United States
      EivronTiental Protection
      Agency
Of'ce of'-Vate' [4303)
Washington. DC 20-500
&EPA Development Document
      for Final Effluent
      Limitations Guidelines and
      Standards for Commercial
      Hazardous Waste Combustors

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                   DEVELOPMENT DOCUMENT
                               FOR
                 FINAL EFFLUENT LIMITATIONS
                  GUIDELINES AND STANDARDS
                            FOR THE
COMMERCIAL HAZARDOUS WASTE COMBUSTOR SUBCATEGORY
                             OF THE
        WASTE COMBUSTORS POINT SOURCE CATEGORY

                          Carol M. Browner
                           Administrator

                           J. Charles Fox
                 Assistant Administrator, Office of Water

                         Geoffrey H. Grubbs
                 Director, Office of Science and Technology

                           Sheila £. Frace
                Director, Engineering and Analysis Division

                          Elwood H. Forsht
                   Chief, Chemicals and Metals Branch
                         Samantha Hopkins
                          Project Manager
                           January 2000
                  U.S. Environmental Protection Agency
                           Office of Water
                        Washington, DC 20460

              Additional Support by Contract No. 68-C5-0041

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ACKNOWLEDGEMENTS AND DISCLAIMER

This document has been reviewed and approved for publication by the Engineering and Analysis Division,
Office of Science and Technology, U.S. Environmental Protection Agency. This document was prepared
with the support of Science Applications International Corporation under Contract 68-C5-0041, under
the direction and review of the Office of Science and Technology. Neither the United States government
nor any of its employees, contractors, subcontractors, or other employees makes any warranty, expressed
or implied, or assumes any legal liability or responsibility for any third parly's use of, or the results of such
use of, any information, apparatus, product or process discussed in this report, or represents that its use
by such a third party would not infringe on privately owned rights.

Credit must also be given to the additional members of the CHWC project team (William Anderson,
Charles White, Patricia Harrigan, and Richard Witt) for their professional manner, conscientious effort and
contributions.

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                          TABLE OF CONTENTS

SECTION 1   LEGAL AUTHORITY  	1-1
      1.1    LEGAL AUTHORITY  	1-1
      1.2    BACKGROUND	1-1
            1.2.1  Clean Water Act (CWA)	1-1
                 1.2.1.1 Best Practicable Control Technology Currently Available (BPT)
                       (Section 304(b)(l) of the CWA) 	1-1
                 1.2.1.2 Best Conventional Pollutant Control Technology (BCT)
                       (Section 304(a)(4) of the CWA) 	1-2
                 1.2.1.3 Best Available Technology Economically Achievable (BAT)
                       (Sections 304(b)(2)(B) of the CWA)	1-2
                 1.2.1.4 New Source Performance Standards (NSPS)
                       (Section 306 of the CWA)	1-3
                 1.2.1.5 Pretreatment Standards for Existing Sources (PSES)
                       (Section 307(b) of the CWA)	1-3
                 1.2.1.6 Pretreatment Standards for New Sources (PSNS)
                       (Section 307(b) of the CWA)	1-4
      1.2    SECTION 304(M) REQUIREMENTS	1-4

SECTION 2   DATA COLLECTION	2-1
      2.1    CLEAN WATER ACT SECTION 308 QUESTIONNAIRES AND
            SCREENER SURVEYS  	2-2
            2.1.1  Development of Questionnaires and Screener Surveys	2-2
            2.1.2  Distribution of Screener Surveys and Questionnaires	2-4
      2.2    SAMPLING PROGRAM  	2-6
            2.2.1  Pre-1989 Sampling Program	2-6
            2.2.2  1993 -1995 Sampling Program	2-6
                 2.2.2.1 Facility Selection	2-6
                 2.2.2.2 Five-Day Sampling Episodes	2-8

SECTION 3   DESCRIPTION OF THE INDUSTRY AND SUBCATEGORIZATION .... 3-1
      3.1    GENERAL INFORMATION 	3-1
      3.2    SCOPE OF THIS REGULATION	3-3
            3.2.1  CHWC Facilities  	3-3
            3.2.2  Captive and Intracompany CHWC Facilities	3-3
      3.3    SUMMARY INFORMATION ON 55 CHWC FACILITIES	3-6
      3.4    SUMMARY INFORMATION ON 22 CHWC FACILITIES WHICH
            GENERATE CHWC WASTEWATER 	3-9
            3.4.1  RCRA Designation of 22 CHWC Facilities  	3-10
            3.4.2  Waste Burned at 22 CHWC Facilities	3-10

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           3.4.3  Air Pollution Control Systems for 22 CHWC Facilities	3-11
      3.5   SUMMARY INFORMATION ON 10 CHWC FACILITIES WHICH
           GENERATE AND DISCHARGE CHWC WASTEWATER	3-13
      3.6   INDUSTRY SUBCATEGORIZATION	3-14

SECTION 4  WASTEWATER USE AND WASTEWATER CHARACTERIZATION .... 4-1
      4.1   WATER USE AND SOURCES OF WASTEWATER	4-1
      4.2   WATER USE	4-2
      4.3   WASTEWATER CHARACTERIZATION  	4-3
           43.1  Five-Day Sampling Episodes	44
                 43.1.1 Conventional Pollutants	4-4
                 43.1.2 Priority and Non-Conventional Pollutants	4-7
           43.2  Characterization Sampling Episodes	4-7
      4.4   WASTEWATER POLLUTANT DISCHARGES	4-8

SECTIONS  SELECTION OF POLLUTANTS AND POLLUTANT PARAMETERS FOR
           REGULATION 	5-1
      5.1   INTRODUCTION	5-1
      52   POLLUTANTS CONSIDERED FOR REGULATION 	5-1
      53   SELECTION OF POLLUTANTS OF CONCERN	5-2
           53.1  Dioxins/Furans in Commercial Hazardous Waste Combustor Industry 5-7
                 53.1.1 Background 	5-7
                 53.1.2 Dioxins/Furans in Commercial Hazardous Waste Combustor
                      Wastewater	5-8
      5.4   SELECTION OF POLLUTANTS FOR REGULATION	5-11
      5.5   SELECTION OF POLLUTANTS TO BE REGULATED FOR PSES AND
           PSNS  	5-14
           5 J.I  Removal Comparison Approach	5-14
           5.5.2  50 POTW Study Database	5-15
           533  Fmal POTW Data Editing	5-16
           5.5.4  Final Removal Comparison Results	5-17

SECTION 6  WASTEWATER TREATMENT TECHNOLOGIES	6-1
      6.1   AVAILABLE BAT AND PSES TECHNOLOGIES	6-2
           6.1.1  Physical/Chemical Treatment 	6-2
                 6.1.1.1 Equalization	6-2
                 6.1.1.2 Neutralization or pH Control	6-3
                 6.1.13 Flocculation	6-6
                 6.1.1.4 Gravity-Assisted Separation  	6-6
                 6.1.1.5 Chemical Precipitation	6-7
                 6.1.1.6 Stripping	6-13
                                   u

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                  6.1.1.7 Filtration	6-13
                        6.1.1.7.1     Saiid/Miito-Media Filtration 	6-15
                        6.1.1.72     f stone Filters 	6-17
                        6.1.1.7.3     Utaafihration	6-17
                  6.1.1.8 Carbon Adsorption	6-19
                  6.1.1.9 Chromium Reduction	6-21
            6.1.2  Sludge Handling	6-21
                  6.1.2.1 Stodge Stanymg  	6-23
                  6.122 Vacuum FihraOon  	6-23
                  6.1.23 Pressure Filtration  	6-23
                  6.1.2.4 Centrifuges	6-26
                  6.125 Dryer  	6-26
            6.13  Zero Discharge Options	6-27
                  6.13.1 Incineration  	6-27
                  6.13.2 Off-Site Disposal	6-27
                  6.133 Evaporation/Land Applied	6-27
      62    TREATMENT OPTIONS FOR OTHER WASTEWATERS GENERATED BY
            CHWC OPERATIONS      	6-28
            62.1  Chemical Oxidation	6-28
            622  Zero Discharge Options	6-29
                  622.1 Deep Well Disposal	6-31
      63    OTHER ON-SITE WASTEWATER TREATMENT TECHNOLOGIES ... 6-31
      6.4    TREATMENT PERFORMANCE AND DEVELOPMENT OF REGULATORY
            OPTION	6-32
            6.4.1  Performance of EPA Sampled Treatment Processes	6-32
                  6.4.1.1 Treatment Performance for Episode #4646	6-32
                  6.4.12 Treatment Performance for Episode #4671	6-39
                  6.4.13 Treatment Performance for Episode #4733	6-44
            6.4.2  Rationale Used for Selection of BAT Treatment Technologies 	6-48
            6.43  Performance at Facilities Added Post-Proposal	6-53
                  6.43.1 Treatment Performance for Episode # 6181  	6-53
                  6.432 Treatment Performance for Episode #6183  	6-57
                  6.433 Performance Comparison with Proposed BAT Facility	6-60

SECTION 7  ENGINEERING COSTS	7-1
      7.1    COSTS DEVELOPMENT	7-2
            7.1.1  Sources of Cost Data	7-2
                  7.1.1.1 Cost Models	7-2
                  7.1.12 Vendor Data	7-4
                  7.1.13 1992 Waste Treatment Industry Phase II: Incinerators 308
                        Questionnaire Costing Data	7-4

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                  7.1.1.4 Other EPA Effluent Guideline Studies  	7-4
            7.1.2  Benchmark Analysis and Evaluation Criteria 	7-4
            7.1.3  Selection of Final Cost Models	7-8
      7.2   ENGINEERING COSTING METHODOLOGY 	7-9
            7.2.1  Treatment Costing Methodology	7-9
            7.2.2  Option Costing Methodology	7-11
      7.3   TREATMENT TECHNOLOGIES COSTING	7-14
            7.3.1  Physical/Chemical Wastewater Treatment Technology Costs	7-14
                  7.3.1.1 Chemical Feed Systems	7-15
                  7.3.1.2 Pumping	7-33
                  7.3.1.3 RapidMixTanks	7-33
                  7.3.1.4 Flocculation	7-38
                  7.3.1.5 Primary Clarification	7-41
                  7.3.1.6 Secondary Clarification	7-41
                  7.3.1.7 Sand Filtration	7-44
            7.3.2  Sludge Treatment and Disposal	7-48
                  7.3.2.1 Plate and Frame Pressure Filtration	7-48
                  7.3.2.2 Filter Cake Disposal Costs	7-51
      7.4   ADDITIONAL COSTS	7-51
            7.4.1  Retrofit and Upgrade Costs	7-52
            7.4.2  Land Costs	7-52
            7.4.3  RCRA Permit Modification Costs	7-53
            7.4.4  Monitoring Costs	7-53
      7.5   WASTEWATER OFF-SITE DISPOSAL COSTS 	7-55
      7.6   COSTS FOR REGULATORY OPTIONS  	7-56
            7.6.1  BPT/BCT/BAT  Costs 	7-56
                  7.6.1.1 BPT/BCT/BAT Option: Two-Stage Chemical Precipitation and
                        Sand Filtration	7-56
            7.6.2  PSES Costs 	7-56
                  7.6.2.1 PSES Option: Two-Stage Chemical Precipitation and Sand
                        Filtration	7-57
            7.6.3  New Source Performance Standards Costs	7-57
            7.6.4  Pretreatment Standards for New Sources Costs	7-57

SECTION 8  DEVELOPMENT OF LIMITATIONS AND STANDARDS	8-1
      8.1   ESTABLISHMENT OF BPT/BCT/BAT/PSES  	8-1
      8.2   NSPS 	8-7
      8.3   PSNS 	8-8
      8.4   COST OF TECHNOLOGY OPTIONS	8-9
            8.4.1  BPTandPSES Costs	8-9
            8.4.2  BCT and BAT Costs 	8-10

                                       iv

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      8.5   POLLUTANT REDUCTIONS  	8-10
            8.5.1  Conventional Pollutant Reductions	8-10
            8.5.2  Priority and Non-conventional Pollutant Reductions 	8-10
                  8.5.2.1 Methodology  	8-10
                  8.5.2.2 Direct and Indirect Discharges (BPT/BCT/BAT) and (PSES) 8-11

SECTION 9  NON-WATER QUALITY IMPACTS 	9-1
      9.1   AIRPOLLUTION	9-1
      9.2   SOLID WASTE	9-2
      9.3   ENERGY REQUIREMENTS	9-3

Appendix A  Listing of CHWC Analytes with at Least One Detect

Appendix B  Listing of CHWC Analytes with No Detects

Appendix C  Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-
            Day EPA Sampling Episodes for all Analytes

Appendix D  ACRONYMS AND DEFINITIONS
                                      v

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                                 LIST OF TABLES
3-1    Non-Commercial Grab Sample Episode Data	3-5
3-2    Comparison of Non-Commercial and Commercial Data	3-6
3-3    Number ofThermal Units at Each of the 55 CHWC Facility Locations	3-7
3-4    Types ofThermal Units at 55 CHWC Facilities	3-7
3-5    Amount of Waste Treated by 55 Commercial Facilities in Calender Year 1992 (Tons) 3-8
3-6    Quantity of Process Wastewater Generated by 55 CHWC Facilities in Calender Year
       1992 (Thousand Gallons)	3-9
3-7    1992 RCRA Designation of 22 Commercial Facilities	3-10
3-8    Number of Customers/Facilities Served in 1992 by 22 Commercial Facilities	3-10
3-9    Types of Air Pollution Control Systems at 22 Commercial Facilities	3-11
3-10   Air Pollutants for Which Add-On Control Systems are in Operation for 22
       Commercial Facilities  	3-12
3-11   Scrubbing Liquor Used in Air Pollution Control Systems of 22 Commercial
       Facilities	3-12
3-12   Type of Water Recirculation System Used in Air Pollution Control Systems of the 22
       CHWC Facilities	3-13
4-1    Amount of CHWC  Wastewater Discharged 	4-3
4-2    Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three
       Five-Day EPA Sampling Episodes (ug/1)  	4-5
4-3    Range of Pollutant Influent Concentrations of the Pooled Daily Data from the
       Characterization EPA Sampling Episodes (ug/1)	4-7
4-4    CHWC Industry 1992 Discharge Concentration	4-11
5-1    Pollutants Detected Only During Wastewater Characterization Sampling	5-2
5-2    Pollutants Not Detected Three or More Times Above MDL	5-3
5-3    Pollutants Only Found During Sampling Episodes 4733 and 4671	5-4
5-4    Pollutants Not Detected Three or More Times at an Average Influent Concentration
       Greater Than or Equal To 10 Times the MDL	5-5
5-5    Pollutants Not Treated by the BAT Treatment System	5-6
5-6    Pollutants Indirectly Controlled Through Regulation of Other Pollutants  	5-6
5-7    Dioxins and Furans Eliminated as Pollutants of Concern	5-6
5-8    Breakdown of Detected Dioxins/Furans During CHWC Sampling Program	5-8
5-9    Pollutants Selected  for Regulation	5-10
5-10   Sampling Episode 6181 Analytical Results	5-12
5-11   Sampling Episode 6183 Analytical Results	5-13
5-12   Final POTW Removals for CHWC Industry Pollutants  	5-16
5-13   Sampling Episode Percent Removals  	5-17
5-14   Final Results for CHWC Industry Regulatory Option	5-18
6-1    Description of CHWC Sampling Episodes	6-33

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                                 LIST OF TABLES
6-2   Treatment Technology Performance for Facility 4646 	6-36
6-3   Treatment Technology Performance for Facility 4671 	6-41
6-4   Treatment Technology Performance for Facility 4733 	6-46
6-5   Primary Chemical Precipitation Treatment Technology Performance Comparison  .. 6-50
6-6   Secondary Chemical Precipitation and Filtration Treatment Technology Performance
      Comparison	:	6-51
6-7   Description of CHWC Sampling Episodes	6-54
6-8   Treatment Technology Performance for Episode 6181	6-58
6-9   Treatment Technology Performance for Episode 6183	-.	6-59
6-10  Treatment Technology Performance Comparison	6-61
7-1   Costing Source Comparison 	7-6
7-2   Breakdown of Costing Method by Treatment Technology	7-10
7-3   Additional Cost Factors	7-11
7-4   Regulatory Option Wastewater Treatment Technology Breakdown	7-13
7-5   Chemical Addition Design Method	7-16
7-6   Treatment Chemical Costs	7-16
7-7   Sodium Hydroxide Requirements for Chemical Precipitation  	7-18
7-8   State Land Costs  	7-53
7-9   Analytical Monitoring Costs 	7-55
7-10  Summary of Costs - BPT/BCT/BAT/PSES Final	7-58
7-11  Summary of Costs - NSPS/PSNS  	7-58
8-1   BPT/BCT/BAT Effluent Limitations (ug/1)	8-5
8-2   PSES Pretreatment Standards (ug/1)  	8-6
8-3   Direct and Indirect Discharge Loads (in Ibs.) 	8-11
                                         VII

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                                LIST OF FIGURES
6-1    Equalization	6-4
6-2    Neutralization	6-5
6-3    Clarification System Incorporating Coagulation and Flocculation	6-8
6-4    Calculated Solubilities of Metal Hydroxides	6-11
6-5    Chemical Precipitation System Design	6-12
6-6    Typical Air Stripping System	6-14
6-7    Multimedia Filtration	6-16
6-8    Ultrafiltration System Diagram	6-18
6-9    Granular Activated Carbon Adsorption	6-20
6-10   Chromium Reduction	6-22
6-11   Vacuum Filtration  	6-24
6-12   Plate and Frame Pressure Filtration System Diagram	6-25
6-13   Cyanide Destruction	6-30
6-14   EPA Sampling Episode 4646 - CHWC Wastewater Treatment System Block Flow
       Diagram with Sampling Locations 	6-34
6-15   EPA Sampling Episode 4671 - CHWC Wastewater Treatment System Block Flow
       Diagram with Sampling Locations 	6-40
6-16   EPA Sampling Episode 4733 - CHWC Wastewater Treatment System Block Flow
       Diagram with Sampling Locations 	6-45
6-17   EPA Sampling Episode 6181 - CHWC Wastewater Treatment System Block Flow
       Diagram with Sampling Locations 	6-55
6-18   EPA Sampling Episode 6183 - CHWC Wastewater Treatment System Block Flow
       Diagram with Sampling Locations 	6-56
7-1    Option-Specific Costing Logic Flow Diagram  	7-12
7-2    Sodium Hydroxide Capital Cost Curve	7-19
7-3    Sodium Hydroxide O&M Cost Curve	7-20
7-4    Ferric Chloride Capital Cost Curve	7-23
7-5    Ferric Chloride O&M Cost Curve	7-24
7-6    Sodium Bisulfite Capital Cost Curve	7-25
7-7    Sodium Bisulfite O&M Cost Curve	7-26
7-8    Hydrochloric  Acid Capital Cost Curve	7-28
7-9    Hydrochloric  Acid O&M Cost Curve	7-29
7-10   Polymer Feed Capital Cost Curve	7-31
7-11   Polymer Feed O&M Cost Curve	7-32
7-12   Wastewater Pumping Capital Cost Curve	7-34
7-13   Wastewater Pumping O&M Cost Curve	7-35
7-14   Mix Tank Capital Cost Curve 	7-36
7-15   Mix Tank O&M Cost Curve 	7-37
                                        V1I1

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                               LIST OF FIGURES
7-16  Flocculation Capital Cost Curve 	7-39
7-17  Flocculation O&M Cost Curve 	7-40
7-18  Primary Clarifier Capital Cost Curve	7-42
7-19  Primary Clarifier O&M Cost Curve	7-43
7-20  Secondary Clarifier Capital Cost Curve	7-45
7-21  Secondary Clarifier O&M Cost Curve	7-46
7-22  Sand Filtration Capital Cost Curve 	7-47
7-23  Sludge Dewatering Capital Cost Curve	7-49
7-24  Sludge Dewatering O&M Cost Curve	7-50
                                        IX

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SECTION 1
LEGAL AUTHORITY

1.1           LEGAL AUTHORITY

       Effluent limitations guidelines and standards for the Commercial Hazardous Waste Combustor
Industry (formerly Industrial Waste Combustor Industry) are promulgated underthe authority of Sections
301,304,306,307,308 and 501 of the Clean Water Act, 33 U.S.C. 1311,1314,1316,1317,1318,
1342, and 1361.

1.2           BACKGROUND
1.2.1         Clean Water Act (CWA)

       The Federal Water Pollution Control Act Amendments of 1972 established a comprehensive
program to "restore and maintain the chemical, physical, and biological integrity of the Nation's waters."
(Section 101 (a)).  To implement the Act, EPA is to issue effluent limitations guidelines, pretreatment
standards and new source performance standards for industrial discharges. These guidelines and standards
are summarized briefly in the following sections.

1.2.1.1       Best Practicable Control Technology Currently Available (BPT)
             (Section 304(b)(l)  of the CWA)

       In the guidelines for an industry category, EPA defines BPT effluent limits for conventional, priority,
and non-conventional pollutants. In specifying BPT, EPA looks at a number of factors. EPA first
considers the cost of achieving effluent reductions in relation to the effluent reduction benefits. The Agency
next considers: the age of the equipment and facilities; the processes employed and any required process
changes; engineering aspects of the control technologies; non-water quality environmental impacts (including
energy requirements); and such other factors as the Agency deems appropriate (CWA §304(b)(l )(B)).
                                          1-1

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Traditionally, EPA establishes BPT effluent limitations based on the average of the best performances of
facilities within the industry of various ages, sizes, processes or other common characteristics. Where,
however, existing performance within a category or subcategory is uniformly inadequate, EPA may require
higher levels of control than currently in place in an industrial category (or subcategory) if the Agency
determines that the technology can be practically applied.

1.2.1.2        Best Conventional Pollutant Control Technology (BCT)
              (Section 304(a)(4) of the CWA)

       The 1977 amendments to the CWA required EPA to identify effluent reduction levels for
conventional pollutants associated with BCT technology for discharges from existing industrial point
sources. In addition to other factors specified in Section 304(b)(4)(B), the CWA requires that EPA
establish BCT limitations after consideration of a two part "cost-reasonableness" test EPA explained its
methodology for the development of BCT limitations in the July 1986 Federal Register (51 FR 24974).
       Section 304(a)(4) designates the following as conventional pollutants: five day biochemical oxygen
demand (BOD$), total suspended solids (TSS), fecal coliform, pH, and any additional pollutants defined
by the Administrator as conventional. The Administrator designated oil and grease as an additional
conventional pollutant on July 30,1979 (44 FR 44501).

1.2.13        Best Available Technology Economically Achievable (BAT)
              (Section 304(b)(2)(B) of the CWA)

       In general, BAT effluent limitations guidelines represent the best economically achievable
performance of plants in the industrial subcategory or category. The factors considered in assessing BAT
include the cost of achieving BAT effluent reductions, the age of equipment and facilities involved, the
process employed, potential process changes, and non-water quality environmental impacts, including
energy requirements. The Agency retains considerable discretion in assigning the weight to be accorded
these factors. Unlike BPT limitations, BAT limitations may be based on effluent reductions attainable
through changes in a facility's processes and operations.  As with BPT, where existing performance is
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uniformly inadequate, BAT may require a higher level of performance than is currently being achieved
based on technology transferred from a different subcategory or category.  BAT may be based upon
process changes or internal controls, even when these technologies are not common industry practice.

1.2.1.4        New Source Performance Standards (NSPS)
              (Section 306 of the CWA)

       NSPS reflect effluent reductions that are achievable based on the best available demonstrated
control technology. New facilities have the opportunity to install the best and most efficient production
processes arid wastewater treatment technologies. As a result, NSPS should represent the most stringent
controls attainable through the application of the best available control technology for all pollutants (i.e.,
conventional, non-conventional, and priority pollutants). In establishing NSPS, EPA is directed to take into
consideration the cost of achieving the effluent reduction and any non-water quality environmental impacts
and energy requirements.

1.2.1.5        Pretreatment Standards for Existing Sources (PSES)
              (Section 307(b) of the CWA)

       PSES are designed to prevent the discharge of pollutants that pass through, interfere with, or are
otherwise incompatible with the operation of publicly owned treatment works (POTW). The CWA
authorized EPA to establish pretreatment standards for pollutants that pass through POTWs or interfere
with treatment processes or sludge disposal  methods at the POTW. Pretreatment standards are
technology-based and analogous to BAT effluent limitations guidelines.
       The general Pretreatment Regulations, which set forth the framework for the implementation of
categorical pretreatment standards, are found in 40 CFR Part 403.  Those regulations contain a definition
of pass through that addresses localized rather than national instances of pass through and establish
pretreatment standards that apply to all non-domestic dischargers (see 52 FR1586, January 14,1987).
                                          1-3

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1.2.1.6        Pretreatment Standards for New Sources (PSNS)
              (Section 307(b) of the CWA)

       Like PSES, PSNS are designed to prevent the discharges of pollutants that pass through, interfere
with, or are otherwise incompatible with the operation of POTWs. PSNS are to be issued at the same time
as NSPS. New indirect dischargers have the opportunity to incorporate into their plants the best available
demonstrated technologies. The Agency considers the same factors in promulgating PSNS as it considers
in promulgating NSPS.

1.2.2         Section 304(m) Requirements

       Section 304(m) of the Act (33 U.S.C. 1314(m)), added by the Water Quality Act of 1987,
requires EPA to establish schedules for (1) reviewing and revising existing effluent limitation guidelines and
standards ("effluent guidelines"), and (2) promulgating new effluent guidelines. On January 2,1990, EPA
published an Effluent Guidelines Plan (55 FR 80), that included schedules for developing new and revised
effluent guidelines for several industry categories. One of the industries for which the Agency established
a schedule was the Hazardous Waste Treatment Industry.
       The Natural Resources Defense Council (NRDC) and Public Citizen, Inc. filed suit against the
Agency, alleging violation of Section 304(m) and other statutory authorities requiring promulgation of
effluent guidelines flSfRDC et al. v. Reillv. Civ. No. 89-2980 (D.D.C.Y). Under the terms of the consent
decree in that case, as amended, EPA agreed, among other things, to propose effluent guidelines for the
"Landfills and Industrial Waste Combusters" category by November 1997 and final action by November
1999. Although the Consent Decree lists "Landfills and Industrial Waste Combusters" as a single entry,
EPA is publishing separate regulations for Industrial Waste Combusters and for Landfills.
       hi order to reflect accurately the segment of the combustion industry being regulated today, EPA
has now changed the name for this final regulation from "Industrial Waste Combustor" to "Commercial
Hazardous Waste Combustor" regulations.
                                           1-4

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SECTION 2
DATA COLLECTION

       In 1986, the Agency initiated a study of waste treatment facilities which receive waste from off site
for treatment, recovery, or disposal. The Agency looked at various segments of the waste management
industry including combustors, centralized waste treatment facilities, landfills, fuel blending operations, and
waste solidification/stabilization processes (Preliminary Data Summary forthe Hazardous Waste Treatment
Industry, EPA 440-1-89-100, September 1989).
       Developmentofeffluent limitations guidelines and standards forthe Commercial Hazardous Waste
Combustor (CHWC) (formerly Industrial Waste Combustor (IWQ) Subcategory began in 1993.  EPA
originally looked at RCRA hazardous waste incinerators, RCRA boilers and industrial furnaces (BIFs), and
non-hazardous combustion units that treat industrial waste. Sewage sludge incinerators, municipal waste
incinerators, and medical waste incinerators were not included in the 1989 study or in the initial data
collection effort in 1993. EPA limited the proposed rulemaking to the development of regulations for
industrial waste combustors. Based on comments received on the proposed rulemaking, EPA has limited
the final rulemaking to regulations for Commercial Hazardous Waste Combustors.
       EPA has gathered and evaluated technical and economic data from various sources in the course
of developing the final effluent limitations guidelines and standards for the CHWC Industry. These data
sources include:

       •      Responses to EPA's " 1992 Waste Treatment Industry Phase II: Incinerators Screener
              Survey,"
       •      Responses to EPA's  "1994 Waste Treatment Industry Phase  II:  Incinerators
              Questionnaire,"
       •      Responses to EPA's " 1994 Detailed Monitoring Questionnaire,"
       •      EPA's 1993 -1995 sampling of selected CHWC facilities,
       •      Literature data, and
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              Facility NPDES and POTW wastewater discharge permit data.

       EPA has used data from these sources to profile the industry with respect to: wastes received for
treatment or recovery, treatment/recovery processes, geographical distribution, and wastewater and solid
waste disposal practices. EPA then characterized the wastewater generated by treatment/recovery
operations through an evaluation of water usage, type of discharge or disposal, and the occurrence of
conventional, non-conventional and priority pollutants.

2.1           CLEAN WATER ACT SECTION 308 QUESTIONNAIRES AND SCREENER
              SURVEYS
2.1.1         Development of Questionnaires and Screener Surveys

       A major source of information and data used in developing effluent limitations guidelines and
standards is industry responses to questionnaires and screener surveys distributed by EPA under the
Authority of Section 308 of the Clean Water Act (CWA). The questionnaires typically request information
concerning treatment processes, wastes received for treatment, and disposal practices as well as
wastewater treatment system performance data. Questionnaires also request financial and economic data
for use in assessing economic impacts and the economic achievability of technology options. Screener
surveys generally request less detailed information than the questionnaires regarding treatment processes,
wastes received for treatment and disposal practices.
       EPA used its experience with previous questionnaires to develop one screener survey (the 1992
Waste Treatment Industry Phase II:  Incinerators Screener Survey) and two questionnaires (the 1994
Waste Treatment Industry Phase n: Incinerators Questionnaire and the Detailed Monitoring Questionnaire)
for this project The 1992 Waste Treatment Industry Phase II: Incinerators Screener Survey was designed
to obtain general infomation on facility operations from a census of the industry. The 1994 Waste
Treatment Industry Phase II: Incinerators Questionnaire was designed to request 1992 technical,
economic, and financial data to describe industrial operations adequately from a census of facilities in the
industry that were operating commercially and from a sample of facilities in the industry that were not
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operating commercially. The Detailed Monitoring Questionnaire was designed to elicit daily analytical data
from a limited number of facilities which would be selected after receipt and review of the 1994 Waste
Treatment Industry Phase II: Incinerators Questionnaire responses.
       For the 1994 Waste Treatment Industry Phase II: Incinerators Questionnaire, EPA wanted to
minimize the burden to industrial waste combustor facilities.  Thus, only a statistical sample of the non-
commercial facilities meeting the preliminary scope qualifications received the 1994 Waste Treatment
Industry Phase II: Incinerators Questionnaire. The questionnaire specifically requested information on:

       •       combustion processes,
       •       types of waste received  for combustion,
       •       wastewater and solid waste disposal practices,
              ancillary waste management operations,
       •       summary analytical monitoring data,
       •       the degree of co-combustion (combustion of waste received from off-site with other on-
              site industrial waste),
       •       cost of waste combustion processes, and
       •       the extent of wastewater recycling or reuse at facilities.

       In the 1994 Waste Treatment Industry Phase II:  Incinerators Questionnaire, EPA requested
summary monitoring data from all recipients, but summary information is not sufficient for determining
limitations and industry variability. Therefore, the Detailed Monitoring Questionnaire was designed to
collect daily analytical data from a limited number of facilities. Facilities were chosen to complete the
Detailed Monitoring Questionnaire based on technical information submitted in the 1994 Waste Treatment
Industry Phase II: Incinerators Questionnaire. The burden was minimized in the Detailed Monitoring
Questionnaire by tailoring the questionnaire to the facility operations.
       EPA sent draft screener surveys and questionnaires to industry trade associations, incinerator
facilities who had expressed interest, and environmental groups for review and comment. A pre-test for
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both the 1992 Waste Treatment Industry Phase It Incinerators Screener Survey and the 1994 Waste
Treatment Industry Phase II: Incinerators Questionnaire was conducted at nine industrial waste combustor
facilities to determine if the type of information necessary would be received from the questions posed as
well as to determine if questions were designed to minimize the burden to facilities.
       Based on comments from the reviewers, EPA modified the draft questionnaire.
       As required by the Paperwork Reduction Act, 44 U.S.C. 3501 et seq., EPA submitted the
Questionnaire package (including the 1992 Waste Treatment Industry Phase II: Incinerators Screener
Survey and the 1994 Waste Treatment Industry Phase II: Incinerators Questionnaire and the Detailed
Monitoring Questionnaire) to the Office of Management and Budget (OMB) for review.  EPA also
redistributed the questionnaire package to industry trade associations, industrial waste combustor facilities,
environmental groups, and to any others who requested a copy of the questionnaire package.

2.1.2         Distribution of Screener Surveys and Questionnaires

       Under the authority of Section 308 of the Clean Water Act, EPA sent the 1992 Waste Treatment
Industry Phase II: Incinerators Screener Survey (OMB Approval Number 2040-0162, Expired: 08/31/96)
in September 1993 to 606 facilities that the Agency had identified as possible industrial waste combustor
facilities. EPA identified the 606 facilities as possible industrial waste combustor facilities from various
sources; such as, companies listed in the 1992 Environmental Information (El) Directory, companies that
were listed as incinerators in the RCRIS National Oversight Database (November, 1992 and February,
1993 versions), companies that were listed as BIF Facilities by EPA (updated December, 1992), and
incinerator facilities identified in the development of the Centralized Waste Treatment (CWT) effluent
guidelines.  Since industrial waste combustors were not represented by a SIC code at the time of the
survey, identification of facilities was difficult The screener survey requested summary information on: (1)
the types of wastes accepted for combustion; (2) the types of combustion units at a facility;  (3) the
quantity, treatment, and disposal of wastewater generated from combustion operations; (4) available
analytical monitoring data on wastewater treatment; and (5) the degree of co-treatment (treatment of
CHWC wastewater with wastewater from other industrial operations at the facility). The responses from
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 564 facilities indicated that 357 facilities burned industrial waste in 1992. The remaining 207 did not bum
 industrial waste in 1992. Of the 357 facilities that burned industrial waste, 142 did not generate any
 wastewater from air pollution control systems or water used to quench flue gas or slag generated as a result
 of their combustion operations. Of the remaining 215 facilities that generated these types of wastewater,
 59 operated commercially, and 156 only burned wastes generated on site, and/or only burned wastes
 generated from off-site facilities under the same corporate  structure.
       Following an analysis of the screener survey results, EPA sent the 1994 Waste Treatment Industry
 Phase II: Incinerators Questionnaire (OMB Approval Number 2040-0167, Expired: 12/31/96) in March,
 1994 to selected facilities which burned industrial waste and generated wastewater from air pollution
 control systems or water used to quench flue gas or slag generated as a result of their combustion
 operations. EPA sent the questionnaire to all 59 of the commercial facilities and all 16 of the non-
 commercial facilities that burned non-hazardous industrial waste. Further, EPA sent 32 of the remaining
 140 non-commercial facilities a questionnaire. These thirty-two were selected based on a statistical
 random sample. The questionnaire specifically requested information on:  (1) the type of wastes accepted
 for treatment; (2) the types of combustion units at a facility; (3) the types of air pollution control devices
 used to control emissions from the combustion units at a facility; (4) the quantity, treatment, and disposal
 of wastewater generated from combustion operations; (5) available analytical monitoring data on
 wastewater treatment; (6) the degree of co-treatment (treatment of industrial waste combustor wastewater
 with wastewater from other industrial operations at the facility); and (7) the extent of wastewater recycling
 and/or reuse at the facility. Information was also obtained through follow-up telephone calls and written
requests for clarification of questionnaire responses.
       EPA also requested a subset of industrial waste combustor facilities that received a questionnaire
to submit wastewater monitoring data in the form of individual data points rather than monthly or annual
aggregates. Only facilities that had identified a sample point location where the stream was over 50 percent
wastewater from air pollution control systems or water used to quench flue gas or slag generated as a result
of their combustion operations received the Detailed Monitoring Questionnaire.  These wastewater
monitoring data included information on pollutant concentrations at various points in the wastewater
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treatment processes. Data were requested from 26 facilities.  Sixteen of these facilities operated
commercially and 10 operated non-commercially.

2.2           SAMPLING PROGRAM
2.2.1         Pre-1989 Sampling Program

       In the samplingprogram forthe 1989 Hazardous Waste Treatment Industry Study, twelve facilities
were sampled to characterize the wastes received and evaluate the on-site treatment technology
performance at combustors, landfills, and hazardous waste treatment facilities. Since all of the facilities
sampled had more than one on-site operation (e.g., combustion and landfill leachate generation), the data
collected can not be used for mis project because data were collected for mixed waste streams and the
waste characteristics and treatment technology performance for the combustor facilities cannot be
differentiated. Information collected in the study is presented in the Preliminary Data Summary for the
Hazardous Waste Treatment Industry (EPA 440/1-89/100, September 1989).

2.2.2         1993 -1995 Sampling Program
2.2.2.1        Facility Selection

       Between 1993 and 1995, EPA visited 14 industrial waste combustor facilities. Eight of the fourteen
industrial waste combustors EPA visited were captive facilities because captive facilities were still being
considered for inclusion in the scope of the CHWC regulation at the time of the site visits.  During each
visit, EPA gathered the following information:

       •       the process for accepting waste for combustion,
       •       the types of waste accepted for combustion,
       •       design and operating procedures for combustion technologies,
       •       general facility management practices,
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       •      water discharge options,
       •      solid waste disposal practices, and
       •      other facility operations.

EPA also took one grab sample of untreated industrial waste combustor scrubber blowdown water at
twelve of the fourteen facilities.  EPA analyzed most of these grab samples for over 450 anarytes to identify
pollutants at these facilities. The grab samples from the twelve site visits allowed EPA to assess whether
there was a significant difference in raw wastewater characteristics from a wide variety of combustion unit
types. (See Section 3 for a description of the types of combustion units.)  EPA determined that the raw
wastewater characteristics were similar for all types of combustion units both in types of pollutants found
and the concentrations of the pollutants found.  Specifically, organics, pesticides/herbicides, and
dioxins/furans were generally only found, if at all, in low concentrations in the grab samples. (See Section
5 of this document for a discussion of dioxins/furans found at 7 of the 12 CHWC facilities sampled.)
However, a variety of metal anarytes were found in significant concentrations in the grab samples.
       Based on these data and the responses to the 1994 Waste  Treatment Industry Phase II:
Incinerators Questionnaire, EPA selected three of the industrial waste combustor facilities for the BAT
sampling program in order to collect data to characterize discharges and the performance of selected
treatment systems. Using data supplied by the facilities, EPA applied five criteria in initially selecting which
facilities to sample. Tlieoiteria were based on whether me wastewater treatment system: (1) was effective
in removing pollutants, (2) treated wastes received from a variety of sources (solids as well as liquids), (3)
employed either novel treatment technologies  or applied traditional treatment technologies in a novel
manner, (4) applied waste management practices that increased the effectiveness of the treatment unit, and
(5) discharged its treated wastewater under a NPDES permit The other 11 facilities visited were not
sampled because they did not meet these criteria.  Eight of these 11 facilities visited did not operate
commercially, and are thus no longer included in the CHWC Industry.
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2.2.2.2       Five-Day Sampling Episodes

       After a facility was chosen to participate in the five-day sampling program, a draft sampling plan
was prepared which described the location of sample points and analyses to be performed at specific
sample points as well as the procedures to be followed during the sampling episode.  Prior to sampling, a
copy of the draft sampling plan was provided to the facility for review and comment to ensure that EPA
properly described and understood facility operations. All comments were incorporated into the final
sampling plan. During the sampling episode, teams of EPA employees and contractors collected and
preserved samples. Samples were sent to EPA approved laboratories for analysis.  Samples were
collected at influent and effluent points. Samples were also taken at intermediate points to assess the
performance of individual treatment units. Facilities were given the option to split all samples with EPA,
but most facilities split only effluent sample points with EPA. Following the sampling episode, a draft
sampling report was prepared that included descriptions of the treatment/recovery processes, sampling
procedures and analytical results. After all information was gathered, the reports were provided to the
facilities for review and comment Corrections were incorporated into the final report The facilities also
identified any information in the draft sampling report that were considered to be Confidential Business
Information.
       During each sampling episode, wastewater treatment system influent and effluent streams were
sampled Samples were also taken at intermediate points to assess the performance of individual treatment
units. Selected sampling information is summarized in Section 4 and Appendix A of this document. In all
sampling episodes, samples were analyzed for over 450 analytes to identify the pollutants at these faculties.
Again, organic compounds, pesticides/herbicides, and dioxins/furans were generally only found in low
concentrations in the composite daily samples, if they were found at all. Dioxin/furan analytes were not
detected in the sampling episode used to establish BPT/BAT/PSES. However, dioxin/furan analytes were
found in the two other sampling episodes (see discussion in Section 5 of this document).
       EPA completed the three sampling episodes for the Commercial Hazardous Waste Combustor
Subcategory from 1994 to 1995. Selection of facilities to be sampled was limited due to the small number
of facilities in the scope of the project. Only eight of the operating facilities identified discharged their

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treated wastewater under a NPDES permit Of these eight facilities, only five burned solid as well as liquid
waste. All of the facilities sampled used some form of chemical precipitation for treatment of the metal-
bearing waste streams. All of the facilities were direct dischargers and were therefore designed to
effectively treat the only conventional pollutant found in this industry, total suspended solids (TSS).  Data
from one of these facilities could not be used to calculate the proposed limitations and standards because
influent concentrations for many parameters were low and thus performance data for the treatment systems
could not be adequately ascertained. Also, as discussed in Section 6.4.2, EPA determined that only one
of the two remaining facilities employed BPT technology. However, data from all three facilities were used
to characterize the raw waste streams.  Thus, forthe proposal, only one sampling episode contained data
which were used to characterize the treatment technology performance of Commercial Hazardous Waste
Combustors.
       As described in the Notice of Availability on May 17,1999 (64 FR 26714), EPA received
additional wastewater treatment system performance data from CHWC facilities in early 1999, subsequent
to the close of the comment period for the proposal. Three CHWCs submitted influent and effluent
wastewater treatment system performance data and related information on the operation of their treatment
systems. Each facility submitted daily measurements for chlorides, total dissolved solids (TDS), TSS,
sulfate, pH and 15 metals (aluminum, antimony, arsenic, cadmium, chromium, copper, iron, lead, mercury,
molybdenum, selenium, silver, tin, titanium and zinc.) One facility provided 11 days of sampling data and
the two other facilities provided 30 days of sampling data each.
       Following an evaluation of the three facilities, EPA determined that two of these three facilities
employed BPT treatment technology. EPA used data from these two additional facilities, along with the
data used for the proposed regulation, to revise the proposed limitations and standards. The concentrations
of pollutants in the treated effluent from these two additional facilities are higher for some pollutants and
lower for others, as compared to the facility used to develop limitations and standards for the proposal.
On average, the variability of the effluent concentrations at these two additional facilities were lower than
those at the facility used as the basis for the proposed numerical guidelines.  EPA did not use data from
these two facilities in determining the variability factors used to calculate the numerical guidelines because
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EPA concluded that the average variability observed in the data used to calculate the limitations and
standards for proposal was greater than the average variability determined from the data for the other two
CHWCs. The variability factors used at proposal better reflect the variability seen in waste receipts
accepted for burning over longer periods of time at CHWCs.
       Information on waste stream characteristics is included in Section 4 of this document and
information on system performances is included in Section 6.
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SECTION 3
DESCRIPTION OF THE INDUSTRY AND SUBCATEGORIZATION

3.1          GENERAL INFORMATION

       The universe of combustion facilities currently in operation in the United State is broad. These
include municipal waste incinerators that bum household and other municipal trash and incinerators that
bum hazardous wastes. Other types of incinerators include those that bum medical wastes exclusively and
sewage sludge incinerators for incineration of POTWs' wastewater treatment residual sludge. In addition,
some boilers and industrial furnaces (e.g., aggregate kilns) may burn waste materials for fuel.
       While many industries began incinerating some of their wastes as early as the late 1950's, the
current market for waste combustion (particularly combustion ofhazardous wastes) is essentially a creature
of the Resource Conservation and Recovery Act (RCRA) and EPA's resulting regulation ofhazardous
waste disposal. Among the major regulatory spurs to combustion ofhazardous wastes have been the land-
ban restrictions under the Hazardous and Solid Waste Amendments (HSWA) of 1984 and clean-up
agreements for Superfund sites called "Records of Decision" (RODs).
       Prior to the promulgation of EPA's Land Disposal Restrictions (LDRs)(40 CFR Part 268),
hazardous waste generators were free to send untreated wastes directly to landfills. The LDRs mandated
alternative treatment standards for wastes, known as Best Demonstrated Available Technologies (BDATs).
Quite often, combustion was the stipulated BDAT. Future modifications to the LDRs may either increase
or decrease the quantity of wastes directed to the combustion sector.
       The LDRs have also influenced hazardous waste management under the Comprehensive
Environmental Response, Compensation, and Liability Act(CERCLAX42 U.S.C §§ 9601, et. seq.). The
RODs set out the clean-up plan for contaminated sites under CERCLA. A key attribute of the RODs is
the choice of remediation technology. Incineration is often a technology selected for remediation. While
remediation efforts contribute a minority of the wastes managed by combustion, combustion has been used
frequently on remediation projects. In addition, future Congressional changes to CERCLA may affect
remediation disposal volumes directed to the combustion sector.

