REVISED WORK PLAN FOR REVISION OF BAT EFFLUENT LIMITATIONS
AND PRETREATMENT STANDARDS FOR EXISTING SOURCES
AND NEW SOURCE PERFORMANCE STANDARDS
FOR THE PESTICIDES POINT SOURCE CATEGORY
Prepared by:
ENVIRONMENTAL SCIENCE AND ENGINEERING, INC.
P.O. Box 13454, University Station
Gainesville, Florida 32504
April 1, 1978
Prepared for:
I.S. ENVIRONMENTAL PROTECTION AGENCY
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REVISED WORK PLAN FOR REVISION OF BAT EFFLUENT LIMITATIONS
AND PRETREATMENT STANDARDS FOR EXISTING SOURCES
AND NEW SOURCE PERFORMANCE STANDARDS
FOR THE PESTICIDES POINT SOURCE CATEGORY
Prepared by:
ENVIRONMENTAL SCIENCE AND ENGINEERING, INC.
P.O. Box 13454, University Station
Gainesville, Florida 32604
April 1, 1978
Prepared for:
U.S. ENVIRONMENTAL PROTECTION AGENCY
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TABLE OF CONTENTS
Page
INTRODUCTION 1
TECHNICAL APPROACH 2
OVERVIEW 2
TASK 1. INITIAL PLANNING REVIEW 7
TASK 2. INDUSTRY PROFILE 9
TASK 3. COLLECTION AND ANALYSIS OF SCREENING/VERIFICATION
SAMPLING 12
TASK 4. PROCESSING OF INFORMATION 13
TASK 5. DEVELOPMENT OF TREATMENT TECHNOLOGY 14
TASK 6. DEVELOPMENT OF COST MODELS 16
TASK 7. PREPARATION OF DOCUMENT 17
PROJECT ORGANIZATION 18
QUALITY CONTROL 21
COST RATE SCHEDULE 22
APPENDICES
I. LIST OF PRIORITY POLLUTANTS
II. OUTLINE OF FINAL REPORT
III. QUALITY ASSURANCE PLAN
IV. PROJECT FILING SYSTEM
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INTRODUCTION
Interim Final Guidelines for the pesticide chemicals industry, based on
the best practicable treatment currently available (BPT), were published
on November 1, 1976. These guidelines divided the industry into the
following five manufacturing segments:
Subcategory A Halogenated-Organic
Subcategory B Organo-Phosphorus
Subcategory C Organo-Nitrogen
Subcategory D Metallo-Organic
Subcategory E Formulators and Packagers
These subcategories formed the basis for the July, 1977, Request for
Proposal (RFP) for the Pesticides Point Source Category.
This work plan describes the project that will be undertaken in compli-
ance with EPA Contract No. 68-01-4754 for a technical analysis of
treatment alternatives to be utilized in revising:
1. Effluent limitations based on the Best Available Technology
Economically Achievable (BAT) for existing direct dischargers;
2. New Source Performance Standards (NSPS) to be met by new direct
dischargers; and
3. Pretreatment standards for new and existing indirect
dischargers.
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TECHNICAL APPROACH
OVERVIEW
Successful completion of the BAT review process requires that two
distinct yet interrelated activities be conducted concurrently. One
activity is the review of existing guidelines (BAT, pretreatment stan-
dards for new and existing sources, and NSPS) which are written for what
might be termed "traditional" parameters. The second activity consists
of a special consideration of the Priority Pollutants stipulated in the
June 7, 1976, Consent agreement between EPA and the National Resources
Defence Council, et al.
A meaningful review of existing guidelines requires that an expanded
and updated data base be collected and compiled into a comprehensive
industry profile containing detailed inventory information as well as
statistical information on waste loading and treatment efficiencies for
the traditional parameters of each subcategory.
Consideration of the Priority Pollutants involves determining the extent
and scope of the use, production, and discharge of these pollutants into
the environment by plants in each subcategory. Potential reduction of
the Priority Pollutants through the use of in-process controls and
external treatment systems must be documented, and associated costs
identified. Data will be analyzed to establish any existing
relationship between Priority Pollutant removal and the removal of a
traditional and easily measured parameter such as Chemical Oxygen Demand
(COD) or Total Organic Carbon (TOG).
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When existing information has been reviewed and the industry profile
and sampling-analytical work completed, the existing subcategorization
of the industry will be reviewed and modified as necessary. The focus
of the work will then be on development of treatment technology and cost
analyses.
An interim draft development document will be issued on
October 31, 1978, reporting activities through that date. The final
draft development document will be completed by February 10, 1979,
integrating comments and follow-up activities into a comprehensive and
fully documented report.
Figure 1 presents a bar chart which is keyed to the subtasks described
below. The program is designed to comply with EPA's desire to produce an
Interim draft report by October 31. This deadline, however, is contin-
gent upon certain assumptions, primarily that:
1. Screening and verification sampling be accomplished as soon as
possible. Any sampling or analyses performed by the EPA or
other contractors in support of this program must be completed
within the time frame set forth in the bar graph;
2. No delays be incurred in mailing of 308 letters (see Task 2);
3. No delays are encountered in scheduling plant visits; and
4. That due to the shortened time frame for this project, the
interim draft document be only partially complete.
Figure 2 presents a simplified critical path diagram. The important
milestones for this project are identified in Table 1.
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Table 1. Important Milestones
Milestones
Planned Date
M-l Complete and Revise Work Plan
Complete and Revise General 308 4/1/78
M-2 Complete Task 1 4/28/78
M-3 Complete Screening Sampling 5/19/78
M-4 Complete Review, Printing, and Mailing
of General 308 by EPA 5/26/78
M-5 Complete Verification Sampling 8/11/78
M-6 Complete Review, Printing, and Mailing by
EPA, Return and Processing Follow-Up 308s 8/25/78
M-7 Provide Preliminary Costs 8/31/78
M-8 Complete Task 5 and Interim Draft Document 10/31/78
M-9 Complete Final Document 2/10/79
M-10 Complete Supplements A and B 3/10/79
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FIGURE 1. TASK SEQUENCE DIAGRAM
MONTHS FEB -f~ MAR -j-
WEEKS 0 4 1
SUBTASK DESCRIPTION
Kick-Off Meeting
Draft Work Plan and Revisions
1-1 Define Scope of Coverage
1-2 Collect Historical Data
1-3 Collect P. P. Data
1-4 Update Industry Inventory
1-5 Eng. Analysis of P.P.
1-6 Present Alternative Subcat.
