Document'No' P-2181
April 1976
Prepared for
United States Environmental Protection Agency
Water Planning Division
EPA Contract No. 68-01-3559
DRAFT
Pretreatment
guidance manual
for state and
areawide (208)
water quality
management
planning
agencies
Volume 1
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FOREWORD ON THE USE OF THIS MANUAL
The Environmental Protection Agency is currently reviewing
its position on pretreatment policies, guidelines,regulations,
and standards are all being reconsidered by an EPA Pretreatment
Task Force. The goal of the task force is to develop a coordinated
strategy for pretreatment which integrates the Federal roles of
standard setting, guidelines development and enforcement with the
roles of State and local governments.
This manual is being issued now in draft form for use by those
areawide water quality management (208) planning agencies which have
specified pretreatment and industrial treatment and collection systems
as priorities and which must take immediate actions to include the
solutions to such problems in their water quality management plans.
Several major topics presented in this manual are issues which
are currently under review by the Pretreatment Task Force. These are:
. the manner in which Federal pretreatment standards should be
set
. enforcement of Federal pretreatment standards
. Federal view of intergovernmental relations regarding pre-
treatment
. revision of the general pretreatment regulation, 40 CFR 128,
to reflect EPA's new positon when it is developed
Where such topics are discussed throughout the manual they have been
marked up to show that they are under review. On page 1-10, for example,
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there is a box containing a definition of major contributing
industries taken from the current general pretreatment regulation
(40 CFR Part 128). This box has been marked up to indicate that
the whole concept of MCI's is being rethought. The Federal
Government is considering a number of alternative approaches to
developing standards such as preserving an economic equity between
the direct discharger to a receiving water and an indirect discharger
to a sewer or preserving water quality equity to the stream by
equalizing the environmental impacts from direct and indirect dis-
chargers.
Throughout the manual reference is made to a second volume of
the manual containing appendices. The material in these appendices
has been judged to.be so subject to- change that the second volume is*
not being distributed at this time.
EPA's Pretreatment Task Force 'is planning to have outstanding
issues resolved and a coordinated pretreatment strategy developed by
October, 1976. At such time this manual will be revised and issued
in final form.
U
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PREFACE
This two volume manual contains a comprehensive work-
ing review and analysis of the pretreatment issue. The
manual is designed especially for State and Areawide Water
Quality Management Planning (208) Agencies. As such, the
information presented in the manual will enable planners and
their consultants to more effectively incorporate pretreat-
ment into their planning functions.
The manual was prepared by Process Research Division
of Environmental Research and Technology, Inc. under an EPA
contract (No. 68-01-3559) to the Water Planning Division.
Three of the 8 membered project staff were recruited from
the firms of Urban Systems Research and Engineering, Inc. of
Cambridge, Massachusetts and from the law firm of Bracken,
Selig and Padnos of Boston, Massachusetts.
The project staff appreciates the guidance and support
provided by the Water Planning Division of EPA. The staff
also thanks Gary Ctakie, Municipal Construction Division,
Office of Water Program Operations for his cooperation and
support as well as local 208 'agency staffs who contributed
to the project.
Project Officer_
Project Director
Project Staff
Jeffrey Goodman
Sam Fogel, Ph.D.
Irvine Wei, Ph.D.
Neil Shifrin
Alan Gradet
Paula Schenck
Thomas B. Bracken
Michael R. Alford
Elizabeth E. Lake
EPA
Process Research
Division
Law firm of Bracken,
Selig and Padnos,
Boston, Massachusetts
Urban System Research
and Engineering, Inc.
Cambridge, Mass.
U.S.R.E., Inc.
111
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ABSTRACT
The U.S. Environmental Protection Agency recognizes the need
for Federal, State and Local management programs regulating
industrial point source discharges to municipal sewer systems.
(The ultimate purpose of these pretreatment programs is to pre-
vent the introduction of incompatible pollutants to Publicly
Owned Treatment Works (POTWs) which would result in either
upset of the treatment plant's unit processes or pass-through
of toxic materials to receiving bodies of water.\
This manual is designed for use by State and Areawide (208)
Water Quality Management Planners part of whose job it is
to plan for the establishment of regulatory and enforcement
programs governing the discharge of industrial wastewaters
to municipal systems. The manual includes an analysis of the
pretreatment issue from a Federal, State and Local viewpoint
(Chapter 1) as well as descriptions of the critical management
elements in pretreatment programs such as industrial waste
surveys, monitoring programs, sewer use ordinances, enforce-
ment mechanisms, legal consideration, financial considerations
and possible management functions (Chapter 2). Chapter 3
provides a technical review of pollutants which can interfere
with or pass-through a treatment plant and sample calculations
for estimating the tolerance limits of treatment plant unit
processes to various organic and inorganic compounds. The
final chapter in Volume I provides three case studies on
actual-ongoing pretreatment programs.
Volume II is an appendix to the actual manual and includes
a compilation of Federal minimum pretreatment standards, a
monitoring supplement, a sample ordinance and permit from
the California Water Quality Board and a copy of 40CFR128,
the general pretreatment standard.
This report was submitted in fulfillment of contract No.
68-01-3559, by Process Research Divison of Environmental
Research and Technology, Inc. under sponsorship of the U.S.
Environmental Protection Agency. Work was completed in
April of 1976.
v
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TABLE OF CONTENTS
Page
PREFACE iii
ABSTRACT V
LIST OF FIGURES xi
LIST OF TABLES xii
INTRODUCTION XV
CHAPTER 1: OVERVIEW 1-1
1.1 INTRODUCTION 1-1
1.2 THE PRETREATMENT ISSUE 1-1
1.2.1 Perspective on Pretreatment:
What is it and why is it necessary? 1-1
1.2.2 How Does Pretreatment Interact With
PL92-500 Especially With Water
Quality Management (208) Planning? 1-1
1.3 THE DESIGN AND ADMINISTRATION OF PRETREAT-
MENT PROGRAMS 1-18
CHAPTER 2: MANAQEMENT PROGRAMS . 2-1
2.1 INTRODUCTION 2-1
2.2 OUTLINE OF MANAGEMENT PROGRAM ELEMENTS 2-2
t
2.3 TECHNICAL CONTROL ELEMENTS FOR INDUSTRIAL
POLLUTANTS DISCHARGED TO SEWERS 2-5
2.3.1 Introduction 2-5
2.3.2 The Industrial Waste Survey 2-9
2.3.3 Monitoring Program Options 2-15
2.3.4 Monitoring Techniques 2-23
2.3.5 Development of the Sewer Use
Ordinance for an Industrial
Pollutant Control Program 2-23
2.4 LEGAL MANAGEMENT ELEMENTS 2-39
2.4.1 Introduction 2-39
2.4.2 Federal Role 2-40
2.4.3 Federal Means of Control 2-41
2.4.4 State Role 2-47
2.4.5 Local Role 2-50
2.4.6 Legal Aspects of Citizen Partici-
pation in a Pretreatment Program 2-60
Vll
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TABLE OF CONTENTS (CONTINUED)
Page
2.5 ECONOMIC AND FINANCIAL ELEMENTS 2-62
2.5.1 Basic Benefits and Costs of
Joint Treatment for Industries 2-62
2.5.2 Economic Impacts of Pretreatment
Standards 2-63
2.5.3 Economic Efficiency 2-66
2.5.4 Other Considerations 2-68
2.5.5 The Identification of Affected
Firms 2-29
2.5.6 Assistance to Industries 2-73
2.6 PUBLIC PARTICIPATION 2-76
2.6.1 Legal Requirements 2-76
2.6.2 Public Participation with Pre-
treatment Planning 2-77
2.6.3 Advisory Committees 2-77
2.7 PROBABLE MANAGEMENT FUNCTIONS IN A
PRETREATMENT CONTROL PROGRAM 2-80
2.7.1 NPDES Permits 2-80
2.7.2 Industrial Waste Surveys 2-81
2.7.3 Enforcement of Pretreatment 2-81
2.7.4 Public Participation 2-81
2.7.5 Variance 2-83
REFERENCES
CHAPTER 3: POLLUTANTS WHICH PASS THROUGH OR
INTERFERE WITH POTWS 3-1
3.1 INTRODUCTION 3-1
3.2 POLLUTANTS WHICH AFFECT WASTEWATER
COLLECTION WORKS 3-3
3.2.1 Explosive and Flammable Materials 3-3
3.2.2 Corrosive Materials ' 3-4
3.2.3 Materials Which Cause Flow
Obstruction 3-4
Vlll
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TABLE OF CONTENTS (CONTINUED)
Page
3.3 POLLUTANTS WHICH INTERFERE WITH BIOLOGI-
CAL TREATMENT PROCESS 3-6
3.3.1 Excessive Fluctuations of Hydraulic
and/or Pollutant Discharge 3-7
3.3.2 Heat 3-9
3.3.3 Inorganic Pollutants 3-10
3.3.4 Organic Pollutants 3-14
3.3.5 Pollutants Which Interfere With
Land Treatment 3-16
3.4 POLLUTANTS WHICH PASS THROUGH TREATMENT
WORKS 3-24
3.4.1 Average Performance of Primary
and Biological Treatment Plants 3-24
3.4.2 Impact of Pollutants on Receiving
Waters 3-36
3.5 POLLUTANTS WHICH AFFECT SLUDGE DISPOSAL 3-48
3.5.1 Introduction 3-48
3.5.2 Sludge Composition 3-48
3.5.3 Sludge Disposal Options 3-52
3.5.4 Impacts of Industrial Waste
Discharges on Sludge Disposal
Options 3-53
3.5.5 Determination of Metal Content of
Sludges and Estimation of the Impact
of an Industrial Metal Discharger on
Sludge Quality 3-60
3.5.6 Planning Implications for Sludge
Disposal 3-63
3.6 DETERMINATION OF PRETREATMENT REQUIREMENTS 3-65
3.6.1 Federal Pretreatment Standards 3-65
3.6.2 Local Pretreatment Requirements 3-65
3.6.3 Sample Calculations 3-67
3.6.4 Pilot Testing 3-70
REFERENCES 3-72
IX
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TABLE OF CONTENTS (CONTINUED)
Page
CHAPTER 4: CASE STUDIES 4-1
4.1 INTRODUCTION . 4-1
4.2 CASE STUDY I 4-1
4.2.1 Introduction 4-1
4.2.2 Overview 4-2
4.2.3 Presentation of WQM Pretreatment
4-2
Program
4.2.4 Pretreatment Issues - Analysis of
Specific Issues and Program
Elements 4-8
4.3 CASE STUDY II 4-18
4.3.1 Introduction 4-18
4.3.2 Overview 4-19
4.3.3 Description of Major Program
Elements, City A 4-20
4.3.4 Description of Major Program
Elements, City B 4-29
4.4 CASE STUDY III 4-32
4.4.1 Introduction 4-32
4.4.2 Inventory of Non-Domestic
Dischargers 4-33
4.4.3 Ordinance Development 4-35
4.4.4 Outline of Projected Pretreatment
Plan 4-36
x
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TABLE OF CONTENTS (CONTINUED)
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
SIC Code Numbers and Suiranary of
Pretreatment Standards for Existing
and New Sources
Monitoring Supplement
Sewer-Use Ordinances
40 CFR128 Pretreatment Standards,
General Guidelines
Figure
1-1
1-2
2-1
2-2
2-3
3-1
LIST OF FIGURES
Industrial Point Source Control
Pretreatment As Part of the Planning
Process
Industrial Waste Management
Development and Administration of an
Industrial Pretreatment Program
Industrial Waste Survey
Routes of Formation of Two Different
Sludge Types
Page
1-9
1-12
2-3
2-4
2-11
3-49
XI
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LIST OF TABLES
Page
Table
1-1 Institutional Relationships 1-6
2-1 Pretreatment Management Program
Elements 2-6
2-2 Partial List of References For the
Characterization of Industrial Waste 2-14
2-3 Suggested Sampling or Composting
Schedule 2-24
2-4 Volume of Sample Required For Deter-
mination of the Various Constituents
of Industrial Water 2-27
2-5 Schedule of Fees - Water Analysis 2-29
2-6 Information Required to Develop an
Industrial Sewer Use Ordinance 2-34
2-7 Enforcement Matrix of Pretreatnent
Regulations
2-8 Industrial Usage of POTWS • 2-72
2-9 Distribution of Industrial Impacts -
Plant Closures, Subcategories, Products,
and Region—For Selected Industries 2-74
2-10 Forms of Financial Assistance Available
For Pretreatraent Expenditures 2-75
3-1 Threshold Concentrations of Inorganic
Pollutants that are Inhibitory to
Biological Treatment Processes (3) 3-12
3-2 Threshold Concentrations of Organic
Pollutants that Are Inhibitory to
Biological Treatment Process (3) 3-17
3-3 Suggested Values For Major Inorganic
Constituents in Water Applied to the
Land (5) 3-22
3-4 Recommended and Estimated Concentrations
of Trace Elements in Irrigation Waters (6) 3-23
3-5 Distribution of Surveyed Treatment Plants
by Plant Process 3-25
XII
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LIST OF TABLES (Continued)
Page
Table
3-6 ; Characterization of Primary and Biologi-
cal Plant Performance 3-27
3-7 Effluent Data Summary For Primary Trick-
ling Filter and Activated Sludge Plants
(Selected Parameters) 3-29
3-8 Removal Data Summary* For Primaary,
Trickling Filter and Activated Plants
(Selected Parameters) 3-30
3-9 Correlation Coefficients: . Influent Vs.
Effluent Concentrations 3-31
3-10 Removal in Biological Plants With Chemi-
cal Addition, and Tertiary Plants 3-32
3-11 Removal and Effluent Data Summary For
Oil and Grease, Cyanide and Hexavalent
Chromium 3-33
3-12 Trace Metal Removal Efficiencies of the
Secondary Treatment Process at Hyperion
Wastewater Treatment Plant From Chen
et al (8) 3-35
3-13 Recommended (U. S. EPA) Safe Limits For
Pesticides in Drinking Water Supplies* 3-42
3-14 Possible Effects and Recommended Limits
For Industrial Waste Components 3-43
3-15 Chemical Composition of Low and High
Metal Sludge (12) 3-50
3-16 Impact of Industrial Chemical on POTW
Sludge Disposal Options 3-54
3-17 Reaction of Metals in Aquifers (17) 3-57
3-18 Materials Prohibited From Ocean Dumping
in Other Than Allowable Quantities (18) 3-61
3-19 Sample Calculations Showing the Relation-
ship Between POTW Size, Industrial Metal
Discharges and the Resulting Metal Con-
tent of Sludge 3-62
xiii
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LIST OF TABLES (Continued)
Page
Table
3-20 WQM (208) Areawide Planning - Pretreat-
ment and Municipal Sludge Management 3-64
4-1 WQM (208) Industrial Wastes Program Con-
trol of Pollution From Industrial Sources 4-4
4-2 Summary of Level One Data 4-5
4-3 Summary of Industrial Survey: City A 4-7
4-4 Summary of Industrial Survey: City B 4-7
4-5 Summary of Area Treatment Facilities 4-9
4-6 Waste Materials From Metal Plating and
Finishing Industries Which Can Contami-
nate Sludges 4-1-3
4-7 Alternative Practices and Major Consid-
erations in Residuals Management 4-15
4-8 Employment Characteristics of 208 Area 4-19
4-9 Sewer Authority Industrial Waste Survey
Summary of Industrial Surcharges 4-23
4-10 Sewer Authority Industrial Waste Survey
Summary of Industries Found in Violation
of BSA Sewer Ordinances 4-24
4-11 Sewer Authority Industrial Waste Survey
Sampling Summary 4-25
4-12 Sewer Authority Industrial Waste Survey
Heavy Metal Loading From Major Contribut-
ing Industries Sampled During Phase II
Program 4-26
4-13 Metals Discharge Concentration Limits 4-27
4-14 Industrial Discharges (1970), City B 4-30
4-15 Average Daily Flow and Loadings Used For
the Design of City B Treatment Plant
(1990) 4-31
4-16 Compatible Pollutants For City B Treat-
ment Facility as Defined in the Sewer
Use Ordinance 4-32
4-17 Mean Sewage to Water Ratios 4-34
XiV
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foul smelling rivers were evident to even an environmentally
insensitive populace. To avoid treatment plant upsets and
the resulting undesirable impacts on receiving waters, many
cities began to specify in addition to the general prohib-
itions mentioned above, quantitative limitations on specific
industrial wastes discharged to sewers. These limitations
were legally incorporated into municipal ordinances. The
employment of the ordinance as an effective device for con-
trol of sewer users developed only after the municipality
clearly established its own authority over its service area.
For many large metropolitan areas this has frequently taken
decades as illustrated by the chronology of events shown on
page iii for New York City(l) .
During the 1960's, public consciousness of environment-
al issues increased. Previously less appreciated impacts of
incompletely treated sewage began to be widely understood.
For example, the role of nutrients in causing eutrophication
of rivers and lakes was clearly documented and highly pub-
licized. In response, treatment of industrial and domestic
wastes began to emphasize nutrient removal processes. This
trend is still under way.
As sewage treatment plants increase their effective-
ness in removing traditional types of carbonaceous wastes
and extend removal to nutrients, the inner workings of the
treatment process become more complex and more susceptible
to upset. For example, plant upset is more likely when
such sensitive biological processes as nitrification and
denitrification are used. More stringent pretreatment
requirements are being developed by both local and fed-
eral governments to prevent plant upsets. However, even
the development of a pollutant standard does not mean that
a municipality can effectively use it as a means of control.
This is indicated by the fact that the ordinance, the most
widely used legal device for controlling sewer use is in
many circumstances ineffectively enforced.(2) The reasons
for this are complex. A basic factor such as public
xvi
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Pretreatment;
Control measures and practices including treatment tech-
niques, process and procedure innovations, operating methods
and others for wastewaters from non-domestic point sources
before introduction into the joint treatment works.
Joint Treatment Works:
Treatment works for both domestic and industrial wastewater.
INTRODUCTION
Pretreatment of industrial and commercial wastewater
prior to discharge to municipal sewers has been carried out
ever since sewers were first built to convey wastes away
from their origin. Historically sewage treatment did not
»
exist prior to the late 19th century; collected sewage was
simply discharged directly to receiving waters. In this
historic perspective pretreatment concerns were predominant-
ly directed towards preventing explosions, physical block-
age and physical or chemical disintegration of sewers. Con-
siderably more attention was directed toward possible dis-
ruptions originating from commercial than from industrial
sources due to the latter's historic tendency to locate on
and directly discharge to water bodies. Similarly, when
sewage treatment plants (joint treatment works) came on line
in the early 1900's it was the hazards of explosion,
physical blockage and chemical effects on the 'sewerage
works itself which were the main concerns.
Later, in the mid 1950's, as the need for more effic-
ient sewage treatment increased, the need to prevent treat-
ment plant upsets became more critical. The effects of
discharging poorly treated sewage were dramatized by result-
ing low oxygen levels in receiving waters: fish kills and
xv
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Chronology of New York City's Effort
To Define its Service Area Authority (1)
1898 New York City centralized control over sewer-use,
jurisdiction extended over entire city.
1901 Control was decentralized - 5 borough presidents
gained exclusive authority over sewers.
Limitations on sewer use at this time primarily
concerned with assuring the adequate size of
plumbing to carry off domestic waste and to pro-
hibit the discharge of butcher's offal, garbage,
volatile or inflammable liquid and water at a
temperature greater than 100 degrees Fahrenheit.
1938 New York Charter Revision Commission distinguished
between local and citywide service functions.
Local sewers were the concern of borough presi-
dents. Intercepting sewers and treatment plants
were placed under centralized control.
1962 Authority and responsibility for the operation of
the entire sewer system, centralized under
Department of Public Works.
1968- Authority turned over to newly formed Department
of Water Resources, a part of the Environmental
Protection Administration.
.attitude may be at the crux of the situation. Evidence
for this view was presented by a committee of the Water
Pollution Control Federation in a study which concluded
that sewer collection systems were probably the most abused
of all public utilities. This misuse developed in part
from a common misbelief that a sewer can carry away any
unwanted substance (3). From a more practical viewpoint it
is the economic and political pressure exerted on the muni-
cipality by local industry which sometimes account for the
lack of an effective sewer use or pretreatment program. In
other situations, it may be the passive attitude on the part
of a municipality which accounts for ineffective programs.
This latter situation would develop naturally as a result of
the municipal practice of basing user charge systems simply
xvn
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on water use. A necessary practice should involve basing
industrial user charges on pollutant loadings as well as
volume of discharged"was €e water." Such a ^asis^'Jian^be ^ ^
more equitable and provide a powerful incentive for a muni-
cipality to establish a monitoring and enforcement program.
A newer area of concern is directed at discharges of
toxicants into sewers from commercial and industrial sources.
Toxicants (such as heavy metals, cyanide and a large variety
of organic compounds) can cause treatment plant upsets, and
as a result, indirectly cause pollution of receiving waters
through treatment plant breakdown. But many toxicants,
e.g., polychlorinated biphenyls, do not affect, and are not
decomposed by biological treatment plant processes. A wide
variety of toxicants may therefore be discharged by treat-
ment plants into waters that are used as drinking water
sources or which support edible fish and shellfish popul-
ations. These possibilities add a new dimension to pretreat-
ment as an issue.
•
The traditional understanding of the pretreatment
issue, dealing exclusively with impacts on sewers and treat-
ment plants, is irreversibly being transformed into a
general public health issue. The significance of small but
potentially toxic quantities of organic and inorganic
chemicals passing through treatment plants or concentrating
in sludges is only slowly being understood in public health
terms.
The problem of disposing of treatment plant sludges
containing toxics is a much more visible issue today. For
example, the industrial discharge of certain chemicals,
such as metals, into sewage treatment plants frequently
results in elevated levels of the substances in treatment
plant sludge. The disposal of such contaminated sludges in
fact may pose a public health hazard, whether it is incin-
erated or disposed of in the ocean or on land. In the first
case, metals such as mercury can pollute the air; in the
xvi 11
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second, fish and benthic organisms can accumulate high
levels of metals; in the third, metals contained in land
disposed sludge can contaminate groundwater or crops being
grown on sludge, treated soils. The pretreatment of indust-
rial wastes containing toxicants which can contaminate
municipal sludges should receive the same high pretreatment
priority as the pretreatment of toxicants which can upset
or pass through treatment works.
Finally, the relationship between sludge quality and
pretreatment brings to the fore an important concept con-
cerning toxic pollutant impacts. We have mentioned three
such impacts: 1) the impact of toxic pollutants on plant
processes and the need to prevent upsets; 2) the impact of
toxic pollutants on receiving water quality as a result of
pass through; and 3) the impact of toxic pollutants on
sludge disposal. While the first type of impact is fre-
quently viewed as a function of toxicant strength (or dilu-
tion), the second, and to a greater extent, the third impact
of toxicants (on receiving water and sludge, respectively)
are basically functions of total toxicant contributed.
The distinction between toxicant strength and total
mass is particularly important to planners because standards
will eventually be set in terms of strength (concentration),
total massXaa*jEiafcanfci.ai haaamia. The use of both types of
A
standards will involve a complex set of tradeoffs with
important environmental and economic implications.
As the relationship between industrial discharges into
sewers and its broad reaching impacts begin to be understood,
regulatory and planning agencies will be expected to
respond. The nature of the response will determine to a
great extent the type of pollutant removal technology and
even the industrial process changes necessary to meet sewer
discharge standards. Planners may have to consider to what
extent the concept of joint treatment is applicable in
situations where toxicants have been clearly identified.
xix
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This two volume manual is intended to serve as a guid-
ance and resource document for Water Quality Management
(WQM) Planning Agencies or simply planning agencies. The
main text is contained in Volume 1 and consists of Four
Chapters. Chapter 1 presents the overview of the pretreat-
ment issue. Highlighted issues are boxed-in and appear at
the top of the page. For the most part, Chapter 1 defines
and attempts to clarify the pretreatment issue. In depth
discussions of issues are presented in Chapters 2 and 3.
Chapter 2 is prescriptive in nature and describes the main
elements which constitute a pretreatment management program.
This management theme is built around the industrial waste
survey and the municipal ordinance. Chapter 3 presents a
fairly detailed assessment of the types of pollutants which
require pretreatment as well as their effects on treatment
works and receiving waters. Chapter 4 presents case studies
illustrating how in practice the pretreatment issue is
addressed by municipalities and WQM Planning Agencies.
; Volume 2 is an appendix and contains among other items
an extensive compilation of published and proposed pretreat-
ment standards.
xx
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References
1. Charles Imbelli, William B. Pressman and Harold Radiloff.
The Industrial Waste Control Program in New York City.
Journal WPCF 4£ 1981-2012, 1968.
2. M.O.P. No. 3 Regulation of Sewer Use, Journal WPCF 45,
1985-2011, 1973. —
3. M.V. Mclntire. Improved Procedures for Municipal Regula-
tion of Industrial Discharges to Public Sewers. Prepared
for the Office of Research and Development, USEPA, Grant
No. 801372, Program Element 1 RA 030.
xxi
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Chapter 1
OVERVIEW
1.1 INTRODUCTION
Chapter 1 presents an overview of the pretreatment
issue. Becuase of its complexity the pretreatment issue is
presented as a series of special highlighted topics. These
topics address the issue from a definitional, management,
planning, institutional, legal, and technical standpoint.
Many of the topics discussed in Chapter 1 will be presented
in greater depth in Chapters 2 and 3.
1.2 THE PRETREATMENT ISSUE
1.2.1 PERSPECTIVE ON PRETREATMENT; WHAT IS IT AND WHY IS IT
NECESSARY?
The rather general term, "pretreatment", is used here
to mean industrial treatment of wastes prior to discharge to
sewers, which in turn convey wastes to publicly owned ,
treatment pi«Mta* (POTWs). This specialized usage stems
from its use in the Federal Water Pollution Control Act
Amendments of 1972 Section 307 (b) and (c), the latter is
reproduced on the next page. One intent of this section of
the Act is to protect sewage treatment plants from malfunc-
tions resulting from the discharges of "harmful" industrial
wastes. From a practical viewpoint three general types of
1-1
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Sec. 307 (c) Pub. Law 92-500
"In order to insure that any source introducing pollu-
tants into a publicly owned treatment works, which source
would be a new source subject to section 306 if it were
to discharge pollutants, will not cause a violation of
the effluent limitations established for any such treat-
ment works, the Administrator shall promulgate pretreat-
ment standards for the category of such sources simultan-
eously with the promulgation of standards of performance
under section 305 for the equivalent category of new
sources. Such pretreatment standards shall prevent the
discharge of any pollutant into such treatment works,
which pollutant may interfere with, pass through, o£
otherwise be incompatible with such works."
"harmful" wastes are of concern on the municipal level:
1) Materials that damage collection systems or treat-
ment works per se_ e.g. those which are explosive
or tend to block, or clog up sewers and the treat-
ment works .
2) Chemicals that are toxic to biological-type
treatment plants.
3) Chemicals which interfere with sludge disposal.
A second intent of this section of the Act is to pre-
vent the passage through the .POTW of materials that are
likely to result in pollution of the receiving waters. It
is in this second intent of the section that the objective
of the Act itself resides: that is, to "restore and main-
tain the chemical, physical &f biological integrity of the
Nation's waters". While "plant upset" and "pass through"
are the most frequently mentioned concerns of the pretreat-
ment issue, other concerns such as impact of industrial
wastes on sludge quality and quantity, fall easily within
the meaning of the law. Note how readily the issue of in-
dustrial impacts on POTW sludge fits into the meaning of
the last line of Section 307 (c) of the Act (see box above).
The pretreatment issue takes on importance from a
planning, as well as an operational, standpoint. Industrial
discharges to public treatment plants can contribute a sig-
1-2
-------
nifleant portion of the total flow or load to the treatment
plant. Therefore, in order to upgrade or design a new
treatment plant, the industrial contribution must be known.
In many cases the extent of an industry's contribution will
be influenced by federal and local pretreatment requirements.
(It should be remembered that most industries historically
have been located next to water bodies and therefore fre-
quently have the choice of discharging directly or using
public sewers.) The quality as well as the quantity of
industrial wastes needs to be known for planning purposes,
since the type of treatment process employed by the POTW may
need to be designed to take into account specific types of
industrial wastes. As a result, facility plans are directly
influenced by the pretreatment issue.
The pretreatment issue has strong economic impacts (see
Chapter 4.2.4) since certain costs are incurred by industries
and POTWs in meeting federal and local pretreatment standards
In addition to the direct costs of on-site industrial pre-
treatment processes, which are borne solely by the industry,
other costs are:
1) user charges paid to municipality for use of
sewer and POTW
2) surcharges paid to municipalities by dischargers
whose waste "strength" is greater than ordinary
users
3) capital costs repayed by the industrial users of
the treatment works, of that portion of the
Federal grant which is allocable to the treatment
of water from those users.
The above costs influence an industry's choice to dis-
charge into a POTW or to utilize direct discharge. The
consequences of an industry's decision "to go into sewers"
can also be economically important to the municipality.
The pretreatment issue will be of particular relevance
to the water quality management (WQM) plan. This plan is
supposed to define ways in which the discharge of industrial
pollutants can be significantly reduced or eliminated.
1-3
-------
.Pertinent Literature
Federal Guidelines Pretreatment of Pollutants
Introduced Into Publicly
Owned Treatment Works
October, 1973, EPA
This document represents the first effort on the part of
EPA to define pretreatment as described in PL 92-500.
These guidelines were published pursuant to Section
304(f) of the Federal Water Pollution Control Act
Amendments of 1972. A brief discussion is presented
describing the benefits of joint treatment of industrial
wastewater. Similarly, all of the elements of the pre-
treatment issue are briefly described. Much of the
material presented has been updated by new federal guide-
lines (presently in draft form).
Federal Guidelines (Draft) State and Local Pretreatment
Programs, August, 1975, EPA
This is a two volume report which updates the original
Federal Guidelines published in 1973. The purpose of
these guidelines is to assist municipalities, States, and
Federal agencies in developing pretreatment requirements
for the discharge of industrial wastewaters into POTWs.
Volume 1 contains sections on technical, legal and man-
agement aspects of the pretreatment issue. A highly
technical section is presented on pollutants which inter-
fere -with POTWs. Appendices giving detailed information
on ordinance preparation, pui»i*«fee^M»*4MftMMMMwto»*4MMMhM*£»,
test procedures for analysis of pollutants and additional
technical data on pollutants is presented, along with
an annotated bibliography. Volume 2 contains a detailed
description of industrial processes, their SIC categories
and their chemical make-up.
One of the many ways of accomplishing this is to
achieve effective pretreatment requirements on the municipal
level.
the pretreatment issue?
There are, in the issue of pretreatment, elements
that include the entire spectrum of institutions involved
in water pollution control. These responsibilities are
described in Table 1-1.
1-4
-------
Urtdcr
I«W)
T*VI«W
Operationally, the Federal role in the pretreatment
issue will be clearly secondary to that of the States and
municipal governments.] In most instances, the pretreatment
issue will be expressed on an areawide, municipal and State-
wide level. The Planning agency will review industrial
plans, assess potential impacts and lend guidance to the
municipal effort, which should constitute the mainstay of
the pretreatment issue.
1.2.2 How Does Pretreatment Interact With PL 92-500
Especially With WQM Planning Under Section 208?
Goals and Objectives of PL 92-500
The basic objective of PL 92-500, the Federal Water
Pollution Control Act Amendments of 1972 is stated in
Section 101:
"The objective of this Act is to
restore and maintain the chemical,
physical, and biological integrity
of the Nation's waters."
This objective is followed by six goal and policy statements
that are meant to achieve this objective.
"it is the national goal that the
discharge of pollutants into the
navigable water be eliminated by
1985;
"it is the national goal that where-
ever attainable, an interim goal of
water quality"which provides for the
protection and propagation of fish,
shellfish, and wildlife and provides
for recreation in and on the water
be achieved by July 1, 1983;
"it is the national policy that the
discharge of toxic pollutants in
toxic amounts be prohibited;
"it is the national policy that Fed-
eral financial assistance be provided
to construct publicly owned waste
treatment works;
-------
TABLE 1-1
INSTITUTIONAL RELATIONSHIPS
PRETREATMENT
ELEMENTS
RECU1.ATOMY
AUTHORITY
EWOKCLMEMT
MONITORING
FINANCIAL
PR£TK£ATMEHT
STANDARDS
RESIDUALS
FEDERAL
Specified by Sec JO7(b)
I (c) at PL 92-5OO. Reg-
ulations establish pre-
treatment standards Cor
significant Industrial
users. Federal guide-
lines un pretreatjient
are specified In Sec
304 (f).
Direct enforcement
of Federal FT
Standard*
Hay carry out Monitor-
ing of KITH discharges.
Reviews POTU Monitoring
data. Access and Inspec-
tion rights.
Conbtruction grants
review •£• £«»»•* 4Wt
pe*»Jt c*-**^
U« U «M* f«r
WTVJ.
Federal miniaua Stand-
ard setting.
Provides guidance on
sludge disposal.
STATE t AHEAWIDt;
I'l-ANNlNLi/HANAoliMtNT
Reviews Kmi Permit,
and 201 plans. Cruatua 20
year plan. £stdbl Isliua rag-
ulatory i>ronitor-
ing datat may review
eelf-iDonitorlng data fro*
Reviews «rf SS^Sfc**
federal construction grant 0.
May provide an aasessnent of
economic impact of pretre.it-
•ent requirenents on local
Industry.
lncor|x>rated T^Jeral di.d
local tftandard* inl>.« plaj..
Aids Municipality in prepa-
ration of PT ordinance »*•••>-
ii ji^r*^>tf<<^»»^»*
Identifies both tonic com-
ponents of sludge and indus-
Proposcs standards for
sludge quality and specifies
neat sludge standard.
Establishes nanagenent pio-
graa for disposal of indus-
trial pretreatnent sludg^a.
STATK
. May give pemit to
POTW and specify nu-
tablishes enabling
law for HUtnlci|ial
authority.
May luive direct
encoiCJToent ovor
K5TH Petnits coapli-
ancai in S4<«e case*
. over sewer dlvcltar-
gers into POTW.
May carry out Mon-
itoring of POTU dis-
charges. Reviews
POTU nun it or ing data.
Access and inunction
rights.
May provide *natchln.
^^ets local aim*
Affmf'in compliance
with fbderal mini-
mum.
Carries out sludge
disposal in an envi-
ronmentally accept-
able manner.
Coordinates with
208 agency in selec-
ting sites fur dis-
posal of industrial
prctreatotent sludge.
INDUSTRY
MOIM
Won*
May perform
e« 1 f -moni tor ing .
(most common) .
Subject to
user charges and
fines. Coat re-
covery require-
ments. ASSU90
cost of monitor-
ing.
Subject to fvd-
oral and local
re^Airt^cxW-.
treatment sludges.
PT
POTW
PretreaUnunt
Publicly Owned Treataent Works
-------
'T.
-1 (Continued)
INSTITUTIONAL RELATIONSHIPS
PltkTHKATMKNT
KJJJ1KNTS
POTW PERMITS
AREAU1DE PLAN
PLAN IMPLEMEN-
TATIOU
PUBLIC PARTIC-
IPATION
MUNICIPAL ORDI-
NANCE
INDUSTRY WASTE
SURVEY
FEDERAL
In some cases EPA issues
POTW Permits.
Reviews and approves
Plan.
Establishes financing
provisions, approves des-
ignated management agen-
cies.
Holds public hearings
on Federal PT Standards.
Supports efforts such
as the preparation of
guidance documents.
Supports efforts such
as the preparation of
guidance documents.
STATE fc AHKAWIDfc
PLANN I NG/HANACEWENT
Review existing draft permits —
incorporate permit specifica-
tions into HQM plan. Manage-
ment phase — once plan has been
adopted POTW Permit and PT
standards must be compatible
with plan
Establishes plan which may
include specific: minimum
pretrcatment requirements)
industrial waste survey pro-
cedures; ordinance types.
Requires a management
agency to run PT program.
Arranges public hearings
and information transfer
sessions on relevant pre-
treatment issues'. Assists
municipalities in arranging
public hearings on sewer
use regulations.
Gives direct aid to munic-
ipality in ordinance devel-
opment. Reviews all munici-
pal ordinances within plan-
ning area. May recommend
regional ordinance.
In many cases will carry
out survey. Identify dis-
charges of tonic wastes.
STATE
In some cases state
Issues POTW Permits.
certifies plan.
State designates
management agency (s) .
Develop State legis-
lation such as
enabling laws.
Comment and review
on pretreatmeitt
issues as they affect
water quality stand-
ards and wyH plans.
Aids municipality
in ordinance develop-
ment. Reviews ordi-
nance for complete-
ness.
May require munici-
pality to modify sur-
vey approach .
MUNICIPAL
Municipal POTW
•uat meet require-
ments of NPDES Per-
fltoWrfLa
In ordinance) should
relate to NPDES
permit requirements.
Contributes to WQM
plan.
In order to be
eligible for Federal
funding must be con-
sistent with 208
plans PT require-
ments.
May have to amend
ordinance to be in
compliance with PT
provisions of Area-
wide plan.
Holds or partici-
pates in public
hearings on new
sewer use regula-
tions, provide forum
for all interested
persons.
Creates ordinance.
Will be directly
involved in implemen-
tation of ordinance.
Frequently carries
out survey.
INDUSTRY
Compliance with
IT Standards is
required.
Industry partic-
ipates on
advisory committee.
Committee partic-
ipates on technical
and policy commit tees.
Participates in pub-
lic hearings on sewer
use regulations.
Complies with ordi-
nance requirements.
Provides information
to satisfy survey
requirements .
PT
POTW
Pretreatment
Publicly Owned Treatment Works
-------
"it is the national policy that area-
wide waste treatment management plan-
ning processes be developed and
implemented to assure adequate
control of sources of pollutants in
each State; and
"it is the national policy that a
major research and demonstration
effort be made to develop techno-
logy necessary to eliminate the
discharge of pollutants into the
navigable waters, waters of the
contiguous zone, and the oceans."
The policy statements on how to meet this objective fo-
cus largely on pollutant discharge. Industrial pretreatment
requirements are one element of the pollutant and toxic pol-
lutant control effort.
The NPDES System
The major tool in the Act for implementation of source
control of water pollution is found in the National Pollutant
Discharge Elimination System (NPDES), section 402 of the Act.
NPDES permits are issued to all point sources discharging
directly into "waters of the United States". These point
sources include municipal treatment facilities, factories,
some specific agricultural operations, service and commercial
operations. The permits are designed to effect compliance
with the requirements of the Act:
1) to insure effluent limitations are met on a pre-
scribed compliance schedule;
2) to insure .the necessary waste treatment technology
is applied; and
3) to insure water quality standards are met on a pre-
scribed schedule.
The following figure (1-1) places pretreatment require-
ments on the vector between industrial point sources and the
publicly owned waste treatment works. It shows that in part,
pretreatment requirements are indirectly affected by the NPDES
requirements of the POTW.
1-8
-------
Figure 1-1
INDUSTRIAL POINT SOURCE CONTROL
Industrial
Source of Pollutant
Prefreatment
Requirement
POTW
JVPDES
Permit
Surface
Waterbody
Although the NPDES does not require issuance of permits
to industries discharging to sewers*, the POTW that treats
the waste is required to have a discharge permit. As -part
of the NPDES permit for. the POTW, the municipal operating
authority must submit forms identifying the discharges to
the sewers from major contributing industries ~
The General Planning Guidelines of the Act
The major planning programs of the Act are organized
under each State's Continuing Planning Process. Water
Quality Management (WQM) Planning under Sections 208 and 303
is conducted fcp designated problem areas. This planning is
the responsibility of the State in all other areas, although
this responsibility may be delegated to other local, State,
interstate or Federal agencies. Facilities plans are pre-
pared by local agencies where it is determined that a POTW
is needed.
1) State Continuing Planning Process - The primary
goal of the continuing planning process is to ensure
that the institutional arrangements and management
Municipalities often require sewer use permits.
1-9
-------
Major Contributing Industry (from 40 CFR 128) :
.A major contributing industry is one that: 1) has a
flow of 50,000 gallons or more per average work day;
2) has a flow greater than five percent of the flow
carried by the municipal system receiving the waste;
3) has in its waste a toxic pollutant in toxic amounts
as defined in standards issued under Section 307(a)
of the Act; or 4) has a significant impact, either
singly or in combination with other contributing in-
dustries, on a publicly owned treatment works or on
the quality of effluent from that treatment works.
programs are established to make and implement
water quality decisions. Specific outputs of the
CPP are the State strategy, the State-EPA agree-
ment on timing and level of detail of planning,
water quality standards, and individual State and
areawide .WQM plans.