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       The Agency proposed a draft Waste Minimization and Combustion Strategy in 1993 and 1994 to
promote better combustion of hazardous waste and encourage reduced generation of wastes. The key
projects under the broad umbrella of the strategy are:  "Revised Standards for Hazardous Waste
Combustors" 61 FR17358, April 1996, me Waste Minimization National Plan completed in May 1995,
and the "RCRA Expanded Public Participation Rule" 60 FR 63417, December 1995. Waste minimization
will directly affect waste volumes sent to the combustion and all other waste management sectors.
       In recent years, a number of contrary forces have contributed to a reduction in the volume of
wastes being incinerated. Declines in waste volumes and disposal prices have been attributed to: waste
minimization by waste generators, intense price competition driven by overcapacity, and changes in the
competitive balance between cement kilns (and other commercial boilers and industrial furnaces (BIFs))
and commercial incinerators. These trends have been offset by factors such as increased overall waste
generation as part of general economic improvement, industrial waste combustor consolidation, and
reductions in on-site combustion.
       The segment of the universe of combustion units for which EPA is regulating includes units which
operate commercially and which use controlled flame combustion in the treatment or recovery of RCRA
hazardous waste. For example, industrial boilers, industrial furnaces, rotary kiln incinerators and liquid-
injection incinerators are all types of units included in the Commercial Hazardous Waste Combustor
(CHWC) Industry.
       Combustion or recovery operations at these facilities generate the following types of wastewater,
described more fully in Section 4: air pollution control wastewater, flue gas quench wastewater, slag
quench, truck/equipment wash water, container wash water, laboratory drain wastewater, and floor
washings from the process area. Typical non-wastewater by-products of combustion or recovery
operations may include: slag or ash developed in the combustion unit itself, and emission particles collected
using air pollution control systems. There are many different types of air pollution control systems in use
by combustion units. The types employed by combustion units include, but are not limited to: packed
towers (which use a caustic scrubbing solution for the removal of acid gases), baghouses (which remove
particles and do not use any water), wet electrostatic precipitators (which remove particles using water but
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do not generate a wastewater stream), and venturi scrubbers (which remove particles using water and
generate a wastewater stream). Thus, the amount and types of wastewater generated by a combustion unit
are directly dependent upon the types of air pollution control systems employed by the combustion unit

3.2           SCOPE OF THE REGULATION
3.2.1         CHWCFacilities

       EPA promulgated effluent limitations guidelines and pretreatment standards for new and existing
thermal units/except cement kilns,  that are subject to either to 40 CFR Part 264, Subpart O; Part 265,
Subpart O; or Part 266, Subpart H if the thermal unit burns RCRA hazardous wastes received from off-site
for a fee or other remuneration in the following circumstances.
       The thermal unit is a commercial hazardous waste combustor if the off-site wastes are generated
at a facility not under the same corporate structure or subject to the same ownership as the thermal unit and

       (1)  the thermal unit is burning wastes that are not of a similar nature to wastes being burned from
           industrial processes on site, or
       (2)  there are no wastes being burned from industrial processes on site.

3.2.2         Captive and Intracompany CHWC Facilities

       As noted above, the rule does not apply to wastewater discharges associated with combustion units
that bum only wastes generated on-site. Furthermore, wastewater discharges from RCRA hazardous
incinerators and RCRA BIFs that burn waste generated off-site (for fee or other remuneration) from
facilities that are under the same corporate ownership (or corporate structure) as the combustor are
similarly not included within the scope of this rule.
       EPA has decided not to include facilities which only bum waste from off-site facilities under the
same corporate structure (intracompany facility) and/or only bum waste generated on-site (captive facility)
within the scope of this regulation for the following reasons.  First, based on its survey, EPA identified (as

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of 1992) approximately 185 captive facilities and 89 facilities that bum wastes received from other facilities
within the same corporate umbrella. A significant number of these facilities generated no CHWC
wastewater. EPA's data show that 73 captive facilities (39 percent) and 36 intracompany facilities (42
percent) generated no wastewater as a result of their waste combustor operations. Second, EPA believes
the wastewater generated by waste combustor operations almost of the captive and intracompany facilities
that EPA has identified are already subject to national effluent limitations (or pretreatment standards) based
on the manufacturing operations at the facility. Specifically, 140 of the 156 captive and intracompany
facilities  which received a screener survey and generated CHWC wastewater as a result of their
combustion operations: 1) were either previously identified as subject to other effluent guidelines by EPA
or 2) identified themselves as subject to other effluent guidelines. There are 97 facilities subject to the
Organic Chemicals, Plastics and Synthetic Fibers category (40 CFR Part 414), 17 subject to the
Pharmaceuticals category (40 CFR Part 439), 16 subject to the Steam Electric Power Generating category
(40 CFR Part 423), 3 subject to the Pesticide Manufacturing  category (40 CFR Part 455), and 7 subject
to other categories. EPA could not identify an effluent guideline category applicable to their discharges for
16 of these 156 facilities (five of these are federal facilities). Moreover, in the case of the small number -
less than 10 percent -- for which EPA could not identify a specific guideline that would apply, the permit
writer has authority to obtain any necessary data to write facility-specific best professional judgement (BPJ)
limitations or standards.
       In addition,  EPA looked at the pollutant data for commercial and non-commercial hazardous
facilities and concluded that their scrubber water is qualitatively different EPA evaluated the  grab samples
of untreated scrubber water it collected from eight non-commercial facilities to determine if there was a
difference  in wastewater characteristics at non-commercial versus commercial facilities.  See  Table 3-1 for
a presentation of grab sample data from non-commercial facilities.  For each regulated pollutant, the
average untreated CHWC wastewater concentration is less for the eight non-commercial facilities than for
the three commercial facilities used to determine the final limitations (see Table 3-2). EPA concluded these
results from the fact that non-commercial facilities do not treat the large variety of different wastes that
commercial facilities treat. Additionally, two of the nine regulated metal pollutants (mercury and silver)
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were not at treatable levels at any of the eight non-commercial facilities. Two more of the nine regulated
metal pollutants (arsenic and cadmium) were at treatable levels at only one of the eight non-commercial
facilities. Further, only one of the nine regulated metal pollutants (zinc) was at treatable levels at more than
half of the eight non-commercial facilities. In contrast, seven of the nine regulated metal pollutants (arsenic,
cadmium copper, lead, mercury, titanium and zinc) were found at treatable levels at all three of the
commercial facilities used to determine the final limitations. Further, the remaining two metal pollutants
(chromium and silver) were found at treatable levels at two of these three commercial facilities. These
circumstances further support EPA's decision not to subject non-commercial, captive  hazardous
incinerators to the limitations and standards developed here.

Table 3-1.    Non-Commercial Grab Sample Episode Data
Analyte
TSS (rng/1)
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
Non-Commercial Grab Sample Episodes
#9
310
78.4
300
250
698
3300
ND(0.2)
ND(4)
3770
1830
#1
10
42.1
ND(5)
236
101
ND(47)
0.68
ND(5)
110
44.7
#2
ND(4)
ND(1.9)
ND(1.2)
ND(3.6)
16.02
84.26
ND(O.l)
4.12
ND(2.2)
47.19
mi
44
ND(l.l)
19.05
24.42
75.85
319.46
ND(O.l)
15.74
59.06
1745.6
#6
40
1420
41.9
1650
131
96.6
1.04
ND(5)
98.9
341
#10
48
ND(20)
ND(4)
52.7
59.7
ND(49)
ND(0.2)
ND(5)
9.2
1120
#A
46
ND(2)
ND(4)
19.9
1960
ND(49)
0.63
ND(5)
134
3200
#B
95
ND(2)
ND(4)
ND(9)
ND(10)
ND(49)
ND(0.2)
ND(5)
7.5
283
Values in (ug/1) unless otherwise noted.
ND - Non-Detects
Note: Values in parentheses are the detection limits.
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Table 3-2,    C'ompurlion of Non-Commercial and Commercial Data
Analyte
TSS(mg/l)
Arienio
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
Number ol
Detect N
(out of 8)
7
3
1
6
7
4
3
2
7
H
Treatable
Level
(IO*QL)
40
100
50
100
100
100
2
30
100
200
Number of
Timei at
Treatable
Level
6 of 8
Iof8
Iof8
3ofH
4 of 8
2 of 8
Oof 8
Oof 8
3 of 8
6 of*
Avg, Influent
Concentration of
Non-Commercial
Qrabi
74,63
195.94
47,39
280,70
381.45
499.29
0.39
6.11
523.86
1076,44
Avg, Influent
Concentration of
Three Commercial
Facilities Uitd for
Final Limitations
147,40
654.33
376,57
835,67
2575,33
2395,33
93,87
124.27
2163,67
6482.00
Vnlun In (ug/l) unlm othorwln notid,
Ql» QuantltBtion Limit
       There may be initancei when a combuitor IN operated in conjunction with on-iitc induitrial
activitiei and the combuitor waitewater ii treated and diicharged leparately from the treatment of
induitrial waitewater (or treated leparately and mixed before diioharge). Permit writere ihould ooniider
thii guideline a* one lource of information when developing limitation! and itandardi ibr then lituatiom,
3,3
SUMMARY INFORMATION ON SS CHWC FACILITIES
       For 1992, EPA identified 55 wombuitor facilitiei that accept hazardoui or hazardoui and non-
hazardoui induitrial waite from off-ilte facllitleiii not under the name corporate umbrella for combuitlon,
The follow11IB tablei provide lummary information from the 1992 Waite Treatment Induitry Phaie II;
Incinerator! Suoaner Survey on theie *>*> combuitor facilitiei,
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       Many of the 55 CHWC (acilltiei have more than one unit on-lite, The majority ulfecilitiei with
two or more unit* on-iite operate bolleri, induitrial furnaeei, or aggregate Idlni, Table J-3 preientt ilir
number of thermal uniti at each of the 55 CHWC facilitiei that provided data in the aurvey,

Table 3-3.    Number of Thermal Unlti at Each of the 99 CHWC Facility Location*
Number of Uniti
Number of Facilitiei
1
26
2
14
3
6
4
4
5
2
6
1
7
0
8
0
>8
0
       There are more induitrial fljmaoei, botleri, and aggregate kilni than any other unit typei. However,
more than one of theie uniti often ii preient at a ilngle facility, Table 3-4 present* the unit typei at all ^5
CHWC faoilitiei that provided data in the lurvey,
Table 3-4,    Typei of Thermal Uniti at 99 CHWC Paclllttei
Type of Thermal Unit
Kotary Kiln Incinerator
Liquid Injection Incinerator
Pluidized-Bed Incinerator
Multiple-Hearth Incinerator
Fixed-Hoarth Incinerator
Pyrolytic Deitruotor
Induitrial Boiler
Induitrial Furnace
Other
Number of Each Unit Type
22
16
1
6
3
3
19
25
9
       Moit of the waite burned by the 55 CHWC facilitlei ii hazardoui or non-hazardoui induitrial
wane containing organic compound!, Only one facility indicated it burned waite containing dioxini/furann
and only four ftoilitlei indicated burning weite regulated under the Toxic Subitancei Control Act (TSC A»
Table 3*5 preienti the typei and amount of waite treated at all 55 CHWC facilitiei,

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Table 3-5.    Amount of Waste Treated by 55 Commercial Facilities in Calendar Year 1992
              (Tons)

Waste Type
Non-RCRA
Sewage Sludge
Containing
Metals
Containing
Organics
All Others
RCRA
Containing
Metals
Containing
Organics
Containing
Dioxins/Furans
Containing
Pesticides/
Herbicides
All Others
Special
Radioactive
Wastes
TSCA Wastes
(PCBs)
Medical Wastes
Tons
1-50

0
3
5
2

6
9
0
0
3
51-100

1
0
2
0

0
1
0
2
0
101-500

0
3
9
2
501-
1,000

0
1
0
1

1
6
1
0
1
1
3
0
1
1
1,001-
5,000

0
4
9
5

7
5
0
8
1
5,001-
10,000
>10,000

0
1
5
0

0
1
0
0
1
0
4
6
1

16
24
0
1
6

1
0
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
0
3
0
#of
Facilities

1
16
36
11

31
49
1
12
13

1
4
1
       For the CHWC regulations, only air pollution control water, slag quench and flue gas quench are
considered "CHWC wastewater." The largest wastewater stream generated by the 55 CHWC facilities,
stormwater runoff, is regulated under other effluent guidelines. The industry also generates large quantities
of boiler blowdown. Boiler blowdown wastewater was not considered for regulation for this industry
                                           3-8

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because it does not come into contact with any of the wastes being burned. Table 3-6 presents the quantity
of process wastewater generated by the 55 CHWC facilities that provided data in the survey.
Table 3-6.
Quantity of Process Wastewater Generated by 55 CHWC Facilities in Calendar
Year 1992 (Thousand Gallons)

Type of Process Water
None
Air Pollution Control
Water
Slag Quench
Process Area Washdown
Truck/Equipment Wash
Water
Container Wash Water
Stormwater Runoff
Laboratory Waste
Flue Gas Quench
Boiler Slowdown
Other
Gallons (1,000s)
0-5
16
1
1
4
2
1
0
2
1
4
2
5-15
0
1
0
2
0
0
0
0
0
0
0
15-50
0
2
2
3
1
1
0
0
0
2
0
50-100
0
2
0
1
2
1
2
2
0
1
0
100-500
0
0
2
4
1
1
3
2
0
0
0
500-750
0
0
0
0
0
0
3
0
0
2
0
>750
0
13
0
2
1
0
11
0
7
8
3
#of
Facilities
16
19
5
16
7
4
19
6
8
17
5
3.4
SUMMARY INFORMATION ON  22  CHWC  FACILITIES  WHICH
GENERATE CHWC WASTEWATER
       Following the distribution of the screener survey, EPA sent the 1994 Waste Treatment Industry
Phase II: Incinerators Questionnaire only to those commercial facilities that generated CHWC wastewater.
Thirty-three of the 55 CHWC facilities did not generate any CHWC wastewater, thus, EPA only has
detailed operation information on the 22 CHWC facilities that generated CHWC wastewater.  The
following tables provide summary information from the 1994 Waste Treatment Industry Phase II:
Incinerators Questionnaire on these 22 commercial combustor facilities.
                                         3-9

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3.4.1
RCRA Designation of 22 CHWC Facilities
       Most of the 22 facilities that generate CHWC wastewater are regulated as incinerators under
RCRA. Very few boilers and industrial furnaces regulated under RCRA generate air pollution control
water, flue gas quench, or slag quench. Table 3-7 presents the RCRA designation of the 22 commercial
facilities.

Table 3-7.    1992 RCRA Designation of 22 Commercial Facilities

Hazardous Waste Incinerator
Boiler and/or Industrial Furnace
Total Thermal Units
25
6
3.4.2
Waste Burned at 22 CHWC Facilities
       The number of customers served by a facility varies greatly in this industry. Some facilities bum
primarily waste generated on site and only take very few waste shipments from facilities not under their
corporate structure. Other facilities operate a strictly commercial operation, serving hundreds or thousands
of customers on a regular basis. Table 3-8  presents the number of customers served by the 22 commercial
facilities.
Table 3-8.   Number of Customers/Facilities Served in 1992 by 22 Commercial Facilities

Minimum
Maximum
Mean
Median
Total
Number of Customers
1
4,000
858
83
27,450
                                         3-10

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3.4.3
Air Pollution Control Systems for 22 CHWC Facilities
       The type of air pollution control system used by a CHWC facility has a direct effect on the
characteristics and quantity of the CHWC wastewater generated by that facility. Table 3-9 presents the
types of air pollution control systems in use at the 22 commercial facilities. Table 3-10 presents the types
of air pollutants for which add-on control systems are in operation for the 22 CHWC facilities. Some of
these systems do not generate any wastewater (e.g., a fabric filter for particulate removal). Other systems
would generate wastewater (e.g., a packed tower scrubber with lime used for halogenated acid gas
removal).
Table 3-9.    Types of Air Pollution Control Systems at 22 Commercial Facilities
Type of Air Pollution Control System
Spray Chamber Scrubber
Impingement Baffle Scrubber
Wet Cyclone (including multiclones)
Venturi Scrubber
Packed Tower
Ionizing Wet Scrubber
Wet Electrostatic Precipitator
Fabric Filter
Dry Scrubber
Spray Dryer
Other (Includes: Demister; Dry Cyclone; Dry Electrostatic
Precipitator; Horizontal Packed Absorber; Scrubber Quench Unit;
Steam Atomization)
Total Thermal Units
16
2
2
12
16
4
3
11
2
1
12
                                          3-11

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Table 3-10.   Air Pollutants for Which Add-On Control Systems are in Operation for 22
              Commercial Facilities
Air Pollutant
None
Halogenated Acid Gases
Sulfiir Compounds
Nitrogen Compounds
Particulates
Metals
Other (Organics)
Total Thermal Units
2
21
17
5
28
23
1
       Of the facilities that use water in their air pollution control systems, the chemicals added to the water
and the types of water recirculation systems vary greatly by facility. The addition of chemicals to the water
is dependent upon the purpose of the scrubbing system (e.g., no chemicals would be used to trap
particulates in a cyclonic scrubber and sodium hydroxide would be used to remove halogenated acid gases
in a packed tower scrubber). The chemicals added to the scrubber water would have a direct effect on
the characteristics of the wastewater generated. Table 3-11 presents the types of scrubbing liquors in use
at the 22 commercial facilities.
Table 3-11.   Scrubbing Liquor Used in Air Pollution Control Systems of 22 Commercial
              Facilities      »
Scrubbing Liquor
None
Water With No Added Chemicals
Sodium Hydroxide
Lime Slurry
Other (Includes: Lime-Hydrated; Sodium Carbonate Solution;
Sulfuric Acid)
Total Thermal Units
7
13
17
8
5
                                           3-12

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       The type of water recirculation system used by a facility also has a direct effect on the amount of
 wastewater generated. If a facility operated a closed loop air pollution control system with no discharge,
 no wastewater would be generated. Alternately, a facility that did not recirculate its air pollution control
 system wastewater, would tend to generate a large quantity of wastewater. Table 3-12 presents the types
 of water recirculation systems.
Table 3-12.   Type of Water Recirculation System Used in Air Pollution Control Systems of the
              22 CHWC Facilities
Water Recirculation System
None (once through)
Closed Loop (no discharge)
Recirculating with Intermittent Slowdown
Recirculating with Continuous Slowdown
Total Thermal Units
2
7
1
12
3.5           SUMMARY  INFORMATION  ON  10  CHWC  FACILITIES  WHICH
              GENERATE AND DISCHARGE CHWC WASTEWATER
       Twelve of the twenty-two facilities generate CHWC wastewater but do not discharge the
wastewater to a receiving stream or to a POTW. These facilities are considered "zero or alternative
dischargers" and use a variety of methods to dispose of their wastewater. At these facilities, (1)
wastewater is sent off-site for treatment or disposal (four facilities); (2) wastewater is burned or evaporated
on site (four facilities); (3) wastewater is sent to a surface impoundment on site (three faculties); and (4)
wastewater is injected underground on-site (one facility). Thus, EPA has identified only 10 facilities that
were discharging CHWC wastewater to a receiving stream or to a POTW in 1992. Of these 10 facilities,
2 facilities have either stopped accepting waste from off-site for combustion or have  closed their
combustion operations since 1992. These eight facilities are found near the industries generating the wastes
undergoing combustion.
                                          3-13

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       The eight open facilities identified by EPA operate a wide variety of combustion units. Three
facilities operate rotary kilns and are regulated as incinerators under RCRA. Three facilities operate liquid
injection incinerators and are regulated as incinerators under RCRA. One facility operates a furnace and
is regulated as a BIF under RCRA. One facility operates a liquid injection device and is regulated as a BEF
under RCRA.
       Also, the eight open facilities identified by EPA use a wide variety of air pollution control systems.
The types of air pollution control systems in use are: fabric filters, spray chamber scrubbers, packed tower
scrubbers, ionizing wet scrubbers, venturi scrubbers, dry scrubbers, dry cyclones, and wet electrostatic
precipitators. Seven of the eight open facilities use more than one of the air pollution control systems listed
above. Four of the eight facilities use a combination of wet and dry air pollution control systems. Three
of the eight facilities use only wet air pollution control systems.

3.6           INDUSTRY SUBCATEGORIZATION

       Division of an industry into groupings entitled "subcategories" provides a mechanism for addressing
variations between products, raw materials, processes, and other parameters which result in distinctly
different effluent characteristics. Regulation of an industry by subcategory provides that each has a uniform
set of effluent limitations which take into account technology achievability and economic impacts unique to
that subcategory.
       The factors considered in the regulation of the CHWC Industry include:

       •      waste type received;
       •      type of combustion process;
       •      air pollution control used;
       •      nature of wastewater generated;
       •      facility size, age,  and location;
       •      non-water quality impact characteristics;  and
       •      treatment technologies and costs.
                                           3-14

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       EPA evaluated these factors and determined that subcategorization is not required.
       For most facilities in this industry, a wide variety of wastes are combusted. These facilities,
however, employ the same wastewater treatment technologies regardless of the specific type of waste being
combusted in a given day.
       EPA concluded that a number effectors did not provide an appropriate basis for subcategorization.
The Agency concluded that the age of a facility should not be a basis for subcategorization because many
older facilities have unilaterally imrjrovedormodifiedtheirtreatmentprocess overtime. Facility size is also
not a useful technical basis for subcategorization for the CHWC Industry because wastes can be burned
to the same level regardless of the facility size and has no significant relation to the quality or character of
the wastewaters generated or treatment performance. Likewise, facility location is not a good basis for
subcategorization; no consistent differences in wastewater treatment performance or costs exist because
of geographical location.  Non-water quality characteristics (waste treatment residuals and air emission
effects) did not constitute a basis for subcategorization. The environmental effects associated with disposal
of waste treatment residual or the transport of potentially hazardous wastewater are a result of individual
facility practices. The Agency did not identify any consistent basis for these decisions that would support
subcategorization. Treatment costs do not appear to be a basis for subcategorization because costs will
vary and are dependent on the following waste stream variables: flow rates, waste quality, waste energy
content, and pollutant loadings. Therefore, treatment costs were not used as a factor in determining
subcategories.
       EPA identified three factors with significance for potentially subcategorizdng the CHWC Industry:
the type of waste received for treatment, the type of air pollution control system used by a facility, and the
types of CHWC wastewater sources (e.g., container wash water vs. air pollution control water).
       A review of untreated CHWC air pollution control system wastewater showed that there is some
difference in the concentration of pollutants between solid and liquid waste combustion units. In particular,
for nine of the 27 metals analyzed at six CHWC facilities, the average concentration of a particular metal
was higher in the water from facilities mat burned solids (as well as liquids) than in facilities that burned
liquids only. EPA believes that this difference is probably the result of two factors: the type of air pollution
                                            3-15

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control employed by the facilities and the amount of wastewater generated. Specifically, the data reviewed
by EPA showed that two of the three facilities mat bum liquid waste use dry scrubbing devices prior to
using scrubbing devices which generate wastewater. One of these facilities uses a baghouse initially and
the other uses a fabric filter. These dry scrubbers would remove some of the metals which would have
ended up in the wastewater stream. In comparison, only one of the three facilities that bum solids uses a
dry scrubbing device prior to using scrubber devices which generate wastewater. This facility uses an
electrostatic precipitator initially. In addition, all three of the faculties that bum liquid waste do not recycle
any of their wastewater for reuse in the scrubbing system following partial wastewater treatment.  In
comparison, two of the three facilities that bum solids recycle some of their partially treated wastewater
for reuse in their scrubbing system. One of these facilities recycles 60 percent and the other recycles 82
percent. The reuse of partially treated wastewater would have the effect of reducing the wastewater
discharge and increasing the concentration of metals in the recycled wastewater. Thus, the Agency could
not conclude that there is in fact any significant difference in the concentrations of pollutants in wastewater
from facilities burning solid versus liquid waste. This situation in general makes subcategorizmg on this basis
difficult See CHWC Record W-97-08, #72.0.1 forthe presentation of this statistical analysis. Therefore,
EPA has concluded that available data do not support subcategorization either by the type of waste
received for treatment or the type of air pollution control system used by a facility.
       Based on analysis of the CHWC Industry, EPA has determined that it should not subcategorize
the Commercial Hazardous Waste Combustors for purposes of determining appropriate limitations and
standards.
                                           3-16

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SECTION 4
WASTEWATER USE AND WASTEWATER CHARACTERIZATION

       In 1993, under authority of Section 308 of the Clean Water Act (CWA), the EPA distributed the
" 1992 Waste Treatment Industry Phase II: Incinerators Screener Survey" and, subsequently, the " 1994
Waste Treatment Industry Phase II: Incinerators Questionnaire" to facilities that EPA had identified as
possible CHWC facilities.  Responses to the screener survey and questionnaire indicated that, in 1992,10
CHWC facilities operated commercially and discharged their CHWC wastewater to a receiving stream
or to a POTW. Of these 10 facilities, 2 facilities have either stopped accepting waste from off site for
combustion or have closed their combustion operations since 1992. Thus, this section presents information
on water use at only the remaining 8 facilities. This section also presents information on wastewater
characteristics for the CHWC facilities that were sampled by EPA and for some of those facilities that
provided self-monitoring data.

4.1          WATER USE AND SOURCES OF WASTEWATER

       Approximately 820 million gallons of wastewater are generated and discharged annually at the 8
CHWC facilities. EPA has identified the sources described below as contributing to wastewater discharges
at CHWC operations. Only air pollution control wastewater, flue gas quench, and slag quench, however,
would be subject to the CHWC effluent limitations and standards. Most of the wastewater generated by
CHWC operations result from these sources.
a.      Air Pollution Control System Wastewater.  Particulate matter in the effluent gas stream of a
       CHWC is removed by four main physical mechanisms (Handbook of Hazardous Waste
       Incineration. Brunner 1989). One mechanism is interception, which is the collision between a water
       droplet and a particle. Another method is gravitational force, which causes a particle to fall out of
       the direction of the streamline. The third mechanism is impingement, which causes a waterparticle
       to fall out of the streamline due to inertia. Finally, contraction and expansion of a gas stream allow
       paniculate matter to be removed from the stream. Thus, removal of particulate matter can be
                                          4-1

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       accomplished with or without the use of water. Depending upon the type of waste being burned,
       Commercial Hazardous Waste Combustors may produce acid gases in the air pollution control
       system. In order to collect these acid gases, a caustic solution is generally used in a wet scrubbing
       system.
b.     Flue Gas Quench Wastewater. Water is used to rapidly cool the gas emissions from combustion
       units. There are many types of air pollution control systems that are used to quench the gas
       emission from Commercial Hazardous Waste Combustors. For example, in packed tower
       scrubbing systems, water enters from the top of the tower and gas enters from the bottom. Water
       droplets collect on the packing material and are rinsed off by the water stream entering the top of
       the tower (Handbook of Hazardous Waste Incineration. Brunner 1989). This rapidly cools the gas
       stream along with removing some paniculate matter.
c.     Slag Quench Wastewater.  Water is used to cool molten material generated in slagging-type
       combustors.
d.     Truck/Equipment Wash Water. Water is used to clean die inside of trucks and the equipment used
       for transporting wastes.
e.     Container Wash Water. Water is used to clean the insides of waste containers.
f.     Laboratory Wastewater. Water is used in on-site laboratories which characterize incoming waste
       streams and monitor on-site treatment performance.
g.     Floor Washings and Other Wastewater from Process Area This includes stormwater which
       comes in direct contact with the waste or waste handling and treatment areas. (Stormwater which
       does not come into contact with the wastes would not be subject to today's promlugated limitations
       and standards. However, this stormwater is covered under the NPDES stormwater rule, 40 CFR
       122.26).

4.2           WATER USE
       As mentioned in Section 4.1, approximately 820 million gallons of wastewater were discharged
from 8 of the 55 commercial industrial combustors identified by EPA based on questionnaire responses.
                                          4-2

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Table 4-1 presents the total, average, and range of discharge flow rates for the eight discharging facilities.
There were 45 facilities that either do not generate any CHWC wastewater (33) or do not discharge their
wastewater (12) as discussed previously.  In general, the primary types of wastewater discharges from
discharging facilities are: air pollution control system wastewater, flue gas quench, and slag quench. EPA
is using the phrase "CHWC wastewater" to refer to these three types of wastewaters only. Other types
of wastewater generated as a result of combustor operations  (e.g., truck washing water) are not
considered "CHWC wastewater".
       This regulation applies to direct and indirect discharges only.
Table 4-1.    Amount of CHWC Wastewater Discharged
Number of
Facilities
8
Total Amount of
CHWC Wastewater
Discharged
(Gallons/Day)
2,247,580
Average Amount of
CHWC Wastewater
Discharged
(Gallons/Day)
280,948
Range In Average
Amount of CHWC
Wastewater Discharged
(Gallons/Day)
47,430 to 1,007,640
4.3
WASTEWATER CHARACTERIZATION
       EPA conducted 15 sampling episodes at 13 different facilities in an effort to characterize CHWC
raw influent wastewaters during the formulation of the CHWC rule. These included three five-day sampling
efforts and twelve individual grab samples. A total of 467 pollutants were analyzed in the raw wastewater,
including 232 toxic and non-conventional organic compounds, 69 toxic and non-conventional metals, 4
conventional pollutants, and 162 toxic and non-conventional pollutants including pesticides, herbicides,
dioxins, and furans. Of these 467 pollutants, only 139 were ever detected at any of the CHWC influent
samples; most being metals and other non-organic compounds. Therefore, 328 pollutants analyzed were
never found at detectable levels in any CHWC influent samples. Appendix A presents a list of all analytes
that were detected at least once, along with: the detection limit, number of observations (samples), number
of detects, and minimum, maximum, and mean values of the pollutant Appendix B lists all of the remaining
                                           4-3

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328 pollutants never found in CHWC wastewaters, including the number of observations and detection
levels of the analytes.

4.3.1         Five-Day Sampling Episodes

       The Agency's five-day sampling program for this industry detected 21 pollutants (conventional,
priority, and non-conventional) in waste streams at treatable levels at the facility that provides the basis for
the BPT/B AT limits. Two additional pollutants were detected at treatable levels in the two other five-day
sampling episodes: strontium and dichlorprop. The quantity of these pollutants currently being discharged
from all facilities is difficult to assess. Limited monitoring data are available from facilities for the list of
pollutants identified from the Agency's sampling program prior to commingling of these wastewaters with
non-contaminated stormwater and other industrial waste water before discharge. EPA used monitoring data
supplied in the 1994 Waste Treatment Industry Phase II: Incinerators Questionnaire and data supplied in
the Detailed Monitoring Questionnaire, wastewater permit information, and EPA sampling data to estimate
raw waste and current pollutant discharge levels. EPA used a "non-process wastewater" factor to quantify
the amount of non-contaminated stormwater and other industrial process water in a facility's discharge.
Section 4.4 of this document provides a more detailed description of "non-process wastewater" factors
and their use. A facility's current discharge of treated CHWC wastewater was calculated using the
monitoring data supplied multiplied by the "non-process wastewater" factor.

4.3.1.1        Conventional Pollutants
       The most appropriate conventional pollutant parameters for characterizing untreated wastewater
and wastewater discharged by CHWC facilities are:

       •      Total Suspended Solids, and
              pH
                                            4-4

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       Total solids in wastewater are defined as the residue remaining upon evaporation at just above the
boiling point. Total suspended solids (TSS) is the portion of the total solids that can be filtered out of the
solution using a 1 micron filter. Untreated wastewater TSS content is a function of the type and form of
waste accepted for treatment (e.g., wastewater that results from the combustion of solid waste receipts
would tend to have higher TSS values than waste received in a liquid form).  TSS can also be due to
treatment chemicals added to the wastewater as it is being generated (e.g., a caustic solution may be used
in a CHWC air pollution control system). The total solids are composed of matter which is settleable, in
suspension or in solution, and can be removed in a variety of ways, such as during the metals precipitation
process or by multimedia filtration, depending on a facility's operation. Untreated wastewater TSS levels
found in the three five-day EPA sampling episodes are presented in Table 4-2.
       The pH of a solution is a unitless measurement which represents the acidity or alkalinity of a
wastewater stream, based on the dissociation of the acid or base in the solution into hydrogen (H+) or
hydroxide (OH-) ions, respectively. Untreated wastewater pH is a function of the source of waste receipts
as well as a function of the chemicals used in the air pollution control devices. This parameter can vary
widely from facility to facility. Control of pH is necessary to achieve proper removal of pollutants in the
BPT/BAT treatment system (chemical precipitation).
       As shown in Table 4-2, raw waste five-day biochemical oxygen demand and oil and grease are
very low, ranging from 1 mg/1 to 53 mg/1 and from 5 mg/1 (not detected) to 6 mg/1, respectively. Both of
these parameters are indirect measurements of the organic strength of wastewater. The wastewater
sampled by EPA is generated from air pollution control systems and consists primarily of inorganic
pollutants and very  low concentrations of organic compounds because they  are destroyed  during
combustion.  (Furthermore, a more direct measure of the organic strength of the raw wastewater, total
organic carbon, also shown in Table 4-2, only ranges from 10 mg/1 (not detected) to 16 mg/1).
Table 4-2.    Range of Pollutant Influent Concentrations of the Pooled Daily Data from the
              Three Five-Day EPA Sampling Episodes (ug/1)
Pollutant
Aluminum
Mean
897.6
Minimum
13.6
Maximum
2,538.0
                                           4-5

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Pollutant
Ammonia as Nitrogen
Antimony
Arsenic
BOD5
Boron
Cadmium
Calcium
Chemical Oxygen Demand
Chloride
Chromium
Copper
Fluoride
Iron
Lead
Manganese
Mercury
Molybdenum
Nitrate/Nitrite
Oil and Grease
Phosphorus
Potassium
Selenium
Silicon
Silver
Sodium
Strontium
Sulfur
Tin
Titanium
Total Dissolved Solids
Total Organic Carbon
Total Phosphorus
Total Sulfide
Mean
14,312.4
268.2
166.4
9,960
1,604.6
312.2
293,146.0
343,140.0
6,833,746.7
127.2
1,786.7
82,620.5
2,904.1
1,613.9
114.7
21.1
336.7
2,650.9
5,067
32,480.0
77,743.0
102.8
15,414.0
98.9
3,443,333.3
630.2
400,788.1
665.9
777.7
12,815,853.3
10,485
1,088.6
28,261.3
Minimum
100.0
7.8
4.6
1,000
918.0
1.8
8,140.0
67,000.0
1,010,000.0
5.8
8.5
16,500.0
149.0
2.1
4.0
0.2
4.6
360.0
5,000
3,210.0
1,310.0
2.3
5,380.0
1.0
6,400.0
100.0
2,145.0
14.5
5.0
158,000.0
10,000
10.0
1,000.0
Maximum
75,000.0
958.8
827.2
53,000
3,760.0
2,616.0
1,270,000.0
1,036,000.0
17,002,400.0
529.2
10,554.0
360,000.0
10,838.0
13,248.0
388.0
115.4
1024.4
4,560.0
6,000
225,800.0
195,400.0
429.2
28,100.0
390.8
11,250,600.0
2,280.0
1,078,240.0
6,046.0
4,474.2
32,641,200.0
16,000
4,460.0
103,200.0
4-6

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Pollutant
Total Suspended Solids
Zinc
Dichlorprop
MCPP
Mean
122,553.3
3,718.8
7.7
375.7
Minimum
4,000.0
89.8
1.0
50.0
Maximum
522,000.0
12,310.0
47.0
2,594.0
4.3.1.2
Priority and Non-Conventional Pollutants
       Table 4-2 above presents the range of the pooled daily pollutant influent concentration data from
the three five-day EPA sampling episodes. This table includes treatment chemicals and nutrients found in
CHWC wastewater as well as pollutants to be removed from CHWC wastewater.
4.3.2
Characterization Sampling Episodes
       As discussed in Section 2.2.2.1 of this document, EPA obtained a grab sample of untreated
CHWC wastewater at 12 facilities. These samples were used to help characterize the CHWC
wastewaters at a wide range of combustor types, including captive facilities. Data from one facility was
excluded due to the sample solidifying soon after collection, thus provided, in the Agency's opinion, data
of a poor and misrepresentative nature. Table 4-3 below presents a breakdown of levels of typical
pollutants found in the raw CHWC wastewater at 11 different facilities. The pollutants presented in Table
4-3 were detected at more than one facility with a mean concentration of at least 10 times the pollutant
detection limit.
Table 4-3.    Range of Pollutant Influent Concentrations of the Pooled Daily Data from the
              Characterization EPA Sampling Episodes (ug/1)
Pollutant
Aluminum
Ammonia as Nitrogen
Arsenic
Benzoic Acid
Mean
5,458.8
2,908.8
323.2
263,249.8
Minimum
21.5
130.0
1.1
50.0
Maximum
34,800.0
13,000.0
1,420.0
3,157,556.0
                                           4-7

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Pollutant
BOD5
Boron
Cadmium
Chemical Oxygen Demand
Chloride
Chromium
Copper
Fluoride
Iron
Lead
Manganese
Mercury
Molybdenum
Nitrate/Nitrite
Potassium
Selenium
Silicon
Sodium
Sulfur
Titanium
Total Dissolved Solids
Total Organic Carbon
Total Phenols
Total Phosphorus
Total Sulfide
Total Suspended Solids
Uranium
Zinc
Mean
1,092,333.3
22,565.2
225.7
2,284,583.3
10,203,416.7
342.0
894.2
879,230.0
10,413.5
1,604.5
245.8
32.7
131.3
5,166.7
147,574.2
65.8
42,997.6
12,377,392.9
22,998,416.6
463.9
37,896,083.3
391,041.7
12,316.3
1,279.2
163,340.8
100,000.0
10,099.6
5,436.6
Minimum
1,000.0
20.0
1.2
13,000.0
40,000.0
3.6
10.0
120.0
239.2
45.5
10.8
0.1
4.0
210.0
478.6
0.5
28.2
8,244.3
12,500.0
2.2
89,000.0
1,700.0
6.0
10.0
10.0
1,000.0
608.2
44.7
Maximum
10,100,000.0
182,000.0
1,632.8
19,100,000.0
28,300,000.0
1,650.0
4,621.8
7,500,000.0
50,600.0
12,358.0
1,534.6
217.0
508.5
33,280.0
805,000.0
288.0
340,000.0
62,400,000.0
174,000,000.0
3,770.0
185,000,000.0
4,540,000.0
146,000.0
4,520.0
1,180,000.0
416,000.0
67,100.0
28,569.0
4.4
WASTEWATER POLLUTANT DISCHARGES
       As previously discussed, most of the effluent monitoring data received from facilities included non-
CHWC wastewater, such as other industrial waste streams and stormwater. Due to the lack of effluent
                                         4-8

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data for CHWC wastewater, the EPA had to develop various methods to estimate their current wastewater
pollutant discharge.  This section describes the various methodologies used to estimate current
performance.
       Most of the data supplied by the CHWC facilities represented data that included non-CHWC
wastewater in the form of non-contaminated stormwater and other industrial stormwater prior to discharge.
Therefore, the amount of a pollutant in the final effluent would be equal to the amount of the pollutant in the
CHWC process in addition to the amount in the non-CHWC process, as shown in Equation 4.1.
    F
                   TOTAL
                                 FCHWC + CNON-CHWC  FNON-CHWC
(4.1)
where:
CT
FTOTAL
CCHWC
FCHWC
CNON-CHWC
FNON-CHWC
Concentration of pollutant in the combined wastewater stream — the concentration
reported in the CHWC Questionnaire, the CHWC Detailed Monitoring Questionnaire,
in POTW permits, in NPDES permits, or from EPA sampling program.
Flowrate of total wastewater stream.
Concentration of pollutant in the CHWC (and other similar) wastewater streams.
Flowrate of CHWC (and other similar) wastewater streams.
Concentration of pollutant in stormwater or non-contact wastewater streams.
Flowrate of stormwater or non-contact wastewater streams.
       Stormwater or non-contact wastewater was assumed to be significantly lower in concentration in
comparison to the CHWC wastewater, and thus, the concentration of non-CHWC wastewater streams
was set equal to zero. This assumption simplifies Equation 4.1 as shown in Equation 4.2 below. Also,
other industrial wastewater streams were assumed to have the same concentrations as the CHWC
wastewater streams.
                                          4-9

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                           CCHW * F
                             CHWC    CHWC
       For each facility, the EPA calculated die portion of CHWC wastewater in the facility discharge and
then calculated the CHWC effluent concentration by solving Equation 4.2. Thus, the non-process
wastewater factor is the flowrate of the total wastewater stream divided by the flowrate of die CHWC (and
other similar) wastewater stream.
       The hierarchy of data used to estimate current loading concentrations was as follows:
1 .)    Detailed Monitoring Questionnaire (DMQ)for the CHWC Industry data from effluent sample
       locations for 1992.  The facility's long-term monitoring data was supplied in this questionnaire.
       Often, this data had to be corrected for inclusion of non-CHWC wastewater streams using
       Equation 4.2 above.
2.)    Detailed Monitoring Report (DMR) data from  effluent sample locations for 1992.  The
       faculty's long-term monitoring data was supplied to EPA in this report Often, mis data had to be
       corrected for inclusion of non-CHWC  wastewater streams using Equation 4.2.
3 .)    Waste Treatment Industry Phase II: Incinerators Questionnaire data from effluent sample
       locations for 1992.  The facility's year-long monitoring data was supplied in this questionnaire.
       Often, this data had to be corrected for inclusion of non-CHWC wastewater streams using
       Equation 4.2.
4.)    POTW or NPDES permit effluent concentrations for 1992.  Often,  this data had to be
       corrected for inclusion of non-CHWC  wastewater streams using Equation 4.2.
5.)    EPA Five-Day Sampling Data for three CHWC facilities.  This data was used either for specific
       facilities sampled or averages were obtained to model facilities for which limited data was available.
6.)    Averages from similar facilities. Data averages from similar facilities were used to model current
       loadings concentrations for facilities for which limited data was available.

       The average, flow-weighted, estimated 1992 discharge concentration for facilities in the CHWC
Industry is presented in Table 4-4.
                                          4-10

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Table 4-4.    CHWC Industry 1992 Discharge Concentration
Pollutant
Chemical Oxygen Demand
Total Dissolved Solids
Total Suspended Solids
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
Zinc
Discharge
Concentration
145.2
10,430.0
30.6
663,7
559.0
217.7
1,614.9
118.4
4,276.9
944.2
306.2
363.4
156.2
10.6
239.2
34.2
31.0
88.4
79.6
385.6
Unit
mg/1
mg/1
mg/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
                                      4-11

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SECTION 5
SEIJECTIONOFPOIIAJTANTSANDPOI^

5.1           INTRODUCTION

       As previously discussed, EPA evaluated sampling data that was collected from the industry prior
to the proposal of this regulation as well as data submitted by industry following the proposal of this
regulatioa EPA used these data (presented in Section 4) to identify which pollutants present in combustor
wastewaters it should consider for regulation - the so called "pollutants of concern" for the Commercial
Hazardous  Waste Combustor (CHWC) Industry. EPA classifies pollutants into three categories:
conventional, non-conventional, and toxic pollutants.  Conventional pollutants include 5-day biolgoical
oxygen demand (BODj), total suspended solids (TSS), oil and grease, and pH. Toxic pollutants - EPA
also refers to them as priority pollutants—include selected metals, pesticides and herbicides, and over 100
organic parameters that represent a comprehensive list of volatile and semi-volatile compounds. Non-
conventional pollutants are any pollutants that do not fall within the specific conventional and toxic pollutant
lists, for example, total organic carbon (TOC), chemical oxygen demand (COD), chloride, fluoride,
ammonia as nitrogen, nitrate/nitrite, total phenol and total phosphorus.
      This section presents the criteria used for the selection of pollutants EPA evaluated for regulation
and the selection of pollutants for which EPA has established effluent limitations and standards.

5.2           POLLUTANTS CONSIDERED FOR REGULATION

      To characterize CHWC wastewaters and to determine the pollutants that it should evaluate for
potential limitations and standards, EPA collected wastewater characterization samples at 12 CHWC
facilities, in addition to influent data collected during three five-day sampling episodes. EPA analyzed
wastewater samples for 467 conventional, toxic, and non-conventional pollutants including metals, organics,
pesticides, herbicides, and dioxins and furans. Section 4 presents this wastewater characterization data.
                                          5-1

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       From the original list of 467 analytes, EPA developed a list of "pollutants of concern" that it would
further evaluate for possible regulation.  A total of 328 pollutants were never detected in CHWC
wastewaters during EPA sampling episodes, leaving 139 pollutants to be considered as pollutants of
concern that served as the basis for selecting pollutants for regulation. These 328 pollutants are presented
in Section 4.

5.3           SELECTION OF POLLUTANTS OF CONCERN

       EPA determined "pollutants of concern" - pollutants that EPA evaluates for regulation - using the
raw wastewater data collected during the EPA sampling program. EPA only considered the three five-day
sampling episodes to determine the pollutants of concern. Therefore, EPA did not include sampling data
from the 12 wastewater characterization sampling episodes. Of these 12 facilities, eight were captive
facilities that did not operate commercially (outside the scope of this regulation) and the samples from one
facility solidified during transport to the analytical laboratory and were not re-sampled. Two of the
remaining three facilities were selected for five-day sampling episodes and therefore, characterization data
is included as part of these events.  A total of 25 pollutants were detected during the wastewater
characterization sampling episodes but were not detected during the three five-day sampling episodes and
were eliminated as pollutants of concern. These 25 pollutants are listed in Table 5-1.

Table 5-1.    Pollutants Detected Only During Wastewater Characterization Sampling
                                       Pollutants
 Amenable Cyanide
 Atrazine
 Benzoic Acid
 Beryllium
 Bromodichloromethane
 Carbon Disulfide
 Chloroform
N-Decane
N-Docosane
N-Docecane
N-Eicosane
N-Tetradecane
P-Cresol
Tribromomethane
                                          5-2

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                                       Pollutants
 Dibenzothiophene
 Dibromochloromethane
 Erbium
 Hexanoic Acid
 Isophrone
 Methylene Chloride
Trichlorofluoromethane
Yttrium
2-Butanone
2-Propanone
2-Propenol
       EPA further determined a pollutant to be a potential pollutant of concern if it was detected three
or more times in the influent above the method detection limit (MDL) at a five-day sampling episode. This
ensured that pollutants that were detected relatively frequently at CHWC faculties were given consideration
as pollutants of concern. This criterion eliminated the 47 pollutants listed in Table 5-2.

Table 5-2.     Pollutants Not Detected Three or More Times Above MDL
Pollutants
Acetophenone
Cerium
Cobalt
Dalapon
Dicamba
Dinoseb
Dysprosium
Europium
Gadolinium
Gallium
Germanium
Hafnium
Holmium
Indium
Iodine
Oil and Grease
Osmium
Phenol
Platinum
Praseodymium
Rhenium
Rhodium
Ruthenium
Samarium
Scandium
Tantalum
Terbium
Thallium
Thorium
Thulium
                                          5-3

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                                        Pollutants
  Indium
  Lanthanum
  Lutetium
  MCPA
  Monocrotophos
  Neodymium
  Niobium
  Norflurazon
  OCDF
Total Phenols
Tungsten
Ytterbium
Zirconium
2,4-D
2,4 - DB
2,4,5-T
2,4,5 - TP
       EPA then further examined the characteristics of the three facilities that were sampled as part of
the five-day episodes. As noted in Section 6, influent concentrations for many parameters were low due
to the liquid injection system employed at the facility sampled during Episode # 4733 and the actual raw
wastewater characteristics as well as treatment system performance could not be adequately determined.
In addition, raw wastewater pollutant concentrations also were lower at the treatment system employed
at the facility sampled during Episode 4671 and treatment system performance was not as good as the
system considered BAT. Therefore, EPA determined that only data collected from five-day sampling
Episode 4646 should be considered further in determining pollutants of concern. This criterion eliminated
the six pollutants listed in Table 5-3, leaving a total of 61 pollutants remaining.

