-------

-------
           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

-------

-------
                             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.

-------

-------
                        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

-------

-------
                        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

-------
                         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

-------
                        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

-------

-------
                    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

-------

-------
                          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

-------
                           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

-------
                         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

-------

-------
                    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.

-------
 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
                               ii

-------
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.
                                iii

-------

-------
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

-------
 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

-------
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

-------
              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

-------
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.

-------
TECHNICAL SUPPORT STUDY

-------
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.

-------
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).

-------
                                   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

-------
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

-------

i
1
SOLVENTS
k
I
| RESINS
t
T 1


>
I


MIXING TAMK
1
f

??.38L£ SAND
OR 3ALL WILL
<
»
SURFACTANT
1
r




PIGMENTS
1
i
I


HIGH SPEiD
OISPS.^S>ON

EXTENDING
AGENT
t

             TINTS
           ACOIT1VES
 ACOIT1CRAL RESINS,
SOLVENT, SURFACTANT
•RNT1NG AND
 THINNING
   TANK
                              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

-------
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

-------
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

-------
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

-------
 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

-------
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

-------
     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

-------
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

-------
                 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

-------
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

-------
 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

-------
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

-------
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

-------
                                                                  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

-------
                                   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

-------
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

-------
                       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

-------
                        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

-------
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

-------
 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

-------
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

-------
                                    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

-------
                                  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

-------
 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

-------
                                  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

-------
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

-------
                                    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

-------
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

-------
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

-------
ENVIRONMENTAL IMPACT ANALYSIS
               87

-------
 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

-------
                                  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

-------
                                   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

-------
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

-------

-------
^
*i



i
e

i
      lit
§
I1
         i
            3'5333'2v3SJ'3S2	'23'|i '
                                                         i  i § _, i
                   » • Ci ' •
                       » ' »
•» •  ••(.••
                                       ,,
                    .E  ..  .1    ..  II
                        8ft **  fltCti • i S **
                       i w*   ~ S    K
                            K
           i r s


          I



          |
                        I Sii
         . . .  .MiiM-liMii
             »•  •• »' *> »• »*  «f •• E • •' •*
                                   ......
                                    i
                              D-l

-------




» •
ri
[i
i
i **
I
C E £
if 1!
M H
IK 'E
I1
|
i
11
£ B
E £



s
i


i
i
§
i
£


•
I
m
E




1



?s
is

!
e
i
K
•<


|
I
i
I
s
i
i
*
|
!
!5

„ „
' ar 	 .'**;•«





I
C 6
5 . , , £ 	 , 	
-> w
-< WWW
...,S, ,,,•",, |,|,,
jf c-'l"




,,,,.,» 	 s»
! !!

D-2

-------
ii   lliii liiii  i  i

   .« '
i m i S t i i l • * '
            Sirr-rSI'lS	
            p .•  j»  .•
           i S * * i * * *
                     	
          H'rrir-i

          ii'i-i'ii1-i	

     	*!•,*». S».S»!*.22	
     	aa  s  s  s*  as

ill1 ' ll'ilS' «iaiiliS»' I	
                                                I
                              §3 = 3  §5*
                                 |!
                                                   i!
                                                 i i ti
                                                 I  ii
                                     I 31
                                     IS
                                    15
                                           -
    i i i t i i >
          "'
               1 '' '
  • ' • •
     33 «-
   ? ........ i
                              S-5'S'SS'iS .....
                                                I  I
                                               I!
                                    .• !•
                                               S" I
                                I!
                      , , , . . . . .
                                - 2 • ? • i • ' ' 2 .....
 I I • 1 I
                                               !!f

-------






ri


§•
I
e *
i


t
B s 2
I •'
|
1 - r
E K i i
IE B 2
ii *i
i"
1
1
i
i
T •
|e
g §
is







i
i
t
e
i



£
|
§
E

6







5
g
Cl
S
c








I


1






V &
ii


1
f
i


fc£
p«





I
1

1
1

1
i
i



e
t
i
t
i
i
i
I

I
g!

•w m ^ v ^ _
"l!" t!