2) State and areawide Water Quality Management (WQM)
Planning - This planning forms the basis for imple-
menting point and nonpoint source controls necessary
to achieve the goals of the Act. It includes an
assessment of municipal and industrial waste treat-
ment system needs, and an identification of necessary
regulatory programs and management agencies.
3) Facilities Plans (Section 201) - Facilities plans
are the initial step in three step construction
grant process. These plans must examine the cost-
effectiveness of adequate construction programs to
achieve necessary effluent limitations, considering
different numbers, sizes, and sites for facilities.
Wastewater treatment options such as land treatment
and flow reduction are also examined.
The Continuing Planning Process is addressed in regula-
tions in the Code of Federal Regulations, Chapter 40, Part
130 (40CFR130). State and areawide WQM planning is dealt
with in 40CFR131 and 40CFR35, Subpart A. These'regulations
-------
were published in the Federal Register on November 28, 1975.
Pretreatment Within State and Areawide WQM Planning and 201
Facilities Planning
State WQM planning and 201 facilities planning will in-
directly affect the development of pretreatment programs.
Effluent limitations for POTWs will be set based in part on
criteria developed within the WQM and 201 planning processes.
Strategies to meet water quality goals, including maximum
daily pollutant loads, are integral parts of the WQM plans.
The 201 plan describes the process and capacities of treat-
ment facilities. Information from WQM plans and 201 plans
is critical in structuring effluent limitations of the POTW.
Figure 1-2 illustrates the role of WQM and-201 planning in
setting both effluent limitations for POTWs and pretreatment
requirements. It can also be seen from this figure that
pretreatment requirements can be used to correct a treatment
plant design limitation on the one hand and be reflective
of certain characteristics of POTWs on the other (e.g. if.ani
POTW is a physical-chemical plant and effectively removes
metals then BMHMt«*peri> pretreatment »*M»iUM»£« may not have
to be stringently set).
Pretreatment Within State and Areawide WQM Planning
Because of the multitude of problems which planning
agencies must address and the limited time and resources
available to them, planning agencies should prioritize
their tasks. Due to varying local situations pretreatment
will take on greater or lesser importance. Some planning
areas may have virtually no industrial users of POTW's;
other areas may have industrial users which contribute only
compatible wastes to the POTW. In such cases little or
no attention may be given to pretreatment. In other areas,
pretreatment may be the most important element of an
industrial wastewater control program.
Pretreatment may be addressed either separately as a
program element under the WQM planning process or as part
1-11
-------
State and
Areawide Water Quality
Management Planning
Water Quality Standards
1
Maximum Pollutant Load to
Water Body Segment
201
Facilities
Planning
Degree of Reduction
Attainable Through
Secondary Treatment and BPWTT*
Specific POTW
Effluent Limitation
-NPDES Permit-
Characteristics of
Specific POTW
Determination of
»H load Pretreatment
Requirements
• The 1977 and 1983 Technology-Based Effluent Limitations Required of POTW's by
Sections 301 and 201 of the Act (BPWTT = Best Practicable Waste Treatment
Technology).
Figure 1-2
PRETREATMENT AS PART OF THE PLANNING PROCESS
1-12
-------
of an industrial waste management and planning program.
Pretreatment programs have two main purposes : to insure
protection of the POTW against upset and interference with
sludge disposal, and to prevent industrial pollutants from
passing through treatment plants and polluting receiving
waters. Industrial dischargers into municipal treatment
require****?
systems will be required to meet "pretreatment **ww»d*ip*e"
rAouirtiKCiMt*
set up by municipalities. These sfemMtowta will be evaluated
within the WQM process in order to insure that the effluent
limitations for the POTW designated in its NPDES permit are
not violated due to treatment plant upset caused by inter-
ference from industrial contributions. Similarly, facilities
plans will be reviewed and pretreatment will be an issue in
pl«M»i*9
these reviews. In practice^agencies will work closely with
municipalities, giving expert advice on how to write pre-
rftyMrch*c*l»
treatment •tMMbMMto for inclusion in the municipal ordinance.
Table 1-1, Institutional Relationships, presents the manage-
ment and planning functions of WQM planning (208) relative
to pretreatment. The planning functions of WQM planning may:
lot*\ prctafttmcftt rH*iftiwt.Hfi l»ci«4 u»«v»
r- --- .
2) Organize and update information on the type and
number of industries discharging to sewers, as
well as quality and quantity of their wastewater
constituents;
3) Identify all industries which discharge toxic wastes
to sewers connected to POTWs;
4) Identify industries whose pretreatment sludges will
contain toxic substances. Incorporate such informa-
tion into the areawide residuals program plan;
5) Assist municipalities in properly utilizing indus-
trial waste survey information for inclusion into
ordinances;
6) Assist municipalities in preparing enforceable
ordinances;
7) Organize two-way industrial information exchanges
in order to evaluate possible industrial responses
to pretreatment standards;
1-13
-------
8) Assess potential trends initiated by areawide
industries in disposal options such as sewer dis-
charges versus direct discharges to receiving
waters. Determine for example, the historic annual
rate at which industries connect to sewers compared
to the present rate;
9) Prepare an assessment of economic impacts of pre-
treatment on local industries.
The prime management function of WQM planning relative to
pretreatment is to establish a regulatory program to insure
industrial pretreatment requirements are met.
Discharge to Publicly Owned Treatment Works (POTWs)
Under sections 301(b), 304 (d) and 201(g) of the Act,
municipal treatment works (POTWs) must meet "secondary treat-
ment" requirements by July 1, 1977, BPWTT requirements by
July 1, 1983, or more stringent limitations if necessary to
meet water quality standards. Users of POTWs also fall
within the statutory scheme set out in section 301(b). Thus
industrial point sources which discharge to POTWs via
sewerage systems must comply with pretreatment standards
established pursuant to section 307.
Pretreatment Standards for Existing and New Sources
The EPA promulgated general pretreatment standards on
November 8, 1973, under Title 40, Part 128 of the Code of
Federal Regulations. These regulations are meant to satisfy
the requirements of section 307(b) of PL 92-500.
"Pretreatment standards...shall be
established to prevent the discharge
of any pollutant through treatment
works (as defined in section 212 of
this Act) which are publicly owned,
which pollutant interferes with,
passes through, or otherwise is in-
compatible with such works."
The general standard includes no specific numerical limita-
tions but only definitions, general rules on prohibited wastes
and pretreatment requirements for incompatible pollutants
that all industries discharging to the POTW must comply with.
1-14
-------
The regulation states that pretreatment is not required for
compatible pollutants. (A more detailed description of 40
CFR 128 is provided on p. 1-17.)
tants (see box page 1-17]. [BPT
allBig^
Subsequent to the issuance of 40CFR128, EPA has proposed
pretreatment standards for categories of point sources which
will apply to existing sources. According to the regulation,
the proposed standards are identical to BPT effluent limita-
tions except the standards only apply to incompatible pollu-
[BPT or best practicable tech-
301 (b) (1) (A) of the Act.]
EPA has promulgated pretreatment standards for existing
sources in 15 industrial categories. These 15 categories
have, however, only compatible wastes in their effluents.
As a result of 40CFR128, these pretreatment standards re-
quire "no limitations" on discharge. It should be noted
that no pretreatment standards have been promulgated yet
for existing sources which have incompatible pollutants in
their effluents.
The basis for pretreatment standards for new sources is
also found within section 307. According to section 307 (c),
the EPA is required to establish pretreatment standards for
new sources simultaneously with the standards of performance .
for new sources that discharge directly to waters of the
United States. In many cases the regulations promulgated are
identical (new source performance and pretreatment standard
for new sources) . The reason for this overlap of standards
is very clear in the case where a particular pollutant passes
through a POTW untreated or inadequately treated. The source
discharging such a pollutant causes essentially the same
environmental damage as a direct discharger of the same
pollutant and, therefore, should meet essentially the same
requirements .
For an industry to be subject to the minimum limitations,
it must be classified a major contributing industry*^ see
p. 1-10). A compilation of the proposed and promulgated
pretreatment standards these industries must comply with is
provided in Appendix A of the manual.
40 Cf R
-------
Because of numerous comments made to the EPA concerning
the inadequacies of 40 CFR 128, a new regulation has been
drafted (40 CFR 403) which, when promulgated, will replace
40 CFR 128. This new regulation will serve the same purpose
as 40 CFR 128 but will be considerably easier to understand.
1-16
-------
TITLE 40 CODE OF FEDERAL REGULATIONS PART 128
This general regulation defines pollutants in two
categories: compatible and incompatible. Compatible
pollutants are biochemical oxygen demand, suspended solids,
pH, fecal coliform plus "...additional pollutants iden-
tified in the NPDES permit if the publicly owned treat-
ment works was designed to treat such pollutants...".
Examples of such pollutants are given as chemical oxygen
demand, total organic carbon, phosphorus-nitrogen and
related compounds, fats, oils and grease. Incompatible
pollutants are any that are not compatible pollutants.
The standards set forth for these two categories apply
only to major contributing industries which are defined
on page 1-10 of this chapter. The only specific regula-
tions established by 40 CFR 128 are those for prohibited
waste. These can be found in Appendix D of this handbook.
t
The key section of this regulation is Section
128.133 which defines the pretreatment standards for.
incompatible pollutants. This paragraph sets the pre-
treatment standard for existing sources as the BPT re-
quirements which are described on p. 1-15. This
standard is modified somewhat by two additional state-
ments. First of all, if the related POTW is committed
in its NPDES permit to remove a specified percentage
of any incompatible pollutant the pretreatment standard
will be correspondingly reduced. In addition, when the
BPT regulation for direct dischargers is promulgated
for a specific industry a pretreatment standard will be
proposed for indirect dischargers in that industry.
It is important to note that this regulation
covers existing sources only. Pretreatment standards
for new sources are proposed and promulgated simul-
taneously with the new source performance standards
according to 307 (c). For new sources there are no
general pretreatment'«*«**««p«to which correspond to
40 CFR 128.
1-17
-------
The Design and Administration of Pretreatment Programs
^fhe Federal government is involved in industrial waste
A
management through its planning efforts, funding programs,
and effluent regulations, but much of its contact with
A K«avy
industry is indirect. !•••••. burden of industrial waste
management—and, therefore, of pretreatment—falls on State
and municipal governments.
About half of the States currently have responsibility
for granting NPDES permits which regulate direct discharge
of wastes into navigable waters. Although NPDES States
assume responsibility to insure that industrial users of
POTWs comply with pretreatment standards, large numbers of
industrial users have not yet been addressed by finalized
In non-permit States, EPA regional offices are re-
sponsible for NPDES permits, either alone or in
cooperation with the State.
1-18
-------
2
pretreatment standards. As a result, States have not yet
been forced to assume major pretreatment responsibilities.
Nevertheless several States have instituted effective pre-
treatment programs on their own.
Municipalities have the responsibility of designing
and administering pretreatment programs (see chapter 4.3),
their authority coming from the general police powers, and
from State enabling legislation. They must enforce what-
r*4uirc**>«tr
ever pretreatment MMNMMMM^ are necessary to meet Federal
standards, prevent violations of their NPDES permits due to
plant upsets caused by interference from industrial contri-
butions, minimize their sludge disposal costs, and protect
their systems from damage or upset due to industrial wastes.
The basic issues and problems they face in discharging their
responsibility are discussed in the remainder of this chapter.
Industrial wastewater management on the municipal
level breaks down into two basic elements: a survey and
analysis of industrial wastes discharged into the local sewer
system, and an administrative and regulatory program to con-
trol and monitor these wastes. One objective of industrial
waste management at the municipal level is usually the crea-
tion of an industrial cost recovery system (see chapter 4.3.3)
and the establishment of appropriate user charges. But
whenever industry is a major contributor (see p. 1-10) to ^
POTW influent, pretreatment may be an issue of equal a£ Cf
greater importance, particularly from the environmental point
of view.
Survey and Analysis of Industrial Wastes
A data base of the types and quantities of industrial
wastes discharged to sewers is obtained by an industrial
waste survey (IWS). While it usually is conducted as part
2
The only promulgated pretreatment standards for exist-
ing sources are for categories which have compatible
wastewaters. The standards call for "no limitations"
on discharge.
1-19
-------
of a pretreatment program, an IWS can be used in several
ways:
1) To forecast annual 0/M costs in order to allow
a user and surcharge system to be created;
2) To update the industrial cost recovery
system;
3) To aid in forecasting industrial discharge
levels for planning POTW expansions or
new facilities for which 201 facilities plans
will be done;
4} To identify industrial wastes subject to
local and federal pretreatment artmiataHHi*;
r*5Uir«*w«t*
5) To gauge the impact of industrial wastes
on the quantity and quality of POTW sludge;
6) To help planning agencies evaluate total
toxicant pollution in a region; and
require «*«*tj
7) To set local pretreatment 9***i*KfA*.
While there are a number of cheaper ways to fulfill
all these functions of an IWS, they are less reliable in
their results, potentially less equitable in their economic
impacts on industries, and ultimately less effective in
serving water quality goals. Procedures for conducting
IWSs are discussed in length in Chapter 2, Section 2.1.
The Administrative and Regulatory Program
Conducting an industrial waste survey is relatively
straightforward in principle and execution; designing and
r«^u>«»*t»«br
administering pretreatment staandai'do, on the other hand,
<«MM likely to be a complex and difficult process, with many
economic, legal, political, and technical issues to resolve,
Since the pretreatment issue is still new, the following
discussion of the dynamics of standard setting and enforce-
ment must be to some extent speculative.
Setting Pretreatment
1-20
-------
Such a program consists of legally binding arrangements
with local industries, usually in the form of a Pretreatment
Ordinance, which establishes exact conditions for discharges.
Federal pretreatment standards, as discussed in the previous
section, are binding on major contributors to the system.
Smaller contributors, however, may alsp be regulated by the
rbfu%v«i*«wtv
municipal ordinance, and municipal otaandageis for all contri-
butors may be more strict, if necessary, than federal standards.
It is important to remember that POTWs have three
different, often separable, objectives in setting up pre-
1123053
treatment*: 1) to improve plant efficiency to prevent upsets;
2) to maximize sludge quality (and, therefore, minimize
disposal costs) ; and 3) to prevent pass- through of dangerous
pollutants. Plant upsets cost money and cause permit vio-
lations; avoiding them is perhaps the highest priority of
pretreatment from the POTWs standpoint. Present sludge •
disposal practices are not always the most environmentally
adequate methods available. When pollution control proce-
dures are better defined, costs for sludge management may
be considerably higher. Thus POTWs are currently not ex-
periencing the real costs of sludge disposal. Pass-through,
especially where plant efficiency is completely unaffected
by a particular pollutant, entails no direct dollar costs,
but possibly very heavy environmental costs; giving this
issue the top priority it deserves may be economically and
politically difficult, but every effort must be made to do so.
Industries' Response to Pretreatment Steandagets : Once
espo
lt**)!*
.
4 pretreatment standard has been set, industries must bear
the often substantial costs of meeting them. They have three
major alternatives: 1) to pretreat wastes; 2) to change
manufacturing processes to lower pollutants in their waste
stream; or 3) to disconnect from the system (go out of
business, move, or seek their own NPDES permit). Different
e»»«»rtr
ltti.'da may provoke different responses as shown above .
If industries select the first response — setting up
1-21
-------
Trends in Sewer Use
Industries converting from direct discharge (into
navigable waters) to sewer discharge may represent a
trend in some areas. Although this trend has not been
precisely documented there appear4 to be at least two
incentives for it:
1} Some permitting authorization may encourage
industries to relinquish their permits for
direct discharge and utilize POTWs instead.
This rationale appears to be based on the
"desirable" goal of reducing the number of
pollution point sources in receiving waters.
2) Industries may find it less expensive to
discharge into sewers due to:
a) the implicit and explicit subsidies
mentioned in Chapter 2.5.6.
b) less stringent regulations as a
result of poor municipal regulation .
of its industrial dischargers.
treatment processes to reduce concentrations of controlled
pollutants to acceptable levels—the results will be predict-
able. But if they approach compliance in other ways, the
results are less certain. Process changes may involve
introducing new pollutants into an industry's waste stream,
or raising the levels of minor pollutants above effluent
requirements. Disconnection from the system reduces total
flow to the POTW (with possible economic and technological
effects), but also reduces contaminant loadings. In both
cases, standards might have to be reviewed in order to define
pretreatment requirements as equitably as possible for all
contributing industries.
'Planners
will probably wish to set tentative requirements on the
1-22
-------
I
basis of the IWS results, approach industries with the
results, and ask for their responses. A second and final
set of requirements might then be necessary. Industries
severely affected by the requirements should be given
particular attention and all help possible to prevent their
f«^u!r«»»Ol
going out of business (see below) . The final set of o tea net'
aae&e should be so well understood by industry and the POTW
that their implementation will cause no surprises, and will
meet all pretreatment goals.
Other Considerations; Setting pretreatment elandai'do
is further complicated by a variety of issues (discussed in
more detail in Chapter 2) . One of these is allowance for
re^owenlr
industrial growth: if afeanclagdo are calibrated just tightly
enough to meet immediate pretreatment needs, they would
have to be recalculated and changed if new industries were
to connect to the system. Aside from the administrative
costs this would incur for the municipality, it could well
p^ose far heavier costs to existing industries, which might
be forced to change their entire pretreatment strategies.
raguirt,»»»udj
Other issues include safety margins within the standards,
criteria for setting variances and allocating their costs
among participating industries, and the impacts of pre-
treatment on industrial location and on environmental pro-
tection programs such as the Clean Air Act.
Relief to Endangered Firms
The high cost of pretreatment unit processes may endanger
the existence of some marginally profitable firms, and will
*
be a significant burden on most others. The only options
open for the relief of economically endangered firms are to
give them financial and technical advice on how to meet
loot
requirements, or to grant them variances*, variances should
only be granted as a last resort, for if pretreatment goals
are not to be compromised, all concessions granted to one
industry must be paid for through stricter requirements on
other industries. Financial and technical advice, on the
1-23
-------
other hand, can be highly useful in helping industries find
ways of complying with pretreatment at minimum cost. (These
are discussed at greater length in Chapter 2.)
There are several forms of Federal financial assistance
available for recouping the cost of pretreatment, including
various investment tax credits, tax-exemptions on construc-
tion bonds, loan subsidies, and rapid amortization procedures
for pollution control equipment. These should be brought to
the attention of all industries.
Technical advice can take a number of forms . Site
visits by engineers familiar with pretreatment problems can
reveal good housekeeping processes that would reduce pollu- "
tion emissions. They could also recommend process changes
that would permit compliance with pretreatment standards at
lower cost than pretreatment. Directories of available pre-
treatment equipment .can also be compiled, giving industries
information On vendors, local prices, and technical specifi-
cations .
All possible relief measures should be made available
to local industries as soon as possible, preferably before
oteandarda are set. In this way firms can anticipate what
their response to pretreatment frfaandarac will be, and can
inform the ateaadaga setting agency.
Conclusions
Because of the heavy economic impacts that pretreatment
requirements may have in many areas, economic issues may
obscure the real objective of pretreatment — environmental
protection. Industries will exert pressure on POTWs to
relax requirements wherever possible, especially on pollu-
tants that impose no direct costs on the design and operation
of municipal treatment plants. Because pass-through, and
to a lesser extent sludge disposal, pose few such costs,
economic pressure for compromise will be felt exactly where
environmental damage is least understood and potentially of
the greatest long-term significance.
1-24
-------
While the economic impacts of pretreatment on industries
cannot be ignored, and while aid toward compliance must be
proffered wherever needed, planners must always place the
water quality objectives of pretreatment first.
1-25
-------
Chapter 2
MANAGEMENT PROGRAMS
2.1 INTRODUCTION
This chapter describes the elements required for the
development and administration of an industrial pretreatment
program. The technical, legal and economic considerations
for the management of industrial wastes are brought into
focus by a description of two key activities: the indus-
trial waste survey (IWS) and the development of a local
sewer use ordinance. The IWS will serve to define the
quantity and quality of industrial wastes in a locality and
will lay the groundwork for planning a control program. The
information obtained from an IWS will be an integral part of
all the water quality management efforts for an area includ-
ing facilities (201) plans, updating State program plans,
WQM (208) planning, NPDES permit and cost recovery require-
ments, and, especially pertinent to industrial waste control,
2-1
-------
the development of a sewer use ordinance (Figure 2-1). As
the IWS is to definition and planning, the sewer use ordin-
ance is the core of enforcement and management of industrial
wastes. It is the legal basis for establishing industrial
pretreatment limitations and assigning of financial respon-
sibility (Figure 2-1). The ordinance traditionally has been
a document defining general sewer-use regulations. Histori-
cally, there were provisions against discharging wastes that
would either damage the sewerage system or obstruct flow
within the pipes. Enforcement proceedings were often
detailed but mostly ignored by administrators of the ordin-
ance (13). Subsection 2.3.5 presents planning guidance on
how municipalities can develop more readily enforceable
ordinances to control industrial wastes in the sewerage
system. An alternative to the traditional approach of
controlling sewer discharges would be to enact a general
enabling ordinance providing for negotiation of individual
contracts with each industry. This is also discussed in
subsections 2.3.5 and 2.4.5.
2.2 OUTLINE OF MANAGEMENT PROGRAM ELEMENTS
Several activities will proceed in either chronological
or parallel succession in planning an industrial pretreat-
ment program. The capacity and capabilities of the sewerage
facilities must be determined. An assessment of the indus-
tries and their wastes will be assembled mainly from the IWS
and supported by information from federal, regional and
State planning activities (Figure 2-2). A comprehensive
review of the existing ordinances will identify what con-
trols are already in use and how effective these have been
in regulating industrial discharges.
Because of water quality considerations, some municipal
NPDES permits will specify limitations on pollutants that
originate essentially from industrial discharges. In such
cases, these specific limitations will probably only be con-
trollable by establishing local pretreatment requirements,
2-2
-------
Definition and Planning
Industrial Cost
Recovery
Water Quality
Management (WQM) Planning
Federal Minimum
Pretreatment Standards
IWS
• 201 Facilities Planning
Municipal
Ordinance Development
NPDES Permit (inventory requirement)
Management
Financial
Legah
ORDINANCE
Technical
(discharge requirements}
Enforcement
Monitoring
Figure 2-1
INDUSTRIAL WASTE MANAGEMENT
2-3
-------
WQM Plans
I
Facilities
201 Plans
1
Financial Decisions
TECHNICAL REQUIREMENTS
• Identify a Characterize Industries
• Receiving Water Quality Goals
» Define POTW Capacity Q Capabilities
» NPDES Requirements of POTW
• Federal Pretreatment Guidelines ft Standards
State or
Regional
EPA
Regional
Master Plans
Planned Growth
for Area with
Municipal Service
Requirements
ORDINANCE
COMMITTEE
Engineering
Legal Staff
Industrial Representatives
Public Representatives
Government Representatives
Review
a
Update
ORDINANCE
Pretreatment
a Industrial
Activities
Monitoring
a
Enforcement
Development
- Administration •
Figure 2-2
DEVELOPMENT AND ADM I ill STRATI ON OJ«y INDUSTRIAL PRETREATMENT PROGRAM
-------
e.g., a municipal ordinance. These elements (IWS, Ordinance
Review, POTW Study) are listed and described in Table 2-1.
Several additional elements of a mangement program such as
impacts on industry, sludge disposal and toxic substances
are also described in this table.
2.3 TECHNICAL CONTROL ELEMENTS FOR INDUSTRIAL POLLUTANTS
DISCHARGED TO SEWERS
2.3.1 Introduction
The function of a monitoring program will be to deter-
mine compliance with pretreatment requirements, to supple-
ment data for computation of user charges and surcharges,
and to evaluate any important changes in the system. The
intial stages of a monitoring program will involve a survey
of the existing non-residential discharges to a sewerage
system. This information will provide a technical data base
for the development of a local pretreatment ordinance, of
treatment strategies and of any subsequent monitoring pro-
gram that is needed. A well structured monitoring program
will reveal any changes in the quantity, quality, or number
of industrial discharges, and will aide in the planning of
future treatment plants or the expansion or upgrading of
present systems. Moreover, by supplying immediate notice of
the presence of interfering materials in unacceptable quan-
tities, monitoring could serve as a warning device, initi-
ating precautionary measures to avoid treatment plant upsets
or decreased operating efficiencies.
The responsibility of monitoring industry can rest upon
either the industries themselves or upon sewerage works
personnel. Federal authority to require self-monitoring by
industries is described in section 308 of PL 92-500.
According to this section, the owne-r or operator of any
waste discharge can be required by the Administrator of EPA
to:
1) install, use and maintain monitoring equipment;
2) sample effluents at appropriate locations and
frequencies;
2-5
-------
Table 2-1
PRETREATMENT MANAGEMENT PROGRAM ELEMENTS
1. INDUSTRIAL WASTE SURVEY
Data Compilation
•Identify all industrial contributors.
•Establish quality and quantity of pollutants.
Data Analysis
•Assign S.I.C. categories. •Identify toxic
dischargers. "Identify significant contributors.
2. MUNICIPAL SEWER ORDINANCES
Survey
•Examine ordinances for completeness and enforce-
ability.
Review and Analysis
•Determine what ordinances require updating and
change. »Advise and aid individual municipali-
ties in drafting (or changing) sewer use ordi-
nance.
3. ENFORCEMENT PROGRAM
Scope
•Determine if an effective enforcement program
exists and recommend improvements.
Monitoring Program
: "Identify monitoring program possibilities.
Select best suited for circumstances.
4. PRETREATMENT FINANCIAL PROGRAM
Cost Breakdown
•Breakdown the costs of pretreatment program into
survey, monitoring, analysis, legal and treatment,
Cost Assignment
•Develop system for equitably assigning cost re-
covery and user charges to industry.
2-6
-------
5. POTW STUDY
POTW Pretreatment Characteristics
•Relate the type of POTW, its capacity, and type
of industrial user to the specific pretreatment
needs, e.g., physical-chemical versus biological,
trickling filter versus activated sludge.
•Include historical review of POTW upsets and
negative water quality impacts.
POTW Discharge Permit (NPDES) Permit Survey
•Ascertain the technical degree to which the
standards in the sewer use ordinance are
reflected in the municipal NPDES permit.
Impacts on Sludge Disposal
•Relate sludge treatment options and disposal costs
to industrial users of POTW.
6. PUBLIC PARTICIPATION
Awareness of Pretreatment
•Initiate efforts to increase citizen understand-
ing of important issues. • Conduct public infor-
mation meetings with public and industrial repre-
sentatives.
Industrial Participation
•Form advisory committees with significant indus-
trial representation.
7. SECONDARY ISSUES
Impacts on Industry
•Determine what impacts program has on industrial
costs. •Advise industries on available incen-
tives.
Toxic Substances Legislation
•Ascertain to what degree pretreatment program
must respond to 307(a) standards.
2-7
-------
3) establish and maintain records as deemed neces-
sary;
4) prepare and submit reports; and
5) provide other information that may be reasonably
required.
The extent to which this authority is enforced will depend
on existing discharges and water quality standards, the
resources of the industry, and the resources of the sewage
system organization. It is likely that self-monitoring by
industries would be an efficient approach in many cases, but
it must be determined to what extent POTW support and sur-
veillance will be needed to double check such a program. If
Federal authority to require monitoring appears to be inade-
quate or inappropriate for local conditions, it can be
augmented or defined more specifically in the local ordin-
ance or user regulations.
Monitoring is a cornerstone of a pretreatment program
and its enforcement; care should be taken to avoid its
•
becoming a hinderance. Monitoring activities will not
always involve costly sampling and measurement. In situ-
ations where resources are limited, monitoring activities
should be used selectively. For example, there may be
enough published literature on industrial wastes to roughly
characterize the local industrial discharge. More fre-
quently available information may permit a decision to be
made whether to monitor an industrial contributor. Thus,
monitoring could merely involve assembling and updating
information such as the list of industries and their pro-
duction characteristics without having to sample effluents.
The published literature will also be instrumental for
identifying special items of concern, such as toxic sub-
stances, for a given industry. However, actual sampling
will at times be required to measure compliance with pre-
treatment requirements or when an industry challenges the
characterization given to its wastes.
2-8
-------
The purpose of this section is to describe the options
available for a monitoring program and provide guidance for
performing such activities. Because local conditions will
vary/ instruction on which option is best suited to a given
situation would be quite complex and is thus deliberately
avoided. Rather, criteria for an agency to use in making
such decisions are posed. Requirements for personnel,
costs, technical equipment and data are considered herein.
Monitoring has several purposes. Compliance monitoring
measures an industry's progress towards, or adherence to,
pretreatment requirements. User charge monitoring will
provide initial data or update existing data used in com-
puting an industry's share of the costs involved with public
treatment of wastes. Emergency (or Demand) monitoring will
be conducted during unusual conditions, including plant
upsets.
Development of a monitoring program may be the task of
the local authority, with the planning agency serving as
consultant arbiter, or it may primarily be the task of the
planning agency itself. In either case, it is important
that the planner take responsibility to tailor a well organ-
ized, simple monitoring program that will effectively report
on the status of the industrial waste pretreatment program
by obtaining maximum cooperation of the industries involved
without feelings of undue harrassment.
2.3.2 The Industrial Waste Survey
The extent of industrialization will vary considerably
between regions, and thus the quantity and quality of indus-
trial wastes should be systematically identified. Metropol-
itan areas (.such as New York City, with 44,000 non-residential
sources) will have widely diversified industries which are
sometimes difficult to identify or analyze. Rural or sub-
urban areas may have few industrial discharges or none at
all, but even one discharge, such as a large paper mill,
could significantly affect sewerage works operations. A
2-9
-------
An Industrial Survey May:
1) Identify all non-residential sources;
or
2) Categorize the industries (e.g., Sewer grt direct discharge;
products manufactured; size of plant)
3) Classify and sample each waste discharge.
thorough industrial survey may be required to provide
baseline data for NPDES permits, but it will also aid in the
development of a pretreatment ordinance as well as in the
planning of sewerage system improvements or additions.
Moreover, such a data base could be of value for areawide
toxic substance surveys and economic and land-use planning.
Sewer user charges and surcharges will also be based on the
results of the industrial survey and analysis.
Description of Tasks for the Industrial Waste Survey
The text entitled: "The Treatment of Industrial Wastes",
by E. B. Besselievre (9) presents a detailed guidance for
the development of.an industrial waste management program
beginning with obtaining the baseline data to be acquired
from an industrial waste survey. From a complete list of
firms in the area and with some basic information on their
activities, the significant contributors of industrial waste
should be sorted from the insignificant and non-manufacturing
firms. The wastes from this former grouping can then be
characterized by survey and analysis and control or pre-
treatment strategies can then be developed. Figure 2-3
summarizes the activities and intended outputs of an Indus-
f
trial Waste Survey (IWS).
List of Firms. In smaller areas, there may be a group
or an individual already familiar with all of the non-
residential discharges. Where such familiarity does not
exist, there are various sources from which a complete list
of firms can be compiled. Some of these are:
2-10
-------
INDUSTRIAL WASTE SURVEY
CTIV1TY
_ LIST
INDUSTRIES
JL
PRELIMINARY QUESTIONNAIRES
OUTPUT
USE
SEPARATE
'DIRECT.DISCHARGERS
PROM'- '
SEWER USERS
IDENTIFY
MAJOR & SIGNIFICANT
INDUSTRIES
PRODUCTS S PRODUCTION RATE
OWNER/ADDRESS CONTACT
WATER CONSUMPTION
WASTEWATER CONSTITUENTS
NUMBER OF EMPLOYEES -
RAW MATERIALS
DETAILED INTERVIEW
AND
SITE VISITS
TERATURE
SURVEY
I
SAMPLING
PLANT LAYOUT
SEWER CONNECTIONS
WASTE SAMPLING ACCESS
EQUIPMENT
PROCESSES
SPECIAL PROBLEMS
(e.g.: VARIABLE PRODUCTION
SCHEDULES)
WASTEWATER FLOW RATES
MASS DISCHARGE RATES
CONCENTRATIONS
VARIABILITY
FINAL REPORT AND
ACTIVE FILING SYSTEM
1. SIC INFORMATION
2. (MUNIC.) NPDES
PERMIT
3. INDUSTRIAL CATA-
LOGUE
1. SAMPLING STRATEGY
1. SEWERAGE SYSTEM
COMPATIBILITY
2. SURCHARGE
3. USER CHARGE
4. MONITORING STRA-
TEGIES
5. INDUSTRIAL SECTOR
MASS BALANCE S
CATALOGUE BY
POLLUTANT
1. ORDINANCE DEVEL-
OPMENT :
PRETREATMENT AND
DISCHARGE RE-
QUIREMENTS
2-11
-------
1) Census records
2) Tax records
3) Chamber of Commerce or other business organizations
4) State liquor authorities (or breweries, wineries, etc.)
5) Other licensing agencies (e.g., Fire Department)
6) State directory of manufacturers
7) Board of Health
8) Public Utilities
a) Gas and electric suppliers often bill com-
mercial and industrial accounts separately.
b) Water utilities can often identify large con-
sumers.
9) Insurance company statistics
10) Telephone directory yellow pages
Industry Classification. A preliminary questionnaire
will help identify the industries that will require more de-
tailed study. This initial survey should be limited to sim-
ple questions like:
1) What is your product(s)?
2) What is your production capacity?
3) ' How many people do you employ?
It can be conducted by mail, telephone, or in person. Most
likely some amount of personal interviewing will be necessary.
The information obtained should be sufficient to separate the
manufacturing from the non-manufacturing and dry production
firms. These latter two can then be stored in an inactive
file.
The remaining manufacturing industries should then be
surveyed in more detail in order to ascertain which firms pro-
duce wastes that are:
1) below surchargeable concentrations;
2) above surchargeable concentrations (portion to
be taxed);
3) hazardous, prohibited, or toxic;
4) resistant to treatment and likely to pass through
to receiving waters.
2-12
-------
Tasks involved with this detailed survey will include personal
site visits and interviews with plant personnel; determination
of water usage and effluent flow rates, description of unit
processes, including heating and air conditioning systems;
listing of raw materials and (if possible) preparation of
material balances for the operations; and sampling of
effluents. A flow chart, showing major equipment and piping
should be prepared.
Once the products, processes, and size of an industry
have been defined the wastewater discharges must be identified
and characterized according to:
1) flow rates;
2) waste constituents;
3) pollutant quantities (concentration and mass
discharge rates); and
4) variability of each of the above.
The literature, much of it quite recent, contains wastewater
effluent characteristics for many industrial classifications
and subcategories. The wastewater constituents to be ex-
pected from an industry, their concentrations or mass dis-
«r
charge rates per production rate, and treatment
-------
Table 2-2
PARTIAL LIST OF &FFERENCES
FOR THE CHARACTERIZATION OF INDUSTRIAL HASTES
TITLE, AUTHOR, REFERENCE NUMBER
Handbook for Monitoring Industrial
Wastewater, U.S. EPA, 1973 (4)
REVELANT TOPICS
Program planning. Waste constituents
by industry. Parameters to be mea-
sured, sampling schedule, sample vol-
umes. Sampling techniques. Data ana-
lysis. Personnel training.
Cost of Implementation and Capa-
bilities of Available Technology
to Comply with PL 92-500, Battelle,
Inc., 1975 (18).
Description of 38 industrial cate-
gories. Effluent characteristics
(constituents and concentrations).
Residuals after treatment. Avail-
able treatment technology.
Capabilities and Costs of Techno-
logy for the Organic Chemicals In-
dustry to Achieve the Effluent
Limitations of PL 92-500, 1975,
Catalytic, Inc. (19).'
Description of the industry. Plant
process analysis for 37 product/pro-
cesses. Extensive BOD/COD wastewater
characterization. Descriptions of 29
"Generalized Plants" with concentra-
tions and mass discharge rates for
various important parameters.
Capabilities and Cost Technology
for the Inorganic Chemicals Indus-
try to Achieve the Requirements
and Goals of the Federal Water
Pollution Control Act, Catalytic
Inc., 1975 (20).
Similar to above but for Inorganic
Chemicals industry.
Innovative Technology Study, Water Wastewater characteristics for 9
Purification Associates and Process major industrial categories. Advanced
Research, Inc., 1975 (21). treatment technologies
Theories and Practices of Indus-
trial Waste Treatment, Nemerow,
1963, (22).
Origin and quantitative characteris-
tics of major industrial wastes from
32 industries under: . apparel, food"
processing materials, chemicals,
energy. Treatment theory and basic
practices.
Industrial Wastes: Their Disposal Emphasizes treatment. Describes
and Treatment, Rudolfs, 1953 (23). (quality/quantity) wastes from unit
processes of 14 industrial categories.
OTHER REFERENCES
Eckenfelder, W.W. Industrial Water Pollution Control, McGraw Hill, 1966.
Patterson, J.S. Wastewater Treatment Technology, Ann Arbor Science, 1975.
Nancy, K.H., Weber, W.J., Jr., Analysis of Industrial Wastewaters, Wiley
Interscience, New York, 1971.
Lund, H.F. Industrial Pollution Control Handbook, McGraw-Hill, 1971
2-14
-------
A comprehensive industrial waste survey was conducted
in Long Island City, New York (1) . It found that of 2,000
firms identified, 82 percent did not discharge any industrial
waste, 9.5 percent contributed insignificant amounts, 5.7 per-
cent discharged toxic or prohibited wastes, and only 3 per-
cent discharged wastes in amounts that were surchargeable.
The reference given above for this survey describes in de-
tail each of the activities that were performed and is recom-
mended as an example of IWS procedures. The study noted that
an average of 172 man hours was required per firm to complete
all the tasks involved with the IWS. Surcharge formulas, or-
dinances, program organization, waste problems, and sampling
techniques are explained in the reference.
Another IWS has been described in a report by the New
Castle County (Delaware) 208 Planning Agency (2). The
planning agency itself conducted this survey which compiled,
categorized, and where necessary sampled industries discharging
to sewers in the area. In its conclusions about the IWS, the
agency suggested that a permit system, similar to the NPDES,
be initiated for dischargers into the public wastewater col-
lection system. In another study for the City of Buffalo
CNew York), consulting engineers were hired by the sewer
authority to survey the local industries, develop a monitoring
program, and develop an equitable cost recovery system in
compliance with U.S. EPA regulations. Detailed description
of the sampling and analysis of industries is given in the
engineering report (.3) .
2.3.3 Monitoring Program Options
The results of an industrial survey will provide a basis
for development of a simple and effective monitoring program.
As a first step, a working map should be drawn up to illus-
trate the list of industrial discharges that will require
2-15
-------
monitoring. This map should display the relevant sewer
lines, streets and addresses to enable personnel to quickly
locate the sources and routes of pollutants during any
routine surveillance or emergency situations. Next, each
discharge should be considered in terms of the following:
1) the reason for monitoring (e.g., surcharge or
pretreatment compliance);
2) the need for actual sampling;
3) the wastewater constituents to be measured;
4) appropriate sampling stations and their
accessibility;
5) frequency and duration requirements for sampling;
6) sampling methodology; and
7) projected sampling and reported costs for that
discharge per annum.
From this information (some of which will have been obtained
from the IWS) an overall monitoring program can be developed.
If actual sampling and measurement is required, the
options available for monitoring range from analysis of
simple grab samples at the treatment plant influent to
continuous, automatic analysis of each discharge and telemetering
the information to a central location. The degree of sophistica-
tion of a program will depend on several factors, including
the size of the system, the types of industries, and the
available resources. For example, a chemical industry would
probably already have the facilities to monitor its own
effluent and it would thus be most efficient to require it
to do so. Large sewerage systems will often have analytical
facilities at their disposal, but such systems are also
likely to have many industries to monitor and might require
a substantial expansion of existing facilities and per-
sonnel. If the costs of such expansion are to be passed on
to the industries, self-monitoring by the industries may be
more efficient. Small sewerage systems may find it best to
contract with consultants or another agency to perform
monitoring functions, but again, the industries themselves
should be considered as part of the available resources.
