'-
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MIDWEST RESEARCH INSTITUTE
WASTEWATER TREATMENT TECHNOLOGY DOCUMENTATION FOR
ALDRIN/DIELDRIN MANUFACTURE
~lGION III L~BRARY .
ENVIRONYENTAt PR01ECTION AGENCY
'. . 'iJ
FINAL REPORT
February 6, 1976
t..
..
Contract No. 68-01-3524
MRI Project No. 4127-C
,
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EPA Project Officer
.Mr. Ralph H. Holtje
For
Office of Water Planning and Standards
U.S. Environmental Protection Agency
Waterside Mall, Room 2834
Mai I Stop WH595
40 1 M Street, S. W .
Washington, D.C. 20460
EPA Report Collection
Regional Center for Environmental Information
US EPA Region III
Philadelphia, PA 19103
425 VOLKER BOULEVARD, KANSAS CITY, MISSOURI 64110 . 816 561 -0202
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MIDWEST RESEARCH INSTITUTE
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ii?-igg.s^rr-
WASTEWATER TREATMENT TECHNOLOGY DOCUMENTATION FOR
ALDRIN/DIELDRIN MANUFACTURE
by
Midwest Research Institute
425 Volker Boulevard
Kansas City, Missouri 64110
FINAL REPORT
February 6, 1976
Contract No. 68-01-3524
MRI Project No. 4127-C
EPA Project Officer
Mr. Ralph H. Holtje
For
Office of Water Planning and Standards
U.S. Environmental Protection Agency
Waterside Mall, Room 2834
Mail Stop WH595
401 M Street, S.W.
Washington, D.C. 20460
?jllDVViST RESEARCH INSTITUTE 425 VOLKER BOULEVARD, KANSAS CITY, MISSOURI 64110 « 816 561-0202
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~
PREFACE
This is one of four reports on pesticide-containing wastewaters pre-
pared by Midwest Research Institute for the Office of Wate~ Planning and
Standards.
These reports concern the wastewater treatment technology in-
vo1ved in the manufacture
of aldrin/dieldrin, endrin,
toxaphene, and DDT.
This report is concerned with aldrin/dieldrin.
These reports were prepared by Dr. Alfred F. Meiners, Mr. Charles E.
Mumma, Mr. Thomas L. Ferguson, and Mr. Gary L. Kelso.
This program (MRI
Project No. 4127-C) has been under the general supervision of Dr. Edward W.
Lawless, Head, Technology Assessment Section.
Dr. Frank C. Fowler, Pres i-
dent, Research Engineers, Inc., and Mr. William L. Bell, President, Arlington
Blending and Packaging, acted as consultants to the program.
Approved for:
MIDWEST RESEARCH INSTITUTE
~ ~ ~n~irector
PhYSiC~ Sciences Division
February 6, 1976
ii
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INTRODUCTION
Midwest Research Institute has performed a comprehensive examination
of the wastewater treatment technology applicable to aldrin/dieldrin, endrin,
DDT, and toxaphene.
The work was performed for the Environmental Protection
Agency under Contract No. 68-01-3524.-
The basic objectives of the program were:
(a) to perform an examina-
tion of the wastewater management practices current~y employed in the manu-
fac ture
~ of the specified pesticide; (b) to examine the state
of the art of potential wastewater treatment processes that might be app1i-
. cable to this industry; and (c) to select those processes that. would be ap-
plicab1e to EPA toxic pollutant effluent control technology requirements.
Of special interest was the cost of existing and proposed wastewater treat-
ment methods.
This
report concerns the wastewater treatment technology for
aldrin/dieldrin manufacture.
i11
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CONTENTS
List of Tables.
. . . . . . . . . . . . . .
. . . . . . .
. . . .
List of Figures.
. . . . . . . . . .
. . . . . . . .
'. . .- . . . .
ALDRIN/DIE1..DRIN MANUFACTURE
Sections
I
Summary. .
. . .
. . . . . . . .
. . . . . . . . .
. . . .
II
Characterization of the Industry.
,- . . . . . . . . . . .
General. . . . . . . . . . . . . . . . . . . . . . . . .
Manufacturing Process. . . . . . . . . . . . . . .
Wastewater Characteristics. . . . . . . . .
In-Plant Controls. . . . ... . . . . . . . . . . .
Plant Visit. . . . . . . . . . . . ". . . . . . . . . . .
III
Wastewater Disposal Method
. . . .
. . . . .
.......
IV
Effluent Disposal Methods. . . . .
. . . . . . . . . . . .
V
Wastewater Disposal Cost Estimate.
. . .
.........
Description of the Evaporation System. . . . . . .
Installed Cost of the Evaporation System. . . . . . . .
Total Cost Estimates. . . . . . . . . . . . . . .
. References. . . . . . . . . . . . . . . . . . . . . . .
Appendix A - Definition of Terms and Discussion of Conventional
Engineering Practices Used in Estimating Costs of Pesticide'
Wastewater Treatment Processes
iv
Page
v:
v.
1
4
4
5
7
9
10
11
13
14
15
16
23
25
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No.
1
2
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1
2
TABLES
Title
ALDRIN/DIELDRnl MANUFACTURE
Total Installed Capital Equipment and Land Cost for the
Evaporation System. . . . . . . . . . . . . . . . . . .
. Total 'Investment Cost and Annual Operating Cost for the
Evaporation System to Treat Aldrin~Contaminated
Wastewater. . . . . . . . . . . . . . . .
. . . . . . .
FIGURES
Title
Production and Waste Schematic for Aldrin.
. . . . . . .
Production and Waste Schematic for Dieldrin
. . . . . . .
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Page
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24
Page
6
8
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ALDRm/DIELDRm MANUFACTURE
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SECTION I
"
SUMMARY
The pesticides, aldrin and dieldrin, are not currently manufactured
in the United States.
These insecticides were formerly produced domesti-
cally by one manufacturer, the Shell Chemical Company at Denver, Colorado.
Shell ceased production following an order of the Environmental Protection
Agency suspending the registration and prohibiting the ~ale of these two
insecticides for crop use in the United States.
A brief review of' recent events concerning aldrin and dieldrin is pre-
s~nted.
The manufacturing processes for aldrin and dieldrin are reviewed
, and in-plant controls are described.
No liquid effluent was discharged from
the premises during the manufacture of these pestic~des, and no information
is available concerning the amounts of wastewater that may have been gener-
ated during the manufacture of aldrin or dieldrin.
The concentrations of
aldrin or dieldrin that may have been present in the wastewaters is also un-
known.
