United States
Environmental Protection
Agency
Washington, D.C. 20460
April 1977
Clean Water
and the
Cane Sugar
Industry
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This booklet is about the cane sugar industry and water pollution. It is
intended to help you understand how this industry—and all other
industries—are affected by a law passed by Congress to reduce and
eventually eliminate water pollution.
There are approximately 20,000 men and women employed in the mills
and refineries of the cane sugar industry—about 8,000 in mills and 12,000 in
refineries. The 29 cane sugar refineries discharge approximately 276
million gallons of waste water daily, while the 74 raw cane sugar mills
currently discharge approximately 1.13 billion gallons of waste water daily.
This booklet describes what these plants must do to keep their wastes
from polluting the Nation's waters.
In non-technical language, this booklet explains that:
• The technology exists to reduce water pollution from cane sugar plants to
safe levels.
• Applying that technology costs money—but the majority of cane sugar
plants can afford to make the necessary investments to control pollution.
• Such pollution control investments will not unduly affect the financial
condition of the plants, or the price consumers pay for the sugar.
This booklet also describes why a few cane sugar plants may not be
able to comply with pollution control standards and, unfortunately, may
have to shut down, with the subsequent loss of jobs.
In brief, this booklet discusses the facts of life about water pollution
—how it affects all of us, why it must be controlled, and what the law
requires the cane sugar industry to do as its part of the national program to
clean up our Nation's waterways.
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The Problem
You and millions of other
Americans have probably seen
the warning signs: "No Fishing,"
"No Boating," "Beach Closed," or
"Danger, Do Not Drink the
Water." The signs are there
because the water is polluted with
raw or poorly treated human
wastes, with runoff from city
streets, farmlands, animal
feedlots, and mines; with leaks
and spills from ships. And with
waste from industries—
including the cane sugar
industry.
Each year, some 402 million
tons of pollutants from human
activities enter the Nation's
waters. That's almost two tons for
every man, woman, and child in
the United States. The pollutants
include bacteria, viruses, organic
materials, animal fats, oil, acids,
metals, pesticides, a myriad of
other chemicals, and hot water
from power plants and industrial
boilers.
Not only do the pollutants make
our waters unsightly, but without
expensive purification they can
make the water unfit for drinking,
for irrigation, and for industrial
use. They contaminate fish and
shellfish, making them
unpalatable or actually unsafe to
eat. Some pollutants endanger
reproduction, causing
deformities and even death in
various life forms.
It is impossible to put a precise
price tag on the cost of water
pollution. But there is no doubt
that water pollution exacts a
heavy toll. It's estimated that dirty
water costs the American people
at least $13 billion a year—in
water purification bills, in damage
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to fishery resources, in lost
recreation.
In short, water pollution is a
major national problem.
How did so many of our
waterways become open sewers?
For many years we thought the
waste products of human
activities dumped in our
waterways would decompose and
disappear harmlessly. But we
learned otherwise. We learned
that we had overburdened the
capacity of water to cleanse itself,
to assimilate the sewage
discharges from increasing
numbers of people and the
increasing wastes discharged
from industry, agriculture, and
mining.
Finally, after more than two
decades of generally ineffective
attempts to control water
pollution, we realized that a
completely new approach was
needed.
To Solve the Problem
In response to widespread
public concern about the sad
condition of the Nation's
waterways, Congress, building
upon the experiences of earlier
water pollution control laws,
enacted the Federal Water
Pollution Control Act
Amendments of 1972. It brought
dramatic changes.
What the 1972 law says, in
essence, is that nobody—no city
or town, no industry, no
government agency, no
individual—has a right to pollute
our water. The free use of our
waterways as dumping grounds
for our wastes is no longer
permitted. From now on, under
the 1972 law, we must safeguard
our waterways, even if it means
fundamental changes in the way
we manufacture products,
produce farm crops, and carry
on the economic life of our
communities.
Congress declared that the
objective of the 1972 law is "to
restore and maintain the
chemical, physical, and
biological integrity of the
Nation's water."
The 1972 law has two goals:
First, whenever possible by July
1983, achieve water quality that's
clean enough for recreational
use, and clean enough to protect
fish, shellfish, and wildlife.
