he Rubber
       U.S. Environmental Protection Agency
       Region 5, Library (PL-12J)
       77 West Jackson Boulevard, 12th Floor
       Chicago, IL  60604-3590

    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


w^...  .  .;*r iKijJi '"' >,'    .         -nTnal     ^WBf-'

                ^ --w

                         The Problem
           i  .

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.

  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
  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
  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


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

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
  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
  Processes used in synthetic
rubber plants, which  are actually
just particular kinds of chemical
factories, are completely
different from those used in tire


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

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)

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.

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
         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

         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

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.


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
  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.

  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


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

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

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,
Public Information Center (PM-215)
EPA, Washington, D.C 20460


        3&mh  Dearborn
       e*gos Illinois