The' wastewater disposal system at Shell consisted of a IOO-acre asphalt-
lined evaporation basin located on the plant grounds.
This system is consid-
'.
ered adequate to achieve zero discharge of any wastewater generated at the
, -L
.'. ~..()
Shell facility should produc~ion resume in the future.
c',
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A limited market for aldrin may continue to exist in the .future.
This
market, consisting of still-registered uses such as termite control, could
be as high as 1 million pounds annually, especially if restrictions are
placed upon other pesticides which are currently used in such applications.
Shell might resume manufacture of aldrin when its inventory is exhausted or
may determine that the relatively low volume would not justify reopening
the Denver plant or the construction of a new plant.
Another company might,
however, consider aldrin manufacture a profitable opportunity.
If Shell decides to resume manufacture of aldrin at the Denver plant,
then the available lOO-acre evaporation basin would very likely be used
again to achieve zero discharge. If a new plant were constructed, an~
disposal system would be required; possibly an evaporation pond would be
built to achieve zero discharge of the liquid effluent, although the volume
of wastewater could be so low that a different method (for example, landfill
or incineration) would be selected.
This report examines the design of an evaporation pond for wastewater
disposal at a new aldrin manufacturing plant.
The costs of this pond have
been estimated assuming that the new plant would have an annual production
volume of 1 million pounds of aldrin and an annual wastewater discharge of
520,000 gal. (from spill cleanups and floor washings).
The" evaporation system consists of an 18,000 ft3 (60 ft x 60 ft x 5 ft)
concrete pond covered by a built-up five-ply wood roof.
The estimated in-
stalled capital c~st of the evaporation system is $24,100 and the estimated
2
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annual operating cost of the system is $5,610.
/
The unit operating cost
of disposal of the aldrin-contaminated wastewater is $0.006/lb of aldrin.
3
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SECTION II
CHARACTERIZATION OF THE INDUSTRY
GENERAL
~
The Shell Chemical Company plant at Denver, 'Colorado, had an annual
production capacity of about 20 million pounds for the two insecticides
and produced an estimated l3'million pounds ,of aldrin and 0.5 million
,
pounds of dieldrin in 1972 (von RUmker, Lawless, and Meiners, 1974).
Shell Chemical Company was notified on April 4, 1975 (U.S. Court
of Appeals, 1975) that the U.S. Court of Appeals for the District of
,Columbia Circuit had upheld the order of the Environmental Protection
Agency Administrator, Russell E. Train, dated October 1, 1974, suspend-
ing the registration and prohibiting the manufacture and sale of the'
insecticides aldrin and dieldrin for crop use in the United States.
This order permitted continued use of aldrin and dieldrin for subter-
ranean termite control, as a root dip for nonfood plants, and for use
in closed mothproofing systems.
As a result of the decision and the economic forecast for limited
production, Shell Chemical Company decided on April 18, 1975 (Shell,
4
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1975), to terminate immediately its manufacture of aldrin and dieldrin in
the United States for any use.
Shell had not, in fact, manufactured aldrin/
dieldrin since April 1974 (Martin, 1975).
This action by Shell r~sulted in
an accelerated decision cancelling the registrations of aldrin and dieldrin
(Perlman, 1975).
In the future, a limited market for aldrin may develop (perhaps about ,~:,,~
1 million pounds annually), especially if restrictions are placed upon pes-
tic'ides which are currently used in applications for which aldrin use would
be permitted.
-
Shell might again manufacture aldrin or may determine that
[
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the relatively low volume would not justify reopening the Denver plant or
the construction of a new plant.
Also, another company might consider
ald~in manufacture a profitable opportunity.
J-
MANUFACTURING PROCESS
...-.,o~'1
The production and waste schematic for aldrin is shown in Figure 1
(Lawless, Ferguson, and von RUmker, 1972).
Aldrin was manufactured in
dedicated equipment using raw materials shipped from various sources by
rail cars, tank cars, and gondola cars.
These raw materials were:
(a)
calcium carbide from Oregon and the Midwest; (b) dicyclopentadiene from
Baton Rouge; (c) hexachlorocyclopentadiene from Niagara Falls; and (d)
petroleum solvent (for formulation) from Houston (Lawless, Ferguson, and
von Rumker, 1972).
5
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l
lime
Slurry -----lime Pit
CaC2
,
H20
Acetylene
Generator
C2H2
CSCI6
Bicyclohepta
Diene
Generator
C7Ha
Diene
. Reactor
Aldrin
Solution
Solvent
Stri pper
Technical
Aldrin
~
CIOH12
Crocker
CSH6
C7Ha
(Excess)
Bottoms
By-Products
+
Boiler
Fuel
Figure 1 - Production and Waste Schematic for Aldrin
Source:
Lawless, E. W., T. L. Ferguson, and R. von Rumker, "Po11ut ion Potential in Pesticide Manufac-
turing," Final Report by Midwest Research Institute on Contract No. 68-01-0142 for the En-
vironmental Protection Agency, June 1972. (NTIS Nos. PB-213,782/3.)
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The reaction chemistry for the production of aldrin was:
CaC2 + ~o~ Ca(OH)2 + C2~~
) CSH6 /'"
. C10Hl2 ~
C12
)o~
Cbl C1/@()
CI C1
C12
)
The production and waste schematic for dieldrin is shown in Figure 2
(Lawless, Ferguson, and von RUmker, 1972).
Dieldrin was manufactured from
aldrin produced on-site with the use of additional raw materials.
These
raw materials were toluene, acetic acid, sulfuric acid, and hydrogen per-
oxide.
, The reaction chemistry for the production of dieldrin was:
00
H202
~so4
HOAc
)~O+HzO
Aldrin
Dieldrin
WASTEWATER CHARACTERISTICS
The manufacture of aldrin did not produce wastewater or any liquid
waste streams containing aldrin (Ferguson and Meiners, 1974).
Sma 11
amounts of aldrin-containing liquid wastes resulted from spill cleanup
or floor washings.
The amount of aldrin in these wastes and the amount
of liquid wastes involved in spill cleanup and washing the floor are
unknown.
7
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H202::1
CH3COOH
f-II Peril Acid
H2S0 4
Aldrin
Toluene
Filter
Ox idation
Reactor
Dieldrin
Solution
Aldrin
Solution
00
Paper
+
Inc inerator
Aqueous
Phase
I
Figure 2 - Production and Waste Schematic for Dieldrin
Source:
Lawless, E. W., T. L. Ferguson, and R. von Rumker, "Pollution Potential
Final Report by Midwest Research Institute on Contract No. 68-01-0142
tection Agency, June 1972. (NTIS Nos. PB-213,782!3.)