Table 5-3.    Pollutants Only Found During Sampling Episodes 4733 and 4671
Pollutants
Bismuth
Dichloroprop
Strontium
Total Cyanide
Total Organic Carbon
Uranium
       Next, EPA evaluated which pollutants were present in raw wastewaters at treatable levels by
determining the pollutants that were detected three or more times at an average influent concentration
                                          5-4

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greater than or equal to 10 times the MDL (in the case of aluminium and lead, criteria of five and three
times the MDL was used, respectively, to determine treatable levels because of higher MDLs). EPA
determined that this criterion eliminated the 11 pollutants listed in Table 5-4, leaving a total of 50 pollutants
remaining.
       The raw wastewater value for pollutants detected during sampling Episode 4646 was a flow-
weighted average of two sample points. Barium (291 ug/1), bis (2-ethylhexyl) phthalate (37 ug/1), BOD5
(3.7 mg/l),hexavalent chromium (35 ug/1), lithium (497 ug/l), magnesium (5,431 ug/1), nickel (151 ug/1) and
vanadium (315 ug/1) were all detected at an average concentration well below the 10 times the MDL
threshold for treatable levels. For n-hexacosane, n-octacosane and n-tricotane, samples were analyzed
using different analytical methods that yielded values in different units, ug/kg and ug/1. In both cases, the
average concentration also was well below the 10 times the MDL threshold for treatable levels for all three
pollutants.
Table 5-4.    Pollutants Not Detected Three or  More  Times at  an Average  Influent
              Concentration Greater Than or Equal To 10 Times the MDL
Pollutants
Barium
Bis (2-Ethylhexyl) Phthalate
BOD5
Hexavalent Chromium
Lithium
Magnesium
N-Hexacosane
N-Octacosane
N-Tricotane
Nickel
Vanadium

       EPA then excluded pollutants that are used as treatment chemicals in this industry from the
pollutants of concern list. These compounds include ammonia as nitrogen, calcium, chloride, fluoride,
nitrate/nitrite, phosphorus, potassium, silicon, sodium, sulfur, total phosphorus, and total sulfide. Eliminating
these 12 pollutants leaves a total of 38 pollutants remaining.
                                            5-5

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       EPA eliminated pollutants that received ineffective treatment by the selected BAT treatment
technology. Concentrations of these pollutants increased or decreased insignificantly during sampling
Episode 4646 and could not be considered treated. This criterion eliminated the five pollutants listed in
Table 5-5, leaving a total of 33 pollutants remaining.

Table 5-5.    Pollutants Not Treated by the BAT Treatment System
Pollutants
Boron
Chemical Oxygen Demand
Manganese
MCPP
Total Dissolved Soilds
       EPA then eliminated those pollutants indirectly controlled through the regulation of other pollutants
in the final rule. This criterion eliminated the six pollutants shown in Table 5-6, leaving a total of 27
pollutants remaining.

Table 5-6.    Pollutants Indirectly Controlled Through Regulation of Other Pollutants
Pollutants
Aluminum
Antimony
Iron
Molybdenum
Selenium
Tin
       Finally, EPA eliminated the 16 dioxins and furans presented in Table 5-7, for the reasons presented
below.

Table 5-7.    Dioxins and Furans Eliminated as Pollutants of Concern
Pollutants
234678 - HXCDF
23478 - PECDF
123678 - HXCDF
12378 - PECDD
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                                      Pollutants
 2378-TCDD
 2378 - TCDF
 123478 - HXCDD
 123478 - HXCDF
 1234789 - HPCDF
 123678 - HXCDD
12378 - PECDF
123789 - HXCDD
123789 - HXCDF
OCDD
1234678 - HPCDD
1234678 - HPCDF
5.3.1         Dioxins/Furans in Commercial Hazardous Waste Combustor Industry

5.3.1.1       Background

       Scientific research has identified 210 isomers of chlorinated dibenzo-p-dioxins (CDD) and
chlorinated dibenzofurans (CDF). EPA's attention has primarily focused on the 2,3,7,8-substituted
congeners, a priority pollutant under the CWA, of which 2,3,7,8-TCDD and 2,3,7,8-TCDF are
considered the most toxic. Evidence suggests that non-2,3,7,8-substituted congeners may not be as toxic.
Some sources report that these non-2,3,7,8-substituted congeners may either be broken down or quickly
eliminated by biological systems.  Dioxins and furans are formed as a by-product during many industrial
and combustion activities, as well as during several other processes. The combustion activities that may
create dioxins under certain conditions may include:

       •      Combustion of chlorinated compounds, including PCBs;
       •      Some metals are  suspected to serve as catalysts in the formation of dioxin/furans;
       •      Metal processing and smelting;
       •      Petroleum refining;
       *      Chlorinated organic compound manufacturing.
                                        5-7

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 5.3.1.2
Dioxin/Furans in Commercial Hazardous Waste Combustor Wastewater
       EPA identified a number of dioxin/furan compounds as present in the untreated wastewater streams
 at seven of the twelve facilities sampled (including grab and composite samples). Two of the facilities with
 dioxins detected in their CHWC wastewater are now closed and no longer within the scope of the final
 rule, so data from these facilities has not been considered further here. Thus, the following discussion relates
 to data from the ten remaining facilities (a total of 32 aqueous samples). Table 5-8 below summarizes the
 dioxin/furans detected in CHWC wastewaters during the sampling program. Similar isomers that contain
 the 2,3,7,8 base were grouped together for this analysis due to their similar nature and characteristics.

 Table 5-8.    Breakdown of Detected Dioxin/Furans During CHWC Sampling Program
Dioxin/Furan
2,3,7,8- TCDF
2,3,7,8- PeCDF
2,3,7,8- HxCDD
2,3,7,8- HxCDF
2,3,7,8- HpCDD
2,3,7,8- HpCDF
OCDD
OCDF
Toxic
Equivalent
Value
(TEQ)
0.1
0.5
0.1
0.1
0.01
0.01
0.001
0.001
Universal
Treatment
Standards
63,000 pg/1
35,000 pg/1
63,000 pg/1
63,000 pg/1
none
none
none
none
Mean
Concentrations
CHWC Industry
(detects only)
17 pg/1
93 pg/1
68 pg/1
249 pg/1
272 pg/1
939 pg/1
971 pg/1
6165 pg/1
Total # of
Aqueous
Samples
Detected
(out of 32)
2
1
1
7
5
7
10
6
# of Facilities
Detected
(out of 10)
2
1
1
3
4
4
5
4
       It is important to note that EPA did not detect 2,3,7,8-TCDD (the most toxic congener) or
2,3,7,8-PeCDD in the raw wastewater samples collected. The dioxin/furans detected in untreated CHWC
wastewaters during EPA sampling at 10 sites show that these dioxin/furans were all detected at levels
significantly (orders of magnitude) below the "Universal Treatment Standard" (40 CFR 268.48) level
established under RCRA for dioxins/furans. hi addition, low levels of HpCDD and OCDD (as indicated
                                           5-8

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above) are generally considered pervasive in the environment and Universal Treatment Standards have not
been set for these compounds. EPA identified no dioxin/furans in the CHWC wastewater treated effluent
       CDD/CDFs are lipophilic and hydrophobic. As such, they are most often associated, or have an
affinity for, suspended particulates in wastewater matrices. The more highly chlorinated isomers (i.e., the
hepta- and octa- congeners) are the least volatile and more likely to be removed through paniculate
adsorption or filtration.  While recommended treatment technologies differ according to the wastewater
characteristics, there is some evidence that dioxins generally will bind with suspended solids and some
sources (EPA NRMRL Treatability database) have asserted that these compounds may be removed by
precipitation and filtration technologies.
       Of the three five-day sampling episodes conducted by EPA, the episode from which BAT/BPT
limits were developed had no dioxins detected in the influent or effluent. At the other two facilities,
HpCDD, HpCDF, OCDD, and OCDF were detected in the influent but none were detected in the effluent
Both facilities employed a combination of chemical precipitation and filtration that may have contributed
to these removals.
       The most toxic congener, 2,3,7,8-TCDD, was never detected in CHWC wastewater during the
sampling program and the CDD/CDFs detected were neither detected at most facilities sampled nor found
in any significant quantity. The toxic equivalent (TEQ) values found in the CHWC wastewater were low
when compared to other dioxin sources in industry. The detected congeners were of the highly chlorinated
type which maybe treated by the methods recommended by Ihis guideline (chemical precipitation, filtration,
see Section 6). Also, since no dioxins were detected in the treated effluents at any of the three facilities
EPA sampled, this may be evidence of dioxin removals.
       Based on EPA's sampling program, no CDD/CDF met the criteria for wastewater regulation in
the final rule.
       The Agency has proposed CDD/CDF air emission  limits of 0.2 ng/dscm from the stacks of
hazardous waste burning incinerators (see 61 FR 17358 of 4/19/96 and 62 FR 24212 of 5/2/97), and
believes that the incinerators have to operate with good combustion conditions to meet the proposed
emission limits. In the final Land Disposal Restrictions (LDR) rulemaldng that set treatment standards for
                                          5-9

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CDD/CDF constituents in non-wastewater and wastewater from RCRA code F032 wastes, the Agency
has established (62 FR 26000,5/12/97) incineration as the BDAT, after which the CDD/CDF constituents
do not have to be analyzed in the effluent
       Based on the data available and the resulting decision not to establish limitations and standards for
dioxins, EPA also cannot justify a monitoring program for dioxins, as suggested by a commenter on the
proposal. While EPA recognizes that the promulgation of the Hazardous Waste Combustor (HWC)
MACT (64 FR 52828, September 30,1999) dioxin/furan emission standards may result in some changes
in the volume and character of air pollution control wastewater generated, EPA does not believe that the
changes will result in a media transfer for dioxins that would change its decision not to establish dioxin
limitations and standards. The promulgated MACT standards for 85 percent of the hazardous waste
incinerators in the final HWC rule are based on changes in air pollution control device process conditions
to minimize generation of dioxins and furans. Various studies have shown that a significant source of dioxin
in waste incinerators is from the formation of dioxin in the flue gas as it is cooled to around 400 degrees
C. The longer the flue gas is held at this temperature the greater the formation of dioxin. One useful control
measure is the rapid cooling of flue gas to levels below this temperature range to minimize this dioxin
production window. EPA has concluded that the largest portion of the reduction in dioxin emissions will
be through reductions in the amount generated rather than media transfer.
       Table 5-9 presents the 11 pollutants selected for regulation for the CHWC Industry.
Table 5-9.    Pollutants Selected for Regulation
                                        Pollutants
 Arsenic
 Cadmium
 Chromium
 Copper
 Lead
 Mercury
pH
Silver
Titanium
Total Suspended Solids
Zinc
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5.4           SELECTION OF POLLUTANTS FOR REGULATION

       All of the analytes listed in Table 5-9 were included in data submitted by two facilities (Sampling
Episodes 6181 and 6183) following the proposal of the CHWC regulation, presented in Tables 5-10 and
5-11. EPA received additional sampling data from three facilities. These facilities only tested for
conventional, priority and non-conventional pollutants that they considered treatable and likely to be found
inCHWCwastewater. These pollutants included TSS, total dissolved solids (TDS), chloride, sulfate,
aluminum, antimony, arsenic, cadmium, chromium, copper, iron, lead, mercury, molybdenum, selenium,
silver, tin, titanium, and zinc. TDS, chloride and sulfate were included in the testing to characterize the
wastewater and evaluate the pollutants' potential effect on the treatability of metals.
       Based on several factors, EPA specifically excluded data from the third facility (Episode 6182)
from consideration as BAT technology. The facility treated less than 2 percent of their wastewater through
the filtration unit considered BPT/BCT/BAT.  Hence, the data submitted represents single-stage
precipitation with clarification only. Not only does the single-stage treatment sampled during Episode 6183
not represent BPT/BCT/BAT technology, but it does not provide sufficienttreatment for the typical profile
of metals detected in CHWC wastewaters. There are a variety of metals at significant and treatable
concentrations in CHWC wastewaters that pose a problem for a single-stage precipitation system. To
properly treat a large number of different metals effectively, several different pH settings and treatment
chemicals are ususally required.  Hence, many CHWC facilities currently employ two-stage chemical
precipitation. When a single-stage of precipitation is employed with a narrow pH range (as was the case
for Episode 6182), many of the metals present in the influent are not effectively removed and some are not
removed at all. Removal efficiencies and effluent concentrations for Episode 6182 can be characterized
as poor when compared to EPA-conducted sampling episodes.  Based on these factors, the Agency
determined that data from sampling Episode  6182 would not be used in this rulemaking.
       After reviewing the data submitted by these two facilities (Sampling Episodes 6181 and 6183),
EPA has decided to promulgate the CHWC regulations for the same analytes as proposed.  Review of the
additional TSS and TDS data submitted brought EPA to the same conclusion as at proposal: TDS should
not be regulated because treatment chemicals associated with the technology selected for BPT/BCT/BAT
                                         5-11

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increased TDS levels and TSS should be continue to be regulated. In addition, not all of the analytes
proposed for regulation were found in one of the submitted sampling episodes (Episode 6181) in "treatable
levels" at the influent sampling point, as defined above in this section. Also, not all of the analytes proposed
for regulations were effectively treated (as indicated by the percent removal calculated in Section 6) in
Episode 6181.
       The following tables illustrate the results of the analyses to determine which pollutant data could
be used from Episode 6181 and 6183 to develop the final regulations. For four of the metal analytes
(arsenic, lead, selenium and silver), EPA received data for Episodes 6181 and 6183 using more than one
analytical method.  For arsenic, methods 200.7,200.8 and 206.3 were used. For lead, methods 200.7
and 200.8 were used.  For selenium, methods 200.7,200.8 and 270.3 were used. For silver, methods
200.7 and 200.8 were used. EPA elected to use the results from method 200.8 for all of these metal
analytes because of the quantitation limit achieved by this method and because of the reliability of this
method. EPA received data using only method 200.7 for aluminum, antimony, cadmium, chromium,
copper, iron, molybdenum, tin, titanium and zinc. EPA received data using only method 245.1 formercury.
Finally, EPA received data using only method 160.2 for TSS.
Table 5-10.   Sampling Episode 6181 Analytical Results1
Episode 6181
Pollutant
TSS (mg/1)
Aluminum
Antimony
Arsenic
Cadmium
Chromium
Copper
Iron
Avg.
Influent
Cone.
78.8
7000
874
278
103
37.0
528
3050
Quanti-
tation
Limit
(QL)"
4
100
60
10
5
10
10
20
10X
QL
40
500*
600
100
50
100
100
200
Treatable
Level?
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Avg.
Effluent
Cone.
4.77
102
806
87.8
7.1
13.1
11.9
23.6
%
Removal
93.95
98.54
7.78
68.42
93.11
64.59
97.75
99.23
Pollutants used
from Epsiode 6181
to Develop Final
Regulations
TSS
Aluminum
Antimony
Arsenic
Cadmium
-
Copper
Iron
                                         5-12

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Episode 6181
Pollutant
Lead
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
Zinc
Avg.
Influent
Cone.
895
3.40
387
136
20.0
151
345
1690
Quanti-
tation
Limit
(QL)+
10
0.2
50
10
5
50
10
20
10X
QL
100
2
500
100
50
500
100
200
Treatable
Level?
Yes
Yes
No
Yes
No
No
Yes
Yes
Avg.
Effluent
Cone.
10.3
0.209
445
137
5.37
62.6
10
23.1
%
Removal
98.85
93.85
-14.99
-0.74
73.15
58.54
97.10
98.63
Pollutants used
from Epsiode 6181
to Develop Final
Regulations
Lead
Mercury
-
-
-
-
Titanium
Zinc
1   Values in (ug/1) unless otherwise noted.
+  Quantitation limit development is detailed in Commercial HWC record (W-97-08, Item 16.4.9, Attachment VI.)
*  For aluminum, the treatable level was set at 5 times the quantitation limit of 100 ug/1 because 100 ug/1 is a high
   quantitation limit.
Table 5-11.   Sampling Episode 6183 Analytical Results1
Episode 6183
Pollutant
TSS (mg/1)
Aluminum
Antimony
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Mercury
Molybdenum
Selenium
Avg.
Influent
Cone.
350
61500
1710
1210
97.7
2250
1970
231000
1600
219
1550
113
Quanti-
tation
Limit
(QL)+
4
100
60
10
5
10
10
20
10
0.2
50
10
10X
QL
40
500*
600
100
50
100
100
200
100
2
500
100
Treatable
Level?
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
yes
Avg.
Effluent
Cone.
84.6
319
289
26.1
5
10
10
434
10
0.478
856
32.8
%
Removal
75.83
99.48
83.10
97.84
94.88
99.56
99.49
99.81
99.38
99.78
44.77
70.97
Pollutants used
from Epsiode
6183 to Develop
Final Regulations
TSS
Alumjpum
Antimony
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Mercury
Molybdenum
Selenium
                                               5-13

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Episode 6 183

Pollutant


Silver
Tin
Titanium
Zinc
Avg.
Influent
Cone.
69.8
1330
4030
8300
Quanti-
tation
Limit
5
50
10
20
10X
QL

50
500
100
200

Treatable
Level?


yes
yes
yes
yes

Avg.
Effluent
Cone.

5.53
134
10
64.3

%
Removal


92.08
89.92
99.75
99.23
Pollutants used
from Epsiode
6 183 to Develop
Final Regulations

Silver
Tin
Titanium
Zinc
1   Values in (ug/1) unless otherwise noted.
+  Quantitation limit development is detailed in Commercial HWC record (W-97-08, Item 16.4.9, Attachment VI.)
*  For aluminum, the treatable level was set at 5 times the quantitation limit of 100 ug/1 because 100 ug/1 is a high
   quantitation limit.
5.5
SELECTION OF POLLUTANTS TO BE REGULATED FOR PSES AND PSNS
       Indirect dischargers in the CHWC Industry send their wastewater streams to a POTW for further
treatment, unlike direct dischargers, whose wastewater will receive no further treatment once it leaves their
facility. Therefore, the levels of pollutants allowable in the wastewater of an indirect discharger are
dependent upon (1) whether a given pollutant "passes through" the POTW's treatment system or (2)
whether additional treatment provided by the POTW will result in removal of the pollutant to a level
equivalent to that obtained through treatment by a direct discharger.
5.5.1
Removal Comparison Approach
       To establish PSES, EPA must first determine which of the CHWC Industry pollutants of concern
(identified earlier in Section 5.3) may not be susceptible to POTW treatment, interfere with, or are
incompatible with the operation of POTWs (including interferences with sludge disposal practices). EPA
evaluates the susceptibility of a pollutant to POTW treatment by looking at the removal performance of
POTWs for a particular pollutant. EPA's removal comparison evaluates the percentage removed by
POTWs with the percentage removed by direct dischargers using BPT/BCT/BAT technology. EPA has
                                          5-14

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assumed, for the purposes of its removal comparison and based upon the data received, that the untreated
wastewater at indirect discharge facilities is not significantly different from direct discharge facilities.
       EPA's comparison satisfies two competing objectives set by Congress: (1) that standards for
indirect dischargers be equivalent to standards for direct dischargers, and (2) that the treatment capability
and performance of the POTW be recognized and taken into account in regulating the discharge of
pollutants from indirect dischargers. Rather than compare the mass or concentration of pollutants
discharged by the POTW with the mass or concentration of pollutants discharged by a BAT facility, EPA
compares the percentage of the pollutants removed by the facility with the POTW removal. EPA takes
this approach because a comparison of mass or concentration of pollutants in a POTW effluent with
pollutants in a BAT facility's effluent would not take into account the mass of pollutants discharged to the
POTW from non-industrial sources, nor the dilution of the pollutants in the POTW effluent to lower
concentrations from the addition of large amounts of non-industrial wastewater.

5.5.2         50 POTW Study Database

       For past effluent guidelines, a study of 50 well-operated POTWs was used for the pass-through
analysis. This study is referred to as the "The Fate of Priority Pollutants in Publicly Owned Treatment
Works", September 1982 (EPA 440/1-82/303), also known as the 50 POTW Study. Because the data
collected for evaluating POTW removals included influent levels of pollutants that were close to the
detection limit, the POTW data were edited to eliminate influent levels less than 10 times the minimum level
and the corresponding effluent values, except in the cases where none of the influent concentrations
exceeded 10 times the minimum level. In the latter case,  where no influent data exceeded 10 times the
minimum level, the data were edited to eliminate influent values less than 5 times the minimum level.
Further, where no influent data exceeded 5 times the minimum level, the data were edited to eliminate
influent values less than 20 ug/1 and the corresponding effluent values. These editing rules were used to
allow for the possibility that low POTW removals simply reflected the low influent levels.
       EPA then averaged the remaining influent data and also averaged the remaining effluent data from
the 50 POTW database. The percent removals achieved for each pollutant were determined from these
                                          5-15

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averaged influent and effluent levels: This percent removal was then compared to the percent removal for
the BAT option treatment technology.
5.53
Final POTWData Editing
       The final percent removal for each pollutant was selected based on a data hierarchy, which was
related to the quality of the data source. This hierarchy was:

       1.  50 POTW Study Data (1 Ox NOMDL edit)
       2.  50 POTW Study Data (5x NOMDL edit)
       3.  50 POTW Study Data (20 ug/1 edit)

       The final POTW removals for the CHWC regulated pollutants, determined via the data use
hierarchy, are presented in Table 5-12.
Table 5-12.   Final POTW Removals for CHWC Industry Pollutants
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
CAS
Number
7440382
7440439
7440473
7440508
7439921
7439976
7440224
7440326
7440666
Percent
Removal
66
90
91
84
92
90
88
92
78
Source of Data
50 POTW - (20 ug/1 edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
50 POTW - (lOx NOMDL edit)
                                        5-16

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5.5.4
Final Removal Comparison Results
       For each CHWC regulated pollutant, the daily removals were calculated using the BPT/BCT/BAT
data. Then, the average overall BPT/BCT/BAT removal was calculated for each pollutant from the daily
removals (see  Table 5-13).  The averaging of daily removals is appropriate for this industry as
BPT/BCT/BAT treatment technologies typically have retention times of less than one day. For the final
assessment, the final POTW removal data determined for each CHWC regulated pollutant was compared
to the percent removal achieved for that pollutantusing the BPT/BCT/BAT option treatment technologies.
Of the 9 pollutants regulated under BPT/BCT/BAT, all were found to pass through for the regulatory
wastewater treatment technology option selected (see Section 7 for a description of the selected
BPT/BCT/BAT Regulatory Option) and are proposed for PSES.  The final results for the CHWC
Regulatory Option are presented in Table 5-14.
Table 5-13.   Sampling Episode Percent Removals

Aluminum
Antimony
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
6181 Percent
Removal
98.54
7.78
68.42
93.11
*64.59
97.75
99.23
98.85
93.85
*- 14.99
*-0.74
*73.15
*58.54
97.10
6 183 Percent
Removal
99.48
83.10
97.84
94.88
99.56
99.49
99.81
99.38
99.78
44.77
70.97
92.08
89.92
99.75
4646 Percent
Removal
85
49
98
98
95
99
98
99
97
38
89
98
99
99
Average Percent
Removal
94
47
88
95
97
99
99
99
97
41
80
95
94
99
                                        5-17

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Zinc
6181 Percent
Removal
98.63
6183 Percent
Removal
99.23
4646 Percent
Removal
99
Average Percent
Removal
99
   These pollutants from Episode 6181 could not be used to develop final regulations either because they were not
   found at a treatable level or because the percent removal was a negative value.
Table 5-14.   Final Results for CHWC Industry Regulatory Option
Pollutant
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
Option Percent Removal
88
95
97
99
99
97
95
99
99
POTW Percent Removal
66
90
91
84
92
90
88
92
78
                                               5-18

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SECTION 6

WASTEWATER TREATMENT TECHNOLOGIES



       This section describes the technologies available for the treatment of wastewater generated by the

55 commercial facilities within the Commercial Hazardous Waste Combustor (CHWC) Industry. This

section also presents an evaluation of performance data on treatment systems collected by EPA during field

sampling programs and the rationale used in the development of the regulatory options. Specifically,

Section 6.1 describes the technologies used by CHWC facilities to treat air pollution control, flue  gas

quench, and ash/slag quench wastewaters, which are the only types of wastewater covered by this

regulation. Section 6.2 describes technologies used by CHWC facilities for the treatment of wastewater

generated as a result of CHWC operations (e.g., container wash water and truck wash water) for which

EPAisnotproposingregulations. Section 6.3 lists technologies used by CHWC facilities for the treatment

of wastewater generated as a result of other operations on-site (e.g., landfill leachate and sanitary water).

Section 6.4 presents the EPA performance data on selected treatment technologies as well as the rationale

used in selecting the treatment technologies for the regulatory options.

       Of the 55 CHWC facilities, 16 facilities generate no wastewater. A breakdown of the types of

wastewaters collected at the remaining 39 CHWC facilities which generate wastewater is as follows:


       Type  of wastewater collected                             Number of CHWC facilities
       CHWC wastewaters only                                                8
              (air pollution control, ash/slag quench, flue gas quench)
       Wastewaters generated from CHWC operations only                           7
              (container, area, and truck wash waters)
       Other on-site wastewaters only                                            9
              (sanitary wastewater, leachates)
       CHWC wastewaters  and wastewaters generated from
       CHWC operations                                                       13
       CHWC wastewaters, wastewaters generated from CHWC
       operations, and other on-site wastewaters                                     1
       Wastewaters generated from CHWC operations and other on-site
       wastewaters                                                           3

       As demonstrated above,  only 22 of the 55 CHWC facilities generate CHWC wastewaters and

therefore, were considered to be within the scope of this regulation.

                                           6-1

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 6.1           AVAILABLE BAT AND PSES TECHNOLOGIES

       CHWC facilities use either physical/chemical treatment technology to treat CHWC wastewaters
 or treatment and disposal methods that result in no discharge of CHWC wastewaters.
       Through its CWA Section 308 Questionnaire, EPA obtained information on nine different
 wastewater treatment technologies currently in use by the 22 CHWC facilities for the treatment of air
 pollution control, flue gas quench, and ash/slag quench wastewater. In addition, EPA collected other
 detailed information onavailable technologies from engineeringplant visits to anumber of CHWC facilities.
 The data presented in Section 6.4 are based on these data collection activities.

 6.1.1         Physical/Chemical Treatment
 6.1.1.1       Equalization

       Wastewater generation rates at incinerators are sometimes variable due to variations in bum rates
 and system down times. To allow for the equalization of pollutant loadings and flow rates, CHWC
 wastewaters may be collected in tanks or lined ponds prior to treatment These are designed with sufficient
 capacity to hold the peak flows and thus dampen the variation in hydraulic and pollutant loads.
 Minimization of this variability increases the performance and reliability of downstream treatment systems,
 and can reduce the size of subsequent treatment by reducing the maximum flow rates and concentrations
 ofpollutants thattheywill experience. Equalization also lowers the operating costs of associated treatment
 units by reducing instantaneous treatment capacity demand and by optimizing the amount of treatment
 chemicals required for a less erratic set of treatment variables. The EPA's Section 308 Questionnaire
 database identifies 10 facilities that use equalization technology as part of their treatment of CHWC
 wastewaters.
       EqualizationsystenisconsistofsteelOTfiberglasshol^
capacity to contain peak flow conditions and wastewater volumes of high pollutant loadings. Detention
times can vary from a few hours to several days, with one day being a typical value.  Some equalization
                                          6-2

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systems contain mechanical mixing systems that enhance the equalization process. A breakdown of
equalization systems used is as follows:

       Equalization Type                  Number of Units
       Unstirred                                  7
       Mechanically stirred                         2
       A typical equalization system is shown in Figure 6-1.

6.1.1.2        Neutralization or pH Control

       In the treatment of CHWC wastewaters, neutralization or pH control systems are used in
conjunction with certain chemical treatment processes, such as chemical precipitation, to adjust the pH of
the wastewater to optimize process control. Acids, such as sulfuric acid or hydrochloric acid, are added
to reduce pH, whereas, alkalis, such as sodium hydroxides, are added to raise pH values. Neutralization
may be performed in a holding tank, rapid mix tank, or an equalization tank.  Neutralization systems are
widely used at CHWC facilities for pH control in chemical precipitation systems. Chemicals, such as
sodium hydroxide or lime, are frequently used in order to raise the pH of the wastewater to a range
somewhere between 9 to 12 in order to optimize precipitation of metal compounds.  Acids, such as
hydrcrcUoric add, are also used in conjunction with ferric cMoride for chemical predpitation^Neu^
systems at the end of a treatment system are typically designed to control the pH of the discharge to
between6and9. There are 14neutrak^tion systems in place among the CHWC fecilities that use various
caustic and/or alkalis to treat CHWC wastewaters. A breakdown of these neutralization systems is as
follows:
       Type of Neutralization              Number of Units
       Caustic                                  4
       Acid                                    2
       Multiple Chemicals                         5
       Other                                    1
Figure 6-2 presents a flow diagram for a typical neutralization system.
                                           6-3

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           Wastewater
             Influent
                             Equalization Tank
.Equalized
Wastewater
Effluent
Figure 6-1. Equalization
                                      6-4

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           Wastewater
             Influent
                            Neutralization Tank
Neutralized
Wastewater
Effluent
Figure 6-2. Neutralization
                                      6-5

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6.1.1.3        Flocculation

       Flocculation is a treatment technology used to enhance sedimentation or filtration treatment.
Flocculation precedes these processes and consists usually of a rapid mix tank, or in-line mixer and a
flocculation tank. The waste stream is initially mixed while a flocculation chemical is added. Flocculants
adhere readily to suspended solids and each other to facilitate gravity sedimentation or filtration.
Coagulants can be added to reduce the electrostatic surface charges and enhance the formation of complex
hydrous oxides. Coagulation allows for the formation of larger, heavier particles, or flocculants (which are
usually formed in a flocculation chamber), that can  settle faster.  There are three different types of
flocculants commonly used; inorganic electrolytes, natural organic polymers, and synthetic polyelectrolytes.
The selection of the specific treatment chemical is highly dependent upon the characteristics and chemical
properties of the contaminants. A rapid mix tank is usually designed for a detention time ranging from 15
seconds to several minutes. After mixing, the coagulated wastewater flows to a flocculation basin where
slowmixingofthe waste occurs. The slow mixing allows forthe particles to agglomerate into heavier, more
settleable solids. Mixing is provided either by mechanical paddle mixers or by diffused air. Flocculation
basins are typically designed for a detention time of 15 to 60 minutes. There are 5 flocculation systems
used among the CHWC facilities used to treat CHWC wastewaters.

6.1.1.4       Gravity-Assisted Separation

       Gravity-assisted separation is a simple, economical, and widely used method for the treatment of
CHWC wastewaters. There are 12 such systems in place at the  CHWC facilities. Clarification systems
remove suspended matter by allowing the wastewater to become quiescent As a result, suspended matter,
which is heavier than water, settles to the bottom, forming a sludge which can be removed. This process
may take place in specially designed tanks, or in earthen ponds and basins. Sedimentation units at CHWC
facilities are typically used as either primary treatment options to remove suspended solids or following a
chemical precipitation process.
                                            6-6

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       Clarifiers may be rectangular, square, or circular in shape. In rectangular tanks, wastewater flows
from one end of the tank to the other with settled sludge collected into a hopper located at one end of the
tank. In circular tanks, flow enters from the center and flows towards the outside edge with sludge
collected in a center hopper. Treated wastewater exits the clarifier by flowing over a weir located at the
top of the clarifier. Sludge which accumulates in the bottom of the clarifiers is periodically removed and
is typically stabilized and/or dewatered prior to disposal.
       Flocculation systems are commonly used in conjunction with gravity assisted clarification systems
in order to improve their solids removal efficiency. Some clarifiers are designed with a center well to
introduce flocculants and allow for coagulation in order to improve removal efficiencies. A schematic of a
typical clarification system using coagulation and flocculation is shown in Figure 6-3. The main design
parameters used in designing a clarifier are the overflow rate, detention time and the side water depth.  The
overflow rate is the measure of the flow as a function of the surface area of the clarifier. Typical design
parameters used for both primary and secondary clarifiers are presented below:
 Design Parameter                 Primary                        Secondary
 Overflow Rate, gpd/sq ft            600-1,000                       500-700
 Detention Time, min               90-150                         90-150
 Minimum Side Water Depth, ft        8                             10
Source: ASCE/WEF, Design of Municipal Wastewater Treatment Plants, 1991.

       There are three facilities that use corrugated plate interceptor technology. These systems include
a series of small (approximately 2 inch square) inclined tubes in the clarification settling zone.  The
suspended matter must only travel a short distance, when settling or floating, before they reach a surface
of the tube. At me tubes'surface, me suspended matter further coagulates. Because of the enhanced
removal mechanism, corrugated plate interceptor units can have much smaller settling chambers  than
standard clarifiers.

6.1.1.5       Chemical Precipitation

       Chemical precipitation is used for the removal of metal compounds from wastewater. In the
chemical precipitation process, soluble metallic ions and certain anions, which are found in CHWC
                                            6-7

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                                                                 Sludge
Figure 6-3. Clarification System Incorporating Coagolation and Floceulation
                                    6-8

-------
wastewatere, arc converted to insohibk forms, which precipitate from the solution.  Most metals are
rdativelyinsolubk as hydroxides, suffides, or cartxjnates. Coagulation piocesses are iised in cagmction
                                                                                      The
(or some other form of gravity assisted sedimentation). Other treatment processes such as equalization,
chemical oxidation orreduction(e^hexavalent chromium reduction), precede the chemical piecipitation
process. The perfonnance of the chemical precipitation process is affected by chemical interactions,
temperature, pH, solubility of waste contaminants, and mixing effects. There are a total of 7 chemical
precipitation systems in use by the CHWC facilities to treat CHWC wastewater.
       ConimonpnxipitaDOTcheniicakusedintheOiWCIndustiyinch^
ash, sodium aiffidc. and ahim Pore diemicakiisedm the precipitant process f»
     ilatinn tnrJiidg «iHmv- and phmyhnrir aci^ fetrir fhlnritytr« Many facilities USC,
orhavedienieanstouse^aconibinationofthesediemicals. Precipitation using sodium hydroxide or lime
is the conventional memod of ronoving metals from wastewater. However, sulfide precipitation is also
frequently used instead of hydroxide precipitation in order to remove certain metal ions. Hydroxide
precipitation is effective iniemovmg such metals as antiniony,anenic,dmxmum, copper, ka4 mercury,
nickel, and zinc. Sulfide precipitation is more appropriate for removing mercury, lead, and silver.
Carbonate precipitation, while not frequently used in the QiWCmdustry, is another mediod of chemical
                                                     Ahim^anotherprecipitant/coagulantagent
infrequendyused,foniualuniinumhydroxk)esinwastewa^
alkalinity. Aluminiimhydroxideisaninsohd>legeiaanousfkx:which settles slowly and entraps suspended
materials. For metals sudi as arsenk; and cadnTnim.cxipiecipitation wife
treatment process.
       Hydroxide piecipitation using fane or sodium hydroxide is the most commonly used means of
chemical precipitation in the CHWC industry, and of these, lime is iised more ofien than sodium bydroxkk
The chief advantage of hone over caustic is its lower cost However, fane is more difficult to handle and
feed, as it must be slaked, shmied, and mixed, and can plug the feed system tines. Ume precipitation also
                                           6-9

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producesalaigervolumeof sludge. The reaction mechanism forprecipitation of a divalent metal using lime
is shown below:
                                + Ca(OH)2 -  M(OH)2 + Ca"

       The reaction mechanism forprecipitation of a divalent metal using sodium hydroxide is as follows:

                                + 2NaOH - M(OH)2
       Inadditiontothetypeoftreatmentchemical chosen, another important design factorin the chemical
precipitation operation is pH. Metal hydroxides are amphoteric, meaning mat they can react chemically
as acids or bases. As such, their solubilities increase toward both lower and higher pH levels. Therefore,
there is an optimum pH for precipitation for each metal, which corresponds to its point of minimum
solubility. Figure 6-4 presents calculated solubilities of metal hydroxides. Another key consideration in
a chemical precipitation application is the detention time in the sedimentation phase of the process, which
is specific to the wastewater being treated and the desired effluent quality.
       The first step of a chemical precipitation process is pH adjustment and the addition of coagulants.
This process usually takes place in separate mixing and flocculation tanks. After mixing the wastewater
with treatment chemicals, the resultant mixture is allowed to agglomerate in the flocculation tank which is
slowly mixed by either mechanical means, such as mixers, or recirculation pumping. The wastewater then
undergoes a separation/dewatering process such as clarification or filtration, where theprecipitated metals
are removed from solution. In a clarification system, a flocculent, such as a polymer, is sometimes added
to aid in the settling process.  The resulting sludge from the clarifier or filter must be further treated,
disposed, or recycled. A typical chemical precipitation system is shown in Figure 6-5.
                                          6-10

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              100
               10 -
                1 -
              0.1 J
         §
g


I

1
        3.   0.01
        o
        GO
            0.001 -
           0.0001
                                                 8


                                                PH
                                                10
12
14
16
Figure 6-4.  Calculated Solubilities of Metal Hydroxides
                                            6-11

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       Wastewater
        Influent
                   Chemical Precipitation Tank
Figure 6-5.  Chemical Precipitation System Design

                                         6-12

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6.1.1.6       Stripping

       Stripping refers to the removal of pollutant compounds from a wastewater by the passage of air,
steam, or other gas, through the liquid. The stripped volatile components are generally condensed and
recovered for reuse, disposal, or allowed to be stripped into the atmosphere. If the pollutants are in
sufficiently low concentrations, the gaseous phase can be emitted through a stack without treatment.
       Air stripping is a process in which air is brought into contact with the liquid.  During this contact,
the volatile compounds move from the liquid to the gas stream. The process usually takes place in a
stripping tower (as shown in Figure 6-6) which consists of a vertical shell filled with packing material to
increase the surface area for gas-liquid contact Usually, the liquid flows down through the stripping column
and air passes upward in a counter-current fashion. Another orientation is called "crossflow", where the
air is pulled through the sides of the tower along its entire length.
       There is only one CHWC facility that uses air stripping as a treatment option for the removal of
excess treatment chemicals contained in its flue gas quench wastewater.

6.1.1.7       Filtration

       Filtration is a method for separating solid particles from wastewaters through the use of a porous
medium. The driving force in filtration is a pressure gradient, caused by gravity, centrifugal force, vacuum,
or higher than atmospheric pressure.  Filtration treatment processes can be used at CHWC facilities to
remove solids from wastewaters after a chemical precipitation treatment step, or can used as the primary
source of treatment. Filtration processes include a broad range of media and membrane separation
technologies from sand filtration to ultrafiltration. To aid in removal, the filter medium may be precoated
with a filtration aid such as ground cellulose or diatomaceous earth.
       CHWC facilities currently have the following types of filtration systems in operation to treat their
CHWC wastewaters:
                                           6-13

-------
             Wastewater
               Influent
         Air
                       Blower
                                          I—U-LTTJ—LTTJ-'
                                                                Off-gas
                                                                     Distributor
                                                                  Treated
                                                                  Effluent
Figure 6-6.  Typical Air Stripping System
                                            6-14

-------
       Type of Filtration System           Number of Units
       Sand                                      2
       Granular Multimedia                         1
       Fabric                                    1
       Ultrafiltration                               1

       Dissolved compounds in CHWC wastewaters can be pretreated by chemical precipitation
processes to convert thecompound to an insoluble solid particle before filtration. Polymers can be injected
into the filter feed piping downstream of feed pumps to enhance flocculation of smaller floes that may
escape an upstream darifier.
       The following paragraphs describe each type of filtration system.

6.1.1.7.1      Sand/Multimedia Filtration

       Granular bed filtration in the CHWC industry is used primarily for achieving supplemental removal
of residual suspended solids from the effluent of chemical treatment processes, or rarely, as the primary
form of wastewater treatment.  These filters can be operated either by gravity or in a pressure vessel. In
granular bed filtration, the wastewater stream is sent through a bed containing one or more layers of
different granular materials. The solids are retained in the voids between the media particles while the
wastewater passes through the bed. Typical media used in granular bed filtersinclude anthracite coal, sand,
and garnet. These media can be used alone, such as in sand filtration, or in a multimedia combination.
Multimedia filters are designed such that the individual layers of media remain fairly discrete. This is
accomplished by selecting appropriate filter loading rates, media grain size, and bed density. Hydraulic
loading rates for a multimedia filter are between 4 to 10 gpm/sq ft. A typical multimedia filter vessel is
shown in Figure 6-7.
       The complete filtration process involves two phases: filtration and backwashing.  As the filter
becomes filled with trapped solids, the efficiency of the filtration process falls off. Head loss is a measure
of solids trapped in the filter. As the head loss  across the filter bed increases to a limiting value, the end
of the filter run is reached and the filter must be backwashed to remove the suspended solids in the bed.
During backwashing, the flow  through the filter is reversed so that the solids trapped in the media are

                                            6-15

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         Coarse Media
         Finer Media
         Finest Media
             Support
     Underdrain Chamber
                               Wastewater Influent
                                      Coal
Silica Sand
                                    Garnet
  Gravel
                                              t
                               Treated Effluent
                                                           Backwash
                   Backwash
Figure 6-7. Multimedia Filtration
                                    6-16

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dislodged and can exit the filter.  The bed may also be agitated with air to aid in solids removal.  The
backwash water is then recycled back into the wastewater feed stream.

6.1.1.7.2     Fabric Filters

       Fabric filters consist of a vessel that contains a cloth or paper barrier through which the wastewater
must pass. The suspended matter is screened by the fabric, and the effectiveness of the filter depends on
the mesh size of the fabric. Fabric filters may either be backwashed, or built as disposable units.
       For waters having less than 10 mg/1 suspended solids, cartridge fabric filters may be cost effective.
Cartridge filters have very low capital cost and can remove particles of one micron or larger in size. Using
two-stage cartridge filters (coarse and fine) in series extends the life of the fine cartridge. Disposable or
backwashable bag filters are also available and may be quite cost effective for certain applications.
Typically, these fabric filters act as a pre-filter and are used to remove suspended solids prior to other
filtrations systems in order to protect membranes and equipment and reduce solids fouling.

6.1.1.7.3     Ultrafiltration

       Ultrafiltrationuses a semi-permeable, microporous membrane, through which the wastewater is
passed under pressure.  Water and low molecular weight solutes, such as salts and surfactants, pass
through the membrane and are removed as permeate. Emulsified oils and suspended solids are rejected
by the membrane and removed with some of the wastewater as a concentrated liquid. The concentrate
is recirculated through the membrane unit until the flow of permeate drops, while the permeate can either
be discharged or passed along to another treatment unit.  The concentrate is usually stored and held for
furthertreatmentordisposal. Several typesoMtxafOtrationmembranes configurations areavaikble:tubular,
spiral wound, hollow fiber, and plate and frame. A typical ultrafiltration system is presented in Figure 6-8.
       Ultrafiltrationin the CHWC industry is used for the treatment of metal-bearing wastewaters. It can
remove substances with molecular weights greater than 500, including suspended solids, oil and grease,
and complexed heavy metals. Ultrafiltration is used when the solute molecules are greater than ten times
the size of the solvent molecules, and are less than one-half micron.  The primary design consideration in
                                            6-17

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                           Permeate (Treated Effluent)
    Wastewater
    Feed
Concentrate
                               Membrane Cross-section
Figure 6-8. Ultrafiltration System Diagram

                                       6-18

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ultrafiltration is the membrane selection. A membrane pore size is chosen based on the size of the
contaminant particles targeted for removal. Other design parameters to be considered are the solids
concentration, viscosity, and temperature ofthe feed stream, and the membrane permeability and thickness.

6.1.1.8       Carbon Adsorption

       Granular activated carbon (GAC) adsorption is a physical separation process in which organic and
inorganic materials are removed from wastewater by adsorption, attraction, and/or accumulation ofthe
compounds on the surface ofthe carbon granules. While the primary removal mechanism is adsorption,
the activated carbon also acts as a filter for additional pollutant removal. Adsorption capacities of 0.5 to
10 percent by weight are typical.  Spent carbon can be regenerated thermally on site by processes such
as wet-air oxidation or steam stripping.  For smaller operations, spent carbon can be regenerated off site
or sent directly for disposal. Vendors of carbon typically, under contract, exchange spent carbon with fresh
carbon.
       Activated carbon systems usually consist of a vessel containing a bed of carbon (typically 4 to 12
feet in depth), whereby the wastewater is either passed upflow or downflow through the filter bed. A
carbon adsorption vessel is shown in Figure 6-9. Carbon vessels are typically operated under pressure,
however, some designs use gravity beds. For smaller applications, GAC systems are also available in
canister systems which can be readily changed-out and sent for either off-site regeneration or disposal. The
key design parameter is the adsorption capacity of the GAC, which is a measure ofthe mass of contaminant
adsorbed per unit mass  of carbon, and is a function ofthe chemical compounds being removed, type of
carbon used, and process and operating conditions. The volume of carbon required is based upon the
COD ofthe wastewaterto be treated and desired frequency of carbon change-outs. The vessel is typically
designed for an empty bed contact time of 15 to 60 minutes. Non-polar, high molecular weight organics
with low solubility are readily adsorbed using GAC.  Certain organic compounds have a competitive
advantage for adsorption onto the GAC, which results in compounds being preferentially adsorbed or
causing other less competitive compounds to be desorbed from the GAC.  Most organic compounds and
                                           6-19

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      Fresh
      Carbon
      Fill
        Collector/
        Distributor
            Spent
            Carbon
            Discharge
                                         Wastewater
                                         Influent
Backwash
                                                           Backwash
                                                              Treated
                                                              Effluent
Figure 6-9. Granular Activated Carbon Adsorption

                                       6-20

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some metals typically found in CHWC wastewaters are effectively removed using GAC. Two CHWC
facilities employ GAC for treatment of CHWC wastewaters.