2-1 Compile 308 Mailing List
2-2 Draft General 308 Letter
2-3 Draft Specific 308 Letter
2-4 308 Review and Mail by EPA
2-5 Wait for and Process 308's
2-6 Draft, Review, Wait for, and
Process Follow-Up 308's
3-1 Collect Screening Samples
3-2 Analyze Screening Samples
3-3 Collect Verification Samples
3-4 Analyze Verification Samples
4-1 Finalize Subcategorization
4-2 Statistical Analyses (Traditional)
4-3 Statistical Analyses (P.P.)
5-1 Identify Technologies
5-2 Develop Design Criteria
5-3 Determine % Removal
6-1 Meet Econ Contractor
6-2 Provide Preliminary Costs
6-3 Costs for Draft Document
6-4 Costs for Final Document
7-1 Prepare Draft Report
7-2 Prepare Final Document
7-3 Pi opaie Supplements A & B
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4,5,6-3.7-1
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NOTES;
O
TASK:
1. Initial Planning Review
2. Draft, Review, Wait for and Process 308's
3. Collect and Analyze Screening and Verification Samples
4. Finalize Subcategorization
5. Identify and Design Treatment Technology
6-2. Provide Preliminary Costs by August 31
6-3. Provide Costs for Draft Document
7-1. Prepare Draft Document
7-2. Prepare Final Document
7-3. Prepare Supplements A and B
Number of Weeks
Critical Path
Revisions to Tasks Identified Above
Figure 2
Simplified Critical Path Diagram
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY v
DATE: APR 1 1 1978
SUBJECT: Pesticide Chemicals Working Group Meeting, April 17, 1978
George M. Jett
FROM: Working Group Chairman
Addresses:
TO:
Attached is the material I would like you to review prior to
the first working group meeting for the pesticide manufacturing
industry as part of the NRDC settlement agreement. The meeting
will be held.at 9am in Room 2814 WSM on April 17. Please attend
or send a representative from your office.
The addendum will include:
A. Technical Contractor Work Plan
B. 308 Industrial Questionnaire
C. Interaction between working group members
If for some reason no one from your office can attend please
supply any comments to: .
George M. Jett
Environmental Protection Agency
WH-552 Room 923 ET
401 M. Street, S.W.
Washington, DC 20460
8-426-2497
EPA Form 1320-6 fRcv. 3-76)
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Attendees:
Miller, WH-552
Michael Kosakowski, WH-552
Atly Jefcoat, RTP
Dale Denny, RTP
Coke Cherney, A-131
Louis DuPuis, WH-586
Charles Cook, WH-553
Paul DesRosiers, RD-681
Wayne Garrison, ORD
Lee Wolfe OR&D
James Lichtenberg, OR&D
Tim Fields, AW-465
Murray Strier, WH-552
Gunter Zweig, WH-568
Dean Jarman, WH-547
Mark Segal, WH-553
Ralph Holtje, WH-585
Dave Davis, WH-553
Greg Kew, EN-336
Art Masse, NFIC, Denver
John Frisco, Region II
Walter Lee, Region III
James Patrick, Region IV
John Barney, Rfegion V
John Dehn, Region VI
Carl Walter, Reg. VII
Clyde Eller, IX
Gary O'Neil, Region X
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TASK I—INITIAL PLANNING REVIEW
ESE will implement a program to assemble data required to make two pre-
liminary recommendations: modifications to current subcategorization
and location of plants to be sampled.
Identified subtasks are as follows:
Subtask 1-1. Define scope of coverage for the study. Standard
Industrial Classification (SIC) listings, Office of Pesticide Programs
registrations, and currently regulated products will be combined in
order to establish a logical basis for inclusion/exclusion of products.
Subtask 1-2. Collect historical analytical wastewater data for
traditional parameters. These data are found principally in the final
development document and its supplements. Currently regulated
parameters will be emphasized (Biological Oxygen Demand (BOD), COD,
Total Suspended Solids (TSS), and Pesticides); however, the existence of
data on other parameters of interest will be documented (phenol,
cyanide, NE^-N, etc.). National Pollutant Discharge Elimination
System (NPDES) data will be included in this review.
Subtask 1-3. Collect existing priority pollutant analytical data and
identify future plants to be sampled by personnal other than ESE.
Priority pollutant samples have been taken by ESE at three plants, and
by regional EPA teams at sixteen additional plants as of March 27, 1978.
These data will be utilized to identify what supplementary screening
sampling will be required. GC/MS tapes for these data will be requested
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to be sent to ESE for quality control evaluation. Use of GC/MS tapes in
this fashion will supplement the usual quality control data required by
the current EPA analytical protocol.
Subtask 1-4. Display inventory information on currently identified
plants. Data from the BPT file concerning plant location, product(s),
method of disposal, and treatment technology are currently in a com-
puterized data file at ESE. This file will be updated and expanded to
include several plants for which information was not avialable during
the BPT Study.
Subtask 1-5. Conduct engineering analysis of the potential for priority
pollutants on a product/process basis. A major emphasis will be to
establish which groups of priority pollution analyses (acid-neutral,
base-neutral, VGA's, metals, cyanides, etc.) might be excluded from
verification sampling. This judgement would be undertaken in
conjunction with evaluation of existing screening data (Subtask 1-3).
Subtask 1-6. Based on current knowledge of this industry, present
alternating subcategorization/sampling schemes for EPA review. Estimate
sampling and analytical costs for each alternative.
The output of Task 1 will be available at the time of the first working
group meeting. It consists of a set of alternative courses of action
detailing:
1. The most cost-effective utilization of currently contracted
hours;
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2. Additional sampling/analytical requirements beyond the scope of
the current contract, but deemed desirable for the statisti-
cal/legal basis of the anticipated guidelines; and
3. Priorities for subsequent tasks to be completed prior to
October 31.
TASK 2—INDUSTRY PROFILE
A letter and data collection portfolio will be sent by EPA to each
manufacturer in the pesticide chemicals industry, under authority
contained in Section 308, Public Law 92-500, Federal Water Pollution
Control Act.
The primary purposes of the 308 letter are as follows:
1. To obtain general inventory information on all manufacturers
not previously identified;
2. To obtain specific follow-up data for major manufacturers
already a part of the BPT file;
3. To obtain priority pollutant production, sampling, and treat-
ability data; and
4. To obtain raw material, process, and in-plant control tech-
nology information not heretofore available to the degree
required for all manufacturing facilities.
It is assumed that no 308 letter will be required for formulators/
packagers.