H20
Extractor
Solvent
Stripper l
Dieldrin
Waste
Water
~!
Evaporation
Basin
in Pesticide Mimufacturing,"
for the Environmental Pro-
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The manufacture of dieldrin produced wastewater from the extractor
and oxidation reactor.
The amount of this wastewater is unknown and
the amount of dieldrin in this wastewater is unknown also.
Dieldrin was
also present in floor washings and spill cleanups as in the aldrin process. .
IN-PLANT CONTROLS
The aldrin manufacturing process did not generate liquid effluent
containing aldrin since the excess bicycloheptadiene was recycled from
the solvent stripper back to the diene reactor.
Floor washings and spill
cleanups containing aldrin were discharged into a 100-acre evaporation
basin.
The PFoduction area was diked so that water used for cleanup of
spills and the production floors would not run off from the plant site
(FeFguson and Meiners, 1974).
During summer shutdown, the dedicated aldrin production equipment
was washed down with toluene.
All of this toluene was collected for use
as a raw material input into the dieldrin process (Ferguson and Meiners,
1974) .
The aldrin which was produced was packaged in 28-gal. fiber Mylar-
lined drums for shipment.
About 90% of production was shipped as tech-
nical product and was nearly all formulated to granules.
The remaining
10% of aldrin product was formulated on-site as an emulsifiable concen-
trate (4 lb/gal), and packaged in 5, 30, and 55 gal. lined drums.
Dam-
aged drums were cleaned and the washings were discharged into the evap-
oration basin.
The cleaned, damaged drums were then incinerated, flat-
tened, and sold as scrap steel (Lawless, Ferguson, and von Rumker, 1972).
9
~EGIO~ III LIBRARY
ENVIRONM~~TAL PROTECTION AG~~CT
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The dieldrin manufacturing process discharged the wastewater from
the oxidation reactor' and extractor to the lOO-acre evaporation basin.
A small amount of solid waste, including filter paper which contained
. .
aldrin, was burned in a smokeless type incinerator., The floor washings
and spill cleanups, which. occurred in the diked production area, were
discharged into the evaporation basin.
Excess liquid from the solvent
stripper was recycled in the process (Lawless, Ferguson, and von RUmker,
1972).
The equipment was cleaned and washed with toluene.
This contami-
nated toluene was collected and recycled as a raw material input into
the process (Lawless, Ferguson, and von Rumker, 1972).
No dieldrin formulation was conducted on-site.' The technical diel-
drin was packaged in drums and handled in the same manner as aldrin
(lawless, Ferguson, and von R~ker, 1972).
PLANT VISIT
Much of the information concerning the manufacture of aldrin/dieldrin
and the associated wastewater technology. was obtained from a visit by MRI
/
personnel to the Shell Chemical Plant at Denver, Colorado, on October 7,
1971 (Ferguson and Lawless, 1971).
Additional information was requested
by MRIpersonnel on July 1, 1975 (Mumma, 1975).
A reply from the General
Manager,' Manufacturing and Distribution (Martin, 1975); indicated that
Shell was not producing aldrin/dieldrin and had not produced these pesti-
cides since April 1974.
. 10
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SECTION III
WASTEWATER DISPOSAL METHOD
Shell's method of disposal of all contaminated liquid wastes from
aldrin/dieldrin manufacture was to discharge them into a lOO-acre asphalt-
lined evaporation basin located on the plant grounds (Ferguson and Meiners,
1974).
The basin was reported by the company to have had no leaks in its
17 years of use (Knaus, 1971).
The amount of aldrin and dieldrin discharged
to the evaporation basin from the plant and the volume of contaminated water
involved are unknown.
The method of disposal used by Shell appears to have been adequate to
prevent the discharge of aldrin and dieldrin into off-premises waterways.
The rate at which aldrin/dieldrin decomposed or accumulated in the basin is
unknown, and any plans that the company had to dispose ultimately of any
accumulated pesticide have not been disclosed.
No data are available on
any losses of aldrin/dieldrin from the basin to the atmosphere.
No alternate wastewater treatment method is proposed in this report
since (a) aldrin and dieldrin no longer have regular domestic agricultural
markets and the resumption of large domestic production of these two insec-
ticides appears unlikely; (b) if domestic production does resume, Shell may
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,
again be the sole producer and, as in the past, would probably discharge no
wastewater (zero discharge); and (c) if production began at a new site, an
evaporation pond could be constructed to maintain zero discharge ~f waste-
water at the new site.
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SECTION IV
EFFLUENT DISPOSAL METHODS
Shell's wastewater treatment method consisted of zero discharge and,
,--
of course, there was no effluent.
However, had the plant continued to op-
erate, the sludge in the .100-acre evaporation basin may have accumulated
to the point where disposal of the sludge would have been required.
The
disposal of the sludge containing aldrin and dieldrin could have been
achieved by landfill or incineration.
A new plant for the manufacture 'of aldrin could use an effluent dis-
posa1 method similar to Shell's.
The disposal method would most likely
consist of a small evaporation pond (zero discharge), and the disposal of
sludge containing aldrin would be achieved by landfill or incineration.
13
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SECTION V
WASTEWATER DISPOSAL COST ESTIMATE
The existing wastewater treatment system at the Shell Chemical Company
plant in Denver, Colorado, involves a zero discharge concept.
The waste-
water and disposal system which was in operation up to the time of 'closing
the Denver plant in 1975 consisted essentially of dikes, unlined storage
basins, the lOO-acre evaporation basin, and auxiliary facilities including
piping, conduits, etc.
No figures are available for the actual cost in-
-'~: .
, "
' -;.-r, 4'.':<
curred by Shell in constructing their facility.
~.
Since the 100-acre evaporation pond currently exists at Shell, no es-
timates for the cost to construct the facility are required.
However, in
the event that aldrin is manufactured in the future by another company, the
construction of an evaporation pond at a new plant site would be required.
The cost estimates presented here are the estimated order-of-magnitude costs
for contructing a lined evaporation pond and auxiliary facilities for a new
(,"
aldrin plant with a 1 million pound annual production capacity.
"
The lOO-acre pond at Denver, Colorado, was used for a multipurpose
plant, and its capacity far exceeds that required for a plant whose sole purpose
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is to manufacture aldrin.
As previously mentioned, the manufacture of a1-
drin produces no wastewater or any liquid waste streams containing aldrin.