6.1.1.9        Chromium Reduction

       Chemical reduction processes involve a chemical reaction in which electrons are transferred from
one chemical to another in order to reduce the chemical state of a contaminant The main application of
chemical reduction in CHWC wastewater treatment is the reduction of hexavalent chromium to trivalent
chromium. The reduction enables the trivalent chromium to be precipitated from solution in conjunction
with other metallic salts. Sodium bisulfate is the reducing agent used by one CHWC facility that
incorporates reduction technology for treatment of its CHWC wastewater.
       Once the chromium has been reduced to the trivalent state, it can be further treated in a chemical
precipitation process, where it is removed as a metal hydroxide or sulfide. A typical chromium reduction
process is shown in Figure 6-10.

6.1.2         Sludge Handling

       Sludges are generated by anumber of treatment technologies, including gravity-assisted separation
and filtration. These sludges are further processed at CHWC facilities using various methods. Following
are the number of CHWC facilities which employ each type of sludge handling process.

       Type of Sludge Handling           Number of Units
       Sludge Slunying                            1
       Vacuum Filtration                           1
       Pressure Filtration                           6
       Centrifuge                                 1
       Dryer                                     1

       The following paragraphs describe each type of sludge handling system.
                                          6-21

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                       Sulfuric
                         Acid
    Treatment
     Chemical
          D-
           pH Controller
            Wastewater
              Influent

                 I	
i-
                             1
	a
 Chemical Controller
                                 Reaction Tank
                                                               ->• Treated
                                                                 Effluent
Figure 6-10. Chromium Reduction
                                        6-22

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6.1.2.1       Sludge Slurrying

       Sludge slurrying is the process of transporting sludge from one treatment process to another. It can
only be applied to liquid sludges that can be pumped through a pipe under pressure.  Only one CHWC
facility utilizes a sludge slurry process.

6.1.2.2       Vacuum Filtration

       A typical vacuum filtration unit is shown in Figure 6-11. Vacuum filtration provides more
aggressive sludge drying by placing the sludge on a screen or mesh and drawing a vacuum through the
screen, which draws the liquid out of the sludge. Often the screen is oriented on a cylindrical support,
which rotates.  The sludge is distributed over the cylinder as it rotates. As the screen rotates, the dried
sludge is removed with a scraper, and collected in a hopper placed below the filtration unit These units
can dry sludges to approximately 30 to 50 percent solids. Only one CHWC facility utilizes vacuum
filtration for sludge dewatering.

6.1.2.3       Pressure Filtration

       The plate and frame pressure filtration system is the most common process used by the CHWC
industry to dewater sludges from physical/chemical treatment processes.  Six CHWC facilities use a plate
and frame pressure filtration system to dewater sludge.  Sludges generated by CHWC wastewater
treatment processes are typically 2 to 5 percent solids by weight These sludges are then dewatered to a
30 to SO percent solids by weight using a plate and frame filter. Sludges from treatment systems can be
thickened by gravity or stabilized prior to dewatering, or may be processed directly with the plate and
frame pressure filtration unit.
       A pressure filter consists of a series of screens (see Figure 6-12) upon which the sludge is applied
under pressure. A precoat material may be applied to the screens to aid  in solids removal. The applied
pressure forces the liquid through the screen, leaving the solids to accumulate behind the screen. Filtrate
which passes through the screen media is typically recirculated back to the head of the on-site wastewater
                                            6-23

-------
       Influent
                                                                          Fitter Cake
                                                                          Discharge
                                                                      Hopper
                                                       Spray Wash
Figure 6-11.  Vacuum Filtration
                                            6-24

-------
      Fixed End
     Sludge
      Influent
   Filtrate
                                                         Filter Cloth
                                                           Filter Cake
                                                         Plate Assembly
Figure 6-12. Plate and Frame Pressure Filtration System Diagram
                                   6-25

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treatment plant.  Screens (also referred to as plates) are held by frames placed side by side and held
together with a vice-type mechanism. The unit processes sludge until all of the plates are filled with dry
sludge as indicated by a marked rise in the application pressure. Afterwards, the vice holding the plates
is loosened and the frames separated.  Dried sludge is manually scraped from the plates and collected in
a hopper for final disposal. The size of the filter and the number of plates utilized depends not only on the
amount of solids produced by treatment processes, but also is highly dependent on the desired operational
requirements for the filter (e.g., shifts per day). A plate and frame pressure filter can produce a sludge with
a higher solids content than most other methods of sludge dewatering. Pressure filters offer operational
flexibility since they are typically operated in a batch mode.

6.1.2.4        Centrifuges

        Centrifuges use centripetal force to separate the liquid from the sludge solids. The sludge enters
the top of a rapidly spinning cylinder where the solids are "thrown" to the outer wall of the vessel. The
separated solids are continually removed through an orifice on the outer wall, and the liquid stream is
collected at the bottom.
        Because the unit is spinning rapidly, and sludge often contains abrasive materials, centrifuges often
require a high level of maintenance. Centrifuges typically dry sludgesto the range of 20 to 30 percent soh'ds
by weight. One CHWC facility utilizes a centrifuge for sludge dewatering.

6.1.2.5        Dryer

       One CHWC facility employs a sludge dryerto remove the moisture from its sludge prior to disposal
of the solid waste. The sludge dryer uses thermal energy derived from steam or electricity to evaporate
the moisture from the sludge in a drying bed/tank.
                                            6-26

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6.1.3         Zero Discharge Options

       Some CHWC facilities use treatment and disposal practices that result in no discharge of CHWC
wastewaters to surface waters. These practices are described below.

6.1.3.1       Incineration

       Two CHWC facilities generate annual flow rates of 108,100 gallons and 300,000 gallons and
dispose of their CHWC wastewater exclusively by incinerating them on site. Normally, these wastewater
flows are minimal compared to the amount of fuel and/or waste the thermal unit handles, and as such, these
CHWC facilities find it cheaper to dispose of their wastewaters in this fashion rather than utilizing other
disposal methods.

6.1.3.2       Off-Site Disposal

       Three CHWC facilities transport their wastewater off site to either another CHWC facility's
wastewater treatment system or to a Centralized Wastewater Treatment (CWT) facility for ultimate
disposal. Thesethree facilities generate annual flow rates of 18,250 gallons, 10,000 gallons, and 43 million
gallons. A fourth facility with an annual flow rate of 4.865 million gallons sells their wastewater as oil well
completion fluid.

6.1.3.3       Evaporation/Land Applied

       One CHWC facility with an annual flow rate of approximately 100 million gallons discharges its
CHWC wastewater into on-site surface impoundments as a means of ultimate disposal. There is no
discharge to a receiving water from these impoundments.  Rather, water is lost by evaporation.
                                           6-27

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6.2           TREATMENT OPTIONS FOR OTHER WASTEWATERS GENERATED BY
              CHWC OPERATIONS

       CHWC facilities employ the same two treatment options (physical/chemical treatment or zero
discharge) to treat other wastewaters generated as a result of CHWC operations (see Section 4).  Most
of the same treatment technologies are used to treat these secondary wastewaters as are being used to treat
CHWC wastewaters. The EPA's Section 308 Questionnaire obtained information on eight different
technologies currently in use by 37 CHWC facilities for the treatment of various washdown waters, run-off
from CHWC areas, and laboratory wastewater. Abreakdown of these treatment systems is shown below:

       Treatment Technology             Number of CHWC Facilities
       Equalization                                 7
       Neutralization                                8
       Flocculation                                  5
       Gravity Assisted Separation                      7
       Chemical Precipitation                          5
       Air Stripping                                 1
       Carbon Adsorption                             5
       Chemical Oxidation                            2
       Sludge Handling                              9

Each of the above treatment technologies, with the exception of chemical oxidation, has been previously
described in Section 6.1. As for CHWC wastewaters, the design and operation of these treatment systems
to treat other wastewaters generated by CHWC operations are the same. Since the amount of wastewater
generated by other CHWC operations is minimal as compared to CHWC wastewater flow rates, these
small flows are typically mixed with CHWC wastewaters for treatment in the physical/chemical treatment
system. Below is a description of the only new treatment technology listed above that was not described
in the previous section: chemical oxidation.

6.2.1         Chemical Oxidation

       Chemical oxidation treatment processes may be used to remove ammonia, to reduce the
concentration of residual organics, and to reduce the bacterial and viral content of wastewaters. CHWC

                                         6-28

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facilities that use chemical oxidation processes use them for the treatment of other out-of-scope
wastewaters generated at these facilities, such as landfill leachate, storm water, groundwater, or sanitary
wastewater. Both chlorine and ozone can be used to destroy some residual organics in wastewater. When
these chemicals are used for this purpose, disinfection of the wastewater is usually an added benefit.  A
further benefit of using ozone is the removal of color. Ozone can also be combined with hydrogen peroxide
for removing organic compounds in contaminated wastewater. Oxidation is also used to convert pollutants
to terminal end products or to intermediate products that are more readily biodegradable or more readily
removed by adsorption. There are two CHWC facilities that use chemical oxidation units as part of their
treatment process to treat secondary CHWC wastewaters.
       Chemical oxidation is a chemical reaction process in which one or more electrons are transferred
from the chemical being oxidized to the chemical initiating the transfer (the oxidizing agent). The electron
acceptor may be another element, including an oxygenmolecule, or it may be a chemical species containing
oxygen, such as hydrogen peroxide and chlorine dioxide or some other electron acceptor. This process
is also effective in destroying cyanide and toxic organic compounds. Figure 6-13 illustrates one such
chemical oxidation process. According to the Section 308 Questionnaire data, CHWC facilities use
chemical oxidation processes to treat organic pollutants and as a disinfectant. When treating organic
wastes, these processes use oxidizing chemicals, such as hydrogen peroxide, or ozone. As a disinfection
process, an oxidant (usually chlorine) is added to the wastewater in the form of either chlorine dioxide or
sodium hypochlorite.  Other disinfectant chemicals include ozone, peroxide, and calcium hypochlorite.
Once the oxidant is mixed with the wastewater, sufficient detentiontime is allowed (usually 30 minutes) for
the disinfecting reactions to occur.

6.2.2         Zero Discharge Options

       Other CHWC facilities use treatment and disposal practices that result in no discharge of their
secondary CHWC wastewaters to surface waters. A breakdown of the zero discharge options for
secondary CHWC wastewaters at CHWC facilities is as follows:
                                           6-29

-------
        Caustic Feed
                                       Hypochlorite or Chlorine Feed
           Wastewater
           Influent
              Acid Feed
     Treated
     Effluent
                                                  First Stage
                              Second Stage
Figure 6-13. Cyanide Destruction
                                         6-30

-------
       Zero Discharge Option       Number of CHWC Facilities
       Incineration                               2
       Off-Site Disposal                           5
       Evaporated/Land Applied                     1
       Recycled                                  2
       Deep Well Disposal                         2

       Most of the above zero discharge options, with the exception of deep well disposal,  have been
described previously in Section 6.1.3. Below is a description of the only new zero discharge option listed
above that was not described in the previous section; deep well disposal.

6.2.2.1        Deep Well Disposal

       Deep well disposal consists of pumping the wastewater into a disposal well which discharges the
liquid into a deep aquifer. These aquifers do not typically contain potable water and commonly are
brackish. These aquifers are thoroughly characterized to insure that they are not hydrogeologically
connected to an aquifer which is or has the potential to be used for potable water.  Characterization
confirms the existence of impervious layers of rock above and below the aquifer in order to prevent the
migration of pollutants.

6.3           OTHER ON-SITE WASTEWATER TREATMENT TECHNOLOGIES

       There are other treatment technologiesused by CHWC facilities to treat other on-site wastewaters
(leachates, sanitary wastewater).  Some facilities may use one or more of the technologies described above
for the treatment of these wastewaters. Four CHWC  facilities use some form of biological treatment as
the preferred method of treatment of leachates and other organic wastewaters. The biological treatment
technologies used at these CHWC facilities are listed below:

       Treatment Technology             Number of Facilities
       Activated Sludge                            1
       Trickling Filter                             1
       PAC  System (Powdered Activated Carbon)       2
                                           6-31

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 6.4           TREATMENT PERFORMANCE AND DEVELOPMENT OF REGULATORY
              OPTION
       This section presents an evaluation of performance data on treatment systems collected both by
 EPA during field sampling programs and by industry generated data (provided to the Agency post-proposal
 and used to revise limitations), as well as the rationale used in the development of the regulatory option.

 6.4.1         Performance of EPA Sampled Treatment Processes

       To collect data on potential BAT treatment technologies, Questionnaire responses were reviewed
 to identify candidate facilities that had well operated and designed wastewater treatment systems.  EPA
 conducted site visits to 13 CHWC facilities to evaluate treatment systems; based on these site visits, three
 facilities were selected for a five consecutive day sampling episode (Episode ID #s 4646,4671, and 4733).
 At these facilities, EPA collected data on a variety of physical and chemical treatment processes.
 Technologies evaluated at the selected sampling facilities include hydroxide precipitation, sulfide
 precipitation, sedimentation, carbon adsorption, sand filtration and ultrafiltration. Table 6-1 presents a
 summary of the treatment technologies sampled during each EPA sampling episode. Summaries of the
 treatment system performance data collected by EPA during eachof these sampling episodes are presented
 below.

 6.4.1.1        Treatment Performance for Episode #4646

       EPAperformedafive^ysamplmgprogram,Episode#4646. This facility was evaluated by EPA
 in order to obtain performance data on several treatment technologies installed at this facility including
hydroxide precipitation, ferric chloride precipitation, and sand filtration. A flow diagram of the CHWC
wastewater treatment system sampled during Episode # 4646 is presented in Figure 6-14. The wastewater
treatment system used at this CHWC facility treats wastewater from the air pollution control system
(quench chamber run-down and packed tower wastewater) and the ionizing wet scrubber.  The
                                          6-32

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     Table 6-1. Description of CHWC Sampling Episodes
Episode
4646
4671
4733
Influent
Sample Point
1+2
4
5
1+2
1
2
1
1
2
1
Effluent
Sample Point
4
5
6
6
2
3
3
2
4
4
Description
First-stage chemical precipitation using sodium hydroxide
Second-stage chemical precipitation using ferric chloride
Sand filtration
Overall treatment system- first-stage chemical precipitation, second-stage chemical precipitation, and sand Filter
First-stage chemical precipitation using sodium hydroxide
Second-stage chemical precipitation using sodium hydroxide and ultrafiltration
Overall treatment system- first-stage chemical precipitation.second-stage chemical precipitation, and ultrafiltration
Sulfide precipitation and Lancy filters
Carbon adsorption system
Overall treatment system- sulfide precipitation, Lancy filters and carbon adsorption system
o\

-------
Figure 6-14. EPA Sampling Episode 4646 - CHWC Wastewater Treatment System Block Flow Diagram with Sampling Locations
Quench
Run-Down —
Picked Tower
Wulcwiter


Sodium
Bilulfilc
I Sodium
Hydroxide
i 1
1
	 fc Chromium
Reduclhrn


(oij 	
loniiingWet
Wulnnuer
Filmic

Weik Ferric Sodium Hydroxi
Hydrochloric AeM CMortd. Wynw o.Ltae
I I I i


[~^\ SKnplingLoc.tioi.

. To Quench
9 Clumber
Prinwy
Cbrifler
/C7X
^

V^ r uewueted
| PUte Bud Frame 	 ^ Sludge
I Filler Prea loOn-Sile
f Undfill
^
j i
fe
Sludgo



* CUnnu I mm


ToEqusliaUon VV
udDUchaite

-------
wastewater treatment system is comprised of two separate systems both of which were sampled by EPA.
The primary system is part of the primary water circulation loop that serves the incinerator and consists of
chromium reduction and hydroxide precipitation treatment followed by sedimentation.  Only the
precipitation portion of the primary system was sampled by EPA.  Blowdown from the primary loop is
treated in the secondary system. Treatment in the secondary loop consists of precipitation using ferric
chloride followed by sedimentation and sand filtration. Table 6-2 presents a summary of percent removal
data collected at Episode #4646 for the performance of the entire treatment system, both the primary and
secondary system, as well as the primary system, secondary system, and sand filter separately.  Percent
removal efficiencies for the processes were calculated by first obtaining an average concentration based
upon the daily sampling results for each sample collection location (influent and effluent point to the
treatment process). Next, the percent removal efficiency of the system was calculated using the following
equation:

       Percent Removal = [Concentration Influent -  Concentration Effluent] xlOO
                                  Concentration Influent

Negative percent removals for a treatment process were reported on the table as "0.0" percent removals.
       The treatment efficiency of the primary system was assessed using the data obtained from sampling
points 01,02, and 04 (see Figure 6-14).  Influent concentration data was obtained using a flow-weighted
average for sample points 01 and 02. Effluent from the primary treatment system was represented by
sample point 04. As demonstrated on Table 6-2, the primary treatment system experienced good overall
removals for TSS (90.9 percent). COD was removed at 70.9 percent, whereas, no removal was observed
forTDS. Many of the metals observed in the influent were removed to high levels; these include aluminum^
cadmium, chromium, copper, iron, lead, tin, titanium, and zinc.  Other metals also with limited removals
include manganese (66.5 percent), mercury (63.9 percent), silver (40.3 percent), and strontium (19.7
percent).  Poor removal efficiencies were observed in the primary system for antimony, arsenic, boron,
molybdenum, and selenium.
                                          6-35

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        Table 6-2. Treatment Technology Performance for Episode 4646



Pollutant of Concern

Conventional
TSS
Non-Conventional
COD
IDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#


C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
First-Stage Chemical Precipitation
Sample Points 1+2 to 4

DL


4,000

5,000


200
20.0
10.0
100
5.0
10.0
25.0
100
50.0
15.0
0.2
10.0
5.0
10.0
100
30.0
5.0
20.0

1.0
50.0
Influent
SP


01+02

01+02
01+02

01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02

01+02
01+02
Cone, (ug/1)


122,560

535,920
30,694,160

1,104
672
475
1,280
929
220
5,228
7,066
4,691
228
59.2
936
240
283
408
1,882
2,116
9,456

3.1
1.027
Effluent
SP


04

04
04

04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04

04
04
Cone, (ug/1)


11,200

156,200
50,320,000

170
1,026
494
1,744
174
53.4
321
254
117
76.6
21.4
1,137
263
169
328
45.9
32.9
209

NS
NS
%
Removal


90.9

70.9
0.0

84.6
0.0
0.0
0.0
81.2
75.8
93.9
96.4
97.5
66.5
63.9
0.0
0.0
40.3
19.7
97.6
98.4
97.8

NS
NS
Second-Stage Chemical Precipitation
Sample Points 4 to 5

DL


4,000

5,000


200
20.0
10.0
100
5.0
10.0
25.0
100
50.0
15.0
0.2
10.0
5.0
10.0
100
30.0
5.0
20.0

1.0
50.0
Influent
SP


04

04
04

04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04

04
04
Cone.
(ue/1)

11,200

156,200
50,320,000

170
1,026
494
1,744
174
53.4
321
254
117
76.6
21.4
1,137
263
169
328
45.9
32.9
209

NS
NS
Effluent
SP


05

05
05

05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05

05
05
Cone, (ug/1)


13,400

238,800
36,910,000

197
381
8.8
1,705
47.2
ND
18.8
1,994
47.7
517
2.6
578
49.6
9.5
689
33.0
3.9
121

NS
NS
%
Removal


0.0

0.0
26.6

0.0
62.9
98.2
2.2
72.9
81.3
94.2
0.0
59.1
0.0
87.7
49.1
81.1
94.4
0.0
28.2
88.2
42.2

NS
NS
ON
         Negative percent removal are recorded as 0.0
         NS: Not Sampled
         ND: Non-Detect
         DL: Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
         SP: Sample Point

-------
Table 6-2.  Treatment Technology Performance for Episode 4646 (continued)



Pollutant of Concern

Conventional
TSS
Non-Conventional
COD
IDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#


C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
Sand Filtration
Sample Points 5 to 6

DL


4,000

5,000


200
20.0
10.0
100
5.0
10.0
25.0
100
46.8
15.0
2.0
10.0
5.0
5.0
100
30.0
5.0
20.0

1.0
50.0
Influent
SP


05

05
05

05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05

05
05
Cone.
(UB/1)

13,400

238,800
36,910,000

197
381
8.8
1,705
47.2
ND
18.8
1,994
47.7
517
2.6
578
49.6
9.5
689
33.0
3.9
121

NS
NS
Effluent
SP


06

06
06

06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06

06
06
Cone.
(UR/1)

5,500

257,900
38,150,000

160
346
8.1
1,731
19.9
ND
10.1
128
ND
545
ND
580
26.0
ND
674
31.5
6.8
24.2

ND
1.482
%
Removal


59.0

0.0
0.0

18.4
9.3
8.1
0.0
57.7
0.0
46.1
93.6
1.8
0.0
24.2
0.0
47.5
47.3
2.1
4.5
0.0
80.0

NS
NS
Entire Treatment System
Sample Points 1+2 to 6

DL


4,000

5,000


200
20.0
10.0
100
5.0
10.0
25.0
100
46.8
15.0
2.0
10.0
5.0
5.0
100
30.0
5.0
20.0

1.0
50.0
Influent
SP


01+02

01+02
01+02

01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02

01+02
01+02
Cone, (ug/l)

•
122,560

535,920
30,694,160

1,104
672
475
1,280
929
220
5,228
7,066
4,691
228
59.2
936
240
283
408
1,882
2,116
9,456

3.1
1,027
Effluent
SP


06

06
06

06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
06

06
06
Cone, (ug/l)


5,500

257,900
38,150,000

160
346
8.1
1,731
19.9
ND
10.1
128
ND
545
ND
580
26.0
ND
674
31.5
6.8
24.2

ND
1.482
%
Removal


95.5

51.9
0.0

85.5
48.5
98.3
0.0
97.9
95.5'
99.8
98.2
99.0
0.0
96.6
38.0
89.1
98.2
0.0
98.3
99.7
99.7

67.3
0.0
Negative percent removal are recorded as 0.0
NS: Not Sampled
ND: Non-Dclcct
DL: Specific detection limits of sample when there is a non-deled, otherwise it is the method detection limit
SP: Sample Point

-------
       The treatment efficiency of the secondary system was assessed using the data obtained from
 sampling points 04 and 05 (see Figure 6-14).  Influent concentration data to die secondary system was
 obtained using sampling point 04 which is also the effluent from die primary system. Effluent from the
 secondary treatment system was represented by sample point 05.  As demonstrated in Table 6-2, the
 secondary treatment system experienced no additional removals for TSS or COD. As in the primary
 system, no removal was observed for IDS. For those metals for which there was little or no removal in
 the primary system, improved removals were generally observed in the second system.  These metals
 include antimony (62.9 percent), arsenic (98.2 percent), selenium (81.1 percent), and silver (94.4 percent).
 Other metals for which adequate removals were observed in the primary system also experienced
 additional removals in the secondary system. The data show the following removals: cadmium (72.9
 percent), chromium (81.3 percent), copper (94.2 percent), mercury (87.7 percent), and titanium (88.2
 percent).
       The treatment efficiency of the sand filter was evaluated using the data obtained from sampling
 points 05 and 06 (see Figure 6-14).  Influent concentration data was obtained usingsample point 05 which
 represents me discharge from the secondary treatment system. Effluent from die sand filter as well as the
 overall effluent from die treatment process was represented by sample point 06. As demonstrated in Table
 6-2, die treatment system achieved a removal rate for TSS of 59.0 percent No removals were observed
 for COD or IDS. Additional metals were removed by die sand filter including cadmium, copper, iron,
 selenium, silver, and zinc. Limited additional removals were also observed for aluminum and mercury.
       The treatment efficiency of die entire treatment system was evaluated using die data obtained from
 sampling points 01,02, and 06 (see Figure 6-14). Influent concentration data was obtained using a flow-
 weighted average for sample points 01 and 02.  Effluent from die treatment system was represented by
 sample point 06. As demonstrated in Table 6-2, die treatment system achieved good overall removal for
 TSS (95.5 percent). COD was removed at 51.9 percent, whereas, no removal was observed for TDS.
 Many of die metals observed in die influent were removed to levels exceeding 95 percent These include
 arsenic, cadmium, chromium, copper, iron, lead, mercury, silver, tin, titanium, and zinc. Other metals also
with high removals include aluminum (85.5 percent) and selenium (89.1 percent). Overall poor removal
                                           6-38

-------
efficiencies were observed for antimony (48.5 percent) and molybdenum (38.0 percent). No removals
were observed for the treatment system for boron, manganese, and strontium.  Dichloroprop, a pesticide
parameter, was detected in the influentin low levels and was not detected intheeffluent MCPPdidnot
experience any removal through the treatment system.

6AL2        Treatment Performance for Episode #4671

       EPAperfixmedafiveHlay8an^lingprogram)^jisode#4671. This facility was evaluated by EPA
in order to obtain performance data on various treatment units which are in operation at this facility,
mcludgigacombinanVm«ulftfeandty
and ultrafiltratioa A flow diagram of the CHWCwastewater treatment system sampled during Episode
#4671 is presented in Figure 6-15.  The wastewater treatment system used at this CHWC facility treats
wastewater from die air pollution control system. The air pollution control system consists of a quench
tank, packed tower, and a venturi scrubber. The wastewater treatment system is comprised of two
separate systems bom of which were sampled by EPA The primary system is part of the primary water
circulation loop that serves the incinerator. Treatmem processes for the priniaty system consists of sulfide
precipitation iismgfemnissiilfatefollowedty
then followed by sedimentation.  The facility treats the discharge from the primary loop in the secondary
system. Treatment in the secondary loop consists of hydroxide precipitation using sodium hydroxide
followed by sedimentation and uhrafiltration. Table 6-3 presents a summary of percent removal data
collected at Episode #4671  for the performance of the entire treatment system, both the primary and
secondary system, and for the primary system only.
       The treatment efficiency of the primary treatment system was evaluated using the data obtained
fromsampling points 01 and 02 (see Figure 6-15).  Influent concentration data for the primary system was
obtained using sample point 01, Effluent from the primary treatment system was represented by sample
point 02.  As demonstrated on Table 6-3, the primary treatment system removal rate for TSS was 70.6
percent COD was removed at 123 percent, whereas, TDS was removed at 7.8 percent. Metals with
                                         6-39

-------
Figure 6-15. EPA Sampling Episode 4671 - CHWC Wastewater Treatment System Block Flow Diagram with Sampling Locations




































Ferrous
Sulf"e Sodium
i Hydroxide Lltnc ™W
1 i i
* * + TflAir

Chemical Control
nn.i*i.«ii>». "'* Tank _ -_.—,



r-\ ^^ v^

Sludjc
, .
Filmic
Fi|ler Dewllered Sludge

i >
Sodium Sulliiric
Hydroxide Sludge Add
i 1 &
.h P.rrinil.il,,!, h, UllllflHrtlion 	 fc MPH|I»||MII«I 1 k To Eqnalfellfan
Unit end Dispoul
    o
Sampling LocMion

-------
Table 6-3. Treatment Technology Performance for Episode 4671



Pollutant of Concern

Conventional
TSS
Non-Conventional
COD
TDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#


C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
First-Stage Chemical Precipitation
Sample Points 1 to 2

DL


4,000

5,000


200
20.0
10.0
100
5.0
10.0
25.0
100
50.0
15.0
0.2
10.0
9.7
10.0
100
30.0
10.0
20.0

1.0
50.0
Influent
SP


01

01
01

01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01

01
01
Cone, (ug/1)


241,100

259,400
7,481,000

1,575
110
19.2
1,723
4.2
124
121
1,217
149
107
0.7
69.7
ND
5.7
1,382
49.5
206
1,598

ND
ND
Effluent
SP


02

02
02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02

02
Q2
Cone.
(ug/1)

70,900

227,600
6,896,000

266
107
19.9
1,219
2.4
3.2
33.8
79.8
14.3
74.3
0.4
66.6
14.0
9.1
1,582
39.0
ND
813

NS
NS
%
Removal


70.6

12.3
7.8

83.1
2.5
0.0
29.2
43.1
97.4
72.0
93.4
90.4
30.5
33.8
4.5
0.0
0.0
0.0
21.2
95.1
49.1

NS
NS
Second-Stage Chemical Precipitation
Sample Points 2 to 3

DL


4,000

5,000


6.5
20.0
10.0
100
5.0
10.0
25.0
100
1.5
15.0
0.2
10.0
11.5
10.0
100
28.3
10.0
20.0

1.0
50.0
Influent
SP


02

02
02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02

02
02
Cone.
„ (UE/1)
r. > *
Vo,9do

227,600
6,896,000

266
107
19.9
1,219
2.4
3.2
33.8
79.8
14.3
74.3
0.4
66.6
14.0
9.1
1,582
39.0
ND
813

NS
NS
Effluent
SP


03

03
03

03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03

03
03
Cone.
(ue/1)

13,800

154,800
6,560,000

ND
94.2
25.6
1,069
0.4
1.0
18.8
50.1
ND
2.3
ND
59.5
ND
2.0
1,315
ND
ND
239

ND
ND
%
Removal


80.5

32.0
4.9

97.6
12.2
0.0
12.3
83.6
67.7
44.4
37.1
89.5
96.9
54.5
10.6
17.6
77.7
16.8
27.4
0.0
70.7

NS
NS
Negative percent removal are recorded as 0.0
NS: Not Sampled
ND: Non-Dctect
DL: Specific detection limits of sample when there is a non-detecl, otherwise it is the method detection limit
SP: Sample Point

-------
                                Table 6-3. Treatment Technology Performance for Episode 4671 (continued)
k



Pollutant oflnterest
Conventional
TSS
Non-Conventional
COD
IDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium

Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#

C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492

7440224
7440246
7440315
7440326
7440666

120365
7085190
Entire Treatment System
Sample Points 1 to 3

DL

4,000

5,000


6.5
20.0
10.0
100
5.0
10.0
25.0
100
1.5
15.0
0.2
10.0
9.7
/1 1.5
10.0
100
28.3
10.0
20.0

1.0
50.0
. Influent
SP

01

01
01

01
01
01
01
01
01
01
01
01
01
01
01
01

01
01
01
01
01

01
01
Cone, (uR/1)

241,100

259,400
7,481,000

1,575
110
19.2
1.723
4.2
124
121
1,217
149
107
0.7
69.7
ND

5.7
1,382
49.5
206
1,598

ND
ND
Effluent
SP

03

03
03

03
03
03
03
03
03
03
03
03
03
03
03
03

03
03
03
03
03

03
03
Cone, (ug/1)

13,800

154,800
6,560,000

ND
94.2
25.6
1,069
0.4
1.0
18.8
50.1
ND
2.3
ND
59.5
ND

2.0
1,315
ND
ND
239

ND
ND
%
Removal

94.3

40.3
12.3

99.6
14.4
0.0
37.9
90.7
99.2
84.5
95.9
99.0
97.8
69.9
14.6
0.0

64.1
4.8
42.8
95.1
85.1

0.0
0.0
                                 Negative percent removal are recorded as 0.0
                                 NS:  Not Sampled
                                 ND:  Non-Detect
                                 DL:  Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
                                 SP:  Sample Point

-------
high removal rates in the primary system include: aluminum (83.1 percent), chromium (97.4 percent),
copper (72.0 percent), iron (93.4 percent), lead (90.4 percent), and titanium (95.1 percent). The system
achieved limited removals for other metals through the primary system. These include boron, cadmium,
manganese, mercury, tin, and zinc.
       Poor to no removals were observed for antimony, arsenic, molybdenum, silver, and strontium.
However, influent concentrations to the primary treatment system for some metals, such as arsenic,
cadmium, silver, and zinc, were low or not detected. Therefore, the influent concentrations for these
parameters are close to the treatability levels using chemical precipitation, making it difficult to achieve
additional removals for these pollutants. For example, cadmium was found in the influent and effluent of
the primary treatment system at concentrations of 4.2 ug/1 and 2.4 ug/1, respectively. This resulted in a
percent removal of only 43.1 percent Therefore, the low percent removal efficiency is a function of the
low influent concentration (near treatability levels) and not indicative of poor performance.
       The treatment efficiency of the secondary treatment system was evaluated using the data obtained
from sampling points 02 and 03 (see Figure 6-15). Influent concentration data to the secondary system
was obtained using sample point 02, which is the effluent from the primary system. Effluent from the
secondary treatment system was represented by sample point 03.  As demonstrated on Table 6-3, the
secondary treatment system removal rate for TSS was 80.5 percent COD was removed at 32.0 percent,
whereas, TDS was removed at 4.9 percent Metals with high removal rates or removed to non-detectable
levels in the secondary system include; aluminum, cadmium, chromium, lead, manganese, mercury, silver,
tin, and zinc.  Limited additional removals were observed for copper and iron. Poor removals were
observed in the secondary system for antimony, boron, molybdenum, and strontium.
       The treatment efficiency of the entire treatment system, born primary and secondary treatment
systems, were evaluated using the data obtained from sampling points 01  and 03 (see Figure 6-15).
Influent concentration data was obtained using sample point 01. Effluent from the entire treatment system
was represented by sample point 03. As demonstrated on Table 6-3, the treatment system achieved good
overall removals for TSS (94.3 percent). COD was removed at 40.3 percent, whereas, TDS was
removed at 12.3 percent. Selenium, dichloroprop, and MCPP were not detected in the influent or effluent.
                                         6-43

-------
 Many of the metals observed in the influent were removed to levels exceeding 95 percent removal; these
 include aluminum, chromium, iron, lead, manganese, and titanium. Other metals also with high removals
 or removed to non-detectable levels include cadmium (90.7 percent), copper (84.5 percent), mercury
 (69.9 percent), silver (64.1 percent), and tin (42.8 percent). Poor removal efficiencies were observed for
 the entire treatment system for antimony( 14.4 percent), boron (37.9 percent), molybdenum (14.6 percent),
 and strontium (4.8 percent). Arsenic was observed at below treatable levels throughout the system.

 6.4.1.3        Treatment Performance for Episode #4733

        EPA performed a five-day sampling program, Episode #4733. This facility was evaluated by EPA
 in order to obtain performance data on various treatment units which are in operation at this facility,
 including sulfide precipitation, Lancy filtration, and carbon adsorption.  A flow diagram of the CHWC
 wastewater treatment system sampled during Episode #4733 ispresentedinFigure6-16. Thewastewater
 treatment system used at this CHWC facility treats wastewater from the air pollution control system. The
 air pollution control system consists of a quench tank and a wet scrubber. Table 6-4 presents a summary
 of percent removal data collected at Episode #4733 for the performance of the sulfide precipitation and
 Lancy filtration process, carbon adsorption system, and the entire treatment system.
        The treatment efficiency of the sulfide precipitation and Lancy filtration system was evaluated using
 the data obtained from sampling points 01 and 02 (see Figure 6-16).  Influent concentration data to the
 primary system was obtained using sample point 01. Effluent from the first-stage treatment system was
 represented by sample point 02. As demonstrated on Table 6-4, the first-stage treatment system had non-
 detectable levels in the influent for TSS, aluminum, cadmium, lead, molybdenum, silver, strontium, and
 MCPP.  Other parameters were observed in the influent at levels near to or below treatable levels, such
 as antimony, arsenic, and copper. COD was removed at 11.8 percent, whereas, no removal was observed
 for TDS. Metals with high removal rates in the first-stage system include; chromium (84.4 percent), iron
 (85.3 percent), manganese (86.3 percent), mercury (94.0 percent), and zinc(92.2 percent). Titanium was
removed to non-detectable levels in the first-stage system. The treatment system achieved limited removal
                                           6-44

-------
     Figure 6-16. EPA Sampling Episode 4733 - CHWC Wastewater Treatment System Block Flow Diagram with Sampling Locations
               Normal Flow Pallcrn



               Divtnion/Optioiul Treatment Pattern
Sludge
                                                                                                             Combined Raw
(OU 	 Wutewticr
Luicy Sulfldc 2nd Slice Ul Stage r •*—

Ritas '"" T»nk T«nk Tmk
, 	 	 ., _ , .. , 	 _ ..., , FV?"
Equalization
Tank
Filtered
Wutewiler
e
1 	 1 * *
(-» P'e-Fito — 1 (M)


1 — » Pre-Filier 	 ' JL
^ 	 ^© 11 IT
i 	 i
s
, . i .. i
	 	 I
i
NOT" 1
In Vtt During Sampling i
Filler C«ke Sludge slall.e !

Dispoul 	 " 	

Supenuie
^ 1
I J Simpling Locfllon
Divereion Diversion

1 1

AirPolluliw
Control







10 NPOES
Diwhirge














Supenuie
Return
i
1
- |
i
:
:
1
i


















.



-------
Table 6-4. Treatment Technology Performance for Episode 4733



Pollutant of Concern
Conventional
TSS
Non-Conventional
COD
TDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead

Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium

Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#

C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921

7439965
7439976
7439987
7782492
7440224
7440246

7440315
7440326
7440666

120365
7085190
First-Stage Lancy Filter
Sample Points 1 to 2

DL

4,000

5,000


13.6
20.0
10.0
100
3.5
5.8
25.0
100
2.1

1.2
0.2
4.6
5.0
7.8
100

30.0
5.0
20.0

1.0
50.0
Influent
SP

01

01
01

01
01
01
01
01
01
01
01
01

01
01
01
01
01
01

01
01
01

01
01
Cone, (ug/1)

ND

234.100
272,400

ND
22.8
5.3
1,811
ND
37.1
10.9
430
ND

8.8
3.3
ND
59.1
ND
ND

65.9
11.4
102

18.9
ND
Effluent
SP

02

02
02

02
02
02
02
02
02
02
02
02

02
02
02
02
02
02

02
02
02

02
02
Cone, (ug/1)

ND

206,600
2,206,000

ND
24.6
4.9
1,846
ND
ND
9.5
63.4
ND

ND
ND
ND
43.9
8.1
ND

145
ND
7.9

NS
NS
%
Removal

0.0

11.8
0.0

0.0
0.0
8.3
0.0
0.0
84.4
12.5
85.3
0.0

86.3
94.0
0.0
25.6
0.0
0.0

0.0
56.3
92.2

NS
NS
Carbon Adsorption System
Sample Points 2 to 4

DL

4,000

5,000


13.6
20.0
10.0
100
3.5
5.8
25.0
2.4
2.1
/1. 8
1.2
0.2
4.6
5.0
7.8
100
/86.7
30.0
5.0
2.4

1.0
50.0
Influent
SP

02

02
02

02
02
02
02
02
02
02
02
02

02
02
02
02
02
02

02
02
02

02
02
Cone, (ug/1)

ND

206,600
2,206,000

ND
24.6
4.9
1,846
ND
ND
9.5
63.4
ND

ND
ND
ND
43.9
8.1
ND

145
ND
7.9

NS
NS
Effluent
SP

04

04
04

04
04
04
04
04
04
04
04
04

04
04
04
04
04
04

04
04
04

04
04
Cone, (ug/1)

ND

192,300
2,899,000

ND
26.4
4.1
2,381
ND
ND
7.4
ND
ND

1.3
0.4
7.1
56.5
8.1
ND

48.6
ND
ND

ND
ND
%
Removal

0.0

6.9
0.0

0.0
0.0
15.4
0.0
0.0
0.0
22.1
96.2
0.0

0.0
0.0
0.0
0.0
0.0
0.0

66.4
0.0
69.8

NS
NS
 Negative percent removal are recorded as 0.0
 NS:  Not Sampled
 ND:  Non-Dclcci
 DL:  Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
 SP:  Sample Point

-------
                                Table 6-4. Treatment Technology Performance for Episode 4733 (continued)
ON



Pollutant of Concern
Conventional
TSS
Non-Conventional
COD
IDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead

Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium

Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#

C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921

7439965
7439976
7439987
7782492
7440224
7440246

7440315
7440326
7440666

120365
7085190
Entire Treatment System
Sample Points 1 to 4

DL

4,000

5,000


13.6
20.0
10.0
100
3.5
5.8
25.0
2.4
2.1
/1. 8
15.0
0.2
4.6
5.0
7.8
100
/86.7
30.0
5.0
2.4

1.0
5.0
Influent
SP

01

01
01

01
01
01
01
01
01
01
01
01

01
01
01
01
01
01

01
01
01

01
01
Cone, (ug/1)

ND

234,100
272,400

ND
22.8
5.3
1,811
ND
37.1
10.9
430
ND

8.8
3.3
ND
59.1
ND
ND

65.9
11.4
102

18.9
ND
Effluent
SP

04

04
04

04
04
04
04
04
04
04
04
04

04
04
04
04
04
04

04
04
04

04
04
Cone, (ug/l)

ND

192,300
2,899,000

ND
26.4
4.1
2,381
ND
ND
7.4
ND
ND

1.3
0.4
7.1
56.5
8.1
ND

48.6
ND
ND

ND
ND
%
Removal

0.0

17.9
0.0

0.0
0.0
22.5
.0.0
0.0
84.4
31.8
99.4
0.0

85.2
88.6
0.0
4.4
0.0
0.0

26.2
56.3
97.7

94.7
0.0
                                Negative percent removal are recorded as 0.0
                                NS: Not Sampled
                                ND: Non-Deled
                                DL: Specific detection limits of sample when there is a non-dctecl, otherwise it is the method detection limit
                                SP: Sample Point

-------
 of selenium through the first-stage primary system (25.6 percent). Poor to no removals were observed for
 boron and tin.
        The treatment efficiency of the carbon adsorption system was evaluated using the data obtained
 from sampling points 02 and 04 (see Figure 6-16).  Influent concentration data to the carbon adsorption
 system was obtainedusing sample point 02, which is also the effluent from the first-stage treatment system.
 Effluent from the carbon adsorption system was represented by sample point 04 which is also the effluent
 point for the entire treatment system.  As demonstrated on Table 6-4, the carbon adsorption system had
 non-detectable levels in the influent for the same parameters as in the first-stage system, plus the metals
 were removed to non-detectable levels in the first-stage system, such as chromium, manganese, mercury,
 and titanium. Additional removals were observed for iron (96.2 percent), tin (66.4 percent), and zinc (69.8
 percent). No removals in the carbon adsorption system were observed for boron and selenium. As in the
 first-stage system, antimony, arsenic, and copper are at concentrations in the influent below treatable levels.
        Thetreatmenterficiencyoftheentire treatment system, mchiding the first-stage suMdeprecipitation,
 Lancy filtration, and carbon adsorption, were evaluated using the data obtained from sampling points 01
 and 04 (see Figure 6-16).  Influent concentration data was obtained using sample point 01. Effluent from
 the entire treatment system was represented by sample point 04. As demonstrated on Table 6-4, the
 treatment system achieved a COD removal of 17.9 percent, whereas, there is no removal for TDS. For
 the overall treatment system, the metals with high removal rates include chromium, iron, manganese,
 mercury, titanium, and zinc. Poor removals were observed for selenium and tin. Other metals were only
 detected at concentrations at or near treatable levels. Dichlorprop was removed to non-detectable levels
 at 94.7 percent. MCPP was not detected in the influent or effluent from the treatment system.