Second, by 1985, no more
discharges of pollutants into our
waters.
To achieve these goals the law
set in motion a new national
system of uniform controls on
the discharge of pollutants, to be
carried out by the U.S.
Environmental Protection
Agency (EPA) in cooperation
with State and local
governments:
• The law requires EPA to
establish national "effluent
limitations" for industrial
plants—including cane sugar
plants. An "effluent limitation" is
simply the maximum amount of
a pollutant that anyone may
discharge into a water body.
• By July 1, 1977, the law
requires existing industries to
reduce their pollutant discharges
to the level attainable by using
the "best practicable" water
pollution control technology
(BPT). BPT is determined by
averaging the pollution control
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effectiveness achieved by the
best plants in the industry.
• By July, 1983, the law requires
existing industries to reduce
their pollutant discharges still
more—to the level attainable by
using the "best available"
pollution control technology
(BAT). BAT is based on the best
pollution control procedures
economically achievable. If it is
technologically and
economically feasible to do so,
industries must completely
eliminate pollutant discharges
by July 1, 1983.
• The law requires new
industrial plants to limit pollutant
discharges to the level attainable
by meeting national "standards
of performance" immediately,
without waiting for 1977 or 1983.
These new plant standards may
require greater reduction of
pollutant discharges than the
1977 and 1983 standards for
existing plants, or zero
discharge where applicable.
• The law requires industrial
facilities that send their wastes
to municipal treatment
plants—as some cane sugar
plants do—to make sure the
wastes can be adequately
treated by the municipal plant
and will not damage it. In some
industries, discharges to
municipal plants may thus have
to be "pre-treated." That is, the
portion of the industrial waste
that would not be adequately
treated or would damage the
municipal plant must be
removed from the waste water
before it enters the municipal
system.
• The law does not tell any
industry what technology it must
use. The law requires only that
industries limit pollutant
discharges to levels prescribed
by law.
• The law also says that if
meeting the 1977 and 1983
requirements is not good
enough to achieve water quality
standards, even tougher controls
may be imposed on dischargers.
• And while the law requires
industries to meet the national
discharge standards set for 1977,
1983, and for new plants, the law
also allows a State or community
to impose stricter requirements
if it wishes. The national
standards are thus minimum
requirements that all industries
must meet.
Setting limits on industrial
discharges is only the first step
in controlling water pollution, of
course. The next step is to make
sure those limits are met. This
law provides the mechanism to
do that.
Permits
The key to applying the effluent
limits to industries—including
the cane sugar industry—is the
national permit system created
by the 1972 law. (The technical
name is the "National Pollutant
Discharge Elimination System,"
or NPDES.)
Under the law, it is illegal for
any industry to discharge any
pollutant into the Nation's waters
without a permit from EPA or
from a State that has an EPA-
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approved permit program. Every
industrial plant that discharges
pollutants to a waterway must,
therefore, apply for a permit.
Essentially, all have done so.
When-issued, the permit
regulates what may be
discharged, and the amount of
each identified pollutant from a
plant. The discharger must
monitor its wastes and report on
such pollutant discharges. The
discharger must comply with all
applicable national effluent
limits and with any State or local
requirements that may be
imposed. If the plant cannot
comply immediately, the permit
contains a compliance schedule
of firm dates by which the
pollutants will be reduced or
eliminated.
The permit, in essence, is a
contract between a company
and the government.
This combination of national
effluent standards and limits,
applied to specific sources of
water pollution by individual
permits, with substantial
penalties for failure to comply,
constitutes the first effective
nationwide system of water
pollution control.
Now, what does this mean to
the cane sugar industry?
The Cane Sugar Industry's
Pollution Problems
Both segments of the cane sugar
industry's operations—milling
and refining—may give rise to
pollution. There are pollution
problems unique to each
segment, and others common to
both. The first step in applying
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8 the 1972 law to the cane sugar
industry was to identify these
problems and determine how to
solve them.
The Environmental Protection
Agency conducted an exhaustive
review of available literature on
the industry, reviewed
applications to the Corps of
Engineers for permission to
discharge effluents into public
waters, and made on-site
inspections of various factories
and refineries in operation.