Small amounts of aldrin-containing liquid wastes are generated from spill
cleanup and floor washings.
An evaporation pond at a new plant site would
need to handle only the spill cleanups and floor washings, and would not
require an area of 100 acres.
The costs for an evaporation pond to handle the liquid effluent from
a new aldrin plant are discussed below.
The discussion is divided into
three sections:
(a) description of the evaporation system; (b) installed
cost of the evaporation system; and (c) total cost estimates for the evap-
oration system.
DESCRIPTION OF THE EVAPORATION SYSTEM
The purpose of the evaporation system is total containment of the con-
t~minated water used for spill cleanups and floor washings in the aldrin
, production facility.
The required equipment for this system is a concrete
evaporation pond covered with a roof, and a single conduit to transport the
water from the production area to the pond.
The concrete pond is sized to allow a retention time of 3 months for
the wastewater containing aldrin.
The amount of wastewater is estimated to
be 2,000 gal. each'day for daily floor washings and intermittent spill clean-
ups.
The new plant will operate all'year, 5 days a week, and will generate
130,000 gal. of wastewater in a 3-month period.
No provisions are made to
contain surface runoff in the pond since the new plant will be enclosed in
a building, and will allow no aldrin to escape onto the plant grounds.
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The size of the concrete pond will be 60 ft x 60 ft x 5 ft (18,000 ft3
or 134,600 gal.).
Three feet of the pond depth will lie below the ground
surface, and 2 ft will lie above the ground surface (to prevent rainwater
runoff from entering the pond).
Wastewater will enter the pond from a 6 in.
diameter conduit.
Since the future site of the new plant is unknown and, therefore, the
net evaporation rate (gross evaporation minus rainfall per unit time) of
----
the area in which the plant would be built is unknown, a roof is provided
for the concrete pond.
The roof will be constructed of built-up five-ply,
will be a pyramid 70 ft on a side with a l5-ft height, and will be supported
10 ft above the top of the pond.
INSTALLED COST OF THE EVAPORATION SYSTEM
The installed cost of the evaporation system described above consists
of the following cost items:
(a) land; (b) excavation; (c) pond construc-
tion; (d) roof construction; (e) auxiliary facilities construction; and (f)
related indirect .construction costs.
Each of these cost items are estimated
below.
Land costs vary widely throughout the United States and range from
less than $l,OOO/acre to greater than $50,000/acre, depending upon location.
Since the aldrin plant can be constructed at any number of sites, it is as-
sumed that the plant will be built in an isolated rural area where land is
valued at $l,OOO/acre.
The amount of land required for the evaporation sys-
tern is 1/2 acre; ~hus, the land cost for the system is $500.
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Excavation costs depend directly upon the volume of earth moved and
amount of finish grading done for preparation of the pond site.
Sixty
percent of the pond lies below the ground surface, thus, 10,800 ft3 (0.6
x 18,000 ft3) or 400 yd3 must be excavated, assuming the ground is flat.
The average cost of site clearing, foundation excavation, and grading is
$1.93/yd3 in 1970 prices (Guthrie, 1974).
This cost is adjusted to April
1975 prices using the Engineering News Record construction cost index, which
rose from 1,445.08 in 1970 (Engineering News Record, December 19, 1974) to
2,150.1 in April 1975 (Engineering News Record, May 1, 1975). Thus, the
(400 yd3 $1.93 2 150.1 )
estimated excavation cost for the pond is $1,150 x . x' .
1 yd3 1,445.08
The construction cost for the concrete pond is estimated from tqe cost
of installing 6-in thick reinforced concrete with a 6-in. sub-base, which
averages $9.76/yd2 at 1970 prices (Guthrie, 1974).
This cost is adjusted
to April i975 prices in the same manner as above, and results in a cost of
$14.50/yd2 ($9.76 x 2,150.1 ). The inside surface area of the pond is
yd2 1,445.08 .
5,525 ft2 [(65 x 65) x (4)(5)(65)J or 614 yd2. Thus, the installed cost
of the pond is $8,900 (614 yd2 x $14.50/yd2).
The construction cost of the built-up five-ply roof is $0.37/ft2, based
upon 1967 prices (Peters and Timmerhaus, 1968).
The surface area of the
roof is 5,330 ft2 (4 x 70 x 38.1 x 0.5).
Thus, the cost of the roof in 1967
prices is $1,970.
This cost is adjusted to April 1975 prices using the. En-
gineering News Record building cost index, which rose from 690.48 in 1967
17
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(Engineering News Record, December 19, 1974) to 1,279.1 in April 1975 (~
gineering News Record, May 1, 1975).
Thus, the estimated installed cost
for the roof in April 1975 prices is $3,650 ($1,970 x 1,279.1.\.
690.48)
Additional allowance is made for installation of auxiliary facilities,
which in this case is the 6-in. diameter asbestos cement pipe.
The in-
stalled cost of this pipe is $5.00/linear foot in 1970 prices (Guthrie,
1974).
Assuming the pipe will be 100 ft long, the cost of the pipe, unad-
justed, is $500.
This cost is adjusted to April 1975 prices using the En-
gineering News Record building cost index, which ~ose from 865.62 in 1970
(Engineering News Record, December 19, 1974) to 1,279.1 in April 1975 (En-
gineering News Record, May 1, 1975).
Thus, the estimated installed cost
for the pipe in April 1975 prices is $740 ~500 x l'~~~:i2)'
Over and above the costs given above, there are related indirect con-
struction costs such as engineering, supervision, consulting, soil testing,
etc., that must be added.
These costs are estimated to be 25% of construction
costs for small ponds that cost less than $25,000 to construct (Parker, 1975).
TOTAL COST ESTIMATES FOR THE EVAPORATION SYSTEM
The estimates for the total costs to construct and operate the evapor-
ation system' are presented below in two sections.
The first section gives
the total installed capital investment cost, and the second section gives
the total annual operating cost.
Total Installed Capital Investment Cost
The cost of purchasing and installing the capital equipment and land
has been previously given.
Table 1 summarizes and totals the capital in-
vestment for .the entire evaporation system.
A 30% contingency is added to
the costs to allow for unanticipated expenses (see Appendix A).
18
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Table 1. TOTAL INSTALLED CAPITAL EQUIPMENT AND
LAND COST FOR THE EVAPORATION SYSTEM
Item
Capital Investment C~st
(1975 $)
Land
Excavation
Concrete pond
Built-up five-ply roof
6-in. diameter pipe
Indirect construction
costs
(25%)
500
1,150
8,900
3,650
740
3,600
Subtotal
18,540
Contingency (30%)
5,560
Total
24,100
Annual Operating Costs
The total annual operating costs to operate the system are estimated
below.