Below is a list of possible monitoring programs:
2-16
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MONITORING CAN BE PERFORMED PRIMARILY BY:
1) Industry
2) Sewerage Authority personnel
3) Automatic equipment
AT:
1) Industrial sites
2) Sewer junctions
3) Sewage treatment plant
1) continuous and intermittent monitoring of toxic
wastes at the source;
2) continuous and intermittent at key junction
points in the sewer system;
3) continuous^ monitoring of the treatment plant
influent;
4) industrial self -monitoring;
5) sewerage personnel monitoring;
6) private contractor monitoring.
The following briefly describes some of the options for
monitoring. In choosing the optimal arrangement for a
locality, the planning agency may possess objective informa-
tion and thus be a valuable participant in the decision-making
process.
Industrial Self-Monitoring
Similar to the NPDES approach to measuring compliance,
the self-reporting of discharge data will place responsibility
on the industries using publicly owned treatment works and
requiring pretreatment regulation. Self -monitor ing could pojsi
prove to be the most efficient approach because it will be
performed by those closest to and presumably most familiar
with the processes that are involved. Better maintenance and
optimization of pretreatment and sampling processes is likely
to occur from direct participation by industry rather than by
2-17
-------
regulatory procedures. A minimum amount of expansion of
sewerage system personnel and facilities would be required.
The success of such a program would of course depend on the
integrity and accuracy of the discharger's reports. Periodic
.. . , , _ , ^ Wl'Tl^.lnece*ga*y +
on-site compliance checks by the regulator AaHMMMMMM^
industrial diligence.
Effluent samples collected by the industry could be
analyzed in-house if laboratory facilities are available.
Duplicate samples could be sent to an independent laboratory
or to sewerage authority facilities to corroborate the results
obtained by the industries' laboratories. Alternatively,
these samples collected by industries could simply be sent to
outside laboratories. The frequency, number, and volume of
samples will depend on numerous factors discussed in
section 2.3.4.
A standard reporting procedure should be established by
the planning agency or by the agency that will subsequently
administer the program. United States EPA regulations
(40 CFR 128) state that when pretreatment standards are
promulgated, a contributor would be required to be in com-
pliance with such standards within 3 years from the date of
.*
promulgation. Thus, reports showing compliance progress
should be devised. Besides flow data and discharge rates of !
specific water quality factors, these reports should state
any changes in production capacity, raw materials, process
design, and wastewater pretreatment operations.
Sewerage Authority Monitoring of Industrial Discharges
The formation of a monitoring unit within the sewerage
authority will require field equipment, laboratory facilities
and skilled personnel. The size of the monitoring unit or
the number of monitoring teams will be determined by both the
* Note Compliance, dUfes ore, wMtar review oJonj wt'tka vtu*Wv of Issues
. Soe. R>w*o«J a*
2-18
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number of industrial contributions and the frequency at
which they must be sampled. Each field team will have the
responsibility to: 1) take on-site measurements (e.g.: flow,
temperature, dissolved oxygen); and 2) collect samples and
return them to the laboratory for analysis. Procedures for
data and sample gathering should be adequately defined and
adhered to so that the results are acceptable as official
documentation. Duplicate samples should be offered to the
industry for parallel analysis. Most often the sampling
site will be on the industry's property and satisfactory
procedures should be established for entry and use of the
premises. During the monitoring task, a member of the team
should interview a representative of the industry to discuss
any pertinent aspects of the waste discharge and to review
any required records.
It must be insured that the results of the monitoring
visit represent the complete range of conditions that are
possible for the waste discharge. For example, a complex
industry with integrated batch and continuous processes may
require several weeks to monitor wastes from one cycle of
products and intermediates. If equalization is not practiced
at the plant, a highly variable waste discharge should be
expected Ce.g., see Nemerow, (22)) and one day of sampling
will not be representative. A lengthy stay or repeated
visits by the monitoring team would be required.
A typical monitoring team might consist of one engineer
and two technicians, visiting an average of 200 industries
per year. The team would be supported by a laboratory
chemist and technician dedicated at about half time. The
engineer would interface with the industry while giving
support to the technicians. With sufficient equipment, two
sites could be sampled simultaneously. Each monitoring
visit would thus average 2 to 3 days. The engineer in
2-19
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charge would be responsible for the entire operation, in-
cluding the final disposition of information. Based on
common pay scales, the personnel cost of such a program
would roughly amount to about $300 per site. Materials,
maintenance, laboratory expenses, and overhead will increase
this figure. Multiples of these monitoring groups could be
formed as required.
Automatic Monitoring
Automatic water sampling devices can be installed at many
industrial sites. A list of some currently available units
is given in Appendix B. These units either take discrete,
timed samples of a designated volume or a composite sample
collected over a period of time. Composite samplers collect
at a rate either proportional to time, for sampling waste
streams that are essentially constant, or proportional to
flow rate, for waste streams that are variable. Discrete
samplers collect a sample volume (often 1 liter) at con-
trollable intervals that usually range from once every 15
minutes to once every 3 hours. With either type, samples
must be transported to a laboratory and then analyzed.
Several water quality factors can be automatically
analyzed on site by mechanical or electronic devices. These
devices consist of a sensor, usually immersed in the waste
stream; a signal conditioner, which receives the measurement
and usually converts it to a voltage analogue (digital machine
language may also be used); and an output device, most often
a recording volt meter calibrated to measure the signal in
pertinent units (.e.g., mg/1) . Additionally, the signal can
be transmitted to a remote output device: this is commonly
done across rented telephone lines. The capital expense for
this type of equipment is often high and frequent maintenance
is often required. It has been estimated (3) that capital
costs for automatic monitoring will run about $4,000 for each
2-20
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parameter measured, while telemetering and recording equip-
ment could cost up to $12,000 per total system. Protective
enclosures could cost up to $15,000. Below are some of the
water quality parameters that can be monitored automatically.
FLOW TURBIDITY CYANIDE
CURRENT CONDUCTIVITY AMMONIUM
DEPTH DISSOLVED OXYGEN pH
PRESSURE TOTAL ORGANIC CARBON FLUORIDE
TEMPERATURE OIL OTHER SPECIFIC ITEMS
Interference by other water quality components and
fouling effects can be a problem with such equipment.
Nevertheless, there will be situations where automatic
monitoring will be the most effective approach. Detection
of a toxic or hazardous material is one likely application.
Automatic equipment can be connected to an alarm at a given
industry or at the treatment plant.
Sewerage System Monitoring
Besides the issue of who (or what) will perform the
monitoring, the most suitable monitoring sites must also be
determined. In some cases, extensive monitoring on a
regular basis at each industrial site may not be necessary.
Monitoring key intersections or selected locations in the
sewerage system itself may be adequate. From the industrial
discharge map, these key locations could be identified.
Sampling stations consisting of automatic, semi-automatic or
manual equipment could be established in manholes and sewerage
system personnel would visit each station periodically.
Upon detection of excessive amounts of some component, the
treatment plant would be notified and the violator located
by tracking the pollutant upstream. In other cases monitoring
the municipal treatment plant influent may be adequate.
2-21
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Treatment Plant Influent Monitoring
By continuously monitoring the sewage treatment plant
influent, it may be possible to avoid a disruption of plant
functions caused by unacceptable amounts of toxic compounds.
Upon detection of such material that would interfere with
treatment operations, a predetermined influent bypass proce-
tto «,UUtM »•»* 1
dureTcould toe initiated and a field crew dispatched to locate
the source of this material. Telephone interviews could pos-
sibly identify an overt upset at a particular industry.
Given a familiarity with the types of upsets that are likely
to occur at each industry, and guided by the industrial dis-
charge-sewer map, a mobile unit should be able to backtrack
to the source and advise on remedial measures. Ideally, the
bypass detention capacity would be equivalent to the maximum
time required to locate and eliminate the toxic material in
the system, although such conditions may not be feasible.
It is improbable that a total plant failure will occur
due to the presence of a toxic compound. Instead, reduced
removal efficiencies are likely. This is particularly true
in biological plants where the microorganisms will somewhat
adapt to the sublethal conditions caused by various compounds.
Thus, upset conditions will often be somewhat obscure and the
remedial response will be less drastic than bypass and deten-
tion.
Industrial Operations Records
Presumably if an accurate materials balance is known for
a given industrial process, the composition and amount of a
waste discharge could be computed from raw material consump-
tion records or production data. Fluctuations in efficiencies
and the often disorganized status of such data for many indus-
tries would preclude employing such a technique to detect
small changes in effluent quality. However, significant shifts
in production could be detected which might call for a re-
evaluation of the monitoring of that particular industry.
2-22
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Cor 'oination of Options
Described above were some of the individual options that
are available for a monitoring program. Most likely, local
conditions will exist which resist a straightforward applica-
tion of any one approach. The needs of both industry and the
publicly owned treatment works should be realized. Economics,
reliability, simplicity, and ultimate impact upon water qua-
lity are factors for a planning agency to consider.
2.3.4 Monitoring Techniques
Where sampling will be required, a permanent. sampling
station, or control manhole, should be established. This
station should be safely and easily accessible; it should be
large enough to contain any equipment required for sampling,
measurement, or automatic monitoring; and it should be lo-
^cated so as to sample the actual discharge to the sewer.
The required frequency of sampling will depend on the
, variability of the quantity and quality of the wastewater
and the reliability of any pretreatment system in use. There
are two intervals to consider: the sample intervals for a
given monitoring event; and the monitoring event interval.
Initially, more frequent monitorina and sampling may be re-
quired until the range of variability of the discharge is de-
termined. Monitoring intervals may vary from one to twelve
months or more. Criteria for choosing the interval will be
based on: available personnel and financing the potential
impact of the constituents being monitored, the relative sig-
nificance of the pla; ' to the sewerage system operations, and
any particular requirements to measure, compliance with efflu-
PflTWI i naqft^T^uMHaty -fey *tW .
.
ent limitations^ or pretr i tffl'e H^SSgaia-ei'bTnrr^T h e potential
for the periodic discharge of slugs of pollutants should be
evaluated and measured if applicable. Sample intervals during
a monitoring event will usually range from 1 to 24 hours (Ta-
ble 2-3) . The terms "high- and low-variability" are indeed
subject to interpretation (4) .
2-23
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MONITORING REFERENCES
1) Improved Procedures for Municipal Regulation of
Industrial Discharges to Public Sewers -
Mclntire (13)
2) Handbook for Monitoring Industrial Wastewater -
EPA (4)
3) Sampling of Wastewater - Shelley (5)
4) Wastewater Sampling Methodologies and Flow
Measurement Techniques - EPA (6)
5) Standard Methods for the Examination of Water
and Wastewater - APHA (7)
6) Estimating Laboratory Needs for Municipal Waste-
water Treatment Facilities - EPA (8)
Table 2-3
SUGGESTED SAMPLING OR COMPOSITING SCHEDULE
Source: U.S. EPA Handbook on Monitoring Industrial Wastes (4)
CHARACTERISTIC HIGH
BOD3
COD or TOCa
Suspended Solids
Alkalinity or Acidity
PH
Nitrogen and Phosphorus
Heavy Metals
VARIABILITY
4 hr
2 hr
8 hr
1 hr grab
Continuous
24 hr
4 hr
LOW VARIABILITY
12 hr
8 hr
24 hr
8 hr grab
4 hr grab
24 hr
24 hr
Notes:
aThe compositing schedule where continuous samplers
are not used depends on variability, i.e., 15 rain
for high variability to 1 hr for low variability.
Does not apply to nitrogen or phosphorus wastes
(e.g., fertilizer).
The water quality factors to be measured will depend on
the industry and the purpose of monitoring. Measurements
may be limited to BOD and suspended solids for surchage in-
formation, or they may be aimed at heavy metals or specific
ions to prevent plant upsets or pass-through of these mate-
rials to the environment.
2-24
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The sampling procedure used must ensure that a truly
representative sample of the wastewater is collected. The
difference between discrete-timed samples, flow proportional
samples, and time-composite samples was mentioned in the sec-
tion on automatic monitoring„ Where suspended solids or im-
miscible fluids are presents mixing and sampling inlet velo-
city considerations will be of importance for either manual
or automatic sampling„ It is critical for both sampling and
for measurement that the technique used does not interfere
with the accuracy of the data,, The reader is referred to the
following documents on sampling;
1) Sampling of Wastewater, by P.E.D Shelley (EPA Techno-
logy Transfer) HO
2) Wastewater Sampling Methodologies and Flow Measure-
0 ment TecHnTquesJ (U,So EPA Report 907/9/-74-QQ5)TFT
The volume of sample to be collected will depend on the
physical or chemical analysis requirements for the parameter(s)
of concern and their range of concentration,, Generally, each
constituent will require 100 to lOOO ml for analysis (Table
2-4). Specific detail on each water quality parameter is
given in the U0S<, EPA handbook mentioned previously and in
"Standard Methods for the Examination of Water and Wastewater"
(published by the American Public Health Association) (7).
Upon collection of a sample it should be minimally labelled
with the date/ time, location, and parameters to be analyzed.
For some parameters, the sample must be preserved after col-
lection „ Typical contmerical prices for laboratory analyses
are listed by constituent in Table 2-5.,
Flow data is essential for computing the total mass rate
of discharge of any material to the sewerage system. There
are a variety of measurement techniques for the two types of
flow systems; open channel flow, such as in sewers; and pre-
surized flow, such as from the many industrial process units
that use pumps and pressurized reactions. For pressurized
flow, some measuring devices are;
2=25
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Venturi meter Pitot tube
Flow nozzle Magnetic flow-meter
Orifice meter Rotameter ,
For open channel flow:
Current meter Pitot tubes
Depth measurements Wiers
Depth & Surface Flumes
velocity measurement
Additionally, tracer dilution methods are useful where equip-
ment cannot be installed. Water meters and tank depths may
also provide adequate flow data. Timed collection in a cali-
brated vessel (bucket and stopwatch) is also a common flow
measuring technique.
In addition to flow measurement and sampling devices,
analytical equipment will be required. A discussion on equip-
ping an analytical laboratory is beyond the scope of this
manual, but the reader is referred to the document "Estimating
Laboratory Needs for Municipal Wastewater Treatment Facilities"
published by the Operation and Maintenance Program of the U.S.
EPA Office of Water Program Operations (8). This publication
includes specific requirements for laboratory facilities for
various sized systems as well as requirements for laboratories
handling samples from non-residential sources.
Where applicable, mobile field equipment and on-site
apparatus will also be required. Generally there are three
techniques utilized for analysis: wet chemical, electrochem-
ical, and bioassay. There are various portable and automatic
wet- and electro-chemical instruments on the market. A list
of these, the parameters that they measure, and the manu-
facturers is given in Appendix B. When selecting field equip-
ment, the following should be considered:
1) Special environmental enclosures or carrying apparatus;
2) Chemical interferences present in the wastewater;
3) Physical interferences (floating debris, grit, and
grease);
4) Microorganism fouling;
2-26
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Table 2-4
OF SAMPLE REQUIRED FOR DETERMINATION OF THE
VARIOUS CONSTITUENTS OF INDUSTRIAL WATER
Voferae of
PHYSICAL TESTS
•Color and Odor ................. 100 to 500
*Corro$ivity .................. flowing sample
'Electrical conductivity .................. 100
*pH, electrometric ...................... 100
Radioactivity ................... 100 to 1000
•Specific gravity ....................... 100
Temperature ................ flowing sample
Toxicity ................... 1000 to 20 000
Turbidity ..................... 100 to 1000
CHEMICAL TESTS
Dissolved Gases:
^Ammonia, NK^
t Carbon dioxide, free
.500
CO
'2-'
200
tChlorine, free G2 200
'tHydrogen,H2 1000
tHydrogen sulfide, H-,5 .500
tOxygen.02 7 500 to 1000
tSulfur dioxide, free S02 100
Miscellaneous:
Acidity and alkalinity 100
Bacteria, iron .500
Bacteria, sulfate-reducing 100
Biochemical oxygen demand 100 to 500
Carbon dioxide, total CO->
(including CO^JHCO^,
and free) .200
Chemical oxygen demand
(dichromate) 50 to 100
Chlorine requirement 2000 to 4000
Chlorine, total residual C12
(including OCT. HOG,
NH2C1, NHC12, and free) 200
Chloroform • extractable
matter 1000
Detergents 100 to 200
Volume of
Sample,3 ml
Miscellaneous:
Hardness 50 to 100
HydrazJne 50 to 100
Microorganisms 100 to 200
Volatile and filming amines 500 to 1000
Oily matter 3000 to 5000
Organic nitrogen 500 to 1000
Phenolic compounds 800 to 4000
pH, colorimetric 10 to 20
Polyphosphates 100 to 200
Silica 50 to 1000
Solids, dissolved 100 to 20 000
Solids, suspended 50 to 1000
Tannin and lignin 100 to 200
Cations:
Aluminum, A1+** 100 to 1000
t Ammonium,NH^* .500
Antimony, Sb*** to Sb***** ... 100 to 1000
Arsenic, As*** to AS-H-H-+ 100 to 1000
Barium, Ba** 100 to 1000
Cadmium, Cd** 100 to 1000
Calcium, Ca*+ 100 to 1000
Chromium .Cr*** to Cr"1''' • ' ... 100 to 1000
Copper, Cu** 200 to 4000
tlron, Fe** and Fe*** 100 to 1000
Lead, Pb** 100 to 4000
Mapesium, Mg-n- 100 to 1000
Manganese, Mn^to Mn"" " " ' .. 100 to 1000
Mercury, Hg* and Hg^ 100 to 1000
Potassium, K* 100 to 1000
Nickel, Ni-w- 100 to 1000
Silver, Ag* 100 to 1000
Sodium, Na* 100 to 1000
Strontium, Sr** 100 to 1000
Tin, Sn** and Sn+*** 100 to 1000
Zinc, Zn-w- 100 to 1000
2=27
-------
Table 2-4 (Continued)
VOLUME OF SAMPLE REQUIRED FOR DETERMINATION OF THE
VARIOUS CONSTITUENTS OF INDUSTRIAL WATER
Volume of
Sample,3 ml
Anions:
Bicarbonate, HC03 100 to 200
Bromide, Br* 100
Carbonate. C03~ 100 to 200
Chloride, CT 25 to 100
Cyanide, Cn" 25 to 100
Fluoride, Fl" 200
Hydroxide, OH* 50 to 1.00
Iodide, F 100
Nitrate, N03' 10 to 100
Nitrite, N02 150 to 100
Phosphate, ortho, P04~,
HP04", H,PO4- 50 to 100
Sulfate, S04~, HS04' 100 to 1000
Sulfide, S~, HS" 100 to 500
Sulfite, S03~, HSO3' 50 to 100
Volumes specified in this table should be considered as a guide for the approximate quantity of
sample necessary for the particular analysis. The exact quantity used should be consistent with the volume
prescribed in the standard method of analysis, whenever the volume is specified.
• Aliquot may be used for other determinations.
t Samples for unstable constituents must be obtained in separate containers, preserved as prescribed,
completely filled and sealed against all exposure.
2-28
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Table 2-5
SCHEDULE OF FEES - WATER ANALYSIS
TEST 5 FIRST SAMPLES
Acidity or Alkalinity $ 5.00
Aluminum 10.00
BOD 25.00
Calcium 5.00
Carbonate 10.00
Chloride 5.00
Chlorine, Free 5.00
Chromium,
Hexavalent 8.00
Total 10.00
Coliform, Membrane Filter Technique
Total 10.00
Fecal 10.00
Color
Apparent 3.00
True 5.00
Conductivity 2.00
Copper 8.00
Cyanide
Free ' 10.00
Total ' 15.00 '
Detergents (L.A.S.) 10.00
Fluoride 10.00
Grease & Oil 15.00
Hardness, Total 5.00
Iron 8.00
Magnesium . 5.00
2-29
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Table 2-5 (Continued)
SCHEDULE OF FEES - WATER ANALYSIS
TEST 5 FIRST SAMPLES
Nitrogen
Ammonia - Direct Nesslerization 8.00
Ammonia - Distillation 10.00
Kjeldahl 15.00
Nitrate 10.00
Nitrite 10.00
Oxygen Demand, COD 12.00
pH 2.00
Phenol . 20.00
Phosphorus, Total 10.00
Phosphate
Total 10.00
Ortho 8.00
Metals by Atomic Absorption Spectrophotometry 10.00
Solids
Dissolved 5.00
Settleable 5.00
Suspended 5.00
Total 5.00
Volatile 5.00
Sulfate 8.00
Sulfide
Direct Determination 8.00
Distillation 12.00
Silica 8.00
Turbidity 2.00
2-30
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5) Calibration and reagent stocking requirements;
6) Cost: automatic or kit-form equipment costs are high,
but the use of such equipment may save time and thus
personnel costs;
7) Simplicity and dependability: available personnel
should be capable of performing routine and repair
maintenance;
8) Data: the analytical technique must be accepted by
regulating authorities.
In cases where sewerage system personnel are performing
a substantial amount of the monitoring, a well-equipped mo-
bile laboratory would be a worthwhile investment. The cost
of such a unit would be about $20,000. This unit could also
aid in emergency detection of hazardous and toxic discharges.
Personnel Requirements
The technical personnel and their classification will
vary according to the organizational structure of the sewerage
authority. Preferably, the manager of an industrial survey
•
and monitoring program will be an engineer who is familiar
with industrial processes, their wastes, and wastewater treat-
ment. Depending on the size of the program, direct subordi-
nates may be field technicians and laboratory personnel; other
engineers may be required to direct the field operations and
laboratory group(s). Technicians must be able to operate and
maintain all of the equipment as well as understand the basic
concepts of chemistry and wastewater treatment. The educa-
tional background for technicians could be a recent B.S., or
engineering degree with no experience, an associate degree,
or a high school degree with directly applicable experience.
As previously mentioned, a field team of one engineer and two
technicians may be able to monitor about 200 industries per
year.
Results of a Monitoring Program
The information acquired from monitoring must satisfy
the stated objectives of the program. It must be easily ac-
cessible and in usable form, and it must be of acceptable
2-31
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precision and origin to satisfy any requirements of regula-
tory or legal authorities. Besides serving as potential evi-
dence in legal enforcement proceedings, the data may be use-
ful in designing future wastewater treatment procedures for
each particular industrial category. A general description
of the data according to monitoring objectives is described
below.
Hazardous and Toxic Materials. It is imperative
that this information be transferred quickly to
the treatment plant operator so that he may take
precautionary measures if such action is required.
The most expedient method would be an~alarm panel
at the treatment plant. If a material is being
measured at the treatment plant, influent data
will most likely be either in concentration units
or presence/absence notation. In the event of an
alarm for any material, any available data should
be carefully logged for future documentation. For
industrial site monitoring of these materials an
alarm procedure must be established. When a pre-
determined upper limit for a given compound is
exceeded, notice must be given to the treatment
plant. A log should be kept of the measurements.
This could consist of strip charts from a record-
ing instrument. Periodic reports should be sub-
mitted to the regulating authority.
Surcharges and User Charges. User charges are im-
posed upon an industry according to the fraction
of the total sewerage system that it uses. Waste-
water flow data will most often suffice for user
charge evaluation. Surcharges are often required
of industries that discharge wastes in excessive
amounts over an "average" concentration for that
locality. Most often surcharges are imposed for
BOD and suspended solids, which are the two pri-
mary water quality components that most treatment
plants are designed to remove. A surcharge for-
mula will require flow and concentration data
(e.g., mg/1, Ib/million cu ft) for each parameter
of concern.
Compliance. Whether or not an industry pretreats
wastes, regulations will exist for the quantity
and quality of wastewater allowable from each industry.
These regulations will range from "no limitation"
to "zero discharge" with various concentration or
mass discharge limits in between. For an industry
to report on compliance, their data will be in the
form (e.g., mg/1) identical to the regulation for
each parameter. Strip charts or signed log sheets
should be submitted with any reports.
2-32
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Sample forms for recording monitoring data are given in
\ppendix B. A "Data Summary Form", "Compliance Monitoring
Log", "Toxic or Hazardous Compounds Monitoring Log", and a
"Sample Bottle Label" are included in the appendix. These
forms may require modification to suit individual local re-
quirements, but generally they will be appropriate for most
needs.
2.3.5 Development of the Sewer-Use Ordinance for an Indus-
trial Pollutant Control Program
Traditional municipal sewer use ordinances* define pro-
grams and limitations for controlling the quality of indus-
trial dischargers to sewers. These ordinances should be re-
sponsive to individual characteristics of the municipality.
For example, the waste treatment needs of a community with
diverse industries, but centrally located, may be very dif-
ferent from areas with scattered or with only one predominant
industry. This section defines the nature of an ordinance
j^ind discusses its development. Administration and enforce-
ment of ordinances is discussed in the next section entitled,
Legal Control Elements.
Information required for Ordinance Development. For an
ordinance to be effective in preventing sewerage system up-
sets and pass-through of undesirable materials to receiving
waters, information from many sources should be analyzed and_
integrated before preparing the ordiance. The most likely
data sources include the IWS, Regional Master Plans, EPA, 201
Facilities Plans, and Water Quality Management (WQM) Plans;
these will yield information on water quality goals, POTW
capabilities, and growth projections (Table 2-6).
The procedures for developing an ordinance are highlighted
in Figure 2-2 (page 2-4). The arrows suggest the sequence of
information acquisition and thus the logic guiding ordinance
development. For example, the industrial waste survey (IWS)
and other regulatory devices.
2-33
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necessarily precedes^the development of the ordinance. It
identifies the industries and their effluents that will be
subject to pretreatment regulation. In cases where ordinances
have already been developed prior to the development of va-
rious water pollution control plans or before the IWS has
been completed, review and update of the ordinance will be
necessary.
The Ordinance Development Committee. The ordinance is
not only a legal document but a technical and managerial ref-
erence. The committee that develops it should include indi-
viduals with expertise in the fields of environmental engi-
neering, law, management, planning and health. There should
be representatives from all the government jurisdictions as
well as industrial representatives, private individuals (en-
vironmentalists) and attorneys. The following list of indi-
viduals constitutes an ordinance committe.
1) Representative of 208 areawide planning agency;
2) The top supervisory official, who will have respon-
sibility for the administration and execution of the
requirements of the final document;
3) The municipal attorney;
4) The municipal or city engineer;
5) The head of the local sewerage system or public
works department;
6) The superintendent of sewers or sewage treatment;
7) The chief operator of the local sewerage-treatment
plant;
of
8) The chief chemist ^£ chief laboratory technician
of the local city or sewage or water-treatment
plant;•
9) A representative, or several, of the important
local industries;
10} A local private sanitary engineer with experience
in industrial-waste treatment, or a representative
of the regular consultants of the city;
11) A representative of the local health department;
12) A representative of the state health department
or pollution control agency;
13) The city planning engineer, if there is one.
2-35
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Elements of an Ordinance. The Journal of Water Pollution
Control Federation published guidelines for drafting a sewer
use ordinance and a model ordinance, "Manual of Practice 3:
Regulation of Sewer Use" (10). The model includes many of
the necessary elements for a general ordinance. The infor-
mation presented below discusses those elements relevant to
industrial dischargers to municipal sewer systems.
Unmodified application of this model is not likely
because individual municipal ordinances should reflect local
needs, statutes, regulations, and policies. Below is a list
of the elements of an ordinance:
I. Introduction of the Ordinance - The first section of
the ordinance should state the purpose, jurisdiction
and scope of the document.
II. Definition of Terms - The ordinance, a technical as
well as legal document, will employ specific language.
Specialized terms should be defined. A suggested
reference is: "Glossary-Water and Wastewater Control
Engineering", published by the Water Pollution Con-
trol Federation (11).
III. Prohibited Wastes - The ordinance should clearly iden-
tify categories of wastes that may not be discharged
m*y
into public sewers. These prohibited wastes •••. in-
ffeU*»faqj
elude the • categories: ••••••^••••••••••••••fe
^
1) wastewaters with pollutants- that create- -a
fire or explosion hazard in the POTW;
2) wastewaters which will cause corrosive damage;
3) wastewaters which contain solid or viscous
- wastes in amounts which would cause obstruc-
tion to flow or interference in the POTW;
4) YMstevwfat towtauttM V>t«f m «.*
-------
or Q*
5) a volume of wastewater ^released in a slug
discharge* as to cause treatment plant upset.
IV. Toxic Wastes - the discharge of wastewater con-
taining toxic pollutants should be limited.
Although Federal standards for toxicants have not
been promulgated to date, State and local health
and water resource boards may very well give
guidance on toxic limitations.
V . Industries Subject to Indirect Discharge Limita-
tions - The industries to which the municipal ordinance
is to apply should be clearly stated.
VI. Indirect Discharge Limitations - Industrial
indirect discharge limitations should be presented
and should reflect minimally •• Federal pre-
treatment standards. flMBAHhBBMBMMpBHHHBM*
••••pHHfe The limitations are described in
terms of both pollutant concentration and quantity
of discharge (mass discharge rate).
VII. Sampling and Analysis - Legal provisions for moni-
toring should be included in the ordinance.
Reporting procedures and stipulation for inspec-
tion by local authorities or their designated
agents should be defined. General and minimum
requirements for flow measurement, sample collec-
tion, and laboratory analysis should be presented.
*Slug Discharge: ^the release of wastewater such that the
average hourly discharge over any period of two-hour dura-
tion is more than twice the daily average hourly discharge.
i.e., a slug discharge is: Hourly average over 2 hours _
Hourly average over 1 day
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Furthermore, procedures for setting, approving
and subsequently requiring specific monitoring
activities should appear in this part of the
ordinance.
VIII. Enforcement and Penalties - Administrative enforce-
ment proceedings prior to court actions should be
delineated. Violators of the ordinance may be
assessed fines and other penalties. The ordinance
should clearly define the penalties and the pro-
secution procedure. Schedules of compliance
should be stated.
IX. Financial Information* -
Section 204(b)(l)(B) of the Federal Water Pollution Control Act
Amendments of 1972 (PL 92-500) requires that Industrial users of the
treatment works make payments for that portion of the cost of constr-
uction of such treatment works (as determined by the Administrator)
which 1s allocable to the treatment of such Industrial wastes.
For $it4er
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XI. Regulation for Building New Sewer Connections -
The ordinance may include regulations for new
sources and their sewer connections. This could,
however, require a separate permit and ordinance.
XII. Legal Requirements - The ordinance must be enacted
in accordance with State and local laws. The last
section of the ordinance should include:
- A validity clause to insure there are no
conflicts with other regulations;
- An enacting clause with the date the law is
to be legally enforceable; and
- ,Proper signatures and attests of appropriate
officials.
An Alternative to the Traditional Ordinance
An alternative approach to development of the sewer use
ordinance is to draft a general enabling ordinance to pro-
vide authorization and regulations for specific industrial
'
wastewater treatment contracts^ (1 3 ) . The general enabling
ordinance would include policy statements, methods for the
negotiation and development of the individual contract, and
the general provisions of the contracts. Specifically, each
contract would:
1) establish the relationship between the units of
product and the character and quantity of waste;
2) require installation of a control manhole, con-
tinuous flow measuring device and sewer shut-off
mechanism;
3) establish an industrial self-reporting system; and
4) delineate specific control remedies for non-
compliance.
An example of the general ordinance has been included in
Appendix C. Individual contracts are discussed further in
Section 2.4.5 under "Agreements".
2 . 4 Legal Management Elements
2.4.1 Introduction
The purpose of this section is to identify and examine
some of the most important legal issues which should be
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considered in developing and implementing an industrial
pretreatment program. The roles of the Federal, State and
local water pollution control and planning agencies and the
POTW operators in carrying out such a program will be dis-
cussed. Control measures which may be implemented at each
level of governmental organization will be considered.
Finally, this section will address the types of enforcement
actions which may be taken by the various governmental
entities as well as private citizens to insure compliance
with the industrial pretreatment program.
The legal problems inherent in the implementation of an
effective industrial pretreatment program become particu-
larly complex when the POTW is under the jurisdiction of a
regional authority which does not have legal control over
the industrial users of the system. Indeed, some regional
authorities do not even have the ability to effectively con-
trol the discharges from the municipal users. For example,
in the Boston area, the Metropolitan District Commission
(MDC) acts essentially as a waste treatment wholesaler
serving some forty municipalities. It is not clear whether
the MDC has the legal authority, under any circumstances, to
refuse wastes from any member municipality.
2.4.2 Federal Role
The Federal Water Pollution Control Act Amendments of
1972 (the "Act") requires the operator of a POTW to be able
to exercise control, either directly or indirectly, over
industrial users. Section 301(a) of the Act prohibits the
discharge of any pollutant into waters of the United States
by any person (including municipalities and sewerage dis-
tricts) , except in compliance with a permit containing
certain effluent limitations applicable to such person,
incremental dates for compliance and other requirements of
the Act. The permit is issued either by EPA or the state
pursuant to the National Pollutant Discharge Elimination
System (NPDES) as set forth in Sec. 402. In order to enable
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the POTW to meet the effluent limitation requirements, one
of the principal premises of the Act is that industrial
users of a POTW will pretreat their wastes to the extent
necessary to remove all substances incompatible with the
process for treatment of domestic wastes. To implement this
objective, Sec. 307(b) requires the Administrator of EPA to
establish pretreatment standards for incompatible pollutants
discharged by industries into POTWs that (a) are not sus-
ceptible to treatment (pass through the POTW and into the
receiving waters) or (b) may interfere with the operation of
the POTW.
In addition to the EPA pretreatment standards, it may
be necessary for municipalities to impose supplemental con-
trols on industrial users in order for the POTW to meet its
NPDES requirements. The extent to which such additional
controls may be necessary will depend on the strength and
quantity of the industrial pollutants, the quantity of
domestic waste, the size and length of connecting and inter-
cepting sewers and other factors. Some of the EPA regional
offices (principally those on the east coast) have attempted
to deal with this issue directly by including in the NPDES
permits for POTWs a requirement for adoption and implementa-
tion of sewer use ordinances and other legal controls to
regulate the entry of industrial pollutants into the POTW.
2.4.3 Federal Means of Control
The principal means of Federal control over industrial pretreatment
is through the promulgation and direct enforcement of pretreatment stan-
dards pursuant to section 307 of P.L. 92-500. Additional legal possibil-
ities include prohibitions on new sewer connections, imposition of indus-
trial self-monitoring and reporting requirements through section 308 of
the Act, and financial incentives through 208 planning grants,
[((•. and the EPA construction grants program.
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pcrmnrmu
Table 2-7
ENFORCEMENT MATRIX OF PRETREATMENT REGULATIONS
10*4 WQMJ
ADMINISTRATIVE
JUDICIAL
Federal
Review of Section 20llT(208^%Ml
«wfe*9H«4*i* plans
Grants and financial incentives
-Construction grants and
-Government procurement
of goods
Orders of compliance
-Schedules
-Fines
Civil Actions for
noncompliance
-Permanent or
temporary
injunctions
-Compliance
schedules
Judicial Review
State
Issuance of NPDES permits
Enabling Legislation
Aid to POTW (Capital Costs
(N.H.) O.M. Costs (N.Y.))
Civil Actions based on
State Statutes, NPDES
permits if issued.
Regional
Areawide planning agencies
-Grant approval
-NPDES review
Municipal
POTW** operating authority
-Requirement of industry
reporting
-Regulation of input to
sewers - tie-ins
-Imposition of surcharge
Hearings
Civil actions based on
ordinance, agreements
-Injunctions
-Damages award for
non-compliance with
local authorities
Individual
Civil actions against
violators for non-
compliance with
effluent standards
Civil actions against
EPA for failure to
meet requirements
of PL 92-500
*Section 20i^;208 *w*"t01 refer to sections of PL92-500, the
Federal Water Pollution Control Act Amendments of 1972.
**Publicly Owned Treatement Works.
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Federal Enforcement
The industrial pretreatment requirements may be con-
tained in standards set by EPA under Section 307, and they
may also be contained in control measures adopted by the
States or the local operator of the POTW. EPA could enforce
the POTW for violation.of'an effluent limitation contained
in the NPDES permit issued to the POTW (caused by high
yotr W* tftH*TUfwoe.T»«w» i*
-------
New Sewer Bans
EPA has authority under the Act to prohibit any new
users from discharging to the POTW if the POTW is not in
compliance with all the conditions of its NPDES permit. One
common cause of non-compliance could be that an industrial
user is not meeting its pretreatment requirements. The
authority for this control is contained in Section 402(h)
which allows EPA to obtain a court order prohibiting the
discharge of pollutants into a POTW by any source not
utilizing the POTW prior to the EPA finding of an NPDES
permit violation.
Industrial Self-monitoring
EPA also has authority to require industrial users of POTW's to
monitor their effluents and keep records of that monitoring under sec-
IFPA!
Mt££J
tion 308 of the Act. IfTrollowed up by spot-checking of monitoring and
n
record-keeping performed by industry, industrial self-monitoring could
become an effective mechanism for insuring compliance with Federal pre-
treatment standards. The authority for EPA to enter the premises of
industrial users of POTW's, sample effluents, and inspect records is
also contained in section 308.
Grants and Financial Incentives
Section 204 (a) of the Act provides that before approving
grants for POTWs, the Administrator of EPA shall make
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certain determinations. One such determination is "that
such works are included in any applicable areawide waste
treatment management plan developed under Section 208".
(Section 204 (a) (1)). Section 208(b)(l) provides that
(208) planning agency shall, within one year after its
designation, have in operation "a continuing areawide waste
treatment management process." An initial plan prepared in
accordance with the continuing process is to be certified by
the Governor and submitted to the Administrator not later
than two years after the planning process is in operation.
The plan prepared under such process must include various
specified items, including a regulatory program to assure
that "any industrial or commercial wastes discharged into
any treatment works in such area meet applicable pretreat-
ment requirements". (Section 208(b) (2) (C) (iii)) . The
phrase "applicable pretreatment requirements" is not limited
to those established under Section 307, and therefore pre-
sumably would include any standards set by the-State,
regional, authority, or political subdivision. Thus, the
Act requires that a WQM plan be in effect within three years
after designation of the 208 planning agency and that there-
after no construction grants for a POTW be made by EPA unless
the proposed POTW is included in the 208 plan.
Another determination which the Administrator must make
before approving a construction grant is "that the appli-
cant... has made adequate provisions for assuring proper and
efficient operation..." (Sec. 204(a)(4)).
"TVUs
Z-4S*
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A further means to assure compliance with pretreatment
requirements is Section 208(c)(l) which requires that the
Governor designate one or more waste treatment management
agency for each designated 208 area at the time a plan is
submitted to EPA for approval. This agency will be respon-
sible for the operation of the POTW in the 208 area.
Section 208 (c) (2) provides that the designated management
agency shall have adequate authority —
(A) to carry out the WQM (208) plan,
(H) to refuse to receive any wastes from any munici-
pality which does not comply with any provisions
of an approved plan,
(I) to accept for treatment industrial wastes.
The WQM plan must provide that each municipality enact
and enforce measures of control (such as a sewer ordinance),
as discussed in Section 2.3.5, to ensure compliance by the
industrial users with necessary pretreatment requirements.
The management agency must have the authority to refuse to
accept the wastes from a municipality if it does not enact
such controls or does not enforce them effectively against
an industrial user under its jurisdiction.
Section 208 (d) provides that after a waste treatment
management agency has been designated and a plan for the
area has been approved, EPA shall not make any grants for
construction of a POTW except to such designated agency 'and
for works in conformity with such plan. At this point, it
is not clear what entities will be designated at the manage-
ment agencies since no designations have been made.
-------
Another means of using Federal financial assistance to
encourage POTWs to comply with clean water standards,
including pretreatment requirements, is making a POTW in
noncompliance with applicable standards ineligible for any
federal contracts, grants or loans. The authority for this
control is found in Section 508 (c) of the Act which requires
the President to issue an order requiring each Federal
agency to adopt regulations and procedures to ensure that no
person, including States and local units of government,
found by EPA to be in violation of requirements of the Act
will receive any Federal contracts, grant or loan. EPA has
issued regulations to implement the order issued-by the
President under Section 508(c) (see 40 CFR Sec. 15.1).
Under these regulations, EPA will maintain a list of violat-
ing facilities which EPA determines are in noncompliance
with a requirement of the Act, including specifically con-
ditions contained in an NPDES permit. The EPA regulations
provide an exemption for any grant or loan for the purpose
of assisting a facility to comply with an environmental
pollution regulation (Sec. 15.5). Therefore, although a
listed POTW would remain eligible for construction grants
from EPA for improvement or expansion of the POTW, the
listed POTW would not be eligible for loans or grants from
other Federal agencies for purposes unrelated to abatement
of environmental pollution.