Personal and telephone
interviews were conducted, and
the results of a voluntary
questionnaire of the industry
were closely studied. In addition,
information from samplings of
selected plants were taken to
verify the accumulated data.
Finally, a contractor's study was
prepared under EPA supervision
to provide a basis for evaluating
the potential economic impact of
effluent limitations guidelines
and standards of performance
established by EPA.
With this broad base of data,
EPA was able to identify the raw
waste characteristics, including
analyses of the source and
volume of water used in the
process employed, and plants
were grouped in
subcategorizations to better
evaluate particular problems of
waste water. The constituents of
waste water which should be
subject to the effluent limitations
guidelines were identified.
Existing control and treatment
technologies were identified
along with the problems,
limitations, and reliability of
each, and the costs and time
required to implement them were
also defined.
From all this emerged the
following facts:
• The 74 raw cane sugar mills
discharge approximately 1.13
billion gallons of waste water
daily. The 29 cane sugar
refineries discharge
approximately 276 million
gallons of waste water.
• The waste water from cane
sugar refineries contains 3.5-8.5
pounds of oxygen-robbing
organic materials and about 18
pounds of suspended solids per
ton of raw sugar melted, while
the waste water from cane sugar
mills contains 4.2-21 pounds of
organic matter and 35-200
pounds of suspended solids per
ton of sugar cane processed.
• A major pollutant in both cane
sugar milling and refining is
organic material. The
measurement of these oxygen-
consuming pollutants in water is
called "biochemical oxygen
demand," or BOD. (This is
usually expressed in terms of the
amount of biochemical oxygen
demand in five days, or BODS.)
When dumped untreated into a
stream or river, the organic
material is decomposed by
micro-organisms which consume
oxygen in the water, eventually
depleting the oxygen content to
the extent that aquatic animal
and plant survival is menaced.
Even when all the oxygen in a
body of water has been used, the
decay of organic matter
continues, producing noxious
gases, such as hydrogen sulfide
and methane.
• Another major pollutant from
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the cane sugar industry is
suspended solids, both organic
and inorganic. Among the
inorganics are silt, sand, and
clay. The organic components
include such things as bagasse,
boiler ash, and so forth. These
pollutants are collectively called
"total suspended solids," or TSS.
Suspended solids discolor and
cloud water, impairing
photosynthesis in aquatic plants.
If pollutants containing organic
matter settle on the bottom, they
become sludge beds that further
deplete the water's oxygen
content, and create gases toxic
to aquatic life. In addition to
esthetic and ecological
considerations, suspended solids
in water from streams used by
industry can interfere with many
industrial processes. They can
cause foaming in boilers,
damage equipment, and impose
high purification costs on
industries that need water to
make their products.
There are two key points to
keep in mind: Raw wastes from
cane sugar mills and refineries
contain unacceptable amounts of
organic materials and suspended
solids. Therefore, the wastes
must be treated before they can
be discharged into a water body.
and
The cane sugar industry can
successfully control these two
major water pollutants.
• Other identified pollutants in
cane sugar industry wastes
include coliform bacteria,
nitrogen, phosphorus, dissolved
solids, and heat.
• Another consideration is the
acid or alkali content of liquid
wastes. This is called the "pH" of
the mixture. (Pure distilled water
has a pH of about 7, a strong acid
solution has a pH of 1, and a
strong alkali solution has a pH of
14.) Extremes of pH or rapid pH
changes can create stress
conditions on aquatic life, or kill
it outright. Even moderate
changes from "acceptable"
criteria limits of pH are
deleterious to some species. In
general, however, the pH of
wastes from cane sugar plants
can be easily adjusted where
necessary.
• In raw cane sugar milling, the
reduction of waste waters or
waste water pollutants can be
effected by such in-plant control
measures as recirculation of
barometric condenser cooling
water through cooling towers,
ponds, or canals; dry hauling of
filter mud; recirculation of cane
wash water; and reducing the
amount of sucrose in barometric
condenser cooling water.
• For the cane sugar refineries,
waste water or waste water
pollutants can be reduced by in-
plant control measures such as
recirculation of barometric
condenser cooling water, dry
hauling of filter mud, recovery of
floor drainage, and reduction of
sucrose entrainment in
barometric condenser cooling
water. A primary portion of in-
plant control is to prevent
sugar loss.