Most of these costs are a percentage of either the installed capi-
tal equipment cost or labor costs.
The following list shows all of the
cost items considered in this estimate.
Direct costs
Indirect costs
Materials
Labor
Supervision
Payroll charges
Maintenance .
Operating supplies
Utilities
Laboratory services
Depreciation
Property taxes
Insurance
Capital cost
Plant overhead
Materials - No materials are required.
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Labor - Labor costs are wages paid to operating labor.
The only operating
labor required i~ for sludge. removal from the pond.
The amount of sludge
that accumulates in the pond is unknown, but the quantity of sludge should
be small enough so that removal will only be necessary annually.
An esti-
mated 160 man-hours is required to remove the sludge to a nearby landfill
on the plant grounds.
The hourly earnings of production or nonsupervisory workers in the
---
chemical and allied products industry, as reported. in Monthly Labor Review
(May 1975), was $5.18/hr in March 1975.
For April 1975, the 'estimated wage
rate is $5.20/hr.
This gives .an annual operating labor cost of (160)($5.20)
or $830.
Supervision - Jelen (1970)' reported that supervision of labor is normally
estimated as a percentage of operating labor, a typical value being 20%.
Using 20% of operating labor costs for labor supervision costs gives an es-
timate of $170 for this cost.
Payroll Charges - These costs are the result of the many fringe benefits
employees receive in addition to their salaries.
Recent emphasis on these
benefits in labor contracts makes this cost substantial and it is steadily
increasing with time.
According to Perry and Chilton (1973), the sum of
fringe benefits may add between 15 and 40% to the wage rate of employees,
and this varies widely from company to company.
In this estimate, payroll
charges (fringe benefits) are taken to be 30% of the wages paid to both 1a-
bor and supervision or $300.
20
-------
Maintenance - The annual maintenance cost for an evaporation pond is about
4% of the installed cost (Blecker and Nichols, 1973) or $600.
The annual
maintenance cost for the roof (which involves painting and patching) is
about $200.
These two costs give an annual .maintenance cost of $800.
Operating Supplies - Jelen (1970) reported that the cost of operating sup-
plies is typically 6% of labor costs.
This amounts to an annual cost for
operating supplies of ($830)(0.06) or $50.
Utilities - No utilities are required.
Laboratory Services - Laboratory services furnished to support the monitor-
ing operations are reported by Jelen (1970) to be about 20% of labor costs.
Thus, the annual laboratory service cost for the system is ($830)(0.20) or
$170.
Depreciation - Depreciation is a periodic charge that distributes the in-
stalled capital equipment cost over its expected service life (see Appendix
A).
This cost estimate uses straight-line depreciation and assumes all cap-
ital assets have a zero salvage value.
Blecker and Nichols (1973) reported that the expected life of a sedi-
mentation system is between 25 and 60 years and the life is taken to be 40
years for the purpose of depreciation of the installed costs (see Appendix
A).
The depreciable installed cost is $24,100 (including contingencies)
less the land cost of $500; or $23,600.
(Note:
The roof would probably
not last 40 years, but this fact is disregarded since the roof is only 15%
of the total installed cost.)
21
-------
The annual depreciation cost, then, is $590 ($2~~600) for the entire
evaporation system.
Property Taxes, Insurance, and Capital Costs - Property taxes, insurance,
and capital costs are estimated as a percentage of the installed capital
equipment cost.
These costs are calculated and reported separately in
this report to show the cost breakdown of these three items.
Jelen (1970) reported that property taxes are taken to be 2% of capi-
tal investment cost, and insurance is generally about 1% of capital invest-
ment cost.
Capital cost.(or interest) is a charge to finance the invest-
ment expenditures.
The annual rate of interest has varied widely in the
recent past, and is taken to be 6.3% (see APpendix.~)~
Using the above' percentages gives the following indirect costs for the
entire system:
(a) property taxes - $480; (b) insurance - $240; and (c)
capital cost ~ $1,520.
Plant Overhead - Plant overhead is a charge to the costs of the manufactur-
ing facility which are not chargeable to any particular operation and are
normally charged on an allotted basis.
Overhead includes such cost items
as plant supervision, plant guards, janitors, cafeterias, administrative
offices, accounting, purchasing, etc.
Overhead costs will vary from com-
pany to company, are usually calculated as a percentage of direct labor
cost or a percentage of installed capital investment for the entire facil-
. ity, and are allocated to each operation based on its labor or investment
cost.
22
-------
Jelen (1970) reported that plant overhead .can range from 40 to 60% of
direct labor costs or 15 to 30% of direct costs.
Plant overhead is taken
to be 20% of direct costs in this report.
TO~L COST ESTIMATES
All of the costs estimated previously and the total investment and an-
nual operating costs are given in Table 2.
The table shows that the esti-
mated total installed capital equipment cost for the evaporation system is
------
$24,100 and the estimated total annual operating cost is $5,610.
Based upon an annual production of 1 million pounds of aldrin, the
unit cost of waste disposal of the aldrin-contaminated wastewater is
$0.006/1b aldrin.
23
-------
Table 2. TOTAL INVESTMENT COST AND ANNUAL OPERATING COST FOR THE
EVAPORATION SYSTEM TO TREAT ALDRIN-CONTAMINATED WASTEWATER
Cost item
Cost (1975 $)
Total installed capital equipment cost
24,100
Annual operating costs
Direct costs
--"
Labor
Supervision
Payroll charges
Maintenance
Operating supplies
Laboratory
830
170
300
800
50
170
Subtotal
2,320.
Indirect costs
Depreciation
Property tax~s
Insurance
Capital cost
Plant overhead
590
480
240
1,520
460
Subtotal
3,290
Total annual operating costs
5,610
24
-------
REFERENCES
Blecker, H. G., and T. M. Nichols,
tion Control Equipment Modules -
July 1973.
"Cap~tal and Operating Costs of pollu-
Vol. II - Data Manual," EPA-RS-73-023b,
Chemical Engineering, p. 117, April 28, 1975a.
Chemical Engineering, inside back cover, October 13, 1975b.
Engineering News Record, May 1, 1975.
Engineering News Record, December 19, 1974.
Ferguson, T. L., and E. W. Lawless, report on plant visit to Shell Chemical
Company, Denver, Colorado (1971).
