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PRELIMINARY DATA SUMMARY
FOR THE
PAINT FORMULATING
POINT SOURCE CATEGORY
Office of Water Regulations and Standards
Office of Water
United States Environmental Protection Agency
Wash ington, D.C.
August 1989
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PREFACE
This is one of a series of Preliminary Data Summaries
prepared by the Office of Water Regulations and Standards of the
U.S. Environmental Protection Agency. The Summaries contain
engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge
pollutants in their wastewaters and whether the EPA should pursue
regulations to control such discharges. The summaries were
prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency
to develop plans to regulate industrial categories that
contribute to pollution of the Nation's surface waters.
The Summaries vary in terms of the amount and nature of the
data presented. This variation reflects several factors,
including the overall size of the category (number of
dischargers), the amount of sampling and analytical work
performed by EPA in developing the Summary, the amount of
relevant secondary data that exists for the various categories,
whether the industry had been the subject of previous studies (by
EPA or other parties), and whether or not the Agency was already
committed to a regulation for the industry. With respect to the
last factor, the pattern is for categories that are already the
subject of regulatory activity (e.g., Pesticides, Pulp and Paper)
to have relatively short Summaries. This is because the
Summaries are intended primarily to assist EPA management in
designating industry categories for rulemaking. Summaries for
categories already subject to rulemaking were developed for
comparison purposes and contain only the minimal amount of data
needed to provide some perspective on the relative magnitude of
the pollution problems created across the categories.
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ACKNOWLEDGEMENTS
Preparation of this Preliminary Data Summary was directed by Mr.
Richard Williams of the Industrial Technology Division.
Preparation of the economic analysis sections was directed by Mr.
Mitchell Dubensky of the Analysis and Evaluation Division. Ms.
Allison Greene of the Assessment and Watershed Protection
Division was responsible for preparation of the environmental
assessment analysis. Support was provided under EPA Contract
NOS. 68-03-3412, 68-03-3548 and 68-03-3339.
Additional copies of this document may be obtained by writing to
the following address:
Industrial Technology Division (WH-552)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Telephone (202) 382-7131
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TABLE OF CONTENTS
Section Title Paqe No-
EXECUTIVE SUMMARY i
1.0 INTRODUCTION !
1.1 Purpose and Authority 1
1.2 Legislative History !
1.3 Regulatory Background 3
TECHNICAL SUPPORT STUDY
2.0 INTRODUCTION TO TECHNICAL SUPPORT STUDY 7
2.1 Introduction 7
2.2 Study Methodologies 7
3.0 DESCRIPTION OF THE INDUSTRY 9
3.1 Industry Profile 9
3.2 Industry Processes H
3.2.1 Solvent-base Paint Formulation 11
3.2.2 Water-base Paint Formulation ... 13
4.0 INDUSTRY SUBCATEGORIZATION 16
5.0 WATER USE AND WASTE CHARACTERISTICS 17
5.1 Wastewater Sources 17
5.1.1 Solvent-base Paint Formulation 17
5.1.2 Water-base Paint Formulation 17
5.1.3 Caustic Cleaning Operations 18
5.2 Wastewater Volume 19
5.3 Wastewater Characterization 21
5.3.1 Background 21
5.3.2 Sampling and Analytical Results 22
6.0 POLLUTANT PARAMETERS 44
6.1 Introduction 44
6.2 Pollutant Categories 45
6.2.1 Organic Pollutants 45
6.2.2 Metals 45
6.2.3 Pesticides/Herbicides 45
6.2.4 Conventional Pollutants 51
6.2.5 Non-conventional Pollutants 51
6.2.6 Sludge - Pollutant Parameters 51
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TABLE OF CONTENTS
(continued)
Section Title Page No
7.0 CONTROL AND TREATMENT TECHNOLOGY 56
7.1 In-plant Source Control Strategies 56
7.1.1 Wastewater Reduction ! 56
7.1.2 Wastewater Reuse ! 59
7.2 Water Wash Wastestream Treatment and Disposal
Practices 59
7.3 Solvent Wash Wastestream Treatment and Disposal
Practices 60
ECONOMIC IMPACT ANALYSTS
8.0 INTRODUCTION TO THE ECONOMIC IMPACT STUDY 62
8.1 Introduction 62
8.2 Industry Profile !!!!!! 62
8.3 Number and Location of Facilities ! ! ! ! 64
8.4 Employment Characteristics ! ! 64
8.5 Ownership Characteristics ! ! 69
8.6 Products and Prices ! ! ! 70
8.7 Financial Characteristics '.'.'.'.'. 71
8.8 Foreign Trade '.'.'.'. 73
8.9 Trends in the Industry '.'.'. 73
9.0 ECONOMIC IMPACT ASSESSMENT 74
9.1 Methodology 74
9.2 Definition of Typical Plants '.'.'.'.'. 75
9.3 Economic Impacts ! 78
10.0 LIMITS OF THE ANALYSIS 85
10.1 Definition of Industry 85
10.2 Economic/Financial Data ] 85
10.3 Regulatory Options and Compliance Costs ....!!85
ENVIRONMENTAL IMPACT ANALYSIS
*
11.0 ENVIRONMENTAL IMPACT ANALYSIS 88
11.1 Summary of the Environmental Impact Study 88
11.2 Methodology 91
11.3 Impacts on Human Health ! ! 91
11.4 Impacts on Aquatic Life 91
11.5 POTW Impacts ! ! ! 92
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TABLE OF CONTENTS
(continued)
Section
Title
Page No.
11.6 Receiving Stream Profiles
11.7 Pollutant Fate
12.0 REFERENCES
92
92
94
APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
APPENDIX F
DATA SUMMARIES FROM PREVIOUS STUDIES
LIST OF PRIORITY POLLUTANTS ANALYZED IN WASTEWATER
OF PAINT PLANTS A, B, C, and D
LIST OF NON-PRIORITY POLLUTANTS ANALYZED IN
WASTEWATER OF PAINT PLANTS A, B, C, AND D
POTW MODEL RESULTS USING 50TH PERCENTILE POTW AND
RECEIVING STREAM FLOWS
POTW MODEL RESULTS USING 25TH PERCENTILE POTW AND
RECEIVING STREAM FLOWS
DILUTION FACTOR RESULTS-INDIRECTS
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LIST OF TABLES
Table _ Title
3-1 1985 PAINT PRODUCTS BY TYPE AND END USE DISTRIBUTION . 10
5-1 AMOUNT OF WATER USED TO CLEAN A PAINT TANK ...... 20
5-2 SUMMARY OF REPORTED ANALYTICAL RESULTS, PAINT PLANT A. 25
5-3 SUMMARY OF REPORTED ANALYTICAL RESULTS, PAINT PLANT B. 32
5-4 SUMMARY OF REPORTED ANALYTICAL RESULTS, PAINT PLANT C. 35
5-5 SUMMARY OF REPORTED ANALYTICAL RESULTS, PAINT PLANT D. 40
6-1 DATA SUMMARY 1986/1987 SAMPLING PROGRAM, PRIORITY
POLLUTANTS ...................... 46
6-2 DATA SUMMARY 1986/1987 SAMPLING PROGRAM, NON-PRIORITY
POLLUTANTS ...................... 48
6-3 SUMMARY OF REPORTED ANALYTICAL RESULTS FOR WASTEWATER
SLUDGE SAMPLES .................... 52
7-1 SUMMARY OF MUNICIPAL TREATMENT SYSTEM INFLUENT
LIMITATIONS ...................... 57
8-1 LOCATION OF PAINT FORMULATING PLANTS ......... 65
8-2 SIZE OF THE PAINT FORMULATING INDUSTRY ...... • • 67
8-3 DISTRIBUTION OF PLANTS BY NUMBER OF EMPLOYEES ..... 68
8-4 HISTORIC PROFITABILITY LEVELS ........ ..... 72
9-1 TYPICAL PAINT FORMULATING PLANT ............ 76
9-2 FINANCIAL PROFILES - TYPICAL PAINT PLANTS ....... 77
9-3 IMPACT ON TYPICAL PLANT PROFITS VARIOUS ANNUAL
COMPLIANCE COSTS ................... 79
9-4 ESTIMATE 1986 COMPLIANCE COSTS ............ 84
11-1 PROFILE OF PAINT FORMULATING INDUSTRY USED IN THE
ENVIRONMENTAL IMPACT ANALYSIS ............. 89
11-2 SUMMARY OF WATER QUALITY CRITERIA EXCEEDANCES RCRA/ITD
SAMPLING DATA ..................... 90
11-3 ENVIRONMENTAL FATE OF POLLUTANTS OF CONCERN ...... 93
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LIST OF TABLES
IN APPENDICES
Table
APPENDIX A
A-l DATA SUMMARY 1985 DSS SAMPLING PROGRAM - RAW WASTEWATER AND
TREATEbwASTEWATER SAMPLES FROM A PAINT FORMULATING FACILITY
A-2 AVERAGE UNTREATED WASTEWATER CONCENTRATIONS - 1975 PAINT
SAMPLING PROGRAM - SAMPLING OF NINE PAINT FORMULATIVE
FACILITIES
A-3 AVERAGE TREATED OF WASTEWATER CONCENTRATIONS 1976 PAINT
SAMPLING PROGRAM SAMPLING OF NINE PAINT FORMULATING
FACILITIES
A-4 RAW WASTEWATER DATA SUMMARY 1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONAL^, NON-CONVENTIONALS
A-5 TREATED WASTEWATER DATA SUMMARY 1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONAL, AND NON-CONVENTIONALS
A-6 SLUDGE DATA SUMMARY - 1977/1978 SAMPLING PROGRAM PRIORITY
POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
A-7 INTAKE (TAP) WATER DATA SUMMARY 1977/1978 SAMPLINGvPROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
APPENDIX B
B-l LIST OF PRIORITY POLLUTANTS ANALYZED IN WASTEWATER OF PAINT
PLANTS A, B, C, AND D
APPENDIX C
C-l LIST OF NON-PRIORITY POLLUTANT PARAMETERS ANALYZED IN
WASTEWATER OF PLANTS A, B, C, AND D
APPENDIX D
50th Percentile
D-l ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT A
D-2 ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT B
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LIST OF TABLES
IN APPENDICES
(continued)
D-3 ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGES - PLANT D
D-4 ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT E
APPENDIX E
25th Percent- i 1 A
E-l ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT A
E-2 ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT B
E-3 ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT D
E-4 ENVIRONMENTAL ANALYSIS FOR THE PAINT FORMULATING INDUSTRY
INDIRECT DISCHARGERS - PLANT E
APPENDIX T
F-l SUMMARY OF INDIRECT DISCHARGERS
F-2 INDIRECT DISCHARGE DILUTION FACTOR
F-3 DISTRIBUTION FREQUENCIES (MGD) - INDIRECT DISCHARGERS
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LIST OF FIGURES
Title Paq$ No
3-1 GENERAL FLOW DIAGRAM OF FORMULATION PROCESS FOR
SOLVENT-BASE PAINTS 12
3-2 GENERAL FLOW DIAGRAM OF FORMULATION PROCESS FOR
WATER-BASE PAINTS 14
5-1 WASTEWATER TREATMENT SYSTEM, PAINT PLANT A 24
5-2 WASTEWATER TREATMENT SYSTEM, PAINT PLANT B 31
5-3 SOLVENT PURIFICATION, PAINT PLANT C 37
5-4 SAMPLE POINT SCHEMATIC, PAINT PLANT D 39
9-1 IMPACT ON PROFITS OF SMALL-SIZE PLANTS 80
9-2 IMPACT ON PROFITS OF MEDIUM-SIZE PLANTS 81
9-3 IMPACT ON PROFITS OF LARGE-SIZE PLANTS 82
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EXECUTIVE SUMMARY
The Hazardous and Solid Waste Amendments of 1984 (HSWA) to the
Resource Conservation and Recovery Act (RCRA) required EPA to
submit a report to Congress concerning those substances
identified or listed under Section 3001 of HSWA which are not
reflated under this subtitle by reason of the exclusion for
mixtures of domestic sewage and other wastes that pass through a
sewer system to a publicly owned treatment works (POTW).
The "Report to Congress on the Discharge of Hazardous Wastes to
Publicly Owned Treatment Works, •' EPA/530-SW-86-004, February 1986
(the Domestic Sewage Study, or DSS) examined the nature and
sources of hazardous wastes discharged to POTWs, evaluated the
effectiveness of Agency programs in dealing with such discharges,
and presented recommendations for improving controls on hazardous
waste discharges to POTWs. The paint formulating industry is one
of 12 industries identified in the DSS as a potential source of
hazardous waste discharges to POTWs. The paint formulating
industry had been previously excluded from coverage under the
Clean Water Act under the authority of Paragraph 8 of the
EPA/Natural Resources Defense Council (NRDC) Consent Decree.
The DSS recommended that additional research, data collection,
and analysis be conducted to fill paint formulating industry
information gaps concerning the sources and quantities of
hazardous waste constituents and their effects on POTWs and the
environment.
The purpose of this study was to gather information to assist the
Agency in deciding whether to develop national effluent
limitations guidelines and standards for the industry. The
document comprises three studies, undertaken independently,
listed as follows:
o a technical support study
o an economic impact study
o an environmental impact study
The technical support study consisted of two parts: the
collection and analysis of paint formulating wastewater and waste
solids samples, and the collection of sufficient information
about the industry to develop a preliminary updated industry
technical profile. The economic impact study consisted of a
review and update of the economic profile of the paint
formulating industry and an analysis of the projected economic
impact of wastewater regulation on the industry. The
environmental impact study involved an evaluation of the impacts
of paint formulating wastewater discharges to publicly owned
treatment works (POTWs) and their receiving streams.
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In the technical support study, samples of raw wastewater
treated final effluent, and waste solid samples were^ colIJc-ed
and analyzed for toxic, conventional, and non°conventional poUu?
approx?Ltely faCllltles' The nonconventional pollutants included
250 organic and inorganic substances on the Industrial Technoloav
Division (ITD) List of Analytes. in addition, plant visits we?e
conducted at ten paint formulating facilities^ (including the
sampled facilities) during which information on paint formulation
practices and waste treatment and handling was obtained
Twenty organic compounds were detected in the raw wastewater-
samples The highest value detected was for acetone founJ ill
a^n^'V'0?0 mg/1' Three P^ticide/herbicide compounds?
ni^i«; Jrhlordane' and Phosmet, were detected at iw
concentrations. Twenty-five metals were detected in the raw
aa^?nater famPlest The honest concentrations found were
aluminum, calcium, iron, magnesium, sodium, and zinc.
Economic data characterizing the paint formulating industry were
a °m-t?? U'S CenSUS Bureau' the National Paint an!
Association (NPCA) and earlier USEPA Effluent Guidelines
6 Slgnificant Bindings from the economic study wire
o
the industry is comprised of many rather small firms
(less than 20 employees) that own a single plant and
a few large ones which economically dominate the industry
the paint formulating industry is a mature industry
and its growth is dependent on the level of construction
activity and the general business climate
many small plants would have difficulty absorbing
additional compliance costs while medium and larae
plants would not have difficulty.
^enKal impact Study evaluated the water quality
* (?arges fr°m f°Ur indirect paint plants on publicly
rent .W°rkS and ulti™*tely on the POTWs' receiving
?PaSn5M°n the- P°TWS were e^luated in terms of
„ • • operations and contamination of the POTW
Rece,lvlng stre™ i^acts were evaluated by comparing
^stream pollutant concentrations with aquatic lifl
h H ^S 1SVelS ai?d EPA Water Quality Criteria developed for
human health and aquatic life protection.
Onvw«oh impacts were projected to be minimal.
2?i£i 5u 64 evaluated pollutants (benzidine - Plant A, and
dichloromethane - Plant E) were projected to exceed human health
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criteria at both the 25th and 50th percentiles. These two
pollutants are known or suspected carcinogens; however, they are
generally not persistent in water, having a half-lives of 6 hours
or less. Only one pollutant (mercury) is projected to exceed
chronic aquatic life criteria (Plant D). Another pollutant,
zinc, is projected to exceed inhibition levels at the 25th
percentile. No pollutants exceed the sludge contamination
levels.
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1.0 INTRODUCTION
This document presents the most current information available
about the paint formulating industry point source category, and
was prepared in response to recommendations of the DSS. it
contains a description of the paint formulating Process and the
results of analyses of wastewater and waste solids obtained from
sampling episodes. The document provides a technical basis for
evaluating the need for regulation of the industry and can be
used to assist permit writers and POTW officials in developing
appropriate controls for the handling and disposal of wastewater
and waste solids from the paint formulating industry.
A description of the paint formulating industry is presented in
Section 3.0, and the industry subcategorization scheme is
presented in Section 4.0. Section 5.0 characterizes paint
industry wastewater flows and pollutant concentrations and loads.
Pollutants of concern are identified in Section 6.0, and control
and treatment technologies are discussed in Section 7.0.
1.1 Purpose and Authority
The Federal Water Pollution Control Act of 1972 (Clean Water Act,
or CWA), as amended, established a comprehensive program to
"restore and maintain the chemical, physical, and biological
integrity of the Nation's waters" (Section 101(a)). The CWA
required EPA to issue effluent limitations guidelines,
pretreatment standards, and new source performance standards for
34 industrial categories. Effluent guidelines and standards for
a portion of the paint formulating industry were promulgated in
1975. The paint formulating industry regulations were reviewed,
following the EPA/NRDC Consent Decree in 1976; revised rules were
proposed in 1980 (45 FR 912; January 3, 1980).
1.2 Legislative History - Solid Waste Disposal Act and
Amendments
The Solid Waste Disposal Act (SWDA) of 1965 authorized limited
research and grant programs to study solid waste disposal
practices. However, authority and funds for research on domestic
sewage disposal were not included in the SWDA, because Congress
felt the funds for construction of wastewater treatment plants
were available under the CWA to study and treat domestic sewage.
This exclusion, the Domestic Sewage Exclusion (DSE) in the 1965
Act, was not regulatory in nature, and did not distinguish
between solid and hazardous wastes.
The Resource Conservation and Recovery Act (RCRA), amending the
SWDA, was passed in 1976. The DSE, included in Section 1004
(subparagraph 27) of the 1976 RCRA, states that solid or
dissolved material in domestic sewage is not solid waste as
defined in RCRA; therefore, such materials cannot be considered
hazardous waste for RCRA purposes. The DSE applies to industrial
wastes discharged to POTW sewers that contain domestic sewage,
even if the industrial wastes would otherwise be considered
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hazardous. Under the DSE, industrial facilities that discharge
R?^eSa™r-^^rS Son,tainin9 domestic sewage are not subject to
RCRA generator and transporter requirements (e.g., manifesting
w?dhrH^rti"g) • In addition< POTW* receiving these' wastes mixed
with domestic sewage are not deemed to have received hazardous
SSJS™,, therefore they need not comply with certain RCRA
w?th t2™ i- ^ +-Kreatment' stora*e' and disposal requirements
with respect to these wastes. The DSE does not, however, apply
to sludge produced by a POTW as a result of wastewater treatment
The 1980 regulations implementing the RCRA of 1976 interpreted
the DSE to apply both to sanitary sewage and mixtures of
sanitary sewage with other wastes in a sewer sys~ti^ - This
interpretation was based on EPA's determination that the
legislative policy reflected in the SWDA of 1965 would also
exempt mixed wastestreams because they would be subiect to
C?njr°1^nder the CWA' The Preamble to the 1980 RCRA regulations
stated that not only did the construction grants program provide
financial assistance for the proper treatment of these wastes
but that proper pretreatment requirements would ensure that
environmental problems would not result. The preamble to the
rule published in 1980 did, however, point out that some mixtures
?isks°. 1C SSWage With °ther wastes may present environmental
K t0 RCRA added Secti°n 3018 (a), which required
to submit to Congress within 15 months of enactment of HSWA
a report concerning substances listed in Section 3001 that are
not regulated under this subtitle by reason of the DSE. The
report, known as the Domestic Sewage Study or DSS, included the
types, sizes, and number of generators disposing of these sub-
stances to sewer systems. The report also identified significant
generators, wastes, and waste constituents not regulated under
existing federal law, or not regulated in a manner sufficient to
protect human health and the environment.
The DSS was prepared by EPA's Office of Water Regulations and
Standards and submitted to Congress on February 7, 1986. The DSS
^mr"!lned the nature and sources of hazardous wastes discharged to
POTWs, measured the effectiveness of EPA programs in dealing with
these discharges, and recommended improvements to the programs
SSJ; W°Uld achieve better control of hazardous wastes entering
POTWs. Section 3018 (b) of HSWA required the Administrator, based
on his review of the DSS, to evaluate existing regulations and
develop and promulgate the additional regulations necessary to
ensure that hazardous wastes discharged to collection
systems/POTWs would be adequately controlled to protect human
health and the environment. These regulations were to be
promulgated pursuant to RCRA, Section 307 of the CWA, and any
other appropriate authority of EPA.
In the DSS, EPA concluded that the DSE should be retained for the
present time, and recommended ways to improve various programs
administered under the CWA to obtain better control of hazardous
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wastes entering POTWs. In addition, EPA recommended research
efforts to fill certain information gaps, and indicated that
other statutes (e.g., RCRA and the Clean Air Act) should be
considered along with the CWA to control hazardous waste
discharges to POTWs, if the recommended research indicated the
presence of problems that can not be adequately controlled by the
CWA.
One of the main recommendations of the DSS was that EPA review
and amend categorical pretreatment standards (if necessary) to
achieve better control of hazardous wastes. The DSS recommended
that EPA modify existing standards to improve control of organic
priority and non-priority pollutants, and that EPA promulgate
standards for industrial categories and subcategories not
included in the NRDC Consent Decree (NRDC v. Train; 8 ERC 2120;
D.C.C.; 1976).
After considering the scope of the NRDC Consent Decree and the
extent of Paragraph 8 exemptions, EPA found that some industrial
sources of potentially hazardous waste discharges to POTWs may
not be sufficiently regulated by existing categorical
pretreatment standards. Among the industrial sources identified
were paint formulating facilities.
In response to the conclusions and recommendations of the DSS,
EPA began to collect additional data from the paint formulating
industry and other industries.
This study was conducted under the authority of Sections 301 (d)
and 304 (m) of the CWA, which require periodic review and revision
of limitations promulgated pursuant to Sections 301, 304, and 306
of the CWA.
Section 301
Any effluent limitation required by paragraph (2) of subsec-
tion (b) of this section shall be reviewed at least every
five years and, if appropriate, revised pursuant to the
procedure established under such paragraph.
Section 304 (m)
Schedule for Review of Guidelines -
(1) Publication. Within 12 months after the date of the
enactment of the Water Quality Act of 1987, and
biennially thereafter, the Administrator shall publish
in the Federal Register a plan which shall:
(A) establish a schedule for the annual review and
revision of promulgated effluent guidelines, in
accordance with subsection (b) of this section;
(B) identify categories of sources discharging toxic or
nonconventional pollutants for which guidelines
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under subsection (b)(2) of this section and Section
306 have not previously been published; and
(C) establish a schedule for promulgation of effluent
guidelines for categories identified in subparagraph
(b) , under which promulgation of such guidelines
shall be no later than four years after such date of
enactment for categories identified in the first
published plan or three years after the publication
of the plan for categories identified in later
published plans.
(2) Public Review. The Administrator shall provide for
public review and comment on the plan prior to final
publication.
1.3 Regulatory Background
£*mre"!LregUlations for the Paint formulating industry are BPT
BAT, NSPS, and PSNS for the oil-based solvent wash subcategory of
the paint formulating point source category. These regulations
SSTSJnJ* ln 1?L5X rec^ire no discharge of process wastewater
pollutants. in 1980, EPA proposed BAT, PSES, NSPS, and PSNS for
the caustic and/or water wash subcategory. However, after
proposal, the water wash subcategory was excluded from further
regulations pursuant to Paragraph 8 of the EPA/NRDC Consent
Decree.
To update earlier facts, current information has been gathered by
means of a literature search, telephone surveys with state and
local environmental agencies, site visits to 10 paint formulating
plants, meetings and conversations with NPCA representatives and
a sampling and analysis program. '
Previous studies of the paint formulating industry completed by
the EPA Effluent Guidelines Division (now the ITD) produced
several documents. The initial task of this study was to review
previous EPA work. Reports that provided background information
are discussed in the following paragraphs.
•— Proposed—Development Document for Effluent Limitations
Guidelines and Standards for the Paint Formulating Point finnr-no
Category? EPA-440/l-79/049-b; 1979.This document was prepared
?Lnthe- EPA Effluent Guidelines Division and published in late
«™^nH supp°rt °f th,e January 1980 proposal. The information
presented in the 1979 document was based on a study that occurred
S1"^9 h-e late 1970s' which included the sampling and analysis
of 22 paint formulating plants. Also included in the document
are the results of an analysis of information collected in a mail
SJJSo • °f /JKi?* fo™la.ting plants. This data collection
portfolio (DCP) was designed to gather information for the
unregulated segments of the paint industry. The DCP was mailed
to 2,778 potential paint formulating facilities. Of those
mailed, 1,374 questionnaires were completed and returned The
remaining DCPs were either mailed to facilities that were no
longer in business, were not paint formulators, were duplicate
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mailings, were mailed to people who did not respond, or were
undeliverable. The survey was divided into seven manor sections:
general information, plant operations, production
characteristics, tank and equipment cleaning, other wastewater
sources, wastewater handling and disposal, and raw materials.