• Finally, the EPA study
determined that the process
waste waters from cane sugar
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10 refining contain sufficiently low
concentrations of water
pollutants to allow them to be
discharged to publicly owned
treatment plants. Moreover,
where such treatment plants are
available, there should be no
problem in introducing cane
sugar milling waste waters
directly into them.
In sum, the water pollution
problems of the cane sugar
industry were identified, and it
was determined that water
pollution from the industry can
be controlled by use of
machinery and methods already
in use. In other words, the
technology to do the job already
exists.
The Law and the Industry
Having assembled these facts,
EPA's next step was to prepare
standards for cane sugar mills
and refineries under the 1972
law. Many factors were
considered: the age and size of
the facilities, the quality and
nature of raw materials used, raw
waste characteristics, existing
control and treatment
technologies, with their
attendant problems, limitations,
and reliability of each. The
energy requirements and costs of
each control and treatment
technology were also studied.
For the purposes of developing
these guidelines, the cane sugar
refining segment was divided
into two subcategories—liquid
cane sugar refining and
crystalline cane sugar refining.
The cane sugar milling segment
was divided into five
subcategories determined
primarily by differences in waste
water characteristics due to
different harvesting methods and
conditions, manufacturing
processes, and treatment
technology. The subcategories
are I (comprised of factories
located within the state of
Louisiana); II (factories located
in Florida and Texas); III
(factories located on the Hilo-
Hamakua Coast of the Island of
Hawaii); IV (factories located in
Hawaii other than those in
subcategory III); V (factories
located on the Island of Puerto
Rico).
The proposed regulations were
issued December 7,1973 for
cane sugar refineries, and
February 27,1975 for cane sugar
mills. They were sent to the
industry and other interested
organizations for review and
comment. When the comments
were received, EPA carefully
analyzed them and made
appropriate changes in the
standards.
On March 20,1974, EPA issued
the final standards for carte sugar
refining the industry must meet
to comply with the requirements
of the 1972 law. Similar final
standards will be issued for the
milling segment.
In brief, the regulation:
• Establishes the limits to be met
by July 1,1977 through the best
practicable control technology
currently available.
• States the limits to be met by
July 1,1983, using the best
available technology
economically achievable.
• Establishes the requirement
that all new cane sugar mills and
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refineries, at the time they are
built, must meet the standards
that existing plants must meet by
July 1, 1983, and, wherever
possible, should have zero
discharge of pollutants.
• Identifies the major cane sugar
industry pollutants, and
establishes maximum limitations
for BOD and TSS that cane sugar
plants can discharge during any
one day on an average over a 30-
day period.
• Requires that the pH (acidity or
alkalinity) of cane sugar industry
plant discharges be within the
range of 6.0 to 9.0.
• Explores the costs of attaining
the required effluent reductions.
• States that waste waters from
cane sugar mills and refineries
are not harmful to municipal
treatment plants.
• Allows flexibility in applying
pollution controls to meet the
1977 standards in special cases.
• Does nof tell cane sugar plants
what technology to use to meet
the regulations. The standards
require cane sugar mills and
refineries to limit pollutant
discharges to levels found
attainable by using best
practicable control technology.
What does all this mean—to
cane sugar companies, to those
of you who work in cane sugar
mills and refineries, and to the
public?
Impact of the Guidelines
Let's consider some questions
you may very well be asking
yourself at this point about the
impact of pollution control on the
cane sugar industry.
1. Can cane sugar mills and
refineries meet the 1977
limitations? That is,
technologically, can they reduce
their discharges of pollutants to
the levels required by 1977?
The answer is yes. All existing
cane sugar mills and cane sugar
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12 refineries can meet the 1977
standards. While there is no
single treatment process
(impoundment, waste
stabilization, irrigation, or—in
refineries—biological treatment)
which is universally applicable in
achieving reduction of pollutants
in waste waters, the technologies
already exist which can be
applied to any given plant to
meet the guidelines limitations.
Raw cane sugar milling plants in
Subcategories II and IV are
currently achieving zero
discharge. Other mills in
Subcategories I and V are
meeting or doing better than
BPT. In addition, urban
refineries, representing
approximately three-fourths of
all American cane sugar refinery
production, discharge process
water and in some cases
barometric condenser cooling
water directly to municipal
sewage treatment plants. Many
refineries are currently attaining
BPT.
