Pretreatment Of Industrial Wastes Joint Municipal & Industrial Seminar Seminar Handout


v°/EPA
         United States
         Environmental Protection
         Agency
             600R78101
         Technology Transfer
Pretreatment of
Industrial Wastes
Joint Municipal &
Industrial Seminar
                  SLUDGE
                  DISPOSAL
         SEMINAR HANDOUT 1978

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     PRETREATMENT OF INDUSTRIAL WASTES



               SEMINAR HANDOUT



                    1978
         Independent Sessions For


    Municipal  and Industrial Attendees
               Prepared for
   U.S. ENVIRONMENTAL PROTECTION AGENCY

ENVIRONMENTAL RESEARCH INFORMATION CENTER

      CINCINNATI,  OHIO  45268
      U.S. Environmental Protection Agency
      Jegton 5, Library (PH2J)
         West Jackson Boulevard, 12th Floor
             it  60604-3590

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                                 TABLE OF CONTENTS

                                   OF PAPERS


                                                                    Page

   I. Elements of an Industrial Waste Control Program 	   1

  II. The Impact of Toxic Pollutants on Municipal
      Wastewater Systems 	 73

 III. Local Pretreatment Program Requirements 	 135

  IV. Overview Comments Prepared for Environmental Protection
      Agency - Technology Transfer Program 	  164

   V. Effects and Removability of Industrial Pollutants
      In a Municipal System	207

  VI. Addressing the 65 Priority
      Pollutants	 . 304

 VII. Financial Strategies to Alleviate the Costs of
      Compliance With Pretreatment Requirements 	 390

VIII. Case History - City of Grand Rapids, Michigan
      Program of Industrial Waste Control 	 453
                                         11

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ELEMENTS OF AN INDUSTRIAL WASTE CONTROL PROGRAM

                  Prepared For

          Environmental Protection Agency

                Technology Transfer

        Joint Municipal/Industrial Seminar

                       on

         Preatreatment of Industrial Wastes
                      1978
                  Prepared By

            Arnold  S. Vernick,  P.E.
      Manager, Environmental Engineering

             Howard D. Peiler,  P.E.
        Supervising  Environmental Engineer

               Paul D. Lanik, P.E.
        Supervising  Environmental Engineer

     Burns and Roe  Industrial Services Corp,
               Paramus, New Jersey

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FOREWORD

The objective of an industrial pollutant control program within a
POTW system is to assure continuity of treatment, provide physical
protection of collection and treatment facilities, and prevent
the discharge of pollutants from the treatment plant which would
violate NPDES permit conditions or other regulatory requirements.
Recently, additional impetus has been provided for the establish-
ment of viable local programs by the Clean Water Act (CWA) of
1977, which encourages local enforcement of Federal pretreatment
standards.  In order to achieve these objectives and comply with
regulatory requirements, POTW operators must develop comprehensive
programs which address the complex technical, economic, legal,
institutional and environmental factors inherent in industrial
waste control.

This paper presents a detailed review of three of the essential
elements of an industrial waste control program, namely the
development and management of the program, user charge systems,
and monitoring and reporting.  Each element is discussed in
detail, with specific examples and case histories included to
illustrate the principles involved.

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                         TABLE OF CONTENTS


                                                           Page

I.    DEVELOPMENT AND MANAGEMENT OF A CONTROL PROGRAM          8

          Need for the Program                                8
            Regulatory Requirements                           8
            Environmental Factors                            10
            Financial Factors                                10

          Development of a Data Base                         11
            Identification of Industrial Contributors        n
            Preliminary Data Analysis                        13
            Questionnaire Survey                             14
            Detailed Data Analysis                           17
            Sampling Program                                 17

          Legal Aspects                                      18
            Legal Authority                                  18
            Sewer Use Ordinances                             19

          Administration                                    24
            Organizational Structure                        24
            Policy Considerations                           33
            Public Relations                                35

II.  USER CHARGE SYSTEMS                                     36

          Definitions                                        36
            User Charge                                      36
            Surcharge                                        36
            Sewer Rental                                     37
            Industrial Cost Recovery                         37
            Ad Valorem Tax                                   37
            Special Assessment                               38
            Summary                                          38

          Purposes of a User Charge Program                  38
            Clean Water Act of 1977                          38
            State Requirements                               41
            Revenue Production                               41

          System Development                                 4l
            Development of Costs                             41
            Allocation of Costs                              42

          System Implementation                             42
            Example - Buffalo Sewer Authority               42

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                     TABLE OF CONTENTS (Cont.)
III. MONITORING AND REPORTING

          Elements of an Industrial Monitoring Program
            Purposes
            Types of Monitoring

          Field Considerations                              57
            Background                                      57
            Preparation for a Monitoring Visit              57
            Scheduling                                      58
            Sampling and Flow Measurement                   59
            Magnitude of Errors                             60
            Sampling and Analysis for Priority Pollutants   61
            Sample Handling                                 61
            On-Site Safety                                  62
            Equipment Set-Up and Field Analysis             63
            Use of Control Manholes                         63
            Continuous On-Line Monitoring                   63

          Laboratory Considerations                         64
            Background                                      64
            Standard Analytical Techniques                  64
            Analytical Quality Control                      65
            Laboratory Equipment                            65
            Special Analytical Considerations               68
            Personnel and Degree of Expertise               69
            Correlation of Analytical Techniques            69
            Standard Reporting Procedures                   70
            Contracting for Analytical Services             70

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                          LIST OF FIGURES
Figure No.                     Title                        Page

    1        Development of an Industrial Waste Control      12
             Program

    2        Buffalo Sewer Authority Industrial Waste         -1-5
             Survey

    3        Buffalo Sewer Authority Industrial Waste        16
             Survey,  Continued

    4        Conceptual Organization of an Industrial        26
             Wastewater Control Program

    5        Typical Organization of a Large System          27

    6        Typical Organization of a Medium Size System     30

    7        Typical Organization of a Small System           32

    8        Cost Recovery & User Charge System               39
             Under PL 92-500

    9        BSA System, First Year Cost Distribution         49
             Capital and O&M

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                          LIST OF TABLES

Table No.                      Title                        Page

    1        Buffalo Sewer Authority,  Distribution of        45
             O&M Costs by Design Parameters

    2        Buffalo Sewer Authority,  Distribution of        46
             Construction Costs by Design Parameters

    3        BSA System, First Year Capital Cost             47
             Distribution

    4        BSA System, First Year O&M Cost Distribution    43

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                             CHAPTER I
DEVELOPMENT AND MANAGEMENT OF A CONTROL PROGRAM

The development and management of an industrial waste control
program within a POTW system is, in effect, the starting point
for any consideration involving industrial wastes in municipal
systems.  This portion of the paper addresses the needs for the
program, the development of a data base, the legal aspects of a
control program and the factors involved in the administration of
the program.
NEED FOR THE PROGRAM

There are three  major considerations which compel POTW's to
establish local  industrial waste control programs.   The foremost
of these is the  regulatory requirements which have been incor-
porated in Federal and State statutes and regulations.  The other
major needs for a control program relate to environmental and
economic factors, involving protection of POTW facilities and the
surrounding environment, and the generation of income for the
POTW.
Regulatory Requirements


Pretreatment Regulations

The new general pretreatment regulations, 40CFR403,  set forth the
overall regulatory mandate for development and management of a
control program.  Under the CWA of 1977, POTW's are required to
establish local programs by 1983.  In the future, reissued or
modified NPDES permits to POTW's will include requirements for a
control program, if the POTW has a design flow of greater than 5
MGD and receives industrial wastewater that interferes with or
passes through the treatment system.  For smaller POTW's, EPA may
elect to require the development of a program if deemed necessary.
In either case, the POTW pretreatment program must be developed
within three years of the permit modification or reissuance.

The new general pretreatment regulations also outline the elements
that will be required, at a minimum, in an acceptable program.
These required features of the program include:

          Appropriate Legal Authority
          Procedures to assure compliance
          Funding to assure appropriate execution of the program.

Funding for operation of the program may be locally derived, but
EPA will provide incentives in the form of grants to POTW's for
the purpose of establishing the industrial control program.
These financial incentives will be provided under the authority

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of Sections 106, 201 and 208 of the CWA.  Grants providing up to
75% of the cost of developing a POTW industrial waste control
program will be provided.  Under revised construction grant
regulations (40CFR35), funding for the program and actual program
development will be integrated into the construction grants step
process.

Under Section 307 of the Clean Water Act, EPA is specifically
required to develop national, technology-based pretreatment
standards.  The pretreatment standards developed for each in-
dustry will not only consider conventional pollutant parameters,
but will primarily address the control of priority pollutants in
industrial contributions to POTW's.  Currently, EPA is in the
process of developing priority pollutant oriented pretreatment
regulations for indirect discharges from 21 specific industrial
categories.  Under 40CFR403, the program developed by the POTW
will be required to include provisions for local enforcement of
these categorical pretreatment standards.

Also within the regulatory framework is the ability of a POTW,
with EPA1s approval, to grant variances from the national standards
to specific contributors.  The granting of variances will depend
upon the ability of the local compliance program to enforce
pretreatment standards, and a demonstration by the POTW of
pollutant removal capability in its treatment facility.


NPDES Permit for the POTW

Beyond the requirement for development of a control program in
reissued municipal NPDES permits, POTW's must be cognizant of the
impact of industrial contributions on maintenance of overall
permit requirements.  Treatment plant upsets that result in
excessive discharge of compatible pollutants, or pass through pf
incompatible or toxic pollutants to navigable waters, can consti-
tute NPDES permit violations.  A well managed control program is
most often the best remedy for such problems.

The NPDES permit may also require the enactment of an enforceable
ordinance for the control of industrial contributions.  Coupled
with the requirement of obtaining a completed EPA Standard
Form A - Municipal; Section IV form from each major contributor,
the NPDES permit can provide substantial regulatory impetus for
developing an industrial waste control program.


Water Quality Requirements

If State or local water quality requirements for specific pol-
lutants are imposed that are more stringent than the NPDES
permit, development of a control program may be required to
pinpoint the sources of the pollutants in question.  An example

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of such a regulatory need for development of a pretreatment
program is the ocean discharge restrictions imposed on the
Sanitation Districts of Los Angeles County.  Since ocean dis-
charges of specific pollutants are limited under the California
State Ocean Plan, the detailed control program developed by the
County Sanitation Districts essentially originates from the water
quality standards set forth under the Plan.


Environmental Factors

In addition to regulatory requirements, the impetus for a control
program can come from the need to assure maximum environmental
protection.  This protection in turn falls into several cate-
gories.  Assurance of continuity of treatment plant operations is
a central goal.  Within the context of a control program, plant
upsets or interference can be minimized by limiting contributions
of incompatible pollutants or excessive discharge of compatible
pollutants.  Similarly, by controlling generally hazardous dis-
charges that are explosive or corrosive, as well as excluding
materials that might block a sewer, the protection of the physical
POTW facilities can be assured.

In the absence of plant upsets, the contribution of incompatibles
can remain an environmental impetus for the institution of a
control program.  By definition, incompatible pollutants are
those which the POTW was not designed to treat.  If the incom-
patible pollutants are toxic, an adverse impact on receiving
waters can result from their passing through a POTW.  Similarly,
incidental removal of the incompatible pollutant can be detri!
mental to sludge quality, interfering with sludge disposal
operations.


Financial Factors

Industrial contributors, no matter how small, are users of the
POTW facilities.  Their discharges contribute to both capital
costs and operation and maintenance expenses.  In general, the
POTW should look toward each industry in • the system to provide
its proportionate share of these costs.

If a POTW has a Federal construction grant, industrial cost
recovery and user charges are probably being required.  In the
absence of a construction grant, the POTW may employ a user
charge or surcharge program to generate income.  In either case,
an industrial waste control program is a necessary prerequisite
which provides the information necessary for developing appro-
priate charges to industry.
                                 10

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DEVELOPMENT OF A DATA BASE

The development of an accurate data base upon which an industrial
waste control program can be established, is perhaps the most
significant step in the evolution of a viable program.  The
information obtained in this exercise will form the basis for
specific stipulations in the ordinance for industrial use of
sewers, and for the user charge system.  It also will be of
significant importance in the eventual enforcement of the pro-
visions of the ordinance.

The development of a data base is accomplished by means of an
industrial waste survey, which can be approached in three distinct
ways.  Common to all three approaches, is the identification of
the industries using the system.  Once identified, the first
method then estimates the specific industrial contributions from
waste characteristics published in literature.  The second
method goes one step further by requiring that all significant
contributing industries submit to the POTW, analysis of their
waste streams for review.  The third method differs from the
second in that the POTW itself samples and analyzes each dis-
charge from a significant contributor.

The third method is always preferred, in that it will provide the
most accurate and unbiased data.  By scheduling sampling and
analyzing the industrial waste stream itself, the POTW minimizes
the possiblity of the results being obtained on non-typical
production days or having some of the discharge and flow data
omitted. Although this method requires the POTW to commit the
most resources to the survey, in the final analysis the invest-
ment will be more than justified by the accuracy and reliability
of the data obtained.

Regardless of which method is ultimately selected, the conducting
of an industrial waste survey is invariably a phased operation.
An example of an approach to the survey is shown in Figure 1,
which depicts the development of the industrial waste control
program for the Buffalo Sewer Authority in Buffalo, New York.
The industrial waste survey segment of the entire program is
outlined by a dashed line on the chart.  In this instance, a
three phased approach was used, consisting of identification,
cross section sampling and follow-up sampling.  Typically, an
industrial waste survey must begin with identification of the
industrial contributors, and then proceed through preliminary
data analysis, a questionnaire survey, detailed data analysis and
a sampling program.


Identification of Industrial Contributors

The objective of the initial task in the industrial waste survey
is the compilation of a master list of industrial and commercial
contributors within the POTW system.  In developing the inven-
tory, the approach should be to make the list as all-inclusive as
                               11

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possible, since insignificant dischargers can always be elimi-
nated at a subsequent point in time. Factors of interest for the
initial identification include location of the industrial facility,
Standard Industrial Classification (SIC) designation for the
facility, product line, production volume, indication of whether
the industry is wet or dry, and if wet, the water usage.

For the small municipality, identifying contributors within the
wastewater collection system is usually an easy task. The plant
operator, or the system's superintendent, is generally familiar
with the area served, and the contributors within it. For
larger systems, and those small systems where this familiarity
does not exist, identifying industrial contributors can be more
complex. The location of wastewater sources can be accomplished
by using the various listings of commercial establishments that
are available to the public. Such listings include:

Existing Sewer Authority Files
City and State Industrial Directories
Labor Department Records
Property Tax Records
Chamber of Commerce Rosters
Census Bureau Records
Local Telephone Directory
Water Consumption Records
Dun's Market Identifiers - Dun & Bradstreet
Preliminary Data Analysis

This phase of the survey consists of analyzing the data obtained
in the identification phase, and utilizing it to serve as the
basis for the questionnaire survey which follows. The master
list of industries should be reviewed to eliminate dry industries
from further consideration, and to tentatively identify the
significant dischargers within the system.

A preliminary breakdown between major and minor contributors
generally can be made on the basis of flow, which in turn can be
estimated from water usage. In addition to consideration of
flow, the municipality must decide, on the basis of specific
other factors in the POTW system, which industrial facilities to
consider significant contributors. A minimum flow value, such as
25,000 or 50,000 GPD should be used as a first step in a major-
minor delineation. However, other factors including water
quality standards, and the POTW1s sensitivity to a particular
type of wastewater, must also be taken into account.

Establishing a reliable list of significant contributing in-
dustries on this basis ultimately requires direct contact with
industry, and detailed analysis or evaluation of each plant's
wastewater. Nevertheless, at this stage of the survey, any
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industrial discharge suspected of having such characteristics
should be tentatively classified as significant.

The final list of industries to be included in the questionnaire
phase of the survey should as a minimum include all significant
dischargers, which will automatically encompass facilities
subject to Federal pretreatment regulations. If POTW resources
permit, the questionnaire should be mailed to the most inclusive
list of industries possible, in order to preclude the possibility
of missing any significant dischargers.

Questionnaire Survey

This phase of the overall industrial waste survey is essential to
confirm the data previously obtained from the various sources of
information used in the identification of industrial contributors.
The development of a questionnaire form should consider the
degree of detail desired, which usually relates to the size and
complexity of the POTW system. As a minimum, information should
be requested on production, employment, water usage, the number
and location of sewer connections, wastewater discharge character-
istics and historical analytical data. If Section IV of NPDES
Standard Form A has not yet been completed for each major discharger
in the system, it can be conveniently attached to the questionnaire.

Figures 2 and 3 illustrate the first two pages of the question-
naire utilized by the Buffalo Sewer Authority (BSA). The third
page of the BSA questionnaire related to the chemical analysis of
the plant's discharge and was only applicable to historical data.

BSA's experience regarding responses to the questionnaire indicated
that telephone follow-up as a minimum is essential to obtaining
meaningful information. They employed a newspaper campaign
during this phase of the survey to acquaint industry with the
program and to stimulate cooperation. A public relations effort
of this sort should be incorporated into the program if possible,
making use of radio and television as well as newspapers to
inform and solicit cooperation.

Despite this effort, plans should be made for direct telephone
contact with a major portion of the industrial community.
Additionally, plant visits to industries which require help in
completing the forms should also be planned as part of the
program. The Buffalo Sewer Authority's experience was that
approximately 40% of the establishments returned the question-
naire with some reminding by phone; 30% of the questionnaires
were completed over the phone, and the remaining 30% of the
questionnaires were completed by plant visits. In a similar
survey conducted by the East Bay Municipal Utility District of
Oakland, California, 60 percent of the industries receiving a
questionnaire voluntarily returned the completed form to the
District.
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Figure 2.
BUFFALO SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
Sheet 1 of 3
Sic*
Map#
Loc#
S.D.
(For BSA use only)
Company Name_

Addre s s
Representative,
Title
Phone No.
Hours of operation/day_
_Days of operation/week.
No. of employees: Shift No. 1_
Shift No. 2
Shift No. 3
Type of Business: (Manufacturer, Distributor or Retail)

RAW MATERIALS
AMOUNT PER YEAR
PRODUCTS
AMOUNT PER YEAR
Type of Process: Continuous

Industrial Wastes:

What waste products are disposed to: Sewer.

Is discharge to sewer: Intermittent__

Quantity/day
Batch
Other
Steady
Est. or measured
Are wastes pretreated? If so, which and how:_,

Plant Sewer Connections to BSA

Size & Shape Material Location in Plant

(1) __.„___
Connected To
(2)
(3)
Are maps showing sewer connections available ?_
ADDITIONAL INFORMATION TO BE SUPPLIED ON YOUR LETTERHEAD.
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Figure 3.
BUFFALO SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
Sheet 2 of 3
ANNUAL VARIATION.IN OPERATION
Is there a scheduled shutdown?
Is production seasonal?
If so:
Period of full production
If not:
WATER USE
Source (s) of water
Period of limited production.
Period of no production _
Employees (No.) Max.
Min.
Average # of employees
If from an agency, Account #_
Water used for:
Sanitary
Air Conditioning
Process water
Jacketed cooling water
Other
Period of max. water use_
Period of mln. water use
Water disposal other than sewer_
Is water consumed in product?
Type and number of air pollution devices.
When?
to
to
.to
% of time at max..
% of time at min.
gpd
gpd
gpd
gpd
Amount
Amount
% of total
Amount/day.
Have the waste streams been previously analyzed?.
Are radioactive isotopies used in your process?
Specify:.
Recirculated
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Detailed Data Analysis

Analysis of the data obtained through the questionnaire survey
should be primarily aimed toward delineation of those industries
to be included in the sampling program. This task essentially
involves confirmation and/or correction of the original industry
data by means of a detailed analysis of the questionnaire responses,
Such preliminary information as wet or dry industry, SIC classi-
fication, flow, production volume, etc. should be updated for
each industrial facility submitting a completed questionnaire.

Another important task in this phase of the work is the review of
wastewater data submitted by the industry. This information may
in many instances constitute the first data available on the
characteristics of the discharge from a specific facility. In
municipalities where there has not been a previous enforcement
program, industries in general know very little about their
wastewater characteristics. The questionnaire program provides
the incentive for them to discover the strength of the wastewater
that they are discharging to the sewer system, and any problems
and difficulties that are encountered in obtaining a representa-
tive sample of wastewater. These data also provide the basis for
the POTW to decide which pollutant parameters require monitoring
in the subsequent sampling program.

Sampling Program

The sampling program constitutes the last and perhaps most
important phase of the development of a data base for industrial
contributors to a POTW system. A subsequent section of the paper
is devoted to specific aspects of monitoring and reporting, so
that a detailed discussion of the subject is not necessary here.

Nevertheless several significant points regarding the sampling
program must be emphasized. The first relates to planning and
scheduling, which should be thoroughly addressed prior to the
start of the program in the field. It is essential that the
initial sampling program obtain accurate representative data, in
that this information will form the basis for specific stipu-
lations in the ordinance, development of the user charge system
and the establishment of a viable enforcement program.

Another important consideration in this phase of the effort is
the role of self-monitoring in the development of a data base.
Self-monitoring can be helpful in POTW systems where resources
are limited. This type of approach is also most applicable where
a local permit program is utilized, and the self-monitoring data
form then becomes a permit application. Data accumulated in this
manner can serve as the basis for establishment of an industrial
pollutant control program, with verification achieved through
subsequent compliance monitoring.

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Nevertheless, it is recommended that the initial data gathering
effort be performed by POTW personnel whenever possible. Confi-
dence in the data at this stage of development of the overall
control program is essential, and this can best be achieved by
means of a POTW sampling program. The investment in personnel
and other resources to accomplish this task can ultimately be
recovered from industry by various cost recovery techniques
available to most POTW1s.
LEGAL ASPECTS
Legal Authority

One of the most significant factors in the establishment of a
viable industrial pollutant control program is the provision of
adequate legal authority to develop, administer and enforce the
program. Whatever agency is designated to operate the program
must have sufficient power to enforce its rules and regulations
on industrial users, and to obtain the data necessary to ensure
compliance.

In many cases, legal authority may be complicated by the structure
of a sewer district or regional sewer authority. Many districts
and regional authorities act essentially as wholesalers serving a
number of political subdivisions, and do not have any direct
contact with industries in the system. In these POTW's, the
industries discharge to municipal sewers which in turn connect to
the regional agency. In such instances, the development and
enforcement of ordinances controlling the discharge of industrial
wastewaters is legally the responsibility of the individual
municipalities in the system. They may look toward the regional
agency for guidance in such matters, but nevertheless the munici-
palities retain the legal authority to deal with industries in
their systems in these situations.

The solution to the problem depends to some extent on the legal
structure of the sewerage agency. If it is only a voluntary
association of independent municipalities, the agency will generally
only have such authority as has been delegated to it by the
compact creating the sewerage authority or district. If the
sewerage agency has been established by a superior governmental
jurisdiction, it then may be able to superimpose its authority on
that of the local municipalities.

In some instances, it may be necessary to have the state legis-
lature revise the compact or charter of the regional agency in
order to obtain legal authority. In other instances, renegotiation
of the agreement between the regional agency and the municipalities
in the service area might be the most direct method for obtaining
the necessary authority. In particular, the 208 planning agency
may be able to provide assistance in obtaining the legal authority
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to interface directly with industrial contributors to the system.
In any case, to comply with NPDES permit and pretreatment require-
ments, it is essential that the operating agency of the POTW
obtain the power to deal directly with industry in order to
establish a viable industrial control program. The revised
general pretreatment regulations (40CFR403) require the POTW to
obtain legal authority to apply and enforce the requirements of
sections 307(b) and (c) and section 402(b)(8) of the Clean Water
Act. As a minimum, this legal authority must enable the POTW to:

Deny or condition new or increased discharges of
pollutants to the POTW by industrial users;

Require compliance with pretreatment standards by
industrial users discharging wastes to the POTW.

Control, through permit, contract, order, etc., the
discharge to the POTW by each industrial user to ensure
compliance with pretreatment standards.

Require the development of a compliance schedule by the
industrial user to meet applicable pretreatment standards
and the submission of notices and self-monitoring
reports from industrial users.

Carry out inspection, surveillance and monitoring
procedures necessary to determine compliance with
applicable pretreatment standards, including authori-
zation to enter the premises of any industrial user in
which an effluent source, records or a treatment system
is located.

Independently assess or recover through judicial action,
civil or criminal fines, penalties, and injunctive
relief for the noncompliance by an industrial user.
The POTW shall also have authority to halt or eliminate
any discharge of pollutants to the POTW which presents
an imminent or substantial danger to people or to the
proper operation of the POTW.

POTW's faced with the problem of obtaining legal authority,
should have their legal counsel examine all aspects of their
charter or compact to determine the most direct method for ac-
quiring such authority.

Sewer Use Ordinances

The ordinance is the heart of any industrial pollutant control
program, providing the essential mechanism for controlling the
discharge from industries within the POTW system. Consequently,
the ordinance must be carefully drawn to include all essential
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ingredients for the particular system. Once promulgated, the
ordinance should be utilized for the control of all industrial
wastewater discharges and the eventual enforcement of its terms
against all violators. Therefore, the administration or enforce-
ment of the ordinance is equally as important as its contents.

Historical Perspective

The content of sewer use ordinances has evolved over the years
roughly paralleling the increased sophistication in wastewater
treatment facilities. Early ordinances were outgrowths of local
plumbing and health codes, the contents of which were primarily
devoted to standardization of materials used in the construction
of sewers and connections thereto. Since sewage treatment was
limited to settling of solid material, the content of ordinances
at this stage focused on protection of sewers from clogging,
corrosion and explosive hazards. Most ordinances are built
around these basic provisions and have increased in scope as new
needs have arJsen.

With the advent of secondary treatment processes and the develop-
ment of anaerobic digestion, closer control over certain dissolved
organic and inorganic pollutants became necessary to prevent
inhibitory effects in these units. In many instances, this type
of control was provided by setting concentration limits for the
acceptable discharge of critical pollutants.

The recent application of State and Federal effluent and water
quality standards, which in many cases requires the removal of
even trace quantities of certain toxic pollutants, has caused
many POTW's to establish direct control over significant industrial
users. To gain information and control over these sources, many
ordinances are now including permit provisions and self-monitoring
provisions, or both.

Types of Ordinances

There is no single ordinance now in force that could be considered
typical of all, or even most, ordinances currently being utilized.
Effective control of sewer use has been obtained by both simple
and complex ordinance structures.

Two factors influence the size and content of a sewer use ordinance,
The first of these is whether the ordinance is designed to be
self-contained, or whether it simply states general provisions
and relies on separately published rules and regulations for
interpretation and implementation. The second factor is whether
or not the ordinance incorporates a permit system for either
industrial users or all users of the system.
20
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Obviously, an ordinance which is self-contained will be a longer
document than one which is not. Permit systems, if used, will
also add length. Generally, smaller communities with relatively
few industries will use a self-contained ordinance and will not
employ a permit system. Enforcement of the ordinance for the few
industrial users in such cases can be achieved on the basis of
personal contact between the pollution control officer and the
industry plant manager. As the size of the POTW increases or,
more importantly, as the number of industrial users increases, it
becomes more difficult to provide flexibility for the numerous
individual differences between users within the ordinance document
itself. In these systems, a shorter document stating general
provisions may be more effective. This type of ordinance is
usually supplemented by a separate set of rules and regulations
that explain the responsibilities of users with respect to the
general provisions.

Regardless of the type of ordinance employed, its scope and
complexity should be limited to the resources available to the
enforcement authority. If enforcement of the ordinance relies
heavily on a permit system and self-monitoring, then there should
be an adequate office and field staff to issue and review permits
and to check the periodic self-monitoring information. If
enforcement is based on analysis of samples taken by the authority,
then an adequate field and laboratory capability is necessary.
In all cases, sufficient manpower should be available to follow
up violations through the administrative procedures provided in
the ordinance. Only by following up on each violation to gain
compliance, will credibility for both the ordinance and the
enforcement authority be established.

Ordinance Provisions

The ordinance provisions discussed below pertain only to those
portions of a complete sewer use ordinance which relate to the
industrial use of sewer systems. Excluded are those parts of a
typical ordinance which relate to standards for construction of
sewers and appurtenances, provisions relating to the control of
infiltration and inflow, and other miscellaneous provisions.

If the ordinance is self-contained, all of the essential pro-
visions would be incorporated into the ordinance itself. If the
ordinance is general, the accompanying rules and regulations
would necessarily cover many of the specific provisions dealing
with prohibitions, limitations, enforcements, etc. Generally,
about eight to ten specific sections are required, which can be
grouped into four basic parts as follows:

Introductory sections consisting of the introduction,
purpose, legislative background, statement of the area
of jurisdiction, and definitions.
21
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The body of the regulation consisting of prohibitions
and limitations on discharges, control of prohibited
wastes, sampling and analysis of wastes and enforcement
procedures.

Optional add-on sections for a local permit program,
user charge system, etc.

Procedural clauses.

The introductory section is simply a short statement of the
content of the ordinance. It usually includes the purpose,
legislative authority and precise location (city, county, State)
of the area under jurisdiction of the ordinance. All ordinances
contain a section on definition of terms used in the body of the
ordinance. As few as 10, and as many as 50 definitions have been
used depending on the sophistication of the ordinance.

The body of the ordinance contains the essential regulations
controlling discharges to sewerage systems, provisions for
sampling and analysis, and procedures for enforcement of the
ordinance. Most ordinances cover prohibitions and limitations of
wastewater discharges in two parts; general prohibitions on
materials which have proven to be hazardous, or interfere with
both collection and treatment systems, and limitations on certain
critical pollutants which either interfere with, or pass through
the treatment facilities. The general prohibitions should
delineate all objectionable materials as specifically as possible,
and also should provide legal coverage for unanticipated problems.
In this context, it should provide the POTW with the flexibility
to effectively act against violators discharging materials not
specifically named in the ordinance.

The establishment of specific limitations for pollutant para-
meters is one of the most critical portions of any industrial
waste control ordinance. Setting such limitations requires
thorough knowledge of the sewerage system, data on industrial
contributors, and familiarity with applicable water quality
standards, Federal pretreatment standards and the provisions of
the NPDES permit for the POTW. In establishing specific limits,
there are four major factors to consider; (1) Federal pretreatment
standards, (2) pass through of pollutants which would affect the
POTW1s NPDES permit or water quality standards (3) inhibition of
treatment processes and (4) interference with sludge handling or
disposal operations.

Of these factors, setting limits for industrial contributors on
the basis of pass through of pollutants is the most complex. The
method required to establish limits for industrial contributors
based on permit or water quality provisions is "back-calculating,"
using the allowable discharge level in the standard as a starting
point. This procedure requires knowledge of the removal capability
of the treatment plant and the average plant influent concentration
22
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for the pollutant parameters of interest. In addition, inform-
ation is necessary on dilution, background levels of the pol-
lutant in question and peak to average flow ratios within the
system.

Frequently, sampling of the plant influent and effluent is required
to establish its removal capability for a specific pollutant.
Additional sampling and flow measurement within the collection
system may also be necessary to obtain all of the required data.
One major POTW system, the Sanitation Districts of Los Angeles
County, has developed a formula for use in establishing limits on
its industrial contributors based on allowable pollutant concen-
trations set by the State in the treatment plant discharge to the
Pacific Ocean.

The body of the ordinance should also establish the authority and
procedure for the control of prohibited wastes. It should include
the necessary clauses relative to regulatory actions, submission
of plans for pretreatment facilities, proper operation and
maintenance of pretreatment facilities, admission of POTW personnel
to industrial plants and reporting of accidental discharges.
Several clauses in the body of the ordinance should be devoted to
monitoring and record keeping, encompassing the type and frequency
of samples required.

The section of the ordinance dealing with enforcement should
provide a structured approach for the handling of violations.
Enforcement should be a step-by-step process, starting with
written notification and conference and conciliation, prior to
the institution of more formal proceedings.

Formal action could begin with a show cause hearing, which provides
the violator with an opportunity to show cause why an order
should not be issued directing the discontinuance of the discharge.
Show cause hearings are usually open to the. public, and held
before a hearing board composed of appropriate officials of the
municipality, authority or district. Upon submission of all
evidence, the hearing board has the option of issuing an order
for the cessation of the discharge within a specified time period.
If an order is issued, and not complied with, then court action
is the next and final step in enforcement of the ordinance. This
step-by-step approach to enforcement provides the maximum oppor-
tunity for the resolution of ordinance violations, without resorting
to court proceedings until absolutely necessary.

The optional and procedural provisions constitute the two remaining
portions of an ordinance regulating the industrial use of POTW
facilities. Whereas the sections of the ordinance dealing with
definitions, prohibitions, limitations, control procedures,
monitoring and enforcement are required in every ordinance,
sections addressing local permit systems and user charges are
considered optional since they are not applicable to every POTW.
23
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Where local permit systems are utilized, the ordinance should
contain specific provisions detailing the procedures involved.
Similarly, where user charges are imposed or other cost recovery
methods are employed, the ordinance should specifically delineate
the formula or other basis for calculating costs.

The procedural clauses generally contain references to other
related ordinances, and reconcile differences that may exist
between the various ordinances. In addition, many ordinances
contain a "saving" clause, which provides that the bulk of the
ordinance remains in force if any section is declared invalid
or unconstitutional. Finally, the procedural clauses also
typically set forth the date that the ordinance becomes effective,
ADMINISTRATION

The scope of any industrial waste control program depends to a
large degree on a number of factors. Of prime importance is
the size of the sewerage system and the number and type of
industries utilizing the system. Other significant elements
include the type of treatment facility, the water quality
standards applicable to the POTW and the provisions of the
plant's NPDES permit.

From an administrative point of view, POTW1s have been divided
into large, medium, and small systems, referring in general to
systems with average dry weather flows in excess of 100 mgd,
between 10 and 100 mgd, and less than 10 mgd. However, a
system with a heavy industrial contribution, but an average
flow of under 10 mgd may opt for a more extensive program,
whereas a system with an average flow in excess of 10 mgd but
only limited industrial contribution, may adopt a less compre-
hensive program. Thus the categorization by size is provided
as a general guideline only, and should be considered flexible
depending upon the needs of a particular system. The degree of
industrialization in a community and the type of industrial
facilities contributing to the system, are major factors in
determining the requirements of a control program for a given
POTW.
Organizational Structure

An industrial waste control program consists of the activities
and personnel assigned specific functions and responsibilities
in relation to the control of industrial pollutants. For most
larger systems, this involves a well-defined organizational
structure with assigned personnel having specialized training
and qualifications. For smaller systems, it may involve only a
part time assignment for a single individual. However, even
small systems should be aware of the functional steps involved
in an industrial pollutant control program and provide for
these functions on a appropriate scale.
24
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Figure 4 illustrates a conceptual organizational structure
based on the functions required for a workable control program.
The manner in which these elements are organized can vary
greatly depending on the local situation. The essential aspect
is the need for an efficient information transfer mechanism.
The typical organization shown outlines the interrelationship
of the essential elements of a program.

Generally, the larger the system, the more complex the organi-
zation. Individual responsibilities also become more clearly
defined as the system increases in size. For very small systems,
outside experts are frequently utilized to provide engineering,
legal and laboratory expertise. In order to supply the most
meaningful guidance, the organization necessary for an effective
industrial waste control program is specifically discussed in
the following paragraphs in terms of small, medium and large
systems.
Large Systems

Figure 5 presents an example of an industrial waste control
organization for a large POTW system. The chart illustrates
the need for a structured organization to most effectively
administer a control program in a large system. The larger and
more complex the POTW, the more highly developed and structured
the organization should be. Nevertheless the components of an
effective organization demonstrated by the chart are essential
for a functional industrial waste control program in any large
system. Specific sections of an industrial waste control
organization for a large system should include the following:

Administrative

Administrative responsibility for the program should rest with
a single person who has intimate knowledge of all aspects of
pollution control and wastewater treatment within the juris-
dictional boundaries. In municipal systems, usually the Director
of Public Works or Superintendent of Sanitation would be the
appropriate individual. In regional authorities, day-to-day
operations are usually administered by an Executive Director,
General Manager, Chief Engineer or Superintendent.

Decisions pertinent to pretreatment policy should be made by
this individual drawing upon information supplied by key sub-
ordinates. These subordinates should include personnel such as
the Chief Industrial Waste Engineer, Chief Plant Operator,
Chief Chemist, and other specialists concerned with the control
program, including field investigators, engineers and attorneys.
Specific functions of the administration should include (1)
basic policy decisions (2) management of budgetary needs (3)
personnel administration and (4) coordination with the public
and appropriate municipal, State and Federal authorities.
25
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MUNICIPAL
GOVERNMENT
OR
REGIONAL BOARD
STATE&
FEDERAL
REGULATORY
AGENCIES
POTW
ADMINISTRATION
LEGAL-
ENFORCEMENT
PUBLIC
RELATIONS
COLLECTION &
TREATMENT
SYSTEM
OPERATION
INDUSTRIAL
WASTE
DIVISION
LABORATORY
FIELD
MONITORING
CONCEPTUAL ORGANIZATION OF AN
INDUSTRIAL WASTEWATER CONTROL PROGRAM
FIGURE 4
26
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Industrial Waste Division

The individuals comprising the industrial waste division represent
the heart of any industrial waste control program. Generally
the division is comprised of engineers that conduct the program
and field inspectors and laboratory technicians that provide
the necessary support for effective operation. The engineering
staff engaged in this activity should be the most knowledgeable
group of individuals on all aspects of industrial wastewater
within a given system. They should be thoroughly familiar with
the operation and wastewater produced by industries in the
system, pretreatment facilities utilized by the industries,
applicable provisions of Federal and State standards and local
ordinances and characteristics of the treatment processes
utilized in the system. Generally this group will formulate
industrial wastewater policy and recommend specific policies to
the administrator for implementation. The industrial waste
division would also generally coordinate enforcement activities
and provide necessary technical expertise to the legal staff in
court actions.

Staff levels vary considerably depending upon size, fiscal
resources, organizational structure, number and type of industries
present and the specific NPDES permit requirements of the
system. The largest POTW systems in the country have as many
as 50 to 80 individuals reporting to the Chief Industrial Waste
Engineer. Smaller cities and regional authorities obviously
require smaller staffs, with the level generally varying from
approximately 1/2 to 2 individuals per 10 MGD, depending upon
the factors indicated above.

Field Monitoring

The organization should include a group of inspectors whose
only responsibility is the monitoring of non-residential con-
tributors. These field investigations should include initial
plant surveys, data acquisition at the plant site, and all
follow-up monitoring and inspection activities.

The field monitoring section should have total responsibility
for surveillance of industrial sources. Specific functions to
be carried out by field inspectors include: (1) sampling and
flow measurement at wastewater sources, (2) inspection of plant
and pretreatment operations at the time of sampling, (3) maintenance
of specialized field equipment, and (4) performance of specialized
monitoring activities in connection with locating the source of
problems within the system, enforcement activities, etc. The
Metropolitan Sanitary District of Greater Chicago provides
uniforms and badges for its inspectors to formalize their
status in the community. This can be helpful in gaining quick
access to industrial facilities when necessary. In any event,
all field inspectors should be provided with proper credentials
which should be carried for identification at all times.
28
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Laboratory

An industrial waste control program will generally require some
expansion of the typical laboratory required for control of
biological treatment processes. As a result, additional personnel
may be necessary to carry out analyses in conjunction with a
monitoring program. Frequently, these technicians are incorporated
into the existing laboratory organization, so that coordination
with the industrial waste division is essential. Some POTW's
are structured so that laboratory personnel engaged in industrial
wastewater analysis report directly to the Chief Industrial
Waste Engineer. Such an arrangement may be preferable for
improved communications and delineation of responsibility.

Where this function is part of the overall laboratory responsi-
bility, then data must be reported to the industrial waste
division so that pretreatment performance can be evaluated. If
any ordinance violations are suspected, then analytical data
would also be passed on to the legal staff for evaluation and
possible enforcement action. The specific functions of the
laboratory in connection with industrial wastewaters include
(1) analysis of field samples, (2) maintenance of laboratory
equipment and (3) proper record keeping and reporting in support
of industrial waste division activities.

Legal

One or more attorneys may be required to provide legal services
with regard to enforcement of ordinance regulations. Attorneys
may not have full time responsibility in connection with ordinance
enforcement. Instead the legal staff may serve the dual function
of supporting legal action against ordinance violators, and
general legal support of other activities in the water pollution
control area.

For enforcement activity, the legal group should receive information
directly from the industrial waste division staff, as well as
from field monitoring and laboratory personnel. The special
functions of enforcement include (1) assistance in evaluation
of suspected ordinance violations, (2) notification of suspected
violators, (3) participation in follow-up meetings with violators
(4) preparation of briefs for litigation, and (5) court action.

Medium Size Systems

As the size of a POTW decreases, the operation of the industrial
pollutant control program becomes less of a separate entity,
and more entwined in the overall operation of the wastewater
collection and treatment facility. Because of limited resources,
administrative and laboratory personnel generally become responsible
for both plant operations and control of pollutants contributed
by non-residential sources. Figure 6 provides a typical organization
chart for a medium size POTW system.
29
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MUNICIPAL
ATTORNEY
1
1
1
1
1
1
(

1
SEWER SYSTEM
OPERATION &
MAINTENANCE
1
MUNICIPAL
GOVERNMENT

COMMISSIONER
OF PUBLIC WORKS

DIRECT
POLLl
CON1
Overall re
for indust

OR OF
innw
•ROL
sponsibility
rial waste

ASSISTANT DIRECTOR
3F POLLUTION CONTROL
Administers industrial
waste program

TREATMENT PLANT
OPERATION &
MAINTENANCE
1
I
1
I
1
CONSULTING
FN|r,|WFFR
IF REQUIRED
(Contract)

LABORATORY

FIELD
MONITORING
""" Conducts field
monitoring of
industrial wastes
— 1
1
1
1
1
1
_J
TYPICAL ORGANIZATION
OF A MEDIUM SIZE SYSTEM
FIGURE 6
30
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Since fewer individuals are involved and the organization is
not as structured as in large systems, the essential functions
of industrial waste control must be necessarily performed in
conjunction with other duties. Among these functions is the
use of a field monitoring group to carry out plant inspections
and effluent sampling. The field crew is essential for all of
the specific monitoring requirements necessary to control
industrial contributors to the system. Likewise, other specific
functions of a control program would have to be maintained in a
medium size system, such as ordinance enforcement, summary and
analysis of industrial data and user charge administration.
However, unlike the large system organization where individuals
or groups of individuals have well defined task assignments,
the control program for a medium size system will most likely
contain individuals with multiple functions and responsibilities.
Some medium size systems with many industrial contributors may
find it necessary to have an industrial waste engineer or other
individual specifically assigned to the control of discharges
from these facilities.

Small Systems

A large proportion of municipal POTW's that treat non-residential
wastes fall into the small system category. In a small system,
adequate resources would generally not be available to have any
individual whose sole responsibility lies in the area of in-
dustrial waste control. Instead, all of the elements of an
industrial waste control program that are delineated for large
systems would have to be handled by personnel currently employed
by the municipality. This is not unrealistic, since quite
often a small system would be concerned with only a few, or
even a single industrial contributor.

Figure 7 illustrates an organizational arrangement for a
typical small system. The structure shown is only one of
several that could be effectively utilized in a small muni-
cipality. The variety encountered in the organization of small
local governments suggests that a number of different arrange-
ments may be equally effective in the administration of an
industrial pollutant control program.

In small systems, generally one person has responsibility for
monitoring, and all specialized analysis is contracted to
commercial laboratories. Similarly, the Director of Public
Works would most likely have overall administrative responsi-
bility in addition to performing the functions of the industrial
waste engineer. A town engineer may be utilized for industrial
waste control, reporting either to the Director of Public Works
or directly to the governing body. The town engineer may be a
full time employee if the needs of the system dictate, but he
is most frequently a consulting engineer under a retainer type
contract to the municipality. Specialized engineering require-
ments would usually be provided by either the town engineer or
another consultant, with legal questions being handled by the
municipal attorney.

31
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MUNICIPAL
ATTORNEY
(contract)
MUNICIPAL
GOVERNMENT
~l
COMMISSIONER
OF PUBLIC WORKS
Overall responsibility
for industrial waste
TREATMENT PLANT
& SEWER SYSTEM
OPERATION &
MAINTENANCE
TOWN AND/OR
CONSULTING
ENGINEER
IF REQUIRED
(contract)
Administers Industrial
waste program
PLANT LABORATORY
Conducts field
monitoring of
industrial wastes
CONTRACT LABORATORY
SERVICES FOR
SPECIALIZED ANALYSES
IF REQUIRED
TYPICAL ORGANIZATION OF A SMALL SYSTEM

FIGURE 7
32
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Policy Considerations
Joint Treatment

Joint treatment is a policy alternative that can be advantage-
ous to both the POTW and industry with regard to the construction
of new POTW treatment facilities. Generally, the treatment of
industrial wastewaters in a POTW is incidental to its primary
function of treating domestic sewage. Where the industrial
contribution constitutes a significant portion of the total
flow and substantially alters the concentration of pollutants
normally contained in domestic sewage, the public agency may
resort to the joint treatment approach.

In this approach, the industry is made a partner in the design
and construction of the system, and the treatment works are
designed to specifically remove the industrial pollutants.
Both capital and operating costs are allocated to the industry
and the public agency according to an agreement arrived at
through negotiation, or as required by Federal regulations if
construction grant funds are involved.

Joint treatment of industrial wastewaters with municipal domestic
sewage offers these advantages:

Savings in capital and operating expenses due to the
economics of large-scale treatment facilities

Increased flow over separate treatment which can
result in reduced ratios of peak to average flows

More efficient use of land resources, particularly in
cases where available land for treatment facilities
is scarce

Improved operation (larger plants are potentially
better operated than smaller plants)

Increased number of treatment modules with resultant
gains in reliability and flexibility

More efficient disposal of sludges resulting from
treatment of wastewaters containing pollutants
susceptible to treatment in POTW's

Utilization of the nutrients available in domestic
wastes for biological treatment of industrial wastes
which are nutrient deficient.
33
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Possible disadvantages of joint treatment are as follows:

Where the pollutants are different from those usually
treated in a POTW, design to treat the combined
industrial-domestic waste stream for these pollutants
may not be cost-effective

Joint treatment by definition implies that the POTW
was designed so as not to be interfered with by
industrial wastes. However, where this requires
design modifications ordinarily not required for
domestic wastes, joint treatment may not be cost
effective

If joint treatment results in sludge disposal or
utilization problems it may not be acceptable

Some costs for the construction of joint treatment
works solely to treat industrial pollutants are not
eligible for Federal construction grants.

Sludge Disposal

The ultimate disposal of sludges produced by either pretreat-
ment or joint treatment operations is an important factor to
consider. The POTW must be aware of the effect of its policies
on environmental problems that may result from sludge disposal.

Generally pretreatment facilities will remove imcompatible
pollutants that may eventually be deposited in the sludge
produced by the operation of the publicly owned treatment
works. This can be a meaningful advantage in terms of the
environmental effects of the ultimate disposal of sludge from
the POTW. Incompatible pollutants in sludges can cause problems
in most disposal techniques utilized, including incineration,
landfills, ocean dumping and land spreading. Consequently, the
removal of incompatible pollutants at their source by pretreat-
ment is usually advantageous to the POTW in terms of its sludge
disposal.

Nevertheless, incompatible pollutants removed by pretreatment
also require an ultimate disposition, although the impact on
the POTW may have been eliminated. In some cases the sludge
produced by pretreatment operations may be pure enough to
warrant by-product recovery or recycle. When this is not
economically or technically feasible, disposal of sludge is
necessary. Although the sludges produced by industrial pre-
treatment may not technically be under municipal regulatory
Control, the impact on other environmental areas should be
ted. A possible approach to this problem would be an effort
'-he municipality to coordinate off-site disposal with
nriate regulatory agencies. If on-site disposal is
d by the industry, attempts should be made to evaluate
disposal schemes to prevent future air and water
i problems.
t
34
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Policy instituted by a POTW must be determined on the basis of
conditions within the system. One of the most important factors
to consider is the potential effect of the chosen course of
action on critical environmental problems such as sludge disposal,
As a result, policy should be instituted on the basis of a
broad overview of all aspects and consequences of action taken.

Public Relations

It must be recognized that some industries using a public
sewerage system will be reluctant to provide the necessary
pretreatment facilities, particularly if they have been using
the public system for some time and the effects of their contri-
bution are not apparent. It is incumbent upon the POTW when
instituting a control program, to attempt to develop a feeling
of mutual trust between POTW and industry representatives.
This can be best accomplished through a series of meetings with
industry personnel to inform them of the regulations and programs
involved, and to provide a forum for industry to input their
suggestions, concerns and recommendations.

One way in which some public agencies have been able to enlist
the support of their contributing industries is through the
formation of an informal coordinating committee, which would
consist of representatives of the affected industries and the
public agency. This committee would explore all aspects of the
Federal regulation, including pretreatment requirements and the
NPDES permit for the POTW, and develop programs which would
meet the requirement of the regulatory agencies. Such committees
would be purely advisory and would not have any legal status,
but could serve as a forum for the exchange of ideas.
35
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CHAPTER II
USER CHARGE SYSTEMS

The subject of municipal nser charge systems is addressed in
four parts: first, a def nition of terms generally associated
with this subject; second, the purpose and the need for these
systems; third, the procecure whereby an equitable financial
system may be developed; and fourth, an example of an EPA
approved user charge and industrial cost recovery system
currently in effect in the City of Buffalo.
DEFINITIONS

The terms generally associated with the subject of municipal
user charges include user charge, surcharge, sewer rental,
industrial cost recovery, ad valorem tax, and special assessment.

User Charge

User charge is a general term that traditionally has many
connotations, including the overall charges to an industry for
the use of a POTW facility. However, in the context of PL92-500,
and the Clean Water Act of 1977, the term user charge assumes a
specific denotation.

In PL92-500, it is defined as that charge paid by users of a
treatment works for their proportional share of operation and
maintenance (including replacement) costs. The system must
fulfill the objective of distributing the costs of operation
and maintenance among all users in proportion to their waste
load contributions. Factors to be included in the calculation
of charges are the volume, flow rate and strength of the wastes
of all users. Each user, or class of users, must be charged on
an equitable basis to fairly apportion the operation and mainte-
nance costs. It should be noted that the definition of user
charge has been revised in the 1977 Clean Water Act to include
as a user charge that portion of the ad valorem taxes paid by a
user for his share of the cost of operation and maintenance.

In this paper the term user charge is used not only in relation
to the EPA definition, but also in the broad generic sense of
any charge imposed on an industrial user of a POTW facility.

Surcharge

The term surcharge is another traditional expression used to
denote a charge imposed on industrial contributors to a POTW
based on quality and quantity of wastewater beyond the charge
for normal domestic sewage. Typically, the surcharge was
viewed as a revenue producing mechanism only, and the treat-
ability or compatibility of the industry's wastewater may or
may not have been considered by the POTW agency.

36
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Sewer Rental

Sewer rental is another loosely defined term commonly used in
the past as a charge imposed on industry by a publicly owned
sewerage agency. It generally was computed on a volume of
wastewater basis, and typically including a standard hook-up
charge.
Industrial Cost Recovery

Industrial cost recovery is a Federal term for the means whereby
industrial users of a publicly owned treatment works repay the
proportionate Federal share of the construction cost of the
treatment works allocated to their use. Capital costs are to
be recovered by the POTW, as a grantee of Federal funding, over
the useful life of the treatment works, but not to exceed 30
years. The system is applicable only to the Federal share of
the construction cost. There is no Federal requirement for
recovery of the State or local share of costs for treatment of
industrial wastes, although State or local laws may be so
enacted. The Federal share of the cost of construction includes
the Step 1, 2, and 3 grants, except for the costs associated
with infiltration and inflow analysis, sewer rehabilitation and
non-excessive infiltration and inflow if they are not attri-
butable to industrial users.

Industrial cost recovery assessments are levied in proportion
to the industrial user's wastewater characteristics. However,
in the past several years, municipalities have strongly opposed
this assessment for small dischargers. Under the Clean Water
Act of 1977, Congress has agreed to exempt those industries
with less that 25,000 gallons per day of wastewater, as long as
the discharge does not include pollutants that would contaminate
the plant's sludge. As for the larger dischargers, Congress
has placed an 18 month moratorium on EPA1s move to make the
awarding of construction funds dependent upon a municipality
having an industrial cost recovery system. In the meantime, a
study of the effectiveness of the cost recovery provision will
be made.
Ad Valorem Tax

The ad valorem tax is a charge for sewer use, both domestic and
industrial, that is based typically on property value. As
such, the cost of sewer service is generally combined with
other municipal costs and financed from the municipality's
general fund. The tax might also be based on the property area
(square footage) less equitable factors determined on a local
basis.
37
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Special Assessment

The term special assessment is a kind of catch-all method used
in the past to develop sewer charges based on factors such as
front footage or water consumption.
Summary

In summary, the user charge and industrial cost recovery system
are the two current requirements imposed on the recipient POTW
by the Federal government as a condition of the construction
grant program. The other terms represent traditional methods
of assessing industry for the use of publicly owned sewerage
facilities. The balance of this discussion will focus on the
purposes of an industrial user charge system and the develop-
ment and implementation of such systems in POTWs. In this
context, the EPA industrial cost recovery and user charge
program will be emphasized, although other equitable cost
recovery methods are applicable where construction grant funds
are not involved.
PURPOSES OF A USER CHARGE PROGRAM

The purpose of a user charge program is primarily to comply
with Federal legislation and regulations. Under PL92-500 and
the Clean Water Act of 1977, industrial cost recovery and user
charge systems are mandated for those POTWs which have accepted
construction grant funds. Figure 8 provides a pictoral represent-
ation of the system as mandated by PL92-500. POTWs which have
not received Federal funds may nevertheless be required to
develop user charge programs to finance the industrial waste
control program required by 40CFR403.

In addition to Federal requirements, the State may also require
a financial recovery system as a condition of acceptance of
their funds. However, even if a municipality should choose to
build and operate a wastewater treatment facility without
Federal or State funds, there is a strong and legitimate incentive
for an equitable user charge program strictly on the basis of
revenue production and local cost recovery.
Clean Water Act of 1977

The Clean Water Act of 1977 modified the mandate of PL92-500 on
user charges and industrial cost recovery in several ways that
have already been mentioned, and will now be further detailed.
In addition, the requirement for a local industrial waste
control program under the 1977 Act will be discussed as it
relates to the need for a system of cost recovery.
38
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39
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Industrial Cost Recovery

Section 24 of the 1977 Act amends section 204 PL92-500 to authorize
EPA to exempt from the industrial cost recovery requirement any
industrial user with a flow equivalent to 25,000 gallons per day
or less of sanitary waste. Section 24 also permits grantees to
develop industrial cost recovery systems on a system-wide,
rather than on a project-by-project basis. It further permits a
portion of the industrial cost recovery revenues retained by the
grantee to be used for the administration of the industrial cost
recovery system, and maintains the current authority to establish
a fund for future expansion or reconstruction of the grantee's
treatment works.

Section 75 of the CWA directs the Agency to conduct a study of
the industrial cost recovery requirement. During the period of
the study, and ending eighteen months after enactment of the
statute (June 30, 1979), EPA may not enforce the collection of
industrial cost recovery payments. This is known as the "moratorium"
period. At the end of the moratorium, if Congress has not
acted, the requirement to make payments of industrial cost
recovery attributed to this period will come back into force.
Any industrial cost recovery obligations incurred during the
moratorium will become immediately due, but payment of these
obligations may be paid in a lump sum within one year or spread
out over the remaining industrial cost recovery period.

User Charges

Section 22 of the CWA amended the user charge requirements in
section 204 of PL92-500. This amendment permits grantees to use
dedicated ad valorem tax systems for the collection of operation
and maintenance costs. Such use is contingent upon whether a
portion of the grantee's ad valorem taxes was dedicated for O&M
costs on December 27, 1977, and if the grantee's system results
in the distribution of these costs proportionally among user
classes.

In implementing this amendment in the interim regulations, EPA
has made the following major changes to the regulations promulgated
in February 1974:

The definition of user charge has been revised to
include as a user charge that portion of the ad
valorem taxes paid by a user for his share of the cost
of operation and maintenance.

The regulations require, in accordance with the statute,
that operation and maintenance costs be distributed
proportionally among the classes of users, even though
ad valorem taxes may be used to collect the charge

40
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within the residential user and small non-residential
user class. Each member of the industrial and large
commercial user class must pay its share of the costs
of O&M based on actual use, but ad valorem taxes may
be used to collect all or part of these user charges.

Industrial Waste Control Program

Under the CWA, each POTW control agency shall institute an
industrial waste control program, and shall provide adequate
funding to carry out the procedures required by the program. In
combination with other sources of funding, the system of user
charges required under section 201 of PL92-500 and 40CFR35.929
is to be utilized by the POTW if construction grant funds are
involved. In this manner, any increased costs attributable to
the POTW pretreatment program will be passed on to industrial
users through increased user charges. If Federal construction
grant funds are not involved, an equitable system of user charges
will be required to enable the POTW to recover its cost for the
industrial waste control program.

State Requirements

Another purpose for a user charge system may be to satisfy
individual State requirements. State requirements for a cost
recovery system to recover the industrial portion of the capital
construction or O&M costs vary on a state-by-state basis. If
State cost recovery requirements do exist, it may be that the
Federal systems described here would also be generally applicable
to the State requirements as well.
Revenue Production

In addition to the Federal and State incentives to develop an
equitable system of user charges, a traditional incentive among
municipalities has also been the use of these systems to supple-
ment the general municipal operating fund. In addition, revenue
production from these systems to cover general aspects of POTW
cost recovery is an additional incentive that has traditionally
been used.
SYSTEM DEVELOPMENT
Development of Costs

The development of an equitable user charge system should begin
with an itemization of the annual POTW costs, including operation
and maintenance and the debt service on capital expenditures.
41
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In addition, the cost of the industrial waste control program
should also be detailed. The allocation of these costs to the
system users, should be such that each pays according to the
benefit obtained in terms of POTW utilization and the potential
advantage of future access to the POTW.

The cost of the industrial waste control program may include
varying expenses attributable to the office staff, laboratory
personnel and equipment, services of a consulting engineer,
field monitoring, and legal expenses. As noted earlier, these
costs should be recovered through an equitable industrial user
charge.

Allocation of Costs

The methods that may be used in the equitable assessment of
industry's share of both O&M costs and capital expenditures
include the consideration of wastewater flow and mass loading
for certain parameters; BOD, suspended solids, oil and grease,
and perhaps incompatible pollutants. Incompatible pollutants
are considered those wastewater parameters a POTW is not designed
to treat and are therefore not effectively removed in the typical
wastewater treatment facility. In this context, the incompatible
pollutants must then be removed by the industrial contributor to
levels acceptable for direct discharge, unless the POTW can
demonstrate some removal credit that occurs in their treatment
system without an adverse impact on the POTW sludge.

The cost recovery formula developed by the POTW should include
both the user charge and fee for industrial cost recovery. This
formula should utilize a base charge for all contributors that
incorporate an equitable assessment of user benefits and treat-
ment costs. In addition, it should provide an apportionment of
the costs for industrial wastewater treatment as an increment
above that for normal domestic wastewater treatment. The basis
utilized in this development of charges may include the character-
ization of standard domestic sewage for the POTW system, and
assessment of charges based on the characteristics of the industry
wastewater as compared to standard domestic sewage. It may also
consider the costs of installing and operating various elements
of the POTW system, such as pumping stations, and provide an
allocation to industry for their fair share of each of these
costs.

SYSTEM IMPLEMENTATION

Example - Buffalo Sewer Authority

Background

The City of Buffalo secured a Federal grant prior to March 1,
1973. Hence, the regulations governing industrial cost recovery
42
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and user charges were those of PL84-660, rather than PL92-500.
There are two basic differences between these two laws: first,
PL84-660 does not require the recovery of the industrial portion
of the Federal grant and second, PL84-660 requires the applicant
to demonstrate the use of ad valorem tax as the base for the
user charge. Nevertheless, the user charge system developed by
the Buffalo Sewer Authority provides an excellent working example,

The problems involved in developing a method by which the Buffalo
Sewer Authority (BSA) should distribute its financial obligation
to those that benefit from it is quite complex, and perhaps
similar to the problems of other municipalities of their size and
age. The guiding principle in the development of a method by
BSA was that the total annual revenue required for the operation
of the sewage works should be distributed to the users of the
system. In addition, the distribution should be approximately in
proportion to the cost of providing the use and benefits of that
works. The philosophy used in Buffalo was that the cost should
be distributed according to the benefit and use made of the
system. Community benefit, readiness to serve, and ability tc
pay factors were not considered.

The cost distribution method approved by EPA for the Buffalo
system included a volume and loading base for the costs resulting
from point source discharges, both domestic and industrial, and
an ad valorem base for the non-point source discharges in the
form of infiltration and future use. It should be noted that
while EPA approved this method under PL84-660 regulations, and
would disapprove it under PL92-500, the Agency under the Clean
Water Act of 1977 would now approve of the ad valorem tax base
under the conditions mentioned earlier.
Distribution of Costs by Design Parameters

The BSA's secondary treatment plant has a number of design
considerations (flow, BOD, S.S., PO.) and the relative proportions
charged to users and property owner, differ for the various unit
processes. For example, the pump station, final settling tank,
chlorine tank, plant outfall and modification to the gate chamber
were all designed based on flow. Consequently, the costs should
be distributed based on flow. On the other hand, the grit
disposal facility, the modification of the primary tanks and the
primary digesters were designed based on suspended solids loading.
Since the capital as well as the 0& M costs of the treatment
facility are directly related to the parameters for which it was
designed, the allocation of the relative proportion of the works
to the users of the system or the property owners should be
based on these same parameters.
43
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To derive the formula for the allocation of the estimated first
year operation and maintenance costs, the new plant was broken
down into 15 unit operations (simplified to five for purposes of
this illustration as shown in Table 1) with each being assigned
its portion of the total O&M cost relative to the appropriate
design parameters. The apportionment resulted in: 25% of the
total O&M cost assigned to flow; 41% to suspended solids removal;
18% to BOD removal; and 16% to phosphate removal.

The allocation of capital construction costs was arrived at in
much the same manner (Table 2) with the costs of twenty individual
facilities each being assigned its portion of the total cost
relative to the appropriate design parameters. This breakdown
resulted in 31% of the total construction costs being attributed
to flow; 25% to suspended solids removal; 42% to BOD removal;
and 2% to phosphate removal.

Based upon estimated material balances for the design parameters
in the Buffalo system, and the plant's design criteria, the
loadings received at the plant were distributed to future use,
infiltration, residential use, and industrial use. According to
this distribution then: 27% of the first year capital costs
would be attributed to future use; 9% to infiltration; 46% to
residential users; and 18% to industrial users as shown in
Table 3.

Similarly, the estimated first year O&M costs were distributed,
with the notable exception that none of these costs were attri-
butable to future use. Therefore, 12% of the O&M costs were
assigned to infiltration; 59% to residential users; and 29% to
industrial users as shown in Table 4.

Combining the distribution schemes for the capital construction
cost and the O&M cost, a total of 19% was chargeable to property
based on future use and infiltration, and 81% was chargeable to
the industrial and residential users as illustrated in Figure 9.

Domestic Rate Formula

Having established the allocation of capital and O&M costs based
on design parameters, and in turn the individual waste character-
istics actually being discharged, the ground work was laid for
the determination of unit rates, rate formulas and charges.
However, it was neither administratively nor economically feasible
to measure the strength, and charge each individual user of a
sewerage system independently. Therefore the BSA established as
a standard for domestic strength waste 250 mg/1 BOD, 250 mg/1
S.S. and 15.35 mg/1 PO. to be used in establishing the basic
sewer use charge. In addition, since high strength wastes are
directly responsible for increased costs at the treatment plant,
an extended charge or surcharge, over and above the basic sewer
use charge, was levied against industries discharging wastes with
strengths above the domestic waste standard.
44
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TABLE 3

BSA SYSTEM

FIRST YEAR CAPITAL COST DISTRIBUTION

PERCENT CHARGEABLE TO:
PROPERTY USER
PARAMETER
BOD
SS
P04
FLOW
TOTAL
FUTURE
USE
28
50
35
6
27
INFILTRATION
4
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13
21
9
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26
60
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18
47
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TABLE 4
BSA SYSTEM
FIRST YEAR O&M COST DISTRIBUTION
PERCENT CHARGEABLE TO:
PROPERTY
USER
PARAMETER
BOD
SS
P04
FLOW
TOTAL
FUTURE
USE
0
0
0
0
0
INFILTRATION
6
5
21
23
12
RESIDENTIAL INDUSTRIAL
60 34
68 27
40 39
63 14
59 29
48
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FIGURE 9
BSA SYSTEM

FIRST YEAR COST DISTRIBUTION
CAPITAL AND O&M
INFILTRATION

USERS
-------
Based on the allocation of loading previously described, rate
formulas were developed. There are two basic formulas, the
first for computing the charge to the customers who discharge
only domestic strength waste and the second for computing the
rates charged to the industrial user. The domestic rate formula
consists of two terms and is stated as follows:

Domestic Treatment Charge = Domestic User Charge + Property
Charge

Each of the above terms contains a portion of the capital as
well as the operating and maintenance costs.

By using the domestic strength waste characteristics, all the
unit rates for user charge could be expressed in terms of flow
as follows:

Domestic User Charge = $0.078/1000 liters
Industrial User Charge = $0.106/1000 liters

The industrial user charge was set higher than the domestic
charge to account for the additional administrative and engineering
costs associated with the industrial waste control program
described above.

Using the appropriate unit cost and the total assessed valuation
of taxable property in the City of Buffalo, a property rate of
$2.32/$1000 and $1.75/$1000 of assessed valuation for the capital
and operations portions, respectively, was derived. It must be
kept in mind that the formula equates charges in dollars to
water consumption in thousands of liters.