. Ferguson, T. L., and A. E. Meiners, "Wastewater Management Review No. I--
Aldrin/Dieldrin," EPA Contract No. 68-01-2579, May 1974.
Guthrie, K. M., Process Plant Estimating Evaluation and Control, Craftsman
Book Company of America, Solana Beach, California (1974).
Jelen, F. C., Cost and Optimization Engineering, McGraw-Hill Book Company,
New York (1970).
Knaus, J. H., Plant Manager, Shell Chemical Company, personal communication
to T. L. Ferguson and E. W. Lawless during plant visit, Denver, Colorado,
October 7, 1971 (Cf. Ferguson and Lawless, 1971). .
Lawless, E. W., T. L. Ferguson, and R. von RtWker, "Pollution Potential in
Pesticide Manufacturing," Final Report by Midwest Research Institute on
Contract No. 68-01-0142 for the Environmental Protection Agency, June
1972 (NTIS Nos. PB-213, 782/3).
Martin, A. J., General Manager, Manufacturing and Distribution, Shell Chem-
ical Company. Letter to C. E. Mumma, Senior Chemical Engineer, Midwest
Research Institute, July 16, 1975.
Monthly Labor Review, Vol. 98, No.5, May 1975.
Mumma, C. E., letter to A. J. Martin, General Manager, Manufacturing and
Distribution, Shell Chemical Company, Houston, Texas, July 1, 1975.
25
-------
Parker, C. L., "Estimating the Cost of Wastewater Treatment Ponds," Pollu-
tion Engineering, Vol. 7, No. 11, November 1975.
Perlman, H. L., Chief Administrative Law Judge, Accelerated Decision, in re:
Shell Chemical Company et a1., Registrants, I.F. & R. Dockets Nos. 145 et
a1., May 27, 1975.
Perry, R. H., and C. H. Chilton, Chemical Engineer's Handbook, 5th Ed.',
McGraw-Hill Book Company, New York (1973).
Peters, M. S., and K. D. Timmerhaus, Plant Design and Economics for Chemi-
cal Engineers, 2nd Ed., McGraw-Hill Book Company, New York (1968).
Shell Chemical Company, News Release, April 18, 1975.
U.S. Court of Appeals for the District- of Columbia Circuit in Environmental
Defense Fund, Inc., et a1. versus Environmental Protection Agency et a1.,
510 F. 2d 1292 (1975). The April 4, 1975, decis ion in the aldrin/dieldrin
suspension proceedings.
U.S. Environmental Protection Agency, "Development Document for Effluent
Limitations Guidelines and New Source Performance' Standards for the Major
Inorganic Products Segment of the Inorganic Chemicals Manuf~cturing Point
Source Category," EPA-440/1-74-007a, March 1974.'
v
-------
APPENDIX A
DEFINITION OF TERMS AND DISCUSSION OF CONVENTIONAL
ENGINEERING PRACTICES USED IN ESTIMATING COSTS
OF PESTICIDE WASTEWATER TREATMENT PROCESSES
A-l
-------
Several terms used. in the cost estimates requir.e further defini-
tion and have been placed in this appendix to avoid' a lengthy discus-
sion in the text of the report.
The terms which are defined and dis-
cussed in this appendix are (a) limits of error for cost estimates, (b)
cost indexes, (c) six-tenths factor, (d) one-fourth factor, (e) payroll
charges, (f) pperating supplies, (g) control laboratory costs, (h) main-
,_. .
tenance and repairs, (i) depreciation, (j) capital cost, (k) plant over-
.--
- .. _.. . .
head, and (1) contingency for capital investment.
LIMITS OF ERROR FOR COST ESTIMATES
The probable limits of error for the study cost est~mates in this
report range from 30% above to 30% below the actual costs.
Study cost
estimates are commonly used to estimate the economic feasibility of a
project before expending significant funds for piloting, market studies;-
land surveys, and requisitions.
They may be off by 30% but they can be
prepared at relatively low costs using minimum data as follows (see Fig-
ure A-I).
Location of site;
Rough sketches of process flow;
Pr~liminary sizing and material specifications of equipment;
Approximate sizes of buildings and structures;
Rough quantities of utilities;
Preliminary piping;
Preliminary motor list; and
E~g~n~ering and drafting man-hours.
A-2
-------
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A-3
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-------
COST INDEXES (Peters and Timmerhaus, 1968)
Most cost data which are available for immediate use in a prelimi-
nary or predesign estimate are based on conditions at some time in the
past.
Because prices may change considerably with time, due to changes
in economic conditions, some method must be used for converting costs
applicable at a past date to equivalent costs that are essentially cor-
rect at the present time.
This can be done by the use of cost indexes.
-----
A cost index is merely a number for a given. year showing the cost
at that time relative to a certain base year.
If the cost at some time
in the past is known, the equivalent cost at the present time can be
determined by multiplying the original cost by the ratio of the present
index value to the index value applicable when the original cost was
obtained.
Present cost =
original cost index value at present time
index value at time original cost was obtained
Cost indexes can be used to give a general estimate, but no index
can take into account all factors, such as special technological ~dvance-
ments or local conditions.
The common indexes permit fairly accurate
estimates if the time period involved is less than 10 years.
Many different types of cost indexes are published regularly.
A-4
-------
En~ineering News-Record Construction Cost Index
Relative construction costs at various dates c~n be estimated by
use of the Engineering News-Record construction index.
This index
shows the variation in labor rates and materials costs for industrial
construction.
It employs a composite cost for 2,500 lb of structural
steel, 1,088 .fbm of lumber, 6 bbl of cement, and 200 hr of common labor.
The index is usually reported on one of three bases:
an index value of
100 in 1913, 100 in 1926, or 100 in 1949.
Marshall and Swift (Formerly Marshall and Stevens) Equipment-Cost Indexes
The Marshall and Stevens equipment indexes are divided into two cate-
gories.
The all-industry equipment index is simply the arithmetic average
of the individual indexes for 47 different types of industrial, commercial,
and h~using e~uipment.
The process-industry equipment index is a weighted
average of eight of these, with the weigh~ing based on the total product
value of the various process industries.
The percentages used for the
~eighting in a typical year are as follows:
cement, 2; chemicals, 48;
clay products, 2; glass, 3; paint, 5; paper, 10; petroleum, 22; and rub-
ber, 8.
The Marshall and Stevens indexes are based on an index value of 100
for the year 1926.
These indexes take into consideration the cost of
machinery and major equipment plus costs for installation, fixtures, tools,
office furniture and other minor equipment.
