-------
"2* g
«IA CK
!»** ft
j* a-
- o— —
•5~
28
•o
'-I
i
Crt
-------
ATTACHMENT 5-2
TELEPHONE LOGS FOR FOLLOW-UP TO BRS DATA
-------
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
5-2-1 ; . •
TELEPHONE LOG
Buckbee-Mears, Cortland
" 12/9/94 and'12/15/94
, Bill George .
604-753-9615
Daniel Goldberg
Waste Generation and Management
Mr. George said that the facility generates wastewaters from acid cleaning and
photoresist stripping.
These wastes carry RCRA waste codes of D002 and D002 & D007. The wastes
are treated on site, and when, they go to POTW they are considered non-
hazardous wastewater.
The UTS constituents with their end-of-pipe concentrations, in the wastewater are
the following: Phenol [O-.l rag/1]; chromium [.2-.8 mg/1]
The waste streams are aggregated with other waste streams. They are treated by
chromium reduction, pH neutralization, precipitation, and settling.
Mr. George said that one land-based unit is used and it is a concrete clarifier tank.
There are no Subtitle C surface impoundments at the facility. The sludge in the
clarifier tank is not a toxicity characteristic waste and it'.is managed as a hazardous
waste. The contents of the clarifier tank do not leak into surrounding soils. The
concentration of the total volatile organic compounds (VOC) in the wastewaters in
the clarifier tank is 50 ppb maximum. .
Additional/Alternative Treatment
Mr. George did not think that the plant would,re-pipe and/or otherwise modify the
system if the previously discussed wastes were required to be segregated and
treated for underlying UTS constituents. - . ,
He did not know if there are any alternative treatment systems that are available
or will soon be available. ' . .
-------
5-2-2
Waste Discharge Agreement
The facility uses a City Industrial Wastewater Discharge Permit which is attached
to this phone log. Mr. George did not know if the permit uses .indicator or
surrogate chemicals to represent the presence of others or if there are other
pollutants in the wastewater not addressed by the permit
Special Wastes
Mr. George said thai the facility does not generate ash or other waste that is
classified as a "special" waste.
-------
COMPANY NAME:
DATE:
CONTACT NAME: '
TELEPHONE NUMBER:
ICF CONTACT NAME:
5-2-3
TELEPHONE LOG
National Semiconductor Corporation
12/2/94
' . '
Sam Pakdel
408-72175941
i.
Daniel Goldberg
Waste Generation and Management
Mr. Pakdel said that the facility generates corrosive wastewate'rs, both acidic and
caustic, in the process used to etch copper tape. The plating facility generates
reactive wastes (cyanide laden with metals) and corrosive (acidic with metals)
wastewaters. ' .
These wastes carry RCRA waste codes of D002, D003, DOll, F007, and F009.. All
liquid wastes generated at this facility receive full treatment for cyanide,, removal of
metals from solution and pH adjust prior to release to the POTW under terms of
the wastewater permit. The caustic wastewater (D002) is generated and treated at
a typical rate of 200K gallons per day; the acidic rinses (D002) are generated and
treated at a rate of 174 K gallons per day.
Mr. Pakdei stated that the waste contains the following UTS constituents in
varying concentrations: lead, nickel, silver, cyanides. Contaminant concentrations
at the end-of-pipe meet or exceed all discharge requirements for the San
Jose/Santa Clara Water Pollution Control Act, which discharges into South San
Francisco Bay.
The waste streams are segregated at the source and then "grouped" together based
on treatabiiity. These groupings combine streams that are similar in nature and
generation. For example, materials running with a high concentration of copper
cyanide are segregated from materials running high in silver cyanide.
Mr. Pakdel said that all treatment for wastes on site is performed in secondarily
contained process tanks. Tanks used for cyanide oxidation and metal precipitation
are exhausted to scrubbers for emissions control. The sludge generated from this
process is managed through a filter press system. The sludge is sent off site and
managed through a metals recycler for smelting and metals recovery. No land
based units are used for treatment at this facility.
-------
'5-2-4
Additional/Alternative Treatment
•. When asked if the plant would re-pipe and/or otherwise modify the system if the
.previously discussed wastes were required to segregated and treated for underlying
UTS constituents. Mr. Pakdel said that plans for repiping the facility to further
segregate/aggregate similar waste streams are still in the draft process.
• , When asked if there are any alternative treatment systems that are available or will
soon be available, he said that the facility has investigated for both electrolytic
recovery of metals from solution as well as a reverse osmosis system for wastewater
treatment. v . . -
Waste Discharge Agreement
• Mr. Pakdel said that the facility discharges pretreated industrial wastes directly to
the San Jose/Santa Clara Water Pollution Control Plant in compliance with terms
of the wastewater discharge permit.
• The permit regulates the following constituents fj in mg/1 (maximum allowable
concentration): TTO [2.13], cadmium [.69], chromium [1.0], copper [2.7], cyanide
total [1.0], lead [.4], nickel [2.6], silver [.43], zinc [2.6]. Mr. Pakdel said that the
sampling and analysis are performed for the materials, both internally and :
externally, without the use of any surrogate chemicals.
• He said lhat there were no pollutants that are not addressed at all.
Special Wastes ~
* i Mr. Pakdel said that the facility does not generate ash or other waste that is
. • classified as a "special" waste. .
-------
CHAPTERS
INQUIRED TREATMENT CAPACITY FOR THE
ELECTROPLATING/METAL FINISHING INDUSTRY
6.1
INTRODUCTION
This analysis of the required treatment capacity for the electroplating/metal finishing
(E/MF) industry was developed to support today's rule. The following sections are presented:
summary of findings (Section 6.2); background on the E/MF industry (Section 6.3); waste types
potentially subject to today's rule (Section 6.4); available data on wastes generated and managed
at E/MF facilities (Section 6.5); and an analysis of required treatment capacity for the E/MF
industry (Section 6.6).
6.2 SUMMARY
The E/MF industry includes all facilities that conduct any one of the following six types of
core unit operations: electroplating, electroless plating, anodizing, conversion coating, chemical
etching, or printed circuit board manufacturing. A summary of the estimated impact of today's
rule is presented in Exhibit 6-1. •" ,
EXHIBIT 6-1
MAJOR FINDINGS FOR THE ELECTROPLATING/METAL FINISHING INDUSTRY
Discharge
Mode
Direct
Indirect
Zero
Total
Number of
Facilities
50
178
0
228
-
Total Wastewaters
Mixed With ICRT
Wastes (million
tons/yr)*
39
14.7
0
40.4
Facilities
Without
RCRA-
equivalent
Treatment*
2
8
0
10
Facilities
with Land-
based
Units"
!
8
2
.0
10
• •
Affected
Facilities"
Oto 1
0 to 1
0
Oto2
Affected
Wastewater
(million
tons/yr)"
0.78
0 to 0.08
0
Oto 0.86
9 The numbers or quantities in this column were determined on an aggregated basis and apportioned to the
direct, indirect, and zero, dischargers based on the percentage of each discharge mode.
Facilities that conduct one of the six types of core unit operations and are in the seven
industries, covered by the .metal products and machinery (MP&M) Effluent Guidelines Phase I
group are covered under the MP&M category. Facilities that conduct one of the six unit
operations and are in the eight industries covered by the MP&M Effluent Guidelines Phase II
group,are covered under the E/MF category until the MP&M Effluent Guidelines Phase II
-------
' ' ' •' 6-2 . •
rulemaking is promulgated. All other facilities performing these six types of core unit operations
are covered under the E/MF category.-
Since the operations conducted by the MP&M Effluent Guidelines Phase I facilities and
E/MF facilities are similar, EPA assumed that the E/MF facility, wastewaters affected by today's
rule are similar in type (i.e., similar constituents and concentrations) and quantity to those
generated by MP&M Effluent Guidelines Phase I facilities. Hence, the results of the MP&M
Effluent Guidelines Phase I facility data review were extrapolated to the E/MF facilities. Refer to
Chapter 12 for details on the procedures and assumptions used in the analysis for the MP&M
category. Other assumptions used in this analysis are detailed in Section 6.6.
Using the data and assumptions outlined above, EPA developed estimates for affected
E/MF facilities and wastes. However, if an existing rule on effluent limitations guidelines
adequately addresses these priority pollutants, this category may not be significantly affected by
today's rule. ' . -
63 BACKGROUND1
The electroplating/metal finishing (E/MF) industry is addressed in 40 CFR Parts 403, 413,
420, 421, 433, 461, 463; 464, 465r 466, 467, 468, 469, and 471 and is included in the SIC codes 34
through 39. The E/MF category of the effluent limitations guidelines and standards program is
defined by six types of core unit operations performed at a facility; electroplating, electroless
plating, anodizing, conversion coating, chemical etching, and printed circuit board manufacturing.
These unit operations are briefly discussed below: .*
• Electroplating is the electrodeposition of a thin surface coating of one metal upon
.another metal. This process typically includes solvent degreasing, alkaline cleaning,
electrolytic cleaning, acid cleaning, salt bath descaling, electroplating, chromate
conversion coating, phosphate conversion coating, and coloring.
• Electroless Plating is the chemical deposition of a metal coating by immersion in
an appropriate plating solution. This process typically includes alkaline cleaning,
acid etching, vapor blasting (plastic surface preparation), honing, solvent
degreasing, and electroless plating.
s
• Anodizing is an electrochemical process which converts the metal surface to a
coating of an insoluble oxide. This process typically includes solvent degreasing,
alkaline cleaning, alkaline etching, acid treatment, and anodizing.
' * fc
• Coatings include chromating, phosphating, metal coloring, and passivating. This
process typically includes alkaline cleaning, acid cleaning, solvent degreasing, salt
1 Most of this section is summarized from U.S. EPA, 1984 (February), Guidance Manual fen-
Electroplating and Metal Finishing Pretreatment Standards, Effluent Guidelines Division and Permits
Division, Document No. 440/l-84/091g. It is important to note that the processes and data may have
changed since the writing of the guidance document.
-------
6-3
-- bath descaling, polishing, chromate conversion coating, phosphate conversion
coating, coloring, and immersion plating. .
• Etching and Chemical Milling are processes used to produce specific design
configurations or surface appearances on parts by controlled dissolution with
chemical reagents or etchants. This process typically includes solvent degreasing,
alkaline cleaning, electrolytic cleaning, acid cleaning, salt bath descaling, masking,
acid dipping, chemical milling, chemical etching, and bright dipping.
• Printed Circuit Board Manufacturing fPCBM) involves the formation, of a circuit
pattern of conductive metal (usually copper) on non-conductive board materials
such as plastic or glass. The basic steps in the process are:
i • ^
a. Surface preparation - scrubbing, alkaline cleaning, acid cleaning, etchback,
catalyst application, and activation;
b. Electroless plating; ,
c. Pattern plating - acid cleaning, alkaline cleaning, copper plating, and solder
plating; / '
d. Etching - etching and solder brightening; . --'
e. . -Tab plating - solder, stripping, scrubbing, acid cleaning, and nickel, gold, or
. . other plating operations; and ,
\ - •
f. Immersion plating - acid cleaning and immersion tin plating.
i •' ~
Facilities that conduct one of the six types of core unit operations and are in the seven
industries covered by the metal products and machinery (MP&M) Effluent Guidelines Phase I
group are covered under, the MP&M category (see Chapter 12). Facilities that conduct one of
the six types of core unit operations and are in the eight industries covered by the MP&M
Effluent Guidelines Phase n group are covered under the E/MF category until the effluent
guidelines rulemaking for the MP&M Effluent Guidelines Phase n group is promulgated. All .
other facilities performing these six types of core unit operations are covered under the E/MF
category. • .
In addition to the six types of core unit operations, the E/MF category includes 40 more
associated unit operations. However, if a facility does not conduct any of the six types of core
unit operations, then the facility is not included in this category. These 46 unit operations are
presented in Section 6.4. , . , ,
.The E/MF facilities vary greatly in size, age, number of employees, and number and type .
of operations performed. They range from very small job shops with less than 10 employees to
large facilities employing thousands of production workers. Because of the differences in sizes
and processes, production facilities are custom-tailored to the specific needs of each individual'
plant The possible variations of unit operations within the industry are extensive. Some products
-------
• . , :• .6-4 .: .
could require the use of nearly all of the 6 core and 40 associated unit operations, while a simple
product might require only a single operation.
Facilities in the E/MF industry are either "captive" facilities (those that in a calendar year
own more than 50 percent [area basis] of the materials undergoing metal finishing); or "job shops"
(those that in a calendar year do not own more than 50 percent [area basis] of material
undergoing metal finishing). Job shops usually perform very few operations compared to the
captive facilities which often have a complex range of operations.
Captive facilities can be further divided by two definitions: "integrated" plants; which prior
to treatment combine electroplating waste streams with significant process waste, streams not
covered by the electroplating category^and "non-integrated" facilities, which have significant
wastewater discharges only from operations covered by the electroplating category. Over 50
percent of the captive facilities are "integrated" facilities. In theory, the job shops can be further
divided like the captive facilities; however, approximately 97 percent of all job shops hi this
industry are "non-integrated" facilities.2
Many different raw materials are used by the E/MF facilities. Basis materials are almost
exclusively metals,' which range from common copper and steel to extremely expensive high grade
alloys and precious metals. The solutions utilized in the various unit operations can contain
acids, bases, cyanides, metals, complexing agents, organic additives, oils, and detergents. All of
these raw materials can potentially enter wastewater streams during the production sequence.
6.4 WASTE TYPES POTENTIALLY AFFECTED BY TODAY'S RULE
The wastewaters generated by the E/MF industry contain several organic and metal -
pollutants.. The wastewater characteristics and pollutant loadings vary with the 'unit operations
generating the wastewaters. The various unit operations conducted in the MP&M facilities and
their,standard water usage are given in Exhibit 6-2.
'. Water usage within the E/MF categories are variable. Typically, the E/MF core unit
operations generate significant quantities of wastewaters. Of these, the plating and cleaning
operations are typically the biggest water users. While the majority of metal finishing operations
use water, some of them are completely dry. The type of rinsing utilized can have a marked
effect on water usage as can the flow rates within the particular rinse types. Product quality
requirements often dictate the amount of rinsing needed for specific parts. Parts requiring exten-
sive surface preparation will generally necessitate the use of larger amounts of water.
2 U.S. EPA, 1984 (February), op. tit.
-------
6-5
EXHIBIT 6-2
UNIT OPERATIONS IN E/MF FACILITIES3
Unit Operation
Electroplating13
Electroless Platingb
Anodizing13
Conversion Coating13
Etching (Chemical Milling)13
Printed Circuit Board Manufacturing1*
Cleaning .
Machining
Grinding
Polishing
Tumbling (Barrel Finishing)
Burnishing
Impact Deformation
Pressure Deformation
Shearing !
Heat Treating
Thermal Cutting
Welding
Brazing
Soldering .
Rame Spraying
Sand Blasting
Other Abrasive Jet Machining
Elec. Discharge Machining
Electrochemical Machining
Electron Beam Machining
Laser Beam Machining
Major Water
Usage
X
X
x N
X
X
X
X , '.
x
X
X
X
X
-
X
. ,
\
Minimal
Water Usage,
,
X
X
X
X
X
x
'
X
• i x
X
X
X
x
Zero
Discharge
•"
-
i
-
.
,
\ -
X
X
-------
6-6
EXHIBIT 6-2 _ /
UNIT OPERATIONS IN E/MF FACILITIES8 (continued)
Unit Operation
Plasma Arc Machining.
Ultrasonic Machining ,
Sintering
Laminating
.Hot Dip Coating
Sputtering
Vapor Plating
Thermal Infusion
Salt Bath Descaling
Solvent Degreasing
Paint Stripping
Painting
Electrostatic Painting
Electropainting
Vacuum Metalizing
Assembly ,
Calibration
Testing
Mechanical Plating
Major Water
Usage
X
X
X
X
X
X
X
Minimal
Water Usage
X
X
.
,
X
x
Zero
Discharge
X
X
X
x
X
X
.
'
X
X
3 U.S. EPA, 1987 (October 19), Estimates of Waste Generation by the Fabricated Metal Products
Industry (SIC 34), the Industry and Commercial Machinery and Computer Equipment Industry (SIC
35), the Electronic and Other Electrical Equipment and Components Industry (SIC 36), and the
Transportation Equipment Industry (SIC 37, except 371), Draft Report, Office of Solid Waste,
prepared by Midwest Research Institute (MRI). It is important to note that the processes and
data may bave changed since the writing of the document. ' ' • "
b Core unit operation.
-------
6-7 ' •
The specific pollutants typically generated by the different unit operations of the E/MF
facilities are given in Exhibit 6-3. The typical pollutants used and generated by the six types of
core unit operations include: , • • - ,
• Electroplating: The electroplating baths contain metal salts, alkalies, and other
bath control compounds in addition to plating metals such as copper, nickel, silver,
and lead. Many plating solutions contain metallic, metallo-organic, and organic
additives to induce grain refining, leveling of the plating surface, and brightening
.of the deposits. . " - .
• - Electroless Plating: Immersion plating baths are usually formulations of metal salts,
- alkalies, and complexing agents (typically cyanide or ammonia).
• Anodizing: Anodizing wastewater typically contains the basis material and either
chromic or sulfuric acid. When dyeing of anodized coatings occurs, the wastewater
will contain chromium or other metals from the dye. Other potential pollutants
include nickel acetate (used to seal anodic coatings) and other complexes and
metals from dyes and sealers.
\
• Coatings: Pollutants associated with these processes enter the wastewater through
rinsing and batch-dumping of process baths. The process baths usually contain
metal salts, acids, bases, and dissolved basis materials.
\
• Etching and Chemical Milling: The major waste stream constituents are the
dissolved'basis materials and etching solutions.
• Printed Circuit Board Manufacturing (PCBM>: Wastewaters are generated from
rinses after the various steps in the process. Additionally, water may be used for
subsidiary purposes such as rinsing away spills, air scrubbing water, equipment
washing, and dumping spent process solutions. The principal constituents of the /
waste streams from the printed circuit board industry are suspended solids, copper,
fluorides, phosphorus, tin, palladium, and chelating agents. Low pH values are
, characteristic of the wastes because of the necessary acid cleaning and surface
pretreatment ' : • :
-------
6-8,
EXHIBIT 6-3
TYPICAL POLLUTANTS GENERATED BY THE E/MF UNIT OPERATIONS8
Operations
Electroplating1"
Electroless Platingb
Anodizing*3
Conversion Coatingb
.Etching (Chemical Milling)b
Printed Circuit Board
Manufacturingb
Cleaning
Machining .
Grinding .
Polishing
Barrel Finishing (Tumbling)
Burnishing
Impact Deformation
Pressure Deformation
Shearing
Heat Treating
Thermal Cutting
Welding
Brazing
Soldering
•Flame Spraying
Sand Blasting
Other Abrasive Jet Machining
Electric Discharge Machining
Electrochemical Machining
Electron Beam Machining
Laser Beam Machining '
Plasma Arc Machining
Ultrasonic Machining
Metals
X
X
X
X
X
,- *
X
X
X
X
X
X
X
- X
X
X
X
X
X
X
X
1
X
x"
, X.
X
•
Hexavalent
Chromium
• X
X
X
X
X
X
X
J
Cyanide
X
X
X
X "
X
X
X
X
.
Oils
X
. X
X
X
X
X
X
X
X
X
X
Toxic
Organics
X
X
X-
•i
X
X
X
X
•
X
Zero
Discharge
X
X
' X
X
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6-9
EXHIBIT 6-3
TYPICAL POLLUTANTS GENERATED BY THE E/MF UNIT OPERATIONS* (continued)
Operations
Sintering
Laminating • . • -
Hot Dip Coating
Sputtering
Vapor Plating
Thermal Infusion
Salt Bath Descaling
Solvent Degreasing
Paint Stripping
Painting
Electrostatic Painting
Electropainting
Vacuum Metalizing
Assembly
Calibration
Testing
Mechanical Plating .
Metals
X
X
-
X
X
X
X
X
X
X .
'X
Hexavalent
Chromium
.
X
X
Cyanide
-
Oils
X
X
X
X
X
Toxic
Organics
X
X.
x -
X
X
X
Zero
Discharge
X
..
x •
X
X
'
X
X
.
a U.S. EPA, 1984 (February), op. cit.
b Core unit operation. - _ • ' • .
The direct and indirect dischargers of the E/MF industry are given .in Exhibit 6-4. The
total number of facilities identified in the source for this exhibit was 13,470 facilities. The
numbers of facilities presented in the source were proportionately scaled down to obtain a total of
228 facilities that are covered in the E/MF category for the analysis of today's rule.