Analysis of the survey data resulted in an estimate of the number
of direct, indirect, and zero discharge facilities, as well as
useful information for the regulation development process.
2. Report to Congress. Minimization of Hazardous Waste
(unpublished); Appendix B; EPA/530-SW-86-033; October 1986.
Appendix B of the Report to Congress. Minimization of Hazardous
Waste is part of a report written in response to Section 8002(r)
of the HSWA of 1984. Section 8002(r) requires EPA to evaluate
the desirability and feasibility of: (1) establishing performance
standards or taking additional actions to require hazardous waste
generators to reduce the volume or quantity and toxicity of the
hazardous waste they generate; and (2) establishing (with respect
to hazardous waste) required management practices or other
requirements to ensure that wastes are managed such that present
and future risks to human health and the environment are
minimized. Appendix B presents a description of the paint
industry, as well as an overall view of industry processes and
waste generation. The industry description is geared toward
solid waste generation and handling; however, it does refer to
all types of wastes generated at a paint formulating facility,
waste reduction, and waste handling.
3. Report to Congress on the Discharge of Hazardous Wastes to
Publicly Owned Treatment Works; EPA/530-SW-86-004; February 1986.
This report, known as the DSS, was required by Section 3018(a) of
the HSWA of 1984 to the RCRA of 1976. The DSS, as discussed
previously, examined the nature and sources of hazardous wastes
discharged to POTWs, measured the effectiveness of EPA programs,
and recommended ways to control the discharge of hazardous waste
discharges to POTWs.
4. The U.S. Paint Industry; Technology Trends. Markets. Raw
Materials; SRI International; September 1986. This report,
published semiannually for the National Paint and Coatings
Association (NPCA), updates information on the economic aspects
of the industry, market trends, consumption of paint, raw
materials, and other related information.
5. The Paint Red Book; 18th Edition; 1986. The Paint Red Book
is a comprehensive directory of paint formulators and suppliers
to the paint and coatings formulating industry.
6. Kline Guide to the Paint Industry; Sixth Edition; 1981. This
document provides a summary of the economics of the industry, an
analysis of major product groups, a directory of 400 major paint
companies, and a summary of information available from industry
organizations, publications, and technical and statistical
literature.
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TECHNICAL SUPPORT STUDY
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2.0 INTRODUCTION TO TECHNICAL SUPPORT STUDY
Sections 2 through 7 of this document provide a technical study
of the paint formulating industry focused primarily on waste
generation and characterization and wastewater treatment. The
study reviews previous EPA wastewater studies of the paint
formulating industry and updates the EPA data base.
2.1 Introduction
The technical study provides an updated profile of the paint
formulating industry, and chemical analyses of wastewater and
waste solids obtained from recent sampling episodes and recent
wastewater monitoring data obtained from state and local
authorities. The document provides a technical basis which can be
used to determine whether regulations should be developed for
this industry. The document will also serve as a summary of
information which can be used by permit writers and POTWs in
controlling hazardous wastes discharges from paint plants.
The paint formulating subcategory is defined and described in
Section 3 and subcategorization is reviewed in section 4.
Section 5 characterizes paint formulating wastewaters in terms of
flow, concentrations and loads. Pollutants of concern are
identified and discussed in Section 6, and control and treatment
technologies are discussed in Section 7.
2.2 Study Methodologies
Previous data were reviewed, data gaps and requirements were
determined, and industry comments and assistance were obtained in
meetings with NPCA personnel, specifically the NPCA Water Quality
Task Force Group.
Information to update our data base and identify candidate plants
for sampling was obtained from the following sources:
o NPDES permit files
o telephone interviews with and visits to personnel at
EPA regional offices, state offices, and paint
formulating plants
o literature searches, including research reports,
journals and magazines, and computer data bases
This information was obtained to update industry process
descriptions, review subcategorization, identify pollutants of
potential interest to determine pollutant treatability, and
identify candidate treatment technologies and waste control
practices.
As a result of previous data gathering efforts, detailed
information was collected, and it served as the basis for the
existing industry profile presented in the Development Document.
Information collected during the present study has been used to
-------
update earlier information, relating to process operations
wastewater volumes and characteristics, and handling and
disposition of wastewater and sludge. The current literature
about the industry was reviewed, and the data obtained during the
data collection efforts (including the current sampling program)
were evaluated.
A program was undertaken to collect and analyze samples of
wastewater, waste solids, and/or waste solvents at paint
formulating facilities. EPA relied on its existing database and
the advice and assistance assistance of the NPCA staff to
identify ten paint formulating facilities for site visits; four
of the ten were selected for sampling (Plants A, B, C, and D) .
Two facilities were 100 percent water-base paint formulators, one
was a 100 percent solvent-base paint formulator, and one
formulated both water- and solvent-base paint.
During sampling at the two water-base paint formulators, samples
of raw wastewater from tank and equipment cleaning operations,
treated wastewater, and sludge generated from the treatment
process were collected. During sampling at the solvent-base
paint formulator, samples of waste solids generated from a
solvent steam distillation unit were collected. During sampling
at the facility that formulated both types of paint, samples of
raw wastewater, treated wastewater, waste solids generated from
the treated wastewater, spent solvent, and spent caustic were
collected.
The wastewater samples were analyzed for conventional, toxic, and
nonconventional pollutants on the ITD List of Analytes. Solids
samples were analyzed for the same parameters, except that wet
chemistry methods were not generally used, and dioxins were
analyzed for when appropriate. In addition, sludge leachate from
solids samples, processed according to the proposed toxicity
characteristics leaching procedure (TCLP), were analyzed for the
compounds on the ITD List of Analytes.
As part of the Agency's review of the analytical data, the
amounts, frequency of occurrence, and toxicity of pollutants
found in paint formulating industry wastes are presented and
discussed in this document.
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3.0 DESCRIPTION O*1 THE INDUSTRY
As defined by Standard Industrial Classification (SIC) Manual
(1972), Code 2851, the paint and allied products industry is
composed of "establishments primarily engaged in the manufacture
of paints (in paste and ready-mixed form); varnishes; lacquers;
enamels and shellac; putties; wood fillers and sealers; paint and
varnish removers; paintbrush cleaners and allied paint products.
Establishments engaged in the manufacture of pigments (organic or
inorganic), resins, printing inks, adhesives and sealants, or
artist materials are not included in SIC 2851. The information
and discussion presented in this report addresses only the
formulation and packaging of water- and solvent-base paints.
The major products of the paint industry are architectural
coatings (usually water-base) and industrial coatings (usually
solvent-base). Architectural coatings are also referred to as
trade sales paints, which are primarily off-the-shelf exterior
and interior paints for buildings and other structures. A large
percentage of paint used for architectural coating is water-based
(i.e., more than 70 percent). Industrial coatings, also referred
to as chemical coatings, are sold to manufacturers for factory
application to such products as automobiles, aircraft, furniture,
and machinery. A large percentage of paint used for industrial
coatings is solvent-based.
Special-purpose coatings, primarily solvent-based, are formulated
for special applications and/or special environmental conditions
(e.g., extreme temperatures, chemicals, and fumes). The major
market segments for special coatings include marine, automotive
refinishing, highway and traffic markings, aerosol paints, and
miscellaneous. Special purpose coatings accounted for
approximately 15 percent of the total 1985 industry production.
Amounts of products formulated by the paint industry in 1985 are
shown in Table 3-1.
3.1 Industry Profile
Detailed information on the paint formulating industry was
developed from the 1979 Proposed Development Document.
The basic steps involved in the formulating of paint have not
changed significantly since the collection of information
supporting the 1980 proposal. The number of paint formulating
facilities in the U.S. has decreased somewhat; the proportion of
water-base to solvent-base paint production has increased signif-
icantly: and, the most significant change, has been a trend
toward eliminating the discharge of process wastewater and
pollutants, either to receiving waters or municipal treatment
works (POTWs).
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TABLE 3-1
1985 PAINT PRODUCTS BY TYPE AND END USE3
Architectural Coatings 465 million gallons
Industrial Coatings 380 million gallons
Metal Containers 15%
Automotive 12%
Machinery 10%
Sheet, Strip, and Coil 5%
Metal Furniture 7%
Wood Furniture 14%
Wood Flat Stock 4%
Other1 32%
Special-purpose Coatings 156 million gallons
Special Maintenance
Aerosols
Auto Refinishes 25%
Traffic 28%
Other2
3
1 Includes appliances, other transportation, marine, and paper and foil.
2 Includes roof, bridge, marine shelf goods, and metallic.
SRI - International - Sept. 1986 - U.S. Paint Industry
10
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Approximately 1,170 companies operate the estimated 1,440 paint
plants which employ about 54,600 people. According to the 1982
Census of Manufacturers. 28,000 people are directly involved in
the formulating and packaging of paint. Plant size, in terms of
employees per plant, is relatively small. The
Census of Manufacturers indicates that more than half of the
plants employ less than 20 employees each. Approximately half of
the 1,441 plants listed in the 1982 Census of Manufacturers are
located in five states (i.e., California, New Jersey, New York,
Illinois, and Ohio). About two-thirds of all paint formulating
plants are located in 10 states.
Paint formulating facilities may generate significant quantities
of both priority and non-priority hazardous constituents.
Earlier studies of the industry, conducted after passage of the
1977 amendments to the CWA, revealed that high concentrations of
various priority pollutants (e.g., carbon tetrachloride, benzene,
ethyl benzene, methylene chloride, phenol, toluene, zinc, lead,
mercury, copper, nickel, cadmium, and chromium), and non-
conventional and non-priority hazardous constituents (e.g.,
aluminum, iron, acetone, methanol, and N-butyl alcohol) are
generated.
Based on information currently available, most facilities
generate less than 500 gallons per day (gpd) of process
wastewater. Based on industry sources, it has been estimated
that less than half of the paint formulating facilities discharge
process wastewater to POTWs; the remaining majority of facilities
do not discharge process wastewater either directly or
indirectly.
3.2 Industry Processes
Paint formulating plants usually produce only one type of paint
[i.e., either architectural (water-base) or industrial coatings
(solvent-base)] at a given facility. A relatively small
percentage of the total number of plants produce both types of
paint at the same facility.
3.2.1 Solvent-base Paint Formulation
There are three major steps involved in the solvent-base paint
formulation and packaging process: (1) mixing and grinding of
raw materials; (2) tinting and thinning; and (3) filling
operations. Figure 3-1 illustrates these steps.
The production of solvent-base paint begins by mixing portions of
the resin, surfactant, and solvent together in a high-speed
mixer. During this operation, pigments and extenders are also
added. Following the mixing operation, the batch is transferred
to some type of dispersing equipment, including pebble, sand, or
ball mills. The type of dispersion equipment used depends on the
11
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i
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SOLVENTS
k
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t
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I
MIXING TAMK
1
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??.38L£ SAND
OR 3ALL WILL
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SURFACTANT
1
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PIGMENTS
1
i
I
HIGH SPEiD
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EXTENDING
AGENT
t
TINTS
ACOIT1VES
ACOIT1CRAL RESINS,
SOLVENT, SURFACTANT
•RNT1NG AND
THINNING
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FILTERING
I
PACKAGING
AND
LABELING
I FiNAL PRODUCT
P9COUCT QUALITY
TESTING
FIGURE 3-1
GENE.RAt FLOW DIAGRAM OF FORMULATION
PROCESS FOR SOLVENT-BASE PAJNTS
12
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type of pigment being handled and the nature of the paint being
formulated. Mixing and dispersing operations can occur
simultaneously in a high-speed mixer when the gloss, texture,, and
consistency are not as critical as in a special-purpose coating.
After dispersion, the batch is transferred to an agitated tank
where tints, thinner (solvent), and additional resin and
surfactant are added. Additives such as adhesion promoters,
anti-floating agents, anti-fearning agents, and corrosion
inhibitors may be added at this point as well. After product
quality testing and adjustment (if necessary), the paint is
filtered to remove any non-dispersed solids and then transferred
to a loading hopper. From the hopper, the paint is poured into
cans, labeled, packaged, and moved to storage.
Paint on the sides of the tanks may be allowed to drain
naturally, and the remaining "clingage" is cleaned with a
squeegee until only a small quantity of paint remains. The final
cleanup of the tanks generally consists of flushing with a
solvent. The used solvent is treated in one of three ways: (1)
it is used in the next paint batch as part of the formulation;
(2) it is collected in drums that are sold to a company where it
is redistilled and resold; or (3) it is collected in drums for
subsequent tank-cleaning operations and returned to the drums.
Ultimately, sludge settles in the drum. The sludge is disposed
of in an approved landfill.
Some plants clean solvent-base paint tanks and equipment with hot
caustic, either on a regular or periodic basis. The caustic is
generally recycled, and the caustic cleaning is followed by a
water rinse. Part of this rinse water is returned to the caustic
tank as make-up, and any remaining water is disposed of by (1)
discharging to the sewer or receiving water; (2) holding,
treating, and discharging to a sewer or receiving water; (3)
drumming and landfilling; or (4) reusing as rinse water.
3.2.2 Water-base Paint Formulation
Water-base paints are produced in a slightly different manner
than solvent-base paints. The pigments and extending agents are
usually purchased in the appropriate particle size. The pigment,
extenders, surfactant, and resin are then dispersed in water with
a saw-toothed, high-speed mixer. Small plants thin and tint the
paint in the same tank; larger ones transfer paint to special
tanks for thinning and tinting. When the formulation is correct,
the paint is transferred to a filling operation where it is
filtered, packaged, and labeled in the same manner as solvent-
base paints. The formulation process for water-base paints is
diagrammed in Figure 3-2.
As in the solvent-base paint operation, as much product as
possible is removed from the sides of the tub or tank before
final cleanup. For the water-base paint tubs, cleanup involves
13
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SURFACTANT
PIGMENTS
PRODUCT
QUALITY
TESTING
RES;NS
WATER
HIGH SP£2D
DISPERSION
TINTING AND
THINNING
I
FILTERING
EXTENDING
AGENT
TJNTS
PACXAGING
AND
LABELING
FINAL
PRODUCT
FIGURE 3-2
GENERAL FLOW DIAGRAM OF
FORMULATION PROCESS FOR WATER-BASE PAINTS
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washing the sides with either a garden hose or a more
sophisticated washing device. The wash water may be (1)
collected in holding tanks and treated before discharge; (2)
collected in drums and taken to a landfill; (3) discharged
directly to a sewer or receiving stream; (4) reused in the next
paint batch; or (5) reused in the washing operation.
Some paint plants regularly or occasionally rinse water-base
paint tanks and equipment with hot caustic, in a manner similar
to that described for solvent-base paints. Any rinse water
generated is combined with the regular clean-up water, and
disposed of by one of the same methods.
15
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4^0 INDUSTRY SUBCATEGORIZATION
The "Development Document for Effluent Limitations Guidelines and
Standards for the Paint-Formulating Point Source Category -
Proposed (1979)" identified the following factors for
consideration in developing a subcategorization scheme:
o raw materials and products
o production methods
o size and age of production facilities
o wastewater characteristics
o tank-cleaning techniques
EPA concluded that tank-cleaning techniques offer an appropriate
basis for subcategorizing the paint industry.
The Federal Register notice announcing the proposed rule (42 FR
912, January 3, 1980) suggested the following two subcategories
for the paint-formulating industry:
1. paint formulating plant which, either exclusively or in
addition to other operations, produces solvent-base or
oil-base paints where equipment cleaning is performed
using organic solvents
2. paint formulating plant which, either exclusively or in
addition to other operations, produces water-base or
solvent-base paints where equipment cleaning is
performed using water or caustic solution.
Following publication of the proposed rule, the paint formulating
industry was excluded, under authority of Paragraph 8 of the
modified Consent Decree, from further regulation under the CWA.
Therefore, Item 2 was not finalized (promulgated). For the
purpose of this document, the proposed subcategories for the
industry are appropriate.
16
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5.0 WATER USE AND WASTE CHARACTERISTICS
5.1 Wastewater Sources
The primary source of wastewater in paint formulating operations
is the rinsing of tanks and filling equipment. Wastewater
sources also include cleaning, spills, laboratory and plant
sinks, boiler and cooling water blowdown, air pollution control
devices, and the cleaning of raw material tank cars or trucks.
Most paint formulating facilities segregate non-contact cooling
water and sanitary wastewater from the process, and either
discharge the non-paint formulating wastewaters directly to the
sewer without pretreatment or to a wastewater treatment system.
Paint formulation involves three basic steps: dispersing, or
mixing, of raw materials; tinting and thinning; and filling and
packaging. Some facilities combine the first two steps by using
high-solids dispersion equipment for dispersing, mixing,
thinning, and tinting in the same tank. Other facilities mix or
disperse, and then transfer to a thinning/tinting vessel. When
the steps occur in separate vessels, dispersion tanks or ball
mills generally are cleaned by rinsing with solvent or water
(depending on the base of the particular paint batch). Caustic
rinses may follow either solvent rinses or water rinses. Many
plants routinely use a caustic-washing system for small portable
tanks or tote bins, while fixed tanks are cleaned with caustic
only when the build-up of paint residue makes it necessary.
5.1.1 Solvent-base Paint Formulation
Rinsing of solvent-base paint tanks results in a waste solvent,
which is generally handled in one of three ways:
o used in a subsequent compatible batch of paint as part
of the formulation
o collected and redistilled, by the plant or by an outside
contractor, for subsequent resale or reuse
o reused, with or without treatment (i.e., usually
settling), to clean tanks and equipment until spent;
sludge or solvent is then drummed and disposed of in an
approved site, usually by contract hauling
5.1.2 Water-base Paint Formulation
Wastewater from water-base paint tanks and equipment-cleaning
operations is usually handled in one of three ways:
o reused in a subsequent compatible batch of paint as part
of the formulation
o reused, with or without treatment, to clean tanks and
equipment until spent; after settling the sludge is
disposed of in an approved site, usually by contract
hauling; and the decant is drummed
17
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o drummed, without reuse, and disposed of in an approved
site, usually by contract hauling
5.1.3 Caustic Cleaning Operations
Plants with caustic rinse systems generally use water to rinse
the caustic residue from tanks; however, a few plants allow the
caustic water to evaporate from the tanks. Evaporation of
caustic water, however, often results in odor problems, and the
caustic residue can have a negative effect on the quality of some
paint formulations. Several types of caustic rinse methods are
used by the paint industry; for cleaning fixed tanks, two methods
are common:
o The caustic is kept in a holding tank (usually a heated
tank), and is pumped through fixed piping or flexible
hoses to the tank to be cleaned. Often a portable hood
is placed over the tank. Nozzles are used to direct the
caustic spray. After the cleaning operations are
completed, the caustic is returned to the holding tank.
o The caustic solution is prepared in the tank to be
cleaned, and the tank is soaked until clean. The
caustic solution is either transferred to the next tank
to be cleaned, stored for subsequent use in drums or
tanks, or disposed of by contract hauling.
For cleaning small portable tanks, three methods are common:
o The caustic is kept in a holding tank (usually heated)
and pumped through fixed piping or flexible hoses to the
tank to be cleaned. After cleaning, the caustic drains
to either a floor drain or a sump, and then is pumped
back to the holding tank, or, is pumped directly back to
the holding tank.
o Small tanks are put into a strainer device and dipped
into an open-top, caustic holding tank until clean.
o The tanks are placed in a dishwasher-like device that
circulates hot caustic solution, followed by a water
rinse.
The water rinse following a caustic wash is rarely reused in a
subsequent batch of paint. Following are the two common methods
for handling this rinse:
o recycling it to the caustic rinse solution
o drumming it for contract hauling
Most plants reuse the caustic solution until it loses its
cleaning ability. The caustic then is usually disposed of by
contract hauling; however, sometimes the pH is adjusted to near
neutral, and the solution is discharged to a treatment facility.
18
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5.2 Wastgwater Volume
The amount of water used to clean tanks of various sizes is
summarized in Table 5-1. The information presented is based on
an analysis of the responses to the 1977 DCP returned by the
operators of more than 1,300 paint formulating facilities.
The amount of water generated by tank cleaning is influenced by
the water pressure used. Paint formulating facilities that use
high-pressure water for tank-cleaning operations tend to generate
a smaller volume of wastewater per batch of paint produced than
facilities that use low-pressure water.
In addition to water pressure, another factor affects the amount
of wastewater generated per batch of paint produced; that is, the
presence of floor drains, which often results in the increased
use of water. The tendency to use water for cleaning is greater
when there is a place for it to drain. In the absence of floor
drains, troughs, or ditches, dry cleaning methods are often used
(e.g., rags, squeegees, vacuum pick-up devices).
Many plants, especially newer ones, have installed ditches that
drain to sumps, which pump directly to a wastewater treatment or
recycling system. In this set-up, wastewater generation can be
somewhat better controlled.
An analysis of responses to the 1977 DCP indicated that the total
wastewater generated by the paint industry was between 750,000
and 1,500,000 gallons per day. However, NPCA's comments on the
1980 proposed regulation stated that this estimate of wastewater
generation was inaccurate. In their opinion, questions asked in
the DCP concerning wastewater generation and discharge were
misinterpreted. NPCA felt that questions regarding wastewater
did not clearly differentiate between wastewater generation and
wastewater discharge. Facilities responding to the DCP had
included wastewater generated from sources other than the paint
formulating processes in their responses. Thus, quantities of
process wastewater generated and discharged were reported larger
than the actual quantities.
19
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TABLE 5-1
AMOUNT OF WATER USED TO CLEAN A PAINT TANK
Tank Size
Under 250 gal.
251-500 gal.
501-1000 gal.
1001-1500 gal.
1501-2500 gal.
2501-6000 gal.
Over 6000 gal.
Source: Proposed
Standards
1-79/049-
0-60 gal
*>
97.9
90.1
79.6
62.9
54.8
38.7
59.4
61-100 cal
Percent of Plants Responding
1.6
7.1
13.5
22.5
22.0
26.7
15.6
Development Document for Effluent
for the Paint
b; 1979, Table
Formulating Point
V-2
0.4
1.9
3.1
9.6
11.3
18.8
12.5
Limitations Gui
Source Cateeorv:
0.1
0.9
3.8
5.1
11.9
15.8
12.5
delines and
EPA-440/
Total
100%
100
100
100
100
100
100
20
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The paint formulating industry has, since the late 1970's,
significantly increased the rate of reuse and recycling of
process water and solvents. The total industry process
wastewater volume discharged, or otherwise disposed of at this
time, is much lower than the volume estimated in the 1979 support
document. In order to develop an accurate estimate of current
industry wastewater volume it will be necessary to distribute a
new survey to a statistically valid segment of the paint
formulating industry.
5.3 Wastewater Characterization
5.3.1 Background
In an effort to characterize the occurrence of conventional
pollutants and metals in wastewater from the paint formulating
industry, relatively current information was assembled.
Data presented in Appendix I of the DSS report are from the 1985
sampling of one paint formulating facility. Samples of raw
wastewater, supernatant after flocculation, wastewater sludge,
and spent caustic were collected. At the time of the sampling
episode, approximately 95 percent of the paint formulation at the
facility was water-base paint, and approximately 5 percent was
solvent-base paint. Plant personnel estimated that 75 percent of
the wastewater generated at the time of sampling was from the
washdown of tanks and filling equipment. The remaining 25
percent was estimated to be generated from floor and spill
cleanups. In 1984, an average of 2,000 gpd of wastewater
generated from water-base paint formulation was discharged to the
municipal treatment system. Treatment consisted of adding a
flocculant (i.e., Amerfloc 485) to the collected wastewater and
allowing the solution to settle for 30 to 90 minutes. The
supernatant was pumped to a second collection tank and visually
checked prior to discharge to the municipal treatment system. As
the treated wastewater was discharged to the sanitary sewer, it
was filtered to collect any fine solids. Typically, the sludge
that collected in the bottom of the treatment tank was handled in
one of two ways:
o the sludge was pumped to a truck pick-up bin located
outside the production building to be taken by a
contract hauler to a landfill approved for hazardous
material
o the sludge was pumped to a third collection tank for
further concentration if a higher percentage of solids
was desired before discharge to the pick-up bin
Three locations were sampled: a holding tank containing raw
wastewater, a treatment tank holding treated wastewater, and a
tote tank containing spent caustic. The samples were analyzed
for approximately 400 hazardous/toxic pollutants. The analytical
results are summarized in Table A-l of Appendix A.
21
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The 1976 Draft Development Document, prepared by Burns and Roe,
included a sampling program of treated and untreated paint
process wastewater streams and sludge from nine paint formulating
plants. Average untreated and treated wastewater concentrations
for metals, conventional and non-conventional pollutants from the
1976 sampling program are presented in Tables A-2 and A-3 of
Appendix A.
The 1979 Development Document presented data from sampling and
analysis of 22 paint formulating plants in 1977-78. A summary of
the analytical data for the pollutants from each of the 22 paint
plants is presented in Tables A-4 through A-6 of Appendix A.
