SW-131c
                                                U.S.  DEPARTMENT  OF COMMERCE
                                                National Technical Information Service
                                                   PB-261  018
             ASSESSMENT OF INDUSTRIAL HAZARDOUS WASTE  PRACTICES
             LEATHER  TANNING AND  FINISHING  INDUSTRY

             SCS ENGINEERS.,  INC,
             NOVEMBER  1976


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BIBLIOGRAPHIC DATA 1. Report No. 2.
SHEET
4. Title and Subtitle
Assessment of Industrial Hazardous Waste Practices —
Leather Tanning and Finishing Industry
7. Au,hor E. T. conrad, Gary L. Mitchell, David H. Baue
9. Performing Organization Name and Address
SCS Engineers, Inc.
11800 Sunrise Valley Drive
Reston, Virginia 22091
12. Sponsoring Organization Name and Address
EPA, Hazardous Waste Management Division •
Office of Solid Waste Management Programs
401 M. Street, S.W.
Washington. D'C. ?nAftn
3. Recipient1!. Acrrs-.ion No._
i PB-261 018
5. Report Date
November 1976
6.
.8. Performing Orpiiiiriinon Krpt.
No.
10. Proiect/Taslc/Vork Unit No.
11. Contract/Grant No.
EPA No. 68-01-3261
13. Type of Report & Period
Covered Final
rune 1975 to Noyembe:
14.
15. Supplementary Notes
EPA Project Officer - Allen Pearce
16. Abstracts
rh is report, which covers the leather tanning and finishing industry, is one of a series of studies which examines land-
aentined waste from selected industries. Por purposes of this study, the tanning industry has been categorised by the
types of process solid wastes generated. A total of seven different categories were established.
 rocesa sol-rt wastes  from the industry consist primarily of pieces of  leather in various  stages of processing and w.iste-
water treatnent sludqes.  Virtually every tannery waste stream (except those in vegetable tanneries)  was designated as
           ha=.ir.1ous.  Th" concentration of heavy metals (particularly trivalont chroniun,  load, COMX.T, and mac}
h.Te  foj-c! to t: at  levels such that the wastes containing these constituents were considered to be potentially
m-..iii!^.:j.  l.iter.xti-re concern'nr  the hazardous nature of trivalont chromium was conflict Ing.  In 1974,  •inn'!'
ff.-ei.ff* ,vatoter.ti.V.iy
                                                          rics
                                                         wan
 ro..tnent Cf t.-.!»ncrv  ..istes «* restricted to th« dc-witcrinu of w.ijtuwater treatment  sludges,.  Sludgea  .md otl.or tannery
 •-•tc.- pri-£1oT.n.inll> arc boir.j disposed directly to the Innd.  Approxliiutely 60 rrrocnt of the r-'->t.cnfi..lly hiixardaun
 «.n-ri «-a:--.es is disposoil in some form of landfill with the remainder (Ucposed Jn trenches or l.igooni.

 stinatea are given for the cost of potentially hazardous waste treatment and disposal for each category of tannery
 nd  for each of  the three levels of treatment and disposal.
17. Key Vords and Document Analysis.  17o. Descriptors


            Leather
            Tanning
            Hazardous  Wastes
            Process  Wastes
          Treatment Technology
          Disposal  Technology
          Landfill
 7b. Identifiers/Open-Ended Terms
                                                                   PUCES  SUBJECT TO CHAKGE
17c. COSATI Field/Group
  REPRODUCED Bf
 NATIONAL TECHNICAL
INFORMATION SERVICE
  U. S. DEPARTMENT OF COMMERCE
     SPRINGFIELD. VA, 22161
18. Availability Statement
     NTIS-SB (RRV. 1O-73I
                       ENDORSED BY ANSI AND UNESCO.
19. Security Class (This
   Report)
                                                 [21. No. of Pages
                                                                    20. Security Class (This
                                                                       Page
                                                                          UNCLASSIFIED
                                                            THIS FORM MAY BE REPRODUCED

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16.  Abstracts

This report, which covers the leather tanning and finishing Industry, 1s one of a series
of studies which examines land-destined waste from selected Industries.   For purposes of
this study, the tanning Industry has been categorized by the types of process solid
wastes generated.  A total of seven different categories were established.

Process solid wastes from the Industry consist primarily of places of leather 1n various
stages of processing and wastewater treatment sludges.  Virtually every tannery waste
stream (except thos In vegetable tanneries) was designated as potentially hazardous.   The
concentration of heavy metals (particularly trlvalerit chromium, lead, copper, and zinc)
were found to be at levels such that the wastes containing these constituents were
considered to be potentially hazardous.  Literature concerning the hazardous nature of
trlvalent chromium was conflicting.  In 1974, tanneries generated approximately 200,000
metric tons of total process solid wastes of which approximately 75 percent was considered
potentially hazardous.

Treatment of tannery wastes Is restricted to the dewaterlng of wastewater treatment sludges,
Sludges and other tannery wastes predominantly are being disposed directly to the land.
Approximately 60 percent of the potentially hazardous tannery wastes Is disposed In some
form of landfill with the remainder disposed 1n trenches or lagoons.

Estimates are given for the cost of potentially hazardous waste treatment and disposal for
each category of tannery and for each of the three levels of treatment and disposal.

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   034
                  LEATHER TANNING AND FINISHING  INDUSTRY



            Assessment of Industrial Hazardous Waste  Practices
 _
CO
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ro
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       This final report  (SW-131c) describes work  performed for  the
                  Federal solid waste management program
                       under contract no. 68-01-3261
             and is reproduced as received from the contractor
                   U.S.  ENVIRONMENTAL PROTECTION AGENCY


                                   1976
                                         Chicago. »L

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This report has been reviewed by the U.S. Environmental
Protection Agency and approved for publication.  Approval
does not signify that the contents necessarily reflect the
views and policies of the U.S. Environmental Protection
Agency, nor does mention of commercial .products constitute
endorsement by the U.S. Government.
                             ii

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                              TABLE OF CONTENTS
        1.0   EXECUTIVE SUMMARY                                1

               1.1  Introduction                               1
                  1.1.1  Coverage                              1
                  1.1.2  Approach                              2
                  1.1.3  Methodology                           2

               1.2  Industry Characterization                  3
                  1.2.1  Magnitude of the Industry             3
                  1.2.2  Geographical Distribution             3
                  1.2.3  Categorization Criteria               5

               1.3  Waste Characterization                     6
                  1.3.1  Process Solid Wastes                  6
                  1.3.2  Potentially Hazardous Wastes         12

t\e             1.4  Treatment and Disposal Technology         15
 '                 1.4.1  Treatment                            15
eg                1.4.2  Disposal                             16
X.                1.4.3  Alternatives to Disposal             18

               1.5  Cost Analysis                             20
                  1.5.1  Treatment                            20
                  1.5.2  Disposal                             20
                  1.5.3  Summary and Discussion               21


        2.0   INDUSTRY CHARACTERIZATION                       29

               2.1  The Tanning Industry                      29
                  2.1.1  Introduction to Tanning              29
                  2.1.2  Background                           3 3
                  2.1.3  Industry Organization and            36
                          Structure
                  2.1.4  Industry Trends and Future           37
                          Developments

               2.2  Approaches to Characterizing Tanneries    40
                  2.2.1  Census of Manufactures               40
                  2.2.2  Production                           4 0
                  2.2.3  Tanning Process                      41
                  2.2.4  Raw Material                         41
                  2.2.5  Industry Categorization              45
                                   iii

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3.0   WASTE CHARACTERIZATION                          49

       3.1  Development of Typical Plants             49
          3.1.1  Approach to Waste Characterization   49

       3.2  Determination of Potentially              52
             Hazardous Waste
          3.2.1  Criteria                             52
          3.2.2  Definition of Potentially            54
                  Hazardous Waste
          3.2.3  Discussions of Hazardous             56
                  Constituents

       3.3  Complete Chrome Tannery                   61
          3.3.1  Plant Operations                     61
          3.3.2  Potentially Hazardous Solid          64
                  Waste
          3.3.3  Non-Hazardous Solid Waste            68
          3.3.4  Factors Affecting Future Solid       68
                  Waste Generation
          3.3.5  Typical Plant Summary                69
          3.3.6  EPA Region and National Waste        69
                  Summary

       3.4  Vegetable Tannery                         80
          3.4.1  Plant Operations                     80
          3.4.2  Process Solid Waste                  80
          3.4.3  Factors Affecting Future Solid       83
                  Waste Generation
          3.4.4  Typical Plant Waste Summary          83
          3.4.5  EPA Region and National Waste        '84
                  Summary

       3.5  Sheepskin Tannery                         84
          3.5.1  Plant Operations                     '84
          3.5.2  Potentially Hazardous Solid          86
                  Waste
          3.5.3  Non-Hazardous Solid Waste            88
          3.5.4  Factors Affecting Future Solid       88
                  Waste Generation
          3.5.5  Typical Plant Waste Summary          89
          3.5.6  EPA Region and National Waste        89
                  Summary
                            iv

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 3.6   Split  Tannery                              94
    3.6.1  Plant  Operations                      94
    3.6.2  Potentially  Hazardous  Solid          94
            Waste
    3.6.3  Non-Hazardous  Solid Waste             97
    3.6.4  Factors Affecting Future Solid       97
            Waste Generation
    3.6.5  Typical Plant  Waste Summary          98
    3.6.6  EPA Region and National Waste         98
            Summary

 3.7   Leather Finishers                          98
   3.7.1  Plant  Operations                      98
   3.7.2  Potentially Hazardous  Solid          98
            Waste
   3.7.3  Non-Hazardous  Solid Waste            104
   3.7.4  Factors Affecting Future Solid      104
            Waste Generation
   3.7.5  Typical Plant  Waste Summary         105
   3.7.6  EPA Region and National Waste        105
            Summary

 3.8   Beamhouse/Tanhouse  Facilities             110
   3.8.1  Plant  Operations                     HO
   3.8.2  Potentially Hazardous  Solid         HO
            Waste
   3.8.3  Non-Hazardous  Solid Waste            112
   3.8.4  Factors Affecting Future Solid      H2
            Waste Generation
   3.8.5  Typical Plant Waste Summary         H3
   3.8.6  EPA Region and National Waste        113
            Summary

3.9  Retan/Finishers                           117
   3.9.1  Plant Operations                     117
   3.9.2  Potentially Hazardous Solid          H7
           Waste
   3.9.3  Non-Hazardous Solid Waste            120
   3.9.4  Factors Affecting Future Solid       120
           Waste Generation
   3.9.5  Typical Plant Waste Summary          121
   3.9.6  EPA Region and National Waste        121
           Summary

3.10 State and EPA Regional and  National       129
      Waste  Quantities

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4.0   TREATMENT AND DISPOSAL TECHNOLOGY              135

       4.1  Introduction                             135
          4.1.1  In-Plant Management                 135
          4.1.2  Collection and Hauling              135
          4.1.3  Treatment and Disposal              136

       4.2  Present Treatment and Technologies       137
          4.2.1  Non-Mechanical Devatering           137
          4.2.2  Mechanical Devatering               137

       4.3  Present Disposal Technologies            138
          4.3.1  Open Dumping                        138
          4.3.2  Landfilling                         139
          4.3.3  Certified Hazardous Wast*           141
                  Disposal Facilities
          4.3.4  Disposal in Lagoons, Trenches*      142
                  Pits, and Ponds
          4.3.5  Agricultural Spreading              142

       4.4  Alternatives to Disposal                 143
          4.4.1  Municipal Sewage Treatment          143
          4.4.2  Source Reduction Through In-Plant   144
                  Process Change
          4.4.3  Sale as By-Products                 145

       4.5  Approach to the Selection of Treatment   147
             and Disposal Technologies
          4.5.1  Technology Levels                   147
          4.5.2  Treatment                           147
          4.5.3  Disposal                            148
          4.5.4  Outline of Subsequent Sections      148

       4.6  Treatment and Disposals   Complete        149
             Chrome Tanneries
          4.6.1  Treatment                           149
          4.6.2  Disposal                            151

       4.7  Treatment and Disposals   Sheepskin       151
             Tanneries

       4.8  Treatment and Disposals   Split           152
             Tanneries

       4.9  Treatment and Disposals   Leather         154
             Finishers
                           vi

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                                                     Page

       4.10  Treatment and Disposal:   Beamhouse/     157
              Tanhouse Facility
          4.10.1  Treatment                          157
          4.10.2  Disposal                           159

       4.11  Treatment and Disposal:   Retan/         159
              Finishers

       4.12  Treatment and Disposal Technologies     161
              and Waste Quantity Summary
5.0   COST ANALYSIS                                  165

       5.1  Bases and Criteria for Cost              165
             Estimation
          5.1.1  Capital Costs                       165
          5.1.2  Interest Costs                      165
          5.1.3  Time Index for Costs                167
          5.1.4  Useful Service Life                 167
          5.1.5  Depreciation                        167
          5.1.6  Operating Expenses                  167

       5.2  On-Site Waste Treatment                  167

       5.3  Off-Site Disposal                        168

       5.4  Treatment and Disposal Costs             168

       5.5  Variables Effecting Treatment and        181
             Disposal Costs
          5.5.1  Size                                181
          5.5.2  Processing Operations               181
          5.5.3  Location                            181
          5.5.4  Method of Dewatering Sludge         182

       5.6  Sample Cost Calculation                  182
          5.6.1  Level I Technology                  182
          5.6.2  Level II Technology                 184
          5.6.3  Level III Technology                184


6.0   REFERENCES                                     187


7.0   ACKNOWLEDGEMENT S                               191
                          vii

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                                                     Page

8.0   GLOSSARY                                       193


9.0  APPENDICES                                      197

      A   Alphabetical Listing of Establishments     199
           in the Leather Tanning and Finishing
           Industry

      B   Outline of Procedures for Field Visits,     213
           Sample Collection*  and Sample Analysis

      C   Private Disposal Sites Accepting           229
           Tannery Waste

      D   Methodology for Projecting Waste           231
           Quantities on a State, EPA Regional,
           and National Basis
                            viii

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                        LIST OF TABLES
Table                                                   Page
   1        Total Process and Potentially Hazardous        8
           Solid Waste Generated by All Types of
           Tanneries in 1974
   2        Total Process and Potentially Hazardous        9
           Solid Waste Generated by All Types of
           Tanneries in 1977 (Projected)
   3        Total Process and Potentially Hazardous       10
           Solid Waste Generated by All Types of
           Tanneries in 1983 (Projected)
   4        Potentially Hazardous Tannery Wastes          14
   5        Treatment and Disposal Technology Levels      17
           and Associated Potentially Hazardous
           Waste Quantities
   6        Summary of Treatment and Disposal Costs       22
           for the Typical Tanneries
   7        Annual Treatment and Disposal Costs           26
   8        1974 Tannery Production by State              35
   9        Distribution of Tanneries by Size             42
 10        Distribution of Tanneries by Tanning          43
           Process
 11        Distribution of Tanneries by Raw              44
           Material
 12        Distribution of Tanneries by Category         48
 13        Geometric Mean Compositions,  and              55
           Geometric Deviations,  of Samples of
           Soils and Other Surficial Materials
           in the Conterminuous United States
 14        Potentially Hazardous Tannery  Wastes           57
 15        Summary of Toxicity-Related Information       58
           for Chromium (III),  Lead,  Zinc,  and
           Copper
                            ix

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Table                                                   Page

  16        Trivalent Chromium Toxicity to Aquatic        62
           Organisms

  17        Haste Generation Factors for a Complete       70
           Chrome Tannery

  18        Total Process and Potentially Hazardous       71
           Waste Generated in 1974 by Complete
           Chrome Tanneries

  19        Total Process and Potentially Hazardous       74
           Waste Anticipated to be Generated in
           1977 by Complete Chrome Tanneries

  20        Total Process and Potentially Hazardous       77
           Waste Anticipated to be Generated in
           1983 by Complete Chrome Tanneries

  21-       Total Process and Potentially Hazardous       85
           Waste Generated by Vegetable Tanneries

  22        Waste Generation Factors for a Typical        90
           Sheepskin Tannery

  23'       Total Process and Potentially Hazardous       91
           Waste Generated in 1974 by Sheepskin
           Tanneries

  24        Total Process and Potentially Hazardous       92
           Waste Anticipated to be Generated in
           1977 by Sheepskin Tanneries

  25        Total Process and Potentially Hazardous       93
           Waste Anticipated to be Generated in
           1983 by Sheepskin Tanneries

  26        Waste Generation Factors for a Typical.        99
           Split Tannery

  27        Total Process and Potentially Hazardous      100
           Waste Generated in 1974 by Split
           Tanneries

  28        Total Process and Potentially 'Hazardous      101
           Waste Anticipated -to be Generated in
           1977 by Split Tanneries

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Table

 29        Total Process and Potentially Hazardous
           Waste Anticipated to be Generated in
           1983 by Split Tanneries

 30        Waste Generation Factors for a Typical       106
           Leather Finisher

 31        Total Process and Potentially Hazardous      107
           Waste Generated in 1974 by Leather
           Finishers

 32        Total Process and Potentially Hazardous      108
           Waste Anticipated to be Generated in
           1977 by Leather Finishers

 33        Total Process and Potentially Hazardous      109
           Waste Anticipated to be Generated in
           1983 by Leather Finishers

 34        Total Process and Potentially Hazardous      114
           Waste Generated in 1974 by Beamhouse/
           Tanhouse Facilities

 35        Total Process and Potentially Hazardous      115
           Waste Anticipated to be Generated in
           1977 by Beamhouse/Tanhouse Facilities

 36        Total Process and Potentially Hazardous      116
           Waste Anticipated to be Generated in
           1983 by Beamhouse/Tanhouse Facilities

 37        Waste Generation Factors for a Typical       122
           Retan/Finisher

 38        Total Process and Potentially Hazardous      123
           Waste Generated in 1974 by Retan/
           Finishers

 39        Total Process and Potentially Hazardous      125
           Waste Anticipated to be Generated in
           1977 by Retan/Finishers

 40        Total Process and Potentially Hazardous      127
           Waste Anticipated to be Generated in
           1983 by Retan/Finishers

 41        Total Process and Potentially Hazardous     130
           Solid Waste Generated by All  Types of
           Tanneries in  1974

                              xi

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                                                      Page
         Total Process and Potentially Hazardous      131
         Solid Haste Generated by All Types of
         Tanneries in 1977 (Projected)

43       Total Process and Potentially Hazardous      132
         Solid Waste Generated by All Types of
         Tanneries in 1983 (Projected)

44       Treatment and Disposal Technology Levels     150
         for Complete Chrome Tannery

45       Treatment and Disposal Technology Levels     153
         for Sheepskin Tannery

46       Treatment and Disposal Technology Levels     155
         for Split Tannery

47       Treatment and Disposal •technology Levels     156
         for Leather Finishers

48       Treatment and Disposal Technology Levels     158
         for Beamhouse/Tanhouse Facility

49       Treatment and Disposal Technology Levels     160
         for Retan/Finishers

50       Treatment and Disposal Technology Levels     162
         and Associated Potentially Hazardous
         Waste Quantities

51       Bases and Criteria for Cost Estimation       166

52       Contractor Hauling and Disposal Costs        169

53       Treatment and Disposal Costs - Typical       171
         Complete Chrome Tannery Without
         Primary and/or Secondary Wastewater
         Treatment

54       Treatment and Disposal Costs - Typical       I7'2
         Complete Chrome Tannery With Primary
         and/or Secondary Wastewater Treatment

55       Treatment and Disposal -Costs - Typical       173
         Sheepskin Tannery

56       Treatment and Disposal Costs - Typical       174
         Split Tannery
                             xii

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Table                                                   Page

 57        Treatment and Disposal Costs  - Typical       175
           Leather Finisher

 58        Treatment and Disposal Costs  - Typical       175
           Beamhouse/Tanhouse Facility

 59        Treatment and Disposal Costs  - Typical       177
           Retan/Finisher

 60        Annual  Treatment and Disposal Costs          180
                             xiii

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                        LIST OF FIGURES

Figure                                                  Pag*
  1              Distribution of Tanneries                4
  2              Potentially Hazardous Solid             11
                 Waste Generated in 1974
  3              Typical Tanning Process Steps           30
  4              Example of Wastestream Matrix           51
  5              Process Flow Diagram - Typical          63
                 Complete Chrome Tannery
  6              Process Flow Diagram - Typical          81
                 Vegetable Tannery
  7-              Process Flow Diagram - Typical          87
                 Sheepskin Tannery
  8              Process Flow Diagram - Typical          95
                 Split Tannery
  9              Process Flow Diagram - Typical         103
                 Leather Finisher
 10              Process Flow Diagram - Typical         111
                 Beamhouse/Tanhouse
 11              Process Flow Diagram - Typical         118
                 Retan/Finisher
                              xiv

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                           SECTION  1.0

                        EXECUTIVE SUMMARY


                        1.1  Introduction

      This  industry  study is  one of a series  by the Office
 of  Solid Waste Management  Programs, Hazardous  Waste
 Management Division.  The  studies  were  conducted for
 information purposes only  and not  in response  to a Congressional
 regulatory mandate.  As such, the  studies  serve to provide
 EPA with:   (1) an initial  data base concerning current  and
 projected  types and quantities of  industrial wastes and
 applicable disposal methods  and costs;  (2) a data base  for
 technical  assistance activities; and (3) as  background  for
 guidelines development work  pursuant to Sec. 209,  Solid
 Haste Disposal Act, as amended.
      The definition of  "potentially hazardous  waste"  in this
 study was  developed based  upon contractor  investigations and
 professional judgment.  This definition does not necessarily
 reflect EPA thinking since such a  definition,  especially in
 a regulatory context, must be broadly applicable to widely
 differing  types of waste streams.  Obviously,  the  presence
 of  a  toxic substance should not be the  major determinant of
 hazardousness if there were mechanisms  to  represent or
 illustrate actual effects of wastes in  specific  environments.
 Thus, the  reader is cautioned that the  data  presented in
 this  report constitute only the contractor's assessment of
 the hazardous waste management problem  in  this  industry.  EPA
 reserves its judgments pending a specific  legislative
 mandate.

      1.1.1  Coverage.  Process solid waste in the  leather
 tanning and finishing industry is the subject of this study.
 The tanning industry is designated by SIC  3111.  Relevant
 to this study are those establishments within SIC  3111  with
 production facilities.
     Process solid wastes  (including liquid  sludges) are
 generated directly as a result of production operations and
 destined for land disposal.  Thus,  solid waste associated
with in-plant storage or movement of material,  e.g., broken
pallets, general office waste,  and  cafeteria waste, was not
a part of the project.  Similarly,  wastewater and air emissions
were not included;  however, solids  resulting from wastewater
pretreatment or treatment and residues  collected by air
pollution control devices were included if disposed to the
land.

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      1.1.2  Approach.  Specific tasks of the project were
 as follows:

         Characterize the industry in terms of number, size,
         and location of plants.
         Determine the types, quantities, and sources of
         total process solid wastes and potentially hazardous
         wastes currently generated by tanneries and project
         quantities for 1977 and 1983.
         Sample and analyze the solid waste to determine the
         presence and concentration of potentially hazardous
         constituents.
      .   Define potentially hazardous solid wastes applicable
         to the tanning industry,  and characterize the process
         waste streams as non-hazardous or potentially
         hazardous using the definition.
         Identify current and potential future methods of
         treatment and disposal for the potentially hazardous
         solid wastes and describe three technology levels:
             Level I—most commonly used current technology.
             Level II—best current technology in full-scale
             operation
             Level III—technology necessary to provide
             adequate health and environmental protection.
         Estimate the costs of potentially hazardous waste
         treatment and disposal"for the industry.

      1.1.3   Methodology.   The collection of information
necessary to meet the above objectives required field visits
to various  tanneries and the collection  and analysis of solid
waste samples.   Field visits to disposal sites serving tanneries
were  also an integral part of the  project.   Tanneries were
selected on the  basis that they represented the major types
of tanning  operations carried on  in  this country  and thus
generated solid  wastes typical of  the  industry.
      Field  visits to tanneries were  conducted  by  staff
personnel,  sometimes augmented by  industry  or  EPA officials.
During the  visits, waste management  information was  collected
utilizing standardized data collection forms.   Production
operations  were  examined,  and solid waste samples  were
collected at  selected tanneries.  The  samples were shipped
to a  laboratory  for  analysis.   Land disposal sites were
visited whenever  possible.  A total of 23 sites which  receive
tannery  solid wastes  were  visited.  Often tanneries were
selected for visits  because they were known to  have advanced
treatment technology  or unique disposal methods.   A total
of 41 tanneries were  visited  during the project.   They
represented 14 percent of  the plants in the industry and nearly
50 percent of the industry's  production nationwide.

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                 1.2   Industry  Characterization

      1.2.1  Magnitude of the Industry.   The  total number of
 establishments  in  the leather  tanning and finishing industry
 is  298.  According to the U.S.  Bureau of the Census,  there are
 517 establishments in the leather  tanning and finishing
 industry, SIC 3111.x   However,  many  of  the establishments
 included in the Census report  have no actual leather
 processing facilities, and therefore were not included as a
 part of the study.    For purposes  of this study,  the  following
 types of facilities have been  eliminated from the Census
 figures:

        Converters.
        Double  entries.
        Hobbyists  and taxidermists.
        Other nonproduction establishments.

      Most of the tanneries in  this country are relatively
 small, family owned businesses.  Employment  ranges from 5
 to  500, and production ranges  from less  than 200  hides per
 day to over 2,600  hides per day.2  The Bureau of  the  Census
 reports the value  of  industry  shipments  in 1967 as $846 million
 and in 1972 as  $1,026  million.1  The  Tanners'  Council of
 America estimates  1974 value of shipments at $1,026 million.
      The sum of the production  for all types of tanneries
 in  1974 is estimated  at 35.7 million  equivalent hides.2  This
 is  the total of all hides put  into production by  all  categories
 of  tanneries.   Total  output production for 1974 was
 approximately 20 million equivalent hides.2   The  difference
 is  due to the fact that hides may be  counted twice.   A single
 hide  put into production at a tannery is  usually  split
 (sliced through its thickness)  after  partial processing.
 This  yields two pieces of leather, a  grain side and a split.
 The grain side  may be  sent to a leather  finisher   where it is
 also  counted as input.  The split  is  sent to a  split  tannery
 where  it is counted as input.  Input  production is  used
 throughout this report.

      1.2.2  Geographical Distribution.  Tanning is  one of
 the oldest industries  in this country, beginning  in the New
 England and Middle Atlantic States (EPA Regions I,  II,  and III)
 during colonial times.  The greatest  concentration  of  tanneries
 is  still found  in these areas.   During the 19th and 20th
centuries,  tanneries have tended to follow the  source  of  their
 raw materials—cattlehides.   This gave rise  to  the  location
 of  tanneries west of the Mississippi  River.  Currently,
 there are tanneries in 34 states.   Figure  1  illustrates the
 geographical distribution of tanneries in the nation.  As
 shown, approximately 30 percent of all tanneries are  located
 in New York (EPA Region II)  and Massachusetts  (EPA  Region  I),
 and 85 percent of all tanneries are located east of the
Mississippi River.

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                            FIGURE 1



                    DISTRIBUTION OF TANNERIES
States Containing No Tanneries

-------
      1.2.3   Categorization Criteria.  A  combination  of
 criteria was used to categorize the tanning  industry with
 respect to  its  total process  solid waste and potentially
 hazardous solid waste generation.  Major differences are
 apparent between the two predominant  types of tanning
 processes—chrome tanning and vegetable  tanning.  Within
 the  chrome tanning category,  processing  differences  based
 upon the raw material  (type of hide or skin)  used and the
 type of finished leather produced yielded additional
 categories.  A  major operation conducted on  a contract
 basis is the finishing of leather.  No actual tanning is
 conducted by these establishments, and thus  finishing is
 another tannery category.
      Trends  in  the industry were also taken  into account in
 the  establishment of industry categories.  Recently,
 operational  changes in the most common type  of tannery
 (complete chrome) have given  rise to  the  development of
 two  new types of operations:  the beamhouse/tanhouse facility
 and  the retan/finisher.  Essentially, these  are the  operations
 carried on in a complete chrome tannery with the processing
 of the hides through the tanning operation conducted in the
 beamhouse/tanhouse facility and the processes from retan
 through leather finishing conducted by the retan/finishers.
 Although these  operations have been in existence for less
 than 20 years,  they already account for about 10 percent of
 the  total production in this  country.    It is expected that
 this  trend will continue.
      In summary, the following industry categories were
 developed for purposes of this study.
     Category

Complete chrome tannery



Vegetable tannery



Sheepskin tannery




Split tannery
            Rationale

The most common  type of  tanning
operation  in the United  States;
includes the chrome tanning of
cattlehides and  pigskins.
The absence of chromium  and other
heavy metals in  tanning  and
processing hides is unique to this
segment of the industry.
The importation  of partially
processed sheepskins and unique
sequence of processing yields
waste streams notably different
from the complete chrome tannery.
Specialized operations on
previously tanned hides produce
waste streams with higher
generation rates than found in
complete chrome  tanneries and the
lack of finishing operations
eliminates one or more waste
streams.

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     Category                           Rationale

Leather  finisher            Usually a contract operation
                            specializing  in the  finishing of
                            leather with  no tanning  facilities.
                            Finishers normally have  only
                            one or two of the waste  streams
                            found in the  complete chrome
                            tannery.
Beamhouse/tanhouse          The two "halves" of  the  complete
  facility  and               chrome tannery.  A trend towards
Retan/finisher              separating tanning operations
                            geographically with  partial
                            processing near the  source of the
                            raw material  and completion in
                            another location gives rise to
                            these two categories.

                  1.3  Waste Characterization

     1.3.1 Process Solid Wastes.  Pieces of leather (containing
10 to 50 percent moisture) in various stages of  processing,
and wastewater treatment sludges constitute the  bulk of the
process  solid wastes from tanneries.  In  order to produce the
quality  products required by leather consuming  industries,
tanneries  trim off inferior portions of hides at many
steps in processing.  Smaller pieces of leather wastes are
produced in shaving and buffing operations.  Approximately
35 percent of all tannery solid waste is  trimmings and
shavings of various types.
     Another source of tannery wastes is  the finishing
department.  Finishes are sprayed or rolled onto leather
and the residue is considered to be a solid waste since it is
land disposed.  Finish residues are usually slurries containing
10 to 50 percent solids.  Waste finishes  account for about 2
percent of tannery solid waste.
     Wastewater treatment is the single largest  source of
process solid waste.  Almost all tanneries screen their
wastewater.  Direct dischargers and some discharging wastewater
into municipal sewers have some form of primary or secondary
treatment  (only direct dischargers use secondary treatment).
The screenings and sludges from these operations contain lime,
chromium compounds, pieces of leather, hair,  and other
protein-like substances which are land disposed.  Wastewater
screenings and sludge account for about 60 percent of tannery
solid waste.
     Floor sweepings are the final source of process solid
waste.   These include twine used to tie bundles of hides,
salt used  to preserve the hides prior to tanning, and general
plant debris.  Approximately 3 percent of tannery solid waste
is floor sweepings.

-------
     Tables  1 through 3 provide estimates of  the  state,
EPA Region,  and national quantities of tannery  process solid
waste destined for land disposal.  The data presented is
based on the quantity of solid waste generated  at the 41
tanneries visited  (in units of kg per equivalent  hides).
Data for states with less than three tanneries  has been
combined in  order to protect the confidentiality  of production
information.
     As shown in Table 1, more tannery process  solid wastes
and potentially hazardous solid wastes are generated in
Massachusetts than in any other state, followed by Wisconsin
and New York.  Similarly, approximately one-half  of the
total process and potentially hazardous solid waste generation
occurs in EPA Regions I and V.  Minor amounts of  solid waste
are generated in EPA Regions VI, VIII, and X.  In  most states,
the potentially hazardous solid waste generated represents
about 90 to  95 percent of the total process solid waste.
Significant  exceptions ot this pattern occur  in states such
as Pennsylvania, Georgia, Kentucky, and Virginia,  where most
or all of the production occurs in vegetable  tanneries.  As
discussed below, vegetable tanneries do not generate  potentially
hazardous solid waste.
     Figure  2 diagramatically shows the relative  quantity of
potentially  hazardous waste currently (1974)  generated in
each state.  As indicated, Massachusetts and  Wisconsin are the
only states  which generate more than 20,000 metric tons per
year, and California,  New York, and Maine are the only three
states which generate between 10,000 and 20,000 metric tons
per year.  Tennessee is the only southern state (EPA Regions
IV and VI)  which generates more than 1,000 metric tons per
year.  West  Virginia,  Georgia, and Indiana have only vegetable
tanneries and therefore do not generate potentially hazardous
solid waste.
     Tables  2 and 3 show the distribution by  state of total
process and  potentially hazardous waste generation projected
for 1977 and 1983, respectively.  As indicated, waste generation
is projected to increase gradually through 1983 in all states
except those with a large proportion of vegetable tanneries.
This trend is anticipated since production of chrome tanned
cattlehides  and pigskins is expected to increase,  while
vegetable tanned and sheepskin leather production is expected
to decline.  In addition, the proportion of total  process
solid waste which is potentially hazardous is projected to
increase slightly as a result of increasingly stringent
wastewater pretreatment and  direct discharge  standards.   Most
new wastewater treatment facilities are projected  to be installed
at complete chrome tanneries and beamhouse/tanhouse facilities.
Consequently, increases in the portion of total process solid
waste which  is potentially hazardous will be most  notable
in states with a high proportion of other types of tanneries
(vegetable tanneries,  leather finishers,  etc.), such as
Pennsylvania.

-------
                            TABLE 1
      TOTAL PROCESS AND POTENTIALLY HAZARDOUS SOLID WASTE
          GENERATED BY ALL TYPES OF TANNERIES IN 1974
            (metric tons per year, wet and dry basis)
State (s)
AK.WA
AZ.CA
CO.OT
DE
PL,GA
IL
IN, OH
**•"*
KY
LA.TX
ME,VT
ND,VA,WV
MA
MI
MN
MO
NH
NJ
NY
NC
OR
PA
TN
WI
Total
Region I
II
III
IV
V
VI
VII
VIII
IX
X
"reduction
(thousands of
equivalent hides)
28
1.870
221
230
169 H
1.631
20C
512
4:
11
7
17
2.630
1.150
8.273
1.147
898
774
1.670
1.340
4.020
21
-1
115
: .860
: .230
- .980
35,700

«!r17fl
1-740
2-040

1
107
1 ,99
n
•>•»!
1 B70
. 143
Total
Process
Solid
Waste
Wet
192
13,200
2.09
64

<
1,950
7.500
1,390
4.69
5,48
,i
!'
845
13,160
14, ;i
31. !(
7.(i
6,' :
7,87
10,11
3,41




)
)
)
16,20)
2.42
90
i

16,00)
8.43.
25,901


203,000
55,100
19,700
31,000
18,300
49,100
846
12.570
2.090
13,200
1.100
Or/.
61
4.380
562
212
442
2.490
332
2. 25(
1.2l(
22*
< .430
; .iso
isIooO
2,49(
1.98C
2,030
3.370
1.130
5.650
238
262
4.2K
2!38(
6,500
65,000
20,800
6,780
71600
4,270
15,800
227

562
4,380
322
Total
Potentially
Hazardous
Wastes
Wet
177
12,200
2r02*
SH
61
6.900
1S4
4.560
6
626
11,260
• Ui
29.600
7,250
S[980
7,380
9.266
3,1!IO
14;CI>0
3
600
5,570
4.620
23.800
151,000
50,100
17.800
6I290
4.680
44.100
626
11.900
2,020
12,200
777
Dry
48
3.620
49fi

18
2.066
51
I,lo6
0

3,420
3!
11.201
1,97' i
1,596
l!666
2,716
185
4,' 20
1
163
l.S8(
1.28C
6.730
45,200
17,300
s.2:c

!^3i^
12,: oo
:.Ss
2.770
49i "
3.626
211





























Source:
Note:
  SCS Engineers, except production information,which
  is from Tanners' Council of America.

Totals may not add due to rounding.
Production is based on the sum of all hides put into
processing at all seven types of tanneries.
                             8

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                            TABLE 2
    TOTAL PROCESS AND POTENTIALLY HAZARDOUS SOLID WASTE
GENERATED BY ALL TY?ES OF TANNERIES IN 1977 (PROJECTED)
        (metric tons per year,  wet and dry basis)
•••••— ^M~W«^^^^
State (s)
AK.WA
AZ.CA
CO.UT
DE
FL.GA
IL
IN, OH
IA,NE
KY
LA,TX
MEjVT
HD,VA,WV
MA
MI
MN
MO
NH
NJ
NY
NC
OR
PA
TN
WI
Total
Region I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Process
Solid
Waste
Wet
215
14,900
2.581
717
1,840
8,350
1,340
5,840
5^150
908
14,400
13,500
34,600
8,790
7,320
9,600
11,100
3,980
17,600
2,280
964
16,100
8,850
29,300
220,000
60,100
21,600
30,300
18,100
55,100
908
15,440
2,580
14,900
1,180
Dry
68
4,920
689
232
417
2,750
321
1,530
1,140
258
4,600
3,000
14,100
2,760
2,230
2,470
3,700
1,280
6,110
505
281
4,290
1,840
9,550
69,100
22,450
7,390
7,520
3,900
17,600
258
4,000
689
4,920
349
Total
Potentially
Hazardous
Wastes
Wet
220
13,700
2,528
625
68
• 7,440
225
5,700
0
768
12,300
165
33,900
8,040
7,050
8,660
10,300
3,920
17,000
3
749
6,860
5,740
27,500
173,000
56,500
21,400
7,750
5,810
50,250
768
14,400
2,540
13,700
969
Dry
54
4,100
612
180
19
2,240
56
1,380
0
188
3,610
40
12,200
2,210
1,820
2,080
3,000
1,020
5,030
1
183
1,780 .
1,430 ;
7,640
51,000
18,800
6,050
2,000
1,450
14,000
188
3,460
612
4,100
237
         Source:  SCS Engineers

         Note:  Totals may'not add due to rounding.

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                            TABLE 3

  TOTAL PROCESS AND POTENTIALLY HAZARDOUS SOLID WASTE
GENERATED BY ALL TYPES OF TANNERIES IN 1983 (PROJECTED)
       (metric tons per year,  wet and dry baaia)
State (s)
AK.HA
AZ,CA
CO.UT
DE
FL,GA
IL
IN, OH
IA,NE
KY
LA,TX
ME,VT
MD,VA,WV
HA
MI
MN
NO
NH
NJ
NY
NC
OR
PA
TN
WT
Total
Region I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Process
Solid
Waste
Wet
287
20,200
4,000
943
1,750
11,100
1,344
9,130
4,870
. 1,350
18,600
12,800
43,300
11,700
10,100
14,600
14,500
5,570
22,900
2,150
1, 200
17,800
10.600
40 100
281,000
76,600
28,500
31,500
19,400
.74,300
1,350
23,700
4,000
20,200
1,490
Dry.
89
6,540
1,053
298
382
3,580
317
2,390
1,030
356
5,860
2,260
17,100
3,640
3,020
3,780
4,720
1,720
7,690
457
348
4,7?0
3,010
12.800
87,700
27,700
9,410
7,800
4,800
23,400
356
6,170
1,060
6,540
437
Total
Potentially
Hazardous
Wastes
Wet
269
19,100
3 a or

77
9,670
269
8,890
0
1,160
17,500
200
24,100
11,000
9,550
13,600
13,700
5,240
21,100
2
912
8,400
7,010
37.60Q
214,000
55,300
26,300
9,480
7,090
68,100
1,160
22,500
3,890
19, 100
1,180
Dry
75
5.600
MS
243
22
3,020
75
2,140
0
283
4,830
55
15,100
3,040
2,560
3,270
3,980
1,440
6,260
1
252
2,410
1,960
10.600
68,200
23,900
7,700
2,700
1,980
19.300
283
5,410
950
5,600
326
        Source:  SCS Engineers

        Note:  Totals may not add due to rounding.
                             10

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                                       FIGURE  2


                  POTENTIALLY  HAZARDOUS SOLID  WASTE  GENERATED  IN  1974
Legend (metric tons/yr
        wet weight basis)
       0
    0-1,000

    1,000-10,000
10,000-20,000

20,000-30,000

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      It is also worth noting  that  a comparison  of  Figure  1
 and 2 indicates a general  correlation between the  number  of
 tanneries  in a state and the  quantity of  potentially
 hazardous  solid wastes generated.  Variations from this
 general relationship occur principally  due  to concentrations
 of vegetable tanneries (which do not generate potentially
 hazardous  wastes)  and leather finishers (which  generate
 relatively small amounts of potentially hazardous  wastes),
 e.g.,  Pennsylvania and New York.
      Chromium (III)  is by  far the  most  abundant potentially
 hazardous  constituent found in tannery  wastes.  Lead, copper,
 and zinc are also present  in  the wastes.  Estimates of the
 nationwide total quantities of these heavy  metals  generated
 in tannery wastes is shown below:

                         Potentially hazardous  constituents
                              (metric tons  per  year)
                         Chromium  (III)   Zinc   Lead Copper

      1974                     909         0.46   10.6  16.9
      1977                   1,000         0.59   11.9  19.6
      1983                   1,300         0.94   14.7  28.0

      1.3.2  Potentially Hazardous  Wastes.   "Potentially
 hazardous  wastes"  are defined as wastes or  combinations of
 wastes, which  pose a substantial present  or potential future
 hazard  to  human health or  living organisms  because  such
 wastes  are lethal,  non-degradable, or persistent in nature;
 may be  biologically magnified; or  otherwise cause or tend
 to cause detrimental cumulative effects.3
     Many  of the substances of particular concern  in this
 study,  primarily heavy metals, are prerequisites to life  in
 trace quantities,  but are  toxic at higher concentrations.
 The uncertainty and  confusion about what concentration levels
 are hazardous  arises because:

        In the  complete absence of certain  elements, life
        cannot exist.
      .  There  is a vaguely defined intermediate concentration
        range  in which these  substances are essential and/or
        can  be  tolerated.
        There  is a higher  level above which chronic and
        acute toxicity may result.

     Definition  of Potentially Hazardous Haste.   Scientific
 studies of  the environmental  fate of tannery wastes following
 land disposal have not been conducted,  and  in many  instances
 the chemical structure of  tannery solid waste is not well
understood.  As  a result,  it was necessary to select a
                              12

-------
 recognized reference for identifying the concentration level
 above which the presence of a hazardous constituent in
 tannery waste makes the waste potentially hazardous.  As
 a guide as to what constitutes potentially hazardous
 concentration levels in wastes destined for land disposal,
 the geometric means of the background concentration levels
 in soils in the United States of the toxic heavy metals
 found in tannery wastes were used as the reference datum.4
      Using this definition in conjunction with analyses of
 tannery waste samples, the types of tannery wastes which
 should be considered potentially hazardous were identified.
 Table 4 lists the various types of potentially hazardous
 wastes; the hazardous constituents present in each type
 at concentration levels above the mean concentration in
 soils; the results of tannery waste sampling and analyses;
 and the relevant background soil values.   As shown, four types
 of tannery waste were identified which contain four hazardous
 constituents at potentially hazardous concentration levels,
 one type of waste with three hazardous constituents, one
 type of waste with two hazardous constituents,  and two types
 of waste with a single hazardous constituent.   Analyses were
 made for other heavy metals,  pesticides,  and phenols;  however,
 none were found at potentially hazardous  concentrations.
      Several types of wastes which are not considered
 potentially hazardous were also identified.   Plant floor
 sweepings and related miscellaneous solid waste were found
 to be non-hazardous in all types of tanneries.   In vegetable
 tanneries,  all types of solid waste generated are  considered
 non-hazardous since hazardous constituents were not found
 at concentrations  above the  mean soil  concentration.   For
 example,  copper was found  at  an average concentration  of
 13.4  ppm (dry weight)  in wastewater  treatment residues from
 four  vegetable  tanneries,  whereas  the  geometric mean
 concentration in U.S.  soils  is  18  ppm  (dry weight).

      Discussion of  Potentially  Hazardous Wastes.   Although
 the environmental effects  of  lead,  zinc, and copper are
 not completely  understood, the  phototoxicity of zinc and
 copper  to agricultural  crops, the  toxicity  of lead to  man,
 and the  toxicity of all three elements to various  aquatic
 organisms, is well established.
      The only  form of chromium of  concern and interest in
 this  study is trivalent chromium,  since other forms of
 chromium are not used in the production of leather.  The
 toxicological information on trivalent chromium, however,  is
 conflicting.  Some information is available on  the
 effects of trivalent chromium on plants which generally
 indicates that low concentrations of trivalent  chromium may
 be essential, or possibly even beneficial, whereas higher
 concentrations may be toxic.  The effects vary with species
 and with the specific chromium compound.  The effects on
plant growth of adding chromium to the soil depend upon the

                               13

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                                           7&3LE  4


                            POTENTIALLY HAZARDOUS TANNERY WASTES
                                               Analytical Results
Waste Stream
Ho. of
Sample*
 Hazardous
Constituent*
Concentration
 (wot weight-
    •g/lcg)
                                                               Concentration
                                                                    Range*•
                                                                 (wet weight-
                                                                    s/kg)
                                            Geometric Mean
                                            Concentration in
                                            U.S. Soils (dry
                                            weight-mg/kg)
Chrome (blue)           10
 trimmings «
 shavings

Chrome fleshings         1

Unfinished chrome        9
 leather trim
Buffing dust            12
Finishing residues      16
Finished leather
 trim
                 ,+3
Cr

Cr
Cu
Pb
Za

Cr*3
Cu
Pb
Za

Cr+3
Cu
Pb
Za
               Cr
               Pb
                                      .+3
                              7,«00
                  4,000

                 16,900
                     90
                    120
                     60

                  5.700
                    960
                    ISO
                    160

                  3,300
                     40
                  8,400
                    ISO'

                 14,800
                  1,000
                               2,200-21,000
                                           4,600-37,000
                                             2.3-468
                                             2.5-476
                                             9.1-156

                                              19-22,000
                                              29-1,900
                                               2-924
                  0.45-12.000
                  0.35-208
                   2.5-69,200
                    14-876

                 1,600-41,000
                   100-3,300
                                                                                      37
                                                                                      37

                                                                                      37
                                                                                      18
                                                                                      16
                                                                                      44

                                                                                      37
                                                                                      18
                                                                                      16
                                                                                      44

                                                                                      37
                                                                                      18
                                                                                      16
                                                                                      44

                                                                                      37
                                                                                      16
Sewer screenings
  17
                                     Pb
                                     Sa
                  2,200
                     30
                     60
                  0.27-14,000
                     2-110
                    35-128
                                                                                      37
                                                                                      16
                                                                                      44
Wastewater treatment    27
 residues (sludges)
                                     Cr
                                     Cu
                                     Pb
                                     Zn
                                       +3
                              3,700
                                370
                                 60
                                 50
                                0.33-19,400
                                0.12-8,400
                                0.75-240
                                 1.2-147
                                      37
                                      18
                                      16
                                      44
Sourcet  Laboratory analytical results and Reference 21

Rote  i  Since tannery wastes are land disposed in a wet condition, i.e.,
         containing moisture, reporting constituent concentrations on a
         wet weight basis realistically portrays the waste streams'
         chemical characteristics with respect to hazardous constituents.
         Constituent concentrations in U.S. soils were not available on a
         wet weight basis.  Geometric mean values on a wet weight basis would
         be slightly less than those reported above.  Thus the method of
         reporting the concentrations (wet or dry basis) does not impact
         on the designation of a waste stream as non-hazardous or potentially
         hazardous.