-------
' 6-10 ^ ,
EXHIBIT 6-4
DIRECT AND INDIRECT DISCHARGERS OF THE E/MF INDUSTRY"
Type of
Discharge
Indirect
Direct
Job shops
and D?CBMb
52
8
Captive Facilities
Non-integrated
63
Integrated
63
,42
Totals
178
50
8 U.S. EPA, 1984 (February), op. cit.
b Independent printed circuit board manufacturers.
Exhibit 6-5 presents a schematic of a typical in-line treatment train at E/MF facilities.
Exhibit 6-6 presents a schematic of a typical end-of-pipe wastewater treatment train at E/MF
facilities. The various treatment technologies used for treating wastewaters generated by the
E/MF unit operations include: x
Treatment of common metal waste: This consists of hydroxide precipitation followed by
sedimentation. . • .
,• Treatment of complexed metal wastes: Complexed metals are bound by chemicals
(completing agents such as ammonia and citric acid) which prevent the metals from
settling out of solution. '
Treatment of precious metal wastes: This consists of the technology basis for common
metal wastes with precious metal recovery including evaporation, ion exchange, and
electrolytic recovery.
; " .
i
Treatment of hexavalent chromium: This involves reducing hexavalent chromium to
trivalent chromium and the removal of the chromium with a conventional precipitation-
solids-removal system. :
Treatment of cyanide wastes: This is almost exclusively performed by alkaline chlorination
which oxidizes the cyanide.
Treatment of oily wastes: Techniques commonly used by electroplaters and metal finishers
to remove oils include skimming, coalescing, emulsion breaking,'flotation, centrifugation,
ultrafiltration, and reverse osmosis.
'•• i . . • ' ' '
In-plant control of toxic organics: The primary control technology for toxic organics is
proper storage of concentrated toxic organics without discharging directly into waste.
streams and segregation from other wastes that will enter the waste treatment system.
-------
6-11
-------
00
6-12
I
u
1
I
e.
O
3
X Z
fid W
a
I
I
S
o
d
1
•c
l
-------
,..'•' • 6-13 - •..-'.
The effluent limitations guidelines and standards for the E/MF facilities address total
suspended solids (TSS), oil and grease, cyanides, pH, and several metals, including cadmium,
chromium, copper, lead, nickel, silver, and zinc. The effluent guidelines only address total toxic
organics as one parameter instead of addressing each toxic organic separately. This is because of
(1) variability in the types and concentrations of toxic organics found in the raw wastewaters and
(2) overall low concentrations of toxic organics found in the wastewaters. At the time the
development documents detailing the effluent limitations guidelines were compiled (August 1979
and June 1983), the other toxic pollutants measured in the wastewaters were not addressed due to
the following reasons: (1) toxic pollutants were not detectable with the use of analytical methods
approved pursuant to section 304(h) of the CWA, (2) toxic pollutants were detected at only a
small number of sources within a category and were uniquely related to the source, or (3) toxic
pollutants were detected in treated effluents in trace amounts and were expected to neither cause
nor be likely to cause toxic effects. , .
L
The E/MF category has'been included under the effluent guidelines program because
many of the facilities identified in the category use processes that generate large quantities of
corrosive wastewaters. .The available data indicate that over 40 percent .of the wastewaters are
strong acids or alkaline wastes and that another 45 percent of the wastewaters contain, spent
plating wastes.3 These wastewaters include both acidic and alkaline streams and include both
concentrated solutions (i.e., process baths) and rinsewaters. Common practice in E/MF industry is
to collect acidic wastewaters in one tank and alkaline wastewaters in a separate tank. The
wastewaters are then used for pH adjustments and to precipitate metals. Most wastewaters
appear to be in tanks rather than in land-based units (i.e., surface impoundments).4 The
following sections address these wastes in more detail, including the degree to which they may
ultimately be affected by today's rule. .
6.5 AVAILABLE DATA
Several data sources were used for obtaining information on the generation and
management of the wastes generated by the E/MF industry. A description of the data sources is
} given in Chapter 3 of the main text of the background document. The applicable information
obtained from these data sources is provided in the sections below.
6.5.1 Effluent Guidelines Development Document . .
\ . • ..
. This section presents the information in the effluent guidelines development document for
the electroplating and metal finishing industries as applicable to this analysis.
3 U.S. EPA, 1986 (February), Report to Congress on the Discharge of Hazardous Wastes to PubKcfy
Owned Treatment Works, Office of Water. It is important to note that the! processes and data may have
changed since the writing of the document. . v
4 U.S. EPA,. 1989 (October), Preliminary Data Summary for the Machinery Manufacturing and
Rebuilding Industry, Office of Water, Document No. 440/1-89/106. It is important to note that processes
and data may have changed since the writing of the document. , , '
-------
6-14
6.5.1.1 Effluent Guidelines Development Document for the Electroplating Industry
The development document for the effluent limitations guidelines for the electroplating
industry5 covered the approximately 13,000 facilities with metal plating operations that were
operating at the time of the compilation of the document The document only presented waste
characterization data on the priority pollutants that were reviewed for regulation under the
effluent guidelines. The document did not present any data on the other priority and non-priority
pollutants that may be present in the wastewaters. Exhibit 6-7 presents the maximum observed
. concentrations of pollutants in raw wastewaters from the six types of core unit operations. This
exhibit indicates that all of the six types of core unit operations generate raw wastewaters with
constituents above UTS. However, these concentrations are at the points of generation, and the
effluent concentrations are typically much lower due to dilution and wastewater treatment.
6.5.1.2 Effluent Guidelines Development Document for the Metal Finishing Industry
The development document for the effluent limitations guidelines for the metal finishing
industry6 covered the approximately 13,500 facilities that were operating and using the 46 types
of electroplating/metal finishing unit operations at the time of the compilation of the document
The document presented waste characterization data on priority pollutants; however, it did not
present any data on the non-priority pollutants. The document reported that the sampled
facilities indicated a range of zero to 13.5 mg/1 of total toxic organics in the raw wastewaters.
Exhibit 6-8 presents the maximum observed influent (to the wastewater treatment systems) and
effluent concentrations of the regulated pollutants in raw wastewaters from the sampled metal
finishing facilities. ~ •
6.5.2 POTW Report to Congress (RTC)
The RTC7 evaluated the types, sources, and quantities of hazardous wastewaters that are
discharged to POTWs. The report indicated that there were a total of 13,502 facilities that '.'
conducted metal plating operations, of which 2,941 facilities were .direct dischargers, 10,561
facilities were indirect dischargers, and there were no zero dischargers. (This agrees with the
numbers presented by the guidance manual on the electroplating and. metal finishing industry.8)
The primary shortcomings of this report for the purposes of this analysis are that it concentrates
.on total mass loadings instead of concentrations and.does not provide any data on the use of
land-based units.
The'total indirect discharge flow indicated by the POTW report is 874 million torts per
year. The POTW report also indicated that over 40 percent of the wastewaters were strong acids
5 U.S. EPA, 1979 (August), Development Document far the Existing Source Pretreatment Standards for
the Electroplating Point Source Category, Final, Effluent Guidelines Division, Document No. 440/1-79/003.
6 U.S. EPA, 1983 (June), op. ciL
7 U.S. EPA, 1986 (February), op. tit ' •
8 U.S. EPA, 1984 (February), op. tit
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6-15
EXHIBIT 6-7
MAXIMUM POLLUTANT CONCENTRATIONS (mg/1) IN RAW WASTEWATERS FROM THE
SIX TYPES OF CORE UNIT OPERATIONS8
Pollutant
Parameter
Copper
Nickel
Chromium
Zinc
Cyanide
Fluoride
Cadmium
Lead
Iron
Tin
Phosphorus
Silver
Gold
Palladium
Platinum
Rhodium
UTS
Level
(mg/1)
—
3.98
2.77
2.61
1.2
35
0.69
0.69
—
; —
-'- '"
0.43
—
'--
—
• -
Common
Metal
Electroplating
272.5
2,954
525.9
252
150
141 •
21.6
25.39
1,482 '
103.4
. 144
,
',
- .-
Precious
Metals
Electroplating
9.97
' -
114
176.4
24.089
, 0.625
6.457
0.034
Electroless
Plating
47.9
46.8
.-
12
18
90 .
109
-'
Anodizing
79.2
78
33.
-
Coatings
79.2
200,
126
168
6.569
53.3
Chemical
Milling &
Etching
• 272.5
(
525.9
200
126
141.7
263
6.569
144
Printed
Circuit
Boards
,535.7
13.3
47.8
•
10.8
680
10.2
54
53.6
0.48
0.11
0.23
'
U.S. 1PA, 1979 (August), op. at
or alkaline wastes and that another 45 percent of the wastewaters contained spent plating wastes.
The POTW report presented data on wastewater characteristics that indicated the presence of
several constituents above the UTS levek set by the Phase n LDRs. Exhibit 6-9 presents the
typical characteristics of wastewaters discharged to POTWs from E/MF facilities.
6.53 Biennial Reporting System (BRS)
' 's . )
EPA has reviewed the 1991 BRS data and did not find any applicable information for this
analysis, since the information provided in the BRS does not permit for the identification of data
that are applicable to the electroplating/metal finishing operations.
-------
6-16
EXHIBIT 6-8
MAXIMUM POLLUTANT CONCENTRATIONS IN THE RAW WASTEWATERS AND
EFFLUENTS AT METAL FINISHING FACILITIES8
Pollutant Parameter
Cadmium
Chromium
Copper
Lead
Nickel
Zinc
Silver
Total Toxic Organics
UTS Level
(mg/1)
0.69
2.77
, .
, 0.69
3.98
2.61
0.43
. • —
Maximum Raw Waste
Concentration (mg/1)
1.88*
393*
108 . x
9.7*
" 167*
175* ,
0.29
13.5
Maximum Effluent
Concentration (mg/1)
0.018
- - 2.36 ;
4.47
0.165
7.3* -
3.12*
0.167 -
0.823
U.S. EPA, 1983 (June), op. tit.
Concentration exceeds UTS.
EXHIBIT 6-9
MAXIMUM CONCENTRATIONS OF POLLUTANTS IN WASTEWATERS
DISCHARGED TO POTWsa
Constituent
1,1,1-Trichloroethane*
1,1,2,2,-Tetrachloroethane
1,1-DichJoroethane*
1,1-DichIoroethene* '
1,2-Dichlorobenzene*
1,2-Dichloroethane*
1,3-Dichlorobenzene* '
1,4-DichJorobeazene
Discharge to POTW Maximum
Concentration (mg/1)
11.8
0.028
1.583
0.081
0.294
3.7
0.0512
0.0756
UTS Concentration (mg/1)
0.054
0.057 '.
0.059
0.025
0.088
0.21
0.038
0.09
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6-17
EXHIBIT 6-9
MAXIMUM CONCENTRATIONS OF POLLUTANTS IN WASTEWATERS
DISCHARGED TO POTWs* (continued)
Constituent
2,4-Dimethylphenol*
Acetone*
Acrolein . ,
Antimony
Arsenic
Barium
Benzene '
Bis(2-ethylhexyl) phthalate"
Butyl benzyl phthalate*
Gidmium*
Girbon tetrachloride
Clilorobenzene
Chloroform*
Chromium*
Cyanide"
Di-n-octyl phthalate'
Dimethyl phthalate*
Ethyl benzene*
Uad*
Mercury
Methylene chloride*
Naphthalene*
Nickel*
Phenol* X '
Selenium
f
Silver*
Tetrachloroethylene*
Toluene* " '
Discharge to POTW Maximum
Concentration (mg/1)
390
' . , 1.855
0.01
0.089
0.48
0.0548
0.045
- 0.9337
0.067
21.003
0.013 .
01007
0.0823
600
136.
0.188
0-083
46
100
.,. ' . 0.1019.
•1.087
7.7
338.4
7500
0.115 .
0.8 ^ '
0.805
240
UTS Concentration (mg/1)
0.036
6.28
.0.29
1.9
1.4
•1.2 '
0.14
0.28
0.017
0.69
0.057
0.057 '
0.046
2.77
/
1.2.'
0.017
,0.047 .
0.057
0.69
0.15
0.089
0.059
3.98
, 0.039
0.82
0.43
0.056
0.08
-------
f
6-18
EXHIBIT 6-9
MAXIMUM CONCENTRATIONS OF POLLUTANTS IN WASTEWATERS
DISCHARGED TO POTWs3 (continued)
Constituent .
trans-l,2-Dichloroethene
Trichloroethene*
Zinc* ;
Discharge to POTW Maximum
Concentration (mg/1) '
0.009
1.062
65.1
UTS Concentration (mg/1)
0.054.
0.054
2.61
4 US- EPA, op. tit
Concentration exceeds UTS:
6.5.4 Toxic Release Inventory .(TRI)
EPA has reviewed the TRI data and did not Gnd any applicable information for this
analysis. _ . ' .
6.5.5 Permit Compliance System (PCS)
EPA has reviewed the PCS data and did not find any applicable information for this
analysis, since this data source keys off the SIC codes which do not permit the identification of
data that are applicable to the electroplating/metal finishing operations.
6.5.6 Industrial Subtitle D Screening Survey
EPA has reviewed the Industrial Subtitle D Screening Survey data and did not find any
applicable information for this analysis, since this data source keys off the SIC codes which do not
permit the identification of data that are applicable to the electroplating/metal finishing
operations. - .
6.5.7 Industry Studies Data Base (ISDB)
EPA has reviewed the ISDB and did not find any applicable information for this analysis.
6.5.8 Industry Contacts
Electroplating/metal finishing operations are an integral part of large metal products and
machinery industries. It is difficult to discern specific information on the electroplating/metal
finishing operations. However, the information provided in Chapter 12, also applies to
electroplating/metal finishing, since these are the operations that generate the bulk of the
wastewaters at the metal product and machinery industries. Please refer to Chapter 12 for
specific information on these industry contacts.
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6-19
6.5.9 Comments to Previous Rules .
EPA reviewed industry comments on related rules, such as the Phase n Rule, the
Emergency Rule, and the Notice of Data Availability for information regarding the management
of wastes at MP&M facilities. However, EPA did not find any data that would support this
analysis. .
6.5.10 Data Collected for the Effluent Limitations Program ,
In order to better characterize the E/MF industry and its wastewaters for the effluent
guidelines limitations, EPA has conducted several data collection efforts. However, EPA has not
yet analyzed these data sources. .These data collection efforts are briefly described below:
v '
Questionnaires
Three types of data collection portfolios (DCP) (i.e., a detailed questionnaire) were sent
to a large number of manufacturing facilities 'in the metal finishing industry. The first DCP was
utilized during the Machinery and Metal Products Industries study. Data were obtained from 339
production facilities that were selected from a group of 1,422. Requested information included
general plant data, principal raw materials consumed, specific production processes employed,
composition of effluent streams, -and wastewater treatment in use.
The second DCP was used during the Mechanical and Electrical Products study. This ' <
- DCP was sent to 900 facilities selected from approximately 160,000 manufacturers. This DCP
requested information on general plant characteristics, unit operations-performed, data relating to
•specific plating operations, wastewater treatment facilities, and the contract hauling of wastes.
i '
The third DCP was1 used during the Electroplating Industry study. The DCP was sent to
• 1,833 companies believed to operate plating facilities selected randomly from the approximately
13,000 facilities that perform plating. A total of 419 companies (1,190 responses) provided usable
information. This DCP requested information regarding general plant characteristics, production
history, manufacturing processes, process and waste treatment, wastewater characteristics,
treatment costs, and economic analysis data. ' . -
SamplingJProgram , .
i s
A total of 322 manufacturing facilities were visited during the sampling program. The
facilities were selected based on the characteristics of their effluent, the physical layout (i.e., if it
facilitates sampling), the use of waste treatment, and whether the facility is an indirect or direct
discharger. The sampling episode focused on both the production and treatment operations. *
,. 6.5.11 Other Data Sources .
The guidance manual9 details the Categorical Pretreatment Standards for the •
electroplating and metal finishing industry. The guidance manual was developed to provide
U.S. EPA, 1984 (February), op. cit
-------
6-20 . . .
" guidance to POTWs on the application and enforcement of these pretreatment standards. The
guidance manual covered the 13,470 facilities conducting metal plating operations that were
operating at the time of the compilation of the document The document only presented
summary statistics for the E/MF industry and concentrated on presenting the effluent limitations
guidelines and standards for this industry. The document did not present any waste
characterization data. The document estimated that 78 percent of the E/MF facilities are indirect
dischargers, 22 percent are direct dischargers, and none are zero dischargers.
6.6 . REQUIRED CAPACITY ANALYSIS
This section presents an estimate of the number of facilities and quantity of wastewater
affected by today's rule. The estimates provided in the POTW Report to Congress on the
number of direct, indirect, and zero dischargers were proportionately scaled down to obtain a
total of 228 facilities that are covered in the E/MF category for the analysis of today's rule.
Similarly, the estimate for the total wastewater flow~at indirect dischargers was scaled down to
obtain a total of 14.7 millions tons per year. .All other estimates were obtained from the analysis
done for the MP&M industry.
Since the operations conducted by the MP&M Effluent Guidelines Phase I facilities and
E/MF facilities are similar, EPA-assumed that the.E/MF facility wastewaters affected by today's
rule are similar in type (i.e., similar constituents and concentrations) and quantity to. those
generated by MP&M Effluent Guidelines Phase I facilities. Hence, the results of the MP&M
, Effluent Guidelines Phase I facility data review were extrapolated to the E/MF facilities. Chapter
12 on the MP&M industry provides details on the data sources used and the procedures and
assumptions used in the analysis for the MP&M category.
The queries and assumptions used to estimate the number of affected facilities and
wastewater volumes in the E/MF industry are described below:
• Exclude from the scope of the E/MF analysis all MP&M Effluent Guidelines
Phase I facilities that conduct one of the six types of core E/MF unit operations.
Query the MP&M database to determine the number of facilities that reported at
least one of the six types of core E/MF unit operations.
• Exclude from the scope of the E/MF analysis all MP&M Effluent Guidelines
Phase II facilities that conduct one of the six types of core E/MF unit operations.
Assumption: Because Effluent Guidelines Phase I and Phase n of MP&M are
expected at this time to be very similar, this analysis assumes that the same
percentage of faculties removed from E/MF due to MP&M Effluent Guidelines
Phase I will be removed as'a result of MP&M Effluent Guidelines Phase D.
*. Estimate the number of facilities with land disposal units and the number of
; facilities that have constituents with end-of-pipe concentrations above the UTS •
levels. Assumption: The wastewaters generated by the MP&M and E/MF
industries are very similar in type (i.e., constituents and concentrations above UTS)
and quantity, as illustrated by the significant overlap in operations covered by each .
category. Consequently, EPA applied the same percentage of facilities in MP&M
-------
6-21
Effluent Guidelines Phase I group, that are affected by today's rule to the facilities
in the E/MF category. Refer to Section 4.3.12 for details on the procedures and
assumptions used in the analysis for the MP&M category.
Using the data and assumptions mentioned above, EPA found that (1) only 228 facilities
'of the approximately 13,500, facilities conducting metal plating operations are covered by this
category (the other facilities are covered by the MP&M category) and (2) several facilities have
priority pollutants at concentrations higher than the UTS levels set by the Phase II LDRs. None
of the facilities appear to have any non-priority pollutants with end-of-pipe concentrations being
above the UTS levels set by the Phase II LDR rule.
Based on the results of the analysis for the MP&M industry, EPA estimates that up to 9
E/MF facilities are using land-based units for managing or treating their wastewaters. EPA
estimates that the maximum number of facilities and wastewater volume that may be affected by
.today's rule are 2 facilities and 0.86 million tons of wastewater per year. However, if the existing
rule on effluent limitations guidelines adequately addresses the priority pollutants that were found
to exceed their UTS levels, this category may not be affected by today's rule.
-------
-------
CHAPTER 7
REQUIRED TREATMENT CAPACITY FOR FEDERAL FACILITIES
7.1 INTRODUCTION .
This analysis of the1 required treatment capacity for federal facilities was developed to '
support today's rule. Note, however, that because federal facilities generate wastes using
essentially the same industrial processes as private industry, and because these wastes are reported
by the facilities according to those industrial processes, these federal facilities are already included
within the analyses of the other industries. Therefore, this chapter only provides rough estimates
, of the number of federal facilities and the quantity of waste that will require alternative
treatment. Furthermore, these estimates have not been added to the total number of facilities
and quantity of waste requiring alternative treatment that are calculated in Chapter lsof this
appendix. • -, . " .