Industrial Rate Formula

The industrial rate formula is only an expanded version of the
formula for domestic discharges just described. It consists of
three basic terms, as follows:

Industrial Waste Treatment Charge = Domestic User Charge
+ Property Charge + Surcharge

The simple addition of the surcharge term makes the formula
broadly applicable to all industries. When applying it to an
industry that discharges only domestic strength waste, the last
term just drops out and the formula becomes that of a domestic
user. The surcharge portion, as stated below, provides an
additional charge for each milligram of BOD, S.S., and PO. being
discharged over and above what is considered domestic strength
waste:
50
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Surcharge = Q(0.152(BOD - 250) + 0.291(SS - 250)
+ 1.63(P04 - 15.35)
Where: Q = average annual discharge rate expressed in
million liters/year

The determination of waste characteristics that would define an
upper limit for domestic strength waste required a great deal of
investigation. Ordinances from other municipalities across the
country were reviewed and it was found that the range of values
adopted varied from 250 mg/1 to 350 mg/1 for BOD and suspended
solids. Since the Buffalo metropolitan area has always had what
would be considered a weak waste, it was deemed appropriate to
use the low values.

In conclusion, if the industrial user charge and property charge
are substituted in the above formula, the final form is as shown
below, where Q, is the industrial wastewater flow in thousand
liters per year, and A is the assessed property valuation in
thousand dollars:

Yearly Industrial Waste Treatment Charge ($) =
Q1(0.106) + A(4.071) + Surcharge.
51
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CHAPTER III
MONITORING AND REPORTING
ELEMENTS OF AN INDUSTRIAL MONITORING PROGRAM

As outlined above, the management of an industrial waste control
program requires a constant flow of information on the quality
and quantity of industrial contributions to the publicly owned
system. In general, the function of a monitoring program is to
provide a mechanism by which the POTW operator can obtain infor-
mation on the pollutants introduced into the sewer system. The
information obtained through monitoring activities may then be
applied to specific areas of concern to the municipality. These
specific areas include compliance with ordinance requirements,
ascertaining user charge fees, and completion of reports required
by EPA. Additionally, the POTW operator may use monitoring
information to determine the contributors who are responsible for
releasing materials potentially harmful to collection or treat-
ment systems.

Depending on the specific situation, information obtained by
monitoring may also be used in the development of the ordinance
and in its enforcement. Monitoring information can be especially
useful in developing those sections of the ordinance that set
levels for incompatible pollutants, as well as determining orders
of magnitude for an equitable system of user charge fees. As a
result, ordinance development and enforcement work hand in hand
with monitoring activities.

Although monitoring in a broad sense performs the single function
of obtaining quantitative and qualitative information on non-
residential contributors, specific subfunctions should also be
completed to provide a total program. For monitoring, there are
well defined intermediate steps that should be accomplished
during the course of the overall program. In a well managed
system for industrial pollutant control, information should be
transferred in a closed loop where monitoring, ordinance com-
pliance, ordinance enforcement and user charge fee determinations
all input to one another.

Purposes

Reports to Permitting Authority

As part of many NPDES permits, POTW1s are required to provide the
NPDES permitting authority, which is either the EPA regional
office or a designated State agency, periodic reports concerning
the nature of industrial contributions to the system. An indus-
trial monitoring program is usually the means by which the infor-
mation required for these reports is collected.
52
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Compliance with Pretreatment Standards

Pretreatment standards fall into three broad categories: general
prohibitions, national technology based standards and locally
developed standards. Under the revised Federal pretreatment
regulations (40CFR403), POTWs will be required to enforce the
first two of the categories of pretreatment standards listed
above. Additionally, under the new regulations, local programs
will be required which may result in the development of local
pretreatment standards. In either case, monitoring of the indus-
trial contributions to a POTW will be required to assure compliance,

Ordinance Development

An ordinance will generally prohibit, or set limits on the release
of specific materials to the municipal wastewater treatment
system. Wastes that cause an explosion hazard, or block or corrode
the sewer are generally completely prohibited. Other pollutants
that may either inhibit biological processes, or pass through the
system, may be limited by ordinance. It is therefore essential
that the monitoring program supply data on the contributions of
prohibited and limited substances. These data are essential to
development of the ordinance limits as well as to the ongoing
enforcement of ordinance requirements.

Analytical Data Base Development

Control of pollutants contributed to POTW systems by industries
requires a thorough knowledge of the normal concentrations of
pollutants in the collection and treatment system. Information
on background levels can shed light on the proportion of a parti-
cular pollutant that originates at industrial facilities and is
therefore controllable. Mass balance calculations for the total
system can provide information on the impact of dilution. A well
conceived monitoring program can form the data base necessary to
quantify both background concentration and dilution characteristics
for the system.

Enforcement

An important function of a monitoring program is its ability to
provide specific information required by enforcement activities.
Enforcement implies that there has been a violation of a regu-
lation. In general, municipalities will use monitoring information
to assess deviations from ordinance stipulations. If conducted
with the proper rigor and quality control, wastewater sampling
and analysis previously performed by the municipality can be used
in enforcement activities directed at ordinance violators. The
final product is defensible data, which when applied to compliance
with the ordinance or other standards, provide the link between
monitoring and the overall control program.

53
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Types of Monitoring

Scheduled Monitoring

Scheduled monitoring involves the systematic sampling and inspection
of significant industrial contributors to the POTW system in
accordance with a predetermined schedule. The schedule should be
developed by the POTW personnel administering the industrial
pollutant control program, and should be maintained as confidential
information so that the industries in the system are unaware of
contemplated monitoring visits well in advance of their occurrence.
Notification is necessary, however, prior to the visit when the
sampling point is located on plant property, to arrange for
required utilities and proper access to sampling areas. The
schedule should attempt to provide for the monitoring of each
significant industrial contributor at least once per year if at
all possible. If resources do not permit this type of coverage,
then visits should be planned as often as possible within the
limitations of available resources.

Scheduled monitoring should serve a number of specific needs,
including: (1) checking for compliance with the ordinance, (2)
user charge and industrial cost recovery determinations, and (3)
completion of required EPA reports. Scheduled compliance moni-
toring should be aimed at obtaining all the information necessary
to determine adherence to the local ordinance. The information
required for user charge and capital cost recovery coincides to a
large degree with the data necessary for the completion of required
EPA reports.

In general, scheduled monitoring would include on-site inspection
of pretreatment facilities and plant operations, and composite
samples and flow measurements taken over a period of several
days. On-site inspection is necessary to insure that pretreatment
facilities are being operated properly and to detect any dilution
of plant wastewaters. The determination of flow is important for
several reasons. Primarily, flow information is essential in the
calculation of user charge fees. Additionally, flow readings are
necessary as an added safeguard against dilution and to confirm
the validity of concentration measurements taken for ordinance
compliance.

The degree of care and conformance to established procedures in
obtaining samples and flow measurements during scheduled monitoring
visits is an extremely important consideration. Information
obtained during this process may ultimately be used in enforcement
activities culminating in court action. Additionally, in the
determination of user charges, the municipality may be compelled
to monitor with sufficient rigor to satisfy the industry that the
information obtained is sufficiently accurate. This situation is
especially valid in those cases where sewer use charges are a
significant expense for the industry.

54
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Unscheduled Surveillance

In addition to the planned approach, POTWs should institute a
less formal type of compliance monitoring designed to provide a
spot check of industrial contributors. This random type of com-
pliance monitoring should be focused on maintaining a degree of
surveillance, and would generally not be formally planned by the
POTW.

Scheduled compliance monitoring is designed primarily to establish
the characteristics of contributions from major sources, whereas
unscheduled surveillance attempts to randomly survey all sources
within the system. By checking all contributors over an extended
period of time, the municipality can continue to expand its data
base, and keep abreast of trends and changes within the system.
This type of monitoring should be conducted on a random basis,
with contributors being observed during normal operation, thus
providing information on the true nature of the wastewater. If
ordinance violations are suspected, the information obtained
during unscheduled surveillance can also be used to evaluate the
need for further, more detailed, evaluation of a particular con-
tributor.

Unscheduled surveillance can be conducted with less rigor than
scheduled compliance monitoring. Since surveillance activities
are intended only to provide a quick spot check to determine the
need for future more detailed analysis and evaluation, this type
of monitoring can be less formal than a full compliance monitoring
visit. Unscheduled surveillance should involve no more than a
few samples, perhaps composited over a short period of time, and
a cursory inspection of plant operations and pretreatment activities,
Where resources are limited, grab samples are frequently used for
this type of surveillance. Flow measurements should be taken if
facilities are available to obtain readings without difficulty.

Demand Monitoring

As the name implies, demand monitoring should be conducted when
an upset or other disruption of system operation occurs, which
may have been caused by an industrial source. Additionally, any
discharge of prohibited or limited materials can prompt demand
monitoring. Specific occurrences that may initiate a demand
monitoring sequence are as follows:

Contributions of Explosive or Corrosive Material to the
Sewer

Release of these types of materials are generally prohibited by
the municipal ordinance. Because of the magnitude and immediacy
of the potential impact of explosive or corrosive materials,
swift location of the source is essential. The most effective
55
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means of locating sources of explosive or corrosive materials is
by utilizing sewer back tracking, which is a systematic search
upstream through the sewer system until the source is pinpointed.

Operating Difficulties

Treatment plant and collection system operating difficulties can
also prompt demand monitoring. One of the more serious operating
problems is caused by the release of materials into sewers which
can cause blockages or plugging. Similarly, excessive quantities
of viscous or floating solids entering a treatment plant can
disrupt unit operations such as sludge digestion. The presence
of excessive foaming can also cause operating difficulties, and
may prompt a demand search. In general, any upset of normal
operating routine may be considered cause for initiating demand
monitoring.

Violation of the POTW's Permit Requirements

A POTW's permit generally contains limits on the concentrations
of specific pollutants that it can discharge to navigable waters.
If the treatment process is disrupted to the extent that these
limits are exceeded, it becomes the responsibility of the muni-
cipality to determine the source of the materials that might be
passing through the system, or causing poor removal of the pollutants
that the treatment system is designed to remove.

Violation of Pretreatment Regulations

Since NPDES permits will now require the development of a control
program that contains requirements for compliance with Federally
mandated and locally enforced pretreatment regulations, a suspected
violation of these standards can initiate demand monitoring. In
such cases, demand monitoring should provide information on the
cause of interferences, and the responsible party. In these
situations, demand monitoring can be most successful when the
municipality has access to a good data base. Using data base
information, the probable sources of interfering materials can
generally be determined and monitored so that responsibility can
be properly assigned.

It should be noted that in those cases where demand monitoring is
prompted by the presence of an explosive material, the removal of
the explosion hazard must have top priority. It is unwise to
attempt sewer backtracking until any possible danger has been
eliminated.

Self-Monitoring

Many of the monitoring activities that have been outlined in the
preceding paragraphs require that samples be taken at the effluent
of an industrial contributor, and analyzed for appropriate pol-
lutant parameters. Depending on the available resources and

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manpower, the municipality may not be able to perform all of the
various monitoring functions required for industrial contributors.
As a minimum, the municipality should attempt to conduct with its
own personnel, compliance and demand monitoring activities for
all significant industrial contributors within the system.
However, complete coverage of all contributors to the POTW may be
more difficult to implement using municipal personnel and resources,
One way to circumvent this problem is to require each major con-
tributor to do its own sampling and analysis, a function which is
usually termed self-monitoring.

Self-monitoring systems require that a mechanism for reporting
and recordkeeping be maintained by the industrial establishment.
Periodic reports would generally be sent directly to the POTW.
The recordkeeping function permits access to a history of source
quantity and quality which can aid in both data base development
and compliance determination.
FIELD CONSIDERATIONS
Background

Organizational and managerial aspects of a monitoring program may
vary considerably from system to system, but the approach to the
technical problems encountered in any field monitoring activities
remain fairly constant. The need to maintain rigor and objec-
tivity dictates that sound, uniform and well defined procedures
be maintained during plant investigations and sampling programs.
Some guidance on how to develop and carry out a monitoring program
is available in an EPA Technology Transfer document entitled,
"Handbook for Monitoring Industrial Wastewater." This document
describes technical aspects of monitoring, but its major emphasis
is directed at industries discharging directly to navigable
waters that are engaged in self-monitoring activities. Although
many of the details remain the same, field considerations for
monitoring industrial contributors in a pretreatment situation
have a slightly different orientation. Special field consider-
ations for monitoring pollutants introduced into POTW's are
outlined in this section.
Preparation for a Monitoring Visit

Industries should not be notified well in advance of scheduled
monitoring or unscheduled surveillance visits. It is generally
agreed that by not giving prior notice to the industry, the
samples that are obtained will be more representative of daily
operation. Nevertheless, notification just prior to the visit is
necessary when the sampling point is located on plant property,
to allow for necessary utility and access arrangements by plant
personnel.
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Prior to sampling at a contributor, the sampling crew or inspector
should obtain specific information about the industry. During the
initial visit, a plant inspection report should be prepared.
Several specific items should be included in this report:

A sketch of the location of all wastewater effluent
lines that flow into the publicly owned sewer system.
The sketch should also include the layout of major
plant features.

A description of major product lines and processes
utilized within the plant.

A detailed description and appropriate sketches of
existing pretreatment facilities, including operating
data if available.

A list of pollutants of interest at the plant, with
emphasis on materials limited or prohibited by the
ordinance.

A list of raw materials or products stored at the plant
that may have a pollutant potential.

Scheduling

An attempt should be made to systematically cover all significant
contributing industries annually if resources permit. After
initial data base development, monitoring should be conducted at
each major contributor to determine progress toward compliance.
Once compliance is achieved, the contributor must be sampled
periodically to assess continued compliance. Additionally, when
a scheduled compliance monitoring visit uncovers a violation,
scheduling should be altered to provide more detailed analysis of
the wastewater. This extended sampling program is normally required
to obtain data sufficiently valid for enforcement activities.

In all cases, the frequency and order of investigations should be
determined on the basis of size and importance of the contributor.
Sampling should be started with the largest, or most significant
industry. Once the major industries are covered for data base
and initial compliance purposes, a continuing program of follow-
up monitoring should be instituted. It may not be within the
resources of the municipality to cover all contributors within
its system thoroughly and equally. A schedule in which major
contributors are monitored more frequently than minor contributors
will generally be necessary.
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Sampling and Flow Measurement

On-site inspection, flow measurement and sampling should be
accomplished during each visit. Accurate flow measurement and
sampling techniques are of prime importance in obtaining valid
monitoring information. Both flow measurements and sampling can
be accomplished either manually or through the use of automatic
devices. Three types of sampling may be utilized:

Grab samples, in which a single volume of wastewater is
obtained and analyzed. This type of sample will not
always provide an accurate measure of wastewater char-
acteristics, especially when the flow is heterogeneous,
or varies with time.

Simple composite sampling is a timed sequential col-
lection of equal volume grab samples that are combined
in a single reservoir. This type of sample can give a
partial evaluation of the variability of wastewater
composition with time. It does not provide any measure
of the total pounds of pollutant discharged since
pollutant loading is a flow related value.

Flow proportioned composite samples are obtained by
collecting incremental samples with volumes proportional
to flow. This type of sample, when analyzed and com-
pared to total flow, provides the most accurate measure
of wastewater quality and pollutant loading.

Automatic sampling devices that can obtain all three sampling
types are commercially available. These automatic samplers vary
over a wide range in cost, applicability and reliability. Two
EPA documents are available which provide thorough evaluation of
commercial automatic samplers:

"Sampling of Wastewater," by Philip E. Shelley, available
through EPA Technology Transfer

"Wastewater Sampling Methodologies and Flow Measurement
Techniques," by Daniel J. Harris and William J. Keffer,
EPA Report 907/9-74-005

The second document also includes information on the performance
of portable automatic flow measuring devices. There are consid-
erably fewer devices of this type on the market than automatic
samplers. However, a few portable instruments are available that
can provide reasonably accurate flow measurement data.

For the smaller system, or those municipalities that have only
limited resources, both sampling and flow measurement may be
accomplished using manual techniques. All three sample types can
be collected using manual methods. In general, there is little
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equipment commercially available for manual sampling. What is
usually needed is an extendable pole, with a stoppered bottle
attached to the end. This type of sampling pole can be easily
fabricated. The sample bottle should be hinged so that it can be
tilted to align parallel to the wastewater flow. This orientation
allows for sampling from very shallow streams. The bottle stopper
would be attached to a string so that it can be removed while the
sample bottle is submerged.

Magnitude of Errors

Special attention should be paid to the accurace of sampling
activities. Sampling errors can range up to 200% of the true
value. The basic problem results from the fact that the typical
industrial waste may have a large proportion of its pollutants in
the form of suspended solids. As a result, it is important that
the quantity of suspended solids entrained during sampling be
proportional to the suspended solids content of the total waste-
water stream. Common practice is to simply place a suction tube
in the wastewater flow, or to immerse an open sampling bottle in
the stream. Since solids entrainment is a velocity controlled
process, an attempt should be made to obtain samples isokineti-
cally. There should be a minimum fluid velocity difference
between the interior and exterior of the sampling tube. Accom-
plishing this type of sampling is a difficult procedure, but the
situation can be significantly improved by aligning the sample
tube such that it is facing upstream and is secured rigidly in
place. Because of the potential for large errors associated with
sampling, it is essential that extreme care be exercised in
selecting sampling devices and procedures.

With regard to flow determination, the accuracy of any flow
measurement depends greatly on the control surface utilized.
Some ordinances may require that major contributors install a
special control manhole designed to provide sufficient access for
sampling and an appropriate control surface*for flow measurement.
Depending on the situation, permanent flow recording equipment
may also be required.

The installation of a standard weir or flume makes flow measure-
ment a simple matter of measuring wastewater depth. No control
surface is completely accurate, but the combined use of a quality
automatic flow measuring device and a control surface can typically
yield flow measurement accuracy of better than - 15%.
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Sampling and Analysis for Priority Pollutants

Complicating the equipment and techniques needed for accurate
wastewater sampling and analysis are the detailed requirements
associated with detection of trace quantities of the priority
pollutants. The term "priority pollutants" refers to a list of
toxic materials suspected in the effluents from the 21 consent
decree industries. Because of the very low concentrations and
difficult analytical methods associated with these pollutants,
special sampling techniques are required. For analysis of the
organics on the priority pollutants list, samples are collected
in specially prepared, organic free glassware. Similarly, care
must be taken to assure that samples are not contaminated during
the sampling process. Specifically with regard to detection of
phthalate esters (one group within the list of priority pollutants)
typical automatic samplers cannot be easily used because of the
potential for leaching of phthalates from the plastic tubing into
the sample.

The examples cited above illustrates the complexity involved in
looking for priority pollutants in industrial contributions. EPA
has issued several protocols for priority pollutant sampling and
analysis which should be studied in depth before attempting
detection of these materials.
Sample Handling

Stabilization

Once an accurate sample has been obtained, several steps should
be taken to assure that the validity and objectivity of the moni-
toring operation is maintained. All samples must be properly
preserved. Sample preservation techniques are outlined in various
analytical handbooks such as Standard Methods and the EPA Chemical
Methods Manual. The content of these and other similar handbooks
are discussed in more detail in the section devoted to laboratory
considerations in monitoring.

Because of the heterogeneous nature of many industrial waste-
waters, the parameters to be analyzed may require the use of
incompatible stabilizing reagents. To solve this problem, it is
usually necessary to take a relatively large volume of sample, so
that it may be divided for appropriate preservation. In addition
to assuring adequate volume for sample preservation, sufficient
sample size must be maintained so that a portion of the sample
can be offered to the industrial contributor. The option should
be given to the industry of independently checking the munici-
pality's analytical results if they so desire.
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Chain of Possession

Once an appropriate sample is obtained and properly stabilized,
it is essential that the possession of the sample be properly
documented. That is, the person completing the field sampling
should maintain a log, containing pertinent information such as
date, time and location of the sampling activity. Before re-
leasing the sample to the laboratory, or any other appropriate
official, a signed receipt should be obtained documenting the
exchange. As the sample is transported, a continuous history of
its condition and locations should be maintained through succes-
sive log entries and receipts.

The reason for such caution in the handling and transfer of
samples stems from the need to be certain of sample integrity as
part of any enforcement activity. It should be assumed that
every scheduled compliance monitoring sample may become evidence
in a court of law. In practice, few ordinance violations will
require legal action, but nevertheless, sample integrity must be
maintained. If the municipality cannot prove that a sample has
not been mishandled or tampered with, then any inferences regarding
the quality of the wastewater that the sample represents fall
into jeopardy. It is therefore essential that a chain of pos-
session be maintained and recorded.
Split Sampling

The facility being sampled will often request parallel sample
portions for separate confirming analysis. These samples,
commonly referred to as "split samples" are usually obtained by
dividing the collected samples and providing half to the plant.
Split sampling may be required at the discretion of the plant
being sampled. In all cases the parallel analysis can provide
valuable back-up information, as well as fostering good will with
the industry being sampled.

On-Site Safety

Visitors to industrial establishments are usually required to
abide by any safety regulations observed by plant management.
Ideally, access to wastewater flows should be available from
manholes or junction boxes located outside of plant property. In
this way, plant inspectors would not be exposed to any hazardous
operating activities and would be able to sample without the need
to gain entry to the plant. Unfortunately, accessible manholes
located outside of plant boundaries are rare, and consequently
inspectors are generally required to enter plant property. Under
these circumstances, all pertinent safety rules in force at the
plant must be adhered to. The first step upon presenting cre-
dentials and entering the plant, is to notify appropriate plant
management, and request applicable safety information. In most
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cases, a formal set of safety rules are in effect, and these
rules should be recorded and filed with the plant inspection
report.

Equipment Set-Up and Field Analysis

In the absence of a control manhole equipped with brackets or
ledges for mounting automatic samplers and flow measuring devices,
a method must be devised for securing and mounting equipment.
Within the boundaries of a plant some degree of security can be
assumed, but unattended sampling points in public areas can be
tempting to vandals. One solution to this type of field problem
is the use of a self-contained trailer or van outfitted with
appropriate materials and equipment. A further advantage to using
a monitoring vehicle is that the time required for set-up and
removal of equipment is greatly reduced. Furthermore, the
vehicle can be outfitted with appropriate field analytical equip-
ment. Certain parameters require immediate analysis upon sampling,
such as dissolved oxygen and pH. Equipment for these analyses
can be mounted in the vehicle to facilitate rapid analysis.

For the small system, resources may not be available, nor the
need apparent, for a sophisticated well equipped monitoring
vehicle. At the very least, a compact package containing neces-
sary equipment should be utilized. A minimum number of separate
equipment packages should be maintained, with the dimensions of a
foot locker being an ideal size for each equipment carrier.

Use of Control Manholes

For the larger contributors, the frequency of sampling activities
may make the use of a permanent sampling facility cost effective.
A manhole through which the total plant sewer discharge flows is
commonly outfitted with permanent equipment for sampling and flow
measurement. At a minimum, brackets and ledges appropriate for
mounting flow measurement and sampling equipment should be provided,

Continuous On-Line Monitoring

In recent years, equipment has been developed which can auto-
matically monitor various wastewater characteristics. For indus-
trial wastewaters, numerous constituents may be of interest.
However, as a result of operating difficulties, generally only a
few parameters can be successfully analyzed on a continuous
basis.

The sensors typically used in automatic monitoring equipment are
often very sensitive to interferences found in wastewater, and as
a consequence great care should be exercised in choosing this
type of specialized equipment. Because of the commonly encountered
operating difficulties, continuous on-line monitors generally
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require a high level of maintenance and attention. If the equip-
ment works well, it can serve as an excellent source of continuous
data which will not only aid in wastewater and process operation
evaluations, but through the use of auto punching can also reduce
the amount of manual handling of data.

Various manufacturers offer continuous on-line analytical equip-
ment which can provide excellent monitoring information. However,
it should be noted that automatic analysis is still a developing
technology, which should be approached with an appropriate degree
of caution.
LABORATORY CONSIDERATIONS
Background

Once an administrative approach, and technical methodology are
developed for obtaining industrial wastewater samples, a mechanism
for accurate and rapid analysis of the samples must be provided.
It is essential that analytical results be accurate and repro-
ducible to assure that monitoring activities will provide the
quality of information necessary for a successful industrial
pollutant control program.

Standard Analytical Techniques

Precise and well recognized techniques have been established for
the analysis of wastewaters. EPA has promulgated rules and regu-
lations on this subject entitled "Guidelines Establishing Test
Procedures for Analysis of Pollutants," dated December 1, 1976.
These rules stipulate specific analytical methods that are recom-
mended by EPA for the determination of 115 chemical and biological
parameters as reported in three analytical handbooks. The three
referenced manuals are:

"Manual of Methods for Chemical Analysis of Water and
Wastes" available through EPA technology Transfer.

"Standard Methods for the Examination of Water and
Wastewater," published by the American Public Health
Association.

"Annual Book of Standards, Part 31, Water, Atmospheric
Analysis, 1975," published by the American Society for
Testing and Materials (ASTM)

Each of these documents provides a short synopsis of the analy-
tical method for each parameter, information on interfering sub-
stances, and step-by-step instructions on how to carry out the
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analysis. Also included is information on the calculation of
results, the precision and accuracy of the analytical method, and
techniques for chemically stabilizing and preserving samples.

These three publications should be considered a minimum require-
ment for any analytical laboratory. These manuals and handbooks
supply the basic information that a trained lab technician would
need to successfully perform nearly all analytical procedures
that may be required in connection with monitoring programs.

Analytical Quality Control

The potential errors encountered during analysis of wastewater
samples, although not as great as the errors associated with poor
sampling techniques, can nevertheless have a great impact on the
acceptability of monitoring information. Without the aid of
independent checks and general quality control, the lab technician
can report erroneous results without being aware that a problem
exists.

Analytical quality control assistance is available in several
forms from EPA. A document entitled "Handbook for Analytical
Quality Control in Water and Wastewater Laboratories," has been
published by the EPA Technology Transfer Program. In this hand-
book, specific information is provided that can guide the lab
technician or chemist toward sound and reliable techniques and
procedures. In addition, standard approaches to data handling
and reporting, and information on calibrating equipment are
included.

The EPA "Manual of Methods for Chemical Analysis of Water and
Wastes" also includes information pertinent to laboratory quality
control. Each of the ten EPA regional offices has an office of
Analytical Quality Control headed by a Regional Analytical Quality
Control Coordinator.

Included in the EPA Methods Manual are a listing of the ten
Quality Control Coordinators, accompanied by appropriate addresses
and telephone numbers. Through the Quality Control Coordinators,
any interested party can obtain preanalyzed samples that can be
used to test the accuracy of analytical techniques. Periodic
analysis of known samples can provide the lab technician with an
independent check of his accuracy, providing the opportunity to
correct any improper procedures.

Laboratory Equipment

A document entitled "Estimating Laboratory Needs for Municipal
Wastewater Treatment Facilities" published by the Operation and
Maintenance Program of the EPA Office of Water Program Operations,
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provides specific information on the minimum requirements for
laboratory facilities at various sized wastewater treatment
plants. This publication also includes recommendations on how a
laboratory operation may be altered to handle the analysis of
pollutants contributed by non-residential sources.

Laboratory equipment required for a municipal wastewater treat-
ment plant is generally standard, with variations occurring only
in degree, as the size of the plant varies. If, however, a
publicly owned system receives wastewater from a particular
industry, specialized analytical equipment may be required. The
range of applicability of several special types of equipment are
discussed in the following paragraphs.

Atomic Absorption

Atomic absorption spectrophotometry provides a rapid and easily
performed technique for the analysis of metals in wastewater.
Nearly all of the more than thirty elements that can be analyzed
by atomic absorption, can be analyzed by standard wet chemical
techniques. However, the wet chemical methods can be tedious and
time consuming, requiring detailed sample pretreatment procedures.
Atomic absorption methods provide for metal analyses with minimum
sample preparation and, in many instances, analyses can be com-
pleted to the parts per billion level, which is not attainable
with standard wet chemical techniques.

In some respects atomic absorption does have limitations. In all
cases, atomic absorption provides only the total concentration of
the element. Unless specialized pretreatment is utilized, no
breakdown of oxidation state or ionic species can be determined.
However, for the analysis of metals at very low concentrations,
atomic absorption is unsurpassed in speed and accuracy. In
situations where a large number of metal analyses may be neces-
sary, such as those POTW1s that receive wastewaters from metal
processing or finishing industries, atomic absorption capabil-
ities may be required. But in all cases, the relatively high
cost of atomic absorption equipment should be weighed against the
need for high volume trace metal analysis.

Specific Ion Electrodes

Specific ion electrodes are sensing probes that can detect the
concentration of chemical species when immersed in a solution
containing the substance to be measured. As long as the probe is
completely submerged, a concentration can be measured regardless
of the volume of sample present. In contrast to atomic absorption,
specific ion electrodes, as the name implies, detect only certain
ionic species as they exist in solution. As a consequence,
specific ion electrode readings are greatly dependent on the
environmental conditions within the sample, such as pH and
oxidation-reduction potential.

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More than two dozen ionic species can be analyzed using specific
ion electrodes. Analyses are rapid, but require some pretreat-
ment to remove interferences prior to simple immersion of the
probe in the sample and meter readout. The drawbacks to this
type of specialized equipment include possible fouling of the
probe membrane, long readout equilibrium periods and the ability
to detect only specific ionic species. However, progress is
continually being made in ion sensing electrode technology.
Excellent use has been made of the commercially available dis-
solved oxygen probes for measuring oxygen demand, and an ammonia
sensing electrode has been successfully used for monitoring
nitrification in an activated sludge treatment plant. Because of
the potential ease and speed of analysis that can be realized
with specific ion electrodes, consideration should be given to
the possible use of these methods for selected ionic species.

Automatic Analyzers

A few manufacturers currently market automated wet chemical
analyzers that are typically called automatic analyzers. These
devices automatically draw a small sample, add pretreatment
chemicals, filter the sample if necessary, add chemicals to
develop a color with an intensity proportional to the concen-
tration, and finally automatically read and record the concen-
tration proportional to the developed color. Other more sophis-
ticated automatic analyzers may use infrared or ultraviolet
spectrophotometric detection, and some use fluorometers of flame
photometers. In effect, the typical automatic analyzer eliminates
the steps that a technician would have to perform in carrying out
typical wet chemical analysis.

Although an automatic analyzer can greatly reduce the time
required to perform a particular analysis, use of these instru-
ments is only economical when the analysis is required on a mass
production basis. Furthermore, automatic analysis instruments
are relatively complex devices that can require a substantial
maintenance effort. As indicated for the other specialized
equipment, automatic analyzers should only be used when the
presence of a specific pollutant contributed by a particular
industrial source is so important that frequent analyses are
required.

IR-UV Spectrophotometry

Infrared (IR) and ultraviolet (UV) spectrophotometers, like gas
chromatographs are used to analyze for organic materials in
wastewater. UV spectrophotometry has been used recently for
detecting oil and grease in wastewater samples. However, these
two types of specialized equipment generally have only limited
and specialized uses because of cost and the requirement for
skilled operators.
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Gas Chromatography - Mass Spectrometry

Gas Chromatography (GC) refers to several variations of a technique
in which a wastewater sample is vaporized and the organic fraction
is analyzed. GC alone is most useful in analyzing for a particular
pollutant in a relatively homogeneous wastewater. However, with
complex mixtures of organic pollutants, GC often cannot distin-
guish between similar organic materials. In such cases, GC
analysis is coupled with Mass Spectrometry which is capable of
sorting charged gas ions according to their masses. The combined
GC-MS systems are capable of measuring trace organics to the part
per billion level.

GC-MS is by far the most effective way of analyzing for trace
organics in wastewater. However, most GC-MS systems are relatively
expensive and require highly skilled operators. As a result,
this type of equipment finds only limited application in POTW
analytical laboratories.

Special Analytical Considerations

Underlying the compliance and enforcement uses of analytical data
is the need to know the true composition of wastewater contri-
butions so that the presence of harmful materials can be detected.
In general, EPA recommends that wastewater samples be stabilized
in a manner that will solubilize otherwise insoluble, or suspended
materials. This is an especially important factor in the case of
metals which are generally insoluble at high pH levels. Metal
concentrations are of particular interest to plant operators
since relatively small quantities of these materials can cause
operating problems. However, the metallic pollutant generally
must be in solution before it can cause an upset of biological
treatment processes. As a result, the practice of acidifying
samples and obtaining total, rather than dissolved metal concen-
trations can give misleading results for samples with high pH
levels. Metallic pollutants at high pH values would tend to be
in the form of suspended solids, and would more likely be sub-
stantially removed prior to reaching biological treatment facilities,
Consequently, the impact of a wastewater stream can greatly
depend on the pH of the wastewater as it enters the treatment
system.

Another similar example is the importance of the oxidation state
of the constituent being measured. For example, hexavalent
chromium is generally considered to have a greater impact on
biological treatment processes than trivalent chromium. The
impact of hexavalent chromium can be significant, but the typical
environment in a sewer system would tend to reduce this material,
and often ensure that only trivalent chromium reaches the treat-
ment plant. Clearly, the analysis of wastewaters containing
materials which depend on the conditions in the sample, must be
approached prudently, considering the state of the pollutant as
it enters the treatment system.

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Personnel and Degree of Expertise

Laboratory manpower requirements are outlined in the Operation
and Maintenance Program document "Estimating Laboratory Needs for
Municipal Wastewater Treatment Facilities." Some quantitative
information is provided for determining how laboratory manpower
should be altered to handle non-residential contributions.
Although a thorough general analysis is provided in the publi-
cation, it should be noted that each system presents a unique
situation. Nevertheless, it can be stated in general terms, that
any monitoring program will require an added degree of laboratory
support.

For very small systems with few industrial contributors, the
additional analytical work can probably be handled by the tech-
nician performing regular sanitary chemistry. Larger systems may
require the addition of personnel to handle the greater load
created by the industrial monitoring program.

If analyses in connection with the monitoring program require the
use of any of the specialized analytical equipment outlined
above, technicians or chemists with more than the usual level of
expertise may be required. Although the utilization of specific
ion electrodes is relatively simple, proper use of atomic absorption,
automatic analyzers, gas chromatographs or IR-UV spectrophotometers
does require a higher degree of expertise. Automatic analyzers
and atomic absorption require good technique, and special attention
to equipment maintenance. In order to properly utilize either
GC-MS techniques or IR-UV spectrophotometry, special technical
expertise beyond the four-year college level may be required.

Correlation of Analytical Techniques

In determining compatible pollutant loadings, it is necessary to
analyze industrial wastewater contributions for the typical
oxygen demand parameters. BOD historically has been used to
measure oxygen demand, but this test is time consuming and can be
inaccurate. COD has been used in place of BOD, but it too can be
tedious, and it also takes a significant amount of time to complete.
In recent years, catalytic oxidation approaches have been developed
that yield measures of oxidizable substances that can be correlated
to the more standard BOD or COD tests. These analyses, which are
termed total organic carbon (TOC) and total oxygen demand (TOD),
are rapid and reproducible.

A large body of data has been developed showing that the more
rapid TOC and TOD methods can be correlated to BOD, and therefore
can act as a more efficient measurement tool for an operating
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facility. Other similar correlations can be developed that can
increase the efficiency of laboratory operations. For example,
oil and grease is usually measured by an extraction gravimetric
technique. This measurement can be simplified or accelerated by
utilizing a UV spectrophotometer to detect the levels of organics
if this type of device is available. Substitutions of methods
that are either faster, more accurate, or encompass a broader
range of parameters should be considered for unofficial use, when
they can be correlated to standard methods.

Standard Reporting Procedures

Laboratory data handling and reporting require two basic con-
siderations; reliable methods for recording both laboratory and
field data, and criteria for determining the significance and
acceptability of the data. Without a good system in which
standard procedures are used for accurate recording of analytical
and field data, the usefulness of the information obtained from
monitoring operations can be greatly diminished. Standard forms
should be developed for recording field information, which would
include the conditions at the time of sampling. All laboratory
data should be recorded in bound notebooks with numbered pages.
This assures a continuity in time, with a sequence for all
analytical data. All forms should be completed in duplicate,
with each copy being stored separately as a precaution against
accidental loss of data.

Of equal importance to proper recording methods is the signif-
icance and acceptability of data collected. One must be certain
that the sample being analyzed is representative, and has not
been influenced by infrequent or rare laboratory or plant occur-
rences. Numerous statistical techniques are available that can
provide a measure of the appropriate confidence that should be
assigned to the data. These statistical techniques are adequately
covered in several of the handbooks cited above. However, caution
should be exercised when using statistical methods.

Generally, statistics offer a means by which variations in a set
of data can be analyzed, assuming that all of the data used in
the analysis are equally valid. Although statistics can be a
powerful tool, it is always preferable to evaluate the significance
of data variation on the basis of first-hand knowledge of the
situation during sampling and analysis. Many times, if unusual
circumstances are apparent, the data can be eliminated from
consideration by inspection, and the problem can be rectified
without the use of more sophisticated statistical analysis.

Contracting for Analytical Services

Many of the considerations discussed above concerning laboratory
aspects of a monitoring program are based on the assumption that
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a POTW either has an existing laboratory which will be expanded
to handle industrial wastewater, or has the resources to develop
such facilities. This may be true for the larger systems, but
the more numerous small systems may not have the resources or
capability to complete the necessary analyses required for proper
monitoring of industrial wastes. In such systems, analytical
work must frequently be performed by commercial laboratories.
When choosing a laboratory several criteria should be considered
to assure that proper services are being provided.

At the present time only a few states have developed a certi-
fication system for commercial laboratories. EPA is currently in
the process of developing a guidance document for lab certifi-
cation programs. As a result, for the short term, POTW1s wishing
to engage qualified laboratory services will be required to
evaluate laboratory performance independently. For the long
term, use may be made of the upcoming guidance to be supplied by
EPA.

Several techniques can be used to compare the quality of analytical
services provided by commercial labs:

Use of samples spiked with known amounts of pollutants
of interest. Chemicals used in the spiked samples can
be obtained from the appropriate EPA Regional Quality
Control Coordinator. Use of spiked samples is a de-
sirable method for testing laboratory performance when
analyzing complex wastewater mixtures.

Parallel analysis of identical samples at two or more
commercial labs. This procedure can provide information
on the relative performance of the laboratories in
question.

Adherence to standard procedures is essential, and as a
result should be used as a primary criteria for evalu-
ating lab performance.

Competitive costs are also important, providing that an
acceptable quality of analytical services is provided.
71
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REFERENCES
1. "An Industrial Waste Sampling Program," Woodruff, Paul H.,
Journal of the Water Pollution Control Federation,
Vol. 37, No. 9, p. 1223 (September, 1965).

2. "Automatic Samplers for Sewage and Effluents," Levin, V. H. and
A. Latten, Process Biochemistry, June, 1973, p. 15.

3. "Comparison of Wastewater Sampling Techniques," Tarazi, D. S. et.
al., Journal of the Water Pollution Control Federation, vol. 42,
No. 5, p. 708, (May, 1970).

4. Federal Guidelines - State and Local Pretreatment Programs, U.S.
Environmental Protection Agency Publication No. EPA - 430/9-76-017a,
MCD-43, January, 1977.

5. "Gauging and Sampling Industrial Wastewater (Open Channel)," Klein,
Larry A. and Albert Montague, Journal of the Water Pollution Control
Federation, Vol. 42, No. 8, p. 1468 (August, 1970).

6. "How to Measure Industrial Wastewater Flow," Thorsen, Thor and Rolf
Oen, Chemical Engineering, Vol. 82, No. 4, p. 95 (February 17, 1975),

7. Industrial Waste and Pretreatment in the Buffalo Municipal System,
U. S. Environmental Protection Agency Publication No. EPA-600/2-77-
018, MCD31, January, 1977.

8. "Make Water Pollution Control a Meaningful Local Responsibility,"
Craddock, John M., The American City, May, 1974, p. 63.

9. "Routine Surveillance Alternatives for Water Quality Management,"
Ward, Robert C., Journal of the Water Pollution Control Federation,
Vol. 46, No. 12, p. 2645 (December, 1974).

10. Williams, R. T. and Dolan, R. J. How to Manage Industrial Inflow,
Water and Sewage Works, December, 1974 p.46 - 49.

11. Williams, R. T., Classifying Industrial Wastewater Emissions, Water
and Sewage Works, July, 1974, p. 86 - 89.
72
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THE IMPACT OF TOXIC POLLUTANTS

ON MUNICIPAL WASTEWATER SYSTEMS

Prepared For

ENVIRONMENTAL PROTECTION AGENCY
TECHNOLOGY TRANSFER
JOINT MUNICIPAL/INDUSTRIAL SEMINAR

PRETREATMENT OF INDUSTRIAL WASTES

1978

Prepared By

H.G. Schwartz, Jr. and J.C. Buzzell, Jr.
Sverdrup and Parcel and Associates, Inc.
73
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THE IMPACT OF TOXIC POLLUTANTS ON MUNICIPAL WASTEWATER SYSTEMS
Henry G. Schwartz, Jr., Vice President
James C. Buzzell, Jr., Chief Engineer
Environmental Division
Sverdrup & Parcel and Associates, Inc.
With the passage of the Clean Water Act of 1977, the focus on the control
of point source discharges has expanded from conventional parameters,
such as BOD and suspended solids, to the so-called toxic pollutants.
Section 307 (a) of the Act requires that effluent limitations be estab-
lished for toxic pollutants for the various industrial categories. In a
similar manner, pretreatment standards are to be developed under Section
307 (b) for any pollutant that "interferes with, passes through, or
otherwise is incompatible" with publicly owned treatment works (POTW).
The pollutants to be considered for pretreatment standards include the
same set of toxic pollutants considered for direct dischargers. The
legislation specifically references a list of 65 pollutant classes
orginally identified in the Consent Decree in NRDC vs. Train, 8 ERC 2120
(D.D.C. 1976).

It is the purpose of this paper to provide a broad overview of the
current state of knowledge regarding the effects of these toxic pollutants
on POTW and on the water, land, and air environments to which they may
ultimately be released. The discussion is divided into several major
areas. First, the paper briefly reviews pertinent aspects of the new
pretreatment regulations and introduces the subject of toxic pollutants.
Second, information on the interference or inhibition of the POTW opera-
tions by metals and, separately, by organics is presented. Third, the
impacts of toxic pollutants on the receiving water, land, and air is
broadly examined. And, finally, the interim pretreatment standards for
eight industries are discussed.

PROHIBITED AND CATEGORICAL PRETREATMENT STANDARDS
Under the new pretreatment regulations, 40 CFR part 403, two types of
federal pretreatment standards are established. The first, "prohibited
74
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discharges," are specifically identified in Section 403.5 of the new
regulations. All industrial users, regardless of size or industrial
category, are subject to the prohibitions given in this section.
Specifically, the following pollutants may not be introduced into POTW:

0 Pollutants that create a fire or explosion hazard.
0 Pollutants that will cause corrosive damage to POTW, more
specifically discharges with pH values below 5.0.
0 Solid or viscous pollutants in amounts that could cause ob-
struction in sewers or otherwise interfere with the operation
of POTW.
0 Slug discharges, in terms of volume, strength, or oxygen
demand, of such magnitude as to cause treatment process upsets
and subsequent loss of treatment efficiency.
0 Heat in amounts that will inhibit biological activity at POTW,
specifically discharges that cause the temperature at the
POTW influent to exceed 40°C (104°F).

The second type of pretreatment control are the ""categorical standards."
These standards will be developed for individual industrial point source
categories and published as separate regulations in 40 CFR Chapter I,
Subchapter N. The national categorical pretreatment standards will
place specific limitations on the concentrations or quantities of pollu-
tants that may be discharged to POTW by new or existing industrial
users. The standards will be technology based requiring the use of the
"best available technology economically achievable" for existing industrial
users and "best available demonstrated control technology" for new
sources.

Attention will be focused initially on developing national pretreatment
standards for toxic pollutants for the 21 industrial categories listed
in the Consent Decree. The 65 highest priority toxic pollutants ref-
erenced in the Act will be candidates for pretreatment standards subject
to their presence in the wastewaters from the 21 specific industries and
their compatibility with POTW. Limitations established under this
regulation will be in terms of concentration with equivalent mass units
provided wherever possible.
75
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In developing categorical pretreatment standards, the question of compati-
bility with POTW must be addressed. Compatible pollutants are those
that POTW are capable of treating, including BOD and suspended solids,
and will not be covered by federal pretreatment standards or guidelines.
Incompatible pollutants are those that interfere with the operation of
POTW, pass through POTW into the environment, or contaminate the sludge
and other residues from POTW. Each of the toxic pollutants will be
evaluated to determine its compatibility/incompatibility in POTW. Most,
if not all, of the 65 toxic pollutants will be subject to numerical
categorical standards as incompatible pollutants.

In addition to toxic incompatible pollutants, there are certain substances
that are non-toxic, but incompatible with the operation of POTW. Excessive
concentrations of oil and grease (of a mineral origin) and ammonia are
examples of non-toxic incompatible pollutants. Such substances will not
be subject to federal pretreatment standards. Rather, the EPA will
issue guidance documents to assist state and local authorities in control-
ling these substances.

TOXIC POLLUTANTS
The 65 classes of toxic pollutants referenced in the Clean Water Act
were selected as the most important of 232 pollutant categories consid-
ered to be of the greatest environmental concern. The selections were
based on the following criteria:

0 "Substances for which there is substantial evidence of carcino-
genicity, mutagenicity and/or teratogenicity;
0 Substances structurally similar to the aforementioned compounds
or for which there is some evidence of carcinogenicity, muta-
genicity, or teratogenicity; and
0 Substances known to have toxic effects on man or aquatic
organisms at sufficiently high concentrations and which are
present in industrial effluents."

Within the 65 classes, 129 specific elements or compounds have been
identified as priority pollutants. These include 13 metals, 114 or-
ganics, plus cyanides and asbestos. The 13 metals are listed in Table 1
76
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and a complete list of all 129 elements or compounds is provided in
Appendix A.

Table 1
Priority Pollutants - Metals

Antimony Mercury
Arsenic Nickel
Beryllium Selenium
Cadmium Silver
Chromium Thallium
Copper Zinc
Lead

HEAVY METALS
Although the heavy metals are often thought of as a group because of
their several common characteristics and behavioral properties, each has
distinctive characteristics that influence its behavior in POTW and the
effect that it will have on the environment. In addition to the indi-
vidual characteristics of the metals acting alone, synergistic or
antagonistic effects have been observed between metals in terms of
removal, toxicity, etc.

Generally, the insoluble compounds and complexes of the metals tend to
be more prevalent than the dissolved forms in municipal wastewaters and,
as will be discussed later, efficient removal of suspended solids tends
to increase removal of heavy metals in POTW. Metals, however, can also
exist in solution and in various complexes with organic material, and
the ratio of soluble to insoluble forms varies widely.

The concentration of metals generally is higher than the concentration
of individual toxic organics. Metals are not appreciably biodegradable
and removal mechanisms depend upon physicochemical processes. While
there is still much to be learned about the behavior of metals and their
impact on POTW, there has been a considerable amount of research on this
subject in recent years.
77
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ORGANICS
The organics can be subdivided into the following broad classifications:

Aliphatics 36
Aromatics 59
Pesticides _T9
114

Approximately 30 of these organic compounds can be considered volatile,
and 69 contain chlorine. Typical examples of the molecular structure of
some of these organic pollutants are given in Figures 1, 2, and 3.

Compared to the metals, the majority of the toxic organic compounds are
present in municipal wastewaters at much lower concentrations, some in
only fractions of micrograms per liter. These concentrations will be
relatively insignificant compared to the organics that are measured by
the standard BOD, COD and TOC tests. The organics provide a much greater
variety of molecular structures and behavioral patterns in POTW.

The organic compounds exhibit a wide degree of solubility, which greatly
affects their treatability. Unlike the metals, some of the toxic organic
compounds are biodegradable, although few could be regarded as highly
desirable food for microorganisms in biological treatment systems.

TOXIC METALS IN POTW
A primary concern with toxic pollutants in municipal wastewaters is the
interference with or inhibition of the wastewater treatment process.
Biological treatment processes are known to be very susceptible to
relatively small quantities of some toxic substances. Of the- 129
priority pollutants, the 13 heavy metals are best understood in terms of
their inhibitory effect on conventional POTW.

A recent EPA funded survey (38) collected data from POTW in order to
determine influent levels, removals, sludge concentrations, and other
information for 21 heavy metals, including 10 of the 13 on the priority
list. The information consisted of historical data collected from POTW,
78
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regional EPA offices, previous EPA surveys, and, to a limited extent, the
literature. The results of the survey, which will be discussed herein,
represent data from 103 POTW scattered across the country. Of the 13
metals listed in Table 1, sufficient data were available to provide some
insight into the behavior of cadmium, chromium, copper, lead, mercury,
nickel, and zinc in POTW.

POTW INFLUENT LEVELS
For each of the metals, the average influent concentrations to the POTW
were arranged in sequence by magnitude and plotted on logarithmic
probability paper. The data for cadmium, chromium, and nickel are
presented in this manner in Figures 4, 5, and 6 as examples. The steeper
the slope of the plots, the greater the range, or diversity, among
treatment plants. The middle 70 percent of the POTW was arbitrarily
selected as being representative. On this basis, the influent levels
for the seven metals are summarized in Figure 7, which shows the median
value and the middle 70 percent range. Influent concentrations of
chromium, copper, lead, nickel, and zinc were all roughly equal, with
cadmium and mercury being at much lower levels.

There are several interesting aspects to the data. Except for zinc, few
of the 103 POTW have concentrations greater than 1 mg/1 (1,000 ug/1) for
any of the heavy metals. Another element of interest is the wide range
of values observed in the survey. The maximum value for a given metal
is at least two orders of magnitude greater than the minimum value, and
the range is more than three orders of magnitude for mercury and chromium.
Such wide ranges among POTW are much greater than associated with con-
ventional parameters such as BOD, solids, and nitrogen. Undoubtedly,
the industrial waste contributions in the various cities account in part
for the fluctuations.

A limited amount of data was available regarding non-industrial sources
of the heavy metals in the influent to the 103 POTW. Generally, data
were not available on the water supplies in the community. It is con-
ceivable that metals in the raw water could account for much of the
79
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metals in the influent to some of the POTW. Seven of the 103 reporting
POTW indicated little or no industrial flow, and data from these plants
on six of the metals (excluding mercury) indicated ranges of values that
encompass the median values from the total population of 103 POTW. In
other words, the POTW without industrial discharges produced median
values comparable to the median values for all of the plants, many of
which had significant industrial waste contributors. While industrial
contributions are undoubtedly significant in many cases, it is possible
that some POTW receive heavy metals from largely uncontrollable sources.

INTERFERENCE/INHIBITION OF TREATMENT PROCESSES
The threshold concentrations of the common metals that upset biological
treatment processes have been investigated by many researchers (4, 14).
Under given conditions, measurable activity will begin to slow down, or
be inhibited, at a given threshold concentration, and at a higher level,
the microorganisms will be killed. The threshold concentration depends
upon the biomass concentration and cell age, and such environmental
factors as pH, temperature, water chemistry, and the presence of other
heavy metals. Another important consideration is the degree of variation
in the concentration of the metal. Most POTW operators are familiar
with the problems created by higher than normal metals concentrations
received as shock loads.

Table 2 presents some threshold concentration values and ranges for
activated sludge, nitrification, and anaerobic digestion processes (37).
As might be expected, the levels for nitrifying organisms are lower than
for activated sludge biota and higher for digester bacteria, in large
part perhaps because of the higher solids levels in digesters. The
sulfide concentration of the digester contents is important because this
ion can precipitate metals, thus removing them from the aqueous phase.
The ranges of values that have been reported by different investigators
reflect different environmental conditions and other variables.
80
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Table 2
Reported Threshold Concentrations - Metals

Cadmium
Chromium- IV
Chromium-Ill
Copper
Lead
Mercury
Nickel
Zinc
Arsenic
Silver
Activated Nitri-
Sludge fication
mg/1 mg/1
1.0
1 - 10 0.25
50
0.4-1.0 0.005-0.5
0.1 0.5
0.1 - 5.0
1.0-2.5 0.25
0.08 - 10 0.08 - 0.5
0.1
5.0
Anaerobic
Digestion
mg/1
180
50
50 - 500
-
1360
500
5-20
1.6
-
It is interesting to note that in more than 90 percent of the 103 POTW
cited above, the influent concentrations of all seven of the metals for
which adequate data exist are below the minimum threshold levels in
Table 2. The secondary unit microbes would normally be subjected to
levels somewhat below those in the POTW influent because of prior
removals in the primary clarifier.

REMOVAL EFFICIENCY
Reliable data on effluent metals concentrations were limited to 22 POTW
in the survey (38). This reduction in the data base reflects both an
absence of effluent data plus the additional requirement that the POTW
had to meet secondary treatment standards, i.e., 85 percent removal of
BOD and suspended solids with effluent levels of 30 mg/1 or less for
each.
The effluent concentrations were used to calculate percent
removals of the metals for each of the POTW, using average values. The
percent removals for cadmium, chromium, and nickel are shown in Figures
8, 9, and 10. The results for mercury were similar to that shown for
cadmium. Relatively poor removals were found for nickel, as indicated
81
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in Figure 10. The removal data for the seven metals are summarized in
Figure 11. The median removal of chromium, copper, lead, and zinc was
65 percent or higher with minimum removals of at least 30 percent.
Cadmium, mercury, and nickel had median removals ranging downward from
45 percent to 33 percent. Some POTW showed essentially zero removal of
these metals. The wide ranges of the average values demonstrate that
this incidental removal is not predictable for POTW in general.

Statistical analysis showed good correlation between percent suspended
solids removal and percent metal removal, except for nickel. Nickel was
reported to be predominantly in a soluble form at one POTW and, if true
at other POTW, this observation would explain the generally low removal
for this metal. Attempts to correlate metals removal with other factors,
such as pH, mixed liquor suspended solids, and BOD removal, were unsuc-
cessful. It must be recognized that many factors influence the behavior
of metals in POTW including influent concentrations, form of the metal,
water hardness, the presence or absence of complexing agents, and re-
actions between the metals themselves. It is virtually impossible to
test theories about removal mechanisms using uncontrolled empirical data
of this type.

Based on a very limited amount of data, there was an indication that
removal of metals in the primary portion of the surveyed POTW was somewhat
less than half the total removal achieved by the plant. Once again,
this indicates a relationship between metal removals and suspended
solids removals.

SLUDGE CONCENTRATIONS
Only nine POTW in the survey (38) provided meaningful data on metals
concentrations in sludges. For each of the metals, there were data from
five or fewer plants for raw sludge and only three POTW had data on
digested sludge. Based on this limited amount of data, concentration
factors (concentration of the metal in the sludge divided by the concen-
tration in the POTW influent) were calculated for both raw and digested
sludges. It was found that the concentration factors in the raw sludges
82
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ranged from 0-10 up to 100-300 for some of the metals. The digested
sludges showed a minimum concentration factor of 12, with peak values as
high as 1,000 to 3,000 for some of the metals. The higher concentrations
noted in the digested sludge again suggest that the metals are associated
with the solid phase rather than the liquid.

In order to supplement the data base on sludge, a literature review was
conducted. Data from approximately 90 POTW were collected and compiled
in order to gain a broader perspective of metals concentrations in
sludges. The results, expressed on a dry weight basis, are summarized
in Figure 12. Processed sludge involved various degrees of stabilization
depending on the particular POTW. Once again, wide ranges were observed
between minimum and maximum values. Interestingly, despite the fact
that these data represented an entirely different population of POTW,
the relative position of the median values for each of the metals
(except nickel) are the same as the relative positions for the median
influent levels discussed previously. Calculations for this set of data
showed that the median sludge concentrations for chromium, copper, lead,
and zinc were relatively proportional to the median influent levels.
This observation indicates that the removals of these metals by the POTW
are approximately equal.

REMOVAL MECHANISMS IN POTW
Heavy metals are not taken up by biological systems to any significant
degree and their removal in conventional municipal treatment systems is
"incidental" in that the processes and operations are not specifically
designed or operated to remove metals. In other words, plant operations
cannot be adjusted readily to achieve greater or lesser removal of heavy
metals. Both laboratory and full-scale field studies have indicated
that removals of metal occur largely through removal of suspended solids
and associated metals in an insoluble form (4, 15). Dissolved metals
may be partially converted to an insoluble form by reactions with municipal
wastewater, by oxidation with chlorine, or by lime treatment and/or
coagulation. It is also conceivable that ion exchange mechanisms are
responsible for some conversion of dissolved metals to a solid form.
83
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That high metals removal in POTW can be associated with very high suspended
solids removal has been demonstrated in a study of POTW (38), although
the data are not extensive or conclusive. Among a limited number of
POTW that achieved at least 85 percent removal of suspended solids and
an effluent averaging 30 mg/1 or less, there were excellent correlations
between suspended solids removal and the removal of cadmium, chromium,
copper, lead, mercury, and zinc. The correlation was not good for
nickel. Studies elsewhere have indicated that nickel is largely in a
dissolved form and is poorly removed in treatment plants that do a good
job removing the other common heavy metals (4, 15).

Data from a 45-MGD treatment plant that daily measures both total and
dissolved concentrations of influent and effluent cadmium, chromium,
copper, nickel, and zinc were reviewed and the results are summarized in
Table 3. These data show that 90 percent or more of the insoluble metal
is removed at this treatment plant. A much lesser fraction of the
influent dissolved metals are also removed and it is not clear whether
they are first converted to a solid form or removed by some other mechanism.
While these data are from only one plant, they do confirm that incidental
removal of metals in conventional municipal treatment processes is
largely a function of removal of solids.

Table 3
Total and Insoluble Metals Levels
at One Municipal Plant
Average Influent Average Effluent Average Removal
Total Insoluble Total Insoluble Total Insoluble
mg/1 % mg/1 % %__ %
Cadmium
Chromium
Copper
Nickel
Zinc

0.88
1.17
0.37
2.8
76
72
74
32
84
0.05
0.13
0.19
0.32
0.45
40
39
26
3.1
47
80
85
84
14
84
89
92
94
92
91
Based on daily analyses over a 2-month period.
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ADVANCED WASTE TREATMENT TECHNOLOGIES
Based on the limited data available, it would seem that incidental
removals could be enhanced at POTW in one or more of several ways, all
aimed primarily at conversion of dissolved metals to a solid form and
then subsequent removal of the solids. Precipitation as hydroxides,
carbonates, sulfides, or other insoluble forms is commonly practiced by
industries treating metal-bearing wastes. Coagulation of wastewaters
would probably be effective in many cases to enhance the incidental
removal of metals also.

Granular bed filtration should be effective at some POTW for removal of
metals already converted into solids. Some studies indicate that sorption
on activated carbon is effective and that the metals are part of the
organics attracted by the carbon. At this time, processes such as ion
exchange, reverse osmosis, dialysis, etc. are regarded as impractical
for treating effluents from municipal treatment plants.

The industrial waste literature on removal of the common metals from
various process-related wastewaters is extensive, but much of the data
cannot be extrapolated to municipal systems because of the much lower
concentrations, the presence of much organic material, and the variations
in concentrations. Industrial processes have been surveyed recently by
Patterson (29) and they involve largely precipitation, sedimentation,
and filtration to achieve high removal efficiencies. A recently reported,
study by Hannah, et.al., (11) concluded that "physical-chemical systems
consisting of chemical clarification, filtration, and carbon adsorption
were effective in removing most of the uncommon trace metals from waste-
water. As with the common trace metals..., removal efficiency depends
on the interacting chemical characteristics of the metal and the coagulants.
If low residuals of a particular metal are required, then the coagulant
and operating conditions must be selected to maximize removal." The
uncommon metals in this study included silver, beryllium, mercury,
antimony, selenium, and thallium.
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TOXIC ORGANICS IN THE POTW
With two exceptions, namely phenols and cyanides, there is little infor-
mation available about toxic organics in municipal wastewater and their
behavior and fate in POTW. A number of special studies have investigated
selected toxic organics in POTW influents, effluents, and receiving
waters with much of the attention focused on pesticides and a few toxics
of local industrial significance. To date, the work on pesticides and
other toxic organics generally has been in the realm of drinking water
supplies and the natural water environment. Much of the information
presented below must be regarded as conjectural without a great deal of
supporting data. It does provide a basis for understanding the nature
of the problem areas, however, as well as the complexity of the situation
faced by operators of POTW in the future.

COLLECTION SYSTEMS
It is important to remember that the presence of some toxic organics in
municipal wastewater is not a new phenomenon. They have been there for
some time and have not been identified. Normally, they are present at
very low concentrations, and have no recognized affects on collection
systems, with the exception of cyanides. Problems with high levels of
solvents, and flammable and explosive materials are not new and are
omitted here.

Hydrogen cyanide gas is readily formed by the cyanide ion in water. It
is highly soluble and extremely toxic. If a significant quantity of gas
existed in the atmosphere in a sewer, safety of maintenance personnel
could be in jeopardy. Lockett & Griffiths (20) found that sewage with
50 mg/1 as cyanide (CN), or hydrogen cyanide (HCN), produces between
0.09 to 0.14 ppm HCN in the air at 70 F in the pH range of 2.8 to 8.1.
Toxicity in air is quoted as: 0.025 ppm, slight symptoms after several
hours; 0.12 ppm, very dangerous within one hour; and 2.5 ppm, fatal.
These studies concluded that with moderate ventilation, 50 mg/1 cyanide
in sewage produces a dangerous atmosphere and 20 mg/1 cyanide should be
safe. In large sewers, in which maintenance personnel may be required
to work for several hours, the concentration of cyanide in sewage should
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not exceed 10 mg/1. The greatest hazard arises from sudden dumping of
high concentrations of cyanide wastes. The effect of pH below 7 is not
important, because most of the cyanide already exists as HCN at this
point. A pH level above 8 suppresses HCN formation, but does not prevent
it completely (10).

POTW INFLUENT LEVELS
Because of their more common occurrence and associated problems, a
reasonable amount of attention has been focused in the past on phenols
and cyanides in municipal wastewaters. Most sewer use ordinances contain
discharge limits on these compounds. They are often named specifically,
rather than included in the general caveat against toxic substances.

In the survey of 103 POTW (38), the range of average influent concen-
trations and the median values were found to be:

Phenols
Cyanide
Range
0.1 to 176
10 to 710
Median
(ug/1)
16
120
INTERFERENCE/INHIBITION OF TREATMENT PROCESSES
Phenol concentrations of both 50 mg/1 and 150 mg/1 have been reported
separately as the maximum levels that can be tolerated in biological
treatment systems (9, 21). However, concentrations much higher than
these have been reported to be biologically treatable in industrial
facilities. One municipality required an industrial discharger to
reduce the phenols in its waste from 10 to 1 mg/1 before discharge to
the sewer. In this case, it had been determined that the waste with 10
mg/1 of phenols, even when diluted 500 to 1 with city sewage, was
detrimental to the biological treatment process (13). This case indicates
that a concentration of 0.02 mg/1 was capable of upsetting that particular
activated sludge system. Slug loads of phenols of 200 mg/1 are reported
to have deactivated aerobic treatment plants by killing the biomass
(37). Denitrification of ammonia was decreased by the presence of 3
87
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mg/1 of phenol and cresol and was completely inhibited by levels of 10
mg/1 (36). Anerobic digestion processes were inhibited by 1.0 mg/1 of
dichlorophenol and by 0.4 mg/1 of pentachlorophenol (16). Activity in a
anaerobic Warburg system was decreased 50 percent by concentrations of
300 to 1000 mg/1 of phenol (14).

Wastewaters with 0.01 to 0.05 mg/1 cyanide have been reported to have no
deleterious effects on the activated sludge process. Levels of 0.3 to
5.0 mg/1 cyanide, however, have been reported to have adverse effects on
this process (15). BOD removal was decreased 50 percent by the presence
of 3.6 mg/1 sodium cyanide and 0.75 mg/1 zinc cyanide in the sewage at
one plant (23) . Concentrations of 2 mg/1 as hydrogen cyanide have been
reported to be the toxic limit for unacclimated sludge (33). Recommended
maximum cyanide limits in the influent to biological treatment systems
of 0.1 to 2.0 mg/1 have been cited in the literature.

Shock loads of cyanides to POTW can cause severe problems in biological
treatment units. A spill of a plating bath that resulted in a concentra-
tion of 8.6 mg/1 cyanide in the influent to one POTW caused complete
failure of the activated sludge unit (23). Another activated sludge
plant was upset for two days by a slug dose of 40 mg/1 (37).

Cyanide concentrations of 2 mg/1 were found to interfere with nitrification
in trickling filters and to result in a higher BOD in the effluent.
Nevertheless, up to 10 mg/1 of cyanide was destroyed in the filter. At
30 mg/1, filter operations were impaired, however.(23) Another report
stated that up to 200 mg/1 cyanide could be tolerated by a trickling
filter (37).

Nitrification is a specialized process carried out by microorganisms
that are less adaptive than those responsible for oxidizing carbonaceous
organic matter. Consequently, a pollutant may interfere with this
process and it should be evaluated separately. Nitrification was not
affected in an activated sludge plant by the presence of 3.5 mg/1 cyanide
in the wastewater (1). In another report, however, nitrification was
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reduced by 75 percent due to the presence of 0.65 mg/1 sodium cyanide
(16). Another report indicates that from 2 to 72 mg/1 of cyanide, as
hydrogen cyanide, interfered with nitrification, with the process being
completely inhibited at the higher levels (37).

Unlike some toxic materials, the effect of cyanides on anaerobic systems
seems to be approximately equivalent to that for aerobic systems.
Various reports have indicated that cyanide concentrations in the range
from 4 to 10 mg/1 cause some upset of anaerobic digestion (15, 23).

There is little general widespread information on inhibitory effects of
the other toxic organic pollutants. It is probable that all would cause
inhibition, destruction, or other upset of biological processes if
present at sufficiently high concentrations. In most cases, however,
they are at such low concentrations that the effects, if any, are
unrecognized and cannot be measured. At this time, the impact of these
compounds on POTW efficiency can only be assumed to be negligible.

EFFLUENT CONCENTRATIONS
A survey of 103 POTW (38) indicated that average effluent concentrations
for phenols and cyanides were as follows:

Range Median

Phenols 0 to 203 7
Cyanides 3 to 90 30

Relatively few studies have been carried out on effluent concentrations
for other organic priority pollutants. In addition to the complications
involved in sampling and analyzing for the low concentrations present,
there are the problems of controlling the operating parameters so that
the removal mechanisms can be evaluated. A survey of two municipal
treatment plants in Ohio (12) analyzed influent and effluent concentra-
tions of 12 priority pollutants, 9 of which were organic. This study
also evaluated sampling procedures and survey techniques. The study
concluded, among other things, that "most of the compounds show wide
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ranges between maximum and minimum concentrations found in grab samples.
True mean concentrations may be determined with reasonable accuracy only
from a large number of grab samples or preferably from long-term composite
samples."