These tables summarize the number of times each pollutant was
analyzed for, and the number of times each pollutant was found
above the detection limit. The average (mean), median, minimum,
and maximum values are also presented. For many parameters in
paint wastewater, the average value is significantly higher than
the median value. This may be caused partly by the variability
between batches, and the limited amount of data. In some
instances, the minimum, maximum, and median values are all less
than the detection limit; in these cases, the average values were
reported as the detection limit. Because the raw data from which
the tables were developed are no longer available, the data
presented in the tables cannot be verified.
Samples were taken, and test results are noted for intake tap
water (Table A-7), untreated wastewater (Table A-4), treated
wastewater (Table A-5), and sludge (Table A-6). These samples
were analyzed for 126 priority pollutants. Of the 22 plants
reported in the 1979 Proposed Development Document, 17 treated
wastewater by a batch physical-chemical (P-C) treatment system,
using chemical addition, mixing, and settling. Three plants used
a continuous system with the same unit operations as the batch P-
C plants. The two remaining plants used neutralization and
gravity separation.
5.3.2 Sampling and Analytical Results
As discussed in Section 2.0, four plants were selected for
sampling in 1986 and 1987. Liquid and solid samples were
collected and analyzed for conventional, non-conventional, and
toxic pollutants. Solid samples, if collected, were also
analyzed for their toxicity characteristic contaminants per Fed.
Reg. Prop. Rules, 6/13/86 Part 261, Toxicity Characteristics
Leaching Procedure (TCLP). This procedure requires that an
extraction be performed on the sludge sample under precise
conditions. Then tests are performed on the extract, or suspend-
ing liquid if a low solids sludge (<0.5% solids), to detect any
of 52 "Toxicity Characteristic Contaminants." Additional tests
(including volatiles) may be performed on the sludge extract
using the specific test procedures and preparations cited in
Section 261.24. If the extract concentration levels, noted in
Table I of Section 261.24, are equaled or exceeded, then the
waste sludge is considered to exhibit the characteristics of
toxicity and to be above regulatory levels. All samples were
analyzed for pollutants on the ITD List of Analytes, which
22
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includes over 300 organic pollutants previously identified as
toxic and/or hazardous by the Office of Solid Waste (RCRA,
Appendix VIII), various states (e.g., Michigan and California),
the Superfund Hazardous Substance List (HSL), the CWA Appendix C
pollutants, Paragraph 4(c) pollutants, VTOX Chemicals, and the
Priority Pesticides Review List, as well as compounds on the
original Priority Pollutants List. These pollutants are listed
in Appendices B and C.
The following paragraphs describe each of the facilities sampled,
including production information, treatment processes, and reuse
and recycling procedures.
Paint Plant A. The product from Plant A is 100 percent water-
base paint; approximately 7 million gallons are produced per
year, 70 percent of which is white paint. This plant operates
eight hours per day, five days per week. Approximately
8,000 gallons of paint wastewater (i.e., two treatment tank
batches) is generated daily. The wastewater treatment system
consists of four 5,000-gallon collection and/or treatment tanks
and a vacuum filter system for sludge dewatering.
The major source of wastewater is from the rinsing of mixing
tanks and filling equipment. Additional wastewater is generated
by floor and spill cleaning and plant sinks. The wastewater is
collected in a 5,000-gallon tank for treatment. Aluminum sulfate
is added to the treatment tank containing wastewater to create a
floe, which is then allowed to settle for approximately 25
minutes to 1 hour before discharge. Sample points are indicated
in Figure 5-1. All in-plant test data from Plant A are
summarized in Table 5-2. Solid waste is generated as sludge from
the vacuum dewatering system.
Grab samples were collected at three locations: a 5,000-gallon
holding tank containing raw wastewater; a 5,000-gallon treatment
tank containing treated wastewater; and a 5,000-gallon sludge
holding tank.
Paint Plant A discharges approximately 8,000 gpd (i.e., two
batches) of treated process wastewater.
Paint Plant B. The product from Plant B is 100 percent water-
base paint; approximately 2 million gallons are produced per
year. This plant operates eight hours per day, five days per
week. Approximately 8,000 gallons of paint wastewater are
23
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N)
WASTEWATER
COllECIION
EQUALIZATION
AND
HOLDING TANK
FLOCCULATION /
CLARIFICATION
TANK
SLUDGE
CONCENTRATION
TANK
TREATED
EFFLUENT
TANK
EFFLUENT
to WWTP
LEGEND
(§) SAMPLE POINTS
TO
WASTf
MANAGEMEN!
FIGURE 5-1
WASTEWATER TREATMENT SYSTEM
PAINT PLANT A
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TABLE 5-2
SUMMARY OF ANALYTICAL RESULTS
PAINT PLANT A
N)
m
Pollutant
Category
and Pollutant
Type 1 Organics
acetone
alpha- terpineol
benzidine
wethylene chloride
n-octacosane
n-tetracosane
1 , 1-dichloroe thane
1 , 1 , 1- trichloroethane
2,6-dinitrotoluene
tetrachloroethene
ethylbenzene
Type 2 Organics
Raw
Waste
Day 1
(Liquid)
P*/«
— —
—
5,233
136
5,133
6,919
313
~
—
—
—
Treated
Waste
Day 1
(Liquid)
P8/A
734
5,169
—
—
—
—
306
581
—
—
--
Treated
Waste
Day 1
(Replicate)
PI?/*
..
—
—
—
—
—
—
--
—
—
--
Raw
Waste
Day 2
(Liquid)
PR/*
--
—
--
—
—
—
1,22-9
—
—
—
Treated
Waste
Day 2
(Liquid)
Pu/e
715
—
.-
357
—
--
--
—
3,917
--
--
Solid
(Sludge)
PR/kg
..
_.
—
—
--
._
—
--
26
--
TCLP
Extract
(Sludge)
P8/«
__
__
__
.-
--
__
-.
..
15
13
thloxanthone
Pesticides/Herbicides
phosaet
Purgeable Organic
Compounds (TVO)
Dioxins/Furans
Hone Detected
56,000
4,800
60,000
1,886
18t — NA
41,000 78,000 5,400,000
NA
NA
— Tested, but lower than detection limit
-------
N)
TABLE 5-2
(continued)
Pollutant
Category
and Pollutant
Metals
calcium
magnesium
sodium
aluminum
manganese
lead
vanadium
boron
barium
beryllium
cadmium
molybdenum)
tin
yttrium
cobalt
chromium
copper
iron
nickel
titanium
zinc
silver
antimony
mercury
Elements
erbium
germanium
iodine
Raw
Waste
Day 1
(Liquid)
PR/*
858,000
49,000
84,000
424,000
3,060
211
299
136
1,720
2.7
21
«
554
41
76
228
167
132,000
126
4,650
155,000
2.7
51
""
DET
DET
DET
Treated
Waste
Day 1
(Liquid)
PR/*
108,000
30,000
357,000
806
224
—
--
155
102
.-
--
—
—
—
—
—
81
—
10
5,810
--
43
™~
„
—
—
Treated
Waste
Day 1
(Replicate)
PR/*
113,000
31,000
383,000
859
234
__
2.5
230
104
__
—
—
__
._
—
—
74
—
—
6,100
--
131
--
NA
NA
NA
Raw
Waste
Day 2
(Liquid)
PR/*
224,000
41.000
110,000
138,000
1,090
56
127
131
2,830
__
16
386
5.3
82
250
195,000
52
2,000
11,300
..
331
—
DET
DET
Treated
Waste
Day 2
(Liquid)
PR/*
95,000
36,000
198,000
1,790
179
__
26
126
271
*•»
..
.» _
V •
_.
.-
335
at.
872
• «.
514
--
_ _
--
Solid
(Sludge)
i*R/kg
17,300
593
941
14,300
118
55
10
19
271
4
40
45
10
18
10
12,600
446
3,030
._
0.14
DET
—
TCLP
Extract
(Sludge)
Ug/JK
258,000
6,540
1,810,000
13,000
571
1,580
10
100
„
»
139
63
297,000
66
NA
NA
NA
-------
10
TABLE 5-2
(continued)
Pollutant
Category
and Pollutant
potassium
phosphorus
praeseodymium
sulfur
selenium
silicon
strontium
thallium
tungsten
Conventional Pollutants
Raw
Waste
Day I
(Liquid)
mg/«
DET
DET
DET
DET
DET
DET
DET
DET
DET
Treated
Waste
Day 1
(Liquid)
mg/£
DET
—
—
DET
--
DET
—
DET
--
Treated
Waste
Day 1
(Repl icate)
mg/«
--
—
—
—
—
—
—
--
Raw
Waste
Day 2
(Liquid)
mg/«
DET
DET
—
DET
DET
DET
—
DET
--
Treated
Waste
Day 2
(Liquid)
mg/kg
DET
--
—
DET
—
DET
--
DET
--
Solid
(Sludge)
mg/kg
DET
—
DET
—
DET
—
DET
--
TCLP
Extract
(Sludge)
mg/«
NA
NA
NA
NA
NA
NA
NA
NA
NA
BOD-5 Day (carbonaceous) 6,000
oil and grease,
total recoverable 470
pH, soil NA
residue, non-filterable 33,000
Hon-conventtonal Pollutants
residue, filterable 8,100
fluoride 0.32
ammonia, as N 24
nitrogen, Kjeldahl, total 120
nitrate-nitrite, as N 0.14
>3,400b
62
NA
40
2,400
0.28
30
81
0.38
3,400
70
NA
47
2,400
0.26
31
83
0.42
1,700
160
NA
20,000
5,500
0.28
16
44
0.14
1,500
33
NA
76
1,700
0.25
14
42
0.05
NA
NA
7.5
NA
NA
NA
140
1,100
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
TABLE 5-2
(continued)
Pollutant
Category
and Pollutant
total phosphorus, as P
chemical oxygen demand
total organic carbon
corrosivity
Raw
Waste
Day I
(Liquid)
•*/«
— —
34,000
4,900s
Treated
Waste
Day 1
(Liquid)
mg/£
0.16
6,8000
2,500
Treated
Waste
Day 1
(Replicate)
mg/£
0. 13
7,100
2,400
Raw
Waste
Day 2
(Liquid)
»(?/*
17,000
1 , 100s
Treated
Waste
Day 2
(Liquid)
-------
treated and discharged each week. The plant wastewater treatment
system consists of four 5,000-gallon collection and/or treatment
tanks. The wastewater flow discharge, including process water,
cooling water, and sanitary, totals approximately 22,000 gpd.
The normal procedure for treatment involves the following steps:
1. Collect 3,500 gallons of wastewater in the first tank.
2. Pump the collected wastewater into the second tank.
3. Add 150 pounds of aluminum sulfate and agitate for
approximately 30 minutes.
4. Add 10 gallons of caustic and agitate for approximately
30 minutes.
5. Let the solution settle overnight.
6. Pump about 400 gallons into the final tank.
7. Add 4,000 gallons of tap water; mix and sample prior to
discharge.
8. This process (6 and 7) is repeated until all the settled
wastewater is discharged to the sewer.
The generated sludge from the second tank is pumped to a sludge
holding tank before being transferred to a truck for hauling.
The sludge is hauled to a waste management facility, where it is
dehydrated and transferred to an appropriate landfill.
At the time of the sampling event, wastewater generation was low.
Thus, obtaining a full batch of wastewater for treatment resulted
in a more diluted batch than normal. Treatment consisted of
adding caustic and aluminum sulfate to the batch of wastewater
and allowing it to settle overnight. Prior to discharging to the
sanitary sewer, approximately 900 gallons of treated wastewater
was transferred to another tank and diluted with water at a ratio
of 4 to 1 (instead of the normal ratio of 10 to 1). Samples were
collected prior to discharge to check for pH and suspended
solids.
The major source of wastewater is from the rinsing of mixing
tanks and filling equipment. Additional wastewater is generated
by floor and spill cleaning, and laboratory and plant sinks. The
wastewater is collected in a 5,000-gallon tank for treatment.
Solid waste is generated as sludge from the flocculation
treatment.
Samples were collected at four locations: a 5,000-gallon holding
tank containing raw wastewater; a 5,000-gallon treatment tank
containing treated wastewater; a 5,000-gallon tank containing
diluted treated wastewater; and the sludge discharge from the
5,000-gallon settling tank. Sample points are indicated in
Figure 5-2, and test data are summarized in Table 5-3.
29
-------
Paint Plant C. The products from Plant C are 100 percent
solvent-base paints and varnishes. This plant operates thirteen
hours per day, five days per week. No wastewater is generated at
this plant, with the exception of sanitary waste. Sludge is
generated at this plant from waste solvents. Treatment involves
a steam distillation system which yields solvents for reuse.
Sludge samples were collected at the discharge outlet from the
steam distillation system. The sludge discharges at a
temperature of 210°F. Approximately four 55-gallon drums of
sludge are generated daily. A diagram of the plant's
distillation system is shown in Figure 5-3. Table 5-4 summarizes
test results from on-site sampling at Plant C.
Paint Plant D. Plant D operates a batch-formulating system
24 hours per day, three shifts per day, five days per week.
Total yearly paint production is approximately 6 million gallons;
approximately 35 percent is water-base paint, and approximately
65 percent is solvent-base paint. The wastewater treatment
system consists of four 6,300-gallon collection and/or treatment
tanks.
Wastewater is generated from tank and equipment washing. White
wash water (i.e, wash water generated from the cleaning of
certain white paint formulation tanks) is stored in one of four
6,300-gallon treatment tanks located in the waste treatment room.
Approximately 5,000 gallons of wastewater are generated weekly.
When enough wastewater is collected to fill the treatment tank,
it is treated with aluminum sulfate and allowed to settle for
24 hours. After treatment the supernatant is pumped to a second
6,300-gallon treatment tank, and is used as make-up water for
caustic wash solution. The sludge generated from treatment is
pumped to a third 6,300-gallon treatment tank. The sludge,
although not considered a hazardous waste, is hauled to a
hazardous waste landfill. A fourth 6,300-gallon treatment tank
is available for wastewater collection if extra capacity is
needed. The facility does not discharge any process wastewater
to the sanitary sewer. The caustic wash is used until it becomes
ineffective. The spent caustic is contained in 250-gallon tote
tanks until it can be pumped into a hazardous waste tanker truck
and hauled off-site to a hazardous waste landfill. Approximately
118,000 gallons of spent caustic and 170,000 gallons of sludge
are generated yearly. Waste solvent generated from solvent tank
washing is collected in a 6,000-gallon, spent solvent storage
tank located outside the waste treatment room. The facility has
a solvent distillation unit on-site; however, it was not
operating during the sampling visit. The solvent distillation
system is expected to restart operations sometime soon. At the
present time, solvent waste is collected and sent off-site for
reclamation.
30
-------
\
WA3UWATER
COLLECTION
EQUALIZATION
AND
HOLDING TANK
LEGEND
SAMPLE POINTS
FLOCCULATION /
CLARIFICATION
TANK
SLUDGE
CONCENTRATION
TANK
CHEMICAL
WASTE MAMAOEMENT
FIGURE 5-2
WASTEWATER TREATMENT SYSTEM
PAINT PLANT B
CITY
WATER
DILUTED
TREATED
EFFLUENT
TANK
EFFLUENT
to WWTP
-------
TABLE 5-3
SUMMARY OF ANALYTICAL KF.SUI.TS
PAINT PLANT K
ro
Pollutant
Category
and Pollutant
Type 1 Organ ics
acetone
a Ipha-terpineol
diplicnylamiiic
methyl ene chloride
n-decane
n-dodecanc
n-eicosane
n-octadecane
n-tetradecane
n-triacontane
naphthalene
2-chloronaph thai ene
Raw
Waste
(Liquid)
L'g/e
—
1,028
15,338
—
12,069
7,642
3,857
4,621
—
—
8,053
8,120
Treated
Waste
(Liquid)
[Jg/£
1,523
2,046
--
—
—
—
—
1,168
--
—
--
5,515
Treated""
;ind Diluted
Waste
(Liquid)
I'8/S
136
--
--
—
—
--
—
20
16
--
—
—
(Sludge)
I'gAg
363
283
—
60
166
--
—
34
--
191
43
--
TCLP
Extract
(Sludge)
I'gM
141
23
—
1,415
22
—
--
11
-_
49
12
—
Type 2 Organics
isobiityl alcohol
Pesticides/Herbicides
chlordane
Purgeable Organic
Compounds (TVO)
Dioxins/Furans
Not Detected
NA
130,000
NA
12.50
7,600
NA
310
NA
117
NA
160,000
ND
NA
NA
NA
"' Not used in data Avg. Diluted. Not representative
— Tested less than detection limit
-------
TAIH.F. 5-3 (continued)
ui
U»
Pollutant
Category
and Pollutant
Metals
calcium
magnesium
sodium
aluminum
manganese
lead
vanadium
boron
barium
beryllium
cadmium
molybdenum
tin
yttrium
cobalt
chromium
copper
iron
nickel
titanium
zinc
arsenic
antimony
mercury
Elements
erbium
germanium
iodine
potassium
phosphorus
Raw
Waste
(Liquid)
Mg/*
270,000
31,000
83,000
230,000
9,100
53
190
87
2,300
3
—
15
250
25
31
110
320
140,000
110
8,900
3,400
83
—
~~
*
DET
DET
DET
DET
DET
Treated
Waste
(Liquid)
Mg/«
20,000
2,100
1 ,000,000
33,000
140
--
38
100
20
—
—
28
--
--
5
6
97
2,900
23
63
130
14
33
~ ~
__
--
—
DET
DET
Treated
and l)i (tiled
Waste
(Liquid)
l'S/«
32,000
9,200
72,000
2,600
13
--
3
23
40
—
—
--
—
--
—
—
8
290
--
21
13
--
--
""
—
--
—
--
Dry
(Sludge)
mg/kg
7,870
2,640
7,400
21,000
622
—
—
--
373
™~
— -
78
— —
--
--
31
23
40,300
25
1,060
169
--
--
0.44
DET
—
~ —
--
TCLP
Extract
(Sludge)
Mg/*
117,000
7,060
1,460,000
25,800
1,310
•• —
--
1,040
747
_ •»
"• ~
--
~ ~
™ -
•• ""
--
- -
--
60
--
1,460
— —
--
NA
NA
ET A
NA
NA
NA
Less than detection limit
-------
TABLE 5-3 (continue*!)
Pollutant
Category
and Pollutant
strontium
thallium
tungsten
Raw
Waste
(Liquid)
mg/£
DET
DET
DET
Tre.ited
Waste
(Liquid)
mg/«
Nl)
Nl)
ND
Treated
and Diluted
Waste
(Liquid)
mg/£
ND
ND
ND
(Sludge)
mg/kg
Nl)
ND
ND
TCI.P
Extract.
(Sludge)
MR/*
NA
NA
NA
Conventional Pollutants
BOD 5-day (carbonaceous)
oil and grease, total
recoverable
pH, soil
residue, non-filterable
w Non-conventional Pollutants
residue, filterable
fluoride
ammonia, as N
nitrogen, Kjeldahl, total
nitrate-nitrite, as N
total phosphorus, as P
chemical oxygen demand
total organic carbon
sulfide, total (iodometric)
flash point (°C)
residue, total (%)
residue, total volatile (%)
>4,000b
330
NA
32,000
22,000
25
94
0.27
32,000
5,900
1.4
NA
NA
NA
>4,100b
69
NA
330
4,400
0.35
24
81
0.63
14,000
2,800
4.7
NA
NA
NA
430
Indicates pollutant at a concentration lower than the stated detection limit.
NA Indicates not analyzed.
b BOD calculated from limiting value.
DET Indicates compound was detected.
NA
NA
--
NA
21
440
1.0
1.4
8.8
0.29
0.14
980
160
2.1
NA
NA
NA
NA
7.1
NA
NA
NA
190
—
30
NA
NA
NA
NA
55
35
33
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
TABLE 5-4
SUMMARY OF REPORTED ANALYTICAL RESULTS
PAINT PLANT C
Pollutant
Category
and Pollutant
Sludge
Dry
TCLP Extract (pg/D
Type 1 Organics
acetone
chlorobenzene
ethyl benzene
toluene
trichloroethene
1,1,1-trichloroethane
2-Butanone (MEK)
Type 2 Organics
isobutyl alcohol
Pesticides/Herbicides
Not Analyzed For
Purgeable Organic
Compounds (TVO)
Not Analyzed For
Dioxins/Furans (ng/kg)
2,3,7,8-TCDD
97
1,503
10,013
110
4,027
235,287
2,560
330,000
597
122
100
18,941
NA
12.71
NA
35
-------
Pollutant
Category
and Pollutant
Metals
calcium
magnesium
sodium
aluminum
manganese
lead
boron
barium
cadmium
molybdenum
tin
cobalt
chromium
copper
iron
nickel
titanium
zinc
mercury
Elements
sulfur
Conventional Pollutants
Total Residue - %
pH, soil
Non-conventional Pollutants
ammonia, as N
nitrogen, Kjeldahl, total
nitrate-nitrite, as N
flash point (°C)
residue, total (%)
residue, total volatile (%)
sulfide, total
(Monier-Williams)
corrosivity
TABLE 5-4
(continued)
Sludge (mg/kg)
45,400
8,230
2,800
4,400
594
152
--
1,960
7
121
1,370
886
3,590
338
31,100
28
168
6,100
0.56
DET
30
6.8
110
4,700
240
51
30
15
12
<10
TCLP Extract (MR/£)
41,600
2,080
1,530,000
279
1,840
* _
368
1,780
. _
_ _
__
1,650
830
188
--
69
__
6,960
—
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA Indicates not analyzed.
Indicates that pollutant detected at a concentration lower than the
stated concentration limit.
DET Indicates that pollutant concentration qualitatively detected.
36
-------
U)
HEAT
EXCHANGER
r t
SOLVENT
STORAGE
TANK
COALESCER/
SEPARATOR
SAMPLE
POINT
SLUDGE
PURIFIED
WATER
COLLECTED
FOR REUSE
SOLVENT
WATER
SEPARATOR
FIGURE 5-3
SOLVENT PURIFICATION
PAINT PLANT C
-------
t /«™,i^• lng °Pffation is essentially separate from the
j- formulating operation. A 6,000-gallon, organic storage
blending tank contains waste solvent and resin waste from th!
S!J" °PeraV°n- s?me solvent-base paint waste is added to this
tank; the mixture is then sent out for use in a fuel-blendina
wa?!ra?;oGrab<- Sa*Pltt Wfre collected ««» six locations: ciSy
non^in^ * P ^ the laboratory<* a 6,300-gallon treatment tank
So«a g1raW.Wastewater; a 6'°00-gallon storage tank containing
spent solvent; a 6,300-gallon treatment tank containing
rPfier,nntanV; a 250-gallon tote tank containing spent GausS^and
a 6 300-gallon treatment tank containing sludge (generated from
wastewater treatment). Sample points are indicated in Figure 5-
4, and test results are summarized in Table 5-5.