The following sections are presented: summary of findings (Section 7.2); background on
federal facilities (Section 7.3); waste types potentially subject to today's rule (Section 7.4);
available data on wastes generated and managed at federal facilities (Section 7.5); and an analysis
. of required treatment capacity for federal facilities (Section 7.6).
' '. ' - - ' ' ' '
7.2 ' SUMMARY ' . • •
Several industrial processes — including electric power generation, electrical and
electronics components, electroplating and metal finishing, industrial laundries, metal products and
machinery, and transportation equipment cleaning — are conducted at the approximately 941
federal facilities in the U.S. According to an analysis based on the 1992 Inventory of Federal
Agency Hazardous Waste Activities1 (also called the Federal Facility Inventory), from 2 to 69
federal facilities may require alternative treatment due to today's rule. Assuming federal facilities
generate approximately the same quantities of wastewater as the industries to which they are most
closely associated, affected wastes could range from 32 million to 1.1 billion tons/year. Note,
however, that because federal facilities report wastes according to the industrial processes used, .
federal facilities are already included within the analyses of the other industries. Therefore, these
estimates have not been added to the total number of facilities and the quantity .of wastes
requiring alternative treatment that are calculated in Chapter 1 of this appendix.
13 BACKGROUND
Federal facilities include all operations and facilities owned or managed by the .U.S.
federal government. These facilities cover a wide range of services and processes, including
electric power generation, electrical'and electronics components, electroplating .and metal
finishing, industrial laundries, metal products and machinery, and transportation equipment
cleaning. Within the SIC code system, however, federal facilities are classified according to the
1 U:S. EPA, 1993, Inventory of Federal Agency'Hazardous Waste Activities: 1992 Report,
Office of Solid Waste. . . ' •' - ' , /
-------
• '.7-2 • '; '
operation of the facility and thus dp not have a separate code designating them, as federal
facilities. For example, a steam-electric plant that is operated by the federal government is
classified under SIC 4911, the same SIC code as a privately-owned facility. Therefore, see
Chapters 4, 5, 6,9,12, and 17 for additional background on the industrial processes used at
federal-facilities. " , ,
7.4 WASTE TYPES POTENTIALLY AFFECTED BY TODAY'S RULE
As indicated above, federal facilities are classified according to the SIC code for the
industrial process used at the facility. EPA believes, therefore, that the wastes generated by
federal facilities are similar to the wastes generated by the most closely matched industry. Thus,
Chapters 4, 5, 6, 9, 12, and 17 provide additional detail, on waste types generated by federal
facilities. . ,
7.5 AVAILABLE DATA " ,
Several data sources were used for obtaining information on
-------
• . ' 7-3 .. ' ' . ' .
7.5.1 Types of Units Specified by the Federal Facility Inventory
\ * • • •
The Inventory contains information on three types of land-based units that could be used
in managing such wastewaters:
Surface impoundments (Sis);
Land treatment units (LTUs); and
Underground injection wells (UIWs).
For each federal site, the 1992 Inventory identifies the number of Sis, LTUs and UIWs that have
been classified as (1) hazardous waste management units (HWMUs); and/or (2) solid waste ,
management units (SWMUs). Because SWMUs include both hazardous waste and non-hazardous
waste units, the Inventory does not directly identify the number of non-hazardous waste units.
7.5.2 Estimating Non-hazardous Waste Units
The Inventory defines a SWMU as any discemable waste management unit at a RCRA
facility from which hazardous constituents might migrate, irrespective of whether the unit was
intended for the management of solid and/or hazardous waste. On the other hand, a HWMU is
defined as a unit that is used to manage hazardous waste only. As such, the definition of a
SWMU includes hazardous and son-hazardous waste management units. Because of this, EPA
subtracted the number of HWMUs from SWMUs at each facility for each unit type (i.e., Sis,
LTUs, and UIWs). This resulted in the number of nonhazardous waste management units at the
facility that could potentially be managing affected characteristic wastewaters. If this number for
a given unit type was greater than zero, then a facility was assumed to have a nonhazardous'waste
management unit. " • .
One problem that EPA noted with these data is that, in response to the question on
SWMUs, several facilities appear to have provided information only on nonhazardous waste units
rather than on both hazardous waste and nonhazardous waste units. Some of these facilities were
identified by the larger number of HWMUs reported compared to SWMUs. (The number of
HWMUs should always be less than or equal to the number of SWMUs:) For these facilities,
EPA assumed that the number of nonhazardous waste units at the facility was equal to the ,
number of SWMUs reported. • ^
Exhibit 7-1 present the results of this analysis. The total number of federal facilities with
a surface impoundment, land treatment unit, or both is estimated to be 69.
7.53 Limitations of This Approach
The following are some of the limitations of this approach.
1 •
• • EPA is required to compile an Inventory of hazardous waste treatment, storage,
and disposal facilities. As such, the Inventory does not address hazardous (or
nonhazardous) waste generators. Therefore, the number of federal facilities with
surface-based units and with ICRT wastes may be larger than 69.
• For facilities that reported the same number of SWMUs as HWMUs, EPA could
-------
7-4 .
not detennine whether the facility considered SWMUs synonymous with
nonhazardous waste management units (rather than as both hazardous waste and
nonhazardous waste management units). EPA assumed that these facilities
correctly reported their HWMUs and SWMUs, and thus no nonhazardous waste
units were assumed to be present at these sites. Only two facilities were found in
this category. ,
The Inventory data have not been subjected to a thorough QA/QC review. Thus,
the data are likely to contain some inconsistencies. '..
7.6 REQUIRED CAPACITY ANALYSIS
This section presents an estimate of the number of facilities and quantity of wastewater
affected by today's rule. According to the analysis of the 1992 Federal Facility Inventory,
approximately 69 of the-941 federal facilities manage wastewaters in nonhazardous surface-based
units (i.e., land treatment units, or surface impoundments). Because the Inventory does not focus
on waste generators, however, EPA believes that the actual number of federal facilities managing
decharacterized wastewaters in land-based units may be higher. Nevertheless, because only a
portion of these faculties are believed to generate wastes that actually are subject to today's rule
(i.e., after accounting for whether the wastes are decharacterized ICRT wastes, the end-of-pipe
concentrations of underlying constituents are above UTS, and the constituents are adequately
addressed by CWA or CWA-equivalent standards), this estimate of 69 facilities is believed to be
the maximum number of federal facilities requiring alternative treatment because of this rule.
The lower bound of federal facilities requiring alternative treatment capacity is likely to be
less than 69 because the^type of waste generated and how it is treated ultimately determines
whether the facility will require alternative treatment due to today's rule.. However, because
federal facilities are "captured" via the analyses of the other industries in this document, EPA •
decided not to attempt to refine this lower bound estimate beyond stating that the percentage of
federal facilities generating wastes with underlying hazardous constituents above the UTS, and for.
which RCRA-equivalent treatment is not conducted, could be as low as the lowest percentage
among the related industries. The. industry with the lowest such percentage is the metal products
and machinery industry,'with only about 650 of its 30,600 facilities (2 percent) appearing to
generate inadequately (i.e., non-RCRA-equivalent) treated ICRT wastes with end-of-pipe
constituent concentrations above the UTS. (see Chapter 12). Thus, EPA expects that, at a
minimum, 2 percent of federal facilities with surface-based units — or about 2 facilities — will be
affected by this rule. Nevertheless, EPA believes that the actual'number is much higher.
/
EPA estimated waste quantities that could be affected By today's rule by assuming that
each potentially affected federal facility generates approximately the same quantity of wastewater
as the average of the affected facilities from the industries to which federal facilities are most
closely associated. That is, EPA first summed the estimates of affected waste for the following
industries: electric power generation, electrical and electronics components, electroplating and
metal finishing, industrial laundries, metal products and machinery, and transportation equipment
cleaning. This resulted in a total of 9.3 billion tons/year of waste. Next, EPA summed the
estimates of the numbers of affected facilities for these industries. This resulted in a total of 574
facilities. The per-facility average for the facilities thus is approximately 16 million tons/year.
-------
Therefore, for the upper bound of 69 affected federal facilities, EPA estimates that about 1.1
billion tons/year of wastewater could be affected by this rule, and for the lower bound of 2
facilities, EPA estimates that about 32 million tons/year of wastewater will be affected.
In summary, from 2 to 69. federal facilities and 32 million to 1.1 billion tons/year of. waste
may require alternative treatment due to today's rule. No.te, however, that because federal
facilities report wastes according to-the industrial processes used, federal facilities are already
included within' the analyses of the other industries. Therefore, these estimates have not been
added to the total number of facilities and quantity of waste requiring alternative treatment that
are calculated in Chapter 1 of this appendix.'
-------
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. , CHAPTERS
REQUIRED TREATMENT CAPACITY
FOR THE FOOD AND KINDRED PRODUCTS INDUSTRY
8.1 INTRODUCTION
This analysis of the required treatment capacity for the food and kindred products industry
was developed to support today's rule. The following sections are presented: summary of
findings (Section 8.2); background on the different food sectors within the industry (Section .8.3);
waste types potentially subject to today's rule (Section 8.4); available data on wastes generated
and managed at food processing establishments (Section 8.5); and the treatment capacity analysis
for the food arid kindred products industry (Section 8.6).
8.2 SUMMARY , ' . ' .
The food and kindred products industry sector is composed of six subsectors: dairy
products; fruits and vegetables; grain mill products; meat products; sugar processing; and seafood
processing. A summary of the estimated impact of today's rule is presented in Exhibit 8-1, These
facilities discharge approximately-29 million tons of total wastewaters mixed with
ICRT wastes every year. Approximately 60 percent of the facilities discharge their wastewaters
indirectly, 10 percent of the facilities discharge directly, and 30 percent are zero dischargers.
Land treatment/application is a preferred method of wastewater treatment/disposal in this
industry. Approximately 40 to 50 percent of the facilities appear to use land-based units as part
of their wastewater treatment system. Review of fairly old data on the average concentrations of
underlying hazardous constituents showed that none exceeded the UTS levels. Nevertheless,
. . ' ' - *- '
EXHD3IT8-1
SUMMARY OF DATA ANALYSIS FOR THE FOOD AND
KINDRED PRODUCTS INDUSTRY
• ,
Discharge
Mode
EHrect
Indirect
Zero -
Total
s
Number of
Facilities
1,135;'
6,811
3,406
11,353
Total Wastewaters
Mixed with ICRT
Wastes (million
tons/yr)a
2.91
17.45
8.73.
29.08
Facilities
Without
RCRA-
equivalent
Treatment2
23 to 45
136 to 272
68 to 136
227 to 453
Facilities with
Land-based
Units'
182 to 341
1,090 to 2,043
3,406
4,678 to 5,790
*
Affected
Facilities"
4 to 14
22 to 82
68 to 136
94 to 232
Affected
Wastewater
(thousand
tons/yr)a
102 to 35.9
56.4 to 210
174 to 348
241 to 594
a The numbers1 or quantities in.this column were determined on an aggregated basis and apportioned to'the direct,
indirect, and zero dischargers based on the percentage of each discharge mode. •
-------
8-2.
based on industry knowledge and review of several other data sources/EPA believes that, some of
the constituents exceed their UTS levels at the end-of-pipe. Based on these factors, EPA
estimates that 94 to 232 facilities are likely to be impacted by today's rule.
83 BACKGROUND
This industry sector is composed of six subsectors:
dairy products;
fruits and vegetables;
grain mill products;
meat processing;
sugar processing; and
seafood processing.
These sub-sectors were selected to correspond with the food-related industries identified
in the Clean Water Act (CWA) effluent guidelines, .described in EPA's Effluent Guidelines Plan
(59 Federal Register 25859; May 18, 1994). The selected SIC codes .identified in Section X.3.2 '
were obtained based on a review of relevant industries. As shown in Exhibit 8-2, there are a total
of 11,353 establishments in this industry.1
EXHIBIT 8-2
NUMBER OF ESTABLISHMENTS IN THE FOOD AND
KINDRED PRODUCTS INDUSTRY
Subsector
Dairy Products
Fruits and Vegetables ~
Grain Mill Products .
Meat Products - .
Sugar Processing
Seafood Processing
Total
Establishments
2,364
1,914 ' ' .
2,607
3,241
103
1,124
11,353
The following subsections summarize the1 background information and production
processes for each food industry subsector.
U.S. Department of Commerce, 1987, Census of Manufactures.
-------
8-3
codes:
8J.1 Daily Products
The dairy products subsector addressed in 40 CFR Part 405 include the following SIC
SIC 2021 Creamery butter;
SIC 2022 Cheese, natural and processed;
SIC 2023 Dry, condensed, evaporated products;
SIC 2024 Ice cream and frozen desserts; and
SIC 2026 Fluid milk.
This industry includes establishments that produce processed fluid milk and cream
. (pasteurized, homogenized, vitaminized, bottled), butter, cheese, condensed and evaporated milk,
ice cream, yogurt, and other products. A limited' number of non-milk products such as fruit juices
an; processed in some plants. In 1987 there were 2,364 establishments in this industry.2
>
While some processes in the dairy industry are common throughout the industry, others *
.are limited to certain segments. Common processes include receiving, storage, transfer,
separation, pasteurization, and packaging. Churning, flavoring, culturing, and freezing are among
processes that are limited to industry segments. .
/ '
Raw materials for dairy products processing typically consist of milk and milk products
(cream, condensed or dried milk and whey, etc.). Non-dairy, ingredients (sugar, fruits, flavors,
nuts, and fruit juices) are utilized in certain manufactured products such as ice cream, flavored
milk, frozen deserts, yogurt, and others. A raw material may be involved in the manufacture of a
number of finished products; for example, cream may serve as a raw material for such varied
finished products as fluid milk and cream, butter, ice cream, and cultured products. Moreover,
considerable variation is encountered in the raw materials employed in the manufacture of a
single product , <
83.2 Fruits and Vegetables Products
The fruits and vegetables products industry is addressed in 40 CFR Part 407 and includes
the following codes under the SIC system:
,l •
SIC 2032 Canned specialties; -
SIC 2033 Canned fruits and vegetables; , :
SIC 2034 Dehydrated fruits, vegetables, and soups;
SIC 2035 Pickles, sauces, and salad dressings;
SIC 2037 Frozen fruits and vegetables; and . '
SIC 2038 Frozen specialties, not elsewhere classified (NEC).
2 U.S. Department of Commerce, 1987, 1990 (February), Census of Manufactures, MC87-I-20B.
-------
8-4
This industry produces a variety of goods from fruits and vegetables, including frozen,
dried, and canned fruits and vegetables, juices, jam and jelly, condiments, baby foods, and soups.3
In 1987, the industry operated 1,914 establishments.4 The fruit and vegetable industry is
categorized into three main segments based on the natural processing activities, principle sources
of waste and common usage: .
Preserved fruits;
Preserved vegetables; and
Miscellaneous specialties.
A large number of commodities are present within these three segments. In developing
waste water effluent limitation guidelines, EPA identified subcategories within these segments
based on the following parameters: .
Raw material;
Products and byproducts;
Production processes;
Age of plant;
Size of plant;
Plant location; and
Waste treatability.
Within the subcategories, commodities that are not significantly different in their raw
waste load characteristics are grouped together. Some commodities are deleted because of their
minor environmental or economic significance. Exhibit 8-3 outlines the final effluent guidelines
subcategory list defined by industry segments.
Standard food processing process begins with harvesting the crop, preparing the crop for
subsequent processing and transporting it to the processing plant. In the processing plant the raw'
material undergoes the following processes:
• Washing and rinsing - to remove the soil, dust, stems, dirt, stones,
pesticides, microbial contamination, insects and their residuals, etc. from the raw
materials. .
• Grading - to separate by size and quality. Performed either manually or by using
mechanical devices, such as density graders. Grading is important for many
commodities because it facilitates handling operations (pitting, peeling, filling) and
affects the number of servings or pieces that can be secured from a package of a
specified size. .
3 U.S. EPA, 1975 (October), Development Document for Interim Final and Proposed Effluent
Limitations Guidelines and New Source Performance Standards for the Fruits, Vegetables and Specialties
Segment of the Canned and Preserved Fruits and Vegetables Point Source Category, Office of Water and
Hazardous Materials - Effluent Guidelines Division, EPA 440/1-75/046. It is important to note that the
processes and data may have changed since the writing of the development document
- 4
U.S. Department of Commerce, 1987, 1990 (March)", Census of Manufactures, MC87-I-20C.
-------
8-5 '
EXHIBIT 8-3
FINAL EFFLUENT GUIDELINES SUBCATEGORY LIST
DEFINED BY INDUSTRY SEGMENT3
Fruits
Vegetables
Specialties
Apricots
Caneberries
Cherries,
Sweet
Sour -:
Brined
Cranberries
Dried Fruit
Grape Juice
Canning
Pressing
Olives '
Peaches .
Canned
Frozen
Pears
Pickles
Fresh Pack
Process Pack
Salting Stations•,
Pineapples
Plums .
Raisins .
Strawberries
Tomatoes
Peeled
Products
Asparagus
Beets
Broccoli
Brussels Sprouts
Carrots
Cauliflower
Corn .
Canned
Frozen
Dehydrated Onion/Garlic
Dehydrated Vegetables
Dry Beans.
Mushrooms
Onions (canned)
Peas
Canned
Frozen
Pimentos
Sauerkraut
Canning
Cutting1
Snap Beans
Canned
Frozen
Spinach
Canned
Frozen
Squash
Sweet Potatoes
White Potatoes
Added Ingredients
Baby Food
Chips •
Corn
Potato
Tortilla
Ethnic Foods
Jams and Jellies
Mayonnaise & Dressings
Soups
Tomato-Starch-
Cheese Specialties
a Source: U.S. EPA, 1975 (October), op. ciL . ' • > '
* . '
• •. Stemming; snipping and trimming - to remove stems from fruits and vegetables.
• In-plant transporting - to convey fruit or vegetable products at unloading docks
into and through the processing plant. Water, in one way or another, is used
extensively in this process, in washing and cooling. .
-------
• Peeling - to remove residual soil, pesticide residues, and coarse, fuzzy, or tough
peeling with unpleasant appearance, mouth feei or digestive properties. Water,
hot caustic soda solutions and oil are used for peeling.
• Pitting and coring - to remove seeds or cores from raw materials used for canning
and freezing.
' • Slicing and dicing - often combined with .pitting and coring or accomplished by a
separate machine. .
• Pureeing and juicing - to separate fluid from fruits and vegetables. Equipment
used includes reamers, and a wide variety of crusher-presses, either batch or
continuous in operation.
• De-aeration - to remove oxygen and other gases (nitrogen, carbon dioxide) present
; in freshly pressed or extracted fruit and vegetable juices.
• Concentration bv evaporation - to separate the vapor from the residual liquid.
Involves heating the product to evaporation. •
- • Size reduction - to produce different types of particulate solids.
• . Blanching - to remove air from tissues, remove solubles which may
affect clarity of brine or liquor,.fix pigments, inactivate enzymes, protect flavor,
stop leaching and shrinking, maintain temperature and to destroy microorganisms.
• Canning - to fill the commodity into the can by hand, semi-automatic machines, or
fully automatic machines, depending on the product involved. In some, products,
there is a mixture of product and brine or syrup. In other cases, brine or syrup is .
added hot or cold as top-off liquid.
• Exhausting - to achieve a vacuum and to maintain product quality. Accomplished .
by removing the headspace gas .
l ' *
The.typical process flow diagram of the fruit and vegetable industry is provided in
Attachment 8-1. .
8.3.3 Grain Mill Products
The grain null products industry is addressed in 40 CFR Part 406 and includes the
following SIC codes: . .
SIC 2041 Flour and other, grain mill products;,
SIC 2043 Cereal breakfast foods; - -_
SIC 2044 Rice milling; - '
SIC 2045 Prepared flour mixes and dough;
SIC 2046 Wet corn milling; , x
SIC 2047 Dog and cat food; and " , ' /
SIC 2048 Prepared feeds, NEC.
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8-7 '
» **"•*'
This industry uses milling grain to produce barley, corn, grain sorghum, millet, oats, rice,
rye, and wheat These, products may be sold directly to the consumer or the industry may further
process them into baking mixes, dough, cereals, and animal feed. Production involves cleaning or
other preparation, and milling, or grinding grain into flour, meal, and other products. In 1987
there were 2,607 establishments in this industry.5
k ' .
In the processing plant the raw material undergoes the following processes:
• Shelled corn'is steeped in a dilute solution of sulfurous acid and then processed by
wet means into such products as animal feed, regular and modified starches, corn
oil, corn syrup, and dextrose; - . •
• - Shelled com, wheat, and other grains are washed and subsequently milled into
various products; . • • <,
. • • Wheat, is parboiled, dried, and partially debranned in the production of bulgur;-
« , Processing for normal and parboiled rice; and
• The manufacturing of animal feeds using'primarily grain, by-products which may be
supplemented by-proteins, pharmaceutical, vitamins or mineral additives.