-------
Identified subtasks for this task are as follows:
Subtask 2-1. Compile 308 mailing list via coordination with Office of
Pesticide Programs, regional EPA offices, Office of Toxic Substances,
and other sources such as the Stanford Research Index.
Subtask 2-2. Draft a general 308 questionnaire as identified in (1) and
(3) above, to be sent to approximately 80 potential manufacturers not
previously identified in the BPT study.
Subtask 2-3. Draft a specific questionnaire as identified in (2), (3),
and (4) above, to be sent to approximately 90 confirmed manufacturers
identified in the BPT study.
Subtask 2-4. Reviewing and mailing of 308 letters by EPA.
Subtask 2-5. Process responses to 308 questionnaires and incorporate
data into subcategorization, control and treatment technology, and cost
identification process.
Subtask 2-6. Prepare follow-up 308 questionnaire, as necessary, for
plants identified in Subtask 2-2.
The result of the industry profile will be a narrative, pictorial, and
tabular presentation of existing data, 308 letter results, sampling
analysis, and information contained during plant visits. It will be
10
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summarized in the development document and presented in detail in
Supplement B.
TASK 3—COLLECTION AND ANALYSIS OF SCREENING AND VERIFICATION SAMPLING
The exact scope for collection of screening samples can only be deter-
mined after the initial planning review (Task 1) has been completed.
For purposes of scheduing it will be assumed that there is no existing
priority pollutant data base, when in actuality ESE will provide supple-
mentary screening collection and analyses based on data from plants
screened by regional sampling teams.
Identified subtasks are as follows:
Subtask 3-1. Collect screening samples. One 24-hour composite will be
taken from raw wastewater and treated effluent locations at each plant.
At multi-product plants additional raw wastewater samples may be taken
in order to maximize coverage with the fewest possible visits.
Subtask 3-2. Analyze screening samples. Previously regulated
parameters (BOD, COD, TSS, and Pesticides) will be monitored in addition
to GC/MS identification for the ^[priority pollutants.
Subtask 3-3. Collect verification samples. Three 24-hour composite
samples (one intake water, three raw wastewater, and three treated
effluent) will be taken at five plants in each subcategory.
11
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Subtask 3-4. Analyse verification samples. Based upon the screening
analyses (Subtask 3-2) and process engineering justifications
(Subtask 1-5), specific priority pollutants may be excluded from
consideration at this time. Alternatives to GC/MS procedures will be
utilized for compounds exhibiting no interference.
As a result of this task, initial subcategorization can be finalized and
detailed design of treatment technology can begin. A sample fraction
for the specific pesticides produced at each plant will be sent to EPA,
Bay St. Louis, Mississippi, for separate analysis.
TASK 4—PROCESSING OF INFORMATION
ESE has developed and utilized in previous guidelines projects a com-
puterized industry inventory and data storage system. Each plant has
two data banks, one for Industry Profile information as set forth in the
RFP and one for analytical data. All historical, 308, and analytical
data will be added to these two banks. The current data bank will be
updated in Task 1-4.
The profile data bank may be utilized to procure information on any
stored variable. For example, a printout may be generated of all plants
producing parathion, or those utilizing activated carbon. Such a pro-
gram is essential when large amounts of data must be rapidly assessed.
The analytical data bank is used to summarize data by plant and subcate-
gory. Concentration, total mass, and mass per unit of production for
12
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each pollutant parameter in the intake water, raw wastewater, and
treated effluent may be presented or further analyzed. In combination
with profile data, plots of plant size versus pollutant discharge may be
obtained. ESE has on file all applicable analytical data from the final
pesticide regulation.
Statiscial analysis of each plant effluent is a necessary part of the
guideline process. ESE has previously provided to EGD the following
types of analyses: 1) histograms and statistical coefficients to test
normality; 2) correlations between parameters and auto correlations;
3) variability analysis based on three-parameter log normal distribu-
tion; 4) goodness of fit tests to determine suitability of three-
parameter log normal variabilities; and 5) variability analysis based on
non-parametric methods.
Statistical analyses utilized during the BPT study required that daily
and monthly variability factors be calculated for plants with long term
data for traditional parameters, provided they employed the recommended
treatment technology. The calculations for each factor were designed to
insure compliance 99 percent of the time.
If variability analysis for BAT is again based on non-parametric
methods, a minimum of 100 data points would be required for each regu-
lated parameter. These data are available on traditional parameters at
7-10 plants. Since these data are not available for priority pollu-
tants, correlations to traditional parameters will be attempted.
13
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Identified subtasks are as follows:
Subtask 4-1. Combine historical, 308 response, and analytical data for
determination of final subcategoization.
Subtask 4-2. Provide statistical analyses for long-term averages, daily
variability factors, and monthly variability factors in support of
regulation for traditional parameters.
Subtask 4-3. Provide statistical analyses in support of regulation for
priority pollutant parameters or surrogates.
TASK 5—DEVELOPMENT OF TREATMENT TECHNOLOGY
At least three treatment alternatives will be developed for BAT, NSPS,
and pre-treatment of each industrial subcategory based on information
obtained and processed during previous tasks. The alternatives will be
presented in two forms: 1) model treatment systems (conceptual designs)
and subsequent cost calculations, and 2) a matrix of treatment levels
(degrees of pollutant removed) versus treatment modules.
Individual processes will be evaluated to recommend in-plant technolo-
gies capable of reducing waste flows and removing priority pollutants
identified by screening/varification sampling. Process information
received in 308 responses, coupled with information from plant visits,
will be integrated into these recommendations, based on documentation
currently available regarding wastewater characteristics before and
after control technologies. A process consultant will be utilized to
provide expertise in process modificatons and in-plant controls.
14
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Additional technologies will be identified as a result of a literature
review, from pilot data developed by industry, from studies being con-
ducted by RTF, from projects such as the Organic Chemicals Activated
Carbon Study, and from technology transfer.
The potential effects of the control or treatment technologies on other
pollution problems, such as air pollution or solid waste generation,
will be analyzed via information from the literature, case histories
from plant visits, and engineering judgement. In those cases where
secondary pollution is created, an identification of applicable control
technology will be made. The effect of specific pollutants on the per-
formance of biological systems will be defined (adsorption on sludge,
transformation to other toxic species, etc.).
An important aspect in the development of control and treatment tech-
nology will be energy consideration. When appropriate, less intensive
energy-using systems will be identified. The effects upon control
technology of land availability will be outlined.
Identified subtasks are as follows:
Subtask 5-1. Identify applicable treatment technologies for each
pollutant/subcategory, including in-process measures where applicable.
Subtask 5-2. Develop design criteria for treatment technologies.