38
-------
SUPERNATANT
ILUOftl
TREATMENT
ROOM
to
vO
PROCESS
WATIR
A-l, A-2.A-3' 6.300- GALLON WASTE WATER
TREATMENT TANKS
103 • SUPERNATANT STORAGE TANK
• i tOOO-OALLON SPENT SOLVENT STORAGE TANK
C i 250-GALLON SPENT CAUSTIC TOTE TANK
*• SAMPLE POINT LOCATIONS
LYE
ROOM
TO OUT1IDC
RECLAIMER
TO CONTRACT
HAULER
FIGURE 5-4
SAMPLE POINT SCHEMATIC
PAINT PLANT D
-------
TABLE 5-5
SUMMARY OF ANALYTICAL RESULTS
PAINT PLANT 0
Pollutant
Category
and Pollutant
Type 1 Organics
acetone
acrolein
benzene
bis(2-ethylhexyl)
pbthalate
chlorobenzene
chloroform
di-n-butylphthalate
ethyl benzene
isophorone
•ethylene chloride
naphthalene
p-cymene
tetrachloroethene
toluene
trichlorethene
1,1 dichloroethene
1,1,1 trichloroethane
2-butanone
3,3'-dichlorobenzidine
Tap
Water
(Liquid)
--
•*••
—
—
—
24
"""
__
—
—
•••"
Raw
Waste
(Liquid)
l'g/£
1,926,380
™ ~
--
--
—
119,186
3,090
4,696
1,092
100,793
373
1,444
•••
Treated
Waste
(Liquid)
|lg/£
743,410
~—
~~
--
2,742
1,110
246
--
946
583,400
Spent
Solvent
(Lii)uid)
8,187,200
61,241
153,424
13,661
3,601,700
113,782
6,309,100
~~
73,105
295,520
Spent
Caustic
(Liquid)
12,840,400
""'
~ ™
34,077
3,289
7,395
2,262
293,580
1,261
1,811,550
Dry
(Sludge)
PR/kg
7,617,357
42,460
33,736
129,336
25,979
7,929
88,136
606,300
7,914
6,061,071
174 1S7
j i •* , j j i
TCLP
Extract
(Sludge)
17,548,900
5,943
103
15,553
2,786
__
66,723
880
1,318,660
Type 2 Organics
vinyl acetate
Pesticides/Herbicides
3,653
-------
TABLE 5-5
(continued)
Pollutant
Category
and Pollutant
Elements
indium
iodine
lanthanum
lithium
lutetium
neodymium
osmium
phosphorus
platinum
potassium
ruthenium
samarium
silicon
strontium
sulfur
thorium
zirconium
Tap
Water
(Liquid)
—
--
—
—
--
—
—
—
"•
4
5
•~
•~
Raw
Waste
(Liquid)
—
-—
0.1
0.1
— ~
0.5
7
5
"""*
50
4
126
0.3
Treated
Wnste
(Liquid)
mg/£
—
™~
—
--
""
• —
1
5
4
1
1,020
Spent
Solvent
(Liquid)
1
0.1
0.2
01
. I
0.6
12
2
3
10
3S
in
IV
Spent
Caustic
(Liquid)
~™
0.1
inn
Jvv
17
1 If
16
I
1,180
0.8
Dry
(Sludge)
nig/kg
—
106
—
__
106
21
1,700
11
TCLP
Extract
(Sludge)
pg/*
NA
NA
UA
WA
UA
NA
NA
NA
nn
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
to
TABLE 5-5
(continued)
Pollutant
Category
und Pollutant
Metals
calcium
magnesium
sodium
aluminum
manganese
lead
vanadium
boron
barium
beryllium
cadmium
tin
I & II
cobalt
chromium
copper
iron
nickel
titanium
zinc
silver
antimony
mercury
Tap
Water
(Liquid)
MR/*
12,700
1,910
6,410
--
—
--
62
53
--
—
— —
Raw
Waste
(Liquid)
I'g/e
1,790,000
21,800
921,000
135,000
795
1,830
7A
/ **
1,400
3,780
217
481
1,670
822
313
14,400
2,970
843,000
--
3,500
Treated
Waste
(Liquid)
I'B/K
533,000
6,610
/ 1,120,000
10,100
345
1,640
103
62
791
648
52
118
174,000
--
232
Spent
Solvent
(Liquid)
MB/*
2,880,000
136,000
43,400
292,000
3,710
426,000
107
788
29,100
7
74
2,980
17,900
176,000
745
762,000
694
9,130
1,120,000
55
4,390
159
Spent
Caustic
(Liquid)
MR/*
161,000
4,570
6,360,000
48,600
348
434,000
90
10,300
1,740
11
699
1,110
13,400
711
10,300
889
131,000
1,690
432
(Sludge)
mg/kg
20,100
535
5,940
10,300
28
114
221
3
41
20
28
38
1 ,630
278
7,160
__
67
TCLP
Extract
(Sludge)
MB/*
273,000
4,440
760,000
29,700
120
248
178
496
25*
40*
167
• 1 18
1 1 O
61
V 1
3,280
490
144,000
80
-------
u>
Tap
Pollutant Water
Category (Liquid)
Conventional Pollutants
BOD 5 -Day (carbonaceous)
oil and grease,
total recoverable
pH, soil
residue, non-filterable
Non-conventional Pollutants
residue, filterable
cyanide, total
fluoride
ammonia, as N
nitrogen, Kjeldahl, total
nitrate-nitrite, as N
total phosphorus, as P
chemical oxygen demand
total organic carbon
sulfide, total (iodometric)
flash point (°C)
residue, total (%)
residue, total volatile (%)
sulfide, total
(Honier-Williams)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Indicates pollutant detected at
NA Indicates not analyzed.
* Oxygen depletion exceeded
NR No value reported due to
TABLE 5-5
(continued)
Raw Treated Spent Spent
Waste Waste Solvent Caustic
(Liquid) (Liquid) (Liquid) (Liquid)
mg/£ mR/e «ig/£ me/j
16,000 9,900
560
NA
38,000
2,500 6
0« i
. 1 1
MD
NK
63
370
1^
.3
0.61
89,000 42
11,000 7
NR
NA
U A
NA
NA
LI A
NA
a concentration lower
94
MA
WA
960
,800
NR
nix
£Q
O J
t c
15
i 7
i . i
0.31
,000
,300
1.9
ml it
NA
NA
Nn
MA
NA
MA
vtn
than the stated
NA
NA
NA
NA
NA
NA
NA
NA
NA
Hrt
NA
NA
NA
NA
NA
MA
Fin
NA
NA
i*n
NA
detection
*
240
NA
1,900
31,000
0.077
3.2
34
18
4.7
1.6
88,000
14,000
14
NA
NA
NA
NA
limit.
Dry
(Sludge)
NA
NA
6.8
NA
NA
56
NA
140
--
17
NA
NA
NA
NA
30
14
40
4.8
TCLP
Extract
(Sludge)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
limiting value of 1 mg/Z during incubation.
severe matrix interferences.
-------
1^0 POLLUTANT PARAMETERS
6.1 Introduction
The purpose of the 1977-1979 study of the paint formulating
industry was to determine the presence and amount of toxic?
pollutants present in paint formulating facility wastewaters
The 1977-1979 study focused on a list of 65 compounds and clashes
of compounds published in the Consent Decree, which required EPA
!;0mCO-n.sl.d_eiL .tne need to regulate these compounds during review of
BAT Limitations for twenty-one industries. EPA identified 129
specific toxic pollutants (priority pollutants) for study, based
on criteria including: toxicity, frequency of occurrence in
n^Ao(?hemiSaiv,Stabi^t^.a^d struct»re, amount of the chemical
produced, and the availability of analytical methods. Three of
the pollutants on the list, which is known as the Priority
Pollutant List, have since been deleted; the remaining 126
priority pollutants are listed in Appendix B.
The study of 12 industries identified in the DSS (including the
paint formulating industry) concentrated on a list of pollutants
derived from the "ITD/RCRA List of Lists." This List of Analytes
(more than 350 compounds) includes all the priority pollutants
plus additional compounds. All other pollutants on the List of
Analytes can be found in Appendix C. This ITD List of Analytes
was derived from the following: over 300 organic pollutants
previously identified as pollutants considered toxic, and/or
hazardous, by the Office of Solid Waste (RCRA, Appendix VIII)
various states (e.g., Michigan and California), the Superfund
{Snv OK (?WA; APP®ndix 9 Pollutants, Paragraph 4(c) pollutants,
VTOX Chemicals, the Priority Pesticides Review List, and the
original Priority Pollutant List.
The following rules were used as guidelines for selection of
candidate pollutants. All analytes shall be included in the List
of Analytes, except:
o analytes that appear on the "Acutely Toxic Chemicals
List" only; this list is part of EPA's Chemical
Emergency Preparedness Program
o analytes that are hydrolyzed or destroyed by water
o analytes that are designated for analysis by high
performance liquid chromatography (HPLC)
o analytes that must be derivatized (except for the
phenoxy acid herbicides analyzed by Method 615)
o analytes for which no standard is available
o analytes for which there is no analysis type
44
-------
6.2 Pollutant Categories
Tables 6-1 and 6-2 present data summaries of pollutants found in
vo?ati?es?9 semivolatile, pesticides and herbicides, metals,
conventionals and non-convent ionals.
- ec
is based only on concentrations detected above trie
Tables 5-2, 5-3, 5-4, and 5-5.
6.2.1 Organic Pollutants
A total of 22 volatile or semivolatile organic compounds were
found at above detection limit levels in ™*JJ?^' "gj?8
collected at four paint formulating plants in 1986 and 1987 .
Twelve of these compounds are organic compounds on the 1977
Priority Pollutant List. Table 6-1 presents information ^on th ese
pollutants. The remaining 10 organic compounds found are on the
??87 List of Analytes. These 10 compounds were not analyzed for
in earlier sampling and analysis programs. Table 6-2 presents
information on these pollutants.
fi.3.2 Metals
The metals found in the highest concentrations were aluminum,
Sssr
raw wastewater samples. Concentrations were generally
cantly reduced in the treated effluent except for sodium, cobalt,
boron, and chromium.
Metals found present in the highest quantities in the ™tewater
were calcium, sodium, zinc, aluminum and iron. Only zinc is on
the priority pollutant list.
fi.3.3 Pesticides/Herbicides
Three of these compounds were detected. Priority pollutants
chlordane and aldrin were found at low concentrations in the
treated wastewater, but not in raw wastewater. The aldrin was
found only in a sample of a diluted wastewater stream Dodged as
non-representative of the particular plant and is referenced
only. Phosmet was determined only in one plant 'raw wastewater,
but not in the treated wastewater. No other
pesticides/herbicides were detected.
45
-------
TABLE 6-1
DATA SUMMARY
1986/1987 SAMPLING PROGRAM
PRIORITY POLLUTANTS
RAW WASTEWATER
o»
NUMBER
POLLUTANT CATEGORY/ OF SAMPLES
POLLUTANT ANALYZED
Volatile!
1. 1,1-Dichloroetbane
2. Ethyl Benzene
3. Nethylene Chloride
4. Tetrachloroethene
5. Toluene
6. 1,1,1-Tricbloroethane
7. Trichloroethene
Seaivolatilei
8. Beozidine
9. 2-Chloronapthalene
10. 2,6-Dioitrotolueoe
11. Isopborone
12. Raphthalene
Peiticidei/Herbicidet
13. Chlordane
14. Aldrin
Metals
15. Antimony
16. Arsenic
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
RANGE
NUMBER
OF DETECTIONS Ott/1)
1
1
1
1
1
2
1
1
2
0
1
2
0
0
2
1
ND-313
ND- 119, 186
ND-136
ND- 1,092
HD- 100, 793
ND- 1,444
ND-373
ND-5,233
ND-8,120
ND
ND-3,090
ND-8,053
ND
ND
ND-831
ND-83
AVERAGE MEDIAN
CONCENTRATION
(ME/*) (UE/0
313
119,186
136
1,092
100,793
1,337 1,337
373
5,233
8,120
ND ND
3,090
6,375 6,375
ND ND
ND ND'
191 191
83
NUMBER
OF SAMPLES
ANALYZED
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
i i\K.n i c.u **m? i L.w/1
RANGE
NUMBER
OF DETECTIONS (u*/l)
1
0
2
1
0
2
0
0
1
1
1
0
1
1
4
,
ND-306
ND
ND-1,110
ND-246
ND
ND-946
ND
ND
ND-5,515
ND-3,917
ND-2,742
ND
ND-12.5
ND-0.6
ND-514
ND-14
ttcn
AVERAGE MEDIAN
CONCENTRATION
(PR/I) i u* in
306
ND
734
246
ND
764
ND
ND
5,515
3,917
2,742
ND
12.5
0.6
205
14
..
ND
734
..
ND
764
ND
HD
--
—
..
ND
«
137
— —
-------
POLLUTANT CATEGORY/
POLLUTANT
Metal» (continued)
17. Beryllium
18. Cadaiua
19. Cbro»iua>
20. Copper
21. Uad
22. Mercury
23. Nickel
24. Silver
25. Zinc
Non-Convent i ona 1 1
26. Total Cyanide
NUMBER
OF SAMPLES
ANALYZED
4
4
4
4
4
4
4
4
4
4
niU UiSTFUATER
TABLE 6-1
(continued)
-RANGE AVERAGE MEDIAN NUMBER
NUMBER CONCENTRATION OF SAMPLES
OF DETECTI™"1 '••-'•» lu*'l) (""/t) 'ANALYZED
2
2
4
4
4
1
3
1
4
1
ND-3
ND-217
82-822
167-320
53-1,830
ND-3, 500
ND-126
ND-2.7
3,400-843,000
ND-110
2.9 2.9
119 119
311 169
263 282
538 134
3,500
96 HO
2.7
253,175 83,150
110
5
5
5
5
5
5
5
5
5
5
TREATED UASTEWATER
RANGE AVERAGE ritui™
NUMBER CONCENTRATION
OF DETECTIONS (UK/t) <"*/*)
0 ND
1 ND-62
2 ND-648
2 ND-97
0 ND
1 ND-232
1 ND-23
0 ND
5 130-174,000
0 ND
ND
62
327
75
ND
232
23
ND
37,382
ND
ND
327
75
ND
ND
5,810
ND
-------
TABU 6-2
DATA SUNHART
1986/19*7 SAMPLING PROGRAM
NON-PRIORITY POLLUTANTS
inM.rn
POLLUTANT CATEGORY/ OF SAMPLES
POLLUTANT ANALYZED
VoUtile»
1 . Acetooe
2. 2-Butaeeee
8e«i»olatile«
3. Alpha-Terpiaeol
4. DipheoylniBe
5 . n-Decane
*J 6. a-Dodecaoe
7. a-Eicoaaac
1. a-Octacocne
9. n-Octadecaa*
10. a-Tet raceme
PeiUetdo/Berbicidea
11. Fbosact
Hetali
12. AluaiietM
13. iariiaa
14. loroe
HAW VA5TEHATI
.K
RANGE AVERAGE MEDIAN
NUMBER CONCENTRATION
OF DETECTIONS (|i«/I) (Ug/i) (u«/l)
NUMBER
OF SAMPLES
ANALYZED
TREATED WASTEWATFJt
RANGE
NUMBER
OF DETECTIONS I,,.H1
4
4
4
4
4
4
4
4
4
4
4
4
4
4
1 ND-1,926,380
0 ND
1 HD- 1,028
1 NO-15.33*
1 ND-12,069
1 ND-7,642
1 ND-3,857
1 HD-S.133
1 MD-4.621
1 MD-6.919
1 KD-18
4 135,000-424,000
4 1, 720-3.7*0
4 87-1,400
1,926,380
ND ND
1,028
15,338
12,069
7,642
3,857
5,133
4,621
6,919
IS
231,750 184,000
2,658 2,565
439 134
5
5
5
5
5
5
5
5
5
S
5
5
5
5
4
1
2
0
0
0
0
0
1
0
0
5
5
5
ND- 743, 410
MD-583,400
ND-5,169
ND
ND
ND
ND
HD
ND- 1,168
ND
ND
806-33,000
20-271
100-1,640
AVERAGE MEDIAN
CONCENTRATION
(uc/Jt) '••- '•*
186,596
583.400
3,608
ND
NT)
ND
ND
ND
1,168
ND
ND
9.311
120
450
1,129
—
3,608
HD
HD
ND
ND
HD
• •
HD
ND
1.790
103
15S
-------
TABU 6-2
(continued)
vO
POLLUTANT CATEGORY/
IS.
16.
17.
11.
19.
20.
21.
22.
23.
2*.
25.
Calciuai
Cobalt
Irea
HafMiio*
NantaMte
HolyMenoB
Sodiiaa
Tin
Titaniuai
Vanadiua
TttriuB
NUMBER
OF SAMPLES
*
4
4
4
4
4
4
4
4
4
4
BUI VASTEUATER
TREATED WASTEWATEH
RANGE AVERAGE MEDIAN NUMBER
IIUHBER CONCENTRATION OF SAMPLES
OF DETECTIONS (u«/») (ut/t) (Ut/i) ANALYZED
4
4
4
4
4
2
4
4
4
4
2
224,000-1,790,000
5.3-1,670
14,400-1,950.000
21,800-49,000
795-9100
KD-16
(3,000-921,000
250-554
2,000-8,900
74-299
HD-41
785,000
446
120,350
35,700
3,511
16
299,500
418
4,630
173
33
564,000
54
136,000
36,000
2,220
16
97,000
434
3,810
159
33
5
5
5
5
5
5
5
5
5
5
S
RANGE AVERAGE nuiinn
NUMBER CONCENTRATION
OF DETECTIONS (pi/t) (u«/« (m/«)
5
2
5
5
5
1
5
0
2
3
0
20.000-533,000
HD-791
74-2,900
2,100-36,000
140-345
WD-28
198,000-
1.112,000
ND
ND-63
ND-38
ND
173,800
391
702
21,142
224
28
611.600
ND
37
22
ND
108,000
39*
118
30,000
224
"""
383,000
ND
37
26
ND
Convent ionaU
26. BOD
27. TSS
Non-Conrentionalt
28. AaBwnia. at N
29. Fluoride
30. COD
4
4
4
2
4
1,700,000- 6,925.000 5,000,000 5
16,000,000.
20,000,000- 30,750,000 32,500,000 5
38,000,000
16,000-63,000 32,000 24,500 5
1ID-320 300 300 5
17,000,000- 43,000,000 37,000,000 5
89,000,000
5
5
5
4
5
1.500,000- 4,460,,000 3,400.000
9,900,000
40,000-
960.000
290,600 76,000
14,000-69.000 33.600 30.000
ND-350 231 270
3,600,000- 14,700,000 7.100,000
42,000,000
-------
u
llU&CIf
POLLUTANT CATEGORY/ OF SAMPLES
POLLUTANT ANALYZED
31.
32.
33.
34.
35.
Nitrate-nitrite, as N
Nitrogen, Kjeldahl,
Total
Residue, Filterable
Sul fide (iodoaetric)
Total Phosphorus, a* P
4
4
4
2
4
RAW WASTEWATER
TABLE 6-2
(continued)
TREATED VASTEWATFR
KAHUt AVtKAGt MEDIAN NUMBER
NUMBER CONCENTRATION OF SAMPLES
OF DETECTIONS (pg/t) (pg/e) ltlt/t} ANALVZ™
4
4
4
1
1
140-1,300
44,000-370,000
2,500,000-22,000,000
MR- 1,400 1
ND-610
463 205
157 107
9,525,000 6,800,000
,400
610
5
5
5
3
5
RANGE AVERAGE MEDIAN
NUMBER CONCENTRATION
OF DETECTIONS fn./fl l...n\ /.._>.•>
5
5
5
3
4
50-1,700
8,800-83,000
440,000-6,800,000
1,900-4,700
KO-660
636
60,400
3,540,000
2,900
315
420
81,000
2,400,000
2,100
230
Oi
o
-------
6.2.4 Conventional Pollutants
BODS and TSS were analyzed for at each raw or treated waste
sampling point. They were found at high Concentrations as shown
in Table 6-2. As expected in these plants, where treatment
essentially consists only of gravity clarification, moderate BODJ
reduction occurred (57 percent) , but TSS was reduced 1 by nearly
99%. With the small flows and long settling times, good
clarification was achieved.
BODS concentrations average 6,925 mg/1 in the raw waste and 4,460
mg/1 in the treated effluent. TSS values were 30,750 mg/1 raw
waste and 291 mg/1 in the treated effluent.
6.2.5 Non-conventional Pollutants
The following non-conventional pollutants were quantified:
ammonia (as N) , fluoride, COD, nitrate-nitrite, KDeldahl
nitrogen, filterable residue, sulfide (M-W) , and total
phosphorus. Cyanide was detected in the raw wastewater of plant
D at a concentration of 110
Ammonia was detected in all raw and treated waste samples and was
essentially unchanged between raw and final waste streams.
Similar observations are made in the case of the K^eldahl
nitrogen and nitrate-nitrite parameters.
Fluoride levels were reduced slightly during clarification, and
were present in all but one sampling episode. The COD
concentrations of all raw and treated wastewater samples
were analogous to the observed BOD5 raw and treated
wastewater concentrations, indicating treatment caused reduction.
Filterable residue was reduced by nearly 67% by treatment,
paralleling the TSS reduction, but from overall lower levels.
Phosphorus was detected in only one wastewater sample, and in
four of five final effluent samples. Sulfide was detected in one
raw and three treated wastewater samples.
6.2.6 Sludae - Pollutant Parameters
A data summary for sludge samples is presented in Table 6-3. The
pollutants are separated into the following categories:
volatiles, semivolatiles, metals, purgeable organic compounds,
conventional pollutants, and non-conventional pollutants. Sludge
samples from each paint formulating facility sampled were
analyzed for the same compounds as wastewater samples.
Guideline procedures for determining if a solid waste has the
characteristics of a hazardous waste are presented in 40 CFR 261
Subpart C. The guidelines discuss the characteristics of
ignitability, corrosivity, and EP toxicity.
51
-------
TABLE 6-3
SUHMARY OF ANALYTICAL RESULTS
FOR WASTEWATER SLUDGE SAMPLES
Pollutant
Category
and Pollutant
Plant A
Solid TCLP
(Sludge) (Extract)
Mil
Volatile!
Plant B
Solid TCLP
(Sludge) (Extract)
Mil
Plant
Solid
(Sludge)
pg/kg
C
TCLP
(Extract)
Mil
Plant D
Solid TCLP
(Sludge) (Extract)
pg/kx Mil
Ul
rO
acetone
acrolein
benzene
ethyl benzene
itobutyl alcohol
•ethylenc chloride
tetrachloroetbene
toluene
vinyl acetat*
1,1,1 trickloroethane
2-butanone
Trichloroethene
Chlorohensene
Seaivolatilci
alpha-terpineol
di-n-bntylpbthalate
icophorone
naphthalene
n-decane
•-triacontane
thioxantbooe
3,3 dichlorobenzidin
N-octodecane
1,886
13
IS
363
117
60
283
43
166
191
141
1,415
23
12
22
49
II
1,503
2,560
10,013
4,027
235,287
110
97
597
122
100
18,941
7,617,357
42,450
129,336
7,929
606,300
7,914
6,061,071
33,736
25,979
88,136
374,357
17.548,900
103
15,553
66,723
3,653
1,318.660
2,786
Hetala
calcium
•agneiiuai
sodium
aluminum
manganese
lead
vanadium
boron
barium
cadmium
malybdenum
tin
cobalt
chromium
copper
17,300
S93
941
14,300
118
55
10
19
271
4
40
45
10
18
10
258,000
6,540
1,810,000
13,000
571
1,580
10
100
7,870
2,640
7,400
21,000
622
373
78
31
23
117,000
7.060
1,460,000
25,800
1,310
1,040
747
45,000
8,230
2,800
4,400
594
152
—
1,960
7
121
1,370
886
3,590
338
41,600
2,080
1,530,000
279
1.840
--
365
1.780
..
--
_.
1.650
830
188
20,100
535
5,940
10,300
28
114
221
3
41
20
28
38
273,000
4,440
760,000
29,700
120
248
178
496
75*
40*
167
118
61
-------
TABLE 6-3 (continued)
Ul
Plant A
Pollutant
Category
and Pollutant
Metals (continued)
iron
nickel
titanium
zinc
antiunarjr
•ercury
Conventional Pollutants
pH
Non-conventional Pollutants
auawnia, as N
cyanide
nitrogen, kjedahl , total
nitrate - nitrite, as N
flash point (C)
residue, total (t)
residue, total volatile (1)
sulCide, total
Corosivity * MPY
Purteafcle Organic
Compounds
Solid
(Sludge)
12,600
—
446
3.030
—
0.14
7.5
140
-.
1,100
55
57
24
37
5,400
TCLP
(Extract)
pg/t
139
63
..
297,000
66
»
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Plant
Solid
(Sludge)
pg/kg
40,300
25
1,060
169
— •
0.44
H
190
—
30
55
35
33
NA
<10
160
B
TCLP
(Extract)
P«/«
60
--
1,460
--
"
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Plant C
Solid
(Sludge)
I'lt/kg
31,100
28
168
6,100
-•
.34
6.8
110
NA
4,700
240
510
30
IS
12
<10
330
TCLP
(Extract)
Mil
..
69
--
6,960
"
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Plant
Solid
(Sludge)
1,630
«
278
7,160
~~
67
6.8
140
56
17
30
14
40
4.8
<10
NA
D
TCLP
(Extract)
Mil
3,280
--
490
144,000
••
80
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
— Indicates pollutant detected at a concentration lower than the stated detection liuit.
NA Indicates not analyzed.
* Indicatea duplicate analysis is not within c-.ilrol Haiti.
-------
Nine volatile priority pollutants were detected in either the
sludges or their extracts, along with four non-priority volatile,
four semivolatile priority and five non-priority semivolatiles
pollutants.
Samples from producers of water-base plants, i.e., plants A and
B, contained fewer organics at lower concentrations compared
with samples from plants C and D, which both produce solvent-base
paints. Samples from plant D, which produces both types of
paint, contained more organic constituents than any of the other
samples.
Metal concentrations were appreciable for all four plants
reflecting residues from pigments used in paint manufacturing.
Cyanide was detected in only one sample.
The Toxicity Characteristics Leaching Procedure (TCLP) sludge
extraction method was used to determine the toxic characteristics
of sludges produced at the four plants, per Section 261.24 of 40
CFR Part 261 Hazardous Waste Management System: Identification
and Listing of Hazardous Waste (51 £E 21648, June 13, 1986).
Sludge samples were leached under precise conditions, and then
the leachate (extract) was tested for the compounds listed in
Table 1 of the above reference. If leachate concentrations
exceed any of the values for compounds in Table 1, then the solid
waste is considered to exhibit the characteristics of toxicity
and is subject to regulation.
Results from the analyses of the TCLP sludge extract were
compared to the list of Regulatory Levels of Contaminants for the
Characteristic of EP Toxicity (40 CFR 261.24). None of the
concentrations were equal to or above the regulatory levels.
Based on these findings, the wastewater sludge extracts analyzed
did not have the hazardous waste characteristic of EP toxicity.