A-5
-------
Chemical En~ineerin~ Plant Construction Cost ,Index
Construction costs for chemical plants form the basis of the Cherni-
cal En~ineerin~ plant construction cost index.
The four major components
of this index are weighted in the following manner:
equipment, machinery,
and supports, 6lj erection and installation labor, 22j buildings, mate-
rials, and labor 7j and engineering and supervision manpower, 10.
The
major component, equipment, is further subdivided and weighted as follows:
----
fabricated equipment, 37j process machinery, 14jpipe, valves, and fit-
tings, 20j process instruments and controls, 7j pumps and compressors, 7;
eletrica1 equipment and materials, 5; and structural supports, insulation,
and paint, 10.
All index components are based on 1957 to 1959 m 100.
SIX-TENTHS FACTOR (Perry and Chilton, 1973)
Cost estimates in this report are given for processes that require
scaling up from a given capacity to a larger capacity (e.g., 100 gpm to
300 gpm and 600 gpm).
Equipment size and costs were shown to correlate
fairly well by the logarithmic relationship known as the "six-tenths
factor."
The simple form of this method is:
C = rO.6 C
n
where
Cn
is the new plant cost,
C
is the previous plant cost, and
r
is the ratio of the new capacity to the old capacity.
This method is the best available for estimating the cost of the ,sys-
tems in this report since each system involves multiple pieces of equip-
ment, piping, instrumentation, etc.
The exponent actually ranges from
A-6
-------
0.45 to 1.15 for different pieces of equipment, but in complex systems,
such as the ones dCBcrLbed in this report, estimating the new capacity
cost for each piece of equipment is beyond the scope of this study.
Therefore, when scaling the costs up, for example, from a 100 gpm
plant size to other plant sizes, the exponent 0.6 is used as an approxi-
mation of the scale-up factor for the entire system.
In each case, some
error may be involved using this method, but no other method is available
for this study.
ONE-FOURTH FACTOR (Peters and Timmerhaus, 1968)
The "one-fourth factor" uses the same principle as the "six-tenths
factor" with the exception that the exponent 0.25 is used instead of 0.6.
This factor is used to scale up labor requirements from one plant size
to a larger plant size, and takes into account the fact that larger plant
sizes require less than proportional labor forces due to economies of
scale.
PAYROLL CHARGES
These costs are the result of the many fringe benefits employees
receive in addition to their salaries.
Recent emphasis' on these bene-
fits in labor contracts make this cost substantial and it is steadily
increasing with time.
The sum of fringe benefits may add between 15 and
40% to the wage rate of employees (Perry and Chilton, 1973), and the " per-
centage varies widely from company to company.
In this report, payro\l
\
charges (fringe benefits) are estimated to be 30% of the wages paid to
both labor and supervision.
A-7
-------
OPERATING SUPPLIES
Operating supplies are items such as lubricating oil, instrument
charts, etc., that are neither raw nor repair materials.
The cost of
these items is typically about 6% of operating labor (Jelen, 1970).
CONTROL LABORATORY COSTS
Depending on company practice and the type of project, operating
costs may include several charges by other units of the company, e.g.,
charges by a control laboratory.
Laboratory costs may be estimated as a percentage of operating
labor cost, in the range of 3 to 10%, but the complex situations as
highoas 20% (Jelen, 1970).
Since treatment systems require more labora-
tory support than °typical production processes, in this report the cost
of these services is estimated to be.20% of operaOting labor costs.
MAINTENANCE AND REPAIRS (Peters and Timmerhaus, 1968)
A considerable amount of expense is necessary for maintenance and
repairs if a plant is to be kep~ in efficient operating condition.
These
-
expenses include the cost for labor, materials, and supervision.
Annual costs for equipment maintenance and repairs may range from
as low as 2% of the equipment cost if service demands are light to 20%
for cases in which there are severe operating demands.
The annual main-
tenance costs. are given separately for each process in this report, and
range from 5 to 15% of the capital equipment cost of the various processes.
A-8
-------
DEPRECIATION
Depreciation is a periodic charge that distributes the installed
capital investment cost over its expected service life.
Instead of
charging the cost of the equipment as an expense in the year of pur-
chase, a portion of its cost is charged against revenues each year
throughout its estimated useful life.
In this report the estimated useful life is determined by using the
--.
arithmetic average of the high and low lifetimes of equipment when a
range is given, or 10 years if the useful life is unknown.
In some
cases, the useful life may be too high by U.S. Treasury Department Stan-
dard.Guidelines (such as the 40-year life for the sedimentation process)
which allows an 11 year depreciation for chemical plant equipment (Perry
and Chilton, 1973).
However, using 11 years for all equipment would either
understate or overstate the real cost in most circumstances.
When the use-
ful life is unknown, 10 years is used to conform to the guidelines of the
federal government.
A zero salvage value is assumed in all depreciation estimates and
straight-line depreciation is used.
. .
CAPITAL COST
Regardless of whether the capital investment is to be obtained from
company funds or made available by bankers, it is logical that the in-
vested capital earn a fair interest.
If the company funds are not used
A-9
-------
for the new unit, then they could be invested to bear a reasonable in-
terest.
If the capital is raised by issuing bonds 'or by borrowing from
another corporation, interest would be paid the investor.
It snould be
pointed out that in order to offer a company the incentive to invest its
money in a new plant, it should be able to realize as large an interest
rate as it could earn by making other investments.
Since the risk is
somewhat higher than certain conservative investments. the interest rate
should be higher than that offered by these securities.
Excessive in-
terest rates are not realistic in view of today's regulatory laws.
Nor-
mally, an interest rate of from 6 to 8% on the unpaid principal is con-
sidered satisfactory.
In computing interest, it is necessary to remember that the amount
of interest will decrease each year since the unpaid balance is reduced
by the depreciation allowed the previous year.
An interest rate of 10%
would average approximately 6.3% of the total principal each year if the
principal is repaid in 10 annual installments.
It is customary to ex-
press the interest as a uniform fixed cost item each year.
An interest rate of 10% is used in these estimates based on the
cost literature (Chemical Engineerin~, 1975).
In reali~y, the interest will decline each year and, therefore, the
payment on the principal will increase if uniform principal plus inter-
est payments are made.
Uniform payments for Q periods required to pay
the original sum P can be 'computed from the' following equation (Petroleum
Refiner, 19~7).
A-10
-------
R = P in + On
(1 + i) n - 1
where
P c original sum
R = uniform periodic payment
n = number of payments
i = interest rate as fraction per period
,
The expression (1 - i)n is the compound interest expression found in
table form in many handbooks (Lange, Handbook of Chemistry).