15
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Subtask 5-3. Determine degree of pollutant removal achievable for each
treatment technology.
TASK 6—DEVELOPMENT OF COST MODELS
Each of the treatment models developed in Task 5 will be costed. A
capital cost and annual operating cost will be prepared for each unit
module as well as for complete treatment trains.
Previous experience with developing cost models for effluent guidelines
projects makes it clear that close contact with the economic contractor
is mandatory.
Identified subtasks are as follows:
Subtask 6-1. Meet with economic contractor during the week of April 3
through 7 in order to define approach, assumptions, and requirements.
Subtask 6-2. Provide economic contractor with preliminary cost data by
August 31.
Subtask 6-3. Prepare capital and operating cost data for draft
document.
Subtask 6-4. Prepare capital and operating cost data for final
document.
16
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TASK 7—PREPARATION OF DOCUMENT
All results and conclusions of the study will be presented in a Draft
Development Document, the content and format of which will be closely
coordinated with the Project Officer. A proposed outline is presented
in Appendix II.
The body of the Draft Development Document will contain a summary of the
industry profile; a comprehensive description of the various industrial
processes; the rationale and documentation for subcategorization; a
discussion of the applicable pollutant parameters for each subcategory
(including the Priority Pollutants) and the reason for their applica-
bility; and a complete presentation of control and treatment technology
and cost analyses, including both case histories and model systems.
Supplemental materials will be fully indexed and paginated. The
importance of this material in potential litigation is recognized, and
every effort will be made to make it a viable, functional tool.
Identified subtasks are as follows:
Subtask 7-1. Prepare Interim Draft Report by October 31. Individual
chapters will be submitted as they are completed.
Subtask 7-2. Prepare final document.
Subtask 7-3. Prepare Supplements A and B.
17
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PROJECT ORGANIZATION—KEY PERSONNEL
The project organization is shown in Figure 3. The organization is
designed to allow an efficient operation throughout the life of the
project and is similar to the systems tried and proven on previous
guidelines projects. It allows open communications between EPA person-
nel and ESE personnel, while at the same time providing a well-defined
chain of responsibility and accountability.
The ESE Project Director holds ultimate responsibility for the project
both to the client and to the company. He directly controls project
scheduling, budget, personnel assignments, work quality, and overall
coordination to optimize cost effectiveness and efficiency.
The Project Review Committee, chaired by the ESE Director of Operations,
monitors major project activities, technical progress, and cost effec-
tiveness. It provides consultation on methodologies and on solutions to
any problem areas that might develop during the course of the project.
The Project Director appears before the Review Committee at least month-
ly to report the status of the project and to provide rationalization
for his plans and decisions.
The Project Manager, while reporting to the Project Director and held
accountable by him, communicates directly with the appropriate EPA
Project Officer. The Project Manager is responsible for the day-to-day
technical activities of the project and for supervision of the project
staff.
18
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The Staff Engineers are dedicated to the project on a full-time basis.
Reporting to the'Project Manager, they are responsible for discrete task
assignments.
Special capabilities and experience in specific process areas are pro-
vided by the consultants. All of the consultants have worked previously
with ESE.
The filing system to be used for this project is presented in
Appendix IV.
19
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PROJECT ORGANIZATION
LINE OF RESPONSIBILITY -
LINE OF COMMUNICATION -
EPA PROJECT OFFICER
ESE
REVIEW COMMITTEE
. R. Hendrickson, Ph.D., P.E.
G. M. Barsorn, Sc.D., P.E.
W. C. Zegel, Sc.D., P.E.
ESE
PROJECT DIRECTOR
J. D. Crane, P.E.
SPECIAL CONSULTANTS
J. H.Mayes, Ph.D., P.E.
J. McClave,Ph.D.
I ,
ESE
PROJECT MANAGER
M. J. Greco
M
O
SPECIAL ASSISTANT
J. B. Cowart, P.E.
I
I
STAFF ENGINEERS
M. Mangone
R. V. Bowen
TECHNICAL SPECIALISTS
I
SAMPLE COLLECTION
• E.M. Kellar
TREATMENT TECHNOLOGY
J. D. Crane, P.E.
B. A. Beaudet, P.E.
LABORATORY
COORDINATOR
W. E. Olson
DATA PROCESSING
A. S. Monplaisir
J. D. Doolittle, Ph.D.
M. L. Malacoff
NON-WATER QUALITY
D. E. Bruderly, P.E.
K. F. Kosky, P.E.
H. G. Stangland, P.E.
COSTS ANALYSES
S. M. Hasan, Ph.D., P.E.
M. Mangone
Figure 3
PROJECT ORGANIZATION
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QUALITY CONTROL
It is an ESE policy that all engineering calculations are checked by
another engineer. Text is reviewed by each person's immediate superior
for technical quality, and by the ESE Word Processing Center and Tech-
nical Writing Department for grammar and composition.
Field sampling and sample analyses are carried out by procedures estab-
lished by ESE in other effluent guidelines studies and BAT reviews, and
in accordance with the pertinent EPA protocols. Copies of the ESE Field
Sampling Manual and the ESE Laboratory Quality Assurance Manual can be
provided under confidential agreement.
A summary of the quality assurance program that will be applied to the
Pesticide Chemicals BAT review is included in Appendix III.
21
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COST RATE SCHEDULE
Table 2 presents the man-hours of effort, by labor category, which are
projected to be expended on each task during the course of the project,
The cost/schedule baseline, Form WP-2, depicts the projected expendi-
tures for the duration of the project.,
22
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Table 2. Projected Manhours by Labor Category
Labor Category Task Number
1234567 Total
Project Director 40 60 40 40 80 60 80 400
Senior Engineers 110 163 750 218 218 163 218 1840
Engineers 80 120 1500 160 160 120 160 2300
Associate Engineers 100 150 500 200 200 150 200 1500
Senior Technicians 5 12 1000 12 12 12 12 1065
Technical Support 40 60 1400 80 80 60 80 1800
Consultants 22 21 49 60 49 23 224
TOTAL 397 586 5190 759 810 614 773 9129
23
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COST/SCHEDULE BASELINE (WP-2)
Page.
of.
Contracto
EPA proj
68-01-
Environmental sciences and
n _ , . r
Engineering, Inc.
ect officer- Or. Trvin A Jefcoat
4754 000
Contract No. Task No.
(1)
Work breakdown structure
No.
1.
2.
3.
Noun description
Field/Sampling
Work
Lab/Analytical
Work
Engineering
General and administrative
Management reserve
Tolal
Cumulative total cost (excluding feet
Cumulative
cost to dale
($1000's)b
0
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0
Contractor project manager name,!