REMOVAL MECHANISMS IN POTW
Biodegradation
Many of the organic priority pollutants can be broken down in biological
treatment processes under the proper conditions although none are as
readily degradable as the fatty acids, carbohydrates, proteins, etc.
that comprise the bulk of the BOD in municipal wastewater. Many of the
priority pollutants have been investigated, at least in laboratory
scale studies, at concentrations higher than commonly expected in municipal
wastewater and general findings relating molecular structure to ease
degradation have been developed. The straight chain aliphatic compounds
are generally more readily degradable than the aromatic compounds containing
the benzene ring structure. Microbial systems can be acclimated to
break down many benzene ring compounds without great difficulty and the
substitution of hydroxyl and alkyl groups on the ring tend to make them
somewhat easier to degrade. On the other hand, the substitution of
chlorine, nitrate, and sulfonate groups makes the ring more difficult to
break down. The substitution of chlorine atoms also make the compounds
more toxic. A variety of studies have been reported (35) and the results
on biodegradability tend to vary depending upon the environmental conditions.

An important consideration in biological removal is the concentration of
the compound. It must, of course, be low enough that it does not exert
toxic or inhibitory effects and, secondly, it must be present more or
less continuously so that acclimation can be maintained. Another aspect
of concentration is that the level of more easily degradable compounds
are generally much higher and, in effect, the priority pollutants are
"competing" with these compounds to serve as food for the microrganisms.
Since they are present in very small amounts, it is difficult to know
which may be broken down and which are ignored by the microoganisms. By
themselves, the levels of the organic priority pollutants are normally
inadequate to support a biological population in a treatment plant.
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Sorption
Since many of the organic compounds are hydrophobic, it is likely that
they tend to migrate out of the water and onto solid surfaces. Sub-
sequent removals of suspended solids will, therefore, effect removals of
these compounds. There is a wide spectrum of behavior characteristics
in this regard, however, and the results cannot be predicted with much
confidence.

Chemical Oxidation
Disinfection of POTW effluents with chlorine may either oxidize or
chlorinate some organic materials in the effluent. Oxidation may be
partial in that the compound is modified, or total in which it is con-
verted to carbon dioxide and water. It is also recognized that disin-
fection may produce chlorinated organics and, in effect, create priority
pollutants out of compounds that would otherwise not be so regarded.

Discharge to the Atmosphere
A removal mechanism that has long been recognized, but for which few
data exist, is the escape of organic materials to the atmosphere from
activated sludge aeration tanks and other free water surfaces in treatment
plants. Several of the priority pollutants are volatile in terms of
analytical procedures, and it is likely that these compounds, if present
in the POTW influent, would be air stripped before reaching the plant
effluent. The extent of this phenomena and the impact it may have on
air quality are almost totally unmeasured at this time.

ADVANCED WASTE TREATMENT PROCESSES
There are several advanced waste treatment technologies applicable to
the removal of toxic organics, the two principal ones being sorption on
activated carbon and chemical oxidation. Others that have been investigated
include steam stripping, foam fractionation, and freezing, and they may
find applications in the future that were not practical in the past.
For this presentation, membrane processes such as reverse osmosis and
dialysis, as well as distillation, will not be discussed. Such processes
seem to be more appropriate for direct reuse applications, rather than
treatment and discharge.
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Sorption on Activated Carbon
Many factors have been identified as important in describing the sorption
of organic material on activated carbon. It is not appropriate for this
discussion to include all of the factors relating to the nature of the
carbon and its surface area, particle size, pore size, etc. Instead,
the focus is on the organic materials in the water that are to be sorbed.
General information has been developed about the molecular structure of
compounds, in relation to sorbability, in terms of both polarity and
degree of ionization (41). Molecular structure, of course, is reflected
also in the solubility of the compound and materials that are less
attracted to water tend to be more attracted to activated carbon surfaces.
Concentration of the material is important in several ways including
competition for sites with other organic materials in the water and also
displacement of molecules already sorbed by compounds more favored by
the carbon. A very important consideration relating to concentration is
that the behavior of these compounds has not yet been studied to any
degree at the very low concentrations that are likely in most municipal
wastewaters. The effects of competition with other organics when the
compounds of interest are at extremely low levels, is almost totally
speculative at this time. A last, very important factor in sorption
phenomena is the pH of the solution. Usually, the lower the pH of the
solution, the greater the sorption of many materials although, again, it
depends upon the type of material being taken up.

In general, molecules are more readily sorbed than ionized compounds.
The aromatic compounds tend to be more readily sorbed than the aliphatics,
and larger molecules more readily sorbed than smaller ones, although
extremely high molecular weight materials can be too large to penetrate
the pores in the carbon. Treatment of wastes with carbon is generally
considered for organic rather than inorganic components, although metals
and other inorganics may be sorbed on carbon surfaces or on organic
solids that are removed in granular carbon filters. As pointed out by
Ford (8) and others, sorption with activated carbon cannot be regarded
as a universal panacea capable of removing all types of organics under
all conditions. The process has limitations and must be evaluated for
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particular situations. Preliminary treatment of the waste, such as pH
adjustment, coagulation, or chemical oxidation may improve the sorbability
of some of the priority pollutants.

Chemical Oxidation
The usual goal of chemical oxidation is to change, or modify, the molecule
rather than oxidize it completely to carbon dioxide and water. The
change renders the compound either more treatable or less harmful or
toxic and is less expensive than complete oxidation, but accomplishes
the same end results.

Weber (4l) includes the following factors in defining the efficiency of
chemical oxidation for destruction of organic compounds in wastewaters;
concentration of reactants, temperature, presence or absence of impurities,
pH, variations in concentrations, and environmental conditions. Other
factors include both the nature of the oxidant and the nature of the
organic materials. Weber states, "Although any attempt to classify
organic reactants with respect to oxidizability must be somewhat arbitrary,
a general trend is noticeable throughout the oxidation literature. In a
very qualitative way, the reactivity of selected organic compounds with
respect to oxidation is as follows:

0 High reactivity - phenols, aldehydes, aromatic amines
and certain sulphur compounds;
0 Medium reactivity - alcohols, alkyl-substituted aromatics,
nitro-substituted aromatics, unsaturated alkyl groups,
carbohydrates, aliphatic ketones, acids, esters and amines;
and,
0 Low reactivity - halogenated hydrocarbons, saturated aliphatic
compounds, and benzene.
By no means is this list complete nor completely unambiguous, but it may
serve as a tentative guideline for the selection of oxidation processes
for water and wastewater treatment."

CONCENTRATIONS IN RESIDUES
There are few data available by which to develop "typical" concentrations
of the organic toxic pollutants in wastewaLer sludges and other residues.
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The nature and variability of the various removal mechanisms that may,
or may not, play a role in POTW make results obtained at one plant very
questionable for application to other POTW. Individual studies of
priority pollutants suspected to be present may be necessary at individual
POTW.

RELEASE TO THE ENVIRONMENT
It is likely that the major impact of regulations to control toxic
materials discharged to the POTW will be on the release of treated
effluents, sludges, and other residues to the environment. Because of
the low concentrations for most of the priority pollutants under normal
conditions, little effect on the treatment plant operational efficiency
is likely. Regulations defining acceptable effluent qualities and
disposal of sludges and other residues, however, may force the POTW to
require extensive pretreatment of industrial waste in order not to
violate these regulations. At the present time, most of the available
data is confined to some of the heavy metals, pesticides, and very few
other organic priority pollutants.

WATER ENVIRONMENT
The obvious avenues for direct release of priority pollutants to the
water environment are pass-through at the treatment plant and bypass of
untreated wastewater (e.g., combined sewer overflows) without the benefit
of any incidental or other removals. Indirect avenues include leachate
from sanitary landfills and other disposal sites for sludge, and runoff
from land disposal and/or land treatment areas.

The allowable concentration in the receiving water, whether surface or
subsurface, will depend on the various potential beneficial uses to be
made of the water. We are all familiar with the use of water quality
criteria as a means of requiring a higher quality effluent than would
result from consideration solely of available control and treatment
technologies. EPA is currently reviewing and developing water quality
criteria for each of the 65 toxic pollutant classes for all of the
sensitive beneficial uses of waters. These criteria should be finalized
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soon and made available for review and comment. How these criteria will
be used remains an important consideration. Because these values are
not yet available in final form, and since the general concept of effluent
regulation by water quality criteria is a familar one, this topic will
not be discussed further. Various resources have been developed in the
past, including McKee & Wolfe (24) the "Green Book" (40) and the "Red
Book" (32).

LAND ENVIRONMENT
The avenues for release of toxic pollutants to the land environment
include the use of POTW effluents for irrigation purposes, the applica-
tion of sludges and other residues to the land, the disposal of sludges
in landfills and other land disposal sites, and the disposal of incin-
erator residues, concentrated brines, and RO reject into evaporation
ponds and other land disposal sites. All of these avenues include the
potential for both immediate and long-term release to the water environ-
ment, especially the ground water environment.

Irrigation Use
Limited information on quality criteria for irrigation water is available
from seven states, namely Arizona, Florida, Illinois, Missouri, North
Dakota, Ohio, and West Virginia. The majority of these states have
established concentration limits for arsenic, cadmium, hexavalent chromium,
copper, cyanides, lead, phenols, selenium, and silver. Only a few of
the states have set limits for mercury, nickel, and zinc. Table 4
summarizes the data available.

Sludge Disposal on Land
In recent years, there has been renewed interest in disposing of POTW
sludges on arable land. The presence of toxic pollutants in these
sludges, therefore, is a matter of considerable concern. This discussion
concentrates on heavy metals, since little is known about organic toxic
pollutants in POTW sludges.
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Table 4
Irrigation Water Quality Criteria
Parameter
Minimum Limit
(ug/1)
Arsenic
Cadmium
Chromium-VI
Copper
Cyanide
Lead
Mercury
Nickel
Phenols
Selenium
Silver
Zinc
10
5
50
20
10
40
0.5
1
5
1
500
Maximum Limit
(ug/1)
1,000
50
50
1,000
200
100
5
1,000
100
1,000
50
5,000
Mode No. of
(ug/1) States
50
10
50
25/200
6
5
6
4
5
50
0.5
1/10
10
50
7
3
1
5
5
4
3
Note: Each parameter is expressed as "total" unless otherwise noted.

The fate of heavy metals after application to agricultural land is
complex and depends upon many factors. Although this topic has been the
subject of much research, there are still a number of areas in which
understanding is lacking. The heavy metal concentration in soil that
will result in toxicity depends not only on how toxicity is defined, but
also upon many physical, chemical, and biological factors related to
soil or plant characteristics. However, enough experience has been
gained to show which metals have the most potential to be toxic to
plants and animals. Consequently, the concentrations of these metals in
sludges should be kept as low as practicable.

One very compelling consideration is that once metals are applied to the
soil, it is very unlikely that they can be removed and they may affect
agricultural practices long after they have been applied. Coupled with
this consideration is the lack of knowledge concerning the long-term
effects of heavy metals applied to land. In view of this, achievement
of low concentrations of heavy metals in sludge to reduce buildup in
agricultural soils is important in order to allow continued general
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agricultural use of the land involved. In general, heavy metals may be
divided into three classes; 1) those posing relatively little hazard to
plants and animals, 2) those posing a potentially serious hazard to
plants, and 3) those posing a hazard to animals and humans. Some elements
may fall into more than one category depending upon the assumptions that
are made. The Council for Agricultural Science and Technology (CAST)
(2) has made a comprehensive appraisal of potential hazards of heavy
metals to plants and animals and a summary of their findings, and those
of others, is presented below.

Metals Posing Relatively Little Hazard
Metals that are regarded as not particularly hazardous include arsenic
and selenium. Some researchers also include lead, chromium, and mercury
in this category, but others (5, 31) list one or more of these three as
potentially dangerous. They are covered below in the section on hazardous
to animals.

Arsenic. Arsenic is held strongly by clays. Even on sandy soils, high
rates, e.g., greater than 90 kg of arsenic per hectare, must occur for
toxicity to be observed. Even when arsenic is taken up by plants, it
accumulates in the roots, rather than the stems or leaves, and is not
readily passed on to animals and humans. The low levels of arsenic
usually found in sludge is a third factor contributing to lack of concern
about this element when considering land application.

Selenium. Selenium may be of concern under certain conditions in dry
regions where toxicity to livestock may occur if soils have developed on
seleniferous parent materials. While more research is needed about the
selenium content of sludges and reactions in soils, the low concen-
trations of selenium in sludge lessen concern about this element.

Metals Hazardous to Plants
Metals that are hazardous to plants include zinc, copper, and nickel (2,
5, 31, 19).
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Zinc. Zinc is taken up by plants as divalent ions and in excessive
quantities can be toxic. The most important mechanisms for zinc retention
in soils are sorption on clay and hydrous iron oxide surfaces and chelation
by organic matter. Under acid soil conditions, zinc occurs as the
divalent ion and is available to plants. In the neutral pH range, zinc
should not generally be a serious hazard to plants or to the food supply
unless exceptionally high concentrations are present in sludge.

Copper. As with zinc, toxicity may develop in plants from the application
of sewage sludge if the concentration of copper is relatively high. In
soils, copper occurs in association with hydrous oxides of manganese and
iron and also as soluble and insoluble complexes with organic matter.
Copper is considered more toxic to plants than zinc, but as with some of
the other heavy metals, a certain amount of copper is essential to the
growth of plants. Under some conditions, livestock, especially sheep,
may be susceptible to copper toxicity due to accumulations in the liver
when molybdenum intake is low.

Nickel. Whether nickel in sludge becomes toxic to plants depends on the
soil characteristics, the amount of nickel applied, and the levels of
other metals in the sludge. Unlike most other metals, nickel uptake
seems to be promoted, rather than retarded, by the presence of organic
matter. Nickel toxicity to plants has been observed in acid soils only.

Metals Hazardous to Animals
Metals regarded as significantly hazardous to animals and man include
cadmium, chromium, copper, lead, mercury, and zinc. Copper and zinc
have been discussed above. Cadmium is considered to be by far the most
critical element limiting or discouraging land application of sewage
sludge at the present time.

Cadmium. Cadmium accumulates in human kidney and liver tissue. It also
affects the spleen and has been linked to calcification of bones, heart
disease, and hypertension. Other possible effects are not yet fully
recognized. In addition, there is little understanding of its chemistry
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in the soil. A very large number of factors influence cadmium concen-
trations in plant tissues including application rates, soil pH and
temperature, crop species, nitrogen and phosphorus levels, fertilization,
and the presence or absence of other metals. Due to selective uptake by
plants and uneven accumulation in different plant parts, vegetation may
have high cadmium concentrations without showing toxicity symptoms.
Since cadmium is relatively mobile in soils and is not excluded by
plants, careful management is required to reduce cadmium concentrations
in food and feed crops.

Chromium. Most researchers, including CAST, believe that chromium
presents relatively little hazard in sludge, but some are cautious due
to the lack of knowledge concerning its health effects (2, 6). Hexavalent
chromium is toxic to plants, but it is rarely present in sludge since it
is usually reduced to the trivalent state during digestion.

Lead. While exhibiting a low degree of toxicity to plants, lead exhibits
a high degree of potential toxicity to animals. It has been shown to
damage the central nervous system. Soluble lead reacts with soils to
reduce its solubility. The lead content of most plants is higher in the
roots than in plant tops. To insure that lead does not become a problem,
the pH should be maintained above 5.5 and the growth of root crops
should be avoided, as should the application of sludges with high lead
contents.

Mercury. Mercury is hazardous in food supplies because after ingestion
it undergoes "biological magnification" in animal food chains. It can
also be harmful to plants. Once in the soil, mercury enters into reactions
with the exchange complexes of the clay and organic fractions, forming
both ionic and covalent bonds. For this reason, and that most sludges
are relatively low in mercury, concern over this metal on land is much
less than in the aquatic environment. In addition, because of the high
affinity between mercury and solid soil surfaces, mercury persists in
the upper layer of soil and is a lesser threat to groundwater.
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From the above, it may be seen that restrictions on land application of
sludge are much more dependent on concentrations of some of the metals
than others. Other variables are also important in establishing safe
heavy metals concentration in sludge applied to agricultural land to
minimize risks of toxicity. The application rate of the sludge to
cropland is very important, and this may in turn be based upon soil
properties and mechanisms, the crops that are grown, landscape features,
and other factors.

Application Rates
A number of concepts have been used to limit or define sludge applica-
tion rates. Application rates are usually devised to limit nitrogen,
phosphorus, and/or heavy metals applied to cropland. Each application
concept has advantages and drawbacks, and these are discussed here with
particular emphasis on concepts devised to limit heavy metals.

It is commonly believed that for short application periods, nitrogen
content is probably the most important characteristic controlling the
amount of sludge that can be applied to land. Concentrations of nitrogen
in sludge that are in excess of crop needs will result in the release of
nitrates to surface drainage or groundwaters (18). The moisture content
of the sludge has an important bearing on nitrogen-based application
rates. The advantage of using a nitrogen basis to develop application
rates is that the nutrient needs of the crops are satisfied. The dis--
advantage is the possibility of metals accumulating to toxic levels in
the soil when applications are made continually to the same tract of
land over a period of time.

Plant nutrients are used more efficiently when sludges are applied to
meet the phosphorus needs of the crop instead of the nitrogen needs,
because, relative to nitrogen, this element is present in excess. Heavy
metals additions are also reduced. The disadvantages are the higher
costs for application since supplemental nitrogenous fertilizer will be
required for non-leguminous crops, i.e, those that cannot fix atmospheric
nitrogen through root nodule bacteria.
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Application rates based on heavy metals in the sludge have been developed
largely due to considerations such as those expressed by Chaney (5). He
states that "even though we can manage land application sites to control
short- and long-term hazards from nitrogen, organic matter, and pathogens,
the toxic heavy metals will accumulate and/or persist, thus becoming the
long-term hazard to the environment." Attempts to limit the metal
levels, particularly cadmium, copper, nickel, and zinc, that can be
applied safely to cropland has resulted in a number of methods or concepts
in use or proposed, and six of the more common are discussed here. The
zinc-equivalent concept presumes that toxicities of copper and nickel
can be expressed in terms of some multiple of zinc and that the toxicities
to plants of these three elements are additive. This concept has been
widely discussed, but recently doubts have been raised as to the validity
of the premise that the effects of these elements are additive. In
addition, it has been suggested that the equation does not apply uniformly
over a broad spectrum of plant species and that it underestimates the
amounts of sludge-borne metals that can be safely applied to neutral
soils (2).

Another widely discussed concept is the zinc to cadmium ratio, based
upon two premises. The first is that cadmium is not lost as fast as is
zinc in soils. The second premise is that regulation based on the ratio
of zinc to cadmium would result in high enough zinc concentrations in
the soil to kill plants before cadmium could accumulate in foods to
levels considered hazardous to animals and humans. This premise has
been questioned since many plants grown in neutral to alkaline calcareous
soils tolerate high levels of zinc in the soil and still show an increase
in the concentration of cadmium. Also, at a given ratio of zinc to
cadmium, the concentration of cadmium in plants increases with increasing
cadmium applications. Particularly in soils with pH above 6.5 it seems
advisable to use a criterion other than the zinc to cadmium ratio for
limiting sludge applications to soil.(2)

Two related concepts are very straightforward and are particularly
attractive to limiting cadmium. One is an annual rate of application
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(Ib metal/acre-yr) and the other is a total or "lifetime" application
(total cumulative Ib metal/acre). Total limits for addition of individual
heavy metals have been proposed by various researchers, but additional
information is needed to develop more confidence in proposed application
rates (2). The same holds true for the general concept of limiting
maximum concentrations of metals (mg/kg dry weight basis) that can be
applied to croplands.

The Province of Ontario has developed application rates based on both
ratios of ammonia-nitrogen to metal and maximum metal addition to soil.
The reasoning is that sewage sludge application rates should be based on
plant-available nitrogen content and that acceptable metal concentrations
should be related to nitrogen. In addition, health and agricultural
considerations necessitate setting of values for maximum metal addition
to soil.(31)

Soil Properties
The concepts that are discussed above are helpful, to some extent, in
limiting heavy metals buildup in the soil, but, as has been noted, a
number of complications result from simplistic approaches. The
complications include the fact that metals may not be equally available
in sludge from different sources. Also, marked interactions between
copper, nickel, and zinc, and between these metals and soil constituents
may influence their availability in different soils.(17) Some application
rate concepts have attempted to incorporate soil properties or other
factors into their structures, making the concept more accurate at the
expense of simplicity and utility.

The effects of soil properties cover many disciplines, and only major
considerations in their applicability to heavy metals in sludge applied
to agricultural land are discussed here. Soil pH is of primary concern
in the application of sludge to the land. With the exception of molybdenum,
most heavy metals are more soluble at lower pH than under neutral to
alkaline conditions and, thus, it is important to maintain soil pH at or
above 6.5. Since sludge may lead to a lowering of soil pH, monitoring
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may be required (5). Cation exchange capacity (CEC) is also an important
soil property. CEC is a measure of a soil's ability to hold and immobilize
heavy metals, and can give insight into the content of organic matter
and the nature and content of clay and sesquioxides in the soil. Cation
exchange capacities are given in milliequivalents per 100 grams of soil.
Application rates, especially those of the total cumulative type, are
often based upon the CEC of a soil.

Texture of the soil, somewhat reflected by the CEC values, is probably
the most important physical characteristic of soils because it affects
many other soil properties. Sandy soils and organic soils are probably
the least desirable for application of sludges containing heavy metals.
Since sandy soils have low phosphate retention capacity, low CEC, and
low buffering capacity, leaching of nitrates, phosphates, and soluble
heavy metals is a major hazard. Organic soils, on the other hand, while
having high cation exchange capacities, also frequently have high water
tables, high nitrification rates, and low pH values. The most desirable
soils for sludge application are loams and sandy loans (2, 17, 27). The
important role of soil organic matter in retaining metals is due to its
high CEC and chelating ability (27), although Chaney (5) notes that
chelation appears to be the more important of the two. One important
concern about sludge application to land is that as the organic matter
added with the wastes gradually decomposes, its protective effect is
lost. A related factor is "reversion," here used to describe the
immobilization of metals in soils. This process may continue slowly for
months or years. It is attributed to solid state diffusion of metals
into crystalline materials, including clays, and may be important in
diminishing phytotoxic effects following over-application of metal-
bearing sludges.

A number of other considerations apply to sludge application, whether
heavy metals are present or not, but heavy metals may make neglect of
these factors even more troublesome. Site selection for sludge application
to land should avoid landscape features such as shallow soils, high
groundwater tables, pronounced seepage, steep slopes, and proximity to
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water as well as soils with susceptibility to erosion, very high or low
permeabilities, and poor drainage or aeration.

Crop Behavior
As has been discussed, retention mechanisms for metals in soils are
numerous, complex, interrelated, and poorly understood. However, in
addition to availability in the soil, two other factors governing entry
of an element into the above ground portion of plants are uptake by
roots and translocation. Thus, crop selection can also play an important
role in determining acceptable heavy metals concentrations in sludge
over the short-term.

Different crops require different amounts of nutrients, and some are
more susceptible to toxic effects than others. Not only is there
variability in metal uptake by various types of plants and by the various
tissues of a particular plant, but there is also variability of resistance
to heavy metals among various plant species. Root depth may be important.
Orchards and vineyards have been known to flourish on toxic soils because
their roots avoided the contaminated zone (5). In addition, because of
interactions among metals in the soil, elemental deficiencies in some
plants may be induced by sludge applications. The plants themselves may
cause reactions leading to heavy metal availability. For example, some
crops, such as alfalfa, naturally make a soil acidic.

A number of approaches have been suggested to take advantage of crop
variabilities. In many crops, the seeds contain lower concentrations of
most heavy metals than do the vegetative tissues, and grain crops present
a lesser heavy metal hazard to the food supply than do forages, pastures,
and leafy vegetables. It has been suggested that little or no hazard to
the food supply from heavy metals applied in sewage sludge would be
presented by crops that are processed to supply refined substances, such
as sugar and distilled alcohol (2). Sewage sludge could be applied only
to non-agricultural land or to land used only for production of crops
that are grown for their non-edible products. Reclamation of strip mine
spoils and other low quality land, as well as application of sludge to
forest sites, are examples of this alternative.
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Other Criteria
As previously mentioned, sludge can be applied as a liquid directly from
the stabilization process, as a dewatered sludge, or as a dried material.
A dewatered, composted sludge may contain less than half the nitrogen
content of the liquid sludge. If nitrogen is the basis for application,
larger amounts of heavy metals will be applied to the land using a
dewatered, composted sludge, depending on the nutrient requirements of
the crop.

AIR ENVIRONMENT
Avenues for release of priority pollutants to the atmosphere include air
stripping and volatilization in activated sludge and other POTW treatment
processes, sludge incineration which may volatilize mercury and other
heavy metals and partially oxidize organic chemicals, irrigation practices
allowing the escape of aerosols, and air pollution associated with
sludge disposal facilities. In regard to this last area, it was reported
by Markle, et.al., that background air concentrations of 0.1 to 0.3 ppm
vinyl chloride monomer were detected at a landfill site receiving sludge
from a wastewater plant treating wastes from a polyvinyl chlorine manu-
facturing facility (22).

The release of toxic pollutants to the atmosphere through wastewater
treatment and disposal practices has not been investigated extensively.
Wastewater sludges contain metals that could be toxic if discharged into
the atmosphere at excessive levels from sludge incinerators (30).
Mercury is the primary concern because the temperatures employed are
normally high enough to decompose mercury compounds to mercuric oxide or
metallic mercury. Although there are few data on the metals being
discharged to the atmosphere from municipal sludge incinerators, it is
known that the forms in which metals are found in sludge affect their
behavior during incineration. With the exception of mercury, it is
believed that most metals are present primarily in the particulate
matter removed by air pollution control devices and in the incinerator
residues (27). The possibility that zinc, lead, and cadmium may also be
discharged to the air does exist because of the volatilization temperatures
of some of their compounds (28).
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EPA is attempting to establish limits on emissions from sludge incinerators.
It has been stated that such emissions must not violate ambient air
quality standards and must meet air pollution emission standards contained
in the new source performance standards for sludge incinerators (26).
It has also been stated that sludges with high mercury content may not
be suitable for incineration (7) since the temperatures employed are
known to vaporize mercury and other metals. As a result, EPA has published
amendments to the national emissions standards that limit mercury emissions
from the drying and incineration of wastewater treatment plant sludges
(26).'

SLUDGE DISPOSAL LEGISLATION AND REGULATIONS
The previous discussion on land spreading and agricultural uses of
wastewater treatment plant sludges and other residues today applies to
only a relatively small number of POTW. Not surprisingly, therefore,
few legal restrictions have been placed by state or federal agencies on
the concentrations of toxic substances in sludges. Recommendations and
guidelines dealing with heavy metal aspects of sludge disposal have been
developed by some agencies, study groups, and researchers, but numerical
limits for the various metals are not contained in most regulations (3,
25, 38).

Concerns for toxic substances in municipal sludges will undoubtedly
increase as new regulations regarding sludge disposal are promulgated.
EPA is currently considering criteria for defining hazardous wastes
under the Resource Conservation and Recovery Act of 1976, and they
recognize that there are many factors that must be considered. It seems
likely, however, that some POTW sludges will be classified as hazardous
wastes. Whether they will be regulated under RCRA or Section 405 of the
Clean Water Act, or both, is not certain at this time. A brief review
of these two pieces of legislation relating to sludge disposal is presented
below.
106
-------
RESOURCE CONSERVATION AND RECOVERY ACT
The Resource Conservation and Recovery Act of 1976 has some far reaching
implications for the disposal of sludges from wastewater treatment
systems. In its entirety, RCRA is directed at controlling the disposal
of all solid wastes, including sludges, that may constitute a hazard to
the environment.

Subtitle C, Hazardous Waste Management, is of particular importance to
the owners and operators of wastewater treatment systems. The first
five sections of this subtitle, given below, are of special significance.

Sec. 3001. Identification and Listing of Hazardous Waste
Sec. 3002. Standards Applicable to Generators of Hazardous
Waste
Sec. 3003. Standards Applicable to Transporters of Hazardous
Waste
Sec. 3004. Standards Applicable to Owners and Operators of
Hazardous Waste Treatment, Storage, and Disposal
Facilities
Sec. 3005. Permits for Treatment, Storage, or Disposal of
Hazardous Waste

Hazardous waste guidelines and regulations will eventually be published
as 40 CFR 250 and draft regulations for Section 3001 are now being
circulated by EPA for comment. Under the draft criteria, a solid waste
will be deemed hazardous if it is ignitable, corrosive, infectious,
reactive, radioactive, or toxic.

The regulation further defines a toxic waste as one that produces an
elutriate, by specified procedures, which has any of the following
characteristics:

0 Gives a positive response to one of several required
tests for mutagenic activity.
0 Gives a positive result in the Bioaccumulation Potential
Test.
0 Contains more than specified concentrations of any compound
on a "special chemical list."
0 Has a concentration greater than or equal to ten times
the EPA primary drinking water standards for a particular
substance.
107
-------
0 Contains any organic substance above a calculated threshold
concentration related to human toxicity.
0 Has a concentration of any aquatic toxicant greater than
that specified in the regulations.
0 Has a concentration of any phytotoxic substance greater
than that specified in the regulations.

Several important lists of chemicals and industrial sludges are contained
in the draft regulation. The "special chemicals list" contains about 44
substances that are known to be mutagens, but register as false positive
on the mutagenic tests. The phytotoxicity list presently contains seven
organic pesticides. The third list identifies sludges and solid waste
that are considered hazardous from specific industries. It is not clear
how this list will impact a POTW receiving wastewaters and/or sludges
from one of the specified industries.

It appears likely that sludges from POTW could well be determined hazardous
under Section 3001, particularly in systems receiving substantial quantities
of industrial wastewaters. In that event, the POTW operations would be
subject to Section 3002 as generators of hazardous waste, Section 3003
if the sludges are transported, and Sections 3004 and 3005 as operators
of hazardous waste treatment, storage, and disposal facilities.

SECTION 405, CLEAN WATER ACT
Section 405 of the Clean Water Act also covers the disposal of sewage
sludge. This section requires the development of guidelines for the
disposal or utilization of sludge. These guidelines shall identify the
concentrations of pollutants that may interfere with each use or disposal.
The POTW must dispose of sludge from their facilities in accordance with
these guidelines.

Under Section 405, restrictions on POTW can be incorporated into the
NPDES permit. Thus, it is possible that a POTW would be subject to
regulation and permit procedures under both the Clean Water Act and
RCRA. EPA is currently studying this situation with the stated intent
108
-------
of developing a single permit procedure for POTW, probably under Section
405. Industrial wastewater treatment plants, however, would have to be
regulated and permitted under RCRA.

DEVELOPMENT OF FEDERAL PRETREATMENT STANDARDS

EXISTING INDUSTRIAL USERS
The national categorical pretreatment standards for existing industrial
facilities will be based upon the degree of effluent reduction that can
be obtained through the application of the "best available technology
economically achievable" (BATEA) for each industrial category. The
approach that will be used by EPA in establishing such standards will be
similar in concept to the approach that has been used in developing BPT
and BATEA effluent limitations for direct dischargers. Industrial users
of a POTW, however, will be evaluated as a separate distinct group.
Among the factors to be taken into account in establishing the pre-
treatment standards are:

0 The cost of achieving the pretreatment limits;
0 The age of the equipment and industrial facili-
ties involved;
0 The industrial processes employed;
0 The engineering aspects of the application of
various types of control techniques and
process changes;
0 Non-water quality environmental impact;
0 The economic impact, including user charges,
surcharges and industrial cost recovery.

The ability of a POTW to remove a portion of a given pollutant will only
be a consideration in determining whether that pollutant should be
regulated, i.e., whether that pollutant is compatible or incompatible.
The POTW removal capability generally will not be a factor in setting
the level of control for an incompatible pollutant.
109
-------
In some instances, the BATEA for direct and indirect dischargers may be
identical and, therefore, the pretreatment standards and direct discharge
effluent limitations may be the same for a given industrial category.
Since the indirect dischargers will be evaluated as a separate distinct
group, however, it is likely that pretreatment standards will differ
from the effluent limitations for many, if not most, of the industrial
categories.

NEW INDUSTRIAL USERS
New source pretreatment standards would be established under Section 307
(c) and will be based on the application of the best available demon-
strated control technology (BADCT). These standards will be similar in
concept to the new source performance standards for direct dischargers.
The factors to be considered in establishing pretreatment standards for
existing sources, noted above, will also be considered in developing
these new source pretreatment standards. Usually, the pretreatment
standards for new sources will be more stringent than those for existing
industries. This regulatory practice reflects the generally accepted
philosophy that new industrial plants can be designed to reduce or
eliminate objectionable discharges.

INTERIM PRETREATMENT STANDARDS
Pursuant to the Consent Decree, interim pretreatment standards have been
established for the following eight industries:

0 Electroplating
0 Inorganic Chemicals Manufacturing
0 Leather Tanning & Finishing
0 Non-ferrous Metals Manufacturing
0 Petroleum Refining
0 Steam Electric Power Plants
0 Textile Mills
0 Timber Products Processing

Virtually all of these interim pretreatment standards contain the basic
prohibitive standards protecting against pollutants that create:

0 Fire or explosion hazards
0 Corrosive environment (low pH)
0 Solid or viscous obstructions
0 Shock loads

110
-------
Prohibitions against excessive discharges of oil and grease and ammonia
nitrogen are contained in several of the interim industrial pretreatment
standards.

Categorical pretreatment standards are established for certain metals in
several industries, for cyanide in the electroplating industry, for
fluoride in one subcategory of the inorganic chemicals industry, and for
PCBs in the steam electric power category as shown in Table 5. In the
nonferrous metals, textile mills and steam electric power categories,
the new source pretreatment standards are set at the same level as the
new source performance standards for direct dischargers.

For comparison, the results of a survey of municipal sewer use ordinances
is presented in Table 6 (38). The table presents the minimum and maximum
concentration values cited in the ordinances surveyed together with the
modal value, which represents the most frequently stated limitation.
Generally the local pretreatment regulations address the prohibited
discharges, some heavy metals, cyanide, and phenols. Virtually, no
other organic substances on the list of 129 priority pollutants were
included in any of the surveyed local regulations. In view of the state
of knowledge regarding the presence of these toxic substances in waste-
waters, such a finding is not surprising. It is interesting to note
that the interim pretreatment standards for metals that have been
established are on the same order or magnitude as the modal values for
the surveyed municipalities.

SUMMARY
The control of toxic pollutants is nov the main thrust of EPA's pre-
treatment strategy. National pretreatment standards will be established
for at least 21 industrial categories with a focus on at least 129
priority pollutants. With time, p-^etreatment standards will undoubtedly
be established for additional industrial categories and other priority
pollutants.
113
-------
Table 5
Current Interim Pretreatment Standards
Substance

Oil & grease
Ammonia nitrogen
Fluoride

Arsenic
Cadmium
Chromium-VI
Chromium-T
Copper
Gold
Lead
Nickel
Zinc

PCB
Maximum
mg/1

100
100
50

4.0
0.4
0.15
3.0
1.0
2.0
5.0

0
Average
mg/1
25
0.2
0.09 (4.0-)
1.0
0.5 (5.0*)
0.5
1.0
1.0
2.5

0
"Values for timber products category.
Table 6
Survey of Local Sewer Use Ordinances
Arsenic
Cadmium
Chromium-T

Chromium-VI
Chromium-Ill
Copper

Lead
Mercury
Nickel

Selenium
Silver
Zinc

Cyanide
Cyanide(free)
Phenols
0.01
0.002
0.1

0.05
1.0
0.06

0.05
0.0005
0.1

0.01
0.03
0.2

0
0.2
0.005
Max.
mg/1

3
15
25

10
10
17.6

5
5
15

5
5
50

10
2
3,000
Mode
mg/1

0.05/1.0
0.1/2.0
5

5
10
1.0/3.0

0.1
0.005
1

0.02
0.1
2
2
0.5
Number of
Municipalities

35
58
49

29
3
66

49
30
57

24
35
64

72
7
40
112
-------
The need for controlling the discharge of these toxic pollutants to POTW
should be apparent. Many of them can interfere with or inhibit the
efficient operation of POTW or pass through it to impact the environment
adversely. Metals, for example, can inhibit biological processes or
accumulate in waste sludges preventing them from being used for agricultural
purposes. Incineration of such contaminated sludges may release these
metals to the atmosphere and leaching from landfill sites may return
them to aqueous environment. Organic toxic pollutants can have similar
impacts on POTW causing toxicity to biological processes and possible
contamination of waste sludges. Some of these compounds can be stripped
from the waste stream and discharged to the atmosphere during the waste
treatment process.

Establishing equitable pretreatment standards will be a difficult task,
particularly in the area of the organic compounds. There is little
information currently available regarding the sources, quantities,
treatibility, variability,
113
-------
References

1. Adams, C. E., "Treatment of High Strength Phenolic and
Ammonia Wastestream by Single - and Multi-Stage Activated
Sludge Processes," Proc. 29th Ind. Waste Conf., Purdue
Univ., Lafayette, Ind. (1974).

2. "Application of Sewage Sludge to Cropland: Appraisal of
Potential Hazards of the Heavy Metals to Plants and Animals,"
Council for Agricultural Science and Technology, Report
No. 64 (Nov. 1976).

3. Baldwin, D., "Sludgegate," Environmental Action, Environmental
Action Inc., Washington, DC, p 3 (June, 1976).

4. Earth, E. F-, Ettinger, M. B., Salotto, B. V., and McDermott,
G. N., "Summary Report on the Effects of Heavy Metals on
the Biological Treatment Processes," Jour. Water Poll.
Control Fed., 37, 86 (1965).

5. Chaney, R. L. , "Crop and Food Chain Effects of Toxic Elements
in Sludge and Effluents," Recycling Municipal Sludges and
Effluents on Land, Information Transfers Inc., Rockville,
MD (1973).

6. Committee of Biological Effects of Atmospheric Pollutants,
Division of Medical Sciences, National Research Council,
"Medical and Biologic Effects of Environmental Pollutants:
Chromium," National Academy of Sciences (1974).

7. Farrell, J. B., "Overview of Sludge Handling and Disposal,"
Municipal Sludge Management, Information Transfer Inc.,
Rockville, MD (1974).

8. Ford, D. L., "Putting Activated Carbon in Perspective to
1983 Guidelines," Ind. Water Engrg., p. 20 (May/June 1977).

9. Fox, R. D., and Himmelstein, K. J., "Recovery or Destruction -
New Developments for Industrial Wastes," Proc. 29th Ind.
Waste Conf., Purdue Univ., Lafayette, Ind (1974).

10. Gurnham, C. F., Principals of Industrial Waste Treatment,
Joh Wiley & Sons, New York (1955).

11. Hannah, S. A., et. al., "Removal of Uncommon Trace Metals by
Physical and Chemical Treatment Processes," Jour. Water
Poll. Control Fed., 49, 2297 (Nov. 1977).

12. Hannah, S. A., et. al., "Survey of Two Municipal Wastewater
Treatment Plants for Toxic Substances," Wastewater Research
Div., MERL, EPA, Cincinnati, Ohio (1977).
114
-------
13. Henshaw, T. B., "Adsorption/Filtration Plant Cuts Phenols
from Effluent," Chem. Engrg., (May 31, 1971).

14. Hovious, J. C., et. al., "Identification and Control of
Petrochemical Pollutants Inhibitory to Anaerobic Processes,"
U.S. EPA Technology Series EPA-R2-73-194 (Apr. 1973).

15. Interaction of Heavy Metals and Biological Sewage Treatment
Processes, U.S. Dept. HEW, Environmental Health Series,
Water Supply and Pollution Control, Publ. No. 999-WP-22
(1965).

16. Jackson, S., and Brown, V. M., "Effects of Toxic Wastes on
Treatment Processes and Watercourses," Water Poll. Control,
69, England (1970).

17. Keeney, D. R., Lee. K. W., Walsh, L. M., "Guidelines for the
Application of Wastewater Sludge to Agricultural Land in
Wisconsin," Techncial Bulletin No. 88, Department of
Natural Resources, Madison, WI (1975).

18. Larson, W. E., Clapp, C. E., and Dowdy, R. H., "Research
Efforts and Needs in Using Sewage Wastes on Land," Proceedings
of the 28th Annual Meeting of the Soil Conservation Society
of America, p 142 (1973).

19. Larson, W. E., "Cities Waste May Be Soils' Treasure," Crop and
Soils, American Society of Agronomy, Inc., Madison, WI,
p 9 (Dec 1974).

20. Lockett, W. T., and Griffiths, J., "Cyanides in Trade
Effluents and Their Effects on the Bacterial Purification
of Sewage," Jour. Inst. Sew. Purif., Part II, p 121 (1947).

21. McKinney, R. E., "Biological Treatment Systems for Refinery
Wastes," Jour. Water Poll. Control Fed., 39, 3 (Mar. 1967).

22. Markle, R. A., et. al., "A Preliminary Examination of Vinyl
Chloride Emissions from Polymerization Sludges During
Handling and Land Disposal." Residual Management by Land
Disposal, Proc. Hazardous Waste Research Symp., U.S.
Environmental Protection Agency Report EPA-600/9-76-015,
186 (1976).

23. Masselli, J. W., et. al., "The Effects of Industrial Wastes
on Sewage Treatment," New England Interstate Water Pollution
Control Commission (1965).

24. McKee, J. E., and Wolfe, H. W., Water Quality Criteria, 2nd Ed.,
Publ. No. 3-A, The Resources Agency of California, State
Water Quality Control Board (1963).
115
-------
25. Morris, C. E. and Jewell, W. J., "Regulations and Guidelines
for Land Application of Wastes - A 50 State Overview" Paper
presented at 8th Annual Cornell University Agricultural
Waste Manage lent Conf. (Apr. 1976).

26. "Municipal Sluc'je Management-Environmental Factors," Federal
Register, Vol, 41, No. 108, p 22532 (June 3, 1976).

27. "Ohio Guide for Land Application of Sewage Sludge," Research
Bulletin 1079, Ohio Agricultural Research and Development
Center, Wooster, OH (May, 1976).

28. Olthof, M., "The Effect of Pretreatment Requirements on
Industrial Waste Discharges, Grand Rapids Area," Lancy
Laboratories, Zelienople, PA (October, 1975).

29. Patterson, J. W., Wastewater Treatment Technology, Ann Arbor
Science Publishers, Inc., Ann Arbor, Michigan (1975).

30. Process Design Manual for Sludge Treatment and Disposal,
U.S. Environmental Protection Agency Technology Transfer,
EPA 625/1-74-006 (1974).

31. "Provisional Guidelines for Sewage Sludge Utilization on
Agricultural Land," Joing Ministerial Committees of Ontario
Ministry of Agriculture and Food, Ontario Ministry of the
Environment, Ontario Ministry of Health (Apr. 1975).

32. Quality Criteria for Water, U.S. Env. Protection Agency,
Wa shTngton," ~D 7cT~( 1976).

33. Raef, S. F., et. al., "Fate of Cyanide and Related Compounds
in Industrial Waste Treatment," Proc. 29th Ind. Waste
Conf., Purdue Univ., Lafayette, Ind. (1974).

35. Ryckman, D. W., et. al., "Behavior of Organic Chemicals
in the Aquatic Environment - A Literature Critique,"
Manufacturing Chemisto Assn., Washington, D.C. (1966).

36. Stafford, D. A., "The Effects of Phenols and Heterocyclic
Bases on Nitrification in Activated Sludges," Jour. Appl.
Bact., 37, 75, Great Britian (1974).

37. "State and Local Pretreatment Programs," Vol. I, Federal
Guidelines (Draft), U. S. EPA, Office of Water Programs
Operations, Washington, D.C. (Aug. 1975).

38. Study of Selected Pollutant Parameters in POTW (Draft),
Prepared for U.S. EPA by Sverdrup & Parcel and Assoc.,
Inc. (Feb. 1977).
116
-------
39. Walker, W. R., and Cox, W. E., "Legal Aspects of Land
Application of Wastewater Residuals," Williamsburg
Conference on Mangement of Wastewater Residuals,"
Sponsored by Hampton Roads Sanitation District, NSF-RANN,
and Colorado State University. Williamsburg, VA (Nov. 1975).

40. Water Quality Criteria, Report of the National Technical
Advisory Committee to the Secretary of the Interior, FWPCA,
Washington, D.C. (1968).

41. Weber, W. J., Physicochemical Processes for Water Quality Control,
Wiley-Interscience, New York (1972).
117
-------
APPENDIX A

PRIORITY POLLUTANTS
1. acenaphthene
2. acrolein
3. acrylonitrile
4. benzene
5. benzidine
6. carbon tetrachloride (tetrachloromethane)
7. chlorobenzene
8. 1,2,4-trichlorobenzene
9. hexachlorobenzene
10. 1,2-dichloroethane
11. 1,1,1-trichloroethane
12. hexachloroethane
13. 1,1-dichloroethane
14. 1,1,2-trichloroethane
15. 1,1,2,2-tetrachloroethane
16. chloroethane
17. bis(chloromethyl) ether
18. bis(2-chloroethyl) ether
19. 2-chloroethyl vinyl ether (mixed)
20. 2-chloronaphthalene
21. 2,4,6-trichlorophenol
22. parachlorometacresol
23. chloroform (trichloromethane)
24. 2-chlorophenol
25. 1,2-dichlorobenzene
26. 1,3-dichlorobenzene
27. 1,4-dichlorobenzene
28. 3,3'-dichlorobenzidine
29. 1,1-dichloroethylene
30. 1,2-trans-dichloroethylene
31. 2,4-dichlorophenol
32. 1,2-dichloropropane
33. 1,3-dichloropropylene
34. 2,4-dimethylphenol
35. 2 ,4-dinitrotoluene
36. 2,6-dinitrotoluene
37. 1,2-diphenylhydrazine
38. ethylbenzene
39. fluoranthene
40. 4-chlorophenyl phenyl ether
41. 4-bromophenyl phenyl ether
42. bis(2-chloroisopropyl) ether
43. bis(2-chloroethoxy) methane
44. methylene chloride (dichloromethane)
45. methyl chloride (chloromethane)
118
-------
46. methyl bromide
47. bromoform (tribromomethane)
48. dichlorobromomethane
49. trichlorofluoromethane
50. dichlorodifluoromethane
51. chlorodibromomethane
52. hexachlorobutadiene
53. hexachlorocyclopentadiene
54. isophorone
55. naphthalene
56. nitrobenzene
57. 2-nitrophenol
58. 4-nitrophenol
59. 2,4-dinitrophenol
60. 4,6-dinitro-o-cresol
61. N-nitrosodimethylamine
62. N-nitrosodiphenylamine
63. N-nitrosodi-n-propylamine
64. pentachlorophenol
65. phenol (4APP method)
66. bis(2-ethylhexyl) phthalate
67. butyl benzyl phthalate
68. di-n-butyl phthalate
69. di-n-octyl phthalate
70. diethyl phthalate
71. dimethyl phthalate
72. benzo(a)anthracene (1,2 benzanthracene)
73. benzo(a)pyrene (3,4-benzopyrene)
74. 3,4-benzofluoranthene
75. benzo(k)fluoranthane (11,12-benzofluoranthene)
76. chrysene
77. acenaphthylene
78. anthracene
79. benzo(ghi)perylene (1,12-benzoperylene)
80. fluorene
81. phenanthrene
82. dibenzo (a,h) anthracene
83. indeno (1,2,3-cd) pyrene
84. pyrene
85. tetrachloroethylene
86. toluene
87. trichloroethylene
88. vinyl chloride (chloroethylene)
89. aldrin
90. dieldrin
91. chlordane (tech. mixture & metabolites)
92. 4,4' - DDT
93. 4,4' - DDE (p,p' DDX)
94. 4,4' - ODD (p,p'-TDE)
95. alpha-endosulfan
119
-------
96. beta-endosulfan
97. endosulfan sulfate
98. endrin
99. endrin aldehyde
100. heptachlor
101. heptachlor epoxide
102. alpha-BHC
103. beta-BHC
104. gamma-BHC (lindane)
105. delta-BHC
106. PCB-1242 (Aroclor 1242)
107. PCB-1254 (Aroclor 1254)
108. PCB-1221 (Aroclor 1221)
109. PCB-1232 (Aroclor 1232)
110. PCB-1248 (Arcolor 1248)
111. PCB-1260 (Aroclor 1260)
112. PCB-1016 (Aroclor 1016)
113. Toxaphene
114. Antimony (Total)
115. Arsenic (Total)
116. Asbestos (Fibrous)
117. Beryllium (Total)
118. Cadmium (Total)
119. Chromium (Total)
120. Copper (Total)
121. Cyanide (Total)
122. Lead (Total)
123. Mercury (Total)
124. Nickel (Total)
125. Selenium (Total)
126. Silver (Total)
127. Thallium (Total)
128. Zinc (Total)
129. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
120
-------
APPENDIX B
Figures 1-12
121
-------
H
HC-CI
H

Methyl Chloride
H
CI-C-CI
I
Cl

Chloroform
Cl
I
CI-C-CI
I
Cl
Carbon
Tetrachloride
Cl
H I
HC-C-CI
H I
Cl

Trichloro-
ethane
H H
HC = C-CI
Vinyl Chloride
H
HC=C-C=N

Acrylonitrile
Figure 1. Examples of Aliphatic Priority
Pollutants
123
-------
MONONUCLEAR-23
Benzene
Cl

Pentachlorophenol
SIMPLE POLYNUCLEAR-16
^v^
oTo
Naphthalene
Benzofluoranthene
OTHERS-20
O
Cxo

C/O^CH3
Benzidine
O

Dimethyl Phthalate
Figure 2. Examples of Aromatic Priority
Pollutants
124
-------
DDT
Cl
Cl

Lindane
Figure 3. Examples of Pesticides
on List of Priority Pollutants
125
-------

3
Z 100
O
5
tc.
LN30NOO
•o
O
z
UJ
D
Z
2 10
O
1
FIGURE 4
TOTAL CADMIUM
INFLUENT DISTRIBUTION

i
i

•

MMI
1

1
•
••»—

•1
•
_l 1

MMH

««•••

l»*
»

•

1
10
20
30
40 50
60
70
80
90
95 97
PERCENT OF POTW WITH CONCENTRATION
LESS THAN INDICATED
126
-------

3
z 1,000
g
cc
L..
CONCENl
ft.
O
z
UJ
3
UL
Z
^ 100
O
10
FIGURE 5
TOTAL CHROMIUM
INFLUENT DISTRIBUTION
-
•
;
•

•

J- • ••

»« '

i
i

•
X
1.

«
— ••»
••

^
1

4
•M^
»

•
tf

••'
••*
;

•
•
•*

1
10
20
30 40 50 60
70
80
90
95 97
PERCENT OF POTW WITH CONCENTRATION
LESS THAN INDICATED
127
-------

^ 1,000
g
t—
DC
l_
CONCENl
4
Z
1—
z
HI
D
LJL
Z
_J
< 100
o
10
FIGURE 6
TOTAL NICKEL
INFLUENT DISTRIBUTION

i
I

•
i

•M
1

•••
1

.'
I
1

•
*
• .

•

i
3 5 10 20 30 40 50 60 70 80 90 95 9
PERCENT OF POTW WITH CONCENTRATION
LESS THAN INDICATED
128
-------
10,000
1,000
(14,000'
POTW INFLUENT METALS CONCENTRATIONS

FIGURE 7
O)
D

Z100
cc

z
LU
o
z
o
o
z
Ul
10
0.1
70% RANGE

MEDIAN
Cd
Cr Cu
Pb Hg Ni Zn
129
-------
IU\J
90
80
70
-1 6°
<
O
s
lil 50
CC
T3
O
^ 40
30
20
10
n
FIGURE 8
TOTAL CADMIUM
REMOVAL EFFICIENCY DISTRIBUTION

•

.
•

•*

•
•

•'

•

'•

•

10
20 30 40 50 60 70
80
90
95
98 99
PERCENT OF POTW WITH REMOVAL EFFICIENCY
LESS THAN INDICATED
130
-------
IUU
90
80
70
60
s
o
UJ 50
CC
k.
O
^ 40
30
20
10
n

FIGURE 9

TOTAL CHROMIUM
REMOVAL EFFICIENCY
DISTRIBUTION

•

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•
•

•

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10
20
30 40 50 60 70
80
90
95
98 99
PERCENT OF POTW WITH REMOVAL EFFICIENCY
LESS THAN INDICATED
131
-------
IVSU
90
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FIGURE 10

TOTAL NICKEL
REMOVAL EFFICIENCY DISTRIBUTION

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10
20
30 40 50 60 70
80
90
95
98 99
PERCENT OF POTW WITH REMOVAL EFFICIENCY
LESS THAN INDICATED
132
-------
90
80
70
60
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LU
CC
8*
30
20
10
0
POTW REMOVAL EFFICIENCIES FOR HEAVY METALS
: - FIGURE 11
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133
-------
100.000
METALS CONCENTRATIONS IN PROCESSED SLUDGE

FIGURE 12
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134
-------
LOCAL PRETREATT€NT PROGRAM
135
-------
LOCAL PRETREATMENT PROGRAM REQUIREMENTS

Prepared For
Environmental Protection Agency

Technology Transfer
Joint Municipal/Industrial Seminar

Pretreatment of Industrial Wastes
1978
Prepared By

Jon C. Dyer, P.E.

Environmental Technology Consultants

Springfield, Virginia
136
-------
TABLE OF CONTENTS
Chapter Page

INTRODUCTION 138

I LOCAL PRETREATMENT REQUIREMENTS 144
1. Overview 144
2 . Definitions 146

II OBTAINING AN APPROVED LOCAL PRETREATMENT
PROGRAM 148
1. Developing a POTW Control Agency
Pretreatment Program 148
2. Pretreatment Program Submission
for Approval 151
3. Enforcement Mechanisms 152

III MODIFICATIONS OF CATEGORICAL PRETREATMENT
STANDARDS 155
1. POTW Removal Credits 155
2. Approval Procedures ,-. 158

IV VARIANCES FROM CATEGORICAL PRETREATMENT
STANDARDS FOR FUNDAMENTALLY DIFFERENT
FACTORS , 159
137
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INTRODUCTION
The U.S. Environmental Protection Agency will promulgate in
the near future revised general Pretreatment Regulations (*»0
CFR, 403). These Regulations will become effective 30 days
after promulgation and will establish the framework for appli-
cation and enforcement of techno 1ogy-based pretreatment stand-
ards (published as separate regulations) for industrial wastes
discharged into municipal wastewater treatment works.

The purpose of this publication and presentation in the U.S.
EPA Technology Transfer Joint Hunicipa 1/Industria 1 Seminar
Series on Pretreatment of Industrial Wastes is to assist muni-
cipalities in working cooperatively with their respective
industries to develop sound, equitable and self-sufficient
local pretreatment programs which will be required to meet the
general Pretreatment Regulation when promulgated. Other publi-
cations presented in this seminar series will discuss the
following areas of interest:
Toxic Pollutants and Resulting Effects
Key Considerations in Municipa 1/Industria 1 Sludge
Treatment and Disposal
Industrial Waste Surveys
User Charge Systems
Monitoring and Reporting

The general Pretreatment Regulations will implement various
sections of the Federal Water Pollution Control Act as amended
by the Clean Water Act of 1977 (Public Law 95-12). The Regu-
lation will apply to the following:
Industrial pollutants discharged into or trans-
ported and introduced into pub 1ic1y-owned waste-
water treatment works.
138
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Publicly-owned wastewater treatment works (POTWs)
which receive wastewater from sources subject to
national pretreatment standards.
Any new or existing source of discharger subject
to toxic and pretreatment standards.

Figure 1 presents an overview of the pretreatment problem.
The objectives of the Pretreatment Regulations will be to:
Prevent introduction of pollutants into POTWs which
will interfere with plant operations and/or use or
disposal of municipal sludges.
Prevent introduction of pollutants into POTWs which
will pass through treatment works or be incompatible.
Improve feasibility of recycling and reclaimation
of municipal and industrial wastewaters and sludges.

Two types of National Pretreatment Standards are being develop-
ed, "prohibitive discharge" standards and "categorical" stand-
ards. A brief discussion of each follows:
1. Prohibitive discharges apply to all non-domestic dis-
charges of pollutants to POTWs whether or not the user
is subject to other standards. Pollutants include:
Materials that may create a fire or explosive
hazard.
Corrosive-type material and no discharge with
pH < 5 (unless POTW is specifically designed
for such).
Solid or viscous pollutants in amounts to ob-
struct flow or interfere with operations.
Discharges of any pollutant (including BOD and
SS) in volume or strength to cause unit pro-
cess upset and violation of POTWs permit.
139
-------
Heat discharges which will inhibit biological
activity or increase POTW influent >^0°C (10A°F).

2. Categorical discharges apply to existing and new
sources in specific industrial subcategories. Con-
sideration will be given to POTW inhibition/interfer-
ence in selecting the pollutants to be regulated, but
when the decision to regulate has been made, numeric
discharge limitations will be based on best available
treatment technologies economically achievable for
industries to remove the pollutant. All 21 industries
listed in the 1976 Consent Decree (NRDC vs. Train) are
candidates for categorical standards. Table 1 indi-
cates the 21 industries with those of immediate concern
in script type.

Federal categorical standards will normally deal only
with toxic incompatible pollutants. Table 2 lists
the 65 pollutants where attention will be focused
initially. These toxic pollutants are of the greatest
environmental concern because they:
Occur in effluents, aquatic environments and/or
drinking water.
Lead to immediate or long-term human health
hazards under certain conditions.
Have toxic effects (at high concentrations) in
human or aquatic organisms. Epidemiology studies
show some evidence of careinogenicity , mutageni-
city and/or texatogenicity.

Where these 65 toxic pollutants are found to be incompatible,
they will be regulated in categorical pretreatment standards
of any of the 21 industries that discharge them. Current esti-
mates indicate there are more than 87,000 industrial dischargers
to publicly-owned wastewater treatment works in the 21 industrial
140
-------
categories to be considered initially in the focus for Pre-
treatment Standards.

A large portion of the industries, potentially subject to the
national pretreatment standards, discharge to approximately
3,000 of the POTWs in the United States. About 1,000 of POTWs
effected are providing levels of treatment greater than second-
ary. By 1983, potentially as many as 38,000-55,000 industrial
dischargers are expected to be in compliance with the National
Pretreatment Program.

It is essentially to the success of this national effort that
there be substantial cooperation and dedication at all levels
of government involved: municipal, state, and Federal.
TABLE - 1
Initial 21 Industries of Concern
Auto and Other Laundries
Coa1 Mining
Electroplating*
Inorganic Chemicals Manufacturing*
Iron and Steel Manufacturing
Leather Tanning and Finishing*
Machinery and Mechanical Products Manufacturing
Miscellaneous Chemicals Manufacturing
Nonferrous Metals Manufacturing*
Ore Mining
Organic Chemicals Manufacturing
Paint and Ink Formulation and Printing
Paving and Roofing Materials
Petroleum Refining*
Plastic and Synthetic Materials Manufacturing
Pulp and Paperboard Mills and Converted Paper Products
Rubber Proces sing
Soap and Detergent Manufacturing
Steam Electric Power Plants*
Textile Mills*
Timber Products Processing*
* Interim standards promulgated in 1977 and 1978 pursuant to
the Consent Decree.
141
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TABLE - 2

65 Toxic Pollutants Listed in Consent Decree and

Referenced in 307(a) of The CWAof 1977
Acenapthene
Ac role i n
Acrylonitri]e
Aldrin/Dieldrin
Antimony and compounds
Arsenic and compounds
Asbestos
Benzene
Benz i d i ne
Beryllium and compounds
Cadmium and compounds
Carbon tetrach1 oride
Chlordane
Chlorinated benzenes
Chlorinated ethanes
Chloralky1 ethers
Chlorinated naphthalene
Chlorinated phenols
Chloroform
2-ch1oropheno1
Chromium and compounds
Copper and compounds
Cyanides
DOT and metabolities
D i ch1orobenzenes
Dichlorobenzidine
Dichloroethylenes
2, ^-dich1oropheno1
Dich1oropropane &
Di chloropropene
2, *»-d i methy 1 pheno 1
Dinitrotoluene
D i pheny1hyd raz i ne
Endosulfan and metabolites
Endrtn and metabolites
Ethyl benzene
Fluoranthene
Ha 1oethe rs
Ha 1omethanes
Heptachlor and metabolites
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachlorocyclohexane
Isophorone
Lead and compounds
Mercury and compounds
Naphtha 1ene
Nickel and compounds
N i t robenzene
N i t ropheno1s
Nitrosamines
Pentachloropheno1
Phenol
Phthalate esters
Polychlorinated biphenyls (PCBs)
Polynuclear aromatic
hydroca rbons
Selenium and compounds
Silver and compounds
2,3,7,8,-Tetrachlorodibenzo-
p-d ioxi n (TCDD)
Tetrachloroethylene
Thallium and compounds
To 1uene
Toxaphene
Trichloroethylene
Vinyl chloride
Zinc and compounds
142
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143
-------
CHAPTER 1
LOCAL PRETREATMENT REQUIREMENTS
Ove rv i ew
The general Pretreatment Regulations are being developed
with the intent to assist local government in developing
pretreatment programs which are fair, equitable, cost-
effective, and successful in preventing interference
by industrial dischargers and in reducing industrial
pollutant discharges through publicly-owned wastewater
treatment works and into the environment. Development of
approved local pretreatment programs will result in better
coordination among municipal and industrial water pollu-
tion control programs and provide a consistent and equit-
able nationwide approach toward industrial users of POTWs.

The Pretreatment Regulations will apply to municipalities
whether or not the POTW is federally funded. All local
authorities operating public1y-owned wastewater treatment
works with total flows in excess of 5MGD and which receive
industrial wastes subject to the national pretreatment
standards will be required to establish pretreatment pro-
grams. The establishment and enforcement of the local
pretreatment program will be a condition of the NPDES
permit. Also, where needed, establishment of a pretreat-
ment program will be a condition of any new construction
grant.

Publicly-owned treatment works less than 5MGD will be re-
quired to develop pretreatment programs where special
problems warrant and/or in order to modify national stand-
ards to account for POTW removal of specific pollutants.
144
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The Clean Water Act provides for modification of national
pretreatment standards to compensate for removal attained
by POTWs. Where a local pretreatment program is approved,
the municipality can request authority to modify national
pretreatment standards to account for POTW removal. Modi-
fications are subject to a POTWs sludge management meeting
applicable EPA criteria for sludge disposal. This area
will be covered in more detail in Chapter III.

Local enforcement of pretreatment standards is encouraged.
EPA grants (construction grants or 208 funds) will be made
available to assist local authorities in establishing pre-
treatment programs.

The following items are essential to meeting the require-
ments for a local pretreatment program. Chapter II will
discuss obtaining an approved local pretreatment program
in detail.

A. Establish a POTW Control Agency with an appropriate
organization within the municipal structure.
B. Establish legal authority, binding upon industrial
users, for the POTW Control Agency to work within.
Examples are ordinances, statutes, contracts, permits,
etc. Authority must be granted to enable the POTW
Control Agency to enforce the pretreatment require-
ments .
C. Establish procedures and authority to require moni-
toring and reporting by industries and enter industrial
grounds for monitoring and inspection to verify com-
p 1 i ance.
D. Establish a resource program to provide funding, per-
sonnel, etc., to implement the pretreatment program.
145
-------
E. Establish procedures for public notification and
participation in the pretreatment program.

Definitions
For the purpose of this publication and, in general, EPA
publications, the following definitions are applicable:
Act - Clean Water Act of 1977-
Approval Authority - Director of a NPDES State or
EPA Adm i nIs t ra tor.
POTW Pretreatment Program - "Program" - a program
administered by a POTW control agency and approved
by Regional EPA or State Director.
Director - chief administrative officer of a State
or Interstate Water Pollution Control agency with
an approved NPDES permit program.
Indirect Discharge - discharge or introduction of
non-domestic pollutants from any source regulated
under section 307(b) or (c) of the Act, into a POTW.
Industrial User - owner or operator of an indirect
discharge source.
Interference - inhibition or disruption of a POTW,
including collection system, unit processes, opera-
tion, and/or sludge disposal or utilization.
National Pretreatment Standard - "Pretreatment Stand-
ard" - any EPA promulgated pretreatment standard in
accordance with the Act. Includes categorical and
prohibited.
New Source - any source where construction has com-
menced after publication of proposed regulations with
categorical pretreatment standards applicable to that
source, and if the standard is promulgated.
146
-------
NPDES Permit - "Permit" - a permit issued to a POTW
pursuant to the Act.
POTW - "publicly-owned treatment works" - a treatment
works, as defined in the Act, which is owned by a
state or municipality.
POTW Control Agency - person, board, body, agency or
other entity having jurisdiction over indirect dis-
charges to and discharges from a POTW.
Pice treatment - reduction of the amount of pollutants,
elimination of pollutants, or alteration of the nature
of pollutant properties prior to or in lieu of dis-
charge to a POTW.
Pretreatment Requirements - any pretreatment condi-
tions besides National Pretreatment Standards imposed
on Industrial Uses or POTW Control Agencies.
Regional Administrator - appropriate EPA Regional
Administrator.
Submission - submission by a POTW Control Agency of
a POTW Pretreatment Program, with or without an ac-
companying request for removal allowance, to the
Approval Authority.
147
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CHAPTER I I

OBTAINING AN APPROVED LOCAL PRETREATMENT PROGRAM
As discussed earlier in the publication, local municipalities
will have the responsibility of developing local pretreatment
programs, approvable by the EPA or where applicable, the NPDES
State. This chapter will discuss in more detail the following:
Developing a POTW Control Agency Pretreatment Program.
Pretreatment Program Submission for Approval.
Enforcement Mechanisms.