-------
o'-'lr-" K'- ••-.-'",.•-' Y -• S.'i' .5t v- .
2.4.4 State Role _.,, ,
The statutes of many States require the water pollution
control agency to establish pretreatment standards for
industries discharging into a POTW. However, in some States,
the agencies are not exercising this responsibility. For
example, the water pollution statutes of Massachusetts and
New Hampshire require their respective water pollution con-
trol agencies to establish pretreatment standards for indus-
tries discharging into a POTW. Under these statutes, the
municipalities are prohibited from accepting industrial
wastes into their facilities which do not comply with the
State established standards. However, despite these
requirements, neither State agency has established pre-
treatment standards for existing users, or taken any other
action with respect to pretreatment. Instead, the State
agencies are looking to the municipalities to handle the
entire pretreatment program. However, the water pollution
control agency in Massachusetts does require proper pre-
treatment for new industrial tie-ins, and enforces this
requirement through its authority to issue permits for new
sewer connections. The agency has used this authority to
deny permits to new users, if overloading would result. It
has not exercised the authority to prevent incompatible
pollutants from entering the system. However, a recent
Federal court case involving a regional sewerage system
indicates that such authority could be validly used for this
purpose. In Smoke Rise v. Washington Suburban Sanitary
Commission, 8 ERC 1350 (D. Md. 1975)(a), the court upheld a
moratorium declared by the State department of water pollu-
tion control on additional hook-ups to the regional public
sewer system as a reasonable exercise of the State's police
powers and denied the plaintiff's claim that it was a
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"taking" requiring compensation under the U.S. Constitution.
The moratorium was declared because the POTW was providing
inadequate treatment which caused "discharges of raw and
inadequately treated sewage into the waters of the state,
which waters are being, or are likely to become polluted in
a way dangerous to health, thereby constituting a menace and
nuisance prejudicial to the health, safety and comfort of
the public". Moreover, a State with an approved NPDES
permit program under Section 402(b) of the Act can prohibit
new tie-ins to the POTW of the State which has found a
violation of any of the conditions in the NPDES permit
applicable to the POTW (see Section 402(h) of the Act).
Grant and Financial Incentives
Under the Act, the Federal share of the capital cost of
a POTW is 75 percent (Sec. 202(a)), and the applicant (POTW)
must agree to pay the non-Federal share. There is no
requirement in the Act that the States pay any portion of
the .capital costs. However, most States.do participate in
the non-Federal share of the capital costs. Thus, the State
may use its grants assistance as leverage to insure proper
operational maintenance of the POTW, including a requirement
for an effective industrial pretreatment program. Moreover,
the States may utilize this assistance in a manner better
designed to effect compliance with the pretreatment program
than the federal assistance. For example, under the law of
New Hampshire, the State share of the construction costs is
payable over the period of the bond issue, usually 20 years.
This procedure allows the State to stop payment at any time
during the 20 year payout period if the municipality is not
meeting the State requirements. The State has exercised
this authority and is using it now by withholding payments
from Nashua. The State considers this withholding authority
to be a very effective device for improving plant perfor-
mance.
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In addition to providing grants for construction of
POTWs, some states (New York and Pennsylvania, for example)
have programs to provide financial assistance for the opera-
tion and maintenance of the POTW. Such programs contain
controls to insure that the operator of the POTW will take
necessary measures to prevent incompatible pollutants from
entering the system and interfering with the proper opera-
tion of the plant. For example, the enabling act which
creates this program in New York requires, as a condition
•for the grant, that the POTW operator must submit evidence
that "the applicant municipality has enacted and is enforc-
ing appropriate ordinances or regulations to maintain such
controls as are necessary to regulate the use of the sewer
collection systems and sewage treatment works to insure that
the sewerage systems will not be adversely affected". This
requirement compels the municipality to enforce pretreatment-
standards against its industrial users. The New York law
provides for an annual inspection of the POTW by a State
representative whose certification of compliance with the
applicable standard is necessary for the POTW to remain
eligible for State assistance. One of the standards is that
the POTW is being operated in accordance with the discharge
permit, which, as discussed above, will contain industrial
pretreatment requirements.
State Enforcement
If a State has not been delegated the NPDES permit
program, the State nevertheless may take an enforcement
action against a discharger where the State permit program
parallels the NPDES program or where the State law authorizes
State officials to enforce a Federal NPDES permit. In
addition, a State may commence an enforcement action against
94tUwAo»«L
an industrial user for violating a pretreatment !••<:; M jar am girt:
established under Section 307 of the Act. The State may
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also commence an enforcement action against a municipality
for violating an effluent limitation of its NPDES permit
under the "Citizen Suits" provision contained in Section 505
of the Act. The latter enforcement action may occur under
two circumstances:
1) when an industrial discharge causes a POTW upset
and this in turn causes the POTW to violate an
effluent limitation for a pollutant such as BODS.
SpeVttt
2) When a POTW NPDES permit contains a UMQMM limita-
tion (such as metals) and where an industrial dis-
charge causes a POTW to violate its permit due to
"pass thru" as a result of a POTW design limita-
tion for this pollutant.
Section 505 allows "any citizen" to commence a civil action
for certain violations and the term "citizen" defined in
Section 505(g) as a "person", which term is defined in
Section 502(5) to include a "State". See Section 2.4.6
below for a discussion of actions which may be taken under
the "Citizen Suits" section of the Act.
If a State has an approved NPDES permit program under
Section 402(b), it can bring an action against the POTW for '
the violation of any conditions of the permit. It should be
noted that under the Citizens Suit section, a suit can be
brought against the POTW only for violations of an effluent
standard or limitation. Indeed, the State NPDES program
will not be approved unless the State has the authority to
abate violation of a permit, including levying civil and
criminal penalties (Sec. 402(b)(7)). Moreover, in order to
qualify for the NPDES program, a State must also have the
authority to insure that an industrial user of the POTW will
comply with the pretreatment standards set under Section 307
(see Sec. 402(b)(9)).
2.4.5 Local Role (Municipalities, sewage districts, etc.)
Responsibility Under NPDES Permits
No POTW may discharge treated wastes into waters of the
United States except in accordance with the terms of an
NPDES permit. Generally, such permits require the POTW to:
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1) meet certain discharge limitations for specified
pollutants based on a monthly and weekly average
and daily maximum, (these limitations may not be
met unless the industrial users of the POTW per-
form pretreatment, which may be more extensive
than required by the EPA issued standards under
Section 307),
2) undertake a survey of industrial users to deter-
mine the volume, constituents and strength of
their wastes and establish a schedule for each
user for the installation and operation of the
necessary pollution control equipment.
As noted in Section 2.4.2, some EPA regions also require the
operator of the POTW to have in effect a sewer use ordinance
or some other legal measure to control industrial discharges
into the POTW.
Instead of requiring eachjindustrial user to pretreat
its own wastes, the POTW couldlinstall and operate the pre-
treatment equipment at the POTW/ll If it is technologically
feasible, the latter procedure might be more cost-effective
than requiring each industrial user to install and operate
its own equipment. In th'is case, the industrial user would
be required to pay its share of the capital costs of such
pretreatment facility through the industrial cost recovery
program under Sec. 204(b)(1)(B) and an increased share of
operation and maintenance under the user charge requirement
of Section 204(b)(1)(A). In either situation, the POTW must
have the authority to either require the industrial user to
install and operate pretreatment equipment or to pay its
share of the capital costs of constructing such equipment at
the POTW.
Legal Authority
The entity which owns the POTW, and the management
agency designated under Section 208(d), if different from
the owner, must have sufficient legal authority to effec-
tively control the wastewaters of the industrial users.
If the area serviced by the POTW is confined to the
boundaries of a political subdivision of a State (such as a
city or county), the legal authority is relatively clear.
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Such political subdivisions can control the wastes discharged
into the public sewers by industrial users located within
their jurisdiction under their inherent police powers. On
the other hand, more complex problems arise in the case of
a regional authority created to handle the sewage of several
political subdivisions. If the regional agency is establ-
ished by the political subdivisions themselves, such agency
will have only those powers as are specifically delegated to
it in the compact or agreement creating it. Municipalities
may be reluctant, for political reasons, to surrender to a
regional agency the authority to regulate the wastes con-
tributed by their industries as well as the power to set
sewage treatment rates charged to those industries. If the
regional agency is created by the State legislature, such
agency will have those powers specifically granted in the
enabling act. This act may include controls over individual
users located within the political subdivisions.
However, many existing regional sewerage authorities or
districts are not able to legally interface with industries
in the system. This is because the enabling acts have not
given the authorities the power to control the discharges
into municipal sewers which in turn connect to the sewers
controlled by the regional agency. In such instances, the
development and enforcement of ordinances controlling the
input of industrial wastewaters is legally the responsibility
of the individual municipalities in the system. They may
look toward the regional agency for guidance in developing
effective controls, but nevertheless the municipalities in
these cases retain the legal authority and the responsibility
of controlling these industrial users.
It should be remembered that whether the regional
agency is created by compact or by special act of the
legislature, the agency does not have any inherent police
powers to control the discharges of the users.
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Although the enabling act creating the regional agency
may give it the legal authority to control only discharges by
the municipalities, and no direct authority over the indiv-
idual users, a method of operation may be informally agreed
upon between the agency and the municipalities (apart from
a formal compact) which in effect gives the agency control
over the users. For example, the enabling act creating the
Greater Lawrence Sanitary District in Massachusetts author-
izes the Commission to establish rules and regulations
covering the discharge of wastwater into sewers under its
control. However, the District only actually controls the
interceptor; it does not control the industrial tie-ins.
Despite this legal limitation, the municipalities included
in the District want the Commission to be able to effec-
tively control all wastes entering the District's intercept-
ors. This is because the District owns the treatment plant
facilities and has funds to employ professional personnel to
operate the plant and to obtain and maintain laboratory and
metering and sampling equipment. The municipalities,
however, do not have sufficient funds to perform those tasks.
Accordingly, with the consent of the municipalities the
District requires each industrial user (those already tied-in
as well as new users joining the system) to make written
application to the District for a discharge permit. The
application must set forth the volume and strength of all
the pollutant constituents in the applicant's effluent.
The permit will contain the necessary treatment requirements
for effluent beyond the tolerances of the treatment plant.
The District also is preparing regulations which will include
re^i*«M«e4r
pretreatment_ oteandai'da. It is expected that each municipality
in the District will adopt a sewer ordinance consistent
with the District's regulations.
The Lawrence.District requires each industrial user to
provide access through a manhole to its wastes and to allow
the District's inspectors to enter the manhole and use port-
able meters and monitors to determine the flow and pollutant
2-53
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constituents of the effluent. The District sends bills
directly to the industrial users for treatment services and
payment is made to the District through the municipalities.
Although the District has no direct enforcement auth-
ority over the industrial users, pressure can be and is
applied through the municipalities with the ultimate recourse
of cutting off a municipality in which an industrial user
who refuses to meet the District's requirements is located.
Of course, such action is rather extreme and might, as a
practical matter, never be used because of the tremendous
health problems it would cause to the municipality involved.
Local Means of Control; Introduction
The principal means for local entities to control the
pollutants discharged into the POTW by industrial users of
the system are the sewer ordinance, rules and regulations,
•wunicipally issued sewer discharge permits, and agreements
between the discharger and the manager of the POTW. The
most commonly used means of control is the sewer ordinance. '
However, rules and regulations issued by an administrative
agency sometimes are utilized to add greater specificity to
the ordinance. In addition to the ordinance and the rules
and regulations, permits may be issued to the industrial
users to set forth the specific quantity and quality of each
user's discharge and to place the user on a schedule leading
to final compliance with the pretreatment and effluent
limitation requirements. Finally, an agreement between the
industrial user and the POTWs operator may be appropriate
in situations where there is one principal industrial user
of the POTW.
Sewer Ordinance
A municipality has the authority to enact a sewer use
ordinance under its police powers, which include the power
to act to protect the public health, safety and general
welfare. The NPDES permits covering POTW discharges issued
by some EPA regions require the permittee to have in effect
by a specified data a sewer use ordinance or some other
similar legally enforceable device to control the discharges
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An Alternative to the Traditional Municipal Ordinance
Municipalities may choose to enact sewer-use ordinances
with general enabling provisions: The statv^ would
allow for specific contracts negotiated with individual
industrial dischargers. The enforcement mechanisms would
be established by mutual agreement of industry and munici-
pality and would emphasize these three civil proceedings:
1) Surcharges for wastes in excess of the
amounts contracted for;
2) Payment of costs incurred by government as
a result of damage caused by industrial
discharges not contracted for, and
3) Termination of treatment service (for very
serious infractions).
Citizen suits based on industries not meeting their
contractual obligations stipulated in the agreement would
be adequately provided for in the ordinance. Industries
would monitor their own discharges according to the con-
tract. This alternative stresses the active involvement
of industry in setting enforcement procedures (13).
of users. For example, General Condition' 20 of the NPDES
permits issued to the operators of POTWs in Massachusetts
requires the permittee to have in effect a sewer use ordinance
and/or Rules and Regualtions, acceptable to the Regional
Administrator which at a minimum:
1) prohibits a major contributing industry from dis-
charging any incompatible pollutants in an amount in
excess of that allowed under the EPA pretreatment
standards, and
2) requires all major industrial dischargers to perform
such monitoring of its discharges as the permittee
may reasonably require.
Rules and Regulations
Apart from the general authority of municipalities to
enact sewer ordinances under the general police powers, a
State enabling act may authorize municipalities and sewer
districts to adopt rules and regulations governing the use of
sewers. For example, Chapter 83, Section 10 of the
Massachusetts General Laws authorizes a city, town or sewer
2-55
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district to prescribe rules and regulations regarding the
use of public sewers to prevent the entrance of any substance
which may tend to interfere with the flow of sewage or the
proper operation of the sewage system and the treatment and
disposal works. This section also allows for penalties of
up to twenty dollars for each violation of any such rules or
regulation. Rules and regulations may also be utilized in
conjunction with a sewer ordinance. The ordinance may set
forth the general provisions and authorize a specified agency
to issue rules and regulations from time to time interpreting
and further implementing the ordinance. The rules and regula-
tions can provide quite specific limitations on the contri-
butions of whole industrial categories or each individual
user and can be revised as necessary by the implementing
agency. The ordinance, on the other hand, can only be
changed by action of the City Council or the Town Meeting.
Permits
In addition to the sewer ordinances and rules and reg-
ulations, the operator of the POTW also may want to
develop a permit system under which permits are issued to
each industrial user. The permits set forth .the specific
allowable rate of flow and pollutant constituents of the
was.tes for each permittee. This device may be particularly
useful if the municipality can identify possible problems
with the users complying with the ordinance. The permit,
may contain a time schedule for performance of certain
acts toward final compliance, such as ordering, installing
and operation of the pretreatment equipment. Violation
of any provision of the permit, including the compliance
schedule, would warrant an enforcement action against the
permittee. A permit system is being used in the Greater
Lawrence Sanitary District as discussed above.
Agreements
In areas where there are a limited number of major
industrial users of the POTW, separate written agreements
between the municipality and the industrial users may
2-56
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be ah effective method o'f control. For examplef""in_ the
Town of Merrimack, N.H., the POTW was specially designed to
handle the brewery wastes of the Anheuser-Busch Company.
Therefore, the Town and the Company entered into an agreement
whereby the Town agreed to accept the Company's wastes for
treatment and the Company agreed,to-pay a specified charge
based on certain effluent limitations for BOD, suspended
solids and chlorine, with the charge'to be renegotiated in
the event the limitations were exceeded. Unlike a sewer
ordinance or rules and regulations, an agreement between
the operator of the POTW and £he major-industrial discharger
gives the discharger specific rights in and to the POTW
which can only be terminated i'f it breaches certain terms
of the agreement. Industries regulatedby local ordin-
ances or rules and, regulations do. not have such contractual
rights in the POTW.
'• •< . i •
.Specifically, in the , Agreement^ between Merrimack and
Anheuser-Buschr/the Town r agreed'tp,, .construct a POTW what
would adequately treat the company's wastes in the approxi-
mate quanti/ty.^ndr'6f ,;the approximate characteristics as
described in -the Agreement"•and 'the Company agreed not to
discharge'any wastes which':-., ' .v
1) contain inflammable solvents, • '
''••.'' ,•''•»; ' '"' i
'•• 2) has PH lower than "'5. Q or higher than 10.0,
'*'•:•• r -!- -4 i"~ • , . -e'
3) 'contains oils and' fats greater £han 25 ppm,
'•••'• *"',•• "*£" 'r •
'
4) contain^'-'«tpxic materials'*"''/' >ir
5) would impair the'-'Strength, durability, hydraulic
biological capability of the POTW.
The agreement further provided that the Town would
~eha~ct_a~sewe~r "'ordinance" cons is tent "with J±e_ terms of the
Agreement and that in the event of any conflict, the terms
of the Agreement shall prevail.
Enforcement of Pretreatment Standards
Enforcement of the measures contained in. the control
instruments (sewer ordinances, permits, rules and regulations
2-57
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and agreements) is an important part of the pretreatment
program. Effective enforcement requires a combination of
administrative and judicial procedures and sufficiently
stringent sanctions to compel compliance'with the control
.measures. Moreover, the implementation of the enforcement
program requires teamwork between administrators, engineers
and lawyers and cooperation between the administering agency
A
and the legal enforcement agency (such as the office of
the city solicitor).
Monitoring
Under the terms of the NPDES permits issued for the POTW,
the permittee is required to monitor its discharges and
submit monthly reports to EPA (or the State agency) on the
pollutant constituents of the treated effluent. The NPDES
permit issued for the POTW does not require monitoring
by the industrial users of the system. However, the POTW
will have to monitor the industrial discharges that enter
the POTW at some point in the system (the initial point
of discharge, at the connection with the interceptors; at
the POTW, etc.) in order to enable it to take measures to
meet the effluent limitations of the permit. Such monitoring
can be done in several ways. The POTW can require each
industrial user to do its own monitoring at the point of
discharge or the POTW can perform the monitoring at the
treatment plant or at some point in the collection system.
Such a decision will depend on the number of industrial
tie-ins and the methods of connection. If the waste is
not monitored until it reaches the treatment plant or the
main interceptor, the dilution effect may make it difficult
to determine the actual flow and the strength of the wastes
of any one industrial user. However, many municipalities
are reluctant to require monitoring by each user because of
the expense this imposes on local industry.
If the industrial users perform self monitoring, the
POTW, through one of the means of control discussed above,
should establish monitoring guidelines, such as type of
2-58
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equipment, calibration, frequency of monitoring, reporting
procedures, training of personnel required to operate the
monitors (and the pretreatment equipment itself), and
establish inspection procedures (See also Section 2.3).
Procedure
The most effective procedure for enforcement of the
control measures is a combination of administrative and
judicial measures. Generally these measures would be set
out in the following steps. The first step is a determina-
tion by the agency on the basis of monitoring and inspections,
that a particular user of the system is in violation of a
control measure applicable to it. The second step, if the
violation does not appear to be clearly willful and does
not involve an emergency which could endanger the public
health, could be for informal discussion between officials
of the agency and the user to determine whether the matter
can be resolved without formal enforcement proceedings.
If not, the third step would be formal written notif-
ication by the agency to the user of the violation with a
specified time for compliance. A next step involving a
%
conference would be a possibility. If compliance does not
result in the specified time period, the next step would be
the issuance of a show cause order by the agency or the
enforcement authority of the legal entity (i.e. the city
solicitor of the municipality). The show cause order would
specifiy the date for a hearing before the agency at which
the user would have the opportunity to show why an order
should not be issued. Thereafter, an order may issue which
could require the immediate discontinuance of the discharge
to the sewer or such discontinuance to take place at some
future time, the payment of a civil fine, with a minimum
and maximum penalty ususally specified for each offense. Each
day's continuance of the violation may be considered a sep-
arate offense. If the violator fails to comply with the
agency's order, depending on State law and any special legis-
lation creating the management agency,violations of an
2-59
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administrative order may be directly enforceable by the agency
or it may ~be necessary for the agency to bring a separate
court action to enforce the order, with the possibility of
ciminal sanctions.
2.4.6 Legal Aspects of Citizen Participation in a
Pretreatment Program
Section 505 provides that any citizen may commence a
civil action on his own behalf—
1) against any person (including the United States
Government and its agencies) alleged to be in
violation of (a) an effluent standard or limit- ;
ation or (b) an order issued by EPA or the State
regarding such standard or limitations, or
2) against the Administrator for his alleged failure
to perform any non-discretionary act or duty
under the Act.
An"effluent standard or limitation" is defined to include
pretreatment standards under Section 307 (See Sec. 505(f)).
In such an action the Federal district courts may
enforce the standard or limitation or order, or order the
Administrator to perform a certain act or duty, and apply
any appropriate civil penalties as provided under Section
309(d). The latter referenced section provides, inter alia,
that any person who violates Section 307 shall be subject
to a civil penalty not to exceed $10,000 per day of violation.
Section 505 allows "any citizen" to bring an action
without regard to whether or not the citizen is actually
harmed by the alleged violation. It does not allow the
citizen to recover any damages caused by the polluter. The
court does have the discretion to award plaintiffs the costs
of litigation (including reasonable attorney and expert
witness fees). However, the proof of a violation of a
pretreatment standard in a suit under Section 505 would be
evidence of negligence by the discharger in an independent
cause action for damages, such as that discussed below.
Independently of Section 505 of the Act, a citizen
2-60
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could bring suit against an industrial user for violation
of the provisions of a local sewer ordinance. Such an
action would be based on negligence, nuisance, or the common
law rights of a riparian owner. The relief sought would
be an injunction and/or damages actually suffered by the
plaintiffs as a result of the actions of the discharger. A
case which is instructive on this point is Springer v.
Schlitz Brewing Company, 7 ERG 1516 (4th Cir. 1975) where
the plaintiff (downstream riparian owners) alleged that
they were damaged by the wastes discharged from the defend-
Jan?s_Jbrewery~''arid 'that such discharges "to "the 'POTW violated'~the
"provisions of the local sewer ordinance.""" The brewery' claimed '
that any damage to plaintiffs resulted from the failure of
the POTW to provide adequate treatment, for which the brew-
ery could not be held liable. The POTW was not joined as
a party and there was no allegation that the POTW was in
violation of any Federal or State permits or other require-
ments. The Court found that under the law of North Carolina
industrial users are immune from liability only when their .
discharges of wastes are as prescribed by law. Accordingly,
the Court held that the violation of a municipal sewage
ordinance which is intended to protect downstream riparian
owners can subject an industrial user of the POTW to private
civil liability. Moreover, independently of the sewage
ordinance, the Court held that'the plaintiffs could recover
damages if they could prove that the brewery knew, or in
the exercise of reasonable care should have ascertained,
that the POTW could not adequately treat the brewery waste.
The Court further pointed out that in order to recover
damages the plaintiffs would have to prove that the wastes
from the brewery actually caused harm to the plaintiffs.
2-61
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2.5 Economic and Financial Elements
2.5.1 Basic Benefits and Costs of Joint Treatment for
Industries
Industries choosing to discharge their wastes to muni-
cipal sewer systems receive several economic benefits.
Although they must repay at least their portion of the Federal
share of POTW construction costs (without interest, however)
as well as a proportional share of the operations and main-
tenance costs, they can take advantage of any economies of
scale of the POTW and avoid the extra costs incurred in
obtaining their own NPDES permit for direct discharge. Not
having to go to the capital market to borrow funds to
purchase pollution control equipment, they may also favorably
affect their debt/equity ratio. EPA has estimated that
the implicit subsidy to industry on the Federal share of plant
costs is 69 percent or even higher if the local share is not
recovered or if supplementary interest-free State grants
are available. In some cases the implicit subsidy to
industry may exceed the 75 percent subsidy to municipalities.
Aside from pretreatment, an industry discharging to
a municipal system may face two basic charges.
Industrial Cost Recovery (ICR) Charges
Section 204(b)(l)(B) of the Federal Water Pollution Control Act
Amendments of 1972 (PL 92-500) requires that industrial users of the
treatment works make payments for that portion of the cost of constr-
uction of such treatment works (as determined by the Administrator)
which is allocable to the treatment of such industrial wastes.
The congressional intent of this provision is that "it is
inappropriate in a large Federal grant program providing a high
percentage of construction funds to subsidize industrial users from
funds provided by taxpayers at large" (legislative history).
This provision was implemented in the Code of Federal Regulations
at 40 CFR Part 35, Subpart E, promulgated by the Environmental Protection
Agency on February 11, 1974. Specifically, 40 CFR 35.928 and 35.935-13
state the industrial cost recovery system shall be prepared by the
grantee, approved by the Regional Administrator, and implemented and
maintained by the grantee in accordance with those regulations.
2-62
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Additional guidance on this subject is available in Federal Guidelines -
Industrial Cost Recovery Systems. Copies may be obtained by requesting
publication # MCD-45 from:
General Services Administration (8FFS)
Centralized Mailing List Services
Bldg. 41, Denver Federal Center
Denver, Colorado 80225
User Charges
In addition to ICR charges, industry must pay a propor-
tional share of the operational, maintenance, and replacement
costs of the POTW. User cV*rtc tnfor**cln»» I.
40 OPR 35.935-13
2.5.2 Economic Impacts of Pretreatment Standards
Certain industrial wastes pose additional system costs.
Most important to the operation of the POTW, some pollutants
are incompatible with biological treatment processes.. They
may lower the efficiency of the processes,, causing increased
pass-through of pollutants and possible violation of the
municipal NPDES permit; they may even cause a complete plant
breakdown. Industrial pollutants may also lower the quality
of sludge, making it unsuitable for certain disposal methods
such as soil conditioning, thereby increasing disposal
costs. Lastly, some industrial pollutants may pass through
a plant with no effect on plant processes. This may also
2-63
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cause the POTW to violate its NPDES permit if specific
effluent limitations appear in the permit due to water
quality considerations. Pass-through entails no direct 0/M
costs to the treatment plant.
Pretreatment standards established to reduce the con-
centration of incompatible wastes in the POTW influents can
dramatically increase the industrial plants share of the cost
of joint treatment. The economics of compliance with these
standards is complex and planners should anticipate the
dynamics of industry response. Basically, an industrial plant
has five options through which to comply with a given set
of pretreatment standards:
1) Drop out of the POTW system (go out of business,
move out of the area, seek own discharge permit);
2) adopt process changes that alter its waste
stream;
3) build individual pretreatment facilities;
4) build joint pretreatment facilities with other
local industries; or
•
5) finance, with other industries, a central pretreat-
ment facility or other special process at the POTW
itself.
An Industry will seek to select that option, or combination
of options, that maximizes its profits after complying with
pretreatment standards. Let us examine the economic con-
sequences of each option in general terms:
Drop out of system; If an industry drops out of
the system, its entire volume of effluent disappears from
the POTW influent. On the one hand this may decrease the
total flows so much that dilution of pollutants contributed
by other industries drops significantly, raising net concen-
trations (unlikely). In such a situation, pretreatment
fir4anaa»4g would have to be raised. On the other hand, the
total mass of imcompatible pollutants would decrease, as
well as the proportion of incompatible wastes with respect
to compatible base flows, thereby reducing 0/M costs to
Operation and maintenance
2-64
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the plant, improving sludge quality, .and reducing pass-
through. Pretreatment atmRdaudj for pollutants contributed
by the industry in question could then be lowered. In some
"cases, the POTW:may be left "with unanticipated reserve capa~-
city formerly allocated to the industry .that dropped out.
This may pose MpMttHHMMHMMBMBBp^HBMMMfc
Process changes; A variety of options are available
to the industry in the way of process changes. On one extreme,
simple good housekeeping practices can reduce pollutant
discharges, often saving the industry money directly. On
the other hand, pretreatment might provide the incentive
to construct a whole new manufacturing plant using a low
pollution technology; in this case the industry might also
decide to drop out of the system and relocate. Between the
two extremes are incremental on-site process changes that
change the effluent profile of the user, and these may pose
difficulties to standard setters.
Where municipal pretreatment »LuiiQardJ for small con-
tributors are more lenient than Federal standards, industries
might lower the water content of 'their effluent to drop below
the Federal standards threshold of 50,000 gpd. Though this
may force them to pay a surcharge on the increased concen-
tration, expensive pretreatment processes might be avoided.
The resulting increase in 0/M unit costs to the POTW would
probably be recovered through the surcharge formulae, but
there would be no improvement in sludge quality or reduction
in upset risk, decreased plant efficiency, and increased
pass-through. Process changes could also involve a change in
the mix of pollutants emitted: an industry might shift to
i
a process that allows one pollutant to drop to
but another to rise up to the afcandaget, increasing
the total amount of the second pollutant in the POTW influent
reqwtVefetxt
and possibly requiring a recalculation of the standard for
the second pollutant. The best outcome of a process change
might be that a major contributing industry would change to
such a markedly less polluting process that pretreatment
2-65
-------
for other industries could be relaxed (though no
farther than the levels at which the first industry would
elect to make the process shift.)
Individual pretreatment: The construction by an
industry of pretreatment facilities on-site would simply
lower its contribution of controlled pollutants to the
POTW. This option would have few, if any, dynamic effects
fiwutroKtk*
on gtandflgd setting. It would predictably lower POTW costs,
reduce upset risk, predictably lower pass-through, and pre-
dictably raise sludge quality. Unfortunately, this option
may be the most expensive one for industry, as estimates
put such pretreatment costs at the level of conventional
secondary treatment (see Section 2.5.5). Despite certain
financial subsidies available under this option, industry
may seek alternate means of complying with standards.
Joint pretreatment; Similar to individual pretreatment
by a number of cooperating industries (for instance, in
an industrial park) , joint pretreatment of wastes could
realize economies of scale for participants with particular
benefits for smaller and less efficient ones. Joint pre-
treatment could be one route by which to avoid having to
grant variances to marginally profitable older industries,
and therefore it could conceivably allow certain standards
to be relaxed.
Pretreatment at POTW: An extreme version of joint
pretreatment, the construction of a facility or a process
modification at the POTW itself may be the least costly
option through which to meet certain standards. It would
have to be planned and constructed entirely by industry,
and with private funds, and it raises complicated admin-
istrative, legal, and technical problems.
2.5.3 Economic Efficiency
Faced with this range of possible responses to pre-
rea«of«i»e«frf irarpo^r.-Uc -fa- an»ci*yfrj PuEw^***
treatment a frcmAaBdo , the atandageT jiLLuitJ JylllLyi ^ill seek
A
to make administrative decisions that simplify industries'
2-66
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options and make their response to pretreatment more pre-
dictable. This probably means ruling out the last com-
pliance option, pretreatment at the POTW, despite its
possible economies. Modifying the plant itself to take
over pretreatment functions would reduce system flexibility:
it might be difficult for new industries to utilize such
a system, and it would also be disruptive if any participating
industries disconnected from the system, for other industries
would be unwilling to make up the deficit of options mainten-
ance, and replacement costs (OMR costs) specified in fo&R
35.905-17.
Economic efficiency, in the economist's sense of
minimization of total costs, will be difficult to achieve
with pretreatment. One reason is that economically efficient
approaches such as pretreatment at the POTW may be so
administratively awkward that they are not practical. More
important, optimum efficiency could well require that different
nwuiroHotk
pretreatment otobndagda be set for every industrial contri-
butor, based soley on the costs to each user of reducing its
contribution of incompatible wastes. This could be approached
through the wholesale use of variances (both more lenient
and more strict than the uniform standards) or through
individual contractual agreements in place of a municipal
ordinance or perhaps most easily through an effluent fee.
However, all these approaches are inconsistent with the
philosphy expressed by the Federal pretreatment standards
for significant contributing industries, and seem opposite
to the mandate of P.L. 92-500. Disproportionate allocation
of pretreatment responsibilities to those industries able
to meet them at lowest cost would also run into resistance
from industries themselves—those asked to do more than ..
their minimum share would resist except under a fee system.
Most POTWs, particularly those with a large number of
reauifltK-tv4r
industrial contributors, will probably set uniform at-an da I'd a
and seek to help heavily affected firms after the fact.
2-67
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2.5.4 Other Considerations
Growth: C feandardo . should be set to allow for industrial
- /I
growth; otherwise these would have to be revised constantly.
rqquirewteNtr
Inevitably, this means more stringent otenndarda for pretreat-
ment than are strictly necessary considering the flows
documented by the Industrial Waste Survey (IWS) . Industries
re^uJcejffctxV*
will object to these higher stondagdo (except, perhaps, if
they themselves plan to extend operations) and they may
force the available growth margin down. Thus, long term
economic growth of an area may be mildly constrained by
r«nu»i*wYtxhr
pretreatment standardo. Deliberate economic trade-offs may
AsauifUMwV
have to be made by the gfeandard setting agency between
immediate economic impacts on local industry and long-term
costs of developing industrial growth*
Safety Margins; Standard setting will also have to
allow some margin for safety, increasing the costs to industry
of compliance. For instance, manufacturing processes usually
give off different quantities and qualities of wastes at
different stages of their cycles. Processes from two or
more industries may go in and out of phase, producing inter-
mittent peak loadings of pollutants that must be accounted
TW» For a nvwft 4i»ovotMK oliccuwim we
25.
2-68
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not escape their observation: every variance carries with
r&iuiTO*o
-------
"Establishment of Federal pretreatment standards for
industry may have a more dramatic effect than the
cost recovery and proportionate charge provisions."1
For example, for the metal finishing industry and for
textiles, pretreatment represents 80 percent of total treat-
ment costs necessary for meeting EPA's 1977 BPT standards.
Facing substantial pretreatment costs, some firms will
elect to treat their own wastes and obtain their own dis-
charge permit, others simply will not be able, or will
choose not to bear, the costs of complying with the require-
ments of P.L. 92-500, either through self or joint treat-
ment; they will relocate, or go out of business. Such
effects must be considered by areawide planners. Treatment
-------
review of regional economic trends. Most planning agencies
have the necessary information: their examination of the
area's economic base normally includes historical consider-
ations. Published sources, such as County Business Patterns
and the Census of Manufacturing (for larger areas) may also
be useful. In addition, State and local employment offices
and local chambers of commerce may be helpful in identifying
marginal industries.
The second step involves a review of the studies of
the costs of treatment for particular industries: a number
of studies have been conducted for the Environmental Pro-
tection Agency, and for the National Commission on Water
Quality. These studies identify the industries which are
heavy users of municipal treatment facilities. Their find-
ings are presented in Table 2.8. According to this table,
the metal finishing industry is particularly dependent on
municipal facilities: 70 percent of all establishments,
or some 49,000 plants discharge to POTWs. Textile mills,
pulp and paper mills, and canneries for fruits and vegetables
are other sectors dependent on municipal facilities. Heavy
users with incompatible wastes—the metal finishing industry--
may be expected to be sensitive to pretreatment costs.
The Commission studies go on to examine plant closings
due to water pollution control requirements. They conclude
that "A majority of plant closures are for plants which are
users of municipal systems and are defined by EPA as having
incompatible pollutants," i.e., industries subject to pre-
treatment regulations. Further, they conclude that....
"Plant closures are significant in Pulp and Paper
Metal Finishing, Textiles, Fruit and Vegetables,
Feedlots (including dairies), and Meet Packing. They
are concentrated in a small high-cost segment of the
industry (usually 5-10 percent of capacity). Gener-
ally they are the old, small, single-plant firms, that
in many cases could not remain economically viable
over the next decade regardless of water pollution
control requirements."
2-71
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Table 2.8
Industrial Usage of
Industrial
Categories
Canned & Preserved
Fruits and Vegetables
Inorganic Chemicals
Organic Chemicals
Plastics & Synthetics
Iron & Steel
Metal Finishing
Pulp and Paper
Steam Electric Power
Textiles
Total
No. of Plants
2,123
3,700
416
70,000
598
1,037
1,926
POTWs
By Number of
Plants
40%
negligible
10%
(40%)
unknown
70%
30%
negligible
76%
Source: National Commission on Water Quality, op.
|
By Production
Capacity
(50%)
negligible
10%
(20%)
negligible
unknown
10%
negligible
unknown
cit.
2-72
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Estimates of expected plant closures by sector and region
are presented in Table 2-9. It should be noted that not
all of these closings are caused by pretreatment require-
ments; the list, however, is indicative of the sectors in
each region which may be expected to have difficulties
in meeting pretreatment costs.
A consideration of regional economic trends, together
with pretreatment cost estimates should aid regional plan-
ners in identifying the severely impacted industries.
2.5.6 Assistance to Industries
Although a pretreatment program is legally required
for all POTWs, areawide planners have a number of alterna-
tives for assisting severely affected industries. These
include financial advice, technical advice, and the grant-
ing of variances.
As described above, the firms most likely to be
severely affected by pretreatment requirements are the
smaller, older industries. They are also the least likely
to have the resources for investigating the financial assis-
tance available to them. The forms of federal assistance
available for meeting pretreatment costs are summarized in
Table 2-10. Planners should investigate whether firms have
considered these forms of assistance, and others which may
be available in their particular planning region.
Secondly, areawide planners may offer technical
assistance to affected firms, as the small, older firms
may not have the resources to investigate technical alter-
natives—potentially of low cost—for meeting their pre-
treatment requirements. First, planners may commission
their engineers to develop a directory of pretreatment
equipment, including types of equipment, vendors of the
equipment, local prices, and technical evaluations. Such
a directory would facilitate the investment program under-
taken by industries.
2-73
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Table 2-9
Distribution of Industrial Impacts - Plant Closures,
K>
1
--4
1
1
Industry
Pulp and Paper
Iron and Steel
Petroleum Refining
Textiles
Metal Finishing
Steam electric
Chemicals
Canned & Preserved
Fruits fi Vegetables
Beef Feedlots
Dairy Feedlots
Hog Feedlots
Dairy Products
Fertilizer
SOURCE :
Subcategories, Products, and
Number of Plant Percentage of •
Closures. BPT/1977 Capacity, BPT/1977
Max. 80 4.5%
N.A. 1.7%
1O l.O%
479 4.8%
Unct«'i-X'*v 7.3%
N.A. Negligible
13 Negligible
104 4.0%
9
7,200-15,700 1-3%
15,700-33,500 3-7%
13,700-45,400 2-5%
149 0.75%
20 1.5%
National Commission on Water Quality, Draft Final
Region — for Selected Industries
. —
Most Impacted Most Impacted
Subcategory Products
Dissolved Sulflte Non- Bleached Paper
integrated Paper
Independent Forming and Hot and Cold Finished
Finishing Products
Topping Lube High sulfur fuel
Imbricating Oils
Wool Dyeing Wool
Fabric Finishing
Small job and Captive
Shops
Construction
Retrofits
Small volume Producers
Dchydrators & Freezers Citrus, Potatoes
Processing
Less than 500 head
Less than 1OO head
Less than 1000 head
Small Butter t
Evaporative Milk
Phosphates Urea, Di -ammonia.
Phosphate
Report, op.cit., P. 111-72
Most Impacted
Region
Northeast
North Central
North Central
Mid-Atlantic
Gulf Coast
New England
Mid-Atlantic
California, Illinois
Ohio, Michigan
New England
Northeast
North Central
New Jersey, Ohio,
West Virginia,
Delaware
Florida,
Northwest
Moisture Excess, South)
Equal National
Southeast
Florida
-------
Table 2-10
Forms of Financial Assistance Available for Pretreatment Expenditures
Rapid Amortization (over sixty months) for state certified
pollution control equipment as introduced into the
Internal Revenue Code as part of the Tax Reform Measure,
1969 (15).
— If Rapid Amortization is not applicable,
• The investment tax credit allows commercial
enterprices to deduce 7% of the cost of new
equipment from corporate taxes due the same
year the equipment was purchased. Investment
tax credit may be used if the investment does
not qualify for rapid amortization(12).
• The industrial portion for construction of
pollution cpntrol facilities may be financed
by tax-exempt bonds. The facilities are then
owned by the public and leased to the industry
until interest and principal is paid off *(12).
• Low interest, long-term loans are available to
small businesses for construction of pollution
control equipment including pretreatment
facilities and interceptor sewers if industry
would suffer "economic injury," Section 8 of
the Small Business Act (12).
*This may require legal changes in some states, although
it is permissible under Section 103(c) of the Internal
Revenue Code.