. Pro.iect Director - Jc
^^^
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Signature
itifl Michael Rrp^n
»hn D. Crane
Date
— Re\
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D
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Approval by EPA project officer3
(3)
Monthly budgeted cost of work scheduled (BCWS)b-c ($1000's)
Mo.
2
Yr.
/a
0
0
3
0
3
3
Mo.
3
Yr.
ya
0
0
7
0
- "" s ' -
7
10
Mo.
4
0
0
7
Yr.
/H
.5
0
,'~ \r •*
7.5
17.5
Mo.
5
Yr.
/a
0
0
9.5
0
'y :.
-------
ro
en
COST/SCHEDULE BASELINE (WP-2)
contra: Environmental Science and
EPA proj
68-0
Enaineerinq, Inc.
rtr<«~- Dr. Irvin A. Jefcoat
1-4754 ooo
Contract No. Task No.
(1)
Work breakdown structure
No.
1.
2.
3.
Noun description
Field/Sampling
Work
Lab/Analytical
Work
Engineering
General and administrative
Management reserve
Total
Cumulative total cost (excluding feel
(2)
Cumulative
cost to date
($1000's)b
Contractor project manager name.title Ml
Project Director - John D. Cre
ty^J
/^^/
t&r-
Signature
chael Greco
me
Date
Paga_
— Re
/ision
D
_2 of_2
Mn 1
ate 4/1/78
Approval by EPA project officer3
Monthly budgeted cost of work scheduled (BCWS)b-c ($1000's)
Mo.
JIL
Yr.
/y
6
8
2
Q
1fi
PR
Mo.
1 1
Yr.
78
0 '
8
10
0
>
18
11
3
Mo.
12
Yr.
78
1 0
0
22
0
•
22
135
Mo.
1
Yr.
/y
0
0
20
0
\ " ""
20
1
55
Mo.
2
Yr.
79
0
0
20
0
/ "
20
175
Mo.
3
Yr.
/y
0
0
17.6
0
;' '
17.6
192.6
Mo.
Yr.
Mo.
Yr.
* ^1 *' > "*
(4)
Total
budget D
(SIOOO's)
0
0
192.6
-'"l^M
a Once the cost/schedule baseline has been approved,
the figures may not be changed without the approval
of Ihti EPA project officer.
" All costs shown are exclusive of fee.
c Montly budgeted costs for entire contract—
-------
-J-
APPENDIX I
LIST OF PRIORITY POLLUTANTS
-------
EPA Effluent Guidelines Division List of
Priority Pollutants for B.A.T. Revision Studies
COMPOUND NAME
1. 'acenaphthene
2. 'acrolein
3. 'acrylonitrile
4. 'benzene
5. 'benzidine
6. 'carbon tetrachloride
(tetrachloromethane) .,
•chlorinated benzene* (other than
dichlorobenzenes)
7. chlorobenzene
8. 12,4-trichlorabenzene
9. hexachlorobenzene
•chlorinated str-anes (including 12-
dichloroethane. 1,1.1-trichioro-
ethana and f.exachloroethane)
10. 1 2-dichloroethane
11. 1,1.1 -trichlorcsthane
12. hexachloroethane
13. 1,1-dichlornethane
14; 1,1,2-trichl aroethane
15. 1.1 22-tetrachloroethane
16. chloroethane
•chloroalkyl jthars (chloromethyl,
chloroethyl and mixed ethers)
17. bis(chloromethyl) ether
18. bis(2
-------
APPENDIX II
OUTLINE OF FINAL REPORT
-------
TABLE OF CONTENTS
Section
Abstract
I. Introduction
II. Industry Profile
III. Industrial Subcategorization
IV. Process Descriptions
V. Wastewater Characterization
VI. Control and Treatment Technologies
VII. Cost, Energy, and Non-Water Quality Aspects
VIII. Acknowledgements
IX. References
X. Glossary
XI. Metric Conversions
Appendices ,
-------
ABSTRACT
The abstract will provide a brief overview of the report: what it is
about, how the study was conducted, and what the essential results were.
Its primary purpose is to allow the reviewer to determine whether he
should read all or part of the document.
I. INTRODUCTION
A. Purpose and Authority
This section will define the purpose of the BAT review of the Pesticides
Point Source Category and summarize the relevant federal legislation
authorizing the review.
B. Technical Approach
The steps and procedures of the review process will be summarized to
provide an overall view of the project. The intent of this subsection
is to lay out the sequence of events which are vital to the completion
of the BAT review, including:
1. The subcategorization of the industry;
2. The gathering of historical data on the raw waste character-
istics of the various subcategories and the source of such
data;
3. The identification and efficiency, obtained from 308 surveys
and other sources, of the treatment technologies that exist
within the subcategories;
4. The documentation of in-process controls and associated
effectiveness in reducing waste loads;
-------
5. The selection of plants to be visited and sampled, and the
rationale for the selection; and
6. The evaluation of the information gathered to determine what
level of technology constitutes BAT.
C. Scope of Study
The list of pesticides covered by the study will be discussed. The
basis for generating this list, as well as the rationale for excluding
certain products, will be provided.
II. INDUSTRY PROFILE
The industry profile will contain such information as facility age and
size, geographic distribution, raw materials used and products produced
and methods of wastewater treatment and discharge. The information will
be summarized in tabular form with detailed data contained in appendices
or supporting files. For cost effectiveness, computer-generated tables
will be used to the extent possible. The tables will be accompanied by
a narrative discussing the tabular information and pointing out trends.
III. INDUSTRIAL SUBCATEGORIZATION
A detailed description of the subcategorization of the industry will be
presented. This description includes the listing of the pesticide
products by subcategory. The rationale for arriving at the final
subcategorization will be presented in terms of the differences and
similarities in such factors as 1) the chemical structure of the
products; 2) the nature of the priority pollutants generated; 3) the
quantity and treatability of wastewaters; etc.
-------
IV. PROCESS DESCRIPTIONS
The processes used in the manufacture and formulation of pesticides will
be discussed in detail relative to wastewater generation. The two
primary purposes of this section are to provide documentation for
subcategorization and ultimately to assist the permit writer.
The section may be organized such as to correspond to the subcategor-
ization in the previous section or independently in terms of major
process types; the latter approach is more appropriate for currently
existing subcategories.
In any event, the discussion will emphasize means of in-plant control,
and process flow diagrams will be presented. Sources of wastewater will
be identified along with approximate ranges of volumes.