2. Can cane sugar plants meet
the 1983 limitations? That is,
technologically, can they reduce
their pollutant discharges to the
levels required by 1983?
Again, the answer is yes,
although some development
work may possibly be required in
some cases. Five refineries are
presently achieving zero
discharge of pollutants to
navigable waters, two discharge
all process waste waters to
municipal treatment systems,
and ten or more currently
discharge all wastes except
barometric condenser cooling
water to municipal systems.
Many cane sugar mills are
already attaining BAT in
Subcategories I, II, IV, and V.
3. Can new plants meet the new
source performance standards?
Yes. In all five categories of raw
cane sugar milling, where new
plant construction is likely, and
in raw cane sugar refining, new
plants, using the best available
control technology, can meet the
required standards.
4. Can the cane sugar industry
afford to meet the 1977 water
pollution control requirements?
The answer is yes. It's
estimated that meeting the 1977
standards will cost the cane
sugar milling segment $9.8-10.4
million, with annual operating
costs estimated at $2.8-4.03
million. It is estimated that
meeting the 1977 standards will
cost the cane sugar refining
segment approximately $5.9
million, representing
approximately 2 percent of the
total investment needed to build
a typical refinery.
5. Can the cane sugar industry
afford to meet the 1983 water
pollution control requirements?
/es, in most cases. The total
capital cost to the cane sugar
refining segment in meeting the
1983 guidelines is estimated at
approximately $17 million. This is
approximately 3.5 percent of the
total investment needed to build
the typical refinery. To meet the
1983 standards should cost the
milling segment an investment of
$11.6-14.2 million, with estimated
total annual costs of $2.9-4.3
million.
So far, we've talked about cane
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sugar mills and refineries that
can—technologically and
financially—meet the 1977 and
1983 standards. Now a tougher
question:
6. What about cane sugar plants
that cannot financially meet the
1977 standards? What will
happen to them?
The 1977 standards will
probably cause one plant closure
in the cane sugar milling
segment. However, the economic
analysis of cane sugar refining
indicates that three to five plants
will close by the time of
implementation of the 1977
standards, or due to the
incremental costs of meeting
both 1977 and 1983 standards.
Two to three of these plant
closures are in Puerto Rico
where lost production can be
absorbed by other Puerto Rican
refineries which have unused
capacity. EPA is very much
aware of the impact these
closures will have on the men
and women employed by the
plants. It will mean relocating to
another job in the cane sugar
industry, perhaps involving a
move to another community.
Some people may find it
necessary to enter a totally new
career, or accept early
retirement. But to lower the 1977
standards any further to prevent
these closures would mean
continuing discharges of raw
wastes into our public waters, a
practice no longer
environmentally tolerable. It
should be noted that the *
regulation will create new jobs in
construction and maintenance of
new pollution control facilities.
In sum, if a plant can only
operate by polluting our public
waterways, it must close down
for the benefit of us all.
7. What about the 1983
standards? Will any more cane
sugar mills and refineries have to
close because of those
standards?
Unfortunately, one raw cane
sugar processing plant in
Louisiana may have to close due
to the costs of meeting the 1983
standards. This closure would
affect no more than 300
employees.
There should be very good
chances for re-employment in
Louisiana. Some small mills may
decide to consolidate into larger
ones, creating new jobs. Also, the
general economic development
along the Mississippi River
suggests the creation of new jobs
within the general area.
Closing cane sugar plants
could definitely affect farmers. At
current price levels, the loss of
sugar cane as a crop would
greatly reduce farm income.
However, alternative uses of land
in Louisiana could include
soybean and pasture. While
these crops would produce a
smaller farm income, reducing
the economic base of the
community, that base would at
least not be eliminated.
8. How will the 1977 and 1983
standards affect consumers?
What impact will they have on the
price of cane sugar?
It is generally thought
that the cost of pollution
control will not be passed
on to the consumer. The
household consumption of sugar
remains relatively stable and
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industrial users appear to be
very price-conscious. If substitute
sweeteners continue to be
available, it is unlikely that
there will be any significant
price increases. Any price
adjustments that might include
incremental cost of pollution
control would most likely be
intertwined with the economics of
the entire domestic sugar
industry, which includes both
cane and beet sugar. It is also felt
that any losses in U.S. production
due to pollution control would
not influence world prices
of sugar.