1

t C



, , , , § 	 I , , , .
s 	 * —

§•" « »
> > • i * i 8 i 8 i i
fi- sf s










H?....g 	 1 i
• » o »' •' •'
Sen1 * ' * » ' ' ' ' * i £ i
1 .
iili?,il .. -!
||Ii|fl| j|]iUf|l


-------
                                              3

                                              i



                                              I
• ilsc,• III- SlaJi.e* *'Hlsi- •• I-88 = 813 • •• !•••
           !•!»!»  V !».«.•  .•  !» i- .<» 5» P
                                 •»«.»!».«
                                ?!•!•.«!*
. ,a8ii  in'i|i  • in-1-nair • -i- -8888ai• ••••••

. -I	I	i'lilii1 • •!• -iiiiii	
                 • • in- •
                              1  1 =
•!• • • 'i'il' ' 3' "ViSlllSjlJIJjCIJaaislSiJJJsS:1
  3
                                               !
^1
2 ,
1

i

                                                    i


                        SSS'-'21'22:222'•  i ••
 •••••iij1'1'**'
                    2-2222 2 i • -2- -222222	
                                               •
                                           i
                                                    i

-------
'I
i
ci
i
fi






ri
. .
B ft
|f
i



g.
* *•
f" i
i
||
5 1
*E



i
i
1*
l I



i




w
£



1
1
i
t







i

e
'






1
i
B
i
g




§ i



*


w
I
*
i



i
i

•

t
8
I
i
i

I
i
i
E
k
I
i

I
Ij
• • 'S'S* * • *25v2* • •









••••••iii.iiii,,,
E


5., , ,K , , , , 	

. , , , 1 	 I , , , ,
e* •*
^j _i _ j .
^* ^* •* ••
,1,,|,,,,~(1|,f
R* tf sf




>..•.•...,••,•,,,

>.<•.•.,.,••,•,,,

If II 8
I I 11 S
•» »* VI » 4*

144 j .i t.
i||]i|f|j]!iti|fj
                                1-6

-------
•38' ' ' 'wI'SBli'll'B1 'ISI' ' ' •S'i's'a'aSa'a' '

-ii- • • -ii-iiii-ii-i1 -SSi- • • -a-ri'i'StiS'S1 -IH

. •• — • • •••!•• ••••••• ill — i'il'i'iiU- -i
 i 9 i i
          I ,.,..,.•.
                      !»!»!•
                                                s
                    i» « !» . . . . ? . ^ . •• . ^ t !* ~ ^ • •? « ' 2 « «
                    aas1• ' • a a a a aaa s  »"•

                       3*3»--I
                    ill-'
                        	I '3sl'11*
           — — •

           *
1' I1 ' 3' ' ' ' 198' ' J'-SJX;

                                                i
                                                I!

                   --------		  ,. ,. !?!
                                                     ^)»
                                                         i
                                                         I
                       a i • -
 • B a • • • •


 .-.§-•••
IB'lllB'11'1' '-ii' ' '




.........••••••ll'1'
•2|21212'222'21•m'



• •-2-2-2-222-•


,«•,.-,!», s» , 2 2 2 . 2
                                         • » x i »
                                  2- 2- §22- 2- • 2-
,j	."...j	2 2 2 ''''?' B



, a	',.. ,s	• §22- • • • 8-2- B-2- 222- 2- -2- •


                            j»
                                                 1


-------
'
L
    f
             x
   ....g|.,3
                  il'l!5


                   a
      II
 ''I'l1
   ^  i—


 .,,,j.
           .....
                         I!
                         ii

                      i if
  * > • • • > t i • •
      s

      I
      ii
              i • • • •
                   I
     52- -•:•-.§.... if
                    i
»i  i
a <4  a
                   if


-------
                  APPENDIX E

           POTW MODEL RESULTS USING
25TH PERCENTILE POTW AND RECEIVING STREAM FLOWS

-------

-------
   ii
   i
                                      •s-r
               • •    '  •
              3 • «
               ' *    *  '
	i.iSSS'S'SSS'SSS	31,ii,•••••••••..•••



  «   .  ..i  «.  .»    .«  ii      5   5s  2
, , 2 , ,R,SR8.B~.R|- • • I" • i I • ' ' . .R. •*•.•'	' ' '
  *       »      _*        *T          ^  ^
                                   tw
   .. I!
   ii'ii
ir
I1
      I
      ii i
                   ,,1(111111111111
                                   I I I I « I t I * * *
                ,11111 . .fill . . • .



. • • .5.5555'5<55S(553	•" i§
                                                   i i i i i *
                         i
 ....§.. {if 1 liHii
                               i, 1111 ^ •
                                    ^
                                             i i i > i i i
                           E-l

-------



••t
MJi
I
§_4
»
i!