V. WASTEWATER CHARACTERIZATION
This section will define the quantities and qualities of wastewater
generated by the industry. The information will be presented primarily
in tabular form showing both pollutant loadings and concentrations.
Stress will be given to differences resulting from process variations
and in-plant control.
The section will be sub-divided by subcategory, and case histories for
each subcategory will be discussed. A representative model, in terms of
wastewater quantity and quality and plant production, will be developed
ixxix^
for each subcategory. >^,
-------
VI. CONTROL AND TREATMENT TECHNOLOGIES
With subsections by subcategory, case histories of in-plant and
end-of-pipe treatment facilities will be discussed. Each subsection
will be further subdivided by major treatment operations. In addition,
discussions will be given on relevant pilot plant or other research
activities and on potential transfer technologies. At least three
treatment levels will be presented for each subcategory.
VII. COST, ENERGY, AND NON-WATER QUALITY ASPECTS
The purpose of this section is to provide cost information which can be
used for economic impact analyses, each model treatment system developed
in the previous section will be costed in terms of investment cost, land
cost, and annual operating cost (including a break-out of annual energy
cost) .
The section will be divided by subcategory with separate discussions of
energy consumptions and non-water quality aspects—the later including a
qualitative discussion of impacts on air and (most significantly,
especially in terms of sludge disposal) on land.
A separate subsection will list all assumptions used in the cost
analyses.
VIII. ACKNOWLEDGEMENTS
-------
IX. REFERENCES
References will be cited in the text in the following manner: Smith,
1971. They will be listed in this section in alphabetical order.
X. GLOSSARY
All technical terms and abreviations will be defined and listed in this
section in alphabetical order.
XI. METRIC CONVERSIONS
Table providing conversion factors from English to Metric.
-------
APPENDICES
The appendices will contain various material which, if inserted into the
text of the report, would interfere with reading continuity. Potential
appendices include the following:
* Itemization of Priority Pollutants
* Index of common pesticide compounds by subcategory
* Blank copy of general 308 survey form
* Techniques of data analysis
* Engineering aspects of treatment technologies.
-------
APPENDIX III
QUALITY ASSURANCE PLAN
-------
LABORATORY QUALITY ASSURANCE PLAN
PESTICIDE CHEMICALS BAT REVIEW
Prepared by:
ENVIRONMENTAL SCIENCE AND ENGINEERING, INC.
P.O. Box.13454, University Station
Gainesville, Florida 32604
March 1, 1978
Prepared for:
U.S. ENVIRONMENTAL PROTECTION AGENCY
-------
PESTICIDE CHEMICALS BAT REVIEW
LABORATORY SUBPROJECT 78-012-200
Quality Assurance Plan
I. Description of Task
The laboratory task of this project requires the following analytical
effort:
Analysis of 77 Screening/Verification Samples for the following
parameters:
1. 129 priority pollutants (volatile organics, non-volatile
organics, pesticides, metals, cyanides);
2. Total Suspended Solids;
3. Biochemical Oxygen Demand;
4. Chemical Oxygen Demand;
5. Oil and Grease determinations on selected samples; and
6. Total Phenols analysis on selected samples.
The priority pollutants are those compounds associated with the "consent
decree" and are listed in the U.S. EPA Protocol for sampling and
Analysis of Industrial Effluents for Priority Pollutants.
II. Quality Assurance Organization and Responsibility
The primary responsibility for the quality of the data resides with the
group leaders. Ultimate responsibility for the quality of the data
belongs to the Subproject Manager and the Project Manager. The setting
-------
of these guidelines for rejection of data rests with the Quality
Assurance Supervisor with guidance from the Subproject Manager.
III. Sample Collection
Sample collection is not the responsibility of this subproject. How-
ever, coordination with the field team to insure the proper preservation
and labeling of field samples will be a responsibility of this subproj-
ect. Sample check-in and storage will be handled in such a manner so as
to insure that analyses are conducted by specified holding times and
that proper documentation of the sample is available throughout its
residency time in the laboratory.
IV. Sample Analysis
A. Priority Pollutants
All the priority pollutants will be analyzed according to the
protocol in "Sampling and Analysis Procedures for Survey of
Industrial Effluents for Priority Pollutants," U.S. EPA,
Environmental Monitoring and Support Laboratory, Cincinnati, Ohio,
revised April, 1977. Any significant deviations from the general
approach of this protocol will be documented and cleared with the
EPA Project Officer.
B. Total Suspended Solids, BOD, COD, Oil and Grease
These analyses will be conducted according to the procedures in
"Methods of Chemical Analysis of Waters and Wastes," U.S. EPA
-------
Environmental Monitoring and Support Laboratory, Cincinnati, Ohio,
1974.
V. Data Reporting and Validation
All data will be reported in a standard computer format which will
include such parameters as project name, file number, date of report, a
list of analyses or parameters, a list of sample numbers, and the
results of the analyses. When described for specific analyses, the
quality assurance procedures in the EPA protocol concerning duplicate
samples, spiked samples, and blanks will be followed.
In order to monitor the quality of ESE data, an extensive quality con-
trol verification system will be employed. To a very large extent, this
QC verification system is computerized. A major feature of this compu-
terized data system is the automatic verification of many QC parameters
at the time of data collection with an automatic rejection of any data
failing to meet all criteria for acceptability.
The precision and accuracy of most of the laboratory analyses are tested
by the use of control charts. The control charts to be used by ESE are
industrial control charts used by the U.S. Environmental Protection
Agency in their analytical quality control courses. A large advantage
in the use of control charts is that they are specific for each labora-
tory analysis. No two analyses have exactly the same control limits.
-------
Control charts are constructed using historical ESE performance on an
analysis as their basis. This historical data is then used in calcu-
lating the control limits for the analysis. Control limits for each
analysis are stored in the memory of the laboratory HP 9825A calculator.
When an analysis is performed, the quality control values for that
analysis are compared to the control limits, and the analysis is either
accepted or rejected.
Data is rejected if the difference between replicate concentrations or
the percent recovery exceeds the 3 standard deviation control limt for
the analysis. If the difference between replicates or the percent
recovery lies between the 2 and 3 standard deviation limits on the
control charts, a warning is printed.
When applicable, additional quality control criteria must be met. These
criteria include analysis of at least one blank, analysis of at least
10 percent replicate analyses, and the number of spikes must be greater
than or equal to 5 percent of number of samples. For analyses which
require the use of a standard curve, there must be at least 5 standards,
the correlation coefficient of the standard curve must exceed 0.99, and
the y-intercept must not deviate from 0 by more than a preset level.