1 • }[
The processes used in com wet milling are distinct from other types of grain milling. Corn
wet milling plants are large chemical complexes that employ wet production methods. Because of
the high levels of water used in corn wet milling, a substantial amount of waste water discharges
are from this subcategory. Products of corn wet milling include starch, oil,.syrup, and dextrose.
Flow diagram of a typical com wet milling process is provided in Attachment 8-2.
Water use in com dry milling is generally limited to corn washing, tempering, and cooling.
The only process wastewater in corn dry milling is usually from washing the corn.
- /
The normal milling of wheat into flour uses water only in tempering and cooling and no
process wastewaters are discharged. The production of bulgur does involve water use, but the
only source of process wastewater is from steaming and cooking. Water is added on the
conveyors and waste water is discharged as the grain is transferred from bin to bin.
The ordinary milling of rice to produce either brown or white rice generates no process
wastewater, but water is used in the production of parboiled rice.' In the parboiled rice process,
water is added in the steeping or cooking operation, but the discharge from the process, along
with wheat and com dry milling, is relatively low. • .
8.3.4 Meat Products
1 ^ '
This industry is made up of establishments primarily engaged in (1) the slaughtering of
cattle, hogs, sheep, lambs, and calves for meat to be sold or to used on the same premises in
canning, cooking, curing and freezing, and in making sausage, lard, and other products, and (2)
5 U.S. Department of Commerce, 1987, 1990 (April), Census of Manufactures, MC87-I-20D.
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8-8
\ ? • •
slaughtering, dressing, and packing poultry, rabbits, and other small game. The SIC codes for this
industry include:
• ', SIC 2011 Meat Packing Plants; -(
• SIC 2013 Sausages and Other Prepared Meats; and
• SIC 2015 Poultry Slaughtering and Processing.
There are an estimated 3,241 meat products processing establishments in the United
States.6 The major meat processing areas in the United States are the Midwest, Northwest,
Southeast, and Southern regions. ,
Attachment 8-3 shows the process flow in a full-line packing plant, or "packinghouse".
The meat packing operations begin at the point at which animals arrive at the plant and cany
through the shipping of the product to the wholesale trade. In the case of very small operations.
the product may go directly to the consumer. Production related activities at meat packing plants
include: . . -
• Stockyards and Pens - In most meat packing plants, animals are held in holding
pens for less than a day, and are usually watered but. not fed while waiting their
turn for slaughter.
• Slaughtering - The slaughtering of animals,includes the killing and hide removal
for cattle, calves and sheep, and scalding and dehairing for hogs; evisceration;
washing of the carcasses, and cooling. • ,
• Blood Processing - Handling and processing of the blood is usually a part of the
slaughterhouse operation. However, in some cases, the blood may be shipped out
of a plant for processing elsewhere^ The blood may be heated to coagulate the
albumin; then the albumin and fibrin are separated from the blood water and
forwarded for further processing into such products as pharmaceutical
preparations. In most cases, the whole blood is sent directly to conventional blood
dryers and used for animal feed. .
• Viscera Handling - The beef paunches may be handled wet or dry. For wet
handling, the contents of the paunches, 50 to 70 Ibs of partially digested feed are
washed out with water and passes over a screen. The separated solids go to solid
waste handling. The liquor passing through the screen is generally severed. In dry
handling, paunch contents are dumped on a screen or other dewatering device and
- the solids are sent either to a dryer or to a truck for removal from the plant.
Often, the beef paunches and hog stomachs and the intestines are washed and
saved-for edible products. • - .
* Hide Processing - Hides may be processed wet or dry. Wet processing involves
hide demanuring, washing, and defleshing, followed by a brine cure in a brine vat
or raceway. In dry curing, the washed, defleshed hides are packed with salt and
'stacked in the curing room. -
U.S. Department of Commerce, 1987, op. cit.'
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8-9
• Cutting - The carcasses are cut for, direct marketing of smaller sections or
individual cuts, or for further processing in the processing operations, trimmings
from this operation that do not go to products, such as sausages and canned meats,
go to rendering of edible fats and tallow. Inedible materials are rendered for
inedible fats and solids.
'- i
• Meat Processing - The edible portion resulting from slaughtering and cutting are
pressed in many ways. These include the manufacture of many varieties, of
sausages, hams, bacon, canned meats, pickled meats, hamburger, proportional cuts,
etc. The processing of edible products is complex and varies from plant to plant.
Some beef cuts are delivered to curing rooms for preparation of corned beef. Hog
carcasses are cut up and hams, sides, and shoulders are generally sent to curing.
Some loins may be deboned and cured for such products as Canadian bacon. The
curing operation involves injecting a salt and sugar solution in the meat, usually
with a multineedle injection machine. Some curing is done by soaking in cure
solution. Smoked flavors are, also obtained by soaking in or injecting a solution
containing "liquid smoke".
• • Rendering - Rendering separates fats and water from tissue. Two types ,of
rendering, wet or dry, may be used for either edible or inedible products. Wet
rendering is usually carried out in pressure tanks with 40 to 60 psi steam added
directly. The fat phase is separated form the water phase after cooking. The
. solids in the water phase are screened but, leaving "tankwater". Tankwater is
frequently evaporated to a thick protein-rich .material known as "stick", which is
added to animal feeds. Dry rendering is carried out either in vessels that are open
_jo atmospheric pressure or arex closed and kept under a vacuum. The material is
. cooked until all of the free moisture in the tissue is driven off. The cooked
material is then screened to remove the fat from the solid prbteinaceous residue.
Low temperature rendering is a fairly recent development used primarily to
produce edible products. • '
• Materials Recovery - The wastewater from the plant, excluding only the waste
from the holding pens and paunch screening, usually runs through catch basins,
grease trapsj or flotation units. The primary purpose of this system is not waste
treatment but grease recovery, which is sent to inedible rendering and represents a
valuable by-product. The most widely used method of solids recovery employs a
catch basin. Solids (grit, residual flesh) settle to the bottom and are removed
continuously or periodically; grease floats to the top and is scraped off, often,
continuously. In addition to these systems, some plants also recover part of the
settleable solids before the-waste streams enter the grease removal system by
employing self-cleaning screens, either static, vibrating, or rotating. The solids that
are recovered from these, as well as the solids recovered from the catch basins are
sometimes returned to the plant's inedible rendering system. - -
83.5 Sugar-Processing •
The sugar processing industry consists of establishments that are engaged in manufacturing
of raw sugar, syrup and-molasses, cane sugar from sugarcane, refined cane sugar and sugar syrup,
and sugar from sugar beets. The SIC codes for the sugar processing industry include:
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8-10 \ - '
» SIC 2061 Raw Cane Sugar;
SIC 2062 Cane Sugar Refining; and
SIC 2063 Beet Sugar.
There are an estimated 103 sugar processing establishments in the United States.7 The
major sugar processing areas in the United States are the Southern, 'Northeast, and Midwest
regions. ' " . '
The raw sugar manufacturing process begins with harvesting the cane, transporting and
storing at the processing facility. The actual manufacturing of raw sugar begins with the
extraction of juice from the sugarcane. Generally, washing the cane prior to extraction is
necessary. However, hand harvesting done by many processing factories generally precludes the
need for cane washing. ,
-(
• Milling - is the process by which the juice is extracted from the cane stalk. This is
accomplished by revolving cane knives, shredders, crushers, and mills. The
extracted juice is sent for clarification and the cane fiber(bagasse) is burned for
energy recovery.
• Clarification - removes substantial portion of impurities (fine fibers, fats, waxes,
gums, etc.) in the-juice. Lime, heat, and a small amount of phosphate are used to
remove as much of the remaining impurities as possible..
• Filtration - is the process where the precipitated sludge from the clarification
process is thickened by rotary vacuum filters to form filter cake. The amount of
• / . filter cake produced fluctuates between 20 and 75 kkg of cane ground, depending
upon cane conditions. The filter cake (with 70-80 percent moisture) in the slurry
form is discharged as waste water. It is also dried and applied as a soil conditioner
or fertilizer.
• Evaporation - concentrates the juice from the clarification process which is about
, 85 percent water and 15 percent solids. A syrup of about 60 percent solids is
attained through this process.
• Crystallization - is generally accomplished in single effect, batch type evaporators
called 'Vacuum pans". After the formation of crystals in the pans, the massecuite
(mixture of sugar crystals and syrup) is transferred to a mixer, gently agitated, and
then into high speed centrifugals where crystals are separated from the syrup.
• Product Handling - is the final stage where the raw sugar from the centrifugals is
conveyed to shipping or to storage warehouses by various means, the most
common of which are^belt or screw conveyors. From the warehouse, the sugar is
transported as the market requires, by truck, rail, or ship to refineries.
7 U.S. Department of Commerce, 1987, 1990, Census'of Manufactures, MC87-I-20F,
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8-11
The final "blackstrap" molasses, from which sugar is unrecoverable by ordinary means, is usually
sold as animal feed or used for alcohol production. The raw sugar sent to the refineries
undergoes the refining process shown in Attachment 8-4.
8.3.6 Seafood Processing
The seafood processing industry consists of companies that are engaged in manufacturing
of animal oils and tallow, cooking and canning various seafood, shucking and packing fresh
seafood, and freezing and preparing fresh fish. The SIC codes for the sea food processing
industry include:
• SIC 2077 Animal and marine fats and oils;
• SIC 2091 Canned and cured fish and seafood; and
• SIC 2092 Fresh or frozen prepared fish.
\ \ ' r
. There are an estimated 1,124 seafood processing establishments in the United States.8
The major seafood processing areas in the United States are the Northwest, Northeast and
Southeast regions. ' " . , ,
The processing of Atlantic menhaden and Pacific anchovy into meal, oil and solubles is
considered to be one of the most important segments of the seafood processing industry, in terms
of its significance as a wastewater source. Standard seafood processing begins with the delivery of
the fish to the processing plant. Fish is delivered to the plant in the holds of large carrier vessels.
Because of the volume of fish to be processed, the industry uses a mechanized bailing system for
fast and efficient unloading. Depending on the plant location, the raw material could also be
vacuum drawn from the boat holds directly into the processing plant. .Some plants transport the
raw materials by tank truck and flush out the truck inside the plant with high pressure hoses. The
raw material is dry conveyed to the weighing room from where they are augured into the
reduction facilities. The .waste water (bailwater) from unloading is collected and may be treated
to remove suspended solids or recirculated or discharged.
The first step in the rendering process is steam cooking. The cookers are screw conveyers
with steam injection ports located along their lengths. The fish is cooked at 230-240 °F for about
10 to 15 minutes. Oil and water are released in this process. This process is critical, because
undercopking or overcooking results in excessive oil in the meal and poor oil recovery.
From the cookers the fish proceed to a battery of screw presses where the liquid and solid
portions of the cooked fish are separated under increased pressure. The separated fish solids
contain about 55 percent moisture and some oil. The press solids are referred as "press cake."
The press cake is next conveyed to dryers to remove most of the moisture. The meal is
'ground and stored for shipment. The liquid separated in the pressing operation is referred to as
press liquor. It contains solid and dissolved fish protein, oil, fats, and ash. The larger solids are .
separated from the mixture by the use of vibrating screens and/or centrifugal decanters. The
^separated solids join the press cake flow at the drying operation. Oil is extracted from the press
liquor by the use of centrifugal oil separators. These devices operate in a continuous manner,
U.S. Department of Commerce, 1987, Census of Manufacturers, MC87-I-20I, 1990.
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'"• . ' 8-12 ,
spinning the press liquor at a high velocity to effect a three phase separation of solids, oil, and
stickwater by nature of their different densities.
The oil produced in this process is usually refined or polished by the reintroduction of
water, known as washwater. The oil-water mixture is then re-separated. This polishing removes
fish protein and solubles which cause putrefaction of the oil during storage. The oil is then piped
to large storage tanks and held for shipment. The water separated from the press liquor mixture
contains dissolved and suspended protein, fats, oil, and ash. This mixture is termed "stickwater."
As the stickwater is generated, it is piped to large tanks and stockpiled, awaiting further
processing, such as concentration by evaporation.
Small plants with no evaporator discharge the stickwater or barge them to sea.
Attachment 8-5 shows the generalized process flow diagram of a typical large fish meal production
process where both bailwater and stickwater are processed. Attachment 8-6 shows a typical small
fish meal production process where the bailwater and stickwater are simply discharged.
8.4 WASTE TYPES POTENTIALLY AFFECTED BY TODAY'S RULE
The use of process waters - and thus, the generation of wastewaters — varies with different
subsectors in the food industry. Also, within each subsector, the use of water varies highly
depending on the production process. The amount of wastewater generated however, does not
necessarily correspond to the quantities of fresh water used. For example, in the sugar processing
industry, a significant portion of fresh water is lost due to evaporation, while at the same time the
amount of process water is increased due to processing of sugarcane containing about 70 to 75
percent moisture.
The wastewaters discharged from food processing industries is high in organic content,
nutrients, and total suspended and dissolved solids. In most food processing facilities, wastes from
various processes are aggregated into one waste stream for further treatment At large facilities
the wastewater generally is treated on site. Most wastewaters undergo primary treatment, which
includes screening, pH control, gravity sedimentation, and air flotation. Some wastewaters
undergo secondary treatment, which includes spray irrigation, oxidation and aerated lagoons,
activated sludge system, and biological filter system. Many facilities include a surface
impoundment as part of the treatment train of wastewaters. For some wastewaters, tertiary
treatment is conducted, which includes chlorination, carbon adsorption, electrodialysis, and reverse
osmosis. At many facilities, the wastewater undergoes primary treatment and is then discharged
toPOTWs. .
•' . /.
The following subsections summarize the wastewater generation processes in different
subsectors of the food industry. . • .
8.4.1 Dairy Products
Pollutants contained in the wastes discharged by dairy products plants are materials lost
through direct processing of raw materials into finished products and materials lost from ancillary
operations. The former group consists of milk, milk products, and non-dairy ingredients. The
latter group consists of cleaners and sanitizers used in cleaning equipment, lubricants,'and sanitary
and domestic sewage from toilets, washrooms and kitchens. These wastes, with the possible minor
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8-13
exceptions of some lubricants, cleaners, sanitizers, and concentrated wheys, are readily degradable
in typical biological treatment systems.
Ninety-four percent of the organic matter in dairy waste waters is contributed by milk,
milk products, and other edible matters. Cleaning products and employee wastes (sanitary and
domestic) are primary contributors of the remaining six percent.
8.4.2 Fruits and Vegetables Products
Fruit and vegetables products processing plants use large amounts of water in their
production processes and they also generate large amounts of waste. Raw foods must be
rendered clean and wholesome for human consumption, and food processing plants.must be
sanitary at all times. Therefore, relatively large volumes of clean water are used and sometimes
reused prior to- discharge. .Many of the available information sources on raw waste load for this
industry are commodity-specific. As a result, waste characterization is done based on the
individual commodity, instead of the manufacturing process.
Wastewater is generated from each of the processes described in Section 8.3.2. The flow
diagram of the generation of wastewater from a typical fruit and vegetable processing plant is
shown in Attachment 8-1. In general, 55 percent of the waste water is discharged to
municipalities, 33 percent discharged to land, and 12 percent is discharged to navigable waters.9
Large amounts of waste water is also reused. Attachment 8-7 shows different processes where
water is recovered for recycling.
Exhibit 8-4 provides the raw waste loads for the three industry segments. Significant
differences in raw waste load can be observed between the three industry segments.
The waste load summary of individual commodities under all subcategories is provided in
Attachment, .8-8.
8.4.3 Grain Mill Products
There are significant differences in the waste water discharges from each of the processes.
Corn wet milling results in high levels of waste discharge, while corn dry milling, flour milling, and
rice milling generate almost no process waste waters. In the com wet milling process, the starch
modifying, washing and de-watering processes are the greatest contributors to the wastewater
stream. Other waste water streams include discharges from feed de-watering, oil extraction and
refining, and general plant cleanup. .
U.S. EPA, 1975 (October), op. cit
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8-14,
EXHIBIT 8-4
RAW WASTE LOADS FOR THREE INDUSTRY SEGMENTS8
Parameter
Avg. water usage
(gal/ton) .
Avg. BOD5 (Ib/ton)
Avg. TSS (Ib/ton)
Industry Segments
Fruits
2586
23.5
4.4
Vegetables
5454
26.0
13.1
Specialties
3612
29.6
283
Source: U.S. EPA, 1975 (October), op, cit.
BAA Meat Products -
Water is a raw material in the meat packing industry that is used to cleanse products and
to remove and convey unwanted material. The principle operations and processes in meat
packing plants where wastewater originates are:
• Animal holding pens;
- • Slaughtering;
* Cutting;
• Meat processing;
• Secondary manufacturing (by-product operations) including both edible and
inedible rendering; and
• Clean-up.
Waste waters from slaughterhouses and packinghouses contain organic matter (including
grease), suspended solids, and inorganic materials such as phosphates, nitrates, nitrites, and salt.
These materials enter the waste stream as blood, meat and fatty tissue, meat extracts, paunch
, contents, bedding, manure, hair, contaminated cooling water losses from edible an inedible
rendering, 'curing and pickling solutions, preservatives, and caustic or alkaline detergents.
.Attachment 8-9 provides a typical process flow diagram for the packinghouse.
I i
8.4.5 Sugar Processing
• ', _ . •
Water is used in various ways in cane sugar factories and a variety of wastewaters result.
The uses of water in cane sugar factories include:
»• Washing of cane; - . • '
- • • Cooling vapor in condenser;
• Slurrying of filter cake, boiler bottom ash, and boiler fly ash;
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8-15 .
Boiler makeup;
Maceration;
Floor wash and miscellaneous clean-up; and
Miscellaneous cooling.
A schematic diagram of water usage and waste water flows in a cane sugar factory is
provided in Attachment 8-10.
8.4.6 Seafood Processing
There are three general types of wastewater discharges from a seafood processing plant:
evaporator water, bailwater/washwater, and stickwater. The flow diagrams in Attachments 8-5 and
8-6. show the generation of these waste waters from different stages of seafood processing. In
general, most large plants discharge only evaporator water. Some medium-size plants evaporate
(.the stickwater but discharge the bailwater, and the smaller, older plants often discharge both
stickwater and bailwater.
8.5 AVAILABLE DATA .
> ' f
Several data sources were used for obtaining information on the generation and
management of the wastes by the food and kindred products industry. A description of the data
sources is given in Chapter 3 of the main text of the background document The applicable
information obtained from these data sources is provided in the sections below. • '
8.5.1 Effluent Guidelines Development Document
Data from the following development documents were examined for the six subsectors in
the. food and kindred products industry:
• U.S. EPA, 1974 (May), Development Document for Effluent Limitations Guidelines
and New Source Performance Standards for the Dairy Product Processing Point
Source Category, Office of Water and Waste Management, PB-238 835.
• U.S. EPA, 1975 (October), Development Document for Interim Final and Proposed
Effluent Limitations Guidelines and.New Source Performance Standards for the
Fruits, Vegetables and Specialties Segment of the Canned and Preserved Fruits and
Vegetables Point Source Category, Office of Water and Waste Management, EPA
440/1-75/046. , .''.'.'
• U.S. EPA, 1974 (December), Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Animal Feed, Breakfast
Cereal, and Wheat Starch Segments of the Grain Mills Point Source Category, Office
of Water and Waste Management, PB-240 861.
• U.S. EPA, 1974 (February), Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Red Meat Processing
Segments of the Meat Products and Rendering Processing Point Source Category,
Office; of Water and Waste Management, PB-238 836.
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- ' 8-16
• U.S. EPA, 1975 (February), Development Document for Interim Final Effluent
Limitations Guidelines and Proposed New Source Performance Standards for the
Raw Cane Sugar Processing Segment of the Sugar Processing Point Source Category,
Office of Water, EPA 440/1-75-044.
• U.S. EPA, 1975 (September), Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Fish Meal, Salmon,
Bottom Fish, Clam, Oyster, Sardine, Scallop, Herring, and abalone segment of the
Canned and Preserved Fish and Seafood Processing Industry Point Source Category, .