2-75
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In addition, the engineering firms retained by the
areawide planners are likely to have some experience with
pollution control techniques, including process modifica-
tions and good housekeeping practices. They may visit
plants claiming severe impacts to offer suggestions on the
best methods of pretreatment; programs of capital invest-
ments, process changes, and good housekeeping practices. A
brief study of the firms claiming severe economic impacts
would not only provide technical advice, it would enable
the planning agency to validate such claims.
The final method of assistance involves granting
variances to firms—relaxing their pretreatment requirements.
Besides water quality ocnsiderations, this should depend on
the magnitude of the cost elements involved. Pretreatment
standards normally involve a number of pollutants. The
sensitivity of treatment plant costs and pretreatment costs
should be established for each pollutant category.
2.6 PUBLIC PARTICIPATION
EPA has published guidelines for the minimal amount of
public participation needed to comply with the law (40 CFR
105). Additional guidance to planning agencies on how to
effectively involve the public in the planning process is
detailed in the EPA documents entitled: "The Public
Participation Handbook for Water Quality Management" (Draft)
(16) and chapter ten of the "Guidelines for Areawide Waste
Treatment Management Planning" (17) . The planning agency
should strive to obtain the maximum amount of public parti-
cipation that is efficiently possible for areawide planning.
2.6.1 Legal Requirements
Title One section 101(e) of the Federal Water Pollution
Control Act (PL 92-500) requires that the public participate
in water pollution control activities.
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"Public participation in the development,
revision, and enforcement of any regulation,
standard, effluent limitation, plan or
program established by the Administrator (of
EPA) or any State under this Act shall be
provided for, encouraged, and assisted by the
Administrator and the States."
In meeting this requirement, planning agencies must include
a mechanism in their areawide planning process for eliciting
input from the public.
2.6.2 Public Participation with Pretreatment Planning
Part of the Water Quality Management (WQM) planning
process is to serve as a forum for involving the public in
water resource planning (see Chapter 4.2.4). The public
should have a role in formulation of the control plan for
industrial discharges to sewers. The regulation of indus-
trial discharges to sewers will affect sectors of the public
including industry itself, consumers, individual taxpayers,
environmentalists, and local government agencies. For suc-
cessful implementation of the industrial control plan, these
sectors should be a part of all phases of the WQM process
for pretreatment including definition of goals, priorities
setting, implementation schedules and management strategies.
2.6.3 Advisory Committees
The most effective way to insure that a pretreatment
plan will be well received and be complied with by industry
is to intimately involve industrial representatives in pre-
paration of the plan. The industrial subcommittee of the
general advisory committee should have frequent opportuni-
ties to suggest means to control industrial pollutants to
sewers. The 208 planners may also request alternative
solutions directly from industry on an individual basis.
One person in all WQM planning agencies should be designated
a liaison with the industrial sector of the area.
Other members of the general advisory committee may
include municipal officials (or their designated represen-
tatives), municipal engineers, local scientists and engineers,
2-77
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state health officials, independent environmentalists and
regional/local planners. Incorporating the goals of this
cross-sectional committee into the WQM plan, the Cantinuing
advisory committee may become advocates for the plan and
may function in educating the rest of the community.
The advisory committees will take part in both the
industrial waste survey and the development of the sewer
use ordinance (subsections 2.3.2 and 2.3.5). The industrial
subcommittee should be able to assist the industrial waste
survey. The list of the ordinance committee in subsection
2.3.2 presents a suggested group of.individuals from public
and private sectors of the community who would either draft
a sewer use ordinance or advise the municipality on how to
draft its sewer use ordinance. This ordinance committee is
representative of a temporary committee set up within a
WQM planning agency as required to fulfill specific tasks.
Some Issues Requiring Public Participation
As discussed above, the regulation of industrial
discharges to.sewers will impact on facets of the general
community such as its economy, political institutions, and
water resources. Some of the more significant issues
requiring public input are:
1) Direct Discharge or Sewer Discharge. The planning
agency, as an open forum for communication, will
have a major role in educating industries as to
the requirements of PL 92-500. Industries may be
quite uninformed on the technical and financial
requirements of pretreatment and cost recovery.
Similarly, the requirements for direct discharge,
including legal liabilities, should be explained
to industry. The planning agency will disseminate
accurate information. Whether industries choose
direct discharge or joint treatment must be con-
sidered in the overall WQM plan and also may
affect the economy of the community. The impor-
tance of these decisions which will have impact
on the WQM areawide plan, 201 facilities plan
and State program plan, demands that they be based
on accurate information.
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2) Control of Industrial Wastes and the General
Economy of the Community. Industrial waste
treatment or pretreatment costs (capital and oper-
ating) , sewerage system user charges, surcharges,
and monitoring costs will to some degree increase
manufacturing costs. These increases are likely
to be passed on to the consumer. Offsetting these
small increases of prices for consumer goods
should be a decrease in an individual resident's
share of waste treatment if the costs of such
services are equitably distributed. To some
extent, the quality and intended uses of receiving
waters in a community is a public decision. The
aesthetic or recreational desire for high quality
water and the stringent control requirements for
industry should be weighed against possible cor-
responding plant closures or relocations with the
loss of jobs resulting. Conversely, there are
economic benefits associated with improved water
quality and new industries, based on recreation
for example, could arise. High quality process
water sources could attract new industry to an
area. Proper land-use planning such as industrial
park locations resulting in optimal waste manage-
ment could yield economic benefits. These issues
must be identified for each community and will
require decisions by its members.
3) Control of Industrial Wastes and Community Public
Health. Industrial wastes are a primary source
of toxicants to the environment. As our under-
standing of these materials increases as well as
our capabilities to control their fate, this issue
gains in significance. During the treatment of
industrial wastes a given compound will either be
altered chemically or simply removed to a different
phase. In the latter case the compound which may
be toxic and often resides in a sludge, will be
disposed of via land, water, or air. Besides
recycling, there is no alternative. Land appli-
cation of these materials can affect crops and
groundwater supplies which can then be consumed
by residents. Incineration can volatilize com-
pounds to the surrounding atmosphere in the
community posing physiological threats upon
inhalation or skin contact. Discharge to receiving
waters can affect organisms consumed by man,
recreational participants, and water supplies.
Considering that some estimates indicate that 40
percent of the U.S. population is supplied with
water that has been used at least once before
for domestic or industrial purposes the public
should be aware of their local situation. Con-
trol and avoidance of harmful materials is
2-79
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somewhat a public choice; the conventional economic
analysis which compares costs to benefits will
have to be modified to weigh the more complex
cost-benefit-risk tradeoffs involved with both
obtaining a living from and living with industry
in the community.
2.7 PROBABLE MANAGEMENT FUNCTIONS IN A PRETREATMENT
CONTROL PROGRAM
The initial WQM (208) plan will identify an agency or
agencies which will be responsible for managing the pre-
treatment program in the planning area. Such a management
agency would be empowered to refuse municipal wastes which
do not comply with the plan, i.e., those wastes requiring
pretreatment to comply with the plan. The management agency
would also be empowered to refuse or accept industrial
wastes for treatment. These authorities enable the manage-
ment agency to function in controlling industrial discharges
to sewers. This section highlights some of the probable
management functions of the agency in pretreatment. The
management role may be expanded from this list.
2.7.1 NPDES Permits
The (208) management agency(s) may have six direct
functions within the NPDES to insure control over industrial
discharges to sewers. The management agency could:
1) review any industrial and municipal monitoring
reports of industrial discharges to sewers, POTW
influent and POTW effluent;
2) arrange for spot monitoring checks of industrial
discharges to sewers;
3) review new POTW applications for compliance with
pretreatment program for the area;
4) review all renewal POTW applications for compliance
with area pretreatment requirements; and
3) advise the NPDES issuing authority (if different)
on results of review.
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2.7.2 Industrial Waste Surveys
The management agency(s) should implement a system
to periodically update the information from the initial
IWS for the area. Changes in industrial discharges to
sewers (including new dischargers) should be integrated with
the areawide industrial pollution control program. The
updating activities such as sampling and interviewing may
be conducted by individual municipalities but the integra-
tion into the areawide waste management program should be
the task of the 208 agency. To insure that municipalities
adequately update their IWS, the 208 management agency may
require annual reports.
2.7.3 Enforcement of Pretreatment
Enforcement of the control program for industrial
dischargers to municipal sewers can be predominantly a
function of local and State government (see section 2.4,
Legal Management Elements). Because it will possess a com-
prehensive familiarity with the area, the 208 management
agency(s) could have a significant supporting role in enforce-
ment. This responsibility will include:
1) writing new municipal sewer ordinances and/or
updating existing ordinances;
2) reviewing enforcement and penalty clauses of
existing ordinances for insurance of pretreatment
compliance;
3) advising EPA of industries not complying with
pretreatment to make them ineligible for Federal
contracts, grants, loans; and
4) advising regional EPA on POTW grant applications
based on pretreatment compliance.
2.7.4 Public Participation
The management agency (s) is a likely forum for
continuing information exchange between industry, environ-
mentalists, municipal governments and the local community.
A substantial input from the public is required in formula-
tion of the plan; so a continuing exchange during plan
2-81
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implementation will naturally follow. Both citizen advisors
and industrial liaison people will be included in the manage-
ment structure.
2.7.5 Variance
The (208) management agency(s) would review the criteria
used in setting pretreatment requirements to determine if
all information relevant to the particular industry was
not included into the process of setting regulations for
the industry. The agency might function directly by propos-
ing to the regional EPA a variance, setting more lenient or
more stringent requirements or it may act as arbiter during
negotiations between an industry and a municipality.
2-82
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References Chapter 2
1. Imbelli, C., Pressman, W.B., Radiloff, H. The Industrial
Wastes Control Program In New York City. Journal Water
Pollution Control Federation, ££(12) : 1981-2012, 1968.
2. Inventory of Non-Domestic Dischargers to the Wastewater
Collection System In New Castle County, Delaware, report
by the New Castle County 208 Areawide Waste Treatment
Management Program, Newark, Delaware, 1975.
3. Industrial Waste Survey Phase II Engineering Report. Re-
port to the Buffalo Sewer Authority by McPhee, Smith, Ro-
senstein Engineers, New York, 1975.
4. Handbook for Monitoring Industrial Wastewater. Report
to the U.S. Environmental Protection Agency (Technology
Transfer) by Associated Water & Air Resources Engineers,
Inc.(Nashville), 1973.
5. Shelley, P.E. Sampling of Wastewater. Report to the
U..S. Environmental Protection Agency (Technology Transfer) .
6. Wastewater Sampling Methodologies and Flow Measurement
Techniques. U.S. Environmental Protection Agency Report
907/9-74-005.
7. Taras, M.J., et al.(ed). Standard Methods for the Exami-
nation of Water and Wastewater: Thirteenth Edition. Am-
erican Public Health Association, Washington, D.C., 1971.
8. Estimating Laboratory Needs for Municipal Wastewater Treat-
ment Facilities, U.S. EPA Office of Water Program Opera-
tions (Operations and Maintenance Program).
9. Besselievre, E.B. The Treatment of Industrial Wastes,
McGraw-Hill, Inc., 1969.
10. Manual of Practice 3: Regulation of Sewer Use. Journal
of Water Pollution Control Federation, £5(9,10), 1973.
11. Glossary Water and Wastewater Control Engineering. Pre-
pared by joint Editorial Board representing American Pub-
lic Health Association, American Society of Civil Engi-
neers, American Water Works Association, Water Pollution
Control Federation, 1969.
12. Berlin, H.G. Federal Aids for Pollution Control. Envi-
ronment Reporter, £(24), Monograph 16. 10-12-73
13. Mclntire, M.V. Improved Procedures for Municipal Regula-
tion of Industrial Discharges to Public Sewers. Report
to the U.S. Environmental Protection Agency, Office of
Research and Development.
2-83
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14. Economic Report, Alternative Methods of Financing Waste-
Water Treatment, U.S. Environmental Protection Agency,
p IV-45.
15. Mclntyre, M.J. Amortization of Pollution Control Faci-
lities - Section 169. Environment Reporter, 4_(30) ,
Monograph 13.
16. Public Participation Handbook for Water Quality Manage-
ment - DRAFT, U.S. Environmental Protection Agency.
January, 1976.
17. Guidelines for Areawide Waste Treatment Management Plan-
ning. U.S. Environmental Protection Agency, August, 1975.
18. Cost of Implementation and Capabilities of Available
Technology to Comply with PL 92-500. Report to the
National Commission on Water Quality by Battelle, Inc.,
1975.
19. Capabilities and Costs of Technology for the Organic
Chemicals Industry to Achieve the Effluent Limitations
of PL 92-500. Report to the National Commission on
Water Quality by Catalytic, Inc., Philadelphia, 1975.
20. Capabilities and Costs of Technology for the Inorganic
Chemical Industry to Achieve the Requirements and Goals
of PL 92-500. Report to the National Commission on
Water Quality by Catalytic, Inc., Philadelphia, 1975.
21. Innovative Technology Study. Report to the National
Commission on Water Quality by Water Purification Asso-
ciates and Process Research, Inc., Cambridge, Mass., 1975,
22. Nemerow, N.L. Theories and Practices of Industrial
Waste Treatment. Addison-Wesley Col, Reading, Mass.,
1963. -
23. Rudolfs, William (ed.). Industrial Wastes: Their Dis-
posal and Treatment. Reinhold Publishing Corp., New
York, 1953.
24. Lager, J.A. Urban Stormwater Management and Technology:
An Assessment, Report to U.S. EPA National Environmental
Research Center, Office of Research and Development.
Metcalf & Eddy, Inc. Palo Alto, California, 1974.
25. Itote*., ftlU/v\ 0*4 Bleor Barter.
pp. 97-141
2-84
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NOTE: Portions of this chapter dealing with POTW
interference and.pass through are developed
in greater detail in Federal Guidelines -
State and Local Pretreatment Programs which
are prepared pursuant to section 304(f) of
P.L. 92-500. These guidelines will be
published shortly.
Chapter 3
POLLUTANTS WHICH PASS THROUGH OR INTERFERE WITH POTWs
3.1 INTRODUCTION
It is an accepted practice for some industries to dis-
charge their wastewater into POTWs and have it treated and
disposed of jointly with domestic wastewater by a common
treatment facility. Such an arrangement may or may not be
detrimental to the objectives of water pollution control
at the POTW, depending on the type of industrial waste and
level of industrial waste management. However, because
of the diverse nature of industrial wastes, it is very
likely that certain constituents of industrial wastes may
not be compatible with the POTW and may cause interference
with various components of the POTW. In general, such
interference may affect:
1. Wastewater Collection Works;
2. Biological Treatment Processes;
3. Receiving Water of POTW;
4. Sludge Disposal.
3-1
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Significant wastewater parameters for 21 selected
industrial classifications may be found in Table 4-1
of the Handbook for Monitoring Industrial Wastewater,
U.S. Environmental Protection Agency, August, 1973.
In the following sections, the pollutants which
affect these components will be examined, their
threshold concentrations available in the literature will
be summarized as general guidelines, some useful tech-
niques to reduce excessive fluctuations of hydraulic and/or
pollutant discharge will also be discussed. In addition,
the general approach to determine pretreatment requirements
as well as some illustrative sample calculations will be
presented in Section 3.6. For information which is site-
specific or unavailable from the literature, general
considerations and approaches are also suggested. It is
hoped that the information assembled in this Chapter will
be helpful to 208 areawide planning agencies and their con-
sultants in coping with the technological and scientific
aspects of industrial pretreatment programs.
3-2
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3.2. POLLUTANTS WHICH AFFECT WASTEWATER COLLECTION WORKS
The first category of industrial pollutants which should
be excluded from the POTWs are those wnicn may damage
the wastewater collection works, e.g., sewers, pumping
stations, etc. In general, the following wastewaters shall
not be introduced into a POTW:
•1) wastewaters with pollutants- that create— a ------- •
fire or explosion hazard in the POTW;
2) wastewaters which will cause corrosive damage;
»e
3) wastewaters which contain solid or viscous
- --wastes in amounts which would cause obstruc-~*
tion to flow or interference in the POTW; -s
sr s .
4) VMstcWcfai
-------
The sources of these hazardous materials are most likely
those industries manufacturing or using them in their' normal
operations.
The production of sewer gas, methane, as a result of an-
aerobic conditions in a sewer system also presents a well-
known potential fire and explosion hazard. Although this
hazard may not be directly attributed to any industrial
waste constituents, an indirect cause-effect relationship
might exist. Certain conditions of industrial wastes could
be highly conducive to the creation of anaerobic conditions
in the sewers, such as high BOD loads and/or high temperature
of industrial discharges.
3.2.2.. Corrosive Materials
Corrosive materials contained in industrial waste may
deteriorate sewers and pumping equipment, cause structural
damages and failures, and ultimately lead to economic losses
to POTWs. Those commonly regarded -as corrosive to POTWs include:
•(1) Sulfate and sulfide, and substances which may lead
to their production in the sewer system. The resultant
corrosion usually occurs at the crown of concrete
sewers.
(2) Low pH (acidic) wastes. The acidic nature of
industrial wastes may attack and disintegrate metal
and concrete pipes and structures. Unless the
works is specifically designed to accommodate such
wastes, the pH of wastewaters is usually required
to be not lower than 5.0.
(3) Strong oxidizing agents which tend to react chemically
with the pipes and structures, and render them struc-
turally unsound.
3.2.3. Materials which Cause Flow Obstruction
Certain constituents of industrial wastes may settle to
form deposits, adhere to surfaces to form slime or scale, or
float and accumulate to form scum. The overall effect of all
these mechanisms is a change in the sewer's hydraulic charac-
teristics and consequently an obstruction of wastewater "flow.
3-4
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Experience in New York City*
The flammable substances in the industrial laundry
wastes may cause explosion and fire hazards, and this
potential may be determined by using a standard
explosimeter.
The acidic wastes discharged by a pigment manu-
facturer seriously corroded a large concrete sewer and
caused a cave-in under a commercial pier and deterioration
of other sewer pipes further_up the line.
A paint manufacturer discharging untreated caustic
washwater caused a sewer blockage and created a con-
tinuous fire hazard. This problem was solved by requiring
pretreatment to remove paint solids and solvents from the
washwater.
Sewer clogging due to fats and greases is a major
maintenance problem for sewers receiving industrial
discharges from meat processing plants. However, the
pretreatment of the wastes by a process or device, such
as a grease trap or interceptor, may remove fats and
greases effectively.
"The Industrial Wastes Control Program in New York
City," by Charles Imbelli, et al_, JWPCF 4£ (1),
1981-2012 (December, 1968).
These materials should be excluded from any industrial
discharges into POTWs, and they generally include the
following categories:
(1) High levels of suspended solids which tend to settle
by gravity in the sewer system;
(2) Oil and grease which tend to solidify in the sewer
system;
(3) Colloidal materials which tend to agglomerate and
then settle in the sewer system.
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3.3 POLLUTANTS WHICH INTERFERE WITH BIOLOGICAL TREATMENT
PROCESSES - -
Wastewater treatment facilities represent a combination
of physical, chemical, and biological treatment processes
which are designed to remove, concentrate, and stabilize
the deleterious water pollutants, convert them into harmless
or even useful form, and ultimately dispose of them in an
ecologically sound fashion. Normal and efficient operation
of these processes constitutes a significant fraction of the
effort towards a successful program of water pollution control.
Conversely, any interference or upset of these processes
due to the presence of industrial toxicants may render the
treatment facility partially or completely inoperative, degrade
the water quality which was desired to be protected, and
incur losses, tangible as well as intangible, to the public
good.
The goal of wastewater treatment, such as secondary or
higher treatment, can frequently be achieved by various
combinations of treatment processes, most broadly classified
as biological and physical-chemical treatment. For POTWs,
biological treatment processes are by far the dominant
choice mainly on the basis of domestic wastewater charac-
teristics. In view of the mechanism of operation, land
treatment systems may be considered a form of biological
treatment, and will be included in this section.
In terms of probable process upsets due to industrial
wastes, biological treatment is generally more susceptible
than physical-chemical treatment.This section will be
directed to pollutants which interfere with normal type
biological treatment processes. Should the POTW utilize
"physical-chemical'rather than biological" treatment," it is
conceivable that the pretreatment guidelines and require-
ments will be established with considerations which are
rather different from those discussed in this section.
3-6
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The factors and pollutants considered in this section'
include excessive fluctuations of hydraulic and/or pollutant
discharge, i.e. slug discharges, heat, inorganic and organic
pollutants. Thise factors will be considered in view of
their effects on three biological treatment processes: aerobic.
oxidation by activated sludge or trickling filter, nitrifica-
tion, and anaerobic digestion. Those pollutants which
interfere with land treatment primarily consist of chemicals
which may have undesirable impact on the soil and crops systems.
The technical information presented in this section
should be considered as general guidelines. Local waste-
water characteristics and the operation of treatment
facilities may play an important role in determining the
treatment performance . In using the threshold concentrations
of pollutants which are toxic to certain treatment processes,
the different degrees of acclimation possible with different
biological treatment processes and the sequence of these
vulnerable processes in a normal type biological treatment
plant should also be taken into consideration.
3.3.1. Excessive Fluctuations of Hydraulic and/or Pollutant
Discharge
The design of municipal wastewater treatment plants is
usually based on certain prescribed ranges of fluctuation
in wastewater flow and compatible pollutants mass loading.
Design treatment performance may be achieved when the
fluctuations in flow and/or pollutants fall within the
prescribed range. In general, the treatment performance
will deteriorate or collapse as the fluctuation exceeds the
prescribed design level.
The wastewater originating from residential areas usually
exhibits diurnal fluctuation in flew and concentration of
common pollutants such as BOD, and the fluctuations of this
kind are usually considered and accommodated in-the design
of treatment plants. For a POTW receiving industrial
discharges, the situation might become more complex, since
2-1
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the industrial discharges might cause excessive fluctuations
in flow and/or concentrations of pollutants, the key con-
siderations being the pollutant mass flux and its discharge
schedule. Since those pollutants which are usually not
designed to be removed by secondary biological treatment
plants will be discussed in other sections, only common
pollutants such as BOD, suspended solids, etc. will be
considered here.
If a large flow rate of industrial waste or a large
quantity of pollutants are introduced into a POTW within a
relatively short time period, these are commonly referred
to as slug discharges. Although the wastewater flow and
pollutants like BOD may be well received at the design levels
of loading, the slug discharges may cause a treatment process
upset and subsequent loss of treatment efficiency. Under these
conditions, slug discharges may be considered as prohibited
wastes.
The rigorous definition of slug discharges will be
related to the design and capacity of the specific treatment
plant receiving the industrial wastewater, and are cense-;
quently site-specific. Although generalized statements on
site-specific issues like slug discharges are difficult to
establish, it should be obvious that any remedial measure
which can reduce the fluctuations in flow and pollutants
will be highly beneficial in reducing the impact of slug
discharges on a POTW.
One important means of coping with slug discharges is
the use of a flow equalization process, especially in the
consideration of industrial pretreatment. Essentially,
equalization means the provision of a storage facility for
industrial wastewater so that the wastewater can be discharged
to the POTW more uniformly and continuously rather than in the
fluctuating and intermittent fashion in which it is actually pro-
duced at the industrial facility. The result is a relatively
more uniform discharge in both flow and pollutant loading
3-3
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into the treatment works, and many treatment processes,
especially those of biochemical nature, will benefit
significantly from flow smoothing and concentration dampening.
For those industries contributing significant fractions
of the total flow and pollutants into the POTW, equalization
as an industrial pretreatment may be particularly useful
because it represents a rather flexible technique to manipu-
late the flow and pollutant loading at their sources rather .
~thari"~at"theTreatment plant: TdeallyT'equaTIzation as industrial
pretreatment may even be utilized to augment the low points
in the diurnal cycle of domestic wastewater flow, and
thus to reduce the magnitude of fluctuations, if the indus-
trial wastewater has characteristics comparable to the
domestic wastewater.
Useful information on the design, costing, and case
studies of flow equalization has been made available (2)
although it is not discussed specifically for industrial
pretreatment.
A modification of the equalization technique, propor-
tioning, may be useful under certain conditions. Proportion-
ing refers to the discharge of industrial wastewater from .a
holding tank in proportion to the flow of domestic wastewater
in the sewers. The industrial wastewater is usually metered
into the sewer according to a predetermined schedule based
on the flow pattern of domestic wastewater. The objective
of proportioning is to keep constant the ratio of industrial
to domestic wastewater flow entering the treatment works.
The relatively constant dilution achieved by such propor-
tioning can be designed to insure that any incompatible
industrial pollutants will be diluted to an acceptable level
at the treatment works. ,
3.3.2 Heat
Heat will interfere with a POTW when its level is high
enough to inhibit the normal biological activity of treatment
3-9
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processes at a POTW. This critical level of heat is generally
considered to be 40° C (104°F) at the treatment facility.
In many cases, substantial quantities of heat can be
discharged into a municipal sewage system along with waste-
water without causing an upset to treatment processes. In
fact, some heat, particularly in cold weather, may actually
improve the effectiveness of biological treatment processes.
In addition to the thermal effect on treatment processes,
the thermal impact on the wastewater collection system
warrants additional considerations. Anaerobic decomposition
of organics within the wastewater collection system is
usually unavoidable, and the generation and accumulation of
methane within the sewer system would be a natural conse-
quence. As discussed in section 3.2, excessive accumulation
of methane may present a potential fire and explosion
hazard, which should be strictly regulated and avoided.
Since most biochemical processes will be accelerated as
temperature rises up to a certain critical level, it is
conceivable that methane production and accumulation will
increase as a result of the industrial thermal discharge
into public sewer systems. Therefore, it is possible that
thermal discharges may cause adverse effects on the sewer
system even though the wastewater temperature at the
treatment plant might be still lower than 40°C. The de-
lineation of such thermal impact on sewer systems depends
on the type and design of sewer systems involved. Local
monitoring and analysis for the methane and waste temperature
-might-be-the-best solution to such~site-specific questions.
3.3.3 Inorganic Pollutants
Wastewater usually contains a large number of inorganic
substances, many of which are not detrimental to biological
treatment processes. Those of concern are primarily dissolved,
present in molecular or ionic form. Since the concentrations
of dissolved substances are dictated by various chemical
3-10
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equilibria, the presence of some substances, not harmful
themselves, may still have significant effects on the
toxicity to biological treatment processes. The toxicity
of certain cations, for example, may be enhanced or reduced
by the presence of certain anions or other chemical forms
which may combine with the cations to form complexes.
Table 3-1 (3) summarizes those major inorganic pollutants
that are likely to be toxic to biological treatment processes.
The majority of cations of concern are metals, which mostly
originate from the metal processing and plating industry.
Much metal plating is carried out in numerous small indepen-
dent shops located in metropolitan areas; this tends to make
the control of these troublesome metals more difficult.
Although the threshold concentrations tabulated are the total
concentration of each metal, it should be recognized that
the effects of metals are dependent on the amounts of EDTA,
hydroxide, sulfide, carbonate, and phosphate (4), etc.,
present, which determine the available concentration of free
metal ions in solution through certain chemical reactions
such as complexation and precipitation. The fact that some
metals are amphoteric (3), i.e. they may exist in solution
as a cation or anion under different conditions, also
indicates that the toxic effects of these metals may vary
with other parameters such as pH.
In addition to the chemical considerations discussed
above, certain biological factors may be highly significant
in establishing the threshold concentrations that are toxic
to biological treatment processes. For certain toxic pollutants
it has been long recognized that a population of microor-
ganisms may be developed through appropriate acclimation,
which can function effectively for the treatment purposes
and show low or no sensitivity to the presence of the toxic
pollutants. For inorganic metals, the acclimated population
may show high levels of tolerance while certain toxic
organic pollutants can_.even be degraded by the acclimated
3-11
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Table 3-1
THRESHOLD CONCENTRATIONS OF INORGANIC POLLUTANTS THAT ARE
INHIBITORY TO BIOLOGICAL TREATMENT PROCESSES (3)
POLLUTANT
Ammonia
Arsenic
Borate( Boron)
Cadmi urn
Calcium
Chroml urn
(Hexavalent)
Chromium
(Trivalent)
Copper
Cyanide
Iron
Lead
Manganese
Magnesium
Mercury
Nickel
Silver
Sod1 urn
Sulfate
Sulfide
Zinc
ACTIVATED
SLUDGE
PROCESSES
480
0.1
0.05-100
10-100
2500
1-10
50
1.0
0.1-5
1000
0.1
10
0.1-5.0
1.0-2.5
5
0.08-10
CONCENTRATION (mg/1)
ANAEROBIC NITRIFICATION
DIGESTION PROCESS
PROCESSES
1500
1.6
2
0.02
50 0.25
50-500
1.0-10 0.005-0.5
4 0.34
5
0.5
1000 50
1365
0.25
3500
500
50
5-20 0.08-0.5
Note: Concentrations shown represent influent to
the unit processes. Blanks represent lack
of data.
3-12
-------
Anaerobic Digester Upset by Metals
"In the Long Island City area, in 1960, the discharge
of toxic metal from more than 40 metal platers was held
responsible for the upset of the sludge digestion process
at the Bowery Bay pollution control plant. An educational
campaign as a preliminary step to enforcing compliance was
resorted to because of the difficulties encountered by
the many small firms in meeting the prescribed limits.
Housekeeping procedures, instituted by the platers, were
highly effective in reducing the toxic metals reaching the
treatment plant."*
*"The Industrial Wastes Control Program in New "York City,"
by Charles Imbelli, e_t al, JWPCF 40_ (1), 1981-2012 (December,
1968).
population. It is conceivable that the performance of the
acclimated population may depend on a relatively narrow range
of the flow and pollutant composition in the actual operation.
Since different microbial populations are utilized in
different biological treatment processes, those processes *
will exhibit different degrees of adaptability. Activated
sludge processes have been known to be more adaptable to
toxic pollutants than either anaerobic digestion or nitrifi-
cation processes. This difference in adaptation may be
attributed to different degrees of biological diversity
among the processes. Both anaerobic digestion and nitri-
fication processes require rather specific microorganisms
to achieve the treatment purposes while the activated sludge
processes involve a great variety of organisms.
In view of these complicating factors discussed above,
the threshold concentrations in Table 3-1 should be considered
as general guidelines to be adopted with caution. Preferably,
a pilot testing program should be conducted to determine
the feasibility of biological treatment on a specific mix of
industrial and domestic wastewaters.
3-13
-------
3.3.4 Organic Pollutants
Organic chemicals may be defined as those compounds made
up of carbon in combination with one or more other elements
such as'hydrogen, oxygen, nitrogen, sulfur or phosphorus.
In general, organic compounds may be derived from biological
species such as animals and plants, or may be produced through
chemical synthesis. Some of the synthesized organic compounds
are rarely, if ever, found in the natural environment, and con-
sequently may not be readily biodegradable by the microorganisms
utilized in biological treatment processes. At certain levels
of concentration, some organic chemicals are toxic to the micro-
organisms which are the active agents of biological treatment
processes. Under such conditions, interference with the bio-
logical treatment process usually results in significant re-
ductions in treatment efficiency, which might or might not be
recovered within reasomable periods of time, depending on the
treatment process involved and the degree of process upset.
Although many of the organic chemicals of concern can be
identified, and their concentrations may be determined by using
modern analytical techniques, the proce'ss of delineating the
problem may be complicated by several factors. Some toxic
organic compounds, such as phenol and formaldehyde, may be
effectively removed from wastewaters by biological treatment
if the biological population has been allowed to acclimate
gradually (4). Therefore, the threshold concentrations of
organic pollutants that are inhibitory to biological treatment
processes become flexible and will vary with the operating con-
ditions, such as type of biological process and even the design
of the process. Many organic pollutants may become susceptible
to biological degradation after acclimation. However, it should
be pointed out that the performance of the acclimated population
may depend on a relatively narrow range of the flow and pollutant
composition in the actual operation.
In addition to removal by degradation after acclimation,
toxic organic chemicals can also be removed by other mechanisms.
Volatile compounds may be lost to the atmosphere during aerobic
biological treatment. Other substances, such as some chlorinated
3-14
-------
Anaerobic Digester Upset by Kepone
An industrial wastewater containing Kepone, a chlorinated
ketone insecticide in the same category as DDT, was allowed
to be discharged into the POTW of Hopewell, Va., in March, 1974,
without adequate consideration of its toxic impacts*. Early
in April, 1974, the anaerobic digesters of the Hopewell
sewage treatment plant failed completely**. The Kepone
discharger was closed in July, 1975*, and the digesters were
not back in service until January, 1976**.
* Washington Post, January 1-4, 1976.
** Personal communication with William R. Havens, super-
intendent of Hopewell sewage treatment plant.
organic coumpounds, may be adsorbed on suspended particules
or precipitated and thus removed to different extents.
Anaerobic digestion of sludges is the biological treat-
ment process which is most susceptible to interference by toxic
pollutants, especially phenols, chlorinated organic compounds
and metals. The effect of chlorinated organic compounds even
at very low concentrations is remarkable (4), and therefore,
particular attention must be focused on the treatment of
•
industrial wastwaters containing such compounds, which might
be used as insecticides or solvents for various purposes.
Among aerobic biological treatment processes, nitri-
fication seems to be most sensitive to toxic substances.
The specific autotrophic bacteria which are responsible for
nitrification are much more easily inhibited than are the
heterotrophic bacteria which are responsible for the oxidation
of organic carbon compounds. Organic sulfur compounds,
expecially those with sulfur-carbon-nitrogen linkages are well
known (4) inhibitors of nitrification. However, acclimation
is possible to some extent with nitrification processes.
Among the aerobic processes for the oxidation of organic
carbon, activated sludge and trickling filters are the
most common. Acclimation of biological populations to
3-15
-------
toxic organic substances is possible with both these
processes. However, trickling filters seem to be more
resistant to shock loads and toxic wastes than do activated
sludge processes. Those using specially-designed plastic
sheets as filter medium are even more adapted to industrial
wastewater treatment because of many advantages in the
surface characteristics which are made available in such
designs.
In general the organic compounds of most concern in
terms of interference with biological treatment processes
include phenols, chlorinated organic compounds, aromatic
nitrogenous compounds, and surfactants. Table 3-2 lists
threshold concentrations of various organic pollutants to
three biolocical treatment processes (3). Many of these
data are derived from laboratory experiments under certain
operating conditions. Extrapolation of these data to
other applications therefore, will require careful
consideration of pertinent factors. The information
contained in Table 3-2 is far from complete; it is presented
here to serve as a guideline where no other pertinent and
detailed information is available for specific applications.
3.3.5 Pollutants Which Interfere with Land Treatment
Land treatment of municipal wastewater effluents
utilizes the soil-crops system for the removal of certain
water pollutants. In addition to waste treatment, the reuse
of water for agricultural irrigation can also be achieved
simultaneously. Since this combination of waste treatment
and water reuse may be highly beneficial and cost effective
in certain localities, especially in water-short regions,
land treatment of wastewater will probably be more widely
practiced in the future. This trend will be particularly
true for the treatment of municipal wastewaters, including
those receiving industrial discharges in a POTW. Therefore,
it becomes essential to consider any possible impact an
industrial discharge may have upon land treatment systems.
3-16
-------
Table 3-2
THRESHOLD CONCENTRATIONS OF ORGANIC POLLUTANTS THAT ARE
INHIBITORY TO BIOLOGICAL TREATMENT PROCESSES (3)
CONCENTRATION (rag/1)
ACTIVATED
SLUDGE
POLLUTANT PROCESSES
Alcohols
Allyl
Crotonyl
Hepty 1
Hexyl
Octyl
Propargyl
Phenols
Phenol • 200
Creosol
2-4 Dinitrophenol
Chlorinated Hydro-
carbons
Chloroform
Carbon Tetrachloride
Methylene Chloride
1-2 Dichloroethane
Dichlorophen*
Hexachlorocyc lohexane
Pent ach loropheno 1*
Tetrachloroethylene
1, 1, 1, -Trichloroethane
Trichloroethylene
Trichlorof luoromethane*
Trichlorotrif louroethane
(Freon)
Allyl Chloride
Dichlorophen
Organic Nitrogen Compounds
Acrylonitrile
ANAEROBIC NITRIFI-
DIGESTION CATION
PROCESSES PROCESSES
100 19.5
500
500
1000
200
500
4-10
4-16
150
10-16
10-20
100-500
1
1
48
0.4
20
1
20
0.7
5
180
50
5
3-17
-------
Table 3-2 (Continued)
CONCENTRATION (mg/1).
ACTIVATED
SLUDGE
POLLUTANT PROCESSES
Organic Nitrogen Compounds
(Continued)
Thiourea
Thioacetamid
Analine
Trinitrotoluene (TNT) 20-25
EDTA 25
Pyridine
Surfactants
Nacconol 200
Ceepryn 100
Miscellaneous Organic
Compounds
Benzidine 500
Thiosemicarbazide
Methyl isothiocyanate
Allyl isothiocyanate
Dithio-oxamide
Potassium thiocyanate
Sodium methyl
dithiocarbamate
Sodium dimethyl
dithiocarbamate
Dimethyl ammonium
dimethyl
dithiocarbamate
Sodium cyclopentamethylene
dithiocarbamate
Piperidinium
cyclopentamethylene
dithiocarbamate
Methyl thiuronium
sulphate
Benzyl thiuronium
chloride
ANAEROBIC
DIGESTION
PROCESSES
NITRIPI- .
CATION
PROCESSES
0.075
0.14
0.65
300
100
0.18
0.8
1.9
1.1
300
0.9
13.6
19.3
23
57
6.5
49
3-18
-------
Table 3-2 (Continued)
POLLUTANT
Miscellaneous Organic
Compounds (Contd.)
Tetramethyl thiuram
monosulphide
Tetramethyl thiuram
disulphide
Diallyl Ether
Dimethyl-
paranitrosoaniline
Guanidine carbonate
Skatole
Strychnine
hydrochloride
2 chloro—6 trichloro-
methyl-pyridine
Ethyl urethane
Hydrazine
Methylene blue
Carbon disulphide
Acetone
8-hydroxyquinoline
Streptomycin
CONCENTRATION (mg/1)
ACTIVATED ANAEROBIC NITRIFI-
SLUDGE DIGESTION CATION
PROCESSES PROCESSES PROCESSES
50
30
100
7.7
19
16.5
7.0
175
100
250
58
100
35
840
73
400
Note: Concentrations shown represent influent to
the unit process. Where indicated with a *,
the concentration represents total plant
influent. Blanks represent lack of data.
3-19
-------
Three basic methods of land application can be defined
for the treatment of wastewaters: irrigation, infiltration-
percolation, and overland flow. These different methods
are designed to achieve different overall objectives, to
be adapted to different site conditions, and to produce
renovated water of different qualities. Generally, various
levels of wastewater pretreatment prior to its application
to land may be necessary for their successful operation.
The discussion of these aspects of land treatment has
been detailed in recent publications on land treatment (5,6).
Land application systems may be subject to interference.
of various wastewater constituents. However, some pollutants
such as BOD and suspended solids can usually be controlled
by appropriate POTW pretreatment and do not interfere with the
subsequent process of land application. In general,. BOD and
suspended solids at the level of secondary effluent or
lower will not cause difficulties in subsequent land
applications.
Nevertheless other wastewater constituents could
interfere with land application in different ways. The
possible interferences include those with the soil system,
crops involved (if irrigation is used), and quality of
renovated water. For example, relatively high concen-
trations of sodium in comparison with calcium and magnesium
(the sodium adsorption ratio) may cause deflocculation of
the soil structure, decreasing soil permeability, and
perhaps eventual sealing of the soil. Excessively high
levels of salinity or total dissolved solids may present
a hazard in irrigating certain crops. A number of trace
elements, including heavy metals, are also major concerns
because of their toxic effects on plants or their excessive
accumulation in soils. The nitrogen content of the
renovated water may become a major consideration if the
water becomes the source of a drinking water supply.
The nitrate nitrogen in drinking water is limited to 10 mg/1
because of the possibilities for methemoglobinemia in children,
3-20
-------
Nitrogen mass balance computations can determine whether
this constraint will be limiting.
Some quantitative guidelines on those chemical
constituents in irrigation water which may interfere with
soil-crops system are available in the literature (5,6).
Shown in Table 3-3 are some major inorganic constituents
to be regulated in the irrigation water (5) , mainly on the
basis of their effects on soil structure and their
toxicity towards crops. As to trace elements in the
irrigation water, key factors to be considered are concen-
tration levels toxic to crops as well as the absorptive
capacity of the soil. Table 3-4 shows recommended maximum
concentrations of trace elements in irrigation water (6,11)
for various types of soil and application rates of irrigation.