.
i f -
E * ft
• -
t •
1 .. i
if ii i
E I Bl *
B* i S
§i *fc
r I
I
i
§
§
!
i^
f §
Is i
i
1




C ff E
£ I
I O
? r
I

i *
i
i



§
*
I ,
r E
" ?S
i
e
6

I
9
i

i
*
t
I
|
i
*
i
j













i

t c
6 , , ,K 	

^ _,
. , , , 8 	 8 , , , ,
«f 5 ' ' ' '

.,,,8, ,,,•", ,8 I
fi sf £




1 ' ' • • • • • • « • I I | i • i





	 • 	 «


•» Me*



I
i

•4.

-------
   i
               « • • »
          , .  , • .  • •
                                               t I I I I I I I  I I I

                       "
                                  IE

                                                       , , I , .
   ilil
                                      ' * ii  «otw«n*w ^ft»****"*3R**8
I1
         E
      ii
           ,1/E,I,
                                           I I I I I I
	i- •fi'l'i'll
	I* Ii  i  I  il
                                                ••''''
i i i g '•'•'•' 8

     • . I Hill > •••••

                                                          »*
         It I
           iSSi
                  :**TTll-

                  E-3
               &A •» ^ •» V ^ ^

-------
         i
                          3-5
    e
f
£
           • II
                          • . I
                        I

                        S
   B 2
   c c
   | E

   * 6
      I t
re
I"
               I
                        ./
         • • 5 • • •  • "" • • § i S . ,
           &       sf  sf

Si,
          ,i
     !   III!'
         -
      I Ilif • • • • | ...... g,|
                     »• «;

                     I,"
               - . .
        Illlllllllillililll

-------
                                            •H ^ ^ »» W .
                                            »•»••! U «3 '
   s? ! • • -2 • • •5^S:sn- -g- • -SSSJS-5-3555 •--•"'-»"' '
  lls
      	:::•::• •:• ••::»::•«	5	*''
      	ssisss' ••• • 'SSSSS'S	fi • •;	:<'
         	5:::ss- -s- • tsssss-s	5	:>'
  i
     I  *
  ^ !
    £

    S
                   i3- -5 • •••53333'5-
                              i i i • > ' ^
                                     ijitii"*'11^11

         . . .> > •
                 :•;: • -s- • •-.
             . «.l »« «»    «;
               !RS , R~ . R| • • • E
K  K • K
«..*«.«
                                      .
           "i - * » 5  • '
           «* ••< £  "
                                               C
                                              ,f , ,
i
I1
II
I!
         i i < i i —
               ,6s! .8 , • •
               33   • •
                                               5
                                               ft

                          !li?l  I ""  "1* "* ""I*
          •••!•••!!?!!!•    ••Mm'HSlHIHIHHp-

          . . .1. . .B»SII

-------
9.-a

qf'fifnffflffff
'? '•'{"*

1 1 1 «• 1 * 1 1 * 4 1 A t i i
21 • • • ^ i «» t i i
!» «o « o
. . . 2. ||. . , . |, 1 , , .


• • • i • n • • • • ••••><

• * ' 9 ' 9 • * * ' '•*•( • »

III 	 1 1 1 1 1 1 1 1 ,
.3 P jl
1 ' 1 ' § ' ' • • • t « • i i ,
r* r* r* ' r*

/• .a
1 * i • • > 	 9111,
•• r-

_
	 "a • • • a
3 3
1












1

• • • £ • 22 • • • • 2 • 2 • • •

>
i 1
ji



a
|

a
I
I
I
1
V
i
1

i

i
i


i
a




S
i
|
"




ii




,


j
j
a
i
1
1




3

—


-


o
5
* i
a
1
g
i
a
5




3
i



i
j







a|
i|
a
|
J
11 !j
ii |I
11 |
3
• *
Si 1
1
i

I *
X fl
• ^r



»-








-------
                 's' 'S	M's1 3'***     .
,,§....,,.,,§....-1--iii-••-i-i-l-i-ill1 i111"  \\\
      	|	Hi- •  • •i'i'i-i'ili'l' •!• •
. . 2 ,
                   111''§§111'
                   	§•isi
                                                1,
                                                  1 i a
                                                  -!i
                                                    a
                                                I
                                                m
                                                a

                                                    33
 i i ^ iiiiit**'***     •« 3 9 
   S                 rtj 9 9 O 9 O •*
   I                 "'	"