If any of the quality control criteria are not met, the QC failures and
warnings are listed. When applicable, the standard curve is also
plotted, enabling detection of an outlier among the standards. This
feature prevents the use of questionable data. The listing of QC
-------
failures is forwarded by the Laboratory Data Assistant to one of the
Group Leaders who may either require that the questionable samples be
re-analyzed or authorize an override of the failure. No analytical data
are released from the laboratory until the quality control criteria have
been met.
For the pesticides and the non-volatile organics analyses by GC/MS,
insufficient historical data exists on the precision and accuracy of
these analyses as carried out according to the EPA protocol. Thus,
appropriate QC limits on precision and recovery cannot be set for these
analyses. The precision obtainable for duplicates and the recovery
values from spiked samples will be highly variable and depend upon the
physical and chemical nature of the particular samples. In order to
obtain historical data and to help validate our analytical techniques, a
QC program of analyzing at least 10 percent of these samples in dupli-
cate and carrying out spiking experiments on 5 percent of the samples
will be carried out. The spiking experiments will be performed using
compounds representative of those species to be analyzed for.
VI. Calibration
Where necessary, the calibration of all analytical instruments will be
carried out according to the manufacturer's recommended practices.
Calibration of the GC/MS system will be accomplished daily according to
the procedure in the EPA Priority Pollutant Protocol, using
decafluorodiphenylphosphine as the calibration standard.
-------
VII. Preventive Maintenance
Preventive maintenance of all the instruments is continually being done
in the laboratory by the analysts as required. GC/MS maintenance is
performed on a regular schedule by manufacturer's representatives.
VIII. Auditing and Interlaboratory Test
An audit of the field sampling procedures will be conducted by the
quality control supervisor to ensure proper sampling techniques and
sample labeling. The quality control supervisor will, from time to
time, perform an audit of laboratory procedures which may include
analyses of control samples to check the laboratory data quality for
precision and accuracy.
IX. QC Report at End of Project
A QC report will be submitted at the end of the project which will
include a summary of duplicate analyses data, recovery data from spikes,
and all other QC activities.
X. Distribution List
Distribution of this document will be as follows:
Project Manager
QA Supervisor
Group Leaders
Division Manager
Project Officer from EPA
-------
XI. Bibliography
"Sampling and Analysis Procedures for Survey of Industrial Effluents for
Priority Pollutants," U.S. EPA, Environmental Monitoring and
Support Lab, Cincinnati, Ohio. Revised April, 1977.
"Manual of Methods for Chemical Analysis of Water and Wastes," U.S. EPA,
1974.
-------
APPENDIX IV
PROJECT FILING SYSTEM
-------
PROJECT FILING SYSTEM
All information pertinent to the project is filed according to the
attached outline. All telephone conversations are recorded on the
attached memorandum form and placed in the proper file. All confi-
dential information is retained separately under appropriate EPA
requirements.
-------
PROJECT FILING SYSTEM
I. INDEXES
A. Key to Filing System
B. SIC Codes
C. Subcategory/Plant Code Key
II. GENERAL CORRESPONDENCE (Not Subcategory Specific)
A. EPA EGD
B. EPA Regions
C. State and Local Regulatory Agencies
D. Industry/Trade Association
E. Other
III. SUBCATEGORY FILES
A. Subcategoy A
1. Correspondence (Not Plant Specific)
(a) Industry Comments
(b) Other
2. Final Report
3. Supplemental Report
4. Subcategory Specific Literature
5. Raw Waste Load Development (Rationale, Assumptions,
Calculations, Etc.)
6. Treatment System Design
(a) Design Printouts
(b) Manual Calculations
7. Treatment System Cost
(a) Coding Sheets
(b) Cost Assumptions, Calculations
8. Pretreatment Information
9. Water Use/Wastewater Management
-------
10. Survey Data (Not Plant Specific)
(a) Surveys Not in Plant Files
(b) Industry Inventory Information
11. General Information (Not Elsewhere Classified)
12. Plant Files
(a) Person(s) to Contact
(b) Survey Information
(c) Correspondence
(d) Field Visitation Form
(e) Raw Waste Load Data
(f) Treatment System Data
(g) Sampling Data
(h) Permit Information
(i) Pretreatment Data
(j) Consultant Reports
(k) Other
B.
C.
D.
IV. DESIGN/COST FILE (General)
A. Assumptions
B. Cost Tables
C. Procedures for Cost and Design
D. Program Printouts
V. ESE REPORTS
A. Work Statements/Work Plan
B. Field Reports
-------
C. Monthly Progress Reports
D. Other
VI. LITERATURE (Not Subcategory Specific)
A. General
B. Process
C. Treatment
D. Other
-------
environmental science and engineering. Inc.
MEMORANDUM TO FILE
Date: Project No:
From: File:
Re: !
Route To: Q D D D D
-------
308 QUESTIONNAIRE
Pesticide Chemicals Industry
PART I GENERAL INFORMATION
1. Corporate/Plant Data
A. Name of Corporation
B. Address of Corporation Headquarters
Street
City '
State Zip Code
C. Name of Plant
D. Address of Plant
Street
City
State Zip Code
E. Name(s) of personnel to be contacted for information
pertaining to this data collection portfolio:
Name Title Telephone No,
2. Type of Plant Operations:
A. Indicate below the type of operation(s) conducted
at this facility.
Manufacturer of_ Pesticide Active Ingredients Yes No
Formulator/Packager of_ Pesticides Yes No
Manufacturer of Pesticide Intermediates Yes No
Non-Pesticide Producer Yes No
B. If pesticide active ingredients are not manufactured at
this facility, complete and return this page only.
1-1
-------
Plant
City State
3. Type(s) of Product(s)
A. Indicate below the common name and/or chemical name for
each pesticide active ingredient or pesticide intermediate
manufactured. For each entry list the total production
(1000 Ibs.) and number of operating days in 1977.
1977 Total
Production Operating
Common Name Chemical Name (lOOOlbs) Days/Year
B. Indicate below the industrial classification (organic
chemicals, Pharmaceuticals, etc.,) and 1977 total production
(1000 Ibs.) for each non-pesticide produced.
1977 total production
Classification (1000 Ibs)
1-2
-------
Plant
City State
4. Method of Disposal:
A. Indicate below the method of disposal and volume disposed
(millions of gallons per day, or MGD) for process wastewater
from products listed in 3.A.
Note: Individual products disposed by the same method may
be grouped and entered on one line.