Sludge samples were also analyzed for corrosivity; results showed
all values for corrosivity to be less than the detection limit
(i.e., less than 10 mils per year [mpy]). The pH of the sludge
was also measured. Criteria set forth in 40 CFR 261.22 state
that a waste is corrosive if its pH is less than or equal to 2,
or greater than or equal to 12.5; all results showed pH levels
were greater than 2.0 and less than 12.5. Additional criteria
state that the corrosivity cannot be greater than 6.35 mm per
year (or 0.25 inches per year). Based on these criteria, the
wastewater sludges tested do not have the hazardous waste
characteristic of corrosivity.
Flash point, the measurement for ignitability, was measured for
the actual sludge samples (40 CFR 261.21). The criteria set
forth in 261.21 state that a waste exhibits the characteristic of
ignitability if it is a liquid containing less than 24 percent
alcohol by volume and has a flash point of less than 60 °C.
Analysis results revealed flash points less than 60eC; therefore,
54
-------
based on these data, the sludge samples tested do have the
characteristic of ignitability.
55
-------
7.0 CONTROL AND TREATMENT TECHNOLOGY
The paint formulating industry has, in the past 10 years, made
significant efforts to reduce the volume of wastewater
discharged. Review of current information on the 41 NPDES-
permitted direct dischargers, provided by EPA's Office of Water
Enforcement and Permits (the "Quick Look Report," April 22, 1986)
revealed that none of the permitted plants are allowed to
discharge process wastewater directly to the navigable waters of
the United States. Allowable water discharges usually include
stormwater runoff, noncontact cooling water, and/or boiler
blowdown, but not process wastewater. The only paint formulating
plants known to be discharging process wastewater do so to
municipal wastewater treatment facilities (POTWs). The degree of
control and treatment of wastewater practiced by facilities
discharging to POTWs, often depends on the requirements
established by the municipal system. For example, some municipal
systems may monitor influent for conventional pollutants only
(e.g., BOD, TSS, pH, oil and grease, and fecal coliform) , while
others monitor for conventionals and also for metals. Many POTWs
require submittal of discharge monitoring reports from the
facilities contributing to the POTW influent.
Information on pretreatment requirements was obtained from three
municipal treatment systems located near the paint formulating
facilities visited during this study. Each of the systems had
specific influent limits for conventional pollutants and metals.
Specific municipal treatment plant influent limits for the areas
visited are presented in Table 7-1. Limits cited in Table 7-1
are those for the actual maximum allowable concentration of paint
plant discharge to the sewer, and are based on levels determined
by the POTW to be consistent with safe POTW plant operations and
POTW discharge limits.
7.1 In-plant Source Control Strategies
Two widely used, general strategies for reducing the amount of
wastewater that paint formulating plants discharge to the
environment include: (a) reducing the volume of fresh water
required, and (b) reusing as much water as possible in plant
processes. The amount of wastewater needed to be disposed of is
influenced by the water pressure used for tank and equipment
cleaning, the degree of cleaning required, and the use, when
possible, of dry cleaning techniques.
7.1.1 Wastewater Reduction
The amount of water required to clean a paint tank can be reduced
by cleaning the tank walls with a squeegee or rag (when tank size
and product type permit) prior to rinsing with water. The use of
high pressure water for tank cleaning is also an effective
technique for reducing cleaning water requirements. Several
56
-------
TABLE 7-1
SUMMARY OF MUNICIPAL TREATMENT SYSTEM INFLUENT LIMITATIONS
Pollutant
Atlanta*
Baltimore
Chicago
Metals (mg/£)
arsenic
boron
cadmium
chromium (total)
chromium (hexavalent)
copper
iron
lead •
mercury
nickel
silver
zinc
Conventionals
BOD (mg/£)
Oil & Grease (mg/£)
pH
Non-conventionals
1.0
1.2
13.0
1.5
4.5
0.6
0.05
4.0
1.0
25
5.5-12.5
1.3
7.0
4.5
0.7
4.1
1.2
4.2
300
100
6.0-10.0
1.0
2.0
25.0
10.0
3.0
50.0
0.5
0.0005
10.0
15.0
100
4.5-10.0
phenol
cyanide (mg/£)
COD (mg/£)
temperature °F
dissolved solids (rng/2)
suspended solids (mg/£)
total solids (mg/£)
15.0
4.0
--
--
—
—
1.31
500
150
1,500
400
1,900
10. 01
™ *
150
~ ••
— —
Limits are reported for (total) cyanide.
Indicates that no limit exists.
Wastewater strength limit-at discharger-per City of Atlanta Specific
Pollutant Limits - R. Hadden
Baltimore - per Table 22 - "Discharge Limitations" - Memo 7/25/86
M. Zawmm to R.B. Sellars.
Chicago - "Sewage and Waste Control Ordinance" - pg. 20 - Rev. Oct. 1978.
57
-------
commercial systems are available consisting of booster pumps,
flow regulators, and nozzles. These systems supply low-volume,
high-pressure water sprays that clean tanks as well or better
than hand-held hoses at normal water pressure. High-pressure
sprays, if used properly, can clean in a shorter time with less
water.
Hand-held wand nozzles and large, fixed, whirling nozzles are
available for tank cleaning. The wand nozzles also can be used
for other cleaning operations in a paint plant (e.g., filling
equipment cleanup). A permanent high-pressure wash system with
enough outlets to service the whole production area can be
installed at larger paint plants. Portable high-pressure pumps
with flexible hoses that can be moved from place to place, can be
used at smaller plants.
Another effective in-plant control measure to reduce wastewater
is the sealing or elimination of floor drains and trenches (where
permitted under fire codes). Because all tank and filling area
rinse water must be collected if no drains are available, the
operating staff has an incentive to reduce the volume of water
used. Spills can be picked up with shovels or squeegees; floors
usually are mopped, vacuumed, or cleaned by machine. Where floor
drains and trenches exist, the tendency to hose down equipment
and floors is greater, thus leading to greater water consumption
and wastewater generation.
Additional wastewater reduction methods are as follows:
o use of mechanical devices (e.g., rubber wipers) to
scrape the sides of the mixing tanks to reduce the
amount of clinging paint (mixing tanks with automatic
wall scrapers are now available)
o use of Teflon-lined tanks to reduce adhesion and improve
the drainage of paint (this method is especially
applicable to small batch tanks that are cleaned
manually)
o use of a plastic or foam "pig" to clean pipes (the
"pig," forced through the pipe from the mixing tank to
the filling machine, pushes paint clinging to walls of
the pipe ahead, thereby increasing the yield and
reducing the degree of pipe cleaning required)
o scheduling a specific paint production run for as long
as possible, or cycling from light to dark colors to
reduce the need for equipment cleaning.
All of these methods are currently used at paint formulating
plants, more often at the larger facilities. Recovery and reuse
of wastewater or spent solvents, resulting in reduced costs, is
the most common and beneficial method used for wastewater
reduction.
58
-------
7.1.2 Wastewater Reuse
Some paint plants produce a variety of paint colors and finishes.
However, a large number of paint formulators produce base color
paints (white and off-white paints) for subsequent tinting.
Standard practice at many plants, is to segregate white paint
production from other colors and to reuse wastes from each batch
in subsequent batches of the same color. Use of the same tank
for subsequent batches eliminates the washdown operation after
each batch and minimizes the generation of wastewater. This
procedure can also be used in isolated cases when a plant
produces a large amount of any given color over a short period of
time.
Even when plants cannot dedicate tanks to a single product,
recycling opportunities result from scheduling batches of similar
products back-to-back in the same tank. The rinse water from the
first batch remains in the tank and is used in the next batch as
part of the formulation, reducing raw material requirements and
wastewater volume, and also reducing disposal costs.
When paint plants cannot immediately reuse material in the next
batch, recycling methods are available. For example, some plants
collect all paint wastewater in drums or tanks, label it by color
and base, and reuse it in the next compatible batch (i.e., a
similar or darker color). This wastewater may need protection
against spoilage, e.g., treatment with a biocide, and is usually
used as soon as possible.
7.2 Water Wash Wastestream Treatment and Disposal Practices
The most common wastewater treatment method in the water-base
paint formulating segment is physical-chemical (P-C), usually
chemical addition and gravity settling for suspended solids
control. P-C treatment in the paint formulating industry is a
batch operation. The plants collect wastewater in a holding tank
until a sufficient quantity is collected for treatment. As
necessary, the pH is adjusted to an optimum level; a coagulant
(i.e., lime, aluminum sulfate, ferric chloride, or iron salts)
and/or a coagulant aid (i.e., polymer) are added and mixed; the
batch is then allowed to settle (from 1 to 48 hours) . The
supernatant is either discharged or reused for tank cleaning
until it is spent. Often the sludge remains in the tank during
treatment of subsequent batches to allow additional settling and
to reduce the frequency of sludge handling prior to disposal.
Skins (i.e., coagulated paint product) that float to the surface
are usually removed manually and disposed of as a solid waste
along with the generated sludge.
According to results of a survey conducted by the NPCA
Manufacturing Committee (April 1986), in which 45 paint-
formulating plants participated, 33 percent of the facilities
discharge equipment wash water to the municipal sewer without
treatment; 44 percent recycle the wash water back into the
process; 14 percent treat the wash water by flocculation and
59
-------
settling, and discharge the supernatant to the municipal sewer;
and 9 percent treat the wash water by flocculation and settling,
and reuse the supernatant in the process. Of the plants that
treat with flocculation, 30 percent recycle the settled solids
(i.e., sludge) back into the paint-formulating process, and 70
percent dispose of the sludge as a non-hazardous waste. Some
paint formulating facilities that generate a small amount of
wastewater sludge dispose of it as a hazardous waste along with
other hazardous wastes generated on-site (e.g., spent solvent and
spent caustic).
2-^2—Solvent Wash Wastestream Treatment and Disposal Practices
Pretreatment standards for new sources do not permit the
discharge of process wastewater pollutants to municipal
wastewater treatment systems. Industry practices in both newer
and older plants include reuse of wash solvent until it is spent,
reclamation of wash solvent through distillation or settling on
or off-site, and disposal of waste solvent by incineration, or
off-site use as a fuel supplement.
According to the NPCA survey of 45 paint formulating facilities,
28 percent send wash solvents off-site to a reclaimer for
recovery; 18 percent dispose of the wash solvent "as is"; 23
percent reuse wash solvent in the process without treatment; and
31 percent recover wash solvents on-site. Methods for on-site
recovery include: 39 percent by vacuum distillation, 39 percent
by steam distillation, and 22 percent by settling/decanting.
Most of the solvents disposed of "as is", are ultimately burned
as a fuel supplement.
60
-------
ECONOMIC IMPACT ANALYSIS
61
-------
8^0 INTRODUCTION TO THE ECONOMIC IMPACT STUDY
Sections 8 through 10 of this document present an outline and the
results of a study of the economic characteristics of the paint
formulating industry. The purpose of the study was to determine
the economic health of the industry and the likely economic
impact on the industry of governmental regulations on paint
formulating wastewater discharge.
8.1 Introduction
This industry profile and preliminary economic impact analysis is
divided into three sections:
o Section 8.0 provides an introduction; Section 8.2 provides a
brief review of the processes employed by the industry.
Section 8.3 describes the number and location of firms and
establishments. Section 8.4 discusses employment and wages
in the industry. Section 8.5 presents ownership
characteristics. Section 8.6 describes products and prices.
Section 8.7 discusses financial characteristics.
Section 8.8 presents the foreign trade issue. Section 8.9
describes trends in the industry.
o Section 9 presents an economic impact assessment of the
industry. Section 9.1 describes the methodology involved.
Section 9.2 is a definition of the typical plants.
Section 9.3 is the economic impact of compliance costs on
profitability.
o Section 10 describes the limits of the analysis.
Section 10.1 is a definition of the industry limits.
Section 10.2 describes the limits on economic and financial
data. Section 10.3 presents regulatory options and compli-
ance costs.
There were approximately 1,450 paint formulating establishments
in the United States in 1982, owned by 850 firms, with total
employment of approximately 54,000. Total 1985 industry revenues
were approximately $9.2 billion.
The paint formulating industry is a very mature industry with
predicted annual growth rate of about 2 percent. The number of
both companies and plants has been declining and is expected to
continue as companies seek to increase sales and provide more
resources for R&D efforts through consolidation.
8.2 Industry Profile
For purposes of this analysis, the Paint Formulating Industry is
defined to cover all facilities that formulate paint products.
While paint formulating processes differ slightly between
solvent-based and water-based products, they usually involve
three steps:
o mixing and grinding (if necessary) of raw materials
o tinting and thinning
0 filling (filtering, packaging and labeling)
62
-------
Generally, paints and coatings are classified into three
categories. Ranked in order of their value of shipments in 1986,
the three categories are:
o Architectural Coatings (42 percent of industry
shipments). Usually water-based, these are general-
purpose paints, varnishes and lacquers used on
residential, commercial and industrial structures. Sold
through wholesalers and retailers, they are also called
trade sales paints.
o Industrial or Product Coatings for Original Equipment
Manufactures (37 percent of industry shipments).
Usually solvent-based, these are formulated to customer
specifications and applied during manufacturing. They
are used on durable goods, such as automobiles,
appliances furniture and metal containers.
o Special-purpose Coatings (21 percent of industry
shipments). Usually solvent-based, they are formulated
for special applications or special environmental
conditions. Sold by wholesalers and retailers, major
markets for these products include automobile and
machinery refinishing, bridges, industrial maintenance
and traffic markings.
Paint formulating plants tend to specialize in either solvent-
based or water-based production. In the case of water-based
production, wastewater is generated primarily by the clean-up
process. After removing as much of the paint as possible from
the tubs and tanks, water-based paint clean-up involves washing
the equipment with water. The wash water may be disposed of in
one of several ways, including (1) collected in tanks and treated
before discharge, (2) collected in drums and disposed of in a
landfill, (3) discharged directly to a sewer or receiving stream,
(4) reused in the next paint batch, or (5) reused in the washing
operation. Likewise with solvent-based paints, as much of the
paint as possible is removed from the equipment by allowing it to
drain out and through the use of squeegees. Then the equipment
is flushed with a solvent. The used solvent is handled in one of
three ways: (1) used in the next batch as part of the
formulation, (2) collected in drums and sold to a company for
redistillation and resale, or (3) collected in drums for
subsequent tank-cleaning operations.
This chapter describes the size and financial characteristics of
the industry, based of data available at this time from secondary
sources. Much of this data is organized in terms of SIC codes.
The category of interest in this analysis is SIC 2851:
establishments primarily engaged in manufacturing paints (in
paste and ready mixed form); varnishes; lacquers; enamels and
shellac; putties, wood fillers and sealers; paint and varnish
removers; paint brush cleaners and allied paint products.
63
-------
8.3 Number and Location of Facilities
Over the last several years, there has been a reduction in the
number of paint formulating facilities in the U.S. but there has
been no major shifts in the location of these facilities.
According to the U.S. Census of Manufactures, in 1982 there were
1,441 facilities classified as paint formulators (SIC 2851) by
comparison, based on data collected by the Agency under authority
of Section 308 of the Clean Water Act, there were 1,500 plants in
1976. Table 8-1 lists the number of plants located in each state
having more than 150 employees in SIC 2851 in 1982. Data for
other states is suppressed by the Census Bureau in order to
maintain confidentiality. This table shows that in both 1976 and
1982, the five states with the largest number of plants were
California, by far the largest; New Jersey; Illinois; New York;
and Ohio. Together these five states accounted for 42 percent of
all plants in 1976 and 44 percent of all plants in 1982. These
five states are characterized by large populations and well-
developed durable goods industries.
The formulating of paints is a highly specialized activity,
tending to take place at facilities dedicated to that purpose.
According to the 1982 Census of Manufactures, 97 percent of the
plants that formulate paints have this as their major activity
(i.e., 2851 is their primary SIC). In addition, 96 percent of
paint is formulated at facilities with 2851 as their primary SIC.
8.4 Employment Characteristics
Based on data collected in 1976, the Agency categorized
65 percent of the plants in this industry as small, i.e., having
less than 20 employees. As shown on Table 8-2, in 1982 about
57 percent of the plants had less than 20 employees. In
addition, the total number of employees declined by nearly
18 percent between 1972 and 1982. Since 1982, employment in this
industry has grown slightly. Table 8-3 lists the number of
plants in various size categories for three different years. As
shown, the distribution of plants across size categories has
changed little in the last 10 years. While the data are from
three different sources, they present a relatively consistent
pattern of heavy concentration in the smallest size category with
a slight shift towards larger facilities over time.
64
-------
TABLE 8-1
LOCATION OF PAINT FORMULATING PLANTS
State
California
New Jersey
Illinois
New York
Ohio
Florida
Texas
Michigan
Pennsylvania
Missouri
Massachusetts
Wisconsin
Georgia
Indiana
North Carolina
Tennessee
Washington
Kentucky
Maryland
Connecticut
Minnesota
Oregon
Virginia
Number
in 1982
204
122
118
96
90
83
80
62
58
54
48
37
37
35
26
25
24
20
20
18
17
17
16
Percent
of Total
14%
8
8
7
6
6
6
4
4
4
3
3
3
2
2
2
2
1
1
1
1
1
1
Number
in 1976
196
112
106
109
103
69
58
47
66
51
54
34
35
34
20
17
22
22
20
10
19
20
13
Percent
of Total
13%
7
7
7
7
5
4
3
4
3
4
2
2
2
1
1
1
1
1
1
1
1
1
65
-------
State
Oklahoma
Alabama
Colorado
Iowa
Mississippi
Louisiana
Kansas
Arkansas
Utah
South Carolina
Not Identified
Total
LOCATION
Number
in 1982
1A
1A
12
12
10
9
8
5
5
A
Al
1,AA1
TABLE 8-1
(continued)
OF PAINT FORMULATING
Percent
of Total
1
1
1
1
1
1
1
0
0
0
3
PLANTS
Number
in 1976
9
12
11
13
5
15
10
7
A
5
172
1,500
Percent
of Total
1
1
1
1
0
1
1
0
0
0
11
66
-------
TABLE 8-2
SIZE OF THE PAINT FORMULATING INDUSTRY
Companies
Establishments
Total
20 or More Employees
Employees (000)
Total
Production
Value of Shipments
($ million)
Current Dollars
1982 Dollars
19721
1,318
1,599
687
65.9
36.2
3,822
19771
1,288
1,579
653
61.4
33.0
6,630
19821
1,170
1,441
620
54.1
27.6
9,162
9,162
19842
55.3
29.1
10.848
10,412
19852
56.7
29.4
10,539
9,924
19862
56.9
29.4
11,101
10,250
New Capital Expenditures
($ million)
Current Dollars 81.5 167.4 264.2 283.6 336.3
SOURCE:
1 U.S. Department of Commerce, Census of Manufactures . 1982
2 U.S. Department of Commerce, 1987 Industrial Outlook, Section 15.
67
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TABLE 8-3
DISTRIBUTION OF PLANTS BY NUMBER OF EMPLOYEES
Percent of Plants
Number of Employees
10 or Less
11 to 20
21 to 50
51 to 100
More than 100
19761
41.7%
21.2
19.5
9.7
7.7
1982*
36.6%
20.3
23.0
11.9
8.3
19873
41.9%
17.7
20.5
10.1
9.8
SOURCE:
2 Economic Impact Analysis. December 1981, EPA-440/2-81-026 Table 5
3 U'S; Ce"sus of Manufactures. 1982, U.S. Department of Commerce.
Dun's Census of American Business. Dun & Bradstreet, 1987.
68
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8.5 Ownership Characteristics
The number of companies owning paint formulating plants steadily
declined over the 1972 to 1982 period. Exact figures for more
recent years are not available, but industry observers maintain
that the consolidation trend has continued. As shown in Table 8-
2, the number of companies has dropped from 1,318 in 1972 to
1 170 in 1982, or a drop of 11 percent. Nevertheless, the
majority of companies continue to own only one paint formulating
plant. The average number of plants per company in 1972 was 1.21
and the average in 1982 was 1.23. One reason for the generally
fragmented nature of this industry is the relatively high
transportation costs of the product. Therefore, it is more
profitable to produce paint close to the point of sale. In
addition, original equipment manufacturers (OEM) coatings are
like specialty chemicals in that they are formulated for a
specific customer and frequent contact with the customer is
desirable.
A measure of the distribution of company sizes in this industry
was derived from the 1987 paint Red Book. This directory of
paint procedures lists 847 companies, owning 1,342 plants that
produce paint in the United States. Total company employment is
listed for most of these companies. Out of the 847 companies,
approximately 96 (11 percent) had more than 200 employees. Of
these 96 companies, approximately one-third had between 200 and
299 employees, one-third had between 300 and 699 employees, and
one-third had more than 700 employees including four companies
with more than 5,000. Among the large companies that produce
architectural coatings are: Sherwin Williams, Valspar Corp., and
Benjamin Moore. Large OEM coating producers include: DuPont and
Inmont (BASF). Large companies that produce both architectural
and OEM coatings are: PPG Industries, Grow Group, DeSoto, and
Glidden.
One reason for consolidation in this industry is the need for
higher sales in order to support increased R&D expenditures.
Some of the technological changes are in response to
environmental regulations aimed at reducing emissions of organic
compounds. Other changes are in response to needs of users, such
as developing paints that make plastic automobile parts exactly
match metal parts.
A second major trend is the increased globalization and
integration of the industry. While several domestic companies
have followed major OEMs out of the country to lower cost areas
such as the Far East, foreign producers are entering the U.S.
market in search of growth opportunities through acquiring exist-
ing paint companies. For example, BASF acquired Inmont Corp. in
late 1985, and Imperial Chemicals Industries (ICI) acquired
Glidden. This latter acquisition marked Id's entry into the
U.S. paint industry and made it the world's largest paint
company. An example of increased vertical integration of the
industry is DuPont's 1986 acquisition of Ford Motor Co.'s paint
business. As a result, the automobile industry is primarily
served by three companies: DuPont, PPG Industries, and Inmont.
69
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industry is somewhat concentrated, with the
u C01npanijes accounting for 24 percent of the shipment s
However' Respite a 20 percent decline in the number of
Owin9 Pamt formulating facilities between 1967 and
as
Year
1967
1972
1977
1982
Number of
Comoanies
If
1,
1,
1,
459
318
288
170
Percent of Shipments Accounted
for bv Laroest Comnan<*>=
TOD 4
22 %
22
24
24
TOP 8
35%
34
36
36
TOP 20
48%
51
52
53
TOD 50
61%
W JU ^Q
66
\J \J
67
\J 1
67
8_._6 — Products and Prices
including? °0atings are fo™ulated from over 1,000 raw materials,
o binders, to make paint adhere
o pigments, for color and protection
o solvents, to adjust viscosity
o additives, such as driers, plasticizers, and biocides
earlier section, paint is classified into
or slvent Tl'- and iS Droduced in either water-based
mii™ * J? formulatlons- The usual unit of measure is the
IS ,S? ,, ^ avera9e' wholesale price for paint was
!?i Z#ali?n ^ 1985' This price is expected to rise ?o
labie%9f ^8? 19h° an
-------
es
ranged from 64.7 percent to 69 7 percent of sales and (selling
expenses ranged from 15.0 percent to 17.6 percent of sales.
During the same period, after-tax profits ranged from a low of
2 5 percent of sales in 1982 to a high of 3.2 percent of sales in
1984 However, profits measured against either net worth or
working capTtal looked much better. After-tax profits as a
percent of net worth ranged from a low of 8.9 percent in 1982 to
= iTJvSr Tvf n a nercent in 1984. Table 8-4 presents several
proAt mefsures fP0r lach year from 1979 to 1986. As the table
Shows? ?he different profit measures move together showing this
industry's sensitivity to business cycles. All the profit data
provided fay the industry hit a low during the 1982 recession and
climbed rapidly as the construction industry rebounded in 1984.
The profit information provided by Robert Morris Associates (RMA^
'
shown
uaua. The apparent one year lag in profit level
^__c business cycle is in part due to the reporting
conventions used by RMA.
Financial data on specific paint companies was not collected at
SiS time for several reasons. Most of the companies are small
and privately-held, and financial data are not available for
?hem.P Many of the large, publicly-held companies,f^ ^versified
and data are not available on their paint business alone.
Therefore, it was felt that the NPCA and RMA data provided a
better picture of the overall industry than would be available
from publicly available data on specific companies. F.11"fn";i
data for different sized facilities are presented in the next
chapter.
8.8 For-eian Trade
Most of the sales by U.S. producers are directed at satisfying
the domestic market. For example, in 1986 only $249 million (or
2 3 percent of paint industry shipments) were exported. In the
same year, only $187 million of paint (or 1.7 percent of
Sipments plus imports) were imported. However imports have been
increasing, both in absolute value and as a percent of shipments
plul imports, while exports have remained constant or declined
slightly. This decline is expected to continue, with net exports
predicted to decline in terms of constant 1977 dollars from $154
million in 1977 to $68 million in 1995. In addition to direct
imports and exports, U.S. manufactures are producing paxnt abroad
and foreign companies are buying U.S. plants.