Office of. Water,.EPA-440/1-75/041 a. . • .
i V
These data indicate that large amounts of wastewater are being treated in surface impoundments
and other land-based units. Land treatment/application is a preferred method of wastewater
treatment in this industry. The mode of wastewater discharge differs significantly among the
subsectors in this industry. EPA averaged the direct, indirect, and zero dischargers across all the
six subsectors. According to this estimate, approximately 60 percent of the facilities discharge
their wastewaters to POTWs, and 30 percent of the facilities discharge their wastewaters through
land application, and the remaining 10 percent of the facilities discharge directly to surface waters.
Data from the development documents indicate little ICR or TC organic wastes generated by this
industry. Corrosive wastes, which are generated in some food processing stages, appears to be the
largest quantities of these wastes-. However, most of the facilities neutralize these wastewaters by
aggregating them with other process wastewaters. Exhibit 8-5 provides the average pH in the
wastewaters, at the end-of-pipe, for the six subsectors in this industry.
EXHIBIT 8-5 ,
AVERAGE pH OF WASTEWATERS IN DIFFERENT SUBSECTORS OF THE FOOD AND
KINDRED PRODUCTS INDUSTRY
Industry Subsector
. Dairy Products
Fruits and Vegetables Products
Grain Mill Products.
Meat Products
Sugar Processing Products
Seafood Processing Products
Average pH in Wastewater
4.0 to 11.0
4.0 to 12.0
5.0 to 10.0
6.5 to 8.5
5.0 to 8.0
4.0 to 8.0
8.5.2 POTW Report to Congress (RTC)
The 1986 RTC indicated that there are 22,130 facilities in the food and
kindred products industry. These data include all the industries in the two digit SIC code 20xx,
however, and.not the more limited list of industries that are the focus of today's rule.
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' 8-17 - '
EXHIBIT 8-6 '*. •
CONSTITUENT CONCENTRATIONS IN THE WASTEWATERS FROM THE FOOD AND
FOOD BY-PRODUCTS INDUSTRY3
Constituent
(priority pollutants)
Antimony
Arsenic
Cadmium*
Chromium
Cyanide .
Lead
Mercury
Nickel \
. Selenium ' - :
Silver
.Zinc
Maximum Concentration in the
Discharge to POTW (mg/1)
0.83
0.008
1.05
0.75 .
0.008
0.1
0.00178
0.4
0.019
0.058
1.09
UTS Concentration (mg/1)
1.9
1.4
, 0.69
• 2.77
- ' 1-2
0.69 ..
0.15
3.98
0.82
0.43
. 2.61
a Source: U.S. EPA, 1986" (February), Report to Congress on the Discharge of Hazardous Waste to
Publicly Owned Treatment Works, Office of Water Regulations and Standards, Appendix I, State
and Local Data. .
* Concentrations exceed UTS. '
' ~ ~ . ' 1 ' ' " ' ' • ' '
These data also indicate the presence of priority, toxic, and-non-conventional pollutants in the
wastewaters discharged by the food processing facilities. Many underlying hazardous constituents
are present in concentrations above the UTS levels (refer to Exhibit 8-6 for the concentration
• data). , . " . ,
8.5.3 Biennial Reporting System (BRS) . ~
EPA extracted data from the 1991 BRS to determine what types of affected wastes are
. generated by the food processing facilities. BRS data indicated that none of these facilities treat
their hazardous wastes on site. However, BRS data identified one facility that treats hazardous
waste off site (see Attachment 8-12). EPA contacted this facility to follow-up on the BRS data
submitted to collect more information on the waste generation and •management practices. This
information is discussed in Section 8.5.8.
8.5.4 Toxic Release Inventory (TRI)
analysis.
EPA has reviewed the TRI data and did not find any applicable information for this
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8-18 .
8.5.5 Pennit Compliance System (PCS)
The PCS data identified 1,783 direct discharging facilities in the food processing sector.
Of these, 16 percent (279 facilities) appear to treat their wastes on site in land-based units.
\
8.5.6 Industrial Subtitle D Screening Survey
The Industrial Subtitle D Screening Survey indicated that there are 14,277 facilities.
These data include all the industries in the two digit SIC code 20xx, however, and not the more
limited list of industries that are the focus of today's rule. These data indicate that there are
14,277 waste generators, of which 12 percent of discharge their wastewaters in surface
impoundments, and 9.6 percent use land application units. The quantity of wastewater managed
in land-based units at large facilities (generators of 100 kg or more) is 3.28 x 10s metric tons, of
which 70 percent is managed in surface impoundments and 20 percent is managed in land
application units.10
8.5.7 Industry Studies Database (ISDB)
EPA has reviewed the ISDB and did not find any applicable information for this analysis.
8.5.8 Industry Contacts-
In order to better understand the generation and management of wastewaters in the food
processing sector, EPA contacted staff from six different facilities. EPA selected these six
facilities at random from the Million Dollar Directory11, and contacted them to collect
information on general industrial practices for wastewater management. The information
obtained indicated that some facilities generate ICRT wastes and aggregate them with other
wastewaters. All the facilities contacted discharge their wastewaters to POTWs. Many facilities
reported using land-based units. No facility reported constituent concentration above the UTS,
although none of the facilities analyzed the wastewaters for the underlying constituents. A
summary of the information obtained is provided in Exhibit 8-7- Detailed information from these
facilities is provided in the form of telephone logs in Attachment 8-13.
8.5.9 Comments to Previous Rules
EPA has reviewed the comments to previous rules and did not find any applicable .
information for this analysis.
8.6 REQUIRED CAPACITY ANALYSIS
This section presents an estimate of the waste quantities in the food and kindred products
industry that would require alternative or additional treatment due to today's rule.
10 Westat, Inc., 1987 (December 29), Screening Survey of Industrial Subtitle D Establishments, Draft
Final Report, submitted to EPA.
11 Dun & Bradstrat, 1994, Million Dollar Directory, America's Leading Public & Private Companies
'Series Cross-Reference by Industry."
-------
8-19
EXHIBITS-?
SUMMARY OF TELEPHONE LOG FOR THE FOOD AND
KINDRED PRODUCTS INDUSTRY
Company Name
Animal By-
products
Corporation
Atwater Canning
Company
Incorporated
Colonial Sugars
Incorporated
Land O'Lakes
Incorporated
Packeriand
Packaging
Company
Incorporated
Quaker Oats
Company
Incorporated
ICRT
Wastes
Yes
Yes
No
Yes
No
No
Land-
Based
Units
No
No
Yes
Yes
No/?
No
Constituent
Concentrations
above UTS
No/?
No/?
No/?
No/?
No/? '
No/?
Quantity
Discharged
(MGD)
NA
1.5
!> "
1.2
-0.06 .
1.0
0.1 to 1.0
Direct .
Discharger
No ,
No
No
No
No
No
Indirect
Discharger
Yes
Yes
Yes
Yes ,
-Yes
Yes .
Zero
Discharger
No
No
No
No
No
- No
NA - Information not available.
There are significant data limitations in assessing the extent of the impact of today's rule
in this industry due to fairly old data and due to high variability in the waste generation and
management practices. The wastewater flow data reported in the effluent development
documents were almost 20 years old, and therefore EPA relied on recently published data to
estimate an average wastewater use of 2,562 tons per year per facility in the industry.12 Based
. on this flow rate and the TRI loadings, EPA calculated the concentrations of underlying
hazardous constituents, and found that the wastewaters discharged by at least a few facilities may
have concentrations exceeding the UTS for xylenes, acetone, barium, and ethyl ene, oxide. The
number of affected facilities were estimated by calculating the probability of the number of
facilities with constituents above UTS that also have land-based units. To bridge other data gaps,
EPA made few assumptions based on industry knowledge and professional judgment The key
assumptions specific to the food and kindred products industry are listed below.
• The end-of-pipe pH concentrations of the wastewaters average between 4 and 12.
This indicates that there could be significant quantities of corrosive wastes
generated. Therefore, EPA believes that all food processing facilities are likely to
'• generate ICRT wastes that are aggregated and decharacterized prior to treatment
or discharge. . • .
12
The Water Encyclopedia, Table 5-39 (Water Use in Food Industry), p.346.
-------
. 8-20
* Data on the percentage of facilities using land-based units varied among different
data sources. For example, the effluent guidelines document indicated 30 percent
of the facilities to use land-based units, and the PCS data indicated 16 percent, and
the Subtitle D survey indicated 22 percent therefore, EPA used these data to set
the upper bound at 30 percent and lower bound at 16 percent to estimate the
number of facilities with land-based units.
• Based on professional judgment and limited available data on the constituent
concentrations in the wastewaters, EPA believes that approximately 2 to 4 percent
of the food processing facilities may have constituent concentrations that exceed
the UTS levels.
s
Based on these assumptions EPA estimates that approximately 94 to 232 facilities are
likely to be impacted by today's rule.
-------
ATTACHMENT 8-1
TYPICAL PROCESS FLOW DIAGRAM (APRICOT COMMODITY) FOR THE FRUITS AND
VEGETABLES SUBSECTOR
Source: U.S. EPA, 1975 (October), Development Document far Interim Final and Proposed Effluent
Limitations Guidelines and New Source-Performance Standards for the Fruits, Vegetables and
Specialties Segment of the Canned and Preserved Fruits and Vegetables Point Source Category, Office
of Water and Hazardous Materials * Effluent Guidelines Division, EPA 440/1-75/046.
-------
ATTACHMENT 8-2 ' -
TYPICAL PROCESS FLOW DIAGRAM (CORN WET MILLING PROCESS) FOR THE GRAIN
MILL PRODUCTS SUBSECTOR
Source: U.S.EPA, 1974 (March), Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Grain Processing Segment of the Grain Mills Point Source
Category, Office of Water and Hazardous Materials - Effluent Guidelines Division, EPA 440/1-74-
028-a. It is important to note that the processes and data may have changed since the writing of .
the development document.
-------
ATTACHMENT 8-3 .
TYPICAL PROCESS FLOW DIAGRAM FOR A MEAT PACKAGING PLANT
Source: U.S.EPA, 1975 (January), Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Renderer Segment of the Meat Products and Rendering
Processing Point Source Category, Office of Water and Hazardous Materials - Effluent Guidelines
Division, EPA 440/1-74-031-d.
-------
ATTACHMENT 8-4
TYPICAL PROCESS FLOW DIAGRAM FOR CANE SUGAR REFINING
AFFIMTlOi
comunans
riMi
NriMStt
-| COTT»IFU«TIO> I
NCMfilW
-------
0
, ATTACHMENT 8-5
TYPICAL PROCESS FLOW DIAGRAM FOR A LARGE FISH MEAL PRODUCTION
FACILITY
Source: U.S. EPA, 1975 (September), Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Fish Meal, Salmon, Bottom Fish, Clam, Oyster, Sardine,.
Scallop, Herring and abalone segment of the Canned and Preserved Fish and Seafood Processing
Industry Point Source Category, Office of Water, EPA-44Q/l-75A)41a.
-------
ATTACHMENT
TYPICAL PROCESS FLOW DIAGRAM FOR A SMALL FISH MEAL PRODUCTION
FAOLJX3L
™S—r^*«
Source: U.S. EPA, 1975 (September), Development Document for Effluent Limitations Guidelines and New
• Source Performance Standards for the Fish Meal, Salmon, Bottom Fish, Clam, Oyster, Sardine,
Scallop, Herring, and abalone segment of the Canned and Preserved Fish and Seafood Processing
Industry Point Source Category, Office of Water, EPA-440A-75A)41a. .
-------
ATTACHMENT 8-7
WASTEWATER USE AND RECYCLING IN A FRUIT AND VEGETABLE PROCESSING
FACILITY
•*«•»•»«
Va
So
Qai
A. Fn van MkMtf I*:
Y«
Yo»
*-
CM
D. APT
Km
Ya
No
Y.
Y.
Ne
No
No
a Son. or
No
No
No
but OK *»on, «c.
Y«
iav»
No
dec
U.1
A.CaMOtc
a c«
LOnptti
Vo.
C*o«
Yoi
IT 801«
Y.
CMC
Source: U.S. EPA, 1975 (October), Development Document for Interim Fined and Proposed Effluent
Limitations Guidelines and New Source Performance Standards for the Fruits, Vegetables and
Specialties Segment of the Canned and Preserved Fruits and Vegetables Point Source Category, Office
of Water and Waste Management, EPA 440/1-75/046. ' ,
-------
, ATTACHMENTS^
* '
RAW WASTE LOAD SUMMARY FOR A FRUIT AND VEGETABLE PROCESSING PLANT
I*U
- tas/f**
i*n
ro • tssstw
CMCMMIt*
MttI CMMII*
Ml* MMICS
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-------
ATTACHMENT 8-9
* • ' ' , «-
TYPICAL WASTEWATER FLOW DIAGRAM FOR A MEAT PRODUCTS PACKINGHOUSE
WMtt
Solid | liquid
Animals
I. Stcendory
Source: U.S.EPA, 1975 (January), Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Renderer Segment of the Meat Products and Rendering
Processing Point Source Category, Office of Water and Hazardous Materials - Effluent Guidelines
Division, EPA 440/1-74-031-&
-------
ATTACHMENT 8-10
WATER USAGE IN A TYPICAL CANE SUGAR FACTORY
Source: U.S. EPA, 1975 (February), Development Document for Interim Final Effluent Limitations
Guidelines and Proposed New Source Performance Standards for the Raw Cane Sugar Processing
Segment of the Sugar Processing Point Source Category, Office of Water, EPA 440/1-75-044.
-------
ATTACHMENT 8-11
TYPICAL PROCESS FLOW DIAGRAM (DRY WHEY) FOR THE DAIRY PRODUCTS
SUBSECTOR
t.
"I-—©
1.
*«•
t.
tlt«f
h Q
fv ru«i
•.
t—; 1 I
IT • CM
Source: U.S.EPA, 1974 (May), Development Document for Effluent Limitations Guidelines and New Source
Performance Standards for the Dairy Products Processing Point Source Category, Office of Water
and Hazardous Materials - Effluent Guidelines Division, EPA 440/1-74-021-a.
-------
-------
ATTACHMENT 8-12
BRS DATA
-------
-------
8-12-1
u -
as S
§'
-e
•z
cc
66
8-
I
93
OS
a
1991 TONS
GENERATE
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55
-------
-------
ATTACHMENT 8-13
TELEPHONE LOGS
-------
-------
COMPANY NAME:
DATE:
CONTACT NAME-
TELEPHONE NUMBER:
i
ICF CONTACT NAME:
8-13-1
TELEPHONE LOG
ANIMAL BY-PRODUCTS CORP.
1025 W 11th St
Mishawaka, IN 46544
September 29, 1994
Dennis Skeens
Environmental Safety Manager
219/259-7834
Jay Prakash
The company generates wastewaters in its daily operations.
The company might generate corrosive wastes but are neutralized before
discharge. ' . .
The wastewater is sent to a control manway where it undergoes primary •
treatment-which includes screening and pH control, and then is discharged
to the city sewage. •
According to Mr. Skeens, the wastewater does not contain any underlying
hazardous constituents that are above the Universal Treatment Standards
(UTS). . _ ' . .
-------
COMPANY NAME:
i.
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
8-13-2 .
TELEPHONE LOG
ATWATER CANNING CO INC.
901 Packers St.
Atwater, CA 95301
September 29; 1994 '
Bill Effinger
Plant Manager
.209/358-5616 . ' .
Jay Prakash'
. The facility generates about 1.5 million gallons of wastewater per day..
Corrosive wastes might be generated, but are neutralized before
discharged.
The wastewater undergoes primary treatment which includes screening and
pH control, and then is discharged to POTW.
. The wastewater is analyzed for BOD, COD and TSS before it is
discharged. ' '
According to Mr. Effinger, the wastewater does not contain any underlying
hazardous constituents that are above the Universal Treatment Standards
(UTS). ' .
-------
COMPANY NAME:
' v
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
• . 8-13-3
TELEPHONE LOG
COLONIAL SUGARS INC.
208 E Bryan SL
Savannah, GA 31401
September 29 and December 6, 1994
Mike Kelly
, Environmental Manager
912/964-1361
Jay Prakash/Alex Turchi
The facility generates about 1.2 million gallons of wastewater per day. \
The wastewater contains lime and sucrose. The wastewater is discharged in
a mud pond where lime is separated. The wastewater containing sucrose is
treated for BOD, COD, pH, and TSS and then is discharged to the PQTW.
According to Mr. Kelly, the wastewater does not contain any underlying
hazardous constituents that are above the Universal .Treatment Standards
(UTS). .' - ' .
The facility does not generate any ICRT wastes.
Mr. Kelly stated that the facility uses a temporary storage pond with
aeration equipment. This pond handles 1,000,000 gallons of wastewater
per day. The remaining 200,000 gallons is handled at a lift station which
pumps the wastewater to a POTW. •
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
8-13-4
?HONE LOG
,t
• LAND O'LAKES INC
4001 Lexington Ave N
Minneapolis, MN 55440
September 23, and December 6, 1994
Tod Boehne '
Environmental Engineer
612/481-2222
Jay Prakash/Alex Turchi
The facility generates about 60,000 gallons of. total wastewaters that are;
mixed with ICRT wastewaters every day.
Wastewaters from* equipment cleaning operations is land spread.
Process wastewater undergoes primary treatment which includes screening
and pH control, and then is discharged to.the POTW.
The wastewater is analyzed for BOD, COD and TSS before it is
discharged. ' .
According to Mr. Boehne, the wastewaters does not contain any underlying
hazardous constituents that are above the Universal-Treatment Standards,
(UTS). -Mr; Boehne did say, however, that traces of lead in very low levels
existed in some of the sludges generated.at the facility. He also stated that
, tests have shown mercury in levels up to .00034 tng/1 in the wastewaters.
Mr. Boehne also stated that the facility uses aerated lagoons, sludge
holding tanks, and spray fields to treat its wastewaters.
-------
COMPANY NAME:
*
DATE:
CONTACT NAME:
8-13-5
TELEPHONE LOG
PACKERLAND PACKAGING CO INC.
2580 University Avenue
Green Bay, WI 54311
September 23 and December 6, 1994
Dick Gabriel
Wastewater Plant Manager
TELEPHONE NUMBER: , 414/468-4000. EXT. 284
ICF CONTACT NAME: Jay Prakash/Alex Turchi
The facility generates about 950,000 gallons of wastewater per day.
The facility has a pretreatment plant where the wastewater undergoes
primary treatment which includes screening and pH control, and then is
discharged to Green Bay Metro (POTW).
The wastewater is analyzed for BOD, COD and TSS before it is
discharged.
According to Mr. Gabriel, the wastewater does not contain any underlying
hazardous constituents that are above the Universal Treatment Standards
(UTS). , , - . .
This facility does not generate ICRT waste. .
Mr. Gabriel stated that the facility uses an anaerobic digestion system for
pretreatment of its wastewaters. This water is then stored in two primary
tanks (2.3 million gallons and 350,000 gallons each) until it is discharged to
the POTW.
The sludge from the tanks is spread out over Gelds by a land mover.
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
8-13-6
TELEPHONE LOG
QUAKER OATS CO INC.
321 N. Clark St.
Chicago, IL 60610
September 23, 1994
Randy Parson
Environmental Program Supervisor
312y222-7156 :
JayPrakash
The company has many facilities which generate wastewaters ranging from
100,000 gal/day to 1,000,000 gal/day.
NO ICRT wastewaters are generated and no land-based units are used.
The wastewater undergoes primary treatment which includes screening and
pH control, and then is discharged to POTW.
The wastewater is analyzed for BOD, COD and TSS before it is
discharged.
According to Mr. Parson, the wastewater does not contain any underlying
hazardous constituents that are above the Universal Treatment Standards
(UTS). ^ , V '
-------
CHAPTER 9
REQUIRED TREATMENT CAPACITY FOR INDUSTRIAL LAUNDRIES
9.1 INTRODUCTION
This analysis of the required treatment capacity for the industrial laundry industry was
developed to support today's rule. The following sections are presented in this report: summary
of findings (Section 9.2); background on the industrial laundries industry (Section 9.3); waste
types potentially subject to this rule (Section 9.4); available data on wastes generated and '
managed at industrial laundry facilities (Section -9.5); and a capacity analysis for the industrial
laundries industry (Section 9.6). .
9.2
SUMMARY
The industrial laundries industry is a subcategory of the auto and other laundries .point
source category. Industrial laundry facilities (SIC 7218) are primarily engaged in supplying
laundered or, to a limited extent,, dry-cleaned work uniforms, wiping towels, safety equipment
(e.g., gloves, flame-resistant clothing), dust covers and cloths, and similar items to industrial or
commercial users. A summary of the estimated impact of today's rule is presented in Exhibit 9-1.
As shown, there are approximately 1,000 facilities in this industry.