     •  For which analyses were made.
     ••  Range not shown when only one sample was analysed for the constituent.
                                             14

-------
amount of chromium naturally present in the  soil.   In  some
instances, crop yields have been improved by application of
chromium to soils; conversely, a number of observations have
been made of toxic effects of trivalent chromium on orange
and corn seedlings, oat and corn plants, and tobacco.4»5,6,7,8,9
     Similarly, trivalent chromium has been  reported in the
literature as toxic to a variety of aquatic  species, including
sticklebacks, flathead minnows, polycelisnigra  (flatworm),
Daphina and young eels.6'9  However, recent  attempts to
repeat some of the earlier studies regarding the toxicity
of trivalent chromium to sticklebacks and other fish have
concluded that pH and/or the solubilizing agents used  were
the cause of the reported toxicity.8
     As the preceding paragraphs have indicated, the existing
information on the toxicity of trivalent chromium  to plants
and aquatic organisms is contradictory in many instances.
However, trivalent chromium could ultimately be leached from
tannery wastes, and since it is reported by  some researchers
as being toxic to various plants and aquatic organisms,
trivalent chromium is considered to be a hazardous
constituent  of tannery solid waste.

            1.4  Treatment and Disposal Technology

     1.4.1  Treatment.  Sludges from wastewater pretreatment/
treatment facilities are the only potentially hazardous
wastes which are currently treated prior to  disposal.
Treatment consists of dewatering the sludges.  The only
categories of tanneries with such facilities are the complete
chrome tanneries and the beamhouse/tanhouse  facilities.  This
is due to the fact that the beamhouse is the major source
of suspended solids in a tannery.
     Sludge dewatering is accomplished using gravity (sequential
settling) or mechanical means.   Three mechanical methods of
sludge dewatering are used by tanneries—vacuum filters,
centrifuges, and filter presses.   All three  are effective;
however, there seems to be a preference for  filter presses
due to the slightly drier (40 percent solids) filter cake
produced.   Gravity dewatering systems are also used to a very
limited extent, but the prevalence of this method  of treatment
appears to be declining.   One of the largest gravity dewatering
systems has recently been replaced with a filter press.
     As restrictions on the wastewater discharges  from tanneries
become more stringent, more tanneries will install  wastewater
pretreatment facilities.   This will lead to more widespread
use of mechanical dewatering of the sludge generated.  The
complete chrome tanneries and the beamhouse/tanhouse facilities
will be the  two types of  operations most likely to  install
sludge dewatering equipment.
                              15

-------
     Sludge dewatering is the only type of solid waste
treatment applicable and appropriate for tannery wastes.
No exotic treatment such as detoxification or chemical
fixation is considered necessary.

     1.4.2  Disposal.  Approximately 60 percent of potentially
hazardous tannery waste is disposed in landfills.  "San if .try
landfills"  (as defined by FPA which provide  for engineered
disposal and daily cover) accept 10 percent  of the potentially
hazardous tannery waste.  Engineered landfills which do not
provide daily cover accept about 25 percent  of the waste.  The
remaining landfills are converted dumps.  Open dumps accept
about 25 percent of the waste.  Dumps are most common in EPA
Region I and are normally municipally owned.  Most of these
are being closed or converted to landfill operations.
     Potentially hazardous waste (including  sludge) is usually
mixed with municipal refuse, compacted, and  covered.  At
some disposal sites, wastewater treatment sludge is segregated
and placed in trenches or lagoons.  Operational problems
include some reported difficulty in spreading and compacting
large quantities of waste (particularly blue trimmings and
shavings) that are mixed with municipal refuse.
     Leaching of the heavy metals from potentially hazardous
waste is the primray environmental concern associated with
landfilling.  A secondary problem is the flammability of some
finishing residues; however, only small quantities of this
waste are disposed at any one time.
     The more advanced disposal technologies for potentially
hazardous waste examined during site visits  included lined
trenches for wastewater pretreatment/treatment sludge, and
State-certified hazardous waste dipsosal facilities.
     Tanneries normally use the least expensive site
available—normally a municipally-owned landfill or dump.
Tannery-owned facilities are usually operated because of the
plant's remote location or the fact that other disposal sites
will not accept the waste (usually sludges).  It is estimated
that only 10 percent of all tanneries operate their own
disposal sites.
     Industry treatment and disposal technologies are
classified herein as Level I, Level II, or Level III.  Level
I is the most common practice currently employed.  Level II
is the best technology currently employed.   Level III
treatment and disposal technology is that which provides
adequate health and environmental protection.  The
technologies for these three levels of treatment and disposal,
and the quantities and percentage of wastes  going to each
level of technology, for the six tannery categories generating
potentially hazardous wastes are shown in Table 5.  As indicated.
Level III technology is currently (1974)  used only in two
categories of the industry,  and only in situations where
Level II and Level III are the same.   Using  the data in

                              16

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                                         TABLE  5
                            THP.ATMENT AND DISPOSAL TECIWOMXSV LEVF.tS AND
                           ASSOCIATED POTENTIALLY HAZARDOUS WASTE OUAMT1TIES
Category
Coxploto chrome
tannery
Sheepskin
tannery
Split tannery
Leather finisher
Beanhouso/
tanhouse
facility
Rotan/flnahor
Troatmont/Dlsoosal Technolotv
" Kvel 1 '
Landfill
Landfill
Dump
Landfill
Dewaterod
sludge,
disposed
In lund-
fill
Landfill
1 l.c veil I!
Dewater sludge.
all waste
disposed in
certified
hazardous waste
disposal
facility
Landfill
Landfill
Landfill
Countered
sludge
disposed in
11 nod tranches
Landfill
Lovol III
Sane as Level
II, landfill
with loaehato
collection
Landfill with
leachato
collection
Landfill with
leachato
collection
Landfill with
loachate
collection
Same as Level
II, or landfill
with lonchnte
collection
Landfill with
loachnte
collection
Current (1974) Distribution of Haste Cctwoon
Treatment/Disposal Tcchnolonipii
E.uvcl'1 "
metric tona/yr,
(w«t/dry)
52,000/14,000
2,500/800
11,200/5.500
540/180
12,600/3,000
2,500/1,300
1
50
CO
70
60
60
55
Loviil 11
metric tons/yr
{wot/dry>
4,200/1,200
2,500/800
4,800/2.400
540/180
4,300/1,000
2.500/1,300

I
4
60
30
60
20
55
LCVv'l 11.
metric tons/yr
(wot/Jry)
4,200/1,200
0
0
0
4,200/1,030
0

V
<
0
0
0
20
0
Source:   SCS  Engineers

-------
 Table 5 and correcting for the overlap between technology
 levels, it is estimated that 85 percent of tannery potentially
 hazardous waste is going to Level I technology, 10 percent
 to Level II, and 5 percent to Level III.

      1.4.3  Alternatives to Disposal.

      Municipal Sewage Treatment.   Some tanneries are located
 in communities where most of the wastewater received at the
 municipal sewage treatment plant is discharged by tanneries.
 These situations are somewhat unique to the tannery industry
 and deserve mention.
      This situation is particularly prevalent in New England
 (EPA Region I), where three tanneries  were visited which
 provided 80 to 95 percent of the flow  to municipal treatment
 facilities.  In other New England and  New  York (EPA Region II)
 communities, up to 60 percent of the flow  was contributed by
 tanneries.   Thus,  the municipalities were  essentially treating
 tannery wastewater and generating and  treating tannery sludge.
         In the community in which the  tannery contributed
 95 percent of the flow, the primary treatment plant sludge was
 dewatered using centrifuges and disposed in trenches at the-
 city's landfill.   In the two other communities visited,  the
 tanneries contributed about 80 percent of  the flow.   Both of
 the treatment plants were constructed  recently and neither
 was producing any secondary sludge.  Primary sludge was
 dewatered with centrifuges.   One  operation was disposing
 of the dewatered  sludge  in trenches, and the other treatment
 plant was stockpiling the sludge  near  the  plant until a
 disposal site was  found.

      Source Reduction Through In-Plant Process Changes.
 There are several  in-plant processing  changes in use by
 varying numbers of tanneries.   These changes primarily
 contribute  to economic advantages  and  secondarily  impact on
 waste generation.   These  processes  are  in  various  stages of
 development from experimental  through  pilot  plant  and full
 scale operation.   However,  none of  the  processes are in
 widespread  use  in  any  of  the  tannery categories,  let alone
 the  tanning industry as  a whole.
      It is  doubtful  that  many  of the in-plant  processes
 will  come into  widespread use  by 1983.   The  impression
 gathered  from tannery  officials during  the course  of this
 project was that tanning  is considered  an  art.   Each tanner
 feels  that  he knows  the  "tricks of  the  trade"  as far as  the
 production  of his  particular  leather is concerned.   Tanners
 strive  to maintain a quality product of consistent color,
 texture,  pattern,  etc., in order to retain their established
 customers.   Some tanners  are not sure that they  can  reduce
 their chemical  usage,  use  reformulated  finishes, reuse
chrome, etc., and  still produce the same product, and  thus

                              18

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 are  reluctant to make even minor changes  in  their  processing.
     Therefore, tanners will move  slowly  in  altering  their
 processing  procedures.  Since the  in-plant process changes
 are  not  applicable  to nor likely to be  adopted by  all
 tanneries in a particular category, no  attempt has been made
 to suggest  them to  the entire industry.   Consequently,
 in-plant process changes which impact on  the quantity or
 nature of potentially hazardous waste have not been included
 as any level of treatment/disposal technology.

     Sale as By-products.  Economic feasibility  is currently
 the  primary factor  affecting by-product utilization of
 potentially hazardous waste.  Following is a list  of  the
 types of potentially hazardous wasteswhich are currently
 saleable and by-product uses:
     Waste  stream

     Blue trim and shavings


     Solvent-based finish
      residues
     Leather trimmings
By-product use

Fertilizer
Hog feed supplement
Glue
Solvent recovery

Glue
Craftsman—small leather
 articles
     With the exception of solvent recovery, by-product
utilization of potentially hazardous waste is volatile and
dependent upon location.  The major type of potentially
hazardous waste sold is blue trim and shavings.  These
are, and have been, sold to producers of fertilizer, animal
feed supplements, and glue.  These markets are apparently
declining as evidenced by the fact that, within the last
two decades, the number of fertilizer producers utilizing
leather waste has been reduced from 28 to 3.  In addition,
glue manufacturing from leather waste has essentially ceased.
However, tanneries located in the Midwest are able to sell
their blue trim and shavings to a producer of fertilizer
used principally in citrus groves and to a lesser extent
in other orchards.  Similarly, some tanneries also sell blue
trim and shavings for use as a hog feed supplement.  If
possible, finsihed leather trimmings are sold to local
craftsmen or foreign countries for the manufacturing of
small leather goods.
     Sale of potentially hazardous waste for by-product'
uses is encouraged as an alternative to disposal if the
ultimate use of the waste is environmentally sound.  Blue
trim and shavings are considered potentially hazardous due
to their high trivalent chromium content.   Information in
the literature indicates that trivalent chromium is hazardous
to aquatic organisms and to lower forms of terrestrial plant
                              19

-------
life, but not to mammals and higher plant forms.  Consequently,
the use of blue trim and shavings as a hog feed supplement
is approved by the U.S. Department, of Agriculture  (chromium
content not to exceed  275 ppm).  Similarly, the use of this
waste as an. orchard fertilizer can be beneficial as long
as the application does not become excessive and ground
and surface water pollution does not result from the practice.
Use of the waste for other fertilizer applications, such
as vegetable crops, must be studied further before the
environmental adequacy of the practice is known.

                       1.5  Cost Analysis

     The cost data presented in this report is based upon
actual costs reported  by tanneries, and from prices quoted
by disposal contractors serving tanneries.  As necessary,
additional informationis included from equipment suppliers,
published literature,  government sources, and SCS files.
     All cost information is given in December 1973 dollars,
and when necessary, have been adjusted to this basis using
the Chemical Engineering (CE) Plant Cost Index.  For
purposes of comparing  the total cost of potentially hazardous
waste treatment and disposal for the tanning industry to the
value added in manufacturing and the total value of shipments,
the latter indicators were converted to December 1973 dollars
using the wholesale price index furnished by the Bureau
of Labor Statistics.

     1.5.1  Treatment.  Sludges resulting from primary and/or
secondary wastewater treatment at beamhouse/tanhouse facilities
and some complete chrome tanneries are the only solid waste
generated- by the leather tanning industry which is treated
prior to disposal.  The only treatment is dewatering, and it
is always conducted on-site..  The annual cost for sludge
dewatering at a typical complete chrome tannery with primary
and/or secondary wastewater treatment or a typical beamhpuse/
tanhouse facility generating 10,000 kg of dewatered sludge
per 1000 equivalent hides processed is $86,000 per year.

     1.5.2  Disposal.  All of the typical plants- for the
six categories of tanneries which generate potentially
hazardous solid waste utilize contractor service for hauling
and disposal. .Contractor hauling and disposal charges range
from $2 per metric ton of waste for open dumping to $46
per metric ton for a State-certified hazardous waste disposal
facility,-depending upon the type of disposal utilized,
the quantity of waste generated by a particular plant, and
the type of waste.  Landfill disposal of potentially
hazardous waste is the most common disposal method in this
industry,  and costs a typical tannery $10 per metric ton'.
                               20

-------
     1.5.3  Summary and Discussion.  A summary of the cost
estimates for the three levels of treatment and disposal
technology for typical plants in the six categories of
tanneries is presented in Table 6.  As shown, there are
significant differences in cost for the typical plants of
the different categories of tanneries.  These variations
are due to a variety of factors, including:

        Plant production.
        Contractor hauling and disposal costs.
        Local and geological conditions.
        Urban or rural location.
        Equipment used.

Individual plant production varies widely for plants within
a given category, especially for complete chrome tanneries,
where the largest plant is more than 100 times as large as
the smallest plant.  For tanneries generating relatively
small quantities of solid waste (a few hundred kilograms
daily), the cost of solid waste treatment and disposal per
metric ton of waste is approximately three times that of
plants which generate quantities more typical of operations
in most of the categories (more than one metric ton per day).
The other factors mentioned above are all site specific
considerations, and estimation of changes in cost must be
made on a case-by-case basis.
     As shown, the total annual cost for Level I and Level
III is the same for a typical complete chrome tannery without
primary and/or secondary wastewater treatment.  Although
the cost per metric ton of waste is higher for Level III,
due to higher costs for disposal in a landfill with leachate
collection,  the total cost is the same since Level III
assumes that trimmings and shavings are sold as a by-product.
     For a complete chrome tannery with primary and/or
secondary wastewater treatment,  the total fixed cost is
due entirely to sludge dewatering.  Sludge dewatering accounts
for approximately 90 percent of the increase in total annual
cost for complete chrome tanneries with primary and/or
secondary wastewater treatment,  relative to complete chrome
tanneries without wastewater treatment facilities.  The
other 10 percent of the increase in costs is the result of
sludge disposal charges.
     Two different Level III treatment and disposal
technologies are shown for split tanneries.   The more
expensive Level III technology (Alternative 1) is based on
disposal of  the waste in a landfill with leachate collection.
The less expensive Level III technology (Alternative 2)
costs are based on the sale of trimmings and shavings and
the disposal of other potentially  hazardous waste.  The
large difference in the total cost of these two alternatives
arises because blue trimmings and  shavings represent 90


                              21

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                                             TABLTS 6
M
M


Category


Complete Chrome
Tannery, without sludge
(Production - 26o7oOO
equivalent hides/year)



Complete Chrome
Tannery wi^h sludge
(Production - 2(0,000
equlvalmt *4«>«/»M«>



Sheepskin Tannery
(Production - 200,000
equivalent hides/
y«e*)



Cost Item
Total Fixed
Total Annual

Cost/1000 equivalent
hides

Cost/metric tea of
waste*
Total Fixed
Total Annual

Cost/1000 equivalent
hides
Cost/metric tea of
waste*
Total Fixed
Total Annual
Cost/1000 equivalent
hides
Cost/Mtric ton of
waste*
Level Z
(S)
None
13,000

40


10
304,000
119,400

451

37
None
0,700

34

20
Level ZZ
(S)
None
10,000

30


10
304,000
131,000

504

46
Voae
6, .700

34

30
Level ZZZ (5)
Alt. 1
None
13,000

46


14
304,000
131,000

504

46
None
0,100

40

24
Alt. 2
—
...

...


•..
304,000
125,500

402

44
...
—

.—

...

-------
to
TABLE 6
(Continued)
Category

Split Tannery
(Production = 400,000
equivalent hides/
year)


Leather Finishers
(Production » 225,000
equivalent hides/
year)

Cost Item
Total Fived
Total Annual
Cost/1000 equivalent
hides
Cost/metric tons of
waste*
Total Fixed
Total Annual
Cost/1000 equivalent
hides
Cost/metric ton of
waste*
Level I Level II Level III ($)
($} ($} Alt. 1 Alt. 2
None None None None
7,000 3,600 48,000 4,300
17 9 121 11
2 20 14 24
None 'None None 	
1,100 1,100 1,500
4.9 4.9 6.6
31 31 41
           Beamhouse/tanhouse
           facility
             (Production =  300,000
             equivalent hides/
             year)
Total Fixed

Total Annual

Cost/1000 equivalent
 hides

Cost/metric ton of
 waste*
304,000   304,000  304,000   304,000

115,800   121,800  121,800   129,800
    390
                                                                 38
406
               41
406
          41
                                 426
           43

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                             TABLE  6
Category

tetan/finianef
(Production • 675,000
equivalent aidoa/
year)

. Coat Xten
Total Fixed
Total Annual
Coat/1064 equivalent
hidee
Coat/aetrio ten of
vaate*
Laval X
t$)
Bone
12,000
18
10
Laval XX
IS)
Bone
8,000
12
20
Laval XXX
($)
Alt.- 1 Alt. 2
Bone
17,000
25
14
Bone
9.000
1)
24
 I  SCS Inginaara
•  Vet voifkt aeaiav

-------
 percent of the waste generated by  a  typical  split tannery.
 The cost per metric ton  of waste actually  disposed for
 Alternative 2 is  increased due to  the  substantially reduced
 quantity of waste which  must be collected  and  disposed.
      A typical leather finisher generates  less solid waste
 than any other type of tannery.  Consequently,  the annual
 contract hauling  and disposal costs  for  all  three
 levels of technology are less than for any other  categories.
 However, the cost per metric ton is  higher than for most
 other categories  due to  the small  volumes  of waste which must
 be  collected and  disposed.
      Since wastewater treatment sludge is  the  only potentially
 hazardous waste generated by a typical beamhouse/tanhouse
 facility,  all costs shown are the  result of  treatment  and
 disposal of sludge.  The cost of treatment and disposal for
 the most expensive Level III (Alternative  2) is only about
 10  percent higher than for Level I.  However,  since about 90
 percent of the total annual cost is  the result of sludge
 treatment,  which  is the  same for all levels  of technology,
 the percentage increase  in total cost  to go  from  Level I
 to  Level III technology  is not very  substantial.
      Table 7 summarizes  the total  costs of treatment and
 disposal for each category of tannery  and  illustrates
 the differences in costs discussed above.  For complete
 chrome  tanneries  with primary and/or secondary  treatment
 sludge,  approximately 90 percent of  the total  annual
 treatment  and disposal costs are the result  of  wastewater
 treatment  sludge.  For beamhouse/tanhouse  facilities,  100
 percent of the treatment and disposal  costs  are the result
 of  wastewater treatment  sludge.   As a  result,  approximately
 65  percent  of the cost of treatment and disposal  for the
 total  industry for all three technology levels  is  a result
 of  wastewater sludge dewatering and disposal.   For  complete
 chrome  tanneries without primary and/or secondary wastewater
 treatment  sludge, the total annual  treatment and disposal
 costs for  all levels of technology  are substantially
 higher  than for other categories such as sheepskin,  split
 tanneries, retan/finishers and leather finishers because
 the production of the complete chrome category  is many times
 larger.
     Another important factor effecting the cost of  treatment
 and disposal technology for the  total industry  is the ability
 of complete chrome tanneries (without primary sludge),  retan/
 finishers, and split tanneries  to sell trimmings and shavings
 as a by-product.   For these three categories of tanneries,
 the cost of treatment and disposal  is less for Level II
 (with sale) than  Level I  (without sale),  with the  result
 that the total cost to the industry of Level I technology is
virtually the same as  for Level  II.  Similarly, the difference
 in cost between the most  and least  expensive Level III
technology is primarily a function  of whether trimmings and
shavings are sold or land disposed.

                             25

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             ANNUAL TRBATKBMT AMD DISPOSAL COSTS
                     (00e. 1973 dollars)
Tannery
Category
Chrome «/
sludge
Chrome v/o
sludge
Sheepskin
Split
Leather
finisher
Beamhouse/
Tanhouse
Facility
Retail/
Finisher
Total
Level I
1,524,000
675,000
84,000
60,000
27,000
812,000
37,000
3,219,000
Level IX
1,702,000
519,000
84,000
31,000
27,000
•54,000
25,000
3,242,000
Lew
Least costly
1,629,000
•75,000
101,000
37,000
37,000
•54,000
28,000
1,361,000
il III
Moaft costly
1,702,000
675,000
101,000
411,000
37,000
896,000
53,000
3,875,000
Source:  SCS Engineers
                             26

-------
     Using the distribution of production between the
various categories observed in 1974, the value added in
manufacturing (in December 1973 dollars) during 1974 was
$480 million, and total value of shipments was $1,010
million.  Thus,  the costs of the three levels of treatment
and disposal technology compared to the value added in
manufacturing and the value of shipments are as follows:

                      Treatment and      Treatment and
                      disposal cost—    disposal cost—
                      percent of value   percent of value
Technology level      added	   of shipments	

I                           0.67              0.32
II                          0.68              0.32
III (least costly
     alternatives)          0.70              0.33
III (most costly
     alternatives)          0.81              0.38

     Thus, it appears that there is little difference in
the overall costs between Level I and Level III technologies
(Table 7) and also in relative costs as percentages of
value added and value of shipments  (as tabulated above)-
These figures are industry-wide averages, and the impact on
individual tanneries may be quite different than shown.
                              27

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                         SECTION 2.0

                  INDUSTRY CHARACTERIZATION


                  2.1  The Tanning Industry

     2.1.1  Introduction to Tanning.  Tanning, one of the
oldest arts known to man, is the process of converting the
skins and hides of animals into leather.  Pictures carved
by Egyptians over 5,000 years ago depict tanning operations.
The Greeks had developed leather making into a well
established trade by the year 500 BC and in the 12th
century, tanners' guilds were organized in England and
Europe to regulate the manufacturing processes and advance
the art of leather making.10
     Tanning involves a complex combination of mechanical
and chemical processes.  The heart of the process is the
tanning operation itself in which organic or inorganic
materials become chemically bound to the protein structure
of the hide and preserve it from deterioration.  The substances
used to accomplish the tanning process for viturally all
of the leather produced in this country are chromium or
extracts from the bark of trees, such as chestnut.  These
tanning agents give rise to the two "predominant types of
tanning operations—chrome and vegetable tanning.

     Chrome Tanning.  Approximately 85 percent of the
leather produced in this country is chrome tanned.2 Chrome
tanning produces leather better suited for certain applications,
particularly for the upper parts of boots and shoes, and
requires less processing time than traditional vegetable
tanning.
     While cattlehides are the most common raw material
for chrome tanning;  sheepskins,  calfskins, pigskins, and
other hides and skins are tanned in this manner.   It should
be noted that the terms "hides"  and "skins" refer to the
entire skins removed from an animal and used as a raw material
for tanning.   "Hide" is used for large animals, e.g.,
cattlehide, horsehide.  "Skin" is used for smaller animals,
e.g.,  pigskin,  sheepskin, calfskin.   The term "hide" will be
used hereafter unless a specific type of hide or skin is
being discussed.
     The general steps required  for chrome tanning of leather
are shown in Figure 3  and described briefly below.  No two
tanneries are identical;  each has its unique characteristics
and subprocesses; some perform only some of the processes
shown and ship their goods to another tannery to complete the
processing.  The following description is intended to be
illustrative and to provide the  layman with a general
                              29    Preceding

-------
                 FIGURE 3

       TYPICAL TANNING PROCESS STEPS
 CHROME TANNING
    VEGETABLE TANNING
 HIDES RECEIVED

   |  SOAKING |
   (FLESHING)
        1
   I  LIMING  |
^
t
BATE
PICKLE
TAN
I SPLIT  AND SHAVE\
      RET AN
      COLOR
    FATLIQUOR
       DRY
   MECHANICAL
  CONDITIONING
   [FINISHING)
 MEASURING  AND
   PACKAGING
    IHIDES RECEIVED
       [ LIMING
           1
[MECHANICAL HAIR REMOVAL
       --
       [FLESHINGJ
[MECHANICAL CONDITIONING]
           1
[MEASURING AND PACKAGING)
                   30

-------
 understanding of the major processing steps.
      Hides and skins are received from meatpacking plants
 by truck or railroad car.   Each cattlehide is tied in a
 bundle weighing approximately 25 kg.   The bundles are cut
 open and the hides  unfolded,  inspected, and usually split
 along the backbone,  producing two sides from each hide.
      Next follows a  sequence  of wet  operations.   The sides
 are soaked in water  to  return some of the lost natural
 moisture.   The remaining flesh or fatty substance adhering to
 the inside or flesh  surface of the side is removed; these
 fleshings are usually either  rendered in the  tannery or sold.
 The cattlehides are  then soaked in a  lime and sulfide solution
 which either loosens or dissolves the attached hair.  In some
 operations,  the hair is only  loosened through the caustic
 action of the lime with the hair removed mechanically,
 followed by washing,  drying,  and sale as a by-product (for
 carpet pads or similar  uses).   However,  the more common
 approach for hair removal  is  to completely dissolve the hair
 and discharge it to  the wastewater stream.
      Following hair  removal,  the hides are ready to be
 prepared for the actual tanning operation.    The hides are
 placed into  large rotating drums and  are treated in turn with
 an enzyme  solution and  then a  salt-acid solution,,   These
 operations (called bating  and  pickling respectively)  prepare
 the hide for the tanning process.  While still in the drum
 after the  discharge  of  the pickling solution,  the hides are
 tanned.  A chromium  sulfate solution  is  added  to the drum
 and the hides and chrome solution  are  mixed for  periods of
 up to 24 hours.
      Following  chrome tanning,  all hides have  a  characteristic
 blue  color caused by the chrome tanning  solution.   Upon
 removal from the  tanning drums,  excess moisture  is removed
 from  the hides  through  a wringing operation.
      Cattlehides  are too thick  for most  purposes and therefore
 the tanned hides  are split, using a machine similar to a
 horizontal band  saw.  The  splitting operation  produces a
 grain  side of more or less  uniform thickness.  One surface
 of  this grain side is the  original outer  surface of the
 cattlehide and retains the  natural grain.  The splitting
 operation also yields a  thin,  inner portion of the hide
 known  as a "split" or "blue drop."  Splits have  no graining
 and are often used for suede garments.   Both the grain side
 and the split may be further processed to form a piece of
material of uniform thickness.  This operation is  called
 shaving and results  in the removal of small pieces  of  leather
with a consistency similar to  very coarse sawdust.
     Another series  of wet operations gives the  leather the
color and other properties desired in the finished material.
The tanned hides are placed into another drum for retanning,
coloring and fatliquoring.   Retanning is a second,  shorter

                              31

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 tanning operation normally using a tanning agent other than
 chromium.   After the retanning solution is discharged from
 the drum,  a pigment is added in order to dye the leather to
 the desired color.    The coloring solution is also discharged
 from the drum.   Next a mixture of oils is added and the
 hides and  oil are rotated in the drum.   This operation, called
 fatliquoring, helps to produce the desired softness.
      After removal from the retan,  color, and fatliquor
 drum, the  leather is dried and physically conditioned.   The
 two most common approaches to this conditioning are staking
 and buffing.   Staking is a form of massaging which makes
 the leather more plyable.   Buffing is a light sanding
 operation  applied to either the grain surface or the underside
 of a piece of leather.  It is used to improve the nap of the
 underside  or to smooth out surface imperfections on the grain
 surface.
      One or more of several possible  finishing steps are
 then accomplished to give  the leather the required pattern
 gloss,  or  waterproof qualities.   Usually all leather receives
 at least one coat of a liquid finish  material.   Finishes are
 either  rolled or sprayed onto the leather.   These operations
 are followed by drying.  Often three  or more coats of finish
 are applied to  leather;  each is followed by a drying cycle.
 Other finishing operations include  embossing,  in which
 patterns are pressed into  the leather surface.   Finally,  the
 surface area of each piece of leather is measured electronically
 and the area stamped on the underside.   The leather is  then
 packaged and stored for shipment.

      Vegetable  Tanning.  Vegetable  tanning  employs the  use
 of extracts from the bark  of various  trees  as  the tanning
 agent.   Since the introduction of chrome tanning,  vegetable
 tanning has decreased in importance.  Soles of  shoes have
 been  traditionally  vegetable tanned;  however,  since the
 introduction  of synthetic  materials for  shoe soles,  vegetable
 tanning has further decreased in  importance.  Vegetable tanning
 is  the  process  by which  most leather  shoe soles  are tanned,
 and it  is  also  used to produce  leather used in crafts.
     Many  of  the  basic steps used in  the  chrome  tanning
 process are also  present in vegetable tanning.   The sequence
 in which these  steps  are employed is  somewhat different,  and
 there are  few finishing  operations associated with vegetable
 tanning.   A processing diagram for vegetable tanning  is
 also shown in Figure  3.
     The processing of hides prior to vegetable  tanning begins
with a  soak in  a  lime solution to loosen  the hair.   Hides  are
then removed  from the  lime  solution and the  hair removed
mechanically.   The  hides are  then soaked  and rinsed,  and the
 fleshing operation  is  accomplished.  Note that in  the chrome
tanning process,  fleshing preceded the hair  removal operation.

                              32

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      After fleshing,  the hides are trimmed into a roughly
 rectangular shape and then passed through a bate and pickle
 operation similar to  that used in the chrome tanning process.
 Coloring, the next operation,  is often done utilizing a weak
 tanning solution.  Normally vegetable tanned leather is not
 highly colored.   After coloring, the hides are placed into
 vats containing  the bark extract tanning solution and moved
 from a strong tanning solution to a slightly weaker one,
 then rinsed and  partially dried.
      True splitting is not usually a part of the vegetable
 tanning process; however,  an operation called leveling is
 used to produce  a uniformly thick piece of leather.  Leveling
 removes only the thickest portions of the underside of the
 hide,  and no "split"  is produced.   Next, the hide is oiled,
 which is a process similar to  the fatliquoring in chrome
 tanning.   Following oiling,  the hide is dried and then
 mechanically conditioned.
      Virtually no finishing  is done at vegetable tanneries.
 Few,  if any,  spray finishes  are applied and often the only
 finishing process employed is  pressing to yield a smooth grain
 surface.   Finally,  the hides are measured,  packaged, and stored
 prior to shipment.

      2.1.2   Background.

     History  in  the United States.   Tanning is  one of the
 oldest arts  known in  this  country.   Early explorers and
 colonists noted  that  the Indians knew and practiced the art
 of leather tanning.   Early colonial  tanneries were begun
 in the New England States in  the  1600's.   Shortly  after
 colonial times,  tanneries continued  to be established in the
 New England States and also  in rural  locations  close to the
 source  of the bark necessary for the  tanning  solutions.   During
 the 19th and  20th centuries, tanneries moved west following
 the westward movement of cattle.  Today,  leather  tanning and
 finishing plants  are  located in  34 states.  However,  tanneries
 are still concentrated in their  traditional areas  of New
 England and the Middle Atlantic  States.2

     Magnitude of the  Industry.  For  the  purposes of this
 report, there are 298 different establishments  in the leather
 tanning and finishing industry which  have production facilities.
 This is 219 less  than the number reported by the  Bureau  of
 the Census.1  The difference arises from  the accounting  methods
 used by the Bureau of the Census and  from  interpretation as
 to which operations constitute actual production  activity.
 First, the Bureau of the Census data  includes 76  converters.
These operations were not included as part of this  industry
 study because the converters have no production facilities.
They perform such functions as  warehousing, contract measuring,

                             33

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 and  shipping.   A second difference concerns small  operations.
 Establishments with one to  four  employees  are usually
 considered  to  be taxidermists or hobbyists and are not  truly
 part of the leather tanning and  finishing  industry.  Finally
 those companies conducting  two or more activities  from  the
 same location  and other instances  (not counted as  converters)
 where no production facilities exist were  eliminated.   The
 Bureau of the  Census requires reports from companies engaging
 in different lines of activity at one location.  This
 duplication has been eliminated.  Similarly,  one-man sales
 offices and the like were subtracted from  the Bureau of the
 Census figures.   An alphabetical listing of the remaining
 establishments,  including their  name and address,  is included
 as Appendix A.
      Tanneries tend to be small when measured by the number
 of employees.   As noted above, the smallest operation
 considered  to  be a viable part of the industry has at least
 five employees.   The largest plant in the  industry employs
 about 500 workers.   Only 87 plants employ  more than 100
 workers.*
      The facilities in which tanning operations are conducted
 tend to be  old.   The majority of the plants are more than
 50 years old,  and few completely new plants have been built
 in the last two decades.2  The age of plants  in the tanning
 and  finishing  industry is distributed as follows2:

      Age of plant                     Percent of plants

      Less than 10 years                       1
      10 to  14.9  years                         1
      15 to  19.9  years                         3
      20 to  29.9  years                         4
      30 to  50  years                          18
      Over 50 years                           67
      Data not  available                       6
                                            TOO

      Production  in the tanning industry is  normally measured
 in terms of  equivalent hides.  An equivalent  hide has an area
 of 3.7  m2 (40  ft2).   Production in 1974 by  state is shown in
 Table 8.    In  order to protect the confidentiality  of
 production  information,  states are combined when there  are
 less  than three  tanneries in a state.  As  shown, Massachusetts
 has  the most production, followed by Wisconsin and New  York.
The  total production  of 35.7 million equivalent hides represents
 the  sum of  the hides  processed by the seven types of tanneries
discussed in Section  2.2.6.  Cattlehides accounted for
approximately  90  percent or 32.1 million equivalent hides
with  the remaining  3.6 million made up of  sheep, pig, and
calfskins and all  others.z


                              34

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                       TABLE 8

            1974  TANNERY  PRODUCTION  BY STATE
                                      Production
                            (thousands of  equivalent  hides
        State(s)                  put  into processing)


Alaska, Washington                         28
Arizona, California                     1,870
Colorado, Utah                            220
Delaware                                  230
Florida, Georgia                          169
Illinois                                1,630
Indiana, Ohio                             200
Iowa, Nebraska                            512
Kentucky                                  437
Louisiana, Texas                          107'
Maine, Vermont                          2,630
Maryland, Virginia, West                1,150
 Virginia
Massachusetts                           8,270
Michigan                                1,150
Minnesota                                 393
Missouri                                  774
New Hampshire                           1,670
New Jersey                              1,340
New York                                4,020
North Carolina                            211
Oregon                                    115
Pennsylvania                            1,860
Tennessee                               1,230
Wisconsin	493

Total                                 35,700
Region









Source :
Note:
I
II
III
IV
V
VI
VII
VIII
IX
X
12,600
5,370
3,240
2,040
8,850
107
1,290
221
1,870
143
Tanners' Council of America
Totals
may not add due to rounding.
                         35

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     Value  of  shipments  is  another indicator of the magnitude
of  an  industry.  The  Bureau of the Census reports the value
of  shipments for the  leather tanning and finishing industry
in  1967  as  $846 million  and in 1972 at $1,026 million.1
The Tanners' Council  estimates the value of shipments in 1974
also at  $1,026 million and  in 1975 at $1,118 million.2
Information on the  value of shipments is not available on a
state-by-state basis.

     Geographical Distribution.  Although there are leather
tanning  and finishing establishments in 34 states, the industry
is  not widely  dispersed.  Table 9  illustrates the number of
tanning  and finishing operations in each of the states.'  The
industry's  geographical  concentration has been determined
by  factors  affecting population concentrations and the locations
of  the sources of raw materials, i.e., meatpacking facilities.
Major regional areas  in  which tanneries are concentrated:

     New England (EPA Region I)—Massachusetts, Maine, and
      New Hampshire
     Middle Atlantic  (EPA Regions II and III)—New York,
      New Jersey, and Pennsylvania
     North  Central  (EPA  Region V)—Wisconsin, Illinois, and
      Minnesota
     Pacific (EPA Region IX)—California

     2.1.3  Industry Organization and Structure.  The leather
tanning  and finishing industry in the United States consists
almost exclusively  of family-owned businesses.  Few
corporations own more than  one tannery.  Only one firm is
listed on a stock exchange, and only a handful of companies
are subsidiaries or operating divisions of larger corporations.
Approximately  nine  tanneries are subsidiaries of larger firms
not primarily  associated with the leather industry.  One
tanning  company is  a subsidiary of a meatpacking company
while three shoe manufacturers  have their own tanning
facilities. 2
     The industry is not characterized by an appreciable
integration, either back to raw material supply or forward
to finished or fabricated leather products.  Thus, tanneries
are not  owned by leather product manufacturers, and they do
not tend to own sources  of their raw material.  Similarly,
the ownership of the tanneries by shoe manufacturers is not
common.  In recent  years there has been a trend to even less
integration.  One major meatpacking firm and one leading shoe
manufacturer recently divested their tanning operations.  Thus,
only the previously mentioned single instance of a meatpacker-
tannery combination and  three examples of direct connections
between tanneries and shoe manufacturers remain.
                              36

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      Tanneries tend to be specialized in the type of raw
 material processed and leather produced.   The first reason
 for this lack of diversification stems from the fact that
 tanning equipment and processes are  specialized and not
 readily interchangeable in terms of  raw material and end
 product.   For example,  some equipment suitable for the tanning
 and finishing of pigskins or sheepskins cannot be used for
 the larger cattlehides.   The second  reason is the fact that
 shoe manufacturing has been and still is  the principal consuming
 industry.   In 1962,  shoes accounted  for 83 percent of all
 leather used.   This  ratio declined to 74  percent in 1972.2
 This caused some tanneries to seek some diversification in
 their production.  Tanneries specializing in leather for
 the upper parts of shoes  (often called side leather tanneries)
 attempted to modify  their production techniques in order to
 enter the growing  garment leather market.   However,  this trend
 does not  reflect diversification of  basic product line.
 Rather,  it indicates an effort  to adapt available plant and
 equipment to moderately different end use requirements.

      2.1.4  Industry Trends  and Future Developments.

      Character and Quantity  of  Raw Material Supply.   In the
 United States  there  has been a  large increase in the number
 of  cattlehides and pigskins  that have become available for
 processing into  leather.   This  has been accompanied  by a sharp
 decline in the availability  of  sheep,  goat,  and calfskins.2
      Increased consumption of beef has lead to a rise in the
 number of  cattlehides available for  tanning.   This number
 has  increased  from 28 million hides  anually to 38 million
 in  the period  from 1957 to 1974.2  In the United States,
 until  recently,  very  few  pigskins have been removed  from the
 animal prior to  processing for  meat.   There are indications
 that economic  considerations are leading to the removal of
 more pigskins  prior to butchering, and it is estimated that
 in  1974 as many  as 4 million pigskins  were  available for
 tanning.2
     Concurrent with the  increase in  cattlehide and  pigskin
 supply in  the  United States, there has  been  a  corresponding
 decrease in the availability of goat  and  kidskins, sheep and
 lambskins, and calfskins.  Skins from goats  and sheep have
 been traditionally imported; however,  it  has become  the
 policy of the nations supplying most of  these  skins to encourage
 the utilization of the skins locally,  thus  leaving few skins
 available to U.S. tanners.  Production of  leather  from these
 skins has declined drastically  in this country.   Goat  and
kid leather production was over 22 million  skins  (about  3.3
million equivalent hides)  in 1957 and practically  zero in 1974.
Sheep and lamb leather production also has shown  a drastic
reduction.2  The worldwide change in taste from veal  to  beef

                              37

-------
 has caused a decline in the availability of  calfskins  for
 tanning.   Calf leather production has  declined  from 9  million
 skins in  1957 to less than 1.5 million in 1974.2
      Other types of skins or hides processed in the United
 States on a very limited basis include deer,  elk, moose,
 antelope, rabbit, horse, and shark.  Cattlehides, however,
 constitute an ever increasing percentage of  the raw materials
 for tanning in this country.  Currently,  nearly 90  percent  of
 all leather tanned is cattlehide leather.2

      Development of Substitute Materials for Leather.  The
 development of a synthetic substitute  for one type  of  leather
 has caused a dramatic decrease in its  production.   Before the
 introduction of synthetics immediately after World  War II,
 over 80 percent of all shoes  had leather soles.  By 1974,
 only 14 percent of the shoes  produced  in the United States
 had leather soles, the remainder using synthetic materials.
 This caused a corresponding decline in the production  of
 vegetable tanned leather.   In 1957, over 5 million  hides were
 vegetable tanned for the production of shoe  soles.   In 1974,
 only slightly over 2 million  were vegetable  tanned.2

      Competitive Economic Status of the Industry.   In  spite
 of  the fact that the United States has a plentiful  supply of
 cattlehides,  American tanners have not been  able to take
 full advantage of this raw material.   The development  of shoe
 and other leather consuming industries in countries with low
 labor costs and government subsidies to their tanning
 industries has put American tanners at an economic  disadvantage
 and has lead to a decline in  this industry in the United
 States.   Consequently,  there  has been  a decline in  leather
 demand by consuming industries in the  United  States.   A
 corresponding increase in the demand for American hides, i.e.,
 not tanned,  has developed in  other countries  to supply their
 tanning industries.   In 1974, the United  States exported
 more than half of the 38  million cattlehides  produced.2

      Economic  and Technical Changes.   In  the  past few  years,
 there  has been a  tendency to  complete  part of the leather
 tanning operations near the source of  the hides, i.e., near
 the meatpacking activity,  to  reduce transportation  expenses.
 This  has  given rise to the development  of two new types of
 tanneries—called,  for the purpose of  this study, the
 beamhouse/tanhouse facility and the re tan/finisher.   Essentially,
 these  are  the  operations  conducted in  a complete chrome tannery
with  the  processing  of  the hides through  the  tanning operation
 carried on in  the  beamhouse/tanhouse facility and the  processes
 from  retain through leather finishing  conducted by  the
 retan/finisher.   The  beamhouse/tanhouse facility receives
and processes  cured or  fresh  hides (currently the trend is
 toward more fresh hides)  through the beaming  and tanning

                              38

-------
operations.  Following chrome tanning, the now blue hides
are  shipped to the retan/finisher where the retanning and
finishing processes are completed.  Some tanneries have
split their operations into two physically separated locations,
and  there are some firms which specialize in one-half or the
other of this process.  In 1974, approximately 10 percent of
the  hides tanned in the United States passed through this
two-step process.  It is estimated that this trend will
continue. ^

     Environmental Considerations.  Tighter restrictions
regarding wastewater discharge from tanneries either directly
to navigable waters or into municipal sewer systems may be
influencing some relocations and changes in the industry.
The  development of the beamhouse/tanhouse facility dnd
retan/finisher is partly due to these considerations.  Older
complete chrome tanneries located in the New England States
often do not have the land available to construct pretreatment
facilities necessary to remove the significant waste load
generated by their beamhouse operations, thus the beamhouse
and tanhouse could be physically moved to a location nearer
to the source of hides.  These locations are also more readily
able to absorb the waste effluent from these operations,
i.e. , they have adequate wastewater treatment capacity or
on-site evaporative disposal can be practiced.   Research is
underway to change operations and processes in order to reduce
water consumption and wastewater generation.

     Trends.  The foregoing description of industry trends
gives an indication as to the future developments that can be
expected in the leather tanning and finishing industry.
It can be predicted that changes will take place gradually
in response to the following factors:

        Changes in the character and quantity of raw material
        supplied will lead to increased production o'f
        leather made from cattlehides in the United States.
        The development of newer substitute materials for
        leather will require experimentation and adapation
        within the tanning industry in order to obtain
        leather of different properties in order to
        adequately respond to the requirements of changing
        markets,  i.e., the tanning industry will have to
        innovate in order to maintain and solidify its
        share  of the market for similar materials.
        Economic and technical changes as well as the
        reaction to environmental considerations will result
        in a continued trend to relocation of facilities
        close  to the source of cattlehide supply.   This will
        lead to a gradual growth in importance of those
        operations having a beamhouse/tanhouse  facility
        in one location and a retan/finisher  in another.

                              39

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          2.2   Approaches  to Characterizing Tanneries

      2.2.1  Census  of Manufactures.  The Bureau  of  the Census
 classified  the leather tanning  and finishing  industry
 (SIC  3111)  into three types of  establishments1:

         Regular tanneries—establishments which  perform
         all or a part of  the  usual manufacturing functions
         within one  organization.
         Converters—handlers  or managers of hides being
         processed into leather.  Converters may  own the
         material in question  but do not perform  manufacturing
         functions which are contracted in whole  or  part
         to  contract tanneries.
         Contract tanneries—processors of materials owned
         by  another  party, e.g., a converter.  Contract
         tanners may provide all manufacturing processes
         or  only selected  steps  in the processing chain,
         e.g.,  contract finishing operations.  The latter
         situation is  the  most common.

      It  should be noted that  the SIC classifications are not
 mutually exclusive.   Some firms in the industry  act in one,
 two,  or  all three of  the  above  classifications.   The Bureau
 of the Census  classified  plants according to  the category in
 which the highest amount  of wage and salary payments are
 made.

      2.2.2  Production.   The  Tanners' Council uses  a
 statistical unit called an equivalent hide to convert all
 types of raw material used for  leather into a common unit
 of measure.  This device  allows the classification  of all
 plants by size regardless of  whether cattlehide,  sheepskin,
 pigskin,  or other raw material  is processed.  An equivalent
 hide  is  equal  to a  surface area measurement of 3.7  m2
 (40 ft2) .  This unit  of measurement was selected because
most  hides  tanned in  the United States are cattlehides and
 the average size of a cattlehide is approximately 3.7 m2
 (40 ft2).   Using production measured in equivalent  hides,
 the Tanners' Council  has divided the industry in the following
manner:

                Production in                      Percent of
 Size            equivalent hides      No. of       plants in
category          per  day	      plants       the industry

X-S (extra      200 or  less             67              22
      small)
S (small)       201 to  600             114              37
M (medium)      601 to  1,200            60              21
L (large)       1,201  to 2,600          32              11
X-L (extra      2,600 or more           25               9
      large)

                              40

-------
     The distribution by state and EPA region  using  the
above production size categories is shown  in Table 9.
It can be seen from this table that most of the  extra  small
and  small tanneries are located in the historical tanning
areas of the New England and Middle Atlantic States  (EPA
Regions I and II).  The large and extra large  plants are
located in the Midwest  (EPA Regions V and  VII) and Far West
 (EPA Region IX), as well as in the New England and Middle
Atlantic States  (EPA Regions I and II), and are  near the
source of cattlehides.