9. What about the productive
capacity that will be lost if some
cane sugar plants do shut down?
Based on consideration of
excess capacity in various plants,
the possibility of new plants in
some regions, and the availability
of imported sugar and substitute
sweeteners, the overall supply of
sugar would probably not be
affected in the event of actual
plant closings.
Thus, water pollution control
requirements for the cane sugar
industry will have no long-range
repercussions in terms of
supplies of sugar, or industry
growth. The standards will have a
negligible effect on the Nation's
balance of trade with other
countries or exports of cane
sugar.
In summary, with just a few
exceptions, the cane sugar
industry can meet the water
pollution control requirements
mandated by the 1972 law. The
result will be cleaner water for all
of us to enjoy and less waste for
the cane sugar industry.
Some Final Words
The effluent guidelines for the
cane sugar and other industries
are only part of the
comprehensive program set in
motion by the 1972 law. Among
other things, municipal treatment
plants must meet certain
discharge standards by 1977 and
1983. The law increased Federal
aid to local governments to help
build sewage treatment facilities,
and established planning
procedures for State and local
governments to control water
pollution from all sources more
effectively, in cooperation with
the Federal Government. The law
also streamlined and
strengthened the enforcement
provisions of the water pollution
control program.
Some water quality control
problems are so complex that
they cannot be solved by using
technology alone. For this reason
the Act included an areawide
waste treatment management
planning process under Section
208. This areawide planning
brings together several aspects
of water pollution control,
including treatment of municipal
and industrial wastes, the issuing
of discharge permits to industry,
and the ways of dealing with
"nonpoint" sources of pollution
such as stormwater runoff, in a
comprehensive approach.
Emphasis is placed upon
planning by local governments.
To help pay for this cleanup,
Congress set up a construction
grants program in which the
Federal Government will pay up
to 75 percent of construction
costs for treatment plants. The
funding for this program is
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16 expected to rival the Federal
highway program in magnitude.
In fact, costs from the beginning
of the program through 1982 are
expected to total $50 billion, or
an average of $5 billion per
year—compared to the $13
billion a year that water pollution
now costs the American people.
Congress felt that expenditures
under the construction grants
program were essential to deal
with a significant and pressing
environmental problem.
With the cooperation, hard
work, and investment of
considerable amounts of money
from industries and all levels of
government, progress has
already beeen made toward
reducing—and eventually
eliminating—pollution in our
Nation's waterways. But much
remains to be done. Still more
money and effort will have to be
invested if the clean water
program is to be successful—if
we are to have water that is safe
and healthful for drinking, for use
by industry and agriculture, for
swimming and boating, for fish
and wildlife.
For additional copies of this
booklet, write: Public Information
Center (PM-215). EPA,
Washington, D.C. 20460.
Some Suggestions on How
to Improve Pollution Control
in Plants
In-plant control measures
are essential in the total
effort to control pollution in
the cane sugar industry.
There are several ways in
which individual plants can
reduce pollutants in cane
sugar waste waters.
Two of the major waste
sources in cane sugar mill-
ing—cane wash water and
filter muds—are directly
affected by harvesting tech-
niques. There are several
mechanical harvesting sys-
tems currently being evalu-
ated which should signifi-
cantly reduce the total
amount of extraneous mate-
rial entering a cane sugar
factory. The goal is to lower
the extraneous material to
such a level that cane wash-
ing is not necessary.
The mills and refineries
can also reduce waste wa-
ters or waste water pollut-
ants by such control meas-
ures as dry hauling of filter
mud, reducing the amount
of sucrose in barometric
condenser cooling water,
and the recirculation of that
water through cooling tow-
ers, ponds, or canals. In
addition, mills can also recir-
culate cane wash water to
further reduce waste water
discharges.
In another effort to reduce
waste, some refineries rec-
over water from nearly all
floor wash drains as sweet
water for reuse. To prevent
untoward sugar loss, most
refineries sweep up as much
spilled sugar as possible
before washing down the
receiving area.
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