EXHIBIT 9-1
MAJOR FINDINGS FOR THE INDUSTRIAL LAUNDRIES INDUSTRY
, t
Discharge
Mode
Direct
Indirect
Zero
Total
Number of
Faculties
1
999
0
1,000
Total Wastewaters
Mixed with ICRT
Wastes (million
tons/yr)"
0.08
76.42 . '
0
76 £
Facilities
Without
RCRA-
equivaient
Treatment8
1
800 to 999
0
801 to 1000
Facilities
with Land-
based Units*
. 1
' 30 to 120
0
31 to 121
\
'Affected
Facilities"
1
24 to 120
0
25 to 121
Affected
Wastewater
(million
tons/yr)a
0.08,
1.84 to 9.18
0-.
1.92 to 9.26
a The numbers or quantities in this column were determined on an aggregated basis and apportioned to the direct,
indirect, and zero dischargers based on the percentage of each discharge mode.
, These facilities discharge approximately 76.5 million tons of total wastewaters mixed with
ICRT wastes every year. All facilities discharge their wastewaters indirectly, but one. EPA
estimates that approximately 3 to 12 percent of the facilities are likely to use land-based units as
part of their wastewater treatment system. EPA believes that all wastewaters discharged by this
industry have underlying hazardous constituents at levels higher than the UTS. Based on the data
-------
9-2
reviewed and industry knowledge, EPA estimates that 25 to 121 facilities are likely to be impacted
by the rule. In addition, EPA estimates that 1.9 to 9.3 million tons of wastewater are likely to be
affected by this rule.
93 BACKGROUND
The industrial laundries is a subcategory of the auto and other laundries point source
category.1 Industrial laundry facilities (SIC 7218) are primarily engaged in supplying laundered
or, to a limited extent, dry-cleaned work uniforms, wiping towels, safety equipment (e.g., gloves,
flame-resistant clothing), dust covers and cloths, and similar items to industrial or commercial
users. These items may belong to the industrial laundry and supplied to users on a rental basis, or
they may be the customer's own goods. In 1980, there were over 1,000 operating industrial
laundries in the United States. The majority of these facilities operate their own laundry facilities;
the remainder are mostly sales establishments, administrative centers, or distribution centers!.
The laundries industry is extremely labor-intensive and conservative in equipment usage.
Equipment usage has not changed greatly in recent years. Basic laundry equipment is durable and
there is a strong tendency in this industry to purchase used or rebuilt machinery when replacing
equipment. The major customers of industrial laundries are chemical and manufacturing plants,
automotive repair shops and service stations, machine shops, printing establishments, and janitorial
services. . "
The three basic processes used at industrial laundries are:
• Water wash (laundering);
• Dry cleaning; and . • . .
• Dual-phase processing. . • ~ -
. In the water wash, or laundering process, soiled materials are first sorted by color and
then by the need for stain treatment Each laundry load is placed in a washing machine that
progresses through various washing stages, including a bleaching or brightening cycle for many
items. In the dry-cleaning process, fabrics are cleaned utilizing an organic solvent Dual-phase or
dual-stage processing utilizes a cleaning method that employs a water/detergent wash and a
separate solvent wash to clean items that contain large amounts of both water-soluble solids and
oil and grease. Relatively large quantities of dry-cleaning solvent may enter the wastewater
stream as a result of dual-phase processing; however, this method is being phased out as a laundry
process.
1 U.S. EPA, 1980 (October), Development Document for Effluent Limitations Guidelines and Standards
for the Auto and. Other Laundries Point Source Category, Office of Water and Waste Management It is
important to note that processes and data may have changed since the writing of the document.
-------
, 9-3
r
9.4 WASTE TYPES POTENTIALLY SUBJECT TO TODAY'S RULE
In typical laundries, there are three principal sources of wastewater:
Water washing laundering processes;
Plant and equipment cleaning; and
Sanitary water.
Dual-phase laundering and dry cleaning are minor sources of process wastewater because
dual-phase is rarely used and dry-cleaning utilizes only small quantities of process water. The
total volume of wastewater ranges from 8,600 to 290,000 GPD and averages 68,000 GPD per
facility. The quantity discharged depends on the efficiency of the equipment, water conservation ..
.methods employed, types of items laundered, and the types and loadings of soils on items. The
characteristics of the wastewaters depend on the general type of cleaning, types and quantities of
soils, and the composition of the various laundering chemicals used. Nevertheless, most laundries
appear to generate at least small quantities of I CRT wastes arid aggregate, these wastes with other
wastewaters.
F
Most industrial laundries conduct limited on-site. treatment of wastewaters prior to
discharging to a POTW. If treatment is performed on site, it typically is not biological or other
types of treatment activities that-would routinely occur in land-based units. Rather, conventional
treatment methods in this'industry include lint screens, oil skimmers, and heat reclaimers. In
addition, industrial laundry facilities do not generate wastewater at a rate that generally would
warrant the use of a land-based unit in a treatment system. '
9.S AVAILABLE DATA . '
Several data sources were used for obtaining information on the generation and
management of the wastes by the industrial laundry industry. A description of the data sources is
given in Chapter 3 of the main text of the background document. The applicable information
obtained from these data sources is provided in the sections below.
9.5.1 Effluent Guidelines Development Document
In 1980, EPA conducted, studies on industrial laundries for developing effluent limitations
guidelines. Results of this study show significant amount of toxic pollutants in the wastewaters.
Exhibit 9-2 provides the toxic pollutant concentrations and loadings in industrial laundry
wastewaters that exceed the UTS levels. Since the laundry facilities are almost exclusively
confined to urban and suburban areas where their customers.are located, almost all the facilities
discharge their wastewaters to POTWs. EPA studies also indicate that few facilities may pretreat
the wastewaters before discharging to the POTWs. General pretreatment technologies used by
the laundries include, bar/lint screens, catch basins, heat reclaimers, oil skimmers, equalization
tanks, neutralization, and physical-chemical systems.. Some of these treatments might be
conducted in land-based units.
" In 1994, in preparation for a new effluent guidelines, EPA .conducted a survey of 1,751
facilities in the industrial laundries category (includes some facilities from other subcategories).
-------
EXHIBIT 9-2
TOXIC POLLUTANT CONCENTRATIONS IN INDUSTRIAL LAUNDRY WASTEWATERS
THAT EXCEED THE UTS LEVELS8
Pollutant
Arsenic
Chromium
Lead
Zinc
Phenol (total)
Benzene
Carbon tetrachJoride
1,1,1-Trichloroethane
Chloroform
Dichlorobenzene
2,4-Dimethylphenol
Ethylbenzene
Methylene Chloride '
Naphthalene -
Phenol
Bis(2-ethylhexyl-phthalate
Butyl(benzyl)phthalate
Di-n-butyl phthalate
Di-n-octyl phthalate
Anthracene/phenanthrene
Toluene
Trichloroethylene
Maximum Concentration (mg/I)
.1.6
8.8
22.0 •
9.0
: 1.5
23.4
1.7 •
6.6
34.6
1.1
0.46
' 17.5
0.54
4.8 '
0.84
17.5
1.5
0.82
0.41
0.47
50.9
0.80
UTS (rag/1)
1.4
2.77 «_
0.69
2.61
. 0.039
0.14
0.057
0.054
0.046
0.09
0,036
0.057
0.089
0.059
0.039
0.28
0.017
0.057
. 0.017
0.059
0.080
0.054
' U.S. EPA, 1980 (October), op. ciL
-------
. 9-5 - _-.'..
This new study indicates that most industrial laundries do not conduct on-site treatment of
wastewaters prior to discharging to a POTW. However; the study also shows that treatment
methods including lint screens, oil skimmers, and heat reclaimers are used by this industry.
Currently, 250 facilities determined by EPA to be statistically representative of the entire
industrial laundries industry is being surveyed. This additional survey is focused on smaller
facilities that were not captured adequately in the initial survey. .
1
9.5.2 POTW Report to Congress (RTC)
The 1986 RTC2 indicated that there are 68,535 facilities in the industrial and commercial '
laundries industry. The focus of the'present study is only on the industrial laundries,' however,
and so these data are not.highly applicable since it includes facilities from all other sectors not
included.in this capacity analysis. Nevertheless, these data also indicate the presence of priority,
toxic, and non-conventional pollutants in the wastewaters discharged by the industrial laundries.
Exhibit 9-3 provides the concentration data for a few underlying hazardous constituents present in
. the wastewaters discharged by the industrial laundries. Several other priority pollutants and non-
conventional pollutants are also likely to be present in concentrations above the UTS levels.
9.5 J Biennial Reporting System (BRS)
Data from the 1991 BRS-were extracted to determine what types of affected wastes are
generated by the industrial laundries sector. BRS data indicated that no industrial laundries treat
. their hazardous waste on site. However, eight facilities reported sending their wastes to off-site
treatment facilities. These facilities were contacted for follow-up on their BRS .data submissions
and telephone interviews were conducted to collect more information on the waste generation
and management practices followed by these facilities. The information obtained is provided in
Attachment 9-1. . . . - .
9.5.4 Toxic Release Inventory (TRI)
"' • \ : ' ' ,
EPA has reviewed the TRI and did not find any applicable information for this analysis.
9.5.5 Permit Compliance System (PCS).
The PCS data showed only seven direct discharge laundry facilities that indicated the type
of treatment or treatment 'unit used. However, none of these facilities reported using any
potential land-based treatment units for treating the wastewaters.
9.5.6 Industrial Subtitle D Screening Survey
The Industrial Subtitle D Screening Survey did not include the industrial laundry facilities.
Therefore, EPA used data from this survey to calculate the average percentage of land-based
uriits used across all the industries for which data were available. EPA found that approximately
12 percent of the facilities in all industrial sectors use land-based units as part of the wastewater
2 U.S. EPA, 1986;(February), Report to Congress on the Discharge of Hazardous Waste to Publicly
Owned Treatment Works, Office of Water Regulations and Standards.
-------
9-6 .
EXHIBIT 9-3
CONSTITUENT CONCENTRATION DATA FOR INDUSTRIAL AND COMMERCIAL
LAUNDRIES*
Constituent
Antimony
Arsenic - .
Cadmium
Chromium
Cyanide
Lead*
Mercury
n-Butyl Alcohol
Nickel
Phenol*
Selenium
Silver
Xylene*
Zinc*
Discharge to POTW
(mg/1, maximum concentration)
0.024 - ,
0.002
0.427
1.4
0.9
• - 6.6
0.0323
0.275
0.95
.24.8'
0.008
0.086
0.5
10.0
UTS Concentration (mg/1)
1.9
' 1.4
0.69
• 2.77
1-2
0.69
0.15
5.6
3.98
0.039
0.82
0.43
0.32
2.61 .
* U.S. EPA, 1986 (February), op. tit. , -
i. •
Concentration exceeds UTS. ' , .
treatment system. EPA-applied this value in calculating the number of facilities with land-based
units in the industrial laundries category, which resulted in 120 facilities.
9,5.7 Industry Studies Database (ISDB)
EPA has reviewed the ISDB and did not find any applicable information for this analysis, t
9.5.8 Industry Contacts .
i-
\
In order to better understand the generation and management oif wastewaters in the
industrial laundries sector, EPA contacted facilities to follow-up on their BRS data submissions.
EPA also contacted two trade associations. This follow-up information indicates that most of the
.facilities discharge their wastewater indirectly to POTWs under a local city or county agreement.
This information also indicates that some organic pollutants present in the wastewaters are not
addressed by the POTW agreement. Most of the facilities have not analyzed for the underlying
hazardous constituents in their wastewaters. The information obtained is summarized in Exhibit
-------
9-7 -.
9-4. Detailed information obtained from the facilities is provided in the form of telephone logs in
Attachment 9-2. , :
EXHIBIT 9-4
SUMMARY OF BRS FOLLOW-UP CONTACTS
Company Name
CINTAS
Corporation ..
Prudential
Overall Supply in
Irvine, CA
Textiles Rental
Service Assoc.
(TRSA)
ICRT
Wastes
NO/?
NO/?
NO/?
Land-
Based
Units
NO/?
NO/?
NO/?
Constituent
Concentrations
above UTS
7
7
\
f
Quantity
Discharged
(MGD)
NA
. NA
NA '
Direct
Discharger
"No
Yes ' '
No . '
Indirect
Discharger
Yes
No
' Yes
Zero
Discharger
No
No
No
NA - Information not available. -
9.5.9 Comments to Previous Rules - , .
• - EPA has reviewed comments to previous rules and'did not find any applicable information
for this analysis. . ' • \
9.6 REQUIRED CAPACITY ANALYSIS
This section presents an estimate of the number of facilities and quantity of wastewate'r -
affected by today's rule. There are significant data limitations in assessing the extent of the
impact of the this rule due to high variability in the waste generation and management practices
in this industry. For the purpose of this rule, EPA extrapolated the data from the Effluent
Guidelines Document to estimate the total ICRT wastewaters mixed with other wastewaters, -
based on the average flow rate. The land-based units were estimated based on the Industrial
Subtitle D Screening Survey data. To bridge other data gaps, EPA made assumptions based on
industry knowledge and professional judgment. The key assumptions specific to the industrial
laundries sector are provided below.
* Based on industry knowledge, EPA believes that all industrial laundries are likely
to generate at least some ICRT wastes that are aggregated with other wastes and
decharacterized prior to further treatment or discharge. .
• Given that most industrial laundries are in urban and suburban areas, EPA
believes that the estimate of facilities with land-based units (12 percent from the
PCS data) may be somewhat high. Therefore, EPA chose 3 percent (one forth of
-------
• 9-8
"\ .
. 12 percent) as a lower bound estimate and; 12 percent as an'upper bound estimate.
• Based on process knowledge and information obtained from several data sources
discussed above, EPA believes that several underlying hazardous constituents are
likely to be present in wastewaters discharged by more than 80 percent of the
indirect dischargers at a level greater than the UTS. Therefore, EPA chose 80
percent as a lower bound and 100 percent as an upper bound estimate of facilities
with constituents above UTS.
Based on'these assumptions and the data reviewed, EPA estimates that approximately 25 to 121
industrial laundries are likely to be impacted by this rule.
-------
ATTACHMENT 9-1
1991 BRS DATA
-------
-------
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-------
-------
ATTACHMENT 9-2
TELEPHONE LOGS FOR FOLLOW-UP TO BRS DATA
-------
-------
.COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
9-2-1 , . • ' ' .
TELEPHONE LOG
i
CINTAS Corporation
12/5/94. ' . '
Steve Pucke, Director of Corporate Environmental Affairs
513-573-4156 . FAX: 513-573-4031 .
* s *
Manisha Shahane
This facility does not generate ICRT wastes., .
No underlying UTS constituents are present in the wastewaters discharged.
Did not specify if the waste streams were aggregated. - '
Most plants use bio-activated sludge units and dissolved air flotation. One plant
uses a system of aboveground feed tanks and ah ultra-filtration membrane system
in a series of tubular membranes. ' .
No land-based units are used: ' ,
Most plants discharge directly to a POTW under a local city or county POTW
agreement . '
The constituents and the standards that the POTW permit regulates are:
metals, organics, oil and grease, BOD, COD, and TSS i
The faculties use a total petroleum limit as an indicator or surrogate to represent
the presence of organics.. - •
There are some pollutants ,that are not addressed at all by the POTW permit-
usually organics. . • .
This facility does not generate any "special" wastes.
This facility does not co-manage any existing wastes with "special" wastes.
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
9-2-2 '
TELEPHONE LOG
Prudential Overall Supply in Irvine, CA
12/6/94
Lee Terry,; Environmental Manager
714-250-4855 ext. 262
Manisha Shabane .
Mr. Terry said that Prudential has the solid wastes checked annually by using TCLP and
other tests. They have not found anything that is considered a RCRA hazardous waste.
Perchloroethylene is used in dry cleaning; however, wastes from this process are being
recycled to the extent possible, and then they are incinerated. Mr. Terry does not believe
that these wastes will be affected by today's rule. —
•
*
•
•
•
This facility does not generate ICRT wastes
No underlying UTS constituents are present in the wastewaters
Did not specify if the waste streams were aggregated
Wastes (distill bottom and residual sludge) are recycled via a distilling process and
then incinerated . ' ,
Not aware of any facilities using land-based units
Wastewater is treated according to local pollution control authority under the
Clean Water Act >
This facility does not generate any "special" wastes
This facility does not co-manage any existing wastes with "special" wastes
-------
.COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
9-2-3
TELEPHONE LOG .
Textiles Rental Service Association (TRSA)
11/29/94
David Trimble, Manager of Environmental Affairs
202-833-6395 FAX: 202-833-0018
Manisha Shahane
TRSA.is a trade association to which small industrial laundries belong. Mr. Trimble
doubted that these facilities would have valuable data, if any, that would answer EPA's
questions. However, he did provide some information about the industrial laundries
industry based on his knowledge. Please note, therefore that the following information
does not pertain to any specific facility.
• He is not aware of any facilities that generate ICRT wastes.
• No .underlying UTS constituents are present in the wastewaters discharged.
• Did not specify if the waste streams were aggregated
• . Most facilities use .dissolved air flotation in aboveground tanks
• Not aware of any facilities using land-based units
• Most plants discharge to a sanitary sewer.
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
' 9-2-4 ' ' . .
TELEPHONE LOG
The Uniform and Textile Service Association (UTSA)
12/6/94, latest contact
Bob Peters
(
(202)296-6744 FAX 202/296-2309 .
Manisha Shahane '
On November 30 I first contacted him to request information on industrial laundry
facilities. Because UTSA is a trade association for large laundries, he said that some
facilities might be willing to speak with ICF. I faxed him EPA's information request which
he, in turn, faxed to several facilities. He called me back in early December with two
names:
Steve Pucke, Director of Corporate Environmental Affairs
CINTAS Corporation
Lee Terry, Environmental Manager
Prudential Overall Supply, Irvine, CA
-------
CHAPTER 10
REQUIRED TREATMENT CAPACITY FOR THE IRON AND STEEL INDUSTRY
10.1 INTRODUCTION
This analysis-of the required treatment capacity for the iron and steel industry was
developed to support today's rule. The following sections are presented: summary of findings
(Section 10.2); background on thfe iron and steel industry (Section 10.3); waste types potentially
subject to today's rule (Section 10.4); available data, on wastes generated and managed at the iron
and steel manufacturing facilities (Section 10.5); and a required treatment capacity analysis for the
iron and steel industry (Section 10.6).. " ' - .
" ' • '""» • ^ ;
10.2 SUMMARY
The iron and steel manufacturing industry is composed of twelve subsectors based on the
different manufacturing processes. EPA estimates that there are approximately 1,020 iron and
'steel manufacturing facilities with 73 percent direct dischargers, 16 percent indirect dischargers,
and 11 percent zero dischargers. EPA estimates that 11 to 22 percent of the facilities have
land-based units and that 31 facilities generate wastewater that contain constituents above UTS
which are not regulated by CWA. Based on these factors, the Agency estimates that 3 to 7
facilities in the iron and steel industry will be affected by today's rule. These facilities are
estimated to generate 26 million to 60 million tons of affected wastewaters per year. A summary
of the estimated impact of today's rule is presented in Exhibit 10-1.
EXHIBITION
MAJOR FINDINGS FOR THE IRON AND STEEL INDUSTRY
Discharge
Mode
Direct
Indirect
Zero*
Total
.
Number of
Facilities
741 .
162
117
1,020
Total, Wastewaters
Mixed with ICRT
Wastes (million
tons/yr)a
6,300
1,400
1,000
8,700
Facilities
without
RCRA-
equivalent
Treatment"
23
5
3
31
Facilities
with Land-
based Units"
81 to 164
18 to 36
13 to 24
112 to 224
1
Affected
Facilities"
2 to 5
1
• 1
3 to 7
*,
Affected x
Wastewater
(million
tons/yr)a
17 to 43
8.5
- 8.5
26 to 60
3 The numbers or quantities in this column were determined on an aggregated basis and apportioned to
.the direct, indirect, and zero dischargers based on the, percentage of each discharge mode.
-------
10-2
10.3 BACKGROUND1
The iron and steel industry (SIG 3312 to 3325) can be segregated into two major
components: raw steel making and forming and finishing operations. There are approximately
1,020 facilities. The industry is further categorized according to the different manufacturing
processes. The 12 subcategories of the steel industry are.as follows:
Coke Making;
Sintering; ' . ,
Iron Making; .
Steel Making;
Vacuum Degassing;. .
Continuous Casting; • . ' u
" Hut Forming;
Salt Bath Descaling; • .