     2.2.3  Tanning Process.  Essentially  all  of the leather
in the United States is produced by tanning with trivalent
chromium (Cr+3) or with extracts from the  bark of certain
trees.  These processes are commonly referred  to as  chrome
and  vegetable tanning, respectively.  Approximately  87 percent
of the 20.2 million equivalent hides tanned in this  country
in 1974 were processed using chrome tanning.2  Essentially
all  of the remaining 2.6 million equivalent hides were
vegetable tanned.  Insignificantly small numbers of  equivalent
hides were tanned for special purposes using alum, zirconium,
or other tanning materials.
     Table 10  indicates the distribution of tanneries  by
the  type of tanning process employed.  The chrome tanneries
make up 93 percent of the total number of  tanneries.   It should
be noted that the vegetable tanneries are  often  located in
sparsely populated Middle Atlantic (EPA Region III)  and
Southern States (EPA Region IV)  and, within those states,
they are often found in rural areas near the former  source
of the barks required in their processes.  Currently,  most
vegetable tanneries in this country use imported bark
extracts for their tanning and do not rely on  local  sources.2

     2.2.4  Raw Material.   As noted earlier, cattlehide
is the most common raw material for the tanning  industry.
It is followed by sheepskin and pigskin, with  only small
numbers of other skins,  e.g., calf, goat, reptile, etc.,
used as raw materials.  Table 11  shows the distribution
of tanneries by raw material.  It can be seen  that the
cattlehide tanneries are widely dispersed as would be
expected by their predominance in the industry.  Pigskin
tanneries are  generally located in the Midwest near  the
source of the  raw material.  Sheepskin tanneries are primarily
located in New England (EPA Region I), and New York  (EPA
Region II).  Although a few domestic sheepskins  are  tanned,
the majority are imported,  primarily from New Zealand.   Thus,
the location of sheepskin  tanneries near seaports is
advantageous.
                             41

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                          TABLE 9


             DISTRIBUTION OF TANNERIES BY SIZE
Region

IX
IX
VIII

IV
IV
' 1
V
VII
IV
VI


I
V
V
VII
VII
I
II

IV
'
X

IV
VI
VIII
I
III
I
III
V
Total
States Containing
Tanneries
Alaska

California
Colorado
Delaware
Florida
Georgia
Illinois


Kentucky

Maine

Massachusetts
Michigan



New riarapshire

New York
North Carolina
Ohio


Tennessee

Utah

Virginia
Washington
west Virginia
Wisconsin

Region I
II
III
IV
V
VI
VII
VIII
IX
X
Total
1
1
14
4
3
s
1
11
2
2
3
1
*
1
79
3
4
3
i
14
25
46
3
4
4
14
9
4
1
1
2
2
2
21
298
103
71
22
19
45
5
6
5
IS
7
xs
1

3
1

2

2






24




1 '
7
19
1

3
1





2


67
25
26
1
3
2


l
3
6
S

1
~T~
J
1
1

4
"T~
1

— T~
4 '

31

~T~*
2
1
— 5—
11
1C
~T™
4
"I"
s
3
"I"
"1

1


4
14
42
27
7
5
IS
5
4
4
4
l
M


~T—

r~

^|—
T'
-I"
•T~
— T~


1"
rr~




-T-
6
~r~
— T~


2
2 '



1


IT'
60
19
' IV
S
5
14

1"

3

L


-J—

~r~


—r~


—r~



~*r
— r~
i~
— r

— j-

— y



3
—2~


~r~


— r
— 3~
32
10
1
S
4
T

T

'2"~

XL


I




I"




S~

2
' 2 '
1



1
1"



3
2"





1
"3-
25
7
2
4
2
T



3

Source:  Tanners' Council of America

     XS (extra small)—200 or less.
     S  (small)      —201 to 600.
     M  (medium)     —601 to 1,200.
     L  (large)      —1,201 to 2,600.
     XL (extra large)—2,600 or more.
                           42

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                TABLE  10
  DISTRIBUTION OF TANNERIES BY TANNING  PROCESS
Region
X
IX
IX
VIII
III
IV
IV
V
V
VII
IV
VI
I
III
I
V
V
VII
VII
I
II
II
IV
V
X
III
IV
VI
VIII
I
III
X
III
V
Total
States Containing
Tanneries
Alaska
Arizona
California
Colorado
Delaware
Florida
Georqia
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Nebraska
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oregon
Pennsylvania
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin

Region I
II
III
IV
V
VI
VII
VIII
IX
X
Total
1
1
14
4
3
3
1
11
2
2
3
1
9
1
79
3
4
3
1
14
25
46

4
4
14
9
4
1

2
2

21
298
103
71
22
19
45
5
6
5
15
7
Chrome
1
1
14
4
3
3

11

2

1
9

79
3
4
2
1
14
25
46
1
4
3
11
7
3
1
1
1
2

21
278
103
71
15
11
43
4
5
5
15
6
Vegetable






1

2

3


1



1




2

1
3
2
1


1

2

20
0
0
7
8
2
1
1
0
0
1
Sourcei  Tanners' Council of America
                     43

-------
                       TABLE  11

        DISTRIBUTION OP TANNERIES BY RAH MATERIAL
Region
X
IX
IX
VIII
III
IV
IV
V
V
VII
IV
VI
I
III
I
V
V
VII
VII
I
II
II
IV
V
X
III
IV
VI
VIII
I
III
X
III
V
Total
Region









States Containing
Tanneries
Alaska
Arizona
California
Colorado
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Nebraska
New Hampshire
New Jersey
New York
north Carolina
onio
Oregon
Pennsylvania
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virgin! -
Wisconsin

I
II
III
IV
V
VI
VII
VIII
IX
X
Total
1
1
14
4
3
3
1
11
7





7


J
1
14
25
46
3
4
4
14
9
4
1
1
2
2
2
21
298
103
71
22
19
45
5
6
5
15
7
Cattle
hide

1
11
1
3
1
i
8
2
1
3

5
1
42
2
2
J
1
11
IS
11
3
4
J
11
5
3
1
1
1

2
12
171
59
26
18
13
30
3
5
2
12
3
Calf
skin


1











1


















1
3
1



1



1

Sheep
skin


1


2

1

1


4

20

1


1
3
22



3

1





2
62
25
25






1

Pig*
akin















1


















I




1





Other
1

1
3



2



1


IB

1


2
7
13


1

4




2

e
61
19
20

4
9
1

3
1
4
Source:  Tanners' Council of America

     *  Although only one tannery in  the country uses pigakin
as its principal rav material,  approximately  20  have  experimented
with pigskin and are developing processes  and technologies  for ita
use.

     ** Primarily specialized contract  operations such as
finishing.
                         A f.

-------
      2.2.5   Industry Categorization.   None of the previously
 discussed approaches to  characterization can be used to
 categorize  the  tanning industry  for the  purposes of  this
 study.   The wastestreams generated currently and in  the
 future  are  functions of  several  factors  including type
 of  tanning,  production operations  (dictated to some  degree
 by  raw  material and type of end  product),  and industry
 trends.  After  considering these factors,  the following
 categories  were developed:

         Complete chrome  tannery.
         Vegetable tannery.
         Sheepskin tannery.
         Split tannery.
         Leather finisher
         Beamhouse/Tanhouse facility
         Retan/Finisher

     During  the first tannery visits and  after discussions
 with industry officials, it became apparent that categories
 to  be used  in this project would not be the SIC subdivisions
 used by  the  Bureau of the Census.1  Objections to
 categorization  based upon SIC were noted  in Section  2.2.1.
 Similarly, a strict delineation based  solely upon tanning
 process, raw material used, product produced,  size,  or
 age of the tannery was not appropriate since none of these
 criteria adequately separated the industry  into categories
 useful in determining and projecting waste  characteristics
 and quantities.  Therefore, the qualitative and quantitative
 differences  among the wastestreams generated in the  various
 types of tanneries served as the bases for  characterizing
 the industry's wastes.
     The first category developed was based upon the type of
 tanning agent, chrome or vegetable.  The chrome tanneries
 and specialty operations were then further  subdivided.  It
was found that cattlehide and pigskin tanneries produced
 similar types of solid wastes and also had  similar waste
 generation factors,  i.e., kg of waste produced  per 1000
 equivalent hides.  Chrome sheepskin tanneries were notably
different.    Since most sheepskins are imported  partially
processed,  little beaming is required.  Additionally, the
 practice of  fleshing after tanning produces  a unique
wastestream—chrome fleshings.   Thus,  based  upon  raw
material and subsequent wastestream generation,  two
additional  categories evolved—the complete  chrome tannery
 (including cattlehide and pigskin)  and the  sheepskin
tannery.
     Another type of operation  yielding considerably
different waste quantities than the complete chrome  tannery
is the split tannery.   In these operations,  the chrome tanned

                             45

-------
split is trimmed, often resplit, and trimmed again before
going through the retan, color, and fatliquor cycle.  The
sequence of trimming, splitting, and trimming yields higher
waste generation factors for trimmings and shavings than is
found in the complete chrome tannery.  Another difference
between the complete chrome operation and the split tannery
is that the split tannery does essentially no finishing.
Thus, there is no finishing residue requiring land disposal.
Therefore, the split tannery was considered a separate
category.
     Contract leather finishers make up the largest segment
of the contract operations conducted in the tanning
industry.  Their operations are similar to the finishing
procedures used in complete chrome tanneries; however, some
unique operations are included for specialty leathers.  Since
the finishers have no actual tanning operations, they were
designated a separate category.
     Vegetable tanneries are notably different in their
processing steps and resultant solid wastestreams.  The
absence of chromium and other heavy metals lead to the
presumption, later supported by analytical evidence, that
vegetable tanneries produced no potentially hazardous wastes
destined for land disposal.
     Industry trends were also considered in the development
of the categories for this project.  The trend most influencing
the types and quantities of solid waste produced in tanneries
is the development of the beamhouse/tanhouse facility and
retan/finisher.  As noted earlier, these operations evolve
from the separation of the classical complete chrome tannery
into two segments.  In the beamhouse/tanhouse facility, the
hide is received and processed through the tanning operation.
It is then transferred to the retan/finisher where processing
continues, beginning with the retan, color, and fatliquor
cycle, and ending with the finishing, measuring, and packaging
of the leather.  Only a small number of beamhouse/tanhouse
operations currently produce "blue stock," or chrome tanned
leather which  has not yet been retanned and finished.
However, a number of tanneries are investigating the
possibility of establishing their own remote beaming and
tanning operations.  Several complete chrome tanneries have
experimented, with varying degrees of success and acceptability,
with using blue stock purchased from a beamhouse/tanhouse
facility.  The trend for the establishment of these two types
of operations was taken into account for purposes of projecting
waste quantities in 1977 and 1983.
     These seven categories were developed to provide as
accurately as possible a picture of the solid waste generated
in the leather tanning and finishing industry.  They include
                              46

-------
as much of the industry as possible and yet minimize the
number of categories.  In addition, the categories were
designed to account for production trends in order to
project the quantities of waste generated in 1977 and 1983.
     Table 12 lists the number of establishments in each
category by state and EPA Region.  As shown, all types of
tanneries, except beamhouse/tanhouse facilities and vegetable
tanneries, are located primarily in EPA Regions I, II, and V.
Vegetable tanneries are located primarily in EPA Regions III
and IV, and beamhouse/tanhouse facilities are distributed
quite evenly among EPA Regions V through IX.
                              47

-------
                                       TABLE  12




                         DISTRIBUTION OP TANNERIES DY CATEGORY
Region
X
IX
IX
VIII
III
IV
IV
V
V
VII
IV
VI
I
III
I
V
V
VII
VII
I
II
II
IV
V
X
III
IV
VI
VIII
I
III
X
III
V
Total
Region









States Containing
Tanneries
Alaska
Arizona
Ca .ifornia
Colorado
Delaware
Florida
Georgia
Illinois
Indiana
Iowa
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Missouri
Nebraska
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oregon
Pennsylvania
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin

I
II
III
IV
V
VI
VII
VIII
IX
X
Total
1
1
14
4
3
3
1
11
2
2
3
1
9
1
79
3
4
3
1
14
25
46
3
4
4
14
9
4
1
1
2
2
2
21
298
103
71
22
19
45
5
6
5
15
7
Complete
Chrome
1

9
3
1
1

8



1
3

15
3
2
1
1
9
4
15

1
3
5
5

1

1
2

12
107
27
19
7
6
26
1
2
4
9
6
Vege-
table






1
1
2

3


1



1




2

1
3
2
1


1

2

21


7
8
3
1
1


1
Split


1




1






14




l

2











5
24
15
2


6



1

Beamhouso/
Tanhouso

1
1
1





1






1
1


1






7





1
10

1


2
Z
2
1
2

Rctan/
Finish


2









1

7




1
3
6



3
1






1
25
9
9
3
1
1



2

leather
Finish


1

2


1




1

29

1


1
16
10
1
3


1






1
68
31
26
2
2
6



1

Sheop
skin





2



1


4

14




;
~J
13



3

1

1



i
43
21
14
3
Z
1
1
1



Source:  Tanners' Council of America
                                          48

-------
                         SECTION 3.0

                   WASTE CHARACTERIZATION


             3.1  Development of Typical Plants

     In this section, production processes and the types
and quantities of process solid waste  resulting from each
process are described for each category of the industry.  A
definition of potentially hazardous waste is presented, and
the types and quantities of process solid waste  currently
generated which are potentially hazardous and are destined
for land disposal are identified.  Projections are made for
the quantities of solid waste  anticipated to be produced
in 1977 and 1983.  Waste quantity projections are based upon
estimates of changes in industry production, the effects
of air and water pollution control regulations, and various
in-plant process changes.  In addition to waste quantities,
the quantities of hazardous constituents within the potentially
hazardous wastestreams are presented for 1974, 1977, and
1983.
     In order to present the available information in a
concise and understandable manner, "typical" plants have
been identified for the major categories of tanneries.  Mass
balance diagrams for these typical plants reflect general
operations as well as input and output of materials per
unit of production.  It must be emphasized that tanneries,
even within the categories described in this section, vary
widely in size and operation, e.g., 100-fold differences.
All typical plants are located in urban areas, predominantly
in the East or Midwest (EPA Regions I, II, III, IV) and
utilize contract services for solid waste hauling and
disposal.  All of the typical plants are 50 years old with
the exception of the beamhouse/tanhouse facility which is
15 years old.

     3.1.1  Approach to Waste Characterization.  Process
solid waste is defined, for this study, as solids, sludges,
and other waste generated directly as a result of the
manufacturing processes in the industry and normally disposed
to the land.  These wastes primarily consist of small pieces
of leather in various stages of processing or sludges
collected from sewer sumps or wastewater treatment facilities.
Other items in the process wastestream include:

     .  Salt and string from the hide receiving areas.
        Empty bags and drums from chemical mixing areas.
     .  Finishing residues (scrapings and sludges) from
        finishing department.
        General plant floor sweepings.

                             49

-------
     Not included as process solid waste was:

        Office and lunchroom waste.
        Paper towels, etc. from restrooms.

     In order to determine the types, quantities, and
characteristics of the process solid waste generated by the
tanning industry, 41 tanneries were visited.  During the
tannery visits, the following types of information were
obtained:

        Production.
        Types and quantities of chemicals used.
        Types and quantites of solid waste generated.
        Analytical wastewater information, particularly
        quantities discharged and solids content.
        Information concerning air pollution control
        devices and solids generated.
        By-product sales data.

     A total of 156 waste samples were collected from 28
of the 41  tanneries visited.  These samples were
subsequently analyzed for a variety of hazardous organic
and  inorganic constituents.  An outline of the procedures
for  collection, shipment, and analysis of the samples
is included in Appendix B.
     Utilizing the data collected at the tanneries and the
laboratory analytical results, a matrix was developed for
each major type of wastestream found in tanneries.  Figure
 4 is an excerpt from one of the matrices.  Examination
of the matrices showed clearly where variations in the
composition of a particular waste occurred as a result of the
type of tannery in which it was generated.  Based upon this
and a consideration of production trends in the industry,
the seven categories of tanneries were identified.  As an
example of the use of the matrix, the toxic, heavy metal
content in wastes from vegetable tanneries was at a level
below the selected threshold.  This was the only group of
tanneries for which this was true and thus led to the
establishment of vegetable tanneries as a separate category.
     In order to summarize the operations performed at each
of these seven categories of tanneries, mass balance
diagrams were developed and are included in Sections 3.3
through 3.9.  Each diagram is divided into three sections
vertically.  General processing steps are shown down the
center.  The materials added are shown on the left and the
finished leather, by-products, and waste are shown at the
bottom and right.  The figures shown are the kg of each
constituent  (on a dry weight basis) per 1000 equivalent
hides.

                             50

-------
                      FIGURE  4
                EXAMPLE OF WASTESTREAM MATRIX
Plant and Sample No.
Process
Production (hides/day)
Waste Quantity
(Ib/day) g|

-------
     Utilizing the above data, information regarding
industry production and trends provided by the Tanners'
Council, and a criteria developed for defining potentially
hazardous waste  (discussed in Section 3.2), the quantities
of total process solid waste and potentially hazardous
solid waste were estimated for 1974, 1977, and 1983.  Waste
generation factors were developed for each wastestream and
hazardous constituent  for each category of tannery.  These
factors are in kg per 1000 equivalent hides and take into
account process changes which will vary the generation rates.
Production for each category of tannery in each state during
1974 was provided by the Tanners' Council and was projected
for 1977 and 1983.
     Each of the seven tannery categories is discussed in
turn, in Section 3.3 through 3.9:   The major points
included in each section are:

        Plant operations (including the mass balance diagram).
        Discussion of sources and quantities of potentially
        hazardous and non-hazardous waste.
        Factors affecting future solid waste generation.
        Summary tables of waste quantities (both total
        process and potentially hazardous solid waste).

     3.2  Determination of Potentially Hazardous Waste

     3.2.1  Criteria.  "Potentially hazardous waste" is
defined as waste or combinations of waste which pose a
substantial present or potential hazard to human health or
living organisms because such waste is lethal, non-degradable,
or persistent in nature; may be biologically magnified; or
otherwise cause or tend to cause detrimental cumulative
effects.3 Waste is classified as potentially hazardous due
to the presence of hazardous constituents at a concentration
level above a selected threshold.  Thus, the constituents
of the waste, e.g., specific, toxic, heavy metals, are
referred to as hazardous.  These hazardous constituents make
a waste potentially hazardous if they occur in sufficient
concentration.
     Potentially hazardous waste contain constituents which
are:

        Radioactive.
        Infectious.
        Explosive.
        Flammable.
        Irritants or strong sensitizers.
        Corrosive.
        Toxic.
                            52

-------
Of the above listed characteristics which may make a
wastestreara potentially hazardous, toxicity is the most
significant to this study, and at the same time the most
difficult to define.  The toxicity of a substance is  largely
dependent upon the concentration levels under various
environmental conditions.  An assessment of the degree of
hazard introduced by the disposal of waste containing naturally
occurring constituents is  not a simple straight line or
exponentially increasing function starting from zero, as it
may be for many synthesized compounds.  This results  from the
fact that life forms have evolved in the presence of, and
acclimated to, these naturally occurring elements and their
compounds at the naturally occurring background concentration
levels in various environmental media.  As a result,  many
of the substances of particular concern in this study,
primarily heavy metals, are prerequisites to life in  trace
quantities, but are toxic at higher concentrations.
     The uncertainty and confusion about what concentration
levels are hazardous arises because:

        In the complete absence of certain elements,  life
        cannot exist.
     .  There is a vaguely defined intermediate concentration
        range in which these substances are essential and/or
        can be tolerated.
        There is a higher level above which chronic and acute
        toxicity may result.

     A clear definition of the threshold toxicity level of
a particular element or compound is further complicated by
the fact that these threshold concentration levels are:

        Highly variable from one species to another.
        Extremely dependent upon the medium or environment
        in which they live, and on the medium of exposure
        (water, soil, or air).
        Altered by synergistic or antagonistic reactions
        in a particular environment.
     .  Affected by such factors as temperature, pH, and
        the presence of other ionic species.

     Furthermore, the form in which an element occurs, e.g.,
as a mineral, as a pure element, or as a water soluble salt
or oxide,  strongly influences its toxicity to various organisms.
Previous studies and lists of hazardous materials promulgated
by Federal agencies served as the basis for determining whether
a given wastestreara constituent should be considered
hazardous.
                             53

-------
     3.2.2  Definition of Potentially Hazardous Waste.
Definitive information concerning the environmental fate
and subsequent effects of the hazardous constituents  in the
solid waste generated by the leather tanning and finishing
industry is not available.  Scientific studies of the
environmental fate of tannery solid waste following land
disposal have not been conducted, and in many instances the
chemical structure of tannery solid waste is not well
understood.  As a result, it was necessary to select a
recognized, reasonable reference for identifying the
concentration level at which a hazardous constituent  should
be present in order to consider a waste as potentially
hazardous.  As a guide as to what constitutes potentially
hazardous concentration levels in waste destined for land
disposal, the geometric means of the background concentration
levels of these constituents in soils in the United States
were used as this reference.4 Table 13 lists these values for
heavy metals.
     The geometric mean concentration in U.S. soils was
selected because the study was confined to and focused on
land disposal of tannery waste in this country.  As noted
earlier, little is known of the environmental fate of tannery
waste following land disposal.  The geometric mean soil
concentration gives the best indication of the concentration
of hazardous constituents in the soil environment which
plant and animal life can surely tolerate.  However, increases
in the concentration of hazardous constituents above these
levels may result in an adverse impact on the environment.
Consequently, tannery waste with hazardous constituent
concentrations above the corresponding mean soil concentration
should be considered potentially hazardous until such time
as studies are conducted which indiate a different value
is environmentally sound.
     During this study, waste samples were collected and
analyzed to determine the concentrations of potentially
hazardous constituents in all types of tannery solid waste.
The results of these analyses showed that copper, zinc, lead,
and trivalent chromium were present in various types of solid
waste at concentrations exceeding the geometric mean background
levels present in U.S. soils.  The information available
in the relevant literature and previously contracted studies
indicates that copper, lead, zinc, and trivalent chromium
are moderately to highly toxic materials.7'11'12
     Samples were analyzed for other heavy metals (mercury,
arsenic, zirconium, beryllium, cadmium, and selenium) and
other hazardous constituents (pesticides and phenols), but
none were found in significant quantities.
     Eight types of solid waste from tanneries producing
chrome tanned leather were identified as being potentially
hazardous due to their heavy metal content.  Additionally,


                             54

-------
                                            TABLE 13


                GEOMETRIC MEAN COMPOSITIONS, AND GEOMETRIC DEVIATIONS, OF SAMPLES OP SOILS
                    AMD OTHER SURFTCIAL MATERIALS IN THE CONTERMINOUS UNITED STATES


                              (GEOMETRIC MEANS REPORTED IN PARTS PER MILLION)
ui
01
The conterminous
United States
n* = 863
Element
Al
B
Ba
Be
Ca
Co
Cr
Cu
Fe
Ga
K
Kg
Mn
Ha
Hi
P
Pb
Ti
V
In
It
Geometric
mean
45,000
26
430
0.6
8,800
7
37
18
18,000
14
12,000
4,700
340
4,000
14
250
16
2,500
56
44
200
Geometric
deviation
2.41
2.05
2.06
2.49
3.92
2.21
2.32
2.28
2.30
2.11
2.71
3.19
2.70
4.11
2.26
2.74
1.96
1.87
2.16
1.86
1.90
Western United States
(west of 97th merMian)
n* ss 492
Geometric
mean
54,000
22
560
0.6
18,000
8
38
21
20,000
18
17,000
7,800
389
10,200
16
320
18
2,100
66
51
170
Geometric
deviation
2.02
2.09
1.80
2.47
2.93
2.01
2.16
2.00
1.90
l.?l
1.60
2.21
1.94
1.98
2.03
2.33
1.93
1.82
1.91
1.78
1.78
Eastern United States
(east of 97th meridian)
ri* ?=• 371
Geometric
mean
33,000
32
300
0.6
3,200
7
36
14
15,000
10
7,400
2,300
285
2,600
13
180
14
3,000
46
36
250
Geometric
deviation
2.70
1.92
2.19
2.53
2.87
2.55
2.52
2.54
2.76
2.53
3.56
3.39
3.65
4.11
2.60
3.03
1.96
1.84
2.41
1.89
1.95
         Sources  Reference 21

              • n » Number of samples,

-------
the finishing residue wastestream (already categorized as
potentially hazardous because of its metal content) also
contains flammable solvents and is thus considered potentially
hazardous on two counts.  The wastestreams categorized as
potentially hazardous are shown in Table 14.   Also listed are
the concentrations (mean .and range)  on a wet weight basis.
This is compared to the geometric mean concentration in U.S.
soils.  The mean concentration of trivalent chromium in
all waste was well above the soil concentration, ranging from
59 to 457 times the mean concentration in U.S. soils.

     3.2.3  Discussions of Hazardous Constituents-.  Information
on the toxicity of copper, lead, zinc, and trivalent chromium
is summarized in Table 15.   As the table indicates, all of
these metals have been shown to be moderately toxic  (LDso
from 500 to 5,000 mg/kg) or very toxic (LD5p from 50 to 500
mg/kg), as a result of tests on experimental animals.
     Although the environmental effects of lead, zinc, and
copper are not completely understood, the phototoxicity of
zinc and copper to agricultural crops, the toxicity of lead
to man, and the toxicity of all three elements to various
aquatic organisms, is well established.  The toxicological
information on chromium, however, is conflicting.  Of these
four elements, only lead is thought .to have detrimental
effects on human health in low to moderate concentrations, and
correspondingly only lead has a mandatory drinking water
standard.  Zinc and copper have recommended limits.  Hexavalent
chromium has a mandatory limit, but there is no stated limit
for trivalent chromium.13

     Chromium.  Chromium and its compounds take on unusual
importance in this study because of-their prevalent use in
the tanning process.  Chromium occurs often, and in high
concentrations, in both wastewater and solid wastestreams.
The chrome tanning process employs basic trivalent chromium,
chromic sulfate (empirical formual Cr(OH)SO4).  However, some
tanneries purchase sodium dichromate  (hexavalent chromium)
as a raw material and reduce it to trivalent chromium
preparatory to usage.  In its hexavalent state  (as chromic
oxide, chromate, or dichromate), chromium is a strong
oxidizing agent which reacts readily with organic matter in
acidic solution.  Complexes in which hexavalent chromium
would be stabilized against reduction by organic matter are
now known.  All biologic interactions with chromate should
result in reduction to the trivalent form and later coordination
to organic molecules.  This has been widely demonstrated by
the effect of chromate on skin, the interaction of dichromate
or chromates with nucleic acids and  with the reaction and
fate of chromate injected into experimental animals.9


                            56

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                                        TABLE 14


                           POTENTIALLY HAZARDOUS TANNERY HASTES
                                               Anal'
                                     Results
Waste Stream
Be. of
Samples
 Hazardous
Constituent*
Concentration
 (wet weight-
    mg/kg)
                                                               concentration
                                                                    Range**
                                                                 (wet weight-
Geometric Mean
Concentration in
O.S. Soils (dry
weight-mg/kg)
Chrome (blue)           10
 trimmings i
 shavings

Chrome fleshings         1

Unfinished chrome        9
 leather trim
Buffing dust            12
Finishing residues      1C
Finished leather
 trim
               Cr+3
                 +3
               Cr
               Cu
               Pb
               •n
               Cu
               Pb
               In

               Cr**
               Cu
               Pb
               Sa
                  7,600
                  4,000

                 16.900
                     90
                    iao
                     60

                  5,700
                    960
                    ISO
                    160

                  3.500
                     40
                  8.400
                    ISO"

                 14.800
                  1,000
                 2,200-21,000
                 4.600-37,000
                   2.3-468
                   2.5-476
                   9.1-156

                    19-22,000
                    29-1,900
                     2-924
                  0.45-12.000
                  0.35-208
                   2.5-69.200
                    X4-87C

                 1.600-41.000
                   100-3.300
                                                                                      37
     37

     37
     18
     16
     44

     37
     18
     16
     44

     37
     18
     16
                                                                37
                                                                16
 Sewer screenings
  17
                                    Pb
                                    In
                  2.200
                     30
                     60
                  0.27-14.000
                     2-110
                    35-128
     37
     16
Mastewater treatment    27
 residues (sludges)
               Cr
               Cu
               Pb
               Sn
                                      ,+S
                  3,700
                    370
                     60
                     50
                  0.33-19.400
                  0.12-8,400
                  0.75-240
                   1.2-147
     37
     18
     16
     44
Sourcet  Laboratory analytical results and Reference 21

      t  Since tannery wastes ere land disposed in a wot condition, i.e.,
         containing moisture, reporting constituent concentrations oa a
         wet weight basis realistically portrays the waste streams*
         chemical characteristics with respect to hazardous constituents.
         Constituent concentrations in O.S. soils were not available on a
         wet weight basis.  Geometric mean values one wet weight basis would
         be slightly less than those reported above.  Thus the method of
         reporting the concentration* (wet or dry basis) does not impact
         on the designation of a waste stream as non-hasardous or potentially
         hasardoua.

     •  For which analyses were made.
     ••  Range not shown when only one sample was anelysed for the constituent.
                                            57

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                                                  TABLE 15


                           SUMMARY OF TOXICITY-RELATED INFORMATION FOR CHROMIUM (III) ,
                                      LEAD, ZINC, AND COPPER
ui
00

LD50
TL
n
USPRS
Drinking
Water
Standard
Chromium (III)
Cr,(S04)3:
500 to 57000
mgAg
1.2 - 40 mg/1.
various species
under various
conditions.
None for Cr
(III); 0.05
mg/1 for Cr(VX)-
mandatory
Lead
Salts: 50 - 500
mg/kg
0.1 - 6.3 mg/1.
various species
of fish, 24 -
96 hours.
0.05 mg/1 -
mandatory
Zinc
Salts: 50 - 500
mgAg
0.1 - 13 mg/1.
Various species
of fish 24 -
96 hours.
5.0 mg/1
(recommended)
Copper
Salts: 50 - 500
mgAg
0.02 - 3.0 mg/1.
Various fish
under various
conditions.
1.0 mg/1
(recommended)
             Sources  References 15. 19

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     This organic reduction of any residual hexavalent
chromium to the trivalent form during the tanning process
has been confirmed by analytical testing of a cross-section
of chromium containing wastestreams selected at random as
a part of this study.  Eighteen such determinations were made
on the following samples:

     Waste type                       No. of samples

     Trimmings and shavings                 3
     Buffing dust                           2
     Finishing residues                     3
     Screenings                             2
     Wastewater treatment sludge            8

     Hexavalent chromium concentrations in all 18 samples
analyzed were below the detection limit (0.05 mg/1).
Based on this, there is strong reason to believe that even
accidental spills of hexavalent chromium would be reduced
before leaving a tannery if conveyed through a portion of
the sewer system and/or treatment process.  One instance
of hexavalent chromium appearing in tannery waste has been
reported.14  However, this isolated report has not been
confirmed.  Thus, the only chromium compound of concern and
interest in this study is trivalent chromium.
     Trivalent chromium is far less toxic than hexavalent
chromium based upon available information in the literature.5'6''
Since a large percentage of the chromium containing solid
wastestreams are now being land disposed,  the concentration
ranges at which chromium impacts on plant and animal forms
is of crucial importance to this study.  Some information
is available on the effects of chromium on plants which
generally indicates that low concentrations of chromium
appear to be beneficial,  or possibly even essential, whereas
higher concentrations may be toxic.   The effects vary with
species and with specific chromium compound.   The effects
on plant growth of adding chromium to the soil depend upon
the amount of chromium naturally present in the soil.  In
some instances, crop yields have been improved by application
of chromium to soils.  The following examples have been
excerpted from the literature:

     .   The addition of chromic sulfate (Cr2(804)3)  to 8oil
        at 600,000 mg/ha  (0.54 Ib/acre)  improved the weight,
        size,  and sugar content of grapes  by  21,  18,  and 23
        percent,  respectively, while increasing the yield
        by 205 to 245 kg/ha (183 to 219 Ib/acre),15
        The application of a fertilizer containing 4,300
        mg/kg chromium resulted in increased  growth in
        flax grown on sand.16


                             59

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         Addition of chromous  acetate  in  concentrations of
         500 mg/1 or less  had  a  beneficial  effect  on  carrots,
         barley,  lupines,  and  cucumbers.17
         Application of chromium (as the  alum)  at  40,000
         mg/ha (0.036 Ib/acre) to  a soil  containing
         extractable chromium  at only  65  mg/kg  increased
         the yield of potatoes from 32.7  to 46.5 tons
         per hectare (13.2 to  18.8 tons/acre).18   Similar
         results  were obtained for peas,  carrots,  and beets.19'20
      .   Applications of potassium dichrornate at 30,000 and
         100,000  mg/m3 (0.03-lb/yd3) of soil increased  the
         yield of cucumbers.
      .   Chromium at 1 mg/1 in nutrient solution benefited
         lettuce  slightly.21
         Chromium at 5 mg/kg increased the  rate of
         nitrification.  Z1

Conversely,  a number of observations  have  been made  of toxic
effects  of  trivalent chromium as  follows9:

               Tolerated        Toxic
             concentration  concentration
Plant            (ppm)           (ppm)        Chemical  form

Orange
 seedlings         75             150           Chromium
Corn
 seedlings           .5             5           Chromic  sulfate
Tomatoes,          16             —           Chromium as
 Oats, Kale,  (yield                           Chromate
 Potatoes     reduced)
Oat           5-10  (produced     15-50           Chromium
 Plants       iron  chlorosis)                   (chromic or
                                               chromate)
Tobacco            —              5           Chromate
Corn               —             10           Chromate

     in  addition,  toxicity has  sometimes been  associated
with trivalent chromium in plant tissues.   In  fruits,
vegetables,  and grains concentrations from  trace  amounts
to 14 mg/kg  (dry tissue) were generally tolerated; but
toxic effects appeared in corn with leaves  containing
4 to 8 mg/kg and in oats with leaves containing 252 mg/kg.
Tobacco  grown in serpentine soil with an atypically high
concentration of trivalent chromium showed  toxic  symptoms
when the leaves contained 18 to 34 (dry weight) mg/kg,
although no toxic effects were visible at 14 mg/kg.  The
roots showed signs  of toxic effects at 375  to  400 mg/kg.21
                             60

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     Toxicity of trivalent chromium to various  aquatic
organisms has also been reported in the literature  and is
summarized in Table 16. 6'9    Conversely, recent attempts
to repeat some of the earlier studies regarding the toxicity
of trivalent chromium to sticklebacks and other fish have
ended with the conclusion  that pH and/or the solubilizing
agents used were the cause of the reported toxicity.8
     Since the predominant method of disposal of chromium
containing tannery waste is land disposal, concern  for the
environmental impact of disposal centers on the propensity
of a chromium containing waste to leach, its relative
mobility, soil attenuation properties, and possible
contamination of groundwater supplies.
     Because the escape of chromium containing  leachate
into the groundwater or to a receiving water body is the
major concern, the Tanners' Council of America  conducted
(as part of this study) leaching tests of various chromium
containing solid waste.  These tests, using distilled water,
indicate that from 200 to 400 mg of trivalent chromium is
released from 1 kg of trimmings and shavings in periods
ranging from 24 to 72 hours.2
     Other research has shown that chromium is  relatively
unaffected by most organic acids but is solubilized slowly
by acetic acid. y  Acetic acid is a major component  of most
anaerobic fermentation or digestion processes within
landfills, comprising an estimated 30 to 60 percent of the
total organic acids produced.   These two studies suggest
that trivalent chromium could ultimately be leached out of
the waste material.
     As the preceding paragraphs have indicated, the existing
information on the toxicity of trivalent chromium to plants
and aquatic organisms is contradictory in many  instances.
However, trivalent chromium could ultimately be leached
from tannery waste, and since it is reported by some
researchers as being toxic to various plants and aquatic
organisms, trivalent chromium is considered to be a hazardous
constituent of tannery solid waste.

                3.3  Complete Chrome Tannery

     3.3.1  Plant Operations.   The basic processes used to
produce chrome tanned and finished leather are shown in
Figure 5.     Brine cured,  prefleshed cattlehides represent
approximately 70  percent of the raw material of the tanning
industry.   The other 30 percent of the raw material utilized
is fresh and salt cured cattlehides or pigskins.    As
received,  hides contain about  50 percent moisture.   After
receipt at the tannery,  the hides are normally sided (cut
in half down the  backbone)  to  facilitate processing, and
then soaked in water to return the natural moisture to the

                            61

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                        TABLE 16

              TRIVALENT CHROMIUM TOXICITY TO
                  AQUATIC ORGANISMS
Concentration
of trivalent
chromium, mg/1
1.2
1.3
2.0
2.4
5.0
5.2
-
40


4C1.2

5
37
42
75


27

0.33
Compound
Used
Cr2(S04)3
Cr2(S04)3
Cr2(S04)3
Cr2(S04)3
Cr2(S04)3
KCr(S04)2
^1 w
Cr2(S04)3
• *9 ij

CrCl3

Cr (III)
Cr (III)
Cr (III)
Cr (III)


Cr (III)

Cr (III)
Organism
Sticklebacks
Sticklebacks
Sticklebacks
Sticklebacks
Sticklebacks
Young eels

Minnows


Daphnia magna

Scenedesmus
Microegma
Daphnia
Polycelisnigra
(flatworm)

Flathead
minnows
Daphnia
Remarks
Lethal limit.
Survived only 1 wk
Survived only 2 days
Lethal limit
Survived only 1 day
Survived an average
of 18.7 hours
Survived in dis-
tilled water only
6 hours
25° C Lake Erie
water
Toxic threshold
Toxic threshold
Toxic threshold
Toxic threshold in
48 hours of
exposure
96 hour XiC^g

Chronic. No effect
                                            level for
                                            reproduction
Source:  References 6,9
                               62

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                              FIGURE 5
                             PROCESS FLOW DIAGRAM
                       TYPICAL COMPLETE CHROME TANNERY

           (all units are kg/1000 equivalent hides on a dry weight basis
            except solid wastes which are given on a wet/dry basis)
MATERIALS ADDED
CURED CATTLE HIDES
     (12.300)
BACTERICIDES (2)1 4 .
LIME (900) V_ SIDE I
NA2S/NAHS (230) f~~ 	 • 	 ft SOAK [~
SODA ASH (450) | FLESH
£ |
CRQHSO  DRY
WATER L SOLVFMT 1 TBlu
BASE FINISHES ( 1 000 If—* CONDI T ION
MISC. (100) J BUFF
y FINISH
TRIM
FINISHED LEATH
(5000)
xn FLESHINGS (800) J ',


SOLID
(550/
PROCESS
WASTES A M
450)
1
xrvTRIM (325/140) ^ ^
X|N SHAVINGS (430/400) A I
A SPL I TS
(7600/3400) J
1
J BY-PRODUCTS
JL^J* VOLATILES TO
f^^^*"^^ ATMOSPHERE (450)
ALEATHER
ABUFFING
TRIM ( 1 14/10O) g
DUST (27/25) 11
xKFINISHING RESIDUES (ISO/45) II
XINFINISHED LEATHCR TRIM Ij
* (220/200) "•
ER WASTEWATER f
r~ i
SCREENING
A
SEWER
SUMP
WASTEWATER
TO SEWER
(SOLIDS - 92
SCREENINGS (390/9O) J
' M
1
SLUDGE (2700/300) **
\
\
\
00) |
4
                                                         PROCESS SOLID WASTES
                                                        TO SANITARY LANDFILL
                                                           (5.410/1.750)
                                     63

-------
 hide fibers.   Excess flesh and fatty substances which
 adhere to the hides are removed mechanically,  and the hides
 are treated with lime and sodium sulfide to dissolve the
 hair.   The hides are then treated with an enzyme in order
 to loosen the fiber structure ("bated"), pickled to prepare
 the hide fibers for penetration of the tanning substance,
 and then tanned with a solution of basic chromium sulfate
 Cr(OH)SO,.
      Following tanning,  excess moisture is removed by
 wringing, and the hides are then split to obtain a uniform
 thickness, and shaved to obtain the exact thickness
 desired.   The resulting blue trimmings and shavings contain
 about 60 percent moisture.   Next,  the hides are retanned
 with vegetable extracts or synthetic tanning agents (syntans)
 colored with a water soluble dye or pigment, and fatliquored
 (a process in which oils are added to the hides to impart
 the desired degree of flexibility).   The hides are stretched
 on a metal frame, pasted on large plates,  or hung on racks,
 and then dried in an oven or heated room.   The resulting
 leather is trimmed to remove ragged edges,  physically
 conditioned to soften the leather,  and buffed  to smooth
 the grain surface or the flesh side of the hides.   At this
 point,  the leather containing about 10 percent moisture  may
 be sold,  but  is normally finished with a water or solvent-
 base preparation to improve wear,  improve its  water repellent
 characteristics,  and/or alter its  color.   The  finished
 leather (also with a 10  percent moisture content)  is then
 trimmed and measured,  and is ready for sale.   A typical
 tannery in this category processed 260,000 equivalent hides
 in 1974.2
     Figure 5 also indicates the basic production operations
 performed,  the types and quantities  of raw materials and
 products  involved,  and the  types and  quantities of waste
 products  resulting from  the  production process.

      3.3.2 Potentially  Hazardous  Solid Waste.   Several  kinds
 of solid  waste is generated.The potentially  hazardous
 wastestreams  are  discussed  below.

     Blue Trimmings  and  Shavings.  Blue trimmings  and shavings
 are  generated when tanned hides  are  split  and  shaved to
 obtain  a  uniform  thickness.  Average  generation rates are
 325  (wet)/140 (dry)  kg per  1000  equivalent  hides  for trimmings
 and  930  (wet)/400  (dry)  kg per  1000 equivalent  hides for
 shavings,  which on  a national basis,  totals  19,500  (wet)/
 8,850  (dry) metric  tons  per  year.  The  latter  figures were
 calculated  using  production  data supplied by the Tanners'
Council of  America.  Samples were collected  from the  shaving
machine and from  fiber drums in  the trimming department of
 six complete  chrome  tanneries.  Analysis of these  samples


                             64

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 indicated  that this  type of  solid waste  has  an average
 chromium concentration of  9,600  (wet)/22,300 (dry)  mg/kg,
 with  a range of 10,000 to  28,000 mg/kg on  a  dry weight
 basis.
      Other naturally occurring hazardous constituents  are
 present only at concentrations below  their respective  average
 background concentrations  in  soils, if at  all.   Synthetic
 substances were not  detected  in this  wastestream.

      Unfinished Leather Trim.  Following drying and before
 finishing, the sides of leather are normally  trimmed to
 remove ragged edges  which  would interfere  with the  finishing
 process.   The average rate of generation of  this waste
 material is 114 (wet/100  (dry) kg per 1000 equivalent
 hides, which on a national basis amounts to  1,900  (wet)/
 1,650 (dry) metric tons per year.  Analysis  of samples
 collected  from the trimming departments  of seven tanneries
 indicated  the presence of  the following  hazardous
 constituents:

                   Avg. concentration   Concentration rang?;
                          {mg/kg)               (mg/kg)
 Constituent        Wet	Dry   	Dry	

 Chromium           15,000        17,000    3,600 -  42,000
 Lead                  110           130         3 -     530

      Buffing Dust.  Buffing dust is produced when the  dried
 and trimmed leather  is mechanically sanded to  remove surface
 imperfections or improve the nap of the  flesh  side.  A
 representative tannery in  this category  generates 27 (wet)/
 25  (dry) kg per 1000 equivalent hides, and all  complete chrome
 tanneries generate a total of 443 (wet)/400  (dry) metric
 tons  per year.   Analysis of samples taken  from  the  dry
 buffing dust collectors (cyclone collectors  and bag houses)
 at seven plants showed the presence of the following
 hazardous constituents:

                   Avg. concentration    Concentration range
                         (mg/kg)                (mg/kg)
Constituent        Wet	Dry    	Dry	

Chromium           20,000        22,000    1,200 -  60,000
Lead                   71            77       44 -     120

     Finishing Residues.   Finishing residues are produced as
a result of water-wash air pollution control devices on spray
booths and from general cleaning of the finishing equipment.
A representative complete chrome tannery generates  150 (wet)/
45 (dry)  kg per 1000 equivalent hides  processed, which

                             65

-------
amounts to 2,460 (wet)/738 (dry) metric tons per year on
a national basis.  Analysis of samples taken from the finishing
area in nine tanneries indicated the presence of the following
hazardous constituents:

                   Avg. concentration     Concentration range
                          (mg//kg)             (mg/kg)
Constituent        Wet            Dry
Chromium              525        1,700       <4 -  5,200
Lead                1,100        3,600      <10 - 17,000
Zinc                  105          340    Not de-  1,400
                                          tected

     In addition, flammable organic solvents comprise
approximately 10 percent of the wet weight of this waste.
This amounts to 15 kg (wet) per 1000 equivalent hides
processed or 246  (wet) metric tons per year nationally.
These solvents also make this waste potentially hazardous.