             "a « • ' K ' ' •
             9 o   *
    1*1*11*
                       11
                                                       S!
                                                       a .*
                                                         i
                                                         31
                                             IIB
                                                 • i
                                                  :  i -a •-•
                                                    li!
                               .*, ^ .!•••*•*• 2 • • 2 •
                             C- i-S- S- i2S- S- • S' '
    -•••-

-------






•- «M
«rf


§*
[
fi
i


t
i ft -
E e |u
«i w
S
c
I r -
t w i i
El II !
tr| 5 £ i
Ii !«
if §
r
i
i
i
if
c *
t k
K •—
E ^
i §







i
i




E
1



1
1
i
i
E








£
f
i
e








_


I

i


i






S f
is


1
1

g


g
Bf
I



6
5
*

t;
|
e

I
vi
i

i
*

c
e
g

i
i
fe
i
f
s_


1

& !
21

g '......„.;....




—




• . • . I , , , I , , Ii , , , .
E

& 6
ft £



-
i &
1 ' ' ' jf 	 5 * ' ' •
. . . .S , , , .*, ,i,I, ,
fi tf s'





... .5 . . .1 ..••,.,,

( »

*

'•''KiiiBiilBii.i
-
i'>i^iii2i>ii'1
Jg «! rf."
K je »r
1
t

- 1 1 - - k
lfrlflt"t" 11 ff
f * J 5 •— Lt4lf?¥ck^M^ '
Ill!?l5fcll?lcsill
E-8

-------
           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
20*0003023
409000300*
701020*001
7140101014
1030*101030
2030104003
2030104002
2030104001
2030104002
204020203*
2*30101007
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
.0144
.0*30
.0543
.0000
.3080
.51**
.17*0
.3240
.02*0
.14*0
.0002
.1270
.1400
.4220
.3510
.30ft*
.0123
.0075
.0108
.2720
.3000
.0070
.0013
.0048
.7050
.1144
.0070
.003*
.1080
.0109
.0290
.101*
.•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
*.700
50. 000
94.000
91.700
*.200
25.000
10.100
30.100
44.200
19.700
134.000
23.***
35.***
195. •••
37.30*
23.400
-
-
-
-
—
-
-
-
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
-
-
-
-
•
-
-
-
47.02
50.99
0.07
389.29
58.98
971.73
2.94
0.0*
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
2***.*7
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
32*3.48
-
14883.9*
54.09
19.**
1.21
1.7*
•
~
90.23
—
•
*
29.99
33.37
7*2.74
1*399.02
—
*
*
—
*
"
*
"*
• .13
10.19
l.*8
14*. *3
120.33
274.31
17.98
1.48
10.23
8.4*
130.01
2*. 37
93.97
-
3493.38
13.32
3.87
1.39
1.29
*
•
1.18
—
•
~
9.2*
4.93
143.30
1081.03
—
*
*
*
™
*
*
"
1.90
1.5*
1.01
19.57
9.04
11.41
1.07
1.00
1.03
1.38
U.34
4.14
22.32

-------
                                                      000-0S
MVC9M
                                                                                 000'M
cw
Ml*
000'
S60'
oao1
000'
C«I'
4U'
f
El
iM
4*0
000
000'
000'
000'

ozr
WO'
000'
Eor
o
s
SI
JSV

ooo*
000*
000*
000*
042*
                  »
000*0
UO'
•0VSI
             •00 *•
                                I
     IVilU
                  1VAIU
000*
Elf
000* I
000*
4C0-
•IS'%1
Clfl
tit-41
000*0
  CIHTU X
     1VJ1U
                                     EOC*
                                     000*
                                     000*
                                     000*
                                     000*
                                     02S*
000*
ICC*
Z01*
000*
                                    4I2'0
                                    CU*Z
                                    000*0
                                             1*101
                                                  SlUfM M 0
                                                       1V1O1
004-filE
000*
m«
000*
000*
004*
002*
000*
000*



41



00«*E
OOC*C0»I
000*0
000*1%!
OS«r*4Ci
00»'C2









1




%«S*«0ff 21
000*0 0
H01JHUM CiNirU JO 0
IViOi 1U01
                                                                                              A«4*OI
E«0*
ceo-
000*
000*
000*
000*
0»r
zoo-
zoc-
000*

%Z0*
000*
S2I-
US.'
MO*

000*0
                                                                                                   IViOi
                                            1VKU

                                               81
                                               II
                                               •I
                                               £1
                                               »l
                                               Cl
                                               II
                                               II
                                               01
                                               *
                                               0
                                               i
                                               *
                                               S
                                               %
                                               c
                                               2
                                               I
                                           Nicva nonru
                                               s-0-s-n
                                                                                                                                     CM
                                                                                                                                     I
                                                                                        U01
                                                                                          (3003 3IS WU
                                                                        MKV0 inrtM *«*a*s*n tan MIMJ.M
                                                                       toautwu

-------
:  £ t  I I
                          S  S *  1           *  M
 i
 *
 •





 i
 i
 !