Method of Volume
Product(s) Disposal Disposed (MGD)
(example) Cyanazine 10 0.01
(example)Cyanazine,Atrazine 2 0.125
Example methods of disposal:
1 No Process Wastewater Generated
2 Direct Discharge to Navigable Waterway with Treatment
3 Direct Discharge to Navigable Waterway without Treatment
4 To Publicly Owned Treatment Works (POTW) with Pretreatment
5 To Publicly Owned Treatment Works (POTW) without Pretreatment
6 Incineration
7 Deep Well Injection
8 Ocean Discharge
9 Land (Spray Irrigation, etc.)
10 Contract Hauling
11 Total Evaporation
12 Other (Specify)
1-3
-------
PIant
City State
B. If National Pollutant Discharge Elimination System (NPDES)
or other EPA permits are required for any of the methods
of disposal listed above, provide the permit number and
effective date. Provide the permit number, name, address,
and telephone number for any other process wastewater
permit (such as with municipal sewage treatment plants, etc.)
End-of-Line Treatment Technology:
A. List the treatment units and volume treated (MGD) for
process wastewaters generated by products listed in 3.A.
See Example methods of treatment.
Note: Individual products disposed and treated by the same
method may be grouped and entered on one line.
Volume
Treatment Treated
Product(s) Units (MGD)
(example)Cyanazine, Atrazine Mf, Ac, Ne 0.125
1-4
-------
Plant
City
State
Example Methods of Treatment:
Activated Carbon (Ac)
Hydrolysis (Hd)
Chemical Oxidation (Co)
Equalization (Eq)
Gravity Separation (Gs)
Aerated Lagoon (Al)
Trickling Filter (Tf)
Activated Sludge (As)
Multi-Media Filtration (Mf)
Evaporation Pond (Ep)
Multiple-Effect
Evaporation (Ev)
Coagulation (Ca)
Floculation (Fo)
Resin Adsorption (Ra)
Chlorination (Ch)
Skimming (Sk)
Ion Exchange (le)
Stripping (Sp)
Metal Separation (Ms)
Neutralization (Ne)
Sludge Thickening (St)
Vacuum Filtration (Vf)
Pressure Filtration (Pf)
Aerobic Digestion (Ad)
None (No)
Other - Specify
B. Provide a simple block diagram of the treatment units
listed above.
C. Are non-contact or cooling wastewaters and process
wastewaters combined in the treatment system described
above? Yes No. If so, what is the volume of
non-contact wastewater? (MGD) .
D. Are sanitary and process wastewaters combined in the
treatment system described above? Yes No.
If so, what is the volume of sanitary wastewater?
(MGD) .
E. What is the ultimate destination of sludge generated in
treatment systems, if applicable?
6. Data Availability:
A. Indicate below if your facility has conducted or has con-
tracted for any of the following as regards its pesticide
process wastewaters.
Bench Scale Treatability Studies
Pilot Plant Treatability Studies
In-Plant Hydraulic/Sampling Surveys
Treatment System Modifications
Process Modifications
Yes
"Yes
"Yes
"Yes
Yes
No
"No
~No
No
"NO
1-5
-------
Plant
City State
B. Briefly describe any activity indicated in 6.A.
C. Indicate below the existence of any historical wastewater
data (such as from studies mentioned above, or from
required monitoring). Describe the following:
product/process which generated the wastewater; parameters
monitored (BOD, COD, pH, Flow, etc.); sample location
(refer to treatment system diagram, if necessary); and
number of data points available.
Sample Number of
Product Parameters Location Data Points
ex. Cyanazine/ Atrazine TOC Before Ac 45
ex. Cyanazine, Atrazine TOC, BOD, TSS After Ac 150
1-6
-------
Plant
City___ State
PART II PRIORITY POLLUTANT INFORMATION
Questions in this part refer to the 131 priority pollutants named
on List 1.
1. Identification and quantification of priority pollutants:
A. Check below any compounds on List 1 which have been
determined or are suspected to be present as raw mater-
ials, intermediates, active ingredients, reaction by-
products, or as hydrolysis, oxidation, or degredation
products at any point in the pesticide manufacturing or
process wastewater treatment system. Also indicate the
known/suspected source of each priority pollutant.
Determined Suspected
Priority to be to be
Pollutant Present Present Source
II-l
-------
List 1
EPA Effluent Guidelines Division List of
Priority Pollutants for B.A.T. Revision Studies
COMPOUND NAME
1. *ac»naphthena
2. *ecrolein
3. •ecrylonitrila
4. 'benzene
5. 'benzidirte
0. 'carbon tetrachlorlde
I terrechloro methane)
•chlorinated benaenea (other than
dicrilorobenzenes)
7. chlorooenzene
8. 1 <2.4-iricfilor3e*n*an«
9. rtaxacnlorob*nz«n«
•chlorinated etr-anee (including 1 2-
Oichloroetnane. 1 .1 .1 -trientoro-
•man* and f.exacftloroetnane)
10. 1 ,2-dlcMoroetnane
11. 1.1.1.iricnlorcathan*
12. hexachioroathene
13. 1 .1 -dicnlomettiane
U. 1.1 2-tricM aroeihene
15. 1.1,2.2-tttTtcMofoaman*
10. cnioroetnan*
•ehloroalkyl jiiMra Ichloromethyl.
chloroethyl and mixed etnersl
17. bislchloromwhyl) ether
18. bis(2-chioroathyl) ether
19. 2cftloroprooana
1 2'dicMoroorooylana (1 3-
dicnioroprooena)
2.4-dinitroioluan*
34. •2.4-dimathylonanol
35.
36.
37.
38.
39.
*1 ^
'ttnvlbanzan*
'fluorantnana
•haloathcrs (other than tnoM listed
eljewnere)
40. 4
-------
Plant
City State
B. For those pollutants in 1 A. that were measured, indi-
cate below the location from which samples were taken,
the average flow (MGD); the range of concentrations
(mg/1), and the number of data points involved.
Range of Number
Average Concen- of
Priority Sampling Flow trations Data
Pollutant Location (MGD) (mg/1) Points
(example) Cyanide After Ac 0.125 0.1-0.5 180
2. Priority pollutant studies/treatment:
A. Describe below any in-plant or end-of-line treatment
facilities installed/modified specifically for the
removal of any of the 131 priority pollutants.
Priority
Pollutant Description of Facilities
II-2
-------
Plant
City State
B. Describe below any bench, pilot, or full-scale treatability
studies conducted for any of the 131 priority pollutants,
not described in 2.A.
Priority
Pollutant Description of Study
II-3
------- |