 6.4.2         Rationale Used for Selection ofBA T Treatment Technologies

       This sectionpresentsrnerationaleusedrnselectmgrne treata^
option. Treatment technologies used at Episode # 4733 were not considered for further evaluation, since
influent concentrations for many parameters were low and performance data for the treatment systems
could not adequately be ascertained. Therefore, the technologies utilized at Episodes # 4646 and # 4671
                                          6-48

-------
were further evaluated in order to select the most appropriate technologies to be used as the basis for the
BAT options. The basis of this evaluation consists of a comparative analysis of the performance data for
the BAT treatment technologies based upon EPA sampling data.
       Table 6-5 presents a summary of the percent removal data collected at EPA sampling Episodes
# 4646 and # 4671 for the primary chemical precipitation systems. As demonstrated on this table, both
chemical precipitation systems achievedsimilarremovalsformanyofthesamemetal parameters. Although
the loadings for some metal parameters were lower for Episode # 4671 which resulted in lower percent
removals, the overall concentrations for some of the pollutants were treated to similar concentration levels
as those for Episode # 4646.  For instance, the percent removal for manganese at Episode # 4671 was
only 33.8 percent, however the effluent concentration of 74.3 ug/1 was comparable to that at Episode #
4646 of 76.6 ug/1 during which a 66.5 percent removal was achieved Metals which experienced good
overall removals in both chemical precipitation treatment systems include aluminum, cadmium, chromium,
copper, iron, lead, manganese, mercury, tin, titanium, and zinc.  Neither system was effective in treating
antimony, arsenic, boron, selenium, silver, and strontium. Episode # 4646 had higher removals for TSS
(90.9 percent) and COD (70.9  percent).
       Next, an evaluation of the secondary precipitation process plus filtration for both facilities was
performed. Table 6-6 presents a summary of the percent removal data collected at EPA for sampling
Episodes # 4646 and # 4671  for the secondary precipitation process and sand filter or ultrafiltration
process, respectively. As demonstrated on this table, either process resulted in low effluent concentrations
for many of the metal parameters such as cadmium, chromium, copper, iron, lead, mercury, and zinc.
However, the most significant difference between the two systems is the removal of antimony (66.3
percent), arsenic (98.4 percent), and selenium (90.1 percent) in the secondary system for Episode # 4646.
Episode # 4671, which employs  a secondary treatment system consisting of hydroxide precipitation and
ultrafiltration, did not achieve significant removals for antimony, arsenic, or selenium.
       Overall both facilities achieved similar removals and/or treated to the same degree for many of the
metal parameters which are readily removed by chemical precipitation using sodium hydroxide, including
but not limited to cadmium, chromium, copper, iron, lead, mercury, and zinc. Both facilities utilized a two
                                           6-49

-------
         Table 6-5. Primary Chemical Precipitation Treatment Technology Performance Comparison



Pollutant of Concern
Conventional
TSS
Non-Conventional
COD
TDS
Metals
Aluminum
Antimony

Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#

C-009

C-004
C-010

7429905
7440360

7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
Episode #4646 First-Stage Chemical Precipitation
Sample Points 1+2 to 4

DL

4,000

5,000


200
20.0

10.0
100
5.0
10.0
25.0
100
50.0
15.0
0.2
10.0
5.0
10.0
100
30.0
5.0
20.0

1.0
50.0
Influent
SP

01+02

01+02
01+02

01+02
01+02

01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02

01+02
01+02
Cone, (ug/l)

122,560

535,920
30,694,160

1,104
672

475
1,280
929
220
5,228
7,066
4,691
228
59.2
936
240
283
408
1,882
2,116
9,456

3.1
1.027
Effluent
SP

04

04
04

04
04

04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04

04
04
Cone, (ug/l)

11,200

156,200
50,320,000

170
1,026

494
1,744
174
53.4
321
254
117
76.6
21.4
1,137
263
169
328
45.9
32.9
209

NS
NS
%
Removal

90.9

70.9
0.0

84.6
0.0

0.0
0.0
81.2
75.8
93.9
96.4
97.5
66.5
63.9
0.0
0.0
40.3
19.7
97.6
98.4
97.8

NS
NS
Episode #4671 First-Stage Chemical Precipitation
Sample Points 1 to 2

DL

4,000

5,000


200
20.0

10.0
100
5.0
10.0
25.0
100
50.0
15.0
0.2
10.0
9.7
10.0
100
30.0
10.0
20.0

1.0
50.0
Influent
SP

01

01
01

01
01

01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01

01
01
Cone, (ug/l)

241,100

259,400
7,481,000

1,575
110
i
19.2
1,723
4.2
124
121
1,217
149
107
0.7
69.7
ND
5.7
1,382
49.5
206
1,598

ND
ND
Effluent
SP

02

02
02

02
02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02

02
02
Cone, (ug/l)

70,900

227,600
6,896,000

266
107

19.9
1,219
2.4
3.2
33.8
79.8
14.3
74.3
0.4
66.6
14.0
9.1
1,582
39.0
ND
813

NS
NS
%
Removal

70.6

12.3
7.8

83.1
2.5

0.0
29.2
43.1
97.4
72.0
93.4
90.4
30.5
33.8
4.5
0.0
0.0
0.0
21.2
95.1
49.1

NS
NS
Ui
o
          Negative percent removal are recorded as 0.0
          NS:  Not Sampled
          ND:  Non-Detect
          DL:  Specific detection limits of sample when there is a non-detecl, otherwise it is the method detection limit
          SP:  Sample Point

-------
          Table 6-6. Secondary Chemical Precipitation and Filtration Treatment Technology Performance Comparison




Pollutant of Concern
Conventional
TSS
Non-Conventional
COD
TDS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP



CAS
#

C-009

C-004
C-010

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
Episode #4646 Second-Stage Chemical Precipitation &
Sand Filtration
Sample Points 4 to 6

DL

4,000

5,000


200
20.0
10.0
100
5.0
10.0
25.0
100
50.0
15.0
0.2
10.0
5.0
10.0
100
30.0
5.0
20.0

1.0
50.0
Influent
SP

04

04
04

04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04
04

04
04
Cone. (UE/I)

11,200

156,200
50,320,000

170
1,026
494
1,744
174
53.4
321
254
117
76.6
21.4
1,137
263
169
328
45.9
32.9
209

NS
NS
Effluent
SP

05

05
05

05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05
05

05
05
Cone, (ug/1)

5,500

257,900
38,150,000

160
346
8.1
1,731
19.9
ND
10.1
128
ND
545
ND
580
26.0
ND
674
31.5
6.8
24.2

ND
1,482
%
Removal

50.9

0.0
24.2

5.9
66.3
98.4
0.7
88.6
81.3
96.9
49.6
57.3
0.0
99.1
49.0
90.1
94.1
0.0
31.4
79.3
88.4

NS
NS
Episode #4671 Second-Stage Chemical Precipitation &
Ultrafiltration
Sample Points 2 to 3

DL

4,000

5,000


6.5
20.0
10.0
100
5.0
10.0
25.0
100
1.5
15.0
0.2
10.0
11.5
10.0
100
28.3
10.0
20.0

1.0
50.0
Influent
SP

02

02
02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02

02
02
Cone, (ugfl)

70,900

227,600
6,896,000

266
107
19.9
1,219
2.4
3.2
33.8
79.8
14.3
74.3
0.4
66.6
14.0
9.1
1,582
39.0
ND
813

NS
NS
Effluent
SP

03

03
03

03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03
03

03
03
Cone, (ug/1)

13,800

154,800
6,560,000

ND
94.2
25.6
1,069
0.4
1.0
18.8
50.1
ND
2.3
ND
59.5
ND
2.0
1,315
ND
ND
239

ND
ND
%
Removal

80.5

32.0
4.9

97.6
12.2
0.0
12.3
83.6
67.7
44.4
37.1
89.5
96.9
54.5
10.6
17.6
77.7
16.8
27.4
0.0
70.7

NS
NS
o\
          Negative percent removal are recorded as 0.0
          NS: Not Sampled
          ND: Non-Delecl
          DL: Specific detection limits or sample when (here is a non-detecl, otherwise it is the method detection limit
          SP: Sample Point

-------
 tiered approach in the design of their treatment system using some type of a chemical precipitation process
 to provide treatment Primary treatment system designs are comparable at both facilities and are designed
 to remove similar pollutants. Both primary treatment systems are designed to remove those metals which
 readily precipitate out of solution at a high pH range using a sodium hydroxide precipitation treatment
 process. Based upon EPA sampling data, this treatment process was determined not to be very effective
 in treating antimony, arsenic, boron, selenium, silver, and strontium. The treatment system at Episode #
 4671 uses a secondary treatment system targeted to achieve additional removals for the same parameters
 which receive initial removals in the primary system.  Chemical precipitation by hydroxide precipitation is
 once again utilized with ultrafiltration as a polishing step in the secondary system. The design of this
 treatment system is primarily due to the characteristics of the wastewater at this facility, as well asa function
 of the discharge limitations in their NPDES permit During the sampling episode, the facility for Episode
 # 4671 was permitted for antimony (2,000 ug/1 daily maximum) and for arsenic (100 ug/1 daily maximum).
 However, neither of these two parameters were observed in the influent at levels above their respective
 discharge limitation in EPA's sampling episode. Therefore, the design and operation of the treatment
 system at Episode # 4671 is not driven by the removals of parameters such as antimony or arsenic, but
 rather by other metals which are removed by hydroxide precipitation such as aluminum. Conversely, the
 facility for Episode # 4646 is designed to remove those metals in the secondary treatment process which
 are not readily removed by hydroxide precipitation.  At the time of the sampling episode, this facility's
 NPDES permit contained discharge limitations for antimony (600 ug/1 daily maximum), arsenic (100 ug/1
 daily maximum), selenium (100 ug/1 daily maximum), and silver (100 ug/1 daily maximum). Each of these
 parameters were observed in the influent to the treatment system at concentrations above their respective
 discharge limitation. Therefore, the wastewater treatment system used at Episode # 4646 is designed and
 operated with a secondary treatment system consisting of chemical precipitation at a low pH range
 facilitated by ferric chloride and multimedia filtration aimed at removing these additional metal parameters
 which are not removed by hydroxide precipitation in the primary treatment system.
       Based upon the results of the above comparative analysis of chemical precipitation and nitration
processes used at CHWC facilities sampled by EPA, the regulatory option utilizes unit treatment processes
                                           6-52

-------
such as those found at Episode # 4646.  Performance data from this facility indicates that a primary
chemical precipitation system utilizing a sodium hydroxide precipitation process can readily achieve high
removals formany metal parameters. A secondary system consisting of chemical precipitation using ferric
chloride and sand filtration can effectively remove additional metals not readily removed by hydroxide
precipitation, such as antimony, arsenic, and selenium, as well as achieve high additional removals for other
metals which are removed by hydroxide precipitation. Therefore, the combining of these treatment
processes results in a highly effective treatment operation which can readily accommodate the pollutants
of concern for the CHWC industry.

6.4.3         Performance at Facilities Added Post-Proposal

       Following proposal of the CHWC rule, the Agency decided to revise its effluent limitations by
including the data gathered by industry at two new CHWC facilities. Both faculties conducted sampling
events using analytical methods agreed upon by EPA at its five-day sampling episodes, and analyzed
influent and effluent samples for regulated pollutants. Both facilities employed a two-stage chemical
precipitation treatment system. Examples oftreatment technologies found include hydroxide precipitation
and ferric chloride precipitation, as illustrated in Table 6-7. Summaries of the treatment system
performance data collected are presented below. Performance data for Episodes #6181 and # 6183 were
evaluated to determine if the effluent data could be included in the calculation of effluent limitations for the
CHWC industry (See Section 8 for limitations). Flow diagrams of the CHWC wastewater treatment
systems found at Episodes* 6181 and# 6183 are presented in Figure 6-17 and Figure 6-18, respectively.

6.4.3.1       Treatment Performance for Episode #6181

       The wastewater treatment system used at this CHWC facility treats water from the air pollution
control system. The wastewater treatment system is comprised of two separate systems: a primary system
that is part of the primary water circulation loop that serves the incinerator and consists of lime/hydroxide
                                           6-53

-------
Table 6-7. Description of CHWC Sampling Episodes
Episode
6181
6183
Influent
Sample Point
1
1
Effluent
Sample Point
2
2
Description
Overall treatment system- equalization, first-stage
chemical precipitation, second-stage precipitation,
neutralization
Overall treatment system- equalization, first-stage
chemical precipitation, pressure filtration, second-
stage precipitation, sand filtration, bag filtration
                                     6-54

-------
          Figure 6-17. EPA Sampling Episode 6181 - CHWC Wastewater Treatment System Block Flow Diagram with Sampling Locations
in
Ln
       Ait Pollution

          Control

        Wutewito




























NiOH
i| Solidi
if ""I*"
1 I Coolta, A
.. ««« r
J
Cmiriiullan » NcUlril' *"""•'• fc Cluillalind b
Gquuiuuon P tailon ialion UuiHeilw* >


Slowdown
Solids
N«OH Polymer .
i I 1



Add
(If needed)
A ft


            o

-------
           Figure 6-18.  EPA Sampling Episode 6183 - CHWC Wastewater Treatment System Block Flow Diagram with Sampling Locations
   Ait Pollution
       Control
    Waslewaler
in
o\
               Ouifill  •*
                                   Caustic
             Equalization
                                            Solids   •*-
                                                                                 Caustic   FeCB
                                                                                                                        Water
                                                                                                     Cluincalion
                                                  Filler
                                                  Press
                                                                                              -><*
Filler
Prat
                                                                                                                        Solids
                                                                                        Chnifler
                                                                                                                       FeCIJ    Polymer

                                                                                                                       11
              o
Sampling Location

-------
precipitation treatment followed by sedimentation, and a secondary system that treats the blowdown from
the primary system and is comprised of precipitation using ferric chloride followed by sedimentatioa Table
6-8 presents a summary of percent removal data at Episode #6181, measuring the treatment performance
of the entire system, both the primary and secondary systems.
       The treatment efficiency of the entire treatment system, both primary and secondary treatment
systems, was evaluated using the dataobtained from sampling points 01 and 02 (see Figure 6-17). Influent
concentration data was obtained using sample point 01. Effluent from the entire treatment system was
represented by sample point 02. As demonstrated on Table 6-8, the treatment system achieved good
overall removals for TSS (94 percent). Many of the metals observed in the influent were removedto levels
exceeding 95 percent, these include aluminum, copper, iron, lead, titanium, and zinc. Other metals also
with high removals include cadmium (94.4 percent), mercury (93.4 percent), silver (63 percent), arsenic
(60 percent), chromium (56.4 percent), and tin (52.3 percent). Poor removal efficiencies were observed
for antimony, molybdenum, and selenium.

6.4.3.2        Treatment Performance for Episode #6183

       The wastewater treatment system used at this CHWC facility treats water from the air pollution
control system. The wastewater treatment system is comprised of a two-stage hydroxide and ferric
chloride precipitation treatment followed by sedimentation and sand filtration. Table 6-9 presents a
summary of percent removal data at Episode #6183, measuring the treatment performance of the entire
system, both the primary and secondary systems.
       The treatment efficiency of the entire treatment system, both primary and secondary treatment
systems, was evaluated using the dataobtained from sampling points 01 and 02 (see Figure 6-18). Influent
concentration data was obtained using sample point 01. Effluent from the entire treatment system was
represented by sample point 02. As demonstrated on Table 6-9, the treatment system achieved fairly
good overall removals for TSS (84 percent). Many of the metals observed in the influent were removed
to levels at or exceeding 95 percent, these include aluminum, arsenic, cadmium, chromium, copper, iron,
                                          6-57

-------
                                  Table 6-8.  Treatment Technology Performance for Episode 6181
ON
dfl
oo



Pollutant of Concern
Conventional
TSS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#

C-009

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
Entire Treatment System
Sample Points 1 to 2

unit

mg/1

ug/1
ug/I
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1

ug/1
ue/1

DL

4

100
60
10

5
10
10
20
10

0.2
50
10
5

50
10
20



Influent
SP

01

01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01

01
01
Cone.

78.8

5,810
919
129

99.6
27.5
522
2,050
1,160

3.04
399
70.3
16.2

135
204
2,120



Effluent
SP

02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02

02
02
Cone.

4.77

100
1,020
51.6

5.54
12
12.9
25.1
10.6

0.2
488
86.6
6

64.4
10
24.3



%
Removal

93.95

98.28
0.0
60.00

94.44
56.36
97.53
98.78
99.09

93.42
0.0
0.0
62.96

52.30
95.10
98.85



                                   Negative percent removal are recorded as 0.0
                                   NS: Not Sampled
                                   ND: Non-Detect
                                   DL: Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
                                   SP: Sample Point

-------
                                  Table 6-9.  Treatment Technology Performance for Episode 6183
in



Pollutant of Concern
Conventional
TSS
Metals
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Strontium
Tin
Titanium
Zinc
Pesticides/Herbicides
Dichloroprop
MCPP


CAS
#

C-009

7429905
7440360
7440382
7440428
7440439
7440473
7440508
7439896
7439921
7439965
7439976
7439987
7782492
7440224
7440246
7440315
7440326
7440666

120365
7085190
Entire Treatment System
Sample Points 1 to 2

unit

me/I

ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1

ug/1
ug/1

DL

4

100
60
10

5
10
10
20
10

0.2
50
10
5

50
10
20



Influent
SP

01

01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
01

01
01
Cone.

315

61,500
1,710
1,210

97.7
2,250
1,970
231,000
1,600

219
1,550
113
69.8

1,330
4,030
8,300



Effluent
SP

02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
02

02
02
Cone.

51.7
'
334
332
27.8

5
10
10
428
10

0.48
919
32.6
5.54

134
10
62.8



%
Removal

83.59

99.46
80.58
97.70

94.88
99.56
99.49
99.81
99.38

99.78
40.71
71.15
92.06

89.92
99.75
99.24



                                  Negative percent removal are recorded as 0.0
                                  NS:  Not Sampled
                                  ND:  Non-Deled
                                  DL:  Specific detection limits of sample when there is a non-detect, otherwise it is the method detection limit
                                  SP:  Sample Point

-------
lead, mercury, titanium, andzinc. All other metals analyzedhad high removals: tin (89.9 percent), antimony
(80.6 percent), selenium (71.2 percent), and molybdenum (40.7 percent).

6.4.3.3        Performance Comparison with Proposed BAT Facility

       In order to decide whether it should include the effluent data from Episodes #6181 and #6183
in its calculation of the limitations and standards, the Agency compared the treatment performance at these
two facilities with the treatment performance at Episode # 4646, whose performance was the basis for the
proposed BAT limitations, to determine if the data generated at the two facilities was of acceptable quality
for limitation calculations (see Section 8).
       Table 6-10 presents a summary of the percent removal data collected at Episodes # 6181, # 6183,
and # 4646 for their entire treatment systems. As the table demonstrates, all three systems achieved
similarly high removals for many of the same metal parameters, especially those metals readily removed
using hydroxide. All three facilities utilize a two-tiered approach in the design of their treatment systems
using some type of two-stage precipitation process to achieve the high levels of removal. Each facility
demonstrates high removals (above 90 percent) for pollutants that appear in high concentrations in the raw
wastewater (often several mg/1).
       EPA decided that it should include the effluent data from Episodes #6181 and # 6183 into its
limitations calculations because both new facilities: 1) employ a two-stage chemical precipitation
wastewater treatment process similar to the proposed BAT facility, and 2) achieve comparable percent
removals of relatively high concentrated raw wastewaterto those achieved at the proposed BAT facility.
                                           6-60

-------
              Table 6-10.  Treatment Technology Performance Comparison



Pollutant of
Concern
Conventional
TSS
Metals
Aluminum
Antimony
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
Zinc
CAS
#

C-009

7429905
7440360
7440382
7440439
7440473
7440508
7439896
7439921
7439976
7439987
7782492
7440224
7440315
7440326
7440666

unit

mg/1

ug/1
ug/1
ug/I
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ug/1
ue/I

DL

4

100
60
10
5
10
10
20
10
0.2
50
10
5
50
10
20
Entire Treatment System
Episode #6181
Sample Points 1 to 2
Inf
SP

01

01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Cone.

78.8

5,810
919
129
99.6
27.5
522
2,050
1,160
3.04
399
70.3
16.2
135
204
2.120
Eff
SP

02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cone.

4.77

100
1,020
51.6
5.54
12
12.9
25.1
10.6
0.2
488
86.6
6
64.4
10
24.3
%
Rem

93.95

98.28
0.0
60.00
94.44
56.36
97.53
98.78
99.09
93.42
0.0
0.0
62.96
52.30
95.10
98.85
Entire Treatment System
Episode #6183
Sample Points 1 to 2
Inf
SP

01

01
01
01
01
01
01
01
01
01
01
01
01
01
01
01
Cone.

315

61,500
1,710
1,210
97.7
2,250
1,970
231,000
1,600
219
1,550
113
69.8
1,330
4,030
8.300
Eff
SP

02

02
02
02
02
02
02
02
02
02
02
02
02
02
02
02
Cone.

51.7

334
332
27.8
5
10
10
428
10
0.48
919
32.6
5.54
134
10
62.8
%
Rem

83.59

99.46
80.58
97.70
94.88
99.56
99.49
99.81
99.38
99.78
40.71
71.15
92.06
89.92
99.75
99.24
Entire Treatment System
Episode #4646
Sample Points 1+2 to 6
Inf
SP

01+02

01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
01+02
Cone.

122.56

1,104
672
475
929
220
5,228
7,066
4,691
59.2
936
240
283
1,882
2,116
9.456
Eff
SP

06

06
06
06
06
06
06
06
06
06
06
06
06
06
06
06
Cone.

5.5

160
346
8.1
19.9
ND
10.1
128
ND
ND
580
26.0
ND
31.5
6.8
24.2
%
Rem

95.5

85.5
48.5
98.3
97.9
95.5
99.8
98.2
99.0
96.6
38.0
89.1
98.2
98.3
99.7
99.7
o\
              Negalive percent removal are recorded as 0.0
              NS: Not Sampled
              ND: Non-Dctcct
              DL: Specific detection limits of sample when there is a iron-detect, otherwise it is the method detection limit
              SP: Sample Point

-------
SECTION 7
ENGINEERING COSTS

       This section of the Commercial Hazardous Waste Combustor (CHWC) Industry Development
Document presents the following information: sources of cost data along with a benchmark analysis of
models; engineering costing methodology and description of each type of additional cost to comply with
options; individual treatment technology costs; and individual compliance costs for each facility in the
database for each option.
       This chapter contains the following sections:

       •       Section 7.1 presents a discussion of the various costing options that were evaluated. The
              criteria used to evaluate these costing options are presented, as well as a benchmark
              analysis to compare the accuracy of each of these options. The selected costing option is
              also presented in this section.
       •       Section 7.2 presents a discussion of the costing methodology used to develop regulatory
              costs. This section discusses the methodology used to cost treatment systems and
              components, as well as to develop regulatory option costs.
       •       Section 7.3 presents the costing method used to cost individual treatment technologies
              which comprise the regulatory options. Cost curves and equations developed for each
              treatment technology are presented in this section.
       •       Section 7.4 presents the approach to developing additional regulatory costs associated
              with the implementation of the CHWC regulation. Additional costs which were developed
              include retrofit, monitoring, RCRA permit modification, and land costs.
       •       Section 7.5 presents the wastewater off-site disposal costs used for facilities with very low
              flow rates of CHWC wastewater.
                                          7-1

-------
       •      Section 7.6 presents summary tables of the total compliance costs, by facility, for each of
              the CHWC Industry regulatory options, including BPT/BCT/BAT and PSES.  Also
              presented in this section are the compliance costs for NSPS and PSNS.

 7.1           COSTS DEVELOPMENT

       This section presents a discussion of the various costing options which were evaluated in order to
 calculate compliance costs for the CHWC Industry. A discussion of the selection criteria used to evaluate
 these costing options are presented in this section, as well as a benchmark analysis to compare the
 accuracy of each of these options. The selected costing option is then presented.

 7.1.1         Sources of Cost Data

       The following sections present the various costing sources considered in developing regulatory costs
 for the CHWC Industry, including computer models, vendor quotes, the 1992 Waste Treatment Industry
 Phase II: Incinerators 308  Questionnaire, and other effluent guidelines.

 7.1.1.1        Cost Models

       Cost estimates of wastewater treatment systems are required to be developed in orderto evaluate
the economic impact of the regulation. Mathematical cost models were used to assist in developing
estimated costs, hi a mathematical cost model, various design and vendor data are combined to develop
cost equations which describe costs as a function of system parameters, such as flow. Using such models
readily allows for iterative costing to be performed to assist in option selection.
       For developing costs for the CHWC Industry regulation, two commonly used cost models were
evaluated:
                                          7-2

-------
       •      Computer-Assisted Procedure for the Design and Evaluation of Wastewater Treatment
              Systems (CAPDET), developed by the U.S. Army Corps of Engineers.
              W/W Costs Program (WWC), Version 2.0, developed by CWC Engineering Software.

       CAPDET is intended to provide planning level cost estimates to analyze alternate design
technologies for wastewater treatment systems. It was developed to estimate treatment system costs
primarily for high flow, municipal wastewater applications. Modules are used which represent physical,
chemical, and biological treatment unit processes. Equations in each of these modules are based upon
engineering principles historically used for wastewater treatment plant design. Modules can be linked
together to represent entire treatment trains. CAPDET designs and costs various treatment trains and ranks
them with respect to present worth, capital, operating, or energy costs.
       WWC is a cost model developed by Culp/Wesner/Culp from a variety of engineering sources,
including vendor supplied data, reported plant construction data, unit  takeoffs from empirical and
conceptual designs, and published data. The program allows for the costing of various unit processes. As
with CAPDET, this program allows for these unit processes to be strung together to develop cost for
treatment trains. WWC does not perform the design of the unit process, but rather prompts the user to
provide design input parameters which form the basis for the costing. The WWC program is provided with
a separate spreadsheet program entitled Design Criteria Guidelines to assist in developing the input
parameters to the costing program. The Design Criteria Guidelines is a spreadsheet of treatment
component design equations which is supplied using default parameters to assist in designing particular
treatment units. Defaultparameters are based upon commonly accepted design criteria used in wastewater
treatment Flexibility is provided with this spreadsheet, in that particular design parameters can be modified
to best satisfy given situations. Once design inputs are entered into the  program, the WWC costing
program yields both construction and operation and maintenance (O&M) costs for the system.
                                           7-3

-------
 7.1.1.2       Vendor Data

        For certain treatment processes, the cost models do not yield acceptable and valid treatment costs.
 In these instances, it was more reliable to obtain equipment and maintenance costs directly from treatment
 system or component manufacturers. Information on the wastewater characteristics was provided to the
 vendor in order to determine accurately the appropriate treatment unit and sizing. Vendor quotes were
 used to determine cost curves for sand filtration and for sludge dewatering using plate and frame
 technology. The cost curves used are based on the vendor quotes and information obtained as part of the
 Centralize Waste Treatment (CWT) effluent guidelines effort.

 7.1.1.3       1992 Waste Treatment Industry Phase II:  Incinerators 308  Questionnaire
              Costing Data

       The 1992 Waste Treatment Industry Phase II: Incinerators 308 Questionnaire costing data was
 only utilized in the benchmark analysis to compare the accuracy of the costing models and is discussed
 further in Section 7.1.2.

 7.1.1.4       Other EPA Effluent Guideline Studies

       Other EPA effluent studies, such as the Organic Chemicals and Plastics and Synthetic Fibers
 (OCPSF) industry effluent guidelines, were reviewed in order to obtain additional costing background and
 supportive information. However, costs developed as part of other industrial effluent guidelines were not
 used in costing for this industry, with the exception of the CWT effluent guideline data referenced in Section
 7.1.1.2 above.

 7.1.2          Benchmark Analysis and Evaluation Criteria

       A benchmark analysis was performed to gauge the accuracy of the costing models presented
above. This benchmark analysis used reported costs provided in the Incinerator 308 Questionnaires as
                                           7-4

-------
compared to costs generated using various costing options. Two facilities (Episodes # 4646 and 4671)
were selected to be used in the benchmark analysis. The facilities had installed treatment systems similar
to the BPT/BCT/BAT/PSES options. Treatment technologies which were used in the benchmark analysis
include:

       •      equalization
       •      chemical precipitation
       •      sedimentation
       •      sand filtration

       Table 7-1 presents a cost comparison of capital and O&M costs for the above technologies.
Costs were developed using the average design flow of the selected facilities and average pollutant loadings
(see Section 4). This table presents costs developed using the WWC program, CAPDET, and vendor
quotes, as compared to industry provided treatment system capital and O&M costs provided in the
Incinerator 308 Questionnaires for the facilities.
       Capital costs provided in the Incinerator 308 Questionnaire for chemical precipitation systems
installed at facilities 4646 and 4671 were $2,207,000 and $1,215,000, respectively. Questionnaire capital
cost for the second-stage chemical precipitation system and filtration process at facility 4646 was
$2,751,000, whereas, the capital cost for the second-stage chemical precipitation at facility 4671 was
$2,265,000. As demonstrated on Table 7-1, capital costs developed by the WWC program for the
various treatment technologies were typically close to the reported costs as provided in the questionnaire.
For the WWC program, the range of accuracy in predicting treatment component capital costs ranged
from plus 76.6 percent for the chemical precipitation system for facility 4671 to a minus 34.8 percent for
the second-stage chemical precipitation system also for facility 4671. The range of accuracy for the
CAPDET program capital costs was greater than that of the WWC program and ranged from a positive
110.6 percent for the chemical  precipitation system for facility 4646 to a minus 46.6 percent for the
                                           7-5

-------
 Table  7-1.  Costing Source Comparison
                                              Capital Costs
                                                  1992 Dollars
Questionnaire
WWC
CAPDET
Vendor Quotes
                   4646 ChcmPrecip  4646 2-stage ChemPrecip 4671 ChemPrecip   4671 2-stage ChemPrecip
2,206,980
3,543,264
4,948,779
  399,878
and Sand Filtration
    2,751,204
    2,950,035
    1,475,480
    3,314,930
1,214,563
2,144,446
  942,216
  319,206
2,265,009
1,476,821
3,072,253
  670,158
                                              O&M Costs
                                                 1992 Dollars
                                                                         E3 Questionnaire
                                                                         • WWC
                                                                         El CAPDET
                                                                         G3 Vendor Quotes
                   4646 ChcmPrccip   4646 2-stage ChcmPrecip  4671 ChemPrecip   4671 2-stage ChcmPrccip
Questionnaire
WWC
CAPDET
Vendor Quotes
 910,000
1,355,505
 585,855
 860,867
and Sand Filtration
      315,000
      231,728
      99,036
      222,135
1,837,000
1,864,219
 515,859
 361,623
 363,000
 686,360
 466,848
 151,889
                                                 7-6

-------
second-stage chemical precipitation and filtration system at the same facility. Vendor quotes consistently
had a large variability from reported questionnaire costs and were typically much lower.
       O&M costs provided in the Incinerator 308 Questionnaire for chemical precipitation systems
installed at facilities 4646 and 4671 were $910,000 and $1,837,000, respectively. Questionnaire O&M
costs for the second-stage chemical precipitation system and filtration process at facility 4646 was
$315,000, whereas, the O&M cost for the second-stage chemical precipitation at facility 4671 was
$363,000. As demonstrated on Table 7-1, O&M costs developed by the WWC program for the various
treatment technologies were typically close to the reported costs as provided in the questionnaire.   For
the WWC program, the range of accuracy in predicting treatment component O&M costs ranged from plus
89.1  percent for the second-stage chemical precipitation system for facility 4671 to a minus 26.4 percent
for the second-stage chemical precipitation and filtration system for facility 4646.  The ranges of accuracy
for the CAPDET program and vendor quotes in predicting O&M costs were typically greater than the
WWC program costs or were significantly lower than questionnaire provided costs.
       Therefore, the benchmark analysis demonstrated that the WWC cost program consistently
developed capital and O&M costs which are considered acceptable estimates of the reported costs from
the questionnaire responses. Whereas, both CAPDET and vendor quotes were determined not to be as
accurate or consistent in estimating capital and O&M costs  for these technologies.
       The following criteria was used in order to evaluate the costing options and to select the appropriate
option for developing the CHWC Industry costing methodology:

       •       Does  the model contain costing modules representative of the various wastewater
              technologies in use or planned for use in the  CHWC Industry?
       •       Can the program produce costs in the expected flow range experienced in this industry?
       •       Can the model be  adapted to cost entire treatment trains used in the CHWC Industry?
       •       Is sufficient documentation available regarding the assumptions and sources of data so that
              costs are credible  and defensible?
                                           7-7

-------
        •       Is the model capable of providing detailed capital and operation and maintenance costs
               with unit costing breakdowns?
        •       Is the program capable of altering the default design criteria in order to accurately
               represent actual design criteria indicative of the CHWC Industry?

 7.1.3          Selection of Final Cost Models

        Based upon the results of the benchmark analysis and an evaluation using the criteria above, the
 WWC costing program was selected for costing the majority of the treatment technologies. It was
 determined that the WWC produces reliable capital and O&M costs for a wide range of treatment
 technologies. As demonstrated on Table 7-1, WWC program costs were consistently accurate in
 predicating both capital and O&M costs for those waste water treatment systems at the selected facilities.
 Capital costs predicted by CAPDET for these various treatment systems were typically less consistent and
 were either much higher or lower than Questionnaire provided costs. O&M costs developed with
 CAPDET were typically low compared to Questionnaire costs. In addition, CAPDET could not cost all
 of the technologies needed for the CHWC Industry and was determined not to be as accurate in predicting
 costs in the low flow range that characterize the CHWC Industry. Vendor quotes for both capital and
 O&M costs in general were much  lower than Questionnaire costs. Therefore, CAPDET and vendor
 quotes (except  as provided for below) were not used for costing.
       The WWC computer-based costing program best satisfied the selection criteria presented above.
 The program cost a wide range of typical and innovative treatment unit operations and combined these unit
 operations to develop system costs. Since the WWC program is a computer based program, it readily
 allowed for the repeated development of costs for a number of facilities. The program utilizes cost modules
 which accommodated the range of flows and design input parameters needed to cost the CHWC Industry.
 Costs developed by this program are based upon a number of sources, including reported construction and
 operation costs, as well as published data. Costs are presented in a breakdown summary table which
 contains unit costs and totals. Finally, the WWC program is adaptable to costing unit operations based
upon specified design criteria, as well as flow rate. Certain unit operations are costed strictly based upon
                                           7-8

-------
the input of flow rate, whereas other unit operations are costed based upon a combination of flow rate and
design loadings or component size. The Design Criteria Guidelines spreadsheet is used in conjunction with
the program to aid in determining particular treatment component design input parameters. This
spreadsheet is based upon design default values, which can readily be modified in order to develop costs
based upon particular design parameters common in the CHWC Industry.
       However, there were particular instances where the WWC program did not produce reliable cost
information, such as for sand filtration and sludge dewatering facilities. WWC program costs for these
technologies were excessively high as compared to industry provided costs in the Questionnaire. For these
technologies, vendor quotes were more accurate in predicating costs and, therefore, were used to provide
costs.

7.2          ENGINEERING COSTING METHODOLOGY

       This section presents the costing methodology used to develop treatment technology and
BPT/BCT/BAT and PSES option costs for the CHWC Industry. Additional costs to comply with this
regulation, such as monitoring costs, are presented in Section 7.4 of this chapter.

7.2.1         Treatment Costing Methodology

       The following discussion presents a detailed summary of the technical approach used to estimate
treatment technology costs for each in-scope facility in the CHWC database. For each facility in the
database and for each option, EPA developed total capital and annual 0 & M treatment costs to upgrade
existing wastewater treatment systems, or to install new treatment technologies, in order to comply with the
long term averages (LTAs). Faculties were costed primarily using the WWC costing program. Vendor
cost curves, as developed in the CWT industry study, were used for sand filtration and sludge dewatering
costing. Table 7-2 presents a breakdown of the costing method used for each treatment technology.
                                          7-9

-------
Table 7-2.    Breakdown of Costing Method by Treatment Technology
Treatment
Technology
Flocculation, Mixing
& Pumping
Chemical Feed System
Primary & Secondary
Clarification
Sand Filtration
Sludge Filter Press
Cost Using
WWC Program
X
X
X


Cost Using Vendor
Quotes'



X
X
Key Design
Parameter(s)
Flow rate
Flow rate & POC
Metals
Flow rate
Flow rate
Flow rate
 (1)  Cost curves developed using vendor quotes in the CWT guideline effort.

       In using the WWC computer model to develop treatment technology costs, the first step was to
 use the Design Criteria Guidelines spreadsheet to develop input parameters for the computer costing
 program. Reported pollutant loadings from me facility were used whenever possible. If pollutant loadings
 were not available for a particular parameter, EPA used an estimated concentration developed based on
 combined waste stream loadings or loadings from similar facilities. The facility's baseline flow rate and the
 regulatory option LTAs were also used in the design of the unit operation. Certain key design parameters,
 such as total suspended solids (TSS), are used directly in the WWC program, and accompanying Design
 Criteria Guidelines spreadsheet, to design me various treatment unit operations, such as a clarifier. Selected
 pollutant of concern (POC) metals were used to assist in the design of BPT/BCT/BAT chemical
 precipitation systems. These metals typically impose a large requirement for the various precipitating agents,
 thereby governing the chemical feed system design. A more detailed discussion of individual treatment
 technology costing and their design parameters is presented in Section 7.3. The design parameters from
 the Design Criteria Guidelines spreadsheet were next used as input for the WWC costing program to
 develop the installed capital and O&M costs.
       Individual treatment component costs were developed by the WWC program by using the
 corresponding module provided by the program for that particular technology. Technology-specific design
parameters were input into the WWC program. The WWC program then calculated both installed capital
costs and annual O&M costs. Treatment technology costs developed by the WWC costing program were
                                           7-10

-------
corrected to 1992 costs using the Engineering News Record (ENR) published indexes. After the installed
capital and annual O&M costs were developed for each facility, selected cost factors, as shown in Table
7-3, were applied to the results to develop total capital and O&M costs. Capital costs developed by the
program include the cost of the treatment unit and some ancillary equipment associated with that technology
(see Section 7.3 for further information on particular items costed for each technology). O&M costs for
treatment chemicals, labor, materials, electricity, and fuel are included in the computer program O&M
costs.

Table 7-3.    Additional Cost Factors
Type
Capital









O&M
Factor
Site Work & Interface Piping
General Contractor Overhead
Engineering
Instrumentation & Controls
Buildings
Site Improvements
Legal, Fiscal, & Administrative
Interest During Construction
Contingency
Retrofit (if necessary)
Taxes & Insurance
% of Capital Cost
18
10
12
13
6
10
2
9
8
20
21
(1)  2 percent of total capital costs, which includes WWC computer costs and capital costs listed above.
7.2.2
Option Costing Methodology
       The following discussion presents a detailed summary of the technical approach used to estimate
the BPT/BCT/BAT and PSES option costs for each in-scope facility in the CHWC database. Zero
discharge facilities were not costed for any of the regulatory options. The costing methodology used to
develop facility-specific BPT/BCT/BAT and PSES option compliance costs is presented graphically on
the flow diagram in Figure 7-1.
                                           7-11

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Figure 7-1. Option-Specific Costing Logic Flow Diagram
                                                                             Provide entire treatment
                                                                            system for this BPT/BCT/
                                                                               BAT/PSES option
                                           Does the facility have
                                           some of the treatment
                                         components for this BPT/
                                         BCT/BAT/PSES option or
                                           equivalent treatment?
   Does the facility have all
of the treatment components for
  this BPT/BCT/BAT/PSES
       option installed?
  Upgrade existing process
  equipment or operation to
ensure compliance with LTAs
for this BPT/BCT/B AT/PSES
          option
 Provide additional treatment
   components necessary to
( achieve LTAs for this BPT/
' BCT/BAT/PSES option. In
some cases upgrades to existing
treatment components or other
incremental treatment processes
   may only be necessary to
  achieve LTAs for this BPT/
   BCT/BAT/PSES option
                                                      Cost upgrade to existing treatment system  X
                                                    to achieve LTAs for this BPT/BCT/BAT/PSES  \
                                                       option; including retrofit, land, residual,       I
                                                     RCRA permit modifications (if hazardous)    /
                                                               and monitoring costs           /
                                                                                                                Cost facility for entire treatment system
                                                                                                               under this BPT/BCT/BAT/PSES option;
                                                                                                                including land, residual, RCRA permit
                                                                                                                  modifications (if hazardous), and
                                                                                                                         monitoring costs
 Cost facility only for additional treatment
   process(es) and upgrades necessary to
achieve LTAs for this BPT/BCT/BAT/PSES
  option; including retrofit, land, residual,
RCRA permit modifications (if hazardous),
          and monitoring costs

-------
       For each BPT/BCT/B AT and PSES regulatory option, it was first determined whether a facility
was complying with the LTAs for each pollutant considered for regulation.  None of the facilities were in
compliance with the LTAs, and were therefore assigned additional equipment and/or upgrade costs to
achieve compliance with that option. The next step was to determine whether a facility had already installed
treatment unit operations capable of complying with the LTAs. If a facility already had BPT/BCT/BAT,
PSES or equivalent treatment installed, the facility was only assigned costs for treatment system upgrades.
       For facilities that did not have BPT/BCT/BAT or PSES treatment systems or equivalent, costs
were developed for the additional unit operations and/or system upgrades necessary to meet each LTA.
Facilities which were already close to compliance with the LTAs were costed for upgrades in order to
achieve BPT/BCT/BAT levels. Upgrade costs were developed using the WWC costing program
whenever possible, and included either additional equipment to be installed on existing unit processes,
expansion of existing equipment, or operational changes. Examples of upgrade costs include such items
as a new or expanded chemical feed system, or improved or expanded sedimentation capabilities. If a
facility had no treatment system, or one that could not achieve desired levels with upgrades or minor
additions, an entire BPT/BCT/BAT treatment system was costed for that facility.
       Once all of the individual treatment technology requirements for each facility were established,
individual capital and O&M treatment technology costs were developed as previously described above
in Section 7.2.1. In order to estimate the total compliance cost for a regulatory option it is necessary to
sum all of the individual component treatment technology costs.  Table 7-4 presents the regulatory option
in the CHWC Industry and the corresponding treatment technologies costed.

Table 7-4.    Regulatory Option Wastewater Treatment Technology Breakdown
       BPT/BCT/BAT/PSES Option
               Description
   Treatment Code Components
WWC
  #
 Two-Stage Chemical Precipitation, Sand
 Filtration & Sludge Dewatering
Pumping
Rapid Mix Tank
Sodium Bisulfite Feed System
Flocculation
  92
  104
  42
  72
                                         7-13

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        BPT/BCT/BAT/PSES Option
       	Description	
                                Treatment Code Components
WWC
  Two-Stage Chemical Precipitation, Sand
  Filtration & Sludge Dewatering (cont.)
                             Sodium Hydroxide Feed System
                             Primary Clarification
                             Pumping
                             Rapid Mix Tank
                             Hydrochloric Acid Feed System
                             Flocculation
                             Ferric Chloride Feed System
                             Polymer Feed
                             Rapid Mix Tank
                             Sodium Hydroxide Feed System
                             Secondary Clarification
                             Sand Filter
                             Sludge Dewatering	
  45
  118
  92
  104
  46
  72
  40
  43
  104
  45
  118
 NA
 NA
NA = Technology costed using vendor cost curves from CWT study.
7J
TREATMENT TECHNOLOGIES COSTING
       The following sections describe how costs were developed for the BPT/BCT/BAT/PSES
treatment technologies. Specific assumptions are discussed for each treatment technology regarding the
equipment used, flow ranges, input and design parameters, and design and cost calculations. Table 7-2,
previously referenced, presented the selected costing method which was used to cost each of the treatment
technologies used in the BPT/BCT/BAT and PSES options. The following subsections present a detailed
discussion on how each of the treatment technologies presented in Table 7-3 were costed. Costs are
presented as physical/chemical wastewater treatment costs, and sludge treatment and disposal costs.
7.3.1
Physical/Chemical Wastewater Treatment Technology Costs
       Table 7-4 presents a breakdown of the WWC treatment modules used in costing each treatment
technology for the regulatory option. The following sections present a description of costs for each
                                         7-14

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physical/chemical wastewater treatment technology used in the regulation. Capital and O&M cost curves
were developed for specific technologies and system components. These curves, which represent cost as
a function of flow rate or other system design parameters, were developed using a commercial statistical
software package (SlideWrite Plus Version 2.1). First, costs were developed using the WWC program
for each technology or component using as a design basis five different flow rates or other system design
parameters (depending upon the governing design parameter).  For instance, a technology costed on the
basis of flow would have costs developed by the WWC program at 0.01 million gallons per day (MOD),
0.05 MOD, 0.1 MOD, 0.5 MOD, and 1.0 MOD. Ranges for the five selected points to cost were based
upon a review of the flow or technology design parameters for all facilities in the database and were
selected in order to bracket the range from low to high. Next, these five data points (flow/design parameter
and associated cost) were entered into the commercial statistical software program. Cost curves to model
the total capital and O&M costs were then developed by the program using curve fitting routines. A
second order natural log equation format was used to develop all curves. All cost curves yielded total
capital and O&M costs, unless otherwise noted.

7.3.1.1        Chemical Feed Systems

       The following section presents the methodology used to calculate the chemical addition feed rates
used with each applicable regulatory option. Table 7-5 presents a breakdown of the design process used
for each type of chemical feed. Chemical costs presented in Table 7-6 were taken from the September
1992 Chemical Marketing Reporter.
       For facilities with existing chemical precipitation systems, an evaluation was made as to whether
the system was achieving the regulatory option LTAs. If the existing system was achieving LTAs, no
additional chemical costs were necessary. However, if the facility was not achieving the LTAs for an
option, the facility was costed for an upgrade to the chemical precipitation system.  First, the stoichiometric
requirements were determined for each metal to be removed to the LTA level. If the current feed rates
were within the calculated feed rates no additional costs were calculated. For facilities currently feeding
less than the calculated amounts, the particular facility was costed for an upgrade to add additional
                                           7-15

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 precipitation chemicals, such as a coagulant, or expand their existing chemical feed system to accommodate
 larger dosage rates.

 Table 7-5.     Chemical Addition Design Method
Chemical
Hydrochloric Acid
Sodium Hydroxide
Polymer
Sodium Bisulfate
Ferric Chloride
Basis for Design
Stoichiometry
X
X

X

Reference1 (mg/1)


2.0

75
 (1) Source: Industrial Water Pollution Control, 2nd Edition.
Table 7-6.    Treatment Chemical Costs
Treatment Chemical
Ferric Chloride
Hydrochloric Acid
Polymer
Sodium Bisulfate
Sodium Hydroxide
Cost1
$200/ton
$72/ton
$2.25/lb
$230/ton
$350/ton
(1) Source: 1992 Chemical Marketing Reporter.

       Facilities without an installed chemical precipitation system were costed for an entire metals
precipitation system. The chemical feed rates used at a particular facility for either an upgrade or a new
system were based upon stoichiometric requirements, pH adjustments, and buffering ability of the raw
influent.
       In developing the CWT industry guideline, EPA's analysis led the agency to conclude that the
stoichiometric requirements for chemical addition far outweighed the pH and buffer requirements. It was
determined that 150 percent of the stoichiometric requirement would sufficiently accommodate forpH
                                           7-16

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adjustment and buffering of the solution. An additional 50 percent of the stoichiometric requirement was
included to react with metals not on the POC list Finally, an additional 10 percent was added as excess.
Therefore, a total of 210 percent of the stoichiometric requirement was used in developing costs.

Sodium Hydroxide Feed Systems

       The stoichiometric requirement for sodium hydroxide to remove a particular metal is based upon
the generic equation:
                                2£~±)(jf22!i|fj!2£
               _                        _ _     treatment chemical \
''treatment chemical  ~ f           f I '
                           /I   "*"M  A    ""'"^Afa/CU
where, M is the target metal and MW is the molecular weight
       The calculated amounts of sodium hydroxide to remove a pound of each of the selected metal
pollutants of concern are presented in Table 7-7. For indirect dischargers, only those metals which were
determined to pass through a POTW were used in determining the stoichiometric requirements. The other
metals present  in the  wastewater will be accommodated  for by the additional 110 percent of the
stoichiometric requirement Sodium hydroxide chemical feed system costs were developed for many
facilities using the WWC costing program. Reported facility loadings were used to establish the sodium
hydroxide dosage requirement. WWC unit process 45 was used to develop capital and O&M costs for
sodium hydroxide feed systems. The capital and O&M cost curves developed for sodium hydroxide feed
systems, based upon the calculated dosages, are presented as Equations 7-1 and 7-2, respectively.
                                         7-17

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 Table 7-7.    Sodium Hydroxide Requirements for Chemical Precipitation

Pollutant
Aluminum
Antimony
Arsenic
Boron
Cadmium
Chromium
Copper
Iron
Lead
Manganese
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
Dosage Rate
Sodium Hydroxide (Ib/lb metal removed)
4.45
1.64
2.67
11.10
0.71
2.31
1.26
2.15
0.77
2.91
0.40
2.50
2.03
0.74
1.35
3.34
ln(Y) = 1 0.653 - 0. 1 841n(X) + 0.0401n(X)2 (7-1)
ln(Y) = 8.508 - 0.04641n(X) + O.OWmCX)2 (7-2)
where:
       X = Dosage Rate (Ib/day), and
       Y = Cost (1992$)
       Figures 7-2 and 7-3 graphically present the sodium hydroxide feed system capital and O&M cost
curves, respectively.
       Costs for a sodium hydroxide feed system are estimated using the WWC unit process cost number
45. Costs are based on sodium hydroxide dosage rates between 10-10,000 Ib/day, with dry sodium
                                          7-18

-------
                                Figure 7-2


                  Sodium Hydroxide Capital Cost Curve
             A   WWC Cost
    1000000 c
~ t*   100000
vo O
  o
       10000
                       I I I I 111  	I
           0.5  1
10
100
1000
10000
                               Dosage Rate (Ib/day)

-------
                               Figure 7-3

                  Sodium Hydroxide O&M Cost Curve
             A   WWC Cost
      50000
      10000
o o
  O
4948
                                           9148,
       1000
           0.5  1
                                      11
             10          100
                               Dosage Rate (Ib/day)
1000
10000

-------
hydroxide used at rates less than 200 Ib/day, and liquid sodium hydroxide used at higher feed rates. The
costing program assumes that dry sodium hydroxide (98.9 percent pure) is delivered in drums and mixed
to a 10 percent solution on-site, A volumetric feeder is used to feed sodium hydroxide to one of two tanks;
one for mixing the 10 percent solution, and one for feeding.  Two tanks are necessary for this process
because of the slow rate of sodium hydroxide addition due to the high heat of solution. Each tank is
equipped with a mixer and a dual-head metering pump, used to convey the 10 percent solution to the point
of application. Pips and valving is required to convey water to the dry sodium hydroxide mixing tanks and
between the metering pumps and the point of application.
       A 50 percent sodium hydroxide solution is purchased, premixed and delivered by bulk transport
for feed rates greater than 200 Ib/day. The 50 percent solution contains 6.38 pounds of sodium hydroxide
per gallon, which is stored in fiberglass reinforced polyester tanks designed to a hold  15 day capacity.
Dual-head metering pumps are used to convey the liquid solution to the point of application, and a standby
metering pump is provided in all systems.  The storage tanks are located indoors, since 50 percent sodium
hydroxide begins to crystallize at temperatures less than 54°F.