     Finished Leather Trim.  The final operation performed
before packaging the finished leather for shipment is
trimming.  A representative plant produces 220  (wet)/200  (dry)
kg per 1000 equivalent hides processed, which on a national
basis amounts to 3,610 (wet) /3, 280 (dry) metric tons per
year.  Analyses of samples taken from the trimming and
shipping department of three plants indicated the presence
of the following hazardous constituents:

                 Avg. concentration     Concentration range
                       (mg/kg)               (mg/kg)
Constituent      Wet _ Dry     __ Dry _

Chromium         19,100        21,200     7,600 - 45,000
Lead                250           280        120 -    460

     Wastewater Screenings.  A representative complete
chrome tannery screens its wastewater prior  to discharge
for further treatment.  This process generates  390  (wet)/
90  (dry) kg of solid waste per 1000 equivalent hides processed,
which on a national basis amounts to 6,400  (wet) /I, 480  (dry)
metric tons per year.  Samples were collected from the
wastewater screens at seven complete chrome  tanneries.  An
analysis of these samples indicates that the following
constituents are present in potentially hazardous concentrations:
                              66

-------
                  Avg.  concentration     Concentration range
                        (rag/kg)               (mg/kg)
 Constituent       Wet	Dry     	Dry	
 Chromium             965         4,200        5 - 14,000
 Lead                  40           176       43 -    190

     Wastewater Treatment Sludges (from sewer sumps).  A
 representative complete chrome  tannery utilizes sewer sumps
 to remove  solids  from their wastewater prior to discharge,
 and generates 2,700  (wet)/300  (dry) kg of  wastewater solids.
 per 1000 equivalent  hides processed, which amount  to
 34,100  (wet)/3,800  (dry) metric  tons per year from all
 complete chrome tanneries in the  Nation.   Analyses of
 samples taken from sewer sumps at seven plants indicated
 that the following constituents  are present in potentially
 hazardous  concentrations:

                 Avg. concentration      Concentration range
                       (mg/kg)               (mg/kg)
 Constituent      Wet	Dry      	Dry	

 Chromium          2,700        24,000       280 - 75,000
 Copper               190          1,700        20 - 13,300
 Lead                  25            230        40 -     380

     Waste Treatment  Sludges (from primary and/or  secondary
 treatment).  A few aytpical complete chrome  tanneries
 utilize primary pretreatment (with a rectangular or  circular
 clarifier) prior to discharge to  a municipal sewer.   In a
 very few instances, primary treatment  is followed  by secondary
 treatment  (activated  sludge)  prior to  direct discharge.
     Complete chrome  tanneries with primary  and/or secondary
wastewater treatment  and kludge dewatering remove  an average
 of 10,000  (wet)/2,400 (dry)  kg of wastewater sludge  per 1000
 equivalent hides processed,  which on a national basis  amounts
to 34,000  (wet)/8,100 (dry)  metric tons per  year.  The
 limited number of plants employing primary and/or  secondary
wastewater treatment, and variations (unquantified)  among
plants in the quantities of  chemicals used,  prevented  the
development of separate generation factors for plants
utilizing primary treatment  and those with both primary  and
secondary treatment.   Analysis of samples of primary and/or
secondary wastewater treatment sludge collected from the
treatment systems at seven plants indicated that the following
constituents are present in  potentially hazardous concentrations:
                             67

-------
                 Avg. concentration     Concentration range
                       (rag/kg)              (mg/kg)
Constituent      Wet	Pry     	Pry	

Chromium          7,700        38,800     15,500 - 75,000
Copper              420         2,000         50 -  5,800
Lead                 65           310       <10 -    800

     Approximately 20 percent of the complete chrome
tanneries employ primary and/or secondary treatment of their
wastewater, and most of the remaining 80 percent of this
category of the industry utilize sewer sumps to remove solids
from their wastewater.   As a result, a total of 68,100 (wet)/
11,800  (dry) metric tons per year of sludge are currently
being generated from these sources nationally.

     3.3.3  Non-Hazardous Solid Waste.   Miscellaneous
process solid waste is generated at a rate of 500  (wet)/
450 (dry) kg per 1000 equivalent hides processed, which
amounts to 8,400 (wet)/7,600  (dry) metric tons per year on
a national basis.  This waste is composed of empty fiber
drums and paper bags, strings cut off the hides, and general
plant floor sweepings, and they do not contain consitutents
at potentially hazardous concentrations.  Fleshings generated
by nearly all chrome tanneries are sold; they were, therefore,
not considered as a solid waste.

     3.3.4  Factors Affecting Future Solid Waste Generation.

     Air Pollution Control.  Air pollution control devices
are used to remove particulates produced by the spray
finishing process and to collect buffing dust.  The complete
chrome tannery typically.has a water-wash system to remove
particulates from the finishing spray booth exhausts.  The
particulates removed are currently a relatively minor source
of solid waste.  It is anticipated that gradual installation
of water-wash collection systems in the few tanneries which
do not currently (1974) utilize them, and retrofit installation
of the more efficient collection systems which will be required
by air pollution regulations in some areas, will not result
in an increase in finishing residues by 1977, but will produce
an estimated 5 percent increase by 1983.^3
     Buffing dust is currently being effectively collected at a
majority of complete chrome tanneries.  Wet scrubbers, cyclones,
and bag houses are all utilized in tanneries, but  wet scrubbers
are relatively uncommon.  Installation of adequate and/or
more effective collection devices at tanneries  not currently
utilizing effective collection systems will not result in a


                              63

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significant increase in the quantity of buffing dust destined
for land disposal by 1977, but will produce an estimated
10 percent increase by 1983.23

     Water Pollution Control.  Treatment of process
wastewater generates a substantial quantity of solid waste.
Most tanneries (88) in this category currently provide
rudimentary screens and sewer sumps for the removal of
wastewater solids, and 19 tanneries provide a significantly
increased degree of solids removal through the use of
screening, primary clarifiers and/or secondary treatment.
When 1977 and 1983 effluent limitations are implemented,
it is estimated that 25 percent and 45 percent, respectively,
of the complete chrome tanneries will provide primary and/or
secondary treatment of their wastewater.  This yields an
approximate 81 percent increase in sludge by 1983, most of
which will be due to primary treatment.

     Industry Trends.  It is estimated that production of
leather by complete chrome tanneries will increase 6.2
percent by 1977 and 17 percent by 1983 relative to 1974 /
This estimate takes into account population growth, growth
trends for related consumer industries, projected changes
in imports and exports, and the availability of the necessary
raw material.  It does not take into account any changes in
U.S. trade policy.

     3.3.5  Typical Plant Summary.  The current  (1974) and
projected  (1977 and 1983) waste generation factors of process
solid waste and the various types and quantities of potentially
hazardous solid waste generated by a typical complete chrome
tannery are summarized in Table 17.   As indicated in the
table, the generation factors for 1974 and 1977 are identical.
Finishing residues and buffing dust are the only wastestreams
expected to have a higher generation rate in 1983.

     3.3.6  EPA Region and National Waste Summary.  Table 18
presents the total quantity of process solid waste and the
types and quantities of potentially hazardous waste, including
their respective hazardous constituents (on a dry weight basis
only), currently  (1974) produced by complete chrome tanneries.
Quantities projected for 1977 and 1983 are presented in Tables
19 and 20, respectively.    The methodology used to develop
these and similar tables is discussed in Appendix D.  As the
tables indicate, more than one-half of the potentially
hazardous solid waste generated by complete chrome tanneries
are produced in Regions I and V.  It is also noteworthy
that the total quantity of potentially hazardous waste is
expected to increase 17 percent by 1977 and 53 percent by
1983 when compared to 1974.  Most of these increases will be

                             69

-------
                        TABLE  17


 WASTE  GENERATION FACTORS FOR A COMPLETE CHROME TANNERY
       (All units are kg pier 1000 equivalent hides)
1974 C 1977*
Waste Type

Total Process Solid Waste
Total Potentially Hazardous
Solid Waste
Trinmings ft Shavings
Unfinished Leather
Trim
Buffing Dust
Finished Leather
Trim
Finishing Residues
Wastewater
Screenings
Wastewater Sludge
(from sewer sump)
Source: SCS Engineers
* No nrnr!f>fiaina i
Total
Cr
Total
Cr
Pb
Total
Cr
Pb
Total
Cr
Pb
Total
Cr
Pb
Zn
Total
Cr
Pb
Total
Cr
Pb
Cu

"hanaAa
Wet
5,410
4,860
1,260
114
27
220
150
390
2,700

APA Awn
Dry
1,750
1,300
540
12.1
100
1.71
0.31
25
0.54
0.0018
200
4.2
0.055
45
0.079
0.165
0.016
90
0.38
0.016 .
300
7.4
0.07
0.51

*>(•«• A<4 ho(
1983
Wet
5,420
4,870
1,260
114
30
220
158
390
2,700

t-WAAri 1 «7
Dry
1,760
1,310
540
12.1
100
1.71
0.13.
28
0.59
0.002
200
4.2
0.055
47
0.083
0.17
0.017
90
0.38
0.016
300
7.4
0.07
0.51

A
and 1977 that would change the  generation factors.   Thus
they are identical.
                             70

-------
              TABLE 18


TOTAL PROCESS MR) POTENTIALLY BAIAKDOOS WASTE
GENERATED IN 1974 BY COMPLETE CHROME TANNERIES
   (metric ton* per year, wet and dry Basis)
EPA
Reaion(8)
I
II
XXX
XV i VI
V
vxx «
vxxz
XX
X
TOTAL
State (•)
ME.VT
HA
MM
MY
KJ
?A,VA,DB
TM,FL,LA
OH, MM
MI
HI
XL
HE,MO,UT
CA
AK.MA

TQtal
Process
Solid
Waste
Wet
11100
13400
8870
12900
2030
6)70
S040
5500
7880
21200
7110
1420
9820
192
11)000
Dry.
3490
4220
2800
4070
640
2010
1600
1740
2490
6680
2250
447
1100
60.8
35600
Total
Potentially
Hazardous
Wastes
Wet
10200
12300
8160
11900
1860
5860
4640
5060
7250
19500
6540
1300
9040
177
104000
Dry.
2770
3350
2220
3230
507
1590
1260
1380
1970
5300
1780
354
2460
48.2
28200
Trim and shavings
Total
Potentially
Hazardous Constituent
wet
2030
2450
16)0
2370
372
1170
925
1010
14 SO
3880
1300
260
1800
3S.3
19SOO
pry.
870
1050
697
1010
159
501 •
396
432
619
1660
559
111
772
15.1
8850
Chtomiun
19.5
23.6
15.6
22.7
3.57
11.2
8.88
9.68
13.9
37.3
12.5
2.49
17.)
0.34
199
Unfinished leather trimmings
Total
Potentially
Hazardous Constituents
tfet
183
222
147
214
33.6
106
83.7
91.2
131
351
118
23.5
16)
).19
1900
Dry.
161
195
129
188
29.5
92.7
73.4
80.0
115
308
104
20.6
143
2.80
1650
ChroniuEi
2. 75
3.33
2.21
3.21
0.50
1.59
1.26
1.37
1.96
5.27
1.77
0.35
2.45
0.048
28.0
Lead
0.20
0.24
0.16
0.24
0.037
0.12
0.092
0.10
0.14
0.39
0.13
0.026
0.18
0.0035
2.06

-------
                                           TABLE 18
                                          (Continued)
SPA
Reg ion (s)
I
II
III
IV « VI
V
VII t
VIII
IX
X
TOTAL
State (s)
NE.VT
MA
NH
NY
NJ
PA.VA.DE
TN.FL.LA
OH.MN
HI
HI
IL
NE.MO.UT
CA
AK.HA

Buffing dust
Total
Potentially
Hazardous Constituents
wet
43.4
52.6
34.9
50.7
7.97
2S.O
19.8
21.6
31.0
83.1
27.9
S.S6
38.6
0.76
443
Dry
40.2
48.7
32.3
46.9
7.38
23-2
18.4
20.0
28.7
77.0
23. 9
5.15
35.8
0.7
400
Chromium
0.87
1.05
0.70
1.01
0.16
0.50
0.40
0.43
0.62
1.66
0.56
0.11
0.77
0.015
8.8S
Lead
0.0029
0.0035
0.0023
0.0033
0.00053
0.0017
0.0013
oiOD14
0.0020
0.0055
0.0018
0.00037
0.0026
0.000050
0.029
Finished leather trim
Total
Potentially
Hazardous Const:
Net
354
428
284
413
64.9
204
161
176
252
677
228
45.3
315
6.16
3610
SSI
322
389
258
375
59
185
147
160
229
616
207
41.2
286
5.6
3280
•
Chromium
6.76
8.18
5.42
7.88
1.24
3.89
3.08
3.36
4.82
12.9
4.35
0.87 '
6.01
0.12
68.9
tuents
Lead
0.088
0.11
0.071
0.10
0.016
0.051
0.040
0.044
0.063
0.17
0.057
0.011
0.079
0.0015
0.90
Finishing residues
Tota
Pote
Haia
Net
241
292
194
282
44.3
139
110
120
172
462
155
30.9
215
4.2
2460
1
ntially
rdous
Dry
72.4
87.6
58.1
84.5
13.3
41.7
33.0
36.0
51.3
139
46.6
9.27
64.4
1.26
738
Const
Chromium
0.13
0.15
0.10
0.15
0.023
0.073
0.058
0.063
0.090
0.24
0.082
0.016
0.11
0.0022
1.30
ituents
Lead
0.27
0.32
0.21
0.31
0.049
0.15
0.12
0.13
0.19
0.51
0.17
0.034
0.24
0.0046
2.71

line
0.725
o.c:
O.Ci
O.C4
0.004
0.015
o.o::
o.c::
0.013
0.04$
o.o:?
0.0033
0.5i€
0.00044
0.26
to

-------
                                  TABLE  IB
                                 (Continued)
EPA
RcgioMs)
I
II
ZIZ
IV t VI
V
VII t
VIII
IX
X
TOTAL
Stated)
•MP,VT
MA
MH
NY
HJ
PA.VA.DE
TR.FL, LA
OH, MM
HI
MI
II
HE,MO,UT
CA
ajc.wa

ttastewater screenings
Total
Potentially
Hazardous Constituents
wet
628
759
503
732
115
362
286
312
447
1200
404
80.3
558
10. 9
(400
Or*
145
175
116
169
26.6
83.4
66.1
72
103
277
93.2
18. S
129
2.52
1480
Chromium
0.61
0.73
0.49
0.71
0.11
0.35
0.28
0.30
0.43
1.16
0.39
0.078
0.54
0.011
6.17
Lead
0.025
0.030
0.020
0.029
0.0046
0.015
0.012
0.013
0.018
0.048
0.016
0.0032
0.022
0.00044
0.25
Wastewater sludge
Total
Potentially
Hazardous Constituents
Wet
6690
8100
5370
7810
1230
3860
3050
3330.
4770
12800
4310
857
5950
116
68100
DTi
1160
1402
930
1350
212
667
528
576
826
2200
745
148
1030
20.2
11800
Chromium
24.8
30.0
19.9
28.9
4.54
14.3
11.3
12.3
17.7
47.4
15.9
3f17
22.0
0.43
252
Lead
0.22
0.27
0.18
0.26
0.040
0.13
0.10
0.11
0.16
0.42
0.14
0.028
0.20
0.0038
a. as
Copper
1.58
1.91
1.27
1.84
0.29
0.91
0.72
0.79
1.13
3.02
1.02
0.20
1.40
0.028
16.1
Source*  BCB Inginears

-------
                 TABLE 19
TOTAL moss MID PonvrxALLY BASA«DOOS WASTE* AHTXCIPATED TO BE
        GEHBftATBD » 1*77 BY COMPLETE CHMMT TANKERIES
           '(netric tens per year, wet and dry basis)


EPA
Region (s)

I



iz

III
XV t VI
V



VZI t
vzxx
IX
•I
TOTAL


State (a)

ME.VT
HA
NH

mr'
NJ
PA,VA,DB
TH.FL.LA
OH, MS
NX
MX
XL
RE«MO»UT

CA
AR.vV

Total
. Process
Solid
waste
wet
12300
14900
9890

14400
2260
7100
5(20
613
8790
23600
7930
1580

11000
214
130000
DT£
•3880
!4690
13110
1
4520
711
'• 2230
1770
1930
2760
7420
2490
496

3450
67.5
39600
Total
Potentially
Hasardous
Waste.
Wet
12700
15300
10200

14800
2320
7300
5780
6300
9040
24300
. 8160
1620
,
11300
221
121000
Or*
3110
3760
249C

3620
569
1790
1420
154*0
2210
5940
2000
398

2760
- 54.0
31700
Trim and shavings
Total
Potentially
Ratardous Constituent
wet
2160
2610
1730

2520
. 39S
1240
984*
1070
1540
4130
1390
276

1920
37.5
22000
Dry,
920
1110
736

1070
168
.528
418
456'
654
1760
590
117

815
16.0
9450
Chromium
70.8
25.1
IS. 7

24.2
3.81
12.0
9.47
10.3
14.8
99.7
13.4
2.66

18.5
0.36
211
Unfinished leather trismings
Total
Potentially
Hasardous Constituents
Wet
195
236
156

227
35.7
112
88.6
'96.8
139
373
125
24.9

173
3.39
1990
Dry
171
206
137

199
31.3
98.3
77. -8
84.8
122
326
110
21.8

152
2.97
1740
Chroaiun
2.93
3.54
2.35

3.42
0.54
1.69
• 1.34
1.46
2.09
S.60
1.88
0.38

2.60
0.051
29.9
Lead
0.214
0.26
0.17

0.25
0.019
0.12
0.098
0.11
0.15
0.41
d.14
0.027

0.19
(.0037
2.18

-------
                                         TABLE 19
                                        (Continued)
"A
S=5ion<»)
I
II
:u
IV « VI
V
VII I
VIII
IX
X
TOTAL
State (s)
MS.VT
MA
NH
NIT
HJ
PA,VA,DG
TM,Ft,IA
OH,MN
HI
HI
II,
SE,«0,UT
CA
A*,t»

flufflne dust
Total
• Potentially
Hazardous Constituents
tfet
4.7
56-. S
37.4
54.4
8.56
26.9
21.3
33.2
33. i
89. J
10.0
5.97
41. S
1.11
47«
23C
43
52. 6
34.9
50.7
7.97
'25.0
19.8
21.6
31.0
B3.1
27.9
5. So
38.6
O.W
443
Chr enter.
0.92
1.11
0.74
1.07
0.17
O.S3
0.42
0.46
0.65
1.76
0.59
0.12
0.12
e.oi6
8.3«
bead
0.009
0.0037
0.0024
0.0036
1.00056
0.0018
0.0014
0.0015
O.G022
0.0058
0.0020
1.00039
0.0027
.000052
0.031
Finished leather trial
Total
Potentially
Hazardous Constltuenta
Wet
377
456
302
43»
69.0
217
172
187
2«B
720
242
48.2
395
6.55
3840
SSI
341
413
274
398
62.5
191
156
170
243
653 .
219
43.7
303
5.94
3480
Chromium
7.24
8.76
5.81
8.45
1.33
4.17
3.30
J.*0
5.16
13.9
4.66
0.93 •
6.44
0.13
73.9
Lead
0.093
0.11
0.075
0.11
0.017
0.054
0.043
0.046
0.067
0.18
0.060
0.012
0.083
1.0016
0.95
Finishing residues
Total
Potentially
B«e.*lo\:s
Wet
257
312
207
300
47.2
148
117
128
184
493
16«
33.0
229
4.48l
2630
D££
77.2
93.5
62.0
90.1
14.2
44.5
35.2
38.4
54.7
148
49.7
9.89
68.6
1.34
787
•• Constituents
Cranium
.0.13
0.16
0.11
0.16
0.025
0.078
0.061
0.067
0.096
0.26
0.087
0.017
0.12
0.0023
1.37
X.3Cd
0.28
0.34
0.23
0.33
0.052
0.16
0.13
0.14
0.20
0.54
0.18
0.036
0.25
0.0049
2.87
Zirc
0.021
0.033
0.022
0.031
0.0050
0.016
0.012
0.013
0.019
0.052
0.017
0.0035
0.024
1.00047
0.27
-4
Ui

-------
 TABLE. 19
(Continued)
BPA
Rcoion(s)

z
11
zzz
IV t VI
V
VII t
VIII '
II
X
TOTAI
State (•)

KE,VT
HA
KH
HY
HJ
PA.VA.0B
m.ri.LA
GB.NH
MI
HI
IL
tlE.KO.UT
CA
AH .HA
.
Wastemter «er*enlnw
TOtel
Potentially
Rasardoue Constituents
*et
•66
806
534
777
122
384
304
331
47.1
197*
428
65.3
S«2
11.4
:«T»O
SSL
154
187
124
180
28.3
89.0
70.3
7C.8
118
2»C
•9.4 -.
1».8
137
t.89
1MO
Chrcaium
0.64
0.78
O.S2
0.7S
8.12
0.37
8.29
0.32
0.4«
1.23
0.41
0.082
O.S7
0.011
i.S7
£«£
0.017
0.012
0.021
0.031
0.9049
0.01S
0.012
0.013
0<019
0.051
8.011
0.0034
0.024
0.00047
0.29
MMtemtM ilu&a*
ifotal
Potentially
Raxardoaa * conn
Net
7710
*330
«1BO
8990
1410
4440
3S20
3830
5490
14700
49400
987
(890
134'
B3008
££
1348
1620
1070
15CO
245
769
«09
•64
9S2
2S60
8S9
171
1190-
23.2
13680
Chrcnium
28.5
34. >
22.9
33.2
S.32
16.4
13.0
14^2
20.3
54.8
18.3
3.65
25.3
0.90
290
ituente
L«ed
0.21
0.31
0.20 .
0.30
0.047
0.15
0.12
0.13
0.10
0.49
O.U
,0.033
0.23
0.0044
2.59
Copper
1.62
2.20
1.46
2.12
0.33
1.05
0.63
0.91
1.30
3.40
1.17
0.23
1.62
0.032
16 ;6

-------
                   TABLE 20


Tona PROCESS ABD POTERTIAU.Y HAZARDOUS HASTE  ANTICIPATED TO
         GENBMTBD ZH 1983  BY COMPUVR CRKMB TANNERIES
            (••trie tana per year, wwt and dry basis)


EPA
Reoion»

X

,
II


zzt
IV ( VI
V



Vtl •
VtZI
IX
X
TOTAt

1
Stated!

ME,VT
MA
HH
HY
NJ

PA,VA,DB
TO, PL. LA
OH.KN
HZ
NZ
IL
«B,NO,m

CA
AX .Ml

, Total
Process
, Solid
• Haste
! Sgt
1SSOO
19940
11200
19200
3020

9490
7520
•190
11100
31500
10COO
2110

14600
287
16TOOO
pry.
Isiio
[6180
.4100
3960
. 936

'2940
!2330
2S40
3640
9770
3190
«S4

4540
88.9
snoo
! Total
j Potentially
; Hax*
Hast
Wet
' 15400
1 18700
; 12400
1 18000
i 2830
1
8900
7040
7680
11000
29500
9930
1980

13700
269
158000
rdous
e=
Dry.
4260
5150
3420
4970
781

2450
1940
2120*
3040
8150
2740
545

3790
74.1
43400
Trin and shavings
Total
Potentially
Hazardous
Wet
2370
2870
1900
2770
435

1370
1080
1180
1690
4540
1530
304

2110
41.3
24200
Dry.
1020
1230
816
1190
186

586
464
506
725
1950
654
130

904
17.7
10300

Chromium
22.8
27.6
18.3
2C.7
4.19

13.2
10.4
11.4
16.3
43.7
14.7
2.93

20.3
0.40
233
Unfinished leather triiminos
Total
Potentially .
. Met
; 214
259
' 172
250
39.2

' 123
97.6
' 106
153
410
138
27.4

190
3.72
2180
Dry.
188
228
151
220
34.5

108
85.9
93.6
134
360
121
24.1

167
3.28
1920
Chror.iun
.22
.89
.58.
.75
.59

1.85
1.47
1.6
2.29
6.16
2.07
0.41

2.86
0.056
32.8
Lead
0.23
0.28
0.19
0.27
0.043

0.14
0.11
0.12
0.17
0.45
0.15
0.030

0.21
0.0040
2.40

-------
 TABLE 20
(Continued)
SPA
Region (8}
t
XX
XXX
XV • VI
V
VXX-a .
VIII
n
.. X
tana
Stated).
NE.VT
HA
NH
MT
. tu
M.VA.OI
18.rL,IA
ORfHN
MI
WI
XL
ra*M(OT
c*
M.MA.
!
Buff ino dust
Potentially
Hazardous
Wet
54.7
66.2
43.9
63.8
10.0
31.5
25.0
27.2
3f.O
105
35.2
7.00.
,40. •
o.9s
SSI
DTJt
51.5
62.3
41.3
60.1
9.44.
30.0
23. S
2S.6
36.7
98.5
33.1
6.59
«M
o.to
S2S
Constituents .
ChrOBittlQ
1.1
1.34
0.89
1.30
0.20
0.64
O.S1
o.ss
0.79
2.11
0..7?
0.14
0.99
0.01*
11. S
Lead
0.0036
0.0044
0.0029
0.0042
0.00067
0.0021
0.0017
' 4.0018
0.0026
0.0070
0.0029
0.00047
, 0.0032
0.000063
0.037
Finished leather trio
Total ,
Potentially |
Raiardous . ; Consti
wet
414
500
332
402
7S.O
230
109
206
29S
791
266
52.9
360
7.20
4220
2St
1 377
456
302
439
69.0
217
172
: 107
;s
- 242
40.2
33S
6.55
3040
' Chrorciun
7.88
9.54
6.33
9.20
1.45
4.54
3.60.
3.92
5.62
15.1
S.I.
1.01
7.01
0.14
00.3
tuents
Lead
0.10
0.13
0.083
0.12
0.019
0.059
0.047
0.051
0.073
0.20
0.066
0.013
0.092
0.0010
1.05
riniehir.9 residues
1 TOt)
• ?0t(
Has
Wet
294'
356
236.
343
34.0
170
•134
146
110
S63
»M
37.7
262
S.1X
3000
11 i
antially
irdeus " • Car.st
Drjr
. 88
107
71.0
103
16.2
51.0
40.4
44
63.1
169.
56 .'9
11.3
76.7
.1.54
903
Chrosi-jr.
' 0.15
0.19
0.12
«.10
0.020
0.009
0.071
0.077
0.11
0.23
0.099
0.020
0.14
0.0027 ,
LSI
Itucr.ts
-aid
0.32
' 0.39
0.26
0.38
0.059
0.19
0.15
0.16
0.33
0.62
0.21
0.041
0.29
0.0056
3.21
Zinc
0.031
0.037
0.025
0.034
O.OOS6
0.018
0.014
0.015
0.022
0.059'
0.020
0.0039
0.027
0.00053
O.il

-------
                               TABLE  20
                              (Continued)
SPA
Region (•)
I
11
III
IV C VI
V
VII t
VZIt
«
X
TOTAL
Stated)
ME,VT
MA
tra
NY
NJ
PA.VA.DB
TN.FL.IA
OH,HN
MI
MI
IL
NE,MO,UT
CA
AR.NK

Wastevater screenings
Total
Potentially
Hazardous Constituents
Wet
715
890
590
858
135
424
335
366
524
1410
473
94.1
654
It.t
7500
Dry,
169
204
136
197
31.0
97.3
77.1
84
120
323
109
21.6
150
2.94
1720
Chromium
0.71
0.86
0.57
0.83
0.13
0.41
0.32
0.35*
0.51
1.35
0.46
0.091
0.63
0.012
7.22
Lead
0.029
0.036
0.024
0.034
0.0054
0.017
0.013
0.015
0.021
0.056
0.019
0.0038
0.026
0.00051
0.30
Wastewater sludge
Total ,
Potentially
Hazardous Constituents
Met
11400
13800
9130
13300
2090
6560
S190
5660
«110
21800
7320
1460
10100
198
116000
Dry.
1970
2380
1580
2300
361
1130
898
979
1400
3770
1270
252
1750
34.3
20100
Chromium
42.2
51.0
33.8
49.2
7.73
24.3
19.2
21.0
30.1
80.7
27.1
5.40
37.5
0.734
429
Lead
0.37
a. 4$
0.30
0.44
0.069
0.22
0.17
0.19
0.27
0.72
0.24
0.048
0.33
0.0065
3.»2
Copper
2.69
3.25
2.16
3.13
0.49
1.55
1.23
1.34
1.92
5.14
1.73
0.34
2.39
0.047
27.4
SOUR* i  80S Engineers

-------
due to wider use of primary and secondary wastewater treatment
with attendant increased sludge generation as noted in
Sections 3.3.2 and 3.3.4.

                   3.4  Vegetable Tannery

     3.4.1  Plant Operations.  This portion of the industry
includes those plants which convert cattlehides to leather
using the vegetable tanning process.
     Brine cured, prefieshed  cattlehides are first soaked
after receipt at the tannery to return moisture tb the
hides. The hides are then treated with lime and Na2S, NaHS,
and soda ash to chemically destroy the hair folicles.  The
hair is then removed mechanically from the hides, aster
which the flesh is! removed from the inner side of; the hide.
Following the fleshing operation, the hides are bftted  (treated
with an enzyme);, pickled (treated with acid) , and then tanned.
The tanning process involves soaking the hides in.a slurry
of vegetable extracts for approximately two weeks^ i
     The hides are then bleached in. order to lighten the
surface colors, Subsequently treated with fat^liqubrs (animal
and vegetable oils)" in. order to return some of. the natural
flexibility to the hide fibers, and then; dried.  The resulting
leather is mechanically split to obtain a uniform thickness
and physically {conditioned to achieve the desired degree of
flexibility.  The^ leather may then be buffed,to remove
unsightly imperfections and, trimmed to remove ragged edges
in final preparation for sale.  A typical vegetable tannery
processed 151,000 equivalent hides in 1974.*
     Figure 6  is. a process, flow diagram for a typical
vegetable tannery indicating the types and quantities of
raw materials and products involved, the basic production
operations performed, and the types and quantities of waste
resulting from the production process.

     3.4.2  Process. Solid Waste.
     Fleshings.* An average of approximately 70 percent of
the cattlehides received are prefieshed at the slaughterhouse.
Any one plant,may use prefleshed hides and hides which have
not been fleshed, or only one type.  As a result, the quantity
of fleshings generated by plants vary widely.  However, virtually
all vegetable-tanners -find it necessary tb fleSh hides which
they have received; thus, some fleshings are generated by
virtually all vegetable tanneries.  A typical Vegetable
tannery generates fleshings at a rate of 3,000 (wet)/700 (dry)
kg per 1000 equivalent hides processed.  Annually 9,500 (wet)/
2,200 (dry) metric tons of fleshings are produced.  Analysis
of one sample collected from the pits below the fleshing
indicated that this wastestream is not potentially hazardous.

                             80

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                    FIGURE 6

                  PROCESS PLOW DIAGRAM
               TYPICAL VEGETABLE TANNERY
(All units are kg/1000 equivalent hides on a dry weight basis
  except solid wastes which  are given on a wet/dry basis)

            CURED CATTLE HIDES
                 (13.100)
MATERIALS AODED 1
•X *
LIME (1800) 1 LIME
SODA ASH ( 20) I FLESH
1 u
(NH4)_S04 . (500 A BATE
NACL (aoo) .PICKLE
ACIDS . (3OO) jS^ TAN
HEXAMETAPHOSPHATE (30O> ^T \
TANNING AGENTS (loon) ^ 4
SYNTANS (400) 9LEACH
FILLERS (1700) _ OIL
NAHC03 ( 50) ^* \
MISC. •aso^-X^ ^
N ^-^^*"**"^ DRV
OILS OOOjV,,**'11^*^ SPLIT
MISC. HOOtJ CONDITION
BUFF
TRIM
I 1
' HIDE TRIM (ISO) J
>Jk MAIR ( 7OO1 li
*t\ FLESH INir.S 9
H (3000/700)
1
FICKLED BP' ' tps a)
(1200)
I
1
_ 1
WASTE SPLITS & TRIM 1
I
1
«| fc
MISC.
PROCESS
SOLID WASTE
(390/300)
AOOX12AOI J
BUFFING DUST (!OO/9OfcJt I?
GOOD SPLITS («SO) ^^

1 PFPAL SALES
V WASTEWATER
LEATHER ' 	 T 	
(10,500) s

S
T

1
ECONDARY
(700/1*0) _.
)0/1S»L J
                            T
                           DIRECT
                         DISCHARGE
                                           PROCESS SOLID WASTE TO
                                           SANITARY LANDFILL  OR
                                               OPEN DUMP
                                              (12.200/2700)
                          81

-------
     Haste Splits and Trimmings.  Waste splits and trimmings
are composed of  leather which is removed from the tanned
hide in order to obtain a uniform thickness and satisfy
purchaser's cutting requirements.  A typical vegetable
tannery generated 1,400  (wet)/I,200  (dry) kg per 1000
equivalent hides processed which amounts to 4,400  (wet)/
3,800  (dry) metric tons per year nationwide.  This waste
material  is primarily animal protein which has been
cross-linked by  vegetable tanning agents in order to eliminate
its susceptibility to bacteriological decomposition.  Analysis
of three  samples collected from below the splitting machines
and from  fiber barrels in the trimming department indicated
that this wastestream is not potentially hazardous.

     Buffing Dust.  A typical vegetable tannery generates
100 (wet)/90 (dry) kg per 1000 equivalent hides processed
which amounts to 320 (wet)/290 (dry) metric tons annually
nationwide.  Buffing dust is generated in sanding operations
performed to remove certain imperfections fromthe surface
of the leather.  Analysis of three samples taken from the
buffing dust collection equipment indicated that this
wastestream is not potentially hazardous.

     Wastewater  Screenings.  Virtually all vegetable
tanneries perform some kind of screening of their Wastewater.
prior to  discharge or further treatment.  A representative
vegetable tannery generates 2,800 (wet)/140 (dry) kg of
screenings per 1000 equivalent hides processed.  Samples of
screenings, which were composed mostly of hair and flesh,
were collected from the wastewater screens at two tanneries.
Analysis  of the  two screening samples collected indicated
that this wastestream is not potentially hazardous.

     Wastewater  Treatment Sludges.  A representative tannery
produces  7,000 (wet)/350 (dry) kg of sludge per 1000
equivalent hides processed which amounts to 22,100 (wet)/
1,100 (dry) metric tons annually nationwide.  Sludge samples
were collected from lagoons at three vegetable tanneries.
Analysis  of these samples indicated that this wastestream
is not potentially hazardous.

     Miscellaneous Process Solid Waste.  Miscellaneous
process solid waste is generated at a rate of 350 (wet)/
300 (dry)  kg per 1000 equivalent hides processed, which oh
a national basis amounts to 1,100 (wet)/950 (dry) metric
tons per year.    This waste is composed of fiber drums, paper
bags,  wooden barrels in which the pickled skins are received,
and general plant floor sweepings, and they do not contain
constituents at  potentially hazardous concentrations.
                             32

-------
      3.4.3  Factors Affecting Future Solid Waste Generation.

      Air Pollution Control.  Most vegetable tanneries utilize
moderately effective equipment to collect the  leather dust
which is produced by buffing, and this situation is not
expected to change by 1977.  However, it is anticipated
that  by 1983, retrofit installation of more effective buffing
dust  collection devices at vegetable tanneries will result
in an increase of 15 percent in the quantity of buffing
dust  destined for land disposal.23

      Water Pollution Control.  Screenings and wastewater
treatment sludges destined for land disposal are currently
generated as a result of wastewater treatment  systems at
an average vegetable tannery.  Since Federal effluent
limitation guidelines are currently under litigation, it
is anticipated that the type and extent of wastewater
treatment at vegetable tanneries will not change significantly
by 1977.  However, it is anticipated that the  improved
quality of wastewater discharged from vegetable tanneries
as the result of future Federal and State water pollution
control regulations will result in a 15 percent increase
in the quantity of vegetable tannery wastewater sludges
destined for land disposal by 1983.
      On the other hand, it is anticipated that efforts will
be made to reduce chemical usage in vegetable tanneries by
1983.  It is estimated that chemical conservation techniques
will  nullify the increase in the quantity of sludge to be
generated by 1983 as a result of water pollution control
regulations.

      Industry Trends.  Vegetable t.anned leather is utilized
primarily for footwear.  It is assumed that the growth and
consumption of footwear in the United States will be
approximately equal to the growth in population, which is
approximately 1 percent per year.  It is also assumed that
the growth rate of the penetration of imported footwear
will  increase 3 percent per year through 1983.2   Therefore,
the production of vegetable tanned leather in the United
States is expected to decrease at the rate of  2 percent
annually through 1983.

      3.4.4  Typical Plant Waste Summary.  The current (1974)
and projected (1977 and 1983)generation rates of process
solid waste in kg per 1000 equivalent hides processed by a
typical vegetable tannery, are as follows:

     1974 and 1977                      1983
     Wet       Dry                 Wet        Dry

    12,200     2,700              13,000      2,750

                             83

-------
     As indicated, a typical vegetable tannery generates
more total process solid waste per 1000 equivalent hides
on a wet weight basis than any other type of tannery, although
none of the waste is potentially hazardous.

     3.4.5  EPA Region and National Waste Summary.   Table 21
presents the total quantity of process solid waste currently
(1974) produced, and the quantities projected for 1977 and
1983.  It is noteworthy that vegetable tanneries produce more
process solid waste on a national basis than any other type
of tannery, except complete chrome tanneries.

                   3.5  Sheepskin Tannery

     3.5.1  Plant Operations.  The major raw material of
sheepskin tanneries is imported, pickled sheepskins.  However,
some sheepskin tanneries which utilize fresh or cured
sheepskins as their raw material have beamhouses where
the hides are soaked, fleshed, and unhaired in preparation
for tanning.
     Pickled sheepskins are normally received by the tannery
in 20 kg wooden barrels.  The pickled skins are removed from
their shipping containers and placed in rotating wooden drums
in which they are degreased, normally with a solvent degreasing
system, and less frequently with water.  In solvent degreasing
systems, the solvent is recovered and sold to be reprocessed.
In water degreasing systems, a detergent solution removes the
grease from the skins.
     The degreased skins are then chrome tanned with a basic
chromic sulfate solution.  In some cases, formaldehyde is
also used in the tanning process, which decreases the amount
of chromium required.  Most of the formaldehyde is incorporated
into the leather with excess discharged as part of the wastewater.
If the skins require fleshing, they are removed from the
tanning drums and mechanically fleshed.  Following fleshing,
or without being removed from the tanning drums if fleshing
is not required, the skins are retanned with vegetable
or synthetic tanning agents, colored with dyes and pigments,
and fatliquored.  The fatliquoring process involves the
addition of oils to lubricate the fibers of the skins so
that after drying they will be able to slide over one
another.  In addition to regulating the pliability of the
leather, the fatliquor increases its tensil strength.
     Following fatliquoring, the skins are stretched on a
metal frame and then dried in an oven.  The resulting leather
is conditioned mechanically to impart the desired degree of
softness.   The skins are then mechanically sanded (buffed)
to remove imperfections in the grain surface, or to produce
the desired nap if the leather is to be a suede.  Finally,
the leather is trimmed to remove ragged edges and packaged
for shipment to the customer.  A typical sheepskin tannery
processed 200,000 equivalent hides in 1974.

                             3/1

-------
                                            TABLE 21


                          TOTAL PROCESS AND POTENTIALLY HAZARDOUS WASTE
                                  GENERATED BY VEGETABLE TANNERIES
                              (metric tons per year, wet and dry basis)
CO
ui
EPA
Reg ion ( s)

III
V
IV
VI, VIII «
X
TOTAL
State(s)

PA
VA,WV,MD
IN, OH
XY
GA,TN,NC
OR,TX,MO

1974
Total
Process
Solid
Waste
Wet
9890
14200
1180
5480
7740
1230
39700
Dry.
2190
3140
261
1210
1720
272
' 8790
1977
Total
Process
Solid
Waste
Wet
9300
13300
1110
5160
7280
1160
37300
Dry
2060
2950
246
1140
1610
256
8260
1983
Total
Process
Solid
Waste
Wet
8780
12600
1050
4870
6880
1090
35300
Dry
1860
2660
222
1030
1460
230
7460
          Sourcei  SCS Engineer*

-------
     Figure  7, a  process  flow diagram  for  a typical
sheepskin  tannery,  indicates the basic production operations
performed, the types and  quantities of raw materials and
products involved,  and  the  typfs and quantities of waate
products resulting  from proilurr ion pro
      3.5.2   Potentially  Hazardous  Solid Haste.   As indicated
in Figure  7,  several kinds  of  solid waste is generated.
The potentially hazardous wastestreams  are discussed below.

     Fleshings.  Mechanical fleshing of sheepskins  to
remove excess fatty  material from the flesh side  of the
skin is normally performed  immediately  following  chrome
tanning.   The typical sheepskin tannery using pickled
sheepskin  as  the raw material  generates 1,200 (wet)/300  (dry)
kg of fleshings per  1000 equivalent hides processed.  On
a national basis,  sheepskin tanneries produce 2,990 (wet)/
747  (dry)  metric tons of fleshings per  year.
     Chrome fleshing sample's were collected from  below
sheepskin  fleshing machines at three tanneries.   Although
the fleshings consist primarily of animal fat and protein,
analysis indicated that they also contain 4,030  (wet)/i6,300
(dry) mg/kg chromium.

     Buffing  Dust.   Mechanical sanding  (buffing)  of sheepskin
leather produces 100 (wet)/90  (dry) kg  of fine leather dust
per 1000 equivalent  hides processed, which on a national
basis amounts to 140 (wet)/125 (dry) metric tons  per year.
Samples were  taken from the buffing dust collection devices
at three sheepskin tanneries.  Analysis of these  samples
indicated  the presence of hazardous constituents  as followst

                 Avg.  concentration      Concentration range
                        (mg/kg)               (mgAg)
Constituent      Wet	Dry           .Dry

Chromium         17,500     19,000        6,700 -  31,000
Lead                 620        670          340 -     990
Copper               980      1,070          130 -  2,000
Zinc                 280        310       Not de—     620
                                          tected

     Leather  Trim.   Sheepskins are normally trimmed befbre
packaging  to  remove  the ragged edges from the skins.  This
trimming operation produces 170 (wet)/I40  (dry) kg  of leather
trim per 1000  equivalent hides processed at a typical
sheepskin  tannery, which on a national basis amounts  to
424 (wet)/349  (dry)  metric  tons per year.   Samples  were
collected  from the fiber drums in the trimming departments
of two sheepskin tanneries.  An analysis of these samples

                             86

-------
                              FIGURE  7

                          PROCESS PLOT* DIAGRAM
                       TYPICAL SHEEPSKIN TANNERY

        (All  units are kg/1000 equivalent hides on a dry weight basis
          except  solid wastes which are given  on a wet/dry basis)
                          PICKLED SHEEPSKINS
MATERIALS
          ADDED
NACL           (8201
SOLVENT (RECYCLED)
TANNING AGENTS ( 90O 1
MISC.          (200)
ACIDS
DYES
FATLIOUORS
RETAN MATERIALS
MISC.
(140)
(  70)
( 120)
(200)
(2400)
DECREASE -
CR TAN _

1 FLESH |_

RETAN
COLOR
IFATLIOUOR
i
DRY
CONDITION
BUFF
TRIM

1
	 1-
1
1
A
T
i
i
	 i
i
i
-ta
A
I

» GREASE SOLD
(200)

FLESHINGS
( 1200/300)
MISC. PROCESS
SOLID WASTES
(4SO/350)
iUFFING DUST (S6/SO)
TRIM (170/140)




,
"

-•

1
g|


                                LEATHER
                                (1200)
                                            KASTEWATER
                                I
                                           I SCREENING]
                                                r

                                                     H
                                            WASTEVATER
                                             TO SEWER
                                          (SOLIDS-2600)
                                                         PROCESS SOLID WASTE.
                                                      TO SANITARY LANDFILL
                                                         (2110/890)
                                   87

-------
indicated the presence of the following hazardous
constituents:

                 Avg. concentration     Concentration range
                       (rag/kg)              (mg/kg)
Constituent      Wet	      Dry     	Dry	

Chromium         37,000      44,000      12,000 - 76,000
Lead                280         330          94 -    560
Copper              140         170          32 -    300

     Wastewater Screenings.  Essentially all sheepskin
tanneries screen their wastewater prior to discharge or
further treatment.  A typical plant generates 230  (wet)/
50  (dry) kg per 1000 equivalent hides processed, which on
a national basis amounts to 574 (wet)/125 (dry) metric tons
per year.  A sample was taken from the wastewater screens
at one sheepskin tannery.  The screenings are composed
primarily of small pieces of leather which are torn off the
sheepskins at various points in the production process, and
contain the following hazardous constituents:

                                Avg. concentration
                                      (mgAg)
     Constituent                Wet	      Dry

     Chromium                   7;200       33,000
     Copper                        50          220

     3.5.3  Non-Hazardous - Solid Waste.  Miscellaneous process
solid waste is generated at a rate of 390 (wet)/350 (dryj
kg per 1000 equivalent hides processed, which on a national.
basis amounts to 1,130 (wet)/870  (dry) metric tons per year.
This waste is composed of fiber drums, paper bags* wooden
barrels in which the pickled skins are received, and general
plant floor sweepings, and they do not contain constituents
at potentially hazardous concentrations.

     3.5;4  Factors Affecting Future Solid Waste Generation.

     Air Pollution Control.  The only significant source of
air pollution from sheepskin tanneries is leather dust which
is generated by the buffing operation, and this is currently
(1974) being controlled adequately by most tanneries of this
type.  Retrofit installation of more efficient collection
systems which may be required by air pollution control
regulations in certain areas are not expected to significantly
increase the quantity of buffing dust destined for land
disposal by 1977.  However, it is estimated that more
efficient buffing dust collection systems will result in a

                              88

-------
 10 percent increase in buffing dust destined for land
 disposal by 1983."

      Water Pollution Control.   The only solid waste currently
 generated as a result of wastewater treatment at most
 sheepskin tanneries is screenings.  Since Federal effluent
 limitation guidelinesand pretreatment standards for the
 tanning industry  are currently under litigation, it is
 anticipated that  wastewater  treatment at sheepskin tanneries
 in 1977 will be limited to screening.  However, it is
 estimated that by 1983, as surcharges and pretreatment
 guidelines are established,  approximately 10 percent of
 sheepskin tanneries will be using primary pretreatment to remove
 solids  from their wastewaters.   Although this figure may
 seem low,  it should be noted that  the only likely candidates
 for primary pretreatment are the sheepskin tanneries with
 high suspended solids  in their wastewater,  i.e., those few
 operations with beamhouses .  It is estimated that this will
 result  in the generation of  1,500  (wet)/ISO (dry)  kg of sludge
 per 1000 equivalent hides processed,  which on a national
 basis will amount to 236 (wet)/24  (dry)  metric tons per year
 (1983)  from the 10 percent of  sheepskin tanneries with
 primary pretreatment.

      Industry Trends.   It is estimated that the production
 of  sheep leather  will  decrease  at  the rate  of 5 percent per
 year through 1983.2    This decrease in sheepskin leather
 production is expected to result from increased importation
 of  sheepskin leather products.   The supply  of sheepskins
 for tanning is  decreasing as a  result of these raw materials
 being processed in  the countries of origin.

     3.5.5   Typical Plant Waste  Summary.  Table 22  presents
 the current (1974)  and projected(1977  and 1983)  generation
 factors  for process  solid waste  and the  various types of
 potentially hazardous  solid waste  generated by a typical
 sheepskin  tannery.  The  increase in potentially hazardous
 solid waste  per 1000 equivalent  hides  anticipated  for 1983
 is  primarily the result of the  installation of a sewer sump
 by  a typical  sheepskin tannery to  remove wastewater solids
 in  order to  reduce sewer  surcharges.