1. Developing a POTW Control Agency Pretreatment Program.
Municipalities required to develop a POTW Control Agency
and POTW Pretreatment Program must have an approved Pro-
gram developed within 3 years after the reissuance or
modification of the POTWs existing NPDES permit. The
Program requirements will be administered by the POTW
Control Agency to assure compliance by Industrial Users
with applicable Pretreatment Standards. The following
requirements will be essential to obtaining an approved
program:
A. Legal Authority: The POTW Control Agency must oper-
ate under legal authority which will enable it to
apply and enforce the applicable sections of the Act
((307(b)(c) and A02(b)(8)) and any regulations im-
plementing the Act. Legal authority such as statutes,
ordinances, contracts, agreements, or other written
legal authorities would be applicable. The legal
authority established must be binding upon industrial
users, enforceable under contract law or police powers
and at a minimum should allow the POTW Control Agency
to:
148
-------
(1) Deny or condition any increased or new discharges
(2) Require compliance with Pretreatment Standards.
(3) Control industrial discharges to the POTW to in-
sure comp1 i a nee.
(k) Require the development of an industrial compli-
ance schedule for installation of required tech-
nologies.
(5) Require submission of appropriate notices and
industrial se1f-monitoring reports necessary to
assess and assure compliance.
(6) Conduct, as necessary, inspections, surveillance
and monitoring procedures to independently deter-
mine compliance or non-compliance. Access to
Industrial records and entry to any Industrial
User's premises, where an effluent source or
treatment system is located, must be authorized.
(7) Independently assess or recover through judicial
action, fines, penalties and injunctive relief
for non-compliance by Industrial Users with:
(a) Pretreatment Standards.
(b) Inspections, entry or monitoring activities.
(c) Any rules, regulations or orders issued by
the POTW Control Agency.
(d) Any reporting requirements imposed by the
POTW Control Agency.
(8) Immediately and effectively halt or eliminate any
actual or threatened discharge of pollutants to
the POTW which would endanger health or welfare
and/or proper operation of the POTW.

B. Compliance Procedures: The POTW Control Agency must
develop procedures to insure compliance with the POTW
149
-------
Pretreatment Program. These procedures should at
a minimum provide for:
(l) Systematic, comprehensive surveys of collection
systems to identify and locate all appropriate
Industrial Users. This inventory shall be made
available to the Approval Authority upon request.
(2) Identification of pollutant discharges by char-
acter and volume by the Industrial Users identi-
fied by the survey .

(3) Notification of Industrial Users identified by
the survey of applicable Pretreatment Standards
and sludge management requirements.
(A) Receiving and analyzing the se1f-monitoring
reports and other notices submitted by Industrial
Users .
(5) Sampling and analyzing at random the effluents
from Industrial Users.
(6) Conducting surveillance and inspection activities
to insure compliance.
(7) Foliowing up conditions of non-compliance and
collecting additional data, samples, etc. suffi-
cient enough to provide admissible evidence for
enforcement proceedings.
(8) Initiating court actions for injunctive relief,
etc. for non-compliance.
(9) Implementing and enforcing other applicable rules,
regu1 at i ons, etc.
(10) Complying with requirements for public partici-
pation, notification, etc. Public notification,
at least once every 12 months in the largest
local daily newspaper, will be required of all
150
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industrial users who were in non-compliance or
violated prohibited standards. A summary of
enforcement actions during the same 12 month
period shall be included in the notification.

C. Adequate Resources. The POTW Control Agency must
show sufficient resources (funds and personnel) to
operate an effective program. In respect to funding
sources, user charges will be required when construc-
tion grant funds are involved. Increased costs at-
tributed to the POTW Pretreatment Program should be
passed on to Industrial Users by increasing user
charges.

The Program must insure effective implementation.
In some limited cases, funding and personnel may be
delayed if:
(1) The POTW Control Agency has adequate legal
authority and procedures to carry out the Pro-
gram requirements, and,
(2) A limited aspect of the POTW Permit Program is
not immediately implemented. In any delay case,
the POTW Control Agency must show that when
needed, the required funding and personnel will
be available.

Pretreatment Program Submission for Approval.
After a POTW Control Agency has developed a Pretreatment
Program, submission of the program description to the
Approval Authority is required. Prior to the submission
of the program description, the POTW Control Agency must
provide information and consultation with interested,as
well as affected members of the public. A copy of the
draft submission should be made available to the public
30 days prior to submission to the Approval Authority.
151
-------
In addition, a fact sheet in layman terms adequately
describing the importance of the local program and/or
request for removal credits should be made available.
The required consultation could be public meetings, work-
shops, task groups or conferences. Submission to the
Approval Authority should include a summary of public
participation efforts, major public comments received
and the manner in which any issues were resolved.

In addition to the above mentioned inclusions, the pro-
gram description should include:
A. A description of the legal authorities granted to
the POTW Control Agency and the procedures for im-
plementing the Program requirements.
B. The procedures to be used to insure compliance and
to enforce them in the event of non-compliance.
C. A brief description of the POTW Control Agency, with
organization charts. If more than one agency is
responsibile for administering the Program, identi-
fication and respective responsibilities should be
explained.
D. A description of the funding levels and personnel
(full and part-time) available to implement the Pro-
gram.
E. A copy of appropriate statutes, ordinances, regulations,
contracts, agreements, etc. relied upon by the POTW
Control Agency for administering the Program. State-
ments reflecting the approval and endorsement of
local boards responsible for supervising and/or fund-
in the POTW Program should be included.

3. Enforcement Mechanisms.
POTW Control Agencies will play the major role in insuring
and enforcing compliance by Industrial Users of Pretreat-
152
-------
ment Standards. Where approved POTW Pretreatment Pro-
grams exist, State and Federal enforcement activities
will serve in a backup capacity. As discussed earlier,
the POTW Control Agency derives its enforcement powers
through the legal authorities established in developing
the Program.

The Approval Authority may request reviews of the Indus-
trial Users se1f-monitoring reports in order to spot-
check the credibility of the POTW Control Agency in detect
ing violations. The Approval Authority will exercise its
enforcement authorities, when necessary, to correct inef-
ficiencies or insufficient enforcement at the POTW leveJ.
Actions taken against a POTW Control Agency will join the
Industrial discharger of the violating source.

The Act, besides granting enforcement mechanisms and
authority to EPA and NPDES States, also provides through
Section 505, the authority for citizens to bring civil
action against violation of pretreatment standards. It is
essential to eliminating future problems, that this con-
sideration be taken into account when developing a POTW
Pretreatment Program and subsequent public notification.

The main vehicle for enforcing POTW Pretreatment Programs
will be through the POTWs NPDES permit. Compliance
schedules for developing a pretreatment program will be
incorporated into the permit. This schedule will not
exceed 3 years. Other conditions enforceable through the
permit include:
A. Executing adequate monitoring, reporting, and inspec-
tion activities.
B. Enforcing violation of the standards.
C. Maintaiing a demonstrated percent removal of pollu-
tants where removal credits have been granted.
153
-------
D. Insuring that sludge management practices do not
violate applicable criteria.
E. Maintaining proper reporting for permit compliance.

In addition, EPA has the authority to enforce against a
POTW for pretreatment violations by its industrial users
even if there is no POTW Pretreatment Program enforceable
through the POTWs permit.

It will prove to be a good business technique for munici-
palities to :
Develop sound pretreatment programs.
Enforce the requirements.
Continue POTW operation to maintain removal credits
and applicable sludge management.
154
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CHAPTER I I I
MODIFICATION OF CATEGORICAL PRETREATMENT STANDARDS
As discussed briefly in Chapter 1, with the approval of a POTW
Control Agency's Pretreatment Program, revision of pollutant
limits in categorical pretreatment standards for existing
sources is authorized. This compensates for pollutant removals/
credits attained by the POTW. The Act provides for revisions,
on a case-by-case nature, as long as the POTW provides some
percent removal, the effluent limitation is not violated, and
sludge management is in accordance with the Act. This chapter
will discuss:
POTW Remova1 Cred i ts
Approval Procedures

1 . POTW Removal Credits.
POTW removal of a specific pollutant means reduction or
alteration of the nature of the pollutant by the POTW to
a less toxic or harmless state prior to discharge into
receiving waters. This reduction or alteration can be
accomplished by physical, chemical or biological processes
either specially designed into the POTW or incidental to
the operation of the POTW. It should be made clear that
dilution will not be considered as a removal mode. Also,
the inability of monitoring or detection equipment to
analyze diluted pollutants in influents or effluents will
not be considered as meeting removal criteria.

The following requirements must be met in order to estab-
lish removal allowances:
A. The POTW Control Agency has an approved Pretreatment
Program.
155
-------
B. The POTW provides consistant removal of each pollu-
tant that a credit is requested for.
C. POTWs with combined sewers or regular by-passes must
be in the process of correcting these conditions.
At a minimum, an approved facility plan which
includes treatment and control and an application
submitted for a Step 2 construction grant will be
required. POTW removal allowances w i11 not be
considered where efforts are not being made to cor-
rect by-passes.
D. Current and subsequent sludge management will remain
in compliance with applicable regulations, criteria,
etc .
E. Approval of removal allowances requested will not
result in the POTW violating water quality standards
applicable to the pollutant.

Supportive data and information required with the POTW
application for removal allowance should include the fol-
1ow ing:
Proposed pollutants.
Operational data on POTW influent and effluent which
demonstrates consistent removal. The data should be
representative of yearly and seasonal conditions and
quality and quantity of normal flows.
Sampling shall be in accordance with EPA procedures.
Composite samples, 3 consecutive days with a minimum
of 12 discrete samples taken evenly over 2^-hour
period.
Grab samples may be used where composite sampling is
not an appropriate technique.
156
-------
List of industrial categories and number of users
in each subcategory and pollutant identification.
Proposed alternative pretreatment limits.
Data showing concentrations in POTW sludge. Similar
sampling techniques as used for liquid stream.
Specific description of POTWs current sludge disposal
methods, including data indicating continuing com-
p1 i a nee.
Removal efficiencies and alternative pretreatment
limits should be calculated in accordance with EPA
regulations and guidelines.

The following formula is recommended in calculating the
proposed pretreatment limit for a specific pollutant:
X
where:
Y = Alternative pretreatment limit (mg/1).
X = Pollutant limit specified in the categorical
pretreatment standard (mg/1).
r = Consistent POTW removal rate (%).

EXAMPLE

Categorical pretreatment standard for pollutant Z=2mg/l.
City "A" provides secondary treatment by the activated
sludge process followed by mixed media filtration. Data
collected at the POTW documents 60% consistent removal of
pollutant Z and sludge management techniques will remain
in compliance. City "A" could apply for removal allow-
ance for pollutant Z and pass this credit to the appro-
priate industries. The proposed categorical pretreatment
limit in this case would be:
157
-------
Y -
This POTW removal credit could prove to be a substantial
savings to the applicable industries.

Approval Procedures.
The POTW Control Agency will be required to submit three
copies of the submission (program and/or removal allow-
ances) to the Approval Authority. After receipt of the
submission, the Approval Authority will examine the sub-
mission and make a preliminary determination as to its'
completeness. If the submission appears to meet the
requirements of the Regulations, then the Approval Author-
ity will:
Notify the POTW Control Agency in writing that the
submission is being reviewed.
Notify the Regional Administrator or State Director,
which ever case applies.
Issue Public Notice of request:
(l) Appropriate Government agencies and interested
citizens or groups.
(2) Public newspapers.
(3) Provide at least 30 days for written comments.

The Approval Authority will provide opportunity for public
hearings, if requested, with respect to any submission.
Public hearings will be held in the locale of interest.
After the public comment period has expired, the Approval
Authority will review the submission, comments, and any
public hearing records and either approve or disapprove
the submission. Notification of the decision will be made
to all interested parties (POTW, State, etc.)
158
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CHAPTER IV
VARIANCES FROM CATEGORICAL PRETREATMENT STANDARDS
FOR FUNDAMENTALLY DIFFERENT FACTORS
As mentioned in Chapter 1, variances from categorical pretreat-
ment standards for fundamenta'1y different factors will be
provided for in the Regulations. Any industrial user of a POTW
or other interested person may request a variance or exception
from the limits specified in a categorical standard. Variances
will be handled on a case-by-case basis and adjusted limits can
be made either more or less stringent. Variances may be ini-
tiated by EPA.

The following points will be essential for approval of a variance
from a categorical pretreatment standard:
Factors relative to the affected industrial user are
fundamentally different from the factors EPA consid-
ered.
The factors which the variance is based on existed
prior to EPA promulgation of the particular standard.
Due to the factors in question, the cost of compli-
ance wo 'd be grossly disproportionate to the cost
EPA considered.
The alternative pretreatment limits are justifieH
by the extent of the fundamental difference.
The request for variance is in accordance with the pro-
cedures in the Regulations.

The following factors may be considered as fundamentally differ-
ent :
A. Fundamental aspects of the industrial process which
significantly affect the nature or quantity of the
159 '
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process wastewater.
B. Fundamental aspects of the industrial process which
significantly affect the volume of process waste-
water and discharge.
C. Age, size, land and space consideration as related
to equipment and facilities, processes utilized and
application of control technology.
D. Adverse impact on non-water quality by control tech-
nology required to meet a categorical standard.
E. Increased energy requirements, provided less energy
consumptive control technology is not available or
a pp1 i cab 1e.
F Disproportinate compliance costs due to one or more
of the above.

Requests for variances with supporting evidence must be sub-
mitted in writing to the Approval Authority. Requests must be
submitted within ninety (90) days after EPA promulgates the
particular categorical pretreatment standards. Requests sub-
mitted after the ninety day period will not be considered.

The following information will be required as part of the var-
iance submission:
Requestor's name and address.
Requestor's interest in variance.
POTW receiving industrial waste.
Applicable categorical pretreatment standard.
List of pollutant or parameter in question.
Alternative limit proposed for each appropriate pol-
lutant or parameter.
Description of the existing industrial water pollution
control facility.

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Schematic of industrial water system; water supply,
process systems, and discharge point.
Clear statement of need for variance; include sup-
portive data, documentation and appropriate evidence
such as EPA Development Documents, economic data,
legal proceeding, etc.
Where control technology recommended will not meet
the standard, or exceed the standard, it is essential
that adequate documentation be presented.

Requests that are deficient will be screened out and held for
30 days. The requestor will be notified of the deficiency.
If correction is not made within the specified period, the
request for a variance will be denied.

The appropriate Regional Administrator will review requests
received from a requestor or State Director, as the case may
be. The Regional Administrator will make a written finding
considering all aspects and determine:
fundamentally different factors do exist or,
fundamentally different factors do not exist.

The results of the findings and the denial will be forwarded
to the requestor (and industrial user if not the same).

The Regional Administrator will forward requests for approved
variances to the EPA Administrator for review. All documenta-
tions, fundings, recommended alternative pretreatment limits,
rationale, etc. will be forwarded with the recommendation
for approval of the variance request. The Administrator may take
the following steps:
Approve or disapprove.
Specify different pretreatment limits.
Request additional information.
Revise the applicable categorical pretreatment stan-
dard for all industrial users in that category.
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REFERENCES
1. Infornrtat:lon For Proposed General Pretreatment Regulations,
(40 CFR, 403) , U.S. Environmental Protection Agency,
March, 1977-

2. Federat Guide1ines - State And Local Pretreatment Programs,
U.S. Environmental Protection Agency, January, 1977.

3- Personal discussions with EPA personnel on the develop-
ment of Pretreatment Regulations, 1978.
162
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NOTES
163
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OVERVIEW COMMENTS
PREPARED FOR
ENVIRONMENTAL PROTECTION AGENCY
TECHNOLOGY TRANSFER PROGRAM
JOINT MUNICIPAL/INDUSTRIAL SEMINAR ON
PRETREATMENT OF INDUSTRIAL WASTES
PREPARED BY
CENTEC CONSULTANTS, INC.
RESTON, VIRGINIA 22091
164
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OVERVIEW COMMENTS

PREPARED FOR

ENVIRONMENTAL PROTECTION AGENCY
TECHNOLOGY TRANSFER PROGRAM
JOINT MUNICIPAL/INDUSTRIAL SEMINAR ON

PRETREATMENT OF INDUSTRIAL WASTES
PREPARED BY
CENTEC CONSULTANTS, INC.
RESTON, VIRGINIA 22091
165
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Table of Contents
Title
FOREWORD 168

Section 1

Pollution Control Legislation

General 169

The Federal Water Pollution Control Act
(PL 92-500) 169

The NRDC Settlement Agreement 175

The Clean Water Act of 1977 (PL 95-217) 177

The Resources Conservation and Recovery Act,
1976 (PL 94-580) 181

The Toxic Substances Control Act, 1977
(PL 94-469) 182

Section 2

The Pretreatment Strategy

General 134

Basic Goals 186

Prohibited Discharges 186

Categorical Discharges 187

General 187

Removal Allowances 187

Fundamentally Different Variances 139
166
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Section 3

The Implementation Plan

Title Page

General 191

Requirements for Municipalities 191

Requirements for Industry 192

Obtaining a Variance 192

Obtaining a Removal Allowance 194

BAT Revisions 195

Monitoring and Reporting 197

Enforcement 198

Section 4

Special Interactions Between Laws

RCRA amd CWA 201

RCRA, CWA, and TOSCA 201

Section 5

Summary 203
167
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FOREWORD

The process whereby legislation passed by Congress is finally

implemented is complex, often requiring the efforts of thou-

sands of professionals. The legislation must be analyzed by

the responsible agencies, the intention of Congress must be

interpreted, and a policy and strategy must be devised to

provide guidance in preparing a practical implementation plan

that is not in conflict with other policies or legislation.

The preparation of the actual regulations requires a careful

attention to details, since the details of implementation can

affect large amounts of the nation's capital resources.

The U.S. Environmental Protection Agency (EPA) has promulgated

the National Pretreatment Regulations (40 CFR 403). These re-

gulations are the result of a laborious process of analysis

starting with the Federal Water Pollution Control Act Ammend-

ments of 1972 (PL 92-500) but modified by the Clean Water Act

of 1977 and strongly affected by the Resource Conservation and

Recovery Act of 1976.

This publication attempts to place the new Pretreatment re-

gulations in perspective with the overall legislation

and to provide industrial attendees of the seminar with

a basic understanding of the key features of the regulations.
168
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SECTION 1

POLLUTION CONTROL LEGISLATION

1.1 GENERAL

Several major pieces of legislation affect industrial and municipal

wastewater discharges and give EPA the authority to promulgate and

enforce regulations. These are:

o The Federal Water Pollution Control Actf as Amended, 1972

(PL 92-500)

o The Clean Water Act Amendments, 1977 (PL 95-217)

o The Resource Conservation and Recovery Act, 1976
(PL 94-580)

o The Toxic Substances Control Act, 1977 (PL 94-469)

In addition to this legislation, an important court decision, The

National Resources Defense Council Consent Decree has influenced

EPA's pollution control efforts.

1.2 THE FEDERAL WATER POLLUTION CONTROL ACT (PL 92-500)

PL 92-500 was a complex law, covering a wide range of regulations

relating to water pollution control. From the point of view of

the average manufacturer, however, the portions of the law relating

to the discharge of industrial wastewater to waterways or municipal

systems are of key importance.

As far as the manufacturing community is concerned, the most far-

reaching feature of PL 92-500 was the requirement that all industries
169
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discharging waste into waterways be required to install a base

level of pollution control technology by July 1, 1977. EPA was

directed to establish the amount of pollutant reduction which

could be obtained by application of the Best Practicable Control

Technology Currently Available (BPCTCA). This base level of

effluent reduction was to be met by all point sources discharging

into waterways.

PL 92-500 also required EPA to establish the level of pollution

reduction achievable from a more advanced technology, called the

Best Available Technology Economically Achievable (BATEA/BAT).

This was to be required of all point sources by 1983. In addition,

a new source standard also calling for advanced technology was

required. This standard was to be applied to any new facility con-

structed after regulations for new sources were proposed. Terms

used to describe the nature of this standard were "best available

demonstrated control technology, processes, operating methods, and

other alternatives including, where practicable, a standard permit-

ting no discharge of pollutants."

In effect, EPA was to set three levels of performance for each in-

dustrial subcategory:

• For existing plants to meet in 1977 BPT or BPCTCA.

• For existing plants to meet in 1983 BAT or BATEA.

• For new plants New Source Requirements.
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Of great importance to this seminar EPA also was directed to set

pretreatment standards for plants discharging to municipal systems.

If the application of BPTCA pollution control techniques by all

sources discharging into a watercourse was inadequate to meet the

established water quality standards for a stream, both EPA and the

state were authorized to impose even more stringent pollution con-

trol requirements. In all cases, the states were authorized to

impose requirements more stringent than the Federal guidelines.

Plants located on "water quality limited streams" were required

to install additional pollution control.

PL 92-500 directed EPA to set standards for manufacturers that

were to be met nationally--regardless of location. This was done

to simplify the administrative task of the Government and to pre-

vent the establishment of "pollution havens" in states anxious to

attract industry. In effect, all industries were told to apply a

base level of pollution control technology, regardless of the

needs of the receiving water.

The key to enforcing the requirements of PL 92-500 was the National

Pollutant Discharge Elimination System (NPDES). This provision of

the law established the activities of the programs begun by EPA

under the 1899 Refuse Act. The Permit Program also included

the issuance of permits for municipalities.

While the States retained primary responsibility for combating water

pollution, they had to comply with specific Federal directives.
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If the states could not or did not choose to establish programs meet-

ing the Federal requirements, the Federal Government assumed the

responsibility.

The heart of the system was the NPDES permit. This is the mecha-

nism by which the Federal Government ensured that all the require-

ments of PL 92-500 were being met. Under the provisions of the

law, each point source discharging into a waterway must apply for

a permit either through the state or the Federal EPA (depending

upon the status of the state permit program). A manufacturer or

a municipality must obtain a permit that contains the following

elements:

• The pollutants that may be discharged. (The average

and maximum daily total amounts may be derived from the

effluent guidelines for the industry, from the require-

ments for toxic substances, or from requirements derived

from water quality standards.)

• A compliance schedule whereby the manufacturer must take

specific steps to bring his facility into conformance

with the requirements of the law for achieving the best

practicable control technology.

• A listing of the monitoring and reporting requirements

stipulated by both EPA and the states.

• The period for which the permit is applicable. (This

may not exceed 5 years.)
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In addition, all permits are issued subject to the following

conditions:

• The permit holder must report any new or increased

discharges.

• Any discharge of a new pollutant or excess discharge of

an authorized pollutant is a violation of the permit.

• The permit may be modified, suspended, or revoked if its

terms are violated or if it was obtained by misrepresen-

tation or failure to disclose all relevant facts.

• The permit holder will allow EPA or state water pollu-

tation control officials to enter and inspect the plant,

the required records, and the monitoring equipment.

Samples of discharges for analysis by EPA also can be

taken.

• The permit holder will keep his pollution control sys-

tems in good working order.

The Federal government was given ample authority to ensure com-

pliance with the conditions of the permit. If violations of

permits issued by the states are not followed by appropriate en-

forcement action, the Federal EPA can, after 30 days' notice,

initiate its own action.

The law further stated that any person who willfully or negli-

gently violates any permit condition shall be punished by a fine

of not more than $25,000, by imprisonment for not more than 6
173
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months, or by both. In this case the term "person" is interpreted

to mean any responsible corporate officer.

To provide the regulatory officials with sufficient information to

establish effluent standards and to maintain information on the

amounts of pollutants which are being discharged, the law allows

EPA to require that a manufacturer or municipality monitor its own

wastes in a manner to be specified by EPA. The manufacturer must

keep adequate records, which he shall provide to EPA on request or

on an established schedule.

EPA also has the right, upon presentation of appropriate creden-

tials, to visit any manufacturing site, examine records, check

sampling and monitoring equipment, and take any samples required

for checking the results being submitted by the manufacturer. All

of this information becomes public, unless to do so would reveal

trade secrets or proprietary information. In these cases, provi-

sions are to be made to allow access only to regulatory officials.

Penalties for refusing to comply, or for falsifying information,

are severe. This "self-monitoring" requirement plays a very

important part in the implementation of controls on manufacturers.

EPA also can require a manufacturer to provide information to as-

sist it in developing guidelines. This authority, from Section

308 of the Law, has led to requests from EPA for such information

to be referred to as "308 letters."
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Each state may develop its own procedures for inspection, monitor-

ing, and entry. After EPA approval, the state will be authorized

to carry out its procedures in the same manner as the Federal EPA.

The law also firmly established Federal control over the operation

of municipal treatment plants. This is accomplished through the

requirement that municipal systems obtain discharge permits under

NPDES. The law specifically directed EPA to develop pretreatment

standards for industrial discharges into publicly owned treatment

works (POTW's). This has now been superceded by the Clean Water

Act, paragraph 307, which is the subject of this seminar. Under

the old law, these pretreatment standards were to be formulated

to prevent the introduction of pollutants that were determined

not to be susceptible to treatment in the municipal system

or that would interfere with the operation of the municipal

treatment works. PL 92-500 also required that EPA develop pre-

treatment standards for new sources simultaneously with the devel-

opment of effluent standards for new plants discharging into

streams. Compliance with these pretreatment standards was re-

quired within a maximum of 3 years after their promulgation.

Under PL 92-500, the Federal government paid 75 percent of the

total construction costs for municipal treatment systems. Since

many states contribute an additional 15 percent of the cost of mu-

nicipal systems, many cities were required to contribute only 10

percent of the cost under the new law. Before the Federal share

could be approved, however, the municipality had to show that a

175
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plan had been developed to recover a proportionate share of the

total Federal construction costs from any industrial users. EPA

was required to develop guidelines for municipalities to arrive at

cost allocation systems that would meet requirements of the law.

In the past, municipalities only recovered the local share of the

cost from industry, with the new law, therefore, there was a sharp

rise in industrial charges for the use of municipal systems.

PL 92-500 contained a special section for dealing with substances

that were designated as toxic. Effluent standards or total prohi-

bitations of these pollutants were established under criteria

that required the consideration of the toxicity, persistence, de-

gradability, likelihood of the affected organisms being present in

the water, importance of the affected organisms, and nature and

extent of the substance on the organisms. EPA was directed to

prepare a list of substances that should be designated as toxic

and to develop effluent standards for those substances.

PL 92-500 also directed EPA to develop guidelines concerning

ocean disposal, oil spills, hazardous material spills, and

specific thermal discharges. In addition, the law allowed

tighter restrictions on plants discharging to water quality

limited streams.

1.3 THE NRDC SETTLEMENT AGREEMENT.
In 1976 EPA after being sued by the National Resources Defense

Council (NRDC), agreed to concentrate attention on potentially
176
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toxic substances using technology-based standards. These

would require as much control of toxic pollutants as tech-

nologically feasible by including toxic substances in the BAT

standards to be issued for individual industries.

This agreement committed EPA to a schedule for developing BAT

effluent limitations for 21 major industries covering 65 recog-

nized toxic substances. Those 65 substances have since been

broken down into 129 specific substances by EPA. Substantial

portions of the agreement were incorporated into the Clean Water

Act.

1.4 THE CLEAN WATER ACT OF 1977 (PL 95-217)

On December 28, 1977 the Federal Water Pollution Control Act

was amended and is known as the Clean Water Act (CWA) of 1977

(PL 95-217). These amendments involve numerous changes to

PL 92-500, including its requirements for control of indus-

trial discharges, construction of municipal sewage treatment

plants, management of nonpoint source pollution and other

related problems. The basic thrust of the CWA, however, is

to provide more emphasis for water pollution control of toxic

pollutants, by incorporating the NRDC decision into the new law.

A summary of the changes that the CWA made to PL 92-500 is

shown in the Appendix.
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Other important changes made by the 1977 Act include:

• Companies that have not met 1977 requirements for some

very specific reasons have been granted an extension.

For those plants discharging directly to navigable waters,

the maximum extension is to April 1, 1979. Companies

planning to tie into municipal systems have been granted

extensions to as late as July 1, 1983 under certain con-

ditions .

• BAT control standards scheduled to take affect July 1,

1983 are extended 1 year, to July 1, 1984.

e Development of BAT effluent guidelines covering all 21

industries and 65 pollutants covered in the NRDC

consent decree.

• Establishment of a "nonconventional" category of

pollutants for which the deadlines for control may

extend as late as July 1, 1987.

9 A one year moratorium was placed on industrial

cost recovery.

Section 307 (b) of the Federal Water Pollution Control Act of

1972 directed EPA to issue pretreatment standards for various

industries placing restrictions on discharges to municipal

treatment systems. Under this Act, EPA has developed

standards for several industries in conjunction with BPT,

BAT, and new source standards for those industries.
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These essentially reflect the same level of control of those pol-

lutants that would be required if the industrial plant were

discharging directly into naviagable waters. The Clean Water Act

Amendments alter those standards in several respects.

While EPA was considering the new emphasis on toxics, industry con-

tended that the application of BAT requirements would entail

enormous costs without significant benefits. In response, the

Clean Water Act divides the requirements for control into three

categories and applies different requirements to each. These

categories are:

• Conventional pollutants-these include parameters, such

as BOD, TSS, pH, etc. These are subject to a new stand-

ard of control, Best Conventional pollutant control

Technology (BCT), to be required by July 1, 1983.

• Toxic pollutants-these include heavy metals and

chemical compounds listed by the NRDC consent decree.

Industries must achieve BAT requirements no later than

July 1, 1984.

• Non conventional pollutants-these include all

other pollutants not specifically identified as con-

ventional or toxic. Compliance with BAT limitations

EPA sets must occur by July 1, 1987.

In addition to these changes, the Act authorizes the POTW to

relax an industrial user's pretreatment obligations if it can
179
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be demonstrated that all of the following conditions are

satisfied:

o The POTW is able to remove all or any part of the

toxic substance.

o The POTWs discharge does not violate any toxic

effluent limitation or standard which the industry

would have to meet if it did not utilize the POTW.

o Treatment by the POTW does not prevent sewage sludge

use or disposal in accordance with EPA regulations.

This provision provides credit to an industrial user for what-

ever removal of the pollutants is accomplished by the POTW with

the result that the net discharge will be less than the dis-

charge that would be permitted if the plant were a direct

discharger meeting BAT levels of control.

Many industrial plants currently discharging their wastes di-

rectly into navigable waters have planned to comply with water

pollution control requirements by tieing into a municipal

treatment systems.

If the municipal system is unable to accept this waste until

facilities can be expanded, the Clean Water Act allows EPA to

extend 1977 compliance deadlines (on a case-by-case basis) to

as late as July 1, 1983 if a corresponding extension has been
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granted to the POTW. The industry must prove, however, it was

committed to discharging to the POTW prior to July 1, 1977. If

it appears the POTW will not be operational by the new deadline,

the industry must install its own pollution control system.

In the event that an industry has been found to be in violation of

1977 BPT or water quality standards and that a time extension

is unavailable to the discharger, the Administrator may issue

an enforcement order directing a plant to discharge to a POTW

at the earliest possible date (but no later than July 1, 1983)

as the most expeditious method of achieving compliance. Issuance

of such an order, however, also would be dependent on a prior

request by the discharger and agreement of the POTW.

1.5 THE RESOURCES CONSERVATION AND RECOVERY ACT 1976 (PL 94-580)

Another import legislative act is the Resource Conservation

and Recovery Act. RCRA is aimed at controlling the disposal of all

solid wastes including sludges that may constitute a hazard to the

environment.

Hazardous waste guidelines and regulations eventually will be

published and draft regulations for the identification and

listing of Hazardous Wastes are now being reviewed. Under the

draft criteria, a solid waste will be considered hazardous if

it is flammable, corrosive, infectious, reactive, radioactive,

or toxic.
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Industry will be most concerned with those substances that are

defined as toxic. That is, which have any of the following

characteristics:

• Give a positive response to one of several required

tests for mutagenic activity.

• Give a positive result in the Bioaccumulation Potential

Test.

• Contain more than specified concentrations of any com-

pound on a "special chemical list."

• Have a concentration greater than or equal to 10 times

the EPA primary drinking water standards for a particular

substance.

• Contain any organic substance above a calculated thres-

hold concentration related to human toxicity.

• Have a concentration of any aquatic toxicant greater than

that specified in the regulations.

• Have a concentration of any phytotoxic substance greater

than that specified in the regulations.

1.6 THE TOXIC SUBSTANCES CONTROL ACT 1977 (PL 94-469)

The Toxic Substances Control Act of 1977 gives the EPA Administrator

broad authorities. These include:

• Requiring the chemical industry to conduct extensive

testing of chemical substances and mixtures.

• Requiring premarket notification to EPA of all new

chemical substances and any significant new use of an

existing substance.

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• Delaying manufacture and marketing of a new product

if sufficient information to evaluate the substance is

not available and if there will be substantial produc-

tion and substantial human or environmental exposure.

• Banning or placing restrictions on the marketing of

existing or new substances that are found to pose an

unreasonable risk to health or the environment.

• Requiring the maintenance of such records and the sub-

mission of such reports as the Administrator may

reasonably request.

This Act and its interrelation with other pollution control laws

will be discussed further in Section 4.
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SECTION 2

THE PRETREATMENT STRATEGY

2.1 GENERAL

Since the passage of PL 92-500 in 1972, it has been well known by

anyone involved in industrial pollution control that the require-

ments for pretreatment of the wastewater from plants that are

discharging to municipal systems would be very difficult to im-

plement cost effectively. Large expeditures will be required.

Concern for the conservation of capital resources requires that

the removal of pollutants by the municipal waste treatment plant

be taken into consideration—or the use of municipal systems By

industry would not make sense. But it is difficult to make pre-

dictions of this removal which are broad enough to be applied

across the nation.

EPA has taken a very careful approach in promulgating these stand-

ards. They have put forth and have held hearings on several pro-

posed strategies across the country. In these hearings the basic

issue was the amount of local discretion which was to be allowed.

The arguement for extensive local discretion held that inherently

this was a more cost effective approach, since the local authorities

would be able to set specific regulations to take account of

local factors and therefore result in the most effective use of

resources. It was argued that national pretreatment standards, to

be applied to all municipalities regardless of special local
184
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situations, could result in over control and wasted resources in

some cases and ineffective control in others.

On the other hand, the opposing view argued that only through

rigid national standards could the required degree of control

be obtained. Local authorities were not felt to have the re-

sources to establish effective standards by themselves.

This was considered to be true especially for the so-called

"priority pollutants," which potentially would affect health.

Under the consent decree with the National Resources Defense

Council, EPA had agreed to provide pretreatment standards for

these pollutants.

The Clean Water Act further stresses the necessity of pretreat-

ment requirements and gives an increased urgency for EPA to

promulgate its pretreatment standards.

Important sections of the Clean Water Act of 1977 will be im-

plemented by promulgation of National Pretreatment Regulations.

These regulations apply to the following:

o Industrial pollutants discharged into or transported and

introduced into publicly owned wastewater treatment works,

o POTWs which receive wastewater from sources subject to

national pretreatment standards (except where 100 percent

of the flow is from industrial sources).

o Any new or existing source or discharger subject to toxic

and pretreatment standards.
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2.2 BASIC GOALS

The objectives of the Pretreatment Regulations are to prevent in-

troduction of pollutants into POTWs which will interfere with plant

operations and/or the use and disposal of municipal sludges or

which will pass through the treatment works. In addition, the re-

gulations are meant to improve the feasibility of recycling and

reclamation of municipal and industrial wastewaters and sludges.

To assure that these goals are reached, two types of National Pretreat-

ment Standards are being developed: Prohibited and Categorical.

2.3 PROHIBITED DISCHARGES

Prohibited discharges apply to all industrial users of POTWs

whether or not the user is subject to other standards. Pro-

hibitive pollutants include:

o Materials that may create a fire or explosive hazard.

o Corrosive-type materials (unless POTW is specifically

designed for such). Any discharge with pH < 5 is

considered corrosive.

o Solid or viscous pollutants that obstruct flow

or interfere with operations.

o Slug discharges in volume, oxygen demand, or strength

to cause unit process upset and loss of efficiency.

o Heat discharges that will inhibit biological activity
o o
or increase POTW influent temperature above > 40 C (104 F).

o Slug discharges in violation of NPDES permit limits.
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2.4 CATEGORICAL DISCHARGES

2.4.1 GENERAL

Categorical discharges apply to existing and new sources in

specific industrial subcategories. Numeric limitations will

be set on treatment technologies available to industries.

Consideration will be given to POTW inhibition/interference.

All 21 industries listed in the 1976 Consent Decree (NRDC vs.

Train) are candidates for categorical standards.

Federal categorical standards normally will deal only with 129

priority pollutants and others that will be added. There are

two procedures by which plants might obtain some relief from

these standards:

• Removal allowances

• Fundamentally Different variances

2.4.2 REMOVAL ALLOWANCES

The Clean Water Act requires that some allowance be made for

removal of pollutions by the POTW. The Pretreatment Strategy,

therefore, provides for revisions of pollutant limits in cat-

egorical pretreatment standards for existing sources to com-

pensate for pollutant removals by the POTW. The Act provides for

revisions to be made on a case-by-case basis, as long as the POTW

provides data demonstrating removal and data showing that the

effluent limitation of the POTW is not violated and that sludge

management is in accordance with the Act.
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The POTW removal of a specific pollutant is defined as the reduction

or alteration of the nature of the pollutant by the POTW to a less

toxic or harmless state prior to discharge into receiving waters.

This reduction or alteration can be accomplished by physical, chemical,

or biological processes either specially designed into the POTW or

incidental to the operation of the POTW. Dilution is not considered

as a removal mode. Also, the inability of monitoring or detection

equipment to analyze diluted pollutants in influents will not be

considered as meeting removal criteria.

The following requirements must be met in order to establish

removal allowances:

• •The POTW Control Agency has an approved Pretreatment

Program.

• The POTW provides consistant removal of each pollutant

that a credit is requested for.

• POTWs with combined sewers or regular by-passes must be

in the process of correcting these conditions. At a

minimum, an approved facility plan which includes

treatment and control and an application submitted for

a Step 2 construction grant will be required. POTW

removal allowances will not be considered where efforts

are not being made to correct by-passes.

• Current and subsequent sludge management will remain in

compliance with applicable regulations and criteria, etc.

• Approval of removal allowances requested will not result

in the POTW violating water quality standards applicable

to the pollutant.

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2.4.3 FUNDAMENTALLY DIFFERENT VARIANCES

Variances for industry from categorical pretreatment standards also

will be provided for in the regulations for "fundamentally different

factors." These are considered as:

o Fundamental aspects of the industrial process which

significantly affect the nature or quantity of the

process wastewater.

o Fundamental aspects of the industrial process which

significantly affect the volume of process wastewater

and discharge.

o Age, size, land, and space consideration as related to

equipment and facilities, processes utilized, and

application of control technology.

o Excessive adverse impact on non-water (e.g. air or

solid waste) control technology required to meet a

categorical standard.

o Increased energy requirements, provided less energy

consumptive control technology is not available or

applicable.

o Disproportionate compliance costs due to one or more

of the above.

Any industrial user of a POTW or other interested person may

request a variance or exception from the limits specified in

a categorical standard. (Even EPA can initiate variances.)
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All variances will be handled on a case-by-case basis and

adjusted limits can be made either more or less stringent.

Economic hardship is not a valid consideration for a variance.

In short, the "fundamentlly different" variance is meant to apply

only to those relatively rare cases where a plant has a special

situation not considered by EPA in developing its effluent re-

gulations. For the bulk of the plants this procedure will not

offer any relief.
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SECTION 3

THE IMPLEMENTATION PLAN

3.1 GENERAL

To implement the Pretreatment Strategy a detailed set of pre-

treatment regulations have been issued. These regulations spell

out the relative responsibilities of the municipalities in

establishing and administrating a pretreatment program and in

applying for a removal allowance for their industrial dischargers

(if they choose to do so). The industrial requirements for

complying with the municipalities pretreatment program also are

established. This section summarizes these regulations.

3.2 REQUIREMENTS FOR MUNICIPALITIES

The Pretreatment Regulations will apply to municipalities

whether or not the POTW is Federally funded. All local au-

thorities operating publicly owned wastewater treatment works

with total flows in excess of 5 mgd and which receive industrial

wastes subject to the national pretreatment standards will be

required to establish pretreatment programs. The establishment

and enforcement of the local pretreatment program will be a con-

dition of the NPDES permit. Also, where needed, establishment of

a pretreatment program will be a condition of any new construction

grant.

Publicly owned treatment works with flows less than 5 mgd will be

required to develop pretreatment programs where special problems
191
-------
warrant and/or in order for their industrial clients to re-

ceive removal allowance from national standards as accounted

for by POTW removal of specific pollutants. Where a local pre-

treatment program is approved, the municipality can request

modification of Federal pretreatment standards to account for

POTW removal. Modifications are subject to a POTW meeting

applicable EPA criteria for sludge disposal.

3.3 REQUIREMENTS FOR INDUSTRY

The national categorical pretreatment standards for existing

industrial facilities will be based on the degree of pollutants

reduction that can be obtained by BAT. Industrial users of

POTW will be considered a distinct group. In some instances

the best available technology for direct and indirect discharges

may be identical and pretreatment standards and direct dis-

charge limitations may be the same for a given industry. It

is likely, however, that pretreatment standards will differ

from effluent limitations in most industries.

3.4 OBTAINING A VARIANCE

Before requesting a variance from categorical pretreatment stand-

ards, the following points must be addressed by the industrial user,

• The factors relative to the affected industrial user are

fundamentally different from the factors EPA considered in

determining BAT.

• The factors upon which the variance is based existed prior

to EPA promulgation of the particular standard.
19;
-------
• Due to the factors in question, the cost of compliance

would be grossly disproportionate to the cost EPA con-

sidered .

• The alternative pretreatment limits are justified by the

extent of the fundamental difference.

• The request for variance is in accordance with the pro-

cedures in the Regulations.

Requests for variances with supporting evidence must be sub-

mitted in writing to the Approval Authority. Requests must be

submitted within 90 days after EPA promulgates the particular

categorical pretreatment standards. Requests submitted after

the 90-day period will not be considered.

The following information will be required as part of the var-

iance submission:

• Requestor's name and address.

• POTW receiving industrial waste.

• Applicable categorical pretreatment standard.

• List of pollutant or parameter in question.

• Alternative limit proposed for each appropriate pol-

lutant or parameter.

• Description of the existing industrial water pollution

control facility.

• Schematic of industrial water system water supply,

process systems, and discharge point.

• Clear statement of need for variance include sup-

portive data, documentation, and appropriate evidence

193
-------
such as EPA development documents, economic data,

legal proceeding, etc.

• Where control technology recommended will not meet

the standard, it is essential that adequate documen-

tation be presented.

Requests that are deficient will be screened out and held for

30 days. The requestor will be notified of the deficiency.

If correction is not made within the specified period, the

request for a variance will be denied.

The appropriate Regional Administrator reviews requests and

determines if fundamentally different factors do exist. If

this is the case, the Regional Administrator submits his

recommendation to the EPA Administrator for approval or

disapproval of the variance request. The Administrator

may, however, specify different pretreatment limits or

revise the applicable categorical standards for all industrial

users in that category.

3.5 OBTAINING A REMOVAL ALLOWANCE

A POTW requesting removal allowances must provide supportive data

and information that should include the following:

• Proposed pollutants.

• Operational data on POTW influents and effluents that

demonstrate consistent removal. The data should be
194
-------
representative of yearly and seasonal conditions and

quality and quantity of normal flows.

• Sampling shall be in accordance with EPA procedures.

Composite samples, 3 consecutive days with a minimum of

12 discrete samples taken evenly over a 24-hour period.

• Grab samples may be used where composite sampling is

not an appropriate technique.

• List of industrial categories and number of users in

each subcategory and pollutant identification.

• Proposed alternative pretreatment limits.

• Data showing concentrations in POTW sludge. Similar

sampling techniques as used for liquid streams.

• Specific description of POTWs current sludge disposal

methods, including data indicating continuing com-

pliance.

• Removal efficiencies and alternative pretreatment

limits should be calculated in accordance with EPA

regulations and guidelines.

Removal allowance requests are submitted to the approval authority

which considers the request. Public notice is served if approval

is given.

3.6 BAT REVISIONS

Part of the NRDC settlement proposed deadlines for EPA promulgation

of BAT guidelines for 21 industries. Table 1 indicates the

present status of the proposed dates along with a schedule worked

out by EPA.

195
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Table 1

NRDC CONSENT AGREEMENT PROPOSAL
DATES VS REALISTIC DATES

Category

Timber Products Processinq
Steam Electric
Leather Tanning and Finishing
Iron and Steel Manufacturing
Petrol eum Refining
Nonf errous Metal s
Paving and Roofing
Paint and Ink Formulation
Printing and Publishing
Ore Mining
Coal Mining
Organic Chemicals
Inorganic Chemicals
Textile Mills
Plastics and Synthetic Materials
Pulp and Paper
Ru bber -
Soaps and Detergents
Auto and Other Laundries
Miscellaneous Chemicals
Pesticide Manufacturing
Gum and Wood Chemicals
Pharmaceutical Manufacturing ......
Explosives Manufacturing
Adhesives and Sealants
Carbon Black
Machinery and Mechanical Products
Mechanical Products
Battery Manufacturing
Plastics Processing
Foundries
Coil Coating
Porcelain Enamel ing
Aluminum Forming
Copper & Copper Alloy Products....
Electrical & Electronic Components
Shipbuilding
Photographic Equipment & Supplies.
Electroplating
NRDC
Proposal
Date
9/30/78
9/30/78
9/30/78
9/30/78
9/30/78
12/31/78
12/31/78
12/11/78
12/31/78
12/31/78
12/31/78
3/31/79
3/31/79
3/31/79
3/31/79
3/31/79
3/31/79
6/30/79
6/30/79

6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79

6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
6/30/79
Real istic
Proposal
Date
9/30/78
8/31/79*
12/30/78
6/30/79
4/ 9/79
5/ 7/79
**
5/31/79
5/ 1/80*
12/31/78
8/31/79
9/30/79
5/31/79
3/31/79
9/30/79
6/30/79
6/30/79
9/30/79
6/30/79

10/31/79
6/30/79
6/30/79
7/31/79
6/30/79
6/30/79

5/ 1/80
11/15/79
11/30/80
7/27/79
6/29/79
6/22/79
12/31/79
11/16/79
5/ 1/80
6/30/79
12/30/79
12/15/79

Months
Late
0
11
3
9
6
4
0
5
16
0
8
6
2
0
6
3
3
->
o
0

4
0
0
1
0
0

10
4.5
17
1
0
0
6
4.5
10
0
6
5.5
* These dates are not firm. May be changed after project review.
** Paragraph 8 entire category.
196
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3.7 MONITORING AND REPORTING

EPA will establish self-monitoring and reporting requirements

for all indirect dischargers covered by national standards.

Industries will be required to report their plans and progress

toward compliance with the applicable pretreatment standards.

Once compliance is achieved, reporting on continued compliance

will be quarterly or semi-annually, depending on the significance

of the source within each industrial subcategory as established by

the national standards. Where there is an approved local program,

industry will report to the POTW, otherwise reports would be

submitted to EPA or the NPDES State.

Municipal permits must require POTW's to furnish the permitting

authority with information concerning the character and volume

of any pollutants discharged by a significant source, new intro-

ductions of pollutants by existing sources, and changes in volume

or character of pollutants and other appropriate information.

Compliance with this permit provision by all POTW's will provide

an initial inventory of sources potentially subject to pretreatment

standards and progress reports on changes in industrial discharges.

If a POTW has an approved local program, the strategy provides

discretion to waive, in part, some monitoring and reporting require-

ments .

In order to facilitate the coordination of RCRA regulations of

industrial sludge management with pretreatment, all POTW's are

required to provide an inventory of industrial users upon

197
-------
request to State or EPA authorities. In addition, POTW1s will

be required to notify all industrial users subject to pre-

treatment standards of the existence of standards (both national

and any local) and of any RCRA requirements for industrial sludge

management. In addition to updating the inventory of industries,

annually, POTWs will be required to notify new users of the

municipal system of the existence of the applicable pretreatment

and RCRA regulations. These notification requirements will be

incorporated into the next revision of municipal permits. POTW's

that are developing approved local pretreatment programs will

be eligible for grant support for compiling the industrial

inventory. Failure of a POTW to comply with certain provisions

of its permit could result in the issuance of enforcement orders

and prosecution of municipal authorities.

3.8 ENFORCEMENT

The implementation plan's strategy emphasizes local enforce-

ment of national and local pretreatment standards where local

compliance programs are approved. Local authorities with

approved programs would notify all indirect dischargers, per-

form compliance reviews and monitoring, and enforce the

standards. EPA and the NPDES States would back up local

enforcement efforts only where requested or needed for water

quality reasons. Where EPA or an NPDES State determines

that enforcement by an approved local compliance program is

inadequate, EPA or the State may, after 30-day notification
198
-------
to the State and local authority, take enforcement action

against the POTW and the industry. Civil action may seek

relief through: permanent or temporary injunction against the

POTW and the industry, requirement of such action as necessary

to secure compliance, and/or restriction or prohibition of the

introduction of any pollutant into the POTW from any new indus-

trial source. In addition, EPA or the State could withdraw

local compliance program approval in whole or part or withhold

construction grant support where a grant is involved.

In areas where local authorities do not assume responsibility

for the program, Federal and NPDES State authorities will exer-

cise their descretion to enforce pretreatment standards directly

against industry and/or against the POTW where permit violations

occur and the POTW does not take appropriate enforcement action

within 30 days after notification of a violation. Operation of

a source in violation of pretreatment standards is unlawful. In

addition, in the exercise of its emergency powers, EPA may recover

from an industry the cost of any emergency assistance required

to deal with a violation of pretreatment standards for toxics.

The Federal and State enforcement priorities will be as follows:

• Indirect dischargers to POTW's without local compliance

programs.

• Indirect discharges to POTWs where violations of pre-

treatment requirements occur and local authorities

request Federal back up

199
-------
• Industrial users of POTW's with approved local com-

pliance programs.

Direct Federal enforcement against industry in areas without local

compliance programs will initially focus on a few, highly visible,

major sources of significant toxic pollution in an effort to en-.

courage industry compliance and local assumption of enforcement

responsabilities.
200
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SECTION 4

SPECIAL INTERACTIONS BETWEEN LAWS

4.1 RCRA and CWA

Both RCRA and CWA cover the disposal of sludge. Under RCRA,

however, a waste treatment system (industrial or municipal)

that generates, treats, transports, and disposes of its sludge

will be subject to several sections of the law if the sludge

is determined to be hazardous.

EPA is currently studying this situation with the intent of

developing a single permit procedure for POTWs under section

405 of the Clean Water Act. Industrial Wastewater Treatment

plants, however, would be regulated and permitted under RCRA.

4.2 RCRA, CWA, and TOSCA

There also is some overlap in these three acts in the intent to

control the fate of toxic pollutants in the environment and

possible health hazards. As seen in Section 1, TOSCA generally

affects the manufacturers of toxics and is aimed at preventative

measures to control these pollutants. Generally, TOSCA

provides guidance to the Administrator on coordinating

this Act with other EPA administered laws. If the

Administrator determines that a risk to health or the

environment could be eliminated or reduced to a sufficient
201
-------
extent under other laws, such as RCRA or CWA, he is instructed

to use those laws unless he determines that it is in the

public interest to protect against such risks under TOSCA.
202
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SECTION 5

SUMMARY

The new pretreatment regulation may seem complex but the follow-

ing key points were clearly summarize their status:

o All municipalities with flows above 5 mgd must have a

pretreatment program.

o Plants discharging to municipalities in the 21 priority

industries must install BAT unless the municipality

presents data that demonstrates removability in the

municipal system.

o Additional monitoring is required of municipalities which

have received a removal allowance.

o The sludge from the municipal system must meet RCRA re-

quirements.

With these points in mind, the industrial plant has three choices:

o Direct discharge to the stream - in which case the manu-

facturer will be required to meet BAT level treatment for

plants which discharge to municipalities.

o Pretreat to BAT.

o Work with the municipality to obtain a POTW removability

allowance and pretreat at less than BAT. The municipality

continues to be the major interface with the NPDES

authority.
203
-------
There is one other option, which will be available only to a few

plants. That is the variance because of fundamentally different

factors. That is basically a special consideration if your plant

represents a major departure from the situation considered by EPA

in deriving the pretreatment requirements.

Each plant must evaluate which is the most economical route for its

particular situation. It is complex, and there are several factors

yet unknown, which could have a major influence on the final decision.

For example, the EPA decision on what is BAT for a particular industry

will be of major importance.
204
-------
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-------
EFFECTS AND REMOVABILITY OF INDUSTRIAL POLLUTANTS
IN A MUNICIPAL SYSTEM
PREPARED FOR

ENVIRONMENTAL PROTECTION AGENCY

TECHNOLOGY TRANSFER
JOINT MUNICIPAL/INDUSTRIAL SEMINAR

PRETREATMENT OF INDUSTRIAL WASTES
1978
Prepared By

A. J. Steffen

Consulting Environmental Engineer

West Lafayette, Indiana
207
-------
TABLE OF CONTENTS

Page

A Typical Publicly Owned Wastewater Treatment Works... 211

Primary Treatment 212
Secondary Treatment 219
Tertiary Treatment 225
Sludge Handling and Disposal 227
Lagoons for Wastewater Treatment 232
Land Disposal of Wastewater 234

Impact Of Toxic Pollutants On POTW 234

Impact of Toxic Pollutants on Aerobic
Biological Processes 234
Impact of Toxic Pollutants on Clarification 241
Impact of Toxic Pollutants on Anaerobic
Sludge Digestion 243
Impact of Toxic Pollutants on Heat
Treatment of Sludge 243
Impact of Toxic Metals on Disposal of
Sludge on Agricultural Land 245

Industrial Cost Recovery 249

Common Practices in POTW Charges for
Industrial Users 249
Clean Water Act Requirements for ICR 250
ICR Moratorium 252
Pollution Parameters in POTW User
Charge Ordinance 253

Removal Allowances And Variances 254

POTW Removal Allowance 254
Fundamentally Different Factors Variance 259

Procedure In Processing A Removal Allowance 261

Financing Removal Allowances 261
Existing Limits in Local Ordinances 262
Exploratory 263
Conventional Data Collection 264
Development of Work Plan for Special Studies 265
208
-------
Pace

Pretreatment: For The Industry By The POTW 268

Introductory Comment 268
Pretreatment: at the Industry 268
Pretreatment: at the POTW 272

Treatment Of Toxic Pollutants In POTW 272

Introduction 272
Phosphorus Removal in Primary and
Secondary Stages 275
Removal of Toxic Pollutants in Biological
Treatment 278
Relative Capabilities of Various Activated
Sludge Process Systems in Treating
Toxic Pollutants 280
Anaerobic Digestion 282
Emergency Treatment of Cyanide Slug 285
Tertiary (Advanced) Treatment at a POTW 285
Sludge Disposal on Agricultural Land 287
Summary 289

In-Plant Wastes Control: The Economic
Approach To Compliance 291

Recycle and Reuse Systems 291
In-Plant Waste Conservation: Some Examples...." 292
Controlled Discharge 294
Industrial Process Alterations 294
Blending 296
By-Product Recovery 296
In-Plant Safeguards 297
Developing A Good Working Relationship With
The Municipality 298

Personnel Relationships 298
Splitting Samples 299
Joint Research 300
Development of Pollutant Disaster Plans 300
209
-------
LIST OF FIGURES AND TABLES
Figure
1
2
3
4
5

6
7
8
9
10

11
12

13
14
Table
1
3
4

5
6

8
Figures Page
Activated Sludge System (Typical) 213
Aerated Grit Chamber 214
Comminutor Installed in Channel 215
Clarifier Section 217
Rectangular Clarifier With Chain
and Flight Sludge Collector 218
Rock Media Trickling Filter 220
Bio-Disc Treatment Plant - Pkg. Type.... 221
Mechanical Aeration 222
Activated Sludge Processes 224
Flow Diagram for Typical Tertiary
Treatment Plant 226
Two-Stage Anaerobic Digestion 228
Sludge Quantities Before and
After Digestion 229
Effect of Mixing in Digestion 283
Typical Dry Weather Flow and BOD
Variation of Municipal Wastewater 295

Tables Page
Threshold Concentrations of Inorganic
Pollutants Inhibitory to Biological
Processes 235
Threshold Concentrations of Organic
Pollutants Inhibitory to Biological
Processes 237
Metals in Digested Sludge - 33 Plants... 246
Common Methods of Pretreatment in
Key Industries 269
Table 4 (continued) 270
Average Removals of Some Priority
Pollutants by Conventional Municipal
Treatment Methods 273
Metals in Raw Municipal Wastewater -
Residential and Industrial 27.6
Maximum Application of Toxic Metals
on Soi 1 28.8
210
-------
INDUSTRIAL WASTES IN MUNICIPAL WASTEWATER SYSTEMS

A. J. Steffen
Consulting Environmental Engineer
West Lafayette, Indiana

A TYPICAL PUBLICLY OWNED WASTEWATER TREATMENT WORKS
Wastewater discharged to publicly owned wastewater treatment
works (POTW), often termed municipal wastewater, is water
containing dissolved, colloidal and suspended solids derived
from residential, commercial and industrial operations, the
latter pretreated if necessary to prepare it for treatment in
the municipal plant. The solids may be organic (of animal or
vegetable origin) or inorganic (inert and not subject to bio-
logical or chemical degradation). In addition, the wastewater
contains dissolved gases such as carbon dioxide and hydrogen
sulfide.

There are commonly three successive steps in the treatment of
municipal wastewater: primary, secondary and tertiary. As
might be expected, secondary treatment uses the effluent of
primary treatment and then goes a step further. Most treat-
ment stops there, but some goes to tertiary treatment which
uses the effluent of primary and secondary treatment and goes
a step beyond. The degree of treatment selected depends upon
the character of the waste, geography, climate, flow vari-
ations and results desired. (See Figure 1. for a typical
flow diagram).
211
-------
Normally, primary treatment is physical (sometimes with chemi-

cals) , secondary is biological, and tertiary is usually chemi-

cal and physical but may also be biological. The treatment of

municipal wastewater, at least in the primary and secondary

phases, is far less complex than the treatment of industrial

wastewater. However, tertiary treatment varies widely.

The greatest problem in POTW's is unanticipated overloads. An

industrial catastrophy may produce spoiled product or a spill

that finds its way into the POTW sewer. Even running the dis-

charge of a storm sewer through a POTW affects the plant's

operation and today's new treatment plants generally are

connected to sewers handling only sewage ("wastewater"), not

storm water. However, there are still many combined (storm-

sanitary) sewers connected to most systems.

PRIMARY TREATMENT

Primary treatment alone generally represents insufficient

treatment for discharge to receiving waters. Federal funds

are no longer granted for construction of primary treatment

alone, and existing primary plants are being extended to

secondary treatment as rapidly as funding and construction can

proceed. However, since this is the first stage, preceding

secondary treatment, it should be considered separately.

Primary treatment begins with either screening or grit removal,

usually the latter. (See Figure 2. and Figure 1) . The grit
212
-------

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FIGURE 3. COMMINUTOR INSTALLED IN CHANNEL
215
-------
chamber may be a long channel where the rate of flow of the

wastewater is drastically reduced, usually to one foot per

second, or a proprietary device that does the same job in

square or circular tanks. The reduction of flow rate allows

the stones, dirt, gravel and other heavy inorganic matter to

settle out. Grit is usually disposed of in landfills or by

separate incineration. (Incidentally, controlled reduction

in the flow rate forms the keystone in primary treatment).

Screening, which follows, is like sifting. It removes rags,

paper and large solids. Stationary screens (or racks) may be

used, with or without mechanical rakes. Frequently the

wastewater goes through comminuting devices (grinders, cutters,

shredders), instead of a screen, to cut up larger solids,

thus eliminating the disposal of screenings. This step pre-

vents solids from clogging pumps and facilitates treatment in

the sedimentation and biological steps that follow.

The wastewater now passes to circular or rectangular sedimen-

tation or settling tanks. (See Figure 4^ and Figure _5) . Here

the velocity is reduced to let organic solids settle. The

settled sludge is collected from the bottom of the tanks, and

grease and scum are removed from the surface. Sludge requires

further treatment in most cases. The treatment and disposal

of sludge is discussed on pages 17 to 22.
216
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SECONDARY TREATMENT

Now that the settleable solids have been removed, the waste-

water goes on to biological treatment for decomposition of the

suspended, dissolved and colloidal organic matter present.

Trickling filter or activated sludge systems are most common.

Both processes are aerobic (done in the presence of oxygen)

and both depend upon aerobic biological growths for their

action, in contrast with the anaerobic biological action in

sludge digestion.

The trickling filter (see Figure 6) is not really a filter but

a large bed of rock or synthetic (usually plastic or wood)

material over which the primary effluent is sprayed, and in

which the organisms grow. The interstices between the media

serve as passages for air to maintain aerobic conditions in

the bed.

A "biological disc" which utilizes the same principle as the

trickling filter, consists of rotating discs which are the

support media for aerobic biological growth. The discs rotate

to dip into the wastewater, then out into the atmosphere, thus

providing controlled exposure to the wastewater and to the air.

(See Figure 7_) .

In activated sludge, the aerobic process is done without bac-

teria "holders." The organisms (the "activated sludge") are

in the mass of liquid, and either compressed air (sometimes

pure oxygen), or a mechanical aeration device (see Figure 8)
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supplies the organisms in the liquid with air in order to main-

tain them in condition to metabolize the organic matter. A

variety of flow patterns have been developed to serve various

waste characteristics. (See Figure 9J .

In both systems, organisms are discharged with the liquid from

the aerobic process. In trickling filters, the organisms

slough off of the rock. In the activated sludge process, they

flow out with the effluent. In both cases, we need to remove

these solids in a settling or sedimentation tank, such as those

described under Primary Treatment. The entire mass of trick-

ling filter sludge is discharged to the digesters. In the

activated sludge process, however, some of the organisms must

be returned to the aeration tank to serve as seed material to

maintain a proper amount of organisms in the tank to metabolize

the organic matter. The waste activated sludge, even after

concentration in the final clarifier, is very dilute, about 0.5

to 1.0% solids, and is pumped to the primary sedimentation tank

to agglomerate with the solids there or is concentrated separ-

ately before discharging to the sludge disposal system.

Before discharging to a watercourse, the liquid is treated with

a disinfectant (usually chlorine), in a "contact" tank where

enough time (about 15 to 30 minutes) is provided for the chlorine

to disinfect the effluent before discharge to a watercourse.
2'.:
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RAW

WASTEWATER
INAL 1 EFFLUENT
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FIGURE 9: ACTIVATED SLUDGE PROCESSES
224
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TERTIARY TREATMENT

If the secondary effluent satisfies state and EPA regulations

for discharge into a receiving water, the treatment is

completed. If, however, it cannot be discharged because of a

downstream need for better quality, tertiary treatment may

become necessary.

There are currently about 750 tertiary treatment plants in

the United States. As concern for the quality of our surface

waters continues, standards will be raised, and more municipal

treatment plants will need to add tertiary treatment.

Tertiary systems vary widely, depending principally upon the

quality of the secondary effluent and the characteristics

desired in the discharge to the stream. The treatment may

consist of slow or rapid sand filtration or filtration through

diatomaceous earth or mixed media. It could be aeration or

flotation to foam out detergents. It may be chemical pre-

cipitation with alum or iron salts to settle out suspended

solids. It may be super-chlorination, followed by dechlorina-

tion to insure positive kill of bacteria. It may be biologi-

cal treatment to remove nitrogen. More could be listed.

(Figure 10 shows one type of tertiary system).

Wastewater effluent is not "wasted" water. Industry will often

buy secondary or tertiary effluent for use as nonpotable water

for cooling or other nonpotable purposes. Ideally, all
225
-------
INFLUENT-
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CARBON L-
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ACTIVATED
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CHEMICAL
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FIGURE 10

FLOW DIAGRAM FOR 'TYPICAL TERTIARY
TREATMENT PLANT
226
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wastewater should be treated to a level of quality based

upon a selected use.

SLUDGE HANDLING AND DISPOSAL

The organic sludge, consisting of raw settled and floated

solids from primary treatment plus waste sludge from second-

ary treatment is most commonly treated in anaerobic digesters.

(See Figures 11 and 12). The waste activated sludge contains

only 0.5 to 1.2 percent solids and, if not concentrated by

discharge to the primary clarifiers, it needs to be thickened

before discharging to the digesters. Thickeners are general-

ly of two types: the gravity thickener which is basically

a conventional clarifier with vertical pickets or deep trusses

to stir the sludge gently, and the flotation thickener, in

which pressurized air floats the sludge to the surface of a

clarification tank.

Digesters generally operate in series, the first one being

well-mixed and heated to enhance metabolism, and the second

being quiescent to separate the liquid and the digested

sludge. Anaerobic digestion operates in the absence of air

and destroys organic solids by their conversion to gas (i.e.,

carbon dioxide and methane) and stabilizes or conditions

the sludge for disposal. Bound water is released in the

process. This biological process requires the establishment

of two distinct populations which must work together in the

same tank. The first population is an acid producing group,
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facultative and anaerobic bacteria with extra-cellular enzymes

that ferment complex organic compounds to simple organic acids.

The second group, strictly anaerobes, converts the soluble

organic acids to carbon dioxide and methane gas, a source of

energy useful for heat and power. The methane producers have

intracellular enzymes that utilize dissolved nutrients and

function best at about 95°F and at a pH above 6.2. The best

operating range is pH 6.6 to 7.6. About 40 to 60 percent of

the volatile solids are destroyed. In efficient ("high rate")

systems, a period of 12 to 15 days is sufficient to produce

a sludge that dewaters well and can be discharged without

nuisance. However, poorly mixed ("standard rate") digesters

may require as much as 40 days detention. Both the biological

process and the safety hazard in dealing with methane dictate

that anaerobic digesters be well sealed to prevent entrance

of air. Because anaerobes have a low cellular growth rate and

convert a substantial portion of the organic matter to methane

gas and carbon dioxide, the resulting solid matter is well

stabilized and is therefore suitable for disposal on land

without nuisance.

Aerobic digestion can produce similar organic solids reduc-

tion over a similar length of time. Because of its operating

simplicity and low first cost, it is particularly attractive

for small plants. Aeration continues until the microorganisms

are starved and begin to subsist on their own metabolic

products, thus reducing the organic residue (cell tissue).
230
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This system produces carbon dioxide gas and is energy-

consumptive, in contrast to anaerobic digestion which produces

burnable gas (methane).