The recommended maximum concentrations for continuous
use on all soils are set for those sandy soils that have
low capacities to react with the element in question. The
criteria for short-term use are suggested for soils that
have high capacities to remove from the irrigation water
the elements being considered (11).
3-21
-------
Table 3-3
SUGGESTED VALUES FOR MAJOR INORGANIC CONSTITUENTS
IN WATER APPLIED TO THE LAND (5)
Problem and related constituent
Salinity*
EC of irrigation water, in millimhos/cm
Permeability
EC of irrigation water, in mmho/cm
SAR (Sodium adsorption ratio)'1
Specific ion toxicityc
From root absorption
Sodium (evaluate by SAR)
Chloride, me/1
Chloride, mg/1
From foliar absorption^ (sprinklers)
Sodium, me/1
Sodium, mg/1
Chloride, me/1
Chloride, mg/1
Miscellaneous8
NO4-*! 1" ng/'1 for sensitive crops
HC03, ae/1 [only with over-"]
HC03, rag/1 mead sprinklers!
PH
No problem
<0.75
>0.5
<6.0
<3
<4
<142
<3.0
<69
<3.0
<106
<5
<90
Normal range »
Increasing
problems
0.75-3.0
<0.5
6.0-9.0
3.0-9.0
4.0-10
142-355
>3.0
>69
>3.0
>106
5-30
1.5-8.5
90-520
6.5-8.4
Severe
>3.0
<0. 2
>9 . 0
>9.0
>35S
"•••
—
>30
>8. S
>520
a. Assumes water for crop plus needed water for leaching requirement (LR) will
be applied. Crops vary in tolerance to salinity. mmho/cm x 640 •* approxi-
mate total dissolved solids (TDS) in rag/1 or ppm; mmho x 1,000 « micromhos.
b. SAR
Na
where Na = sodium, me/1, Ca =• calcium, Mg « magnesium.
c. Most tree crops and woody ornamentals are sensitive to sodium and chloride
(use values shown). Most annual crops are not sensitive.
d. Leaf areas wet by sprinklers (rotating heads) may show a leaf burn due to
sodium or chloride absorption under low-humidity, high-evaporation con-
ditions. (Evaporation increases ion concentration in water films on leaves
between rotations of sprinkler heads.)
e. Excess N may affect production or quality of certain crops, e.g., sugar
beets, citrus, grapes, avocados, apricots, etc. (1 mg/1 NOj-N = 2.72 Ib N/
acre-ft of applied water.) HC03 with overhead sprinkler irrigation may
cause a white carbonate deposit to form on fruit and leaves.
Note: Interpretations are based on possible effects of constituents on crops
and/or soils. Suggested values are flexible and should be modified when
warranted by local experience or special conditions of crop, soil, and
method of irrigation.
3-22
-------
la 4-9
SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
SUMMARY OF INDUSTRIAL SURCHARGES*
--.-•' .
! SIC
Industry Cat.
- "ABC c». i
i •
•F- ' i -; • --•"• - - - — • - 7flfiS
• • IN 0 c HPfck^ ' ~ • •••--• " * o o o
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CoWvpOKy f- ; 7218
_,.--• Quirky G i 3443
^ Co^oy H r 2021
;>; . : !T&fr Co. ; 201.1
Co^OhV k 2649
L-M*N,3>c. 2026
1 Cav»fa*y O 3471
! CovwjXfcy P 3269
i
0°VVfCWy ® 6062
1 - .
i Covp«wy ft 7395
: Cov^/ s 7218
New Surcharges to be Assessed
Under Present System
T.S.S.
( X
r
X
X,
X
X
X
X
.
C12
•
j
3
X
X
X
Surcharges to be Levied
Under Secondary Treatment
B.O.D.
X
X
-
X
X
*
X
T.S,S.
X
X
X
. - •-
X
X
X
X
P04
X
. ..
X
X
X
X
Previous Si
To be U
T.S.S.
.'<•„ , : *
X^-:
„ t*.
-,- " ' '-f
'\-. "a
x • ••>
X
•
X
jrcharges
pdated
C12
,K - ' .'.
x:
....-«. ...v..y.
"'•••'
•Vr •
X
X
X = new surcharge or updated surcharge required for that parameter
if HowCS at*,
-------
Table 4-10
SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
SUMMARY OF INDUSTRIES FOUND IN VIOLATION OF
SEWER ORDINANCES1
Industry
Cov*pa*y A
1 Co^pwye
] C4D,E»<-
Co**fo*y D
BftiGC*.
H Prtxiuek^c.
Co«^««y X
T
-------
TABLE 3-5
DISTRIBUTION OF SURVEYED TREATMENT PLANTS BY PLANT PROCESS
Source: Burns & Roe, 1975 (7)
PROCESS
Primary
Trickling Filter
Activated Sludge
Biological with Chemical
Addition
Tertiary
Other
NO. OF PLANTS
79
81
83
•
8
11
7
PERCENT OF TOTAL
29
30
31
3
4
3
Of the 61 water quality components originally considered,
a detailed study was made of 17 selected materials. The cri-
teria for choosing these 17 materials was based on the avail-
ability and validity of the data and the assumed.signifi-
cance of the material. When using data for generalizations
about plant performance, it is important to realize the
potential limitations of that data. For the plant performance
data to be presented later in this section, there are three
such considerations:
3-25
-------
xaoxe 1-
SEWER AUTHORITY INDUSTRIAL WASTE SURVEY
HEAVY METAL LOADING FROM MAJOR CONTRIBUTING INDUSTRIES
SAMPLED DURING PHASE II PROGRAM*
SIC
CATEGORY
A VG. DAILY
FIjOW MGD
Cr TOTAL
Cr HEX
eU N1
gJTJ
'* cu
1
2 As
w
ex
^
8 CD
t~-
0 Pb
0,
0 Hg
2
u
< Zn
i
Fe
MN
— »
foe. Waller Co.
2649
0.057
0.642
0.305
43.374
20.630
J
A
«r
«
A
26S3
0.068
0.0240
0.0138
.000399
4.906
2.800
j
I
2751
0.014
0.1918
0.0231
.000400
.000048
.2764
.0334
5.370
0.627 ••
6
o
2
2761
0.1715
0.0496
0.0710
0.0576
0.0824
.0048
.0069
1 .622
2.320
1
v
±
3321
0.099
0.041
0.034
0.098
0.081
0.119
0.098
6.782
5.600
0.121
0.100
to
en
-------
TABLE 3-6
CHARACTERIZATION OF PRIMARY AND BIOLOGICAL
PLM PERFORMANCE
Parameter*
Primary
Percent
Removal
GnedianL/(mean)
Cd (ug/D
Cr
Pb
Hg
Cu
Ni
Zn
Fe
Mn
P-TOT(mg/l)
TKN "
NH3 "
1 PHEN (ng/1)
TOC (mg/1)
COD "
SS "
BOD "
7/8
16/26
20/24
22/27
18/26
6/6
26/31
35/40
8/15
JD/13
ID/22
17/20
ID/38
20/24
18/26
50/51
28/30
Plants
Effluent
Concentration
(jnedianj/dnean)
11/14
90/188
110/156
0.6/1.0
110/191
75/165
300/550
1300/1518
160/176
10/13
ID/24
13/20
ID/16
125/142
340/346
78/93
140/167
Biological Plants
Percent
Removal
(median) /(mean)
9/19
41/42
41/38
38/35
56/56
16/21
52/52
59/57
28/35
.32/34
40/42
37/45
68/60
71/69
75/73
80/75
85/81
Effluent
Concentration
(median )/(mean)
10/30
50/218
60/92
0.6/3.5
50/113
65/182
160/277
600/1827
90/140
6/7
17/18
12/14
2.5/175
45/25
100/110
30/40
28/39
Notes:
Metal concentrations are for combined particulate and dissolved
fractions
ID = Insufficient data reported.
Source: Burns & Roe, 1975 (7)
3-27
-------
Statistical information on effluent concentrations and
removal efficiencies for the 17 selected parameters is
given in Tables 3-7 and 3-8, respectively for primary,
trickling filter, and activated sludge plants. It was
determined that a significant correlation exists between
influent and effluent concentrations of 9 metals (Table 3-9).
Median and mean removal efficiencies have also been
determined for a few modified biological and tertiary plants
(Table 3-10). The tertiary plants consisted of conventional
or modified activated sludge processes with polishing lagoons
or filters as the final process unit. Chemical addition with
biological treatment most often consisted of lime or polymer
addition to the primary clarifiers followed by conventional
activated sludge. For Cr, Pb, Hg, Ni, Zn, Total-phosphorus
and TOG, better removal efficiencies were obtained with
modified biological treatment than with tertiary treatment.
For the limited number of primary plants sampled for
cyanide and hexavalent chromium, total pass-through was
noted while for biological plants removals of 29% and 18%,
respectively, were noted (Table 3-11). Better removal of
oil and grease was noted in biological plants (68%) than in
primary plants (48%).
Specific Studies of Pollutant Removals
The discharge of heavy metals was recently studied (8)
at the Hyperion treatment plant, Los Angeles. This plant
discharged a total of 350 mgd, about 235 mgd of which was
primary effluent and 100 mgd was secondary (activated sludge)
effluent. It was thus possible to compare the metal
concentrations in primary and biological treatment effluents
for the same influent. Unfortunately, influent concentrations
of the materials were not presented so that actual pass-through
percentages could not be evaluated. The results of this study
indicated that in primary effluents, most of the Cd, Cr, Cu,
Hg and Zn were associated with a particulate fraction, while
in secondary treatment, which removed about 90 percent of
3-28
-------
TABLED?
EFFLUENT DATA SUMMARY
FOR PRIMARY, TRICKLING FILTER
AND ACTIVATED SLUDGE PLANTS (SELECTED PARAMETERS)
Parameter
Primary Plants
Trickling Filter Plants
Standard Max/ No. of
Cd (,,g/l)
Cr "
Pb
Hg "
Cu "
Ni
Zn "
Fe "
Mn "
P-TOTAL(mg/l)
TKN "
NH3
PHENOL (pg/1)
TOC (mg/1)
COD
SS
BOD "
Mean
14
188
156
1.0
191
165
550
1520
176
12.9
24.4
20.2
16
142
346
93
167
Deviation Min. Plants
9
406
272
1.3
278
387
658
1020
112
22
11.6
34.6
23
84.2
-
62
111
40/3
2600/6
1700/10
5.0/0.1
1700/10
1700/6
3600/30
5000/400
390/30
77/1.3
47/8.5
256/2.1
53/0.1
539/52
768/58
314/15
650/20
35
40
37
23
48
33
49
30
22
10
-
63
-
35
19
54
58
Mean
11
235
116
1.0
133
198
316
2910
136
9.02
16.8
16.6
209
54.3
133
43~
48.6
Activated Sludge Plants
Standard Max/ No. of
Deviation Min. Plants
10
563
276
2.0
283
336
464
11000
130
3.8
11.9
17.2
772
26.3
-
37
47.3
66/1
3200/3
1800/5
10.0/0.1
1800/3
1533/7
2800/40
65600/100
580/20
18.3/3.3
47.8/1.2
115/0.03
3000/0.03
129/23
361/18
228/5
245/4.0
41
52
45
22
54
38
57
34
28
27
21
65
13
23
38
66
61
Mean
50
202
67
6.0
92
165
238
747
144
5.2
19.0
11.1
135
35.3
86
37
28.3
Standard Max/ No. of
'Deviation 'Min. Plants
277
515
68
32
195
387
257
1170
200
2.7
9.6
7.6
473
22.4
-
39
40.7
1970/1
2520/5
350/3
200/0.1
1600/8
1700/6
1400/10
6800/100
940/10
10.4/1.0
34/1.5
27.5/0.07
2000/0.02
95.0/10
275/14
185/2
230/2.0
48
60
51
37
68
56
66
37
23
40
12
63
16
14
42
64
65
I
ro
Source: Burns & Roe, 1975 (7)
-------
TABLE ,3-8
REMOVAL DATA SUMMARY*
FOR PRIMARY, TRICKLING FILTER
AND ACTIVATED SLUDGE PLANTS (SELECTED PARAMETERS)
Parameter
Cd
Cr
Pb
Hg
Cu
Ni
Zn
Fe
Mn
P-TOTAL
TKN
NH3
PHENOL
TOG
COD
SS
BOD
Mean
8
26
24
27
26
6
31
40
15
13
22
20
38
24
26
51
30
Primary
Standard
Deviation
17
26
26
29
24
18
22
22
20
8
20
16
-
19
-
18
22
Plants
Max/
Min.
76/0
80/O
88/0
75/0
77/0
92/0
88/0
89/0
81/0
24/0
60/0
64/O
50/25
56/0
82/0
92/17
89/0
Trickling Filter Plants
No. of
Plants
31
36
34
21
44
28
38
27
16
7
7
42
2
30
18
47
52
Mean
20
37
37
30
54
21
46
50
31
26
50
41
50
64
71
75
77
Standard
Deviation
25
30
31
23
24
23
22
26
23
22
27
30
28
18
-
19
18
Max/
Min.
75/0
99/0
93/0
67/0
95/0
86/0
89/0
90/0
72/0
99/0
94/7
99/0
85/0
84/8
95/34
97/20
96/5
No. of
Plants
35
48
41
20
49
32
52
30
21
24
20
48
12
23
36
66
60
Activated Sludge Plants
Mean
17
46
39
39
57
20
58
63
38
42
34
49
69
73
75
75
84
Standard
Deviation
27
34
32
32
24
21
25
27
32
25
26
31
31
12
-
22
15
Max/
Min.
88/0
98/0
95/0
99/0
95/0
80/0
99/0
98/8
93/0
92/0
92/5
99/4
98/0
89/42
94/24
99/9
99/18
No. of
Plants
44
54
49
34
63
44
58
35
19
36
11
47
16
13
40
62
65
Notes;
* All numbers except the number of plants are in percentage
Source: Burns & Roe, 1975 (7)
-------
*In a study to evaluate the effect of treatment plant variables
upon the removal of metals from sewage, the investigator
found that the effluent concentration was most dependent on the
influent concentration. The actual correlation ~cbeficierits""~
for this influent-effluent concentraTr"relationship are presented
in Table 3-9 for the 9 metals studied under 3 different types of
sewage treatment.
TABLE 3-9
CORRELATION COEFFICIENTS: INFLUENT VS EFFLUENT CONCENTRATIONS
CORRELATION COEFFICIENTS*
COMPONENT
Cadmium
Chromium
Lead
Mercury
Copper
Nickel
Zinc
Iron
Manganese
Primary
0.97
0.98
0.58
0.89
0.97
0.94
0.96
0.67
0.92
Trickling Filter
0.83
0.81
0.67
1.00
0.87
0.69
0.93
0.99
0.85
Activated
Sludge
1.00
0.84
0.77
0.76
0.67
1.00
0.61
0.57
0.95
MO OF
iNW • wf
PLANTS
P/TF/AS
31/35/44
36/48/54
34/41/49
21/20/34
44/49/63
28/32/49
38/52/58
27/30/35
16/21/19
Source: Burns & Roe, 1975 (7)
3-31
-------
TABLE 3-10
REMOVAL IN BIOLOGICAL PLANTS WITH CHEMICAL
ADDITION, AND TERTIARY PLANTS
Biological w/Chem
Addition
CD
CR
PB
HG
CU
NI
ZN
FE
MN
P-TOTAL
TKN
NH3
PHENOL
TOG
COD
SS
BOD
Median/
Mean
0/0
67/70
38/39
33/34
80/75
75/62
79/72
84/84
39/39
80/78
51/57
45/56
82/82
79/79
87/78
83/78
93/86
No. of
Plants
4
6
6
5
5
7
8
3
2
6
6
5
2
3
5
8
6
Tertiary
Median/
Mean
0/6
14/32
31/44
17/22
79/73
13/18
77/63
94/82
47/53
41/43
88/88
89/80
85/65
75/74
88/84
93/90
95/90
No. of
Plants
5
7
10
4
9
5
7
8
5
6
2
9
4
3 .
10
11
11
Source: Burns & Roe, 1975 (7)
3-32
-------
- 11
OJ
u>
REMOVAL AND EFFLUENT DATA SUMMARY
FOR OIL AND GREASE, CYANIDE AND
HEXAVALENT CHROMIUM
Primary Plant
(PP)
Effluent
Percent Removal Concentration
Median/Mean N Median/Mean N
O&G
CYN
HEX.
(mg/1)
(mg/1)
CR. (ng/1)
52/48
0/0
0/0
6 25
1 0.
.0/27.8 6
055/0.075 4
3 20/17 3
Biological Treatment Plants (BP)
Effluent
Percent Removal Concentration
Median/Mean N Median/Mean N
83/68
3/29
0/18
13 9.0/21.0
14 0.010/3.672
19 10/15
25
28
20
Source: Burns & Roe, 1975 (7)
-------
the particulates, the effluent contained mainly dissolved
metals (Table 3-12). However, the remaining particulates
in the secondary effluent were of small diameter in the
range of 0.2 to 0.8y and could thus bear higher fractions
of trace metals per unit mass of particulate than could the
larger primary effluent solids in the range of 44 p. In
general, the total amount of each metal component constituted
from 0.3 to 0.9 percent of the total dry weight of waste-
water particulate matter and the trace metal composition of
the particulates (primary and secondary effluents) generated
from the Hyperion plant consisted as follows (in milligrams
per kilogram,- dry weight) :
Hg 3
Mn 50 - 160
Cd 90 - 200
Pb 200 - 800
Ni 300 - 800
Cu 800 - 1,500
Cr 1,700 - 2,500
Zn 2,000 - 3,000 ;.
Fe 3,000 - 5,000
For primary or secondary treatment, the differences in the
removal of particulates containing adsorbed metals will be
reflected in the metal content of the sludge generated from
either process.
Polychlorinated Biphenyls (PCB's). These compounds,
used mainly for electrical insulation, contain from 12 to 68
percent chlorine and are extremely stable and flame resistant.
The refractory properties of these materials and the relatively
high concentrations found in several aquatic environments
suggest that sewerage systems may convey some amount of PCB's
3-34
-------
TRACE METAL REMOVAL EFFICIENCIES OF THE SECONDARY TREATMENT PROCESS AT
HYPERION WASTEWATER TREATMENT PLANT, FROM CHEN ET AL (8)
U)
I
CO
LTI
Sample
Suspended 05
particulates 06
Cd 05
06
Cr 05
06
Cu 05
06
Hg 05
06
Ni 05
06
Pb 05
06
Zn 05
06
Mn 05
06
Fe 05
06
Total Concentrations Dissolved Fractions*
Primary Secondary Reduction" Primary Secondary Reduction
Effluent Effluent (%) Effluent Effluent (%)
(MQ/D (pg/D (Mg/D (pg/D
75t
net
10.4
28
315
300
102
130
0.5
0.5
191
200
98
110
182
430
38
32
457
700
5t
7t
7
10
50
60
15
40
0.16
0.12
82
150
56
41
102
105
26
24
58
85
93
94
30
64
84
80
85
69
68
76
57
25
43
63
44
75
31
25
87
88
3.0
2.7
147
100
25.5
20
0.13
0.13
169
153
69
95
41
53
23
27
196
120
5.7
9.0
30
47
10.7
27
0.07
0.10
78
140
49
40
94
87
25
23
40.6
53
-90
-230
80
53
58
-35
46
23
54
10
29
58
-130
-64
-9
15
80
56
*Dissolved fractions are those remaining in filtrate after it is filtered
through 0.2 p membrane filters.
^Suspended particulate concentrations are in milligrams per liter.
"Reduction from primary effluent to secondary effluent.
-------
to receiving waters. .The U.S. EPA has issued waste disposal
restrictions aimed at keeping PCB concentrations in aquatic
environments below 0.001 y g/1 while FDA limits for edible fish
is 5 ppm which may possibly be lowered to 2 ppm. Concentrations
of 5 to 20 mg/1 of PCB's have been measured in salmon and
striped bass from Lake Ontario and the Hudson River (9). Of the
18 million kilograms of pcb's produced annually, it is estimated
that 4.5 million kilograms are lost to the environment. The
sources have been partly identified as being the sole U.S. manu-
facturer and various users of PCB's discharging directly to
receiving waters or through the sewage systems of municipalities.
A study (10) of treatment plants in Wisconsin with flows, :
ranging from 0.14 mgd showed effluent concentrations of
PCB's to range from less than 0.05 yg/1 to 42 ug/1 with 6 of
the 11 plants' effluents in the range of 0.1 to 0.5 ug/1.
At a 1 mgd trickling filter plant serving an industrialized
area, about 70 percent removal of PCB's into sludge was noted
with effluent concentrations ranging from 0.28 to l.ly g/1.
The industries in this municipality manufactured cement, metal
work abrasives, paint, fiberglass, and electrical equipment.
Average PCB effluent concentrations from a primary plant and
an activated sludge plant of similar size (about 1 mgd) were
0.17 and 0.14y g/1, respectively, but no influent data was
available to calculate removal percentages. A small, 0.14 mgd,
trickling filter plant that received no industrial wastes
discharged from 0.17 to 0.38y g/1 of PCB's. Cleaning com-
pounds, waxes, detergents and packaging material were cited
as possible residential sources of PCB. The study concluded
that secondary treatment could remove up to 70 percent of the
influent PCB's.
3.4.2 Impact of Pollutants on Receiving Waters
A material introduced to an aquatic environment may have
a singular effect on the physical, chemical, or biological
components of a system, it may cause a succession of events,
or it may have multiple effects on these components. For
example, the discharge of suspended solids to a receiving
water will decrease its clarity—a physical effect. By
3-36
-------
excluding a certain amount of light energy, the decreased
clarity will affect the phototrophic community and such a
shift in species distribution could alter the grazing habits
of higher trophic levels—multiple biological effects.
Furthermore, the suspended solids could provide surfaces
for the adsorption of dissolved materials, such as heavy
metals, and aid in their deposition to the sediments—a
physical-chemical effect. The impact of a material will
be a function of the receiving water's characteristics, as
well as the general characteristics of that material. Initially,
upon discharge of any substance to a receiving water, it
will be subject to dilution and possibly volatilization,
sedimentation, adsorption, precipitation, solubilization,
chemical reaction and biological utilization.
The intended uses of waters that receive treated wastes
must be defined in order to appropriately consider the
impact of pollutants. Waters to be reused for drinking water
supplies are of vital concern because of the obvious or
suspected health-related consequences of ingesting even
minute quantities of many compounds. As a result, much
effort has been invested in developing criteria and
recommending limits for a wide range of compounds in drinking
water supplies. Waters used for fishing and shellfishing
with the catch intended for human consumption pose a special
problem. Numerous compounds, such as metals, pesticides,
and pathogens, are known to magnify in some organisms to
many times the dilute concentrations existent in their
aquatic habitat. The mechanism can be either biomagni-
fication—one organism such as a clam acting as-a filter
and retaining pollutants, or trophic accumulation—concen-
trating a material up the food chain as each higher trophic
organism grazes its prey. The impact of pollutants on waters
to be used for recreation,e.g., swimming and boating, is
very often the most difficult to assess. In addition to
the possibility of ingestion, a bather will be exposed to
the effects of a given material due to skin contact and
3-37
-------
absorption through other bodily orifices. To date, most
epidemiclogical studies of the recreational use of water
have been inconclusive.
Presented herein are the impacts, of materials that are
likely to be present in industrial wastes. The physical and
biological effects which have been observed for these
materials are briefly described. Where possible, recommended
concentration limits are given for receiving waters as
proposed by the National Academy of Sciences, the U.S. EPA,
or other regulatory agencies. Several of the more complex
water quality components are discussed in the text while the
remainder are tabulated for simple reference. An extensive
review on the effects of contaminants on aquatic environ-
ments and man was conducted by the National Academy of
Sciences (NAS). The resultant document, "Water Quality
Criteria 1972," is a comprehensive reference on pollutants
and their impact on all types of waters and intended uses (11).
Organic Material. Sewage treatment plants are designed
specifically to remove some fraction of the influent organic
materials. Organic, or carbonaceous, wastes consist of a
variety of compounds, however, ranging from metabolic
products such as carbohydrates, proteins, and fats to
synthetic or refined chemicals such as pesticides and
benzene derivatives. After their discharge to receiving waters,
many of these compounds are susceptible to further decompo-
sition and oxidation, thus imposing a demand on the oxygen
resources of the water. As dissolved oxygen is consumed by
biological or chemical reactions, numerous secondary
effects may result in the aquatic environment. Conversely,
some of the organic compounds resist decomposition and
persist in toxic forms which may upset the biota of an
aquatic environment and may even pose a threat to human
health. There are several tests that are popularly performed
to help quantify the above types of organic material. The
results of these tests are commonly accepted as water quality
parameters. These are the 5-day Biochemical Oxygen Demand
3-38
-------
(BOD), Chemical Oxygen Demand (COD), Total Organic Carbon
(TOC)/ and Carbon Adsorbable Organics (CCE and CAE; see
page 3-40).
The BOD of a waste ideally measures the amount of
oxygen consumed by heterotrophic organisms during the de-
composition of an organic portion of this waste over a 5-
day test period. For a domestic wastewater, about 1.5
pounds of oxygen are required per pound of organic matter
metabolized, but this could vary considerably for many
industrial carbonaceous wastes. Historically, the BOD test
has been used to estimate acceptable loadings on a
receiving water by consideration of assimilative (or
recovery) mechanisms of the receiving water and prescribed
limits of the minimum acceptable dissolved oxygen concen-
trations for intended uses of the water. The test can be
deceptive, however, because the BOD resulting from a
laboratory test will not necessarily represent natural
conditions in a receiving water.
The COD of a waste measures all of the material that
is subject to oxidation by both biological or chemical
mechanisms. For many industrial wastes which may contain
exotic and possibly toxic (to heterotrophs) organic com-
pounds, the COD test will better represent the potential
oxygen demand on receiving waters. The COD of a waste will
be larger than the BOD and the additional oxygen demand
reflected by this difference will be exercised at a slower
rate in natural waters. Both BOD and COD are used to
relate waste discharge to oxygen depletion in receiving
waters, but universal limitations for these parameters
cannot be stated because of the large variability of
assimilative mechanisms in receiving waters.
The TOC of a waste measures the complete set of organic
carbon compounds. Although the test is relatively simple
and automated devices to perform it are marketed, it does
not identify any specific organic fractions nor does it
3-39
-------
quantify an oxygen demand potential of a waste. However,
it is possible that for some industrial wastes, correlations
between TOG and more specific parameters can be developed
and the test will thus have useful applications. The carbon
adsorbable organics tests are slightly more descriptive.
The Carbon Chloroform Extract test (CCE) measures those
compounds that are adsorbed onto activated carbon and then
are extracted by a chloroform washing. Many of the com-
pounds measured by this test are potentially toxic or
carcinogenic. The presence of substituted benzene compounds,
kerosene, polycyclic hydrocarbons, phenylether, acrylo-
nitrile and insecticides have been noted in CCE tests. A
limit of 0.3 mg/1 CCE in water supplies has been recommended
by NAS and 0.7 mg/1 by the U.S. EPA. The Carbon Alcohol
Extract (CAE) test uses ethyl alcohol to desorb materials
subsequent to the chloroform desorption procedure. Alkyl
benzene sulfonate (ABS) among other compounds, has been
noted to be present in CAE material. The NAS has recommended
a limit of 1.5 irig CAE/1. Both the CAE and CCE may be
particularly pertinent to many industrial wastes. Unless
attempts are made to correlate CCE and CAE with specific
compounds, the test should be considered a general measure
of aesthetically or biologically undesirable compounds of
unidentified organic structure.
Pesticides. It is likely that industries producing
pesticides and herbicides will discharge some amount of these
materials in waste streams. Among such materials are
chlorinated hydrocarbons, organophosphorus compounds, and
chlorophenoxy herbicides. Many of these compounds, parti-
cularly the insecticides, are extremely persistent in the
environment and highly toxic to mammals. Furthermore, they
are magnified in other organisms consumed by man. The herbi-
cides are also toxic but generally at higher concentrations.
Herbicides, if inadvertantly discharged to a receiving water,
could kill the aquatic vegetation which upon decomposition
could deplete the dissolved oxygen and upset other organisms
3-40
-------
James River Closed to Fishing Because of Kepone Pass-
Through at Sewage Treatment Plant of Hopewell, Va.
In addition to the digester upset described on page 3-15
the kepone-containing industrial waste caused the kepone to
pass through the Hopewell sewage treatment plant for 16
months and contaminate the receiving waters—the best shad
and oyster waters of Virginia's James River from Richmond
to Tidewater, and perhaps other Chesapeake Bay tributaries
as well.
Kepone, a toxic substance in all mammalian species and
a suspect carcinogen, tends to persist for years in the
environment and accumulate along the aquatic food chain.
James River was closed to fishing in December, 1975,
denying thousands of fishermen their only livelihood. The
lost catch already runs into the millions of dollars, and
the James River fishermen are suing for $27 million.*
* New York Times, January 28, 1976.
in the water. Recommended safe limits on the concentration
of pesticides in water have been derived from animal and a
few limited human toxicity studies with safety factors of
from 0.002 to 0.1 applied (Table 3-13).
Other Compounds. Table 3-14 gives the possible effects
of 23 other compounds or elements that are likely to be
discharged by industrial operations.
3-41
-------
Table 3-13
RECOMMENDED (U,S, EPA) SAFE LIMITS FOR PESTICIDES
DRINKING WATER SUPPLIES*
CHLORINATED HYDROCARBON INSECTICIDES
Aldrin
Chlordane
DDT
Dieldrin
Endrin
Heptachlor
Heptachlor Epoxide
Lindane
Methoxychlor•
Toxaphene
0.001 mg/1
0.003
0.05
0.001
0.0005
0.0001
0.0001
0.005
1.0
0.005
ORGANOPHOSPHATE AND CARBAMATE INSECTICIDES
As Parathion 0.1 mg/1
CHLOROPHENOXY HERBICIDES
2, 4-D__.
2, 4, 5-TP (Silvex)
2, 4, 5-T
0.02 mg/1
0.03
0.002
*National Academy of Sciences (1972) Water Quality Criteria
3-42
-------
TABLE 3-14
POSSIBLE EFFECTS AND RECOMMENDED LIMITS
FOR INDUSTRIAL WASTE COMPONENTS
COMPOUND EFFECTS
RECOMMENDED LIMITS (mg/1)
Wildlife
Drinking Support
Ammonia 1.Biological nutrient. Used
NH^ by algae, vascular plants &
microorganisms for growth.
2.Exerts an oxygen demand on
receiving waters by reacting
to form nitrate.
3.Interferes with Chlorina-
tion by the formation of
chloramines.
4.Sometimes corrosive to
copper.
5.Toxic in high concentra-
tions .
Arsenic 1.Toxic. Causes fatigue,
As gastrointestinal catarrh,
kidney degeneration, tendency
to edema, polyneuritis, liver
cirrhosis, bone marrow in-
jury, exfoliate dermatitis
and possibly cancer.
Cadmium 1.Toxic. Accumulates in
Cd liver and kidney tissue.
Causes the skeletal de-
forming Itai-itai disease.
2.Toxic to aquatic organisms,
especially in soft water.
Chromium l.Hexavalent chromium is
Cr toxic to humans. Can cause
tumors, skin sensitization,
and possibly intestinal
disorders.
2.Toxic to aquatic organisms,
causing inhibition of growth
and death.
0.05
0.01
0.003
0.0004
1*
0.05
0.OS-
Academy of Sciences, 1972. Where reference notations
are absent, limitations"are from U.S. EPA, (40CFR51 March 14, 1975,
p. 11994 fcdLRogO
*Higher value is for soft water.
3-43
-------
TABLE 3-14 (Cont.)
COMPOUND EFFECTS
RECOMMENDED LIMITS (mg/1)
Wildlife
Drinking Support
Copper 1.Large doses can cause
Cu emesis and liver damage.
2.Imparts taste to drinking
water.
3.Enhances corrosion of
aluminum.
4.Toxic to aquatic life,
especially algae and mol-
lusks. Atlantic salmon
will avoid a concentration
of 0.004 mg/1. Tests sug-
gest a concentration of
0.033 mg/1 would be safe
for flathead minnows.
Cyanide 1.Toxic to fish and to
HCN humans in large (50-60
mg/1) doses.
Iron 1.Imparts taste to
Fe drinking water.
Lead 1.Toxic to man, causing
Pb burning in the mouth,
severe thirst, vomiting,
diarrhea, anorexia, nausea,
severe abdominal pain,
paralysis, mental confu-
sion, visual disturbances, .
anemia, and convulsions.
Especially toxic to young
children.
2.Toxic to fish, especially
in soft water. The 96 hour
LC50 often ranges from 1 to
7 mg/1. Possible chronic
effects include reproductive
and growth interference.
Nickel 1.Toxic to fish. Estimated
Ni safe concentration (for flat-
head minnows) is 0.1 mg/1.
i.o-
0.2
0.3"
0.05
0.005'
0.03'
3-44
-------
TABLE 3-14 (Cont.)
COMPOUND EFFECTS
RECOMMENDED LIMITS (mg/1)
Wildlife
Drinking Support
Nitrate 1.Biological nutrient. Can
"NO.. be especially significant
Nitrite in estuaries where nitrate
NO- has been estimated to be
limiting.
2.Responsible for methemo-
globinemia (hemoglobin al-
teration producing suffoca-
tion) in infants.
3.Possibly responsible for
reactions occurring in the
body to form carcinogens.
Manganese 1.Imparts taste to drinking
Mn water, stains laundered
clothes, and forms deposits
in distribution systems.
Mercury 1.Toxic, especially as
methyl mercury. Symptoms
of acute toxicity are vomi-
ting, abdominal pain, bloody
diarrhea, kidney damage and
death usually within 10 days.
Chronic exposure causes in-
flamation of mouth and gums,
swelling of salivary glands,
excessive salivation, loosen-
ing of teeth, kidney damage,
muscle tremors, spasms of
extremities, personality
changes, depression, irrita-
bility, and nervousness.
2.Can be biologically mag-
nified by aquatic organisms
thus increasing the toxic
potential by human consump-
tion. Magnification of
10,000 times have been mea-
sured in experiments with
brook trout.
10(N03)
0.05'
0.002
0.000051*
0.5 mg/kg
«
Recommended concentration to avoid accumulation in an organism
beyond the limit of 0.5 mg/kg which is the allowable total body
burden in an organism intended for human consumption.
3-45
-------
TABLE 3-14 (Cont.)
COMPOUND EFFECTS
RECOMMENDED LIMITS (mg/1)
Wildlife
Drinking Support
Oil and 1.Cause taste, odor, and
Grease appearance problems.
2.Floating oil affects
waterfowl by decreasing
buoyancy, accelerating heat
loss, and inhibiting egg
hatching.
3.Can cause changes in ben-
thic and shoreline communi-
ties.
4.Toxic to aquatic organisms.
The 96 hour LC50 for various
refined components of oil
(e.g.: benzene, gasoline,
bunker oil) ranges from 5.6
to 14,500 mg/1.
pH 1.Affects corrosion of metals
2.Affects biological processes,
by direct toxicity or enhancing
the effects of other compounds.
PCS 1.Toxic to fish. The higher
the percentage of chlorine,
the lower the toxicity. LC50
values range from 10 to 300 mg/1,
2.Toxic to humans, causing skin
lesions, increased liver enzyme
activity, and Yusho.disease.
Suspected carcinogen.
Phenolics 1.Imparts taste and odor
to drinking water.
2.Affect the taste of fish
consumed by humans.
O.OOl/ij/4
0.001'
o.i-
P04~
Phosphate 1.Associated with eutrophica-
tion of waters. Can stimulate
noxious plant growths.
2.Concentrations above 0.1
mg/1 can affect coagulation
of drinking waters.
**
Possibly a safe concentration.
**
No universal limits can be determined.
3-46
-------
TABLE 3-14 (Cont.)
COMPOUND EFFECTS
RECOMMENDED LIMITS (rag/1)
Wildlife
Drinking Support
Silver
Ag
Sulfate
so4~
Sulfide
H2S
Surfact-
ants
ABS,LAS
Zinc
Zn
1.Causes a grey discoloration
of the skin and eyes, and
mucous membranes of humans.
1.Laxative effect on humans.
2.Can impart taste.
1.Toxic, especially at low
pH and low dissolved oxygen
levels.
1.Produce unsightly masses
of foam in streams or along
shores of lakes.
2.Helps to disperse normally
insoluble or sorbed substances,
thus interferes with sedimen-
tation .
3.High concentrations are toxic
to humans (LAS at 700 mg/1).
4.Lethal to fish at concentra-
tions of 0.2 to 10 mg/1 (as LAS).
1.Imparts taste to drinking
water.
2.Toxic to aquatic life. Toxi-
city is enhanced in soft water
and in waters with low dissolved
oxygen con. For flathead minnows,
the 96-hour LC50 was 0.87 mg/1 in
soft water and 33 mg/1 in hard
water.
0.05
250'
0.5'
0.002'
0.2'
3-47
-------
disposal is Um.W.-fDr "He
s«u«U, by 4<*ic ^HaW*.
of law* utiUia-Kn. of sludge «rc ^ discuss**.
3.5 POLLUTANTS WHICH AFFECT SLUDGE DISPOSAL
3.5.1 Introduction
The type and quantity of industrial discharges and the
degree to which industrial pretreatment is practiced will
directly influence the characteristics of POTW sludges. On
the basis of POTW sludge character, two extreme sludge types
are likely. The first type results when an industry dis-
charges mostly compatible type wastes to a municipal sewage
treatment plant. In this case the resulting POTW sludge re-
sembles a typical domestic sludge. There is within this do-
mestic type sludge a range of sludge compositions extending
from those with low to those with high industrial character.
A second type of POTW sludge, predominantly an industrial-
like sludge, results when an industrial waste constitutes
either the major portion of the total POTW waste, e.g.,
pulp industry waste, or contributes a- high portion of a spe-
cific chemical category, e.g., metals. In addition, indus-
trial sludges are also generated directly by industries
that extensively pretreat their wastewater before discharge
to POTWs. The route of formation of these two extreme
sludge types are depicted in Figure 3-1.
3.5.2 Sludge Composition
The composition of two Type 1 POTW sludges, one with
low and one with high industrial character is shown in Table
3-15. It is the metal content of sludges that frequently
can be used to distinguish its industrial nature. The sludge
(Blue Plains) with low metal character originates from
Washington, D.C., a city known to be predominantly residen-
tial in composition. The sludge (Lawndale) with high metal
content originates in Chicago, a city with much higher in-
dustrial character. The Blue Plains sludge, for example,
contains only l/5th the amount of zinc and nickel and l/30th
the cadmium content of the Chicago sludge. It is important
to recognize, however, that even in the case of a municipal-
ity where sewers service predominantly domestic users, the
-------
Industrial Wastewater
Type I Sludge
Predominantly
Domestic
(Most Common)
Type 2 Sludge
Predominantly
Industrial
(Less Common)
Figure 3-1
ROUTES OF FORMATION OF Two DIFFERENT SLUDGE TYPES
3-49
-------
TABLE 3-15
CHEMICAL COMPOSITION OF LOW AND HIGH METAL SLUDGE (12)
CONCENTRATION, ppm
ELEMENT
N
P
K
Ca
Mg
5
Zn
Cu
Wn
Ni
Cd
Cr
Mo
Fe
B
Hg
BLUE PLAINS, WASHINGTON, DC
25,000
10,000
5,000
15,000
10,000
9,000
2,000
1,100
180
100
20
NAS
8
NA
23
NA
LAWNDALE, CHICAGO
18,250
35,300
1,855
51,000
12,550
7,600
10,325
2,915
340
500
655
4,980
NA
i.
39,950
NA
3.5
a. NA = Not Available
-------
presence of combined storm and sanitary sewers may permit the
entry of significant quantities of certain metals into the
sewage system and ultimately into the sludge. The much higher
metal content of-the Chicago sludge is most likely due to
industrial discharges.
Two general types of industrial chemicals can contami-
nate POTW sludges. These are inorganic chemicals, such as
the heavy metals, and organics which do not biodegrade dur-
ing the treatment process.