     3.5.6	EPA" Region and National Waste Summary.   The
 current  (1974) quantity of process  solid waste  and the •
 types and quantities of potentially hazardous waste,  including
 hazardous constituents, generated on an EPA Region and national
 basis are presented in Table 23.   Quantities projected  for
 1977 and 1983 are indicated in Tables 24 and  25 ,  respectively.
 Examination of these tables shows that sheepskin tannery
waste generation is concentrated in Regions  I and  II.  In

                             89

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                       TABLE 22


WASTE GENERATION FACTORS FOR A TYPICAL SHEEPSKIN TANNERY
        (All units are kg per 1000 equivalent hides)
waste Type

Total Process Solid Waste
Total Potentially Haiardous
Solid Waste
Chrome Fleshing
Unfinished Leather
Trim
Buffing -Dust
Wastewater
Screenings
Wastewater Sludge
(from sewer sump)
Source: SCS Engineers
* ' Mo Tn*nr?A«ain« e
Total
Cr
Total
Cr
Cu
Pb
Total
Cr
Pb
Cu
Sn
Total
Cr
Cu
Total
Cr
Cu
Pb

•IkJUUCAB
1974 t
Wet
2,100
1,660
1,200
170
56
230
._

•vtt' AI>»^»«»
1977*
Dry
•90
540
300
4.8
140
0.63
0.048
0.024
50
0.98
0.035
0.055
0.016
50
1.66-
0.012
III

•»A
-------
                                       TABLE  23
                             TOTAL PROCESS AMD POTENTIALLY HAZARDOUS HASTE
                                GENERATED IH 1974 BY SHEEPSKIN TANNERIES
                                (netxlc ton* pec year, net and dry baaia)


EPA
HvjlonUl

I

(I
(II
IV 1 VI
V I VII
TOTAL



StatQtB)

Mb. Ml
MA
•:v,::j
PA
.-L.TX
HI."!-:, i A
.
T'.l.il
Process
Solid
Vasto
Wot
1550
1440
1800
16S
88.6
219
»CO
Dry
603
608
757
69.1
17.4
92. «
2220
Tnt.il
Potentially
Haiardous
Haate>
Kgt
1220
1110
1410
110
69.6
172
4110
Or*
196
169
460
42.1
22.7
56.2
1150
Chrunu Clculiinuti
Total
Potentially
Hazardous Constituent
wet
881
820
1020
94.0
50.4
125
2990
pry.
220
205
255
21.5
12.6
11.2
747
Chromium
1.52
1.28
4.08
0.18
0.20
0.50
12.0
Un 1 1 n i •hjvi ]»%t9«.*F ^pi^*nif«a4
Total
Potentially
Hazardous Cons
Hat
125
116
145
13. 1
7.14
17.7
424
Dry.
101
9S.fi
119
11.0
S.88
14.6
349
Chromium
0.46
0.41
0.54
0.049
0.027
0.066
1.57
itcents
Copper
0.035
O.C11
0.041
0.0017
0.0020
0.035?
. 0.12
Leai
o.o:~
O.Ole
o.orc
0.0019
O.OOl.i
0.00:4
0.059
r.?A
i'eqionU)

I
II
XII
IV t VI
7 t VII
T07AI.
State IB)

MB. Nil
KA
»Y.NJ
PA
PL.TX
Hl.MJi.lA

Buffing duet
Total
Potentially
Hazardous Constituents
Ket
41.1
18.2
47.7
4.18
2.15
5.82
140
Dry.
36.7
J4.2
42.6
3.92
2.10
5.20
125
Chromlua
0.72
0.67
0.83
0.077
0.041
0.10
2.44
Lead
0.026
0.024
0.010
0.0027
0.0015
0.0016
0.087
Copper
0.040
0.019
0.0«7
0.0041
0.002)
0.0057
0.14
line
0.0115
0.011
0.011
o.ooia
0.00066
0.0016
0.039
waetewater acreeninos
total
Potentially
Hatardous Constituents
Wet
169
187
196
18.0
9.66
23.9
574
2DL
16.7
14.2
42.6
1.92
2.1
5.2
125
ChrcMJun
1.2!
1.11
1.41
0.11
0.070
0.17
4.13
Casper
O.OOS4
O.OOT4
0.0008
0.00090
O.OOi^i!
o.ooi:
0.0:9
Sourcei   tCS Engineers

-------
                                                           TABLE  24
                                      TOTAL PROCESS AND POTENTIALLY IIAXAROOUS KASTU ANTICIPATED TO BB
                                                 GENERATED IN 1977 BY SHEEPSKIN TANNERIES
                                                  (ooirlc tons pec year, vet- and dry basis)
a-k
"".iiori (s)

I
II
III
IV t VI
V-t VII
TOTAL
Ctato (s)

XK,NII
KA
:.v,:u
PA
!•:..«
UI.MM.IA

Total
Process
Solid .
Vaste i
HBB
1130
1240
1540
141
76
198
4520
Dry
562
521
651
59.6
12
79.2
1910
Total
Potentially
Hazardous
Waster
tfot
1040
914
1210
111
59.6
147
3540
pry.
J41
us*
393
36.2
19.4
48.1
1160
Chroma fleshings
Total
Potentially
Hazardous Constituent
Wot
757
706
878
80.4
41.2
107
2*70
SEX
189
176
210
20.1
10.8
26.7
•43
Chromium
1.03
2.82
3.51
0.32
0.17
0.43
10.3
Unfinished leather triisainos
Total
Potentially
Hazardous Cons
wot
107
100
124
11.4
6.12
15.1
364
pry.
88.3
82.3
102
9.18
5.04
12.5
300
Chronium
0.40
0.17
0.4C
0.042
0.023
0.056
1.35
.ituents
Copper
0.030
0,028
0.035
0.0032
0.0017
0.0042
0.10

tead
0.015
0.04
0.017
O.OOlf
0.00086
0.0021
0.077
vo
N>
EPA
I
II
in
IV t VI
V t VII
TOTAL
State (3)
NK.KII
MA
NV.IU
PA
FL.TX
NI.MN.IA

Baffin* dust
Total
Potentially.
Hasardous Constitu
35.3
12.9
41.0
3.75
2.02
4.98
120
31.6
36.6
3.35
1.80
4.45
107
Chrmitaa
0.62
O.S8
0.72
0.066
0.015
0.087
2.10
0.022
0.020
0.025
0.0023
0.0012
0.0031
0.074
Hit!
Copper
0.035
0.012
0.040
0.0037
0.0020
0.0049
0.12
0.0099
0.0092
0.012
0.0011
0.00057
0.0014
0.014
Kastemter screeair.es
to«'a
Potei
naso
145
135
168
15.4
8.28
20.5
492
I
itially
fdous Cor.sti
31.6
2*. 4
36.6
3.15
1.8
4.45
107
fluresiws
1.04
0.97
1.21
0.11
0.060
0.15
3.54
ttCIM
0.0073
0.00«*
0.0064
0.00077
0.00041
0.0010
0.025
                Sourcei  SCS Cnqineers

-------
                                                             TABLE  25
                                        TOTAL PROCESS MID POTENTIALLY HMABDOUS HASTE  ANTICIPATED TO
                                                   GENERATED IN 1983 BY SBBBPSKIH TAMMIES
                                                    (metric tens per year, net and dry basis)
10


EVA
PAIKMllK)

I
IZ
III
IV « VI
•V 6 VII
TOTAL
=====


itatcU)

.«E.:III
"A
«V.MJ
PA
fi.rx
fcl.YS. IA
=- - - —
Total
Process
Solid
Waste
Mot
1090
1010
1260
11«
62.1
154
3690
-
Orx
427
J93
495
49.6
24.4
60. 5
14 SO
- .
Total
Potentially
Haiardous
Waste*
Hot
8BO
819
1020
91.9
SO. 4
115
2990
1
Dry
26S
247
107
21.1
IS. 2
37. 5
900
Chroma flashings
TOUl
Potentially
Wet
555
S16
60
S9.2
31.8
70.6
1800
.— —
Drg
139
129
161
14.8
7.94
19.7
471
Chromium
2.22
2.06
2.S7
0.24
0.11
0.11
7. S3
Unfinished leather trianines
Total
Potentially
Net
78. S
73.1
91.1
8.38
4.49
11.1
267
Dry
64.6
60.1
74.9
6.89
1.70
9. IS
219
Chromium
0.29
0.27
0.14
0.011
0.017
0.042
1.00

Coaper
0.022
0.021
0.026
0.0014
0.0011

0.07S
Lead
0.011
0.010
0.012
0.0012
0.0006

0.017
'— - —
EPA
P«>qlon<3

I
11
III
IV • VI
V 4 VI
TOTAL
StatMri}

4R.NH
'.A
r;y.sj
PA
FL.TI
NI.1H.I A

Buffinq dust
T'«ta 1
latent tally
llizjr>un
H>-r.
t'i.1
28.0
14.9
1.21
1.72
4.2C
ioa
Oa
27.2
2S.1
II.?
2.90
l.SS
1.85
92.3
rhrociimn
O.S1
0.49
0.61
0.056
0.010
0.07S
1.79
Constituents
toad
0.019
0.017
0.022
0.0020
0.0011
9.0026
O.M3
Coi*»*r
0.029
0.027
0.014
0.0011
0.0017
0.0042
C.0999
(ine
0.00*4
0.0079
0.0098
>. 04090
1.00048
0.0012
0.0287
Nastewater screenings
Total
Potentially
Hazardous Constituents
Wet
106
99.0
121
11.1
«.09
15.1
Ml
Drg
21. S
21.9
27.2
2. SI
1.14
1.11
79.8
Chromiua
0.76
0.71
0.89
0.081
0.044
0.11
2.6
Cooper
O.OOS1
0.0049
0.0061
(.09056
». 00010
O.OOOS
0.018
Mastovater sludac
Total
Potentially
Hatardoaa Constituent*
Net
110
102
128
11.7
«.l
IS. 6
174
OTJL
11.0
10.2
12. •
1.17
0.61
1.S6
17.4
Chromiup
0.10
0.28
0.1S
0.032
0.017
0.042
1.01
Coppor
0.0:i
O.OCO
0.025
0.00:i
o.ooi:
0.0:30
0.072
Lead
0.0012
O.OOiO
0.0037
0.0003S
0.00019
0.00046
0.011
          Sourcei   SCS bi7iae*rs

-------
addition, the tables  indicate that the total quantity of
potentially hazardous solid waste is anticipated to decrease
by  14 percent by  1977, and 30 percent by 1983, primarily
as  a result of decreasing production.

                      3.6  Split Tannery

     3.6.1  Plant Operations.  Split tanneries purchase
splits or blue drops  from complete chrome tanneries and
further process them  into suede leather.
     The production process of a typical split tannery is
summarized in Figure  8 and described below.  Blue drops
are received at the split tannery wrapped in plastic to
insure that they  do not dry out.  The splits are trimmed to
remove portions which are too thin to process and then
sorted by thickness.   The splits are then re-split to
obtain a uniform  thickness, and subsequently shaved to obtain
the exact thickness desired.  The -splits are then retanned,
colored, and fatliquored in a manner similar to that used
to  produce chrome tanned grain leather.  Following fatliquoring,
the splits are pasted on- large, plates or stretched on metal
frames and then dried in an oven.  The- resulting suede
leather is buffed to  improve the appearance and obtain a
uniform nap.  After trimming off ragged edges, the splits
are ready for packaging and shipment to the customer.  A
typical split tannery processed 400,000 equivalent hides in
1974.2
     Figure 8 also shows the basic production operations
performed, the types  and quantities of raw materials and
products involved, and the types and quantities of waste
products.

     3.6.2  Potentially Hazardous Solid Haste.  As indicated
£
en
in Figure  8,  several  kinds of solid waste  is generated.
The potentially  hazardous wastestreams are discussed  below.

     Trimmings, 'Splits, and Shavings.  The initial trimming,
resplitting,  and  shaving operations generate a total  of
8,200  (wet)/3,700 (dry) kg of solid waste  per 1000 equivalent
hides processed at a  typical split tannery, which on  a
nationwide basis  amounts to 29,100 (wet)/13,100  (dry) metric
tons per year of  which 14,300 (wet)/6,460  (dry)  is sold as
a by-product.  Samples-were collected from the splitting
machines, shaving machines, and trimming department at six
tanneries.  Analysis  of these samples indicated  an average
chromium concentration of 9,600 (wet)/22,300 (dry) ng/lngt
with a range  of 10,000 to 28,000 mg/kg on-a dry weight basis.
                             94

-------
                             FIGURE 8
                            PROCESS  PLOW  DIAGRAM
                           TYPICAL SPLIT  TANNERY

          (All units  are kg/1000 equivalent hides on a drv weight basis
            except solid wastes which are  given on a wet/dry basis)
MATERIALS APPEO
                       BLUE SPLITS
                         (6000)
DYES       (350)  I
RETAN 6 FATLIOUOR V_—••
 MATERIALS (900)  f
MISC.      (300)J
r-A-,
iTRIMl TR!»
ISDRTl
[SPLIT] SPt,
1 SHAVE SHAV
1
RETAN
COLOR WAS1
FATLIQUOR
f ORY I
IBUFF G
TRIM 1
EOE LEATHER
(2500)
4 g

(8200/3700)
TS ,
t\nqs j Mtsr
PROCESS
(22S/200)
'EMATER JSCREENINC] SCREENINGS
" 	 1 (22/S)
WASTEWATER
TO SEWER
(SOLIDS 1OOO)
UFFING OUST (200/1901
RIM (?30y?0(J

J

1
1
1
1
1
J
1
1
1
1
J
T,
"•1
1
1
1
1
1
                                                       PROCESS SOLID WASTE
                                                      TO SANITARY LANDFILL
                                                          IS.860/4.290)
                                   95

-------
     Unfinished Leather Trim.  Following buffing and before
packaging  for  shipment, suede leather is normally trimmed
to remove  ragged  edges.  A typical split tannery generates
230  (wet)/200  (dry)  kg of leather trim per  1000 equivalent
hides processed,  which on a national basis  amounts to
810  (wet)/715  (dry)  metric tons per year.   Samples were
collected  from fiber drums or self-dumping  hoppers in the
trimming departments of seven tanneries.  Analysis of these
samples indicated the presence of the following hazardous
constituents:

                  Avg. concentration     Concentration range
                        (mgAg)               (mg/kg)
Constituent       Wet	Dry     	Dry	

Chromium          19,000      21,000       7,600 - 45,000
Lead                 250         280         120 -    460

     Buffing Dust.   Mechanical sanding of suede leather to
remove surface imperfections and to produce a uniform nap
generates  fine particles of leather which must be disposed
of as solid waste.   A typical split tannery produces
200  (wet)/ISO  (dry)  kg of buffing dust per  1000 equivalent
hides processed,  which on a national basis  amounts to
715  (wet)/639  (dry)  metric tons per year.   Samples were taken
from the buffing  dust collection devices at seven split
tanneries.  Analysis of these samples indicated the presence
of hazardous constituents as follows:

                  Avg. concentration     Concentration range
                       (mg/kg)              (mg/kg)
Constituent       Wet	Dry     	Dry	

Chromium          20,000      22r000       1,200 - 60,000
Lead                 71          77          44 -    120

     Wastewater Screenings.  Most split tanneries screen
their wastewater  before discharge, and a typical split tannery
generates 22 (wet)/5 (dry) kg of screenings per 1000
equivalent hides  processed, which on a national basis amounts
to 78 (wet)/I8 (dry) metric tons per year.  Samples were
collected from the wastewater screens at seven tanneries.
The screenings primarily consist of relatively small pieces
of leather which  have been torn off'the hides during
processing.  Analysis of these samples indicated the presence
of hazardous constituents as follows:
                             96

-------
                  Avg. concentration     Concentration range
                         (rag/kg)             (ngAg)
 Constituent      Wet	Dry     	Dry	

 Chromium           970         4,200        5 - 14,000
 Lead                40           175      .43 -    190

      3.6.3  Non-Hazardous Solid Waste.  Miscellaneous process
 solid waste is generated at a rate of 225 (wet)/200 (dry)
 kg per 1000 equivalent hides processed, which on a national
 basis amounts to 700 (wet)/650 (dry)  metric tons per year.
 This waste is composed of fiber drums, paper bags, wooden
 pallets on which the splits are received, and general plant
 floor sweepings, and they do not contain constituents at
 potentially hazardous concentrations.

      3.6.4  Factors Affecting Future Solid Waste Generation.

      Air Pollution Control.   Air pollution control devices  are
 utilized to collect the leather dust which is generated by
 buffing.  Buffing dust is currently being effectively
 collected at a majority of split tanneries.   Installation
 of adequate and effective collection devices at tanneries
 not currently utilizing effective collection systems,  and
 retrofit installations of more efficient collection systems
 which may be required by air pollution control regulations
 in certain areas,  will not increase the quantity of buffing
 dust destined for  land disposal  by 1977,  but will result in
 a  10 percent increase by 1983."

      Water Pollution Control.  The vast majority of split
 tanneries discharge their  wastewater  to municipal sewer
 systems  with no treatment  other  than  screening.   Since the
 suspended solids content of  the wastewater from a split
 tannery  is  relatively low, it  is  anticipated that split
 tanneries will  not find  it cost-effective to install
 pretreatment facilities.   As a result,  it is anticipated
 that screening will  continue to be the predominate type
 of wastewater treatment  in 1977 and 1983.

      Industry Trends.  Since the  raw material utilized by the
 split tanning portion of the leather tanning- industry-is
 produced  by  complete chrome tanneries  and retan/finishers,
 it is anticipated that production  from split tanneries will
 follow the growth rate of the sum of the retan/finish  and
complete chrome tannery operations.  Thus, it is assumed
that the growth rate for split tannery production will be
2.6 percent per year through 1983.2
                             97

-------
      3.6.5  Typical Plant Waste Summary.   The current (1974)
 and projected (1977 and 1983)  generation  factors  for process
 solid waste and the various types and  quantities  of potentially
 hazardous solid waste generated by a typical  split  tannery
 are summarized in Table 26.  As the table indicates, the
 generation factors for a typical split tannery are  not expected
 to change appreciably in the future.

      3.6.6  EPA Region and National Waste Summary.   Table
 27  presents the total quantity of process solid waste and
 the types and quantities of hazardous  constituents,  currently
 (1974)  generated by split tanneries.   Quantities  projected
 for 1977  and 1983 are presented in Tables 28  and  29,
 respectively.  As indicated by the tables,  the vast majority
 of total  process and potentially hazardous solid  waste generated
 by split  tanneries is Region I.   This  is  in large part due
 to the  fact that trimmings,  splits, and shavings  comprise
 the vast  majority of both total process and potentially
 hazardous solid waste,  and this type of waste is  currently
 sold as a by-product in Region V;  however,  there  is no
 market  for these wastes in Region I.

                    3.7   Leather Finishers

      3.7.1  Plant Operations.   Tanneries  in this  category
 normally  function on a  contract basis.  Thus,  finishers receive
 unfinished leather from a customer, apply a finish  to it,
 and then  return it to the customer, charging  a fee  for the
 service.   Finishes are  normally applied either by hand or
 in mechanical spray booths and may consist  of either water
 or solvent base preparations.   In addition, the leather
 is sometimes  buffed to  remove  imperfections in the  grain
 surface or improve the  nap of  the flesh side.   A  typical
 leather finisher processed 225,000 equivalent hides  in 1974.
 Figure  9   summarizes the basic production operations performed,
 the types and quantities of  raw materials and products
 involved,  and the types and  quantities  of'waste products.

      3.7.2 Potentially Hazardous Solid Waste.  As  indicated
 in  Figure 9,  three kinds of  solid waste is  generated.   The
 two potentially hazardous wastestreams  are  discussed below.
 The data  presented is based  upon  information  collected during
 visits  to three  contract finishers and  22 complete chrome
 tanneries.  The  information  from  complete chrome  tanneries
 is  included here because  the finishing  operations performed
 in  complete chrome tanneries and  by contract  finishers are
essentially the  same.   However, contractor  finishers do not
 have  screens  or  other treatment works.
                             98

-------
                      TABLE  26


  WASTE GENERATION FACTORS FOR A TYPICAL SPLIT TANNERY
      (All units are kg per 1000 equivalent hides)
1974 I 1977*
Waste Type

Total Process Solid Waste
Total Potentially Hazardous
Solid Waste
Trimmings & Shavings
Unfinished Leather
Trial
Buffing Dust
Wastewater
Screenings
Total
Cr
Total
Cr
Pb
Total
Cr
Pb
Total
Cr
Pb
Wet
8,880
8,650
8,200
230
200
22
Dry
4,290
4,000
3,700
78.7
200
4.37
0.058
180
4.0
0.014
5
0.021
0.009
1983
Wet
8,900
8,670
8,200
230
220
22
Dry
4,310
4,110
3,700
78.7
200
4.37
0.058.
200
4.4
0.015
5
0.021
0.009
Sources  SCS Engineers

     '  80 processing changes  are expected  between 1974
and 1977 that would change  the generation factors.   Thus
they are identical.
                            99

-------
                                                         TABLE  27
                                            TOTAL PMCBSS MB POnRZALU HMMD008 BMW
                                                 GENERATED IN 1974 BY SPLIT TMMSRXBS
                                               (metric tens per year, vet and dry basis}


EPA
Region (s)

I
V t IX
TOTAL


State (s)

MA.MR
MX.IL.CA

Total
Process
Solid
Waste
wet
14500
2200
1C700
Dry
7100
14 SO
0550
Total
Potentially
Hazardous
waste.-
Wet
14100
1900
14000
DW
6700
1200
7900
Trimmings, splits • shavings*
Total
Potentially
Hasardoue Constituent
Wet
13300
1000
14300
pry.
6000
460
64CO
Chromium
130
10
140
Unfinished leather trlrring*

Potentially
Hazardous
Wet
370
440
010
toy.
330
30S
715
Constituents
Chroaius
7.10
0.41
15.51
Lead
0.10
0.11
O.*l
o
o
                        BPA
lion(s)
                           TOTAI,
Statelei
                                                      Bnff ia> duct
                     Potestialiy
                                               330
                     71S
                            290


                           JiS.
                  439
                             e.S

                            -Li.
14.3
          0.03
                                                                         •.OS
                                                Kasteiieter screentncs
                                             Total
                                             Potentially
                                             	 "          ceoetitueate
                                                                                 36


                                                                                JL
                                                       7S
                                  •.030
                                                              •.•71
.0014
                                                                                                           .0031
                                     tae ref leet that, taia
                                      U aa!4 ia

-------
                        TABLE 28
TOtAL PltOCBSS AND POTENTIALLY HAZARDOUS HASTE* ANTICIPATED TO
             GENERATED IB 1977 BY SKIT TANNERIES
            (netrie tens per year, wet and dry basis)
EPA
Reaionfs)
I
V C XX
TOTAL
State lei
MA.NH
HI.XL.CA

Total
Process
Solid;
Haste
Net
19600
2520
uioo
pry.
7610
2470
10100
Total
Potentially
Hazardous
Waste;
S«
1S200
2050
17250
fitt
7270
1300
•570
Trimmings, splits t shavinas*
Total
Potei
Hasai
Met
14400
1110
15500
ttially
Dry.
6500
500
7000
Chromium
138
11
149
Unfinished leather trirwincs
Total
Potentially
Met
400
480
•00
pry.
350
415
7CS
Chroaiua
7.7
9.1
16.8
Leal
0.10
0.12
0.22
EPA
Reaioa(s)
I
v • n
TOTAL
• a
Stated)
NA.HH
VX.tL.CA
B
Buef im doit
Total
Potentially
Batardous Constituents
*££
150
415
7«
u—
S£Z
915
175
690
Quxftipm
7:0
0.1
1S.J
0.025
0.011
0.05C
Nastewater sereeninas
• Total
Potentially •
Batardous Constituents
Vet
39
4«
OS
Or*.
9
10
19
Chroaiun
0.037
0.044
O.OSI
jssai
,0015
0010
.OP33

-------
                                    TABLE  29
            TOTAL PROCESS AND POTENTIALLY HAZARDOUS WASTE  ANTICIPATED TO BE
                          GENERATED  IN  1983 BY SPLIT TANNERIES
                        (metric  tons per year, wet and dry basis)
EPA
Region (a)
I
V i XX
TOTAL
State (s)
MA.NH
WI.IL.CA

Total
Process
solid
Haste
Wet
1B200
- 2950
aiiso*
Dry.
8800
• 2060
10060
Total
Potentially
aasardous
Waste.
Het
17700
2400
20100
Dry.
8400
1580
990Q
Trimmings, splits t shavings*
Total
Potentially
Hasardous Constituent
Hat
16800
1290
18090
pry.-
7S60
S80
8140
Chxo&ium
160
12
1T2
Unfinished leather triceincs
Total
Potentially:1
Hazardous Constituents
Wet
470
560
10JO
pry.
410
480
890
Chresiun
8.94
10.6
19.5
Lead
0.12
1 0.14
: 0.26
 *•*
            •State(s)

            Total
            Potentially
                                                             Wastewatev
                                   Potentially
                                   Basardons
                                                                          Constituents'
   I
   v  *; xx
MA.KH
WX.IL^CA
440
M3
40.
470
 6.0"
10.4
0.011
0.017
41.5
59.0
fitt
9.75
11.5
0.041
0.050
.0010
.0021
    TOTAL
           963
       070
           17'. 2
         0.068
        99. J
                                                                 21.J
                  0.002
                    .0039
Sources  SC8 Engineers
                  reflect that this wast* is sold in

-------
                             FIGURE  9

                              PROCESS FLOW DIAGRAM
                           TYPICAL LEATHER FINISHER

           (All units are kg/1000 equivalent hides on a dry weight basis
             except solid wastes which are given  on a wet/dry  basis)
MATERIALS ADDED
PIGMENTS
WATER BASE  FIN I
SOLVENT  BASE
 FINISH
MISC.
                        CRUST LEATHER
                           (5000)
                     FINISHED LEATHER
                          (5000)
                                          BUFFING OUST  (11/1O1
FINISHING RESIDUE  (150X>
                                          SOLVENTS t VOLATILES
                                          TO AIR U50)

                                          WASTEWATER TO SEWER
                                          SOLIDS (600)
MISC. PROCESS SOLID
   WASTES (85/75)	
                                                            PROCESS SOLID WASTE
                                                           TO  SANITARY-LANDFILL
                                                                 (245/130)
                                   103

-------
     Buffing Dust.   Buffing dust is produced when  the dried
and  trimmed leather  is mechanically sanded to remove surface
imperfections or  to  improve the nap on the flesh side.  A
typical tannery in this category generates 11  (wet)/10  (dry)
kg per 1000 equivalent hides processed, which on a national
basis totals 61  (wet)/56  (dry) metric tons per year.  Analysis
of samples taken  from the buffing dust collectors  at seven
plants showed the presence of the following hazardous
constituents:

                  Avg. concentration     Concentration range
                        (mg/kg)               (mg/kg)
Constituent       Wet	Dry     	Dry	

Chromium          20,000     22,000       1,200 - 60,000
Lead                 71         77          44 -    120

     Finishing Residues.  Finishing residues are produced as
a result of air pollution control devices on spray booths
and  from general  cleaning of the finishing equipment.  A
typical finisher  generates 150  (wet)/45  (dry) kg per 1000
equivalent hides  processed, which totals 832 (wet)/250  (dry)
metric tons per year on a national basis.  Analysis of samples
taken from the finishing area in nine tanneries indicated
the presence of the  following hazardous constituents:

                  Avg. concentration     Concentration range
                        (mg/kg)             (mg/kg)
Constituent       Wet	Dry     	Dry	

Chromium             525        1,700      <4   -   5,200
Lead              1,100        3,600     <10   - 17,000
Zinc                 105          340     (not de-   1,400
                                         tected)

     3.7.3  Non-Hazardous Solid Waste.  Miscellaneous process
solid waste is generated at a rate of 80 (wet)/74  (dry) kg
per 1000 equivalent  hides processed, which amounts to
440  (wet)/420 (dry)  metric tons per year on a national basis.
This waste is composed primarily of fiber drums and general
plant floor sweepings, and they do not contain constituents
at potentially hazardous concentrations.

     3.7.4  Factors  Affecting Future Solid Waste Generation.

     Air Pollution Control.   Air pollution control devices
are used to remove particulates from the exhaust gases of
spray finishing booths and to collect the buffing dust which
is produced by the buffing machines.  A finishing operation
typically has a water-wash system to remove particulates and
aerosols from the finishing spray booth exhaust.   It is

                             104

-------
anticipated that the gradual installation of water-wash
collection systems in the very few tanneries which do not
currently (1974) utilize them, and retrofit installations
of more efficient collection systems which will be required
by air pollution regulations in certain areas, will not
result in an increase in finishing residues by 1977, but
will produce a 5 percent increase by 1983. 23
     Finishers with buffing equipment also are equipped with
buffing dust collection devices.  Installation of more
effective collection devices are anticipated to be required
by air quality regulations in certain areas; it is anticipated
that this will not result in an increase in finishing
residues in 1977, but will produce a 10 percent increase by
1983?^

     Water Pollution Control.  Currently  (1974) , there is no
solid waste generated as a result of wastewater treatment
by most, finishers.  Since the waste load resulting from
finishing operations is relatively low, as compared with
other tanning operations, it is anticipated that pretreatment
of wastewater from finishing plants will not be generally
practiced by 1977 or 1983.  As a result, water pollution
control will not affect the quantity of solid waste destined
for land disposal from finishing operations.

     Industry Trends.  It is projected that there will be
a gradual decline in the production of firms engaged in
finishing only.  This decline is based upon two trends in the
industry.  The first is the general increased concentration
of both leather producing firms and their customers.  Second,
and most important, is a decline in the amount of crust
leather which is being imported for finishing.  It is
expected that production from firms engaged in finishing will
decline at the rate of 3 percent per year through 1983. 2
     3.7.5  Typj-cal Plant Waste Summary.  The current  (1974)
and projected (1977 and 1983) generation factors for process
solid waste and the various types and quantities of
hazardous solid waste constituents generated by a typical
leather finishers are summarized in Table 30 .  As indicated
in the table, a typical leather finisher  currently produces
a relatively small quantity of both process and potentially
hazardous solid waste per 1000 equivalent hides as compared
to other types of tanneries, and this situation is not
anticipated to change significantly by 1983.

     3.7.6  EPA Region and National Waste Summary.  Table 31
presents the total quantity of process solid waste, and the
types and quantities of potentially hazardous waste, including
their respective hazardous constituents, currently (1974)
generated by leather finishers.  Quantities projected for
1977 and 1983 are presented in Tables 32 and 33 , respectively.

                             105

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                       TABLE  30
WASTE GENERATION FACTORS FOR A TYPICAL LBATBB
Waste
Total Process Solid

Waste
Total Potentially Hasardous
Solid Waste
Buffing' Dust
Finishing Residues
Total
Cr
Pb
Total
Cr
Bn
Pb
1974
Wei
24S
1*1
11
ISO
i 1977* .
Dry
110
ss
10
0.22
0.0008
45
0.07>
0.016
0.17
R FIKI8
HER
_ 1983
wet
2SS
170
12
198
Dry
133
SO
-11
0.24
0.0009
'47
0.083
0.017
0.10
Sourcet  SCS Engineers

     •  No. processing changes are''expected''between 1974
and 1977 that would change the generation factors.  Thus
they are identical.
                              106

-------
                                           TABLE  31
                                TOTJUPBOCBM MO PORVTXALLY HW
                                    8BM8KATHD.ni 1974 BT LBATBSB
                                   (••trie ton* per year, wot and dry baala)
EPA
Reqion(e)
I
tt
m
V
w « n
TOTAL
State (a}
MB.MA.m
BY
HJ
PA.DB
OH.tL.NS
TN.OC.CA

Total
7roce«>
Solid
«a*ta
net
•28
1S»
201
40. f

-------
                                                      TABLE 32
                                 TOTAL HtOCBM
MO PonarrxAUT
            1977
                                              (Mtrie tone par yaar, vat and
   MTXClMinn TO
   SHxiu
dry bails)
EPA
Reqionls)
I
XZ
XXX
• V
XV a XX
< TOTAL
State (a)
MA.MH
m
BJ
M,BI
OH.XXuNX
TH.RC.CA

Total
Proeaai
Solid
Hat
747
J4S
186
37.0
61.3
51.0
1230
397
76.7
98.8
19.6
32.5
27. 0"
652
Total
Potentially
Haiardoua
Haata>
Wat
488
94.4
122
24.2
40.0
J3.3
•02
168
32.5
41.0
0.31
13.0
11.4
276
But f ino duat
Total
Potentially
Baaardoua Conatitaanta .
33.6
6.49
8.36
. 1.6«
, 2.75
2.29
55.2
30.5
5.9
7.6
1.51
2.5
2.08
50.1
0.67
0.13
0.17
0.033
0.055
0.046
. a. 10
Uad
0.0024
0.00046
0.00059
0.00012
0.00020
0.00016
0.0039
Viniahinv raaidooa
Total
Potentially
Hasardoua
Wet
458
08.5
114
22.7
37.5
31.2
. 752
SEX
137
26.6
34.2
6.00
11.3
9.36
225
Constituent*
Chroalua
0.24
0.047
0.060
0.012
0.020
0.016
0.39
line
0.040
0.0093
0.0,12
0.0024
0.0040
0.0033
0.079
0.50
0.097
0.11
0.02S
0.041
0.034
0.13
o
09
      Sourcoi  SCf

-------
                                                         TABLE  33
                                                MB POTBMTIAU.T MIMD008 MUTE  ANTICIPATED TO
                                                GENERATED IB 1981 BY LEATHER HBI8RBRS
                                                (metric tens per year* wet and dry baeia)
em
Region (s)
z
zz
zzz
V
ZV * IX
TOTAL
*
State (a)
MA.OT
KY
NJ
PA.DE
Oa.lL.WI
TM.HC.CA

Total
Process
Solid
Haste
Vet
649
125
162
32.1
53.8
44.4
1070
SSL
341
69.7
85.1
1«.9
28.3
23.3
5CO
Total
Potentially
Hazardous
wastes
Hat
433
83.2
108
21.4
35.8
29.6
711
SSL
149
28.6
126
7.39
12.3
10.2
333
Buffing dust
Total
Potentially
Hazardous Constituents
32.1
6.18
• 8.01
1.59
2.66
2.19
92.7
sat
29.1*
5.59
7.25
1.44
2.41
1.99
47.8
Chromium
0.64
0.12
0.16
0.032
0.093
0.044
1.09
Lead
0.0023
0.00044
0.00097
0.00011
0.00019
0.0001C
0.0037
Finishing residues
Total
Potentially
Hasardoua Constituents
Wet
412
79.3
103
20.4
34.2
28.2
(77
Or*
122
23.4
30.3
6.01
18.1
8.32
200
Chromium
0.22
0.042
0.054
0.011
0.018
0.019
0.36
Sine
0.043
0.0083
0.010
0.0021
0.0036
0.0030
0.071
Lead
0.45
0.087
0.11
0.022
0.038
0.031
0.74
o
\o

-------
 More them  one-half of the  total  process and potentially
 hazardous  solid  waste generated  by leather finishers are
 produced in Region I.   This  situation is not anticipated
 to change  by 1983,  although  the  quantity of total process
 and potentially  hazardous  solid  waste generated by leather
 finishers  is anticipated to  decrease  20 percent by 1983.

              3.8  Beamhouse/Tanhouse  Facilities

      3.8.1  Plant  Operations.  As  shown in Figure 3-7,
 beamhouse/tanhouse facilities produce chrome tanned "blue
 stock"  (hides which have been chrome  tanned but not dried
 and which  are sold to  other  tanneries for retanning and
 finishing).   The production  processes utilized to produce
 blue stock are essentially identical  to those used by
 complete chrome  tanneries  to process  leather through this
 stage.
      Brine cured,  prefleshed cattlehides are the primary
 raw material.  After receipt, the  hides are soaked in a
 water solution in  order to return  the natural moisture  to
 the hide fibers.   Excess fatty substances are removed
 mechanically  after  which the hides are treated with lime and
 sodium sulfide to dissolve the hair.   The hides are then
 treated  with  an  enzyme to  loosen the  fiber structure and
 subsequently  pickled to reduce the pH and to prepare the
 fiber for  penetration of the tanning  materials.   The hides
 are then tanned  with a basic chromic  sulfate solution,  after
 which they are rung to obtain a product with uniform
 moisture content.   The blue  stock  is  then measured and  stacked
 on  pallets which are wrapped in plastic to prevent loss
 of  moisture and  shipped to the customer.   A typical beamhouse/
 tanhouse facility processed  300,000 equivalent hides in 1974.'
      Figure 10 summarizes  the basic production operations
 performed,  the types and quantities of raw materials and
 products involved,  and the types and  quantities of waste
 products resulting  from the  production process.

      3.8.2  Potentially Hazardous  Solid Waste.   As indicated
 in  Figure  10, several kinds  of solid  waste is  generated.
The only potentially hazardous wastestream is  wastewater
 treatment sludges.
     Since the waste load of a beamhouse/tanhouse  facility
 is  often more than  20,000 mg/1 total  solids, a  typical
 tannery of this type provides primary clarifications of  its
wastewater prior to discharge to municipal sewers.  The  sludge
which is produced by this process is dewatered and  disposed
 of  as a  solid waste.  A typical plant  generates  10,000'(wet)/
 2,400 (dry) kg of dewatered  sludge per  1000  equivalent  hides
 processed,  which on a national basis  amounts to  21,500  (wet)/
 5,570 (dry) metric  tons per year.  Analysis  of  a sample  taken
 from the primary clarifier at one plant indicated  the presence
of  the following hazardous consitutents:

                             in

-------
                             FIGURE  10

                               PROCESS FLOW DIAGRAM
                           TYPICAL BEAMHOUSE/TANHOU5B

            (All units are  kg/1000 equivalent  hides on  a dry weight basis
              except solid  wastes  which are given on  a  wet/dry basis)
MATERIALS ADDED

BACTER1CIDES (2
LIME       (900
NA S/NAHS  (230)
SODA ASH   (4SO)
CROHSO*
(NHA)2S04
          (1800)
           (700)
           (4SO)
NA FORMATE <360>
H2S04      (230)
MISC.      (250)
                     CURED  CATTLE  HIDES
                          (12.300)

                             1
) 1 SOAK
) [ LIME
J 1
)1 BATE
1 ^f*9 PICKLE
) V^-"^ TAN
,'[ ^^

\J VR NG
< i
BLUE STOCK
(8900)
WASTEVA
TO SE«E
FLESHINGS ISOOJ ^ SOLD
gj



•ASTEXATER
PRIMARY |
CLARIFICATION 1
/
TER
R
\SLUDGE
(30.000/2.400)
IDEWATERING )-^DEMA
                                                                         I
                                                                         I

                                                           PROCESS SOLID WASTE
                                                          TO SANITARY' LANDFILL
                                                                on LAOOON
                                                              (f 1.1SO/2.650>
                                   111

-------
                                Avg. concentration
                                      (mg/Kg)
     Constituent                Wet	Dry

     Chromium                   5,100       28,000
     Lead                          25          140

        3.8.3  Non-Hazardous Solid Waste.   Miscellaneous
process solid waste is generated at a rate of 250 (wet)/
225 (dry) kg per 1000 equivalent hides processed, which
amounts to 526 (wet)/473 (dry) metric tons per year on a
national basis.  This waste is composed of fiber drums,
paper bags, strings cut off the blades, and general plant
floor sweepings, and they do not contain constituents at
potentially hazardous concentrations.  Fleshings generated
by beamhouse/tanhouse facilities are soldi they were therefore,
not considered as a solid waste.

     3.8.4  Factors Affecting Future Solid Waste Generation.

     Air Pollution Control.  Air pollution control devices
are not currently (1974) used by beamhouse/tanhouse facilities,
since spray finishing and buffing operations are not
performed.  It is anticipated that this situation will remain
unchanged through 1977 and 1983.

     Water Pollution Control.  Primary clarification is
currently (1974) utilized by virtually all beamhouse/tanhouse
facilities to reduce the solids content of their wastewater
prior to discharge to a municipal treatment system, and it
is anticipated that this will continue to be the predominant
level of treatment through 1933.  As new beamhouse/tanhouse
facilities are established, it is anticipated that by 1983
an estimated 15 to 20 percent additional waste per 1000
equivalent hides processed will be disposed to the land,
either in the form of sludge from primary (and possibly
secondary) treatment facilities or by evaporation lagoons
or other land disposal means.
     information collected during this study indicates that
the quantities of chemicals used to perform specific
operations (i.e., tanning) vary considerably from one plant
to another.  This variation is in part a result of successful
efforts at some tanneries to conserve chemicals.  It is
anticipated that as the price of chemicals continues to
increase, more tanneries will reduce chemical usage, and
new tanneries will be planned 'so as to use less chemicals.
     As a result of reducing chemical usage; the solids
content of the wastewater can be expected to decrease.
Consequently, less sludge will be generated as a result of
primary treatment of wastewater.  It is anticipated that by

                             112

-------
 1983,  chemical  conservation techniques will reduce the
 quantity of sludge generated per 1000  equivalent hides
 processed by 15 to 20  percent.   Overall it is expected
 that on a dry weight basis  per  1000  equivalent hides processed,
 the reduced quantity of  sludge  generated due to conservation
 of chemicals will  approximately equal  the increased quantity
 of waste destined  for  land  disposal  due to increased
 treatment facility removal  efficiencies and land treatment.

     Industry Trends.  Current  industry opinion is that
 beamhouse/tanhouse facility production will grow at a rate
 of 8 percent per year, as a result of  several considerations.'
 First,  the large beamhouse/tanhouse  facilities observed had
 more efficient  operations than  smaller complete chrome
 tanneries.   Secondly,  it is anticipated that many of these
 beamhouse/tanhouse facilities will be  located close to the
 source  of the cattlehides  (the  West  and Midwest)  in order
 to reduce shipping costs.   Also,  complete chrome tanneries
 currently located  in cities with increasingly stringent
 pretreatment requirements were  discussing the feasibility
 of moving the beamhouse/tanhouse part  of their operations to
 other locations, while maintaining the retan and finishing
 operations in their current location.

     3.8.5  Typical Plant Waste  Summary.   The current (1974)
 and projected (1977 and  1983) generation factors for process
 solid waste  and  the various types of potentially hazardous
 solid waste  are  tabulated below.  These  factors are in
 units of  kg  per  1000 equivalent  hides.   No change in these
 generation factors  is anticipated through 1983.

                                   Wet        Dry

 Total process solid waste          10,250     2,630
 Total potentially hazardous
 solid waste—dewatered
 primary  treatment  sludges         10,000      2,400
 Chromium                                           51
 Lead                                            0.25

     3.8.6  EPA Region and National Waste Summary.   Table 34
 presents  the total quantity of process solid waste,  and  the
 types and quantities of potentially hazardous waste,  including
 their respective hazardous constituents,  currently  (1974)
 produced by beamhouse/tanhouse facilities.  Quantities
 projected for 1977 and 1983 are presented  in Tables 35 and
 36, respectively.  As these tables indicate, the  quantity
of process and potentially hazardous solid waste  generated
by beamhouse/tanhouse facilities is expected to increase  by
 26 percent by 1977 and 100 percent by 1983.  This increase

                             113

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                                         TABLE 34

                        TOTAL PROCESS AND POTENTIALLY HAZARDOUS WASTE.
                      GENERATED IN  1974 BY BEAMHOUSE/TANHOUSB FACILITIES
                            (metric  tons per year, wet and dry basis)
EPA
Region (s)
I, II, VI
ft IX
V ft VIII


TOTAL
'
State (s)
MA.NJ
AS.TX
MN,WI,
CO


Total
Process
Solid
Waste
Wet
4210

6310

11000
21500
ssssssss
Dry.
1090

1630

2850
5570
'.a
Total
Potentially
Hazardous
Waste"
wet
4110

6160

10800.
21100
=========
SEX
986

1480

I 2580
5050
Wastevater sludge
Total
Potentially
•Hasardous Constituents
Wet
4110

6160

10800
.21100
^••^•MMi^^MMH
Dry.
986

1480

2580
5050
SS5S5S8SS
Chromium
21.0

31,4
,
54.9
107
BBBBSBBBBSBSB
Lead
0.10

0.15

0.27
0.5)
SS8SSSS
Sources  8CS Engineers

-------
                                             TABLE 35

                       TOTAL PROCESS AND POTENTIALLY HAZARDOUS HASTE  ANTICIPATED TO BE
                              GENERATED IN 1977 BY BEAMHOUSE/TANHOUSE FACILITIES
                                   (metric tons per year, wet and dry basis)
EPA
Region (s)
It II. VI
& IX
V & VIII

VII
TOTAL
State (s)
MA,NJ
AZ,TX
MN,WI.
CO
I A, MO

. Total
Process
Solid
Waste
Het
5300

7940

13900
27100
Dry
1370

2050

3590
7010
Total
Potentially
Hazardous
Waster-
Wet
5170

7750

13500
26400
Dry
1240

1860

3250
6350
Wastewater sludge
Total
Potentially
Hazardous Constituents
Wet
5170

7750

13500
26400
Dry
1240

1860

3250 •
6350
Chromium
26.3

39.4

68.9
135
Lead
0.13

0.19

0.34
0.66
U1
    Sourcei  SCS Engineers

-------
                           TABLE 36
TOTAL PROCESS AWD POTENTIALLY HAZARDOUS WASTE ANTICIPATED TO BE
           RATED IN 1983 BT BBMUfODSE/TAHHOUSE 7ACXLXTIBS
            (metric tons per year, wet and  dry basis)
EPA
Region (s)

X.IX.VX
• XX
V t VXXX
VII
TOTAL
State (0)

MA,RJ
AB,TX
m*wi,
00
XA.MO

Total
Process
Solid
Haste
Met
•410
11600
22000
43000
Dry.
2170
3260
STOO
11100
Total
Potentially
Baia7^Mu •
Waste
Hat
8200
12300
21SOO
42000

fist
1970
2»SO
9160
10100
Haatevater sludae.
Total
Potentially
Bazardous ' ' Constitv
Hit
6200
12300
21SOO
42000
fist
1970
29SO
S160
10100
Chroaiom
41.9
62.6
110
21S
ents
Mad
0.21
0.31
O.S4
1.06

-------
is anticipated primarily as a result of increased production
by bearohouse/tanhouse facilities, and is expected to occur
in Western and Midwestern states.

                    3.9  Retan/Finishers

     3.9.1  Plant Operations.  The retan/finish portion of
industry includes those plants which purchase blue stock from
beamhouse/tanhouse facilities and process it into finished
leather.  The basic processes utilized, as shown in Figure 11
are essentially identical to those used in the later stages
of the production process at a complete chrome tannery.
     A retan/finisher receives blue stock on pallets wrapped
in plastic.  After unpacking, it is normally sorted by
thickness and then split to a uniform thickness.  Next, it
is shaved to obtain the exact thickness desired and retanned
with chrome, vegetable, and/or synthetic tanning materials.
Following retanning, the hides are colored and fatliguored.
The hides are stretched on a metal frame, pasted on large
plates, or hung on racks and dried.  The resulting leather
is trimmed, physically conditioned to soften the leather,
and buffed to smooth the grain surface or the flesh side.
At this point, the leather is ready for finishing with a
water or solvent base preparation which is used to improve
wear and appearance.  Following finishing, the leather is
trimmed, measured, and then packaged for shipment.  A typical
retan/finisher processed 675,000 equivalent hides in 1974.
     Figure 11 also indicates the basic production operations
performed, the types and quantities of raw materials and
products involved, and the types and quantities of waste
products resulting from the production process.

     3.9.2  Potentially Hazardous Solid Waste.  As indicated
in Figure 11,eight kinds of solid waste is generated by
retan/finishers.  The potentially hazardous, wastestreams are
discussed below.