If final disposal requires concentration of raw or digested

sludge to more than 5 or 6 percent solids, some means of de-

watering is required, normally preceded by chemical condition-

ing. In chemical conditioning, the chemical (usually ferric

chloride, alum, lime, or a polymer/ or any combination of

them) reduces the charge on the suspended particle and thus

decreases its tendency to bind water. The addition of

chemical does, however, increase the sludge quantity for

disposal. Separation by gravity as well as any mechanical

means is thereby enhanced. In some plants raw sludge is

treated chemically to eliminate the biological step. The

process is not widely used, principally due to chemical costs,

operating problems and increased sludge volume.

Among the many methods of sludge dewatering, vacuum filtration

has been the most popular. It removes solids from nearly all

types of sludge efficiently and at low cost. Activated sludge,

being very dilute, presents some difficulties when treated

alone. Belt filters, leaf and frame pressure filters and

centrifuges are also used. Sand beds are commonly used to

dewater digested sludge in small POTW.

Digested sludge is commonly disposed of by 1andspreading.
231
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landfill, incineration, and lagooning. Disposal to the oceans

has been popular in the large coastal cities but is being

phased out by EPA requirements and court orders. Direct

application on cropland (mostly corn and feed grains) is

increasing in popularity. Digested sludge is a good soil

conditioner and a fairly good fertilizer. The nitrogen in

the liquid phase provides additional nutrients when the

sludge is applied in the wet state.

Raw undigested sludge can be heat dried, incinerated or land-

spread by trenching into the soil. A few states permit raw

sludge to be discharged directly to landfills, with immediate

mixing with refuse. Raw sludge can also be stabilized by

oxidizing with large doses of chlorine (about 2000 mg/1).

The product dewaters well and is stable but, with a finished
i
pH at about 2.0, it requires pH adjustment prior to dewatering

on vacuum or belt filters. Lime will also stabilize raw

sludge at pH of 11.5 to 12.2. The product is filterable and

free of pathogenic bacteria.

Chemical fixation of sludge with proprietory additives for

disposal as inert landfill is not generally practical for

the large sludge volumes common to POTW.

LAGOONS FOR WASTEWATER TREATMENT

Where suitable land areas are available, aerobic lagoons

provide low cost secondary and tertiary treatment. Some
232
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(stabilization ponds) depend entirely upon the photosynthetic

effect of sunlight, developing algae that produce oxygen in

their metabolism. Others (aerated lagoons) are aerated

either mechanically or with diffused or bubbled air to both

mix and aerate the lagoon. In some two-stage systems the

first, an aerated lagoon, usually with return sludge, takes on

some of the properties of activated sludge treatment and the

second, an unaerated aerobic lagoon, polishes the effluent by

anaerobic fermentation in the bottom and aerobic utilization

of the solublized organics in the photosynthetic zone. There

are two basic types of stabilization ponds: one, about 6 to

18 inches deep, maximizes the production of algae; the other,

about 5 ft. deep, maximizes the production of oxygen and is

generally recirculated. The deeper pond provides anaerobic

solubilizing of organic solids at the bottom. Both types

receive some oxygen from atmospheric diffusion.

Aerated lagoons are also of two general types: the totally

mixed aerated lagoon which is often operated with sludge

return and the aerobic-anaerobic lagoon which is not mixed in

full depth, to permit decomposition of organic solids anaer-

obically at the bottom (much like a deep stabilization pond).

A settling tank is a normal component of most aerated lagoons.

Commonly the waste sludge is limited in guantity and is

sufficiently stabilized to permit disposal without digestion.
233
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LAND DISPOSAL OF WASTEWATER

In the past decade, ultimate disposal of wastewaters by

irrigation has been studied intensively in this country. It

can serve as a low-cost disposal of municipal wastewater,

after primary clarification or as tertiary treatment. Care-

ful preparatory agronomic studies must be made to determine

runoff, subsoil character and permeability, heavy metal

migration, effect on the underground water table, suitable

crops, needs for storage in wet and freezing weather, and

public health hazards relating to crops and grazing. There

are several EPA publications on land disposal of wastewaters

that provide details on design, costs and operation.

IMPACT OF TOXIC POLLUTANTS ON PQTW

IMPACT OF TOXIC POLLUTANTS ON AEROBIC BIOLOGICAL PROCESSES

Except for accidental spills and slugs, the toxic pollutants

are rarely in such concentrations as to cause toxic kills of

trickling filter or activated sludge biomass in POTW.

However, there is a range of concentration at which the

metabolism of an activated sludge will be inhibited, depend-

ing upon the wastewater temperature, metabolism rate, pH,

the combinations of toxic pollutants present, concentration

of the sludge mass, concentrations of pollutants and their

variability, and the character of the food. Added to this

list are variables related to each individual treatment

plant: design, operating practices, ambient temperatures,
234
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monitoring facilities, laboratory facilities, competency of

personnel and funding. In the light of this array of vari-

ables, it becomes difficult to arrive at any but very general

conclusions from statistical evaluations of multiple research

reports and POTW questionnaire surveys.

However, certain useful facts can be gleaned from available

research reports and full-scale operating data:

• The first effects of excessive heavy metal concentra-

tions are an increase in turbidity and a decrease in

nitrification. Continued excesses will cause a decrease

in BOD removal and bulking sludge.

• If the metal is continuously present, the biomass may

become acclimated and thus have a higher inhibition

threshold.

• Inhibition does not occur at a specific point in bio-

logical fermentation. Rather, it may start at very low

concentrations and not cause serious trouble until the

concentration increases to an order of several magni-

tudes. Tables 1^ and J2./ in part summarizing data col-

lected by the EPA (1), show the levels of concentration

at which some of the toxic pollutants inhibit biologi-

cal treatment processes. The data for cadmium, chromium,

copper, cyanide, lead, nickel and zinc are summarized

from Appendix A of Proposed Regulation 40 CFR Part 413,

"Electroplating Point Source Category Pretreatment
235
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TABLE
THRESHOLD CONCENTRATIONS OF INORGANIC POLLUTANTS
POLLUTANT
Ammonia
• Arsenic
Borate(Boron)
• Cadmi urn
Calcium
Chromium
•, (Hexavalent)
Chromi urn
» (Trivalent)
• Copper
• Cyanide
Iron
• Lead
Manganese
Magnesium
0 Mercury
• Nickel
• Silver
Sodi urn
Sulfate
Sulfide
• Zinc
THAT
ACTIVATED
SLUDGE
PROCESSES
480
0.1
0.05-100
10-100
2500
1-10
50
1.0
0.1-5
1000
0.1
10

0.1-5.0
1.0-2.5
5

0.3
ARE INHIBITORY TO BIOLOGICAL
TREATMENT PROCESSES
CONCENTRATION (mg/1)
ANAEROBIC NITRIFICATION
DIGESTION PROCESS
PROCESSES
1500
1.6
2
0.02

5-50 0.25
50-500
1.0 0.005-0.5
4 0.34
5
0.5

1000 50
1365
2.0 0.53

3500
500
50

PRIORITY POLLUTANTS
0.08-0.5
Note: Concentrations shown represent influent to
the unit processes in dissolved form.
236
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TABLE 2
THRESHOLD CONCENTRATIONS OF ORGANIC POLLUTANTS
THAT ARE INHIBITORY TO BIOLOGICAL
TREATMENT PROCESSES
POLLUTANT
CONCENTRATION (mg/1)
ACTIVATED
SLUDGE
PROCESSES
ANAEROBIC
DIGESTION
PROCESSES
NITRIFI-
CATION
PROCESSES
Alcohols
Allyl
Crotonyl
Heptyl
Hexyl
Octyl
propargyl

Phenols
* Phenol
Creosol
* 2-4 Dinitrophenol
200
100
500
500
1000
200
500
19.5
4-10
4-16
150
Chlorinated Hydro-
c arbons
• Chloroform
* Carbon Tetrachloride
10-16
10-20
• Methylene Chloride 100-500
• 1-2 Dichloroethane 1
Dichlorophen* 1
Hexachlorocyclohexane 48
• Pentachlorophenol* 0.4
•> Tetrachloroethylene 20
• 1, 1, 1, -Trichloroethane 1
• Trichloroethylene 20
t Trichlorof luoromethane* 0.7
Trichlorotrif louroe thane
(Freon) 5
Allyl Chloride
Dichlorophen

Organic Nitrogen Compounds
% Acrylonitrile 5
• PRIORITY POLLUTANTS

Note: Data Represents Influent To
Process, Except * Denotes To-
tal Plant Effluent.
180
50
237
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Standards for Existing Sources", (pages 6565-6567,

Federal Register, Vol. 43, No. 31, Feb. 14, 1978).

The data on activated sludge reflect the effects on

aerobic bacteria operating in the carbonaceous phase,

whereas the nitrification data show the effects on aerobic

organisms operating in the nitrogenous stage of oxidation,

a more sensitive group of organisms producing nitrites

and nitrates. Most types of activated sludge treatment

plants operate in the carbonaceous phase of BOD removal,

but extended aeration (24 hours, with little or no sludge

wastage) usually includes the nitrification stage.

In pilot-scale algal lagoons treating chromium tannery

wastes, acclimated algae showed no growth inhibition at

1.0 mg/1 chromium, whereas common algal assay test

species showed significant inhibition at this concentra-

tion (2). More research is needed in this area.

Some toxic pollutants, such as arsenic and nickel,

inhibit oxygen uptake as well as metabolism.

Synergistic effects, (in which combinations of toxic

pollutants cause a more severe effect than either one

alone) have been noted for combinations of cadmium and

zinc, and manganese, copper and cyanide. Further study

of these interactions is needed.

Some organic compounds on the priority list are biode-

gradable but have high BOD's. For example, phenol has

200 percent BOD, alcohols about 125 percent and benzene
238
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has 120 percent BOD. These high BOD's make excessive

demands on activated sludge systems as well as trickling

filters. The insecticides on the priority list may

cause bacterial kill and can inhibit biological metabo-

lism at concentrations as low as 1 mg/1.

Slug doses can have long-term inhibitory effects and

some may completely upset biological processes. Some

studies showed that slugs of chromium up to 500 mg/1

in the influent did not affect the activated sludge

settling, whereas copper at 50 mg/1, fed for four hours,

showed adverse effects on activated sludge. A short-

time slug of 40 mg/1 of cyanide caused a two-day upset

of an activated sludge plant (3). Slugs of zinc

exceeding 40 mg/1, cadmium exceeding 20 mg/1, and

virtually any level of mercury were found to cause

formation of a highly stable pin-point floe (bulking

or deflocculation) with the loss of significant

quantities of biomass over the effluent weirs of second-

ary clarifiers. Maximum bulking occurred about 10 to

14 days after the metal was fed (4).

Activated sludge that has been acclimated can treat wastes

that contain a consistent level of 60 mg/1 of phenol (5).

Heavy metal concentrations in the 1 to 5 mg/1 range may

have a cumulative effect on trickling filter operation,

causing excessive slime growths with ultimate ponding

and reduced BOD removal. Normally about 30 to 50 percent
239
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of the metal is absorbed by the slime. Sodium cyanide

produces alkalinity which in excess can cause unloading

of trickling filter slimes (6).

• Systems utilizing oxygen rather than air are sometimes

completely closed, to recycle the unutilized oxygen.

The recycle of this oxygen necessarily includes CO- as

a product of the metabolism. The return of this CO,,

depresses the pH and can resolublize toxic metals.

From this overview, a set of general conclusions can be

reached:

1. Activated sludge, acclimated by steady contact, can remove

substantial quantities of heavy metals, cyanide and bio-

degradable organic pollutants from solution.

2. Inhibition of biological metabolism occurs over a wide

range of feed concentrations of heavy metals and organic

pollutants and is influenced by so many variables that

statistical evaluations are useful only in reaching broad

generalizations.

3. Information on the impact of slug doses on biological

processes is scattered and inconsistent.

4. Some heavy metals in combination have more severe effects

than the metals individually.

5. Heavy metals in concentrations of 1 to 5 mg/1 cause excess

slime growths and ponding of trickling filters.
240
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IMPACT OF TOXIC POLLUTANTS ON CLARIFICATION

Primary Clarification

Theoretically, all of the metal hydroxides will be insoluble

above 1.0 mg/1 and should settle in the primary clarifiers.

Heavier than water insoluble organic compounds, such as

chloroform and carbon tetrachloride will also settle. However,

the dispersing effect of colloidal material in the POTW waste-

water may prevent a large portion of the precipitates from

settling and thus permit passage to the secondary treatment

phase. Additionally, the long sludge detention time in pri-

mary clarifiers (in excess of 8 hours where the sludge pump-

ing regime calls for operation once per shift) may produce

anaerobic conditions in the sludge layer and cause a drop in

pH below the level of hydroxide insolubility of some metals.

The pH of the total sludge layer, which includes the more

buoyant sludge that flows over the sludge scrapers is

probably lower than pumped primary sludge (pH 5.5-6.5) because

of its much longer detention. Thus resolublization of heavy

metal hydroxides may be expected.

Secondary Clarification

In the conventional multiple plow type sludge removal equip-

ment employed in circular clarifiers, most commonly used in

secondary clarification, about 3 hours are needed to move a

sludge particle from the periphery of an 80 ft. diameter tank

to the center discharge sump. Also, sludge builds up at the
241
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center over the sump and will remain as long as 8 to 24 hours

before being drawn out by the currents induced by the sludge

discharge pumps.

If a nitrifying sludge is involved, the settled sludge, thus

detained in the absence of oxygen, will reduce the

nitrite and nitrate forms to ammonia and nitrogen gas. This

buoys up the sludge and causes it to rise, producing a pin-

point floe which discharges over the effluent weirs. Surface

skimming devices do little to pick up this fine suspended floe.

If the pH is below the solubility level of the metal

hydroxides in the sludge, the hydroxides will resolublize and

the metals will be discharged in the final effluent. Studies

of individual POTW may demonstrate advantages of pH adjust-

ment at the influent to secondary clarification, to precipi-

tate dissolved metal complexes and to prevent resolubliza-

tion of metal hydroxides. If tertiary treatment is practiced

at the POTW, soluble metal complexes may be removed by carbon

adsorption or may be precipitated incidental to treatment for

phosphorus removal.

A special hydraulic sludge removal device has been designed

for prompt removal of sludges from clarifiers, to minimize

anaerobiosis in the settled sludge. This removal device

consists of nozzles connected to hollow collector pipe arms

that, by head differential, pick up the settled sludge

immediately in every revolution of the collector arm. This
242
-------
is in contrast to the multiple short scrapers on collector

arms in circular clarifiers and the moving slats in rectangu-

lar clarifiers. This equipment is particularly useful in

removing light flocculent sludges such as activated sludge

in secondary clarifiers.

IMPACT OF TOXIC POLLUTANTS ON ANAEROBIC SLUDGE DIGESTION

Anaerobic digestion is sensitive to the presence of most

heavy metals and many organic chemicals, particularly or-

ganic insecticides. Copper, zinc, nickel, chromium and

cadmium are the heavy metals that most commonly cause digester

problems. The effects are additive and some loss of gas pro-

duction will occur at heavy metal concentrations (total) of

200 to 400 mg/1 in the raw sludge (0.4 to 0.8 percent dry

basis) if the sulfate concentration is low (6). At 1000 mg/1

(2 percent dry basis) continuous feed for two to three weeks

digestion was found to cease entirely (6). Cyanide salts may

form soluble complexes which may inhibit digestion.

In an anaerobic environment, such as sludge pits and stag-

nant sewers, hydrocyanic acid gas may be evolved, which can

be lethal to personnel entering such structures.

IMPACT OF TOXIC POLLUTANTS ON HEAT TREATMENT OF SLUDGE

Wet-Air Oxidation

In this process raw sludge is oxidized in the liquid state by

hot air under high pressure. Heavy metal hydroxides (copper,
243
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zinc and nickel) are solublized (7). This is significant

because the liquid phase of the process is usually returned

to the wastewater plant.

Sludge Incineration

There are few data on the fate of toxic pollutants in inciner-

ation. Mercury will volatilize upon incineration, but as

reported in the EPA Process Design Manual for Sludge Treatment

Disposal (EPA 625/1-74-006) Oct. 1974) in limited tests, only

4 to 35 percent of the mercury entering an incinerator, with

emission controls, was found in the off-gas. If cadmium is

present as a chloride, it could also volatilize, but if

present as a precipitated hydroxide it will probably decompose

to the oxide at incineration temperatures (1,200-2,000 F).

Most of the other toxic metals will be converted to oxides

and appear in the ash, and as particulates will be removed by

air scrubbers. Some zinc and lead compounds volatilize at

incineration temperatures and can appear in the off-gas. The

ash residue is about 10 percent.

In the EPA Manual mentioned above, it is stated that PCB's

do not appear in ash or scrubber water of incinerators where

sludge contained 1.2 to 2.5 mg/1 PCB's. Thus they are

either destroyed by incineration or remain as vapors in the

gas stream.

The Manual provides the following information on pesticides:

"Rapid thermal degradation of most pesticides has been shown
244
-------
to begin at approximately 500°C with near total destruction
at 900°c. If these materials volatilize before burning/
the use of afterburners on incinerators would be needed to
provide complete destruction."

Incineration costs are about half the cost of land application
if costs of land application include sterilization of the
sludge before it is placed on the land.

Flash Drying
Flash drying produces dried sludge for use as a fertilizer
and operates at about 1300 F. The impact of toxic pollutants
in this process is similar to that of incineration.

IMPACT OF TOXIC METALS ON DISPOSAL OF SLUDGE ON
AGRICULTURAL LAND
Spreading on agricultural land has become a major means of
sludge disposal in the United States. The percent of POTW
using this procedure rose from 22 percent a decade ago to
46 percent in 1974 (8) . Further increases are, however,,
doubtful, recognizing the increasing public opposition to
this practice and the advent of federal toxic limits for
discharges to agricultural land.

Table _3 lists the median values for concentrations of heavy
metals in digested sludge, in milligrams per kilogram of
dried sludge, from 33 POTW's ranging in size from 0.1 mgd to
150 mgd (EPA data). The mg/kg can be divided by 20 to
245
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convert to the concentration, in mg/1, in a 5 percent
(typical) sludge.

TABLE 3 (9)

METALS IN DIGESTED SLUDGE - 33 PLANTS

Metal Median Value
mg/kg
Cadmium 31
Chromium 1100
Copper 1230
Mercury 6.6
Nickel 410
Lead 830
Silver 355
Zinc 2780

The heavy metal uptake of plants from sludge-conditioned soil
cannot be readily predicted. Soil characteristics, metal
concentrations, moisture content, temperature, climate, pH,
•*
organic content, cation exchange capacity, and many other
agronomic variables must be considered. Increasing tempera-
ture increases uptake, while increasing pH (above 6.5)
*Cation exchange capacity (CEC): An adsorption process in
soil. The negatively charged exchange sites on organic
matter or clay surfaces to which cations (heavy metals,
calcium, magnesium, potassium) can be temporarily bound.
It reflects a soil's ability to hold metals and is
measurable.
246
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decreases uptake. Among the heavy metals appearing in sludge,

cadmium, copper, nickel and zinc pose the greatest potential

hazard for accumulation in edible portions of the plants

(grain, fruit, root, leaf) (10). Nickel and copper are

relatively nonhazardous except on grazing land, since the

plant dies or fails to grow long before it can accumulate

enough to be toxic to humans or animals. Lead is unlikely

to accumulate in plants because it is relatively insoluble

at the normal pH's of soil. Chromium has been found to be

nontoxic at normal sewage sludge levels. A study by the

Texas A & M Research Foundation demonstrated that the

majority of applied cadmium, copper, zinc, nickel and lead

is retained in the upper 5 inches of soil/ where it is

readily available to plants.

Studies show that, if the metal retention in the soil is high,

the amount appearing in the crop will be low. A soil's

ability to tie up metals is related to its cation exchange

capacity.

Cadmium, because of its direct uptake by plants and its

effects on humans and animals is the metal of greatest detri-

mental potential. Criteria proposed by the Environmental

Protection Agency limit the annual application of cadmium on

agricultural land to 2 kilograms per hectare (1.78 Ibs per

acre) before Dec. 31, 1981; then 1.25 kg/ha to Dec. 31, 1985,

then 0.5 kg/ha. Maximum accumulations are proposed at
247
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5 kg/ha for soils with a cation exchange capacity less than 5;

10 kg/ha for a CEC of 5 to 15, and 20 kg/ha for a CEC greater

than 15. A maximum of 25 mg/kg of cadmium is proposed in

sludge applied to tobacco and to leaf and root crops grown

for human consumption.

The suggested criteria provide that cadmium-bearing sludges

should be applied so as to maintain a sludge/soil pH of 6.5

or more. Agronomists generally agree that this pH is attain-

able and represents the level for lowest uptake. Although

studies indicate that the uptake of heavy metals from sludge

treated soil reduces with time (in years), the long term

hazards have not been identified (11).

The Environmental Protection Agency estimates the mean con-

centration of cadmium in POTW sludge at 106 mg/kg (dry basis)

with a range from 3 to 3000 mg/kg. Cadmium normally in

soil ranges from 0.017 to 0.7 mg/kg, with a commonly accepted

level at 0.06 mg/kg (12). There is disagreement among

researchers as to whether crop uptake increases year by year

with continued application of cadmium.

In closing this section, it should be noted that the sludge

use on agricultural land is limited by a number of factors:

1. Land use constraints: environmental, physical,

topographical

2. Public's psychological objections
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3. Odor

4. Weather

5. Cropping system

6. Excess nitrogen, phosphorus and salts

7. Pathogens

8. Excessive toxic elements

9. Regulatory controls

Increasing the heavy metal inventory in waste sludge will

require additional land if landspreading is the process in

use. This adds cost to any system proposed in a removal

allowance if additional heavy metal removal is contemplated,

and may encounter strong public objections.

INDUSTRIAL COST RECOVERY (ICR)

COMMON PRACTICES IN POTW CHARGES FOR INDUSTRIAL USERS

Many strategies have been used to recover from the industrial

users some or all of the costs of providing them with waste-

water treatment. In some cases, large industries have been

singled out for special contract arrangements. This would be

in addition to a user charge, which is usually a flat percent-

age of the water bill charged against all users, including

residential. Many user charges include a downward sliding

scale as volume of waste increases but this is no longer

permitted when the POTW is an EPA grant applicant.

Special charges per unit of flow, BOD, suspended solids,
249
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chlorine demand and other parameters, above a base, are not

uncommon. The base is the user charge and represents the

equivalent in domestic sewage, as paid by all users. Survey

data provide totals of flow and pollutants from which the

total annual costs are calculated. This system can reflect

the cost of treating an industrial wastewater that is dis-

similar from domestic wastewater in pollutant concentration.

CLEAN WATER ACT REQUIREMENTS FOR ICR

The Clean Water Act provides for reimbursement of EPA grants

for the design and construction of plant facilities strictly

for industrial loads. This is in addition to user charges

for operation and maintenance (including replacement) of

POTW's.

The following is a summary of ICR provisions:

• The charge system should be in proportion to the indus-

trial waste characteristics that cause the extra costs,

such as flow (usually maximum flow is important), BOD,

suspended solids, and special pollutants.

• When reductions in flow are made by an industrial user,

the POTW authority can reduce the industrial user charges

proportionately, and when the waste flow is eliminated,

the entire payment is stopped. However, no allowance is

made for temporary downtime.

• Where ad valorem taxes are charged to an industrial user

for a portion of the plant costs, such taxes may be
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subtracted from the ICR.

A non-governmental user of a POTW having a flow of 25,000

gpd or less, including sanitary wastes, is exempt from

ICR requirements, provided that the wastes do not impair

POTW operation and maintenance, do not affect POTW sludge

disposal adversely, do not affect receiving waters

adversely, do not create health hazards and do not create

a nuisance in the POTW system.

New industrial discharges which the POTW can or is de-

signed to handle are charged when they go on stream, in

proportion to the remaining ICR payment period, which is

usually 30 years.

Industries discharging only sanitary non-process waste-

waters may be exempted at the POTW's option. If exempted,

then sanitary wastewaters discharged with process waste-

waters should also be exempt.

Contracts for capital cost recovery operating before

March, 1973, are exempt.

The ICR charges should be based on monitoring by the

industry or the POTW at least annually, as specified

in the ordinance.

Sewer construction is subject to ICR, in proportion to

the industrial flow fraction. It may include either

the entire sewer or only the length used by the

industrial flow.
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ICR MORATORIUM

In Section 75, the Clean Water Act declares a moratorium until

June 30, 1979, on enforcement of and payment into all ICR

systems set up in compliance with grant application or agree-

ments. The moratorium provides that all payments due the EPA

between December 31, 1977 and June 30, 1979 shall be post-

poned and shall be paid after the moratorium in equal annual

installments over the useful life of the treatment works.

This postponement covers only the amount collectible by the

EPA (50 percent of the total charge). During the moratorium,

the EPA will continue to require ICR ordinances as a requisite

for any grants applications and agreements. The moratorium

is intended to provide time for Congress to study the ICR

program. If, in the meantime, the Congress makes no changes

in ICR requirements, the EPA will require grantees to collect

ICR payments after the moratorium in accordance with the

currenct provisions of the CWA.

This does not preclude a POTW authority from collecting

industrial user charges under local applicable ordinances and

agreements. If the authority does collect such payments, the

EPA requires that they will hold the portion due the Federal

government (50 percent) until June 30, 1979 for incremental

payment in accordance with CWA Section 75.

The effect of the moratorium on the industrial user can be nil

if the POTW authority decides to continue the charges, or it
252
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can be a 50 percent postponement of the charges if they post-

pone EPA payments only, or it can be 100 percent postponement

if they decide to postpone the POTW portion as well as the

EPA portion of the charges.

POLLUTION PARAMETERS IN POTW USER CHARGE ORDINANCE

The user charge ordinance should spell out the prohibited

incompatible pollutants and the numerical limits of the

permitted incompatible pollutants. The ordinance may set up

the permit conditions but enable the POTW authority to deter-

mine the constituents, characteristics, and quantities for

which the permittee is to be charged, limits on flow rate and

time (this may call for equalization of flow regulation),

installation of flow measurement and sampling facilities,

requirements for monitoring, reports and records required to

maintain the unit charge schedule and fees, any prohibitions

that relate to the permittee's waste discharge, and duration

of the permit (a maximum should be spelled out in the ordinance)

This places the rate-making in the hands of the POTW authority

and avoids changes in the ordinance every time costs or loads

change.

When criteria are being developed for an ICR at the local

level, the affected industries should participate in their

formulation to the greatest possible extent. The experience

will help strengthen relationships with the POTW management.

It may also reveal some cost advantages in equalization and
253
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pretreatment and may even develop opportunities for a POTW

removal allowance. Industry's aim is to get the lowest over-

all annualized cost without impairing the operation and main-

tenance of the POTW. The first step towards this ideal is a

well-balanced cost-effective program of in-plant waste

conservation, utilization, equalization and pretreatment.

Only then can industry begin to discuss charges for industrial

cost recovery. To reach these objectives, the industry

management and the POTW authority must work together in an

atmosphere of cooperation and mutual respect.

REMOVAL ALLOWANCES AND VARIANCES

POTW REMOVAL ALLOWANCE

The Clean Water Act of 1977 (PL 95-217) provides for removal

allowances in a portion of Section 307(b)(1): "If, in the

case of any toxic pollutant introduced by a source into

a publicly owned treatment works, the treatment by such works

removes all or any part of such toxic pollutant and the

discharge from such works does not violate that effluent

limitation or standard which would be applicable to such

toxic pollutant if it were discharged by such source other

than through a publicly owned treatment works, and does not

prevent sludge use or disposal by such works then the

pretreatment requirements for the sources actually discharging

such toxic pollutant into such publicly owned treatment works

may be revised by the owner or operator of such works to

reflect the removal of such toxic pollutant by such works."

254
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The questions and answers that follow explore the strategy for

a POTW removal allowance.

1. What is a POTW removal allowance?

Ans.: A removal allowance for a POTW is a specific

approval to discharge a concentration of a priority

pollutant into the POTW sewers greater than the

national pretreatment standard because the

particular POTW has a specific removal capability.

2. But don't all approved POTW's have the same removal

efficiency for toxic pollutants?

Ans.: Definitely not....because:

a. No two POTW's are exactly alike in design or in

operating results.

b. Some unusual characteristics of the raw municipal

wastewater, other than the industrial plant's

contribution, may beneficially affect the POTW's

performance in treating the priority pollutant.

Such characteristics might be an unusually high

or low pH, or temperature, or alkalinity, or a

flocculent discharged by another user.

c. Some add-on treatment, incorporated into the POTW

to treat the priority pollutant, may be doing its

job.

d. The POTW may include a non-conventional primary

or secondary treatment facility or a tertiary

treatment system (chemical, physical or
255
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biological) that incidentally has the ability to

remove some of the priority pollutant. Such a

facility might be a chemical added to improve

primary clarification, an improvement in air

bubble retention in the aeration tanks, or a

tertiary treatment to remove phosphorus or any

other system provided for a purpose other than

removal of the priority pollutant.

3. How is the new pretreatment limit calculated?

Ans.: It may be calculated as follows:

x
y =
l-r

where:

x = pollutant limit specified in the applicable

categorical pretreatment standard (expressed

in mg/1)

r = POTW's consistent removal rate for that

pollutant as established under 403.7(c)(2)

(expressed as a percent)

y = alternative pretreatment limit for the

specified pollutant (expressed in mg/1)

(Comment: For example, if the categorical pretreat-

ment standard for a specific pollutant is 1 mg/1 and

the POTW consistently removes 50 percent of that

pollutant, then the alternative pretreatment limit

for that pollutant would be 2 mg/1.)
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4. Who applies for the removal allowance?

Ans.: The legally designated representative of the POTW

control agency.

5. What information should be included in the application?

Ans.: Approval of a removal allowance depends upon proof

that the POTW can accept the pollutant, that treat-

ment is not impaired, and that the uses of the sludge

will not be impaired. Some of the data that will

supply this information are listed in the following:

a. Influent and effluent data/ to show consistent

adequate removal. The removal allowance should be

based upon the lowest measured removal over 95

percent of the measurement period. Data should

be shown in both concentration and mass, with

sufficient statistical analysis to show the

character of the influent and effluent under all

possible conditions, including seasonal and

industrial processing variations. Grab samples

should be taken where the pollutant is one (such

as cyanide and phenol) that will not be stable

over the period required for the composite

sampling.

b. The possibilities for objectionable peak flows

during wet weather should be explored. (By-

passing untreated wastewater during wet weather

may be a valid reason to disallow the application,
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unless a grant under "Step Two" has been applied

for) .

c. Any special method or methods for reducing or

eliminating the specific pollutant should be

described, along with the results.

d. Since some or all of the specific pollutants may

be removed in the POTWs sludge, data should be

presented as to the concentration of the pollu-

tant in the sludge. Federal, state and local

regulations should be reviewed to determine that

no applicable laws are violated in hauling, dry-

ing, incineration (air pollution), irrigation,

land filling, spreading or lagooning the sludge.

6. Can removal allowances be more as well as less stringent?

Ans.: Yes. The POTW can apply for a more stringent pre-

treatment limitation if the operation or maintenance

of the POTW can be shown to be subject to impairment

under the national pretreatment standards for the

pollutant.

7. How is the removal allowance enforced?

Ans.: It is enforced by the local POTW authority, by way

of provisions in the authority's industrial waste

ordinance, permits, licenses or contractual agree-

ments . The effluent standards are enforced through

the POTW's NPDES permit.

8. Can a removal allowance be rescinded?
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Ans.: Yes, if there is a violation of the conditions of

the removal allowance by the industry or if it is

later found that the POTW cannot treat the pollutant

as expected. When a removal allowance is rescinded,

the industrial discharger is given three years to

meet the national pretreatment standards, or less if

non-conformance creates a health or environmental

hazard.

9. What about new sources of a priority pollutant?

Ans.: The POTW authority shall determine whether the new

source(s) can operate under the removal allowance

without impairing the operation or maintenance of

the POTW, and that the new source(s) will not

jeopardize compliance with the POTWs NPDES permit.

10. Does the industrial user get a time extension (for compli-

ance) during the time a POTW removal allowance application

is being prepared and processed?

Ans.: No.

FUNDAMENTALLY DIFFERENT FACTORS VARIANCE

The questions and answers that follow explore the strategy for

fundamentally different factors variances (hereinafter called

"variance").

1. What is a variance?

Ans.: A variance is a specific approval for a change in a

numerical pretreatment standard proposed by an

industrial user of a POTW for factors relating
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to the user's operations.

2. On what basis does the industry request a variance?

Ans.: The industry can request a variance if there are

substantial differences between its circumstances

and those considered normal to the industry that

would affect the quantity and character of its

priority pollutants discharged to the POTW. These

factors might include: materials used, equipment

and processes employed, and excessive cost of

available pretreatment technologies. The factors

cited must have existed prior to final promulgation

of the related pretreatment standard.

3. Is the economic condition of the company or plant a factor

in requesting a variance?

Ans.: No.

4. When must a variance be requested?

Ans.: Within 90 days after promulgation of the applicable.

standard.

5. What information must be included in the application to

the Regional Administrator?

Ans.: Furnish and explain local plant data that document

differences between it and the factors used in

developing the national pretreatment standards.

(Development documents used in producing the

standards are or will be available).
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6. How is the variance enforced:

Ans.: It is enforced by the POTW authority, by way of

provisions in the authority's industrial waste

ordinance, permits, licenses or contractual agree-

ments, in the same manner as a national standard.

7. Can a variance be rescinded?

Ans.: Yes, if there is a violation of the variance by the

industry or if it is later found that the industrial

effluent discharged to the POTW does not warrant the

variance.

8. Does the industrial user get a time extension (for compli-

ance) during the time that a variance application is

being prepared and processed?

Ans.: No.

PROCEDURE IN PROCESSING A REMOVAL ALLOWANCE

FINANCING REMOVAL ALLOWANCES

Construction or reconstruction of facilities at a POTW neces-

sary to achieve treatment to the level of the removal allow-

ance requested is eligible for grants under Section 201 of the

CWA. Any planning incident to development of a removal

allowance request that can be identified as part of an area-

wide waste treatment management program can be funded under
t
Section 208 of the CWA.
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EXISTING LIMITS IN LOCAL ORDINANCES
Many POTW are operating with local ordinances specifying limits
of some toxic pollutants.

A summary of regulatory limits collected in a recent survey (13)
follows:
mg/1
Number of cities Minimum Maximum Average
Cadmium 40 0.002 15.0 1.41
Copper 43 0.20 15.0 2.46
Nickel 38 0.1 15.0 3.04
Lead 36 0.05 5.0 0.79

Of interest is the fact that the maximum tabular limits for
cadmium, copper and lead are from Los Angeles, which also is
second high in nickel (12.0 mg/1).

It is likely that many cities with more liberal limits than
USEPA pretreatment standards will attempt to retain these
limits by submitting requests for removal allowances, if the
POTW satisfies regulatory effluent limitations. Such removals
would be incidental removals being experienced currently and
should not be difficult to document. However, if the current
local limitations are enforced and are more severe than the
USEPA pretreatment standards, the POTW may request a negative
removal allowance if it is felt that the more severe limits ^
are necessary for successful operation of the POTW.
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EXPLORATORY

Collecting data on wastewater discharged by an industry into

municipal sewers is and must be a continuing joint effort.

This is never as vital to the industry as when a removal

allowance is sought. If the industry demonstrated its

cooperation before and during the design and construction of

the POTW and the later operation of the treatment plant pro-

duced no surprises in the industrial wastewater volume and

pollutant characteristics, the groundwork has been laid for a

cooperative study. If a POTW removal allowance appears to be

a possibility, the industrial wastes manager and the superin-

tendent of the POTW should discuss the pros and cons and

examine available records and operating reports to determine

the feasibility for such a request.

A rough material balance should be developed, from the origin

of the pollutant to its ultimate fate in the sludge or POTW

effluent. Hopefully, the data will show the approximate

pollutant removal at various stages of treatment, both in the

industry and at the POTW. If there are indications that

incidental removal may be occuring in the POTW operations,

then the prognosis for success in applying for a removal

allowance is good. Too often there is a frustrating lack of

routine data on toxic pollutants in POTW records.

Routine analyses of compatible pollutants at the POTW should

be studied, however, to locate unexplained variations that
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might be attributable to variations in toxic pollutant load.

Examination of the data may reveal opportunities for a

removal allowance by way of changes or add-ons in an existing

pretreatment system or in the POTW or both.

The areas of investigation should be selected, at least

tentatively, from among the phases of treatment at the industry

and the POTW. Recycle systems and holding tanks should not be

overlooked. Basic information from the literature and study

of the accumulated data will probably eliminate many areas.

Routine analyses of the toxic pollutant concentrations at the

POTW should be undertaken if they have not been done before.

At this point the data should be presented for decision to a

formal or informal committee made up of personnel technically

or administratively equipped for decision making in this area.

A discussion with related EPA personnel may be pertinent.

CONVENTIONAL DATA COLLECTION

Where no special studies are required, the composite sampling

program can be conducted by the POTW. Before undertaking

the sampling program, the POTW should be assured that the

data will be representative of yearly and seasonal conditions

relating to the pollutant under study. It may be necessary

to conduct several sampling surveys to cover the entire

variations that may be expected during any 12-month period.
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DEVELOPMENT OF WORK PLAN FOR SPECIAL STUDIES

If the project requires special studies, the phases will

probably include (a) completion of exploratory phase,

literature search, and finalizing the work plan; (b) select-

ing, procuring and installing flow measuring and sampling

stations, laboratory equipment, and pilot plants; (c) sampling

surveys and analyses; (d) evaluation of data; (e) conclusions

and recommendations; and (f) development and transmittal of

the application for the removal allowance.

The work should be divided on the basis of which agency has

technically qualified personnel available, which one has the

greater share of equipment required and which one would be

able to do the sampling most conveniently. Additional person-

nel may be needed for statistical work, sampling and analysis.

The costs may be divided in a different manner based as much

as possible on benefits, not necessarily on the source of the

manpower and equipment. It is not unusual for an industry to

pay a POTW for running special analyses and studies. Extensive

planning can be funded by a 208 grant as mentioned before. An

interface meeting with the EPA personnel should also be

considered at this time.

If the industry's wastewater is a significant part of the POTW

load, the exploratory phase can become an important part of

the total project. Then events in the industry and the POTW

can be correlated with the daily operating and analytical data.
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Such events may be changes in processing, installation of

waste conservation improvements and incidents such as spills

that would radically affect the characteristics or flow of

wastewater.

An evaluation report should be prepared, summarizing and

explaining the collected existing data. Recommendations for

ways to fill gaps in the data should be made. The report

should recommend areas of investigation and suggest

procedures.

The sampling surveys should now be organized and any proposed

pilot work should be developed. Details on surveys are

included in a subsequent presentation. The sampling personnel

should be closely supervised, since an error in sampling can

jeopardize the entire project. Samples should be split

periodically to maintain a high confidence level.

Sludge handling and disposal should be explored in detail.

Applicable regulations should be checked and discussed with

related regulatory people. The ultimate fate of the pollu-

tants in the environment requires thorough examination. If

the POTW practices landspreading, the services of state and

university agronomists and soils specialists may be enlisted

to evaluate the effects of the toxic pollutant(s) upon the

soil, and vegetation.

Some pilot studies may be necessary. Bench scale biological
266
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reactors can be purchased from laboratory supply houses.

Other systems can be built of glassware and tubing. If a

large scale pilot plant is called for, it should follow bench

scale studies and be built from dimensioned drawings. The

pumps and chemical feeders should be sized and selected during

the design phase. The study can ordinarily be carried out by

POTW personnel with, possibly, some help from industry person-

nel. Extensive studies may require the assistance of a

professional laboratory, or an environmental engineering group

at a university.

A report of the technical survey and collected data should be

prepared jointly by the principal investigator from each

organization. They should cite specific improvements that

must be made both at the industry and at the POTW in order to

consistently obtain the predicted results on which the request

for a removal allowance is based.

The request for the removal allowance should be developing in

a preliminary form as the study proceeds. When the data has

been examined statistically, the application should be roughed

out. The superintendent of the POTW has primary responsibility

for its preparation but will probably ask the industry's wastes

manager to help. They should also seek the counsel of the

EPA representative, at least to review the application for

completeness before it is submitted to the Regional Office.
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PRETREATMENT: FOR THE INDUSTRY BY THE POTW

INTRODUCTORY COMMENT

This and the following section provide process information for

the industrial user interested in possibilities for a joint

venture with POTW. Removals of toxic pollutants in POTW fall

into two general classes: the incidental removal which takes

place in the existing POTW and is incidental to the main

purpose of the POTW process, and the designed removal which is

provided expressly for the removal of a toxic pollutant.

This section deals with designed removal provided prior to

discharge into the POTW. The following section, "Treatment

of Toxic Pollutants in POTW" relates principally to incidental

removals, and to a "grey area" in which incidental removal is

improved by an add-on.

PRETREATMENT: AT THE INDUSTRY

Tables 4. and .5 present a general overview of common pretreat-

ment systems for the eight industries for which pretreatment

standards have been developed. They are used in many combina-

tions depending upon the characteristics of the wastewater,

the degree of treatment desired and treatment equipment

selected.

In many instances it may be feasible for the POTW to construct

and operate the pretreatment facility, at or near the industry.
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TABLE 4
COMMON METHODS OF PRETREATMENT IN KEY INDUSTRIES
POLLUTANTS
COMMON METHODS OF
PRETREATMENT
Electroplating
Dissolved solids, heavy
metals, acidity,
alkalinity, ammonia
Recycle, equalization, solids
separation, neutralization,
cyanide oxidation, chromium
reduction, chemical precipita-
tion (heavy metals), and ion
exchange
Inorganic Chemicals
Insoluble muds, grit,
dissolved and suspended
inorganic solids, weak
brines, cyanide (hydrogen
peroxide electrolytic process),
mercury (fluorine: mercury
cell process), fluorides
(hydrofluoric acid mfg.)/
chromium (sodium dichromate
& sodium sulfate mfg.).
Recycling, impoundment, solids
separation, evaporation, chemi-
cal precipitation, neutraliza-
tion, chemical reduction (hex-
avalent to trivalent chromium),
flocculation, distillation.
Leather Tanning & Finishing
BOD, suspended solids, COD,
grease, hair, alkalinity,
acidity, chlorides, sulfides,
chromium
Reuse (tanning and dehairing
solutions, pickle liquor, retan
liquor), screening hair, equal-
ization, grit removal, solids
separation, coagulation,
secondary treatment, precipitation
of trivalent chromium, neutral-
ization
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TABLE 5 - Continued From Table 4
POLLUTANTS
COMMON METHODS OF
PRETREATMENT
Petroleum Refining
BOD, COD, suspended and
dissolved solids, oil and
grease, phenols, ammonia,
chromium, zinc, nickel,
lead, sulfides, phosphates
Interdepartmental reuse, recycle,
equalization, grease & oil sep-
aration, solids separation,
activated carbon, hydrolysis of
acid sludges, evaporation, neu-
tralization & oxidation of spent
caustics, sulfide stripping
Steam Electric Power Plants
Dissolved & suspended
solids, COD, high and low
pH, heavy metals (ash sluic-
ing & tube cleaning), oil &
grease, heat, surfactants,
phenols, volatile organics
Equalization, neutral-
ization, chemical precipitation,
cyanide oxida-
tion, filtration, grease
separation
Textile Mills
BOD, COD, suspended and
dissolved solids, color,
fiber, oil and grease,
alkalinity, ammonia, alum-
inum, chromium, phenols,
sulfates, chlorides,
phosphates, heat
Screening, equalization, recycl-
ing (caustics & soap), grease
separation, solids separation,
neutralization, chemical coagula-
tion, heat exchange, chromium
reduction, activated carbon,
chemical precipitation
Timber Products Processing
BOD, COD, suspended solids,
color, phenols, phosphates,
oil & grease (wood preserving)\
Recycle, equalization, contain-
ment, solids separation
Nonferrous Metals Manufacturing
Muds (20% solids)(Bauxite
refining), COD (aluminum,
copper & lead mfg), heavy
metals (lead, copper, zinc,
arsenic), fluorides (aluminum
mfg), alum, oil & grease (cop-
per mfg), aluminum
Solids separation, pH control,
grease flotation, lime precipi-
tation, impoundment, & recycle
(lead, zinc and copper)
270
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This produces a number of advantages for the industrial user:

1. The industry pays its share of the construction costs

as an annual charge, which constitutes an operating

cost for income tax purposes.

2. The industry pays no personal property or real estate

taxes for the facility.

3. For a small pretreatment facility, the savings in

separate staffing, which would likely be needed in

an industry-operated facility, can be substantial.

4. The industry is not burdened with the reporting and

laboratory chores.

A financial disadvantage to the industry is the possibility

that operating and maintenance costs can escalate without

much opportunity for control by the industry.

Advantages in this arrangement for the POTW authority:

1. The POTW personnel become more familiar with the

problems of the industry and are better prepared for

emergencies.

2. The extra operating and laboratory time can often be

absorbed at little extra cost.

3. Operations, particularly in a small municipality with

one or two major industries, are simpler when the

entire waste treatment responsibility is centered in

one agency.
271
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PRETREATMENT: AT THE POTW

If the industry is located near the POTW, consideration can

be given to carrying the industrial wastewater flow directly

to the POTW rather than discharging to the public sewer. The

flow can be carried in a small diameter pumped pressure sewer

rather than a gravity sewer. The industrial waste can be

discharged to the POTW at any point in the process and any

suitable pretreatment can be applied to it independently of

the POTW influent. This opens opportunities for treatment of

the industrial wastewater alone, without dilution by the POTW

influent flow.

TREATMENT OF TOXIC POLLUTANTS IN POTW

INTRODUCTION

A U.S.EPA literature review, summarized in Table 6. (1) shows

no significant removals in primary treatment (solids separa-

tion) except for total chromium, copper, lead, mercury, zinc

and phenols. As expected, total chromium, since it includes

the insoluble trivalent form, showed substantial removals in

the primary stage while the soluble hexavalent form showed no

removal at all. Adsorption of soluble metal compounds on

aerobic floe probably account for most of the removal in

secondary treatment. Separate data for soluble and insoluble

metal compounds would be useful. Some higher removals reported

were not incorporated into this table because they include

treatment plants not producing BOD and suspended solids
272
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TABLE
AVERAGE REMOVALS OF SOME PRIORITY POLLUTANTS
BY CONVENTIONAL MUNICIPAL TREATMENT METHODS
POLLUTANT
Selenium
Silver
Arsenic
Cadmium
Nickel
Cyanide
Chromium
(Total)
Chromium
(Hexavalent)
Copper
Lead
Mercury
Zinc
Phenols
%
PRIMARY
TREATMENT :
0
0
%
AEROBIC PROCESSES
CONFORMING TO
EPA STANDARDS FOR
SECONDARY TREATMENT
0
0
0 30
0 to 8 ' 10
6 ; 9
0 30 to 50
i
26 52
0 15 to 20
25
24
27
30
37
70
46
50
71
65
273
-------
of 30 mg/1 (EPA Secondary Treatment Standards) in the effluent.

These data are taken from POTW that have a broad range of

influent metal concentrations, temperature, pH, other pivotal

pollutants present, treatment plant design and operating

variations and other factors that have major impact on treat-

ment of heavy metals.

Not all of the heavy metals in POTW wastewaters originate in

industry. A substantial fraction is normal to purely domestic

wastewater. Data collected in 1973 at the Allegheny County

Sanitary Authority POTW (Pittsburgh, Pa.) showed that water

supply and stormwater runoff reaching the POTW contributed

80.6 percent of the cadmium in the plant influent. Industry

accounted for 15 percent. In 1974, industry accounted for

76.5 percent and in 1975, 46.6 percent (14). Such wide

variations raise the possibility that control of priority

pollutants discharged into POTW by industrial users may not

alone provide the uniformity in loading necessary for good

treatment.

About a third of the copper in New York City's wastewater was

found to be from corrosion of brass plumbing fixtures(15) and

Kaplovsky (15), comments that five separate digested sludges

from POTW without industrial wastes contained concentrations

of heavy metals in the same order of magnitude found in an

extensive series of analyses of digested sludge from the

Chicago Metropolitan Sanitary District.
274
-------
Table 1_ reflects the industrial user's part of the proolem

of toxic metal discharges into POTW. The first two columns

show the concentration of heavy metals in residential waste-

waters without industrial wastewaters. Column 4 is drawn

from a study of POTW in Michigan and reflects the wide range

of toxic metal concentrations among a random group of muni-

cipal plants. The other columns are self-explanatory.

The broad range of metal content in tne municipal wastewaters

included in this survey is not unusual, except for the 880 mg/1

maximum for nickel. The table is useful for rough approxima-

tions where mass and flow data for the industrial discharges

or the raw POTW wastewater are not available. In a study of

Los Angeles data, the percentage of industrial contributions

of heavy metals to the raw municipal wastes ranged from 84 to

88 percent for cadmium, chromium, nickel and zinc. Copper

and lead were 75 percent and total cyanide was 93 percent (17).

PHOSPHORUS REMOVAL IN PRIMARY AND SECONDARY TREATMENT STAGES

The removal of phosphorus in POTW, usually by chemical pre-

cipitation, is becoming more widespread and may well become

commonplace in the next decade. The opportunities for

incidental removal of heavy metals in this process are evident.

Currently, about a dozen states have regulations generally of

two types, either specifying 80 percent removal or a maximum

concentration in the effluent, normally 1 mg/1 as total

phosphorus.
275
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Alum (may be available as alum sludge from water treatment

plants), sodium aluminate, ferrous sulphate or chloride (may

be available as waste pickle liquor from steel treatment),

and ferric chloride are the principal chemicals used in

phosphorus removal. Polymers are frequently added to prevent

carryover of the precipitant into the finished water. The

chemicals may be added at one or more of the following sites:

at the influent to primary clarification; near the exit end

of aeration basins; at the influent to secondary clarification

in activated sludge treatment; and before and after trickling

filters. These additions to POTW have commonly used existing

plant structures, limiting capital costs to mixing and

reaction tanks, chemical storage, feed pumps, valves, feed

lines, controls and instrumentation. Plant operating costs

may increase 20 to 30 percent.

Lime is an effective phosphorus precipitant but produces

unusually high pH's, causing scaling of equipment, generates

excessive amounts of sludge (50 to 150 percent increase) and

requires auxiliary equipment. Lime may, however, be added as

pH control when iron salts are used. This can help maintain

pH levels in the POTW sludge.

Parenthetically, it should be noted that pH will be reduced

by customary alum and iron additions, about 0.5 to 1.5 points

when added to the raw wastes and about 0.5 to 1.0 point in

the aeration basins and the final effluent. Commonly, alum
277
-------
dosages range from about 40 to 100 mg/1, iron salts about

10 to 100 mg/1 as Fe (average about 20 mg/1), and polymers

0.25 to 1 mg/1.

When chemicals are added ahead of primary clarification, the

primary sludge may increase 50 to 100 percent in quantity but

some reduction in secondary sludge is experienced. This is

due to the reduction in BOD loading to secondary treatment

that results from increased removal of the suspended BOD

fraction in primary clarification. As a result, total sludge

is increased only 25 to 50 percent. Alum produces the least

sludge and lime produces the most. Insoluble hydrated iron

oxide, produced when iron salts are employed, tends to

scavenge low concentrations of toxic metals from solution (19) ,

Direct addition of polymers to primary clarifier influent will

improve the removal of insoluble toxic metals without addition

of other chemicals.

Phosphorus removal in tertiary treatment is discussed in a

later section.

REMOVAL OF TOXIC POLLUTANTS IN BIOLOGICAL TREATMENT

Adsorption Of Heavy Metals On Biological Floe

Although there is some entrainment of insoluble heavy metals

in biological floe, the primary removal mechanism is adsorp-

tion of soluble metal compounds on the floe. Because

activated sludge processes carry higher solids concentrations
278
-------
and hence more adsorption sites than trickling filters or

aerated lagoon sites, they can be expected to remove a higher

percentage of metals. Studies (20) show that uptake is

limited to the soluble heavy metal complexes, is highly pH

dependent, and that it increases with increasing pH up to the

level at which precipitation of metal hydroxide occurs. The

association of metal with the sludge was essentially complete

after only ten minutes contact time. At initial concentrations

of copper from 2.1 to 25.2 mg/1, the ten-minute uptake was 81,

and 84 percent in two hours. Similar data for lead with the

same concentrations showed 95 to 97 percent in ten minutes and

97 to 99 percent in two hours. The lowest uptake rate was for

nickel: 47 to 59 percent in ten minutes, and 53 to 65 percent

in two hours.

With enough time, a steady-state concentration of the toxic

pollutant, favorable temperature and environment, a biomass

can be acclimated to tolerate high concentrations of toxic

nonbiodegradables. In an acclimated biomass, the predominant

organisms are types resistant to the toxic pollutants. This

biomass can also withstand concentrated slugs that would

inhibit unacclimated activated sludge biomass.

Treatment of Toxic Organics
Cyanides amenable to chlorination, phenols, organophosphorus

pesticides and some chlorinated hydrocarbons (heptachlor, for

example, and, to some extent lindane) can serve as food for

aerobic metabolism. When such pollutants are fed to activated
279
-------
sludge, at a fairly constant dosage, they encourage the

growth of organisms that can utilize them in metabolic

fermentation. Proper temperature, time, environment and

reasonably steady-state concentration of the toxic pollutant

are essential for the optimum metabolism. The process is the

same as that used in acclimating a biomass to accept higher

than normal concentrations of non-biodegradable toxic pollu-

tants without inhibition.

RELATIVE CAPABILITIES OF VARIOUS ACTIVATED SLUDGE
PROCESS SYSTEMS IN TREATING TOXIC POLLUTANTS (See Figure 9.)

Conventional Activated Sludge Process

In the conventional process, the return sludge and influent

are introduced at one end of the aeration tanks and the

treated effluent is discharged from the other end. With the

oxygen-starved return sludge meeting the entire untreated

influent at the inlet end, the system cannot effectively

handle shock loads or variations in concentration of toxic

pollutants.

Complete Mix

In this system the influent wastewater is introduced in

multiple inlets throughout the tank to produce a uniform

distribution of solids and substrate (feed). In completely

mixed systems, shock loads and toxic wastes can be more

readily treated because they are immediately diluted by the

entire contents of the aeration tank.
280
-------
Contact Stabilization

This modification was developed to take advantage of the

sorptive capacity of activated sludge floe. Sorption of

colloidal and suspended biodegradable organic matter occurs

in 15 to 20 minutes. In practice, the wastewater flows

through an aerated sludge contact tank with about 20 to 40

minutes contact time, followed by clarification. The settled

return sludge, with sorbed organic matter, is then pumped to

another tank for 5 to 7 hours of aeration to stabilize the

sorbed organics and then returned to the contact tank. The

aeration tankage is reduced about 50 percent, but because of

the short sludge contact time with the liquid phase, the

system is not highly successful in treating predominately

soluble wastes. Contact stabilization is not adapted to

handling shock loads.

Step Aeration

In this design, the supply and demand of oxygen are balanced

by distributing the waste flow at several points along the

length of plug-flow aeration tanks. In Figure 9 (page 14),

for example, the oxygen-starved return sludge contacts only

one quarter of the incoming waste and thus is not shock-

loaded as in the conventional system. Step aeration has some

of the advantages of the complete mix system with a longer

detention time and better BOD removal. It can handle slugs

and is not upset by toxic wastes as readily as the conventional
281
-------
and contact stabilization systems. The quantity of influent

discharged to each point in the system can be controlled.

Internal slug flows of digester supernatant, sludge bed

drainage, vacuum filter effluent and the like can be handled

more successfully.

BOD Removals

BOD removals for conventional and step aeration are about

85 to 95 percent; for contact stabilization about 80 to 90

percent and for completely mixed systems about 80 to 95

percent depending upon the unit loading.

ANAEROBIC DIGESTION

If sludge digestion is adversely affected by toxic pollutants,

the problem may lie in poor mixing and/or heating. The graph

in Figure 13 illustrates the effect on the oxidation-

reduction potential (ORP) of a single daily feed (common in

small POTW's) in an unmixed versus a continuously well-mixed

digester. The negative side of the ORP is a measure of

anaerobic metabolism. For fair digestion, the electrode

potential should be greater than 495 millivolts. The graph

shows that a daily feed to an unmixed digester upset the

metabolism for the next 12 hours. Toxic metals can further

inhibit digestion under such conditions. With continuous

mixing, the effect of a single feeding was insignificant.

If digester upsets are a common problem at a POTW, and toxic

pollutants are at a reasonable level, the effectiveness of
282
-------
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283
-------
the mixing (if any) in the digester should be determined. To

check mixing (and heating) efficiency, sludge temperature

profiles can be run, preferably in a radial direction from

the inlet at 5 ft. increments in depth. A range of two

degrees Fahrenheit reflects good mixing and heat distribution.

Many cases of "stuck" digesters (digesters with little or no

methane evolution) have resulted from excessive concentrations

of heavy metals, particularly copper, zinc and nickel. The

presence of sulfides in digesters at 50 to 100 mg/1 is bene-

ficial in reacting with the soluble heavy metal ions to

produce insoluble metal sulfides, but sulfides in excess of

100 mg/1 may in themselves be toxic. Some POTWs maintain an

inventory of sodium sulfide to use when an upset due to heavy

metals is imminent.

Masselli, et al, report that a daily addition of sulfuric

acid to the digester at 0.1 gallon per 1000 gallons feed to

the digester will eliminate toxic metal problems. At the

first trace of hydrogen sulfide in the gas, additions are

stopped for one to six weeks. This procedure not only detox-

ifies the heavy metals but also builds up a sulfide reserve

as ferrous sulfide. The acid does not inhibit digestion

because it increases the alkalinity when it is reduced to

sulfide. The reaction is normally completed in a few hours

(21) .
284
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EMERGENCY TREATMENT OF CYANIDE SLUG

If an accidental dump or spill of cyanide occurs, the chlorine

contact chamber at the POTW can be used for emergency alkaline

chlorination, using 4-6 mg/1 sodium hydroxide and 4-6 mg/1

chlorine for each part of cyanide. The reaction pH should be

at least 10 to 10.5. The primary clarifiers may be used but

the organic sludge in the clarifiers will require higher

chemical doses (6).

TERTIARY (ADVANCED) TREATMENT AT A POTW

Tertiary treatment may be practiced to remove phosphorus,

nitrogen, color, odor, turbidity, BOD, heavy metals and

suspended matter.

For removal of phosphorus, lime may be added to the secondary

effluent in a rapid mix, followed by flocculation, settling,

recarbonation with CO.., (for pH reduction), and multi-media

pressure filtration or sand gravity filters. The lime sludge

may be concentrated and recalcined, slaked and reused. In

addition to phosphorus removal, substantial removals of heavy

metals, BOD, COD, and turbidity are experienced.

Alum may be used to replace the lime but dosages range up to

300 mg/1 for phosphorus removal at this stage of treatment.

Since settling of the alum floe will reduce the phosphorus

to 1 mg/1, the filtration step may usually be eliminated

unless it is needed to improve removals of other pollutants.

Iron salts may be used but are sometimes ruled out because
285
-------
of residual iron in the effluent.

Activated carbon may serve as the only tertiary step following

secondary treatment, for removal of dissolved BOD, COD,

residual suspended solids, turbidity (colloids), color and

organics. The spent carbon is generally regenerated in a

multiple hearth furnace.

If phosphorus removal is not required or where it is accom-

plished by chemical treatment in the primary and/or second-

ary treatment stages, the secondary effluent can be dis-

charged directly to granular or sand filters. The filtration

may be followed by activated carbon treatment. Filtration

will remove suspended solids and some BOD and COD, and carbon

treatment will remove toxic metals and some pesticides. Coag-

ulants can be added directly ahead of filtration, omitting

the clarification stage, but sufficient dosage to remove

phosphorus will reduce filter runs.

Land irrigation of secondary effluents is also classified as

a tertiary process. The comments made in the section on

sludge disposal on agricultural land apply to irrigation as

well.

Nitrogen is generally removed, in tertiary treatment, by bio-

logical nitrification followed by denitrification. The bio-

logical nitrification (oxidation of organic nitrogen and

ammonia to nitrites and nitrates) is usually incorporated into
286
-------
the secondary treatment process. Denitrification is then

accomplished by adding methanol as the electron donor to

convert the nitrites and nitrates to nitrogen gas in the

presence of denitrifying bacteria. Since nitrifying organ-

isms are highly sensitive to toxic pollutants, pretreatment

with lime may be necessary to remove soluble heavy metals.

Ozone oxidizes cyanides, chlorinated hydrocarbons, organo-

phosphorus pesticides, chloroform, benzenes, phenols, alcohols,

butanes, PCB's, and some other toxic organics.

Other tertiary processes, mentioned in the literature but not

in common use, are air stripping for ammonia removal, reverse

osmosis, flotation, ion exchange, and electrodialysis.

A number of reports in the literature attest to the capability

of tertiary systems in removing toxic pollutants. Studies at

Dallas, Texas, for example, show that 95 percent removals of

most of the heavy metals can be achieved in tertiary treatment

consisting of chemical precipitation and activated carbon

treatment.

SLUDGE DISPOSAL ON AGRICULTURAL LAND

The standards proposed by the EPA for a lifetime application of

cadmium on agricultural land (see pages 37 and 38) may produce

a request for a reverse removal allowance at some POTW where

landspreading is practiced and additional land for this pur-

pose is scarce or unavailable. To reduce the cadmium content
287
-------
of its sludge and thereby extend the life of the available
landspreading area, the POTW could request a removal allowance
for cadmium more severe than the national standards. If, in
the future, the EPA promulgates standards of the same type for
other toxic metals, the POTW may again request reverse removal
allowances, this time selecting those metals that are most
limiting in establishing the life of its landspreading area.
Table 8. lists limits for toxic metals suggested in the Process
Design Manual for Land Treatment of Municipal Wastewater (EPA
625/1-77-008) .

TABLE 8

SUGGESTED MAXIMUM APPLICATIONS OF TOXIC METALS ON SOIL
LBS./ACRE

Cadmium 8
Chromium 82
Copper 164
Lead 4,080
Nickel 164
Zinc 1,640
Values were developed for sensitive crops on
soils with low capacities to retain elements
in available forms.

Noting that the suggested maximum lifetime application of cad-
mium in the table (8 Ibs/acre, or 9 kg/ha) compares favorably
with the EPA proposed standards of 5 to 15 kg/ha for a range
of CEC's in soil, it is not unreasonable to expect that any
future standards for other toxic metals could fall somewhere
near the maxima listed in the table. Then this table may
288
-------
prove useful in determining whether, and to what extent, ex-

pansion should be designed into pretreatment facilities cur-

rently contemplated.

With further reference to the cadmium standards, the proposed

regulation states that cadmium-bearing sludges should be

applied on agricultural land so as to maintain a soil pH of

6.5 or more. Lime treatment of the sludge and/or soil may

be necessary to produce this pH level.

SUMMARY

Opportunities for the removal of toxic pollutants in POTW

may be summarized as follows :

1. Settling of particulate insoluble heavy metals, such as

metal hydroxides in primary clarification, with or without

coagulant aids. Phosphorus removal by the addition of

iron salts, alum or lime, often with polymer addition,

ahead of primary clarification, will incidentally precipi-

tate heavy metals.

2. Adsorption of soluble heavy metals on biological floe and

entrainment of insoluble heavy metals in the floe.

Chemical treatment for phosphorus removal in the aeration

stage will remove heavy metals in the secondary clarifiers.

3. Metabolism of some toxic organic pollutants by acclimated

activated sludge floe. Included in this group are phenols,

cyanide, organophosphorus pesticides, and some chlorinated

hydrocarbons. In the latter group, heptachlor, for example,
289
-------
will degrade more than 90 percent in aerobic metabolism,

while lindane degrades only 30 percent.

4. Incidental removal in secondary clarification. The toxic

metals adsorbed on and entrained in the activated sludge

floe are removed with the floe. Chemical treatment for

phosphorus removal ahead of secondary treatment will

incidentally remove heavy metals as in item 1 above.

5. The following tertiary treatment processes provide

incidental removal of toxic pollutants:

a. Chemical treatment (alum, lime, and iron salts, with

or without polymers).

b. Activated carbon adsorption

c. Granular multimedia filtration

d. Rapid sand filtration

e. Ozonation

f. Dissolved air flotation

g. Stabilization ponds and aerated lagoons

h. Irrigation

Comment: In view of the present state of the art, any design

modifications to treat noncompatible pollutants in

POTW should only be attempted after a study of the

literature and sufficient experimental work on a

laboratory or pilot scale followed by plant-scale

trials if possible.
290
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IN-PLANT WASTES CONTROL: THE ECONOMIC APPROACH TO COMPLIANCE

RECYCLE AND REUSE SYSTEMS

The recovery and reuse of products and process ingredients

has been practiced as an economy in processing for many years.

The pulp and paper industry recycles machine waters through

flotation tanks (save-alls), textile plants recycle scour

water, electroplaters use reclaim rinses. Now, when increasing

costs of waste treatment are added to the debit side, proces-

sing systems should be re-examined for new opportunities in

economizing.

We can no longer afford the luxury of wasting water to the

sewer after a single use, without a thorough search for a

second use. The water used for any purpose should be the

lowest quality available that meets the requirements. Often

a slight improvement in quality, such as screening, can con-

vert a wastewater to a useful water. As an example, screened

wastewater, at an acceptable temperature, may be used in

condensers.

In developing recycle systems, efforts should be directed

towards reducing waste in the process to produce the smallest

possible volume for treatment in the system. Much of the

benefit of recycling comes from return of a process ingredient,

such as acid, detergent and heat, and dilution reduces its

value. Much of the cost of wastewater treatment is related to
291
-------
flow. In both instances, dilution before treatment costs

money.

IN-PLANT WATER CONSERVATION: SOME EXAMPLES

A few suggestions for water conservation may serve to demon-

strate the broad rar.ge of opportunity in this facet on in-

plant wastes control:

• Eliminate hose connections on recycle systems.

• Check tanks for possibilities for accidental overflow

and spills.