Value of
i(1 + i)n/(l + i)n - 1 for various values of nand
i
are listed
below (Petroleum Refiner, 1957).
Values of
1(1 + 1)n
(1 + On - 1 .
n 2% 4% 6% 8% 10%
1 1.020 1.040 1.060 1.080 1.100
5 0.212 0.225 0.237 0.250 0 . 26.4
10 0.111 0.123 0.136 0.149 0.163
If the original investment was $1,000,000 and the loan was at 10%
interest for 10 years, the uniform payment would be
R = (1 000 000) 0.1(1 + 0.1)10
, , (1 + 0.1)10 - 1
R = 163,000
In 10 years the total payment would be $1,630,000.
Thus, the total
interest is $630,000 and the average interest rate would be
630,000
10(1,000,000) = 6.3%/year
A-ll
-------
-
PLANT OVERHEAD
Plant overhead is a charge to the costs of the manufacturing facil-
ity which are not chargeable to any particular operation and are normally
charged on an allotted basis.
Overhead includes such cost items as plant
supervision, plant guards, janitors, cafeterias, administrative offices,
accounting, purchasing, etc.
Overhead costs will vary from company to
company and are usually calculated as a percentage of direct labor cost
--
or a percentage of installed capital investment for the entire facility,
and allocated to each operation based on its labor or investment cost.
Plant overhead can range from 40 to 60% of direct labor costs or 15
to 30% of direct costs (Jelen, 1970).
We estimate that plant overhead
is 20% of direct costs in this report.
CONTINGENCY FOR CAPITAL INVESTMENT (Fowler, 1975)
1he selection of a contingency figure for an estimate i8 a matter
of the judgment of the estimator.
This judgment must consider several
factors~ such as:
(1)
Data basis--laboratory, pilot or plant
(2)
Allowance for inflationary trends
(3)
Knowledge of construction costs at plant location
-- .
Under favora~le conditions, the contingency factor may be as low as
10%.
However, lacking actual plant cost and considering present infla-
tionary trends, a contingency figure of 30% would be justified.
A-12
-------
~
In the past, cost indexes have been a reliable method of esti-
ullltinK COHt hOtH.'O upon plant costa in cl1rlh'r years.
The plant Ino~xeH
are more reliable when used on plant cost rather than pilot plant costs.
It is much more difficult to use them successfully when equipment is
pilot plant size or when a small amount of equipment is used.
The use
of the indexes in the last 2 years has not been as accurate as in the
past and can result in too low a plant estimate.
Uncertainty increases
if cost indexes are used to update plant estimates rather than actual
costs.
Unless the estimator has made the original estimate or knows what
the plant costs include, a large amount of uncertainty exists when pro-
jecting plant costs to other plant capacities and times.
It is necessary
to know whether a plant investment includes the cost of utilities, such
as a steam boiler or cooling tower, or whether steam and utilities are
available at the battery limits of the unit in any amount required.
It
is also important to know whether the plant investment includes the cost
of the land and site preparation.. Only if these factors are known can
the contingency factor be kept to a reasonable figure of 30% or lower.
A-l3
-------
~
REFERENCES
1.
Chemical Engineering, p. 89, July 21, 1975.
2.
Fowler, F. C., Chemical Engineering Consultant to Midwest R~search
Institute and President of Research Associates, Kansas City,
Missouri, Personal Communication to C. E. Mumma, October 15, 1975.
3.
Jelen, F. C.~ Cost and Optimization Engineering, McGraw-Hill Book
Company, New York (1970).
4.
Perry, R. H., and C. H. Chilton, Chemical Engineers Handbook, 5th Ed.,
McGraw-Hill Book Company, New York (1973).
5.
Peters, M. S., and K. D. Timmerhaus, Plant Design and Economics for
Chemical Engineers, McGraw-Hill Book Company, 2nd Ed. (1968).
6.
Petroleum Refiner, Process Design Primer, September 1957.
A-14
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BIBLIOGRAPHIC DATA 11. Report No.
SHEET :EPA-440/9-76-007
4. Title and Subtitle
r2.
3. Recipient's Accession No.
Wastewater Treatment Teclmo1ogy Documentation, 1-fanufacture
of A1drin/Die1drin
5. Reoort Date
Pub. Jtme
1976
6.
7. Author(s)
Alfred F. Meiners, Charles E. Mumma:,
9. Performing Organization Name and Address
r-fidwest Research Institute
425 Volker Boulevard
Kansas City, Missouri 64110
Gary L. Kelso
Thomas L. FerlZUSon and
8. Performing Organization Rept.
No. 4127-C
10. Project/Task/Work Unit No.
.
11. Contract/Grant No.
68-01-3524
12. Sponsoring Organization Name and Address
Office of Water P1arurl.ng and Standards
U.S. Environmental Protection Agency
401 r-f Street, SW
Washington, D. C. 20460
15. Supplementary Notes
13. Type of Report & Period
Covered
Interim Report. Edited
14.
Some editing was perfonned by EPA.
16. Abstracts
This report was prepared to provide tecJmo1ogic supporting infonnation for toxic
pollutant effluent standards proposed Dr EPA under S307(a) of the Federal Water
Pollution Control Act Amendments of 1972. The report identifies potential
technologies, assesses implementation feasibility, estirna tes final effluent
characteristics and estimates installation and operation costs for Aldrin/Dieldrin
manufacturers.
"
17. Key Words and Document Analysis.
17a. Descriptors
'\'astewater
Waste Treatment
Cost Analysis
Cost Comparison
Pesticides
Manufacturers
17~ Identifiers/Open-Ended Terms
Toxic Pollutant Effluent Standards
Federal '~ater Pollution Control Act
17c. COSA TI Field/Group
18. Availability Statement
FORM NTIs.n (REV. 10-73)
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19.. Security Class (This
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21. 'N'o. of Pages
I
48 tJ~
22. Price
.,. '/, 00
Release tm1imi ted
USCOMMoDC BZ5S-P74
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INSTRUCTIONS FOR COMPLETING FORM NTIS.35 (Bibliographic Data Sheet based on COSATI
Guid~lines to Format Standards for Scientific and Technical Reports Prepared by or for the Federal Government
" ,
PB-180 600).
1.
Report Number. Each individually bound report shall carry a unique alphanumeric designation selected by "the performing
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2. Leave blank.
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. - .
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22.
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P'ORM NTIs-se (REV. 10'73'
USCOMM.OC 82oa.P74
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