Metals. A large fraction of heavy metals in wastewater
effluents and surface runoff is known to be associated with
suspended solids (13). Because a higher efficiency of sus-
pended solids removal is a characteristic of secondary treat-
ment processes (compared to primary treatment processes)
differences in metal content of respective sludges can be
expected. Chen ejt al. (13) , reported that when secondary
treatment removed 90 to 95% of the suspended solids, from
70 to 85% of the chromium, copper and mercury and from 30 to
60% of the total cadmium, nickel, lead and zinc were also
removed and incorporated into the POTW sl-udge. Thus metals
removed from wastewater appear to be strongly coupled to
the suspended solids removal capability of the treatment
plant.
Organic Chemicals. Organic chemicals which are non
or slowly biodegradable may be concentrated in treatment
plant sludges. Specific information as to type of organic
chemicals and the degree to which they concentrate in
sludges is sparse. The most likely mechanism for concentra-
tion into sludge is a result of a specific organic compound's
capacity to adsorb onto wastewater solids (14).
The concept that removal efficiency of organics by
wastewater treatment sludges is related to the suspended
solids removal capability of the POTW was clearly demon-
strated by the work of Ganz et al (14). The removal by
3-51
-------
wastewater treatment of fluorescent whitening agents (FWAs)
(used in household detergents to improve the visual appear-
ance of laundered fabrics) was studied and found to be di-
rectly related to the POTW's suspended solids removal capa-
bility.
Industrial contribution of dyes, inks, paint pigments,
polychlorinated biphenyls (PCBs) and pesticides are likely
to be found in sludge. This also results from their dual
properties of adsorptivity as well as resistance to biolog-
ical degradation.
Industrial sludges generated as a result of pretreat-
ment will be highly industry specific. Generally these
sludges will not contain significant quantities of pathogens,
and will consist predominantly of either inorganic or exotic
organic chemical sludges. Lime sludges containing heavy
metal hydroxides are a very common industrial type of inor-
ganic sludge.
3.5.3 Sludge Disposal Options
Municipal wastewater sludges are presently disposed of
by the following methods. The frequency of use of each dis-
posal option is listed in parentheses: (15)
1) Land spreading of liquid and dewatered sludges (20%)
2) Lagooning and landfilling (40%)
3) Incineration and landfill of ash (25%)
4) Ocean dumping (15%)
5) Fertilizer by-product recovery ( 1%)
The popularity of landfilling is due to several factors
which include cost-effectiveness, availability of land and
lack of strong environmental requirements governing the
practice. However, the trends in sludge disposal practices
are subject to rapid change and appear to be influenced by
a very complex set of economic, environmental, and institu-
tional factors. For example, the United States EPA has
3-52
-------
Problem of Kepone-Containing Sludge
at Hopewell, Virginia
The admittance of Kepone-containing industrial waste into the
POTW of Hopewell, Virginia, described on page 3-15 also created
a sludge disposal problem. The lagooned sludge was found to
contain 200 to 600 ppm of Kepone with 3 to 5% solids*, and was
deemed unsuitable for land disposal as practiced before the
Kepone contamination**. Solution to this problem might in-
volve chemical fixation of lagoon sludge followed by burial or
incineration*.
*EPA fact sheet on Kepone, 1-9-76 (Office of Water Planning and
Standards, Washington, D.C.)
**Personal communication with William R. Havens, Superinten-
"dent of Hopewell sewage treatment plant.
H* i
un**kkly >U*xc out OOBA* AMMIVM of SVHOM sM«» bv 198
l»vi 6 W jiipo^t *«M* v* U JAiH4<*A
The incineration option on the other hand has come
under strong local disapproval as a result of escalating
costs of fuel and the concern for effects of air pollution.
Land spreading practices are dependent on local attitudes
concerning land use as well as concern about dissemination
of toxic metals and pathogens. Landfilling appears, for the
moment at least, to have escaped careful environmental scru-
tiny. However, substantial adverse environmental impacts
are likely in all but the most rare of landfills and this
disposal option will probably become less available.
3.5.4 Impacts of Industrial Waste Discharges on Sludge
Disposal Options'*
• Table 3-16 presents an overview of available sludge
disposal options and qualitatively describe the environmen-
tal problems associated with each. A more detailed dis-
cussion of how specific industrial chemicals affect each
disposal option is presented in the following section.
Land Spreading . , , ,
—. - - r-^_ iwck W bee* us«i I
One criterionAfor determining sludge loading rates was
based on an early recommendation of the Agricultural Research
1-S3
cfoousi** "t* aUa ralevaJ- -fey w«*-Vv^ur|rtV JfcUaio of
«* runoff f« a
-------
Table 3-16
IMPACT OF INDUSTRIAL CHEMICALS ON POTW SLUDGE DISPOSAL OPTIONS
Municipal Sludge
Disposal Option
Landspreading
Lagooning and
Landfill
OJ
I
Incineration
and Landfill
Ocean Dumping
Resource Recovery
Composts and Fertilizers
Major Environ-
mental Concerns
Metal content of
sludge may injure
or contaminate crops
Metals and organics
in leachates may
contaminate ground
and surface waters.
Air emissions may
cause pollution, e.g.
metals such as mer-
cury; Leachate gene-
ration from disposal
of ash may cause water
pollution.
Metals and organics
in sludges may de-
stroy biological
productivity. Toxi-
cants such as metals
and pesticides may
enter food chain.
Metals and toxic
organisms may contami-
nate product.
Specific Abate-
ment Procedures
Adjust sludge loading
rates to provide safe
limits.
Protect groundwater
at landfill site from
contamination, e.g.
Use of liners
cover materials
underdrainage system
chemical fixation
Install Air pollution
emission controls.
Protect ground water
as described under
Landfill.
None
Longrange Planning
and Regulatory Response
Establish acceptable
sludge metal levels.
Enforce industrial pre-
treatment for selected
problem metals. Estab-
lish a program for
maintenance of records
on sludge compositions,
loadings rates, etc.
Establish selection
procedures for land-
fill sites. Establish
Landfill Management
Program.
Plan to use incinera-
tion for distraction of
toxic or nonbiodegr ad-
able organics if lo-
cally a problem. Up-
grade air pollution
control.
uture phase out of
this disposal option.
Reduce toxic components
by pretreatment.
-------
Service, U.S. Department of Agriculture and is shown below.
This formula illustrates how the metal content of sludge
functions as a limit to the amount of sludge that may be
applied:
Total sludge (dry weight tons/acre)=
32,700 x CEC , h
ppm Zn + 2(ppm Cu) + 4(ppm Ni) - 200
CEC = Cation exchange capacity of the
unsludged soil in meq./lOO g.
ppm = mg/kg dry weight of sludge
This equation limits the heavy metal additions calculated
as zinc equivalents to 10 percent of the CEC. The zinc
equivalent takes into account the greater plant toxicity of.
copper and nickel.
It has been generally recommended that sludges having
a cadmium content greater than 1 percent of its zinc content
should not be applied to cropland except under the following
conditions:
1. There is an abatement program to reduce the
quantities of cadmium in the sludge to an
acceptable level
2. The project is reviewed by the U.S. Depart-
ment of Agriculture and the Food & Drug
administration
Chaney (16) has conservatively proposed a metal con-
Jk,
tent of a sludge appropriate for land application;^
Element Content
Zn 2000 ppm
Cu 800 ppm
Ni 100 ppm
Cd 0.5% of Zn
B 100 ppm
Pb 1000 ppm
Hg 15 ppm
'i Note; 6cu^ of *H»«s
effect Hu*wx» lf\#tWi e-fe-b- -fcrov* €«4iM CMP* "K vj^»'^ -W«^ J^o Accowrt. frr«v -H.U Pofci- of V
C^rK>r»a ou* towBeWocNvt ivt tr^-V^nj cro^r; 4W tri-M?* tv»*y n»
-------
Cheney's formulation is presented here to serve primarily as a
point of reference for later calculations (See Table 3-19). These
proposed limits have been developed to protect plants and reduce
uptake of metals. It is not known what margins, if any, exist between
current levels of heavy metals in the diet and those which may result
in adverse human health effects. It must be insured that not only are
cropland resources protected but also that harmful contaminants are not
accumulated in the food chain.
Landfill
In order to contribute to leachate, heavy metals must
be soluble. Soluble forms may exist as cations, soluble
inorganic complexes, organic chelates and anions. The de-
composition of sludge in soil can create two conditions in
which metals are solubilized. Solubilization results from
both the formation of organic chelates and from reducing
conditions in the soil environment. Quantitative estima-
tions of the degree of movement of metals in soil are de-
pendent on a large number of complex factors. When soils
are highly aerobic and have even a low clay content, metals
will precipitate or bind to soil as a function of the soils
cation exchange ability.
Leachate containing materials can contaminate surface
waters as well as aquifers. If landfills are located in
recharge areas, contamination of aquifers is possible.
Data on the reactivity of individual metals is seen in
Table 3-17.
Incineration
Volatile Organics
Such volatile organics as pesticides and polychlorin-
ated biphenyls are known to accumulate in human and aquatic
organisms. The concentrations of these substances in
emissions from sludge incinerators will depend on the
efficiency of operation. During "normal" operations, pesti-
cides and PCBs will be destroyed in multiple - hearth and
fluidized bed incinerators. New source performance stan-
AT«.
dards for sludge incinerators >6 contained in 40 CFR 60.
3-56
-------
TABLE 3-17
REACTION OF METALS IN AQUIFERS (17)
Vanadium - occurs in cationic and anionic form. In
the cationic form, with the usual prevailing groundwater con-
ditions, the minimum solubility is about 1 ug/1. The anionic
form is slightly more soluble.
Chromium - the trivalent and hexavalent cations can
exist in groundwater at pH values of 8.0 to 9.5. The solu-
bility of the cationic species in uncontaminated water is
about 0.5 g/1. -At pH values of less than 8, the complex
cation CrOH"^ predominates. Anionic forms of chromium are
stable in groundwater, but occur as a result of contamina-
tion, not naturally, and may reach higher concentrations.
Manganese - is present in most soils and rocks and thus
finds its way into groundwater. Although manganese is not
usually a major heavy metal in sewage sludge (it could be
in an industrial sludge), leachate and plant uptake data in-
dicate that application of sludge releases manganese into
percolating water and soil solution (Braids 1975, Hinesly
1974) . The concentration of manganese is usually less than
iron. In the pH range of most groundwater, manganese occurs
as the Mn+2 ion at a concentration of as much as 1 mg/1.
Iron - is an ubiquitous component of soils, sediments,
and rocks. Its most common form in groundwater is ferrous
ion Fe+2. iron solubility is sensitive to the Eh/pH condi-
tions and it can dissolve or precipitate rapidly. Iron con-
tained in recharge water will quickly react to the condi-^
tions encountered in the groundwater. The occurrence of up
to 10 mg/1 in groundwater is common.
Cobalt - occurs in low concentrations in soils, but
in most places is taken up by plants in sufficient quantity
to meet the requirements for animal nutrition. In ground-
water, it probably occurs as the C6^2 cation. Cobalt easily
forms complexes with organic compounds, and also forms a
number of complex ions. The natural concentration amounts
to a few micrograms per liter.
Nickel - behaves much like cobalt, and occurs natur-
ally as the Ni+2 species. Generally nickel species are
more soluble than cobalt, therefore slightly more nickel
may be expected in groundwater.
Copper - solubility is limited by cupric oxide or hy-
droxy-carbonate minerals to about 64 ug/1. Copper may
3-57
-------
TABLE 3-17
REACTION OF METALS IN AQUIFERS (17),,.CONTINUED
occur in higher concentrations in acid mine drainage areas
or in highly mineralized areas.
Zinc - is seldom present in natural waters at concen-
trations which would be in equilibrium with hydroxide or ;
carbonate minerals . Waters have been found with concentra-
tions of several hundred mg/1. It is among the most con-
centrated of heavy metals in sludge, and is a primary candi-
date for a basis for limiting sludge application to land.
It could remain in solution after percolating to groundwater
to the extent of several hundred micrograms per liter.
Molybdenum - can exist in several valence states and as
polymeric hydroxide anion species. It is relatively rare in
nature and in sludges and probably seldom exceeds a few
micrograms per liter in natural groundwater.
Silver - oxide and{ chloride salts have low solubility.
Furthermore, metallic salver is stable at the usual Eh ranges
in groundwater. As a result, silver ion in solution general-
ly amounts to less than 1 ug/1. It is unlikely to reach
groundwater from land application of sludge.
Cadmium - occurs in trace amounts naturally. It is
toxic and could be a problem if sludge source contained a
large quantity . Tk aUtll U.
-------
TABLE 3-17
REACTION OF METALS IN AQUIFERS (17),,.CONTINUED
per liter. Arsenates also form complexes with hydrous iron
oxides which have very low solubilities.
Selenium - chemically resembles sulfur, but is much
less common in nature. Some soils are high in selenium and
drainage water from irrigated seleniferous soil contains as
much as 1 mg/1. It occurs in the anionic selenate S03~2
form. Selenium is a common contaminant in landfill leachate
where paper and inks are source materials. Certain indus-
trial sludges may also have relatively high selenium con-
centrations.
3-59
-------
Metals
EPA has published proposed Amendments to National
Emission Standards which would limit mercury emission from
incinerators to a maximum of 3200 grams per day (40 CFR 61).
Ocean Dumping
Criteria which restrict the concentrations of certain
constituents in materials to be dumped in the ocean were
promulgated by the U.S. EPA on October 15, 1973. (See Table
3-18) These criteria were based on the assumption that pro-
per mixing of sludge dumped into sea water will result in
l'i>>4W«.«*»>u»«3g*tl
concentrationS^wnicn will not be higher than background
levels. (Jn awwJ.WW^H slu^5* CAWn»4r
J
3.5.5 Determination of Metal Content of Sludges and
Estimation of the Impact of an Industrial Metal
Discharger on Sludge Quality
For existing systems a direct chemical analysis of POTW
sludges will establish their metal- composition. This end of
the line approach generally does not permit sewer dis-
chargers to be qualitatively or quantitatively identified.
It is, however, possible to make better than an order
oi» magnitude approximation of an industry's contribution of
metals to sludge by knowing the industrial flow rate and >.
metal concentration and by assuming a specific metal removal
efficiency of the POTW as reported by Chen, et al (13).
This approach is illustrated by Table 3-19. This sam-
ple calculation shows that a single discharger's impact on
sludge quality decreases as the size of the POTW increases.
Conversely, as the industrial discharge increases, the metal
content of the sludge increases.
Using such calculation it should be possible to deter-
mine the percentage of the total POTW sludge metals contri-
buted by individual industries. Pretreatment or a surcharge
could be employed by a municipality to remedy a situation in
which an individual contributor is significantly contaminat-
3-60
-------
TABLE 3-18
MATERIALS PROHIBITED FROM OCEAN DUMPING
IN OTHER THAN ALLOWABLE QUANTITIES (18)
Constituent
Material which may float
or remain in suspension
Mercury
Cadmium
Organohalogens (or com-
pounds which may form
organohalogens in the
marine environment)
Living organisms
Allowable level of concentration
None allowed
Solid phase less than 0.75
mg/kg - Liquid phase less than
1.5 :mg/kg
Solid phase less than 0.6
mg/kg - Liquid phase less than
3.0 mg/kg
Must not exceed:
(a) (After mixing) 0.01 of a
concentration shown to
be toxic to appropriate
sensitive marine organ-
isms as determined by an
EPA approved bioassay.
(b) 0.01 of a concentration
otherwise shown to be
detrimental to the marine
environment.
Must not:
(a) Extend range of biologi-
cal pests, viruses,
pathogens or other agents
capable of infesting, in-
fecting or altering the
normal populations of or-
ganisms.
(b) Degrade uninfacted areas.
(c) Introduce viable species
indigenous to the area.
3-61
-------
TABLE 3-19
S/VfLE CALCULATIONS SHOWING Tl€ RELATIONSHIP BEMEN P01V SIZE,
INDUSTRIAL PETAL DISCHARGES AND THE RESULTING PETAL CONTENT OF SLJJDE
Secondary Treatment Plant Size(mgd)
Sludge Generated (dry tons/day)
(Ib/day)
Industrial Discharges
(assume a metal concentration of 10 mg/1 md
.POTW sludge)
Industrial Flow
(gal/day)
10,000
50,000
100,000
4o c
0.5
0.25
500
5.0 20
2.5 10
5000 20,000
50% removal by
PPM
837
4185
8770
C0<**>
.j "Pow
FT£ ^
(metal in sludge)
84 21
419 105
840 210
vftxJG- GtrraiiA
Z7
3-62
-------
ing the POTW sludge.
3.5.6 Planning Implications for Sludge Disposal
The pollutional impact of industrial wastes on muni-
cipal sludge disposal has been discussed. Associated with
pollutional impacts are economic impacts which arise as a
result of several factors. First, industrial discharges
may increase the quantity of POTW sludge generated in a
manner which is not reflected in the industry as flow, BOD
or suspended solids contribution; e.g., a noribiddegradable,
dissolved solid. In such situations the industrial discharg-
ers are not contributing equitably to POTW sludge disposal
costs.. Second, an industrial discharger may contaminate
municipal sludges to a degree where certain disposal op-
tions .are eliminated and only more costly options are avail-
able.
Areawide management planning agencies should be cogniz-
ant of such potential economic disparities and could aid
municipalities to achieve an equitable solution. Another
planning function that would be particularly critical to
areawide sludge management has to.do with the quantity and
quality of industrial sludges generated as a result of pre-
treatment. Because of the potential toxic nature of these
sludges, disposal sites and methods will have to be care-
fully evaluated. Such techniques as secure landfill in
which liners, cover materials or chemical fixation are
employed to minimize leachate generation may have to be
adopted. Possible management procedures are listed in
Table 3-20.
3-63
-------
Table 3-20
WQMC208) AREAWIDE PLANNING - PRETREATHENT
AND MUNICIPAL SLUDGE HANAGEKEfiT
Pretreatment Sludge Issue
1. Increased POTW sludge gene-
ration as a result of indus-
trial discharges.
2. Contamination of POTW sludge
with toxicants, e.g. metals,
due to a lack of pretreat-
ment on the part of industry.
3. Generation of Industrial
sludges as a result of pre-
treatment.
(2 08) Planning and Management
Insure that industries are paying
their fair share to municipalities
for sludge disposal.
Aid municipality in setting ac-
ceptable levels of toxicants in
sludge. Amend sewer use ordinances
to contain appropriate
Management of industrial sludge
disposal practices is necessary
in order to avoid surface and
ground water pollution. An area-
wide secure landfill site should
be evaluated to minimize multiple
sludge dumping sites. Additional
management practices may include
sludge segregation for future re-
source recovery or supplementary
pollution control efforts.
3-64
-------
3.6 DETERMINATION OF PRETREATMENT REQUIREMENTS
3.6.1 Federal Pretreatment Standards
The Federal pretreatment standards have been described
and discussed in Section 1.2.4, and those already promul-
gated or proposed have been summarized in Appendix A.
These standards have been established on an industry-by-
industry basis.
At
present, most of the numerical limitations in these standards
are in terms of mass, e.g., pounds' per unit weight of product
or unit area of operation, rather than concentration
limitations. In view of the difficulties involved in the
pastor
application of mass limitations, it is likoly that EnHtfc.
^
mass ofc, concentration limitations on.
might be used in the future.
3.6.2 Local Pretreatment Requirements
Industrial water pollution problems are generally
site-specific, and industrial waste pretreatment programs
usually require a high degree of familiarity with the specific
POTW system, its contributing industries, and the particular
problems cjC^feed by their wastes. Therefore, effective
pretreatment programs will best be developed and administered
-------
at the local level, and the primary responsibilities will
be borne by either areawide or Statewide planning agencies.
In designated areas in which pretreatment problems exist,
areawide planning agencies will be responsibile for the
establishment of local pretreatment requirements and the
overall design of industrial user control programs. In
non-designated areas, where the State acts as 208 planning
agency, municipalities may play a greater role in establishing
local pretreatment requirements and the overall industrial
user control programs.
Technically speaking, the basis for establishing local
pretreatment requirements consists of the following consid-
erations :
1) Elimination of industrial pollutants which damage
wastewater collection works;
»
2) Control of industrial pollutants which interfere
with biological treatment processes;
3) Control of industrial pollutants which pass through
treatment works and adversely affect receiving
waters;
4) Control, of industrial pollutants which affect
sludge disposal.
The general guidelines and technical information have
been presented in Sections 3.2, 3.3, 3.4, and 3.5 for these
considerations. If these considerations cannot be fulfilled
by applying Federal pretreatment standards to the industrial
sewer users, then more stringent local pretreatment require-
ments may be needed to achieve the goals of industrial wastes
management. For a specific industrial pollutant, it is
conceivable that the more stringent local pretreatment
requirement may be dictated by one of the above considerations,
3-66
-------
and sample calcualtions will be shown in the next section to
illustrate the determination of limiting concentrations.
3.6.3 Sample Calculations
As indicated in Section 3.6.2, the more stringent
local pretreatment requirements may be dictated by different
considerations. In general, those industrial pollutants
which affect wastewater collection works are classified
as prohibited wastes, and are not allowed toydischarged
^
into the POTW. Therefore, the permissible concentration of
a specific pollutant in the treatment plant influent will
primarily depend on its impact upon:
1) treatment process upset;
2) pollutant pass through;
3) sludge disposal;
Different permissible influent concentrations may be
calculated for each specific pollutant of concern, and
the lowest concentration thus calculated will become the
basis for the determination of industrial pretreatment
for each industrial discharger.
This general approach is illustrated in the following
paragraphs by conducting calculations on a specific indus-
trial pollutant, copper. The treatment plant is assumed
to employ activated sludge and anaerobic digestion processes,
and the digested sludge will be disposed by land spreading.
Technical data compiled in Sections 3.2, 3.3, 3.4 and 3.5
are used in these calculations, and appropriate assumptions
are also made as needed.
Treatment Process Upsets
1. Activated Sludge Process
According to Table 3-1, the threshold concentration of
copper for activated sludge is 1 mg/1. If 26% of the incom-
3-67
-------
ing copper is removed by primary treatment, then the permis-
sible copper concentration in the influent to the treatment
plant is:
2. Anaerobic Digestion Process
According to Table 3-1, the threshold concentration of
copper for anaerobic digestion is 1.0 to 10 mg/1, suppose 5
mg/1 Cu is used for this illustrative calculation. Assume
that 6,900 gallons of primary and secondary sludges are gene-
(19)
rated per million gallons of wastewater ', and 57% of cop-
per is removed by activated sludge plants in the sludges,
then the permissible copper concentration in the influent to
the treatment plant is:
Pollutant Pass Through
If NPDES permit of the treatment plant requires a cop-
per concentration of 1 mg/1 not to be exceeded in the POTW
effluent, and 43% of incoming copper will pass through acti-
vated sludge plants (i.e., 57% removed), then the permissible
copper concentration in the influent to the treatment plant
is equal to:
2.33 mg/1 Cu = Y
Sludge Disposal
According to Section 3.5, the copper content of sludge
has been suggested not to exceed 800 ppm for satisfactory
land spreading. Assume that the digested sludge is generated
at a rate of 1,400 pounds of dry solids per million gallons
(19 )
of wastewater and 57% of copper in the wastewater is re-
moved by the activated sludge plant in the form of sludge,
3-68
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then the amount of Cu in sludge is:
dry solids 800 lbs Cu = i 12 lbs Cu
MGwastewater 1,000,000 lbs dry solids MG
The permissible copper concentration in the influent to the
treatment plant is equal to:
1 12 lb:LCu ^ 0 57 x * m?/* =0.24 mg/1 Cu= Z
H2 u'3 8.34 Ib/MG y/
As shown above, the permissible copper concentration in
the influent to the treatment plant have been calculated and
designated as W, X, Y and Z. These numerical values may be
summarized as follows:
Treatment Process Upsets:
1. Activated Sludge Process W = 1.35 mg/1 Cu
2. Anaerobic Digestion Process X = 0.06 mg/1 Cu
Pollutant Pass Through Y = 2.33 mg/1 Cu
Sludge Disposal Z = 0.24 mg/1 Cu
A comparison of these results shows that the lowest and
thus limiting concentration of copper permissible in the in-
fluent to the treatment plant is X, 0.06 mg/1, which is based
upon the toxic effect of copper to the anaerobic digestion
process. Any further consideration of pretreatment require-
ment on copper-containing industrial wastes will have to be
controlled by a permissible influent copper concentration of
0.06 mg/1.
Following the establishment of the permissible influent
concentration, the next logical question leads to the deter-
mination of the maximum concentration allowable in an indus-
trial discharge. In general, many factors to be considered
in such a determination are site-specific, including most
importantly:
1) The ratio of total wastewater discharge to the indus-
trial wastewater discharge containing the specific
pollutant;
2) The ratio of maximum to average concentration in in-
dustrial wastewater containing the specific pollutant;
3) The fraction of the influent concentration discharged
by non-industrial sources, i.e., the fraction which
cannot be controlled by industrial pretreatment.
3-69
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The information on these key factors should be obtained through
industrial waste surveys and an understanding of the specific
sewerage system receiving the industrial wastes discharge.
3.6.4 Pilot Testing
Although substantial technical data have been presented
in previous sections as a result of literature searches for the
purpose of determining pretreatment requirements, it should.,be
pointed out that pilot testing, if possible, may frequently
prove to be necessary and/or beneficial under certain circum-
stances. Primarily, the purpose of pilot testing is to remedy
the inadequacy of the technical information available in lit-
erature, a situation which is not uncommon in the field of in-
dustrial waste management.
Many factors contribute to the complex nature of in-
dustrial wastes. A large number of industries exist, and even
within the same industry different processes may be selected
for manufacturing the same product and producing distinctly
different wastes. Many constitutents of industrial wastes
may have never been found in nature, and thus may be toxic to
organisms or resistant to biochemical decomposition. Further-
more, because of technological development, a large number of
new compounds of ever-changing variety are and will be added
to the industrial waste stream yearly. On the other hand,
the sensitivity of biological treatment processes to the ef-
fects of various toxic waste constituents may be quite flex-
ible, depending on various operational conditions. For in-
stance, some toxic organic substances such as phenol and for-'
maldehyde can be almost completely removed from wastewaters
by biological treatment if the biological population respon-
sible for the treatment process have been given time to ac-
climate properly. For practical purposes, the limits of bio-
logical treatment are not predictable on general grounds, but
must be determined experimentally.
Much of the quantitative information in sections 3.3.3
VlAf
and 3.3.4 hiure been derived from laboratory experiments with
3-70
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batch and/or continuous-flow reactors, designed to study the
effects of the specific compounds or elements of concern.
While this is a convenient scheme for experimentation and the
most common source of information on toxic pollutants, extreme
care has to be undertaken in extrapolating the experimental
results from the laboratory to full-scale treatment plants.
Outlined below are some key considerations:
1) Effect of acclimation;
2) Presence or absence of other waste constituents
which may have synergistic or antagonistic effects;
3) Accuracy of the simulation of full-scale facilities
by laboratory experiments;
4) Changes in environmental conditions such as effect
of temperature on treatment performance, laboratory
experiments are frequently conducted at the conven-
ient room temperature.
Actual monitoring and testing at existing treatment faci-
lities would provide the most reliable information but, unfor-
tunately, such information is rare for the toxic effects of
industrial wastes. Furthermore, considering the complicating
factors discussed above, much caution should be used in ex-
trapolating data from one treatment plant to another. In de-
termining industrial pretreatment requirements, each POTW
should be studied by pilot testing on a case-by-case basis.
This preferred approach, however, will usually be infeasible
because of technical and/or economic constraints, so the in-
formation contained in this section can be used as general
guidelines.
As to the technical manpower needed, such pilot testing,
ideally, should be carried out by the treatment plant opera-
tors or other technical personnel of the regulatory authority
for the POTW. The pilot testing may also be conducted in con-
junction with industrial waste survey by qualified consultants,
3-71
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References
1. "Response of Activated Sludge to Step Increase in Loading",
by Joseph H. Sherrard and Alonzo W. Lawrence, Journal of
Water Pollution Control Federation, Vol. 47, No. 7, p.. 1848-
56 (July, 1975).
2. Flow Equalization, EPA Technology Transfer Seminar Publi-
cation, May, 1974.
3. Federal Guidelines (Draft), State and Local Pretreatment
Programs, Vol. 1, EPA Contract No. 68-01-2963, August, 1975.
4. "Effect of Toxic Wastes on Treatment Processes and Water-
courses", Jackson, S. and V.M. Brown, Water Pollution Con-
trol, Vol. 69, p. 292-313 (1970).
5. EPA Design Seminar for Land Treatment of Municipal Waste-
water Effluents, Design Factors, Part I, Prepared by Met-
calf & Eddy, Engineers (August, 1975).
6. EPA Design Seminar for Land Treatment of Municipal Waste-
water Effluents, Design Factors, Part II, Prepared by CH-M
Hill (September, 1975).
7. Burns & Roe, Inc., State and Local Pretreatment Programs
(Draft Federal Guidelines) , Vol. I, Report: to U. S. Environ-
mental Protection Agency Office of Water Program Operations,
by Burns & Roe,.Inc., Paramus, N.J., 1975.
8. Chen, K. Y. et al. Trace Metals In Wastewater Effluents.
Journal Water Pollution Control Federation 46 (12) : 2663-
2675. 1974.
9. Maugh, T. H. Chemical Pollutants: Polychlorinated Biphenyls
Still a Threat. Science, 1189, December 19, 1975.
10. Duse, D.J., Verth, G.D., Lee, G.F., Polychlorinated Biphenyls
in Treatment Plant Effluents, Journal Water Pollution Control
Federation, 46_(5) : 966-972. 1974.
11. Water Quality Criteria 1972. Report to the U.S. Environ-
• mental Protection Agency (EPA'R3*73-033-March 1973) by the
National Academy of Sciences. Washington, D. C. 1972.
-------
12. • Innovative Technology Study prepared for the National
Commission on Water Quality, August, 1975.
13. K.Y. Chen et al. 1974. Trace Metals In Wastewater
Effluents, JWPCF 46>(12) 2663-2675.
14. R. Ganz, C. Liebert, J. Schulze and P.S. Stensby.
Removal of Detergent Fluorescent Whitening Agents
from Wastewater, JWPCF £7 2834, 1975.
15. Farrell, J.B. Overview of Sludge Handling and Disposal,
Pretreatment and Ultimate Disposal of Wastewater
Solids Proceeding of Symposium, Rutgers University,
May, 1974.
16. R.L, Chaney. Crop and Food Chain Effects of Toxic
Elements in Sludge and Effluents, 1973 Proceeding of
the Joint Conference on Recycling Municipal Sludge
& Effluents on Land, Champaign, 111. Sponsored by EPA.
17. Environmental Impact of the Disposal of Wastewater
Residue, Vol. 2, Report to the National Commission on
Water Quality, Contract No. WQ5AC072, 1975.
18 • "TVrvJE. 40, "PAW 2.^-7 O? TME CobE OF
Mo.
19. Wastewater Engineering, Metcalf & Eddy, Inc.,
McGraw-Hill, 1972, p. 581.
3-73
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Chapter 4
CASE STUDIES
4.1 INTRODUCTION
To enhance the use of this manual, three examples of
actual ongoing industrial wastes programs are presented here.
The purpose of these case studies is to provide guidance for
establishing pretreatment programs and to highlight particu-
lar problems and issues which may be encountered. They are
chosen on the basis of geography, demography, types of indus-
tries and types of treatment facilities within the area. The
actual manual (chapters 1, 2, 3) and the case studies are
designed to be used together to provide both specific and
general guidelines for planning and managing an industrial
pretreatment program.
4.2 CASE STUDY I
4.2.1 Introduction
This case study emphasizes some of the major issues
involved in developing industrial waste programs. Although
the planning agency discussed here has not completed an
industrial waste survey, it has encountered several issues
4-1
-------
relating to pretreatment while developing its project control
plan. The descriptive sections of this study concern the
agency's overall industrial program and some completed work.
The second half is an analysis of the issues facing this agency.
4.2.2 Overview
The WQM (208) planning area is located along the east-
ern seaboard of the Continental United States. The area
includes four urban centers and 26 smaller towns. Geograph-
ically the region is a coastal plain underlain by several
moderate to high yield aquifers which supply much of the
area's water supply. Situated between an area with a high-
ly industrial economy and one with a tourism-recreation based
economy, the district has an economic base made up predomin-
antly of small industries involved with textiles, metal finish-
ing and food processing. Agricultural industries include
fishing, dairy products and fruit products.
Approximately half the population of the area is
served by sewers which discharge to three primary treatment
plants and ten secondary plants. All three primary plants
are scheduled for upgrade or are in the process of new plant
construction. Many of the secondary plants are undergoing
upgrade or regionalization. Data on the industrial contri-
butions to these treatment plants are at this time, limited.
Information that does exist includes partial industrial flow
inventories for two of the major cities along with guidelines
which provide expected pollutant loadings from various indus-
trial categories and sub-categories. Industrial waste surveys
for the remainder of the area are either in progress or in
the planning stage.
4.2.3 Presentation of WQM Pretreatment Program
Description of Overall Industrial Plan
The thrust of the planning agency's industrial wastes
program, for direct discharge as well as pretreatment, is
clearly indicated in the introduction to their plan for the
control of industrial discharge.
4-2
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"By focusing on the relationship between
pollution control and economic develop-
ment from the start, alternative methods
of meeting the standards which can be
more cost effective than traditional
end of the pipe technologies can be ^
formulated."
The three objectives of the program-are stated as (1) meeting
^•••••Mt water quality standards without transfer of toxic
pollutants to unprotected land and air, (2) keeping as many
waste materials as possible in the economic rather than the
disposal sphere through encouragement of reuse and recycle,
and (3) the recognition of the relationship between pollution
control and economic growth. At this stage of development
the program is designed to emphasize three issues: water
quality, residuals management and economic development. The
issue of pretreatment although not stated as one of these
three key elements will certainly become an important consid-
eration in each of the program tasks listed in Table 4-1.
To facilitate public participation in this program,
the WQM Areawide Planning Agency is' organizing an Industrial
Task Force which will include representatives from industry,
government and planning agencies. The purpose of such a
group is to serve as an information source for both industry
and government as well as a forum for collecting data and
for discussing the various problems faced by its members.
One issue which the task force is designed to address is
sewer use ordinances. By involving both those individuals
responsible for ordinances and those subject to ordinances,
it is believed that the task force will be more able to
effectively deal with this critical element in the pretreat-
ment issue. At this time the desired output of the industrial
wastes program is alternative, cost effective, industrial
pollution control practices emphasizing ideas such as joint
treatment, reuse/recycle and economic incentives.
Description of Key Elements
Industrial Waste Survey
The first task in the industrial program involves the
4-3
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Table 4-1
WQM (208) INDUSTRIAL WASTES PROGRAM
CONTROL OF POLLUTION FROM INDUSTRIAL SOURCES
Source of Data Base
Scope of Work
Permits, plans
and Interviews
Review of Present Status
and Anticipated Plans
for Industrial Wastes
Municipal Plans
Technologies
Reuse/Sink Alter-
natives
Analysis of Anticipated
Plans and Alternative
Waste Handling
Procedures
Industrial Survey
Analysis
Development of
Alternative Programs
for Liquid Wastes
and Residuals
Facilities Plan-
ning
Evaluation of Use and
Consequences of Programs
on Economic Growth,
Anti-Degradation Policy
and Water Quality
4-4
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collection of the industrial data necessary for the remainder
of the program to be generated. The objectives of this task
are as follows:
1. Determination of present industry practices and
proposed plans for meeting water quality standards
in the region.
2. Initial training of staff on data sources and
industry practice.
3. Establishment of potential problem areas.
4. Explanation of WQM Planning Goals to industry
and requests for cooperation.
5. Collection of data on two levels: One on
general industry and the other on specific
sites in the district.
6. Determination of additional data requirements.
Industrial data is being collected using three levels
of effort. Level One data is an inventory of industry types
and employment for each city and town within the district
utilizing the SIC code and description system. Level Two data
employs general EPA guidelines for estimating waste loads by
parameter for specific types of industries. Level Three data
includes specific company data collected for purposes of
sewage treatment plant design.
In the initial stages of this task (Level One data
collection) it became evident that five major industrial
areas existed within the district as shown in Table 4-2.
Table 4-2
SUMMARY OF LEVEL ONE DATA
25
5
" non- indu s tr i a 1 "
Major
industrial
Total No.
of Companies
towns 192
communities 763
Total
Employment
16,479
69,326
On the basis of this data and the fact that the treatment
plants serving these five areas would receive a larger portion
4-5
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of industrial inputs, the five major industrial communities
were chosen for more in-depth study. This basically involved
the generation of Level Two data for these communities. This
data includes sub-categorization of the industries listed in
the Level One, wastewater characteristics (general guidelines),
treatment alternatives, in some cases BPT* effluent limitations
and an assessment of whether a particular category generates
a significant waste load. In addition, Level Two includes
a listing of those industries under NPDES permits for direct
discharge. Finally, in progress is the collection of water
consumption data for the industries in the five industrial
areas.
The expected result of this study is a Pollutant Profile
which will prove useful as a display mechanism to show general
areas where particular concentrations of industrial pollutants
are generated. This will in turn aid the planners in develop-
ing the remainder of the program.
From the currently completed Level Two data, several
decisions concerning the generation of Level Three data have
been made. First, four communities have been initially chosen
for the Level Three effort. Secondly, only those categories
which generate significant waste streams will be surveyed.
At this time, Level Three data has been collected, in part,
only for two cities and is summarized in Table 4-3 and Table
4-4.'
As the data collection process for this task proceeds,
additional data requirements are being determined. Conversely,
certain areas have been chosen for a more limited effort
(Level Two as opposed to Level Three). Thus the outline for
the industrial waste survey is extremely flexible and under-
goes continual change although the overall goals remain.
Treatment Plant Inventory
One of the major outputs of an industrial pretreat-
ment program is the assessment of potential treatment plant
* BPT = Best Practicable Control Technology Currently Available
4-6
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Table 4-3
SUMMARY OF INDUSTRIAL SURVEY: CltY A
SIC
22.
28.
30.
31.
34-39.
Number of
Description Companies
Textile Mill Products 2
Chemical and Allied Products 2
Rubber and Miscellaneous
Plastic Products 1
Leather and Leather Products 1
Miscellaneous Metal Products 16
Total Waste Flow
Gallons/Day (g/d)
1,153,500
145,177
4,500
7,120
197,700
1,508,000
Table 4-4
SUMMARY OF INDUSTRIAL SURVEY: CITY B
SIC
20.
22.
28.
30.
34-39.
72.
Description
Food and Kindred Products
Textile Mill Products
Chemical and Allied Products
Rubber and Miscellaneous
Plastic Products
Miscellaneous Metal Products
Total Manufacturing
Laundries
Car Washes
Total Service
Total Manufacturing
and Service
(or at 275 days/yr : 3
Companies
2
16
1
3
11
14
7
. 5MGD )
Million Gallons/
Year (MG/yr)
95.3
632.4
43.8
23.8
99.6
894.7
48.9
7.6
56.5
951.2
4-7
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upsets caused by industrial discharges. For that purpose
part of the required data base is obviously an inventory of
treatment facilities. In fact, the 208 Project Control Plan
indicates the treatment plant inventory as part of the
required data based for the completion of the industrial
wastes program.
The district includes ten secondary treatment plants
and three primary plants. As shown in Table 4-5, the larger
facilities are operating at capacity or above design flow.
There are two new plants under construction, five plants
proposed for upgrade or new facilities and one upgrade under
design. Most of the secondary plants utilize extended
aeration or trickling filters as their treatment process with
one plant utilizing biological stabilization ponds. Sludge
disposal runs the gamut of possible disposal practices from
incineration to land treatment on farm land.
Several insufficiencies in treatment plant operation
and maintenance have been indicated in the report. First
of all, although all municipalities involved have adopted
sewer use ordinances, few if any are enforced. In addition,,
many of the treatment plants do not have adequate monitoring
facilities compounding this enforcement problem.
4.2.4 Pretreatment Issues - Analysis of Specific Issues and
Program Elements
Economic Impact of Pretreatment
Even before the inception of PL 92-500 the high cost
of environmental protection was generally recognized. The
law itself addresses this fact by placing part of the public
sector economic burden on the Federal Government. The law
does clearly place the economic burden of industrial waste
treatment on the industries themselves (PL 92-500 Sec. 204).