71
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TABLE 8-4
HISTORIC PROFITABILITY LEVELS
Before-tax Profits
After-tax Profits as Percent of
Year
1979
1980
1981
1982
1983
1984
1985
1986
SOURCE :
as Percent of
Sales1
4.5
4.0
3.8
3.3
4.6
4.8
4.4
5.1
1 National Paint &
2 Annual Statement
Sales2
NA
3.8
4.0
3.3
2.5
2.9
4.2
3.7
Sales1
2.8
2.1
2.4
2.5
3.1
3.2
3.1
3.1
Coatings Association.
Studies, 1987. Robert Morris
Total Net
Worth1
11.3
9.7
12.0
8.9
11.9
13.8
11.5
12.1
Assoc.
Net Working
Capital1
14.5
11.1
13.0
11.0
14.0
16.1
12.6
12.9
72
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fl.Q Trends in the Industry
As discussed above, this is a mature industry with a predicted
annual growth rate of about 2 percent. However certain new
products such as powder coatings (sprayed on dry and then
electrically adhered to the product being coated) and radiation
curable coatings (liquid coatings hardened by ultraviolet light
or electron beam energy) are predicted to grow at a rate of 12 to
II percent per year. The number of both companies and plants has
been declining and is expected to continue to decline as
companies seek9 to increase sales and to provide more resources
for their R&D efforts through consolidation. This need_ for
aggressive R&D makes entering the market costly. Foreign firms
have stepped up their activities in the U.S. market by buying
significant shares of domestic companies and this is expected to
continue as long as the dollar remains weak.
73
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9^0 - ECONOMIC IMPACT ASSESSMENT
Neither plant-specific financial data nor plant-specific
compliance costs are available for this preliminary economic
assessment. Therefore, financial profiles are developed for
typical paint formulating plants and the range of potential
impacts is analyzed. potential
9 . 1 Methodology
The analysis depends on several assumptions that were developed
SLS^T. S™°f ^6 industry Profile presented in the preceding
chapter. The first assumption is that the plant is the
appropriate unit of analysis. A majority of the plants are owned
by single-plant companies, and so an analysis of the impact on
company profits reduces to an analysis of plant profits. While
this convergence is not true for plants owned by multi-plant
companies, the data necessary to make separate * analyse! of
profits for the plant and for its owner are not available at this
time. However, the decision of whether or not to close a plant
is usually based on the plant's circumstances. It is also
assumed that the plant can be characterized on the basis of
S=i^i /*in!>, torm2***™3 P^nt financial performances. AS
described in the profile, most paint plants are exclusively paint
producers and nearly all paint is produced at paint formulating
Xclii^S
Third, the analysis assumes that paint formulators are unable to
pass-on any of the compliance costs in the form of higher prices
There are no data available at this time to allow an estimation
of demand elasticities or cost pass-throughs. Assuming no cost
pass-through is a worst case assumption in that it potentially
over-estimates the impact on the industry. it is also a
reasonable assumption in that there are many producers of paint
and many of them already meet likely standards. Those who
already meet the standards would not face increased costs, and
this cost differential across producers would make it difficult
for those with increased costs to raise their prices.
Based on operating cost and profit data provided by the industry
and other secondary sources, financial profiles are developed for
paint formulating plants typical of three different plant sizes.
Since a majority of the plants in this industry are small, none
of the size categories represents a large facility. These
financial profiles allow a comparison of various compliance costs
to changes in profit levels. Based on this comparison, different
regulatory options can be evaluated in terms of their impact on
profits. The likelihood of closure in response to various levels
of compliance costs is not analyzed for these typical plants,
since the data is not available at this time.
74
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Q.2 Definition of TYPical Plants
The two primary sources of information for the financial profiles
are the National Paint & Coatings Association (NPCA) and Robert
Morris Associates (RMA). The NPCA surveys its members and
pSushes annual summaries of operating costs and prof^ levels.
RMA annually publishes financial profiles, based on loan
^licatlons filed with its participating banks. The RMA
statistics are aggregated by four-digit SIC code, and data for
SIC 2851 are used in this analysis.
Data for 1986 are the most recent available from either source.
As shown in Table 9-1, a comparison of 1986 data shows that the
incitements are'very similar. However, before-tax prof its
as reported by RMA are lower than those reported by NPCA. Less
detailed information is available from Dun & Bradstreet, but like
RMA, it shows lower profits than the NPCA data.
The RMA data are used for the typical financial profiles for two
reasons. Its profit levels fall between the other two and so is
neither the highest nor the lowest estimate. Secondly, it is
likelv that the NPCA data underrepresents small companies. Large
companies are more likely to join an industry group and, as will
be shown below, large facilities tend to have larger.P^fits in
relation to sales than small facilities. This is consistent with
NPCA's higher reported profit levels.
RMA reports information for the total industry, representing 128
loan applications in 1986, and for each of three asset sizes, 0-
$? million, $1-$10 million, and $10-$50 million. The six plants
with assets in excess of $50 million are not reported separately
due to confidentiality restrictions. For each group, RMA reports
total sales and number of facilities in the sample. From this,
average sales are calculated. NPCA reported that sales per
employee averaged $126,637 in 1986. Using this amount, the
average number of employees is calculated for each size of plant.
?hS figures are shown in Table 9-2. This table also presents
the costs of goods as a percent of sales and before-tax profits
as a percent of sales, net worth, and total assets.
The smallest asset category, with an average of 12 employees,
corresponds to over 40 percent of the plants in this industry,
while the plants in the two smaller asset categories represent
over 80 percent of the plants in this industry. These two groups
are roughly comparable in terms of their profits relative to
sales and to total assets. However, in terms of profits relative
to net worth, the smaller plants out perform the larger ones.
The largest plants for which there is data are the most
profitable by all measures.
75
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TABLE 9-1
TYPICAL PAINT FORMULATING PLANT
1986 Expenses and Profits as Percent
Total Cost of Manufactured Products
(including wage and benefits)
Selling, Office, Administration
and General Expenses
Net Profit Before Taxes
Net Profit After Taxes
of Sales
67.8%
28.4%
5.1%
3.1%
ruin
68.5%
28.5%
3.7%
NA
IK*B"
67.7%
NA
NA
2.1%
1986 Profits as Percent of Net Worth
Net Profits Before Taxes as Percent 19.9% 17.0% NA
NfxTPr0f,itSuAfter TaXCS 3S Percent 12.1% NA 10.4%
of Net Worth *"••**>
SOURCE:
1 Provided by the National Paint & Coatings Association
Annual Statement Studies. 1987, Robert Morris Assoc.
Industry Norms and Key Business Ratios. 1986-87. Dun & Bradstreet.
76
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TABLE 9-2
FINANCIAL PROFILES - TYPICAL PAINT PLANTS
Sales ($ million)
Employees
Cost of Goods Sold as
Percent of Sales
Profit Before Taxes as
Percent of Sales
Profit Before Taxes as
Percent of Net Worth
Profit Before Taxes as
Percent of Total Assets
0-$1(33)
$1.58
12
68.5%
3.0%
16.7%
5.7%
$1-$10(72)
$7.96
63
68.8%
3.5%
14.3%
5.8%
$10-$50(17)
$48.44
383
68.3%
5.3%
24.6%
8.8%
$50+(6)
$177.93
1,405
NA
NA
NA
NA
SOURCE:
Annual Statement Studies, 1987, Robert Morris Associates Abt Associates
Estimates.
77
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9.3 Economic Impacts
Based on the sales and profitability ratios presented in Table 9-
2 and the assumption that none of the compliance costs are
passed-on in the form of higher prices, new profit levels are
calculated for each of several compliance costs. These are shown
in Table 9-3 and Figures 9-1, 9-2, and 9-3. since the facility
is assumed to absorb the entire costs, profits are reduced by the
amount of the compliance costs, and profit rates drop
accordingly. For the regulation with compliance costs equal to
initial profits, profits are zero. The slope of this profit line
is a function of the size of the initial profits and the profit
rate before any additional regulations.
These graphs can be used to determine the amount of compliance
costs a plant can absorb and still meet a given profitability
criterion. For example, suppose the criterion is: profits
should not be less than 3 percent of sales. In this caseT small
plants could not bear any additional regulations, while medium
size plants could bear regulations with annual costs of up to
$40,000, and large plants could bear regulations with costs of up
to $1,100.000. This is diagrammed on Figures 9-1 to 9-3. These
differences are due to both the size of the facility, and thus
the absolute size of its profits, and its profit rate. Likewise,
the cost of any regulatory option will vary with the size of the
facility. A second example would be a criterion that profits not
drop more than 25 percent. Under this rule, small plants could
absorb annual compliance costs of up to $11,000, mid-size plants
costs of up to $72,000, and large plants costs of up to $600,000.
Note that due to the assumptions made, the cost which results in
a 25 percent drop in the profit rate measured against sales is
the same cost that results in a 25 percent drop in the profit
rate measured against total assets.
Annual costs are based on the annualized portion of the capital
costs plus the annual O&M costs of the treatment system.
Therefore, a single annual cost can represent a wide range of
capital and O&M combinations. To gain some perspective on the
profit level changes displayed in Figures 9-1 to 9-3, compliance
costs developed for an earlier analysis were inflated to estimate
possible costs in 1986. The costs appear in the December 1981
EPA report Economic Impact Analysis for Controlling water
Pollution—in the—Paint Industry. The published costs were
inflated from 1976 costs to 1988 costs by use of the GNP
Implicite Price Deflator. This was used since the costs are a
variable mix of construction and operating costs. The small
plant in this analysis corresponds to the small plant in the
earlier study, and the large plant here corresponds to the very
large plant in that study. However, the medium size plant of
this study falls mid-way between the medium and large plants of
the earlier study. Therefore, an average of the compliance costs
for those two plants was used for the medium size plant in this
study. The resulting cost estimates, inflated to 1986, are
presented in Table 9-4. A comparison of these costs to Figure 9-
1 show that small plants would fail both of the hypothetical
criteria under all of the treatment options. Initial
78
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TABLE 9-3
IMPACT ON TYPICAL PLANT PROFITS1
VARIOUS ANNUAL COMPLIANCE COSTS
Profits as
Percent of Sales
Profits as
Percent of Net Worth
No Additional Regulation
Regulation With Annual
Cost of:
$10,000
$25,000
$50,000
$100,000
$200,000
$500,000
$1,000,000
$1,500,000
$2,000,000
Small Medium
3.0% 3.5%
2.37 3.37
1.42 3.19
2.87
2.24
0.99
—
__
__
— — — —
Large
5.3%
5.28
5.25
5.20
5.09
4.89
4.27
3.24
2.20
1.17
Small Medium
5.7% 5.8%
4.50 5.59
2.69 5.28
4.76
3.72
1.62
—
—
.-
"
Large
8.8%
8.77
8.71
8.63
8.46
8.11
7.09
5.37
3.66
1.94
NOTES:
1 Definitions of Plant Sizes:
Small Plant - 12 employees, $1.58 million in sales, 0.83 million in total
assets.
Medium Plant - 63 employees, $7.96 million in sales, 4.8 million in total
assets.
Large Plant - 383 employees, $48.44 million in sales, 29.17 million in total
assets.
79
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I
or,
-------
.h of
00
fom(tl"t*r<
-------
.1
•§
fl.
-------
profit rates start at 3 percent and the least expensive treatment
option, contract hauling, would reduce profits by over
25 percent. In the case of mid-size plants, one of the treatment
options, physical/chemical pretreatment, would pass the criterion
of keeping profits above 3 percent. This option and three others
(recycle with contract haul, recycle with physical/chemical, and
contract hauling) would pass the criterion of not reducing
profits by more than 25 percent. A comparison of the costs in
Table 9-4 to Figure 9-3 shows that for large plants, all
treatment options pass both criteria.
Based on this analysis of typical plant financial profiles and
compliance costs developed for an earlier study, it is concluded
that the medium and large size plants are capable of incurring
additional treatment costs. However, the small plants that make
up a majority of the plants in this industry could incur little
in the way of additional costs without an undue burden. While
this preliminary economic assessment does not take into account
possible shifts in the competitive structure of the industry, nor
identify possible closures, the basic conclusion that small
plants will have difficulty meeting additional compliance costs
while medium and large plants will not is well supported by the
information currently available.
83
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TABLE 9-4
ESTIMATED 1986 COMPLIANCE COSTS1
($ 000)
.treatment uption
Physical /Chemical Pretreatment
Physical/Chemical Pretreatment
with Biological
Recycle with Contract Haul
Recycle with Physical/Chemical
Pt*Ot- V>A4+-ff*lA«'l +
Small Plant
$17.6
$103.6
$23.4
$32.8
Medium Plant
$39.6
$125.8
$49.1
$53.2
Large Plant
$87.5
$173.7
$92.9
$91.3
Recycle with Physical/Chemical
Pretreatment and Biological
Contract Haul
$118.9
$12.7
$139.0
$62.0
$176.2
$226.1
NOTES:
1 Calculated by inflating costs published in Economic Impact Analysis for
Controlling Water Pollution in the Paint Manufacturing Industry. December
1981, EPA-440/2-81-026.~~ *•
84
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10.0 LIMITS OF THE ANALYSIS
The primary constraint on this preliminary economic impact
analysis is the limited amount of data available. There is no
information on some aspects of the industry and the data that is
available is in aggregate form, thus hiding distinctions among
plants.
10.1 Definition of Industry
The definition of the industry is not sufficiently detailed at
this time to enable a complete comparison between this industry
and SIC Group 2851. Most of the secondary source data is
organized in terms of SIC 2851 and currently it is not possible
to determine what errors the use of this data may introduce. For
example, SIC 2851 includes paint and varnish removers and paint
brush cleaners; does this industry? The error is of an unknown
size, but probably small. Likewise, it is not known if the NPCA
data includes facilities not covered by this regulation. The
Paint Red Book does include makers of artist materials, such as
Binney & Smith, which are not included in SIC 2851. A more
detailed definition of the industry and a survey of facilities in
this industry would provide the basis for eliminating these
errors or at least estimating their size and type.
10.2 Economic/Financial Data
Plant-specific financial/economic data are not available at this
time. Thus the analysis does not include differences among
plants of the same size, such as differences in unit prices or
operating costs. Using averages hides the range of impacts by
not estimating the size and extent of the very largest nor the
very smallest impacts. Second, the information needed to
estimate the likelihood of closure or cost pass-throughs are not
available from secondary sources. In both instances, this
information could be collected via a survey of the industry, in
combination with a clear definition of the industry (i.e., the
universe under analysis). The survey should gather detailed
information about products and markets, as well as balance sheet
and income statement type information from individual plants. If
the survey does not cover all facilities, then a sample must be
drawn that is representative of the different markets within the
paint industry, so that all sectors are covered and so that a
clear picture of the competitive structure is developed. For
example, which sectors or types of producers compete locally and
which nationally?
10.3 Regulatory Options and Compliance Costs
Information gathered by the Agency indicates that many, if not
most, paint formulating facilities already have some type of
wastewater treatment in place. However, the extent and type of
treatment varies, often dependent of the requirements imposed by
the local POTW. This preliminary analysis could not take into
account differences in compliance costs that are the result of
differences in treatment in place. Plant-specific treatment
85
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costs, that take into account amount of wastewater, pollutants
and treatment in place, would enable the economic impact analyst
to be much more accurate. The range of impacts, changes in the
competitive structure of the industry, and cost pass-throughs
could be estimated if plant-specific costs were available.
86
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ENVIRONMENTAL IMPACT ANALYSIS
87
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11.0 ENVIRONMENTAL IMPACT ANALYSIS
A study is presented in this section of the impact of the
wastewater discharge from the paint formulating industry on the
publicly owned treatment works (POTW) and the stream to which the
POTW subsequently discharges.
11-1—Summary of the Environmental Impact Study
This study evaluates the water quality impacts of four indirect
paint plants on receiving streams and on publicly-owned treatment
works (POTWs). Receiving stream impacts are evaluated by
comparing instream pollutant concentrations with EPA Water
Quality Criteria developed for human health and aquatic life
protection and aquatic life toxic effects levels. Instream
pollutant concentrations are calculated at two receiving stream
flow conditions (25th and 50th- percentile). The 25th percentile
analyses mean that 75 percent of the receiving streams and
75 percent of the POTWs with indirect paint plants have flows
greater than the evaluated flows. This type of analysis is
representative of a worst case scenario.
Impacts on POTWs are evaluated In terms of inhibition of POTW
operations and contamination of POTW sludges. Inhibition
problems are estimated by comparing calculated POTW influent
pollutant concentrations with POTW inhibition levels. Sludge
contamination problems are estimated by comparing calculated
sludge pollutant concentrations with phytotoxic sludge
contamination levels. Two POTW flow conditions (25th and 50th
percentile) were evaluated.
Actual discharge data from the four indirect paint plants (Plants
A, B, D, and E) are used in the analyses (Table 11-1) . These
four plants discharge, individually, up to 34 pollutants (a total
of 63 pollutants were evaluated); 27 are priority pollutants.
Inhibition and sludge contamination criteria are not available
for all the priority pollutants. Therefore, only 18 and 7 of the
27 priority pollutants are evaluated for potential inhibition
problems and sludge contamination, respectively. Thirty-four of
the pollutants evaluated have human health criteria or drinking
water standards and 47 have aquatic life criteria/toxicity
levels. Plants A and B only produce water-based paints, while
Plants D and E both produce water and solvent-based paints.
The potential water quality impacts are projected to be minimal.
Only two of the 64 evaluated pollutants (benzidine - Plant A and
dichloromethane - Plant E) are projected to exceed human health
criteria at both the 25th and 50th percentiles (Table 11-2).
These two pollutants are known or suspected carcinogens. They
are generally not persistent in water, having a half-life of
6 hours or less. Only one pollutant (mercury) is projected to
exceed chronic aquatic life criteria (Plant D). One pollutant,
88
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TABLE 11-1
PROFILE OF PAINT FORMULATING INDUSTRY
USED IN THE ENVIRONMENTAL IMPACT ANALYSIS
Number of Facilities
o Water based: Unknown
o Solvent-based: Unknown
Total 1,440
Type of Discharge
o Direct: Unknown
o Indirect: Unknown
Note: Solvent-based facilities generally do not discharge wastewater.
The facilities evaluated in this report and in the Background Decision
Document (ITD, 1987) are indirects.
o Frequency of Discharge: Primarily batch, due to the nature of tanking
rinsing (the primary source of wastewater).
Plants Evaluated in this Analysis
o Plant A: Discharges 8,000 gpd. 100% water-based.
o Plant B: Discharges 1,600 gpd. 100% water-based.
o Plant D: Does not discharge wastewater; however, it generates 1,000 gpd
of wastewater which is disposed of off-site. Thirty-five percent of this
facility's production is water-based, the remaining is solvent-based.
This facility was included as a comparison of solvent-based wastewaters.
o Plant E: Discharges 2,000 gpd. 95% water-based, 5% solvent-based.
Raw Pollutant Loadings to Water
o Information is not available from ITD (1987) to allow loadings from this
subcategory to be calculated.
89
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TABLE 11-2
SUMMARY OF WATER QUALITY CRITERIA EXCEEDANCES
RCRA/ITD SAMPLING DATA
Criteria Exceedances1
Plant
Number
A
B
D
E
Pollutant
Zinc
Benzidine
Mercury
Zinc
Dichloromethane
50th Percentile
(POTW & Rec. Stream)
•» «
HU85.6)
No Exceedances
C(1.2)
"• ™
H(2.7)
25th Percentile
(POTW & Rec. Stream)
1(2.7)
H(428.7)
No Exceedances
C(2.9)
K3.5)
H(6.2)
NOTES :
Criteria exceedances denoted by: type of criteria (concentration/criteria).
Types of criteria: H - Human health-ingesting water and organisms
C - Aquatic life-chronic
I - POTW inhibition
Total number of pollutant evaluated: 53
Number of priority pollutants evaluated: 27
Number of pollutants evaluated for potential inhibition problems: 18
Number of pollutants evaluated for potential sludge contamination
problems:
Number of pollutants evaluated for potential human health/
drinking water problems:
Number of pollutants evaluated for potential aquatic life
problems:
34
47
90
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zinc (Plants A and D) is projected to exceed inhibition levels at
the 25th percentile. No pollutants exceed the sludge
contamination levels.
11.2 Methodology
A POTW model was used to predict the potential environmental
impacts associated with the raw indirect discharge of paint
formulating wastewaters into POTWs and, ultimately, into
receiving streams. The potential environmental impacts evaluated
through the use of the POTW model include: (1) inhibition of
POTW processes (determined by comparing calculated influent
pollutant levels with available inhibition criteria or levels);
(2) contamination of POTW sludge and thereby limiting its use
(determined through comparison of expected pollutant
concentrations in POTW sludge with sludge contamination
criteria); and (3) effect on surface water into which the POTW
discharges (determined through comparison of calculated POTW
effluent concentrations with acute WQC for aquatic life, and
calculated instream concentrations under low stream flow (7-Q-10)
conditions with chronic aquatic life and human health WQC, and
drinking water standards.
To determine potential environmental impacts of indirect
dischargers, 50th (median) and 25th percentile POTW and receiving
stream flows for the entire industry were used for each of the
four plants evaluated. These POTW/receiving stream flows were
based on information provided by the Agency's IFD and GAGE files
for indirect facilities with a SIC code of 2851. Plant flows and
concentrations were obtained from Section V of the "Background
Decision Document for the Paint Formulating Point Source
Category" (ITD, 1987). Average values were used when plants were
sampled more than once.
11.3 Impacts on Human Health
Seven of the pollutants found in the wastewaters of these four
plants are carcinogens (actual, suspected, or probable). Two of
these pollutants, benzidine and dichloromethane (methylene
chloride), caused exceedances of WQC for the protection of human
health (ingesting water and organisms) under 25th and 50th
percentile POTW and low (7-Q-10) receiving stream flows
(Appendices D and E). Benzidine exceeded criteria by a factor of
429 using the 25th percentiles and methylene chloride
concentration was 6.2 times higher than its criteria.
11.4 Impacts on Aquatic Life
Only one pollutant, mercury, exceeded aquatic life WQC after
treatment by a POTW (Appendices D and E). At the 25th percentile
flows, the exceedance factor was 2.9 (1.2 at the 50th
percentiles).
11.5 POTW Impacts
Zinc was projected to cause inhibition of the treatment processes
at two of the POTWs receiving wastewater from paint formulating
91
-------
Zinc was projected to cause inhibition of the treatment processes
at two of the POTWs receiving wastewater from paint formulating
facilities (Appendices D and E). These exceedances of the
inhibition criteria for zinc (30 /*g/l) occurred only at the 25th
percentile POTW flow (8.1 MGD).
11.6 Receiving Stream Profiles
Attachment 3 shows a ranking of the POTW and receiving stream
flow (both average and low) for the indirect discharging paint
formulating facilities contained in EPA's Industrial Discharae
File (IDF). *
11.7 Pollutant Fate
Pollutant fate information summaries for the most significant
pollutants, in terms of loadings and/or criteria exceedances, are
provided in Table 11-3.
92
-------
TABLE 11-3
ENVIRONMENTAL FATE OF POLLUTANTS OF CONCERN
Pollutant
Fate
Benzidine
Mercury
Methylene chloride
Zinc
Sorption to sediments (especially clay) is the
principal fate process. Oxidation by dissolved
ancLprecipitated metal cations, such as Fe ,
Cu , will degrade benzidine in surface waters
(half-life = 6.0 hours). Not persistent.
Mercury is strongly sorbed and persistent in the
sediments and has a solubility of 0.03 mg/SL.
Mercury will become biomethylated and volatilize
to the atmosphere. It is transported cyclically
between all environmental compartments. Mercury
is bioaccumulated (BCF = 5,500).
Volatilization is the principal fate from surface
water. The half-life ranges from less than one hour
to several hours, depending on the agitation of
the water. Biodegradation may occur in stagnant
swamp water (cometabolism) but, generally, other
forte processes are unimportant. This compound is
not considered to be persistent. Bioaccumulative
potential is low (BCF = 5.0).
Zinc is strongly sorbed to both organic and
inorganic components of the sediment where it will
be persistent. Zinc is bioaccumulated by all
organisms. BCF for freshwater fish is 432.
93
-------
12.0 REFERENCES
Burns and Roe Industrial Services Corporation. Draft
Document for Effluent Limitations Guidelines. w^., rea^menT-
Standards and New Source Performance Standards for theP-^n+ ^
^—Formulating Point Source Categories - Water-Base Water-
Wash, and Caustic-Wash SubcategorTI^Paramus,NJ; September
1976.
"Census of Manufacturers." Bureau of the Census; U.S. Department
of Commerce; 1982. ^ wueni.
Current Industry Practices in Waste Management. Wavs to Cener^o
Le^s. Devoe & Reynolds Co., Division of Grow Group; Survey of
Paint Formulators; April 1986.
Environmental Protection Agency. Development Document for
Effluent—Limitations Guidelines and Standards for the PainJ-
Formulating Point Source Category (Proposal); Washington, DC;
December 1979.