• Before washing a tank that contained a pollutant, rinse

it with a fine spray from a quarter-inch hose and

discharge the rinsings to the stock tank.

• Where frequent cleaning is practiced, tanks should be

cleaned automatically, using in-place detergent spray

systems and timed rinse and wash cycles. This not only

reduces the cost of detergents but also reduces water

consumption and saves manpower.

• Provide thermostatic controls on water cooling systems.

• Provide self-closing valves on hoses and other outlets

where water is manually controlled.

Case histories abound where plants have saved half or more of

their water (and wastewateri) by well-planned in-plant water

conservation. Although these savings are not always avail-

able, their possibilities should be investigated.
292
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Case History No. 1; At this plant, water consumption dropped

30 percent merely by reducing the plant water pressure from

70 to 40 Ibs. Savings in plumbing maintenance were a free

bonus.

Case History No. 2; Wastes from the buffing, plating, rolling

and painting operations in a plant manufacturing automotive

wheel covers were reduced from a range of 700 to 1400 gpm to

a steady 600 gpm by water conservation, waste segregation,

recycling and counterflow rinsing.

Case History No. 3: In this case, a water conservation pro-

gram went too far. Water use was reduced dramatically, prin-

cipally cold water, causing the wastewater temperature to

rise. However, the wastewater was being used in condensers

in a rendering operation and the higher temperature forced

the plant engineer to turn to fresh city water for condensing,

thereby virtually nullifying the conservation efforts. The

ultimate least-cost solution was a cooling tower for the

condenser water.

Case History No. 4: A small town launched a charge of 50 per-

cent of the water bill to help pay for an addition to their

treatment plant. This prompted the town's major industries

to institute waste conservation measures which reduced the

town's water consumption by 20 percent. The addition was

redesigned to take advantage of the flow reduction and the

entire community reaped the benefits.
293
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CONTROLLED DISCHARGE

In discharging to a POTW, an industrial user should do his

utmost to equalize the wastewater, both in volume and

character. Figure 14 shows the daily fluctuations of flow

and BOD in a typical POTW. It is evident that, for both

flow and BOD, an industry may discharge its wastewater during

off-hours with less impact on the POTW than discharging dur-

ing daytime processing periods.

Equalizing tanks are most commonly used to equalize the flow

or pollutant load over a 24-hour day. An equalizing system

consists of a tank, pump, and controls for either equalizing

the effluent concentration of a pollutant or equalizing the

flow. If the pollutant is not automatically measurable, a

variable such as pH, conductivity and turbidity, can be

measured automatically to provide reasonable control.

INDUSTRIAL PROCESS ALTERATIONS

Many ingenious substitutions have been made in processing to

eliminate a pollutant, or to substitute a more "treatable"

pollutant for a "difficult" one. There are several good

examples in the textile industry: substitution of biodegrad-

able dyes for nonbiodegradable ones; substitution of ammonium

sulfate or chloride for acetic acid in stock dyeing in wool

processing (in one test the acetic acid contributed 22 percent

of the plant BOD, versus 0 percent for ammonium sulfate or

chloride); replacing open dyeing vats with pressure vats to
294
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1-10
12
10
Q
Q.
O
ec
I
FLOW RATE
-i 300
BOD5 CONCENTRATION
- 9
- 8
- 7
- 6
- 5
- 4
z
Q
(O
5
h 3 Q
O
ca
- 2
- 1
«- 0
12
MIDNIGHT
12
NOON

TIME OF DAY
12
MIDNIGHT
FIGURE 14

TYPICAL DRY WEATHER FLOW AND BOD VARIATION
OF MUNICIPAL WASTEWATER
295
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reduce the amount of dye carriers with resulting reduction in

BOD and heavy metals concentration. In the leather industry,

conversion to amines to replace lime and sulfides (major

pollutants) is an interesting development.

Substitution of a dry process for a wet one is not impossible.

A major process improvement in fruit canning grew out of a

search for waste conservation ideas. Caustic dry peeling has

now been developed, and water usage in this operation, formerly

the largest source of waste in the industry, has dropped from

850 gallons per ton of product to 90 gallons, and eliminated

7 Ibs. of BOD per ton of product.

BLENDING

Blending wastes is another practice that produces economies

in many industries. Recently the acid coal leachate at the

Cornell University power plant was blended with their alkaline

boiler blowdown and discharged to the city sewers, correcting

a highly publicized stream pollution problem. In mining and

producing copper, the alkaline tailing waste can be blended

with the acidic leaching waste in mixing lagoons to produce

a neutral pH, converting the ferrous hydroxide to insoluble

ferric hydroxide which is settled out.

BY-PRODUCT RECOVERY

By-products have been the means for economic survival in a

number of industries. For example, the major meat packers
296
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would not have developed without the advantage of size, to

accumulate "waste products" in sufficiently large quantities

to warrant processing them. While the small packer let blood

go down the sewer, the large packer could recover and dry it.

He could collect stripped protein from animal casings and dry

it for use as an ingredient in cattle feed. He could concen-

trate the liquid from wet rendering and use it as a valuable

feed supplement.

Several years ago a whiskey distiller achieved a major break-

through in waste utilization by producing cattle feed from

spent grains. This is now a major source of income in the

distilling industry.

Sometimes a waste in one industry is a process item in another.

A good example is steel pickling waste used as a flocculating

agent in water and wastewater treatment. Wastewaters can be

pretreated or concentrated for use in another industry. With

the increasing costs of wastewater treatment, possibilities

for by-product recovery need to be re-examined.

IN-PLANT SAFEGUARDS

In-plant safeguards to prevent loss of product ingredients and

water may also help prevent a disaster at the POTW. Here are

a few methods of preventing spills and "disastrous" discharges

from showing up at the POTW:

• Provide emergency storage for spilled product or process
297
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liquids, and for holding liquids during emergency repairs

of tanks, piping and appurtenances.

• Provide holding curbs for emergency containment of the

liquid contents of process tanks in which the level of

liquid is above the storm sewer or floor drains.

• Provide alarms for excessive temperature, turbidity,

conductivity, pH, etc.

DEVELOPING A GOOD WORKING RELATIONSHIP WITH THE MUNICIPALITY

PERSONNEL RELATIONSHIPS

Background

Where industry people are being selected for part-time or

full-time responsibility for wastes control management, a

knowledge of the background of the counterpart person in the

POTW is desirable. The relationship between the industry and

the POTW is, like any other business relationship, founded on

the favorable relationships between people.

Upgrading Personnel

Many industries have training seminars in waste control

management, sampling, analyses, etc., either set up by and for

the waste control personnel at a single plant, or for all the

waste control personnel of a multi-plant company. Some

seminars are operated by trade associations, or, in some cases

by an educational agency. Such industry-oriented training

programs are highly recommended. Whenever possible, the POTW
298
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personnel should be invited to participate.

The industry management should encourage the waste control

manager to become a member of the local water pollution

control association, which includes membership in the Water

Pollution Control Federation. He should attend the sectional

and state meetings. Some state universities conduct annual

industrial wastes conferences that provide good technical

information. Attendance at such technical conferences also

provides exposure to people from municipalities and state and

federal agencies, as well as representatives of other

industries with similar interests and problems.

Consultants

Some consultants specialize in industrial wastes engineering

and a few of these lean towards operation, If such a consult-

ant is close at hand, an industry can use his expertise in

several areas, such as problem solving, future planning,

training, and in developing a request for a fundamentally

different factors variance. The consultant should be accepted

as a qualified expert by the POTW management, to avoid any

possibility of developing an adversary situation.

SPLITTING SAMPLES

Samples collected by either the industry or the POTW, that

relate to maintaining and operating the POTW with an admix-

ture of the industry's wastes, should be split with the other
299
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party. If each party participates in the other's surveys and

shares the samples, they can both be convinced of the reliabil-

ity of the results.

JOINT RESEARCH

Many papers on industrial wastewater technology presented at

technical conferences are joint papers by technologists from

industry and POTW. Joint interest in getting answers,

collecting and evaluating data and producing new ways to solve

old problems produces a durable mutual trust that is a valu-

able asset for both the industrial user and the POTW authority,

Opportunities to enlist a nearby university in executing some

of the research should not be overlooked.

DEVELOPMENT OF POLLUTANT DISASTER PLANS

Holding Lagoons

Preplanning for disaster is a neglected area in industrial

wastewater management. Many of the spills reported in the

news media might have been prevented by good planning.

Sometimes holding tanks or lagoons are provided but are

temporarily used for other purposes and the "temporary"

becomes permanent. An emergency holding lagoon should be

entered on the company property records for what it is and

should be maintained for its intended purpose. The POTW

management should be made aware of this effort.
300
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Chemical Inventories At The PQTW And The Industry

The POTW may store sodium sulfide to be used if heavy metals

cause upsets in digestion (see page 74). The industry should

keep an adequate supply of chemicals such as acid and alkaline

neutralizers for cleaning up after spills. Both the industry

and the POTW management should know what chemicals the other

maintains in stock.

Recovery From A Spill

The attitude displayed by the industry management in dealing

with a spill can establish a cooperative atmosphere or lack of

it. When a spill occurs, it may mean a substantial financial

loss of material to the industry but if it enters the public

sewer it may upset the municipal plant for weeks. If the

effluent is degraded, the receiving stream may be polluted.

This can be bad publicity for both the city and the industry.

A solid mutual understanding exists when the POTW superin-

tendent reports an industry-oriented problem to the industry's

waste control manager before he tells the mayor. The final

test is what the wastes control manager does about it. If he

takes a business-like approach - supplying know-how and calm

leadership - he may be able to keep an emergency situation

from becoming an outright disaster. If the industry has taken

steps previously recommended (pages 82, 87, 88) there may

spills, but they will be retained for salvaging and will not

reach the environment.
301
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REFERENCES
1. "Federal Guidelines: State and Local Pretreatment
Programs," (Vol. II of three), Construction Grants
Program Information, EPA - 430/9-76-017a, Jan. 1977.

2. Ryder, R. A., "Chromium Tannery Wastewater Effects
on Algae Oxidation Pond and Physical-Chemical Treat-
ment Processes," 33rd annual Purdue Industrial Waste
Conference, May 11, 1978, to be published in
Proceedings.

3. "Federal Guidelines: State and Local Pretreatment
Programs," (Vol. I of three), Construction Grants
Program Information, EPA - 430/9-76-017a, Jan. 1977.

4. Neufeld, R. O., "Heavy Metal-Induced Deflocculation
of Activated Sludge," Journal Water Pollution Control
Federation 48, 8, 1940, Aug. 1976.

5. Reed, S. C., "Wastewater Management by Disposal on
Land," Special Report 171, Cold Regions Research and
Engineering Laboratory, U. S. Corps of Engineers,
Hanover, N. H. (May 1972).

6. Masselli, J. W., Masselli, N. W. and Burford, M. G.,
"Controlling the Effects of Industrial Wastes on
Sewage Treatment," New England Interstate Water
Pollution Control Commission, Boston, Mass. (1970).

7. Sommers, L. E. and Curtis, E. H., "Wet-Air Oxidation:
Effect on Sludge Composition," Jour., Water Poll.
Control Fed. 4_9, 11, Nov. 1977.

8. Kirkham, M. B., "Disposal of Sludge on Land: Effect
on Soils, Plants and Ground Water." Compost Science,
March-April, 1974.

9. Solotto, B. V., Grossman, E., and Farrell, J. B.,
"Elemental Analyses of Wastewater Sludge from 33
Wastewater Treatment Plants in the U. S.," presented
at Research Symposium on Pretreatment and Ultimate
Disposal of Wastewater Solids sponsored by U. S. EPA-
Technology Transfer Newsletter, January, 1977.

10. Chaney, R. L., "Crop and Food Chain Effects of Toxic
Elements in Sludges and Effluents," in Proceedings of
the Joint Conference on Recycling Municipal Sludges
and Effluents on Land, July 1973, National Assoc. of
State Univs. and Land-grant Colleges, Wash. D. C.
302
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11. Walker, J. M., "Sewage Sludges - Management Aspects for
Land Application." Compost Science, March-April, 1975.

12. "Process Design Manual for Land Treatment of Municipal
Wastewater," Oct. 1977. U. S. EPA, USDA (EPA 625/1-77-008)

13. Dietz, J. C., and Dietz, J. D,, "A Rationale for
Pretreatment Standards for Industrial Discharges to
Publicly Owned Treatment Works," presented at 33rd
annual Purdue Industrial Waste Conference, May 10, 1978,
to be published in Proceedings.

14. Stern, L., "The Great Cadmium Controversy," Sludge Mag-
azine, Silver Spring, Md. 20910 (March, April 1978).

15. Dean, R. B., and Smith Jr., J. E., "The Properties of
Sludges" (discussion) "Recycling Municipal Sludges and
Effluents on Land," Proceedings of Conference, July 9-13,
1973, Library of Congress Cat. No. 73-88570, Nat. Assoc.
of State Universities and Land-grant Colleges, Wash. D. C.
20036.

16. Klein, L. A., Lang, M., Nash, N., and Kirschner, S. L.,
"Sources of Metals in New York City Wastewater," Jour.
Water Poll. Control Fed., 46, 12, pp. 2653-2662,
Dec. 1974.

17. Eason, J. E., Kremer, J. G. Dryden, F. D., "Industrial
Waste Control in Los Angeles County." Jour. Water
Poll. Control Fed., 5j), 4, pp. 672-677, April, 1978.

18. Cohen, J. M., "Trace Metal Removal by Wastewater Treat-
ment." U.S.EPA Technology Transfer Newsletter, Jan. 1977.

19. Jenne, E. N., "Controls on Mn, Fe, Co, Mi, Cu, and Zn
Concentrations in Soils and Water, ' in "Trace Inorganics
in Water," Advan. Chem. Series 73, American Chemical
Society, Wash. D. C. (1968) .

20. Cheng, M. H., Patterson, J. W., and Minear, R. A.,
"Heavy Metals Uptake by Activated Sludge," Jor., Water
Poll. Control Fed., 4T_, 2, Feb. 1975.

21. Masselli, J. W., Masselli, N. W., and Burford, M. G. ,
"Sulfide Saturation for Better Digester Performance,"
Jour., Water Poll. Control Federation, 39, 1369 (1967).
-------
ADDRESSING TH£ 65 PRIORITY
POLLUTANTS
PRETREATMENT OF INDUSTRIAL WASTES
JOINT MUNICIPAL/INDUSTRIAL SEMINAR
PREPARED FOR THE
ENVIRONMENTAL PROTECTION AGENCY
TECHNOLOGY TRANSFER
by
DR. L. E. LANCY, HON. PRESIDENT
and
MR. F. A. STEWARD, P. E.,
VICE PRESIDENT, ENGINEERING
LANCY
DIVISION OF DART ENVIRONMENT
AND SERVICES COMPANY
ZELIENOPLE, PENNSYLVANIA, 16063
304
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TABLff OF CONTENTS

Waste Water Discharge Survey
309
Introduction 309

I. The Need for a Survey and Monitoring Program. 310
A. The Role of the POTW 310
B. Effluent Survey 312
C. Survey of the Processing System and
Material Balance
D. Use of the Survey in Planning 313
E. Survey of the Sewer System 313
F. External Plant Area Survey 314
G. Flow Measurements 314
H. Effluent Sampling 316
I. Sampling and Accounting for Batch
Dump Discharges 317
J. Sampling Non-Homogenous Effluents .... 3^7
K. Sample Preservation 318
L. Analyze the Survey Data 319
M. Development of the Pretreatment
Program on the Basis of the
Survey Results 320
N. Self-Monitoring Requirements 321

Industry's or the Industrial Community's Role in
Assisting the POTW in Requesting a Variance from
the National Standards „ 323

I. Industry Variance for Fundamental Difference. . . 323

II. Variance in View of the POTW's Demonstrable
and Dependable Removal Capabilities 324

A. Incidental Removal of Incompatible Pollu-
tants in POTWs with Physical-Chemical
Treatment Capabilities 324

p. Incidental Removal of Incompatible Pollu-
tants in Secondary Treatment 325

C. Removal of Incompatible Pollutants
Present in Low Concentrations 325

III. Other Considerations to be Met Before a
Variance Can be Anticipated - .... 326

IV. Industry's Role in Giving Assistance to the
POTW to Secure a Variance 530
305
-------
Table of Contents, continued

V. Demonstration Showing Reliable and Consistent
Removal of a Specific Pollutant by the Use
of Specific Data as Evidence 332

VI. Examples of Priority Toxics and Their
Demonstrable Removal by the POTWs 334

A. Biological Removal of Cyanide Compounds . . . 334
B. Biological Removal of Phenolic Compounds. . . 335
C. Removal Capabilities for Heavy Metals .... 337
D. Removal Capabilities for Iron Cyanides. . . . 339

Sludge Disposal Management

I. Introduction 342

A. What is Sludge? 342
B. Other Solid Waste that May Not Become Sludge. 344

II. Planning the Sludge Handling and Disposal Program 347

A. Sanitary Landfill 348
B. Incineration 352
C. Ocean Disposal 354
D. Secure Landfill 354

III. Formulate Pretreatment Plans Aiming for
Reduced Cost Sludge Disposal 355

A. Process Change or Plant Modernization .... 355

B. Economical Sludge Handling and Water
Conservation 357

IV. Sludge Handling 364

A. Consistency of the Sludge 364
B. Requirements for a Manifest 365
C. Leach Test 366

V. Ultimate Disposal Opportunities for
Industrial Sludges and Solid Wastes 368

A. Sanitary Landfill 368
B. Incineration 370
C. Fixation and Encapsulation. 37!
D. Segregated Landfill 372
306
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Table of Contents, continued
VI. Technical Aspects of the Segregated Landfill
pesign 373

A. Sludge Drying Beds V74
B. Description of Design Features
C. Multi-cell Landfill Design for Large 3
Repositories 375

VII. How to Reduce the Cost of Sludge Disposal .... 376

A. Factors Dependent on the Industry
Generating the Sludge 377

B. Factors Created by the Local Environment. . . 377
307
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ADDRESSING THE 65 PRIORITY POLLUTANTS

Leslie E, Lancy, Hon. President, and
F. A. Steward, Vice President, Engineering
Lancy Laboratojies, Div. of Dart Industries
iielienople, Pa.
GENERAL INTRODUCTION

All manufacturing plants discharge some waste materials. These

wastes may be in the form of waste water effluents, sludges

generated in effluent treatment, or other solid wastes in the

form of discarded materials, industrial refuse, and atmospheric

emissions. This study is centered mainly on those industries for

which, according to Section 307(b) and (c) of the Act, EPA has

issued or plans to issue technology-based, national pretreatment

standards. These standards will be based on criteria used to

define BAT technology and will consider the 21 industrial cate-

gories and the 65 priority toxic pollutants as stipulated in

EPA's Consent Decree. The study is concerned with effluents

discharged to the local sewage treatment plant {POTW), industry's

role in assisting the POTW to request a variance from the numeri-

cal limitation stipulated in the national standards, and the

sludges derived from effluent treatment.
308
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WASTEWATER DISCHARGE SURVEY - PURPOSE AND DEFINITIONS

INTRODUCTION
In a survey of the effluent-producing operations, the potential
objectionable content, and average flow rate is obviously the
first step in the assessment of the problem. It is in the
industrial firms' interest to go beyond the normal flow rate
measurement; i.e., periodic sampling, the preparation of a compos-
ite sample, and reporting the analytically established content.
A sampling program as described is needed by the regulatory
agencies, but it doesn't reveal the unusual waste-producing
activities such as periodic dumping of processing solutions,
wastage of faulty product, accidental spills, periodic drainage
of oil in view of maintenance needs of machinery, etc. Without a
true and factual survey, the firm and its engineers are equally
misguided as well as the survey staff of the POTW. In later
years it may appear as if the firm deliberately would have with-
held important details of their operation from the regulatory
agency. When an industrial firm is able to demonstrate convin-
cingly that the best effort was invested from the very beginning
to satisfy all the regulatory and practical requirements, it may
expect cooperation and leniency if per chance the need would
arise due to some truly unforeseen accident or an employee's
mistake.

EPA's Technology Transfer arm has prepared a most thorough and
detailed "Handbook for Monitoring Industrial Wastewater."1 We
would like to reference this manual here instead of repeating
many of the salient details regarding:
309
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a. The manner in whicij a survey should be conducted;

b. The equipment available for flow measuring and the
installation modes of these devices;

c. How to conduct a sampling program, parameters to be
measured;

d. A general description of some of the pertinent analytical
techniques available; and

e. Monitoring the effluent as a day-to-day effort to
maintain quality control over the treatment program.

We plan to concentrate our efforts to highlight some of the

peculiarities related to planning, instituting and operating a

pretreatment system. The problem will be even more complex in an

old plant with all the limitations that this factor itself creates,

A second and, in our opinion, most important aim of this lecture

is to convey a philosophy of the needed understanding of the

common aims and close cooperation with the POTW staff to develop

the desirable trust in the industrial discharger, confidence in

the integrity of their self-regulating effort, and that they

will assist the POTW and will meet the self-reporting requirements,

I. THE NEED FOR A SURVEY AND MONITORING PROGRAM

A. THE ROLE OF THE POTW

As we have learned from the previous lecture, the local POTW

accepting the waste effluent from the industrial facility is

itself regulated regarding the discharge of the treated waste

effluent by an NPDES permit and the disposal of the sanitary

solids generated considering the restraints of RCRA. The POTW is

also charged by EPA with the implementation of the pretreatment
310
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requirements of the Clean Water Act (CWA) to investigate and be

aware of the nature and volume of the industrial discharges,

require an application for a discharge permit, and to supervise

as the first forum the plant's performance. The implementation

of CWA, the regulatory hierarchy established, the respective

responsibilities of the POTW management, NPDES States and EPA

have been discussed in a previous lecture. It will be apparent

from the foregoing that a survey and monitoring program estab-

lished by the plant management will be a keystone in their

response to the responsibilities established for the implementa-

tion of the CWA. It will provide primarily the following functions

a. It will assure the responsible regulatory agencies that
the plant intends to comply with the stipulated effluent
requirements and the implementation schedule as set forth by
EPA.

b. It will assist in developing the necessary data for the
design of suitable pretreatment facilities and serves as the
basis for an application for a discharge permit.

c. In the event that pretreatment facilities have been
installed and are in operation, it will provide the necessary
assurance that the treatment facility is capable of meeting
the requirements as stipulated in an issued permit or
application for a discharge permit.

d. Continued monitoring of effluent conditions will be
necessary for industry's self-regulating role and to meet
the established reporting requirements.

The flow-measuring and sampling points inside the plant, as well

as the sampling locations located ahead of the outfall (or out-

falls) connection to the municipal sewer collection system, should

serve plant personnel, employees of the POTW, the states' and

EPA's sampling and enforcement staff.
311
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B. EFFLUENT SURVEY

A sampling program and effluent monitoring effort to develop the

needed information is a routine function for most engineering

companies. We would recommend that all those firms that do not

have the trained staff available or whose employees do not have

the necessary time, retain outside services to accumulate the

needed information.

C. SURVEY OF THE PROCESSING SYSTEM AND MATERIAL BALANCE

A conscientious survey goes far beyond a sampling program. As we

have alluded to in the Introduction section of this study, we

urge plant management to uncover to the last detail the plant's

pertinent practices. Purchase records for expendable supplies

and dumping practices noted should help to prepare a material

balance. Maintenance practices and past accidental discharges

will reveal internal conditions that should be rectified and

brought to the attention of the engineers planning pretreatment

facilities or their improvements. An application for a discharge

permit should describe plant operations in detail, as well as the

collection and proposed treatment facilities, detailing the

functions of the proposed equipment in the treatment system. It

is desirable that the industry or their consulting engineers

acquaint the POTW regulatory staff with their practices of batch

waste discharges, type of waste, volume and frequency; also the

proposed treatment method considered in the plans; the potential

accidental discharges that have come to their attention and the

steps that will be taken so that the impact on the POTW of such
312
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an occurrence will be eliminated or minimized.

D. USE OF THE SURVEY IN PLANNING

A survey that can become of material aid for management to appre-

ciate their waste-producing processes, be aware of the volume and

value of these wasted materials, and be able to convey this per-

tinent information to their engineers planning the pretreatment

facilities, should:

a. Detail the flow volume and waste generated in each
processing system by identifying pH, temperature, and
pertinent contaminant concentrations;

b. The time these processes are in operation, whether
continuous or intermittent;

c. Which operations have batch-type discharges, the average
composition of these batch wastes, and the frequency and
volume of the discharge;

d. The type of chemicals or supplies used in each process
to ascertain whether any of the "toxics" are being used or
could be generated during the operation of the process.

E. SURVEY OF THE SEWER SYSTEM

The survey should include a sewer map for the entire plant. It

is imperative for planning, monitoring, or control to know:

a. which processing line enters the sewer system at what
point.

b. The size sewer line that is installed and if it is able
to carry the load without flooding. Are there any impedi-
ments to flow?

c. Where does the sanitary effluent join the industrial
waste?

d. Will it be possible to monitor the industrial waste
stream without it being contaminated by the sanitary drains?

e. Are the roof drains, area drains, cooling water waste
segregated from the industrial waste stream?
313
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f. Are any sampling, monitoring, or flow-measuring loca-
tions available? If such are not available, the pretreat-
ment plans and application for discharge permit should
reflect on the proposed sampling site and proposed flow
measuring device. The sampling location has to be so chosen
that, if possible, the POTW staff may conduct sampling
without entering the plant,"but the chosen manhole has to be
ahead of the roof, area drain, and cooling water discharge
connections.

F. EXTERNAL PLANT AREA SURVEY

The survey should also consider any contamination that may enter

the storm sewer or combined sewer from the plant area. We recom-

mend special attention to:

a. Oily waste discharges from oil, paint thinners, and
other solvent storage areas;

b. Oil discharge from manufacturing scrap, swarf, dumped
oil in the yard;

c. "Toxics" from the shipping and receiving dock area
(split bags, discarded containers). Empty drums that have
contained toxic materials should be rinsed and the rinse
water treated before the container is discarded.

d. Half-finished material storage, spoiled products, etc.,
if they can leach "toxics";

e. Waste material storage lagoons, processing solution
storage tank, etc.

f. Storage tanks for holding concentrated chemical solu-
tions purchased in bulk should be diked or curbed to provide
retention provisions, in case the tank overflows during
filling or develops a leak;

g. Storage tanks for haul-away of wastes should be treated
in a similar manner.

G. FLOW MEASUREMENTS

Measuring the flow rate of the effluent is a most important

aspect of the survey and monitoring requirements. The various

devices that could be useful are well described in the EPA manual

to which we have earlier referred.
314
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If there is only one pretreatment facility and all the industrial

waste discharge from the plant goes through this system, the

problem of installing flow measuring and recording devices is

simplified. A final effluent sampling and flow measuring well

can be installed to receive the treated discharge to serve this

purpose. In plants having highly acidic or alkaline wastes, a

final pH monitor in the collected final effluent stream can also

be of great value as well as other monitoring devices for im-

portant parameters pertinent for the plant stream.

Flow measuring and recording devices in the form of water meters

installed into the main header ahead of the processing facility

can provide internal control regarding water consumption in the

particular department.

Water meters are most useful in water lines serving processing

where the consumed water is not discharged to the POTW sewer

system. As an example, where the water is used up as part of t'he

product and shipped out of the plant; water used for equipment

cooling, air conditioning purposes; and other "non-contact"

cooling water uses. This waste water can be discharged into the

storm water collection system; the facility can receive a credit

for these water uses, and can materially reduce sewer rental

charges. Also, this water use would not be considered in the

"Industrial Cost Recovery" (ICR) calculations.
315
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Water meters and recorders on pumped input, not part of the city

water system (wells, river water, etc.), should be subject to the

self-reporting requirements. This water consumption would not

appear on the meter readings officially supplied to the POTW

staff, but since the effluent is discharged into the sewer

system, sewer rental charges and ICR are applicable.

H. EFFLUENT SAMPLING

The sample should be representative of the effluent stream from

which it is taken. In some plants, as an example, with inter-

mittent flows, it is extremely difficult to gain a sample that

one may call "representative" of the average flow conditions.

There are some approaches that compensate for these fluctuations

and will allow a built-in correction factor to approximate the

desired sampling conditions.

a. A holding facility for flow equalization with agitation
means, to dampen undue fluctuations in flow volume and
concentration.

b. For minor fluctuations in flow volume, a flow- propor-
tioning valve could smooth out peaks and valleys in the flow
rate, if installed in the discharge line from the equaliza-
tion tank.

c. In those cases where the volume of flow is constant and
only concentration fluctuations occur, a composite sample
prepared from a random interval collection of samples may be
useful. The greater the variability of the concentration,
the more samples should be collected to make up the composite,

d. When the concentration is assumed to be reasonably
uniform, but the variation is mainly in the flow rate and
where a flow measuring device is available, potentially the
flow-measuring instrument can be used to operate a flow-
proportionate sampling device.
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I. SAMPLING AND ACCOUNTING FOR BATCH DUMP DISCHARGES

Batch dumps create a different type of sampling problem because

their discharge usually occurs after working hours or on the

week-end. For concentrated wastes, it also has to be recognized

and accepted that slug discharges of concentrates (dependent on

volume and concentration), even when the contents are compatible

and treatable, will not be permitted. For the purposes of the

survey, it can be assumed that batch dumps will be discharged

slowly on a proportional basis with the daily effluent either

after treatment, or untreated if the concentrates require only

dilution by the effluent stream. It is therefore possible to

sample the concentrate and record the volume of the batch.

Knowing the concentration of the constituents and volume of the

batch waste, and assuming a proposed flow rate of the discharge,

calculation can be used to establish the effect the batch dump

will have on the effluent concentrations measured.

J. SAMPLING NON-HOMOGENOUS EFFLUENTS

We refer again to the EPA Monitoring Handbook and only want to

expand here on the relative section. With non-homogenous waste,

taking a representative sample is more involved. We consider

that a wastewater is non-homogenous when all of its constituents

are not in true solution. Variations in concentration can be

therefore experienced if the sample is taken from the top,

bottom, or main body of the waste. Mainly particulates and

imiscible liquids in the waste will cause these conditions
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(precipitated solids, oil, etc.). Non-homogenous streams should

be well stirred when the sample is collected, to insure that a

representative quantity of the non-aqueous phase and solids were

sampled in their true proportions with the water.

K. SAMPLE PRESERVATION

The sample taken in sampling is the basic raw material for a

subsequent laboratory investigation. The parameters of interest

will depend on the processes used in the plant from which the

waste water effluent is derived and the raw materials used in

manufacturing. The toxics suspected to be present will depend

on the type of operation we have sampled and the processes

utilized. The concentration of some of these materials (param-

eters) in the sample container may change, unless certain steps

are taken immediately after the sample has been collected, to

stabilize the existing concentration at the time of sampling

until the analytical work can be performed.

Depending on the type and number of parameters of interest, more

than one sample must be collected to provide the required number

of individual samples, specifically stabilized for the particular

parameters. Specific bottles of teflon or borosilicate glass

could be required. Some samples require storage in the dark,

refrigeration, etc., for reliable analysis of a particular param-

eter. To illustrate our comments, we cite a few examples:
318
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a. An analysis for soluble heavy metals requires filtration
and stabilization of the filtrate at less than pH 2 with
nitric acid, polyethylene bottle is suitable;

b. Total metals require only acidification; otherwise as
in (a);

c. For cyanide analysis sulfides or oxidizing agents
should be immediately removed and the sample stabilized at
pH 12 with sodium hydroxide; a dark polyethylene bottle is
suitable;

d. A test for phenol requires acidification of the sample
and storing in a refrigerator;

e. When pesticides are suspected, the sample bottle should
be borosilicate glass, the sample acidified, filled full,
and stored in the refrigerator, etc.

The sample preservation steps are prescribed in the various

analytical manuals in general use (ASTM, Standard Methods, EPA).

Close collaboration during the sampling program with the labora-

tory conducting the tests and the engineer deciding the selected

parameters for the analytical program is essential.
It is recommended that a few times a year a split sample be sub-

mitted to an outside laboratory or consultant as a quality control

measure. Also, it is desirable that when the local authority

is sampling the waste stream, a split sample be retained for in-

house analysis or analysis by an outside laboratory.

L. ANALYZE THE SURVEY DATA

The raw data developed during the survey should be analyzed to

reveal the problem areas in waste water flow (cost), toxic con-

tent (pretreatment), solids in the discharge (surcharge, lost
319
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materials, sludge handling costs), etc. A material balance

between purchased chemicals and raw material losses vs. the

result of the survey should be attempted to reveal internal

discrepancies, if any, between the dumping frequency and losses

reported by the operating staff and the consumption evidence

from inventory records. A consensus has to be created that the

survey results are factual and have been reasonably corrected for

unusual dumpings, yearly maintenance, and other systematic dis-

cards and accidents. It is most important that the plans

formulated by management and their consultants are based on as

complete an assembly of pertinent facts as can be provided.

M. DEVELOPMENT OF THE PRETREATMENT PROGRAM ON THE BASIS OF THE
SURVEY RESULTS

The greatest value of a thorough survey is that it will reveal

many facts that often have never been systematically uncovered

and laid before management. Using a block diagram, taken from

the EPA Monitoring Manual and refined for our purposes, we have

attempted to illustrate a possible step-by-step decision-making

program. Planning a program of this nature requires time, a

thorough analysis of all the options, comparing the anticipated

cost factors to a budget estimate, revising the budget estimate

in view of anticipated gains in processing efficiency, cost

reduction through process changes, etc. In Figure 1 we show the

anticipated steps toward the development of a Survey and Moni-

toring Program, the information gained from it, and the use of
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this information in the progressive planning steps. Figure 2

shows the logical expansion and refinement of this program as the

pretreatment system is developed, installed, and put into operation,

N. SELF-MONITORING REQUIREMENTS

The monitoring system developed in the early stages of the pro-

gram now takes over the function of supervising the performance

of the treatment system,, but remains an important tool in high-

lighting possible production upsets and the dependable function-

ing of the responsible plant staff. For the 21 industry categories

and 65 priority pollutants, the self-monitoring and reporting

requirements will be governed by EPA regulations.

The scheduled reports will be sent to the local authority where an

approved local compliance program is in operation. Otherwise,

the reports will be addressed to the NPDES State or EPA's

regulatory arm. Those industrial plants whose effluent discharge

is controlled by national standards will also have to report the

plans they have formulated to meet the pretreatment requirements

and the progress with the execution of their plan.

Depending on the rate of progress of local authority's establish-

ing compliance programs and their approval, it is anticipated

that close cooperation will be established between the local

industrial concerns and the authority responsible for the opera-

tion of the POTW. The responsibilities for reporting to the
321
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NPDES State or EPA by the local authority requires a great deal

of data and the upkeep of this information. The information that

will be required concerns an inventory of the local industrial

concerns discharging pollutants into the POTW system. Information

required includes the character and volume of these pollutants

discharged by a significant sourc new sources discharging new

pollutants, changes in the characteristics of the discharge from

an existing source, etc. The POTW operating authority is required

to prepare a yearly report updating the national inventory informa-

tion on file. Industry therefore will have to report to the POTW

any change in processing, processes used, potential inclusion of

new toxics, or elimination of others from their discharge, signifi-

cant changes in the volume of flow, etc.

It is recommended that industry also consider using outside

laboratories or their consultants as a quality control check on

their facilities and staff a few times a year. This could

insure that they are meeting their self-monitoring responsibil-

ities and could generate additional confidence in their estab-

lished dialogue with the local authority.
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INDUSTRY'SQR THE INDUSTRIAL COMMUNITY'S ROLE IN ASSISTING
THE POTW IN REQUESTING A VARIANCE"FROM THE NATIONAL STANDARDS

INTRODUCTION

The national numerical standards that will be applicable to that

segment of the 21 industrial categories found to discharge signifi-

cant quantities of the priority toxics, as of necessity, aims for

general applicability. An individual industry's special condi-

tions or processes cannot be considered during a regulatory effort

covering the whole nation. Neither can these standards reflect

on the demonstrable better than generally anticipated removal

performance of a POTW, although it would be in the interest of

the community and even the national economy if such recognition

could be afforded. As we have heard in the previous lecture, EPA

is aware of the advantages that could be gained from allowing

such exceptions from the general rule and has, therefore, stipu-

lated a "request for variance" procedure to serve this aim.

Industry has an important role to play in the projected procedure

by cooperating and assisting the POTW.

I. INDUSTRY VARIANCE FOR FUNDAMENTAL DIFFERENCE

An existing industry may apply for variance from the promulgated

pretreatment standards because it claims fundamentally different

conditions than those which EPA has weighed when considering the

various factors finally resulting in the promulgation of specific

numerical standards. The industry planning to apply for variance

should recognize that EPA has taken into account the economic

hardship that could be created for some smaller concerns. The
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financial constraint and potentially resulting economical stress

of the affected industrial firms have also been considered vs.

the environmental protectidn requirements which the CWA stipu-

lates. Where applicable, an exemption for small concerns has

been foreseen. Special equipment or processes that couldn't have

been considered, unusual raw materials, potentially a combination

of conditions could provide evidence that can substantiate the

claim that for the stated conditions, economic pretreatment

technology is not available, the national pretreatment standards

cannot be achieved, etc. Provided that the submitted data is

convincing, the unusual conditions proven, they could serve as a

basis for EPA to grant the requested variance. For the granting

of this variance EPA has retained sole authority.
II. VARIANCE IN VIEW OF THE POTW'S DEMONSTRABLE AND DEPENDABLE
REMOVAL CAPABILITIES
A. "Incidental Removal" of Incompatible Pollutants in
POTWs with Physical-Chemical Treatment Capabilities

A number of treatment plants with tertiary treatment systems

employ a chemical treatment step with subsequent sludge removal.

Some of these may have additionally installed filtration steps,

means for the reduction of the dissolved solids concentration,

using water recovery techniques for recharge, reuse, etc. It is

evident that the removal efficiency of these plants, as an

example for heavy metals, may significantly exceed the national

average.
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B. "Incidental Removal: of Incompatible Pollutants
in Secondary Treatment

It is well appreciated that the biological floe formed in sec-

ondary treatment systems (most POTWs will have secondary treat-

ment systems in the near future) due to adsorption and coagulation

effects, provide also significant removal for some of the other-

wise incompatible pollutants.2 Both organic and inorganic

substances may be adsorbed, while the insoluble matter, suspended

solids, are removed by the coagulation and subsequent settling

steps in the POTW. The removal of insoluble matter is consider-

able even in the primary treatment,3 but becomes more significant

in the secondary system in view of the adsorption and coagulation

with the biological floe.4'5 For this reason the concentration

of very small particulates, even colloidal solids (such as dyes),

can be greatly reduced with the subsequent removal of the sani-
»
tary solids.

C. Removal of Incompatible Pollutants Present
in Low Concentrations

Some of the "toxic" organic compounds are considered incompatible

because they can have inhibitory effects and therefore interfere

with the efficiency of the biological treatment in the POTW.

Other priority pollutant organics are assumed to require longer

residence time in the system than available, or are considered

non-degradable, and therefore only physically removed by the

sanitary solids, and thereby may pass through with the discharged

effluent, or be retained as toxic contaminants in the solid

waste. Many of these organic compounds are amenable to biological
325
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treatment when present in low concentration. A specific

bacterial strain is needed for the decomposition which is not

available when shock loads of high concentrations of these same

contaminants are introduced. Tcrlerance levels of the biological

treatment system, even for higher concentrations, can be de-

veloped by slowly increasing the concentration of the toxics and

thereby assisting proliferation of the special bacterial strains,

seemingly increasing the tolerance levels. In sanitary treatment

terminology, this phenomenon is called "acclimation" which prob-

ably is a misnomer because acclimation also refers to bacteria

becoming acclimatized to toxics which are not degraded. We are

discussing here an acclimation phenomenon not due to the fact

that the tolerance levels of the developing and proliferating

bacterial strains have been slowly increased, but the presence of
»
specific bacteria with increasing population of colonies when

specific nutrients, compatible with their enzyme systems, are

present.

We would like to discuss two such toxics as examples to illus-

trate the distinction we would like to make:

a. Cyanide compounds were found to be amenable to bio-
logical treatment and the use of such treatment systems has
been developed and recommended by the British Water Pollu-
tion Research Board.6/ 7> 8 Various strains of responsible
bacteria have been identified and described. The U. S.
HEW has conducted an extensive study in the Robert Taft Research
Research Center9 and was able to confirm the results noted
in England.

b. Phenolic compounds are also amenable to biological
treatment. Nearly all the industrial treatment and pre-
treatment systems for phenol removal are based on biological
decomposition. The specific bacterial strains responsible
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for phenol degradation have been identified. A major in-
dustrial concern found that the complete decomposition of
phenolic contaminants in the effluent from one of their
plants can be economically assured without hampering the
performance of the POTW by a slow measured discharge of the
daily batch waste.10 Previous practices in discharging the
collected, highly concentrated waste in slugs has seriously
hampered the POTWs performance by both inhibiting the
bacterial removal efficiency and due to significant pass-
through of phenol in the effluent discharged.

The conclusions we would like to draw from the foregoing are:

a. Some toxic organic compounds that are assumed to be
"incompatible" are indeed compatible and completely treat-
able if they appear in the influent of the POTW only at low
concentrations. The concentration in the influent should
not exceed the removal capabilities of the bacterial colo-
nies that are present.

b, EPA's concern regarding inhibitory effects and potential
"pass through" are well justified and cannot be simply over-
come with, as an example, higher numerical standards. The
standards are based on the effectiveness of BAT technology,
but if the POTW and industry cooperate, a biological pre-
treatment system can be avoided, or numerical standards can
be safely increased. A cooperating industrial community and
a well operated POTW wi,th biological organism attuned to the
customary "daily fare" of chemical compounds is needed to
provide the necessary assurance of good treatment control.
Under these conditions the "variance" procedure foreseen by
the regulations may be the ideal vehicle to accomplish the
multiple aims of environmental control and economical
pretreatment.

III. OTHER CONSIDERATIONS TO BE MET BEFORE A VARIANCE
CAN BE ANTICIPATED

1. We have discussed the potential for secondary and especially

tertiary treatment systems for the removal of insoluble toxic

matter and adsorbed substances. The toxics so retained by the

POTW are incorporated in the municipal sludge and could be re-

cycled into the environment from the sludges. Both Congress and

EPA consider the soil nutrient or energy value of these sludges

and any removal of the pollutants that would interfere with the
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utilization of these sludges would not be an acceptable treatment

option.11/12 The POTW, on the other hand, may have an accepted

or acceptable sludge management program which may not be affected

by, as an example, the retained heavy metals. Considerations,

such as the beneficial utilization of the sanitary sludges

in the area of the POTW's location would not be economical or

could jeopardize public health, clearly would indicate the desira-

bility of an alternate sludge management scheme.13

2. Equal concern would be raised regarding the claims of excep-

tional removal capabilities of the POTW in those cases where an

atmospheric pollution hazard may be created. Such would be the

case, as an example, for a volatile organic compound in the

industrial discharge that could be discharged to the atmosphere

in the aeration system of the POTW.

3. The effluent discharged by the POTW should also not be

affected. The CWA of 1977 especially conditions the applica-

bility of these variances to the effluent quality of the POTW by

stipulating that the POTW effluent would have to meet the same

effluent criteria that would be required from an industrial

direct discharger meeting the specific treatment standards CBAT]

for the same pollutant.

4. POTWs with combined sewer systems, or where the treatment

plant frequently is bypassed due to storm water, hydraulic over-

loads, the Approval Authority will not grant a variance because

the demonstrated removal applies to dry-weather flow only. An
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exception will be granted from this rule for those POTWs that

are proceeding with their plans to control combined sewer over-

flows. An approved facility plan, including treatment of the

bypass, will appear as suitable indication that efforts are

underway and the proposed removal will be maintained on a

year-round basis.

5. The POTW has to justify a variance request from the national

standard, showing reliable and consistent removal of the par-

ticular pollutant. The dilution factor inherent in the POTW

collection system, considering the volume of discharge from the

affected industry and total flow through the POTW/is not con-

sidered removal. Neither would the fact that the pollutant

concentration is consistently below analytical detection limits

be accepted as sufficient proof for removal efficiency.

6. Request by the POTW for a variance from the national pre-

treatment standards implies that the POTW is willing to accept

the responsibility to take over the regulatory functions over the

affected industry in the locality and has developed a pretreat-

ment program approved by the Approval Authority (the NPDES State

with an approved pretreatment program, or EPA). An approved

pretreatment program will also be mandatory for all larger POTWs

(more than 5 MGD) unless there are no industrial facilities

requiring pretreatment in the locality. Besides a well operated

treatment plant, the POTW would have to have the necessary organi-

zation, control, and supervisory personnel, laboratory, quality
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control means, etc., in accordance with the regulatory require-

ements being developed, which envisions generally—but specially

where POTWs have received a variance—local enforcement and con-

trol over the pretreaters. The new pretreatment limits at

variance from the national standards would have to be stipulated

for each industry in the community for the particular pollutant

in question. The new pretreatment requirements would be enforced

through the local waste ordinance, permits, or contractual agree-

ments with the affected industrial concerns. The allowed vari-

ance would become a part of the POTW's NPDES permit conditions

and violation of the permit, non-enforcement of the regulatory

responsibilities over the local industry, etc., could cause

revocation of the NPDES permit and other regulatory repercus-

sions, possibly criminal action, from the NPDES State's or EPA's

enforcement arms.

IV. INDUSTRY'S ROLE IN GIVING ASSISTANCE TO THE
POTW TO SECURE A VARIANCE

From the foregoing it is evident that in the interest of the

local community and industry, the authority operating the POTW is

willing to accept a number of responsibilities when applying for

a variance from the national pretreatment standards, aiming to

assist the affected plants. It is inconceivable that the

authority would proceed with this effort if it doesn't feel that

the industrial community is backing the project and it has the

maximum cooperation of the industrial concerns needing this

assistance.
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What would be a model procedure to initiate and bring such a

project to a successful conclusion?

1. We would suggest that as a first step, the affected indus-

trial concerns seek the assistance of the entire industrial

community, local chamber of commerce, and other municipal offi-

cials concerned with the maintenance or enlargement of local

industrial activity and employment.

2. When the necessary political groundwork is laid, the regu-

latory requirements and Congressional intent should be explained

as well as the technical basis for the proposed application for a

variance. The technical background and capabilities of the local

POTW staff could be outstanding, but each employee of the POTW is

charged with certain responsibilities. They would not have the

necessary time to collect the needed information, nor would they

necessarily have the experience to conduct the limited amount of

research work, pilot testing that is desirable to create factual

data,, underpinning the request. In a large metropolitan area the

technical support is far greater, staff positions far more

flexible, and the authority may not need any technical assistance

from industry. Considering the fact that median and small-

sized communities are in the majority and industry is widely

dispersed, we would urge the retention of a consultant who is

familiar with the sanitary treatment technology and has had expe-

rience with biological treatability studies. The authority may

have retained .a consultant assisting and periodically supervising

the POTW performance. The industrial concerns could retain the
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same consultant or another whom they consider equally

qualified. The planned action, however, collection of the

evidence, the performance to be demonstrated, and assembly of the

test data should be mutually agreed upon by the consultants.

After an initial political consensus has been reached that the

municipality is interested in providing the requested assistance,

all discussions will be aimed to resolve technical issues. Our

experience teaches us that the most fruitful approach is to let

technically well qualified people talk to each other and do not

let the project become encumbered with legal or political issues.

V. DEMONSTRATION SHOWING RELIABLE AND CONSISTENT REMOVAL OF A
SPECIFIC POLLUTANT BY THE USE OF SPECIFIC DATA AS EVIDENCE

Assuming that a consulting engineer is representing the affected

industry and has taken over the subsequent discussions with the

POTW staff and their consultants, let us consider the various

procedures they may contemplate to collect the needed and con-

vincing evidence that is requiredt

1. The consultant may first want to convince himself that the

POTW is well operated, the pretreatment program is functioning,

reliable data is collected, both on the influent and effluent of

the POTW, the specific pollutants of interest are potentially

removable in the POTW facilities, the potential alterations of

the plant that may be required and their approximate cost, and,

in the case of solids removal, that the enrichment of the sani-

tary solids by the specific toxics will not create insurmountable

problems.
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2. It is essential that during the test program and development

of the necessary data, the affected industry will cooperate and

will actively support the project. The industries who do not

have pretreatment facilities should avoid any slug discharges

containing the specific pollutants; floor spill should be mini-

mized; conditions should be created to approach, if possible, the

treatment levels that the hoped-for variance may sanction.

«*

3. There should be good evidence, both theoretical and prac-

tical, to justify the expectations that the POTW will be able to

demonstrate reliable and consistent removals at the level of

concentration that is anticipated as maximum in the influent. To

demonstrate meeting these criteria, 95% of the data points—that

is, 95% of samples that have been taken—will have to demonstrate

the removal efficiencies claimed. When the polluting industrial

dischargers do not yet practice any pretreatment, it is nearly

impossible to avoid excursions in both the influent and effluent

concentration. This can be easily explainable and may not

seriously affect the application for a variance, but it is data

that has to be explained. Neither is it possible to treat with
i
the same removal efficiency a high .spike in the influent because

i'f the removal depends on bacterial decomposition, as discussed,

a sufficient-size bacterial colony is not present, nor could the

percentage of heavy metals removal be maintained because, as we
>
will discuss further, predictable removals anticipate some pre-

treatment, at least for some of the parameters.
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4. The pretreatment regulations allow the use of pilot plant

data as supporting evidence for the anticipated removal effi-

ciency. The need for pilot plant work has been mainly antici-

pated when some alteration of the POTW system appears necessary.

We would hope that the same type of pilot plant data could be

used for the support of the application when the anticipated

"alteration" is mainly in the industrial dischargers' facilities;

i.e., operation of pretreatment facilities that are not yet

available. It appears to us that if the POTW's application for a

more lenient numerical standard is delayed, the approved variance,

when received, could come too late to assist the pretreaters.

The three-year compliance requirement from the date of promulga-

tion doesn't allow for too much time to await a hoped-for vari-

ance because planning, design of the treatment facilities,

installation, and start-up takes up almost all the time that is

allowed.

VI. EXAMPLES OF PRIORITY TOXICS AND THEIR DEMONSTRABLE
REMOVAL BY THE POTWs

A. Biological Removal of Cyanide Compounds

We* have discussed earlier the theory behind the biological removal

of cyanide compounds. The described mechanism is applicable only

to the cyanides amenable to chlorination. The iron cyanides are

too refractory for biological decomposition. When sampling and

analyzing the influent in a POTW receiving flows discharging *

these pollutants, the influent may show regularly a measurable

level of amenable cyanide or only sporadically, indicating only

the high spikes that occur from accidental or slug discharges.
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1. Where Cyanide is Normally Present ir. Measurable Concentration:

Demonstration of the removal capabilities of the PGTW could be

relatively easy. The daily analysis of the influent and effluent

concentration, tabulation of these results for a sufficiently

long period of time could be all that is required. The data

could be free of high-level excursions if the local industry is

cooperating and avoids any accidental spills or slug discharges

while the data is being collected. Prompt communication if per

chance accidental discharges have occurred could avoid sampling

during the residence time of the slug. The data collection is

not biased by this exclusion of recognized accidents and slugs

because it is anticipated and the pretreatment program is so

tailored that these accidents and slugs will be eliminated after

the industry has installed their pretreatment facilities.

2. Where Cyanide in the Influent is Low cr has £>een Noted
Only Infrequently:

In cases where the normal cyanide concentration in the influent

is noted infrequently or is very low, close to the detection

limit (0.005-0.02 mg CN/liter), it is advisable to model the

system since it is not permissible to spike the POTW influent

with toxic compounds under present EPA regulations. Using a

laboratory pilot-scale model, reinforce the influent concen-

tration by spiking to provide a better data base. We would

recommend controlled feed of a standard solution at the influent

and would use zinc-, cadmium-, or copper-cyanide in the feed.

This avoids any questions regarding the particular metal cyanides
335
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used in the local processes and their specific effect in the

noted removal mechanism. We would recommend maintaining a level

of cyanide concentration in the range of 0.1-0.15 mg CN/liter in

the influent. Start sampling after a few days of biological

acclimation has been achieved. If the program is successful and

it has shown biological removal capabilities, it can be assumed

that the pretreatment program will be satisfactory.

3. Test for Atmospheric Pollution and Sludge Leachability:

We would also recommend testing the atmosphere close to the level

of the aerated biological treatment system to be able to reflect

on the atmospheric pollution question that could be raised. We

wouldn't anticipate any atmospheric pollution effects. Test also

some of the sludges collected from the secondary treatment to

show that no leachable or analytically detectable cyanide residues

were present in the solids. For this demonstration, the lab-

oratory, pilot-scale test or the secondary treatment return

sludge could be sampled after at least one week's test run. We

wouldn't concern ourselves with the potentially increased heavy

metal content of the sludges. The heavy metal content of the

influent is governed by a different regulatory requirement and a

request for variance regarding the cyanide concentration in the

discharge would hot affect the metal accumulation in the sludge.

B. Biological Removal of Phenolic Compounds

We would recommend a test procedure to demonstrate the removal

capabilities of the POTW conducting a test program, very similar
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to the one discussed previously for cyanide compounds. The

concentration levels in the influent to the laboratory pilot-scale

model should be increased slowly to 1-2 mg/1. The same genera of

phenolics should be used for the* controlled feed that are known

to be in the industrial discharges. The atmospheric testing

could be omitted.

C. Removal Capabilities for Heavy Metals

A great deal of conflicting and confusing data in the related

literature has possibly prevented the understanding of the rela-

tively simple chemical and physical mechanisms that are involved.

Maybe the root of the problem is the sampling and analysis pro-

cedure in general practice. The testing program usually calls

for "total metal" determination only. We urge all POTWs adapting

a pretreatment program to collect two samples for heavy metals

analysis and report separately soluble and total metal. Under-

standing problems with pretreatment of heavy metals, controlling

and monitoring the removal efficiency in the POTW can be easy and

simple to follow if the analytical data routinely would provide

information regarding the performance of two distinct and un-

related mechanisms: one chemical, precipitation (to a minor

extent physical-adsorption); the other physical, solids separation.

1**
As we have attempted to show in our earlier reports, the

heavy metal solids separation is enhanced in the POTW by the

coagulation on the biological floe or with the coagulants in

physical-chemical treatment systems. Routinely, a better than
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90% removal can be predicted for all suspended matter, heavy

metals, with either system. It is, on the other hand, a far more

variable and therefore not so dependable effort when the removal

of soluble heavy metals is to be" demonstrated. The physical-

chemical treatment, because it is normally operated at an ele-

vated pH, can accomplish better removals and more dependably, the

more so, because coagulant metal additions are also involved.

Coagulation involves coprecipitation with the nuclei of the

easily flocculated metals; otherwise the heavy metals could

remain in a supersaturated condition and reach solubility equi-

librium only in a long time.

In view of the near neutral pH maintained in the biological

treatment processes, the soluble heavy metals concentration

cannot be depressed below an average of approximately 1 mg/1

each. Noted removals therefore are mainly due to adsorption on

the biological floe. Zinc, cadmium, copper, and trivalent

chromium are more prone to be adsorbed than nickel. Hexavalent

chromium is a soluble compound and has to be reduced to the

trivalent state before it can be precipitated or adsorbed.15

At the pH of the biological processes, the reduction of the

hexavalent chromium by the organics in the waste is incomplete;

50% of the hexavalent chromium has been reported to be reduced

and thereby removed at the concentration level of 0.2 mg Cr^/

liter.5 In general.we can predict a removal of 50% of the soluble

heavy metals in the concentration range of 0.1-0.2 mg/1. Soluble

nickel removal usually does not exceed 20%.5
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Based on these considerations, if a POTW considers processing an

application for a variance from the national pretreatment stan-

dards for a percentage of the heavy metals removal, we would

recommend a program of testing by analyzing the influent and

effluent for both soluble and total metals. The variance could

consider setting separate pretreatment standards for soluble and

suspended matter heavy metals. The removal of the suspended

matter can be easily demonstrated; the allowable residuals in the

pretreated waste could be significantly increased without any

effect on the POTW effluent. In this scheme, the soluble heavy

metal residuals in the effluent from pretreatment would be regu-

lated at a sufficiently low level that pass-through can be

avoided.

The study has to recognize that the POTW effluent contains organic

chelating compounds, some of which are decomposition products

from the treated organic waste, but a significant concentration

could be due to the industrial discharges, water softening,

laundry and dishwasher compound-chemical additives, discharged in

the sanitary effluent. The chelated heavy metal content of the

POTW effluent is not easily reduced and the metal content of the

POTW effluent probably is more affected by the chelating com-

pounds in the industrial waste discharges than by the metal

residuals in the waste streams.2' 17

D. Removal Capabilities for Iron Cyanides

Iron cyanide per se is not a regulated parameter. It is a
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component of "Total Cyanide" together with "Cyanides Amenable to
Chlorination." The latter is a separate parameter and its
removal by the POTW has been discussed under Section A. The
toxicity of iron cyanides has been noted to be due only to their
photodecomposition to simple cyanides by sunlight.18 For this
reason the proposed national pretreatment standards have set a
relatively high allowable limit on the total cyanide, whereas the
limit is low for the amenable cyanide. The difference between
these two parameters could be considered as the regulatory limit
for iron cyanides. The reduction of the iron cyanide in pre-
treatment is complex and costly. A demonstrated removal capa-
bility by the POTW may be of significant assistance to the
affected industry without any environmental risks or any possible
effects on the POTW performance.

The envisioned removal would be based on precipitation of the
soluble iron cyanide from the industrial waste stream in contact
with metallic ions such as iron, copper, zinc, etc., at a rela-
tively neutral or slightly acidic pH, as encountered in the sewer
systems of the POTW. It is postulated that a significant per-
centage of the alkali metal - iron cyanide is precipitated
as the heavy metal-iron cyanide in the municipal sewer system and
appears in the POTW's influent as insoluble matter. Subsequently
this is removed by the flocculation, precipitation reaction in
the secondary treatment or clarifier.

The concentration normally measured in the influent is so low
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that the demonstration of reliable and consistent removal is not
easily demonstrated. We would recommend a test and demonstration
program in which excess soluble iron cyanides are metered into
the effluents of the affected plants, so that the total iron
cyanide in the combined discharges could appear as a measurable
residual in the influent to the POTW. If the analysis of the
influent convincingly shows a percentage removal, proof has been
gained that either no soluble iron cyanide has remained, although
measured additions have been maintained at each plant under
consideration, or a percentage relationship can be established re-
garding the effectiveness of the removal mechanism. Adding the
soluble iron cyanide spike to the waste streams at each plant
tests the mechanism of the removal which could be affected if all
the additions are made at only one plant.

The precipitated iron cyanides cannot be considered toxic or
harmful for the utilization of the sanitary solids as agricul-
tural nutrient or soil build-up of the land. No evidence has
been noted of any harmful effect from iron cyanides on the land,
although for quite a number of years iron cyanides, in signifi-
cant concentration, have been used as an anti-caking agent with
the road salt in all the northern states.

Pretreatment by precipitation of the soluble metals will also help
to reduce the POTW1s effluent chelated toxic metal content. Heavy
metals precipitated in the POTW's treatment are easier to chelate
than the redissolution of the solid matter.
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SLUDGE DISPOSAL MANAGEMENT

I. INTRODUCTION

A. What is "Sludge?"

An industrial facility may have a variety of solid waste

to dispose of. In view of the anticipated regulatory re-

quirements for the control and ultimate disposal of these

solids, it is important to make certain distinctions to aid

an intelligent planning effort.

In the present definition we consider "sludge" to mean solid

or slurry residual from the pretreatment of an industrial

effluent. It could be derived in the course of the bio-

logical or chemical treatment of an effluent or a dumped

batch of a processing solution, faulty product, byproduct of

a wet manufacturing process, etc.

1. Most often pretreatment renders the effluent acceptable

for discharge into the sewer system by biological or chemical

precipitation and physical separation of the solids. The

need for treatment could be because some constituents are

not compatible, are toxic, or have other nuisance effects

impeding the performance of the sewage treatment processes,

and could harm the treatment plant structures or endanger

the safety or health of the employees in the treatment plant

or in the sewer system.
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2. Pretreatment may be required because the periodically

discharged waste is to6 high in strength of biologically

degradable materials and the shock load of this concentrated

discharge could cause upsets in the normal biological ac-

tivity. In these instances, pretreatment may consist of a

biological treatment and the solid waste residual (sludge)

being physically separated from the effluent to avoid over-

loading the sewer system, undue or unusual loads for the

solid waste handling facilities of the treatment plant, or

just to avoid the cost of a "surcharge" in case the solids

would have been discharged with the effluent.

3. Sometimes solid waste has to be washed, such as ashes

from a combustion process,to free the solids from the

soluble metals and allow treatment of these quench waters,

thereby insuring that the remaining ash is inert and can be

disposed as treated sludge.

4. Another accumulation of sludge could be from an oper-

ation where the main purpose of the pretreatment is to

reduce the suspended solids content of the discharge and no

other significant or potentially harmful ingredients require

neutralization or removal from the effluent. The solids

thus removed could be inert ingredients such as sand or

stone chips, paint solids from a water wash spray booth

effluent; granules of plastic from a polymerization process,
343
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etc. From a vegetable processor or meat packer, the solids

removal could be required or desirable to reduce the ex-

cessive loading of the treatment plant with organics or

again to reduce the surcharge otherwise applicable. *

All these enumerated treatment efforts may create a sludge

which will have to be disposed of. The manner in which

these sludges are handled from the point of deciding for a

particular design of treatment scheme, through the dewater-

ing, storing, and dispatching of the collected sludges on an

ultimate disposal site, is what we call "Sludge Disposal

Management."

B. Other Solid Waste That May Not Become Sludge

The imminent implementation of the Resources Conservation

Recovery Act (RCRA) makes it necessary to re-educate our-

selves and change our waste disposal practices. Whereas in

the past we may have considered everything in solid form to

be garbage and can be hauled away to the refuse pile, we

will have to make certain distinctions and organize our

industrial practices to meet the environmental needs and the

parallel regulatory requirements.

1. Refuse:

A certain percentage, in some plants possibly a preponderant

part of the industrially disposed solids, will fall into
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this category. The variety of the materials that are and

will be in such a manner disposed, can't be enumerated.

Generally the materials will not be much different than

those disposed of in an individual household, only more

voluminous, yet the total waste created by industry in a

particular locality could be still a small percentage of the

total.

The ultimate disposal of this refuse will be either on a

sanitary landfill or through an incinerator. We will subse-

quently discuss the environmental hazards which some solids

can create in such disposal and the efforts that are being

made to screen the accumulating industrial solids to estab-

lish their suitability for such discharge. The cost of

refuse handling and disposal may not increase unduly while

the disposal of the potentially hazardous waste materials

will show a significant increase. We therefore anticipate

economical justification for industrial concerns to keep

their solid waste categories segregated.
2. Dry Chemicals and Solid Waste Material
Contaminated with Toxic Compounds
Solid form does not necessarily indicate that such material

would not be partially or perhaps totally soluble in water,

just as a tightly closed drum containing a solution cannot

be considered solid waste. In the sanitary landfill
345
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operation, the most important question is whether a deposited

solid could release soluble compounds through the action of

rainwater, groundwater, etc. Many industrial discards

appear in a solid waste collecting bin because it is mate-

rial that is no longer useful. Examples would be: spilled

chemicals, residual stock of chemicals from an abandoned

process; crystalline residuals from the bottom of a processing

tank, removed at the time of periodical clean-out; product

that doesn't meet specifications and is dumped without

washing and drying; discarded equipment or supplies, etc.

All these types of wasted materials are suspect and could

require pretreatment before they are released to the col-

lector of refuse. It is assumed that a firm responsible for

self regulation before discharging any solids will scru-

tinize these solids as to whether they should be washed or

treated in any way before disposal.

Very little if any attention has been paid in the past to

the potential hazard created by indiscriminant dumping.

Sometimes flammable solvents have been discarded with mate-

rial that could create toxic gases, in case of fire, drums

full of hazardous chemicals, etc. Practices developed of

which the plant management most often was not even aware.

We list these examples only to show the variability of these

customs and assume that each plant will develop its own

security system to guard against all types of hazards. A
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maximum effort will be needed on the part of each industrial

concern aiming to use the common waste disposal sites; one

accident or contamination caused by one plant may create

suspicion and hardship for the entire industrial community.

II. PLANNING THE SLUDGE HANDLING AND DISPOSAL PROGRAM

Sludge handling and disposal could become the most expensive

and toughest to manage problem posed by the anticipated

regulatory requirements, especially in an urban environment.

It is imperative therefore that when the plans for pretreat-

ment are formulated, the type of solid waste that is going

to be generated receives attention equal to if not even greater

than the attention paid to the characteristics of the effluent

discharged. While there may have been a considerable amount of

technical information disseminated insofar as the available

pretreatment options are concerned, the technology for sludge

disposal is more recent and hasn't had the same airing.

It is axiomatic that intelligent and logical planning requires a

basic understanding of the environmental problems that have been

noted or can be anticipated with the available waste disposal

technology. One may also anticipate near future developments

from research currently conducted and the results of testing

programs under way for the last few years.
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Characteristics of the Available Ultimate Disposal Methods:

A. Sanitary Landfill

The preponderant volume of municipal and industrial solid

waste is disposed on these landfill sites. The disposal

process, which may be under public or private management, is

centered on finding a suitable land area which is prepared

to receive the solid waste. The site preparation and design

of the landfill project depends on suitable geological

formation, a subsoil that is limiting percolation through

the ground, protection of the underlying aquifers, and

possible diversion of ground water to avoid contamination of

the nearby land area by leachate-mobilized bacteria or

leached toxics. Many installations add foundation layers of

clay or use plastic liners for added protection to insure an

impervious enclosure for the landfill. The delivered solid

waste is bulldozed into level layers, homogenized, and

compressed with suitable earth-moving equipment to provide a

consolidated basis area to allow the build-up of subsequent

layers of fill. Usually a day's fill is covered by a layer

of clay cover material to divert precipitation from the fill

and also to protect the area from insect and rodent pro-

liferation and other nuisance conditions. The landfilling

program is progressing in parcels, so-called "cells", until

the original design of the land contour has been reached and

the capacity of the site is exhausted. The aim of the

landfill management usually is to create a suitable site for

an ultimate use, such as, for example, an industrial devel-

opment, ski slope, etc.

