure of the
oxygen needed to sustain
biological processes in the waste
materials. The abbreviation used
in the standards for the
measured quantity is BODS,
which refers to a specific test
that measures how much oxygen
is used up over a five-day period.
A high value of BOD indicates
the presence of decomposing
materials that may be offensive
in themselves and that may also
feed microorganisms, leading to
such unpleasant symptoms of
environmental imbalance as
algal blooms.
Control Technology
Methods for controlling rubber-
industry wastes are well
developed and there is no need
to invent any radically new
process to meet the standards
set by the regulations.
Control is basically achieved
through waste collection and
treatment. For some kinds of
waste, collection alone, followed
by separate disposal, is
sufficient and further treatment
is not necessary. For instance,
this can be done with soapstone
slurries or latex-dip solutions.
Instead of being flushed down a
drain, the solutions can be
collected and stored for later
reuse or for disposal in a landfill.
Some wastewaters require
further treatment, but in the
rubber industry this is the same
as that used in municipal
treatment plants. It may be
necessary to adjust the acidity of
the wastewater and to use
coagulating agents, like alum, to
settle suspended particles. The
best available technology now
foreseen includes treatment with
activated carbon for removal of
organic chemicals that
contribute to chemical oxygen
demand.
Treatment is often simpler if
different kinds of waste are not
mixed or if they are not diluted
in large volumes of water.
Therefore EPA recommends that
process waste water (that which
has actually been in contact with
the product) and nonprocess
waste water (such as once-
through cooling water, boiler
blowdown, and sanitary and
storm water runoffs) be kept
separate. Additional control
measures may be necessary to
prevent the mixing of waste
streams. This may even involve
such measures as roofing over
yard areas to prevent rainwater
runoff of pollutants.
Ability of the Industry
to Meet the Standards
After this discussion of the
waste produced by the rubber
industry, it should be clear that
there is no serious problem with
hazardous or poisonous
pollutants. Even in the chemical
wastes produced by synthetic
rubber plants there are no
substances present in the water
that require unusual treatment
methods before being
discharged to a municipal waste
treatment plant.
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EPA studies of the rubber
industry indicated that there
would be some difficulties in
installing pollution controls.
When the final regulations were
published for the tire and
synthetic segments of the
industry, it was estimated that 90
percent of the synthetic plants
were already meeting the best
practicable technology controls
called for by the regulation.
However, only 20 percent of tire
and inner tube plants were
meeting standards. When the
regulations for fabricated and
reclaimed rubber plants were
published, 50 percent of existing
plants already met BPT controls.
Spending money on
equipment and processes that
are not directly used for
production frequently concerns
management, labor, and the
public alike. Although EPA is
required by law to take
economic effects into account in
drawing up the guidelines and
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the law uses the words "best
available technology
economically achievable,"
people have expressed concern
about increased costs,
inflationary effects, possible
closing of marginal plants, and
job losses.
Fortunately, studies of the
rubber industry indicate that
these economic impacts will be
very small—for the most part,
unnoticeable. It is difficult to
make estimates for such a
diverse industry, but price
increases to pay for best
practicable technology are
expected to be under half a
percent in the tire segment and
two percent or less in the
synthetic segment. No plant
closings, no community impacts,
no effects on foreign trade, and
no job losses are expected. In
the fabrication and reclaiming
segments, price increases again
are not expected to be more
than half a percent. Some plants
that are about at the breakdown
point could be faced with
operating at a loss and might be
shut down. If they are, this
would result in about 1,000 fewer
jobs, which is not a large impact
in an industry employing a third
of a million people. Some of this
impact is probably due less to
environmental costs than to
general economic conditions.
For instance, the reclaimed
rubber industry has been
decreasing in size in the last few
years.
The Cleanup Program
The control of industrial
pollution is not the only aim of
the Federal Water Pollution
Control Act. The law also
required municipal treatment
plants to meet certain discharge
standards by 1977 and 1983. The
law increased Federal aid to
local governments to help build
sewage treatment facilities, and
established planning procedures
for State and local governments,
in cooperation with the Federal
Government, to control water
pollution from all sources more
effectively. It also streamlined
and strengthened the
enforcement provisions of the
water pollution control program.
Some water quality control
problems are so complex that
they cannot be solved by using
technology alone For this
reason the Act included an
areawide waste treatment
management planning process
under Section 208. This
areawide planning brings
together several aspects of water
pollution control, including
treatment of municipal and
industrial wastes, the issuing of
discharge permits to industry,
and the ways of dealing with
"nonpomt" sources of pollution
such as stormwater runoff, in a
comprehensive approach.
Emphasis is placed upon
planning by local governments.
In sum, the 1972 law provides
formidable new tools "to restore
and maintain the chemical,
physical, and biological integrity
of the Nation's waters "
With the cooperation, hard
work, and investment of
considerable amounts of money
from industries and all levels of
government, progress has
already been made toward
reducing—and eventually
eliminating—pollution in our
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16 rivers, streams, lakes, and
harbors. But much still remains
to be done. Still more money
and effort will have to be
invested if the clean water
program is to be successful—if
we are to have water that is safe
and healthful for drinking, for
use by industry and agriculture,
for swimming and boating, for
fish and wildlife.
To help pay for this cleanup,
Congress set up a construction
grant program in which the
Federal Government will pay up
to 75 percent of construction
costs for treatment plants. The
funding for this program is
expected to rival the Federal
highway program in magnitude.
In fact, costs of treatment plants,
interceptor services, and
combined sewer overflow
control facilities from the
beginning of the program
through 1982 are expected to
total approximately $50 billion.
That's an average of around $5
billion per year, compared to the
$13 billion a year that water
pollution now costs the
American people. Congress felt
that expenditures under the
construction grant program were
essential to deal with a
significant and pressing
environmental problem.
For additional copies of this booklet,
write
Public Information Center (PM-215)
EPA, Washington, D.C 20460
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