Ferric Chloride Feed Systems

       Ferric chloride feed systems were costed using the WWC unit process 40. Costs were based
upon a dosage rate of 75 tag/I of ferric chloride. The capital and O&M cost curves developed for ferric
chloride feed systems are based upon the calculated dosage and are presented as Equations 7-3 and 7-4,
respectively.

       ln(Y) = 11.199 - 0.1361n(X) + 0.0541n(X)2                                       (7-3)
       ln(Y) = 8.808 - 0.4081n(X) + 0.0741n(X)2                                        (7-4)
where:
       X = Dosage Rate (Ib/hr), and
       Y = Cost (1992$)
                                           7-21

-------
       Figures 7-4 and 7-5 graphically present the ferric chloride feed system capital and O&M cost
 curves, respectively. Costs for ferric chloride feed facilities are based on storage and feeding a 43 percent
 solution of ferric chloride with a weight of 12 pounds per gallon (5.2 Ibs dry ferric chloride/gallon). The
 solution is stored in covered fiberglass reinforced polyester tanks designed to hold a 15 day supply. Cost
 estimates include dual-head metering pumps (one standby) with materials suitable for ferric chloride and
 150 feet of stainless steel pipe and associated valves. Automatic or feed back controls are excluded.

 Sodium Bisulfite Feed Systems

       Sodium bisulfite feed systems were costed using the WWC unit process 42. Costs were based
 upon a stoichiometric requirement of2.81 mg/1 of sodium bisulfite per 1 mg/1 of total chromium. The capital
 and O&M cost curves developed for sodium bisulfite feed systems are based upon the calculated dosage
 and are presented as Equations 7-5 and 7-6, respectively.

       ln(Y) = 10.822452 - 0.0109971n(X) + 0.03 869 lln(X)2                            (7-5)
       ln(Y) = 8.418772 + 0.518241n(X) + 0.0398381n(X)2                              (7-6)
 where:
       X = Dosage Rate (Ib/hr), and
       Y = Cost (1992$)

       Figures 7-6 and 7-7 graphically present the sodium bisulfite feed system capital and O&M cost
curves, respectively.
       A five minute detention period is provided in the dissolving tank. Fifteen days of storage is included
using mild steel storage hoppers which are located indoors. Sodium bisulfite is conveyed pneumatically
from bulk delivery tracks to the hoppers, with the blower located on the delivery truck.  Hopper costs
include dust collectors.  Bag loaders are used on the feeder in systems too small for bulk systems.
Volumetric feeders are used for all installations.  Solution tanks are located directly beneath the storage
                                          7-22

-------
                                 Figure 7-4
                     Ferric Chloride Capital Cost Curve
              A   WWC Cost
      1e+007 F
     1000000 F
•^1
  O
      100000 F
       10000
                   10
100
1000
10000
                                 Dosage Rate (Ib/hr)

-------
                           Figure 7-5

               Ferric Chloride O&M Cost Curve
        A   WWCCost
100000
 10000
  1000
        I  I I I I I I
              10
                       4794 53A11
                        A
                                                    43570
                                                     A
                                         130J
                                     910
I  I i I I I 11	I   I  I I I I I t I	I  I  I  I I I I
       100
1000
10000
                           Dosage Rate (KVhr)

-------
                                Figure 7-6
                   Sodium Bisulfite Capital Cost Curve
              A   WWCCost
     1000000
^ £   100000
«* 5        6
       10000
489
           10
                                                     20883&
                        100
1000
                                Dosage Rate (Ib/hr)

-------
                            Figure 7-7
               Sodium Bisulfite O&M Cost Curve
         A   WWC Cost
1000000
 100000
  10000
   1000
                                                  5284J
       1
10
100
1000
                           Dosage Rate (Ib/hr)

-------
hoppers.  Conveyance from the solution tanks to the point of application is by dual-head diaphragm
metering pumps.

Hydrochloric Acid Feed Systems

       Hydrochloric acid is necessary to neutralize the waste stream or adjust the waste stream for
   mg/L
                                                            2molH*     \molH2S04
chemical treatment The amount necessary was calculated using the following equation.
To allow for solution buffering, 10 percent excess acid was added.
       Hydrochloric acid feed systems were costed using the WWC unit process 46. The capital and
O&M cost curves developed for hydrochloric acid feed systems, based upon the calculated feed rate, are
presented as Equations 7-7 and 7-8, respectively.

       ln(Y) = 10.431273 - 0.1968121n(X) + 0.0442471n(X)2                               (7-7)
       ln(Y) = 7.630396 + 0.3123051n(X) - 0.0024 \9\D$tf                                (7-8)
where:
       X = Feed Rate (gpd), and
       Y = Cost (1992$)

       Figures 7-8 and 7-9 graphically present the hydrochloric acid feed system capital and O&M cost
curves, respectively.
       Costs are based on systems capable of metering concentrated acid from a storage tank directly to
the point of application.  For feed rates up to 200 gpd, the concentrated acid is delivered in drums and
stored indoors.  At higher flow rates, the acid is delivered in bulk and stored outdoors in fiberglass

-------
                                Figure 7-8

                  Hydrochloric Acid Capital Cost Curve
              A   WWC Cost
      100000
-
fc o
00 O
       10000 L-L-1
- 27153
            7  10
                          100
1000
                                Dosage Rate (gpd)

-------
                           Figure 7-9
              Hydrochloric Acid O&M Cost Curve
        A   WWC Cost
100000 r
 10000
  1000
      1
                                                   13209
                                  6945
                8511
                                            958'
                      403J
10
100
1000
                           Dosage Rate (gpd)

-------
 reinforced polyester tanks. Acid is stored for 15 days, and a standby metering pump is included for all
 installations.

 Polymer Feed Systems

       WWC unit process 34 was used to cost polymer feed systems. Polymer dosage rate in Ib/hr was
 calculated based upon a target concentration of 2 mg/1 using the facility's flow rate. Although this module
 is designed to cost for a liquid alum feed system, costs generated by this module were determined to be
 more reasonable and accurate in developing polymer system costs than the WWC unit process 43 for
 polymer feed systems. The capital and O&M unloaded cost curves developed for polymer feed systems
 are presented as Equations 7-9 and 7-10, respectively.

       ln(Y) = 10.539595 - 0.137711n(X) + 0.0524031n(X)2                              (7-9)
       ln(Y) = 9.900596 + 0.997031n(X) + 0.000191n(X)2                               (7-10)
 where:
       X = Dosage Rate (Ib/hr), and
       Y = Cost (1992$)

       Figures 7-10 and 7-11 graphically present the polymer feed system capital and O&M cost curves,
 respectively.
       Polymer is stored for 15 days in fiberglass reinforced polyester tanks. For smaller installations, the
 tanks are located indoors and left uncovered, and for larger installations the tanks are covered and vented,
 with insulation and heating provided. Dual-head metering pumps deliver the polymer from me storage tank
 and meter the flow to the point of application.  Feed costs include 150 feet of 316 stainless steel pipe, along
with fittings and valves, for each metering pump.  A standby metering pump is included for each installation.
                                           7-30

-------
                                Figure 7-10
                     Polymer Feed Capital Cost Curve
              A   WWC Cost
     1000000 r
   o
<*>  o
~ o
  to   100000
10000 '  ' ' "'
     5   10
                                                        5238;
                               100
1000
10000
                                Dosage Rate (Ib/hr)

-------
                                Figure 7-11
                     Polymer Feed O&M Cost Curve
              A   WWC Cost
to
  8
     1e+009
     1e+008
      16+007
     1000000
      100000
       10000
            1
                      1995
10
                                                        98572:
                                               19714}
                                           9862!
                                   1973
                                               I I I III
100
1000
10000
                                Dosage Rate (Ib/hr)

-------
7.3.1.2        Pumping

       Wastewater pumping costs were estimated using WWC unit process 92, and are based on flow
rate. The capital and O&M cost curves developed for pumping are presented as Equations 7-11 and 7-
12, respectively.

       ln(Y) = 10.048 + 0.1671n(X) - 0.0011n(X)2                                     (7-11)
       ln(Y) = 7.499 + 0.0241n(X) + 0.04291n(X)2                                     (7-12)
where:
       X = Flow Rate (gpm), and
       Y = Cost (1992$)

       Figures 7-12 and 7-13 graphically present the pumping capital and O&M cost curves, respectively.

7.3.1.3        Rapid Mix Tanks

       Capital and O&M costs for rapid mix tanks were estimated using the WWC unit process 104 and
are based on reinforced concrete basins. The capital and O&M cost curves developed for rapid mix tanks
based upon flow rate are presented as Equations 7-13 and 7-14, respectively.

       ln(Y) = 12.234467 - 0.6778981n(X) + 0.0781431n(X)2                           (7-13)
       ln(Y) = 10.730231 + 0.6141411n(X) + 0.08322 lln(X)2                           (7-14)
where:
       X = Flow Rate (MOD), and
       Y = Cost (1992$)

       Figures 7-14 and 7-15 graphically present the rapid mix tank capital and O&M cost curves,
respectively.
                                         7-33

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                        Figure 7-12

          Wastewater Pumping Capital Cost Curve
           WWC Cost
100000
 10000
             I	I
      1
                                   38175
                            33590
                             A "
  10


Flow (gpm)
                                                 6424
                                         I	I  I  I  I I I
100

-------
                      Figure 7-13
          Wastewater Pumping O&M Cost Curve
          WWC Cost
10000
                                 2533
                          2213
 1000
                                  _t_——i	i	1—i—i__i—u
                           10
                         Plow (gpm)
100

-------
                           Figure 7-14
                  Mix Tank Capital Cost Curve
         A   WWC Cost
5000000
1000000
 100000
          45823
10000 	
   0.005 0.01
                          0.1
10
                             Flow (MGD)

-------
                          Figure 7-15
                  Mix Tank O&M Cost Curve
         A   WWC Cost
1000000 r
 100000
  10000
                                                  I  I I I I
     0.005 0.01
0.1
10
                            Flow (MGD)

-------
        Common wall construction is assumed for multiple basins. Costs include vertical shaft, variable
 speed turbine mixers with 304 stainless steel shafts, paddles, and motors. Costs are based on a O value
 (G is the mean temporal velocity gradient which describes the degree of mixing; i.e., the greater the value
 of G the greater the degree of mixing) of 300 (3 ft-lbs/sec/cu. ft.) and a water temperature of 15°C. The
 energy requirements are a function of G value, water temperature, and an overall mechanism efficiency of
 70 percent.

 7.3.1.4       Flocculation

        A cost curve was developed for flocculation using the WWC cost program. WWC unit process
 72 was used. Costs for flocculation were based upon a function of flow at a hydraulic detention time of
 20 minutes.  The capital and O&M cost curves developed for flocculation are presented as Equations 7-15
 and  7-16, respectively.

        ln(Y) = 11.744579 + 0.6331781n(X) - 0.0155851n(X)2                           (7-15)
        ln(Y) - 8.817304 + 0.5333821n(X) + 0.0024271n(X)2                            (7-16)
 where:
        X - Flow Rate (MOD), and
        Y-Cost (1992$)

        Figures 7*16 and 7-17 graphically present  the flocculation capital and O&M cost curves,
 respectively. Cost estimates for flocculation basins are based on rectangular-shaped, reinforced concrete
 structures with a depth of 12 feet and length-to-width ratio of 4:1. Horizontal paddle flocculators were
 used in costing because they are less expensive and more efficient. Manufactured equipment costs are
 based on a G value of 80. Cost estimates for drive units are based on variable speed drives for maximum
 flexibility,  and although common drives for two or more parallel basins are often utilized, the costs are based
on individual drives for each basin.
                                           7-38

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                                Figure 7-16
                      Flocculation Capital Cost Curve
              A   WWCCost
     1000000 E
      100000
NO
|J    10000
o
       1000
        100
          0.001
                     0.01
                                                1263(
                                   2884
0.1
10
                                  Flow (MGD)

-------
                               Figure 7-17
                      Flocculation O&M Cost Curve
             A   WWC Cost
     100000
      10000
0 8
       1000
        100
          0.001
                       638
0.01
0.1
10
                                 Flow (MGD)

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       Energy requirements are based on a G value 80 and an overall motor/mechanism efficiency of 60
percent Labor requirements are based on routine operation and maintenance of 15 min/day/basin and a
4 hour oil change every 6 months.

7.3.1.5        Primary Clarification

       Cost curves were developed forprimary clarification using the WWC cost program. WWC unit
process 118 for a rectangular basin with a 12 foot side wall depth was used. Costs for primary clarification
were based upon a function of flow rate, using an overflow rate of 900 gallons per day per square feet in
calculating tank size.  The capital and O&M cost curves developed for primary clarification are presented
as Equations 7-17 and 7-18, respectively.

       ln(Y) =  12.517967 + 0.5756521n(X) + 0.0093961n(X)2                          (7-17)
       ln(Y) =  10.011664 + 0.2682721n(X) + 0.002411n(X)2                            (7-18)
where:
       X = Flow Rate (MOD), and
       Y = Cost (1992$)

       Figures 7-18 and 7-19 graphically present the primary clarification capital and O&M cost curves,
respectively.
       Estimated costs are based on rectangular basins with a 12 foot side water depth (SWD), and chain
and flight sludge collectors. Costs for the structure assumed common wall construction, and include the
chain and flight collector, collector drive mechanism, weirs, the reinforced concrete structure complete with
inlet and outlet troughs, a sludge sump, and sludge withdrawal piping.

7.3.1.6       Secondary Clarification

       Cost curves were developed for secondary clarification using the WWC cost program. WWC unit
process 118 for a rectangular basin with a 12 foot side wall depth, and chain and flight collectors was used
                                          7-41

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                                Figure 7-18
                   Primary Clarifier Capital Cost Curve
              A   WWC Cost
      1e+007 E
     1000000
L tt   100000
N>
  o
       10000
        1000
          0.001
                       I I ll
0.01
            I 11 ll
             ll
0.1
10
                                  Flow (MGD)

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                          Figure 7-19
              Primary Clarifier O&M Cost Curve
        A   WWC Cost
100000 c
 10000
  1000
    0.001
                 667
                 Mil
0.01
                                          2250J
0.1
10
                            Flow (MGD)

-------
 Costs for secondary clarification were based upon a function of flow rate, using an overflow rate of 600
 gallons per day per square feet in calculating tank size. The capital and O&M cost curves developed for
 secondary clarification are presented as Equations 7-19 and 7-20, respectively.

       ln(Y) = 12.834601 + 0.6886751n(X) + 0.0354321n(X)2                           (7-19)
       ln(Y) = 10.197762 + 0.3399521n(X) + 0.0158221n(X)2                           (7-20)
 where:
       X = Flow Rate (MOD), and
       Y = Cost (1992 $)

       Figures 7-20 and 7-21 graphically present the secondary clarification capital and O&M cost
 curves, respectively. Costs for the structure assumed common wall construction, and include the chain and
 flight collector, collector drive mechanism, weirs, the reinforced concrete structure complete with inlet and
 outlet troughs, a sludge sump, and sludge withdrawal piping. Yard piping to and from the clarifier is not
 included in the above costs, but accounted for by the engineering cost factors.

 7.3.1.7       Sand Filtration
       A capital cost curve, as a function of flow rate, was developed for a sand filtration system using
 vendor supplied quotes. The cost curve used in this study was developed as part of the CWT effluent
 guidelines effort. The capital cost curve developed for sand filtration is presented as Equation 7-21.

       ln(Y) = 12.265 + 0.6581n(X) + 0.0361n(X)2                                     (7-21)
 where:
       X = Flow Rate (MOD), and
       Y = Capital Cost (1992$)

O&M costs for filter operation were estimated as 50 percent of the capital cost Figure 7-22 graphically
presents the sand filtration capital cost curve.
                                          7-44

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                           Figure 7-20
             Secondary Clarifier Capital Cost Curve
         A   WWC Cost
 1e+007 F
1000000
 100000
  10000
     0.001
                   ll
0.01
0.1
10
                             Flow (MGD)

-------
                         Figure 7-21
             Secondary Clarifier O&M Cost Curve
        A   WWC Cost
100000 r
 10000
  1000
    0.001
0.01
                                          I I ll
0.1
10
                           Flow (MGD)

-------
                              Figure 7-22
                  Sand Filtration Capital Cost Curve
            A   WWC Cost
   1000000 r
tt   100000
o
     10000
        0.001
                                              212t
0.01
   0.1

Flow (MGD)
10

-------
        The total capital costs for the sand filtration systems represent equipment and installation costs. The
 total construction cost includes the costs of the filter, instrumentation and controls, pumps, piping, and
 installation. The operation and maintenance costs include energy usage, maintenance, labor, taxes, and
 insurance.

 7.3.2         Sludge Treatment and Disposal

        The method of developing sludge treatment and disposal costs are presented in the following
 sections.

 7.3.2.1       Plate and Frame Pressure Filtration

        Regulatory costs for sludge dewatering were developed using cost curves from the CWT effluent
 guideline effort Costs are for a sludge dewatering system using a plate and frame pressure filter, and are
 based upon flow rate. Only facilities without installed sludge treatment were costed.
        The capital and O&M cost curves developed for a plate and frame filter press sludge dewatering
 are presented as Equations 7-22 and 7-23, respectively.

        ln(Y) = 15.022877 + 1.11992161n(X) + 0.0630011n(X)2                          (7-22)
        ln(Y) = 12.52046 + 0.7132331n(X) + 0.06670 lln(X)2                            (7-23)
 where:
        X = Flow (MOD), and
        Y = Cost (1992$)

        Figures 7-23 and 7-24 graphically present the plate and frame sludge dewatering capital and O&M
 cost curves, respectively. For facilities with a flow rate of less than 1,500 gallons per day, the O&M costs
 were estimated as 50 percent of the capital cost.
       The components of the plate and frame pressure filtration system include: filter plates, filter cloth,
hydraulic pumps, pneumatic booster pumps, control panel, connector pipes, and support platform.
                                          7-48

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                               Figure 7-23
                  Sludge Dewatering Capital Cost Curve
             A   WWC Cost
     1e+008 E
     1e+007
^ g  1000000
*> 8
      100000
      10000
          0.001
0.01
0.1
10
                                 Flow (MGD)

-------
    1000000
6, to  100000
<=> 6
      10000
                               Figure 7-24

                  Sludge Dewatering O&M Cost Curve
                 WWC Cost
                 42212
                   A
                  i I
          0.003   0.01
0.1
10
                                 Flow (MGD)

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Equipment and operational costs were obtained from manufacturers' recommendations. The capital cost
equation was developed by adding installation, engineering, and contingency costs to the vendors'
equipment costs. The O&M costs were based on estimated electricity usage, maintenance, labor, taxes
and insurance, and filter cake disposal costs. The labor requirement for the plate and frame pressure
filtration system was approximated at 30 minutes per cycle per filter press.

7.3.2.2       Filter Cake Disposal Costs

       Filter cake was costed for off-site disposal at a landfill. A facility's filter cake generation was
calculated using the difference between the facility's loadings and allowable effluent concentration. A
facility's total influent loading was calculated by taking the sum of the average metals and TSS
concentrations multiplied by the baseline flow. Effluent concentrations were developed similarly using the
LTAs for each option. Then, the sludge generation in the treatment system was calculated as the influent
loading minus the amount in effluent loading, converted to an annual amount (Ibs/yr). The amount of
treatment chemicals added to the system (based upon BPT/PSES option) was also included in the
calculation of sludge generation. The amount of total sludge generated in the treatment system was then
converted to a wet weight basis assuming 35 percent solids filter cake.  Off-site disposal costs were
estimated at $0.19/lb and was based upon the median cost reported by CHWC facilities in the
Questionnaire responses. This cost includes transportation, handling, conditioning, and disposal of the
cake. Costs are based upon a filter cake of 35 percent solids.

7.4          ADDITIONAL COSTS

       hi order to complete the costing for each regulatory option, costs other than treatment component
costs were developed.  These additional costs are required hi order to accommodate for other costs
associated with the development of the guideline. The following additional costs were included in the total
guideline option costs for each facility, as needed:
                                          7-51

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        •      retrofit
        •      monitoring
        •      RCRA permit modifications
        •      land costs

        Each of these additional costs are further discussed and defined in the following sections. Total
 facility compliance costs under each BPT/BCT/BAT and PSES option were developed by adding
 individual treatment technology costs with these additional costs.
        Final capital costs developed for each facility were then amortized using a 7 percent interest rate
 over 15 years. This annualized capital cost was then added to the annual O&M cost to develop a total
 annual cost for each guideline option.

 7.4.1         Retrofit and Upgrade Costs

       A retrofit cost factor was applied when additional equipment or processes were needed to be
 added to existing systems. Retrofit costs cover the need for system modifications and components, such
 as piping, valves, controls, etc., which are necessary in order to connect new treatment units and processes
 to an existing treatment facility. An upgrade cost factor was also applied to allow for existing treatment
 systems to be enhanced to provide sufficient treatment capability. The combined retrofit and upgrade cost
 factor was estimated at 25 percent of the installed capital cost of the equipment.

 7.4.2         Land Costs

       Land costs provide for the value of the land requirements needed for the installation of the
 BPT/BCT/BAT/PSES treatment technology. Land costs were estimated based upon the expected land
requirements for the new treatment units. Land size increments of either 0.5,1 or 2 acres were used
depending on the expected size of the required treatment system.
       Land costs vary greatly across the country depending upon the region and state. Therefore, a
national average would not be appropriate for costing purposes. State-specific unit land costs ($/acre)
                                           7-52

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were developed for each state. These state-specific unit land costs were based upon the average land
costs for suburban sites in each state and were obtained from the 1990 Guide to Industrial and Real Estate
Office Markets Survey. Costs were corrected to 1992 dollars using engineering cost factors.
       According to the survey, unimproved sites are the most desirable location for development and are
generally zoned for industrial usage.  State-specific unit land costs were developed by averaging the
reported unimproved site survey data for the various size ranges (zero to 10 acres, 10 to 100 acres, and
greater than 100 acres). Regional averages were used for states which did not have data provided. Hawaii
was not used in developing regional average costs, due to extremely high costs. Table 7-8 presents the
developed state-specific unit land costs used in costing. Facility land costs for this rule varied from $11,500
to $237,628.
7.4.3
RCRA Permit Modification Costs
       No cost associated with the modification of an existing RCRA Part B permit was included for any
hazardous waste facilities requiring an upgrade or additional treatment processes. The wastewater
treatment unit exemption (40 CFR 264.1 (g)(6), 40 CFR265.1(c)(10)) exempts waste water treatment units
that are subject to NPDES or pretreatment requirements under the Clean Water Act from certain RCRA
requirements, such as permitting modifications. Wastewater treatment units that are exempt from certain
RCRA requirements are defined in 40 CFR 260.10. Since all units costed under this rule fall under this
exemption, no costs were assumed to be associated for the CHWC Industry.
Table 7-8.    State Land Costs1
State
Alabama
Alaska2
Arizona
Arkansas
California
Colorado
Land Cost
(1992 $/acre)
24,595
87,593
49,790
17,170
325,000
47,045
State
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
Land Cost
(1992 $/acre)
26,659
39,204
57,238
96,598
29,083
118,814
                                          7-53

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State
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho2
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana2
Land Cost
(1992 $/acre)
58,570
58,806
68,335
78,408
1,176,120
87,593
39,204
22,764
9,670
7,605
31,363
61,158
21,170
121,532
64,687
14,740
22,738
14,113
43,124
87,593
State
North Carolina
North Dakota2
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island2
South Carolina
South Dakota2
Tennessee
Texas
Utah2
Vermont2
Virginia
Washington
West Virginia2
Wisconsin
Wyoming2
Washington, DC

Land Cost
(1992 $/acre)
36,590
22,127
15,744
26,267
54,886
34,892
64,608
23,000
22,127
22,543
51,488
87,593
64,608
43,124
68,764
51,133
18,818
87,593
188,179

(1)   Source: 1990 Guide to Industrial and Real Estate Office Markets Survey.
(2)   No data available for State, regional average used.
7.4.4
Monitoring Costs
       Costs were developed for the monitoring of treatment system effluent. Costs were developed for
both direct and indirect dischargers and were based upon the following assumptions:

       •      Monitoring costs are based on the number of outfalls through which wastewater is
              discharged. The costs associated with a single outfall is multiplied by the total number of
              outfalls to arrive at the total cost for a facility.  The estimated monitoring costs are
              incremental to the costs already incurred by the facility.
       •      The capital costs for flow monitoring equipment are included in the estimates.
                                            7-54

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       •      Sample collection costs (equipment and labor) and sample shipment costs are not included
              in the estimates because it is assumed that the facility is already conducting these activities
              as part of its current permit requirements.

       Based upon a review of current monitoring practices at CHWC facilities, many conventional and
non-conventional parameters, as well as metals, are already being monitored on a routine basis. Therefore,
monitoring costs were developed based upon daily monitoring of TSS and weekly monitoring of metals.
Qment compliance monitoring for existing facilities is generaUy less than me frequency used for estimating
the monitoring costs of this rule.  Table 7-9 presents the monitoring costs per sample type for the CHWC
Industry.

Table 7-9.    Analytical Monitoring Costs
Pollutants
TSS
Metals
Cost/Sample ($)'
6.00
40.00/metal
(1)   Cost based on 1998 analytical laboratory costs adjusted to 1992 dollars.

7.5           WASTEWATER OFF-SITE DISPOSAL COSTS

       An evaluation was conducted to determine whether it would be more cost effective for low flow
facilities to have their CHWC wastewaters hauled off-site and treated/disposed at a CWT facility, as
opposed to on-site wastewater treatment. Total annual costs for new or upgraded wastewater treatment
facilities were compared to the costs for off-site treatment at a CWT facility. Off-site disposal costs were
estimated at $0.25 per gallon of wastewater treated. Transportation costs were added to the off-site
treatment costs at a rate of $3.00 per loaded mile using an average distance of 250 miles to the treatment
facility.  Transportation costs were based upon the use of a 5,000 gallon tanker truck load. Facilities which
treat their wastewaters off-site are considered zero dischargers and hence would not incur ancillary costs
such as residual disposal, monitoring and land, except for permit modification costs. After review and
                                           7-55

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comparison of costs, EPA found off-site disposal costs to be cost prohibitive because it was more
expensive than on-site treatment. Therefore none of the eight facilities were costed for off-site disposal

7.6           COSTS FOR REGULATORY OPTIONS

       The following sections present the treatment costs for complying with the CHWC guideline for the
BPT/BCT/BAT, PSES, NSPS, and PSNS options.

7.6.1         BPT/BCT/BA T Costs

       One BPT/BCT/BAT option was selected based upon the treatment technology sampled at a
selected facility. Engineering costs for this BPT/BCT/BAT option is presented below.

7.6.1.1        BPT/BCT/BAT Option: Two-Stage Chemical Precipitation and Sand Filtration

       The BPT/BCT/BAT option consists of a two-stage chemical precipitation treatment system using
sodium hydroxide in the first precipitation stage with ferric chloride and sodium hydroxide in the second
stage. Sodium bisulfite is used at the head of the treatment system for hexavalent chromium removal. A
sand filter is provided at the end of the treatment system to polish the effluent Sludge dewatering is also
provided in this option. Table 7-10 presents the total capital and O&M costs for this option. This table
also presents the total amortized annual cost for each facility.

7.6.2        PSES Costs

       One PSES option was selected based upon the technology sampled at a selected facility.  This
PSES option is equivalent to the BPT/BCT/BAT option presented above. Engineering costs for this PSES
option is presented below.
                                         7-56

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7.6.2.1        PSES Option: Two-Stage Chemical Precipitation and Sand Filtration

       The PSES option consists of a two-stage chemical precipitation treatment system using sodium
hydroxide in the first precipitation stage with ferric chloride and sodium hydroxide in the second stage.
Sodium bisulfite is used at the head of the treatment system for hexavalent chromium removal. A sand filter
is provided at the end of the treatment system. Sludge dewatering is also provided in this option. This
PSES option is equivalentto the BPT/BCT/BAT option. Table 7-10 (previously referenced) presents the
total capital and O&M costs for this option. This table also presents the total amortized annual cost for
each facility.

7.6.3         New Source Performance Standards Costs

       The New Source Performance Standards (NSPS) for the CHWC Industry are equivalent to the
limitations for the BPT/BCT/BAT option. Therefore, NSPS consists of a two-stage chemical precipitation
treatment system using sodium hydroxide in the first precipitation stage with ferric chloride and sodium
hydroxide in the second stage. Sodium bisulfite is used at the head of the treatment system for hexavalent
chromium reduction. A sand filter is provided at the end of the treatment system to polish the effluent
Sludge dewatering is also provided in this option. NSPS costs were estimated using an industry average
flow rate of approximately 280,948 gpd and loadings similar to the representative BPT/BCT/BAT facility
(see Section 6). The total NSPS amortized annual cost is $550,248 assuming an average facility daily flow
of 280,948 gpd.  A breakdown of the NSPS capital and O&M costs are presented on Table 7-11.

7.6.4         Pretreatment Standards for New Sources Costs

       The Pretreatment Standards for New Sources (PSNS) for the CHWC Industry is equivalent to
the limitations for the PSES option. This option is also equivalent to the BPT/BCT/BAT option. Therefore,
PSNS consists of a two-stage chemical precipitation treatment system using sodium hydroxide in the first
precipitation stage with ferric chloride and sodium hydroxide in the second stage. Sodium bisulfite is used
                                          7-57

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Table 7-10.  Summary of Costs - BPT/BCT/BAT/PSES Final
ID*
5736
5737
5761
S765
5782
5797
5798
5720
TOTALS
AVERAGE
FLOWRATE
(gpd)
144.290
174,360
510.490
47.340
114,010
135,5(0
1,007,640
113.870
2,247.580
CA PITAL COSTS (S)
EQUIPMENT
611,635
0
880.521
757.143
496,348
528.301
874,679
1.183.603
5,332,230
RETROFIT*
UPGRADE
152.909
0
220.130
0
124,087
132,075
218,670
0
847,871
PERMIT
MODIFICATION
0
0
0
0
0
0
0
0
0
LAND
61.158
0
193.198
237.628
23.000
51,418
102,976
45,530
714.978
TOTAL
CAPITAL
825.701
0
1,293,849
994,771
643,435
711.164
1,196,325
1.229.133
6,895,079
AMORTIZED
TOTAL CAPITAL*
(S/YR)
90,658
0
142.058
109,221
70,646
78,159
131,350
134,952
757,043
O&MCOSTS(S/YR)
EQUIPMENT
140,834
0
178.681
184,273
100,143
104,742
244,830
285,533
1,239,035
SOLIDS
DISPOSAL
6.715
0
23,586
29,186
6,606
6,116
47,994
76,606
196,810
MONITORING
32,454
31,078
30,678
20,010
20,628
20.910
30,686
35.470
221,914
TOTAL
OftM
1 80,003
31,078
232.945
233,469
127.377
131.768
323,510
397.610
1,657,759
TOTAL
ANNUAL
COST (S/YR)
270,661
31,078
375,002
342.690
198,023
209,927
454.860
532,562
2,414,802
-J
oo
        * Assuming 7H interest over • fifteen year period.
        NOTE: Due lo tow flow, costs for 5037 and 5624 were ctfcuhted bised on olT-sile dapossl cost
Table 7-11.  Summary of Costs - NSPS/PSNS
TYPE
NSPS
PSNS
AVERAGE
FLOW RATE
(gpd)
280.948
280,948
CAPITALISTS (S)
EQUIPMENT
1,693,819
1.693.819
RETROFIT*
UPGRADE
0
0
PERMIT
MODIFICATION
0
0
LAND
149,176
149.176
TOTAL
CAPITAL
1.842.995
1.842.995
AMORTIZED
TOTALCAPITAL*
($/YR)
202,351
202.351
O&M COSTS ($/YR)
EQUIPMENT
298.300
298,300
SOLIDS
DISPOSAL
14,128
14.128
MONITORING
35.470
35.470
TOTAL
O&M
347,897
347,897
TOTAL
ANNUAL
COST($/YR)
550.248
550.248
        •A »iuming7%inlcrcll overs fifteen year period.

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at the head of the treatment system for hexavalent chromium reduction. Sludge dewatering is also provided
in this option. PSNS costs were estimated using an industry average flow rate of approximately 280,948
gpd and loadings similar to the representative BPT/BCT/BAT facility (see Section 6.0). The total PSNS
amortized annual cost is $550,248 assuming an average facility flow of 280,948 gpd.  A breakdown of
the PSNS capital and O&M costs are presented on Table 7-11, referenced above.
                                         7-59

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SECTION 8
DEVELOPMENT OF LIMITATIONS AND STANDARDS

       This section describes various waste treatment technologies and their costs, pollutants chosen for
regulation, and pollutant reductions associated with the different treatment technologies evaluated for the
final effluent limitations guidelines and standards for the Commercial Hazadous Waste Combustor (CHWC)
Industry.  The limitations and standards discussed in mis section are Best Practicable Control Technology
Currently Available (BPT), Best Conventional Pollutant Control Technology (BCT), Best Available
Technology Economically Achievable (BAT), New Source Performance Standards (NSPS), Pretreatment
Standards for Existing Sources (PSES), and Pretreatment Standards for New Sources (PSNS).
       For this rule, EPA has combined the presentation of the final regulatory option for direct and
indirect dischargers. EPA has combined these because there are no differences between direct and indirect
discharges with respect to the characteristics of wastewater generated or the model process technologies
considered to develop the final limitations and standards, as well as to prevent the disclosure of confidential
business  information.

8.1          ESTABLISHMENT OF BPT/BCT/BAT/PSES

       Generally, EPA bases BPT upon the average of the best current performance (in terms of pollutant
removals in treated effluent) by facilities of various sizes, ages, and unit processes within an industry
subcategory. The factors considered in establishing BPT include:  (1) the total cost of applying the
technology relative to pollutant reductions, (2) the age of process equipment and facilities, (3) the processes
employed and required process changes, (4) the engineering aspects of the control technology, (5) non-
water quality environmental impacts such as energy requirements, air pollution, and solid waste generation,
and (6) such other factors as the Administrator deems appropriate (Section 304(b)(2)(B) of the Act.) As
noted, BPT technology represents the average of the best existing performances of facilities within the
industry.  EPA looks at the performance of the best operated treatment systems and calculates limitations
from some level of average performance of these "best" facilities. For example, in the BPT limitations for
                                          8-1

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 the Oragnic Chemicals, Plastics, and Synthetic Fibers (OCPSF) Category, EPA identified "best" facilities
 on a BOD performance criteria of achieving a 95 percent BOD removal or a BOD effluent level of 40 mg/1
 (52 FR 42535, November 5,1987). When existing performance is uniformly inadequate, EPA may
 require a higher level of control than is currently in place in an industrial category if EPA determines that
 the technology can be practically applied.  BPT may be transferred from a different subcategory or
 category. However, BPT normally focuses on end-of-process treatment rather man process changes or
 internal controls, except when these technologies are common industry practice.
       The cost/effluent reduction inquiry for BPT is a limited balancing one, committed to EPA's
 discretion, that does not require the Agency to quantify effluent reduction benefits in monetary terms. (See,
 e.g., American Iron and Steel v. EPA, 526 F. 2d 1027 (3rd Cir., 1975.)) In balancing costs against the
 effluent reduction benefits, EPA considers the volume and nature of discharges expected after application
 of BPT, the general environmental effects of pollutants, and the cost and economic impacts of the required
 level of pollution control. In developing guidelines, the Act does not require or permit consideration of
 water quality problems attributable to particular point sources, or water quality improvements in particular
 bodies of water. Therefore, EPA has not considered these factors in developing the final limitations. (See
 Weyerhaeuser Company v. Costle. 590 F.  2d 1011 (D.C. Cir. 1978.))
       EPA set BAT effluent limitations for the CHWC Industry based upon the same technologies
 evaluated for BPT. The final BAT effluent limitations control identified priority and non-conventional
 pollutants discharged from facilities. EPA has not identified any more stringent treatment technology option
 which it considered to represent BAT level of control applicable to facilities in this industry.
       EPA considered and rejected zero discharge as possible BAT technology for the following reasons.
 EPA determined that combustors have two main options for achieving zero discharge — off-site disposal
 or on-site incineration. Facilities will likely choose off-site disposal where the cost of on-site incineration
 is greater than the cost of off-site disposal.  But off-site disposal ultimately results in some pollutant
 discharge to surface waters which will exceed the level achieved by BPT unless the limitations and
 standards applicable to the off-site treater are equivalent to this guideline.  EPA is concerned that adopting
a BAT zero discharge requirement may, in actuality, result in fewer effluent reductions than expected from
                                            8-2

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today's limitations and standards. The second option for zero discharge is on-site disposal/elimination. In
this case, a facility must either incinerate its scrubber water or replace its wet scrubbing system with a dry
scrubber. EPA has determined that on-site incineration would be more expensive than off-site disposal
and therefore would result in off-site treatment. Similarly, EPA believes, but cannot confirm, that the cost
of changing air pollution control systems is probably so high that a combustor would send its scrubber water
off-site for treatment. Moreover, even if the cost is not greater, EPA found that replacement of wet
scrubbing systems with dry scrubbers may result in an unstable solid (as opposed to the stable solids
generated in wastewater treatment systems) that must be disposed of in a landfill, with potentially adverse,
non-water quality effects. Consequently, EPA determined that zero discharge is not, in fact, the best
available technology. EPA is promulgating BAT limitations equal to the BPT limitations for the non-
conventional and priority pollutants covered under BPT.
       Section 307(b) requires EPA to promulgate pretreatment standards to prevent the introduction into
POTWs of pollutants that are not susceptible to treatment or which would interfere with the operation of
POTWs. EPA is establishing PSES for this industry to prevent pass through of the same pollutants
controlled by BAT from POTWs to waters of the U.S.
       EPA considered the same regulatory options as in the BPT analysis to reduce the discharge of
pollutants by CHWC facilities.  The Agency is proposing to adopt PSES pretreatment standards based
on the same technology as BAT.
       As discussed in Sections 2 and 6, EPA concluded that three of the facilities it surveyed are using
best practicable, currently available technology. Thus, the final BPT/BCT/BAT/PSES effluent limitations
are based on the data from three treatment systems.
       As pointed out previously, CHWC facilities burn highly variable wastes that, in many cases, are
process residuals and sludges from other point source categories. The wastewaterproduced in combustion
of these wastes contains a wide variety of metals. Chemical precipitation for these metals at a single pH
is not adequate treatment for metals removal from such a highly variable waste stream. EPA's review of
existing permit limitations for the direct dischargers show that, in most cases, the dischargers are subject
                                           8-3

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to "best professional judgment" (BPJ) concentration limitations which were developed from guidelines for
facilities treating and discharging much more specific waste streams (e.g. Metal Finishing limitations).
       Specifically, EPA has based the final BPT/BCT/BAT/PSES effluent limitations on data from the
CHWC facility used in the development of the proposed IWC limitations as well as data from two other
CHWC facilities that submitted sampling data to EPA (See 64 FR 26714, May 17,1999) following
proposal of the IWC rule. Based on a thorough analysis of the sampling data, EPA considered only one
option for the final BPT/BCT/BAT/PSES limitations. EPA concluded that a two-stage precipitation
process with or without a sand filtration polishing step provided the greatest overall pollutant removals at
a cost that is economically achievable at most CHWC facilities. Consequently, EPA has based the final
limitations on this treatment technology.
       In determining BPT/BCT/BAT/PSES, EPA evaluated metals precipitation as the principal treatment
practice within the CHWC Industry. Seven of the eight facilities in the CHWC Industry currently use some
type of metals precipitation as a means for waste treatment  The precipitation techniques used by facilities
varied in the treatment chemicals used and in the number of stages of precipitation used.
       The currently available  treatment system for which the EPA assessed performance for
BPT/BCT/BAT/PSES is:
•      Option  1  - Chromium Reduction (as necessary), Primary Precipitation, Solid-Liquid
       Separation, Secondary Precipitation,  Solid-Liquid Separation, with  (or -without)  Sand
       Filtration.  Under Option 1, BPT/BCT/BAT/PSES limitations and standards would be based
       upon two stages of chemical precipitation, each followed by some form of separation and sludge
       dewatering. The pHs used for the two stages of chemical precipitation would be different in order
       to promote optimal removal of metals because different metals are preferentially removed at
       different pH levels. In addition, the first stage of chemical precipitation is preceded by chromium
       reduction, when necessary. Also, sand filtration is used at the end of the treatment train, when
       necessary.  In some cases, BPT/BCT/BAT/PSES limitations and standards would require the
       current treatment technologies in place to be improved by use of increased quantities of treatment
       chemicals and additional chemical precipitation/sludge dewatering systems.
                                          8-4

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       The Agencyis promulgating BPT/BCT/BAT effluent limitations for 11 pollutants and PSES for 10
pollutants for the CHWC Industry.  These limitations and standards were developed based on an
engineering evaluation of the average level of pollutant reduction achieved through application of the best
practical control technology currently available for the discharges of the regulated pollutants. The daily
maximum and monthly average BPT/BCT/BAT limitations and PSES standards for the CHWC Industry
are presented in Tables 8-1 and 8-2, respectively. Long-term averages, daily variability factors and
monthly variability factors for the selected technology are also presented in Tables 8-1 and 8-2. A
combination of two different methodologies was used in the development of the variability factors (monthly
and daily). Specifically, pollutant-specific variability factors were calculated and used when a metal
pollutant was detected a sufficient number of times in the effluent sampling data. However, when a metal
pollutant could not be calculated using the effluent sampling data due to the feet that too few points were
detected above the minimum level, a group-level variability factor was used. The group-level variability
factor is the mean of the pollutant-level variability factors calculated for the entire group of metals found in
significant concentrations in the facility used to estimate variability for the CHWC Industry. These metals
are: aluminum, antimony, arsenic, boron, cadmium^ copper, iron, manganese, molybdenum, selenium,
titanium and zinc. The Statistical Support Document of Proposed Effluent Limitations Guidelines and
Standards for Industrial Waste Combustors (EPA 821-B-99-010) provides more detailed information
on the development of the limitations for this option.
Table 8-1.    BPT/BCT/BAT Effluent Limitations (ug/1)
Pollutant or
Pollutant
Parameter
Long-Term
Average
(ug/1)
Daily
Variability
Factor
(Rounded)
Monthly
Variability
Factor
(Rounded)
Maximum for
Any One Day
(ug/1)
Monthly
Average
(ug/1)
Conventional Pollutants
TSS
pH
27,200

4.2

1.3

113,000

34,800
(1)
Priority and Non-Conventional Pollutants
Arsenic
Cadmium
41.8
11.4
2.0
6.2
2.0
2.2
84
71
72
26
                                           8-5

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Pollutant or
Pollutant
Parameter
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
Long-Term
Average
(ug/1)
10
10.7
22.4
0.899
5.27
10.0
37.3
Daily
Variability
Factor
(Rounded)
2.5
2.2
2.5
2.5
2.5
6.0
2.2
Monthly
Variability
Factor
(Rounded)
1.5
1.3
1.5
1.5
1.5
2.2
1.5
Maximum for
Any One Day
(ug/1)
25
23
57
2.3
13
60
82
Monthly
Average
(ug/1)
14
14
32
1.3
8
22
54
 (l)Within the range 6.0 to 9.0 pH units.
Table 8-2.     PSES Pretreatment Standards (ug/1)
Pollutant or
Pollutant
Parameter
Long-Term
Average
(ug/1)
Daily
Variability
Factor
(Rounded)
Monthly
Variability
Factor
(Rounded)
Maximum for
Any One Day
(ug/1)
Monthly
Average
(ug/1)
Priority and Non-Conventional Pollutants
Arsenic
Cadmium
Chromium
Copper
Lead
Mercury
Silver
Titanium
Zinc
41.8
11.4
10
10.7
22.4
0.899
5.27
10.0
37.3
2.0
6.2
2.5
2.2
2.5
2.5
2.5
6.0
2.2
2.0
2.2
1.5
1.3
1.5
1.5
1.5
2.2
1.5
84
71
25
23
57
2.3
13
60
82
72
26
14
14
32
1.3
8
22
54
       EPA's decision to base BPT limitations on the selected treatment reflects primarily an evaluation
of three factors: the degree of effluent reduction attainable, the total cost of the proposed treatment
technologies in relation to the effluent reductions achieved, and potential non-water quality benefits. No
basis could be found for identifying different BPT limitations based on age, size, process or other
engineering factors. Neither the age northe size of the CHWC facility will significantly affect either the
                                            8-6

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character or treatability of the wastes or the cost of treatment. Further, the treatment process and
engineering aspects of the technologies considered have a relatively insignificant effect because in most
cases they represent fine tuning or add-ons to treatment technology already in use.  These factors
consequently did not weigh heavily hi the development of these guidelines.
       The Agency has concluded that this treatment system represents the best practicable technology
currently available and should be the basis for the BPT limitations for the following reasons. First, the
demonstrated effluent reductions attainable through this control technology represent performance that may
be achieved through the application of demonstrated treatment measures currently in operation in this
industry. Three facilities employing the identified BPT technology were used in the database to calculate
the effluent limitations. This database reflects technology and removals readily applicable to all facilities.
Second, the adoption of this level of control would represent a significant reduction in pollutants discharged
into the environment (approximately 94,000 pounds of TSS and metals). Third, the Agency assessed the
total cost of water pollution controls likely to be incurred, in relation to the effluent reduction benefits and
found those costs were reasonable. The pretax total estimated annualized cost in 1998 dollars is
approximately $2.9 million at the eight direct and indirect discharging facilities. EPA's assessment shows
that one of the eight CHWC facilities will experience a line closure as a result of the installation of the
necessary technology.
       EPA set BCT equivalent to the BPT guidelines for the conventional pollutants covered under BPT.
hi developing BCT limits, EPA considered whether there are technologies that achieve greater removals
of conventional pollutants than for BPT, and whether those technologies are cost-reasonable according to
the BCT Cost Test.  EPA identified no technologies that can achieve greater removals of conventional
pollutants than for BPT that are also cost-reasonable under the BCT Cost Test, and accordingly, EPA set
BCT effluent limitations equal to the BPT effluent limitations guidelines and pretreatment standards.