     Blue Trimmings and Shavings.  Blue trimmings and shavings
are generated when tanned hides are split and shaved to obtain
leather of a uniform thickness.  A typical retan/finisher
generated 325 (wet)/I40 (dry)  kg of trimmings per 1000 equivalent
hides processed and 930 (wet)/400 (dry) kg of shavings per
1000 equivalent hides processed, which on a national basis
totals 3,100 (wet)/I,300 (dry) metric tons per year.  Samples
were collected from the shavings machines and fiber drums
in the trimming departments of six plants.  Analysis of
these samples indicated that these wastes have an average
chromium concentration of 9,600 (wet)/22,300 (dry) mg/kg,
with a range of 10,000 to 28,000 mg/kg of a dry weight basis.
                             117

-------
                                FIGURE 11
                                    FLOW DIAGRAM
                           TTMCA1. RETAN/FimSHBft

            (All units are kg/1000 equivalent hides on a dry weight basis
             ' except solid wastes which are given on  a wet/dry' Basis)
                        BLUE STOCK
                          IS900)
MATERIALS AOOEP
                           SPLIT
                           SHAVE
                                     TRIM O*SSt4at
                                     SHAVINGS (41OX*OOI
                                                     AS av-pmnuer
                                                        J
SVNTANS
FATLIQUORS
DYES » PIGMENTS
MISC.
WATFR t SOLVENT
 BASE FINISHES '
MISC.
«730^
(SOOli^g
ISOOJf^
csobj
                           RET AN
                           COLOR
                        FATLIOUOR
   JH
   DRY •
  TRIM
CONDITION
 •BUFF
 FINISH
  TRIM '
                                              ATILES TO
                                                    I«9O»
                                                         4/IOO>

                                         FINISHING RESIDUES  I I SO/451

                     FINISHED LEATHER
                          ISOOO)
                                             SHI-:n LEATMCR TRIM
                                               ( 220/200 1
                                           MISC.  PROCESS
                                             .ID WASTES ~
                                             (2SO/22S)
                                                 SCRECMINfiS  CAOX1OI
                                                                        ^
                                    WASTEWATCR
                                    . TO SEWER
                                   (SOLIOS-ISOO)
                                                           PROCESS SOLID VASTC
                                                          TO SANITARY LANDFILL
                                                               f2086/1130)
                                   118

-------
     Unfinished  Leather Trim.  Following drying and before
 finishing,  the sides  of leather  are  normally trimmed to
 remove  ragged edges which would  otherwise interfere with
 the  finishing process.   The  average  rate of generation of
 this material is 114  (wet)/100  (dry)  kg  por 1000 equivalent.
 hides,  which on  a national basis totals  380 (wet)/246 (dry)
 metric  tons per  year.   Analysis  of samples collected from
 the  trimming departments of  seven plants indicated the
 presence of the  following hazardous  constituents:

                  Avg. concentration      Concentration range
                        (mg/kg)               (mg/kg)
 Constituent      Wet	Dry      	Dry	

 Chromium          15,000      17,000      3.600 - 42,000
 Lead               110          130          3 -    530

     Buffing Dust.  Buffing dust is produced when the dried
 and  trimmed leather is  mechanically sanded to remove surface
 imperfections and/or  to improve  the nap  of the fleshed side
 of the  leather.   A typical tannery in this category generates
 27 (wet)/25 (dry) kg  per 1000 equivalent hides,  which on a
 national basis totals 66 (wet)/61 (dry)  metric tons per year.
 Analysis of samples taken from the buffing dust collectors
 at seven plants  indicated the presence of the following
 hazardous constituents:

                  Avg. concentration      Concentration range
                        (mg/kg)               (mgAg)
 Constituent       Wet	Dry      	Dry	

 Chromium          20,000       22,000      1,200 - 60,000
 Lead                  71           77         44 -    120

     Finished Leather Trim.  The  final operation performed
 before packaging  the  finished leather for shipment is
 trimming.  A typical  plant produces 220  (wet)/220  (dry)  kg
 per 1000 equivalent hides processed, which on a  national
 basis totals 541  (wet)/492 (dry) metric  tons per year.
 Analysis of samples collected from the trimming  and  shipping
 departments of three plants indicated the  presence of the
 following hazardous constituents:

                 Avg. concentration     Concentration range
                        (mgAg)               (mgAg)
Constituent      Wet	Dry     	Dry	
Chromium         19,100       21,200     7,600 - 45,000
Lead                250          280       120 -    460
                             119

-------
     Finishing Residues.  Finishing residues are produced as
a result of air pollution control devices on spray finishing
booths and from general cleaning of the finishing equipment.
A typical retan/finisher generates 150 (wet)/45 (dry) kg
per 1000 equivalent hides processed, which totals 369 (wet)/
111 (dry) metric tons per year on a national basis.  Analysis
of samples-taken from the finishing area in nine plants
indicated the presence of the following hasardous constituents!

                 Avg. concentration     Concentration range
                        (mg/kg)              (mg/kg)
Constituent -     Wet	Dry     	Dry

Chromium           525        1,700       <4 -  5,'200
Lead .            1,100        3,600      <10 - 17,000
Xinc               105          340    (Hot de- 1,400
                                        tected)

     Wastewater Screenings.  Retail/finishers normally screen
their wastewater.  A typical plant, produces 40 (wet)/10  (dry)
kg per 1000 equivalent hides processed, which on a national
basis totals 98  (wet)/25  (dry) metric tons per year.
Analysis of samples collected from the wastewater screens
in seven plants Indicated the presence of the following
hazardous constituents! •

                 Avg. concentration.    Concentration range
                        (mgAg)              (mgAg)
Constituent      Wet	~	Dry           Dry

Chromium.          965        4,200       5 - 14,000
Lead'                40          176      43-    190

     3.9.3  Non-Hazardous solid Waste.-  Miscellaneous
process1 solid waste is generated at a rate of 250  (wet)/
225 (dry) kg per 1000 equivalent hides .processed, which
amounts to 525  (wet)/470  (dry) metric tons per year on a
national basis.  This waste is composed of fiber drums,
paper bags, and general floor, .sweepings, and they do not
contain constituents at- potentially hasardous concentrations.

     3.9.4  Factors Affecting Future Solid Haste Generation.

     Air Pollution Control.  Air pollution control devices -
are used to remove participates produced- by .the spray
finishing process and to. collect buffing dust; - The retan/
finisher typically has,  a water-wash system^ to remove
particulates from the finishing spray booth, exhaust.  The
particulates removed are currently .a relatively minor source
of solid waste.  It is  anticipated that gradual installation


                             120

-------
of water-wash collection systems in the few tanneries which
do not currently  (1974) utilize them, and retrofit installation
of more efficient collection systems which will be required
by air pollution control regulations in certain areas, will
not result in a significant increase in finishing residues
by 1977, but will produce a 5 percent increase by 1983.23
     Buffing dust is currently being effectively collected
at a majority of retan/finishers.  Installation of adequate
and effective collection devices at tanneries not currently
utilizing effective collection systems will not increase
the quantity of buffing dust destined for land disposal
by 1977, but will result in a 10 percent increase by 1983. 23

     Water Pollution Control.  Screenings are the only type
of potentially hazardous solid waste currently generated
by retan/finishers as a result of wastewater treatment.  Since
Federal effluent limitation guidelines for tanneries are
currently under litigation, no changes in solid waste generation
as a result of wastewater treatment are expected by 1977.
However, it is anticipated that by 1983, 25 percent of the
retan/finishers will utilize primary pretreatment to remove
wastewater solids.  It is estimated that this will result
in 1000 (wet)/100 (dry) kg of sludge per 1000 equivalent
hides processed, which on a national basis will total 810  (wet)/
81 (dry) metric tons per year.

     Industry Trends.  The growth in the retan/finish
portion of the leather industry will basically parallel
the growth in the beamhouse/tanhouse portion of the industry,
except that a portion of the blue stock produced by the
beamhouse/tanhouse facilities will be exported.  As a result,
the growth in the retan/finisher category is projected at
5 percent per year through 1983, compared to the 8 percent
per year projected increased for beamhouse/tanhouse facilities.2

     3.9.5  Typical Plant Waste Summary.  The current (1974)
and projected (1977 and 1983) generation factors for total
process solid waste and the various types and quantities
of potentially hazardous solid waste generated by a typical
retan/finisher are summarized in Table 37 .  The increase
in potentially hazardous solid waste anticipated for 1983 is
primarily the result of the installation of sewer sumps by
a typical retan/finisher to renove wastewater solids.

     3.9.6  EPA Region and National Waste Summary.  Table 38
presents the total quantity of process solid waste and the
types and quantities of potentially hazardous waste, including
their respective hazardous constituents, currently (1974)
produced by retan/finishers.   Quantities projected for 1977
and 1983 are presented in Tables 39 and 40, respectively.

                             121

-------
                     TABLE  37


  MASTS GBNERATXOM FACTORS. FOR'A TYPICAL RtTAM/FIWIBWtR
           units an kg per 1000 equivalent
v.
Waste Type ~ •
Total Process Solid W
Total .Potentially Basi
Solid Waste
•7
Trimiiigs t 'Shavings
Unfinished Leather
Trim
Buffing Dust
Finished Leather
Trim
Finishing Residues
Wastewater
Screenings
Wastewater Sludge',,
(from sewer sump)

iste
irdous '
Total
Cr
Total
Cr
Pb
Total!
Cr
Pb
Total
Cr.
Pb' .
Total
Cr
Pb
In
Total
Cr
Pb
Total
Cr
S
1974 4 1977V'

2,0*0 1,150
1,010 tao
1,3«0 540
— 12.1
114 100
— I.ft71
	 0.31
a- as
— 0.54
— 0.0010
220 200
— 4.2
— 0.055
ISO 45
•-• 0.079
— r 0.17
— O.OM
40 . 10
— 0.039
— O.OOlC
::: :E
1903

2,120 1.100
2.070 950
1.240 540
114 100
— 1.71
— 0.31
30 ao
— O.S9
— 0.002
aao ado
— 4.2
— O.OSS
ISO 47
— 0.00
— 0.10
— 0.017'
40 10
— 0.039
— 0.0010
is* ,*a
— 0.05
••*•» Q« OW
Sourcei  SCS Engineers

     • -No processing: .changes are-expected between 1974
and 1977 that would change the generation factors.
they are identical.
                          122

-------
          TABLE 38
TOTAL PROCESS M0> POTB8T1ALLY RAMMOOS WASTF
     GENERATED IB 1974 BY RBTAN/FINISHERS
   (metric tons par year, «%t and dry basis)
BPA
Region (s)
I
IX
III
IV.VHX
TOTAL
State ( s)
MA.NH.ME
NY
NJ
PA
TO.WI.CA

Total
Process
Solid
Waste
wet
2320
1360
185
309
892
5070
Dry.
1290
756
103
172
496
2820
Total
Potentially
Hazardous
Wastes
Wet
2040
1190
163
272
784
4450
Dry.
1040
€07
82.8
138
398
2270
Trim and shavings
Total
Potentially
Basardous Constituent
Met
1420
832
113
189
546
3100
Dry.
608
356
48.6
81.0
234
1330
Chromium
13.6
7.99
1.09
1.82
5.24
29.7
Unfinished leather trimming*
Total
Potentially
Hazardous Constituents
Net
128
75.2
10.3
17.1
49.4
380
pry.
113
66
9
15
43
246
ChroBJuia
1.93
1.13
0.15
0.26
0.74
4.21
Lead
0.14
0.083
0.011
0.019
0.05;
0.31
EPA
Reg ion (s)
I
XX
ttt
xv.vtix
TOTAL
State (s)
MA,NH,MB
NY
HJ
PA
TN.HX.CA

riaishina residues
Total
Potentially
Basardous Constituents
vet
169
•9
13. $
.22.5
65. 0
36*
S0.7
26.7
4.05
6.75
19.5
111
Chroaiua
0.089
0.032
8.0071
0.012
0.034
0.19
Lead
0.19
0.11
0.01S
0.025
0.071
0.41
line '
0.018
0.010
0.0014
0.0024
0.0068
0.019
tfastewater. screenings
Total
Potentially
Hazardous Constitu
Met
45
26.4
3.6
6.0
17.3
98.3
sat
11.3
6.60
.90
l.SO
4.33
24.4
Chroaiun
0.044
0.026
0.0035
0.0058
0.017
0.096
ents
Lead
0.0018
0.0011
0.00014
0.00024
0.00069
0.00)9

-------
                                        TABLE  38
                                        (Continued)
5.
EPA
taafcmd)
I
SZ
III
XV.Vim
font
Stated)
;
NA.HR.NI
m
,93
>A
n.m.cft: ..
.
Buff lM dust
Vofca.
Potw
«*t
30.4
17. •
;a.43
4.05
'11.7
4<.a
itially .
. 28.2
14. S
2.2S
: I-.TS
' 10.1
u.s
•Chromium
0.41
0.34
0.04*
' O.OU
0.23
1.33
tead
0.0020
,0.0012
1.00014
1.00027
1.0007? .
0.0044
riniahca laattor trim
fatal
Potaatially
SSI
240
14S
19. •
32
ts.s
Ml
&EX
229
' 132
10'. 0
30.0
04.4
4ta
.^M^- 	 M 	
CBraBlua
4.73
2.77
0.30
0.41
1.12
1 10.0
toad
0.0(2'
. 0.034
0.0090
0.0003
0.024*
0.1M

-------
                                                            TABLE  39
                                         TOTAL PROCESS AID POTENTIALLY HAZARDOUS HASTE. ANTICIPATED TO
                                                     GENERATED IN 1977 BY RBTAN/PINISBERS
                                                     laetrle ten* per year,  wet and dry basis)
CJ
in
EPA
Region (a)
X
XX
XXI
xv.vtxx
TOTAL
State (s)
MA,NH,MB
MX
8J
PA
TN.HX.CA

Total
Process
Solid
Haste
Net
2680
1570
214
358
1030
5850
1490
875
119
199
574
3260
Total
Potentially
Hazardous
Waste'
Net
2350
1380
188
315
907
5140
Or*
1200
'703
95.7
160
461
2620
Trim and shavinas
Total
Potentially
Hazardous Constituent
Hat.
1640
963
131
219
631
3580
prjt
702
413
56.2
94.0
271
1540
Chromium
15.7
9.24
1.26
2.11
6.06
34.4
Unfinished leather trimmings
Total
Potentially
Hazardous Constituents
Met
148
87.1
11.9
19.8
57.1
324
Dig .
130
76.4
10.4
17.4
50.1
284
Chromium
2.22
1.31
0.178
0.298
0.857
4.86
Lead
0.163
0.096
0.013
0.022
0.063
0.36
EPA
Reaionfsl

X
It
XXX
XV.V.XJC
TOTAL
•IBBBHBW^S^H^^SB^SBB
State (•)

NA.HH,MB
MT
Kf
PA
TS.W.CA

^^•^•••••^•l^MWMMMHMMMH^SSSS^SlSMieMSBeHSBiaM^^H^H^H^MMBVMHM^SM^S^
rinishiiM residues
Vote
Pott
Basa
Wet
195
115
1S.C
26.1
75.2
427
ntially
rdous Constituents
SB
59
14.4
4.66
•
7.83
22.5
128
Chromium
0.10
0.060 •
0.0082
0.014
0.040
0.22
Lead
0.2
0.13
0.017
0.029
0.083
8.46
ifee
0.021
0.012
0.0016
0.0026
0.0075
0.045
Maatewator. screeniiras
xotai
Potentially
Hazardous Constituents
Jet
52.0
30.6
4.16
6.96
20.0
114
fist
13.0
7.64
1.04
1.74
S.Ol
26.4
Chromium
0.0 JO
0.030
0.0040
0.0067
0.019
0.11
Lead
0.0021
0.0012
0.00017
0.00028
0.00080
0.0046

-------
 TABLE 39
(Continued)
IPX
Reqion(t)
i
»
i» ,
< IV.Vtix
' *°W
State (a)
I MftfMRf MS
m
w
PA
i • ; ,<
n.vx.ca
j
Bof f iM 4u«t
Total
Potentially .
Baiardous Conttiti
Ha*
35.0
ao.e
Ml
4.70
19.3
7«.«
33. 0
lt.1
2.6
4.3J
1
>11.S
71. «
' fhroniun
0.70
0.41
O.OM
o.o»4
" '0.»7
1.53
imti
!£«
0.0023
0.0014
0.0001*
0.00091
t
' b.oooo*
0.0050
riaished laatter trim
Teta
Pott
Baia
££
206
IM
22.9
30.3.
' 110
02S
I
ntially
rdous
SEZ
260
153
20.0
94.0
100
M»
. phranim
5.44
3.21
1 0.44
| 0.79
2.10
. 11.9..
Ba«
0.072
0.042
0.0057
0.009*.
0.020
L ••*•

-------
                                                         TABLE 40
                                    TOTAL PROCESS AHD POTENTIALLY HACARDOOS WASTE., ANTICIPATED TO BE
                                                 GENERATED IN 1983 BY RETAN/PINISHBRS
                                                (metric tens per year, wet and dry basis)
EPA
I
II
III
IV.VSIX
TOTAL
State (a)
MA.NH.ME
NY
NJ
PA
TN.WI.CA

Total
Process
Solid
Waste
wet
3910
2290
312
521
1SOO
8530
pry.
2040
1200
163
272
785
4460
Total
Potentially
Hazardous
Wet
3470
2030
277
462
1330
7570
pry.
3470
965
132
219
633
5420
Trim and shavings
Total
.Potentially
Hazardous Constituent
Wet
2210
1290
176
294
849
4820
pry.
946
554
75.6
126
364
2070
Chromium
21.2
12.4
1.69
2.82
8.14
46.3
Unfinished leather tr innings
Total
Potentially
Hazardous
Wet
199
117
15.9
26.6
76.6
435
Dry.
176
103
14.0
23.4
67.5
384
Constituents
Chromiun
3.00
1.76
0.24
0.40
1.15
6.55
Lead
0.22
0.13
0.018
0.029
0.034
0.48
to
EPA
Region (•)
Z
IX
IZI
IV.VtIX
TOTAL
state (•)
MA,NH,MB
NY
HJ
PA
TN.HZ.CA

Buffing dust
Total
Potentially .
Hazardous Constituents
wet
50.7
29.7
4.05
6.75
19.5
111
pry.
46.2
27.1
3.69
6.15
17.8
101
Chromium
1.00
0.59
0.080
0.13
0.39
2.19
Lead
0.00332
0.0020
0.00027
0.00044
0.0013
0.0073
Finished leather trim
Total
Potentially
Hazardous Constituents
Wet
385
226
30.8
51.3
148
841
Dry. f
350
205
28.0
46.7
135
765
Chromiun
7.32
4.29
0.59
0.98
2.81
16.0
Lead
0.097
0.057
0.0077
0.013
0.037
0.21

-------
                  TABLE 40
EPA' _ ,
Region Cs)
X
XI
1X1
XV,V*IJ{
TOTAL
•. statoJklL
MA0HH,M2.
NY
US
PA , ;
"-"TO/WXjCA '

, " Finishing .xesldwoa
,. *etal--
Petontialiy
Hazardous w,uu& vA<*u<;j4u.a>
. We.t -
27li
159
21*7
36.2
104
591
Pry
81.3,
47. S
S.4S
ie.8
31.2
177
;'.. ChroaiUB
-0.14 :
0.084
O.Olt
S/^l§ •
«««8S5
,. . <*°n ..
• jssa*
•0.30-
0.175
;' 9.024. ...
•&. 0.40' ~
0.12 :
o.«s
3iHO
• 0.29
0.17
.0.623
"e.@w :
till'"
'-:*".«,,
Wastewater. ssrconinga
ffotal v
Potentially
"Jfazardous ' -Constituents •
Wet
74.3
43.6
S.,9'3
9.9'
28.6
163
2St
ia.i
.U.2
. 1*»3
-2.«S
7.3«
41.7
ehrgmiusi
:e»e73;
0.042
e.eoss.
ie.ei®'
Q.023
aui
Load
0.0029
o.@ei7
@.8G923
O.SCOSS
0.6011
o.eess
ISP*
rRe^|ohj»]

X
II
' III
my«iit:.
TOTAL
StatoCs)

HA.KB«MI
H¥
KJ
PA
TIL^JUCA

: - ' «*»»t«wat«r ilufl^«
TOtki • * ' "'
Potentially .
Bazairdous Con*titu«nt*
Met
^^*^^
282
16$
22. S
37.5
108
615
SOt
26.2
16.5
2.2S
3.7S
19. S
61,5
Chrmiua
8,76
0.45
0.061
0.10
0.29
, l.M
Cops«r
0,034
0.032
0.0043
0.0072
0.020
°-,H ,
2*£&
0.0071
0.0042
O.OOOS7
0.9009S
0.0027
^J0.016
«oare*t  SCS

-------
 As  the  tables  indicate,  the vast  majority  of retan/finish
 solid waste  is,  and will continue to be, generated in four
 Eastern states.  The quantities of waste generated are
 anticipated  to increase  17 percent by  1977 and  69  percent
 by  1983.

  3.10   State and EPA Regional  and National Waste Quantities

     The quantities of total process and potentially  hazardous
 waste destined for land  disposal  are listed for 1974, 1977,
 and 1983 in  Tables  41 through 43 , respectively.  All
 categories of  tanneries  are grouped together, and  state,  EPA
 Region, and  national quantities are shown.   The data
 presented is based on the quantity of  solid waste  generated
 at  the  41 tanneries visited (in units  of kg per equivalent
 hide processed); the composition  of the waste generated,  as
 determined by  laboratory analysis (in  rog per kg of waste);
 and industry production  data (in  units of  equivalent  hides).
 Data for states  with less than three tanneries  has been
 combined in  order to protect the  confidentiality of production
 information.
     As shown  in Table 41 , more  tannery process solid waste
 and potentially  hazardous solid waste  is generated in
 Massachusetts  than in any other state, followed by Wisconsin
 and New York.  Similarly, approximately one-half of the
 total process  and potentially  hazardous solid waste generation
 occurs in EPA  Regions I  and V.  Minor  amounts of solid waste
 is  generated in  EPA Regions VI, VIII,  and  X.  In most states,
 the potentially  hazardous solid waste  generated represents
 about 90 to  95 percent of the  total process  solid  waste.
 Significant  exceptions to this pattern occur in skates such
 as  Pennsylvania, Georgia, Kentucky, and Virginia,  where most
 or  all of the production occurs in vegetable tanneries.
     Tables  42 and 43 show the distribution by  state  of
 total process  and potentially hazardous waste generation
 projected for  1977 and 1983, respectively.  As  indicated,
waste generation is projected to  increase gradually through
 1983 in all  states except those with a large proportion of
vegetable tanneries.   This trend  is anticipated since production
 of  chrome tanned cattlehides and pigskins  is expected to
 increase, while vegetable tanned and sheepskin  leather
production is expected to decline.
     On a dry weight basis,  quantities of total process
 solid waste will increase 37 percent and potentially  hazardous
waste by 51 percent by 1983.   Industry-wide production is
estimated to increase 12 percent bv 1983; however,  production
for the industry segment generating potentially hazardous
waste (all tanneries with the exception of vegetable  '
tanneries)  will increase 14  percent.2
                             129

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                                         TABLE  41
                      TOTAL PROCESS AND POTENTIALLY HAIAMNMS SOLID MAST!
                         GENERATED BT ALL TYPES OF TANNERIES in 1174
                           (metric tona per year, wet and dry basis)
Source i  8C8 Engineers, except production Inforaation vhteh is from Tanners*  Council oC America
types of tanneries
Note i  Totals way not add due to rounding.
       Production is based on the sun of all hides pat into proMSsiaf at all
                                                 130

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                                 TABLE 42
               TOTAL PROCESS AND POTENTIALLY HAZARDOUS BOtID WASTE
            GENERATED BY ALL TYPES OP TANNERIES IN 1977 {PROJECTED)
                    (metric tons per year, wet and dry baits)
State (s)
AK.NA
A .I:A
vrr

..GA

(] III
f '

.TX
i .VT
1 t.VA.WV

1

1

.

! !
1
!
' 1
•X
Total
Reeion 1
it
ill
IV
V
VI
V1I1
IX
X
Total
Process
Solid
Haste
Wot
215
14.900
Jl.SOl
717
1.0.4
8.3!
1.34
§.84
.l!
! H
1 .41
1 .M
.' J i
.7!
. 3J
£l ll
~v .^ i
3.' >i
17. il
2.21
I
16. 1
*. !
«'i it
i
i!
1
1
l!

o
0
1
1
II

-r
>o
10
ll
III
>4
ib
iO
III
220.000
60.100
21.61
30.31
18.11
Hfll
10
'0
10
0
908
i1. 580
14.900
1.1BO
pry.
68
4.920
689
232
417
2,750
: 21
l.!iJO
1.140
258
,600
,000
1 ,160
.760
.230
,470
.760
,280
Lilo
505
281
i j29ll
. ,s4iP
n , s'i'o"
69.100
22.450
7.390
7, 520
3,900
17 . 600
258
689
4.920
349
Total
Potentially
Hazardous
Hastes
Hot
220
13.100





i >8
7.440
225
5.7OO
0
768
12.:

DO
65
13.900
0.040
7.050
8,1
1Q. .1
3f',l
10
( 1
JO
17.000

9
749
6.860
5.74O
27 . 500
173.000
56.500
21.4
00
7,750
S. 810
5O.250
768
2.540
13.700
969
SSL
54
4,100
612
180
19
2.240
56
1.380
0
IBB
3,610
40
12,200
2,210
1,820
2.080
3,000
1,020
5.030
1
183
1,780
1,430
7.640
51.000
18.800
6.050
2,OOO
1,4 SO
14,000
188
612
4,100
237
Potentially lUsavdous Constituents
Chromiusi
1.07
82.4
1*1*
3.44
0.33
44. S
1.05
28.

3.8
70.
0.7
ZI
41!'.
36.
43.
ii.
19.
91!.
O.OO4
3.6
34.
ia.
153
1.000
375
111
39. O
2S.4
278
3.87
12.9
82.4
4.68
Sine
0.00040
D.O3O
0.00087
8. 655 5
6.OOO28
O.01B
0.O016
V.OO13
O
0.0OOS2
0.037
0.00OJG
0.1O
0.02O
0.013
0.O01O
O.026
0.018
A Oft*
01. 0002 5
0.O016
0.18
O.016
B. AM
0.50
0.16
0.O0J
0.19
0.V17
0.11
d. 00062
O.OOOB7
0.030
O.0021
tesi
o.ou
0.96

.070
O.OO42
O.50
d.v^/
0.16
0
0.025
O.98
O.012
2.08
0.63
0.46
O.24
0.75
0.36
1..55
0.0027
0.052
0.52
0.44
I ••
11.9
1.01
2..B1
O.60
0.90
3.6O
0.029
O.OBZ
O.9C
O.060
Copper
0.032
1.62
0.58
O.flO
O.OoSn
1.17
0.I^Jl
0.040
0
0.017
2.0J
0.024
2.0V
1.30
0.68
d.vss
l.«B
0.34
2.20
0
0.11
0.V3
0.11
\ Jol
19.6

~2.6»
1.06
0.S2
6.B6
B.O17
0.058
1.72
O.14
Source i  SCS Ingii

•otei  Totals s«y not add due to rounding.
                                         131

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                             TABLE 43
                   TOTM, MOCRM MD •OtOfrtAUT
                 CBHERATEO BY ML TWU OT TMBMMB* » IMJ
                       (swtrie
              Total
              Process
              Solid
              Msste
•oareot  8CS Baginaon

   it  Totals
                            to
                                     132

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Thus, part of the increased waste quantities can be attributed
to increased production.  Much of the remainder of the increase
is due to increased generation of wastewater sludge.  Complete
chrome tanneries will generate 68 percent more sludge in 1983
and sludge from beamhouse/tanhouse facilities will increase
100 percent.  No other wastestream in these categories is
expected to increase so significantly; most will generate
from 10 to 25 percent more waste by 1983.  Some wastestreams
in the retan/finisher category are projected to increase
more than 50 percent; however, their total quantities will
not make as significant an impact as the wastewater treatment
sludges.
                             133

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                         SECTION 4.0

              TREATMENT AND DISPOSAL TECHNOLOGY


                      4.1  Introduction

     Essentially all solid wastestreams generated by tanneries
using chrome as their tanning medium and those operations
limited to leather finishing were characterized in Section
3.0 as being potentially hazardous.   In each instance, the
wastestream was designated as potentially hazardous on the
basis of its heavy metal content.  Each of the wastestreams
had one or more of the heavy metals—lead, copper, zinc,
or trivalent chromium in concentrations greater than the
geometric mean concentration found in soils in this
country.  One wastestream, finishing residues, was characterized
as potentially hazardous due to its content of flammable
solvents as well as from possible metal toxicity.  Unless
noted otherwise, all discussion in this section of the report
pertains only to potentially hazardous process solid waste.

     4.1.1  In-Plant Management.  In-plant management of
solid waste is similar in most tanneries.  Waste is collected
at the point of generation and placed (usually by hand) into
fiber or steel drums.  Periodically the drums are moved to a
central loading area where they are unloaded into a tannery
or contractor-owned truck for hauling to a disposal site.
In some plants, notably split tanneries and some complete chrome
tanneries, conveyor or pneumatic systems are used to move
large quantities of blue trim and shavings to semi-trailers
or roll-off bins located outside the tannery building.
     Wastewater treatment sludges accumulated in sewer sumps
are normally pumped out periodically into a contractor's
truck for disposal.  Sludge from primary or secondary wastewater
treatment  is pumped into tank trucks for hauling.  If the
sludge is dewatered at the tannery, it is usually collected
in lugger containers or conveyed directly to a dump truck.

     4.1.2  Collection and Hauling.  Of the 41 tanneries
visited, 11 hauled their own waste to a disposal site and 30
utilized contractor services.  Tanneries which haul their
own waste normally own dump trucks which are used for hauling
both solid waste and general supplies.  Since the waste
(with the exception of wastewater treatment residues) is not
very dense, dump trucks with oversized bodies are often
used.  Contract haulers normally use compactor trucks, although
roll-off containers, roll-off compactors, or dump trucks
are occasionally used.

                       Preceding page blank

                             135

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     When  contract  haulers  are used, tannery  employees
normally take  the waste  from  the point of generation to a
central pickup point in  the tannery yard.  When  tanneries
haul their own waste,  the truck picks up the  waste at or near
the point  of generation.

     4.1.3 Treatment  and Disposal.  Treatment of potentially
hazardous  waste in  the leather tanning and finishing industry
is restricted  to dewatering of wastewater treatment sludges.
Most tanneries which employ primary clarification and/or
secondary  treatment of the  wastewater utilize either
mechanical or  non-mechanical  equipment for dewatering the
resulting  sludges.   One tannery visited used gravity
thickening of  sludge and 10 mechanical dewatering systems
(two vacuum filters,  four filter presses, and four
centrifuges) were observed.   The approaches to dewatering,
their effectiveness and extent of use are discussed in
Section 4.2
     Potentially hazardous  waste from tanneries  is disposed
at three types of sites:

        Dumps.
        Landfills.
     .  Trenches, lagoons,  pits, ponds, etc.

The dumps  may  or may not be burning.  They are relatively
uncontrolled,  are not  covered, and little or  no  attempt
is made to protect  the environment from their effects.

     For purposes of this study, the term landfill includes:

        Sanitary landfills  (as defined later).
        Engineered  land disposal sites with cover applied
        less than daily.
        Dumps  converted to  landfills or non-engineered
        landfills with cover  applied less than daily.

     Both  publicly  and privately owned landfills are utilized
by tanneries,  and some sites  are tannery owned.  One landfill
visited during  the  course of  the study was state certified
to receive  hazardous waste.
     Trenches,  lagoons, and similar depressions are often
used for the disposal  of potentially hazardous sludges and
slurries.    They  are normally only covered when completely
filled.   Most sites utilizing this approach to disposal are
tannery owned.    One trench disposal site visited was state
certified to receive tannery waste.   It provided protection
of the groundwater  and groundwater monitoring wells.
                             136

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      Twenty-three disposal sites (.serving 113 tanneries)
 currently receiving tannery waste were visited.   Landfilling
 was the most prevalent type of disposal operation seen,
 and was the approach used by more tanneries than any other
 disposal method.   Open dumping was noted, especially in
 New England (EPA  Region I)  where about 50 percent of tanneries
 use this disposal mehtod.   Only two tanneries disposed
 of their waste in certified hazardous waste disposal
 facilities.  Further discussion of disposal practices is
 included in Section 4.3

              4.2   Present Treatment Technologies

      Most tanneries which employ primary clarification and/or
 secondary wastewater treatment find it both cost-effective
 and desirable from the  standpoint of disposal to dewater
 the sludges produced.   The  water removed is normally
 returned to the treatment  system.

      4.2.1  Non-Mechanical  Dewatering.   One tannery visited
 utilized sequential settling  to increase the solids content
 of their wastewater treatment sludge prior to disposal.   The
 system  consisted  of a series  of three tanks,  following a
 primary clarifier,  in which the sludge is contained during
 settling.   The sludge settles in the first tank,  the
 supernatant from  that tank  is diverted to the sewer,  and
 the  sludge from the first is  conveyed to a second tank to
 settle  further, and the process  is  repeated a third time.
 The  clarifier plus  the three  settling tanks in series
 produces a sludge with solids  content of approximately 25
 percent.

      4.2.2  Mechanical Dewatering.  Vacuum filter,  filter
 press, or  centrifuge dewatering of wastewater treatment sludge
 was  employed by several of the tanneries visited.   Vacuum
 filters with either  stainless  steel or cloth  membranes were
 seen  at  two plants.  They produced  filter cakes of  25 to  30
 percent  solids.  A  ferric chloride  solution (approximately
 10 kg FeClo per 1000 kg of sludge at  25  percent solids) and  a
 saturated  lime solution (approximately 45  kg  lime per 1000
 kg of sludge at 25 percent solids) were  used  as filter aids.
     One tannery and three municipal  treatment plants
 (receiving between 80 and 95 percent  of  their flow  from
 tanneries) were visited which utilize centrifuges to  dewater
 primary or secondary wastewater treatment  sludge.   One
 centrifuge was a basket-type, while the others were horizontal
decanter centrifuges.  Use of a polymer yielded dewatered
 sludge with about 25 percent solids.  More details  about the
municipal centrifuges and disposal of the  solids generated
are included in Section 4.4.1.
     Two tanneries visited used filter presses to dewater
 sludge.   A typical press has approximately  50 polypropylene
cloth—covered plates.  Buffing dust is sometimes added as a
precoat and filter aid.   A 40 to 50 percent solids  filter

                          137

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cake is typically produced.  The use of buffing dust as
a press aid reduces the number of different wastestreams
to be handled and stored for disposal.  It also improves
the efficiency of the filter press, reducing the overall
quantity of waste requiring disposal.

              4.3  Present Disposal Technologies

     The 23 disposal sites visited during the course of
the study are characterized below with regard to operation
and ownership.  The individual entries do not add to 23
since most of the landfill sites also included trenches
for sludge.

                          Operation

     Method of            Number            Number of
     disposal             visited        tanneries served

     Dump                    5                 11
     Landfill*              15                 99
     Trenches, etc.*         9                 25
     Agricultural
      spreading              1                  1

          * One of which was state certified to receive
     hazardous waste.  These were not collocated.

                          Ownership

                          Number            Number of
     Owner                visited        tanneries served

     Public                  8                 52
     Tannery                 5                  5
     Other private          10                 56

     4.3.1  Open Dumping.  Open dumping of all types of
potentially hazardous waste into dumps and other uncontrolled
disposal areas is still a significant practice.  Five dumps
receiving potentially hazardous waste from 11 tanneries
were visited; four were publicly owned; and one was owned
by a tannery.  Leather trimmings, blue trim and shavings,
buffing dust, finishing residues and wastewater screenings
were all disposed at four of these dumps.  Dewatered wastewater
treatment sludge was disposed at one of the sites, and one
dump received only finishing residues.  Expanded to the
industry, it is estimated that 25 percent of the potentially
hazardous tannery solid waste was open dumped in 1974.  It
is estimated that 90 percent of the dumps are publicly

                             138

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owned, 5 percent are privately owned and 5 percent are owned
by tanneries.
     Host state and local officials and tanneries contacted
recognize the environmental inadequacy of open dumping as
a disposal method.  Municipalities and tanneries commonly
cited economic considerations and lack of information on
adequate disposal methods as the reasons for the continued use
of open dumping.  Due to the general awareness of the
environmental inadequacy of open dumping, it is anticipated
that this practice will be virtually eliminated by 1983.

     4.3.2  Landfilling.  Approximately 60 percent of
potentially hazardous waste is disposed in landfills.  A
sanitary landfill may be defined as "a land disposal site
employing an engineered method of disposing of solid waste
on land in a manner that minimizes environmental hazards by
spreading the solid waste in thin layers, compacting the
solid waste to the smallest practical volume, and applying
cover material at the end of each operating day."24
Approximately 10 percent of the landfills currently  (1974)
utilized by tanneries for potentially hazardous waste
disposal are "sanitary."  An additional 25 percent of the
landfills used are engineered disposal sites but do not
provide daily cover.  The remaining landfills are mostly
dumps which have been converted to landfills without being
engineered.
     This study identified 15 landfills which accept
potentially hazardous waste from a total of 99 tanneries.
The ownership of these landfills is summarized as follows:

                                             Number of
     Type of operation         Number      tanneries served

     Public                      4                42
     Tannery owned               4                 4
     Private                     7                53

     For the total industry, it is estimated that approximately
5 percent of the landfills utilized are owned by tanneries,
45 percent are publicly owned,  and 50 percent are privately
owned.   As can be seen, tanneries tend to prefer off-site
disposal if at all possible.  However, some instances were
noted in which off-site disposal facilities would not accept
tannery waste.   Reasons for refusal include the large volume
of some tannery waste and the lack of facilities to handle
tannery sludge which is often a liquid or slurry containing
less than 10 percent solids.  Thus, a tannery is then forced
to operate its own disposal site.   Public landfills are
preferred by tanneries to those privately owned because
of generally lower costs.

                             139

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     Waste Types.  Most  landfills accept all types of tannery
waste,  including wastewater treatment sludges.  Potentially
hazardous waste  (including sLudae) is usually mixed with
municipal refuse,  compacted, and covered.  Landfill operators
noted no particular  difficulty in handling tannery waste
when it was mixed  in this manner.  However, large quantities
of only tannery waste, particularly blue trim and shavings,
were sometimes difficult to spread and compact.  Landfills
accepting tannery  sludge may either mix it with other refuse
 (tannery and municipal)  or segregate it.  At sites mixing
the waste, operational difficulties have been encountered
if the  sludge is not sufficiently dewatered.  Landfill
equipment has become stuck in refuse/sludge landfills.  However,
if the  ratio at which the sludge is mixed with other refuse
in the  landfill is appropriately controlled (as is the case
for the certified  hazardous waste disposal facility described
later),  operational difficulties are minimized.  In one
instance, sludge  (not dewatered) was dumped in a separate
area of a municipal  landfill until it dried enough so that
it could be mixed  with refuse.

     Adequacy.  Tannery  representatives and local and State
government officials indicated that in their opinion sanitary
landfilling is an  appropriate method of disposal for most
tannery waste.  However, some felt that sanitary landfills
were not appropriate for the disposal of wastewater treatment
sludges.  Due to the prevalence of and general satisfaction
with sanitary landfilling and lacking regulations to the
contrary, it is anticipated that virtually all waste, except
wastewater treatment sludges, will be disposed of in landfills
by 1983.
     The potential for environmental damage as a result of
sanitary landfilling of  potentially hazardous waste depends
upon the method of operation; the specific soil, geological
and climatological characteristics of the site; and the
composition and quantity of all of the solid waste disposed at
the landfill, not  just the fraction hauled from the tanneries.
Although good engineering and site selection,  in conjunction
with careful attention to operating procedures,.minimizes
the potential for  leachate generation, it does not
eliminate the potential  for surface or groundwater
contamination as a result of leachate generation.25  Data
is unavailable to  determine the extent to which environmental
damage  has resulted  from landfilling of potentially
hazardous tannery  waste.  However, experience with tannery
waste and knowledge  of landfill operation indicates that
the potential for  environmental damage exists. s
                             140

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      4.3.3  Certified Hazardous Waste  Disposal  Facilities.
 In  general, certified hazardous waste  disposal  facilities
 have  been developed through modification  of  conventional
 sanitary landfills, or utilize trenches or pits.   Additionally,
 these sites have  forms of groundwater  protection  and
 operational procedures and safeguards  required  to properly
 handle chemical waste.  Such operations "provide  complete
 long-term protection for the quality of surface and subsurface
 waters from hazardous waste deposited  therein,  and against
 hazards to public health and the environment."27   Direct
 contact between the waste and subsurface  and surface water
 must  be prevented, and leachate contained and treated.  In
 addition, monitoring wells are often used for the sampling
 of  groundwater in order to detect any  leachate  contamination
 as  early as possible.
      One of the privately owned certified hazardous waste
 disposal facilities that was visited received all
 potentially hazardous tannery waste, industrial and domestic
 sludges, and municipal refuse.  Loads  of  sludge are spread
 between horizontal layers of municipal refuse at  a mix rate
 not to exceed 50  liters of sludge per  m3  of  dry material
 (in order to minimize leachate formation).   The perimeter
 of  the site is sealed with a compacted clay  berm,  and the 2.5
 m deep lifts of solid waste are covered daily with clay,
 thus  the operations are similar to a sanitary landfill.
 Leachate is collected and recirculated, and  the gas
 generated is vented to the atmosphere.  Since annual
 evaporation exceeds precipitation, leachate  recirculation
 provides adequate groundwater protection.  All  haulers
 utilizing the site are required to have a permit  for each
 source of waste,  describing the composition  and quantity of
 the waste.   In addition, the site has  monitoring  wells which
 are sampled quarterly by the appropriate  state  and local
 agencies.
     As discussed above in reference to landfills,  the
 environmental adequacy of a landfill depends upon its
 design, location, operation, and the type and quantity of
waste being accepted.   Unlike a landfill, however,  a
 certified hazardous waste disposal site,  such as  that
described in the preceding paragraph,  provides  assurance
of  long-term protection of surface and subsurface  waters
and against public health and environmental  hazards  from the
disposal of all types of potentially hazardous waste.
     Based: upon interviews at 41 tanneries and other research,
 it  is estimated that 6 percent of the  potentially  hazardous
waste generated by tanneries is disposed of  in this  manner.
Most tanneries cited the limited availability of  such sites
and the normally higher disposal charges as  the primary
impediments to disposal of waste in certified hazardous
waste disposal facilities—a situation which  is not  expected
to change unless mandated by new regulations.

                             141

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      4.3.4  Disposal in Lagoons t  Trenches,  Pits, and Ponds.
 Lagoons, trenches, pits, and  ponds are terms which are used
 somewhat; Aftterjchangeably to refer to: natural Or manmade
 depressionja.wluclt .are- used  for/ the disposal of semi-solid
 waste.-- This,. type of .'disposal differs- fronf landfilling
 in that -.the waste J.« covered, only when the  trench is filled.
      This^study identified  nine- sites of this type serving
 a to taX, of 2£ .tanneries.  Of  the  nine disposal sites, five
 were tannery, owned , tw», were, private, and two were municipal.
 Wastewatex treatment sludges. are- -the  only potentially
 hazardous waste .which, is ..disposed in  lagoons.  It is
 estimated- that1 15 .pejrcefrt : of  tannery" sludges which are
 disposed , in lagoons ©retrenches* go to on-site facilities,
 40 to pr^vate.sMes, and .-45 percent to municipal sites.
      The environmental,. acceptability; of lagoons for the
 disposal of semingelid waste  is- dependent upon • the methods
 and materials of construction, specif ic- local hydrogeological
 conditions,. -and _ the ttypes of  waste which 'are handled.
 Unfortunately,, the potential  for .significant contamination
 of sxibsux f ace water-. s from .inadequately9 lined lagoons, both
 old, and;>ne,wr. is :,4pErQcJ.able , due:. to improper location,
 const rue U. on, and/or, .design.* •„ .Three Of the 'nine * lagoon
 site^tid&Qtj^ed.; weore • constructed with1 compacted clay
 liners.. ...jOne of- ^hqse; had monitoring  wells  afrid another
 provided. fpr, treatment, of 'Ahe subsurface drainage from the
 lagoon,.. > .jThe othe$r six sites,  were constructed of native
 earth matejrJtaliB <
      The quantity .of. tannery  sludge generated is estimated
 to increase -7.8 , percent fro»'J.974  to 1983.   It rs anticipated
 that lpgoon«/ will continue vtO'be  the  primary irtethod of
 disposal, for Cannery sludges  ±f no' regulations to the
         are imposed^  .
     .4 .J8- 5 -. ., flgr.ieu-lturala.Spreaains. '  With reference to
potent^jLlyj- iiaza.rd^vs wasdb^, agricultural spreading refers
to the  use of buffing dust and possibly other waste
consist^g pf relatively small:, leather particles  as a
soil conditioner .  • One, site was identified which  received
settled, sludge from a , buffing/ dust ^wet" scrubber collection
device.'  The-, buff ing du»t.» sludge -is dumped in piles- on the
edges of .^ejarn fields as /it is ..generated.  The farmer spreads
the sl,u,3ge:, whenever he has an opportunity, and- the  sludge"
is disced, into the.goii twice , a year.  Growth of  the corn
reportedly ^as ,ippjrovedr aincerthe, addition of the  sludge.
     Analy,3.4avof,.e3His!sidn>.s"p"ectrrosrcopy of -»slaiitpieS of corn
coJ,leat,ed<.friqm tjtie atr^a - receiving bti&f ing tfust sludge arid
from, a A ^adjacent farjniAdiicii deed-not -^receive" any  tannery
waste^r i4i»d4.>qa'ted-.^:hat!,the concentration's o*f nicke^,  total1
chromium r; j^ejad,^ artd:J.rojl :were -LO, i:2f  1C, and 5 timete greater

                              142

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 respectively, in the corn taken from the  field  receiving
 tannery waste.  Since the significance of this  observed
 metal concentration phenomenon is unclear,  the  environmental
 adequacy of this disposal practice is questionable.
     In addition, buffing dust is considered to be a
 potentially hazardous waste since it contains high
 concentrations of lead, copper, and trivalent chromium.
 Information is not currently available to determine if
 land application of buffing dust will increase  concentration
 levels beyond acceptable levels or if ground and  surface
 water pollution will result.  Consequently, this  practice
 cannot be considered environmentally acceptable until
 further study is undertaken to determine  the effects on
 crop composition, soil fertility, and adjacent  groundwater
 and surface water quality.