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The waste contained in the sanitary landfill is mainly of

organic origin. There may be inorganics as a minor con-

stituent, some scrap metal that has not been sorted, glass,

bricks, cement blocks, etc. Solid waste of industrial

origin, such as sludges, chemicals, slurries, and liquids,

have also been accepted in the past, but their acceptance is

more and more scrutinized by the landfill operator. The

solid waste that is buried in the ground is slowly decom-

posed by anaerobic bacteria. The decomposition is aided to

some extent by the moisture infiltrating the fill, excluding

ventilation. The products of the bacterial decomposition

are various organic acids, depressing the pH of the envir-

onment. The organic acids are neutralized by the haphaz-

ardly included inorganic wastes such as limestone, cement,

etc., but equilibrium mainly depends on the slow development

of methane-forming bacterial colonies to decompose the

organic acids into methane gas and carbon dioxide. We have

intentionally said "slow development" of the methane formers;

this basically is the main problem in anaerobic decomposi-

tion. The methane formers are slowly developing and easily

inhibited bacteria, sensitive to the pH of their environ-

ment. Dissolved heavy metals have a toxic effect and will

inhibit their proliferation. We know very little about the

bacterial decomposition going on inside a sanitary landfill,

but fortunately we are very much aware of the general con-

ditions in anaerobic decomposition, from many years of

research effort, to understand the problems encountered with
349
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anaerobic digester systems in municipal sewage treatment.19

We also know that metals and insoluble metal hydroxides/

carbonates are much more easily solubilized by organic acids

O f\
than by mineral acids (considering similar pH conditions).

One of the major problems then with industrial sludges

buried in a sanitary landfill is that as organic acids are

generated by the bacterial decomposition, metals in the

sludges are resolubilized, the normal route for the decom-

position of these acids into methane gas is hampered be-

cause the proliferation of the methane formers is inhibited

by the soluble metals in the environment. This condition

becomes aggravated because more and more organic acid is

formed, further depressing the pH to the point where the low

pH itself is enough to block the colonization of methane

formers. The acid, as it trickles through the fill, con-

sumes all available alkalinity, such as additional heavy

metal hydroxides from sludges, if such are present. The end

result is a leach liquor accumulating, finally reaching an

aquifer, or breaking through the landfill, highly contami-

nated by heavy metals, carrying also potentially higher

concentrations of soluble organics (COD, BOD) than would

have been the case if the anaerobic decomposition process

would not have been upset by the metal toxicity.

We wanted to provide an explanation for the environmental

problems that metal-containing sludges create in some sanitary
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landfill sites. This will explain the regulatory attention

to these issues and could result in restrictions regarding

the acceptability of such sludges and industrial wastes in

the future. Recent research results indicate that as the

high-metal-content leach liquors percolate through the

ground strata, a significant attenuation of the metal con-

tent can be expected due to adsorption, ion exchange, etc.,

on particulates in the soil. We assume that since the

soil's adsorptive quality and capacity is not easily quan-

tified, the regulatory aim will be to minimize the heavy

metal input into sanitary landfill and a requirement for

environmentally more positive and safe practices.

An issue not yet widely discussed is the number of years it

will take to stabilize a landfill. Essentially this means

that a higher decomposition rate, accelerated methane

generating capacity, etc., means more rapid stabilization of

the landfill; methane gas generation will cease because the

decomposable organics have essentially all been stabilized;

the land can be turned over to commercial use sooner; and

the monitoring, supervisory, and legal responsibilities of

the owner and control effort by the regulatory agencies can

be terminated sooner.

Some refractory toxics, highly resistant to biological

decomposition, such as for example PCB's, may also be washed

off from the solids in the waste pile and could appear in
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the leach liquors. From the description of the physical and

biological process at work in the stabilization of the solid

waste, it will be evident that it doesn't have treatment

capabilities for most chemicals, solvents, oils, soluble and

toxic compounds, dyes, etc. In simple terms, these mate-

rials should not be disposed on these sites.

Landfill sites in arid areas, such as in some California

locations, do not encounter the described mobilization of

the metals and toxics in the fill. Exemptions may be

granted from the general regulatory requirements that we

anticipate. Conversely, the stabilization of the waste in

the landfill will require a far longer span of time.

B. Incineration

The refuse collected in some municipalities is sorted for

metal and glass recovery and subsequently incinerated. The

caloric content of the waste is utilized for steam or

electric power generation. The problem with this disposal

method, when considering it as an ultimate disposal means

also for industrial sludges, is the potential air pollution

effect. Although the atmospheric emission of these incin-

erators is controlled with various pollution control de-

vices, our understanding of the atmospheric pollution effects

in urban areas is only now emerging. For a variety of

industrial waste solids and sludges a certain risk would be
352
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taken to assume that in the near future the disposal plans

would not have to be changed.

Low-boiling-point metals are vaporized and research results

indicate that even some of the high-boiling-point metals,

metal oxides, silicates, are escaping the pollution control

devices and are discharged to the atmosphere.21 Investigative

research conducted by EPA has indicated, for at least

mercury and lead, that only a small fraction of the metal

content (4%) is discharged.22 To some extent the test results

are not convincing to some of us. First, because the

findings are contrary to the assumptions one would draw

purely on theoretical basis; secondly, this would not neces-

sarily be an emission that can be considered harmless to the
23,24
environment. The condensed metal particulates, as a rule,

are so small a significant fraction is in the submicron size

range, and the pulmonary hazards for humans are so great

that one is not certain whether the present atmospheric

control devices are effectively protecting the population

from the metallics in the emission from even the combustion
25,26
of the relatively low metal content coal. In Japan, a two-

stage pyrolysis system has been proposed and tested to

reduce these hazards, but the issue is yet unresolved.27

Some other industrial wastes or sludges can create acid

gases (plastics) that even if completely scrubbed out of the

atmospheric emissions, may significantly add to the cost of
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the operation of the incinerator. Many of these materials

do not have any caloric content and may create maintenance

problems for the incinerator operation with molten salt

damage to the fire grate and fire box; others may contami-

nate the ash residual, creating problems with its disposal.28

These comments should be mainly regarded as cautionary as

each industry becomes familiar with the nature and antici-

pated volume of sludge that will be generated. Attention

should also be directed to the locally available solid waste

disposal means and the compatibility of the particular

sludge that will have to be disposed.

C. Ocean Disposal

According to existing'EPA regulations, ocean dumping permits

will be phased out in the near future and new permits will

not be granted.

D. Secure Landfill

These are commercially operated disposal sites for hazardous

materials. As we shall discuss in the subsequent parts of

this lecture, these sites will be mainly applicable for

those sludges (and other solid or liquid wastes) when no

more cost-effective means can be found for rendering the

solids "non-hazardous" or a landfill designed which could

become an equally hazard-free disposal site.
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III. FORMULATE PRETREATMENT PLANS AIMING FOR
REDUCED COST SLUDGE DISPOSAL
A. Process Change or Plant Modernization

1. There are very few industrial processes which could

not be improved by the use of more efficient processes;

regeneration of processing solutions traditionally con-

sidered as "exhausted" and therefore discarded; dumping

of material for maintenance or repair when a simple interim

storage facility could overcome these practices, etc. When

discussing the need for internal survey of the operations

and operating practices, we have alluded to the desirability

of rethinking every step in a processing sequence.

2. Within the last few years, due to the efforts of EPA,

most any manufacturing practice has been under close scrutiny

to reveal the least wasteful operating practices, to reduce

the discharged contaminants, to conserve materials and

water, etc. We recommend the reappraisal of all ideas for

changes that each manager may have, parallel with the plans

to be formulated for pretreatment and sludge disposal.

3. Many plants operate in crowded quarters, some of them

with inefficient equipment and a processing sequence dic-

tated more by the limited space available. Some plants are

laid out for a different processing or materials handling

system than the one that appears mast economical today. The
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amortization of the pretreatment facilities, the operation

of the treatment plant, and sludge handling and disposal

will all add to the operating costs wzth no gain in effi-

ciency, to remain competitive.

As will be discussed in a subsequent lecture, the government

recognizes the hardship that is created for many firms and

has marshalled a broad selection of financial programs to

assist industry. The opportunity is given to consider the

silver lining in an otherwise dark cloud. Instead of fur-

ther crowding an existing plant with pretreatment equipment,

a significant number of the plants that will be affected

could and should plan to relocate into more spacious quarters,

abandon that part of the production equipment that is anti-

quated, and realign their processing method, creating a new

plant layout, with equipment designed to take advantage of

the available means for recovery, reuse, and conservation.

In many instances it will be found that the pretreatment

equipment, and especially the installation costs, could also

be significantly reduced. We believe that the opportunity

to integrate the pretreatment needs with an overall moderni-

zation should be seriously considered by many firms. It is

the only way that the material, water and waste water con-

servation aims can be incorporated into one plan that could

provide significant reduction in manufacturing costs, allowing

the amortization of a new facility 'While maintaining a

competitive position in the market.
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B. Choosing Pretreatment Options with a View for
Economical Sludge Handling and "Water Conservation
1. Segregation in Pretreatment

We have preceded this phase of our discussion with an intro-

duction to the most commonly available and economical ulti-

mate disposal means and the environmental problems regarding

the various sludges and solid wastes of industrial origin.

Our purpose has been to create a background of understanding

regarding the problems an industry may face when blindly

planning for the use of disposal facilities unsuitable for

the sludges generated. We have discussed the environmental

concern regarding the potential recycling of toxic materials

from the available disposal methods.

The internal survey that we have recommended will reveal not

only those toxics that could be in the effluent discharge

but also those that will end in the sludge from the pre-

treatment efforts and those that may be leachable from the

solid waste discards and plant area. A pretreatment pro-

cess, aiming to reduce these contaminants to acceptable

levels with an "end of the pipe treatment" system,is no

doubt the simplest approach from an engineering and equip-

ment complexity standpoint, but it is least efficient in-

sofar as the quality of the effluent is concerned. Let us

try to illustrate the point we are trying to make with the

following examples:
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a. When chemical treatment is considered, one has to

remember that each reaction has a finite effectiveness,

resulting in an estimated final concentration in residuals

in the waste effluent. When these residuals are compared to

a segregated treatment approach, one deals with several

effluent streams, each treated at the optimum chemical

conditions, providing a residual concentration for each

toxic probably at a somewhat lower level. The significant

gain is the dilution factor that is achieved when mixing

these various streams. For the sake of clarity, let us

assume that the plant has a cyanide-containing process.

Treating this stream in a segregated manner, we achieve a

certain low residual due to the proper chemical approach and

equipment design. Assuming also that the segregated cyanide-

containing effluent has been only 25% of the total flow,

after mixing this segregated stream with the total effluent,

we have achieved a 1:4 reduction in the final concentration

in cyanide residuals discharged.

b. Let us assume that the plant under consideration is

engaged in compounding, mixing., or manufacturing specialty

chemicals for sale to other industrial customers. A bag of

chemicals has split or chemicals have been spilled in the

course of transferring into the rotary mixer. The practice

is to hose off the floor and chemical spill that occurs

periodically and pretreat the floor washings before they are

discharged. Let us assume next that the particular spill
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that has occurred contains one of the toxics for which we

have great concern. By handling the dust spill in a seg-

regated manner, and picking it up with an industrial vacuum

cleaner we could deliver it automatically into a 10-gallon

can and make the chemical spill available for segregated

treatment. With this procedure we did not affect the quality

of our normal treatment process at the end of the pipe

normally available for the floor washing. Economically, we

have treated in a segregated manner an effluent by holding

it down to a 5-10 gallon volume instead of allowing it to

contaminate a discharge of a few hundred or few thousand

gallons per day.

2. Segregation of Sludges:

Industrial wastes are always complex and are usually derived

from a number of processes. Existing technology and eco-

nomical constraints will tend to restrain efforts to elimi-

nate sludge generation altogether. The question then

remains what is the most economical manner these sludges can

be disposed of. The segregation approach has shown signifi-

cant opportunities for cost recovery, or at least cost

reduction.

Each plant could consider a design exercise when planning

their pretreatment system or sludge handling facilities. We

have to resort again to examples to illustrate the points

under discussion:
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a. A meat-processing facility generates waste fats
and greases which are amenable to floatation and can be
processed into a thickened sludge salable to a ren-
dering plant; other waste materials, such as bone,
hair, etc., require cooking or digesting to create a
byproduct for animal feed; a third waste product,
blood, requires centrifuging for the recovery of the
red blood cells and "ultrafiltration" to remove the
excess water and reconcentrate the serum. The result
is three salable byproducts and no sludge to dispose
of.

b. An electroplating shop, preponderantly in the zinc
plating business, segregating all the zinc-containing
rinse waters and treating them in a segregated manner
can accumulate relatively pure zinc hydroxide sludges.
These can be sold as a byproduct for approximately 50%
of the value of the zinc content, but the main gain has
been that the sludge to be disposed has been signif-
icantly reduced. An opportunity for the future is also
preserved. As the zinc raw material costs increase,
the return will be greater, competition in the by-
product market may develop, and the value of the sludge
kept in a clean, salable form, will keep increasing.

c. Segregation of sludges could be desirable to
simplify the sludge disposal problems. As we shall
discuss in more detail in a subsequent chapter, we
anticipate the establishment of "segregated industrial
landfills." As we have alluded to the environmental
problems created by organic acid in the leachate liquor
in sanitary landfill and the resolubilization of heavy
metals, the creation of parallel landfills, containing
no decomposable organics, could overcome the environ-
mental problem and yet provide a relatively economical
disposal site for industrial concerns who have segre-
gated and excluded organic contaminants from their
heavy metal-containing sludges. Sludges from metal
finishing, water treatment, ashes from combustion and
fly ash accumulate from industrial operations where
this segregation is easily accomplished. A tannery may
have to process the sludges further to achieve these
aims because the organics and metallics are mixed.

3. Treatment Options that Normally.Increase
the Sludge Volume:

We anticipate that sludge handling and disposal will be a

significant, if not the major, part of the operating cost in

pretreatment. The volume of the sludge generated could

depend on the pretreatment process used.
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a. For precipitation or floatation aids, aluminum and
iron salt additions are common. These salts are added
as coagulants to neutralize the static charge during
floe formation. In some applications we have seen
coagulant additions at ten times the concentration of
the floe present in the waste stream. The judicious
selection and dosage of polyelectrolytes may allow
significant reduction of the coagulant that has to be
added, with a parallel reduction of the sludge volume
generated.

b. Some treatment processes depend on coprecipitation
of metal contaminants, a ratio of coagulant in the
range of 1:100-1,000 is not unusual. This method of
overwhelming the residual metal content of an effluent
may be necessary to insure a low residual final con-
centration, but most often segregation of these
effluent streams, treating the solution at a higher
metal concentration with reduced water flow, different
chemistry in the treatment process, could provide the
desired results without creating an excessive amount of
sludge.

c. Sulfides, xanthates, peat moss, etc., used in the
removal of metal residuals, may interfere with a simple
sludge handling program as will be discussed subse-
quently with the topic of "segregated landfill."

d. From some effluent streams, the suspended solids
content cannot be easily separated in settling systems;
it could be due to material lighter than water (plastics,
latex, etc.) or colloidal dispersions, etc. Contrary
to the nature of the suspensoid, limestone, clay, etc.,
are added to weigh down the flocculent materials,
instead of using a floatation technique that could be
in these instances the right approach and without
increasing the sludge volume. Other times we have seen
mixing oily waste streams with high-iron-content
acidic waste to coprecipitate the oil and include it
into the metal sludge. The oil can be separated and
removed from the waste water in this manner, but the
process didn't make a solid out of the oil and the
sludge that is generated is not suitable for any of the
planned ultimate disposal applications.

4. Treatment Options to Reduce the Waste Water
Volume:

The EPA-supported studies, to find the best treatment

approach for a variety of industries, are replete with

information regarding improved technology to reduce water
361
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consumption.

We can't expand this lecture to cover this rather complex

issue which is highly dependent on the particular industrial

operation. It will be evident that one cannot generalize

when discussing water conservation opportunities; a dif-

ferent approach will be required for a meat packer or a

textile dyeing plant. We would only like to stress the

importance of searching out the best technological approach

for each plant in view of the anticipated increased opera-

ting costs that we can foresee.

a. As the previous speaker has discussed, the Clean Water

Act (CWA) makes it mandatory for EPA to implement and en-

force the requirement that industry pay its share as "User

Charge" (sewer rental charges) for the cost of the sewage

treatment plant operation, sewer maintenance, etc. As the

CWA stipulates, no quantity discounts will be allowed for

large users. We may anticipate a continuous increase of

these costs. The treatment plants will have to be enlarged,

tertiary treatment may be required in some areas, and more

sophisticated personnel, equipment, instrumentation, and

laboratory facilities will have to be provided to satisfy

the needs of improved performance, record keeping, reporting,

maintenance and supervision.

We may still have municipalities where the sewer rental

charges are nominal, the effluent volume is not measured.
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The "user charge" most likely will be based on the volume of

effluent discharged with surcharges for higher-than-standard

BOD, COD, and suspended solids content.

The CWA of 1977 allows municipalities to give credit to

industry for "ad valorem" taxes collected when calculating

industry's prorata share of sewage collection and treatment

cost.

b. The previous lecture reflected on the other CWA re-

quirement that industry reimburse the federal government

with its prorata share of the construction grants for the

recent and future treatment plant and sewer system installa-

tion costs (Industrial Cost Recovery, ICR).

We should remember that if a firm's water conservation

efforts have achieved a level of 25,000 GPD or less for

their combined sanitary and process waste discharge, the 1977

revisions of the CWA waive the ICR requirements. In the

event that the waiver for small-volume dischargers is reduced

in the future, the reimbursement for the past years is

forgiven. However, the stipulation remains that the low-

volume flow discharger, if the discharge contains pro-

cess wastes, must not contaminate or impair the usefulness or

utility of the municipal sludge with his discharge. It is

assumed that those industrial plants that are meeting the

stipulations of the national pretreatment standards, if they
363
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are within those categories for which these standards are

applicable, automatically comply with this requirement. On

equal terms, those industries, for which the national

pretreatment standards do not apply, but which meet the

local ordinance requirements, will be considered eligible

for the waiver.

We mention these issues again because they tie in with the

recommended scrutiny of treatment options to stress the

importance of water conservation. A significant aspect of

the operating costs increases a firm may have to face could

be the ICR charges. ICR could easily bankrupt a small

operator with a high waste water effluent in a small community,

IV. SLUDGE HANDLING

A. Consistency of the Sludge:

The sludges, according to our terminology, are generated

when the retained solids from the pretreated effluent are

separated from the water. This separation is a physical

process that can be based on settling in a clarifier, centri-

fuging, filtration, or air floatation. We refer again to

the series of EPA studies on the most applicable treatment

procedure for a variety of industries. Each waste stream

may be amenable to more than one of these physical separa-

tion techniques. The nature of the' pretreatment will also

influence the ease in which one or the other of these tech-

niques can be applied.
364
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The sludges gained from settling systems usually require

additional thickening to remove excess water. As a general

experience factor, we may say that the sludges from a

settling system may contain 2-4% dry solids and can be

thickened with aging and decantation to 10-15%. Centrifuges

can provide 10-30% dry solids content; floatation 8-15%;

subsequent vacuum filtration 10-3t)%; and pressure filtration

30-60%; depending on the nature of the waste material,

treatment process, etc.

The consistency of the sludge, depending on the dry solids

content, can range from a thin slurry through a paste con-

sistency up to a dry cake appearance coming from a filter

press. For the disposal of large volumes of sludge, further

reduction in water content, and therefore additional reduc-

tion in volume and weight,may be economical. The question

of whether a thickened sludge should be further processed on

a vacuum filter or filter press will depend on the savings

in shipping cost that can be achieved vs. the investment and

operating cost of the additional equipment. It should be

considered that the operator of the nearby landfill could

refuse to accept anything but dried sludge, as the wet

material can hamper the performance or operation of the

earth-moving equipment employed at the landfill site.

B. Requirements for a Manifest

It is anticipated that each shipment of sludge will require
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a manifest from the firm, attesting to the nature of the

materials in the sludge, with special emphasis on the

"toxics" content. An analysis of the supernatant to certify

the quality of the waste treatment has been required in some

areas. Such manifests are required by a number of state

regulatory agencies by now.

C. Leach Test

EPA and ASTM Committee D-19 are developing a leach test to

establish whether or not the sludge should be considered

"hazardous waste". The leach solution used in the test will

simulate the environment anticipated in a sanitary landfill.

By placing a prescribed weight of sample in a jar, together

with a measured volume of the synthetic leach solution,

applying a shaker or stirrer for 24-48 hours, the leach-

ability of the solid waste is estimated. The analysis of

the leach liquor determines the nature and concentration of

the "toxics" that can be anticipated to leach from the

sludge in the landfill. The prescribed leach solution will

contain a buffered organic acid in a slightly acidic pH

range.

In conjunction with the environmental problems experienced

with sanitary landfills, we have discussed the leachability

of the heavy metal-containing sludges. The "leach
366
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test" therefore is expected to indicate that these sludges are

ha2ardous if placed in a sanitary landfill.29
We have recognized many years ago that the heavy metal contami-

nation of leach liquors could be at least partially due to metal

sludges being disposed in landfills. Our research efforts have

indicated that this problem can be easily and economically over-

come by the establishment of "segregated landfills" for the

disposal of heavy metal-containing sludges which at the same time

are free of decomposable organics. Conducting long-range tests

on a private landfill site, established by one of our clients and

with the cooperation of the state regulatory agencies, we have

gained the necessary proof that rainwater will not leach any

significant quantities of metal from these sludges. The data

from our research and practical tests have been brought to the

attention of EPA and the various state agencies.30We anticipate

that by the time the regulatory control procedures, to protect

the environment from sanitary landfill leachates, will be pro-

mulgated, the establishment of "segregated landfills" for metal

sludges, ashes, fly ash, water treatment sludge, etc., will also

be permitted. ASTM D-19 is developing a leach test using dis-

tilled water as leach liquor and we are confident that, as our

research has shown, properly treated sludges will show minimal,

if any, leachability. Subsequently, we intend to explain how we

visualize the design of a typical segregated landfill and the

opportunities that we envision to have such landfill sites

created in the industrialized sections of the nation.
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V. ULTIMATE DISPOSAL OPPORTUNITIES FOR INDUSTRIAL
SLUDGES AND SOLID WASTES

A. Sanitary Landfill

In this discussion on Sludge Disposal Management, we have briefly

described the practical and theoretical background for the suc-

cessful and environmentally acceptable manner in which sanitary

landfill operations can continually be used for the ultimate

disposal of the majority of solid waste generated by households

and industry. We believe that appreciating the principle of the

most common disposal methods, our recommendations regarding

consideration for the sensitivity of each method as the ultimate

disposal means for a particular industrial sludge will be easier

to understand.

1. It is our opinion that the sanitary landfill disposal means

will remain available for the preponderant bulk of discarded

solids and sludges. In view of the past indiscriminant use of

these facilities by some firms, regulatory controls had to be

developed and are in force by now in a number of states. The

implementation of the "Resource Conservation and Recovery Act"

(RCRA) will enforce certain criteria for the sludges generated in

waste treatment efforts. The restrictions concern themselves

mainly with the "toxics" in which list the heavy metals are also

included. Heavy metal contamination being the most frequently

encountered "toxic" in these sludges may push a great variety of

wastes (both sludges and solids), which before the implementation

of the act have not been considered harmful, into the "hazardous"

waste category. Most of the other toxic materials in the list
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have been generally recognized by industry to be potentially

harmful. Perhaps the awareness has been lacking that these

materials should not be deposited in a landfill. We didn't even

discuss the "open dump" practices because, obviously, such dis-

posal sites will not exist in the future.

A variance from the regulatory restrictions may be given for

those landfill sites that collect and treat the leachate before

it is discharged to the environment. Ground contamination and

water pollution from leachate could be potentially also overcome

by collecting, neutralizing, and recycling the leachate back to

the landfill and in this manner overcome the inhibition effect of

the methane formers, improving and accelerating the bacterial

decomposition of waste materials in the landfill.31

2. It is anticipated that the implementation of the Act will

rely to a great extent on the "self-regulatory" effort of the

waste producers. Most likely a "manifest" will have to accompany

all the sludge and possibly even solid waste discard shipments

from industrial sources. As explained, a "leach test" will be

the basis of the determination whether the accumulated sludges

are suitable for the disposal site or not. It is recommended

that those firms which suspect that some of their discarded

solids may be contaminated with any leachable toxic compound

segregate these materials and either wash off the harmful sub-

stance or, if it is a continuously leachable residue, avail

themselves of other disposal means.
369
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3. It is anticipated that untreated liquid wastes, oil, sol-

vents, chlorinated solvents, soluble salts, etc., will not be

permitted to be disposed on sanitary landfill.

B. Incineration

1. Municipal incinerators will be available in some areas for

the ultimate disposal of solids and sludges. We anticipate that

far greater concern will be directed towards the potential air

pollution effect of these incinerators. We have to recognize

that the mounting load of solid waste to be discharged by house-

holds and industry alike, the scarcity of land area available,

the reluctance of nearby residents to accept the establishment of

a landfill, the cost of long-distance hauling, all contributed to

an attitude of needed compromise. At this time the urban need for

solid waste disposal is so acute that the ratio of benefits has

to be considered. To what extent these public incinerator

facilities will be able to accept or handle inorganic, non-

combustible wastes, we don't know.

2. Some industrial concerns manufacturing certain toxic chem-

ical compounds will establish their own incineration facilities.

Some of these chemicals will require high temperature and closely

controlled conditions for complete and safe combustion. It is

anticipated that many of these manufacturers, as a customer

service, will assist their customers and will accept small ship-

ments for combustion in their facilities.
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3. Commercial waste treatment firms are established in various

locations and we can anticipate a growth in this trend. The

business aim of these firms is to accept hard-to-treat liquid

wastes and solid wastes for incineration or secure landfill

disposal. The technical capabilities of the staff to deal with a

variety of unusual wastes, to control and supervise incineration

of hazardous chemicals, etc., clearly indicates the usefulness of

these services for many smaller firms. With proper segregation

of those wastes that require special concern, the economical

burden may not be significant.

C. Fixation and Encapsulation

Technology has been developing through the recent years to reduce

or eliminate the leachinig rate of certain contaminant constituents

of sludge or solid waste. For fixation "Chemfix"* and other

commercial products are available. Care must be taken in the selec-

tion of fixation materials to insure that the solids produced

will be alkaline and thus prevent leaching. Somewhat similar

results can be achieved by mixing the sludge with fly ash and

flue dust or cement, etc., in ratios depending on the water

content of the sludge. The process modifies the homogenous

sludge and creates a pebbly or coarser, chunky residue, somewhat

similar to chunks of concrete. The effect is that the leach

liquor cannot penetrate the interior of the solids and from a

leach effect standpoint, only the outer surface of these chunks

is exposed. Comparing the surface area that has been exposed to

the leach liquor, this modification of the surface area amounts

*Trademark of a proprietary product.

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to a reduction of 1:1,000 or greater in leachability. When the

fixation materials are not affected by certain materials in the

sludge (high concentrations of chlorides or sulfate salts), the

weathering capabilities of the solids can be excellent, so that

one may assume that in a few years all the leachable materials

will have been removed from the outer surfaces and thereafter the

solids will remain as an inert material in the fill.

Encapsulation is a processing method usually conducted by the

commercial waste treatment firms for sludges requiring complete

isolation as a prevention from potentially reentering the environ-

ment. Plastics, concrete, or glass, or a combination of these

have been used. Radioactive waste would be a typical waste

requiring encapsulation.

D. Segregated Landfill

This term has been created to distinguish a landfill created for

the special purpose of receiving only inorganics and non-decom-

posable organics. It pertains to a novel land disposal method

for sludges containing normally inert solids which are affected

and made partially soluble in the organic-acid-containing environ-

ment of sanitary landfill. Landfills of this type may be appli-

cable for industrial sludges containing heavy metals, fly ash,

ashes from combustion, sludges from water treatment plants,

sludges derived from water softening, ion exchange, etc. These

landfills would not require the elaborate preparation, ground

protection, leachate collection, etc., normally required when

designing a sanitary landfill project. A simple limestone
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foundation is suitable.

The segregated landfill could receive any other inert waste or

sludge, but excluded would be decomposable organic materials.

Metal sludges containing significant concentration of sulfides,

such as metal sludges, precipitated as their sulfides, Xanthates

which are organic and contain sulfides should also be excluded.

The reason for this recommended exclusion is that sulfides,

especially under aerobic condition, are converted to sulfuric

acid by bacterial action and may allow an acidic pH to develop.

In our opinon, the use of the "segregated landfill" should re-

quire a similar "manifest" discussed as a most likely future

requirement for sanitary landfill. For metal finishing sludges,

the manifest should contain an analysis report on the supernatant

water, from which the sludge was separated as proof of good waste

treatment control. Otherwise the same self-regulating attention

should be required similar to the proposed control exerted over

sludges to be disposed on sanitary landfill.

VI. TECHNICAL ASPECTS OF THE SEGREGATED LANDFILL DESIGN

Segregated landfill may not be required in certain areas of the

country (arid regions), certain states may continue to permit the

disposal of metal sludges on sanitary landfill, some landfill

operations may be equipped to collect and treat the leach liquors,

while again some other installations may have been equipped to

neutralize and recycle the leach liquor back to the landfill

pile. Judging from present restrictions in force, it is antici-

pated that especially in the northeast and midwest states, this,

373
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or a similar, solution of the problem will be encouraged.

A. Sludge Drying Beds

Some smaller plants with reasonably small quantities of sludge

accumulation may find it uneconomical to reduce the entrained

water in their sludge. Common facilities available for a number

of concerns may allow the installation of a few sludge drying

beds prior to moving the dried sludge into the fill. We have

seen the successful operation of an installation such as this and

operated by the municipal authority of a midwestern city. For a

number of small plants in a community, the availability of such a

service may have tremendous value, yet, if operated for the

community adjacent to the landfill area where the occupation of

the land doesn't create any added cost, the minimal additional

operating costs could be easily borne by the users.

Figure 3 shows the schematic layout of such an installation.

Figure 4 shows a segregated landfill, sludge disposal installa-

tion for mixed metal finishing sludges established on the prop-

erty of the industry generating the waste. As it is evident from

the view, a landfill site such as this can be maintained as an

attractive site with no nuisance conditions to worry about.

B. Description of Design Features

The design of a "segregated landfill" site is not significantly

different from the layout of a sanitary landfill operation. As

mentioned earlier, we don't believe that.a liner of impervious

soil layer would be required, at least we didn't consider it
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would have appreciable environmental protection value. The

sajmple design we show in Figures 5, 6, and 7 has a limestone base

layer and French drain surrounds to allow the monitoring of any

leachate that may percolate through the sludge pile. Experience

indicates that metal finishing sludges plug the soil and do not

allow water percolation. In a system as shown, percolation and

drainage is anticipated only through the side walls. Plugging of

the soil wall is not common; the hydraulic pressure is not great

enough to force the sludge particulates into the soil crevices.

The anticipated drainage follows the capillary channels in the

side walls, especially so when the side wall area is maintained

in a reasonably dry state in view of the under drains.

The bulldozed layers of the leveled-off sludge deposit may have

to be shallower than is the practice with sanitary landfill. We

would assume that a 2' - 3' deep sludge layer would be covered

with two to three feet of soil before the next layer of sludge is

spread. A 3"-4" thick coarse limestone cover on the soil layer

could serve the double purpose of additional assurance of excess

neutralization potential in the event that some not-completely-

treated sludge has been shipped; and, secondly, as an additional

means to stabilize the sludge and allow the safe passage of

earth-moving equipment over it. The "cells" may be designed as

smaller parcels of land; also, the separating soil wall between

the cells would be normally wider than in standard sanitary fills

to allow the collection of the rainwater, seepage and for added

stability of the fill. The accumulating ground water is carried
375
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away by a French drain surround that also allows the periodic

monitoring of the leachate from a sampling sump. The drains

are interconnected and the leachate is discharged to the storm

water system as it overflows the sampling sump.

A modification in the sludge handling practices in areas where

both metal treatment sludges and fly ash have to be disposed

could consider mixing these sludges before or during the landfill

operation. Wet metal finishing sludges, gypsum sludges from

neutralized SC>2 scrub waters (FGD) help to stabilize the fly ash

and this mixing of the two materials may eliminate the need for

sludge drying beds that were discussed under A.

C. Multi-cell Landfill Design for Large Repositories

In some areas of the country, near power plants or large indus-

trial centers, a segregated landfill, less wasteful in land utili-

zation, could be desired. In Figure 8 we show a possible scheme,

retaining all the technical features but reducing the landfill

site preparation and operating costs for those sites where larger

volumes of sludge will have to be handled.

VJI. HOW TO REDUCE THE COST OF SLUDGE DISPOSAL

The anticipated cost of sludge disposal could be very high and

also could be reasonable. The cost will depend on many factors,

many of which are within the control of the particular industry,

and some of which will require the cooperation of the industrial

community, outside assistance gained through political efforts,

etc.
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A. Factors Dependent on The Industry Generating the Sludge

Internal factors have been discussed as part of this lecture.

Illustrative examples have been cited and the determining issues

highlighted. A brief recapitulation of the points that have been

raised would include the following:
1. Have an inventory of all the "toxics" in raw mate-
rials, supplies, manufactured products at your fingertips
and keep referring to this list at each step of your plan-
ning process.

2. Segregate all waste materials that may be considered
"hazardous." If possible, remove the toxic content and
render the solid waste acceptable as landfill or suitable
for incineration if this is the local plan for solid waste
disposal.

3. Closely scrutinize the opportunities for regeneration
and reuse or recovery not only in-house but also by other
industry as a by-product.

4. Consider the pretreatment options also from the stand-
point of the nature and volume of sludge that will be
generated. Consider segregation throughout the treatment
process if economically feasible, to be able to accumulate
segregated sludges, for in-house or outside recovery as a
by-product.

5. Reflect on the most likely available method and nearest
ultimate disposal site that will receive your waste mate-
rials and sludges. Consult with the municipal and state
regulatory engineers regarding the nature and anticipated
volume of wastes and sludges generated.

6. Minimize by segregation the volume of those sludges or
solid wastes that may require shipping to a secure landfill
or would require fixation or encapsulation.

7. Enforce strict adherence to the good housekeeping,
treatment, segregation, and other environmental protection
plan adopted, to avoid jeopardizing the good will, permits
and future acceptance of your waste products.

B. Factors Created by the Local Environment

External factors affecting the cost of sludge disposal will

relate mainly to the availability and distance of the disposal
377
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site under consideration. In the event that no suitable disposal

site is available within a reasonable shipping distance, our

recommendation would be to consider the following alternatives:
1. Discuss your problem with the local municipal authori-
ties, county and state engineers, to find out what their
plans and suggestions are. The local authority and the states
will be charged with the responsibility of conveying to
industry the requirements of the RCRA and the manner in which
the implementation of the Act is envisioned. This may include
EPA Guidelines, State Regulatory Procedures, and local
ordinances.

2. Consider the establishment of a suitable landfill site
on company property. For this purpose it may be advantageous
to purchase a suitable site but only after it is ascertained
that a permit for its intended use would be available from
the state agencies.

3. Discuss the problem with the local industrial associa-
tion, chamber of commerce, industrial development agency,
etc., to establish how many other industrial concerns have
similar requirements and what the total disposal needs are
in the area. The State Office of Solid Waste Management
usually is aware of all landfill operations, where the
nearest sites are located and their availability. If it
becomes necessary to establish a "segregated landfill",
again the assistance of the state agencies could be most
helpful. The sanitary landfill operator may desire a longer
range contract to insure a return on his investment in
developing a special site. A multitude of interested
industrialists can be convincing to establish the need for
such a project and could spread the cost of developing the
site, supervising,* monitoring, and reporting on the safe
conditions, during the time activity is maintained.

4. Consider contracting for the use of a nearby private
disposal site, operated by a local industrial concern. If
this company can be convinced that safe operations will be
maintained, they may consider reducing their own operating
costs by snaring the site.

5. Most likely only licensed haulers will be allowed to
accept and deliver sludges to a landfill site. Contract
discussions with the concerns licensed in the area will
disclose the conditions they plan to stipulate, anticipated
cost factors, etc., and allow multichoice decisions if such
can be made.
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2. Mytelka, A. I., et al., "Heavy Metals in Wastewater
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3. Tarvin, D., "Metal Plating Wastes and Sewage Treatment,"
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5. Oliver, B. G., and Cosgrove, E. G., "The Efficiency of
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11. "Fate and Effects of Trace Elements in Sewage Sludge when
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12. Brande, G. L., Jelnick, C. F., and Corneliussen, P.,
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379
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Bibliography, continued

13. Lazarchik, D. A., "Ultimate Disposal of Sewage Sludge,
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14. "Survey and Study for the NCWQ, Regarding the Technology
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20. Lancy, L. E., "The Fate of Heavy Metals from Metal Fin-
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21. Davison, R. L., Natusch, D.F.S., Wallace, J.R., and
Evans, C.A., Jr., "Trace Elements in Fly Ash -
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22. "Air Pollution Aspects of Sludge Incineration," EPA
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23. Olson, K. W., and Skogerboe, R. K., "Identification of
Soil Lead Compounds from Automotive Sources,"
Environmental Science and Technology 9, 3, 227 (1975).

24. Klein, D. G., and Russell, P., "Heavy Metals: Fallout
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25. Davison, R. L., Natusch, D.F.S., Wallace, J.R., and
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27. Takeda, N., and Hiraoka, M., "Combined Process of Pyrolisis
and Combustion for Sludge Diosposal," Environmental
Sci. & Techn. 10, 12, p. 1147 (1976)

28. Brown, J., Ray, N. J., and Ball, M., "The Disposal of
Pulverized Fuel Ash in Water Supply Catchment Areas,"
Water Research 10, pp. 1115-1121, 1976.

29. Grumpier, E. P., Jr., "Management of Metal Finishing
Sludge," EPA Publications EPA/530/SW-561, 1977.

30. Lancy, L. E., "A Non-Hazardous, Simple, and Economical
Method for the Disposal of Metal Sludges, Using a
Segregated Landfill," Proceedings of the National
Conference on Treatment and Disposal of Industrial
Wastewater and Residue, Apr. 26-28, 1977, Houston, Texas,
published by Technical Transfer, Inc.

31. Pohland, F. G., "Accelerated Solid Waste Stabilization
and Leachate Treatment by Leachate Recycle through
Sanitary Landfills," Progress in Water Technology 7,
No. 3/4, pp. 753-766 (1975)
381
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FINANCIAL STRATEGIES TO ALLEVIATE
THE COSTS OF COMPLIANCE WITH
PRETREATMENT REQUIREMENTS.
PREPARED FOR
ENVIRONMENTAL PROTECTION AGENCY
TECHNOLOGY TRANSFER PROGRAM
PRETREATMENT SEMINARS
ATLANTA, GEORGIA
JUNE 27-28, 1978
URBAN SYSTEMS RESEARCH & ENGINEERING, INC.
1218 MASSACHUSETTS AVENUE
CAMBRIDGE, MASSACHUSETTS

390
-------
"Pretreatment of Industrial Wastes'
Environmental Protection Agency
Technology Transfer Pretreatment Seminars

1978
Financial Strategies to Alleviate the Costs
of Compliance with Pretreatment Requirements
Urban Systems Research & Engineering, Inc.
1218 Massachusetts Avenue
Cambridge, Massachusetts 02138
391
-------
TABLE OF CONTENTS
I. Historical Background of Pretreatment

Introduction
396
Pretreatment

Federal Standards 397

General Standards 397
Proposed Amendment to the General Standard 398
Standards for Specific Industries 399
Local Pretreatment Standards 402

Summary 403
II. Financial Assistance to Alleviate the Costs of
Complying with Pretreatment Standards 404

Income Tax Provisions 404

Two Alternative Tax Treatments 404
Other Considerations 408

Leased Property 408

Short Term Leases 409

Industrial Development Bonds 410
EDA Business Development Assistance 413
Farmers Home Administration — Business and
Industrial Loans 416

Small Business Administration Programs 416

SBA Pollution Control Bonds 418

Indirect Assistance 419

Economic Development Title IX 420
Construction Grants for Wastewater Treatment
Plants
422
Water and Waste Disposal Systems for Rural Com-
munities (Farmers Home Administration) 426
392
-------
Page
III. Financing Strategies for Pollution Control Invest-
ments 429
Some General Comments on Comparing Financing 43Q
Options
Bank Financing 434
Lease Financing 437
/op
Fixed Income Securities
Special Loan Programs 439
Comparison of Financing Strategies: An Example 43g
Strategy 1 — Bank Loan
Strategy 2 — IDE Tax-Exempt Bond 439
Strategy 3 — Lease 440
Evaluating the Bank Loan Strategy 440
Evaluating the Tax-Exempt Bond Strategy 443
Evaluating the Lease Strategy ..0
44o
Comparison of Strategies
448
Conclusion 452
393
-------
LIST OF FIGURES
Figure 1-1:

Figure 1-2:

Figure II-l;

Figure II-2;

Figure II-3;

Figure II-4;

Figure II-5:

Figure II-6:

Figure II-7:

Figure III-l^:

Figure III-2:

Figure III-3:

Figure III-4:

Figure III-5:

Figure III-6:

Figure II1-7:

Figure III-8;

Figure III-9:
21 Industries Subject to Court-Ordered
Toxic Pollutant Analysis

8 Industries for Which Pretreatment
Standards Have Been Developed in Re-
sponse to a Consent Decree

Income Tax Provisions

Industrial Development Bonds

Example of an Industrial Development
Bond

EDA Business Development Assistance

EDA Title IX

EPA Construction Grants

Industrial Cost Recovery Requirements

Calculation of Relevant Annual Cash Flows

Comparison of After Tax Cash Flows of
Two Financing Strategies

Financial Statistics of Representative
Industries

Financing Options Available to XYZ, Inc.

Bank Loan Repayment Schedule @ 12%

After Tax Cash Outflow Due to Loan Re-
payment

Depreciation Calculations for 12 Year
Period

Net After Tax Cash Flows Associated with
Bank Loan Option Using 12 Year Deprecia-
tion

Net After Tax Cash Flow Associated with
Bank Loan Option Using Rapid (5 Year)
Depreciation
400

401

405

411

412

414

421

423

427

432

433

436

441

442

444

445
446
394
-------
Figure III-iQ; Schematic Comparison of Bank Loan Options
«- 447
Figure III-11; Net After Tax Cash Flows Associated with
Tax Exempt Bond 449
Figure III-12; Net After Tax Cash Flow Associated with
Lease

TWENTY-ONE INDUSTRIES SUBJECT TO COURT-ORDERED
TOXIC POLLUTANT ANALYSIS
ELECTROPLATING

INORGANIC CHEMICALS MANUFACTURING

LEATHER TANNING AND FINISHING

NONFERROUS METALS MANUFACTURING

PETROLEUM REFINING

STEAM ELECTRIC POV7ER PLANTS

TEXTILE MILLS

TIMBER PRODUCTS PROCESSING

AUTOMATIC AND OTHER LAUNDRIES

COAL MINING

IRON AND STEEL MANUFACTURING

MACHINERY AND MECHANICAL PRODUCTS MANUFACTURING

MISCELLANEOUS CHEMICALS MANUFACTURING

ORE MINING

ORGANIC CHEMICALS MANUFACTURING

PAINT AND INK FORMULATION AND PRINTING

PAVING AND ROOFING MATERIALS

PLASTIC AND SYNTHETIC MATERIALS MANUFACTURING

PULP & PAPERBOARD MILLS AND CONVERTED PAPER PRODUCTS

RUBBER PROCESSING

SOAP AND DETERGENT MANUFACTURING
400
-------
Figure 1-2
EIGHT INDUSTRIES FOR WHICH PRE'TREATMENT STANDARDS
HAVE BEEN DEVELOPED IN RESPONSE TO A CONSENT DECREE
(Name and Date)
Timber Products Processing 12/9/76
Nonferrous Metals Manufacturing 12/15/76
Steam Electric Power Plants 3/23/77
Leather Tanning and Finishing 3/23/77
Petroleum Refining 3/23/77
Textile Mills 5/26/77
Electroplating —- Phase I 7/12/77
— Phase II 2/14/78
Inorganic Chemicals Manufacturing 7/20/77
401
-------
the 65 toxic pollutants. It is clear that modifications to the
list may result as the Agency develops further information about
toxic substances, and those industries which are primarily re-
sponsible for discharging them.
Prior to the development of standards in response to the
Consent Decree, EPA had promulgated pretreatment standards for
existing sources in 10 industrial categories not on the Consent
Decree list, and for new sources in 13 categories not on the list.
Most of these standards were promulgated with no pretreatment
required because the wastes from these sources are compatible
and treatable by most POTWs. In those cases where limitations
were set they will remain in effect with the possibility of up-
ward revision to reflect BAT.
Essentially, then, the promulgation of pretreatment stan-
dards at this time is proceeding in compliance with court-
ordered deadlines. Substantial and costly impacts to various
industries from these guidelines is quite possible. Consider-
able effort will be required by the Agency to defend and support
industrial standards as they come under judicial review and to
redevelop those standards remanded by the courts.
— Local Pretreatment Standards —
Local governments now have the final responsibility for
designing and administering pretreatment programs. They must
enforce whatever pretreatment standards are necessary to meet
the requirements of their NPDES permits, avoid treatment plant
upsets caused by interference from industrial contribution,
minimize sludge disposal costs, and otherwise protect their sys-
tems from damage.
In setting pretreatment standards, local governments often
receive the assistance of Areawide Management Planning Agencies
established under Section 208 of the Act. Generally pretreat-
ment standards established by a municipality are identical to
the federal standards.
402
-------
Summary

Although the Federal Water Pollution Control Act of 1972

has been amended annually by the Congress, some conclu-

sions about the current status of pretreatment are possible:

• The goal of a pretreatment program is to assure that
the combination of pretreatment and treatment by the
municipal treatment works shall achieve at least that
level of treatment which would be required if the in-
dustrial source were making a direct discharge under
an NPDES permit.

• All firms in all industries are prohibited from in-
troducing prohibited wastes into a POTW.

• Categorical pretreatment standards have been developed
for eight industries on a Consent Decree list of 21
industries which are suspected of discharging any of 65
designated toxic pollutants. EPA's current emphasis is
on toxic pollutant pretreatment standards for these
industries.

• In addition, standards for new sources in 13 industries
and existing sources in 10 industries not on the Con-
sent Decree list have been developed.

• At a minimum, owners of municipal treatment works must
adopt the pretreatment standards of EPA. A modifica-
tion is possible to reflect the capabilities of a
treatment work to handle individual classes of pollu-
tants .

• A state or municipality may promulgate standards more
stringent than that of EPA, given appropriate justifi-
cation.

It is clear that EPA is in the midst of its standard-setting
process for major industries. Especially as the list of toxic
pollutants is expanded, it may be necessary to formulate stan-
dards for additional industries which discharge such pollutants.
403
-------
II. Financial Assistance to Alleviate the Costs of Complying
with Pretreatment Standards
Compliance with pretreatment standards may have strong
economic impacts on affected industries. In addition to the
direct costs of on-site industrial pretreatment processes,
other costs may be:
• user charges paid to the municipality for use of
sewer and treatment works;
• surcharges paid by industrial users whose pollutant
discharge rate or waste strength is greater than
ordinary users; and
• capital costs, representing that portion of the
Federal grant for construction of treatment works
which is allocable to the treatment of waste from
these users.
This chapter is aimed at outlining forms of federal or
other governmental unit financial assistance available for re-
covering a portion of the costs of pretreatment. Such assistance
includes investment tax credits, tax exemptions on development
bonds, loan subsidies, and rapid amortization procedures for
pollution control equipment.
Income Tax Provisions
— Two Alternative Tax Treatments —
Businesses installing pollution control equipment currently
may choose between two methods of income tax treatment. Under the
first alternative, the corporation chooses to depreciate the pollution
control equipment over its taxable income each year for the useful
life of the equipment,1 using any IRS-approved depreciation method,
such as straight-line, sum-of-the-years-digits, or declining balance.•
In addition, the company is allowed to take an investment tax credit
of 10%,2 but the credit may not exceed total tax liability, or $25,000
Asset Depreciation Range System of determining the useful life
of the equipment for depreciation allowances may be used for the poll-
ution control facility. The taxpayer may use a variance from the class
life of not more than 20%, rounded to the nearest half-year. - Sec. 167(m)(1)
2Sec. 46(a)(2)(A), Internal Revenue Code.
404
-------
FIGURE II-l
INCOME TAX PROVISIONS
ALTERNATIVE I:

• DEPRECIATION OVER THE USEFUL LIFE OF THE EQUIPMENT

• 10% INVESTMENT TAX CREDIT (ITC)

ALTERNATIVE II:

• RAPID AMORTIZATION OF EQUIPMENT (60 MONTHS)
• 5% ITC

ALTERNATIVE III: LEASED PROPERTY

• ELIGIBLE PROPERTY MUST HAVE BEEN CONSTRUCTED OR
RECONSTRUCTED AFTER DECEMBER 31, 1961; OR ACQUIRED
AFTER THAT DATE, IF THE PROPERTY HAS NOT BEEN USED BEFORE

• PROPERTY LEASED BEFORE NOVEMBER 8, 1971 IS ELIGIBLE FOR
THE
PROPERTY LEASED AFTER THAT DATE IS ELIGIBLE FOR THE ITC
BASED ON THE TERM OF THE LEASE
405
-------
plus 50% of the tax liability in excess of $25,000, whichever is less.3'4
Should the allowable amount result in unused credit, this excess may be
carried back to the 3 preceding tax years, and the balance still unused
in those years may be carried over to the 7 succeeding tax years.
The unused credit must be used in the earliest of these years and
absorbed to the extent allowed. To qualify for the full investment
credit, the property or equipment acquired must be depreciable, have
a minimum three-year useful life, be a tangible, integral part of the
enterprise's operations, and be placed in operation during the year
for which the credit is sought.6 Structures built to house a necessary
component or which are part of a component qualify for credit, although
a structure built to provide shelter alone ordinarily does not qualify
*
for credit. Related mechanical equipment also is eligible even if
located physically apart from the business seeking the tax credit.
Under the second alternative tax treatment, the firm may elect
to take advantage of the special Amortization of Pollution Control
Facilities through Section 169 of the Internal Revenue Code. The
provision was introduced in 1969 to encourage private enterprise
to cooperate in efforts to cope with the problems of industrial
pollution.
Section 169 applies to a "certified pollution control facility."
This is defined to be a facility completed or acquired after 1968 as
a "new identifiable treatment facility which is used in connection with
a plant or other property in operation before January 1, 1969, to abate
or control water or atmospheric pollution or contamination by removing,
altering, disposing, or storing of pollutants, contaminants, wastes, or heat,
3Sec. 46 (a) (3).
4
Example: On your 1977 return you have a tax liability of $42,500.
Your maximum investment credit is $33,750 (25,000 plus 8,750).
5Sec. 46(b).
6Sec. 48(a)(1).
406
-------
and which has been certified by the state and federal pollution control
authorities as being in conformity with applicable state and federal
regulations." In the case of a treatment facility used in connection
with a plant not in operation before 1969, but in operation before 1976,
g
only a portion of the investment may be rapidly amortized. Thus the
rapid amortiziation provision is clearly intended to aid relatively
older manufacturing operations.
In addition, eligible equipment must not significantly increase
the output or capacity, extent the useful life or reduce the total
operating costs of the plant or other property, nor must it alter the
9
nature of the manufacturing or production process.
If the facilities qualify as outlined above, the taxpayer is
allowed to recover the costs over a 60-month period, instead of over
the longer period provided in Section 167. This 60-month amortization
deduction is limited to facilities with a useful life of no more
than 15 years, or that fraction of the basis of a. facility with a
longer life allocable to the first 15 years. Thus, Section 169
provides the typical cashflow advantages associated with other accel-
erated depreciation provisions found in the code.
However, in addition to taking advantage of the rapid amortiza-
tion provision, the taxpayer may also take advantage of half of the
investment tax credit, or 5%, in the year in which the eligible equip-
ment is purchased. As with the 10% credit, the same limitations to
the credit allowable in any one year apply. In addition, the credit
applies only to equipment with a useful life of at least five years.
7Sec. 169(d)(1).
Q
I.e., only that portion of the investment which is properly
attributable to construction, reconstruction, or erection after
December 31, 1975.
9Sec. 169 (d) (1) (c).
For example, if an eligible facility has a useful life of 20
years, 15/20 or 75% of its costs may be amortized over the 60 month
period. The remaining 25% of the costs have to be depreciated by a
traditional method beginning in the first year. The Asset Deprecia-
tion Range (ADR) System may not be used in determining the useful life
of the facility.
Sec. 46(c)(5), Internal Revenue Code.

407
-------
A proposal is being considered by the Carter Administration
to make both the full investment tax credit (10%) and the rapid
amortization concession available to companies installing pollu-
tion control equipment. This would continue the trend of in-
creasingly favorable treatment for pollution control facilities.
The status of the proposal is uncertain at this time.
— Other Considerations —
The combination of rapid amortization with 50% of the invest-
ment tax credit is intended to make rapid amortization more at-
tractive to industry than previously. However, it has been
shown that rapid amortization is attractive only at very high
discount rates or in cases where the equipment would otherwise
have a useful life greater than twelve years. It is essential
for a firm to undertake its own analysis of the benefits of
rapid amortization relative to other traditional amortization
methods.
Also, use of the Additional First-Year Depreciation (AFYD)
allowance for Small Business (Section 179 of the IRS code)
2
and the rapid amortization provision are mutually exclusive.
In effect, this eliminates a maximum $2000 deduction available
from AFYD.
Leased Property
Pollution control equipment leased by a corporation from
another corporation or a public entity may also qualify for
the full investment tax credit of 10%. This has clear appli-
cation in circumstances such as the following:
Marshall, Charles R. Major Financial Assistance Programs
Available for Industrial Pollution Control Expenditures. Pre-
pared for EPA, June 1, 1977, p. II-4.
2
Ruling provided by IRS Regional Office.
408
-------
• a municipality may receivo >i qrant
from the Economic Development Administration for
a pollution control facility under Title IX of the Public-
Works and Economic Development Act of 1965, as amended.
The municipality may then choose to lease the facil-
ity to a private enterprise, in which case the latter
may qualify for the investment tax credit.
Such an arrangement indicates that a company should
consider a lease arrangement with a municipality
or government entity, which may in turn arrange
the financing for the facility or equipment, whether
via tax-exempt bonds or grants from government agencies.
• Equipment leased from another private corporation
is eligible as well.
Eligible property must have been constructed or recon-
structed after December 31, 1961 or acquired after that date,
if the property has never before been used. You are allowed
the investment credit provided that the owner elects to pass
the credit to you. The credit is computed generally on the fair
market value of the property, whether it was constructed or
purchased by the owner.
— Short Term Leases —
If you leased the property after November 8, 1971, the
amount of credit that can be passed to you by the lessor is
limited if the term of the lease is significantly shorter than
the estimated useful life of the property. Under this rule
your investment for the credit is the fair market value of
the property multiplied by a fraction — the term of the lease
divided by the class life of the property.
In addition, eligible property must have a useful life
(class life) exceeding 14 years and be leased for a period less
4
than 80% of its class life.
1Sec. 48 (b) (1) and (2).
2Sec. 48 (d) (1) (A)
3Sec. 48 (d) (2) (B)
4Sec. 48(d)(4).
409
-------
Jndustriiil jX've.lopment Bonds (Kiquro I [-2)
Industry also may reduce costs for installing pollution
control equipment through a program which permits tax-free
interest on industrial development bonds (IDBs) issued by
state or local governments, even though generally that type of
bond is not tax exempt. (An example of these bonds is given
in Figure II-3).
Section 103 (b) of the Internal Revenue Code governs.
Normally, interest on obligations issued by governmental units
to finance construction of facilities for use by non-exempt
persons — that is, a private commercial or industrial enter-
prise — is subject to federal tax. However, for "any obliga-
tion which is issued as part of an issue substantially all of
the proceeds of which are to be used to provide air or water
pollution control facilities," interest is tax-exempt. In
effect, private borrowers are allowed to use the tax-exempt
market normally available only to governmental agencies.
The net effect is that the bonds should be easier to sell and
carry a lower interest rate. The borrowing costs to the corporation
— interest rates of 5^ to 8% for short to long-term bonds — are nor-
mally superior to those rates available from private lending institu-
tions, or from the sale of corporate bonds. Industrial development
bonds may either be sold publicly to institutional or individual
investors, or privately placed with institutional buyers. The
latter method has the benefit of lower administrative costs
and private placements are issued in substantially smaller dollar
amounts (as low as $25,000) than those which are public issues.
Nevertheless, the necessity of marketing and underwriting the
issue of such development bonds normally limits their use to
other than small businesses, and only the very credit-worthy.
Major U.S. corporations have consistently availed themselves
of this form of financing.
•"-Sec. 103 (b) (4) .
410
-------
FIGURE II-2
INDUSTRIAL DEVELOPMENT BONDS
AUTHORIZATION:
SECTION 103(B), INTERNAL REVENUE CODE
PURPOSE:
ISSUED BY STATE OR LOCAL GOVERNMENTAL

UNITS TO FINANCE CONSTRUCTION OF FACILITIES

BY NON-EXEMPT PERSONS, SUCH AS A PRIVATE

CORPORATION
TAX STATUS:
INTEREST IS TAX-EXEMPT IF THE PROCEEDS FROM

THE BONDS ARE TO PROVIDE WATER POLLUTION

CONTROL FACILITIES
INTEREST RATES: 5^ to 8%, DEPENDENT ON TERM
411
-------
FIGURE II-3

EXAMPLE OF AN INDUSTRIAL DEVELOPMENT _DOND_
All of these securities having been sold, this announcement
appears as a matter of record only.