8.2           NSPS

       As previously noted, under Section 306 of the Act, new industrial direct dischargers must comply
with standards which reflect the greatest degree of effluent reduction achievable through application of the
                                           8-7

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best available demonstrated control technologies. Congress envisioned that new treatment systems could
meet tighter controls than existing sources because of the opportunity to incorporate the most efficient
processes and treatment systems into plant design. Therefore, Congress directed EPA to consider the best
demonstrated process changes, in-plant controls, operating methods and end-of-pipe treatment
technologies that reduce pollution to the maximum extent feasible.
       EPA proposed to establish NSPS equal to BPT/BCT/BAT for all conventional, non-conventional
and priority pollutants covered under BPT. EPA has decided that it should not promulgate NSPS based
on any more stringent technology.  EPA considered basing NSPS on zero discharge but has rejected this
technology. As explained above, EPA has concluded that zero discharge may not ultimately result in any
reduction in effluent discharges relative to BPT/BCT/BAT levels or it may have unacceptable non-water
quality effects.
       EPA is promulgating NSPS that would control the  same conventional, priority, and non-
conventional pollutants as the BPT effluent limitations. The technologies used to control pollutants at
existing facilities are fully applicable to new facilities. Therefore, EPA is promulgating NSPS limitations that
are identical to BPT/BCT/BAT/PSES.
       EPA considered the cost of the NSPS technology for new facilities. EPA concluded that such
costs are not so great as to present a barrier to entry, as demonstrated by the fact that currently operating
facilities are using these technologies. The Agency considered energy requirements and other non-water
quality environmental impacts and found no basis for any different standards than the selected NSPS.

8.3           PSNS

       Section 307(c) of the Act requires EPA to promulgate pretreatment standards for new sources
(PSNS) at the same time it promulgates new source performance standards (NSPS). New indirect
discharging facilities, like new direct discharging facilities, have the opportunity to incorporate the best
available demonstrated technologies, process changes, in-facility controls, and end-of-pipe treatment
technologies.
                                           8-8

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       As set forth in Section 5.3 of this document, EPA determined that all of the pollutants selected for
regulation for the CHWC Industry pass through POTWs. The same technologies discussed previously for
BPT, BCT, BAT, NSPS, and PSES are available as the basis for PSNS.
       EPA promulgated pretreatment standards for new sources equal to PSES for priority and non-
conventional pollutants. The Agency is establishing PSNS for the same priority and non-conventional
pollutants as for PSES. EPA considered the cost of the proposed PSNS technology for new facilities.
EPA concluded that such costs are not so great as to present a barrier to entry, as demonstrated by the
fact that currently operating facilities are using these technologies. The Agency considered energy
requirements and other non-water quality environmental impacts and found no basis for any different
standards than the selected PSNS.

8.4           COST OF TECHNOLOGY OPTIONS

       The Agency estimated the cost for CHWC facilities to achieve each of the proposed effluent
limitations and standards. All cost estimates in this section are presented in 1998 dollars. The cost
components reported in this section represent estimates of the investment cost of purchasing and installing
equipment, the annual operating and maintenance costs associated with that equipment and additional costs
for discharge monitoring.  The following sections present costs for BPT/PSES and BCT/BAT

8.4.1        BPT and PSES Costs

       The Agency estimated the cost of implementing the BPT/PSES effluent limitations guidelines and
pretreatment standards by calculating the engineering costs of meeting the required effluent limitations for
each direct and indirect discharging CHWC. This facility-specific engineering cost assessment for BPT
began with a review of present waste treatment technologies. For facilities without a treatment technology
in place equivalent to the BPT technology, the EPA estimated the cost to upgrade its treatment technology,
and to use additional treatment chemicals to achieve the new discharge standards. The only facilities given
no cost for compliance were facilities with the treatment in place prescribed for the option. Details
                                          8-9

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 pertaining to the development of the technology costs are included in Section 7. The capital expenditures
 for the process change component of BPT/PSES are estimated to be approximately $8.2 million with
 annual O&M costs of approximately $2.0 million for the eight CHWC facilities under the selected
 regulatory technology option.

 8.4.2         BCT and BA T Costs

       The Agency estimated that there would be no cost of compliance for implementing BCT or BAT,
 because the technology is identical to BPT and the costs are included with BPT.

 8.5           POLLUTANT REDUCTIONS
 8.5.1         Conventional Pollutant Reductions

       EPA has calculated how much the total quantity of conventional pollutants that are discharged
 would be reduced due to the adoption of the final BPT/BCT/BAT limitations. To do this, the Agency
 developed an estimate of the long-term average (LTA) loading of TSS that would be discharged after the
 implementation ofBPT. Next, the BPT/BCT/BAT LTA for TSS was multiplied by 1992 wastewater flows
 for each direct discharging facility in the industry to calculate BPT/BCT/BAT mass discharge loadings for
 TSS for each facility. The BPT/BCT/BAT mass discharge loadings were subtracted from the estimated
 current loadings to calculate the pollutant reductions for each facility. The Agency estimates that the final
 regulations will reduce TSS discharges by approximately 80,000 pounds per year for the CHWC facilities.
 The  current discharges and BPT/BCT/BAT discharges for TSS are listed in Table 8-3.

 8.5.2         Priority and Non-conventional Pollutant Reductions
 8.5.2.1        Methodology

       The proposed BPT, BCT, BAT and PSES will also reduce discharges of priority and non-
conventional pollutants. Applying the same methodology used to estimate conventional pollutant reductions

                                         8-10

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attributable to application of BPT/BCT/B AT control technology, EPA has also estimated priority and non-
conventional pollutant reductions for each facility.
       Current loadings were estimated using the questionnaire data supplied by the industry, data
collected by the Agency in the field sampling program, facility POTW permit information and facility
NPDES permit information. For many facilities, data were not available for all pollutants of concern or
without the addition of other non-CHWC wastewater. Therefore, methodologies were developed to
estimate current performance for the industry (see Section 4.4 of this document).
       In the construction of the plant-specific pollutant by pollutant loadings, in any case where the
technology option generated an estimated pollutant loading in excess of the current loading, the option
loading was set equal to the current loading.  The rationale for the adoption of this methodology is
consistency with and similarity to the "anti-backsliding" provisions. Also, a well designed and operated
treatment system shouldn't increase pollutant loadings above current practice. (It should be noted in the
situation described above, no removal of the specific pollutant at the specific plant is achieved under the
technology option).
8.5.2.2
Direct and Indirect Discharges (BPTVBCT/BAT) and (PSES)
       The Agency estimates that proposed BPT/BCT/BAT/PSES regulations will reduce direct and
indirect discharges of priority and non-conventional pollutants by approximately 13,400 pounds per year
for the eight CHWC facilities. The current discharges and BPT/BCT/BAT/PSES discharges forpriority
and non-conventional pollutants are listed in Table 8-3.
Table 8-3.    Direct and Indirect Discharge Loads (in Ibs.)
Pollutant Name
Total Suspended Solids
Aluminum
Antimony
CAS NO
C-009
7429905
7440360
Current Load
157,364
1,479
3,938
BPT/BCT/BAT/PSES
Option
76,898
1,003
2,126
                                          8-11

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Pollutant Name
Arsenic
Cadmium
Chromium
Copper
Iron
Lead
Mercury
Molybdenum
Selenium
Silver
Tin
Titanium
Zinc
Total
CAS NO
7440382
7440439
7440473
7440508
7439896
7439921
7439976
7439987
7782492
7440224
7440315
7440326
7440666

Current Load
776
379
5,721
1,276
964
837
32
1,600
197
195
484
348
1,361
176,950
BPT/BCT/BAT/PSES
Option
108
63
65
70
412
127
5
1,527
88
34
272
62
236
83,098
Note: One facility is projected to cease combustion operations while the facility will remain open (a line closure). The
      facility has been assigned 0 Ibs. in the option loads.
                                                   8-12

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SECTION 9
NON-WATER QUALITY IMPACTS

       Section 304(b) and 306 of the Clean Water Act require EPA to consider non-water quality
environmental impacts (including energy requirements) associated with effluent limitations and guidelines.
Pursuant to these requirements, EPA has considered the possible effect of the Commercial Hazardous
Waste Combustors (CHWC) BPT, BCT, BAT, NSPS, PSES, and PSNS regulations on air pollution,
solid waste generation, and energy consumption. In evaluating the environmental impacts across all media,
it has been determined that the impacts discussed below are minimal and are justified by the benefits
associated with compliance with the CHWC regulations.
       During CHWC wastewater treatment, the pollutants of concern are either removed from the
wastewater stream or concentrated.  If the pollutants are removed, they are either transferred from the
wastewater stream to another medium (e.g., VOC emissions to the atmosphere) or end up as a treatment
residual, such as sludge. Subsequent removal of pollutants to another media and the disposition of these
wastewater treatment residuals result in non-water quality impacts. Non-water quality impacts evaluated
for the CHWC Industry regulations include air pollution and solid waste generation.
       Wastewater treatment also results in other, non-water, non-residual, impacts. These impacts are
the consumption of energy used to  power the wastewater treatment equipment.

9.1           AIR POLLUTION

       CHWC facilities treat wastewater streams which contain very low concentrations of volatile organic
compounds (VOCs). These concentrations for most organic pollutants are typically below treatable levels.
This is due to the nearly total destruction of organic pollutants in the original wastes through the combustion
process, which prevents many of these pollutants from being detected in wastewaters and from being
released into the atmosphere and affecting air quality. Losses through fugitive emissions is not expected
to be significant as most of the organics present in the CHWC wastewater typically have a low volatility.
While the wastewater streams usually pass through collection units, cooling towers, and treatment units that
                                          9-1

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 are open to the atmosphere, this exposure is not expected to result in any significant volatilization of VOCs
 from the wastewater.
        Since there are no significant air emissions generated by the selected BPTYBCT/BAT treatment
 technologies, EPA believes that there are essentially no adverse air quality impacts anticipated as a result
 of the CHWC regulations.

 9.2           SOLID WASTE

        Several of the wastewater treatment technologies used to comply with the CHWC regulations
 generate a solid waste. The costs for disposal of these waste residuals were included in the compliance
 cost estimates prepared for the regulatory options.
       The solid waste treatment residual generated as a result of implementation of these regulations is
 filter cake from chemical precipitation processes. In the BPT/PSES wastewater treatment trains of the
 CHWC Industry, hydroxide and ferric chloride precipitation of metals generates a sludge residual.  For
 the BPT/BCT/BAT option, backwash from the sand filter is recirculated back to the treatment system prior
 to the chemical precipitation processes, therefore all solids are removed from the treatment process in the
 clarifiers.  This sludge is dewatered, and the resultant filter cake is typically disposed of off-site into a
 landfill. It is expected that the filter cake generated from chemical precipitation will contain high
 concentrations of metals. As a result, this filter cake may be a RCRA hazardous waste. Depending upon
 the wastewater usage and the resultant characteristics of the sludge, the sludge generated at a particular
 facility may be  either  a  listed or characteristic hazardous waste, pursuant to 40  CFR 261
 regulations (Identification and Listing of Hazardous Waste). These filter cakes are considered to be a
 characteristic hazardous waste based upon toxicity when the waste exceeds allowable standards based
 upon the Toxicity Characteristic Leaching Procedure or exhibits other hazardous characteristics as defined
 under 40 CFR 261 Subpart C (e.g., ignitability, corrosivity, or reactivity). Filter cake may also be
 considered a RCRA listed waste (e.g., wastes which are hazardous based upon definition as per 40 CFR
261 Subpart D) depending upon the types of wastewater produced by the combustion process and
whether it is in contact with the wastes being combusted or residuals from the combustion process. EPA
                                           9-2

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evaluated the cost of disposing hazardous and non-hazardous filter cake.  In the CHWC economic
evaluation, contract hauling for off-site disposal in a Subtitle C or D landfill was the method costed.
       It is estimated that compliance with the BPT/PSES option would result in the disposal of 1.035
million pounds of hazardous and non-hazardous filter cake.
       EPA believes that the disposal of this filter cake would not have an adverse effect on the
environment or result in the release of pollutants in the filter cake to other media. The disposal of these
wastes into controlled Subtitle D or C landfills are strictly regulated by the RCRA program. New landfills
are required to meet lining requirements to prevent the release of contaminants and to capture leachate.
Landfill capacity throughout the country can readily accommodate the additional solid waste expected to
be generated by the institution of this regulation.  For costing purposes, it was assumed that these solid
wastes would be considered hazardous and will be disposed of into permitted RCRA landfills with
appropriate treatment of these filter cakes prior to disposition to achieve compliance with applicable RCRA
land-ban treatment requirements (e.g., stabilization) pursuant with 40 CFR 268 regulations, if necessary.

9.3           ENERGY REQUIREMENTS

       In each of the regulatory options, operation of wastewater treatment equipment results in the
consumption of energy. This energy is used to power pumps, mixers, and other equipment components,
to power lighting and controls, and to generate heat The CHWC BPT/BCT/BAT option would require
the consumption of 1,672 thousand kilowatt-hours per year of electricity for both direct and indirect
dischargers. This is the equivalent of 937 barrels per year of #2 fuel oil, as compared with the 1992 rate
of consumption in the United States of40.6 million barrels per year. The BPT/BCT/BAT option represents
an increase in the production or importation of oil of 2.3 x 10s percent annually. Based upon this relatively
low increase in oil consumption, EPA believes that the implementation of this regulation would cause no
substantial impact to the oil industry.
       In 1992, approximately 2,797.2 billion kilowatt hours of electric power were generated in the
United States.  The additional energy consumption requirements for the BPT/BCT/BAT option
corresponds to approximately 5.9 x 10*7 percent of the national requirements. This increase in energy
                                           9-3

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requirements to implement the BPT/PSES technologies will result in an air emissions impact from electric
power generating facilities. It is expected that air emissions parameters generated by electric producing
facilities, such as particulates, NOX and SOj, will be impacted. This increase in air emissions is expected
to be directly proportional to the increase in energy requirements, or approximately 5.9 x 10"7percent
EPA believes this additional increase in air emissions from electric generating facilities to be minimal and
will result in no substantial impact to-air emissions or detrimental results to air quality.
                                            9-4

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          APPENDIX A
          LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte
ACETOPHENONE

ALUMINUM

AMENABLE CYANIDE

AMMONIA AS NITROGEN

ANTIMONY

ARSENIC

ATRAZINE

BARIUM
BENZOIC ACID
BERYLLIUM

BIS(2-ETHYLHEXYL)  PHTHALATE

BISHOTH

BOD 5-DAY (CARBONACEOUS)

BORON

BROHODICHLOROMETHANE
CADMIUM

CALCIUM

CARBON DISULFIDE

CERIUM

CHEMICAL OXYGEN DEMAND  (COD)

CHLORIDE

CHLOROFORM
CAS_NO
98862
7429905
C-025
7664417
7440360
7440382
1912249
7440393
65850
7440417
117817
7440699
C-002
7440428
75274
7440439
7440702
75150
7440451
C-004
16887006
67663
Min.
Level
10
200
20
10
20
10
10
200
50
5
10
100
2000
100
10
5
5000
10
1000
5000
1000
10
Number Number
of of
Obs . Detects
27
27
3
27
27
27
14
27 •
27
27
27
25
27
27
27
27
27
27
25
27
27
27
1
21
1
25
20
15
1
27
3
1
5
7
17
26
2
16
27
1
4
27
27
1
Mean
16.7
2924.8
610.0
9244.1
203.0
236.1
13.8
235.1
117041.1
0.9
20.7
164.1
491014.8
10920.4
12.4
273.7
181209.8
26.9
479.6
1206003.7
8331377.8
10.2
Min.
10.0
13.6
10.0
100.0
3.3
1.1
8.9
18.8
50.0
0.2
10.0
0.1
1000.0
20.0
10.0
1.2
5299.0
10.0
1.0
13000.0
40000.0
10.0
Max.
86.0
34800.0
1810.0
75000.0
958.8
1420.0
35.6
1158.8
3157556.0
1.5
86.0
887.0
10100000.0
182000.0
58.7
2616.0
1270000.0
466.6
1000.0
19100000.0
28300000.0
15.6
                                                      A-l

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APPENDIX A
LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte
CHROMIUM
COBALT
COPPER
DAIAPON
DIBENZOTHIOPHENE
DIBROMOCHLOROMETHANE
DICAMBA
DICHLORPROP
DINOSEB
DYSPROSIUM
ERBIUM
EUROPIUM
FLUORIDE
GADOLINIUM
GALLIUM
GERMANIUM
HAFNIUM
HEXANOIC ACID
HEXAVALENT CHROMIUM
HOLMIUM
INDIUM
IODINE
CAS_NO
7440473
7440484
7440508
75990
132650
124481
1918009
120365
88857
7429916
7440520
7440531
16984488
7440542
7440553
7440564
7440586
142621
18540299
7440600
7440746
7553562
Min.
Level
10
50
25
0
10
10
0
1
1
100
100
100
100
500
500
500
1000
10
10
500
1000
1000
Number Number
of of
Obs . Detects
27
27
27
11
27
27
11
11
11
25
25
25
27
25
25
25
25
27
17
25
25
20
22
13
26
3
1
2
2
5
2
1
1
4
27
3
2
1
1
2
4
3
4
6
Mean
222.7
21.7
1390.0
0.7
16.6
17.1
0.5
7.2
1.2
74.9
73.9
73.4
436669.2
209.1
224.2
367.7
468.6
23.1
18.2
365.0
489.4
4301.3
Min.
3.6
2.3
8.5
0.2
10.0
10.0
0.2
1.0
0.5
0.1
0.1
0.1
120.0
0.5
0.5
0.5
1.0
10.0
10.0
0.5
1.0
500.0
Max.
1650. 0
221.0
10554.0
1.8
86.0
115.5
1.8
47.0
4.5
100.0
100.0
100.0
7500000.0
500.0
500.0
500.0
1000.0
142.3
76.0
500.0
1000.0
20798.1
                           A-2

-------
APPENDIX A
LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte
IRIDIUM
IRON
ISOPHORONE
LANTHANUM
LEAD
LITHIUM
LOTKTIDM
MAGNESIUM
MANGANESE
MCPA
HCFP
MERCURY
METHYLENE CHLORIDE
MOLYBDENUM
MONOCROTOPHOS
N-DECANE
N-DOCOSANE
N-DODECANE
N-EICOSANE
N-HEXACOSANE
H-OCTACOSMIE
N-TETRADBCANE
CASJSO
7439885
7439896
78591
7439910
7439921
7439932
7439943
7439954
7439965
94746
7085190
7439976
75092
7439987
6923224
124185
629970
112403
112958
630013
630024
629594
Min.
Level
1000
100
10
100
50
100
100
5000
15
50
50
0
10
10
2
10
10
10
10
10
10
10
Number Number
of of
Obs . Detects
25
27
27
25
27
25
25
27
27
11
11
27
27
27
3
27
27
27
27
27
27
27.
7
27
1
2
18
12
2
27
27
4
4
19
2
19
1
1
1
1
1
2
2
1
Mean
539.7
6241.6
16.5
74.8
1609.7
177.5
72.3
18968.0
173.0
334.0
383.7
26.2
10.1
245.4
2.0
44.9
17.0
18.1
18.4
19.5
20.3
17.0
Min.
1.0
149.0
10.0
0.1
2.1
29.1
0.1
1080.0
4.0
50.0
50.0
0.1
10.0
4.0
2.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
Max.
1708.0
50600.0
86.0
100.0
13248.0
532.8
100.0
316000.0
1534.6
1980.0
2594.0
217.0
12.5
1024.4
2.0
780.0
86.0
86.0
86.0
92.9
95.7
86.0
                           A-3

-------
APPENDIX A
LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte
N-TRIACONTANE
NEODYMIUM
NICKEL
NIOBIUM
NITRATE/NITRITE
NORFLURAZON
OCDD
OCDF
OIL AND GREASE
OSMIUM
P-CRESOL
PHENOL
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
CAS_NO
€38666
7440008
7440020
7440031
C-OOS
27314132
3268879
39001020
C-036
7440042
106445
108952
7723140
7440064
7440097
7440100
7440155
7440166
7440188
7440199
7440202
7782492
Min.
Level
10
500
40
1000
50
1
0
0
5000
100
10
10
1000
1000
1000
1000
1000
1000
1000
500
100
5
Number Number
Of Of
Oba . Detects
27
25
27
25
27
14
27
27
24
25
27
27
20
25
20
25
25
25
25
25
25
27
2
7
19
7
27
1
11
7
3
1
1
3
18
4
19
3
5
3
4
4
4
17
Mean
17.3
214.4
166.6
482.7
3769.0
1.9
0.0
0.0
63875.0
75.2
425.5
4936.9
17222.9
488.5
112658.6
723.0
530.6
732.1
471.5
369.3
72.3
86.4
Min.
10.0
0.5
4.5
29.3
210.0
1.0
0.0
0.0
5000.0
0.1
10.0
10.0
204.7
1.0
478.6
1.0
19.4
1.0
1.0
0.5
0.1
0.5
Max.
86.0
500.0
872.0
1000.0
33280.0
8.9
0.0
0.0
1350000.0
100.0
11056.8
132818.0
225800.0
1000.0
805000.0
3910.0
1000.0
1000.0
1000.0
500.0
100.0
429.2
                           A-4

-------
          APPENDIX A
          LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte

SILICON

SILVER

SODIUM

STRONTIUM

SULFUR
TANTALUM

TERBIUM

THALLIUM

THORIUM

THULIUM

TIN

TITANIUM

TOTAL CYANIDE

TOTAL DISSOLVED SOLIDS

TOTAL ORGANIC CARBON (TOC)

TOTAL PHENOLS

TOTAL PHOSPHORUS

TOTAL SULFIDE (IODOMETRIC)

TOTAL SUSPENDED SOLIDS

TRIBROMOMETHANE

TRICHLOROFLUOROMETHANE

TUNGSTEN
CASJJO
7440213
7440224
7440235
744024S
7704349
7440257
7440279
7440280
7440291
7440304
7440315
7440326
57125
C-010
C-012
C-020
14265442
18496258
C-009
75252
75694
7440337
Min.
Level
100
10
5000
100
1000
500
500
10
1000
500
30
5
20
10
1000
50
10
1000
4000
10
10
1000
Number Number
of of
Obs . Detects
25
27
27
25
20
25
25
27
25
25
27
27
17
27
27
27
27
27
27
27
27
25
24
13
27
19
20
1
4
5
2
3
15
21
5
27
9
7
24
22
19
2
1
5
Mean
26447
72
7414026
650
11699602
364
370
8
477
362
451
638
202
23962622
179621
5525
1173
88296
112529
19
11
559
.4
.3
.5
.9
.3
.4
.7
.3
.5
.2
.3
.2
.3
.2
.5
.7
.3
.7
.6
.2
.1
.6
Min.
28
1
6400
32
2145
0
0
1
1
0
14
2
10
89000
1700
6
10
10
1000
10
10
93
.2
.0
.0
.7
.0
.5
.5
.2
.0
.5
.5
.2
.0
.0
.0
.0
.0
.0
.0
.0
.0
.2
Max.
340000.0
390.8
62400000.0
4190.0
174000000.0
500.0
500.0
20.2
1000.0
500.0
6046.0
4474.2
3160.0
185000000.0
4540000.0
146000.0
4520.0
1180000.0
522000.0
162.4
39.6
1000.0
                                                     A-5

-------
APPENDIX A
LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM
1234678-HFCDD
1234678 -HPCDF
123478-HXCDD
123478-HXCDF
1234789-HPCDF
123678-HXCDD
123678-HXCDF
12378-PECDD
12378-PECDF
123789-HXCDD
123789-HXCDF
2-BUTANONE
2-PROPANONE
2-PROPEN-l-OL
2,4-D
2,4-DB
CAS_NO
7440611
7440622
7440644
7440655
7440666
7440677
35822469
67562394
39227286
70648269
55673897
57653857
57117449
40321764
57117416
19408743
72918219
78933
67641
107186
94757
94826
Min.
Level
1000
50
100
5
20
100
0
0
0
0
0
0
0
0
0
0
0
50
50
10
1
2
Number Number
of of
Obs . Detects
25
27
25
27
27
25
27
27
27
27
27
27
27
27
27
27
27
27
27
27
11
11
11
16
1
4
27
5
7
9
1
4
3
1
4
1
2
2
1
1
4
2
2
1
Mean
4697.9
70.7
73.1
3.5
4482.3
152.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
73.3
56.8
15.8
2.5
4.6
Min.
10.1
1.7
0.1
0.4
44.7
0.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
49.9
49.9
10.0
1.0
2.0
Max.
67100.0
488.2
100.0
7.4
28569.0
1310.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
678.2
141.5
93.9
8.9
17.9
                           A-6

-------
APPENDIX A
LISTING OF CHWC ANALYTES WITH AT LEAST ONE DETECT
Analyte
2,4.5-T
2,4,5-TP
234678-HXODF
23478-PECDP
2378-TCDD
2378-TCDF
CASJJO
93765
93721
60851345
57117314
1746016
51207319
Min.
Level
0
0
0
0
0
0
Number Number
of of
Obs . Detects
11
11
27
27
27
27
1
2
5
3
1
4
Mean
0.5
0.5
0.0
0.0
0.0
0.0
Min.
0.2
0.2
0.0
0.0
0.0
0.0
Max.
1.8
1.8
0.0
0.0
0.0
0.0
                           A-7

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyse

           ACENAPHTHENE

           ACENAPHTHYLENE

           ACEPHATE

           ACIFLUORFEN

           ACRYLONITRILE

           ALACHLOR

           ALDRIN

           ALPHA-BHC

           ALPHA- CHLORDANE

           ALPHA-TERPINEOL

           ANILINE

           ANILINE,  2,4,5-TRIMETHYL-

           ANTHRACENE

           ARAMITE

           AZINPHOS ETHYL

           A2INPHOS METHYL

           BENFLURALIN

           BENZANTHRONE

           BENZENE

           BENZENETH-IOL

           BENZIDINE

           BENZO (A) ANTHRACENE
CAS_NO
83329
208968
30560191
50594666
107131
15972608
309002
319846
5103719
98555
62533
137177
120127
140578
2642719
86500
1861401
82053
71432
108985
92875
56553
Min.
Level
10
10
20
10
50
0
0
0
0
10
10
20
10
50
2
1
0
50
10
10
50
10
Number
of
Obs.
27
27
14
14
27
, 14
14
14
14
27
27
27
27
27
11
11
14
27
27
27
27
27
                                           B-l

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte
           BENZO {A) PYRENE
           BENZO (B) FLUORANTHENE
           BENZO(GHI)PERYLENE
           BENZO (K) FLUORANTHENE
           BENZONITRILE, 3, S-DIBROMO^-HYDROXY-
           BENZYL  ALCOHOL
           BETA-BHC
           BETA-NAPHTHYLAMINE
           BIPHENYL

           BIPHENYL, 4-NITRO
           BIS (2 -CHLOROETHOXY) METHANE
           BIS(2-CHLOROETHYL) ETHER
           BIS(2-CHLOROISOPROPYL)  ETHER
           BROMACIL
           BROMOMETHANE
           BROMOXYNIL OCTANOATE
           BUTACHLOR
           BDTYL BENZYL PHTHALATE
           CAPTAFOL
           CAPTAN
           CARBAZOLE
           CARBOPHENOTHION
CAS_NO
50328
205992
191242
207089
1689845
100516
319857
91598
92524
92933
111911
111444
108601
314409
74839
1689992
23184669
85687
2425061
133062
86748
786196
Min.
Level
10
10
20
10
50
10
0
50
10
10
10
10
10
1
50
1
1
10
2
1
20
1
Number
of
Obs.
27
27
27
27
27
27
14
27
27
27
27
27
27
14
27
14
14
27
14
14
27
14
                                             B-2

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte
           CHLORFENVINPHOS
           CHLOROACETONITRILE

           CHLOROBENZENE

           CHLOROBENZIIATE
           CHLOROETHANE
           CHLOROMETHANE
           CHLORONEB

           CHLOROPROPYLATE

           CHLOROTHALONIL

           CHLORPYRIFOS

           CHRYSENE
           CIS-PERMETHRIN

           CIS-1,3 -DICHLOROPROPENE
           COUMAPHOS

           CROTONALDEHYDE

           CROTOXYPHOS

           DACTHAL (DCPA)

           DEF
           DELTA-BHC

           DEMETON A
           DEMETON B
           DI-N-BUTYL PHTHALATE
CAS_NO
470906
107142
10S907
510156
75003
74873
2675776
5B36102
1897456
2921882
218019
61949766
10061015
56724
4170303
7700176
1861321
78488
319868
806S483A
8065483B
84742
Min.
Level
2
10
10
1
50
50
1
10
0
2
10
2
10
5
50
99
0
2
0
2
2
10
Number
of
Obs.
11
27
27
14
27
27
14
14
14
11
27
14
27
11
27
27
14
11
14
11
11
27
                                            B-3

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte

           DI-N-OCTYL PHTHALATE
           DI-N-PROPYLNITROSAMINE
           DIALLATE A
           DIALLATE B
           DIAZINON

           DIBENZO(A,H)ANTHRACENE
           DIBENZOFURAN
           DIBROMOMETHANE

           DICHLOFENTHION

           DICHLONE
           DICHLORVOS
           DICOFOL
           DICROTOPHOS
           DIELDRIN

           DIETHYL ETHER
           DIETHYL PHTHALATE
           DIMETHOATE

           DIMETHYL PHTHALATE
           DIMETHYL SULFONE
           DIOXATHION
           DIPHENYL ETHER
           DIPHENYLAMINE
CAS_NO
117840
621647
2303164A
2303164B
333415
53703
132649
74953
97176
117806
62737
115322
141662
60571
60297
84662
60515
131113
67710
78342
101848
122394
Min.
Level
10
20
2
2
2
20
10
10
2
2
5
1
5
0
50
10
1
10
10
5
10
10
Number
of
Obs.
27
27
14
14
11
27
27
27
11
14
11
14
3
14
27
27
11
27
27
3
27
27
                                            B-4

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte

           DIPHENYLDISULFIDE

           DISULFOTON

           ENDOSULFAN I

           ENDOSULFAN II

           ENDOSULFAN SULFATE

           ENDRIN

           ENDRIN ALDEHYDE

           ENDRIN KETONE

           EPN

           ETHALFLDRALIN

           ETHANE,  PENTACHLORO-

           ETHION

           ETHOPROP

           ETHYL CYANIDE

           ETHYL METHACRYLATE

           ETHYL METHANESULFONATE

           ETHYLBEN2ENE

           ETHYLENETHIOUREA

           ETRIDIA20LE

           FAMPHDR

           FENARIMOL

           FENSOLFOTHION
CAS_NO
882337
298044
959988
33213659
1031078
72208
7421934
53494705
2104645
55283686
76017
563122
13194484
107120
97632
62500
100414
96457
2593159
52857
60168889
115902
Min.
Level
20
2
0
1
0
0
0
0
2
0
20
2
2
10
10
20
10
20
0
5
0
5
Number
of
Obs.
27
11
14
14
14
14
14
14
11
14
27
11
11
27
27
27
27
27
6
11
14
11
                                           B-5

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte
           FENTHION
           FLUORANTHENE
           FLUORENE
           GAMMA-BHC
           GAMMA-CHLORDANE

           GOLD

           HEPTACHLOR
           HEPTACHLOR EPOXIDE
           HEXACHLOROBENZENE
           HEXACHLOROBUTADIENE
           HEXACHLOROCYCLOPEKTADIENE
           HEXACHLOROETHANE

           HEXACHLOROPROPENE
           HEXAMETHYLPHOSPHORAMIDE

           INDENO (1, 2, 3 -CD) PYREHE
           IODOMETHANE
           ISOBDTYL ALCOHOL
           ISODRIN
           ISOPROPALIN

           ISOSAFROLE

           KEPONE

           LEPTOPHOS
CAS_NO
55389
206440
86737
58899
5103742
7440575
76448
1024573
118741
87683
77474
67721
1888717
680319
193395
74884
78831
465736
33820530
120581
143500
21609905
Min.
Level
2
10
10
0
0
1000
0
0
10
10
10
10
20
2
20
10
10
0
0
10
1
2
Number
of
Obs.
11
27
27
14
14
25
14
14
27
27
27
27
27
3
27
27
27
14
14
27
14
11
                                            B-6

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte
           LONGIFOLENE

           M-XYLENE

           MALACHITE GREEN

           MALATHION

           MERPHOS

           MESTRANOL

           METHAPYRILENE
           METHOXYCHLOR

           METHYL CHLORPYRIFOS

           METHYL MBTHACRYLATE

           METHYL METHANESOLFONATE

           METHYL FARATHION

           METHYL TRITHION

           METRIBUZIN

           MEVINPHOS

           MIREX

           N-HEXAOECANE

           N-NITROSODI -N-BUTYLAMINE

           N-NITROSODIETHYLAMINE

           N-NITROSODIMETHYLAMINE

           N-NITROSODIPHENYLAMINE

           N-NITROSOMETHYLETHYLAMINE
CAS_NO
475207
106383
569642
121755
150505
72333
91B05
72435
5596130
60626
66273
298000
953173
21067649
7786347
2365855
544763
924163
55185
62759
86306
10595956
Min.
Level
50
10
10
2
2
20
10
0
2
10
20
2
5
0
5
0
10
10
10
50
20
10
Number
of
Obs.
27
27
27
11
8
27
27
14
11
27
27
11
3
14
11
14
27
27
27
27
27
27
                                            B-7

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte
           N-NITROSOMETHYLPHENYLAMINE
           N-NITROSOMORPHOLINE
           N-NITROSOPIPERIDINE
           N-OCTADECANE
           N-TETRACOSANE
           N, N-DIMETHYLFORMAMIDE
           HALED
           NAPHTHALENE
           NITROBENZENE
           NITROFEN
           O+P XYLENE
           O-ANISIDINE
           O-CRESOL
           O-TOLtJIDINE
           O-TOLUIDINE, 5-CHLORO-
           P-CHLOROANILINE
           P-CYMENE
           P-DIMETHYLAMINOAZOBENZENE

           P-NITROANILINE
           PALLADIUM
           PARATHION (ETHYL)
           PCB 1016
CASJJO
614006
59892
100754
593453
646311
68122
300765
91203
98953
1836755
136777612
90040
95487
95534
95794
106478
99876
60117
100016
7440053
56382
12674112
Min.
Level
99
10
10
10
10
10
8
10
10
0
10
10
10
10
10
10
10
20
SO
500
2
1
Number
of
Obs.
27
27
27
27
27
27
11
27
27
14
27
27
27
27
27
27
27
27
27
25
11
14
                                            B-8

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte

           PCS 1221
           PCB 1232

           PCS 1242

           PCB 1248
           PCB 1254

           PCB 1260
           PENDAMETHALIN
           PENTACHLOROBENZENE

           PENTACHLORONITROBENZENE (PCNB)

           PENTACHLOROPHENOL

           PENTAMETHYLBENZENE
           PERTHANE

           PERYLBNE
           PHENACETIN

           PHENANTHRENE

           PHENOL, 2-METHYL-4,6-DINITRO-
           PHENOTHIAZINE

           PHORATE
           PHOSMET
           PHOSPHAMIDON E
           PHOSPHAMIDON Z
           PICLORAM
CAS_NO
11104262
11141165
53469219
12672296
11097691
11096825
40487421
608935
82688
87865
700129
72560
198550
62442
85018
534521
92842
298022
732116
297994
23783984
1918021
Min.
Level
1
1
1
1
1
1
1
20
0
50
10
10
10
10
10
20
50
2
5
5
5
1
Number
of
Obs.
14
14
14
14
14
14
14
27
14
27
27
14
27
27
27
27
27
11
11
11
11
11
                                            B-9

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
Analyte
PRONAMIDE
PROPACHLOR
PROPANIL
PROPAZINE
PYRENE
PYRIDINE
RESORCINOL
RONNEL
SAFROLE
SIMAZINE
SQUALENE
STROBANE
STYRENE
SOLFOTEP
SULPROFOS
TELLURIUM
TEPP
TERBACIL
TERBUFOS
TERBOTHYLAZINE
TETRACHLOROETHENE
TETRACHLOROMETHANE
CASJJO
23950585
1918167
709988
139402
129000
110861
108463
299843
94597
122349
7683649
8001501
100425
3689245
35400432
13494809
107493
5902512
13071799
5915413
127184
56235
Min.
Level
10
0
1
1
10
10
50
2
10
8
99
5
10
2
2
1000
5
2
2
5
10
10
Number
of
Obs.
27
14
14
14
27
27
27
11
27
14
27
14
27
11
11
25
3
14
11
14
27
27
                           B-10

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte

           TETRACHLORVINPHOS

           THIANAPHTHENE

           THIOACETAMIDE

           THIOXANTHE-9-ONE

           TOKOTHION

           TOLUENE

           TOLUENE, 2,4-DIAMINO-

           TOTAL RECOVERABLE OIL AND GREASE

           TOXAPHENE

           TRANS- PERMETHRIN

           TRANS-1,2-DICHLOROETHENE

           TRANS-1,3-DICHLOROPROPENE

           TRANS-1,4 -DICHLORO- 2 -BUTENE

           TRIADIMEFON

           TRICHLORFON

           TRICHLOROETHENE

           TRICHLORONATE

           TRICRESYLPHOSPHATE

           TRIFLORALIN

           TRIMETHYLPHOSPHATE

           TRIPHENYLENE

           TRIPROPYLENEGLYCOL METHYL ETHER
CAS_NO
22248799
95158
62555
492228
34643464
108883
95807
C-007
8001352
61949777
156605
10061026
110576
43121433
52686
79016
327980
78308
1582098
512561
217594
20324338
Man.
Level
2
10
20
20
4
10
99
5000
5
2
10
10
50
1
5
10
2
10
0
2
10
99
Number
of
Obs.
11
27
27
27
3
27
27
3
14
14
27
27
27
14
11
27
11
11
14
3
27
27
                                            B-ll

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte

           VINYL ACETATE
           VINYL CHLORIDE
           l-BROMO-2-CHLOROBENZENE

           1 - BROMO- 3 - CHLOROBENZENE
           1-CHLORO-3-NITROBENZENE

           1-METHYLFLOORENE
           1-METHYLPHENANTHRENE

           1-NAPHTHYLAMINE

           1 - PHENYLNAPHTHALENE
           1,1-DICHLOROETHANE
           1,1-DICHLOROETHENE
           1,1,1-TRICHLOROETHANE

           1,1,1,2 -TETRACHLOROETHANE
           1,1,2-TRICHLOROETHANE
           1,1, 2,2-TETRACHLOROETHANE
           1,2-DIBROMO-3-CHLOROPROPANE

           1,2-DIBROMOETHANE

           1,2-DICHLOROBENZENE
           1,2-DICHLOROETHANE
           1,2-DICHLOROPROPANE
           1,2-DIPHENYLHYDRAZINE

           1,2,3-TRICHLOROBENZENE
CAS_NO
108054
75014
£94804
108372
121733
1730376
832699
134327
605027
75343
75354
71556
630206
79005
79345
96128
106934
95501
107062
78875
122667
87616
Min.
Level
50
10
10
10
50
10
10
10
10
10
10
10
10
10
10
20
10
10
10
10
20
10
Number
of
Obs.
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
                                             B-12

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Analyte
           1,2,3-TRICHLOROPROPANE
           1,2,3-TRIMETHOXYBENZENE
           1,2,4-TRICHLOROBENZENE
           1,2,4,5-TETRACHLOROBENZENE
           1,2:3,4-DIEPOXYBDTANE
           1,3-BUTADIENE,  2-CHLORO
           1, 3-DICHLORO-2-PROPANOL
           1,3-DICHLOROBENZENE

           1,3 -DICHLOROPROPANE
           1,3,5-TRITHIANE
           1,4 -DICHLOROBENZENE
           1, 4-DINITROBENZENE

           1,4-DIOXANE
           1,4-NAPHTHOQUINONE

           1,5-NAPHTHALENEDIAMINE
           2- (METHYLTHIO) BENZOTHIAZOLE
           2-CHLOROETHYLVINYL ETHER
           2-CHLORONAPHTHALENE

           2-CHLOROPHENOL
           2-HEXANONE

           2-ISOPROPYLNAPHTHALENE

           2 -METHYLBENZOTHIOAZOIiE
CAS_NO
96184
£34366
120821
95943
1464535
126998
96231
541731
142289
291214
106467
100254
123911
130154
2243621
615225
110758
91587
95578
591786
2027170
120752
Min.
Level
10
10
10
10
20
10
10
10
10
50
10
20
10
99
99
10
10
10
10
50
10
10
Number
of
Obs.
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
27
                                            B-13

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
AMI*.
a • MBTM Y 1 .NAPHTHALENE
a-MIT«OANILINB
a-NITROPHBNOL
,.,HBNYU^HTHALEN«
J HCOUNB
1-HimmM,
a-»KOl»BNBNITRIL«, 1-MBTHVL-
J.i HKN80PL.UOMNI
1, J-DlCHWmOAMILIHB
1, }-DICHIX9AONlTROBBN»NB
1,1,4, • -TETRACHIX>RO»H1NOL
V,I,«.TIIXOMMIIO»NINOL
»,4.DXCHLMQMIMO!,
3,4 01MBTHYL,PHKMOL
a,4 DINITROrHlMOL
3,4 DJNtTHOTOUJIMS
^4,|.TRieNbOMmmob
1 , 4 , 1 • TR I CHLOROmENOl,
l,l^|.TMT.Mim.»-MNnOUINOm
;,e.OieMl,ORO-4-NITROANILINE
1,I-DZCHLORO»HBNOL
J,»-D1NJTROTOLUBNB
CAtf.NO
I1I7«
• 1744
• •711
111141
10»0«U
107011
111117
341174
101171
laoeaai
IIIOl
•»7I»
110111
10H7I
Ollll
111141
IIII4
•loia
711111
11101
• 7110
toiaov
Min,
L»v«J
10
10
10
10
10
10
10
10
10
10
ao
10
10
10
•0
10
10
10
II
II
10
10
Number
of
Obf.
17
17
17
17
31
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
                           B-14

-------
APPENDIX B
LISTING OF CHWC ANALYTES WITH NO DETECTS
           Andyct
           l-CHLOHOPMOPINR
           )-MBTHYLCHOUANTHRBNK
           1-NITROANXLINI
           I,1'-DICHM)ROBBNIIDINB
           I,I'-DIMBTHOXyiBMCIDINR
           1,1-OIMITHV1<»H1NANTHRKNB
           4-AMINOIXMIBfYL
           4-iROMomnm. PHBMYI, ITHBR
           4-CHWRO-a-NITROANIUNS
           4 -CHLORO-i•MBTHYkPHBNOL
           4-CHlOROPHBNYLPHBNYt BTHBR
           4 • MBTHYL' 'i • PBNTANONR
           4-NITROPHBNOL
           4,4'-ODD
           4,4'-DD«
           4,4'-DDT
           4,4' -MBTMVLBNBBIB (1-CMLOROMIILIMBI
           4,1-MBTHYLBNB PHBNANTNRBHB
           I-NITRO-O-TOLUIDIW
           7,11 -DTMITMYliBBHt I A) ANTHKACBMB
CAiJIO
107011
14411
MOI1
M»4l
111104
1I7..7.
•1*71
iOllBI
111)4
11107
700171)
101101
100017
73MB
71111
•Oil)
101144
101141
• till
17174
Min
10
10
10
10
BO
10
10
10
10
10
10
BO
SO
0
0
0
10
10
10
10
Number
or
Ob*.
17
17
17
17
17
17
37
37
17
17
17
17
17
14
14
14
17
17
17
17
                                           B-15

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
ACENAPHTHENE
ACENAPHTHYLENE
ACEPHATE
ACETOPHENONE
ACIFLUORFEN
ACRYLONITRILE
AIACHLOR
ALDRIN
ALPHA-BHC
ALPHA-CHLORDANE
ALPHA-TERPINEOL
ALUMINUM
AMENABLE CYANIDE
AMMONIA AS NITROGEN
ANILINE
ANILINE, 2,4,5-
TRIMETHYL-
ANTHRACENE
ANTIMONY
ARAMITE
ARSENIC
ATRAZINE
AZINPHOS ETHYL
AZINPHOS METHYL
CAS_NO
83329
208968
30560191
98862
50594666
107131
15972608
309002
319846
5103719
98555
7429905
C-025
7664417
62533
137177
120127
7440360
140578
7440382
1912249
2642719
86500
Meas.
Type '
ND
ND
ND
NC
ND
ND
ND
ND
ND
ND
ND
NC
ND
NC
ND
ND
ND
NC
ND
NC
ND
ND
ND
Mean
14.83
14.83
30.53
15.47
15.27
50.00
0.31
0.31
0.08
0.15
14.83
897.59
10.00
14312.40
14.83
29.66
14.83
268.16
74.14
166.41
15.27
3.05
3.19
Min
10.00
10.00
20.00
10.00
10.00
49.94
0.20
0.20
0.05
0.10
10.00
13.60
10.00
100.00
10.00
20.00
10.00
7.80
50.00
4.60
10.00
2.00
1.00
Max
35.56
35.56
71.00
35.56
35.56
50.00
0.71
0.71
0.18
0.36
35.56
2538.00
10.00
75000.00
35.56
71.12
35.56
958.80
177.80
827.20
35.56
7.10
5.00
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
         Measurement type ND means that the pollutant was not detected at any data point
         Measurement type NC means that the pollutant was detected for at least one data point
                                            C-l