                4.4  Alternatives to Disposal

     4.4.1  Municipal Sewage Treatment.   Some tanneries are
 located in communities where most of the  wastewater received
 at the municipal sewage treatment plant is discharged by
 tanneries.  These situations are somewhat unique  to the
 tannery industry and deserve mention.
     The situation was particularly prevalent in  New England
 (EPA Region I) where three tanneries were visited which
 provided 80 to 95 percent of the flow to  municipal treatment
 facilities.  In other Mew England and New York  (EPA Region
 II) communities, up to 60 percent of the  flow was contributed
 by tanneries.  Thus, the municipalities were treating
 essentially tannery wastewater and generating and treating
 tannery sludge.
     In the community in which the tannery contributed 95
 percent of the flow, the primary treatment plant  sludge was
 dewatered with horizontal, decanter-type  centrifuges to
 23 percent solids and disposed in trenches at the city's
 landfill.  In the two other communities,  the tanneries
 (a complete chrome tannery and a retan/finisher)  contributed
 about 80 percent of the flow.   Both of the treatment plants
 were constructed recently and neither was producing any
 secondary sludge.  Primary sludge was being dewatered
 with decanter centrifuges with cakes about 25 to  28 percent
 solids.   One operation was disposing of sludge  in trenches.
The other treatment plant was stockpiling the sludge near
 the plant until  a disposal site was found.
     Neither of  the secondary treatment plants was
experiencing major difficulties treating tannery  wastewater.
The plant serving the complete chrome tannery was specifically
designed for tannery wastewater.   It included a carbonation
tank followed by a second primary clarifier for the
precipitation of calcium carbonate (calcium from  lime in
beamhouse waste).   Influent to this plant has a BOD of over
2,500 mg/1 and effluent is approximately 100 mg/1 BOD.

                            143

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      4.4.2  Source Reduction Through In-Plant Process Change.
 Several tanneries have developed or are  developing recovery
 and reuse programs designed to reduce chemical consumption
 and improve the quality of their wastewater.   These programs
 include systems for recovery and reuse of hide soaking
 solutions, beamhouse sulfide liquors, and spent chrome
 tanning liquors.   As reliable systems are developed,  it is
 anticipated that the use of these recovery operations will
 gradually become more widespread.   The effect of this will
 be a reduction in the quantity of wastewater  treatment sludge
 generated at tanneries utilizing primary  clarification and/or
 secondary wastewater treatment and which employ these
 recovery and reuse systems.22
      It may be possible to accomplish potentially hazardous
 waste avoidance through the elimination  of hazardous
 constituents (with the exception of chromium)  from the
 chemicals used in the leather production process.   Since
 laboratory analysis of samples of cattlehides,  sheepskin,
 and pigskin before any tannery processing indicated that
 lead, zinc, and copper are present at only natural background
 levels,  these metals appear in certain wastes as a result
 of the production process.   Tannery experts indicate  that
 these heavy metals are likely introduced in the retan,  coJ,or,
 and finish operations in the form of dyes and/or pigments.22*28
 Contact with tanners and manufacturers of tannery chemicals
 indicate that substitute products  have been developed which
 can be used in place of those  containing lead,  copper,  and
 zinc.   Such substitutions have already been adopted for
 chemicals containing mercury.   However,  the practice  has not
 been extended to  pigments containing other hazardous
 constituents because of the slightly different  product
 obtained,  the increased expense associated with the use
 of substitute organic dyes  and pigments,  and  the general
 reluctance to change.   With the advent of regulations
 governing the disposal  of potentially hazardous waste,  however,
 tanneries  may find it cost-effective to  utilize substitute
 organic  dyes  and  pigments.
      A few tanneries are  looking to  process and equipment
 changes  that  will improve overall  tannery efficiency  and
 coincidentally reduce waste quantities.   "Splitting to
 weight,"  the  extremely  accurate splitting of  tanned leather,
 is  being employed by some tanneries  to essentially  eliminate
 the shaving of entire sides to obtain  uniform thickness.
 Use  of this technique reduces  processing  costs,  increases
 the  value  of  splits  produced and reduces  the volume of
 shavings requiring disposal.
     The process,  however,  requires  the use of  sophisticated,
 expensive  equipment  and was  only seen  in  a  few  tanneries
visited during  this  project.   It was the  opinion of several
tanners that  the widespread  use of splitting to weight will
evolve slowly  due  to current investments  in conventional

                             144

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 splitting  and  shaving  equipment,  the  high cost of the new
 machines,  and  reluctance on  the part  of some tanneries to
 change  from traditional processes.
      The segregation of wastewater  streams within a tannery
 could reduce the quantity of potentially hazardous waste
 requiring  land disposal.  No hazardous  constituents were
 found in beamhouse waste.  Thus,  if beamhouse wastewater
 (high in suspended solids) was segregated and separately
 clarified,  the resultant sludge would not be a potentially
 hazardous waste, and in fact likely could be marketed as
 a  soil  conditioner due to its protein and lime content.
 One tannery is known to be using  this approach.   Wastestream
 segregation would require widely  varying amounts  of plant
 modification.
      The process modifications described above are in
 various stages of development from  experimental through
 pilot plant and full scale operation.   However, none of
 the processes  are in widespread use in  any of the tannery
 categories,  let alone  the tanning industry as a whole.   In
 addition, it is doubtful that many of  the in-plant processes
 will  come into widespread use by  1983.
      The impression gathered from tannery officials during
 the course  of  this project was that tanning is considered
 an art.  Each  tanner feels that he  knows the  "tricks of
 the trade"  as  far as the production of  his  particular leather
 is concerned.  Tanners strive to maintain a quality product
 of consistent  color, texture, pattern,  etc.,  in order to
 retain  their established customers.   Some tanners are not
 sure  that they can reduce their chemical usage, use •:
 reformulated finishes,  reuse chrome,  etc.,  and still produce
 the same product, and thus are reluctant to make  even minor
 changes in their processing.
     Therefore, tanners will move slowly in altering their
 processing procedures.   Since the in-plant  process  changes
 are not applicable to nor likely to be  adopted by all
 tanneries in a particular category, no  attempt has  been
made to suggest them to the entire  industry.   Consequently,
 in-plant process changes which impact on the quantity or
nature of potentially hazardous waste have  not been included
as any level of treatment/disposal technology.

     4.4.3  Sale as By-Products.   Economic  feasibility is
currently the primary factor affecting by-product utilization
of potentially hazardous waste.   Following  is  a list  of the
types of potentially hazardous  waste which are currently
saleable:
                             145

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     Wastestream
By-product use
     Blue-itrim and.-shavings
     .Solvent-based if inish
      -residues
     leather i.trimmiisgs.
Fertilizer
Hog feed supplement
Glue

Solvent recovery
Glue
Grafts—-small:leather
 articles
     Withithe exception of 'solvent recovery,  by-product
utilization of;potentially ^hazardous  waste is volatile and
dependent ^upon? loeat^oru , finished and unfinished leather
trimmings are sometimes sold  to foreign leather goods
manufacturers ijv countries such as Korea,  Japan, Hong Kong,
and Taiwan, where, because of cheap labor, this material
can be haod-rsorted and manufactured into small leather
products;*-: However,'.this market depends, on a  .variety of
unstable variables,'including freight-rates,  hide prices,
labor .cost, and availability/ and market demand...
     The major type of potentially? hazardous  waste sold
is blue trim and shavings.  These  are,  and have been, sold
to producers of: fertilizer', animal feed'supplements, and'
glue.   These: markets are apparently  declining as: evidenced
by the facts :that, within -±he". last-.two  decades  the number of
fertilizer producers .utilizing leather waste.has been reduced
from 28 to-3.  In addition, glue manufacturing from leather
waste has ^essentially .ceased. ;• However, tanneries located
in the Midwest are abjleJto..sell their blue trim and shavings
to a .producer,of fertilizer-used principally  in citrus .
groves:., and to •&-. lesser extent in other orchards.  Similarly,
some tanneries also sell blue triro^andL shavings for use a
a hog .feed supplement>  c;
    :. Sale Qf- potentially hazardous,/ waste for; by-product
uses is gncoutagedas an alternative  to disposal if the
ultimate-xuse ©f the; waste is.  environmentally  sound.  Blue
trim, and rsfeavings are jEonsidered potentially  hazardous due
to their |dgh,trivalent chromium,content.   Information in,
the.literature indicates t^at fcrivalent chromium is hazardous
to aquatic organisms and, to'lower  forms of terrestrial
plant life, but not to mammals and higher plant forms.
Consequentiy» the use:iof -blue trim;and shavings-as a hog
feed,.s»pp:lemen:'t is approved ,,bys 0SDA (chrpmium content not
to exc;e$d..,275 ppm) .v.,Similarly, the use of: this waste as
an orchard•;fertilizer is encouraged as long as the application
does not increase concentration levels beyond acceptable
levels and ground and surface water pollution does not
result from the practice.  Use of  the waste for other
                             146

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 fertilizer applications, such as vegetable  crops, must be
 studied  further before the environmental adequacy of  the
 practice is known.

              4.5  Approach to the Selection of
              Treatment and Disposal Technologies

      4.5.1  Technology Levels.  For purposes of  this  report,
 three levels of technology for the treatment and disposal
 of potentially hazardous solid waste from leather tanning
 and  finishing establishments were identified.  These
 technology levels are characterized as follows29:

      Level I  —Technology currently employed by typical
                facilities, i.e., broad average  present
                treatment and disposal practice.
      Level II —Best technology currently employed.
                Identified technology at this level must
                represent the soundest process from an
                environmental and health standpoint currently
                in use in at least one location.  Installations
                must be commercial scale; pilot  and bench
                scale installations are not suitable.
      Level III—Technology necessary to provide  adequate
                health and environmental protection.  Level
                III technology may be more or less
                sophisticated or may be identical with
                Level I or II technology.  At this level,
                identified technology may include pilot
                or bench scale processes, providing the
                exact stage of development is identified.

      The definition of Level III technology as defined in
 this  report represents contract judgment, and not that
 of the EPA.  This level of technology as defined for a
 particular potentially hazardous wastestream and/or process
 type  is merely an attempt by the contractor to define an
 environmentally acceptable technology.  Thus, the technology
 level defined should not be interpreted as a basis for
 future regulations.   It is not based on cost-benefit,
 economic, or other analyses required to appropriately define
 Level III technology.30

      4.5.2  Treatment.   Treatment is applicable to only
 one wastestream from tanneries.   Sludge from wastewater
 pretreatment or treatment facilities can be dewatered.
Currently, tanneries in both the complete chrome and
beamhouse/tanhouse categories dewater sludge.  The removal
of as much moisture  as  possible  has  lead to reduced on-site
 storage requirements, improved hauling,  more acceptable
disposal practices,  and generally lower disposal cost.  The
previously described approaches  of gravity and mechanical


                            147

-------
dewatering appear to be the only treatment methods applicable
to wastewater treatment sludges.  The single instance of
gravity dewatering is being replaced by a filter press.
Therefore, in those categories in which significant sludge
is generated, mechanical dewatering is suggested for
waste treatment.

     4.5.3  Disposal.  The potential hazard from tannery
waste so designated comes from the possibility of heavy
metals leaching from disposal sites and entering the
surface or groundwater system.  Thus, Level III technology
will have to incorporate some safeguard to prevent leaching.
On the other hand, no special handling methods or equipment
are required at the disposal site for tannery waste.
Level III technology for disposal of potentially hazardous
waste is the use of landfills With a leachate collection
system and an environmentally acceptable means of treatment
and/or disposing of the leachate.  This approach will
prevent any heavy metals leached from the waste from
entering the surface or groundwater system.
     The other potential hazard associated with tannery
waste is the flammability of some finish residues.  These
are disposed in relatively small quantities and on
infrequent bases, e.g., 200 to 400 liters (50 to 100 gal)
per week.  Therefore, the normal, safe operation of a landfill
with leachate collection should provide adequate protection
from this potential hazard.
     Tanneries generating potentially hazardous waste
predominantly use off-site disposal.  This is also true of
the best current practices  (Level II technology).  Therefore,
'only off-site disposal is listed on the technology level
tables in Sections 4.6 through 4.11.  However, equivalent
on-site disposal is also considered adequate.

     4.5.4  Outline of Subsequent:Sections.  The six categories
of tanneries generating potentially hazardous waste are
discussed in turn in Section 4.6 through  4.11.  The data
presented in Section 3.0 for' each category of tannery are
summarized.  Potentially hazardous wastestreams, their
hazardous constituents, waste generation factors, and
national totals for each waste' type are shown.
     The three treatment and disposal technology levels
developed are presented for each category of tannery.
In some instances, more than one alternative is listed for
a single technology level.  Each technology is evaluated
using the following criteria:
                              148

-------
        Current usage in the industry.
        Risk potential.
        Environmental adequacy  (present and  future).
        Monitoring techniques.
        Limitations.
        Impacts.
        Implementation time.

     Treatment and disposal technologies pertinent to
each category are discussed.  The types and  numbers of
operations are listed.  These tables provide the  basis  for
the cost estimates presented in Section 5.0  for each
level of technology for each category of tannery.

   4.6  Treatment and Disposal;  Complete Chrome Tanneries.

     The potentially hazardous waste currently (1974)
generated by complete chrome tanneries is  summarized as
follows:
Wastestream

Trimmings  and
  shavings
Unfinished
  leather trim
Buffing dust
Finished
  leather trim
Finishing
  residues
Wastewater
  screenings
Sewer sump
:  sludge
Dewatered
  wastewater
  or treatment
  sludge
Potentially
hazardous
constituents
    Cr

Cr, Pb, Cu
Cr, Pb

Cr, Pb, Zn

Cr, Pb, Zn

Cr, Pb

Cr, Cu, Pb, Zn
Generation
rate • (wet/dry
kg per 1000
eg. hides)
1,260/540

  114/100
   27/25

  220/200

  150/45

  390/90

2,700/300
Nat't. total
(wet/dry
metric tons
per year)
21,000/9,100

 1,900/1,700
   460/420

 3,700/3,400

 2,500/760

 6,600/1,500

37,000/4,100
Cr, Cu, Pb, Zn   10,000/2,400    100,000/24,000
      Treatment and  disposal  technology levels for complete
 chrome tanneries are presented in Table 44.

      4.6.1  Treatment.   The  only type of potentially hazardous
 solid waste from a  complete  chrome tannery which is
''normally  treated is the  sludge from wastewater treatment or
 pretreatment facilities.   The  treatment utilized is
 mechanical dewatering (filter  press, vacuum filter and
 centrifuge)  which is discussed in Section 4.2  Individuals
                             149

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                                                   TABLE 44
                                                  COMPUTE CimOHl
UI
AJMUM of Matoi io«.ooo(Mt)/it.ooofdry) Mtcio
Pkyalcal aad OMloal PrapaMiMi Seal-Mild tad
Level 1
. Typea of *»<•• «n types

• tMhaolooy Ofl-alto laadflll
* ^SMT ••**"*?*
• % Ojf C*A^le%* CbffMO M
• f of cnaploto.CaWaa* U
. Mat
, . *
• rito o» toploaloo iltoM
-*-«"«•»" "•*"
• Pollnti«ii Nedarato
n.
• Moitortat Taehalajioa • Mno
. UMtatittoa Md riro kaiard and
•voMana «orter aafaiy.aad
larjo quMtitU*
of wakoa
*•>••>• «otar pollution pataatial
. ^U^u.i«iTiM uaiaiud
tona par yaar 11*741
aolid vitb tonie haavy Mtala (P».ta.C«.Crl. flanHftla aalvMta
Lavol IIZ
l***l Ii **«. i «it. i
t having*
II Other naataa

II talo aa a bv-prodoet
II Oavatar alodfaai oil naata*
to off-aita eaztlfiad aataidoua
vaato dlapooal faaility

II U
II «
II M
II • '
II Ml
»l *H
pofe la off-alto
linod trciichM at
UrJsIll wltb
lcjc!ut* ealloetko
II **lo aa a by>
product
II Off«aito laadflll
vitb teacbata
colloatlM

II «
II M
II 0
II •
II I*
II t
lall Ml
II »Ilgbt
Ull Ml
II MlfM
1.1.411 Ml
II Caeolloot
Ull CrauBdvatac walla
Ull foil cooditloao
1} voUtlla MIBM
l.I.tll Ml
Ull laotallod 1411 I yoara
II >ot applirakU
                •ounoi MS

-------
 experienced in tannery wastewater treatment prefer filter
 presses for dewatering tannery wastewater treatment sludges.
 Although centrifuges,  vacuum filters,  and filter presses
 all seem to perform acceptably, the higher solids content
 of sludge dewatered with a filter press may favor its
 use in the future.

      4.6.2  Disposal.  All chrome tannery solid waste,  with
 the exception or  sewer sump or wastewater treatment sludges,
 is normally combined for disposal purposes.  Nineteen disposal
 sites receiving complete chrome tannery waste other than
 sludges were visited:

         On-site dump--1.
         On-site landfill—1.
         Private landfill—8.
         Municipal dump—2.
         Municipal landfill—7.

      Both tanneries  which operate on-site disposal facilities
 also dispose of wastewater treatment sludges on-site.   Zn
 both cases,  the land and equipment were purchased primarily
 for sludge disposal.
      Sixteen sites accepting  sludge from complete chrome
 tanneries were  visited:

         Private landfill—6.
         Municipal landfill—3.
         On-site (tannery)  lagoons—4.
         Private (off-site)  lagoons —2.
         Private certified  hazardous waste disposal
          facilities—1.

      Pour tanneries operated on-site tiludge disposal  facilities
 because  the  local private or municipal  disposal  sites would
 not accept tannery sludge.
      It  is estimated that on a national basis  15 percent
 of  the potentially hazardouswaste  generated by complete
 chrome tanneries currently  (1974)  is disposed  of in on-site
 facilities.  Fifteen percent is disposed  in off-site lagoons
 or  trenches; 16 percent is disposed in  off-site  dumps;
 50 percent is diposed in off-site  landfills* and 4 percent
 is disposed in certified hazardous waste disposal facilities.

      4.7  Treatment and Disposal;  Sheepskin  Tanneries

     The types and quantities of potentially hazardous solid
waste generated by the  sheepskin tanning industry are
summarized below:
                              151

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 Wastestream

 Chrome
  fleshings
 Buffing dust
 Leather trim
 Wastewater
  screenings
Potentially
hazardous
constituents
     Cr
Cr, Pb, Cu, Zn
Cr, Pb, Cu

Cr, Pb, Zn
Generation
rate  (wet/dry
kg per  1000
eg. hides)
1,200/300
    56/50
  170/140

  230/50
Nat'l. total
 (wet/dry
metric tons
per year)
3,000/750
  140/130
  420/350

  570/120
      Treatment and disposal technology  levels  for  sheepskin
 tanneries  are summarized in Table  45.
      Sheepskin tanneries do not treat any of the potentially
 hazardous  solid waste generated.   All of the potentially
 hazardous  waste listed  above  is normally combined  in the
 plant and  disposed together.  Six  disposal  sites receiving
 potentially  hazardous waste from sheepskin  tanneries were
 visited.   One was  a municipal dump, two were municipal
 landfills, and three were private  landfills.   Since most of
 the  sheepskin tanneries are located on  the  East and West
 Coasts in  relatively urban areas,  on-site waste disposal is
 not  normally utilized.
      On a  national basis, it  is estimated that 40  percent
 of potentially hazardous waste generated by sheepskin
 tanneries  currently (1974) is disposed  in municipal dumps,
 30 percent in municipal landfills, and  30 percent  in
 private landfills.

        4.8   Treatment  and Disposal;  Split Tanneries

      The four types of  potentially hazardous waste which is
 generated  by split tanneries  is summarized  below:
Wastestream

Trimmings,
 splits &
 shavings
Buffing dust
Unfinished
 leather
 trim
Wastewater
 screenings
Potentially
hazardous
constituents
    Cr
 Cr, Pb
 Cr, Pb

 Cr, Pb
Generation
rate (wet/dry
kg per 1000
eg. hides)
8,200/3,700
  200/180
  230/200

   22/5
Nat'l. total
(wet/dry
metric tons
per year)
28,000/13,000
   690/620
   790/690

    75/17
                             152

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                                                      TABLE  45
                                               TUMMER MO DISPOSAL Tl
                                                        FOR SflEBSRIli TAMHBKY
                         Aoount of Mastei  4.100(wet)/I,)00(dry) aetrie ton* per year
                         Physical and Chevies! Propertiesi  Solid, containing toale Heavy M*als (Pb,So,Cu)
                                                   Uy«l I               Uxl II              l*nl III
                         Types of Nastm           All typu           VMM M U**l X          Ul types
                              •logy           OM-eite Instill                              Oil-site Undf ill
                                                                                            with leaetete
                                                                                            eelleetiea
                          BstiMte «f current
ui
- » of Sheepskia
   twweriee
- I of 8he«p«kia
   Tanneries
Uek
• fire er faploeie*
• traaspertetiea
• Vellotiea
                                                      •0
                                                      2C
                          Nsalteriav
                          Uaitetiene ea«
                                  i
                                  Seleted
                           lapsets
                                        •is*
                                                   PsU
                                                   fair
                     Corf eee and/or
                     pettaeiM potential
                          Inetelle4
   9
   0

flight
•li«
•il
                                                                            iter welie
                                                                     •oil conditions

-------
      Treatment and 'disposal- technology levels' fior split
 tanneries are summarized in- Table 46  .
      None of the potentially hazardous waste from a split
 tannery receives- treatment of any kind prior to disposal.
 All split tannery waste is normally combined in -the plant
 and disposed together.   Three • disposal sites receiving
 potentially .hazardous waste were visited;  one was a municipal
 landfill, and two were  private landfills.   Since split
 tanneries are normally  located in urban areas, virtually
 all split tannery solid waste is disposed.9, off -site.
      Available information indicates  that; 70 percent of the
 potentially hazardous waste generated by- split tanneries is
 currently (1974 K being .disposed 'in municipal slumps and that
 30  percent is c be ingr disposed in landfills,  the high
 percentage using dumps  is due to the  location of -these
 operations — Mew England (EPA Region  I) where dumps are common.
 In  addition, the split  tanneries in the Midwest (EPA Regions
 V and VII)  are able to  sell their trimmings and shavings
 and thus they . are .not waste .

        4 . 9 ^Treatment and Disposal ;   Leather -Finishers

      The potentially hazardous waste  which is generated/ by
 leather finishers is listed below:          *

                                   Generation      Nat'>'^L. total
                 Potentially       rate (wet/dry   (wet/dry
                 hazardous         kg  per 1000     metric tons
 Wastestream     constituents      eg. hides)       per, year). i

 Buffing 'dust      £r>  Pb            11/10           61/56
 Finishing
 residue        Cr,  Pb,  Zn t
                  solvents          150/45          830/250

     .Treatment and disposal ^technology "levels for 'leather
 finishers are summarized in Arable 4?.  '
     ^either of this potentially "hazardous waste is treated
 prior to^; disposal.   Instead, this ah:d Other waste ^non-process
 waste from ?off ices,  etc.) Sis? normally combined either during
 collection spr [hauling: to the; disposal
                                '   "
     finee |eoss#ntially £ll> Leath'er "t ii&shers  are located in
urban* areas >arid because 'finishers do not generate large
quantities of waste, off-site facilities are 4ised for all
waste disposal.
     Three disposal sites  receiving potentially  hazardous
waste from finishers were  visited, of which two  were
municipal dumps, and one was a private landfill'.  Although
use of municipal dumps is  typical for their location,
disposal in dumps is not typical for leather  finishers.
Therefore, estimates of the type of solid waste  disposal

                            X&4,

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                                                          TABLE  46
                                            TREATMENT ADO DISPOSAt TECHNOLOGY LEVELS
                                                       POR SPLIT TANNERY
Wl
Ul
ABbunt of Nestei U.000(wetl/7.900(dryl
Physical and Chemical
. Types of Mattes
. Technology
. Cstinate of
Current usate
- % of S;.lie
T«r.A«r :•••
- • of T« fineries
. Risk
• Piro or Explosion
• Transportation
- Pollution
. Present Adequacy
. Future Mi-quaey
. Monitoring Technio/ies
. tlmit«tl'jfia and
Problems
. non-Land Piloted
Injects
. Inploaantation Time
Propertiesi Solid.
Level I
All types
Off-site dumping

70
17

Nil
Slight
Moderate
Poor
Poor
*"
metric tons per year
Containing Tmic Heavy Metals (Pb and Crl
Level III
Level II Alt, i
11 Trimmings and All types
Shavings
at Other wastes
11 Sale as a by-product Off-site landfill
at Off-site landfill with Icachate
collection

1*2) 10 0
112) 7 0

11 Nil Nil
21 Nil
11 Ml Slight
at Slight
11 Ml Ml
at Moderate
11 EBcellent Good
at r-ir


***• '
11 Trimmings and Shavings
at Other wastes
11 Sale as a by-product
21 Off-Site landfill with
leachate collection

11 «
at o
it i
at o

uat MI
11 Ml
at Slight
uat MI
U2I Excellent
II Excellent Cood Uat Excellent
at Pair
Oroundwater veils at eroundMter wells
It Volatile sad Ceo* soil conditions
graphically concen-
trated market
11 Volatiband <«M>.*r«eh-
ically concentrate!
market
a) Soil conditions
Surfw and/or ground- a> Surface and/or ground-
water pollution potential ««« pollution potential
Installed
IMl Installed a years
2 year*
          Sourest  SC8 Engineers

-------
                                   TABLE  47
                          1MKIMOT AM DISPOSAL	
                                    PC* uM«ft pnisms
       af Maatai   tOO(wat>/MO aa?rie taaa par yaar (1*94)

Thyaical and =ha*ieai *re?arbiaa-   Baffiaa «aat aoataiaa
 fialsM.fi raai«aaa =«-.t«in heavy  -Mtal'a (Cr,Pa.Ba)i aad
                                                                  ea«ala (Cr.fb)i
                                                                 am f Unubl*
         of Haataa


   Taehnolofy





   tatiaata of Corrane
   • %'of finlahara


   • t of riniahora

   Kiak

   • Fira ar Explaaiaa


   - Traaapertafie«


   • fellatiaa


   Presc-nt


   Putiira


   Monitoring Taehniqua'a

   Ltaitatiuna and
   Non-Uteri' Moiatad
    Impacta
   Isplea-eatatioa Tima
                            fc»»al 1

                         t)  MuCfiaa da
                         1)  Maiafclaff

                       UI)  Off«ai«« laadfiU
                       14X1
                       ua>  «t
                         1) -SlioM
                         I)  -
                         il
                         X) iliatrt
                         I)
                         »
                         il Pair
                         2) Poor

                         1) Pa'.-
                         X) roar
                         1)  Soil condition*
                         X)  fire bacard, aail
                            conditions and
                            work'ar 'aafoty

                       1*2)  Surface and/or greuad-
                            vatar poilntioa potential
                            Xnataltad
                                                                                 111
  1) Buffing «aat
  XI Piaiabing raaiduaa

  I) oer-aita landfill
     Mitk laaehata
     eatlaetiaa  '
  X) Off-ait*
           0


           0
  1} Ml
  2) Slight

  1) Ml
  X) Slight

UX) Ml
  1) Excellent
  X) Goad
  1) Bxeallant
  2)
1*2) Craundwatar walla

1*2) sail conditions
1»2) 2 yaara
Saurcai  SCS Sagiaaara

    •  Buffing diiat'eeneaiaa aaavy
                                   lai fiaiahiag
         la.
                                             156

-------
 facilities utilized nationwide are based upon information
 obtained for solid waste from complete chrome tanneries
 (excluding wastewater sludges).   Thus, on a national basis,
 35 percent of the potentially hazardous waste generated
 by finishers is  currently (1974)  disposed in municipal
 landfills, 40 percent in municipal dumps and 25 percent
 in private landfills.
      Level III technology calls  for finishing residues to
 be disposed in certified hazardous waste disposal facilities.
 This is because these sites  are  more likely able to handle
 the potential fire hazard from the residues which make up
 a larger proportion of a leather finisher's waste than that
 of any other tannery category.   However, if there are no
 certified hazardous waste disposal facilities in the area,
 landfills with leachate collection could be used for
 disposal as long as the finishing  residues are mixed in with
 other waste so as to prevent flammability hazards.
       •
  4.10  Treatment and Disposal;   Beamhouse/Tanhouse Facility

      The potentially hazardous waste which is generated
 by the beamhouse/tanhousefacility  is:

                                   Generation      Nat'l.  total
                 Potentially        rate (wet/dry   (wet/dry
                 hazardous          kg per 1000    metric  tons
 Wastestream     constituents       eg.  hides)       per year)

 Wastewater
  sludge          Cr,  Cu, Pb,  Zn      8,500/2,500    18,000/5,300

      Treatment and disposal technology levels for beamhouse/
 tanhouse  facilities  are summarized  in  Table  48.

      4.10.1  Treatment.  Wastewater  treatment sludges are
 normally  treated prior to disposal.  The only type  of
 treatment  utilized is dewatering, and  this is accomplished
 on-site by non-mechanical  (sequential  settling) or
 mechanical  (filter press, vacuum filter or centrifuge)
 means.  Two beamhouse/tanhouse facilities which treat their
 wastewater pretreatment sludge were visited.   One used the
 sequential settling and one used a filter press.  In  order
 to reduce hauling and disposal charges by further reducing
 the moisture content of the sludge, the plant  currently
 employing the sequential settling method of sludge dewatering
 is in the process of installing a filter press.  Both
plants indicated their preference for the use of filter
presses for sludge dewatering because they are reliable and
effective  (yielding a 40 percent solids filter cake).
                            157

-------
                                     TABLE  48
                             ***
         of Iteafeat  )l,0«»f«a*l/S.tMM*y»

   rhyaical and CbaaUal »co*artiMii MttdoM M^ at 'to
     heavy «ofcala (ffV.ttl
                        '§•* fM* llt*«>
   Type* of «••«••

                       in of C-«iM
fill    i« »tf
Salt*'
    Citmnt

   • -% o(
           Of
   - • of
      Tanhovs*
   !>isk
                         M

                          a
         Of BiplOMt

   • TraiMportotiM

   - POtlutiOA •'
•a
MI
                          rat*
   ruturo Adoquaey
                        toir
   tlaltatiinc and
                       imea* potlwtioa
                  •ail
                                             Ia*taUo«
                                                    «iay*M in off-
                                                    •it* landfill
                                                    •itk l«aehata
                                              0


                                             •a
                                                        Ml

                                                          ll«0t
                                                                               OTlU
                                                       years
    TiM
Soureei   SCS Bnginoora
                                             158

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     4.10.2  Disposal.  One private disposal site which
accepts wastewater pretreatment sludge from a beamhouse/
tanhouse facility was visited.  The site is state certified
to accept tannery waste.  At this disposal site, the
sludge is placed in clay-lined trenches  (Level II technology)
The bottom of the trenches are sloped to allow excess water
from the deposited sludge to drain to the low end.  As this
liquid accumulates, it is pumped out of the trench into an
adjacent evaporative lagoon.  When the trenches become
approximately one-half filled with sludge, they are
completely covered and sealed with the clay soil which was
originally excavated.  The site has only recently been
put into operation and the first sludge trenches constructed
are still being filled.  The site operators indicated that
they have not encountered any particular problems with
operation of the site.
     On a national basis, it is estimated that 40 percent
of the potentially hazardous waste generated by beamhouse/
tanhouse facilities is disposed in facilities utilizing
trenches or lagoons and that 60 percent is disposed in
off-site landfills.  It is known that by 1983 at least
one new beamhouse/tanhouse facility probably will be
operating with on-site evaporative lagoons.

       4.11  Treatment and Disposal;  Retan/Finishers

     The six types of potentially hazardous waste generated
by retan/finishers is summarized below:
Wastestream

Trimmings 6
 shavings
Unfinished
 leather trim
Buffing dust
Finished
 leather trim
Finishing
 residues
Screenings
Potentially
hazardous
constituents
   Cr

Cr, Cu, Pb
Cr, Pb

Cr, Pb, Zn

Cr, Pb, Zn
 & organic
 solvents
Cr, Pb
Generation
rates (wet/dry
kg per 1000
eg. hides)
 1,300/540

   110/100
    27/25

   220/200

   150/45


    40/10
     Treatment and disposal technology levels for
finishers are summarized in Table 49 .
Nat'l. total
(wet/dry
metric tons
per year)
2,600/1,100

  240/210
   60/50

  460/420

  310/90


   80/20

retan/
                             159

-------
                                            TABLE  49
                                       vn
                                          AMD DISPOSAL TBCHSOLOCT LEVELS
                                           FOR MTAN/PXNI8HRRS
Anouat of ttastoi  4.SOO(«ot)/2.300fdry) a*trio tons por yoar

Physical and Choaical Properties!   Planaablo. sail-solid oad solid with tonic heavy metal• (Pb,Sn,Cu,Cr)

                                                                             	Level 111	
   Typos of Mastos
    tavoi I

    All typos



Off-sito landfill
•  Istinato of Cotrott
    Usa
-------
     None of the above waste types are treated prior to
disposal.  All of the waste is normally combined for disposal
purposes either during collection, hauling to the disposal
site, or in the disposal operation.  Four disposal sites
receiving potentially hazardous waste generated by retan/
finishers were visited, of which two were municipal dumps
and two were municipal landfills.
     Operations at one municipal dump have been altered
because of the acceptance of tannery waste.  Until
recently, the tannery waste was mixed with municipal refuse.
When this mixture burned, (reportedly a frequent occurrence)
citizens complained about the obnoxious odor.  To alleviate
this problem, the tannery now disposes its waste (primarily
blue trimmings and shavings) in a separate area of the dump.
Weekly, a crawler dozer spreads the waste and covers it
with imported cover material.  This procedure prevents the
trimmings and shavings from burning.
     It is estimated that on a national basis 35 percent
of the potentially hazardous waste generated by retan/finishers
is disposed at municipal landfills; 20 percent is disposed
at private landfills; 15 percent is disposed at on-site
facilities; and 30 percent is disposed at municipal dumps.

          4.12  Treatment and Disposal Technologies
                 and Waste Quantity Summary

     The treatment and disposal technologies and the current
(1974) distribution of waste between the three levels
of technology are summarized in Table 50 .  As shown,
landfilling is the most common Level I and Level IX disposal
technology.  For all categories of tanneries, a landfill
with leachate collection provides adequate environmental
protection (Level III).  Other acceptable Level III disposal
technologies include landfills and lined trenches certified
for hazardous waste disposal.
     Wastewater pretreatment/treatment sludge is the only
type of potentially hazardous waste which requires treatment
prior to disposal.  Dewatering of the sludge prior to disposal
is the only type of treatment required.  Sludge dewatering
is common at large tanneries which treat their wastewater,
and is included in all levels of technology for complete
chrome tanneries and beamhouse/tanhouse facilities which
generate sludge.
     Comparison of the quantity of waste going to Level III
with the total quantity of potentially hazardous waste
generated reveals that only 6 percent is going to Level III.
Similarly, 12 percent is going to Level II and 87 percent
is going to Level I.  Note that the sum of Level I, II, and
III percentages is greater than 100 due to overlaps between
the various levels, as shown in Table 50 .

                             161

-------
                                           TABLE 50
                                           —•*•----=—— -—
                                           n MtfMtt ti
                                         Mf«nUM BMMOOM
MO 0im9Kt nemetoov tcmi MB
9k
M

-------
     As shown  approximately 34 percent of the total quantity
of potentially hazardous waste generated by the tanning
industry comes from complete chrome tanneries and goes to
Level I (landfills).  Similarly, 7 percent of the waste
comes from split tanneries and goes to Level I (dumps)
and 8 percent comes from beamhouse/tanhouse facilities and
goes to Level I (landfills).
     Since about 34,000 metric tons (wet weight) of sludge
from complete chrome tanneries and 12,600 metric tons
(wet weight) of sludge from beamhouse/tanhouse facilities
goes to Level I disposal (landfills), 57 percent of the
waste going to Level I treatment and disposal technology
is wastewater treatment sludge.  Similarly, 44 percent of
the waste (wet weight basis) going to Level XX and 95 percent
of the waste going to Level XIX is wastewater treatment
sludge.
                            163

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                         SECTION  5.0

                        COST ANALYSIS
      In this section, the costs associated with the three
levels of potentially hazardous waste treatment and
disposal technology in the leather tanning industry are
developed.  The cost information in this section  is
primarily based on data collected during interviews with
tannery representatives.  As necessary, additional
information is included from equipment suppliers, published
literature, and government sources.  Wherever possible, the
cost  data presented is from actual installations, and from
prices quoted by tannery solid waste disposal contractors.
      The general assumptions and bases for the cost
analyses are presented in Section 5.1.  The costs associated
with  on-site treatment of potentially hazardous waste are
presented in Section 5.2, and the costs associated with
contractor hauling and disposal are presented in Section
5.3.  The costs of the various levels of treatment and
disposal technology for typical plants from each of the six
categories of tanneries generating potentially hazardous
waste and for the industry as a whole are presented in
Section 5.4, and the variables which effect these costs
are discussed in Section 5.5.  An example of the cost
calculation methodology utilized to develop the treatment
and disposal costs for the typical plants is presented in
Section 5.6.

         5.1  Bases and Criteria for Cost Estimation

      The basic information utilized to develop the cost
estimates presented in Section 5.4 is shown in Table 51
and discussed in the following paragraphs.

      5.1.1  Capital Costs.  As used in this analysis,
capital costs include all expenditures associated with the
development and installation of treatment and disposal
facilities.  These costs include engineering consulting
services, equipment purchase and installation, electrical
and plumbing connections, buildings, start-up costs, and
land costs where applicable.   Capital costs known for
specific plants were factored to account for capacity
differences and averaged to develop the costs for the
typical plants.

      5.1.2  Interest Costs.   It has been assumed that private
debt financing is used for treatment and disposal facility
investment.  In addition, the cost of capital has been
assumed to be equal to 10 percent annual rate of interest on
investment.
                                   Preceding pan blank
                             165

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                     TABLE  51


             BASES AND CRITERIA FOR COST ESTIMATION
 Cost of
 Capital      -  10 percent annual interest

 Time Index   -  December 1973 dollars

 Depreciation -  Straight line over useful service life of
                  equipment

 Estimated Equipment Lifei

      ..  mobile    — 5 years
      .  stationary—10 years

 Land Value   -  $50,000/ba (S20,000/ac>

 Operating Costs>

      Labor (including 33% fringe benefits) - $4.80 per hoar
      Supervision (assumed) • 10 percent  of labor
      Maintenance » average of costs reported by applicable
       tanneries visited
      Materials • average of costs
      Insurance and Taxes * 2 percent of  capital
      Electrical Power « $0.02 per
      Contract Services » average of costs reported by
       applicable tanneries visited'
Sourcei  SCS Engineers
                            166

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      5.1.3   Time  Index  for Costs.   All cost estimates have
 been adjusted to  December 1973  dollars, using the Chemical
 Engineering (CE)  Plant  Cost Index.

      5.1.4   Useful Service Life.   The useful aervlce life
 of treatment and  disposal erjii iiwuMit v.-iricN ttoptJiulltuj UIH-W
 factors such as usage pattern and  maintenance schedule.
 Based upon  information obtained from private industry
 sources,  the following generalizations have been made
 with regard to the service life of treatment and disposal
 equipment used in the leather tanning industry:

        Lagoons—20 years.
      .  Mobile equipment—5 years.
        Stationary equipment—10 years.

      5.1.5   Depreciation.   For  the  purposes of this cost
 analysis, it has  been assumed that  the salvage or recovery
 value of  treatment and  disposal equipment is zero at the
 end  of  its  useful service life.  In order to annualize the
 capital costs incurred  by tanneries as a result of treatment
 and  disposal equipment, straight line depreciation has been
 utilized  over the useful  life of the service equipment.

      5.1.6   Operating Expenses.  The annual costs associated
 with operating the treatment and disposal facilities include
 labor,  supervision, maintenance, taxes, insurance, materials,
 and  energy.   For  purposes of clarity,  costs associated
 with energy consumption are itemized separately from other
 operating expenses, as  are  maintenance costs.   No interest
 costs for operating capital  are  included in the operating
 expenses.

                5.2   On-Site Waste  Treatment

      Sludges resulting  from primary and/or secondary
 treatment of wastewater at  beamhouse/tanhouse  facilities
 and  some  complete  chrome  tanneries  are the only type of
 potentially  hazardous waste which receive treatment prior
 to disposal.  All  sludge  treatment  is  performed on-site,
 except  for tanneries discharging to municipal  wastewater
 treatment facilities, and consists  of  non-mechanical
 (sequential  settling) or mechanical dewatering systems.
 Since only one  tannery was  identified  which utilizes a
 non-mechanical  sludge dewatering system and this tannery
 is currently in the process  of replacing it with a filter
 press, only mechanical systems are  considered  in these
 cost estimates.
     Filter presses, centrifuges, and  vacuum filters are all
 used in a variety of situations for dewatering tannery
wastewater treatment sludges.  As a result,  the cost information

                             167

-------
presented in Tables 54 and 58 for the typical complete
chrome tannery (with wastewater pretreatment) and the
beamhouse/tanhouse facility, respectively, is the average
of the costs associated with two filter press, one
centrifuge, and one vacuum filter systems.  This cost
information was collected during visits to four tanneries
utilizing these systems.

                   5.3  Off-Site Disposal

     The typical plants from all six categories of tanneries
which generate potentially hazardous waste hire contractors
to haul and dispose their waste off-site.  Although a few
tanneries with wastewater treatment systems dispose
potentially hazardous waste on-site and other tanneries
haul their own waste, these practices are atypical for
all categories in the tanning industry.
     The costs of contractor hauling and disposal of the
potentially hazardous waste are based on information
obtained from tanneries.  Tannery quoted unit costs, which
are presented in Table 52 , range from $2 per metric ton
for disposal in an open dump to $10 per metric ton for
disposal (from a large complete chrome tannery) in a
state certified hazardous waste disposal site to $31 per
metric ton for disposal (from a small finisher) in a
landfill.  The range in disposal costs are due to a variety
of factors, including, distance from the disposal site,
regional location, and the volume of waste generated by
a particular tannery.  Adjusted costs are indicated in
Table 52 to:

        Provide data where no tannery quoted costs were
        available.
     .  Take into account diseconomies due to small
        volumes .
        Account for unusual quoted unit costs.
     .  Account for leachate collection at landfills.

     Total costs are the overall hauling and disposal costs
for each type of waste and are the figures used in
subsequent cost estimates.   Both tannery-quoted and
adjusted costs for dewatered sludge are shown and the total
cost is the same as the adjusted cost.  This is due to
abnormally low tannery-quoted costs.