Environmental Protection Agency. Report to Congress
Minimization—of—Hazardous Waste; Office ofSolidWasteand
Emergency Response; Washington, DC (unpublished); October 1986
Environmental Protection Agency. Reoort to e«narecc «n
Dxsuharqe ot Hazardous Wastes to Publicly Owned Treatment Wn
urrice or Water Regulations and Standards; Washington
February 1986. '
the
irks •
DC;
Kline Guide to the Paint Industry. 6th Edition; Charles H. Kline
and Company; Fairfield, NJ; 1981.
valnt ged Book- 18th Edition; Communication Channels, inc.; New
YorJc, NY; 1986.
SRI International. The U.S. Paint Industry: Technology T™»nrig[
S^tember 1986* Materia1s; (Formerly NPCA Data Bank Program) \
94
-------
APPENDIX A
DATA SUMMARIES FROM PREVIOUS STUDIES
-------
-------
TABLE A-l
DATA SUMMARY
1985 DSS SAMPLING PROGRAM
RAW WASTEWATER AND TREATED WASTEWATER
SAMPLES FROM A PAINT-FORMULATING FACILITY
(CODE E)
Pollutant
Type 1 Organics
acetone 4,576 4,340
acetone > _
366753
' M
^«» •
styrene
1M.6 106,502
Type 2 Organics
l-chloro-2,3-epoxypropane DET
methyl methacrylate DET "
n-propylamine DET
Pesticides/Herbicides
4,4'-DDT 2-°
endosulfan sulfate H30 ""
endrin "0 l'2
Purgeable Organic
Compounds 15° 1U
Dioxins/Furans
NOTE:
See Table 5-2 Footnotes, for definitions of Type 1 and Type 2 Organics,
A-l
-------
APPENDIX A
TABLE A-l
DATA SUMMARY
1985 DSS SAMPLING PROGRAM
RAW WASTEWATER AND TREATED WASTEWATER
SAMPLES FROM A PAINT-FORMULATING FACILITY
(CODE E)
Pollutant
^
Polluta°t
Metals
calcium 100,000 no ooo
26 °°0 23 000
790 000 2 800 000
aluminum '84o Z>*°0>000
chromium
3,200
boron 2in
barium •, o^n
, . l,^oO 2S^
cadmium OQ
cobalt 334 9^
4620
copper 5g
ir°u , 104,000
nickel 4A
titanium 36 "
ZinC . 3,390
arsenic cc
. . JO --
antimony
osmium 1
strontiujn 13,300 7>1go
Elements
aluminum DET
C3l"Um DET DET
Carbon DET
cesium DET
DET
gadolinium DET
A-2
-------
TABLE A-l (Continued)
DATA SUMMARY
1985 DSS SAMPLING PROGRAM
RAW WASTEWATER AND TREATED WASTEWATER
SAMPLES FROM A PAINT-FORMULATING FACILITY
(CODE E)
Conventional Pollutants
BOD-5 Day (carbonaceous) 243 *6
total suspended solids 2,970
Non-conventional Pollutants
fluoride 05 0.9
ammonia, as N 01
nitrate-nitrite, as N O.lb "•"
chemical oxygen demand 24,200 16,200
total organic carbon 4,950 4,800
Indicates that pollutant concentration was below detection limit.
NR No value reported due to matrix interference.
DET Indicates that pollutant concentration qualitatively detected.
Code E is plant 1034 From DSS Vol. II.
A-3
-------
TABLE NO. A-2
AVERAGE UNTREATED WASTEWATER CONCENTRATIONS
1976 PAINT SAMPLING PROGRAM
SAMPLING OK NINE PAINT-FORMULATING FACILITIES
PARAMETER
.iluminiim
antimony
l>a r i urn
boron
cadmium
chromium (total)
rob.ilt
copper
iron
lend
manganese
mercury (|lg/t)
molybdenum
nickel
tin
li tan i um
zinc
Conventional Pol lutants
I'll
HOD (mg/t)
0 f, G (mg/t)
TSS (mg/t)
Non-conventional PojJ_u lanls
COD (mg/t)
COD (dissolved) (mg/J)
TS (mg/t)
Srtlleable Solids (|ig/«)
Total Dissolved Solids -
(TDS) 9 (mg/t)
Total Volatile Solids -
(TVS) (mg/t)
VSS (mg/t)
VOS (mg/t)
phenols (mg/t)
76-A
12
1.0
1.7
0.31
0.01
13
0.38
0.15
2.9
14
0.06
0.9
0.1
0.25
0.5
16
8
10.9
1,300
300
1,600
3,000
1,800
4,000
180
2,400
2,100
900
1,100
2.5
76-n
140
0.45
20
1.6
0.06
15
1.5
0.47
81
22
7.5
2.0
0.15
4.5
1.2
200
260
8.2
16,00
1,700
9,600
42,300
16,500
23,900
40
12,500
8,400
3 , 200
5,200
0.4
76-C
240
0.37
0.66
0.28
0.09
0.23
0.10
0.49
12
0.43
0.21
1.1
0.1
0.64
0.5
280
210
7.8
4,800
1,400
14,100
14,900
4 , 300
20,000
110
5,900
8 , 300
5,400
2,800
0. 1
76-1)
66
0.45
0.61
0.5
0.04
0.12
0.35
0.38
82
0.61
18
14
0.1
0.19
0.5
59
5.9
7.6
4,600
1,400
9,900
22,600
7,100
20,400
90
10,400
10,300
3,900
6,400
0.7
r unn i i.uuc.
280
0.33
0.32
1.4
0.015
0.08
0.67
0.3
100
0.25
0.35
0.5
O.I
0.18
0.5
220
0.76
7.6
1,700
17,400
41.100
7,400
29,300
78
11,900
14,900
6,400
8,500
0.2
lti-r
100
1.9
2.7
8.9
0.07
32
1.1
0.38
31
92
0.69
0.4
2.2
0.65
1.9
140
9.3
12.4
3,200
1,200
2,900
12,800
7,800
102,100
45
99,900
23,300
1,600
21,600
0.1
76-G
35.6
0.1
0.1
21
0.01
0.01
0.17
0.13
1.6
0.20
0.05
0.7
O.I
0.05
0.5
.13
8.5
8.0
8,500
1,400
3,700
28,200
5,900
14,500
70
10,800
12,200
2,600
9,600
O.I
76-M
510
10
0.25
1 .0
0.15
8.5
0.55
600
0.85
0.53
0.004
0.33
I.I
27
940
1 300
9.1
8,500
2 , 300
39,500
63,800
15,200
48,600
10,900
9,100
22,100
16,700
5,500
2.6
76-J
100
0.5
2.2
1.4
0.86
0.14
3.5
0.3
4.5
0.42
0.10
1.2
O.I
0.25
0.38
540
740
8.8
3,500
2,400
15,600
27,900
4,200
36,000
14
17,600
20,600
4,800
8 , 300
1. 1
-------
TABLE NO. A-3
AVERAGE TREATED WASTEWATER CONCENTRATIONS
1976 PAINT SAMPLING PROGRAM
SAMPLING OF NINE PAINT-FORMULATING FACILITIES
I
l/l
PARAMETER
Metals (mg/£)
aluminum
antimony
barium
boron
cadmium
chromium (total)
cobalt
copper
iron
lead
manganese
mercury (|Jg/£)
molybdenum
nickel
tin
titanium
zinc
Conventional Pollutants
PH
BOD (mg/£)
Oil & Grease (mg/£)
TSS (mg/«)
Non-conventional Pollutants
COD (mg/£)
COD (dissolved) (mg/£)
TS (mg/«)
settleable solids (pg/£)
TDS 9 (mg/A)
TVS (mg/1)
VSS (mg/£)
VDS (mg/£)
phenols (mg/X)
76-A
18
1.0
0.9
0.4
0.01
10
0.4
0.07
2 4
6.8
0.02
OC
0.1
0.4
0.5
33
6.0
10.7
980
220
550
3,500
1,500
3,000
140
2,400
1,600
240
1,400
3.5
76-B
57
0.38
0.6
2.6
0.07
7.6
1.0
0.02
15
2.4
2.4
0 Q
0.2
3.9
0.6
17
230
6.0
11,600
250
850
21,000
16,100
14,700
13
13,800
3,000
620
3,400
0.3
2.9
0.2
0.1
0.2
0.01
0.02
0.05
0.1
0.8
0.2
0.04
0 6
0.1
0.06
0.5
17
0.9
7.1
1,700
20
130
9,000
3,500
6,000
1.7
5,900
870
50
790
0.1
20
0.1
0.3
0.4
0.01
0.04
0.1
0.3
38
0.2
3.1
7.4
0.1
0.06
0.5
17
3.9
7.2
2,700
1,100
4,200
16,500
5,800
8,700
40
4,500
6,800
3,100
3,700
0.4
76-1
24.8
0.125
0.2
0.66
0.01
0.02
0.06
3.6
0.13
0.05
0.53
0.55
0.1
0.04
0.5
7.2
0.02
7.1
3,800
170
1,400
9,500
4,900
4,900
22
3,500
3,000
1,100
1,900
0.1
76-F
10
4.1
0.4
7.4
0.15
19
0.7
0.6
11
19
0.3
0.7
3.3
0.6
3.9
1.0
8.2
9.4
6,300
870
2,100
24,600
10,900
85,000
67
83,000
19,000
450
18,600
0.4
76-G
3.2
0.5
0.1
0.1
0.01
0.01
0.04
0.05
0.1
0.8
0.03
0.5
0.1
0.01
0.5
1
0.13
7.5
3,800
37
7.0
6,900
6,600
3,900
0.1
3,900
570
70
60
0.1
76-H
530
13
0.3
1.0
0.2
8.2
0.3
270
0.7
1.0
0.004
0.33
0.8
23
440
1,400
6.4
3,200
1,300
4,500
7,800
4,200
10,200
4,100
5,700
3,700
1,700
2,000
2.6
45
0.07
0.07
1.0
0.2
0.01
1.0
0.1
5.2
0.06
0.2
0.7
0.1
0.01
0.5
380
100
5.7
1,100
160
1,400
3,300
2,000
3,200
11
2,300
2,000
580
680
0.1
-------
TABLE NO. A-4
RAW WASTEWATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
PARAMETER
ORGANIC TOXIC POLLUTANTS
acrolein
benzene
carbon tetrachloride
chlo robenzene
hexachlorobenzene
1,2-dichloroethane
1,1,1-trichloroethane
1,1-dichloroethane
1,1,2-trichloroethane
1,1,2,2-tetrachloroethane
2-chloronaphthalene
2,4,6-trichlorophenol
chlorofon
3,3'-dichlorobenzidine
1,1-dichloroethylene
1,2-trans-dichloroethylene
2,4-dichlorophenol
1,2-dichloropropane
1,3-dichloropropylene
ethylbenzene
fluoranthene
4-chlorophenyl phenyl ether
di(2-chloroisopropyl) ether
di(2-chloroethyoxy) methane
•ethylene chloride
dichlorobronoaethane
naphthalene
nitrobenzene
2,4-dinitrophenol
4,6-dinitro-o-cresol
pentachlorophenol
NUMBER OF
SAMPLES
ANALYZED
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
NUMBER OF
TIMES
ABOVE
DET. LIMIT
0
18
7
3
1
4
15
1
2
1
0
1
15
0
3
1
0
3
1
25
0
1
1
0
17
1
8
2
3
0
5
AVERAGE
(M8/*)
MEDIAN
10
1,933
3,770
1,405
92
118
141
11
568
20
10
2,455
186
10
138
135
10
265
100
7,482
10
266
3,200
10
31,878
27
2,950
100
173
10
6,017
L 10
370
14
56
92
33
76
11
10
20
L 10
L 2,455
92
L 10
23
135
L 10
41
100
1,300
L 10
266
3,200
L 10
620
27
54
HO
160
L 10
750
MINIMUM
(MB/*)
MAXIMUM
(pg/l)
L 10
20
L 10
L 10
92
L 10
10
L 10
L 10
L 10
L 10
L 10
16
L 10
L 10
L 10
L 10
L 10
100
80
L 10
266
3,200
L 10
L 10
27
L 10
L 10
110
L 10
L 10
L 10
9,900
30,000
5,500
92
420
930
13
2,800
30
L 10
4,900
900
L 10
620
260
L 10
968
100
112,800
L 10
266
3,200
L 10
210,000
27
18,000
180
250
L 10
27,000
-------
TABLE NO. A-4 (Continued)
RAW WASTEWATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
>
PARAMETER
phenol
total phenols (Standard Methods)
di(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
diethyl phthalate
benzo (A) pyrene
anthracene
tetrachloroethylene
toluene
trichloroethylene
aldrin
dieldrin
4' ft' -DDE
4 '4' -ODD
beta-endosulfan
endrin aldehyde
alpha-BHC
beta-BHC
gaana-BHC
delta-BHC
METALS
aluminum
antimony
arsenic
bariua
beryllium
boron
cadmium
calcium(mg/l)
chromium
NUMBER OF
SAMPLES
ANALYZED
31
56
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
31
•ji
31
55
57
48
54
60
52
60
54
60
NUMBER OF
TIMES
ABOVE
DET. LIMIT
8
45
9
3
13
1
0
0
16
27
12
0
0
0
0
0
0
0
0
o
0
55
11
25
53
14
39
29
51
50
AVERAGE
(l*/«
746
260
418
474
5,745
233
10
10
567
17,966
81
10
10
10
10
10
10
10
10
10
10
196,758
209
286
8,656
126
4,268
524
2,277
3,120
MEDIAN
(UR/A)
96
125
140
44
160
L 10
L 10
L 10
175
2,500
23
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
100,000
L 25
L 69
L 2,000
10
1,000
L 20
L 281
L 260
MINIMUM
(u*/£)
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
L
8,
L
L
10
1
10
10
10
10
10
10
10
73
10
10
10
10
10
10
10
10
10
10
10
000
10
20
50
2
131
8
20
50
MAXIMUM
<|J8/t)
3,800
1,900
2,810
1,800
69,000
680
L 10
L 10
4,900
259,700
250
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
3,000,000
2,000
2,000
100,000
3,990
40,000
15,600
38,000
40,000
-------
TABLE NO. A-4 (Continued)
RAW WASTEWATER DATA SUMMARY
PRIORITY POLLUTANTS
i
oo
PARAMETER
cobalt
copper
iron
lead
magnesium(mg/£)
manganese
mercury
molybdenum
nickel
selenium
silver
sodium
thallium
tin
titanium
vanadium
yttrium
zinc
CONVENTIONAL POLLUTANTS
PH
BOD(mg/JK)
oil & grease(mg/£)
Total Suspended Solids(mg/jfc)
NON-CONVENTIONAI POLLUTANTS
COD(mg/«)
TOC(mg/£)
Total Solids(mg/£)
NUMBER OF
SAMPLES
ANALYZED
- •
54
60
54
60
54
54
55
53
60
58
59
54
59
54
54
53
52
60
56
54
52
50
57
51
51
NUMBER OF
TIMES
ABOVE
DET. LIMIT
41
58
54
45
54
54
44
42
18
4
5
45
11
53
54
25
4
57
56
54
52
50
57
51
51
2,
5.
AVERAGE
912
2,476
271,307
6,300
107
,901
,161
674
1,350
165
15
397
151
1,111
16,677
409
206
74,746
9,892
1,099
20,424
54,956
10,601
28,945
MEDIAN
(Mg/£)
300
400
40,000
805
36
886
L 500
200
L 50
L 25
L 10
205
L 10
400
7,000
L 100
L 200
10,000
8
4,850
938
12,800
39,000
8,500
22,750
MINIMUM
(Mg/£)
L 20
50
3,000
22
4
40
L 1
L 5
L 5
9
L 1
L 60
6
L 50
80
32
L 16
600
5
280
42
280
1,201
1,500
90
MAXIMUM
(Mg/l)
11,600
40,000
6,000,000
80,000
2,100
40,000
62,000
11,200
40,000
L 2,000
L 100
2,900
L 2,000
20,000
210,000
11,400
L 2,000
900,000
13
65,500
3,400
148,000
350,000
46,000
160,000
-------
TABLE NO. A-4 (Continued)
RAW WASTEWATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
PARAMETER
IDS («g/£)
TVS («g/*)
VDS (•g/i)
TVS («g/A)
NUMBER OF
SAMPLES
ANALYZED
46
46
27
29
NUMBER OF
TIMES
ABOVE
DET. LIMIT
46
46
27
29
AVERAGE
(MR/*)
10,619
13,017
5,400
7,789
MEDIAN
(UR/£)
4,300
11,350
3,600
7,600
MINIMUM
(UR/i)
500
960
270
160
MAXIMUM
(UR/i)
145,000
31,700
21,800
25,000
All units ug/£ unless otherwise noted. . . ,, „„...,
Average, Median, and Minimum values based only on number of times detected for organic toxic pollutants.
L = Less Than
-------
TABLE NO. A-5
TREATED WASTEWATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
PARAMETER
I
(-•
o
ORGANIC TOXIC POLLUTANTS
benzene
carbon tetrachloride
chlorobenzene
1,2-dichloroethane
1,1,1-tricbloroethane
1,1-dichloroethane
1,1,2-trichloroethane
choloroethane
2,4,6-trichlorophenol
chloroform
1,1-dichloroethylene
1,2-trans-dichloroethylene
1,2-dichloropropane
l~3-dichloropropylene
1,2-diphenylhydrazine
ethylbenzene
di(2-chloroetbyoxy) methane
•ethylene chloride
isophorone
naphthalene
nitrobenzene
pentachlorophenol
phenol
total phenols
di(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
diethyl phthalate
diaethyl phthalate
acenaphthylene
anthracene
phenanthrene
NUMBER OF
SAMPLES
ANALYZED
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
53
27
27
27
27
27
27
27
27
NUMBER OF
TIMES
ABOVE
DET. LIMIT
12
2
0
3
10
1
3
0
2
14
2
4
2
1
0
16
1
19
2
4
1
3
11
42
3
4
5
2
1
0
0
0
AVERAGE
(M8/D
684
643
10
71
81
95
930
10
2,400
370
19
51
212
44
10
8,117
16
5,600
113
336
35
105
163
193
36
695
227
464
79
10
10
10
MEDIAN
(!*/£)
307
120
L 10
53
L 16
L 95
805
L 10
2,400
30
L 11
27
212
44
L 10
520
16
1,700
113
L 13
35
L 10
36
90
L 10
67
L 10
L 14
L 10
L 10
L 10
L 10
MINIMUM
(MR/*)
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
1,100
L 10
L 10
L 10
24
44
L 10
L 10
16
L 10
26
L 10
35
L 10
L 10
1
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
MAXIMUM
(Mg/£)
3,800
1,800
L 10
170
560
180
2,100
L 10
3,700
4,700
44
188
400
44
L 10
73,600
16
31,000
200
1,830
35
405
1,240
1,900
160
2,500
1,300
1,820
219
L 10
L 10
L 10
-------
TABLE NO. A-5 (Continued)
TREATED WASTEWATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
>
i
PARAMETER
tetrachloroethylene
toluene
trichloroethylene
4,4-DDE
endrin aldehyde
beta-BBC
METALS
aluainua
antiaony
arsenic
bariua
berylliua
boron
cadaiua
calciua(ag/£)
chroaiua
cobalt
copper
iron
lead
aagnesiua(ag/£)
manganese
•ercury
•olybdenua
nickel
seleniua
silver
sodiua
thalliua
tin
titaniua
NUMBER OF
SAMPLES
ANALYZED
27
27
27
27
27
IT
27
51
52
A7
H/
50
C C
55
48
ec
DJ
50
55
50
55
JJ
50
55
50
en
•*
SO
J V
50
NUMBER OF
TIMES
ABOVE
DET. LIMIT
7
21
8
0
0
41
6
5
26
33
38
29
25
44
32
21
50
44
35
22
13
2
t,
-J
J
42
27
26
AVERAGE
191
2,408
72
10
10
10
1. V
12,219
182
161
1,572
g
2,499
30
309
1,209
483
1,636
99,461
1,362
22
1,814
689
196
2,842
178
9
697
160
175
1,785
MEDIAN
(UR/i)
35
990
14
L 10
L 10
L 10
3,000
L 25
L 25
L 50
L 10
900
L 20
160
L 50
L 50
100
L 2,000
200
11
200
156
L 50
L 50
L 25
L 10
230
L 10
L 50
L 200
MINIMUM
(UK/*)
L 10
43
L 10
L 10
L 10
L 10
L 50
L 10
4
L 5
L 1
137
L 2
8
L 5
L 5
13
L 170
L 20
2
L 5
L 1
L 5
L 5
L 2
L 1
L 60
L 10
L 5
L 15
MAXIMUM
(UR/i)
700
13,200
300
L 10
L 10
L 10
100,000
L 2,000
L 2,000
30,000
L 50
10,000
L 200
1,220
30,000
6,000
60,000
2,000,000
40,000
81
30,000
4,400
6,000
80,000
L 2,000
L 50
15,000
L 2,000
2,000
30,000
-------
TABLE NO. A-5 (Continued)
TREATED WASTEWATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
PARAMETER
vanadium
yttrium
zinc
CONVENTIONAL POLLUTANTS
PH
BOD(mg/£)
oil & grease(mg/£)
total suspended solids (mg/jE)
NON-CONVENTIONAL POLLUTANTS
COD(mg/£)
cyanide
TOC(mg/£)
TS(nig/*)
TDS(ng/£)
TVS(mg/£)
VDS(mg/£)
TVSS(B18/£)
All units ug/£ unless noted.
NUMBER OF
SAMPLES
ANALYZED
49
47
55
51
50
47
49
52
47
48
48
45
42
42
42
NUMBER OF
TIMES
ABOVE
DET. LIMIT
• —
6
1
39
51
48
46
49
52
5
48
48
45
42
42
42
AVERAGE
(Pg/£)
83
152
7,360
5,282
228
1,946
19,655
53
3,867
6,249
4,451
3,146
1,839
1,307
MEDIAN
(Pg/D
L 100
L 200
1,000
7
3,750
25
240
10,050
L 20
2,500
5,190
3,960
1,465
1,120
102
MINIMUM
(|Jg/£)
L 10
L 16
L 60
3
6
1
6
1,350
L 1
460
30
844
240
184
2
MAXIMUM
(pg/jj)
200
L 200
100,000
32,000
1,700
22,000
260,000
530
25,000
23,000
14,966
12,000
9,990
8,200
V3lueS based
number of ti.es detected for .organic toxic pollutants.
-------
TABLE NO. A-6
SLUDGE DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
i
»—•
U)
PARAMETER
ORGANIC TOXIC POLLUTANTS
benzene
carbon tetrachloride
chlorobenzene
1 ,2-dichloroethane
1 , 1 , 1-trichloroethane
1,1,2, 2-tetrachloroethane
2,4,6-trichlorophenol
chloroform
2 , 4-dimethylphenol
ethylbenzene
nethylene chloride
naphthalene
2,4-dinitrophenol
pentachlorophenol
phenol
total phenols
di(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
diethyl phthalate
dimethyl phthalate
anthracene
pyrene
tetrachloroethylene
toluene
trichloroethylene
aldrin
beta-endosulfan
delta-BHC
NUMBER OF
SAMPLES
ANALYZED
9
9
9
9
9
9
9
9
9
37
9
9
9
9
9
NUMBER OF
TIMES
ABOVE
DET. LIMIT
A
t
0
8
4
3
30
6
4
1
1
o
g
AVERAGE
(PR/A)
414
i n
HI
0£.f.
ooo
1 ^
1J
in
1U
Q20
74*U
in
Ivl
U277
9
120,201
166
JWU
18
1O
346
325
552
455
10,410
•) £?2
J ,O££
170
•J 1 V
10
210
10
7 142
f, , i**^
44,740
•>q
J 7
10
10
10
MEDIAN
(MR/£)
30
T 10
Ju Iv
176
17
14
f»
1 J
T 10
U AVJ
920
L 10
237
1,735
202
L 18
125
150
166
215
1412
70
100
10
L 210
L 10
170
905
L 10
L 10
L 10
L 10
MINIMUM
(PR/A)
L 10
L 10
12
17
L 10
L 10
L 10
840
L 10
26
300
L 10
L 10
35
L 10
L 1
L 10
18
L 10
50
L 10
L 10
L 10
L 10
130
L 10
L 10
L 10
L 10
MAXIMUM
(PR/A)
1,900
L 10
340
17
3,200
17
L 10
1,000
L 10
99,000
900,000
1,050
27
1,100
1,120
6,000
1,940
38,800
17,750
960
L 10
410
L 10
8,200
350,000
130
L 10
L 10
L 10
-------
TABLE NO. A-6 (Continued)
SLUDGE DATA SUMMARY
PRIORITY POLLUTES7! "
CONVENT !ONALS
NUMBER OF
SAMPLES
ANALYZED
aluminum
antimony
arsenic
barium
beryllium
boron
cadmium
calciumfnig/£)
•p. chromium
^ cobalt
i> copper
iron
lead
•agnesium(mg/£)
manganese
•ercury
molybdenum
nickel
selenium
silver
sodium
thallium
tin
titanium
vanadium
yttrium
zinc
37
17
12
36
39
34
39
36
39
36
39
36
39
36
36
36
35
39
36
38
36
9
36
36
35
33
39
37
7
5
36
25
29
29
36
37
32
39
36
37
35
36
31
34
27
2
8
32
1
36
36
30
12
36
867,154
1,579
879
9,831
192
2,965
840
2,870
7,050
2,131
7,121
886,452
10,770
156
7,249
15,061
1,680
10,443
547
22
583
967
2,640
38,345
891
207
230,946
60,000
150
495
4,345
20
2,000
200
914
700
600
1,000
200,000
3,000
79
5,000
640
1,000
L 200
L 250
L 10
260
L 400
2,000
20,000
400
L 200
90,000
50,000
L 10
L 25
72
2
175
L 8
250
L 50
L 50
216
22,600
100
L 1
300
5
L 50
L 20
8
L 2
100
L 10
200
1,000
60
45
600
3,000,000
13,000
L 2,000
50,000
3,760
14,200
14,700
30,200
90,000
15,600
80,000
8,000,000
80,000
1,500
50,000
220,000
15,000
200,000
L 2,000
L 100
3,500
L 2,000
14,500
230,000
11,500
L 600
2,000,000
-------
{Jt
TABLE A-6 (Continued)
SLUDGE DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
PARAMETER
CONVENTIONAL POLLUTANTS
pH
BOD(«g/4)
Oil & Grease(ng/£)
Total Suspended Solids (mg/£)
NON-CONVENTIONAL POLLUTANTS
COD(ng/£)
cyanide
TOC(«g/£)
TS(«g/£)
TDS(«g/£)
TVS(«g/£)
VDS(ng/£)
TVSS(mg/£)
NUMBER OF
SAMPLES
ANALYZED
35
34
35
33
38
34
36
32
30
31
16
20
NUMBER OF
TIMES
ABOVE
DET. LIMIT
35
34
35
33
38
3
36
32
27
31
14
20
AVERAGE
(PK/£)
24,982
7,578
101,201
171,641
1,151
35,126
107,785
13,122
39,438
7,440
23,002
MEDIAN
(PR/4)
7
10,200
2,500
70,000
130,000
L 20
29,500
78,000
9,800
37,000
5,250
14,133
MINIMUM
(PK/£)
2
1
230
100
7
L 1
12,000
8
L 1
3,100
L 1
880
MAXIMUM
(pg/£)
10
150,000
129,000
466,100
950,000
36,500
108,000
470,000
100,200
187,000
40,400
89,000
values based only on nun-ber of ti«,es detected for organic toxic pollutants.