NEW ISSUES April 13, 1978

$1,300,000

COUNTY OF MIAMI, OHIO
5.90% INDUSTRIAL DEVELOPMENT FIRST MORTGAGE REVENUE BONDS
$2,250,000

CITY OF PULASKI, TENNESSEE
r>.90% INDUSTRIAL BUILDING FIRST MORTGAGE REVENUE BONDS
Dated: April 1, 1978 Due: April 1, 2008
The Project Bonds are issued by, and represent special or limited obligations of,
the Issuers described in the Official Statement and each issue of Project Bonds
is secured by an Indenture granted by each Issuer. Each issue of Project Bonds
is payable us to principal, premium, if any, and interest solely from a pledge or
rentals, revenues ami other income, charges and moneys derived from the lease
of the respective Project, except to the extent paid out of Project Bond proceeds
(iv investment income. The Project Bonds of each issue are unconditionally guar-
anteed as to the payment of principal, premium, if any, and interest by
THE STANLEY WORKS
BLYTH EASTMAN DILLON & Co.
INCORPORATED
412
-------
An industrial firm planning to construct, install, or
purchase pollution control or abatement facilities by this
method must first persuade a local public body or state agency
to issue bonds to cover costs. Then, an interest and principal
repayment schedule is established. Normally, the borrower pays
interest plus principal into a sinking fund during the term
of the financing. This fund is used to repay the bonds. At
the end of the financing period, the borrower purchases the
facility at nominal consideration, or ownership of the facility
may simply revert to the corporation, if the repayment relationship
has been established as an installment sale. During the financing
period the borrower is treated as the owner for tax purposes,
and may take depreciation and investment tax credits.
The Treasury Department has recently proposed to eliminate
the "particular function" exemption for IDBs. Allowing private
borrowers to use the tax exempt market increases borrowing costs
for regular state and local government purposes, and raises the
overall costs of governmental operations, the Treasury has argued.
Final action on the proposal by the House and Senate will
not be completed until mid-1978, and it is unclear how the pro-
posal will fare. Until that time, IDBs should be viewed as
a viable financial vehicle for reducing the costs of compliance
with pretreatment requirements.
EDA Business Development Assistance (Figure II-4)
The Public Works and Development Act of 1965, as amended,
finances business development in redevelopment areas designated
as eligible under the Act at the time the application is filed.
The goal is to encourage expansion in these areas by providing
financial assistance to businesses that create new permanent
jobs, or expand and establish plants. Pollution control equip-
ment is not specifically mentioned in Title II of the Act,
Catalog of Federal Domestic Assistance 1977, p. 84.
413
-------
FIGURE II-4
EDA BUSINESS DEVELOPMENT ASSISTANCE
AUTHORIZATION:
THE PUBLIC WORKS AND ECONOMIC DEVELOPMENT ACT OF

1965, AS AMENDED, PL 89-136
ELIGIBILITY:
BUSINESSES LOCATED IN REDEVELOPMENT AREAS DESIGNATED

AS ELIGIBLE UNDER THE ACT, UNABLE TO MANAGE

CONVENTIONAL FINANCING
TYPE OF
ASSISTANCE:

RANGE AND
AVERAGE, 1977
DIRECT LOANS OR LOAN GUARANTEES

$260,000 to $5,200,000; $1,500,000

- DIRECT LOAN -
TERMS:
25 YEAR MAXIMUM

INTEREST RATES BELOW MARKET
PARTICIPATION:
65% OF THE TOTAL COST OF THE ASSET WILL BE LENT
BY EDA

10% FROM APPLICANTS' EQUITY

5% FROM LOCAL DEVELOPMENT CORPORATION OR STATE
AGENCY

20% CONVENTIONAL

- LOAN OR LEASE GUARANTEE -
COVERAGE:
EDA WILL GUARANTEE:

• 90% OF A CONVENTIONAL LOAN OR,

• 90% OF RENTAL PAYMENTS REQUIRED BY A LEASE
414
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but may be eligible, especially in conjunction with acquisition
of other fixed assets by the firm.
Financial assistance is directed toward those firms which
are unable to arrange assistance from banks or other private
lending institutions. Long term loans up to 25 years at a
specified Treasury rate are available covering up to 65% of the
cost for the acquisition of fixed assets. Ten percent of the
costs must be in the form of applicant's equity; five percent
will normally come from a local development corporation or
state agency; the remaining 20% must be financed by a con-
ventional commercial lender.
In addition, EDA will guarantee up to 90 percent of the
unpaid balance of loans for the acquisition of fixed assets, and
up to 90% of the rental payments required by a lease. The
latter provision clearly applies to an application filed by an
industrial development corporation to establish a facility to
be leased to a user, such as a local business enterprise leading
pretreatment facilities, which it is unable to finance on its own.
Any private corporation is eligible except those which:
• have, within the previous 3 years, relocated any
of their facilities to another city or state;
• contemplate relocating all or part of their existing
facilities with a resulting loss in employment; and
• produce a product for which there is a sustained and
prolonged excess of supply over demand.
Applicants must provide financial, feasibility, and engin-
eering documentation of the viability of the projects; those
projects in excess of $1,000,000 must have an independent feas-
ibility study.
EDA loans are typically large and are oriented toward large
businesses not covered by SBA programs. In 1977, EDA provided
27 business loans and 20 guarantees, ranging from $260,000 to
$5,200,000, with an average of $1,500,000. However, fewer than
415
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five of these were for pollution control.
Farmers Homo Administration -- Business and Indus trial Loans
Authorized by I he Consolidated Farm and Rural Development
Act, as amended, this program is intended to assist, among
others, private profit organizations in rural areas in obtaining
quality loans for the purpose of improving the economic and
environmental climate, including pollution abatement and control.
The applicant must be located in an area other than a city of
50,000 or immediately adjacent areas with a density greater
than 100 persons per square mile; preference will be given to
projects in cities with less than 25,000 population.
Assistance is provided in the form of a guaranteed loan,
or an insured loan from FmHA in those cases where the applicant
and Farmers Home agree that a guaranteed lender is not available.
Not more than 90% of the principal advanced plus accrued interest
may be guaranteed to a lender by FmHA. For both guaranteed and
insured loans, the applicant is required to provide a minimum
of 10 percent equity. Maximum term for either type of loan is
not to exceed fifteen years in the case of the purchase of
machinery or equipment. No fees for the programs are charged,
other than certain application or closing costs.
The financing of pollution control expenditures represents
only a small part of the purpose of the Business and Industrial
Loan program. FmHA encourages borrowers of less than $500,000
to use the SBA, as available funds are currently inadequate.
There were 484 loans under the program in 1976 with an average
of $448,000; however only a very small proportion were for
pollution control.
Small Business Administration Programs
The Small Business Administration is the sponsor of several
additional programs. A company falls within the SBA definition of a small
business provided that it is "independently owned and operated,
416
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is not dominant in its field of operations, does not have
assets exceeding $9 million, does not have net worth in excess
of $4 million, and does not have an average net income, after
federal income taxes for the preceding two years, in excess of
$400,000." Businesses must qualify as well under SBA rules
which set size standards for individual industries.
— SBA Water Pollution Control Loans —
Authorized by the Small Business Act, as amended, Section
7 (g), the objective of this program is to assist small business
concerns likely to suffer substantial economic injury caused
by compliance with standards established by the Federal Water
Pollution Control Act. It is essential that the applicant re-
ceive a statement from the regional administrator of EPA that
the additions or alterations planned by the applicant are neces-
sary and adequate to comply with requirements established under
the Act. Procedures for obtaining this statement are outlined
in 40 CFR 21 concerning Small Business Water Pollution Control
Plans. According to this procedure any small business firm
subject to pretreatment requirements may qualify for SBA assis-
tance.
Assistance in the form of direct loans or guaranteed/
insured loans is available for making additions to or alterations
in equipment, facilities (including specifically pretreatment
facilities), or methods of operation. Loans are limited to
$500,000 unless substantial hardship is proven, with a maximum
term of 30 years. The SBA share of guaranteed loans may not
exceed 90 percent.
To qualify for a direct loan from SBA at 6 5/8% interest
2
for 30 years, the applicant must demonstrate substantial injury,
meaning in effect an inability to obtain conventional financing,
Environmental Reporter — Current Developments, Bureau of
National Affairs, Vol. 7, #40, February 4, 1977, p. 1485.
2
However, typical repayment is about 15 years.
417
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cither because of insufficient collateral, excessive interest
or an excessively short repayment term. A supporting letter
from a bank is necessary. Because conventional lenders are
allowed to charge 10% interest for SBA guaranteed/insured
loans, direct loans from the SBA are clearly preferable.
In the past, virtually all loans have been direct loans
from SBA, rather than guaranteed loans obtained from a bank.
The range of financial assistance (25 loans) in fiscal 1976
was $6500 to $400,000, with an average of $236,000.
— SBA Pollution Control Bonds —
As a result of an amendment in 1976 to the Small Business
Act, a nationwide program is now underway to help small busi-
nesses finance installation of pollution control equipment
with tax-free municipal bonds. It is hoped that small businesses
will have access to capital markets similar to large companies
which finance pollution control facilities through tax-free
industrial development bonds.
Financing rates for loans from the proceeds of sales of
the bonds are currently 6*2% or less and the loans may run
as long as 25 years, if their repayment is to be guaranteed by
SBA. Ten-year loans in the commercial market would range
from 9 to 14%, so the savings are considerable.
A public entity — probably the state -- issues the tax-
exempt revenue bonds for industrial pollution control projects.
The business receiving the loan from proceeds of the bond signs
a contract for making payments to the public entity and a
trustee for the entity uses those funds to pay bond holders
and make redemptions. Essentially, SBA guarantees these small
business payments to the municipalities or state agencies.
This may vary by state.
418
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It is also possible for the municipality to construct the
pollution control facility, and in turn receive lease payments
from the firm, similar to the IDBs discussed earlier. In this
case, SBA guarantees the lease payments.
Because of the substantial risk involved in a 100%, 25-year
SBA guarantee of the bonds, applicants must have been in business
a minimum of five years and have a history of profitable opera-
tions on average over the last five years. Applicants must pro-
vide evidence of the need for the control facility or equipment
(40 CFR 21). It is expected that the program is most suited
to projects costing more than $100,000, according to the SBA.
In addition, the firm must be sponsored by a bank, in that the
bank renders or provides supporting documentation; however/ no
other obligation is imposed upon the bank.
A final requirement is the guarantee fee, which is currently
set at 3*5% per annum of the minimum annual guaranteed payments
under a qualified contract. This high rate may substantially
reduce the attractiveness of the program.
The first bond issued in California covered the pollution
control financing needs of an apple growers cooperative, a leather
tanning company, a manufacturer and distributor of cheese and
milk products, a timber business, a nonprofit agricultural
cooperative, a metal plating works, and a copper and bronze
scrap smelter/refiner. Generally, the financing needs of several
companies in the state will be combined in such an issue.
By the end of 1978, the program should be available in New
York, Illinois, Pennsylvania, Arkansas, Ohio and Missouri.
Indirect Assistance
This section discusses programs which do not provide aid
directly to businesses, but rather assist governmental units or
political subdivisions in construction of facilities required
to meet state and federal water quality standards. These fa-
cilities may in turn be made available to industrial users,
419
-------
either on a leased basis or through an appropriate system of user
charges. Leasing of a facility by a business enterprise clearly
may have more favorable financial implications than if a firm
were to wholly finance and construct the facility. However,
none of the programs is specifically geared to industries
meeting pretreatment requirements.
--Economic Development Title IX — (Figure Il-b)

Title IX of the Public Works and Economic Development Act of
1965, as amended, is designed to assist states and local areas develop
or implement a comprehensive program of adjustment to an actual or
threatened economic dislocation,such as that precipitated by
compliance with environmental requirements,which threatens to remove
economic activities from a locality.
To be eligible, an applicant must be a redevelopment area or
economic development district established under Title IV of the Act,
a State, a city, or other political subdivision of a state, or a
consortium of such political subdivisions. The smallest entity
deemed capable of dealing effectively with the problem will normally
be the proper applicant.
The basic grant rate may be up to 50 percent of the project cost,
with severely depressed areas eligible for contributions up to 80
percent of the project cost. Long-term (up to 40 years), low-interest
loans may be made to the applicant when financial assistance is not
otherwise available from private lenders or Federal agencies on rea-
sonable terms.
It should be emphasized that Title IX is an indirect means of
financing facilities required to meet pretreatment standards, insofar
as a governmental entity is the applicant for and recipient of the
grant and is responsible for constructing the required facilities.
In turn, the affected business must develop some type of contractual
arrangement which will allow it to lease or otherwise use the facility.
Other more direct means of complying with pretreatment standards
clearly preferable.
420
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FIGURE II-5
- EDA TITLE IX -
AUTHORIZATION:
PUBLIC WORKS AND ECONOMIC DEVELOPMENT ACT OF 1965,

AS AMENDED
OBJECTIVE:
TO PREVENT AN ECONOMIC DISLOCATION SUCH AS THAT

RESULTING FROM COMPLIANCE WITH EPA STANDARDS
APPLICANTS:
POLITICAL SUBDIVISIONS, REDEVELOPMENT AREAS, OR

ECONOMIC DEVELOPMENT DISTRICTS
TYPE OF ASSISTANCE: LOW-INTEREST LOANS
TERMS:
OF PROJECT COST

• MAXIMUM 40 YEARS

• AVERAGE 6% INTEREST RATE

AN AFFECTED INDUSTRY WILL HAVE TO ARRANGE TO LEASE

OR USE THE FACILITY CONSTRUCTED.
421
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- Construction Grants for Wastewater Treatment Works-1- - (Figure II-6)
Previous papers in this seminar have extensively discussed
the methods by which industry may effectively utilize the con-
struction grant program, and thus, its description here will be
brief. Authorized by Title II of the Federal Water Pollution
Control Act, the objective of this program is to assist and serve
as an incentive in the construction of municipal sewage treatment
works by providing project grants to any municipal, intermunicipal,
state, interstate agency or Indian tribe having jurisdiction over
disposal of wastes. Proposed projects may serve all or portions
of individual jurisdictional units, and may include, but may not
be limited* to, treatment of industrial wastes.
Although primarily intended to aid municipal or other local
governments, there are some provisions within the construction
grant program which may be of assistance to industry. For example,
a grant recipient must require pretreatment of any industrial
wastes which would otherwise be detrimental to efficient opera-
tion and maintenance of the facility. This may actually be of
advantage to local industries, for if the publicly-owned treat-
ment works is designed to remove or reduce a portion of industrial
waste otherwise subject to pretreatment requirements, then pre-
treatment requirements for the industrial user can be reduced
accordingly. Industry would then be spared the financial burden
of constructing a pretreatment facility to handle its own wastes.
The industry would still be subject to user charges based on its
use of the municipal facility, but such charges would presumably
be advantageous in relation to direct financing of a company-
owned facility.
Design of a municipal treatment works to eliminate a particular
company's pretreatment requirements obviously implies close co-
ordination between the municipality and the affected industry.
There is a clear degree of uncertainty to such an indirect form
of assistance - as with the previous program discussed - and the
direct forms of financial assistance should be utilized if at all
possible.
Catalog of Federal Domestic Assistance, 1977, p. 817
422
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FIGURE II-6
- EPA CONSTRUCTION GRANTS -
AUTHORIZATION: TITLE II OF THE FEDERAL WATER POLLUTION CONTROL ACT
APPLICANTS:
GOVERNMENTAL UNITS HAVING JURISDICTION OVER DISPOSAL

OF WASTES
LIMITATIONS
• A PROJECT MAY INCLUDE INDUSTRIAL USERS, BUT MAY MOT

BE LIMITED TO THEM

• INDUSTRIAL USER CHARGES AND PRETREATMENT STANDARDS

ARE REQUIRED

INDUSTRY COOPERATION WITH THE APPLICANT AGENCY MAY RESULT

IN A TREATMENT PLANT DESIGNED TO TREAT THE INDUSTRY'S

WASTE, THUS OBVIATING PRETREATMENT REQUIREMENTS.
423
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- Industrial Cost Recovery - (Figure 11-7)
AH a condition for receiving UK- Wastewater Treatment Plant
Construction Grants under the Federal Water Pollution Control Act Amend-
ments of 1972 (PL 92-500), EPA requires that municipalities es-
tablish industrial cost recovery schemes, which insure that par-
ticipating industries pay their proportionate share of the capital
costs supported by Federal funds. The congressional intent of
this provision is that "it is inappropriate in a large federal
grant program providing a high percentage of construction funds
to subsidize industrial users from funds provided by taxpayers at
large." Thus industrial users are to pay for that portion of
construction costs of the treatment plant allocable to the treat-
ment of their wastes.
The capital costs, without interest, are repaid over the
ueful life of the facility or thirty (30) years, whichever is
shorter. ICR is applicable only to the Federal share of the con-
struction costs, usually 75%; however, states or localities may
enact laws to recover their share of the costs as well. For this
state or local portion, interest may be charged by the POTW, unless
the funds have been provided as an outright grant by the State to
the municipality.
Significant users — those firms planning to use 10% or more
of the design capacity — must sign letters of intent, indicating
a willingness to meet ICR payments. However, proportionate ICR
payments are computed for all, and not just the significant users.
A typical scheme is to allocate the costs covered by the Federal
grant among the various components of the wastewater, such as sus-
pended solids or biochemical oxygen demand, resulting in a cost per
unit quantity for each pollutant. A company's discharges are mul-
tiplied by these unit costs to obtain the capital cost allocation
to be charged to the industry over the life of the facility. In
•"-Sec. 204 (b) (1) (B) .
424
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addition to wastes, uncontaminated roolinq water is covered by
1CR requiremontr, as well, even though treatment is not required.
In the absence of the allocation scheme outlined above, the
basis for estimating ICR payments is the company's effluent volume,
regardless of composition. Once the ICR rate has been computed,
by whatever means, each industry may choose between fixed payments,
reflecting reserved capacity, or variable payments, which are
based on maximum flows during four-week peak periods. In addition
to reserving treatment capacity for current use, industries may
reserve some portion of the treatment work's excess capacity to allow
for capacity expansion on their part. Constant annual payments are
required for this reserved excess capacity, with these payments
not affected by actual discharges. The portion of the treatment
works' excess capacity not reserved is excluded from ICR payments.
Further, if one or more industrial users leave, they are no longer
responsible for ICR payments, nor are continuing users required to
pick up these costs.
In February 1976, EPA issued guidelines which recommended a
more complicated component-by-component approach to computation of
ICR payments. According to this approach, the costs for each
major component of the treatment facility, such as the pump station,
grit chamber, sludge digester, or sludge dewaterer are computed
for each pollutant. The guidelines also recommend that each ICR
system provide a mechanism for industries to appeal the amount of
ICR payments that they have been assessed.
In response to strong complaints by many municipalities,
the 1977 Clean Water Act authorizes EPA to exempt from
ICR requirements any industry with a flow less than 25,000 gallons
per day of sanitary waste. The 1977 Act also proposes a moratorium
on the ICR payments from January 1, 1978 to June 30, 1979, so that
EPA may study the requirement further. Any ICR obligations in-
curred by industry during this period will become due at the end
of the moratorium period, unless Congress acts otherwise.
ICR has been classified as a form of financial assistance —
albeit indirect — even though industries, because of the requirement
Federal Guidelines - Cost Recovery Systems. EPA, MCD-45, 2/76,
rev. 8/76.
425
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to pay their share of POTW costs may be paying considerably more
than in the years before the Federal Water Pollution Control Act.
Yet ICR is a form of assistance for the following reason.
To meet effluent limitation guidelines, a company which chooses
ho directly discharge its wastes would most likely experience
much higher costs than if they choose to discharge to a POTW. A
direct discharger must purchase capital equipment and pay interest,
or an opportunity cost. While the indirect discharger is also
assessed capital costs, there are presumably scale economies for
a treatment facility designed to handle many more users than the
one firm, and, in some cases, also designed to handle the wastes
of particular industries, thus removing the pretreatment require-
ment for these industries. Also, in many cases, the company
need only repay on 75% of the capital costs of the treatment works,
representing the Federal portion. The exclusion of interest pay-
ments on the company's portion of the POTW's capital costs is an
implicit subsidy.
2
— Water and Waste Disposal Systems for Rural Communities
(Farmers Home Administration) - -
This program is similar to the EPA VJastewater Treatment
Construction Grants just discussed. It is authorized by Section
306(a) of the Consolidated Farms and Rural Development Act to
provide wastewater facilities for public use in rural areas
and in towns up to 10,000 people. While both guaranteed/
insured loans and grants are available, normally only loans
have been approved. Maximum term is 40 years, currently at
5% interest. Eligible applicants include municipalities,
counties, and other political subdivisions, as well as cooper-
atives and non-profit corporations.
This assumes that the POTW is cost-effective.
2
Catalog of Federal Domestic Assistance 1977, p. 32.
426
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FIGURE II-7_

Industrial Cost Recovery Requirements
Authorization:
Objective:
Applies to:
Type of Assistance:

Terms of Industry
Payments:
Federal Water Pollution Control Act of
1972, Section 204(b)(1)(B)

To assure that beneficiaries of wastewater
treatment pay their share of the service

All those industries discharging more than
25,000 gallons per day of waste to a POTW

Indirect subsidy

• Based on flow and specific composition
of industry's waste
• Based only on Federal share of capital
costs, or 75%

• Payment over 30 years or useful life

• No interest
427
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While facilities must primarily serve residents, industrial
users in the service area may be included in the facility design.
As in the EPA Construction Grants Program, cooperation between
local firms and the applicant may result in appropriate design
of a facility to significantly reduce or eliminate the firm's
pretreatment requirement. The firm must still pay a share of
wastewater treatment costs representing industrial repayment
of a portion of the FmHA loan. However, unlike the EPA program,
firms with large wastewater flows are given bulk discount rates
under the loan repayment/user charge formula.
428
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III. Financing Strategies for Pollution Control Investments
When a firm is faced with the need of acquiring some major
piece of equipment or with expanding its facilities, the usual
procedure is to forecast, as well as possible, the cash require-
ments for this investment and then to establish the best means
of securing the required funds. Assuming the firm has had a
history of sound management and is not trying to expand too
rapidly, there is usually no problem in securing the required
capital. However capital comes in many forms — long-term as
well as short-term debt, secured and unsecured debt, equity
capital, either in the form of retained earnings or new stock
issues, and hybrid instruments such as convertibles and capital
leases — and the firm must decide which mixture of these alter-
native sources of capital is most appropriate for its needs.
This of course is a standard financing decision and every company
has its own way of dealing with it. However, when the invest-
ment involves pollution control equipment, special provisions
and assistance programs specifically designed to reduce associated
financing costs can be utilized. With the advent of these special
pollution control incentives, there are not only new sources of
Hinds available, but also preferred treatment and lower than normal
rates for most sources of financing. Consequently, when making
investments in pollution control facilities such as pretreatment
plants, a firm should modify, or at least reevaluate its usual
approach for securing financing so as to take full advantage of
the various options available to it.
The purpose of this chapter is to illustrate how a company
can evaluate the financial assistance alternatives described in
Chapter II vis-a-vis its specific goals and needs. It should
be clear from the outset that no two firms, even if they ore in
the same industry, face the same financial problems or share
the same management objectives. Hence it is impossible to devel-
op a universal prescription for identifying the optimal financing
strategy for pollution control investments. Rather, our intent
429
-------
is to develop an analysis which a hypothetical firm might perform
in comparing alternative financing options. This hypothetical
analysis serves two functions. First, it may be viewed as a
prototype which, with suitable modifications, can be used by
real companies for developing their own financing strategies;
and, second, it highlights the basic trade-offs between the
different financing options. We start with the premise that
firms are operating in an already established mode. They have
certain goals with respect to profits, earnings per share,
dividends per share, growth, etc. and their overall financial
structure and policy is based accordingly. Our primary concern
will be to address the question of how to optimally finance
the acquisition of pretreatment facilities within this already
existing financial framework.
Some General Comments on Comparing Financing Options
Before we get into a discussion of financing strategies
for pollution control investments, some general comments on
comparing financing strategies are in order. Suppose a firm
acquires a piece of equipment either by purchasing it or leasing
it. What are the financial impacts of this acquisition? Pre-
sumably this new equipment will in some way enhance the produc-
tive capabilities of the firm and hence generate additional
revenues or reduce operating cost. Whatever that aspect of
the impact is, it is the same regardless of how the equipment
is acquired and is therefore irrelevant to the financing de-
cision.
The acquisition of the equipment also obligates the firm
to make certain payments over a prescribed period of time. For
example, if the equipment is purchased in its entirety through
a five-year term loan, the firm may have to make 60 monthly
payments to repay the loan. Of course the interest portion of
the payments is tax-deductible,thereby reducing the income taxes
the firm has to pay; the equipment may also qualify for an
430
-------
investment tax credit, further reducing the payments. Depre-
ciation can also be charged against taxable income yet further re-
ducing taxes. On the other hand, if the equipment is acquired
through a ten-year lease, the relevant cash flow impact would be af-
ter-tax lease costs. Figure III-l illustrates, using a typical income
statement format, how the annual cash flow associated with a financing
option can be calculated. The key point is that every available
option for acquiring the equipment has associated with it a sequence
of cash flows spread over some period of time. Choosing the
optimal financing strategy corresponds to choosing the most
attractive sequence of cash flows and is illustrated schematically
in Figure III-2. The arrows in the figure represent annual after-
tax cash flows associated with financing the equipment, and
for simplicity, are shown here as being the same every year.
How should a firm choose between a five-year sequence of
cash flews of, say, $50,000 each and a ten-year sequence of
$30,000 each. The first sequence involves less total money
($250,000 vs. $300,000), but the second sequence spreads the
burden and is a smaller annual cash drain. Of course there
are some standard methods of making the comparison, for example
the "net present values" or the "internal rates of return" of
the two sequences, but these approaches only capture one aspect
of the comparison and are, from a practical point of view, not
entirely satisfactory. For example, a company which anticipates
substantial growth and hence large working capital requirements
would probably opt for a long-term financing option which would
minimize annual cash outflows. On the other hand, a firm which
anticipates cash surpluses in the future would prefer a short-
term loan, typically available at lower rates than long-term
debt, in anticipation of retiring the lean rapidly. A growth
company would probably rely heavily on retained earnings as a
source of equity financing while a more mature firm might be
more concerned with stable dividends and hence borrow more
heavily. A company anticipating low earnings might choose to
lease rather than buy equipment in order to transfer tax benefits
to the lessor, who could utilize them more advantageously and,
431
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in return, offer attractive lease terms. Clearly the choice
between financing alternatives must be highly individualistic.
The basic options available to the firm are whether to buy or
lease the equipment; in the case of purchase, the mix of retained
earnings, short-term debt, and long-term debt used to finance
the investment; and, for the long-term debt, the choice of debt
instrument and maturity period. Often the range of realistic
options is much more limited as in the case of a growing firm which
has reached the limits of its debt capacity and can only obtain
additional debt financing by matching it, at an appropriate ratio,
with the infusion of new equity capital.
Comparison of financing strategies for pollution control
equipment is essentially identical to comparison of financing
strategies for any capital investments, as described above.
The only difference is that the after-tax cash flows associated
with financing pollution control investments may differ from
those for financing ordinary investments as a result of utilizing
the special investment incentives described in Chapter II. In
what follows we will evaluate a hypothetical investment in a
pretreatment plant and compare a number of financing strategies.
Before we do this, however, we will briefly review the various
financing options which are available.
Bank Financing
Usually when a firm needs money, they call their banker.
Financing from commercial banks can be short-term (less than
a year) or long-term (maturity from one to five years), and
even longer term debt can be obtained from insurance companies
and pension funds. The key aspect of negotiating such a loan
is the repayment schedule, i.e., the rate of interest, the length
of the loan (maturity), and the number and size of payments.
The principal and interest are usually paid off in a sequence
of equal installments, with the interest portion of the payment
being computed on the remaining principal of the loan. If for
434
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example, a firm borrowed $200,000 at 10% interest and repaid this
loan in five equal annual installments, the annual payments would
be $52,757 for a total repayment of $263,785. Some commercial
banks across the country have announced preferential rates and
terms for certified pollution control facilities. However, since
these bank programs are quite random, normal installment bank
financing rates and terms will be used in this analysis.
Occasionally a firm will finance the investment entirely
through bank loans, but more frequently the loan will only con-
stitute partial financing with the balance of the funds coming
through in the form of retained earnings. The use of retained
earnings may reflect the companies' desire to maintain a particu-
lar debt to equity ratio in its overall financial structure, or
may be a requirement imposed by the bank. In any case, the
intent is to keep the total financing of the investment in line
with the debt to equity ratio appropriate for that firm. As
is shown in Figure III-3, these ratios vary substantially between
as well as within industries. If, for example, a firm's debt
to equity ratio is 1.0, it would have to finance 50% of a $200,000
capital expenditure, i.e., $100,000, through equity capital in
order to maintain this ratio. One of the implications of this
is that regardless of how a particular project is financed,
the cost of the financing should be computed as the weighted cost
of equity and debt (the cost of capital) for the firm.
If a company uses bank financing for pollution control equip-
ment, it may be able to reduce the cost of this financing by
using the rapid amortization provision of Section 169 of the
Internal Revenue Code. As described in Chapter II, this pro-
vision allows the company to fully depreciate the equipment in as
little as 60 months. However, if a firm chooses to use this op-
tion it can only claim a 5% investment tax credit during the
year of purchase, rather than the usual 10%.
435
-------

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Lease Financing
Financial leases provide an alternative to bank financing.
A strict financial lease is one that does not provide for main-
tenance services, is not cancellable, and is fully amortized
(that is, the lessor receives rental payments equal to the full
price of the leased equipment). Leasing involves outside own-
ership of the equipment, usually by an insurance company or commer-
cial bank, but permits the company to use the equipment for fees
which are expensed for income tax purposes. In the past, one
of the major attractions of leasing was the fact that it allowed
a company to avoid showing long-term debt on its balance sheet.
However under a recent ruling by the Financial Accounting Stan-
dards Board long-term financing leases must be shown as liabil-
ities on the balance sheet.
Leasing may also be attractive when companies cannot benefit
fully from tax credits and deductions and therefore transfer
these benefits to a lessor in return for favorable lease rates.
However the Internal Revenue Service has issued many rules which
must be adhered to for a leasing arrangement to be a true lease
and not a disguised sale. Two rules are most critical for pollu-
tion control. At the termination of the lease, it must not be
impossible or impractical for the lessor to remove the property.
Secondly, where property is acquired specifically for the lessee,
the IRS may contend that the property has no value to anyone
other than the lessee at the end of the term, thus encouraging the
lessor to abandon the property to the lessee. These are severely
limiting restrictions as far as pollution control leasing is
concerned.
On the other hand there are some incentives for using lease
financing for pollution control. As pointed out in Chapter II,
a municipality may lease a pollution control facility to a pri-
vate enterprise in which case the latter may qualify for the as-
sociated investment tax credit. In other words, a municipality
437
-------
can use low cost financing such as tax-exempt bonds for financing
a pretreatment plant, and yet a private company, through a lease
agreement with the municipality, can reap some of the tax bene-
fits associated with such an investment.
Fixed Income Securities
A firm can raise debt financing through various fixed in-
come securities such as bonds, mortgages, debentures and pre-
ferred stock. A discussion of the advantages and disadvantages
of these instruments goes beyond the scope of this document.
Suffice it to say that these instruments commit the firm to a
sequence of cash flows which, in choosing a financing strategy,
can be compared to payments on term loans or lease payments.
One particular type of bond, the Industrial Development Bond
(IDE), is available for financing pollution control investments
at rates superior to conventional corporate bonds. Once a state
declares that pollution control, or industrial development,
serves a public purpose, equipment can be financed with the pro-
ceeds of IDBs issued by a municipality or quasi-governmental
agency. Because investment in these bonds is tax-exempt, they
can be sold at an interest rate as much as 25% less than pre-
vailing rates on comparable corporate bonds.
However, the substantial flotation costs associated with
the public sale of bonds significantly reduces the financial
advantages to a firm choosing this financing alternative. Given
these constraints, the size of a proposed issue will often
determine the ultimate feasibility of actually going to market
with the issue. Bond underwriters are seldom interested in
placements of less than $750,000, and this factor could limit
a number of firms' ability to use this alternative. Some states
have arranged for a number of private placements. The costs
associated with this type of placement are significantly lower
than a public issue, but the size of the borrowing may still
impact a firm's decision to issue or seek an alternative source
of funds.
438
-------
Special Loan Programs
The Small Business Administration (SBA) as well as the
Economic Development Administration (EDA) have special loan
programs for firms which encounter difficulty securing necessary
funds through conventional financing. However since these loans
represent "last resorts" rather than financial strategy options,
they are not considered explicitly in our subsequent analysis.
Both types of assistance are discussed more fully in Chapter II.
Comparison of Financing Strategies; An Example
XYZ, Inc., a manufacturer of machinery and machine parts,
has decided to install a new $200,000 pretreatment facility
in its production plant. The company has explored a number of
financing possibilities and has narrowed the choice down to
three alternative strategies.
— Strategy 1 — Bank Loan
XYZ, Inc. is a financially sound and well managed company
which enjoys good relations with its bank. The bank has agreed
to lend it the entire $200,000 at a 12% annual rate, with the
loan being repaid in equal installments over a five year period.
(If XYZ takes this strategy, they will probably finance part
of the investment with retained earnings and only borrow the
balance of the funds. But this will reduce the retained earn-
ings available for other investments and require additional
borrowing for those projects. Consequently, for analysis pur-
poses it can be assumed that, one way or another, $200,000 will
be borrowed as a result of the decision to construct the pre-
treatment facility.)
— Strategy 2 — IDE Tax-Exempt Bond —
The municipality in which the XYZ plant is located has in-
dicated its willingness to issue a tax-exempt industrial devel-
opment bond for the pretreatment facility. The bond would have
439
-------
a ten year maturity and pay annual coupons at 10%. However the
bond would have to be sold at a 7% discount of face value and
also requires a 3% flotation fee. In order to cover this ad-
ditional expense, the size of the issue would be set at $220,000.
— Strategy 3 — Lease —
As an alternative to the bond, the municipality has offered
to finance the treatment facility and lease it to XYZ, Inc. for
a fifteen year period (the approximate useful life of the facility)
for annual lease payments of $30,000. XYZ, Inc., can take ad-
vantage of the 10% investment tax credit under this arrangement.

The important features of these three options are summar-
ized in Figure III-4.
Under the first two options, XYZ, Inc., is the owner of the
pretreatment plant and can therefore take advantage of the rapid
amortization available for investment in pollution control equip-
ment. Under this provision they can fully depreciate the
equipment (for tax purposes) over five years and still receive
a 5% investment tax credit. Alternatively, they could depreci-
ate over 12 years, as they do for most of their other eauio-
ment, and take the full 10% investment tax credit. In either
instance XYZ plans to use a combination of double-declining ba-
lance and sum-of-year digits depreciation methods. The company
is currently subject to a 48% marginal tax rate and has a 15%
cost of capital (hurdle rate).
Evaluating the Bank Loan Strategy
Repayment of the $200,000 term loan at 12% results in five
annual payments of $55,480. The details of the repayment
schedule are shown in Figure III-5. The interest portion of
the payments is, of course, tax deductible reducing the actual
after-tax cash outflow by 48% of the interest. This calcula-
tion is shown in Figure III-6. if XYZ uses its normal depreci-
ation and tax credit, it obtains a 10% or $20,000 reduction in
440
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Figure III-4
FINANCING OPTIONS AVAILABLE TO XYZ, INC.
Option
Terms
1. Bank Loan
12% annual rate
5 year repayment
2. Tax-Exempt Bond
• $220,000 issue sold at
7% discount
• 3% flotation cost
• 10% annual coupon rate
• 10 year maturity
3. Lease
• $30,000 annual payment
• 15 year term
• 10% investment tax credit
441
-------
Figure III-5

BANK LOAN REPAYMENT SCHEDULE @ 12%
Year Payment
1
2
3
4
5
*
$55,480
55,480
55,480
55,480
55,480
$277,400
Interest Principal
$24,000 $31,480
20,222 35,258
15,991 39,486
11,253 44,227
5,936 49,546
$77,400* $200,000*
Remaining
Balance
$168,520
133,262
93,773
49,546
0

Due to roundoff in the calculations the col-
umns may not add precisely to the amounts
indicated
Figure III-6

AFTER-TAX CASH OUTFLOW DUE TO LOAN REPAYMENT
Year
1
2
3
4
5
Payment
$55,480
$55,480
55,480
55,480
55,480
tax deduction
@ 48% of interest
$11,520
9,707
7,676
5,401
2,849
Net cash
outflow
$43,960
45,773
47,804
50,079
52,631
442
-------
taxes during the first year and can also deduct the depreciation
on the $200,000 from its taxable income for the
first twelve years. Under the double-declining balance method
of depreciation for the first year and sum-of-years digits for
the remaining 11 years, the depreciation schedule and associa-
ted tax savings can be calculated as shown in Figure III-7.
Combining these tax savings with the $20,000 investment tax
credit during the first year results in the cash flow pattern
shown in Figure III-8.
If, on the contrary the rapid amortization strategy is used
for the bank loan, the first year investment tax credit is
only 5% or $10,000, but the $200,000 can be depreci-
ated over five years. The resultant depreciation tax savings
are shown in Figure III-9. A schematic comparison of these
two alternatives is shown in Figure III-10 and clearly reveals
the superiority of rapid amortization for XYZ, Inc. This is
reinforced by the net present value (NPV) calculations for tne
two depreciation alternatives which shows that with the firm's
cost of capital at 15% the 12 year depreciation has an after-
tax NPV of $-88,290 while the rapid amortization has an NPV of
$-78,750. (The minus signs denote net outflows of cash.)
Evaluating the Tax-Exempt Bond Strategy
As the previous analysis indicated, the rapid amortization
of the pretreatment facility is superior to the usual 12 year
depreciation. We will therefore use this form of depreciation
in evaluating the bond strategy.
With the tax-exempt bond, the annual coupon payments of
$22,000 (10% of the bond's face value) are tax deductible
yielding annual tax savings of (48% x $22,000) = $10,560 per
year over a ten-year period. The 3% flotation cost is also a
tax deductible expense yielding additional savings of (3% x
$220,000 x 48%) = $3,168 in the first year. However, at the end
of the tenth year, XYZ must redeem the bond, which results in a
443
-------
Figure III-7

DEPRECIATION CALCULATIONS FOR 12 YEAR PERIOD

Yoar Depreciation*($000) Tax Savings @ 48% ($000)
16.00

13.33

12.11

10.91

9.70

8.49

7.28
6.06

4.85

3.64
2.43

1.21
*Depreciation in year 1 is calculated as double the
straight line depreciation of the investment; i.e.

$200,000

For years 2 through 12, the sum-of-years digits are
applied to the remaining balance of $200,000-$33,333.
In year 2, for example, this yields

11
1+2+3+4+5+6+7+8+9+10+11 X
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4
5
6
7
8
9
10
11
12
33.33
27.78
25.22
22.72
20.20
17.68
15.16
12.62
10.10
7.58
5.06
2.52
444
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non-tax deductible cash outflow of $220,000 in addition to the
coupon payment. (The firm would probably refund the bond rather
than redeem it, but for comparison purposes we will view this as
a $220,000 obligation.) Combining these cash flows with the tax
bonofits of rapid amortization results in the cash flow pattern
.shown in Figure III-ll.
Evaluating the Lease Strategy
Under the leasing strategy XYZ makes annual after tax
payments of (48% x $30,000) = $14,400. The company cannot
depreciate the equipment (since it doesn't own it), but it
can take a 10% ($20,000) investment tax credit. The resultam:
after-tax net cash flows are shown in Figure 111-12.
Comparison of Strategies
The three strategies — loan, bond and lease — are shown
schematically in Figure 111-13. If the net present value (NPV)
of each option is used as a decision criterion, the bond is
obviously the cheapest source of capital with an NPV of $-24,150
a:; compared to $-54,070 for the lease and $-78,750 for the loan.
Howovor the bond looks attractive only because it defers XYZ's
obligation for ten years while allowing it to take advantage of
investment tax credits and depreciation. Such an obligation
adversely affects the company's balance sheet as well as reduces
its debt capacity. (For many firms, the bond option is not
feasible because of the difficulty of placing such a small issue.)
The term loan on the other hand, makes heavier demands on cash
initially, but frees the company of obligations after a relatively
short period of time. The leasing arrangement constitutes an
intermediate strategy, committing the company for the longest
time period (15 years) but for relatively modest and stable amounts.
As pointed out earlier, the trade-offs involved in choosing between
these alternatives are entirely determined by the circumstances and
goals of the company. A growth company might choose the bond to
448
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defer demands on its working capital; a "cash cow" might choose
the loan so as not to commit itself for an extended period of
time; and so forth. The analysis presented here and summarized
by Figure 111-13 presents the decision makers with the necessary
information for choosing a financial strategy.
Conclusion
The special tax and financing programs available to allev-
iate some portion of the capital costs of pollution control equip-
ment require careful evaluation to determine the best alternatives
to meet the firm's financial objectives. The various financial
techniques discussed in this analysis are relevant to the assess-
ment of financing pollution control-related investment. They
have been shown to be capable of identifying taxation and finan-
cing strategies which are in some sense "optimal" with respect
to the objectives specified by the firm. These techniques, then,
should be of assistance to financial planners in industry for
reducing the financial impacts associated with the promulgation
of environmental regulations.
452
-------
CASE HISTORY
CITY OF GRAND RAPIDS, MICHIGAN
PROGRAM OF
INDUSTRIAL WASTE CONTROL
Prepared By: James A. Biener, Director
Environmental Protection Department

William H. Bouma, PhD
Wastewater Treatment Superintendent
453
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CITY OF GRAND RAPIDS
PROGRAM OF
INDUSTRIAL WASTE CONTROL
TABLE OF CONTENTS

SECTION PAGE

Introduction 455

Sewer Use Ordinance 457

Industrial Sewer Use Regulations 46°

Initial Enforcement Program 464

Compliance Procedures 465

Role of the News Media 467

Surveillance Program 468

Collection and Disposal of Industrial Sludges 471

Effects of the Pretreatment Ordinance 474

Water Quality Improvement 477

Exhibits I - IX 480
454
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INTRODUCTION

Over the past nine years, the City of Grand Rapids has

experienced the differential effects of both non-control of

industrial pollutants and tight regulation of industry's use

of the sanitary sewer system. This paper is presented in

order to share the experiences of Grand Rapids in the area

of water pollution control and the methods developed to attain

and maintain high water quality standards.

The City of Grand Rapids is the largest city in Michigan's

western lower peninsula with a population of 190,000 within the

city limits and 350,000 in the metropolitan area. The Grand

River is in the heart of Grand Rapids and is an important rec-

reational resource for western Michigan. Industry is highly

diversified in the metropolitan area, although Grand Rapids is

perhaps best known for its production of fine furniture. One

of the largest concentrations of electroplating firms in the

country exists in this area, with over 35 companies engaged in

this automotive-related activity.

During the late 1950"s and 1960's industrial contamination

of the Grand River created severe environmental problems. Peri-

odic fish kills were caused by high discharges of cyanide and

heavy metals from the metal plating industry in the area.

*
As the environmental movement gained momentum during the mid

1960's, public attention in Grand Rapids was focused on the dete-

riorating state of the once healthy Grand River. The time for
455
-------
reversing the damaging trend then arrived in Grand Rapids. In

January of 1969 the Grand Rapids City Commission enacted a com-

prehensive Water Pollution Control (now called Sewer Use) Ordi-

nance, establishing effluent limitations for cyanide and heavy

metals, as well as other provisions. Considerable effort was

required to reach this point, however. Metal platers in the area

lobbied strenuously against any limitations, arguing that the

cost of pretreatment of wastes would force them to relocate else-

where. City policymakers were forced to deal with those issues

and acknowledge that comparable effluent standards did not exist

elsewhere in the state. Nevertheless, concern for the quality of

the water and the general environment remained the focus, and the

Ordinance was adopted as City law.

Water pollution control is the responsibility of the City

Wastewater Treatment Plant, a division of the Environmental Pro-

tection Department. In addition to serving the city's wastewater

disposal needs, the Grand Rapids plant provides service to eleven

cities and townships on a contractual basis. The capacity of the

activated sludge wastewater treatment plant is currently being

expanded from 45 MGD to 90 MGD, with assistance of an E.P.A. con-

struction grant. Sludge digestion is being phased out in the new

design and being replaced by a new heat treatment process. With

this new process, sludge incineration will be the principal means

of sludge disposal.
456
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The Sewer Use Ordinance and Industrial Sewer Use Regula-

tions currently in effect were adopted in substantially the

same form in 1969. They set forth the standards, rules and

regulations with which industrial users of the sewer system

must comply, as well as provisions for enforcement and manage-

ment of the law.

SEWER USE ORDINANCE
"2.63. Management of the Sewage Disposal System. The
Grand Rapids Sewage Disposal System shall be and remain under
the management, supervision, and control of the City Manager
who may employ or designate such person or persons in such
capacity or capacities as he deems advisable to carry out the
efficient management and operation of the System. The City
Manager or his designee may make such rules, orders or regula-
tions as he deems advisable and necessary to assure the effi-
cient management and operation of the System; subject, however,
to the rights, powers and duties with respect thereto which are
reserved by law to the City Commission of Grand Rapids.

"2.64. Standards, Rules and Regulations. The standards,
rules and regulations established in or pursuant to this chap-
ter are deemed to be the absolute minimum consistent with the
preservation of the public health, safety and welfare, to pre-
vent pollution of the environment, and to fulfill the obliga-
tions of the City with respect to State and Federal lav; and all
rules and regulations adopted in conformance thereto. The dis-
charge into the System of any substance which exceeds the limi-
tations contained herein, or in any manner fails to conform
hereto, is hereby declared to be a public nuisance, and a vio-
lation of this Code.

"2.65. Use of the Sewage Disposal System. Any person
conforming to the standards, rules and regulations established
in or pursuant to this chapter shall be permitted to discharge
effluent into the System provided there exists adequate sewer
service available to which he can connect.

"2.66. Prohibited Substances. Except as hereinafter pro-
vided no person shall discharge or cause to be discharged any
of the following substances into the sanitary or combined
sewer:
457
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(1) Any effluent having a temperature higher than
140 degrees F.

(2) Any effluent which contains more than 50 mg/1 of
animal fat, vegetable fat, oil or grease, or any combination
thereof.

(3) Any gasoline, benzene, naphtha, fuel oil or other
inflammable or explosive liquid, solid or gas.

(4) Any grease, oil or other substance that will become
solid or viscous at temperatures 60 degrees Celsius and below
after entering the System.

(5) Any substance from the preparation, cooking and dis-
pensing of food and from the handling, storage and sale of
produce which has not been shredded to such a degree that all
particles shall be carried freely under flow conditions nor-
mally prevailing in the public sanitary or combined sewer,
with no particle larger than one-half inch in any dimension.

(6) Any substance capable of causing obstruction to the
flow in sewers or other interference with the proper operation
of the sewage disposal system including but not limited to
mineral oil, grease, ashes, cinders, sand, mud, plastics,
wood, paunch manure, straw, shavings, metal, glass, rags,
feathers, asphalt, tar and manure.

(7) Any effluent pH lower than 6.0 or higher than 10.0 or
having any other corrosive properties capable of causing damage
or hazard to structures, equipment or personnel of the treat-
ment works.

(8) (a) Any effluent in excess of:

1.5 mg/1 of Cadmium as Cd.
6 mg/1 of Zinc as Zn.
2 mg/1 of total Chromium as Cr.
1.5 mg/1 of Copper as Cu.
1 mg/1 of Cyanide as CN.
1.5 mg/1 of Nickel as Ni.
.02 mg/1 of Phenol or derivative of Phenol

(b) Any discharge of phosphorus ammonia, nitrates,
sugars or other nutrients or waste waters con-
taining them which have an adverse effect on
treatment processes or cause stimulation of
growths of algae, weeds, and slimes which are
or may become injurious to water supply,
458
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recreational use of water, fish, wildlife,
and other acquatic life.

(9) Any paints, oils, lacquers, thinners or solvents
including any waste containing a toxic or deleterious sub-
stance which impair the Sewage Treatment process or consti-
tute a hazard to employees working in the Sewage Disposal
System.

(10) Any noxious or malodorous gas or substance capable
of creating a public nuisance.

(11) Any effluent of such character or quantity that
unusual attention or expense is required to handle such mate-
rials at the sewage treatment plant or to maintain the System.

(12) Any discoloration such as, but not 1 limited to, dyes,
inks, and vegetable tanning solutions, or any unusual chemical
oxygen demand, chlorides, sulfates or chlorine requirements in
such quantities as to be deleterious and a hazard to the System
and its employees.

(13) Any redioactive wastes or isotopes of such half-life
or concentration as may exceed limits established by applica-
ble Local, State or Federal regulations.

(14) Any effluent containing a five (5) day biochemical
oxygen demand greater than 300 mg/1.

(15) Any effluent containing suspended solids greater
than 350 mg/1.

(16) Any effluent containing phosphorus greater than 40
mg/1.

(17) Any effluent having an average daily flow greater
than 2% of the System's average daily flow.

The Director upon review may approve discharges in excess
of the limits set forth in subsections 14 through 17 subject
to conditions either set forth in this chapter or special con-
ditions he deems necessary in order'to preserve and protect
public health, safety and welfare, subject to conformance with
the applicable State and Federal law.

"2.67. Inspection. The Director and other duly authorized
employees of the City bearing proper credentials and identifica-
tion shall be permitted to enter upon all properties at reason-
able times for the purpose of inspection, observation, measure-
ment, sampling and testing in accordance with the provisions of
459
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this chapter and any rules and regulations adopted pursuant
hereto. Any person who applies for and/or receives services
from this System under this chapter shall be deemed to have
consented to inspections pursuant to this section, including
entrance upon that person's property at'reasonable times to
make inspections.

"2.68. Use of Storm Sewers. No person shall discharge
or cause to be discharged into any storm sewer or natural or
artificial water course, effluent other than storm water or
uncontaminated effluent, except with authorization by a
National Pollution Discharge Elimination System permit, and
with the approval of the City's Director of Environmental
Protection.

"2.69. Protection from Damage. No unauthorized person
shall maliciously, willfully or negligently break, damage,
destroy, uncover, deface or tamper with or alter any structure,
property, appurtenance, equipment or any other item which is
part of the Sewage Disposal System.

"2.70. Enforcement. Any person found to be violating
any of the provisions of this chapter shall be guilty of a
violation of the Code. The Director is hereby authorized to
bring any appropriate action in the name of the City of Grand
Rapids, as may be necessary or desirable to restrain or enjoin
any public nuisance, to enforce any of the provisions of this
Chapter, to initiate criminal prosecution, and in general to
carry out the intent and purpose of this chapter."
INDUSTRIAL SEWER USE REGULATIONS
R-l. Industrial Cost Recovery System - All industrial users,
connected to the Grand Rapids Sewage Disposal System,
shall be required to pay their share of existing EPA
grants and any grant or grants awarded pursuant thereto,
divided by the recovery period. All industrial users
shall share proportionately, based on flow, in the
recovered amounts. Industrial users shall also pay a
surcharge on Biochemical Oxygen Demand (BOD) and Sus-
pended Solids (SS) on individual plant effluents in
excess of 300 mg/1 of BOD and 350 mg/1 of SS.

R-2. Inspection - When required by the Director, the owner or
occupant of any property served by a sewer carrying
industrial or commercial waste shall install one or more
suitable control manholes to facilitate observation,
460
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sampling and measurement of discharges. Such man-
holes when required shall be accessible and safely
located and shall be constructed in accordance with
plans approved by the Director. The manholes shall
be installed by the owner at his expense and shall
be maintained by him so to be safe and accessible at
all times, in the event that no manhole has been
required, the Director shall designate a proper sam-
pling point.

R-3. Testing Method - All measurements, tests, and analyses
of the characteristics of discharges shall be deter-
mined in accordance with standard methods, herein
defined, and shall be determined by taking suitable
samples at designated sampling points. Such sampling
shall be an appropriate manner of determining both com-
pliance with the requirements and penalties specified
in the Ordinance.

The City and all users of the Sewage Disposal System
shall employ one of the following standard methods for
the analysis of effluent:

a. Standard Methods for the Examination of Water
and Wastewater, available from the American
Public Health Association;

b. American Society for Testing and Materials
(ASTM) Annual Book of Standards, Part 31; or

c. Environmental Protection Agency Methods for
Chemical Analysis of Water and Wastes.

Users shall maintain a sampling frequency which insures
that Ordinance limitations for effluent are met.

R-4. Industrial Surveillance Program - The City shall sample
industrial effluent entering the Sewage Disposal System.
One of two methods of industrial surveillance shall be
utilized for each industry:

a. For those industries contributing toxic or
deleterious substances regulated and controlled
by the City Sewer Use Ordinance, the following
procedure shall be followed: A grab sample
shall be taken at the designated sampling point.

b. For those industries contributing non-toxic
wastes exceeding amounts specified by the City
461
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Sewer Use Ordinance, the following procedure
shall be followed: Three twenty-four (24)
hour composite samples shall be taken at the
designated sampling point during each quarterly
billing period.

Tests on all industrial surveillance samples shall be
performed in accordance with Standard Methods for the
Examination of Water and Wastewater.

R-5. Penalty Charge Methods (Surcharge) - All users of the
Sewage Disposal System shall be subject to penalty charges
for effluent containing Biochemical Oxygen Demand (BOD) in
excess of 300 milligrams per liter, and Suspended Solids
(SS) in excess of 350 milligrams per liter. The City
shall collect three (3) twenty-four (24) hour composite
samples from each designated sampling point once each bill-
ing period, and base the surcharge cost upon such samples.
The penalty charge shall be calculated by an employee des-
ignated by the Director and billed quarterly by the Water
Department.

R-6. Preliminary Treatment Facilities - Where necessary, in
the opinion of the Director, the owner shall provide at
his expense, such preliminary treatment as may be neces-
sary to:

a. Reduce the biochemical oxygen demand to 300
mg/1 and the suspended solids to 350 mg/1, or

b. Control toxic or deleterious substances, or

c. Control the quantities and rates of discharge
of such water and wastes.

Plans and specifications and any other pertinent informa-
tion relating to proposed preliminary treatment facilities
shall be submitted for review by the Director. No con-
struction of such facilities shall be commenced until the
review has been completed.

Where preliminary treatment facilities are provided for
any discharges, they shall be maintained continuously
in satisfactory and effective operation, by the owner at
his expense. Any person required to utilize preliminary
treatment facilities shall, upon the request of the
Director, submit to the Director, records of samplings
taken from waste discharges.
462
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R-7. Septic Tank Waste - Disposal of commercially hauled
septic tank waste into the Sewage Disposal System shall
be prohibited, except that the Director may authorize
disposal of portable containers of domestic waste,
including waste from recreational vehicles and highway
rest areas. If such disposal is authorized, the Direc-
tor shall determine and collect the cost of treating
said waste.

R-8. Disposal of Sludge from Pretreatment Systems - Sludge
from an industrial or commercial pretreatment system
shall not be placed into the Sewage Disposal System.
Such sludge shall be disposed of by a licensed hauler
in a site approved by the Michigan Department of Natural
Resources.
Sections 2.63 and 2.70 designate the management authority

and legal authority necessary to implement and enforce the Ordi-

nance and the Regulations. Sections 2.64 and 2.65 subject all

users to the provisions of the Ordinance and the Regulations

designate violations as a public nuisance subject to penalty.

Section 2.67 permits inspection of the customers' premises by

properly authorized employees.

R-2 provides the authority to require the construction of

a sampling manhole if required. R-3 designates the standard

methods that are to be used for effluent analysis. R-4 designates

a grab sample as an acceptable sampling procedure for toxic

wastes. R-6 designates the responsibility for construction,

operation and maintenance of pretreatment facilities. R-8

requires that all residue sludges be disposed of in a properly

licensed site.
463
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INITIAL ENFORCEMENT PROGRAM

The effluent limitations stipulated in the Sewer Use

Ordinance and accompanying Regulations required significant

changes in industrial waste disposal practices. Local industry

was required to invest several million dollars into the design

and construction of effluent pretreatment facilities and had to

provide the funds to sustain the daily operation.

At the time of enactment of the Ordinance, the City recog-

nized that compliance with the limitations would be best achieved

through cooperation between the City and local industry. The

initial step taken by the City was to attempt to improve its

already strained relationship with industry through personal con-

tact with representatives of affected companies in the area, and

through providing short-term variances to those companies.

Each company was granted a two-year variance to the Ordi-

nance which allowed them to exceed effluent limitations, provided

that the City could determine that satisfactory progress was

being made toward construction of a pretreatment facility. The

variance stipulated that industry must file a set of design plans

wjth the City for its pretreatment system within six (6) months

and submit progress reports every six (6) months thereafter.

During the first six months of the program, City staff

visited each of the companies to meet management personnel and

to explain the details of the effluent limitations. It was

explained that the City staff would be responsible to monitor
464
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the industrial waste on a continuous basis and to recommend
whatever legal action was necessary to achieve compliance.
The industry was informed that we would share samples and com-
pare analyses at their request. The City's role was represented
as that of a "helpful guardian" of their effluent.
During the variance period it was recognized that the
effluent limitations were not achievable within the two (2) year
period and that the variance had to be extended for six (6)
months. Although industry had in most cases made a good faith
effort to meet the deadline, delivery of pumps, motors and other
electrical equipment was slower than anticipated and was not
received in time to complete the pretreatment system in every
plant. The six (6) month extension was offered as a "shake down"
period after which active enforcement would begin.

COMPLIANCE PROCEDURES

Following the two and one-half year variance period, indus-
tries were subject to penalties for effluent limitation viola-
tions. A standard procedure, outlined below, was adopted by
the City to assure uniform treatment for all violations. While
the procedure was developed with a view towards achieving vol-
untary compliance, powers of prosecution were specified to insure
compliance.
1. The person responsible for a particular industry's
pretreatment system is formally notified of any
violation and directed to take immediate corrective
465
-------
action. If such action is taken and is effective
in abating the violation, the City takes no further
action.
2. If any effluent limitations continue to be violated,
a complaint is filed by the City Attorney's office
and a warrant is issued by the court against the com-
pany.
3. After a warrant is issued and prior to scheduling a
trial, the company's officials and attorney are
invited to a pre-trial hearing to discuss the com-
pany's violation and actions. If this meeting results
in commitments by the company to specific corrective
measures, the warrant is held in abeyance until such
time that effluent sampling by City staff indicates
compliance with the limitations. When compliance is
achieved, the warrant is often cancelled.
4. If the company continues to violate the effluent stan-
dards the warrant is sent to the court in order for a
trial to be scheduled. The company may enter a plea
up to the time of the trial.
In most cases, court trials result in convictions and fines.
Company fines usually consist of the maximum City Code penalty
of $100 per violation, City costs of surveillance and court costs
The heaviest fine levied against a single industry was almost
$5,000, representing 41 violations of the Ordinance plus City
surveillance costs. The court authorized payment directly to
466
-------
the Environmental Protection Department for the surveillance

expenses involved.

A total of 212 warrants have been issued for effluent

limitation violations since 1971. Of this number approximately

twenty-five (25) percent have gone to trial. The majority of

the warrants have been resolved in pre-trial conferences.

ROLF OF THE NEWS MEDIA

The news media have played an important role in the enforce-

ment program. During the initial two-year variance period,

(1969 - 1971) reports were made to the City Commission every six

(6) months describing the progress made by each industry toward

construction of its pretreatment system. Because these reports

were public information, they were "fair game" for the news media

and received a great deal of attention.

At one point in the two-year variance program, seven (7)

electroplating industries were cited in the semi-annual report

as being lax in their efforts to install equipment. The news

media referred to these companies as the "Dirty Seven" and
&

focused their attention on them. Public reaction was over-

whelmingly against these companies and resulted in several let-

ters to the editor of the local newspaper, numerous phone calls

to City offices and even some pickets placed at two of the

plants by local environmental groups. The seven industries soon

increased their compliance efforts and never lagged behind again.
467
-------
Following the end of the variance period which was extended

by six (6) months, violations of the effluent limitations were

filed with the local District Court and made a part of the pub-

lic court record. The news media frequently publicized these

violations, which resulted in great embarrassment to the indus-

tries involved. In fact, the negative publicity was a much more

severe penalty than the monetary fine. During this time, the

news media also maintained its "watch" over the City staff to

assure themselves that we were enforcing the law equally and

fairly.

SURVEILLANCE PROGRAM

Industry compliance with effluent limitations is insured

only by an effective surveillance program. A surveillance pro-

gram must be a full-time operation that is adequately staffed

and equipped to conduct regular and routine effluent sampling

in such a way that proper and reliable data results.

In Grand Rapids, three full-time employees are devoted to

the industrial surveillance program with the assistance of other
j.
laboratory technicians, as required. The three-person team

consists of a chemist and two laboratory technicians properly

trained in field and laboratory procedures, and is responsible

for the following:

1. Collecting and analyzing industrial samples on a

regular random schedule.
468
-------
2. Investigating complaints and monitoring water

courses for industrial pollutants.

3. Maintaining a file on each industrial customer and

inputting all appropriate data in the data process-

ing system.

4. Meeting with industry to discuss operation and main-

tenance procedures, changes in the pre-treatment

system or inspection of the facilities.

5. Filing complaints with the District Court when appro-

priate and giving testimony in court cases when required.

The surveillance team spends much of its time in the field

and is equipped with the following:

1. A van-type truck

2. A boat, motor and boat trailer for surveillance of

the Grand River

3. Automatic samplers of the composite and discrete types

4. Portable sample pumps

5. Portable D.O. and pH meters

6- Safety equipment including a manhole blower, air

packs, safety harnesses, etc., to permit safe entry

into sewer manholes

7. Variety of sampling containers, lab forms for data

recording and miscellaneous lab equipment

The cost to equip a surveillance team with the above-

described equipment amounts to about $20,000. The direct cost

for labor, materials and supplies is about $110,000 annually,
469
-------
not including supervisory and administrative costs.

Laboratory Equipment

Speed and accuracy of processing industrial waste sam-

ples is an important consideration in selecting laboratory

equipment. The ability to analyze a problem discharge quickly

may prevent considerable environmental damage. Equipment needs

are also based on the number of industrial customers within

the particular jurisdiction and the various types of wastes

that these customers discharge. Because of the large number of

plating firms in Grand Rapids, and the toxicity of these wastes,

we employ the following instruments:

- Atomic Absorption Spectrometer (AA)

This instrument is designed to identify elements, princi-

pally metals, and is the basic instrument required in any indus-

trial waste program for determining concentration of metals.

The instrument is accurate in a range well within the standard

methods for analyses and provides relatively fast analyses.
^
Further, it is not difficult to operate and requires only a

small degree of training. Maintenance of this instrument is

relatively simple and routine and may be done by lab technicians,

Prices range from $5,000 for simplest versions to $25,000 for

sophisticated models.

- Atomic Emissions Spectromejter J^PjLasma Unit)

This instrument is also designed to identify elements

of which metals are the principal type. The accuracy of the

Plasma unit is at least equal to the AA unit although the speed

470
-------
is considerably greater. Up to twenty-six (26) elements can

be analyzed simultaneously from a single sample. The instru-

ment is computer controlled to assure accuracy while providing

printed analyses and data storage capability. For example,

the instrument requires 50 seconds to analyze a sample for all

metals and to print out the results on a hard copy. Because of

the complex nature of the unit, specialized operator training

is required. Cost of the instrument was $72,000 in 1977 and was

purchased under the EPA Construction Grants Program.

COLLECTION & DISPOSAL OF INDUSTRIAL SLUDGES

Effective control of industrial waste requires proper col-

lection and disposal of the residual materials resulting from

pretreatment systems of industries. Sizable quantities of both

liquid and solid metallic hydroxide sludge began to be generated

in the Grand Rapids area once the pretreatment systems became

operable. The liquid sludges were 2-6% solids and were generated

by those companies that had no physical space for dewatering

equipment or felt that liquid disposal was more economical for

them. Other companies installed vacuum filters, centrifuges

or other filtering devices to solidify their sludges to solid

contents of 20-30% with the consistency of conventional vacuum

filtered sewage sludges.

Creation of industrial sludges created a local demand for

transportation and disposal of these wastes. One local company

suddenly developed into a rather major operation with the

471
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purchase of several large tandem trucks for the transportation

of the liquid sludges. Another company bought some tank trucks

for liquid waste and supplied other containerized equipment for

transporting the solid wastes. This same company constructed

sand bed dewatering cells for dewatering the liquid sludges

before transporting to a disposal site.

Disposal of both the liquid and solid metallic hydroxide

sludges were under the jurisdiction of the Michigan Department

of Natural Resources. Little attention was paid to the disposal

practices, as no specific State legislation applied and no pre-

vious experience existed. Disposal sites were approved quite

readily by the DNR. During the first five or six years of the

industrial program, solid sludges were co-disposed with solid

waste in sanitary landfills or placed in an approved site in an

abandoned gravel pit. Liquid sludges were dewatered in the sand

bed filters of a private hauler, or applied directly on the land

at the gravel pit site.

Recently, monitoring wells located near the gravel pit site

showed a migration of heavy metals into the water table. The

site has been c-losed for disposal of metal hydroxide sludges and

State legislation has been enacted to establish standards for land

disposal of industrial sludges. Co-disposal of liquid or solid

metallic hydroxide with general refuse is not allowed. Separate

sites for disposal of industrial wastes are required, and the stan-

dards for these sites dictate sufficient clay thicknesses that

prevent any migration in either a vertical or horizontal direction,
472
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The present Michigan standards for industrial waste dis-

posal sites are very restrictive and can only be met when the

area being considered has clay depths of 25 to 30 feet. The

process of evaluating an industrial disposal site involves

public hearing procedures which always result in negative pub-

lic reaction that prevents the development of a site or at

least delays the development. The process required to license

an industrial site is equal to or more complicated than obtain-

ing a license for a sanitary landfill operation.

At the present time, there is no licensed site in or near

Grand Rapids for the disposal of either liquid or solid sludges.

Many companies are contracting to have their waste hauled long

distances for disposal and in most cases to the State of

Illinois or Indiana. A temporary storage site for solid sludges

has recently been approved although the sludge must be removed

from this site to a permanent site for final disposal. The

cost for transporting and disposing of sludge has tripled or

quadrupled in the past six months because of the lack of a

local disposal site.

The present sludge disposal dilemma is not near an end.

A local site meets all the criteria of the State licensing

regulations but is being blocked by public reaction and pressure

in the .township where it is proposed. Pressure has also begun

to develop from the other states where the sludges are being

deposited. We can only hope that a disposal site or sites are
173
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developed before industry has no choice but to dispose of its

waste into the public sewer, and we are once again back where

we started in 1969.

EFFECTS OF PRETREATMENT ORDINANCE

Since adoption of the pretreatment Ordinance, there have

been significant reductions in metal concentrations found in

sewage influent and effluent. Total metal concentration in

Grand Rapids sewage is shown in Exhibit I. Influent levels

have dropped from the 12-13 mg/1 range to about 2 mg/1.

Effluent levels have dropped from the 9-10 mg/1 range to close

to 1 mg/1 (representing 87% and 92% reduction respectively).

Exhibit II shows that a similar experience with total cyanide

concentration is even more dramatic, with reductions of 93%

for influent and 96% for effluent.

Chromium is illustrated in Exhibit III and shows excellent

reductions of 90% and 96%. Copper is shown in Exhibit IV and

has reductions of 89% and 93%. Nickel appears in Exhibit V and

shows reductions of 87% and 89%. Zinc displays erratic changes

in Exhibit VI, but shows overall reductions of 79% and 85% for

the influent and effluent respectively. Zinc is an example

of interdisciplinary effects.

In 1970, air pollution control requirements forced brass

foundaries to install scrubbers to remove zinc oxide from their

air stacks. This waste material was then discharged into the
474
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sanitary sewer system, causing zinc concentrations to rebound

to previous levels. City staff then focused energy on methods

of achieving pretreatment that would reverse this trend and

by 1973 levels of zinc in the sewage system plummeted.

Relative reductions between influent and effluent show

that even though lower concentrations were originally present

in the effluent, higher reductions were obtained. This was

observed for all metals and cyanide. It appears that municipal

treatment plants are capable of removing or treating low levels

of metals but that efficiency decreases with increasing influent

concentration. Nickel has often been described as the metal

having lowest removal, a view supported by our data that show

the smallest difference in improvement at two percent.

The idea of non-linear removal efficiency can best be shown

by comparing the removal of each metal at the higher influent

levels of pre-ordinance to the lower concentrations after

pretreatment enactment. Percent removals were as follows:
Cyanide
Chromium
Copper
Nickel
Zinc
Before

43% of 2.1 mg/1
35% of 5.1 mg/1
25% of 2.8 mg/1
25% of 3.2 mg/1
46% of 3.7 mg/1
After

71% of 0.14 mg/1
73% of 0.49 mg/1
63% of 0.30 mg/1
•38% of 0.42 mg/1
63% of 0.78 mg/1
These figures show conclusively that higher removal efficien-

cies are obtained at the lower influent concentration. Also, as
475
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expected, nickel exhibits the lowest removals of all in a

wastewater treatment plant.

Slug discharges are common to any batch operation.

These short but very concentrated discharges can have adverse

effects on a wastewater treatment system, particularly

biological systems. Typically, treatment efficiency is

impaired for times ranging from minutes to days. Exhibits

VII and VIII show examples of large slug discharges and the

effect on treatment as measured by suspended solids and BOD

in the effluent. In each case the concentration of metal is

the average (composite sample) concentration for the day, not

the instantaneous level which probably was an order of

magnitude larger. Prior to the pretreatment ordinance, such

occurrences were common and background levels were continuously

higher. Currently, however, cases such as Exhibits VII and VIII

are rare.

Much of the influent heavy metal passes through municipal

treatment, but much is also trapped in the process and removed

with the sludge. Until Grand Rapids changed to a heat treat-

ment system, this sludge was digested. The reason for chang-

ing was due to the undependability of anaerobic digestion

caused by industrial chemicals.

EPA has required wastewater treatment operations to con-

sider other than "standard treatment" of sewage and sludge,

the end product. Land application of sludge has become more

feasible in Grand Rapids as metal content in sludges continues
476
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to decrease, as illustrated in Exhibit IX. The reductions

average 66%, resulting in sludge that contains only about

one-third the amount of heavy metal compared to pre-ordinance

levels. Agricultural use of sludge could prove worthwhile

both in resource recovery efforts and in reducing costs of

incineration.

WATER QUALITY IMPROVEMENT

The greatest direct public benefit resulting from the

industrial waste control program has been the revival of the

Grand River. For many years, the Grand River served as an

open conduit for transporting industrial wastes from Grand

Rapids to Lake Michigan. The public attitude toward the River

was one of almost total disrespect. Few persons used the Grand

as a recreational resource and fewer yet dared eat the fish

caught from its waters.

In 1972, the flow of industrial wastes into the Grand had

slowed to a mere fraction of its former volume. In the Spring

of that year, the Michigan Department of Natural Resources

selected the Grand as a place to stock Steelhead Trout along

with Coho and Chinook Salmon. These fish would migrate to Lake

Michigan to feed during the summer months when the river warmed

to intolerable temperatures for these species to survive. The

Steelhead Trout return to the river to spawn in the Spring

while the Salmon begin their spawning in the Fall months.
477
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By 1974, the Trout and Salmon spawning runs started to

attract a lot of attention from local fishermen. Trout

weighing as much as 15 pounds and Chinook Salmon up to 35

pounds were common catches below the dam in downtown Grand

Rapids. First a few, then hundreds of fishermen were parti-

cipating in this newly-created fishery usually limited to

northern clear water rivers. The local Chapter of the Izaak

Walton League of American sponsored a Trout fishing contest

within the City limits of Grand Rapids to help promote our

revived water resource.

Development of the fishing in the Grand River was only

the beginning. Canoeing enthusiasts began promoting and

mapping the river as an enjoyable canoeing adventure. Con-

struction and improvement of boat ramps brought more and more

boating enthusiasts. More park land was purchased by the City

and was developed into recreational areas that added important

green belts along the banks of the river. Hundreds of persons

began enjoying the parks. Environmental groups gathered

together to clean the river banks of littered debris.

In 1976, a fish ladder was constructed at the dam in down-

town Grand Rapids for the purpose of passing fish upstream into

the Grand and its many tributaries. On top of this fish ladder

a sculpture was placed that was created by a local artist and

financed by some $75,000 in local donations. Alongside the

fish ladder and sculpture there was created a unique little park
478
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for the benefit of those persons watching Trout and Salmon

"climbing" the fish ladder. As many as two hundred noisy

participants are often present to cheer the fish as they find

their way up the ladder.

The future of the Grand River as a recreational resource

appears to be almost unlimited. Additional parks are being

planned for development and many recreational activities are

often centered on or near the river. The public attitude toward

the Grand Rivet has been converted to one of appreciation and

respect in just a few short years.
479
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13.0
12.0
11,0
IO.Q
9.0
m.
TOTAL MZ7AL
TOTAL METAL i
£FFLU£fJT 92% KEDUC7/OM
6.0
6.0
4.0
3.0
2.0
I.Q
69 70 7/ 75 73 74- 75 76 77 78
EXHIBIT I
480
-------
TOTAL CYAMJDE
m
g/i
*'
8.0
93 % J2EDUCT/OAJ
N
££DUCT/OH
7/
75
77
EXHIBIT II

481
-------
TOTAL CH&OM/UM
66 69 70 71 7t 73 *+ 73 fe 77 W
EXHIBIT III
482
-------
TOTAL COJ°f*£X /*/ SE>VAG£
T5 7* 77
EXHIBIT IV
483
-------
TOTAL
EXHIBIT V
484
-------
TOTAL Z/A/C
4.0
3.0
2.0
1.0
66
70
EXHIBIT VI
485
7$
77 IB
-------
B.G.
40
20
4-.0 mg/l C*J'
2.5 mg/L Cu
CN~ = 0.17 mg/L
Cu - 0.69 m/i
0.6
I.Z mg/l Cu
25 24
SB 26
?B
jo ;
EXHIBIT VII
486
£456
OCTOBER 1376
-------
so*.
B 0. D. /A/

S. •$. /A/
10
/97<2
EXHIBIT VIII
487
9 to
-------
of
6>2.y. o/?
Q ,
EXHIBIT IX
488
*US eOVBWMEHTPRWroiGOFFICE 1978—757-140/1336
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