4-8
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Table 4-5
SUMMARY OF AREA TREATMENT FACILITIES
. 1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
TOTALS
S
S
S
S
P
P
S
S
S
S
P
S
S
Design
Cap. MGD
2.8
. 1.4
1.0
.75
4.7
16.0
1.8
2.0
2.1
.58 ___
30.0
1.75
1.7
66.6
Average
Flow MGD
4.0
2.4
1.2
.80
5.6
22.0
.6
.7
.9
.3.3._.
30.0
1.6
.26
70.4
Future Considerations
New plant proposed
Upgrade proposed
Regional plant proposed
New plant under const.
New plant under const.
Upgrade under design
Regionalization proposed
Upgrade proposed
S = Secondary Plant
P = Primary Plant
4-9
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The planning area in question is not a heavily
industrialized area.* Neither does it base its economy on
tourism and recreation. Lying between these two extremes
its economy is based on small industries centralized in
five "industrial" areas. The major industries are textiles,
metal finishing and food processing, which includes seafood,
dairy products and fruit products. Relatively smaller finan-
cial benefits are gained from the fresh fish industry, dairy
farming and fruit farming. Except for a small percentage of
large industrial plants which are direct dischargers (113
permits) most units are small plants discharging to sewers.
With respect to the minimum pretreatment standards
promulgated by the federal Government, the food processing
industries (dairy products, canned and preserved seafood)
do not face stringent limitations for existing sources.
New sources under the Dairy Products category face no limita-
tions on compatible pollutants while those sources under the
canned and preserved seafood category will be subject only to
general regulations. Standards for existing textile sources
are only proposed at this time and indicate limitations on
COD, Chromium, Phenol, Sulfides and pH depending on the
industrial subcategory. For the metal finishing industries
(electroplating) existing pretreatment source standards are.
only proposed while new source standards are in effect, both
indicating stringent limitations on a variety of metal dis-
charges. The point of this information is that the economic
impact of pretreatment is relative to the industry being
considered. Metal finishers and platers in this case appear
to face a high cost of pretreatment while food processors,
especially existing sources, face little economic burden.
The cost to the textile industry lies between the other two
categories.
Because the area has not been economically stable in
recent years, the planning agency recognizes the importance
in relation to a nearby major metropolitan center (pop.
4-10
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of economic considerations in dealing with pretreatment by
placing great importance on economic impacts, incentives and
alternatives. In fact, one program task is an assessment of
the impact of their total industrial program, including pre-
Sr •
treatment, on economic growth in the area. However, compound-
ing the problem of the economic impact of pretreatment are the
added problems of increasing costs of energy and labor. In
its program the agency is attempting not^only to minimize the
negative impacts of pretreatment but also, to develop alterna-
tives that create incentives to industries.
In light of this point of view, the agency is assessing
ideas such as joint treatment and reuse/recycle as well as
developing a high degree of industrial participation. Other
programs such as industries combining to treat and remove
prohibited wastes will be economically and environmentally
assessed. Additional programs(see Section 2.5) can be added
to aid in this task. First of all, those industries most
severely affected by pretreatment regulations should be iden-
tified. This task should be followed by actual site visits.
Guidance should be provided to these industries on pollution
control techniques, capital investments and process changes.
In this way the Agency can not only provide technical assist-
ance but also validate claims of severe economic impacts,
This particular planning agency is under pressure to
adopt a policy which will not inhibit economic growth in its
district. This fact is reflected in its non-aggressive
attitude toward ordinances and enforcement. However, by not
enforcing ordinances and user charges, the municipalities in
the area are allowing the public sector to pay for the treat-
ment of industrial wastes. The planning agency, being cogni-
zant of this inequity, should develop a program that provides
equitable payment schedules under the law.
In assessing the economic impact of pretreatment care
must be taken to insure that the priorities of a 208 agency
be kept in focus. According to Section 101(a)(5) of PL 92-500
4-11
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"It is the national policy that areawide
waste treatment management planning processes
be developed and, implemented to assure
adequate control of sources of pollutants
in each State."
The mandate is clearly one of environmental protection.
A WQM (208) planner must certainly consider economic issues
but not at the expense of required environmental quality. It
is the job of a planner to balance properly these sometimes
opposing issues.
Planning for Residuals Management
The recent emphasis on "environmentally safe" residuals
disposal practices has evolved from a developing understanding
of the short and long term impacts of hazardous waste materials
The problem becomes an element in the pretreatment issue when
considering the possibility that the enforcement of industrial
pretreatment standards will result in increased generation of
industrial sludges and expand the options for disposal of
POTW sludge. In the case where pretreatment standards are
not enforced the problem is transferred to the generation
and disposal of POTW sludges.
The major contributors of toxic materials in this 208.
planning area are the metal plating and finishing industries.
Of particular importance are jewelry manufacturers (precious
metal finishers) many of which are direct dischargers. How-
ever, may of the smaller electroplating, aluminum finishing
and general metal finishing companies are sewer dischargers.
The current sludge disposal method involves long distance
transport to hazardous waste landfills. Table 4-6 provides
a listing of the most important hazardous wastes
and pollutants associated with metal finishing
industries.
The residual problem has been recently highlighted at
several industrial meetings held in conjunction with the
industrial wastes program. The major issues discussed in-
clude quantities generated, disposal practices and recovery
4-12
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Table 4-6
WASTE MATERIALS FROM METAL PLATING AND FINISHING
INDUSTRIES WHICH CAN CONTAMINATE SLUDGES
Mineral Acids Chromate
Alkali Heavy Metals
Chlorinated Solvents Cyanide
Hydrocarbon Solvents Grease
opportunities. The Project Control Plan deals with the problem
of industrial residuals in several tasks. First, information
concerning residual production and disposal will be collected
as part of the necessary data to evaluate current industry
plans and possible alternatives. A second program addresses
several aspects of the issue in terms of alternative solutions
to the disposal problem by identifying general opportunities
for recycling, evaluating the feasibility of joint treatment
and examining the option of creating a hazardous waste land-
fill.
An additional aspect of the residuals issue which must
be addressed is the impact of pretreatment on the quality
and quantity of sludge generation at the POTW. There are two
distinct situations which can be encountered.
i - limited or no industrial pretreatment
Since many industrial toxics are known to be associated
with suspended solids, the settling processes involved in
primary and secondary treatment will separate much of the
hazardous material from the liquid portion of sewage (see
Section 3.5). This will result in a sludge with some indus-
trial characteristics (see Figure 3-1). The degree to which
the POTW sludge is "industrial" will depend on Jthe level of
input of industrial process wastewater and the degree to which
industrial pollutants pass through the plant. This is depen-
dent on the type of material and the relative efficiency of
a particular POTW.
4-13
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Because of the addition of these toxics to domestic
sludge, disposal by ocean dumping, land filling and land-
spreading may no longer be options for consideration. The
possibility of incineration will be limited depending on the
level of metal emissions (such as mercury) expected. In
cases where the "industrial" characteristics of the sludge
are dominant a hazardous waste landfill may become the only
disposal option.
ii - substantial industrial pretreatment
The biological treatment systems utilized in most
secondary treatment plants are susceptible to upset by many
organic and inorganic compounds (see Chapter 3). Both
Federal and local pretreatment requirements are developed to
protect treatment plants from this type of industry-related
upset.
A secondary impact of enforced pretreatment requirer
ments is the protection of POTW sludge from contamination
by industrial wastes. In this case POTW sludge has primarily
domestic (compatible) characteristics. In terms of the
environmental impacts of toxic substances many options for
disposal are available.
In the case where limited or no pretreatment exists,
the direct impact is to limit the disposal options to one
of the most expensive choices: a hazardous waste landfill.
Other residuals options, such as resource recovery,
should be assessed from a cost-benefit point of view. This
analysis can include consideration of a program in which
several industries combine their waste streams for treatment
and materials recovery.
It should be clear that the issue of residuals genera-
4-14
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tion and disposal is not unique to this area. There are many
industries besides metal plating and finishing that generate
considerable quantities of hazardous materials. In effect,
most agencies will face this issue to some degree. Therefore,
the possible alternatives, summarized in Table 4-7 could be
considered by many different agencies.
Table 4-7
ALTERNATIVE PRACTICES AND MAJOR CONSIDERATIONS
IN RESIDUALS MANAGEMENT
Major Considerations
- Environmental Impact
- Cost vs. Benefit
- Quality and Quantity of Residuals Generated
Disposal Options
- Ocean Disposal
- Landspreading
- Sanitary Landfill
- Hazardous Waste Landfill
- Incineration
Alternate Management Options
- Materials Recovery
As with other issues, the 208 role in planning for
residuals management must be aggressive. One reason is to
insure that industry contributes its fair share to the cost
of POTW sludge disposal (i). Also, by maintaining the domes-
tic characteristics of POTW sludge the possible disposal op-
tions can include the more useful alternatives such as land-
spreading, land reclamation and direct recycling of sludge.
Ordinance Development, Enforcement and Monitoring
One of the most critical elements in any pretreatment
program is the development and enforcement of an effective
sewer use ordinance. The ordinance provides the means, on a
4-15
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municipal level, for the protection of sewers, POTWs and
local water quality and for the control of waste inputs into
the local sewage system (see Section 2.4.5). The role of an
areawide planner in this issue is dictated by the status of
other areawide plans, the level of responsibility accepted by
State and local governments and the Agency's own view of its
responsibility. .
l£l£K*itq/
For this WQM (208). Agency the ordinance issue has not
fully developed, although several aspects have been encountered.
All thirteen municipalities with treatment plants have adopted
ordinances based upon the model suggested by the State although
enforcement of these ordinances is almost non-existent. . Com-
pounding the issue is the fact that many of the area'sjpnfl
plans are complete and include suggested ordinances within
their respective POTW discharge permits. Tne^JjjjaK1 views
its role as one of review and coordination of existing mun-
icipal ordinances and suggested 201 ordinances. This some-
what passive attitude toward ordinances has resulted from
the assumptions that: 1) development of ordinance's is a 201
responsibility, and 2) development of enforcement practices
is solely a municipal responsibility. To resolve these problems
several sections of the manual provide guidance. The above
mentioned Section 2.4.5 is a review of important control
elements in ordinances, Section 2.3.5 suggests ideas for the
development of an ordinance and Appendix C provides a sample
ordinance compiled by the California Water Pollution Control
Association.
An adopted ordinance can only be effective if it is
backed by an operative enforcement and monitoring program.
The area's problem relating to this issue is twofold. At
a recent meeting with the 208 staff it was indicated that
the local municipalities did not take an active attitude
toward enforcement of ordinances. This fact is due in part
to the lack of adequate laboratory facilities in the area
and the added expense of an extensive monitoring program.
For its industrial pretreatment program to become fully
4-16
-------
developed a 208 Agency must take an active role in the ordi-
nance issue. This role should consist of providing guidance
to municipalities on developing effective ordinances, coordin-
ating with 201 planners on review of suggested ordinances,
suggesting strong enforcement procedures (see Section 2.4)
and advising other agencies on monitoring or implementing a
monitoring program themselves.
Coordination of WQM Plans and 201 Plans
In the above discussion an overlap is indicated between
201 facilities plans and Areawide WQM plans concerning the
development of ordinances. This particular problem arose be-
cause several 201 plans containing ordinaces preceeded the
WQM plan. The WQM Agency's minimum responsibility in this
case is to review the ordinance and if it is found to be
deficient to conduct a joint review between 201 and WQM staff
members. The arbitrator in such a review is normally the
Regional EPA Administrator.
This is but one case in.which a possible conflict
could arise between the major ongoing EPA planning programs:
WQM and 201. For this reason the responsibilities of each
must be clearly understood by the Areawide WQM planner.
State Water Quality Management plans constitute the overall
water quality framework within which Areawide Water Quality
Management plans are developed for particular portions of
water bodies, specifically in industrialized areas. A
further discussion of these plans is found in Chapter 1.2.2.
Generation and Use of IWS
The industrial waste survey is the core of the data
base utilized in developing a pretreatment program (see Section
2.3.2). To generate their IWS this Agency has chosen a three
step procedure (see Section 4.2.3) identifying those areas
where, in their judgement, major emphasis should be placed.
For these chosen areas or municipalities an on-site industrial
waste survey is performed. To a large degree the agency is
utilizing literature surveys, general guidelines and water
4-17
-------
consumption data to estimate waste loadings from particular
industries and plants. In quantifying waste loads for the
purpose of developing ordinances and user charges the highest
loading values provided in the estimates should be used, if
for no other reason than to provide for adequate- margin of
safety for POTW operation. In this way industries will have
an incentive to self-monitor. The data generated by indus-
trial self-monitoring would be used to present their case
for the reduction of pretreatment
This approach certainly reduces costs and time necessary
for generating a data base for an industrial wastes program.
In the final analysis this data should be adequate to develop
the following pretreatment program elements :
1) Quantity and quality of industrial waste inputs;
2) Locations of maximum industrial inputs;
3) Ordinances;
4) User charges;
5) Impact on POTW sludge quantity and quality.
Public Participation
This case study provides a good example of how a 208 pUu*
Agency can generate industrial participation in their pre-
treatment program. As part of their industrial wastes pro-
gram several meetings were organized between the 208 staff,
consultants and local industrialists. These meetings resulted
in worthwhile two-way exchanges of ideas, problems and poten-
tial solutions. In addition, it allowed the 208J Agency to
/\
carefully explain their position to industry. However, more
participation from municipal officials is needed to under-
stand all points of view. Continuation of this program with
added municipal participation, will greatly enhance the devel-
opment of the Industrial Waste Program.
4.3 CASE STUDY II
4.3.1 Introduction
This case study provides two examples of the develop-
4-18
-------
ment of the more technically based aspects of an industrial
pretreatment program on a local level. The major program
elements delineated include the generation and use of an
Industrial Waste Survey, development of a comprehensive and
enforceable sewer use ordinance and the establishment of
equitable cost recovery. Unlike Case Study I, which provided
only insights into some of the major pretreatment issues,
Case Study II provides methodologies and techniques for
developing the above mentioned elements. Background informa-
tion on this particular area and its industrial program is
also provided for reference.
4.3.2 Overview
The 208 area is located in the northern United States
and includes one of the major urban-industrial cities
contiguous to the Great Lakes. Population is centralized in
the one major urban area and four smaller urban and suburban
centers. The region's economy is greatly dependent on man-
ufacturing with lesser importance on wholesale trade and
services. Minor economic benefits are gained from contract
construction, transportation, public utilities and finance.
Agricultural and mining activities are very limited, as shown
in Table 4-8.
Table 4-8
EMPLOYMENT CHARACTERISTICS OF
208 AREA
Indus try % of Total Employment
agricultural <1
mining <1
contract construction 4
manufacturing 42
transportation and public
utilities 6
wholesale trade 18
finance, insurance etc. 5
services 16
4-19
-------
Many of the area's major industries are currently
direct dischargers; however, the number of water quality
limited segments in the region may severely limit future
direct dischargers as well as provide an incentive for indus-
tries to discharge to sewers. In view of these facts pre-
treatment must eventually become an important consideration
for WQM (208) planners.
4.3.3 Description of Major Program Elements, City A
The first example is the industrial program currently
under consideration for the major urban center in the area.
Industrial contributions to the treatment system amount to
14% of the average daily flow. The new treatment facility
will consist of secondary biological treatment.
Industrial Waste Survey
The first step needed to comply with the requirements
mentioned in Section 4.3.2 is an industrial waste survey.
The simplest and least expensive method of accomplishing this
task is to utilize water consumption data, literature reviews
on industrial wastes and sewage to water ratios (in-product
retention percentages) to develop estimates on expected
industrial waste loads to a particular sewarage system. Con-
versely, the most intensive method involves actual site visits
and on-site sampling and flow measurements. The choice of
one or the other should be based on economics and the extent
of industrial contributions to the system. The municipality
in question has chosen to conduct its survey using the more
intensive method.
The first step was to compile an initial list of 1600
4-20
-------
industries. Questionnaires were sent to 564 of these which
resulted in 350 industries being chosen for the sampling pro-
gram. These were chosen on the basis of their being a major
contributing industry (see p. 1-10j or their expected dis- \
charges of incompatible pollutants. Next, a four phase
sampling program was instituted which included:
• in-plant investigations
scheduling of industries for sampling
sampling and analysis of the waste
•• reporting
Where access was available, flow measurements were
made using standard apparatus such as weirs, flumes and stage-
flow recorders. Water consumption data was used where direct
flow measurements were not feasible. Water meter readings
provided the raw data to which allowances were made for in-
product retention of water and sanitary discharge. When
actual flow data was obtained, water meter readings were
used to. estimate actual in-product retention and losses.
First stage sampling involved daily collection from
85 industries. Analyses were performed immediately except
BOD's which were prepared twice a week. To eliminate errors
as to the origin of each sample and the analyses required,
each sample was labeled with a code number and date which
provided cross reference to a field data sheet, preliminary
analysis sheet and industrial waste map atlas. All samples
were analyzed for BOD, TSS, PO. and chlorine demand. Based
on the results of the initial surveys and the type of indus-
trial process, forty-five industries were chosen for heavy
metals analysis.
The results of the data collection effort were sub-
mitted monthly in a three-phase format over the two-year
project period. First, a section was provided that described
general information concerning plant operations and sampling
procedures. The second section discussed whether or not the
results of that month's analysis indicated the need for
.
additional or updated surcharges. Three possible surcharge
4-21
-------
situations were considered. Existing surcharges on TSS and
chlorine demand were reviewed as to the necessity for update
or the establishment of new surcharges using the current
formula. Also, industries that would require new surcharges
on the basis of TSS, BOD and PO, under secondary treatment
were indicated. Table 4-9 is a partial listing of the indus-
tries sampled and the results of the surcharge review.
The final section of the monthly reports indicated
those industries which either were in violation of the existing
ordinance or would be in violation of the proposed ordinance.
Violations were based on discharges of grease and oil, toxics
and miscellaneous materials such as solids, pH, phenol, cyanide,
and prohibited debris as shown in Table 4-10.
At this time the second stage collection effort is
continuing with an additional 79 industries scheduled for
sampling. However, even at the initial stage the survey
data was utilized for the development of both ordinances and
cost recovery formulae. ••
The local municipality's consultants have provided two
additional data listings that are important for developing a
comprehensive pretreatment program. The first listing, shown
on Table 4-11, is a summary, by industry, of the sampling
procedures used. The second is the partial results of the
heavy metal analyses performed on 45 specified industries.
The listing shown in Table 4-12 provides heavy metals quanti-
fication in concentration and loading terms.
Sewer Use Ordinance
Since the existing primary treatment facility is pro-
posed to be upgraded to secondary treatment, the current
sewer use ordinance required updating to prevent damage to
the more complex systems. In general, the suggested ordinance
is similar to the California Model Ordinance provided in
Appendix C. The key sections of the ordinance considered here
include an expanded prohibited waste list, a separate article
covering industrial discharges, an enforcement program
4-22
-------
Table 4-9
SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
SUMMARY OF INDUSTRIAL SURCHARGES*
SIC
Industry Cat.
i
3322
ABC Co.
&j?e a:**. 2865
Company f- 7218
Cw^f> a*vy 6 3443
i
Coy»f«»y H 2021
Z<$JCo. 2011
Cowpa>\y K 2649
L-M-N,33«c. 2026
Cov*fav\y O 3471
CovMfwvy P 3269
CoWpCfttV Q* 8062
/. rt . 7TO«;
CoYvponV rs . /OJD
Cov»»j>ahy S 7210
New Surcharges to be Assessed
Under Present System
T.S.S.
X
X
X
X
•
X
X
X
C\2
X
X
X
Surcharges to be Levied
Under Secondary Treatment
D.O.D.
X
X
X
X
*
X
T.S,S.
X
X
X
X
X
X
X
P04
X
X
X
X
X
Previous Surcharg
To be Updated
T.S.S.
X
X
X
X
C12
X
X
X
X
I
to
X
*
new surcharge or updated surcharge required for that parameter
-------
Table 4-10
SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
Industry
Company A
CowpMiiy 8
C^D,3><"
Company 0
6,P,*&C».
H Prt>
-------
Table 4-11
SEWER AUTHORITY
INDUSTRIAL WASTE SURVEY
SAMPLING SUMMARY*
Industry
ABC Co.
D*e,l>»c.
Co*»f**y ¥•
Co^fOKy G
Ccw*fa*yH
X^JCo.
CowpavyK
L-M-N.3>c.
Sample Point t
1
2
1
2
3
4
5
1
1
2
3
4
S
1
2
3
4
5
1
1
1
2
Number of
Sample Days
2
2
8
S
5
3
4
3
3
3
3
3
3
3
4
3
3
3
3
3
2
2
Com posit ing
Time/Hours
8
8
24
24
24/b
8
24
B
24
24
24
24
24
24
24
24
24
24
8
8
8
8
Normal Work
liny/Hours
8
8
24
24
24/8
8
24
8
24
24
24
24
24
24
24
24
2-1
24
8
8
8
a
Type ol
I'low Measurement
Water Meter
Water Meter
Flow Meter at
Pretreatment
Plant
I'lourldt: Iniector
Water Motor
Water Meter
Water Meter
Water Meter
Water Meter
Wiiter Meter
Water Meter
W iter Meter
90° V-notch Wclr
90° V-notch Wf|r
Water Meter
Water Meter
Watt:r Meter
Wiiter Meter
Water Meter
W iter Meter
Water Meter
Water Meter
Type of
Sample Collected
AC Comp. Sampler
.-'C Comp. Sampler
AC Comp. Sampler
AC Comp. Sampler
AC Comp. Sampler
Hand Composite
AC Comp. Sampler
AC Comp. Sampler
DC Come. Sampler
DC Comp. Snim.li.-r
DC.' Com p. Sampler
AC Comp. Sampler
DC Prop. Sampler
DC Comn. Sampler
DC Comp. S.unult-r
UC Comp. Sampler
DC Comp. Sampler
DC Comp. Sampler
AC Comp. Sampler
AC Comp. Sampler
AC Comp. Sampler
AC Comp. Samplei
Point of
Access
Vent
Clean-out
Effluent Chamber
City M.H.
Plant Sewer
City M.H.
Plant Sewer
Settling Sump
Plant Sewer
Plant Sewer
Plant Sewer
Vent
City Sewer
Cilv Sewer
Plant Sewer
Plant Sewer
Plant Sewer
Plant Sewer
Clean-out
Grease Trap
Vent
Vent
I .
tvj
Ul
Hawes are
-------
SEWER AUTHORITY INDUSTRIAL WASTE SURVEY
HEAVY METAL LOADING FROM MAJOR CONTRIBUTING INDUSTRIES
SAMPLED DURING PHASE II PROGRAM*
SIC
CATEGORY
AVG. DAILY
FLOW MGO
Cr TOTAL
Cr HEX
eb NI
S] T3
^* cu
o
< As
U1
fC
8 CD
H
6 I'b
0.
o „,,
It
Ul
< Zn
i
Ke
MN
fee. Walter Co.
2649
O.OS7
0.642
0.305
43.374
20.630
J
up
*
o
26S3
0.068
0.0240
0.0138
.000399
4.906
z.noo
J
1
27S1
0.014
0.1918
0.0231
.000400
.000048
.2764
.0334
5.370
0.-627 ••
d
o
y.
2761
0.1715
0.049C
0.0710
0.0576
O.OB24
. UO-IM
.0(169
1.622
2.320
tf
1
$
{A
2834
0.073
0.0890
O.OS41
0.404
0.246
N
f
2851
0.036
.227
.066
21.331
6.39
.040
7D"I7
O*
T
a
«
O
286S
1.784
0.333
S.S10
2.333
38.600
0.375
6.200
0.683
11.30
0.279
4.620
X
f
3231
0.093
O.Q53
0.041
0.074
O.S75
.000386
9.762
7.580
>•
3269
0.103
10.675
9. 170
0.731
0.628
d
1
£
3312
0.376
0.101
0.314
0.081
0.251
1.456
4.530
i
4
^T
t,
3312
0.066
.0500
.0275
0.020
0.011
0.2440
0.1345
i
1
331S
0.178
411.648
611.200
295.583
438.800
5.524
8.200
86. 156
127.900
3.637
5.400
0.2-13
0.360
6.332
9.400
11.317
1C. 800
2375.178
3526.000
60.221
89.400
>
t
I
3316
0.220
.0190
.0359
0.241
0.443
1
3321
0.099
0.041
0.034
0,098
0.081
0,119
0.098
6.782
5.600
0.12!
0. 100
I
NJ
a\
Ore.
-------
utilizing industrial permits and concentration limits on
toxic substances. These limits were based on the prevention
of both upset to the secondary plant and pass-through of toxics
The prohibited wastes list contains several interesting
elements. One is an "anti-dilution" clause which states that
there shall be no discharge of ...
"Any waters added for the purpose of diluting
wastes which would otherwise exceed applicable
maximum concentration limits."
The limited discharge list not only includes heavy
metals such as lead, chromium and copper but also a 50mg/£
limit.on grease and oil, a .05mg/£ limit on phenol and a
lmg/£ limit on cyanide. The reader should realize that the
values listed in Table 4-13 were derived for this particular
system and cannot be arbitrarily used in any area.
Table 4-13
METALS DISCHARGE CONCENTRATION LIMITS
Chromium
Chromium
Chromium
Copper
Zinc
Nickel
Cadmium
Arsenic
Barium
Lead
Manganese
Silver
Boron
Mercury
Selenium
(Total)
(Trivalent)
(Hexavalent)
Discharge Limit, mg/£
3.0
1.0
1.0
1.0
5.0
1.0
1.0
0.5
1.0
0.1
1.0
0.05
1.0
0.01
0.05
A method for estimating these limits is described in Chapter
3.6.3 of this manual.
The surcharge limits are also set in the ordinance as
follows:
BODs - 250 ppm
TSS - 250 ppm
Phosphorus - 5.0 ppm
4-27
-------
These are based on the estimated quality of local domestic
sewage.
This particular ordinance sets up its own enforcement
mechanism in the form of a Permit for Industrial Wastewater
Discharge (see pp. 2-50 and 2-53 of this manual). The permit
may specify pretreatment requirements, flow restrictions,
points of discharge, time restrictions and payment schedules.
It is required by all non-domestic users and specifies that
incompatible pollutant pretreatment requirements for major
contributing industries shall be the Federal pretreatment
rjulntiono .. - . For compatible
pollutants, surcharges are to be instituted based on the
aforementioned limits. This method allows each industry to
make the financial decision whether to reduce their discharge
of "compatible" pollutants or pay a surcharge fee.
The final section of the ordinance deals with sampling
and monitflg^ng. The responsibility for monitoring is clearly
placed on the discharger either directly or financially if
the local municipality performs the task.
The basis of an equitable uj system is the
fact that each user of the treatment works pays toa>» share
of both the capital and operations and maintenance costs.
Users of the system are categorized as (1) domestic and (2)
commercial and industrial. Charges to y>sne users are made
on the basis of flow. ; Industrial useis present
a special problem in that charges must be made on the basis
of not only flow but also surcharges for compatible pollutant
discharges greater than a standard domestic loading. In some
cases, charges can also be levied for incompatible pollutants.
For the purposes of this manual only local industrial
(for capital and~0~VM costs) is to be considered
here. The basic industrial cost recovery charge includes
is A» feomftv4«v t^cos^OM dF *M E**nfWPCE LOCAL
-------
three components as shown in the following formula:
INDUSTRIAL SEWAGE TREATMENT CHARGE = DOMESTIC RATE +
PROPERTY RATE + SURCHARGE
When considering pretreatment the important component
in the above formula is the surcharge which makes the formula
generally applicable to all industries. If an industry dis-
charges only domestic strength waste, this term drops out
and the treatment charge becomes that of an ordinary domestic
user.
For the municipality in question here surcharges are
&
to be based on three design paranyters of the new treatment
facility: BOD, Suspended Solids and PO.. The domestic
limits were set on the basis of normal domestic strength
wastewater. Thus the surcharge requires industry to pay for
any discharges above these limits.
4.3.4 Description of Major Program Elements, City B
Overview
The second largest municipality in this particular
planning area is somewhat unique in that industrial sources
contribute 50% of the average wastewater flow. This is re-
flected in the fact that the population equivalent based on
the flow of wastewater is over 250,000 while the actual city
population is 86,000. In addition, the city's wastewater
stream contains high concentrations of toxic materials and
metals discharged by local chemical manufacturers. These
factors led to an initial conclusion that the operation of
a biological treatment system would not be feasible.
Industrial Waste Survey
During the preliminary phases of this program it be-
came clear that its successful completion would depend on the
cooperation of all groups involved, especially industries.
For this reason, after preliminary site visits and the collec-
tion of data from industry questionnaires, the municipality's
4-29
-------
consultant allowed each industry to sample its own waste
stream. The industries subsequently paid for analyses per-
formed under the supervision of the consultant. A summary
of the results of that survey are shown in Table 4-14.
Table 4-14
INDUSTRIAL DISCHARGE (1970), CITY B
Contaminated
Industrial Discharge
To municipal sewers
To diversion sewers
TO river
TOTALS
Flow
(MGD)
62.5
30
71
163.5
Suspended
Solids
(LB/Day)
190,000
17,000
67,000
274,000
Chemical Oxygen
Demand (COD)
(LB/Day)
136,000
2,000
104,000
242,000
Several important conclusions were drawn from the
results of this initial survey. The fact that a biological
system would not be feasible for the treatment of the quantity
of industrial waste being discharged was confirmed. The
municipality and its consultant concluded that a physico-
chemical facility would be the most reasonable alternative.
The.industries involved agreed to substantially reduce their
volume of wastewater discharged to sewers by process adjust-
ments and the separation of non-contact cooling waters. The
preliminary design values for flow, suspended solids and COD
were derived based on the industrial waste survey and are
shown in Table 4-15.
It is interesting to note that for the purpose of design-
ing this particular facility contributions from commercial
and industrial dischargers were separated. In effect, this
indicates the compatible nature of commercial discharges with
respect to physico-chemical treatment.
The choice to utilize physico-chemical treatment has
two interesting effects on the pretreatment issue. First of
all, the Federal pretreatment standards (40CFR128, 40CFR403-
4-30
-------
432), promulgated on the basis of secondary biological treat-
ment cannot directly apply. Secondly, the local sewer use
ordinance must be somewhat different than those previously
described in this manual.
Table 4-15
AVERAGE DAILY FLOW AND LOADINGS USED FOR
THE DESIGN OF CITY B TREATMENT PLANT (1990)
Domestic & Commercial
Infiltration
Industrial
TOTALS
Flow
(MGD)
11.2
10.6
26.0
47.8
Suspended
Solids
(LB/Day)
35,340
—
59,750
95,090
Chemical Oxygen
Demand (COD)
(LB/Day)
70,760
—
64,560
135,320
Sewer Use Ordinance
The operation and maintenance of a physico-chemical
treatment plant required a sewer use ordinance substantially
different in content than the standard ordinance covering
biological treatment facilities. Of critical importance in
this ordinance is the definition of compatible pollutants.
The following list defines those pollutants which are to be
considered compatible for the physico-chemical facility.
4-31
-------
Table 4-16
COMPATIBLE POLLUTANTS FOR CITY B TREATMENT
FACILITY AS DEFINED IN THE SEWER USE ORDINANCE
1. Chemical Oxygen Demand 8. Cadmium
2. Total Suspended Solids 9. Zinc
3. Acids and Alkalies within 10. Lead
acceptable .PH limits u> Fecal Coliform
4. Phenols
12> TQtal Nitrogen
5. Phosphates - all forms ^ Settleable Solids (Grit/
6. Nickel Screenings and Particulates)
7. Copper 14. Oil and Grease (in non-
excessive amounts)
As in the Federal regulations, the ordinance defines incom-
patible pollutants as any pollutant which is not compatible.
The ordinance also states that the above pollutants cannot
be discharged in amounts that are not amenable to treatment
by the facility.
The ordinance's enforcement mechanism contains two
major elements. First, each industrial contributor is re-
quired to enter into industrial discharge agreements with the
local municipality. These agreements define the industry's
waste stream in terms of flow, suspended solids loading and
COD loadings. Non-compliance with its agreement requires
the industry to pre treat. The second element involves mon-
itoring. Each industrial contributor is required to construct,
operate and maintain its own sampling and monitoring system.
The financial burden for these activities is placed directly
on the discharger.
4.4 CASE STUDY III
4.4.1 Introduction
The broad spectrum of responsibilities that the WQM
planning process is designed to consider dictates the need
for planners to decide which issues are to receive major
4-32
-------
emphasis. For this reason, few agencies are beyond the initial
stages in developing pretreatment programs. The purpose of
this case study is to describe one particular agency's program
in terms of completed tasks and their projected outline for
the final pretreatment plan.
The WQM (208) planning area, located along the mid-
Atlantic coast, is a semi-industrialized area with population
and industrial centers distributed mainly in its northern
half. Some farming occurs within the area, but major economic
benefits are derived through light manufacturing and services.
Although the area includes seven wastewater treatment
facilities only one receives appreciable quantities of indus-
trial wastes. This facility, located in the area's largest
city (pop. 80,000) , is a 90 MGD secondary activated sludge
plant with anaerobic digestion. The major industrial contrib-
utors are Food and Kindred Products (SIC #20), Paper and
Allied Products (SIC 126), Chemicals and Allied Products (SIC #28),
Leather and Leather Products (SIC #31) and Primary Metals
Industry (SIC 132).
4.4.2 Inventory of Non-Domestic Dischargers
This agency's industrial waste survey began with the
compilation of a list of non-domestic dischargers that would
be considered for sampling. The list was derived from local
industrial studies, directories and sewer billing records.
To determine which industries were sewer dischargers NPDES
permit records were investigated and questionable firms were
contacted by telephone. This procedure resulted in a list-
ing of 800 potential non-domestic dischargers. The final
step in this procedure was to conduct preliminary site visits
to determine if a particular industry was indeed discharging
industrial quality waste.
Although on-site sampling was performed, the Agency was
not able to obtain direct flow measurements. Instead, water
consumption data was utilized with corrections made using
a mean sewage to water ratio (S/W). Table 4-17 is a summary
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of the S/W ratios used by the Agency.
Table 4-17
MEAN SEWAGE TO WATER RATIOS
Industry
Power Generation
Chemical and Allied Products
Petroleum Refining
Natural Gas Products
Primary Metals
Food and Kindred Products
Sand and Gravel Products
Stone, Clay and Glass Products
Cement, Hydraulic
Pulp and Paper Mills
Other Non-Durable Goods
Ratio
.591 ± .
.616 + .
.508 + .
.238 + .
.653 + .
.747 + .
.903 + .
.733 ± .
.387 + .
.876 + .
.665 + .
344
271
210
110
317
237
212
378
387
064
371
Water Quality analyses were performed by^-Agency person-
nel using procedures prescribed in Standard Methods. The
.following parameters were included in their analyses. I
BOD- Suspended Solids Lead
COD Settleable Solids Zinc
pH • Chromium Copper
Nickel
One conclusion that was drawn from the data was that
industries involved in similar operations do not necessarily
discharge similar wastes. One example of this is two beverage
bottling plants listed under SIC #20. Although some heavy
metals concentrations are similar there was substantial
differences in the values for pH, BOD-, COD, Settleable Solids
and Zinc. The reason for this, whether pretreatment or process
differences, is not known at this time.
The most significant conclusion drawn from this initial
survey was the need for a system of industrial discharge
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permits comparable to the NPDES system for direct dischargers.
The initiation of this permit scheme would provide the
agency with much of the data needed to plan additional sur-
veys. Specific information that would be obtained from
permit applications include water consumption, process opera-
tions and wastewater flow. A more detailed description of
this enforcement mechanism is found in the following section.
4.4.3 Ordinance Development
This planning agency has recently helped the local
county_authority in developing amendments to its existing
sewer ordinance. These amendments are specifically concerned
with industrial discharges and are entitled "Regulation of
Non-Domestic Wastewater Discharges in the Public Sewer System".
The ordinance is similar in most respects to the model ordin-
ances provided in Appendix C of this manual. Enforcement is
provided by means of a Wastewater Discharge Permit System,
which states that pretreatment may be required as one of the
permit conditions.
The enforcement program is designed to develop in a
stepwise procedure, as follows:
(1) Notify existing and potential violators,
(2) Preparl draft permit applications and permits,
(3) Standardize procedures for processing permit applica-
tions ,
(4) Standardize procedures for delineation of compliance
and abatement schedules,
(5) Develop interim surcharge formula,
(6) Develop policy statement on responsibility for re-
sampling for dischargers seeking variances or
claiming incorrect sampling,
(7) Issue waste discharge permits, and
(8) Establish abatement schedules either in conjunction
with those dischargers who wish to participate
or draw up involun-cary abatement schedule.
The agency believes it can complete the first six steps
listed above as part of its planning process. The remaining
tasks will be handled by the continuing management agency.
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The permit applications (step (3)) not only provide an
enforcement mechanism for the ordinance but also a refine-
ment of the data collected in the agency's Inventory of Non-
Domestic Dischargers. In this way the agency can collect
data on industrial discharges without sampling the industries
themselves.
4.4.4 Outline of Projected Pretreatment Plan
A completed WQM pretreatment plan must first and fore-
most comply with the requirements of PL 92-500 Section 208.
The initial requirement stated in Section 208(D)(1) is that
the waste management planning process must be "consistent
with Section 201 of (the) Act". Further, the plan must
"contain alternatives for waste treatment management, and
be applicable to all wastes generated within the area in-
volved". The plan must also include:
208 (b) (2) (A) The identification of treatment works
necessary to meet the anticipated mun-
icipal and industrial waste treatment
needs . . .
(C) The establishment of a regulatory pro-
gram to ...
(iii) assure that any industrial or commercial
wastes discharged into any treatment works
in such area meet applicable pretreatment
requirements . . .
The ri"vcd «w»jrcv«\ above is the key mandate as far as
pretreatment is concerned.
r,» regulatory program must establish pretreatment
requirements for those pollutants which will either pass-
through or interfere with a publicly owned treatment works.
The planning agency views their pretreatment program
as not only a method of instituting regulations to protect
treatment facilities, but also an important element in the
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evaluation of their residuals management plan. This view-
point developed through the understanding that the level of
pretreatment required will have a direct impact on the quality
of municipal sludge and, therefore, a direct impact on reuse
and disposal options. The following discussion describes
the three elements in their overall plan.
Treatment Facility Evaluation
The first step-is to identify those treatment facilities
receiving industrial contributions. These facilities will
subsequently be characterized according to the quality and
quantity of their effluent and sludge. By examining treat-
ment process characteristics the agency's industrial staff
will be able .to identify compatible and incompatible pollutants.
This final step provides the initial correlation between
this task and the evaluation of pretreatment requirements.
Pretreatment Evaluation
The compilation of data on industrial discharges to
sewers is the first step necessary for the evaluation of
pretreatment requirements. Work on the agency's Industrial
Waste Survey has begun (see Inventory of Non-Domestic Dis-
chargers) and will be completed in conjunction with the
industrial Permits Program. Using the industrial data collected
and information from the facilities.inventory the present
and projected load of incompatible pollutants can be determined.
After possible reduction alternatives are assessed according
to their technical and economic feasibility, final pretreat-
ment requirements will be determined and used to evaluate
industrial impacts on the residuals management system.
Residual Waste Management Plan
Industrial pretreatment requirements are necessary in-
formation for determining municipal sludge quality. This in
turn allows the agency to evaluate the possible disposal or
reuse options available. A more detailed discussion of this
issue is found in Case Study I.
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By outlining their final pretreatment plan, the planning
agency has effectively separated their planning functions ffom
the continuing management process which will succeed them.
The evaluation of technical pretreatment alternatives, economic
impacts or industrial growth policies and the selection of
pretreatment requirements are viewed as planning functions.
The evaluation and selection of a final residuals manage-
ment program will also be included. However, finaliza-cion
of the industrial permits program will not be completed during
the planning phase. Thus, the establishment of ordinance
enforcement procedures is viewed as a management function.
In many cases the separation of planning and manage-
ment functions will be defined by time and economic constraints
Pilot testing of industrial wastes, which might be considered
a planning function, can only be conducted if the planning
agency has the time and funds remaining after the prerequisites
for this task are complete. The WQM agency being considered
here views pilot testing as a management function. The
critical fact is that due to the limited time frame alloted
them, Areawide WQM planning agencies must decide which plan-
ning functions are to recieve the highest priority.
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