 I   5 3  I S  5 53 i  M  M  <  S  M.  M *  <
 «   ---*-52!:!:s«RS5552SS|

I?                                                  S
 BXXXXXXXXXXXXXXXXXXXX
 RMM«««»»*»SSSSSS«SSSS&

 i







 .  i 5  I £  i S I S  5  s  6  I  M  M M &.  s.

    rf «  * s  s s H  i  s  i  i  i
    xxx
            xxxxxxxxxxxxxxxxx
                     F-3

-------
IWC4M
010*1001
MS*C»I
awn
IWtl
aZfi'CI
•IC'CI
awn
4C0*fi
Z4i*n
410
ttrt
Mi* I
8W*1
oac*i
tw*i
Z40*l
ZtO'l
ZIO'I
t*0*l
MTU 01 • ft
/•a
/4I
/ II
/ZI
/ tl
/fil
/M
/CI
/ai
/ u
/OI
/4
/ 1
/ z
/ *
/ fi
/ fr
/c
/ 1
/ 1
- z
CM'CMfr!
0IO*4fiCOI
«*Z*ItZ
filC'MI
ICO'MI
MO'OtI
MC'OII
Wfi*C4
WO'M
IZfi'CC
fill'OC
ISfi*4I
ozc-w
IBi'ZI
MI'OI
0*t'0
Hl-t
8SZ*I
«Z»*I
fiOI'I
H01J
/ 01
/4I
/•I
/ ZI
/«
/ fil
/«
/ CI
/ II
/ II
/ 01
/ 4
/I
/ Z
/ «
/ fi
/*
/ c
/I
/ 1
uvauic aavuAV
2Z*-*«*U / 41
ZZZ'ZIfitl / ZI
40»-CIZfil / N
fi*-»M* / »a
t44*II4« / CI
•M'CSIfi / II
NC*Mfit / 01
48TMK / 41
OM'fioac / zi
«r»jfii / »i
00C24CI / fil
Ctt'CIV / CI
001'Mfi / II
OSC'ZI* / 01
tM'fifil / 4
CCC'CCI / •
filO'M / 9
4irz* / c
8M*%C / C
fi8Z'4 / I
HUSH Nounno nanas
unuzxvu
S4
04
C0
00
fiZ
oz
fit
ot
fifi
OS
fi»
0%
sc
oc
fil
01
fil
01
fi
aiiiNa:
MU3V4 NOUA1IO UV1M1C HUAIlJitt HIM
                     63003 316 MM NOIllMIIUCia
                                   dOVU NO I
              mum NOiinna aamiosio

-------
NXXXXXXX
     XXXXXXXXXXXX
            g
i i i i i i 3 i i i i 5 5 s s § s i i i
xxxxxxxxxxxxxxxxxxxxg S

             l\
             sj

U iiUnnunnii li
             i
             3
32S355555555---*- * - " 2 3
xxxxxxxxxxxxxxxxxxxxrfj




I 1 I i i I i i i P I M ? ? M ? | ?
:•> « k i s j * s 3 ? ? 3 ? 3 2 1 £ * £ i<
3 j i * i i   s i i
Nxxxxxxxxx
      xxxxxxxxxx
 23238??s?s8--.

i i 3 i I 2 S S 'I 535 5 S 2 5 2 2 I I

-------
          I  I   £5  5  £2   2  g  S  ?  5   S  g  2  I  s
          •  -   -  *  *  *  *   *  *  s  s  s   s  5  5  E  s
      1
 r
• *
 j
 J
      5
     ,!
    I
         *  I  X  3   E  S  R  I  2   £  E  &  f  |   §  $   *
         *  5  ±  *'   S  I  I  I  E   2  S  2'  5      §  5
II      I   I  S   5  i  I   S  Is  •  S   II   I  i  I   I  !   I  S
 |S      •"   -  *   2  2  C   2  X   »  ft  i   i  •   J  *  •   ~  g   s  fe
 j                                                          ••  rrPRIVTTNComrr 1993 .7J5 -003^7051

-------

-------

-------