Acid Pickling;
• Cold Forming;
• Alkaline Cleaning; and
• Hot Coating. - - • -
The manufacture of steel involves many processes which require large quantities of raw
materials and other resources., Steel facilities range from comparatively small plants engaging in
one or more production processes to extremely large integrated complexes engaging in several or
all production processes: Even the smallest steel plant, however, represents a fairly large
industrial facility. - ' ' ,
Because of the .wide variety of products and processes in the steel industry, operations
vary from plant to plant. In the first major, process, coal is converted to coke, which is then .
combined with iron ore and limestone in blast furnaces to produce iron. The iron is then
converted into steel in either open hearth, basic oxygen, or electric arc furnaces. Finally, the steel
can be further refined by vacuum degassing. Following these steel making operations, the steel is
subjected to a variety of hot and cold forming and finishing operations. These operations
produces products of various shapes and sizes, and impart desired mechanical and surface
characteristics (refer to Exhibit 10-2 for a schematic of the steel product manufacturing process
flow).
Steel is an alloy of iron containing less than 1.0 percent carbon. The basic raw materials
for steel making are hot metal, pig iron, or steel scrap, limestone, burned lime, dolomite,
fluorspar, iron ores, and iron-bearing materials such as pellets or mill scale. The principal steel
making processes in use today are the Basic Oxygen Furnace (EOF), the Open Hearth Furnace,
"and the Electric Arc Furnace.
1 The primary source of information for Sections 10.3 and 10.4 is the U.S. EPA, 1982 (May),
Development Document for Effluent Limitations Guidelines and Standard for the Iron and Steel
Manufacturing Point Source Category '(Development Document), Office of Water Regulations and
Standards. It is important to note that the processes and data may have changed since the writing of the
development document.* ' . .
-------
10-3
s
x.
fv)
oo
o
CO
-------
10-4
10.4 WASTE TYPES POTENTIALLY AFFECTED BY TODAY'S RULE
, -\ r "• . ' *
The total process water usage in the steel industry was estimated in 1982 to be about 5.74
billion gallons per day (approximately 8.73 billion tons per year). The untreated process
wastewaters was estimated to contain about 43,600 tons/year of toxic organic pollutants, 121,900
tons/year of toxic inorganic pollutants, and 14,500,000 tons/year of conventional and
nonconventional pollutants. '
include:
Wastewaters produced from the following processes that might be.subject to today's rule
Coke Making: Direct spraying of water on the hot coke to stop the coking
process.
Sintering: Scrubbing of dusts and gases produced in the sintering process, arid
" quenching and cooling of the sinter. . '
Iron Making: Scrubbing and cooling of off-gases. . " -
Steelmaking: Gas cleaning operations. • . _ ,
' Vacuum Degassing:' Particle laden steam coming from the steam ejectors is
condensed in barometric condensers, producing a wastewater.
Continuous Casting: Water directly cools the steel and guides rollers contains
particulates and roller lubricating oils. .
-1
\
Hot Forming: Spraying over the rolls and hot steel product to cool the steel rolls
. and flush away scale; scarfing is used at some mills to remove impurifications in
order to improve the quality of steel surfaces, and scrubbing of these fumes
generates additional wastewater. ' '.
Salt 'Bath Descaling: Reducing and oxidizing operations.
Acid Pickling: Spent pickle liquor, rinse waters, and the water used to scrub acid
• vapors and mists. i .
Cold Forming: Oil-water emulsion lubricant is sprayed on the material as it'enters
, the work rolls of a cold rolling mill, and the material is usually coated with oil prior
to'recoiling after it has passed throughout the mill.
Alkaline Cleaning: Cleaning baths are used to remove mineral and animal fats and
oils from steel.
Hot Coating: Galvanizing, tern coating, and other metal coatings generate
different pollutants due to the variety of the metals used.
-------
10-5
10.5 AVAILABLE DATA
Several data sources were used for obtaining information on the generation and
management of the wastes by the iron and steel manufacturing industry. A description of the
data sources is given in Chapter 3 of the main text of the background document. The applicable
information obtained from these data sources is provided in the,sections below.
10.5.1 Effluent Guidelines Development Document
The development document2 presents information regarding the 1,020 active plants that
were operating at the time of the compilation of the document. This document presents data
regarding the characteristics of the wastewaters, the use of land-based units in the treatment
system (lagoons and ponds were assumed to be surface impoundments), and the concentrations of
constituents. The constituents that were proposed to be regulated by CWA, for both direct and
indirect dischargers, included: ' ' .
• ammonia-N; - - . ' .
• , benzene;
• benzo(a)pyrene;
• chromium;
• .cyanide (total); - ' . •
• fluoride; . . .
lead; . ... ""' ' . ' - - • '
• naphthalene; ' •• / .
: • nickel; ' .
.-• phenols (4AAP);
- • residual chlorine;
• tetrachloroethylene;
* toxic organics;
• toxic metals; and
• , zinc.
.The number of facilities, the estimated wastewater generated annually, the number of
land-based units, and the number of facilities found with concentrations above UTS are presented
in Eixhibit 10-3 (refer to Attachment 10-1 for specific data). Approximately 122 of 704 facilities
(17 percent) with data regarding treatment systems are estimated to use land-based units.
Approximately 4. of 121 facilities (3 percent) with concentration data were found to have
concentrations above UTS, which are not regulated by. CWA. Except for the cokemaking
process, the iron and steel industry is estimated to generate approximately 8,668 million tons of
wastewater per year.. . . '
U.S. EPA, 1982 (May), op. at.
-------
10-6
EXHIBIT 10-3
SUMMARY OF DATA FROM THE DEVELOPMENT DOCUMENT
Process
Coke Making
Sintering
Iron Making
Steel Making
Vacuum Degassing
Continuous Casting
Hot Forming
Salt Bath Descaling
Acid Pickling
Cold 'Forming
Alkaline Cleaning
Hot Coating
Total
Approximate
Number of
Facilities
NA
17
45
43
33
49
254
26
237
118
62
78
962
Estimated
Wastewater
(million tons)
NA
150
1,300
410
84
• ' 350
6,000
1-7
130
120
26.6
46.2
8667.5
Facilities with
Land-based units
• NA '
6
' 12
4
1
9
33
' • • 7
50 .
NA
NA
NA
122
Facilities above
UTS/Number of
Facilities
Sampled
NA
•1/3
NA
0/23
. NA • '
'.0/8
0/76
1/3
2/8
NA
NA
NA
4/121
NA - Data Not Available
10.5.2 POTW Report to Congress (RTC)
The 1986 RTC3, indicated that there are 1,020 iron and steel facilities with 733 direct
dischargers, 162 indirect dischargers, and 125 zero dischargers. The RTC also included
constituent concentration information for priority pollutants in wastes discharged to POTWs and
these data are summarized in Exhibit 10-4. Chromium, cyanide, lead, and zinc (priority
pollutants) were found to be above UTS concentration levels and all of these pollutants are
regulated by CWA. These data also presented an average discharge rate of 106,000 gallons per
day (161,208 tons per year) to POTWs.
3 U.S. EPA, 1986 (February), Report to'Congress on the. Discharge of Hazardous Waste to Publicfy
Owned Treatment Works, Office of Water Regulations and Standards.
-------
10-7
EXHIBIT 10-4
CONSTITUENT CONCENTRATION DATA3
/
Constituent
.Antimony
.Arsenic
Cadmium * ' '
Chromium"
Cyanide* ' -
Lead*
Mercury
Nickel
Selenium
Silver '
Zinc .
Maximum Concentration in
Discharge to POTW (mg/1)
0.02
' , 0.041
0.06
2.808
3.09
' 2.3.
•0.0079
0.3
0.117
0.021
3.37 .
UTS
Concentration (mg/1)
1.9
1.4
0.69 '
2.77
1.2
0.69 .
0.15
3.98
0.82
• 0:43
2.61
0 U.S. EPA, 1986 (February), op. ca.
Concentration •& above UTS.
10.53 Biennial Reporting System (BRS)
Data from the 1991 BRS were extracted to determine what types of affected wastes are
generated by the iron and steel industry. EPA obtained data regarding wastes managed on site at
iron and steel .facilities for the 25 facilities that generated the highest quantities of potentially
affected wastes (the data for these facilities are presented in Attachment 10-2). The data for
some of the facilities were confirmed and summarized in Section 10.5.9.
"* '
10,5.4 Toxic Release Inventory (TRI)
'' i
"The TRI database contains information on loadings of 320 contaminants released to air,
land, and water. EPA compared the concentrations of non-priority pollutants using a low flow
rate of 250,000 gallons per day and a high flow rate of 10 million gallons per day (these flow rates
are based on data provided in the development document). In the high flow rate, scenario, EPA
did'not find any facilities with constituents that exceeded the universal treatment standard (UTS).
-------
10-8
In the low flow rate scenario, one direct discharger exceeded the UTS for barium and one
indirect discharger exceeded the UTS for xylene. Barium and xylene are assumed to,not be
regulated by CWA, ,
10.5.5 Permit Compliance System (PCS)
EPA's PCS is a computerized management information system that contains data on the
National Pollutant Discharge Elimination System (NPDES) permit-holding facilities. According to
the PCS, 460 facilities were reported with SIC codes 3312 to 3325. Of these facilities, 106 .
reported their treatment systems and approximately 22 percent reported using.treatment systems
that are most likely' land-based units as part of their treatment systems.
10.5.6 Industrial Subtitle D Screening Survey
The Industrial Subtitle D Screening Survey was conducted to determine the number of
industrial facilities that manage their wastes in Subtitle D units. According to this data source,
2,234 facilities were reported with SIC codes 3312 to 3321. About. 11 percent of the facilities
were estimated to manage 1.4 billion tons of wastewater in land-based units.
10.5:7 Industry Studies Database (ISDB) >
The ISDB only contains reliable facility information for coke facilities. The data include
the total wastewater volume generated by this sector of the industry, the number of land-based
units, and the quantities of ICRT wastes managed in the land-based units. Specific data extracted
from the ISDB are presented in Attachment 10-3. Based on these data, EPA estimates that 9 of
the 44 coke facilities use land-based units. This estimate may underestimate the actual number of
land-based units because land-based treatment systems t;hat are not defined as lagoons or surface
impoundments were not included in the estimate. Approximately 5 of these 9 facilities generate '.
ICRT wastes. Of the five facilities that manage ICRT wastes in land-based units, 3 of them are
estimated to contain priority pollutants above the universal treatment standard, however, the
pollutants are all regulated by CWA. , ,
10.5.8 Industry Contacts ,
EPA contacted several facilities to confirm the BRS.data (see Attachment 10-4). Six
facilities were contacted and three of them reported generating ICRT wastes, and only one of the
three reported using a land-based unit (summarized in Exhibit 10-5).
10.5.9 Comments to Previous Rules -
.EPA reviewed industry comments to previous,rules. However, the comments did not
provide any relevant information.
10.6 REQUIRED CAPACITY ANALYSIS
This section presents an estimate of the number of facilities and quantity of wastewater
affected by today's rule. EPA relied on the above data sources to determine the required
-------
10-9
EXHIBIT 10-5
SUMMARY OF BRS FOLLOW-UP CONTACTS
• \
^
Company Name
Bethlehem Steel
Corporation,
Burns Harbor,
Indiana
Eastern Stainless
Steel -
Monsanto
Company .
Pacific Tube
Company
Torrington
Company, Broad
Street Plant
U.S. Steel
Corporation,
Fairless Works
ICRT
Wastes
Yes
4
Yes
No
7
No
Yes
Land-
Based
Units
NA
Yes
NA
NA
No
No
Constituent
Concentrations
Above UTS
7
7
7
7
No
*
•
7
Quantity,
Discharged
(tons)
88,940,108
283,956 .
• NA
NA
. NA
1
8,856,750.3
•
Direct
Discharger
Yes
Yes '
. Yes
No
No
Yes
Indirect
Discharger
No
- •
No
No
No '.
Yes
.
No
Zero
Discharger
No
No
No
No
No
No
NA - Data not available
treatment capacity of the iron and steel manufacturing industry. The particular data sources that
EPA used and the assumptions that EPA made to determine the estimate are presented in this
section. According to the development document, there are approximately 1,020 facilities in this
industry. According to the RTC, there are approximately 73 percent direct dischargers, 16
percent indirect dischargers, and 11 percent zero dischargers. The development document also
indicated that 11 of the 12 iron and steel subcategories generate 8.67 billion tons of wastewater ,
per year. The ISDB indicated that the remaining subcategory (coke making) generates 33 million
tons of wastewater per year. Therefore, EPA estimates that this industry generates approximately
8.7 billion tons of wastewater per year (about 8.5 million tons per facility).
The estimated number of land-based units in the industry was based on Subtitle D Survey,
PCS, and development document data. The Subtitle D Survey indicates that 11 percent of the
industry uses land-based units. The development document indicates that.17 percent of the
industry uses land-based units. The PCS indicates that 22 percent of the industry uses Jand-based
units. Based on these data sources, EPA estimates that from 11 to 22 percent of the industry
uses land-based units. .-•'.-'
-------
- EPA estimated the presence of underlying hazardous constituents primarily based on
development document and TRI data. The development document indicated that 3 percent of
the facilities may contain constituents above UTS that are not regulated by CWA. The TRI data
indicate that two facilities (less than one percent) contain constituents above UTS that are not
regulated by CWA. Therefore, EPA estimates that approximately 31 facilities (3 percent) exceed
UTS concentrations. -
' Based on the above information, EPA assumes that 31 iron and steel facilities have
constituents above UTS. EPA also assumes that 11 to 22 percent of these facilities have land-
based units. Therefore, EPA estimates that approximately 3 to T facilities will be affected by
today's rule. In order to determine the quantity of wastewaters at these facilities, EPA assumes
' that each facility generates 8.5 million tons of wastewater per year. Thus, the affected facilities
are expected to generate approximately 26 million to 60 million tons of affected wastewater per
year. • . . .
-------
ATTACHMENT 10-1
DATA FROM THE DEVELOPMENT DOCUMENT
-------
-------
iRON AND STEEL (SJC 3312-3326)
Clata
The Development Document for Effluent Urriftattoni Guideline! end Standard!
for Iron end Steel Manufacturing report* e total of 1,020 active plants (as of 7/B11,
903 of which directly or Indirectly discharge waetewim A/I data is f rain the
Development Document for Effluent Limitations Guidelines and Standard* for Iron and
Steel Manufacturing. The Industry hee been broken into eleven aubpans. Facllrty-
epeclfic date wee not provided for auboarts Including cold forming, atfcaDne cleaning,
or hot forming, . , •- ,
_ - V
The screening methodology le ee follow*:
1 , Determine total quantity of wastewater generated by each cubpert of iron end
eteei menufecture.
2. identify end quantify total volume of waDtewater managed in surface
impoundments. -
, ' ' - " .' i ' • ' .
3. Identify and Quantify total volume of weeteweter that ere potentially I, C, R
characteristic hazardou* waates, or contain TC orgenle conatrtuenta CD018-
D043),
4, Identify and quantify total volume of waatawatar that are potentially i, C, R
eheractariatlc hazardous wattes, or contain TC organic constituents (D018*
0043} end la managed in e surface impoundment.
B. Of those faeilitiea managing ICR/TC wastewatera M aurface impoundments,
determine whether treated wastewater effluent exceeds Phase HI UDR UTS.
Aasiifnpttons '
Total waateweter volumes were determined by using the diacharge flowrate in MGO
timejt the production volume In tone per year bated on 305 operating days per year
and n density of 8.3 pounds per gallon.
> • »
All unit* defined M 'lagoons or ponds' war* esaumed to be aurface impoundments.
A steo-by-step summary of the screening analysis ia as follows. All quantities are
reported in metric tons per year,
/• . • ' • '
Constituent data is only available for the facilities which were visited and sampled.
Therefore, ICR/TC waateweter volumes end ICR/TC westewater volumes have been
extrapolated to a national level besed on the facilities thet{ were sampled. The lower
1
-------
bound and upper bound are specific whan an extrapolated value is less than an actual
value.-
A. Coke Making -Seeseparate analysis attached.
j
B. Sintering
V
Total Waatawatif Volume: 136,600,000
Volume Managed in SI: 14,002,928
Number of Facilities Reporting Management in si: 6
JOTcontalnaTC organic; 196,600,000 (scaled upl
ICR/TC waatewatari in Si: 14,002,926 (scaled up)
Total Number of Facilities:
*
Total Number of Facilities Reporting Weateweter
17(1981)
32 (1980)
16*1961)
21 H880)
Thr«e facilitle* ware visited and sampled, only one of which maneges Their
wastewaten in a surface impoundment. Four TC constituents, benzene,
tetrechioroathyiana, chlorolfiifacr^ad: 2>-dlnitrophtnol are known to exist In
weetew8ter< reauMng IrocaiBsrteaeaaaaeaaajr fwfftvar, these constituent* were
present in below TC tav«tt at ttia facliUlertfiat were sampled, but nave the potential
to be corrosive. The facility below has UTS oonstltueme end maneges their
waetewatem in e surface Impoundment, end potentially exhibits corroeive
characteristics. •—
Constituent
Concentration
-------
Volume Managed in SI: 34,286,071
NufnUar of Fadlrtiw Heportinfi Maneotment in &: 12
iCR/conteJn^TC organic: 108,183,636 (scaled up)
•
iCR/TC wastewawi In Si; 5,887,188 (upper bound)
3,1 17,170 (tower bound)
Total Number of Faciiitiea! 45 (1981)
54(1880)
Number of Fadlrtlii RflpmtlnQ Wan»wottr Volumas: 41 (1881 J
Sampling data was only provided for the eleven plante that ware visited. Only oha of
the piami /that vu» »ampieo has ICR/TC waitawtten.
D. Steel Making .
, •
Total Wattewatar Volume: 378,350,000
Volume Managed In Si: 6,875, 33 1
Number of Faeilftiea Reporting Management In SI; 4
ICR/contalni TC organic: 0
ICR/TC wartcwater* in SI: 0
Total Number of Facllltlet: 43(1881}
200(1880)
.'••.' . » x
Total Number of Facilitlei Reporting Wflitawmror Volumes: 41(1881)
Sampling data was only provided for trie 23 plantt that were visited, The facility
iiated below exhibits UTS conitttuemi below the UTS levels in their effluent.
Constituent Concentration (mg/ll
Facility OOBOF Benzene / 0.000012
Pemachlorophenol 0.000014
Pymne 0.00015
: Fiuorentfiene 0.000010
• \-.
-------
E. Vacuum Decreasing
Total Wastewatsr Volume: 76,268,000
Volume Managed In SI: 8,271
Number of Facilities Reporting Management In SI: 1
iCR/conzalns TC organic: 0
ICR/TC VHBStewatafs In Sh' . 0
Total Numb* of FieilWM; 33(1381)
34(1980)
Total Numoar of Facilities Reporting Wastewataf Volumes: 31 ! 1981)
Seven facilities were sampled, but they do not Include the (acuity that manages their
wastawaters in a surface Impoundment. TC constituents in the waatawatara are
reported to be known to be present bate on knowledge of the Industry, however they
were not found by tempting and analyala.
F. Continuous Casting
Total Wastawater Volume: . 321,130.000
. Volume Managed In SI: 2,098,496
Number of Facilities Reporting Management In SI: $
JCR/contsins TC organic: 0
ICR/TC waatewaters in SI: 0
Totei Number or Facilities: 49(1981)
48(1980}
Total Number of Facilities Reporting Wastewater Volumes: 32 (1981)
Eight faciliilM were sampled, only one of which manages their wastewatar In a
•urface impoundment. However, UTS constituent were not detected.
Q. Hot Forming
-------
Total Wamwatar Volume: 6,472,900,000
Volume Managed in 51: 288,037,913
Number of Facilltiea Aepooinp Mansotmam Jn 51: 33
iCR/contBins TC organic: 0
JCWTC waatewaters In 51: 0 .
Total Number of Facilities: 254 (1981)
485
Total Number of Facflfttea Reporting Westsweter Volumes: 245 (1881)
There ere 76 facilities that were visited and for which sampling data if provided.
Nona of the facilities nave 1CR/TC wastawaterv and the UTS constituents preaem in
th« effluent are below UTS levala.
H. Salt 8ath Dticellng - :
Total Waiiewater Volume: 1,614,800
Volume Managed in SI: 486,388
Number of Facilities Reporting Management In 8l: 7
ICR/eontaine TC organic: 1,514,800 (acaied up)
' ' • > ' i
iCRrrc waatewatera In 51: 488.385 (sealed up)
Total Number of Faeilitiea: 26(1981)
32 (1880)
Total Number of Faeilitiea Reporting Waatawater Volumes: 26 (1 881 )
fen facilities were sampled. Six of the facilities sampled manage their wastewaters
in s surface impoundment. Three facilities contain ICR waate that manage their
weiitewetars in * surface impoundment. Only the facility lieied beiow exhibits
constituents above the UTS levels in their effluent and manages ICR weeteweters in
a surface Impoundment.