L = Less Than
-------
TABLE NO. A-7
INTAKE (TAP) WATER DATA SUMMARY
™T™ 1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
PARAMETER
ORGANIC TOXIC POLLUTANTS
benzene
carbon tetrachloride
chlorobenzene
1,1,1-trichloroethane
1,1,2-trichloroethane
1,1,2,2-tetrachloroethane
2,4,6-trichlorophenol
chloroform
3,3-dichlorobenzidine
1,1-dichloroethylene
2,4-dichlorophenol
2,4-dinitrotoluene
ethylbenzene
fluoranthene
oethylene chloride
bronoform
dichlorobrononethane
chlorodibromonethane
nitrobenzene
pentachlorophenol
total phenols
di(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
3,4-benzofluoranthene
11,12-benzofluoranthene
anthracene
tetrachloroethylene
toluene
trichloroethylene
NUMBER OF
SAMPLES
ANALYZED
29
29
29
29
29
29
29
29
29
29
29
29
29
29
29
29
29
29
29
29
21
29
29
29
29
29
29
29
29
29
29
29
NUMBER OF
TIMES
ABOVE
PET. LIMIT
9
2
0
6
1
0
0
14
0
2
0
0
2
0
16
1
10
5
0
0
6
0
0
2
0
0
0
0
0
0
3
0
AVERAGE
90
13
10
36
14
10
10
118
10
10
10
10
163
10
428
12
25
19
10
10
17
10
10
28
10
10
10
10
10
10
281
10
MEDIAN
MINIMUM
MAXIMUM
16
14
L 10
18
L 14
L 10
L 10
43
L 10
L 10
L 10
L 10
61
L 10
67
L 12
15
L 10
L 10
L 10
L 20
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 1
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
L 10
572
15
L 10
110
18
L 10
L 10
570
L 10
13
L 10
L 10
420
L 10
2,200
14
86
113
L 10
L 10
40
L 10
L 10
100
L 10
L 10
L 10
L 10
L 10
L 10
2,700
L 10
-------
TABLE NO. A-7 (Continued)
INTAKE (TAP) WATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
>
i
PARAMETER
endrin aldehyde
alpha-BBC
beta-BHC
gamma-BHC
METALS
aluminum
antimony
arsenic
barium
beryllium
boron
cadmium
calcium(mg/£)
chromium
cobalt
copper
iron
lead
magnesium(mg/£)
manganese
mercury
molybdenum
nickel
selenium
silver
sodium
thallium
tin
titanium
vanadium
yttrium
zinc
NUMBER OF
SAMPLES
ANALYZED
29
29
29
29
24
25
25
23
27
21
27
23
27
23
27
23
26
23
•>/.
ii
22
26
25
27
23
25
21
22
22
19
26
NUMBER OF
TIMES
ABOVE
DET. LIMIT
0
0
0
0
12
3
3
17
2
9
8
13
12
1
17
8
7
20
q
J
•a
J
6
4
2
2
6
0
16
3
1
0
19
AVERAGE
10
10
10
10
1,303
10
18
64
6
382
25
53
36
25
174
1,029
105
20
33
1
28
32
18
8
90
10
80
101
55
114
974
MEDIAN
(|IR/«
L 10
L 10
L 10
L 10
L 500
L 10
L 25
L 50
L 4
500
L 20
40
L 20
L 20
60
L 700
L 80
10
45
L 1
L 20
L 20
L 25
L 10
L 60
L 10
L 50
L 60
L 50
L 60
L 600
MINIMUM
L 10
L 10
L 10
L 10
L 50
L 2
L 2
5
L 1
L 50
L 2
L 10
L 5
L 5
6
L 17
L 10
L 1
5
L 1
L 5
L 5
L 2
L 1
L 15
L 2
L 5
L 15
L 10
L 16
40
MAXIMUM
L 10
L 10
L 10
L 10
20,000
L 25
L 25
600
L 20
1,000
L 200
210
200
L 50
959
3,000
400
81
70
L 5
60
200
L 25
L 20
240
L 20
300
200
L 100
L 200
8,000
-------
TABLE NO. A-7 (Continued)
INTAKE (TAP) WATER DATA SUMMARY
1977/1978 SAMPLING PROGRAM
PRIORITY POLLUTANTS, CONVENTIONALS, AND NON-CONVENTIONALS
i
i-»
oo
PARAMETER
CONVENTIONAL POLLUTANTS
pH
BOD(»g/£)
Oil & Grease(«g/£)
Total Suspended Solids (ag/£)
NON-CONVENTIONAL POLLUTANTS
COD(mg/£)
Cyanide
TOC(«g/£)
TS(«g/£)
TDS(«g/£)
TVS(«g/£)
VDS(ng/£)
TVSS(Bg/£)
NUMBER OF
SAMPLES
ANALYZED
22
22
18
20
26
20
23
20
18
17
17
18
NUMBER OF
TIMES
ABOVE
DET. LIMIT
22
i
4
17
1-1
20
18
19
18
17
17
12
AVERAGE
(M8/£)
1
3
22
7
318
338
62
56
1
MEDIAN
(p*/£)
7
L 2
L 1
3
L 5
L 20
5
187
187
33
28
1
MINIMUM
(PR/£)
6
L 1
L 1
1
2
L 1
L 1
10
29
12
4
L 1
MAXIMUM
(no/ 9.)
9
L 6
L 5
11
40
93
20
1,500
1,491
190
188
8
All units jJg/£ unless noted.
Thin"'
°Dly °n
°f tinteS detectcd for "ganic toxic pollutants.
-------
APPENDIX B
LIST OF PRIORITY POLLUTANTS ANALYZED FOR
IN WASTEWATER OF PAINT PLANTS A, B, C, AND D
-------
-------
APPENDIX B
LIST OF PRIORITY POLLUTAKTS AKALYEED IH THE -ASTEVATE. Of PAIKT PLAKTS A.i.C. .«d D.
I. KITALS V- BTOACTABLE
I. SEMI-VOLATILES
2. BASES
AJTT1HOKY
AiSENIC
IERYLL1UM
CADMIUM
CHROMIUM
COPPER
LEAD
MERCURY
NICKIL
SELENIUM
SILVER
THALLIUM
ZINC
II. MISCELLANEOUS
ASBESTOS •
CYANIDES
III. OIBESZO-P-DIOXINS
AND OlBESZOrURANS
2.3.7.8-TCDD
IV. PITRCEASLE
1,1. 1-TRICHLOROETRANE
1.1.2 . ;-TE7R>CHLOROETHANE
!.: .I-TR'CHLORCETHANE
1 .1-DICHLOROE7HANE
1,1-OICHLOROtTHENE
1.2-5!CKLOROETHAWI
1 , J-01 CKLOROPROP AWE
1,J-D1CHLOROPROPYLENT
2-CHLORCETXYl. VINYL ETKE1
*,CRCLE:S •
ACEYLOSITR1LE
EENZESE
A. PESTICIDES
I. 01CANOHALIDE
(,,4'-ODD
t,4'-DDt
4,4-.DDT
ALDR1N
ALPHA.BHC
tETA-BHC
CHLOUANE
DELTA-BHC
DIELDRIN
ENDOSULFAN I
ENDOSULFAN II
ENDOSULFAN SULFATE
ENDRIN
ENDtIN ALDEHYDE
CAMU.-BHC
HEPTACHLOR
HEPTACHLOR EPOXIDE
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1244
PCB-1254
PCB-1260
TOXAPHENE
B. SEMI-VOLATILES
1. ACIDS
DI-N-FROFYLNITROSAMINE
FLUORINE
1SOPHORONE
N-N1TIOSODIKETHYLAMINE
H-N1TROSODIPHEJIYLAM1NE
HITROBENZENE
PYRENE
}. NEUTRALS
•. PHTKALATES
BRCC.CD: CKLOROMETHANE
BROHOMETHANE
CARBON TITHACHLORIDE
CKLOP.OBENZENE
CHLORCETKANE
CHLOROFORM
CHLOROHETHANE
DISROHOCHLOROMETHAHE
ETHYL BENZENE
XE7KYLLNE CHLORIDE
TETR>CHLOROETMENE
TOLL'ENE
TRANS-1 ,2-DlCHLOROETHENE
TRICKLOROrTHENE
VINYL CHLORIDE
2.4,6-TR1CHLOROPHENOL
2,4.D1CHLOROPHENOL
2,4-DlKETKYLPHEXOL
2,4-DINmOPKENOL
2.CHLOROPHENOL
2-NITDOPHENOL
4-NTTROPHENOL
DIN'TROCRISOL
PENTACHLOROPHENOL •
PHENOL
2. BASES
1,2-DIPHENYLHYDHAZINE
2.4-DINITROTOLUENE
2.6-DINITROTOLUENE
3.3-DICHLOROBENZIDINE
4-BROMOPHENYL PHENYL ETHE1
4-CHLORO.3-METHYLPHEMOL
4-CHLOROPHENYL PHENYL ETHEI
BENZIDINE
b i> <2-CHLOROETHYL)ETHER
bi.U-CHLOROISOPROPYDETHEI
B1S(2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHALATE
01-N-BUTYL PHTHALATE
Dl-N-OCTYL PHTHALATE
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
b. POLYNUCLEAR AROMATIC
2-CHLORONAPHTHALENE
ACENAPHTHENE
ACENAPHTHYLENE
ANTHRACENE
BENZO( A (ANTHRACENE
BENZO( A) PYRENE
BENZOICHDPERYLENE
BENZO(K)FLUORANTHENE
CHRYSENE
01 BENZOt A. H.) ANTHRACENE
FUJORANTHENE
INDENOtl . 2. 3-CD) PYRENE
NAPHTHALENE
PHENAJTTHRINE
CHLORINATED HYDROCARBONS
1.2.C-TR1CHLOROBENZENE
1.2-DICKLOROBENZENE
1 .3-01CKLOROEENZESE
1,<—D1CHLOROBENZENE
b i >(2-CHLOROETHOXY)METHANE
HEXACHLOROBENZENE
HEXACHLOROBUTADT ENE
HEXACHLOROCYCLOPENTAD1ENE
HEXACHLORCETHANE
SOT ANALYZED FOR SAMPLES COLLECTED.
B-l
-------
-------
APPENDIX C
LIST OF NON-PRIORITY POLLUTANTS ANALYZED FOR
IN WASTEWATER OF PAINT PLANTS A, B, C, AND D
-------
-------
APPENDIX C
LIST OP MOK-PRIORm POU.WTAKT PARAMETERS ANALYZED 1H WASTtWATU Of PAIHT PLAITS A.B.C. .ml D
1. ELEMENTS
ALUMINUM
BARIUM
BISMUTH
BOROK
CALCIUM
CERIUM
COBALT
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
COLD
HAFNIUM
HOLMIUM
INDIUM
IODINE
IRIDIUM
IRON
LANTHANUM
LITHIUM
LUTETIUM
HACNESIUM
MANGANESE
MOLYBDENUM
NECDYMIUM
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SILICON
SODIUM
STRONTIUM
St'LPJR
TANTALUM
TELLURIUM
TERBIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZIRCONIUM
III. CIBENZO-P-D10XINS
AND DIBENZOrURANS
DIBENZOrURAN
HEPTACHLORODIBENZO-P-OXOXIMS
HEPTACHLORODIBEHZOrUBAMS
HEXACHLORODIBCNZO-P-DIOXINS
HEXACHLOROD1 BENZOrVRANS
OCTACHLORODIBCMZO-P-OIOXINS
OCT ACHLOROOl BENZOPURAHS
PEKTACHLORODIBENZO-P-OIOXINS
PENT ACHLORODI BENZOPURANS
TETRACMLORODIBZNZO-P.DIOXINS
TtTRACHLOBODI BENZOFURANS
IV. PURGEABLE
1.1.1.2-TETRACHLOROmiANE
I.2.3-TRICHLOROPROrANC
1.2-DIBROMOETHANE
1.3-D1CHLOROPROPANE
1.3-D1CHLORO-2-PROPANOL
I,4-DIOXANE
1-BROMO-2-CHLOROBENZENE
1-BROMO-3-CHLOROBENZEHE
2-BUTENAL
2-HIXANONE
2-PICOLINE
1-CHLOROPROPENE
^METKYL-2-PENTANONE
ACETONE
ALLYL ALCOHOL
CARBON DISULMDE
CHLOROPRENE
ClS-I.3-DICHLOROPROPENE
DIBROMOCHLOROPROPANE
DIBROMOKETHANE
DlCHLOROFLUOROMETHANE
DlETHYL ETHER
DIMETHYL SULPONE
ETKYL CYANIDE
ETHYL MITHACRYLATE
ISOBUTYL ALCOHOL
METHACRYLONITRILE
METHYL ETHYL KETONE
METHYL IODIDE
METHYL MITHACRYLATE
N.S-DIMETHYLPORMAMIDE
TRANS-1.3-01CHLOROPROPENE
TRANS-l.t-DlCHLORO-2-BUTENE
TR1CHLOROFLUOROMITHANE
VINYL ACETATE
V. EXTRACTAJSLE
1. OICANOPHOSPHORUS
CBOTOXYPMOS
CYCON
DEKETON
DIAZINON
DICMLORVOS
DKROTOPHOS
DIOXATKION
DISULrOTON
EPN
ETHIOM
FAMPHUR
FENSULPOTHION
FEKTHlON
HEXAKITKYLPHOSPHORAKIDE
LEPTOPKOS
MA LATHI ON
METHYL PARATHION
MEVINPHOS
MONOCROTOPHOS
NALED
PARATHION ETHYL
PHORATE
PHCSMET
PHOSPHAKIDON
SULFCTEPP
TEPP
TERBUPOS
TETRACHLORVINPHOS
TRICHLOROFON
TRICRESYLPHOSPHATE
TBIMETHYLPHCSPHATE
4. HERBICIDES
A. PESTICIDES
1. ORGANOHALIDE
CAPTAFOL
CAPTAN
CHLOROBENZ1LATE
ENDRIN KETONE
1SODR1N
KEPONE
METHOXYCHLOR
MIREX
N1TROFEN
PCNB
2. CARBAMATES
ETHYLENEBISD1THIOCARBAMIC
ACID.SALTS. AND ESTERS
MANEB
NABAM
THIRAM
Z1NEB
Z1RAM
). ORCANOPHOSPHORUS
2.<-D
2.4.5-T
2.4.5-TP
DIAL LATE
DICHLONE
D1NOSEB
TRIFLURALIN
B. SEMI-VOLATILES
1. ACIDS
2.3.4.6-TCTRACHLOROPHENOL
2.3,6-TRICHLOROPHENOL
2,4,5-TRICHLOROPHENOL
2.6-DICHLOROPHCNOL
BENZ01C ACID
CARBAZOLE
HEXANOIC ACID
MALACHITE GREEN
0-CRESOL
P.CRESOL
P-CYMENE
PHENACETIN
THIOPHENOL
2. BASES
AZINPHOS-ETHYL
A21NPMOS-METHYL
CARBOPHENOTHIOM
CHLORPENVINPHOS
OtLORPYRIFOS
COUMAPHOS
I.3-DICHLORO-2-PROPANOL
1.3.5-TR1TH1ANI
l.i-DINITROBENZENE
1.4-NAPHTHOOUINONE
1.5-NAPHTHALENED1AMINE
I-CKLORO-3-NITROBENZENE
1-METHYLFLUORENE
I-METHYLPHENANTHRENF
l-NAPHTHYLAMINE
C-l
-------
LIST of NON-riioim roturiAirT PARAMETERS ANALYZED IN WASTWAra or PAIHT PLANTS A.-I.C. ««d o
2. BASES
-PHENYLNAPKTHALENE
.3-DICHLOROAN1L1NE
. 3-01CKLORON1TROBENZEHE
.3-BENZOFLUORENE
. <•. y-TRlMETKYLANILINE
. I-OIAHINOTOLUENE
.t-DI-TERT-BlOTL-P-BENZOQUINONE
-1SOPROPYLNAPKTHALENE
-(HETHYLTH10 > BENZOTH1AZOLE
-HETKYLBENZOTH10AZOLE
-NETHYlJfAPKTHALENE
-NAPKTHYLAMINE
-N1TROANILINE
-PHENYLNAPKTHALENE
.3-0IHETHOXYBEKZ10IKE
.6-DIHETKYLPHENAKTHRENE
-HETMYLCHOLAKTHRENE
)-K:TROANILINE
*. <• • -KITHYLENEb li (2-CHLOROAHILJH
t.5-METHn.ENE PHEHAKTHRENE
i-AMINOBIPHENYL
*-CHLORO-2-NmOANILINE
<-N:TROBIPHENYL
5-CHLORO-0-TOLUID1NE
J-NI7RO-O-TOLU10INE
1.12-DIHETHYLBENZ(•)ANTHRACENE
ACETOPHENOKt
ANILINE
ARAMITE
SEMAN THRONE
SENZYL ALCOHOL
b«i(CHLOROKE7HYL)ETHEB
B. SEMI.VOUTILCS
j. BASES'
BROMOrrNIL
CHLOROACETONITRILE
OICHLORAN
DIBENZOTHIOPHENE
DIPHENYL ETKER
' DIPHENYLAM1NE
ERYTHRITOL ANHYDRIDE
HZSTRANOL
HtTHAPYRILCNE
HETHYL HrrHANESULrONATZ
N.N-DIMETHYLFORHAMIDE
H-NITROSODI.N.BUTYUMINE
N-NITROSODIETHYLAHINE
M-N1TROSOHETKYLPHEXYLAM1NE
N.M iTRosoMmm.rnnruMiNE
N.N1TROSOMORTHOLINE
N-NITROSOPIPERIDINE
0-AN1SID1NE
0-TOLUIDINE
P-CHLOROANIL1NE
P-D1HETHYLAM1NOAZOBENZENE
P-NITROANILINE
PHENOTHIAZINE
PRONAH1DE
PYR1DINE
TH1ANAPKTKCNE
TRIPHENYLENE
TR1PROPYLEHECLYCOL HETHYL ETHtl
). N-ALKANES
N-DICANt
N.DOCOSANE
N.DODECANE
N-EICOSANE
N-HEXACOSANE
H-MEXADEQANt
H-OCTACOSANE
N-OCTADtCANt
N-TETRACOSANE
N-TETRADECANE
N-TRIACONTANE
*. OTHERS
I.2.3-TRICHLOROBEKZCNE
1,2.3-TRtMETHOXYBENZENE
1.2.4.J.TETRACHLOROBENZEHE
ALPHA-TERPINEOL
BIPHENYL
DIPHENYL SULFIDE
ETHYLENETHIOUREA
ETKYLMETHANE SULFONATE
HEXACHLOROPROPENE
ISOSAFDOLE
LONCIFOLENE
PENTACHLOROBENZENE
PENTACHLOROETHANE
PENTANETHYLBENZENE
PERYLENE
RESORCINOL
SAFROLE
SOUALENE
STYRENE
TNIOACETAKIDE
TKIOXAKTHOKE
C-2
-------
APPENDIX C
TABLE C-l (Continued)
Non-Priority Test Parameters
Residue, Filterable
Residue, Non-Filterable
Ammonia, as N
Nitrogen, Kjeldahl, Total
Total Phosphorus
BOD-S
COD
Oil & Grease, Total Recoverable
Total Organic Carbon
Flash Point
pH, Soil
Corrosivity
Fluoride
Nitrate/Nitrite
Sulfide
C-3
-------
-------
APPENDIX D
POTW MODEL RESULTS USING
50TH PERCENTILE POTW AND RECEIVING STREAM FLOWS
-------
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APPENDIX E
POTW MODEL RESULTS USING
25TH PERCENTILE POTW AND RECEIVING STREAM FLOWS
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APPENDIX F
DILUTION FACTOR RESULTS INDIRECTS
-------
-------
•UN BATE I 88/01/29 SUFtlART OF INDIRECT DI9OMITCER3 rmc •
POTMCAT REACH
UNIT NUMBER
18050004001
18070104003
7080104002
7090005014
712000300*
7120004009
7120003007
4840002001
4040002002
4100005005
8090301040
0
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2030104002
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2030104002
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2030201004
4140201057
4110002001
50*0001027
11070107021
170900030*3
20402*3010
313020200*
12*3*102004
1203010*052
12030103022
3010101033
17010307021
17110*1908*
17110013*05
1711*814001
HIT TOTAL IPUNT9
FU8 PUNT FLOM FLOM >0 POTWFION
INGOI ineoi
N
T
T
T
N
T
T
N
T
T
N
If
N
r
T
T
T
N
T
N
T
T
T
T
T
N
N
T
T
T
T
T
T
T
T
T
T
T
.0488
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.1270
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.4220
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.0108
.2720
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.0048
.7050
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.1080
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.0290
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.•37*
.0240
.0090
.0124
.0009
.0073
8.100
RCCEIVINO
8 AVCFIOM
IHGOI
_
238.000
3.000 8 42231.89
44.900 8 2428.4*
10.400 8 203.09
797.000 8 9*0.75
192.000 8 145.47
333.000
18.800
-
-
3*.200 • 1094.1*
s.»oo
0.02*
183.73*
-
-
-
5.45* 8 1*1.0*
20*. 000 • *915.*4
150.000 8 114411.75
3.000 8 31077.07
8*. 400
20.000
2*0.000
0.013
2.720
34.900
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50. 000
94.000
91.700
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25.000
10.100
30.100
44.200
19.700
134.000
23.***
35.***
195. •••
37.30*
23.400
-
-
-
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—
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-
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575.79
934.74
10.43
3*50.77
1215.57
13743.19
794.77
7.47
1371.29
199.**
4550.50
988.88
2189.42
STREAMFIOH
LCMFIOH
ineoi
.
10480.74
597.99
40.20
308.97
47.22
—
-
39.71
-
-
-
28.32
933.04
21525.58
3243.08
-
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-
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•
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47.02
50.99
0.07
389.29
58.98
971.73
2.94
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3.57
32.5*
371.99
199. tS
327.02
9EMER OHUnON
FACTOR
POTW RECEIVIN8 STREAM
DILUTION FACTOR
AVERACE 7-4-1*
1&.90
1*927.78
47.*2
823.83
13*. ••
574.21
34.81
1903.41
90.02
1392.31
24.**
129.0*
14*2.44
38.93
488.19
427.39
9.78
•912.00
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241*3.39
1.**
9.07
4983.71
5153.85
10373.43
133.33
801.37
8B5.71
•944.45
93.32
4574.33
1524.14
195.45
35*3.83
983.33
3888.89
13725.81
41ft*«.*7
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-
14883.9*
54.09
19.**
1.21
1.7*
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90.23
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29.99
33.37
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1*399.02
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10.19
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274.31
17.98
1.48
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3493.38
13.32
3.87
1.39
1.29
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4.14
22.32
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