-------
 APPENDIX C

 Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
 EPA Sampling Episodes for all Analytes
Analyte

BARIUM

BENFLURALIN

BENZANTHRONE

BENZENE

BENZENETHIOL

BENZIDINE

BENZO (A) ANTHRACENE

BENZO (A) PYRENE

BENZO (B) FLUORANTHENE

BENZO (GHI) PERYLENE

BENZO (K) FLUORANTHENE

BENZOIC ACID

BENZONITRILE, 3,5-
DIBROMO-4 -HYDROXY-

BENZYL ALCOHOL

BERYLLIUM

BETA-BHC

BETA-NAPHTHYLAMINE

BIPHENYL

BIPHENYL, 4-NITRO

BIS (2 - CHLOROETHOXY)
METHANE

BIS(2-CHLOROETHYL)
ETHER

BIS (2-CHLOROISOPROPYL)
ETHER

BIS (2-ETHYLHEXYL)
PHTHALATE
CAS_NO
7440393
1861401
82053
71432
108985
92875
56553
50328
205992
191242
207089
65850
1689845
100516
7440417
319857
91598
92524
92933
111911
111444
108601
117817
Meas.
Type
NC
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NC
Mean
237.70
0.31
74.14
10.00
14.83
74.14
14.83
14.83
14.83
29.66
14.83
74.14
74.14
14.83
0.93
0.15
74.14
14.83
14.83
14.83
14.83
14.83
22.57
Min
43.10
0.20
50.00
9.99
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
50.00
10.00
0.30
0.10
50.00
10.00
10.00
10.00
10.00
10.00
10.00
Max
613.00
0.71
177.80
10.00
35.56
177.80
35.56
35.56
35.56
71.12
35.56
177.80
177.80
35.56
1.50
0.36
177.80
35.56
35.56
35.56
35.56
35.56
53.05
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                              C-2

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte

BISMUTH

BOO 5-DAY

BORON

BROMACIL

BROMODICHLOROMETHANE

BROMOMETHANE

BROMOXYNIL OCTANOATE

BUTACHLOR

BUTYL BENZYL PHTHALATE

CADMIUM

CALCIUM

CAPTAFOL

CAFTAN

CARBAZOLE

CARBON BISULFIDE

CARBOPHENOTHION

CERIUM

CHEMICAL OXYGEN DEMAND
(COD)

CHLORFENVINPHOS

CHLORIDE

CHLOROACETONITRILE

CHLOROBEKZENE

CHLOROBENZILATE
CAS_NO
7440699
C-002
7440428
314409
75274
74839
1689992
23184669
85687
7440439
7440702
2425061
133062
86748
75150
786196
7440451
C-004
470906
16887006
107142
108907
510156
Meas.
Type
NC
NC
NC
ND
NO
ND
ND
ND
ND
NC
NC
ND
ND
ND
ND
ND
NC
NC
ND
NC
ND
ND
ND
Mean
205.14
9960.00
1604.60
1.53
10.00
50.00
0.76
0.76
14.83
312.19
293146.00
3.05
1.53
29.66
10.00
1.53
507.47
343140.00
3.05
6833746.67
10.00
10.00
1.53
Min
0.10
1000.00
918.00
1.00
9.99
49.94
0.50
0.50
10.00
1.80
8140.00
2.00
1.00
20.00
9.99
1.00
1.00
67000.00
2.00
1010000.00
9.99
9.99
1.00
Max
887.00
53000.00
3760.00
3.56
10.00
50.00
1.78
1.78
35.56
2616.00
1270000.00
7.10
3.56
71.12
10.00
3.56
1000.00
1036000.00
7.10
17002400.00
10.00
10.00
3.56
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                             C-3

-------
 APPENDIX C

 Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
 EPA Sampling Episodes for all Analytes
Analyte

CHLOROETHANE

CHLOROFORM

CHLOROMETHANE

CHLORONEB

CHLOROPROPYLATE

CHLOROTHALONIL

CHLORPYRIFOS

CHROMIUM

CHRYSENE

CIS-PERMETHRIN

CIS-1, 3-DICHLOROPROPENE

COBALT

COPPER

COUMAPHOS

CROTONALDEHYDE

CROTOXYPHOS

DACTHAL (DCPA)

DALAPON

DEF

DELTA-BHC

DEMETON A

DEMETON B

DI-N-BUTYL PHTHALATE
CAS_NO
75003
67663
74873
2675776
5836102
1897456
2921882
7440473
218019
61949766
10061015
7440484
7440508
56724
4170303
7700176
1861321
75990
78488
319868
8065483A
8065483B
84742
Meas.
Type
ND
ND
ND
ND
ND
ND
ND
NC
ND
ND
ND
NC
NC
ND
ND
ND
ND
NC
ND
ND
ND
ND
ND
Mean
50.00
10.00
50.00
1.53
15.27
0.31
3.05
127.17
14.83
3.05
10.00
10.50
1786.69
7.64
50.00
146.80
0.08
0.53
3.05
0.08
3.05
3.05
14.83
Min
49.94
9.99
49.94
1.00
10.00
0.20
2.00
5.80
10.00
2.00
9.99
2.30
8.50
5.00
49.94
99.00
0.05
0.20
2.00
0.05
2.00
2.00
10.00
Max
50.00
10.00
50.00
3.56
35.56
0.71
7.10
529.20
35.56
7.10
10.00
35.24
10554.00
17.78
50.00
352.04
0.18
1.06
7.10
0.18
7.10
7.10
35.56
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                             C-4

-------
 APPENDIX C

 Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
 EPA Sampling Episodes for all Analytes
 Analyte

 DI-N-OCTYL PHTHALATE

 DI-N-PROPYLNITROSAMINE

 DIALLATE A

 DIALLATE B

 DIAZINON

 DIBENZO (A, H) ANTHRACENE

 DIBENZOFURAN

 DIBENZOTHIOPHENE

 DIBROMOCHLOROMETHANE

 DIBROMOMETHANE

 DICAMBA

 DICHLOFEKTHION

 DICHLONE

 DICHLORPROP

 DICHLORVOS

 DICOFOL

 DICROTOPHOS

 DIELDRIN

 DIETHYL ETHER

 DIETHYL PHTHALATE

DIMETHOATE

DIMETHYL PHTHALATE

DIMETHYL SULFONE
CAS_NO
117840
621647
2303164A
2303164B
333415
53703
132649
132650
124481
74953
1918009
97176
117806
120365
62737
115322
141662
60571
60297
84662
60515
131113
67710
Meas.
Type
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NC
ND
ND
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mean
14.83
29.66
3.05
3.05
3.05
29.66
14.83
14.83
10.00
10.00
0.32
3.05
3.05
7.66
7.64
1.S3
5.00
0.06
50.00
14.83
1.86
14.83
14.83
Min
10.00
20.00
2.00
2.00
2.00
20.00
10.00
10.00
9.99
9.99
0.20
2.00
2.00
1.00
5.00
1.00
5.00
0.04
49.94
10.00
1.00
10.00
10.00
Max
35.56
71.12
7.10
7.10
7.10
71.12
35.56
35.56
10.00
10.00
0.71
7.10
7.10
47.00
17.78
3.56
5.00
0.14
50.00
35.56
3.56
35.56
35.56
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                             C-5

-------
 APPENDIX C

 Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
 EPA Sampling Episodes for all Analytes
Analyte

DINOSEB

DIOXATHION

DIPHENYL ETHER

DIPHENY1AMINE

DIPHENYLDISOLFIDE

DISULFOTON

DYSPROSIUM

ENDOSULFAN I

ENDOSULFAN II

ENDOSULFAN SDLFATE

ENDRIN

ENDRIN ALDEHYDE

ENDRIN KETONE

EPN

ERBIUM

ETHALFLURALIN

ETHANE, PENTACHLORO-

ETHION

ETHOPROP

ETHYL CYANIDE

ETHYL METHACRYLATE

ETHYL METHANESULPONATE

ETHYLBENZENE
CAS_NO
88857
78342
101848
122394
882337
298044
7429916
959988
33213659
1031078
72208
7421934
53494705
2104645
7440520
55283686
76017
563122
13194484
107120
97632
62500
100414
Meas.
Type
NC
ND
ND
ND
ND
ND
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mean
0.87
5.00
14.83
14.83
29.66
3.05
67.17
0.15
1.53
0.15
0.31
0.15
0.15
3.05
66.70
0.15
29.66
3.05
3.05
10.00
10.00
29.66
10.00
Min
0.50
5.00
10.00
10.00
20.00
2.00
0.10
0.10
1.00
0.10
0.20
0.10
0.10
2.00
0.10
0.10
20.00
2.00
2.00
9.99
9.99
20.00
9.99
Max
2.63
5.00
35.56
35.56
71.12
7.10
100.00
0.36
3.56
0.36
0.71
0.36
0.36
7.10
100.00
0.36
71.12
7.10
7.10
10.00
10.00
71.12
10.00
Unit
DG/L
UG/L
OG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                             C-6

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
ETHYLENETHIOUREA
ETRIDIAZOLE
EUROPIUM
FAMPHUR
FENARIMOL
FENSDLFOTHION
FENTHION
FLUORANTHENE
FLOORENE
FLUORIDE
GADOLINIUM
GALLIUM
GAMMA-BHC
GAMMA-CHLORDANE
GERMANIUM
GOLD
HAFNIUM
HEPTACHLOR
HEPTACHLOR EPOXIDE
HEXACHLOROBENZENE
HEXACHLOROBOTADIENE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
CAS_NO
96457
2593159
7440531
52857
60168889
115902
55389
206440
86737
16984488
7440542
7440553
58899
5103742
7440564
7440575
7440586
76448
1024573
118741
87683
77474
67721
Meas.
Type
ND
ND
NC
ND
ND
ND
ND
ND
ND
NC
NC
NC
ND
ND
NC
ND
NC
ND
ND
ND
ND
ND
ND
Mean
29.66
0.10
68.07
7.64
0.31
7.64
3.05
14.83
14.83
82620.53
236.22
236.12
0.08
0.08
335.79
100.33
500.92
0.15
0.08
14.83
14.83
14.83
14.83
Min
20.00
0.10
0.10
5.00
0.20
5.00
2.00
10.00
10.00
16500.00
0.50
0.50
0.05
0.05
0.50
1.00
1.00
0.10
0.05
10.00
10.00
10.00
10.00
Max
71.12
0.10
100.00
17.78
0.71
17.78
7.10
35.56
35.56
360000.00
500.00
500.00
0.18
0.18
500.00
200.00
1000.00
0.36
0.18
35.56
35.56
35.56
35.56
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                     C-7

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
HEXACHLOROPROPENE
HEXAMETHYLPHOSPHORAMIDE
HEXANOIC ACID
HEXAVALEKT CHROMIUM
HOLMIUM
INDENO (1 , 2 , 3-CD) PYRENE
INDIDM
IODINE
IODOMETHANE
IRIDIUM
IRON
ISOBDTYL ALCOHOL
ISODRIN
ISOPHORONE
ISOPROPALIN
ISOSAFROLE
KEPONE
LANTHANUM
LEAD
LEPTOPHOS
LITHIUM
LONGIFOLENE
LUTETIUM
CAS_NO
1888717
£80319
142621
18540299
7440600
193395
7440746
7553562
74884
7439885
7439896
78831
465736
78591
33820530
120581
143500
7439910
7439921
21609905
7439932
475207
7439943
Meas.
Type
ND
ND
ND
NC
NC
ND
NC
NC
ND
NC
NC
ND
ND
ND
ND
ND
ND
NC
NC
ND
NC
ND
NC
Mean
29.66
2.00
14.83
18.67
336.78
29.66
512.02
1943.00
10.00
609.97
2904.13
10.00
0.15
14.83
0.31
14.83
1.53
68.18
1613.89
3.05
231.26
74.14
66.78
Min
20.00
2.00
10.00
10.00
0.50
20.00
1.00
500.00
9.99
1.00
149.00
9.99
0.10
10.00
0.20
10.00
1.00
0.10
2.10
2.00
79.00
50.00
0.10
Max
71.12
2.00
35.56
76.00
500.00
71.12
1000.00
3840.00
10.00
1708.00
10838.00
10.00
0.36
35.56
0.71
35.56
3.56
100.00
13248.00
7.10
532.80
177.80
100.00
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                    C-8

-------
 APPENDIX C

 Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
 EPA Sampling Episodes for all Analytes
Analyte

M-XYLENE

MAGNESIUM

MALACHITE GREEN

MALATHION

MANGANESE

MCPA

MCPP

MERCURY

MERPHOS

MESTRANOL

METHAPYRILENE

METHOXYCHLOR

METHYL  CHLORPYRIFOS

METHYL  METHACRYLATE

METHYL  METHANESDLFONATE

METHYL  PARATHION

METHYL  TRITHION

METHYLENE CHLORIDE

METRIBUZIN

MEVINPHOS

MIREX

MOLYBDENUM

MONOCROTOPHOS
CAS_NO
108383
7439954
569642
121755
7439965
94746
7085190
7439976
150505
72333
91805
72435
5598130
80626
66273
298000
953173
75092
21087649
7786347
2385855
7439987
6923224
Meas.
Type
ND
NC
ND
ND
NC
NC
NC
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NC
NC
Mean
10.00
7435.80
14.83
3.05
114.72
115.60
375.68
21.06
3.58
29.66
14.83
0.31
3.05
10.00
29.66
3.05
5.00
10.00
0.15
7.64
0.31
. 336.68
2.00
Min
9.99
1140.00
10.00
2.00
4.00
50.00
50.00
0.20
2.00
20.00
10.00
0.20
2.00
9.99
20.00
2.00
5.00
9.99
0.10
5.00
0.20
4.60
2.00
Max
10.00
20400.00
35.56
7.10
388.00
399.20
2594.00
115 . 36
7.10
71.12
35.56
0.71
7.10
10.00
71.12
7.10
5.00
10.00
0.36
17.78
0.71
1024.40
2.00
Unit
UG/L
UG/L
UG/L
UG/L
0G/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                             C-9

-------
 APPENDIX C

 Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
 EPA Sampling Episodes for all Analytes
 Analyte

 N-DECANE

 N-DOCOSANE

 N-DODECANE

 N-EICOSANE

 N-HEXACOSANE

 N-HEXADECANE

 N-NITROSODI-N-BUTYLAMINE

 N-NITROSODIETHYLAMINE

 N-NITROSODIMETHYLAMINE

 N-NITROSODIPHENYLAMINE

 N-NITROSOMETHYLETHYLAMINE

 N-NITROSOMETHYLPHENYLAMINE

 N-NITROSOMORPHOLINE

 N-NITROSOPIPERIDINE

 N-OCTACOSANE

 N-OCTADECANE

 N-TETRACOSANE

 N-TETRADECANE

 N-TRIACONTANE

 N, N-DIMETHYLFORMAMIDE

 HALED

NAPHTHALENE

NEODYMIUM
CAS_NO
124185
629970
112403
112958
630013
544763
924163
55185
62759
86306
10595956
614006
59892
100754
630024
593453
646311
629594
638686
68122
300765
91203
7440008
Meas.
Type
ND
ND
ND
ND
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
NC
ND
ND
ND
NC
ND
ND
ND
NC
Mean
14.83
14.83
14.83
14.83
20.41
14.83
14.83
14.83
74.14
29.66
14.83
146.80
14.83
14.83
21.81
14.83
14.83
14.83
16.53
14.83
8.64
14.83
246.75
Min
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
5.00
10.00
0.50
Max
35.56
35.56
35.56
35.56
92.91
35.56
35.56
35.56
177.80
71.12
35.56
352.04
35.56
35.56
95.71
35.56
35.56
35.56
46.21
35.56
17.78
35.56
500.00
Unit
OG/L
DG/L
UG/L
DG/L
DG/L
UG/L
UG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
UG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
UG/L
                                             C-10

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
NICKEL
NIOBIUM
NITRATE/NITRITE
NITROBENZENE
NITROPEN
NORFLURAZON
0+P XYLENE
0-ANISIDINE
0-CRESOL
0-TOLUIDINE
O-TOL0IDINE, 5-CHLORO-
OCDD
OCDF
OIL AND GREASE
OSMIUM
P-CHLOROANILINE
P-CRESOL
P-CYMENE
CAS_NO
7440020
7440031
C-005
98953
1836755
27314132
136777612
90040
95487
95534
95794
3268879
39001020
C-036
7440042
106478
106445
99876
P-DIMETHYLAMINOAZOBENZENE 60117
P-NITROANILINE
PALLADIUM
PARATHION (ETHYL)
PCS 1016
100016
7440053
56382
12674112
Meas.
Type
NC
NC
NC
NO
ND
NC
ND
ND
ND
ND
ND
NC
NC
NC
NC
ND
ND
ND
ND
ND
ND
ND
ND
Mean
134.26
525.87
2650.93
14.83
0.31
1.59
10.00
14.83
14.83
14.83
14.83
0.00
0.00
5066.67
67.19
14.83
14.83
14.83
29.66
74.14
333.50
3.05
1.53
Min
4.50
29.25
360.00
10.00
0.20
1.00
9.99
10.00
10.00
10.00
10.00
0.00
0.00
5000.00
0.10
10.00
10.00
10.00
20.00
50.00
0.50
2.00
1.00
Max
327.00
1000.00
4560.00
35.56
0.71
4.08
10.00
35.56
35.56
35.56
35.56
0.00
0.00
6000.00
100.00
35.56
35.56
35.56
71.12
177.80
500.00
7.10
3.56
Unit
UG/L
0G/L
OG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                    C-ll

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
PCS 1221
PCS 1232
PCB 1242
PCB 1248
PCS 1254
PCB 1260
PENDAMETHALIN
PENTACHLOROBENZENE
PENTACHLORONITROBENZENE
(PCNB)
PENTACHLOROPHENOL
PENTAMETHYLBENZENE
PERTHANE
PERYLENE
PHENACETIN
PHENANTHRENE
PHENOL
PHENOL, 2-METHYL-4,6-
DINITRO-
PHENOTHIAZINE
PHORATE
PHOSMET
PHOSPHAMIDON E
PHOSPHAMIDON Z
PHOSPHORUS
CAS_NO
11104282
1141165
53469219
12672296
11097691
11096825
40487421
608935
82688
87865
700129
72560
198550
62442
85018
108952
534521
92842
298022
732116
297994
23783984
7723140
Meas.
Type
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NC
ND
ND
ND
ND
ND
ND
NC
Mean
1.53
1.53
1.53
1.53
1.53
1.53
0.76
29.66
0.08
74.14
14.83
15.27
14.83
14.83
14.83
17.11
29.66
74.14
3.05
7.64
7.64
7.64
32480.80
Min
1.00
1.00
1.00
1.00
1.00
1.00
0.50
20.00
O.OS
50.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
50.00
2.00
5.00
5.00
5.00
3210.00
Max
3.56
3.56
3.56
3.56
3.56
3.56
1.78
71.12
0.18
177.80
35.56
35.56
35.56
35.56
35.56
44.16
71.12
177.80
7.10
17.78
17.78
17.78
225800.00
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                    C-12

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
PICLORAM
PLATINUM
POTASSIUM
PRASEODYMIUM
PRONAMIDE
PROPACHLOR
PROPANIL
PROPAZINE
PYRENE
PYRIDINE
RBSORCINOL
RHENIUM
RHODIUM
RONNEL
RUTHENIUM
SAFROLE
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SIMAZINE
SODIUM
CAS_NO
1918021
7440064
7440097
7440100
23950585
1918167
709988
139402
129000
110861
108463
7440155
7440166
299843
7440188
94597
7440199
7440202
7782492
7440213
7440224
122349
7440235
Meas.
Type
ND
NC
NC
NC
ND
ND
ND
ND
ND
ND
ND
NC
NC
ND
NC
ND
NC
NC
NC
NC
NC
ND
NC
Mean
0.76
528.11
77743.00
927.87
14.83
0.15
1.53
1.53
14.83
14.83
74.14
615.13
670.22
3.05
504.65
14.83
336.92
66.75
102.82
15414.00
98.92
12.22
3443333.33
Min
0.50
1.00
1310.00
1.00
10.00
0.10
1.00
1.00
10.00
10.00
50.00
205.00
1.00
2.00
1.00
10.00
0.50
0.10
2.30
5380.00
1.00
8.00
6400.00
Max
1.78
1000.00
195400.00
3910.00
35.56
0.36
3.56
3.56
35.56
35.56
177.80
1000.00
1000.00
7.10
1000.00
35.56
500.00
100.00
429.20
28100.00
390.80
28.46
11250600.00
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
OG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                    C-13

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
SQUALENE
STROBANE
STRONTIUM
STYRENE
SDLFOTEP
SULFUR
SULPROFOS
TANTALUM
TELLURIUM
TEPP
TERBACIL
TERBIUM
TERBUFOS
TERBUTHYLAZINE
TETRACHLOROETHENE
TETRACHLOROMETHANE
TETRACHLORVINPHOS
THALLIUM
THIANAPHTHENE
THIOACETAMIDE
THIOXANTHE-9-ONE
THORIUM
THULIUM
CAS_NO
7683649
8001501
7440246
100425
3689245
7704349
35400432
7440257
13494809
107493
5902512
7440279
13071799
5915413
127184
56235
22248799
7440280
95158
62555
492228
7440291
7440304
Meas.
Type
ND
ND
NC
ND
ND
NC
ND
NC
ND
ND
ND
NC
ND
ND
ND
ND
ND
NC
ND
ND
ND
NC
NC
Mean
146.80
7.64
630.23
14.83
4.05
400788.06
3.05
333.89
667.00
5.00
3.05
342.22
3.05
7.64
10.00
10.00
3.05
9.19
14.83
29.66
29.66
512.90
333.98
Min
99.00
5.00
100.00
10.00
2.00
2145.00
2.00
0.50
1.00
5.00
2.00
0.50
2.00
5.00
9.99
9.99
2.00
1.20
10.00
20.00
20.00
1.00
0.50
Max
352.04
17.78
2280.00
35.56
7.10
1078240.00
7.10
500.00
1000.00
5.00
7.10
500.00
7.10
17.78
10.00
10.00
7.10
20.00
35.56
71.12
71.12
1000.00
500.00
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                    C-14

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte

TIN

TITANIUM

TOKUTHIOH

TOLUENE

TOLUENE,  2,4-DIAMINO-

TOTAL CYANIDE

TOTAL DISSOLVED SOLIDS

TOTAL ORGANIC CARBON  (TOO C-012

TOTAL PHENOLS

TOTAL PHOSPHORUS

TOTAL SULFIDE(IODOMETRIC) 18496258

TOTAL SUSPENDED SOLIDS

TOXAPHENE

TRANS-PERMETHRIN

TRANS-1,2-DICHLOROETHENE  156605

TRANS-1,3-DICHLOROPROPENE 10061026

TRANS-l,4-DICHLORO-2-BUTENE 110576

TRIADIHEFON

TRIBROMOMETHANE

TRICHLORFON

TRICHLOROETHENE

TRICHLOROFLUOROMETHANE

TRICHLORONATE
CAS_NO
7440315
7440326
34643464
108883
95807
57125
C-010
C-012
C-020
14265442
18496258
C-009
8001352
61949777
156605
10061026
IE 110576
43121433
75252
52686
79016
75694
327980
Meas.
Type
NC
NC
ND
ND
ND
NC
NC
NC
NC
NC
NC
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mean
665.88
777.71
2.00
10.00
146.80
17.93
12815853.33
10485.33
93.20
1088.60
28261.33
122553.33
7.64
3.05
10.00
10.00
50.00
1.53
10.00
7.64
10.00
10.00
3.05
Min
14.50
5.00
2.00
9.99
99.00
10.00
158000.00
10000.00
50.00
10.00
1000.00
4000.00
5.00
2.00
9.99
9.99
49.94
1.00
9.99
5.00
9.99
10.00
2.00
Max
6046.00
4474.20
2.00
10.00
352.04
105.00
32641200.00
16000.00
681.00
4460.00
103200.00
522000.00
17.78
7.10
10.00
10.00
50.00
3.56
10.00
17.78
10.00
10.00
7.10
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                              C-15

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
TRICRESYLPHOSPHATE
TRIFLURALIN
TRIMETHYLPHOS PHATE
TRIPHENYLENE
TRIPROPYLENEGLYCOL METHYL
ETHER
TUNGSTEN
URANIUM
VANADIUM
VINYL ACETATE
VINYL CHLORIDE
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM
l-BROMO-2-CHLOROBENZENE
1 - BROMO- 3 - CHLOROBENZENE
l-CHLORO-3-NITROBENZENE
1 -METHYLFLUORENE
1 -METHYL PHENANTHRENE
1-NAPHTHYLAMINE
1-PHENYLNAPHTHALENE
1 , 1 -DICHLOROETHANE
1, 1-DICHLOROETHENE
CAS_NO
78308
1582098
512561
217594
20324338
7440337
7440611
7440622
108054
75014
7440644
7440655
7440666
7440677
694804
108372
121733
1730376
832699
134327
605027
75343
75354
Meas.
Type
ND
ND
ND
ND
ND
NC
NC
NC
ND
ND
NC
ND
NC
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mean
15.27
0.15
2.00
14.83
146.80
649.28
1096.71
107.67
50.00
10.00
68.46
4.33
3718.81
67.89
14.83
14.83
74.14
14.83
14.83
14.83
14.83
10.00
10.00
Min
10.00
0.10
2.00
10.00
99.00
93.20
10.10
2.60
49.94
9.99
0.10
3.00
89.75
0.10
10.00
10.00
50.00
10.00
10.00
10.00
10.00
9.99
9.99
Max
35.56
0.36
2.00
35.56
352.04
1000.00
2670.00
488.20
50.00
10.00
100.00
5.00
12310.00
100.00
35.56
35.56
177.80
35.56
35.56
35.56
35.56
10.00
10.00
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                     C-16

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
1,1, 1-TRICHLOROETHftNE
1,1,1, 2-TETRACHLOROETHANE
1,1, 2-TRICHLOROETHANE
1,1, 2, 2-TETRACHLOROETHANE
CAS_NO
71556
630206
79005
79345
l,2-DIBROMO-3-CHLOROPROPANE 96128
1 , 2 -DIBROMOETHANE
1 , 2 -DICHLOROBENZENE
1 , 2 -DICHLOROETHANE
1 , 2-DICHLOROPROPANE
1,2-DIPHENXLHYDRAZINE
1,2,3 -TRICHLOROBENZENE
1,2,3 -TRICHLOROPROPANE
1,2, 3-TRIMETHOXYBENZENE
1,2,4 -TRICHLOROBENZENE
106934
95501
107062
78875
122667
87616
96184
634366
120821
1,2,4,5-TETRACHLOROBENZENE 95943
1,2:3, 4-DIEPOXYBDTANE
1,3-BUTADIBNE, 2-CHLORO
1 , 3 -DICHLORO-2 -PROPAMOL
1, 3 -DICHLOROBENZENE
1 , 3 -DICHLOROPROPANE
1,3,5-TRITHIANE
1 , 4 -DICHLOROBENZENE
1 , 4 -DINITROBENZENE
1464535
126998
96231
541731
142289
291214
106467
100254
Meas.
Type
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mean
10.00
10.00
10.00
10.00
29.66
10.00
14.83
10.00
10.00
29.66
14.83
10.00
14.83
14.83
14.83
29.66
10.00
14.83
14.83
10.00
74.14
14.83
29.66
Min
9.99
9.99
9.99
9.99
20.00
9.99
10.00
9.99
9.99
20.00
10.00
9.99
10.00
10.00
10.00
20.00
9.99
10.00
10.00
9.99
50.00
10.00
20.00
Max
10.00
10.00
10.00
10.00
71.12
10.00
35.56
10.00
10.00
71.12
35.56
10.00
35.56
35.56
35.56
71.12
10.00
35.56
35.56
10.00
177.80
35.56
71.12
Unit
DG/L
DQ/L
DG/L
tJG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
DG/L
OG/L
DG/L
DG/L
DG/L
                                    C-17

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte

1,4-DIOXANE

1,4 -NAPHTHOQUINONE

1,5-NAPHTHALENEDIAMINE

1234678-HPCDD

1234678-HPCDF

123478-HXCDD

123478-HXCDF

1234789-HPCDF

123678-HXCDD

123678-HXCDF

12378-PECDD

12378-PECDF

123789-HXCDD

123789-HXCDF

2-(METHYLTHIO)BENZOTHIA

2-BOTANONE

2-CHLOROETHYLVINYL ETHER  110758

2 - CHLORONAPHTHALENE

2-CHLOROPHENOL

2-HEXANONE

2-ISOPROPYLNAPHTHALENE

2 -METHYLBENZOTHIOAZOLE

2 -METHYLNAPHTHALENE
CAS_NO
123911
130154
2243621
35822469
67562394
39227286
70648269
55673897
576S38S7
57117449
40321764
57117416
19408743
72918219
^E 615225
78933
110758
91587
95578
591786
2027170
120752
91576
Meas.
Type
ND
ND
ND
NC
NC
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Mean
10.00
146.80
146.80
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
14.83
50.00
10.00
14.83
14 . 83
50.00
14.83
14.83
14.83
Min
9.99
99.00
99.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
10.00
49.94
9.99
10.00
10.00
49.94
10.00
10.00
10.00
Max
10.00
352.04
352.04
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
35.56
50.00
10.00
35.56
35.56
50.00
35.56
35.56
35.56
Unit
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                             C-18

-------
APPENDIX C

Range of Pollutant Influent Concentrations of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
Analyte
2-NITROANILINE
2-NITROPHENOL
2-PHENYLNAPHTHALENE
2-PICOLINB
2-PROPANONE
2-PROPEN-l-OL
2-PROPENAL
CAS_NO
88744
88755
612942
109068
67641
107186
107028
2-PROPENBNITRILE, 2 -METHYL- 126987
2 , 3 -BBNZOFLUORENE
2 , 3 -DICHLOROANILINE
2 , 3 -DICHLORONITROBENZENE
2,3,4, 6-TETRACHLOROPHENOL
2,3, 6-TRICHLOROPHENOL
2,4-D
2,4-DB
2 , 4 -DICHLOROPHENOL
2 , 4 -DIMETHYLPHENOL
2 , 4 -DINITROPHENOL
2 , 4 -DINXTROTOLUENE
2,4,5-T
2,4,5-TP
2,4, 5-TRICHLOROPHENOL
2,4, 6-TRICHLOROPHENOL
243174
608275
3209221
58902
933755
94757
94826
120832
105679
51285
121142
93765
93721
95954
88062
Meas.
Type
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NC
NC
ND
ND
ND
ND
NC
NC
ND
ND
Mean
14.83
29.66
14.83
74.14
50.00
10.00
50.00
10.00
14.83
14.83
74.14
29.66
14.83
1.80
3.43
14.83
14.83
74.14
14.83
0.35
0.42
14.83
14.83
Min
10.00
20.00
10.00
50.00
49.94
9.99
49.94
9.99
10.00
10.00
50.00
20.00
10.00
1.00
2.00
10.00
10.00
50.00
10.00
0.20
0.20
10.00
10.00
Max
35.56
71.12
35.56
177.80
50.00
10.00
50.00
10.00
35.56
35.56
177.80
71.12
35.56
3.56
10.46
35.56
35.56
177.80
35.56
0.71
1.25
35.56
35.56
Unit
UG/L
OG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                    C-19

-------
APPENDIX C

Range of Pollutant Influent Concentration* of the Pooled Dally Data from the Three 5-Day
EPA Sampling Epiiodei for all Analytef
2 , C -DI -TERT - BUTYL - t -
BBtZOQUINOMK
CMJK)
                     71*222
                               MM*.
                                 m>
                                            man
                                           14«,*0
                                                       Milt
                                                       99.00
                                                                   Max
                                             1(2,04
                                                                         Unit
00/L
2,<-DZCHLORO-4-
MZT8OAMZLZNK
2 , 6 -DICKLOROFHBMOL
2,<-DZMITROTOLUEME
214<7*-KXCDP
21476-PtCDF
2176-TCDD
2378 -TCDf
l-CHLO*OraOPCME
i -MTTHYLCHOLAMTHJUDre
l-MZTROAMZLZME
3,1' -DZCHLOROBEMZZDZVE
1,3' -DIMETHOXYBEMZIDZME
3 , <-DZMETHYL?HZMAMTHUNC
4 -MfZNOBZPKZHYL
»»10*
87650
«04202
<0«91149
57117314
174(01(
9120711*
107091
54498
99092
.1*41
119904
197«7C
*2«71
4-MCMOPHEMYL PHCMYL ETHER 101991
4 -CMLORO'2 -MZTROAMZLIME
4 -CHLOSO- 3 -MSTHYLPHEMOL
4-CHLOROFMBMYLPHENyL ETHER
4 -METHYL - 2 - WWTWKJME
4-NZTROPHEMOL
89C34
9*907
7009723
10*101
100027
MD
MD
MD
MD
MD
MD
MD
ND
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
MD
14«,*0
14.83
14,11
0,00
0.00
0.00
0.00
10.00
14. *3
29, ««
74,14
74,14
14, (1
14.61
14,61
2»«
14,83
14.61
90,00
74,14
99,00
10.00
10.00
0,00
0,00
0,00
0,00
*,»*
10,00
20.00
90.00
90.00
10.00
10.00
10,00
20,00
10.00
10,00
4*. 94
90.00
192,04
39. 51
35.8*
0.00
0,00
0.00
0.00
10.00
19. 9<
71.12
177,60
177,80
38, St
19, M
19. 9<
71.12
19. 9<
19. 9<
90,00
177,60
00/L
00/L
00/L
00/L
O0/L
00/L
00/L
00/L
O0/L
00/L
00/L
00/L
00/L
00/L
00/L
00/L
00/L
00/L
00/L
00/L
                                       C-20

-------
APPENDIX C

Range of Pollutant Influent Concentration! of the Pooled Daily Data from the Three 5-Day
EPA Sampling Episodes for all Analytes
                           MM**,
Analyt*
4,4'-DDD
4/4'-DDC
4/4'-DDT
4,4' -MZTKYUMCTIS (2-
CHLOROANILZNE)
4,5-KTTHYLOre
PHHMMTHRZNI
5 -NITRO-O-TOLUZDINE
ANTHRACCNC
CM_MO
72641
7255>
502*1
101144
201*46
9*558
67»7t
Typ«
MD
ND
ND
MD
ND
ND
MD
M««n
0.11
0.1S
0,11
2».«
14.13
14, «1
14.11
Min
0,20
0.10
0.10
20.00
10.00
10.00
10.00
Max
0.71
O.K
0.3«
71,12
35.56
16.6*
38.56
Unit
00/L
00/L
00/t
00/L
00/L
00/L
00/L
                                    C-21

-------
APPENDIX D

ACRONYMS AND DEFINITIONS


Administrator — The Administrator of the U.S. Environmental Protection Agency
Agency - The U.S. Environmental Protection Agency
BAT — The best available technology economically achievable, as described in Sec. 304(b)(2) of the
CWA.
BCT - The best conventional pollutant control technology, as described in Sec. 304(b)(4) of the CWA.
BOD5 — Biochemical oxygen demand - Five Day. A measure of biochemical decomposition of organic
matter in a water sample.  It is determined by measuring the dissolved oxygen consumed by
microorganisms to oxidize the organic contaminants in a water sample under standard laboratory conditions
of five days and 70 °C.  BOD5 is not related to the oxygen requirements in chemical combustion.
Boiler - means an enclosed device using controlled flame combustion and having the following
characteristics:
(1)   (i)  The umtmusthave physical provision fOTiecoveringan^
         of steam, heated fluids, or heated gases; and
     (ii)  The unit's combustion chamber and primary energy recovery section(s) must be of integral
         design. To be of integral design, the combustion chamber and the primary energy recovery
         section(s) (such as waterwalls and superheaters) must be physically formed into one
         manufactured or assembled unit A unit hi which the combustion chamber and the primary
         energy recovery section(s) are joined only by ducts or connections carrying flue gas is not
         integrally designed; however, secondary energy recovery equipment (such as economizers or
         air preheaters) need not be physically formed into the same unit as the combustion chamber and
         the primary energy recovery section. The following units are not precluded from being boilers
         solely because they are not of integral design: process heaters (units that transfer energy directly
         to a process stream), and fiuidized bed combustion units; and
     (in)  While in operation, the unit must maintain a thermal energy recovery efficiency of at least 60
         percent, calculated in terms of the recovered energy compared with the thermal value of the fuel;
         and
     (iv)  The unit must export and utilize at least 75 percent of the recovered energy, calculated on an
         annual basis, hi this calculation, no credit shall be given for recovered heat used internally hi the
         same unit (Examples of internal use are the preheating of fuel or combustion air, and the driving
         of induced or forced draft fans or feedwater pumps); or
(2)       The unit is one which the Regional Administrator has determined, on a case-by-case basis, to
         be a boiler, after considering the standards in Section 260.32.
BPT — The best practicable control technology currently available, as described in Sec. 304(b)(l) of the
CWA.
Captive — Used to describe a facility that only accepts waste generated on site and/or by the owner
operator at the facility.
                                          D-l

-------
 Clarification - A treatment designed to remove suspended materials from wastewater-typically by
 sedimentation.
 Clean Water Act (CWA) - The Federal Water Pollution Control Act Amendments of 1972 (33 U.S.C.
 1251 et seq.), as amended, inter alia, by the Clean Water Act of 1977 (Public Law 95-217) and the
 Water Quality Act of 1987 (Public Law 100-4).
 Closed - A facility or portion thereof that is currently not receiving or accepting wastes and has undergone
 final closure.
 Combustion Unit — A device for waste treatment which uses elevated temperatures as the primary means
 to change the chemical, physical, biological character or composition of the waste. Examples of
 combustion units are incinerators, fuel processors, boilers, industrial furnaces, and kilns.
 Commercial Hazardous Waste Combustor — Any thermal unit, except a cement kiln, that is subject
 to either to 40 CFR Part 264, Subpart O; Part 265, Subpart O; or Part 266, Subpart H if the thermal unit
 bums RCRA hazardous wastes received from off-site for a fee or other remuneration in the following
 circumstances.  The thermal unit is a commercial hazardous waste combustor if the off-site wastes are
 generated at a facility not under the same corporate structure or subject to the same ownership as the
 thermal unit and
       (1)    The thermal unit is burning wastes that are not of a similar nature to wastes being burned
              from industrial processes on site or
       (2)    There are no wastes being burned from industrial processes on site.
 Examples of wastes of a "similar nature" may include the following: wastes generated in industrial
 operations whose wastewaters are subject to the same provisions in 40 CFR Subchapter N or wastes
 burned as part of a product stewardship activity.  The term commercial hazardous waste combustor
 includes the following facilities: a facility that bums exclusively waste received from off-site; and, a facility
 that burns both wastes generated on-site and wastes received from off-site. Facilities that may be
 commercial hazardous waste combustors include hazardous waste incinerators, rotary kiln incinerators, lime
 kilns, lightweight aggregate kilns, and boilers. A facility not otherwise a commercial hazardous waste
 combustor is not a commercial hazardous waste combustor if it burns RCRA hazardous waste for
 charitable organizations, as a community service or as an accommodation to local, state or government
 agencies so long as the waste is burned for no fee or other remuneration.
 Commercial hazardous waste combustor wastewater -- Wastewater attributable to commercial
 hazardous waste combustion operations, but includes only wastewater from air pollution control systems
 and water used to quench flue gas or slag generated as a result of commercial hazardous waste combustor
 operations.
 Conventional pollutants — The pollutants identified in Sec. 304(a)(4) of the CWA and the regulations
thereunder (biochemical oxygen demand (BOD$), total suspended solids (TSS), oil and grease, fecal
coliform, and pH).
Direct discharger - A facility that discharges or may discharge treated or untreated pollutants into waters
of the United States.
Disposal — Intentional placement of waste or waste treatment residual  into or on any land where the
material will remain after closure. Waste or residual placed into any water is not defined as disposal, but
as discharge.

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Effluent -- Wastewater discharges.
Effluent limitation - Any restriction, including schedules of compliance, established by a State or the
Administrator on quantities, rates, and concentrations of chemical, physical, biological, and other
constituents which are discharged from point sources into navigable waters, the waters of the contiguous
zone, or the ocean. (CWA Sections 301(b) and 304(b).)
EA - Economic Analysis
EPA — The U.S. Environmental Protection Agency.
Facility — A facility is all contiguous property owned, operated, leased or under the control of the same
person. The contiguous property may be divided by public or private right-of-way.
Hazardous Waste — Any waste, including wastewaters defined as hazardous under RCRA, Toxic
Substances Control Act (TSCA), or any state law.
Incinerator — means any enclosed device that:
(1)   Uses controlled flame combustion and neither meets the criteria for classification as a boiler, sludge
      dryer, or carbon regeneration unit, nor is listed as an industrial furnace; or
(2)   Meets the definition of infrared incinerator or plasma arc  incinerator.
Indirect discharger - A facility that discharges or may discharge pollutants into a publicly-owned
treatment works.
Industrial Furnace — means any of the following enclosed devices that are integral components of
manufacturing processes and that use thermal treatment to accomplish recovery of materials or energy:
(1)   Cement kilns
(2)   Lime kilns
(3)   Aggregate kilns
(4)   Phosphate kilns
(5)   Coke ovens
(6)   Blast furnaces
(7)   Smelting, melting and refining furnaces (including pyrometallurgical devices such as cupolas,
      reverberator furnaces,  sintering machine, roasters, and foundry furnaces)
(8)   Titanium dioxide chloride process oxidation reactors
(9)   Methane reforming furnaces
(10)   Pulping liquor recovery furnaces
(11)   Combustion devices used in the recovery of sulfur values from spent sulfuric acid
(12)  Halogen acid furnaces (HAFs) for the production of acid from halogenated hazardous waste
      generated by chemical production facilities where the furnace is located on the site of a chemical
     production facility, the acid product has a halogen acid content of at least 3 percent, the acid product
      is used in a manufacturing process, and except for hazardous waste burned as fuel, hazardous waste
      fed to the furnace has a minimum halogen content of 20 percent as generated.
(13)   Such other devices as the Administrator may, after notice and comment, add to this list on the basis
      of one or more of the following factors:
      (i) The design and use of the device primarily to accomplish recovery of material products;
      (ii) The use of the device to bum or reduce raw materials to make a material product;
      (iii) The use of the device to bum or reduce secondary materials as effective substitutes for raw

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          materials, in processes using raw materials as principal feedstocks;
     (iv) The use of the device to bum or reduce secondary materials as ingredients in an industrial
          process to make a material product;
     (v)  The use of the device in common industrial practice to produce a material product; and,
     (vi) Other factors, as appropriate.
Intracompany — A facility that treats, disposes, or recycles/recovers wastes generated by off-site facilities
under the same corporate ownership. The facility may also treat on-site generated wastes. If any waste
from other facilities not under the same corporate ownership is accepted for a fee or other remunerations,
the facility is considered commercial.
LTA - Long-term Average. For purposes of the effluent guidelines, LTAs are defined as average
pollutant levels achieved over a period of time by a technology option. LTAs were used in developing the
limitations and standards in today's proposed regulation.
Minimum level ~ The level at which an analytical system gives recognizable signals and an acceptable
calibration point.
Municipal Facility — A facility which is owned or operated by a municipal, county, or regional
government.
New Source - "New source" is defined at 40 CFR 122.2 and 122.29.
Non-conventional pollutants—Pollutants that are neither conventional pollutants nor priority pollutants
listed at 40 CFR Section 401.
Non-detect value  — A concentration-based measurement reported below the sample specific detection
limit that can reliably be measured by the analytical method for the pollutant.
Non-hazardous waste - All waste not defined as hazardous under RCRA regulations.
Non-water quality environmental impact — An environmental impact of a control or treatment
technology, other than to surface waters.
NPDES - The National Pollutant Discharge Elimination System authorized under Sec. 402 of the CWA.
NPDES requires permits for discharge of pollutants from any point source into waters of the United States.
NSPS - New Source Performance Standards
OCPSF - Organic Chemicals, Plastics, and Synthetic Fibers Manufacturing Effluent Guideline (40 CFR
Part 414).
Off-site - "Off-site" means outside the boundaries of a facility.
On-site — "On-site" means within the boundaries of a facility.
Outfall — The mouth of conduit drains and other conduits from which a facility effluent discharges into
receiving waters or POTWs.
Point Source Category — A category of sources of water pollutants.
POTW or POTWs - Publicly-owned treatment works, as defined at 40 CFR 403.3(o).
Pretreatment Standard—a regulation that establishes industrial wastewater effluent quality as required
for discharge to a  POTW.  (CWA Section 307(b).)
Priority  Pollutants - The pollutants designated by EPA as priority in 40 CFR Part 423 Appendix A.
Process wastewater - "Process Wastewater" is defined at 40 CFR 122.2.
PSES ~ Pretreatment standards for existing sources of indirect discharges, under Sec. 307(b) of the
CWA.

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PSNS - Pretreatment standards for new sources of indirect discharges, under Sec. 307(b) and (c) of the
CWA.
RCRA - Resource Conservation and Recovery Act (PL 94-580) of 1976, as amended.
Residuals — The material remaining after a natural or technological process has taken place, e.g., the
sludge remaining after initial wastewater treatment.
Sewage Sludge — Sludge generated by a sewage treatment plant or POTW.
Sludge — The accumulated solids separated from liquids during processing.
Small business - Businesses with annual sales revenues less than $6 million. This is the Small Business
Administration definition of small business for SIC code 4953, Refuse Systems (13 CFR Ch.1, § 121.601)
Solids — For the purpose of this notice, a waste that has a very low moisture content, is not free-flowing,
and does not release free liquids.  This definition deals with the physical state of the waste, not the RCRA
definition.
Treatment—Any activity designed to change the character or composition of any waste so as to prepare
it for transportation, storage, or disposal; render it amenable for recycling or recovery; or reduce it in
volume.
TSS — Total Suspended Solids. A measure of the amount of particulate matter that is suspended in a
water sample. The measure is obtained by filtering a water sample of known volume. The particulate
material retained on the filter is then dried and weighed.
Waste Receipt ~ Wastes received for combustion.
Wastewater treatment system—A facility, including contiguous land and structures, used to receive and
treat wastewater. The discharge of a pollutant from such a facility is subject to regulation under the Clean
Water Act.
Waters of the United States -- The same meaning set forth in 40 CFR 122.2
Zero discharge - No discharge of pollutants to waters of the United States or to a POTW. Also
included in this definition are discharge of pollutants by way of evaporation, deep-well injection, off-site
transfer and land application.
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