Constituent Concentration
-------
Facility 440A-01 Chromium 115.6
The two ftcflltiat fiatad batow axMbha conatituanta abov* the UTS levels in thtlr
effluent and managai waatewatara in a aurface Impaundmam, out TC/JCB in the raw
wMiewtran wera not repoftod.
Conatituant
Faeaity424-0l Chromium
Chloroform
Facility 432K -Metal
Chloroform
Concantration (mg/j)
&00
0.088
I. Acid Pickling .
Total Waatawatar Volume:
Volume Managed in Bl:
. Sulfuric acid
Hydrochloric acid
Combined acid
S • 7 '
Numbar of Faeilitiaa Raporting Managament In Si:
Sulfurte acid
Hydrocnlorlc add
Combined acid
ICR/containa TC organic:
ICR/TC vvaatawatera In SI:
Suifuric aetd
Hydroenlorle aoid
Combined tcid
118,390,000
12,116,242
14,667,406
26,584,948
21
13
Ifi
80
119,300,000
12,116,242
14,667,408
1.BQ1.3QO
28,684,948
Total Numbar of PaellitiM: 2370961)
Total Number of Faellftiaa Raportthg Wastawatar Volume*: 216 (19611
-------
ftcitttiw ns iuJturte add, 14 hydrochloric add, and 8 combined acid
were eamplad. The facilftle. littad below exhibit! cantttuenta above the UTS Jewtft
m itheir effiutnt and manage! ICR waitewatan In M surface impoundment
Sulfurtc Kto
Conrtitutm
Concentratio
Fscdlitv 0760
Chromium
taad
NJcke!
Conttituem
30.0
1.6
21
Facility 03S4A
Combined acitt
Chioroform
Zinc
Conitrtuent
0.024 (below)
0.47 (below)
Concentration (mg/0
FftClllty 0868H
Facility 0432K
Chloroform
Nickel
Nickel
7.3
8.7
- '.' 5,2' " •' .
105,340,000
J. Cold Forming .
.» •
Tote! Wasteweter VoJume:
Volume Menaged in SI;
iCR/oontalna TC organic;
ICR/TC wtarawatart in Sh :
Total Number of Faeiittfae: 11$
Totel Number of Feeilitiee Reporting Waetewater Volumei: 82
K. Alkaline Cleaning ,
1 ' ' !
> Totel Waetewater Volume: 24,098,000
-------
Volume Managed In 51:
ICR/coraainj TC organic: .
ICfVTC wastawaters in 8i-
Total Number of FaeUfclea: . 82
Total Number of Facilities Reporting Waatewater Volumes: 62
i " ' ' *
L Hot Coating
TotaTWsttewaw Volume: 41,862,000
Managed in SI;
1C Wcdntaina TC organic:
iCrVTC wastawatara In SI; .
Total Number of Facilities: 78
Total Number of Fedlitiea Reporting Waetewatar Volumes: 71
Summary Anaivala - • .
From the data available, none of the UTS conitftuanti present were non-prioritv
poiiutanw. From the screening anaiyili, IS iron and Steel Manufacturing facllitlea will
meet tne acreening criteria facilities due to UTS eonstftueme that are aieo priority
pollutant* baaed on a aoeie-up from the number of facilities iamplad having UTS
constituent* present in their effluent. Because many of the facilities may have shut
down since 1981, this number may be an overestimate. On the other hand, UTS
constituents may be present that ware not analyzed for, making this number en
underestimate.
Th« total quantity "of VICR waatewaters managed in surface impoundments is
42,587,873 Mtons/yr based on the Effluent Limitations guidelines. The total quantity
cf ICR wastswetera'managed in a surface impoundment Is 2,125,133 as reported by
BRS. The discrepancy la most Weary due to the number of facilities shut down since
1981. .
-------
ATTACHMENT 10-2
TOP 25 FACILITIES GENERATING ICRT WASTES
FROM THE 1991 BIENNIAL REPORTING SYSTEM
-------
-------
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-------
ATTACHMENT 10-3
DATA FROM THE INDUSTRY STUDIES DATABASE
-------
-------
MEMORANDUM
Bate: September 2,1994
To: Kate Gavaghan, ffic
From: Mario Garaboa, SAIC •
•; ' J
Subject: jmn™ny of I5PB Pfl* fiar tfaa Imn ami Sitti laduiay
i a summary of the ^**» fion the industry Studies |T^*KI
5«!fment of SIC 3312: Coke ud Coke By-products, and Electric Are Furnace Steel Jtck
and I are currently Invenigatiaf other sources of information to cover the rest of the tfor. K
stBel ffiduitiy. ' , • '
Becuiae of tte limited industry coverage, only the data far the coke iadattry is reliabk.
Baaed on the number of queaionnaim and the data found in tfw hazazdooa wute Ksing fn
coke residiaU, it appein that nearly all coke planu were surveyed. At thij nme, we are
trying 10 determine the extent of coverage &t file raeHaialflt segment We do not fad
coaAdeet that this pan of the industry is adequately characterized In the ISDB.
The fbUowing is a bnef summary of the screening raulta for the coke facilirin The detai]
of the screening remits, effluent chencteBzation. and a discussioo of data limitations tad
uiiimpojofu are also attached. ,
All quantities are in metric tons per year,
Total Wastewater Volume: .2
Managed In SI: 1«,8134970 (S7% of total)
ICR/contains TC Crsjanie: 5,885 C52 (20% of total)
ICR/TC Wastewaten in SI: 740,802(2.5* of total)
-------
Told Numb* of Pidlitiei Generumg Wutewaten Imported w 1C* or continu TC
Otpnict CoBHttttfloa: 15
d from tbe stcehmtinf ftcUitiei WM affected by the screening
" •
Constituent!: 11
!^K^
*^**
Qmncty Bgpcated ai ICR or sonnint TC
. j '
Number of Fidltoa Moa|iag IOVTCW±2!sw«B8inSI: 5
epuiuug
5,385,052
: 4
Total Beponad Wuewattr Quantity of ICIUTC Wutewtten itt SI: 740,802 metric ami
in tbeir wittewttor effluent. H» nponed tretted warawitBr effluent
bm fbEowi: .
Conititucot
Pidlityl Bonao(«)py*eoe
Ftolxty 2
Facility 3
Ftooren»
Xyleos
I ppa
O
0
0
G
O
O
IQ
>0.01 X to 0.1% (< 100 to 1000 ppm)
Q
0
Q
O
0: Stupeetfldorotpectedtobepreflem.
-------
IRON AND STEEL (SIC 33U-33J5)
SIC 33! Steel Wa&BJutAamces, utf Honing udFirdsttflf MOb
SIC 3312 SteeJ "Woria 32m Panacea (Including Cole Oveni), and Rdua| MIDj
SIC 332 ltnoindStedJouadii»(indiufcsSIC3321-332f/
StndyDaa BMC OSPK only eontimaA
SXC3312. No other SIC iffltoflnci wiflm this caiopny wen ironed
for fadtititt wit!
of tfa
in thi* otegoiy, the anjority af dttiJi from ccte ud COJKB by-product opentbt
ainrii^ 4« fmrt torn .tr- fttntaee mym*«t *f f^ |p*Hn»- ^ffrniTt The fafrfMrfng im •
^^
Number of Fidlhfei: 6*
Steel: 19
Stad&Cote: 1
Total Nomber of FtdJitfc j Raportrnj Waatewcnr CJowallca: 4?
Majority of wutowttar reported from coke opent^os. {o4 PacaHtie«)
ToaJ Number (rfFtcilitlei Reporting W«taw«t«Volu^ 40
Cok» r^i^aHfiqi* 37 fci»ni»iW
Steal Opentkm* 3fadlittet
TDttiWti»witBrQutotJlyRqp«tM: 34,198,140 metric
CotoOpcntioM: 29,497,980 metric toai
Steal OpotKlooi: 4,710,160 meafcttmi \
T.xtl Wutewtter Qiunrity Manned b Suz&» Impowtteatt (SI): 16,825.320 metric ton*
Cote Openttanf: 16,813,970 outric tons (9 fed
Steel qpeatkm: 11,350 metric ton (i frdlity)
(Twoiddfti
report volumei.)
Note: Afl vobnnes are tool
report manigin| vutowatr* in SI, but did not
1 volumes for 1985,
-------
ISDB dim band oa 1CBA 3007 Quefttanotini ten 1994 for Coke/Tar Befininj
FacBiliet tad 19H5 for Iron and Stea FKflhiei
-------
a total wutewaier di^oicd/maaagBd in PO1W,
VPPBS, ST, HM»p w»n
r, where this jafonnition •was,uadetr« die tnal waaBwacr <*»«^!anml to
POTW or under NH3ES «u icdudad if the WWT system
Wutrwtter
conjdiuenrpte*eittinihewa«ewtiar, iircspective qf the conccntradon level
to niiftoe JnmoundmMts wen efaaactenzed
-------
-------
ATTACHMENT 10-4
TELEPHONE LOGS FOR FOLLOW-UP TO BRS DATA
-------
-------
COMPANY NAME:
DATE:
CONTACT NAME:
10-4-1
N
- TELEPHONE LOG
Bethlehem Steel Corporation.
Burns Harbor, Indiana
11/22/94 - .
Douglas Bley, Supervisor .
TELEPHONE NUMBER: 219-787-2712
ICF CONTACT NAME: ' Daniel Goldberg ,
Waste Generation and Management ,
*' • ' '
• Mr. Bley explained that the facility produces waste ammonia liquor which carries waste
codes D018 and D010. He also mentioned that K062 is generated at the facility.
In 1993, the facility generated 88,940,108 gallons of D010 and D018, and 7,908,863 gallons
ofK062. Mr. Bley could-not answer whether or not the wastes have any underlying UTS
constituents.
• When asked how these streams are managed and/or treated after they are generated, Mr.
Bley stated that the streams are not aggregated with other streams. Mr. Bley said that the
only treatment units used at the facility are tanks.
• When asked about subtitle D land-based units, Mr Bley stated that there are none at the
facility. . " •; ,
Additional/Alternative Treatment
• . Mr. Bley could not answer the question asking whether or not the facility would have to
re-pipe or otherwise modify the system if the wastes were required to be segregated, but
said that there are no alternative treatment systems for the wastes that are available or
that soon will be available on site. i
Waste Discharge Agreement ' „ •
• Mr. Bley stated that UIC permits and NPDES permits are used for discharge to regulate
selenium, benzene,.naphthalene, chromium, nickel, and TDS.
• • ' . i *
• He said;that the following concentrations are from 1992 data: chromium-62 PPM, nickel-
14 PPM, benzene-12 PPM, naphthalene-23 PPM, selenium-2 PPM. He also mentioned
that there are some organics not addressed by the permits.
-------
. • t • 10-4-2
Special Wastes
• Mr. Bley said that the facility does produce Bevill waste, and did not know of any waste
that would be classified as special waste.
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
10-4-3
TELEPHONE LOG
Eastern Stainless Steel Company
12/01/94 and 12/14/94
* - i
Jack Cambell
410-522-6200
I
Daniel Goldberg
Waste Generation and Management •
*. Mr Cambell said that the facility generates acidic rinse waters from cleaning and pickling
operations which is corrosive. . .
• These wastes carry RCRA waste codes of D002 and D007 and in 1991 there were 283,956
tons generated. This is a correction to the .1991 BRS data which reports that 266,663 tons
were generated. ,
i • • . ' ' , • . "
» Mr. Cambell said that the waste that is treated is a blend of the acid rinse waters with
K062 waste. The spent pickle liquor and acid rinse waters are treated as one. He said
that there is sodium sulfate which contains chromium 6, and that is the D007 waste. •
' i . • '
* He stated that these wastes go through the waste water treatment plant, equalization,
neutralization, clarification, and sludge dewatering. ' " ,
1 '
* Mr. Cambell said that there is an old lagoon used as a clarifier, but 'this is only used after
the wastewater has been fully treated. He described the water that goes into the lagoon
as final discharge, and that the lagoon could be considered a polishing lagoon. He did not
know whether or not the lagoon leaks. ' . ' '
Additional/Alternative Treatment
• Mr. Cambell did not feel that he had enough information to answer whether or not they
would re-pipe or modify the system if the wastes were required to be segregated.
Waste Discharge Agreement . .
• Mr. Cambell said that the facility uses a NPDES permit. The permit regulates the
following constituents:., naphthalene [.00161 Ibs/day]; tetrachloroethylene (.00242 Ibs/dayj;
1,2,3 trichloroethane [no standard]; chromium [1.5 Ibs/day]; nickel [1.4 Ibs/day]; oil and
grease [9 mg/liter]. - . ,
• When asked if :the permit uses indicator or surrogate chemicals to represent the presence
-------
10-4-4
of others, Mr. Cambell stated that the ELG's are all based on chromium and nickel.
» He mentioned that there could be trace amounts of many pollutants that are not covered
,by the NPDES permit including barium and manganese.
• When asked how the wastes are.discharged, Mr. Cambell said that they are discharged
directly. . . . . •
Special Wastes
•. . Mr. Cambell said that there is K063 waste which became WWTP sludge because .of
delisting.
-------
DEC 14 '94
13:19 ESSTERN-STSlNLESS ___
VIC HW t-nt. —«-••- • .....
PfiGE.02
.»
Commercial Testing & Engineering Co.
Envfronnwntil Laboratory StrvioM
, LABORATORY ANALYSIS REPORT
OUTfAU
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DEC 14 -94 13:19 EflSTERN_STfllNLE5S___
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DEC 14 '94 13:20 6fiSTERN_STfiINLESS
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-------
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
10-4-5
r i . •
TELEPHONE LOG
Monsanto Company
12/6/94
Don Wind
208-647-3312
Daniel Goldberg
Waste Generation and Management
• Mr. Wind said that the facility does not produce any ignitable, corrosive, or reactive
wastewaters, or any wastewaters that are considered to have organic "toxicity
characteristics" as defined by RCRA.
Waste Discharge Agreement
• Mr. Wind said that the plant has a NPDES permit for the discharge of non-contact
cooling water and storm water only. ' ' " .
.• • The permit does not regulate for constituents, but for thermal loading only.
• ' Mr. Wind said that the permit does not use indicator or surrogate chemicals to represent
. the presence of others. . . .' . (
Special Wastes
i ' t
* Mr. Wind said that there is no ash or other waste that is exempt from RCRA due to its
classification as a special waste.
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, - 10-4-6
^TELEPHONE LOG
COMPANY NAME: Pacific Tube Company, Los Angeles
DATE: 11/28/94
CONTACT NAME: Ashe Woldemariam
TELEPHONE NUMBER:, 213-728-2611 " .
ICF CONTACT NAME: Daniel Goldberg .,
Waste Generation and Management '
• Mr. Woldemariam said that the facility does not produce any ignitable, corrosive, or
reactive wastewaters, or any wastewaters that are considered to have organic "toxicity
characteristics" as defined by RCRA (Although the 1991 BRS data report that the facility
generated 232.7 tons of D002 waste, and 100.1 tons of a different D002 waste in 1991.)
Waste Discharge Agreement - .
• Mr. Woldemariam stated that wastewater is discharged directly into a POTW.
.• He said that the facility uses an industrial waste discharge permit,.and it regulates the
following constituents: cadmium [.69]; chromium [2.77]; copper [3.38]; lead [.69]; nickel
[3.98]; silver [.43]; zinc [2.61]; total cyanide [1.2]; total toxic organics.
• Mr. Woldemariam said that the permit does not use indicator'or surrogate chemicals to
represent the presence of others. •
* He said that there are no pollutants which are not addressed by the permit. ,
• When asked how the wastes are discharged, Mr. Woldemariam said that they are
. discharged directly.
Special Wastes , "
* Mr. Woldemariam said that there is non-hazardous baghouse dust which is generated.
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACT NAME:
10-4-7
TELEPHONE LOG
Torrington Company, Broad Street Plant
11/28/94 and 12/13/94
\
David Sordi '
203-482-9511
Daniel Goldberg
Waste Generation and Management
* Mr. Sordi said that at the present time the plant generates spent corrosive caustic
permanganate liquids and sludge from a tank used to dip wind into it.
. • These wastes carry a RCRA waste code of D002, and in 1991 there were 33.4 .tons - -
generated. .
• Mr. Sordi explained that the plant will only be generating the D002 wastes for another
two months. The plant will be changing some processes and the result will be shutting .
down the present cleaning process. Consequently, in the future there will be no
generation of ignitable, corrosive, or reactive wastewaters, or wastewaters that are
considered to have organic "toxicity characteristics" as" defined by RCRA. '
• , Mr. Sordi stated that there are some manganese, zinc, and iron compounds in the waste,
but that none of the eight RCRA metals are present. - .
f '-. •
• When asked if the streams are aggregated with other streams, Mr. Sordi explained that
some streams are aggregated depending on compatibility.
• . The types of treatment units that are used are wastewater treatment, pH neutralization,
and sludge removal. Mr. Sordi said that no land-based units are used.
• The wastewater on site contains the following UTS constituents: chromium [non-detect];
. .lead [non-detect]; nickel [non-detect]; zinc [below .5 ppm]; and cadmium [.01]. Off-site
wastewater contains the following: total chromium [non-detect]; lead [non-detect]; nickel
[non-detect]; zinc [non-detect]; and arsenic [.142 ppm].
Additional/Alternative Treatment
j . . . ' , ,
* \ ,
• When asked if the'plant would re-pipe and/or otherwise modify the system if the D002
wastes were required to, segregated and treated for underlying UTS constituents, Mr. Sordi
said that the.question is not applicable to the facility because the D002 wastes will not be
generated in the future. - .
-------
10-4-8
.Waste Discharge Agreement ' >
• Mr. Sordi stated that the facility uses a state sewer discharge permit.
• -He explained that the permit regulates all metal finishing standard metals, total suspended
solids, oil and grease, total toxic organics, and pH. It does not use indicator or surrogate
metals to represent the presence of others.
• Pollutants that are not addressed in the permit are COD and BOD.
/
• When asked how the wastes are discharged, Mr. Sordi said that they are discharged to a •
sanitary sewer. > ,
Special Wastes , -
* S . , "
• When asked if the plant generates ash or other waste that is exempt from RCRA, Mr.
Sordi said that non-RCRA sludge is generated (approximately 2 to 3 yards of 45 percent
sludge). None of the D002 wastes are co-managed with the siudge.
Other
Mr. Sordi stressed the fact that no D002 wastes will be generated in the future due to the
previously stated change in the production process.
-------
COMPANY NAME:
DATE:
CONTACT NAME:
TELEPHONE NUMBER:
ICF CONTACTNAME:
10-4-9
TELEPHONE LOG
U.S. Steel Corporation Faifless Works
11/29/94 , . '
Alan Lewis
215-736-4217
Daniel Goldberg.
Waste Generation and Management - .
• Mr.,Lewis said that his facility generates spent caustic cleaning solutions, rinses, and spent
acid cleaning solutions as waste from cleaning carbon steel. .
• These wastes carry a RCRA waste code of 0002, and in 1991 there were 856,750.3 tons
• generated. •* .
• Mr. Lewis explained that the D002 rinses are commingled and neutralized.
1
• The main type of treatment for the wastes is a flash mixer that stabilizes pH, and then the
... waste is transferred to clarifiers. Mr. Lewis said that ho land-based units are used;
Additional/Alternative Treatment
• When asked if the plant would re-pipe and/or otherwise modify the system if the D002
wastes were required to segregated and treated for underlying UTS constituents, Mr. • '
' Lewis did not feel that the question is applicable to the facility.
Waste Discharge Agreement • <
• Mr. Lewis stated that the facility uses a NPDES permit. He did not believe that it uses
indicator or surrogate chemicals to represent the presence of others.
• The NPDES permit regulates these constituents at the following concentrations [mg/1]:
hexavalent chromium [.056], lead [1.89], tetrachlorbethylene [.108], total chromium [2.77],
nickel-[3.98], naphthalene [.071], zinc [2.38], cadmium [.69], copper [3.38], cyanide [1.20],
silver (.43], TPO [2.13]. . .
• • Mr. Lewis said that there were no pollutants that are not addressed at all..
• • Mr. Lewis said that the water is discharged directly.'
-------
10-4-10
Special Wastes
• Mr. Lewis said that the facility does not generate ash or other waste that is classified as a
"special" waste. , .
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