              5.4  Treatment and Disposal Costs

     A summary of the cost estimates for three levels of
treatment and disposal technology for a typical plant in
the six categories of tanneries which generate potentially

                             168

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                                TABLE  52


                                        AMD DISPOSAL COJJTS

typical tannery
Solids
Coapleto chnsse tannery
w/o sludge
Sheepskin tannery

Split tannery




Leather finisher



•etan/fiaisher





Bowaterod Sludoo
Conpleta chrome tannery
with oludgo
•
facility
r
Diipo»l aetnad

Landfill
Landfill with loachato collection
Landfill
Landfill with loachato collection
Dunp (including tr innings and
Landfill with loachato collection
• including trineinga and
shavings
- without triBBiags and shavings
Landfill
Landfill with teachato collection
Certified hazardous waste disposal
facility
Landfill (including trlnaings and
shavings)
Landfill (without trioadngs and
•having*)
Landfill with loachato collection
- including trisnings and shavings
- without trissUnga and shavings
Landfill
Landfill with loachato collection
•Certified hasardous waste disposal
facility
Lined trenches
*r. 19f>
(Wl
OjUMOj
costs

IVI*I



,«bl




ai««>










•«'

Mc.»
,(f)
d^lljrn por
tt wi.iht l-.ii
Adjust^
cost a


I*
ao
a4



M
ad

M

«4

M

M

14
a4
10
14
»•
la
tM>trie ton
nis)
1 Total
costs

10
14
ao
>4
a


14
a4

19

44

10

ao

14
34
10
14
14
ia
    CCS Engineer*

(a)  Average of 11 tanneries.
(M  Average of two aplit tannerios and ono complete
(e>  Average of two finishers.
    Average of throe complete chrone tanneries.
lol
conplote chrone
         ono boaadwuso/tanhouso
tannery.
ise facility.
                                          169

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hazardous waste is presented in Tables 53 through 59  .
The cost items shown in these tables include land,  total
capital investment, annual capital cost, operation,
maintenance, energy and power,, contract services, total
annual cost, and total treatment"and disposal cost  per
unit of product and of potentialJy, hazardous waste.
     At the recommendation of the Tanners' Council  of
America, the median tannery  (with respect to production)
was, .chosen ~as= .the typical plant for each category.-  Since
the .production of -the largest plant in a category is
over-1001time* tha't of a small plant, the median is chosen
as thevbest>estimate of a typical operation.
     All typical plants are located In urban areas,.
preorcrainantly^                           Regions I,  II,
III,  IV) and utilize contract services for solid' waste
haul|ng and disposal-;  All of the typical plants are  50
years* old with the exception of the beamhouse/tanhouse
facility which is 15 years old.-
     As shown, the total annual, cost- for Level  I and  LeveL
III is the same for "a typical complete chrome tannery without
primary and/or secondary was^ewavter:>treatment.  Although
the cost per;metric ton of waste is higher for  Level  III,
due to higher costs for disposal in a landfill  with leachate
collection, phe total cost,is the same: siiice Level  III
assumes that trimmings and*" shavings': are "So" Id 'as a by-product*
whereas Level' I calls for landfilling of this waste.
     For a complete chrome tannery1 with primary and/or
secondary waertewater treatment,•* the* total- fixed cost  is
due entirely':to sludge dewatering... Sltidgcl,:dewatering
accounts for approximate!^--90 percent: of^idhe increase in the
total*; annual^cost for complete chrome1 tanneries with"
primary and/pr secondary wastewater treatment relative to •
complete chrome tanneries" without waXtetfatelr.'1 treatment
facilities. a,ffhe other 10 percent of the- increase in  costs
is the result of sludge disposal charges.
     •In the sheepskin tannery category, thV cost of Level
III technology is slightly higher than Levels I and.IX due
to €S^1c&ffir^n€ tttt leiacti&e'coi't&tion be  provided
in Level III disposal technology.  The cost per ton of waste
disposed for all .three level-s, iSt-approximately  twice  that-.
for complete chrome tannery without primary^ ahd^br  secondary
wastewater treatment.  This variation'-in cost per-tew arises
because substantially different <^ah£iVies ovf' waste are
generated by these two types of tanneries.
     Two different Level III treatment and disposal
technologies are shown for split tanneries, one of  which is
substantially more expensive than Level I and one which is
slightly less expensive.  The cost shown for Level  I  is based
on open dumping of all the potentially hazardous waste
generated.  The more expensive Level III technology
(Alternative 1) is based on disposal of the same quantity

                             170

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                    TABLE  53
                 TREATMENT MID DISPOSAL COSTS
                TYPICAL CXJMPLfcTK CHROME TANNKRY
    Iwithout primary and/or secondary wastewater t
Typical Plant
Characteristics
Annual Production
	(1974)

260.000 equivalent
. hides/year
Urban.
gion I
                                                        factoring
          tanning
V  ft leather
   finishing
                     Potentially
Identification of    Hasardous
Mastestream(s)       Constituent*

Trimmings t shavings     Or
Unfinished leather
 trtimings            Cr.Pb
Buffing dust          Cr.Pb
Finished leather
 trim                 Cr.Pb
Finishing residues    Cr.Pb,In
mastewater
      iiings           Cr.Pb
           sludge     Cr.Pb.Cu
                      Physical
                      •olid

                      •olid
                      •olid

                      •olid
                      •olid
                      Liquid
                                         for
                                      itmont/Dis-
                                      1 (Met/dry
                                         1000
             1.240/S40

               114/100
                If/at

               XIO/IOO
               ISO/45

               3M/M
             2.TOO/300
treatment/Disposal
  Costs/Levels

Annual contract haul-
  ing t disposal
  charges
Average treatment i
  disposal cost
• per unit of
   production
    ($/1000 hides)
• per metric ton
   of waste*
                                    Dollars  (Deo. 1*731
       13.000




           4«

           10
10,
    11.
     30
                   14
 Description of Treatment/Disposal Technology i

  Level  I    Off-site  landfill

  Level  II   Trimmings and shavings  soldi other waste  to off-site
              landfill

  Level  III  Trimmings and shavings  soldi other waste  t* off-site
              landfill with  leaehate collection


 Sourcei  SCS  Engineers

      • On a wet weight basis.
                              171

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                     TABLE 54
                TYPICAL COMPLETE
     (with primary aad/or secondary <
                          Production
                         11074i
Typical Plant
Characteristic*
                   140.000 equivalent
                    bides/year
                                          I or V  • leather
                                                  •touting
                                                          for
     ification of
       Tcantsl
                   Potentially

                       bttuenta'
Trinnings * shavings   Cr
Unfinished leather
 trimmings          Cr.Pb
Buffing dust        Cr.Pb
rinishsd leather
 trim               Cr.Pb
Finishing residues  Cr.Pb.Sn
H«T»0f£dJ4jdJ|f^f}o>
      •ings         Cr.Pb
           sludge   Cr,Pb.Cu
                                                   1, MO/MO

                                                     IM/100
                                      •olid
                                      •olM
                                                    SM/MO
                                                    aso/«s

                                                    JM/M
                                                 10.000/1.400
Ttsntnent/Pisposal
            Costs
   total Pined
      1 Costs
   Capital Coats
   -   atiog
           Services
  Total Annualiced

Average treatment •
 disposal cent
- par unit of
   protection
   . 19/1000 hides)
- per metric ton
   of waste*
                       00.400
                       10.000
                        S.OOO
                        1.400
                       31.400
                      119.155
                          4S1

                           ST
            00.400       00.400
 10.OOO     10.000       10.000
  •ttOOO      ft •> 000        VdjOOO
  1.400      1.400        1.400
 4S.SOO     4S.100      _>Mgf
nniaY    Dims      UI.MI
peacriptioa of Treat

 Level I    Off-site landfill

 level II   Triasiings and shavings soldi other mttaa linoYMding
             detMtcred •ludgnl to off-site certified hasardbos
             waste disposal facility
 level III  Alt. It Sane as Level II
            Alt. li Tristtings and shavings kOld as a by-productt
             other Mastos to off«site landfill with' leacbate
             collection
 Sourcei   SCS  Rnginoers

      • On a wet weight basis.
                              172

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                      TABLE 55
                  RBATMENT AND DISPOSAL COSTS
                   TYPICAL SHEEPSKIN TAHNBRV
Typical Plant
Characteristics
Annual Production
      (1974)

200.000 equivalent
 hides/year
                                        Location
                                                    Manufacturing
 Urban, Re*   Sheepskin
 gion I or II  tanning
Identification off
•astestreaasU)

Chrome fleshings
Unfinished leather
 trissiings
tuffing dust
Mastewater
      lings
treatment/Disposal
  Costs/Levels
Annual contract haul-
 ing * disposal
 charges               6.700
Average treatment ft
 disposal cost
• per unit of
   production
   It/1000 hides)         34
- per metric ton
   of waste*              20
                                                        nt for
                                                    Treatswnt/Dis-
                                                    posal (wet/dry
Hasardous
Constituents
Cr
Cr.Cu.Pb
Cr.Pb.Cu.Zn
Cr.cu
Level I
Physical
Pom
Slurry
Solid
Solid
Solid
Dollars IDec.
bevel ii
kg per 1000
hides)
1,200/300
170/140
S4VSO
2)0/50
1>7J)
Level HI
•.700




   94

   29
                                  t.100




                                     40

                                     14
     ription of Treatment/Disposal Technologyi

 Level I    Off-site landfill

 Level II   Off-site landfill

 Level III  Off-site landfill with leachate collection
 Sourcet.  SC8 Engineers

      • On a wet weight basis.
                                173

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                       TABLE 56
                     TYPICAL SPLIT
      II Plant
        risties
  Production
 g«74)
                                        Location
                                                              ing
400.000 equivalent   Urban. Be-
 hides/year          ffion X
                            ••tanning cattle
                             hid*  splits
Sdiantification of
Mastestreaats)
  ially
  mis
tituents
                    Physical
YriBBihgs, splits
.• shavings
Unfinished leather
. trinnings
Buffing dust
 screenings
f& jatstent/Diaposal
 .. Cbsts/tevels
     il contract haul-
 ing • disposal
        treataent «
 disposal cost
- per unit of
   production
   (1/1000 hides)
- per Metric ton
   of waste*
                     7.
                            0.200/1.700
Cr.Pb
Cr.Pb
Cr.Pb
•olid
•olid
Dollars -CDi
aio/aoo
aoo/ioo
aa/s
M. 19111
                                  JLii
             1,000      40,000      4,100
17

 a
                      9

                     ao
m

 14
11

24
     ietion of
 Level X    Off-site dumping
 level XX   TrisBlngs 'and 'shavings sold as •
             watts off-site landfill

     1 XXX  Alt. li Off-site landfill with leachate collection
            Alt. at TrinaUngs and ahavings sold as a by-product}
             other wastes to off-site landfill with leachate
             collection
Sources  SC8 Bngineera

     • On a wet weight basis.
                               174

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                       TABLE  57
                 TREATMENT AND DISPOSAL COSTS
                   TYPICAL LEATHER FINISHER
Typical Plant
Characteristics
                   Annual Production
                         (19741
225,000 equivalent
 hides/year
                     Location
             Manufacturing
                Process
Urban, Re-   Leather
gion X or XI  finishing
                                                    Mount for
                                                    Treatmnt/Dis-
Xdentification of
Mastestream(s)

Buffing dust
Finishing residues
Treatment/Disposal
  Coats/Levels

Annual contract haul-
 ing & disposal
 charges
Average treatment 4
 disposal cost
- per unit of
   production
   ($/1000 hides)
- per metric ton
   of waste*
Potentially
Hazardous
Constituents
Cr.Pb
Cr,Zn,Pb
Level I
Physical
Pom
Solid
Liquid
Dollars (Dee.
Level II
posal (wet/dry
kg per 1000
hides)
11/10
1SO/SS
1973)
Level III
                     1.100
                  1,100
             1,SOO
                         4.90

                        31
                      4.90

                     31
                 €.60

                41
Description of Treatment/Disposal Technology!

 Level I    Off-site landfill

 Level XX   Off-site landfill

 Level XXX  Off-site certified hazardous waste disposal facility



Sourcei  SCS Engineers

     •  On a wet weight basis.
                                 175

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                        TAPL«!  58
                  TREATMENT AND DISPOSAL COSTS
              TYPICAL BEAMHOUSE/TANHOUSB FACILITY
                    Annual  Production
                          (1974)
                    .Location
               Manufacturing
                  Process	
Typical  Plant
Characteristics
300,000 equivalent--Mid-'or South- Cattlehide
 hides/year         western city    chrome
                                    tanning
Identification  of
WastestreamCs)
 Potentially
 Hazardous.
 Constituents-
  Physical
  '  Form
   Amount for
   Treatment/Dis-
   posal (yet/dry
   kg per 1000
      hides)
Nastewater  sludge  Cr.Pb
                    Sludge cake  10.000/2.400
Treatment/Di sposa 1
•j -Cbsta/LevelS
   Of' „/ * "A-* V " '
InvestmenttiCosts
      ~~
                    Mrs (Dec. 1973)
  Other Vf
  Total .Fixed

Annual Costs
  Capital Coats
  Operating- • '- -•
  Maintenance
  Energy
  Contract  Services
  Total AnriUaJUized

Average treatment ft
 disposal cost
- per unit  of
   production
   ($/1000  hides)
- per metric ton
   of waste*
Level I
4.000
300 ; OOP
3O4;OOO
•i 'Level 'II-
4.0.00
300. 000 *
304 ,-000
Level
Alt. 1
TTTOp
300.000
304', 000
III
Alt. '2
.4.000
300.000
304,000
   60., 400
   18,000
    5.000
    2,400
   30.000
  115,400
      390

       38
 60,400
 18,000
  5.000
  2.400
 36.000
121/800
    406

     41
60.400 '
18.000'-
 5.000.
 2..4190 :
36.000
   406.

    41
 60,400
 18$000
  5,000
  2,.400
 42.000
127,800
    426

     43
Description of Treatment/Disposal Technology!
                                       .T.i ,.?•.. '
 Level I    Dewater and disposal in off-site landfill*
                                       .'   L .  *s i.     —
 Level II   Dewater and dispose in off-site  lined,trenches. ,
   «3iKa-? •_,j-»a<.,i: •„«..• ?-i-I     ,•,-'•-•      • -       •
 Level III  Alt. 1: Dewater and dispose in off-site  lined trenches
            Alt. 2: pewater_Jand_di8pose.in..o£fr8ite  landf-ill with.r.
            "leachate collection        "
Source:  SCS Engineers

              • wet weight basis.

                               176

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                       TABLE  59


                 TREATMENT AND DISPOSAL COSTS
                   TYPICAL RETAN/FINISHER
Typical Plant
Characteristics
Annual Production
(1974)
675,000 equivalent
hides/year
Local ion
Region I
or XX
Manufacturing
Process
Leather re-
tanning *
finishing
                                                    Amount for
                                                    Treatment/Dis-
Zdentification of
Hastestrearn(a >

Trimmings t
 shavings
Unfinished leather
 trim
Buffing dust
Finished leather
 trim
Finishing
 i _>sidues
Mastewater
 screenings

Treatment/Disposal
  Costs/Levels
Annual contract haul-
 ing t disposal
 charges             12.000
Average treatment t
 disposal cost
- per unit of
   production
   (S/1000 hides)        18
• per metric ton
   of waste*             10
Potentially
Hazardous
Constituents
Cr
Cr,Pb
Cr,Pb
Cr,Pb
Cr,Pb,Zn
Cr,Pb

Level Z
Physical
Form
Solid
Solid
Solid
Solid
Liquid
Solid
Dollars (Dec
Level II
posal (wet /dry
kg per 1000
hides)
1,260/540
114/100
27/25
220/200
150/45
40/10
. 1973)
Level III
Alt. 1 Alt. ;
8,000




   12

   20
17.000




    25

    14
9,000




   13

   24
Description of Treatment/Disposal Technology!

 Level I    Off-site landfill

 Level XZ   Trimmings and shavings soldi other waste  to off-site
             landfill

 Level ZXX  Alt.  1:  Off-site landfill with leachate collection
            Alt.  2:  Trimmings and shavings sold as a by-product;
             other waste  to off-site landfill with leachate
             collection
Sourcei  SCS Engineers

     * On a wet weight basis.
                               177

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of waste in a landfill with leachate dellection, which will
cost $12 per metric ton more than open dumping.  The less
expensive Level III (Alternative 2) costs are based on the
sale of trimmings and shavings arid the disposal of other
potentially hazardous waste.  The large difference in the
total cost of these two alternatives arises because blue
trim and shavings represent 90 percent of the waste generated
by a typical split tannery.  The cost per ton of waste
actually disposed via Alternative 2 is increased due to the
substantially reduced quantity of waste which must be collected
and disposed.
     A typical leather finisher generates less solid waste
than any other category in the industry.  Consequently, the
annual contract hauling of the disposal costs for all three
levels of technology are less than for any other category.
However, the cost per metric ton is higher than for
most other categories due to the small volumes of waste
which must be collected and disposed.
     Since wastewater treatment sludge is the only potentially
hazardous waste generated by a typical beamhouse/tanhouse
facility, all costs shown are the result of sludge treatment
and disposal.  The cost of treatment and disposal for the
most expensive Level III (Alternative 2) is only about 10
percent higher than for Level I.  However, since about 90
percent of the total annual cost is the result of sludge
treatment, 'which is the same for all levels of technology,
the percentage increase in total cost to go from Level I
to Level III technology is not very substantial.
     A typical retan/finisher generates the same types of
waste in approximately the same quantity as a complete chrome
tannery without primary and/or secondary wastewater
treatment, except that the complete chrome tannery generates
sewer sump sludge.  The cost per metric ton for Level II
technology for a typical retan/finisher is twice that for
Level I because the total quantity of potentially hazardous
waste being land disposed in Level II is only approximately
30 percent of that in Level I (due to sale of trimmings and
shavings as part of Level II technology).  The more expensive
Level III technology (Alternative 1) reflects disposal of
all potentially hazardous waste, whereas the less expensive
Alternative 2 is based on the sale of trimmings and shavings
as a by-product and disposal of other waste.
     To obtain the total cost of each level of treatment
and disposal technology for each category of the tanning
industry, the following equation was used:

Annual cost of     Total annual category      Annual cost of
technology level =      production          x technology level
for category       Typical plant production   for typical plant

                             178

-------
     Using this relationship, Table 60  was developed to
summarize the total costs of treatment and disposal for
each category of tannery and illustrates the differences
in costs discussed above.  For complete chrome tanneries
with primary and/or secondary treatment sludge, approximately
90 percent of the total annual treatment and disposal costs
are the result of wastewater treatment sludge.  For beamhouse/
tanhouse facilities, 100 percent of the treatment and
disposal costs are the result of wastewater treatment
sludge.  As a result, approximately 65 percent of the cost
of treatment and disposal for the total industry for all
three technology levels is a result of wastewater sludge
dewatering and disposal.
     For complete chrome tanneries without primary and/or
secondary wastewater treatment sludge, the total annual
treatment and disposal costs for all levels of technology
are substantially higher than for other categories such as
sheepskin, split tanneries, retan/finishers and leather
finishers.  This occurs since chrome tanneries produce more
leather and generate more potentially hazardous waste than
the other categories mentioned.
     Another important factor effecting the cost of
treatment and disposal technology for the total industry is
the ability of complete chrome tanneries (without primary
sludge), retan/finishers, and split tanneries to sell blue
trim and shavings as a by-product.  For these three
categories of tanneries, the cost of treatment and disposal
is less for Level II (with sale) than Level I  (without
sale), with the result that the total cost to the industry
of Level I technology is virtually the same as for Level II.
Similarly, the difference in cost between the most and least
expensive Level III technology is primarily a function of
whether blue trim and shavings are sold or land disposed.
     Using the distribution of production between the
various categories observed in 1974, the value added in
manufacturing (in December 1973 dollars) during 1974 was
$480 million, and total value of shipments was $1,010
million.  Thus, the costs of the three levels of treatment
and disposal technology compared to the value added in
manufacturing and the value of shipments are as follows:

                      Treatment and      Treatment and
                      disposal cost—    disposal cost--
                      percent of value   percent of value
Technology level      added	   of shipments

I                           0.67              0.32
II                          0.68              0.32
III (least costly
     alternatives)           0.70              0.33
III (most costly
     alternatives)           0.81              0.38

                             179

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                          TABLE 60

             ANNUAL TREATMENT AND DISPOSAL COSTS
                     (Dec. 1973 dollars)
Tannery
Category
Chrome w/
sludge
Chrome w/o
sludge
Sheepskin
Split
Leather
finisher
Beamhouse/
Tanhouse
Facility
Retan/
Finisher
Total
Level I
1, 524 f 000
675,000
84,000
60,000
27,000
812,000
37,000
3,219,000
Level II
1,702,000
519,000
84,000
31,000
27,000
854,000
25,000
3,242,000
Level
Least costly
1,629,000
675,000
101,000
37,000
37,000
854,000
28,000
3,361,000
III
Most costly
1,702,000
675,000
101,000
411,000
37,000
896,000
53,000
3,875,000
Source:  SCS Engineers
                             180

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     5.5  Variables Effecting Treatment and Disposal Costs

      5.5.1  Size.   The economies of scale in tanneries are
 somewhat limited by the batch process nature of the tanning
 operation, thus plants in the tanning industry vary widely
 in size from a few thousand equivalent hides per year to
 nearly one-half million.   This range in production yields
 a corresponding range in the quantities of potentially
 hazardous waste generated per 1000 equivalent hides.  This,
 in turn, results in great variations in waste disposal
 costs.   For example,  a small tannery with regular, contracted
 hauling spends much more per metric ton of waste than does
 a large tannery (the waste is collected under contract
 hauling whether or not the container is full).   Cost for a
 retan/finisher and a leather finisher reveals the cost of
 solid waste disposal per  metric ton of waste may be three
 times  greater for  plants  producing relatively small
 quantities of waste than  for those producing more typical
 quantities.   These quantity-related differences were taken
 into account (to the extent possible)  in developing the
 adjusted costs shown earlier in Table 52 .

      5.5.2  Processing Operations.   Processing  operations
 also vary greatly  from plant to plant within any category
 of the  tanning industry.   These variations  depend to a
 large extent upon  the  type of market to which a given
 tannery is trying  to make its product appear; i.e.,  a
 tannery may intentionally generate  more waste than normally
 expected in  pursuit of the production of high quality
 products.   No generalizations with  respect  to the effects
 of these variations on treatment and disposal costs  are
 possible.

      5.5.3   Location.   Geographic location  of tanneries
 affects  treatment  and  disposal  costs in the sense that costs
 are higher  for those tanneries  located  in urban areas than
 for those  located  in more  rural  settings.   In addition,
 tanneries  in  certain areas  are  able  to  dispose  their waste in
 municipal  facilities where  the  cost  of  operating the
 disposal  facilities is  included  in their taxes.   In  rural
 settings, the  cost of  treatment  and  disposal  is  estimated
 to  be approximately $3 per metric ton less  than  for  a
 typical plant.  The adjustments made  in Table 52 attempt
 to  account for  some of the variations that  are  found.
      If  there  are  no nearby certified hazardous  waste
 disposal  facilities or  landfills with leachate collection
 systems, a tannery would incur  long  distance hauling charges
 which would  increase their disposal  cost, or the tannery
 would have to establish its own disposal site, either on
 the plant property, or at a remote site.  Situations which
would require a tannery to haul its waste more than  50
miles to such a site are likely rare and have not been
 included in the cost estimates presented.

                            181

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      State and local  regulations governing potentially
 hazardous  waste disposal  impact on only a very few tanneries.
 Thus,  they do not  have  a  significant effect on treatment
 and disposal costs for the industry.

      5.5.4 Method of Dewatering Sludge.  The cost of
 treatment  and disposal  of sludges is primarily dependent
 upon  the type of dewatering system utilized, the
 effectiveness of the  primary clarification system, and the
 quantity of wastewater  treated.  Capital costs for sludge
 treatment  installations varies depending upon the type of
 system used and the equipment manufacturer.  Significant
 variations in operating  costs result from varying'chemical
 usage  which depends on  the type of dewatering system.  The
 cost of operating  different dewatering systems at four
 tanneries  varies from approximately $7,000 to $30,000 per
 year,  depending primarily upon the quantity and types of
 chemicals  used to  aid in  the dewatering process.  Processes
 associated with sludge  dewatering may also vary as a
 function of the effectiveness of the primary clarifier.
 No  information is  available, however, to quantify the effects
 that this might have  on the costs presented for the
 typical tanneries.

                 5.6   Sample Cost Calculation

     For illustrative purposes, the following computation
of the costs of  Levels  I, II, and III technology are
presented  for  a  complete  chrome tannery.

     5.6.1  Level I Technology;  sludge dewatering and off-
site landfill

     Capital costs.   (December 1973 dollars)
      Land requirements
       Disposal is off-site.   Treatment facilities require
        approximately 0.08 ha (0.2 ac)  of land.   It is
        assumed based on contractor experience that land
        costs are $50,000/ha ($20,000/ac).   Land costs are:

                  0.08 x $50,000 = $4,000

      Equipment and installation
       Wastes are hauled by a contractor,  thus dewatering
       equipment is the only equipment  to be considered.
       Interviews at four tanneries and contact with
       equipment suppliers indicated that the average
       price of an installed sludge dewatering unit
       (the costs of a filter press,  centrifuge and vacuum
       filter are all  taken into account)  is $300,000 for
       the  typical plant.

                             132

-------
  Interest costs, assumed at 10 percent of  the capital
  cost of $304,000 for the sludge dewatering system
  and the land, is $30,400/year.
  Using straight line depreciation for the  expected
  life of the equipment  (10 years for $300,000
  equipment), depreciation is $30,000/year.

Operating Costs
  Labor
  1 man, 20 hours per week, 50 weeks per year,
  operating dewatering equipment at $3.60/hr plus
  33 percent fringe benefits equals $4,800/year.
  Supervision = 10 percent of labor cost  (assumed) =
  $500
  Materials
  The cost of materials varies significantly from
  plant to plant ($2,000-$30,000) , depending on the
  volume of production and the type of dewatering
  equipment being utilized.  It is estimated, based
  on data collected for five tanneries, that the
  typical tannery spends $6,700 per year on materials
  (mostly chemicals) .
  Maintenance = $5,000 per year, based on tannery
  information
  Insurance and taxes = 2 percent of capital cost =
  $6,000
  Energy = 60 hp x 8 hr/day x 250 day/yr x  0.746 kW/hp x
  $0.02/kWh = $2,400
  Contract services (with disposal in an off-site landfill)
  = $10/metric ton (see Table 53 )  x 3,160 metric
  tons/year = $31,600/year

Total annual costs                   $ (1973) /year

  Capital costs                       $ 60,400
  Operating
   Labor                $4,800
   Supervision             480
   Materials             6,700
   Insurance and taxes   6,000          18,000
  Maintenance                            5,000
  Energy                                 2,400
  Contract services                     31,600
  Total annualized                    $117,400

Average Treatment and Disposal Costs

  per unit of production (1000 equivalent hides)

            $117,400/yr        =
  y
.  h
         260,000 eq. hides/yr

                       183

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       jper, .metric .ton. of-waste

                                   »  $37
               3,160 metric ton/yr

      5.6; 2  Level II technology t  trimmings' and shavings
                        '   »rtifi<
'sold , all other waste to certified hazardous waste disposal
facility.
     Land requirements, equipment* interest, operating,
maintenance,, and. energy costs are all the sane as for Level

     Contract .services - $16/metric ton  (see Table 52)
      x 2,834 metric tons/year - $45,300/vear
      Note that the sale of trimmings and shavings - reduces
      the quantity of waste.  Revenues from the sale of
      trimmings and shavings (approximately $0.0i/kg) are
      hot included in the calculations.

     Total ... annual . costs                  $(1973) /year

       Capital costs                      $ 60,400
       "Operating                            18,000
       Maintenance  .                         5,000
       Energy                                2,400
       Contract services                    ''45^300
       Total annuali&ed                   9131,100

     Average Treatment arid Disposal Costs

       per unit of ; production (1000 equivalent hide's)
       •  -j      ,

                  131.100/yr     .
            ___
            .260,000 eq. hides/yr

       per metric ton of waste

                 $131,100/yr        . $46
              2,834 metric. tons/yr

    . 5.6,3... Level III Technology;  Alternative  1— same as
Level zz . ' ^-Alternative 2--trimming8 'and shavings  sold, other
wastes to -landfill with leachate collection.
     Land .Requirements , equipment, interest, operating,
maintenance, rand energy costs are all 'the same  as for Level
I.
     Contract services = $14/metric ton (see Table  52 )
     x 2,834 metric tons/year - $39 /700/year
     Revenue from sale of trimmings and shavings  is not
     included in these calculations.
                             184

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Total annual costs                  $(1973)/year

  Capital costs                      $ 60,400
  Operating                            18,000
  Maintenance                           5,000
  Energy                                2,400
  Contract services                    39,700
  Total annualized                   $125,500

Average Treatment and Disposal Costs

  per unit of production (1000 equivalent hides)

            $125,500/yr      = $482
        260,000 eq. hides/yr

  per metric ton of waste

            $125,500/yr        = $44
          2,834 metric tons/yr
                        185

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                           SECTION 6.0

                           REFERENCES
  1.   U.S. Bureau of the Census.  1972 Census of Manufactures.
             Industry series:  Tanning, Industrial Leather
             Goods; and Shoes.  Series MC72(2)-31A.
             Washington, D.C., U.S. Government Printing
             Office, 1975.  27 p.

  2.   Personal communication'.   E. L. Kilik, Tanners'
             Council of America, to SCS Engineers, Inc.,
             Reston, Virginia, June 1975 through Feb. 1976.

  3.   Environmental Protection Agency.  Disposal of
             Hazardous Wastes.  Report to Congress.
             Washington, D.C., U.S. Government Printing
             Office. 1974.

  4.   Schaklette, H.T., J.C. Hamilton, J.E. Boernger, and
             J. M. Bowles.  Elemental composition of surficial
             materials in the conterminous United States.
             Statistical Studies in Field Geochemistry.
             U.S.  Geological Survey Professional Paper 574-D.

  5.    Christensen,  H.E.,  ed.   Toxic  substances list,  1973
             ed. Rockville,  U.S.  Department  of Health,
             Education,  and  Welfare (National Institute for
             Occupational  Safety and  Health).  1973.

  6.    McKee, J.E.  and  H.W.  Wolf, eds.   Water quality criteria.
             2nd ed.  California State Water  Resources
             Control Board.  1971.

  7.    Gleason, M.,  R.E. Gosselin,  H.C.  Hodge,  P.B.  Smith.
             Clinical toxicology  of commercial  products.
             3rd ed.  Baltimore, The Williams 6  Wilkins  Co.
             1969.

 8.    Personal communication.  W.L.  (Pete)  Banks,  Industrial
            Advisor, Region VII, Environmental Protection
            Agency,  to  SCS  Engineers,  Inc.,  Reston, Virginia,
             Dec.  1975.

 9.    National Academy of Sciences.  Chromium.  Washington,
            D.C.  1974.

10.    Leather Facts. 1st ed. Peabody, Massachusetts, New
            England Tanners Club,  1965. 40  p.
                            187
Preceding page blank

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 11.    Versar Inc.  Assessment of industrial hazardous
             waste practices,  inorganic chemicals industry.
             Environmental Protection Agency Contract No.
             68-01-2246.   Springfield, Virginia.   March 1975.

.12.    Versar, Inc.  Assessment of industrial hazardous
            . waste- practices :   storage and primary batteries
             industries.   Environmental Protection Agency
             Report (S«-l02c).   Washington, D.C., U.S.
             Government Print ing Office.  1975.

 13.    U.S.  Department of Health, Education, and  Welfare,
             Public Health Service,  Consumer 'Protection and
            'Environmental Health Services, Environmental
             Control Administration.  Public health service
            .drinking 
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20.   Bertrand,  D.  and A.  deWolf.   Le chrome,  oligoelement
            dynamique pour les vegetaux superieurs.   C. R.
            Acad.  Sci. 26:5616-5617,  1965.

21.   Pratt, P.P.   Chromium.   In Diagnostic Criteria for
            Plants and Soils.  ~TH.D.  Chapman,  ed.)   Riverside,
            University of  California  Division  of Agricultural
            Sciences.  1966.   pp 136-141.

22.   Personal communication.   R.  M.  Lollar, Tanners' Council
            of America, to SCS Engineers,  Inc.,  Reston,
            Virginia, June 1975 through February 1976.

23.   Personal communication.   M.  Jackson,  Particle  Data
            Laboratories,  to  SCS Engineers, Inc., Reston,
            Virginia, Dec. 1975.

24.   Thermal Processing and  Land Disposal of  Solid Waste
            Guidelines. Federal Register,  39  (158): 28334,
            Aug. 14,  1974.

25.   Battelle Memorial Institute.  Final Report; program
            for the management of hazardous wastes.
            Environmental  Protection  Agency.  Richland,
            Washington, D.C.,  July 1973.

26.   SCS Engineers.   Draft Final Report,  Vol. II, Case Study
            Site Reports,  Sewage Treatment Solids Disposal by
            Subsurface Land Application.  Environmental
            Protection Agency.  Long  Beach, California,
            December   26,  1975.

27.   Fields, T. and  A. W. Lindsey, Landfill Disposal of
            Hazardous Wastes:   A Review of Literature and
            Known Approaches.   Environmental Protection Agency
            Publication SW-165.  Washington, D.C., U.S.
            Government Printing Office, 1975.

28.   Personal communication  .  J.D.  Eye,  Tanners' Council!
            of America, to SCS Engineers,  Inc.,  Reston,
            Virginia, June 1975 through February 1976.

29.   Personal communication.   T.  Fields,  Jr., Office of
            Solid Waste Management Programs, Environmental
            Protection Agency, to SCS Engineers, Inc.,
            Reston, Virginia,  October 14,  1975.

30.   Personal communication.   W.  Sanjour,  Hazardous Waste
            Management Division, Office of Solid Waste
            Management Programs, Environmental Protection
            Agency, to SCS Engineers, Inc., Reston,  Virginia,
            Jan. 27,  1976.

                              189

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31.   Environmental Protection Agency.  Contract Mo.
            68-01-3261. July 9, 1975.
                              190

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                         SECTION 7.0

                      ACKNOWLEDGEMENTS


     The conduct of this project was accomplished through
the efforts of the staff of SCS Engineers, Inc., Reston,
Virginia, and Long Beach, California.  E. T. Conrad directed
the study with day-to-day project management by Gary L.
Mitchell.  The Tanners'  Council of America provided
significant input and assistance during the project.
     The project staff is indebted to the U.S. Environmental
Protection Agency personnel in the Hazardous Waste
Management Division for their continuing interest, advice,
and guidance during the entire term of the study.
Particular thanks go to Allen C. Pearce, Project Officer,
and Timothy Fields, Jr., Acting Program Manager.  Thanks
are also due to the management and other staff members of
the Office of Solid Waste Management Programs, Hazardous
Waste Management Division, who reviewed program progress
and assisted with constructive suggestions.  It is the
opinion of the SCS staff that this project has been one
of the best examples of EPA/Contractor coordination in
the firm's history.
     The project could not have been accomplished without
the cooperation of the owners and managers of the leather
tanning and finishing establishments visited as part of
this project.  Their interest in the study and willingness
to provide necessary information greatly assisted in the
acquisition of data.
     The Tanners' Council played an important role in the
study.  As a major subcontractor, the Tanners' Council
provided much of the basic industry information, including
most of that which is included in the Industry Characterization
section.  Additionally,  the Tanners' Council assisted in
the selection of tanneries to be visited and elicited the
cooperation of member firms.  Special thanks are extended
to Dr. Robert M. Lollar and Eugene L. Kilik of the Tanners'
Council.
     Other subcontractors playing important roles in the
project were Dr. J. David Eye and Meryl R. Jackson.  Dr.
Eye accompanied project teams on several plant visits and
provided critical review of several phases of the study
and resultant report.  Meryl Jackson, the project's air
pollution consultant, visited several tanneries and provided
advice concerning the effects of air pollution control
equipment..
     Laboratory analyses were performed by Daylin
Laboratories, Inc., of Los Angeles, California.
Particular thanks to Henry Espoy and Michael Gordon.

                            1D1

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     Our appreciation is extended to the other staff
personnel of SCS Engineers, Inc., for their efforts during
this project.  Specifically our thanks to:

        David R. Bauer
        Ronald J. Lofy
        Robert D. Morrison
        Michael W. McLaughlin
        Cindi D. Culkin
        Ginny B. Paul
        Marcia Saunders
        Dixi A. Russo
        Thomas A. Winner
                            192

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                         SECTION 8.0

                          GLOSSARY
Back
Bate
Beaming
Bend        :


Buffing     :




Buffing dust:




Blue        :




Coloring    :


Dry Milling :
 Equivalent   :
 Hides
A portion of hide formed by cutting the hide
longitudinally along the backbone, then
trimming off head and belly, leaving a bend
and shoulder.

The treatment of hides with enzymes prior to
tanning.  Bating removes the lime used in
the hair removal processes and the enzymes
prepare the hide for the tanning solution by
destroying most of the remaining undesirable
constituents in the hide such as hair roots
and pigments.

The traditional name for the processes of flesh
and hair removal from skins and hides to be
tanned into leather.  Beaming operations also
include one or more soaking steps to loosen or
dissolve hair.

A sole leather back with the shoulder trimmed
off.

A light sanding operation applied to the grain
or underside of leather and also to splits.
Buffing smooths the grain surface and improves
the nap of the underside of the leather.

Small pieces of leather removed in the buffing
operation.  Buffing dust also includes small
particles of abrasive used in the operation
and is of a coarse powder consistency.

The state or condition of hides subsequent to
chrome tanning and prior to retanning.  Hides
in this stage of processing are characteristically
blue in color.

The dying of leather to the desired color and
shade.

The rotating of leather in a large wooden drum
with no added chemicals or water.  Dry
milling softens the leather.

A statistical term used by the Tanners' Council
of America to relate the production of tanneries
using various types of raw materials.  An
                            193

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Fatliquor
Finishing
Fleshing
Fresh Hide
Grain Side
Head
Hide
Mechanical
Conditioning
equivalent hide is represented by 3.7 m2
(40 ft2) of surface area and is the
average size for a cattlehide.

The agitation of tanned hides in oils or
related fatty substances.  Fatliquoring
regulates the softness and pliability of
the leather and also contributes to its
tensile strength.

The application of materials to the grain
surface of leather to provide abrasion
and stain resistance and to enhance color.
Finishes are usually sprayed or rolled
onto the leather followed by drying.
Finishes may be either water or organic
solvent based and normally more than one
finish coat is applied to the leather.
Other operations considered as part of
finishing include plating and embossing.

The mechanical removal of flesh and fatty
substances from the underside of a hide
prior to tanning.  In the case of sheepskin
tanning, fleshing is often accomplished
after the tanning process.

Hide that has not been preserved by brining
or salting.  Fresh hides are usually
received at tanneries within 24 to 48
hours of slaughter.

The outermost portion of a hide having
the characteristic natural graining
associated with the outer surface of a
hide or skin.

That part of the hide which is cut off
at the flare into the shoulder, i.e., the
hide formerly covering the head of the
animal.

The skin of a relatively large animal,
at least the size of mature cattle.

A generic term representing a number of
mechanical operations used to alter the
physical properties of the leather.
Operations included are staking, dry
milling, and buffing.
                             194

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Pickle
Plating
Retanning
Shaving
Shoe Leather
Shoulder


Side
The transforming  of  hides  into an acid
environment prior to tanning.   The hides
are agitated  in a solution of  sulfuric
acid and  sodium chloride to  reduce the
pH of the hides.

The pressing  of grain leather  to smooth
its surfaces.  Plating may also be done
with an embossing plate which  imprints
textured  effects  into the  leather surface.

A second  tanning  process utilizing either
the natural tanning  materials  (chromium
or vegetable  extracts) or  synthetic
tanning agents.   Retanning imparts
specialized properties to  the  leather.

1) An abrasive* mechanical action used to
correct errors in splitting  and thus yield
a uniformly thick grain side or split.
2) The waste  products generated during
the shaving operation.  These  are essentially
small pieces  of the  tanned hide,  which
are approximately the size of  wood
shavings.

This term embraces a variety of leathers.
Included  are: (1)  Sole Leather*  made from
cattlehides and to a small extent from
horsehides and buffalo hides*  which comprises
both the  heavier  grade* used for outer soles
of shoes  and  the  lighter grades and offal
(heads* shoulders* and bellies)*  used to a
greater or less extent for heels*  insoles*
toecaps*  etc.; (2) Upper Leather,  made
principally from  calfskins*  goatskins*
cattlehides* horsehides* and other classes of
animal skins* going  into shoe  uppers; and  (3)
miscellaneous shoe leathers* including welting,
lining stock* tongue  stock*  facing stock* etc.

That part, of the  hide  between  the  neck and the
main body of the  hide.

A one-half of a hide produced  by cutting the
hide down the backbone.  Normally  done to
facilitate processing  using  smaller equipment
than would be required if  full  hides were
processed.
                           195

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Skin
Split
Staking


Syntan
Tanning
Tear-Offs
Trimming
The pelt or skin of animals smaller than
mature cattle, e.g., pigskin, sheepskin,
calfskin.

1) The operation of separating a hide
into two layers, a grain side and a flesh
side ("split").  The process is accomplished
on a splitting machine similar to a
horizontal band saw which slices the hide
through its thickness leaving a relatively
uniformly thick outer, or grain side, and
a split of varying thickness.
2) The underside layer of a hide after
splitting.  The split has no grain
characteristics and is often used for the
production of suede leather.

The mechanical massaging of leather to
soften it and make it more pliable.

Synthetic tanning materials, generally
used in combination with vegetable,
mineral or formaldehyde tannages.  Syntans
are almost exclusively used in retanning
rather than tanning operations.

The process of converting a hide or skin
into leather by soaking it in a tanning
solution made of vegetable extracts, alum,
formaldehyde, or metals such as chromium
or zirconium.

Small pieces of leather, less than half
a skin, which are torn from a skin during
tanning operations.

1) The removal of the ragged edges and
inferior portions of hides and skins either
before or after tanning.  Trimming is
normally accomplished by workers using knives,
2) The hide or  leather scraps produced
during the trimming operation.
                             196

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SECTION 9.0



APPENDICES
   197

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                       Appendix A
          Alphabetical List of Establishments
      in the Leather Tanning and Finishing Industry
A & B Tanning Corp.
101 Belmont Street
Brockton, MA  02401

A.L.M. Corp.
2-18 Mott Street
Newark, NJ  07105

Acme Sponge & Chamois  Co., Inc.
855 E. Pine Street
Tarpon Springs, FL  33580

Adams Tanning Corp.
126 South Street
P. O. Box 5115
Newark, NJ  07105

Admiral Leather Corp.
203 Jansen Avenue
Johnstown, NY  12095

Algy Leather Co., Inc.
15 Mill Street
Danvers, MA  01923

Allen Leather, Inc.
62 Foundry
Wakefield, MA  01880

Bona Allen, Inc.
115 E. Main
Buford, GA  30518

Alliance Leather Finishing Co.
4 Union Street
Peabody, MA  01830

Allied "Leather Co.
324 E. Eleventh Street
Wilmington, DE  19899
L. Alperin Co.
17 Hale Street
Haverhill, MA  01830

Wm. Amer Co.
215 Willow Street
Philadelphia, PA  19123

American Lace & Leather
 Co., Inc.
P. O. Box 121
Richmond, VA  23201

American Leather Mfg. Co.
2195 Elizabeth Avenue
Rahway, NJ  07065

Amoskeag Leather Finishing,
 Inc.
S. Commercial Street
Manchester, NH  03101

Arizona Tanning Co.
P. O. Box 788
Chandler, AZ  85224

Armira Corp.
1113 Maryland Avenue
Sheboygan, WI  53081

Armira Corp.
Highway 18, North
Bolivar, TN   38008

Aztec Leather Corp.
195 McWhorter
Newark, NJ 07105
                        Preceding page blank
                              199

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     B
BTH Tanning Corp.
122 W. 8th Avenue
Glover sville, .NY  12078

Badger State Tanning Corp.
305 N. 25th Street
Milwaukee, HI  53233

Barbour Welting Co., Inc.
932 Nx Montello
Brockton, MA  02403

A . Earth' -Leather Co >
(Div.( of .Caldwell Lace Leather)
New Albany, IN  47150

Beggs & Cobb Corp.
139 Lynnfield
Peabody,i MA  01960
         frfi -Son, Inc-.
76 8,i 8th; Street-
Brooklyn, NY  11211

M . Berger-. Trading,
495 Main Street
Gloversville, NY  12078

Berlin Tanning Co., Inc.
235 S. WisGpnsinf
Berlin, WI ' 54923

Besse , Oaborn & Odell , Inc -
Spring Street
Clinton,, ^ME : 04 92-7 -

Bettencourt Tanning Co. , Inc.
340 Merrimack..
Lawrence /,& Sons, Inc.
Williamsport, MD  21795
                              200-

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Calanpro, Inc.
2466 Van Ness Avenue
P. O. Box 7166
National City, CA  92050

CaIdwe11 Lace Leather Co.
Auburn, KY  42216

California Tanning Co.
1905 Shenandoah Avenue
St. Louis, MO  63104

Calnap Tanning Co.
P. O. Box 2190
Napa, CA  94558

Camden Tanning Corp.
116 Washington
Camden, ME  04843

Carr Leather Co., Inc.
500 Boston
Lynn, MA  01903

Cayadutta Tanning Co., Inc.
98 Harrison
Gloversville, NY  12078

Chestnut Operating Co.
2nd & Chestnut
Reading, PA   19602

Chic Leather  Co., Inc.
84 Wingate
Haverhill, MA 01830

Chicago Tanning Co.
1500 Cortland
Chicago, IL   60622

Cincinnati Kid, Inc.
920 West Ninth
Upland, CA  91786

Clark's Leather Splitting Co., Inc.
36 West  Street
Gloversville, NY  12078
Coey Tanning Co.
Wartrace, TN  37138

Colonial Tanning Corp.
8-10 Wilson Street
Gloversville, NY  12078

The Colorado Tanning &
 Fur Dressing Co.
1787 S. Broadway
Denver, CO  80210

Comet Leather Finishing
 Co., Inc.
Fifth Street
Peabody Industrial Park,
 MA  01960

Concord Leather & Skins
 Corp.
Fifth Street
Peabody Industrial Park,
 MA  01960

Conneaut  Leather, Inc.
W. Adams
Conneaut, OH  44030

Coronet Leather Finishing,
 Corp.
201 Central Street
Georgetown, MA  01830

Corpro Industries
Lubbock,  TX   79408

Creese &  Cook Co.
33 Water  Street
Danvers,  MA   01923

Crescent  Leather Finishing
Townsend  Avenue
Johnstown, NY  12095

Crown  Leather Finishing  Co,
422 N. Perry
Johnstown, NY  21095
                               201

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Cudahy Tanning Co.
5043 S. Packard
Cudahy, WI  53110

Cui
4400 Brighton Blvd.
Denver, CO  80202

E. Cuiranings Leather Co., Inc.
10 High Street
Lebanon, NH  03766

The Custom Tannery, Inc.
1170 Martin Avenue
Santa Clara, CA  95050
J. H. Elliott Leather Co.
356 Adams
Newark, NJ  07105

Ellithorp Tanning Co., Inc.
9-19 Grove
Gloversville, NY  12078

Elton Leather Corp.
47 Spring
Gloversville, NY  12078

Embossing Corp. of America
12 Winter Street
Peabody, MA  01960
Damascus Tanning Co.
Box 470
Coudersport, PA  16915

W. Dardano & Sons, Inc.
37 Grand
Canton, MA  02021

Donne11 & Mudge, Inc.
151 Canal
Salem, MA  01970

Drew Tanning of Brockton, Inc.
62 Watson
Brockton, MA  02401

Dudley Leather Co.
244 Broad
Lynn, MA  01901
Eagle Ottawa Leather Co.
200 N. Beechtree Road
Grand Haven, MI  49417

Eastern Tanning Co.
41 Hardy
Peabody, MA  01960

Eberle Tanning Co.
Church Street
Westfield, PA  16950
Fashion Tanning Co., Inc.
6 Van Road
Gloversville, NY  12078

Fashion Tanning Co.
126 W. Fulton
Johnstown, NY  12095

Fermon Tanning Co.
11-27 Walnut
Peabody, MA  01960

Fidelity Leather Mfg.
 Co., Inc.
80 Lowell
Peabody, MA  01960

Flagg Tanning Corp.
624 W. Oregon
Milwaukee, WI  53204

Flavorland  Industries,  Inc,
Hide  Processing Division
P. O. Box  190
Sergeant Bluff, IA   51054

Florida Tanning & Sponge
 Co., Inc.
S. Walton
Tarpon Spring, FL  33589

J. Flynn &  Sons
80 Boston Road
Salem, MA   01970
                               202

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S. B. Foot Tanning Co.
Red Wing, MN  55066

Foster Leather Co.
R-51 Canal
Salem, MA  01970

L. J. Frebel Sons Co.,  Inc
499 Main
Belleville, NJ  07109

Frielich Leather Corp.
Industrial Park
Haverhill, MA  01830

Frontier Leather Co.
1210 E. Pacific
P. O. Box 502
Sherwood, OR  97140

Frontier Tanning Co.
Box 122 Star Rt.
Anchorage, AK  99502
A. F. Gallun & Sons Corp.
1818 N. Water
Milwaukee, WI  53201

Garden State Tanning
Fleetwood, PA  19522

A. L. Gebhardt Co.
226 N. Water
Milwaukee, WI  53202

Geilich Tanning Co.
491 W. Water
Taunton, MA  02780

General Leather Finishing Co.
32 Varney
Salem, MA  01970

General Split Corp.
5050 S. Second Street
P. O. Box 491
Milwaukee, WI  53201

General Splitting Co.
28 Winter
Peabody, MA  01960
Genesco
Fort Worth, TX  76101

W. Gibb Leather Co.
54th & Grays Avenue
Philadelphia, PA  19143

Gloversville Embossing
 Co., Inc.
28-30 E. llth Avenue
Gloversville, NY  12078

Glove City Abrading Co.,
 Inc.
3 Harrison
Gloversville, NY  12078

Gloversville Leather Co.,
 Inc.
318 W. Fulton
Gloversville, NY  12078

Gnecco & Grilk  Tanning
 Corp.
80 Foster
Peabody, MA   01960

Golden Wool  Co.
3001  Sierra  Pine
Los Angeles,  CA  90023

O. F  Goldsmith Leather  Co.
63 Proctor
Salem, MA  01970

Goldstein Leather Co.
New Jersey R.  R.  Avenue
Newark,  NJ  07102

Goliger  Leather Co.
 5 Hill
Gloversville, NY  12078

Granite State Leather,  Inc
 Fairmount
 Nashua,  NH  03060

 Great Lakes Tanning Co.
 4100 W.  Aver Avenue
 Milwaukee, WI  53216
                               'C3

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Greene Tanning Corp.
Hilton Hills  NH  02852

Win. Greiner Co.
2252 N. Elston Avenue
Chicago, IL  60614

Gunnison Bros., Inc.
Box 166
Girard, PA  16417

Gunther Tanners 6 Master
 Taxidermist
3200 Mariposa
Denver, CO  80202

Gutenstein & Co., Inc.
440 Frelinghuysen Avenue
Newark, NJ  07114

Gutman & Co.
1511 Webster Avenue
Chicago, IL  60614
     H
H. D. C. Leather Co., Inc,
101 Foster
Peabody, HA  01960

H. L. S. Leather Co., Inc.
122-124 W. 8th Avenue
Gloversville, MY  12078

Hallmark Leather Co., Inc.
20 Walnut
Peabody, HA  01960

Harmony Buffing Co., Inc.
7 1/2 Mason
Box 428
Peabody, HA  01960

Harris & Tipograph, Inc.
725 Broadway
New York, NY  10003

A. Harvey Leather Finishing, Inc.
500-B Kennedy Blvd.
Somerdale, NJ  08083
Henry Leather Co.
150 Main
Peabody, HA  01960

Hermann Oak Leather Co.
4050 N. First
St. Louis, MO  63147

Rickey Leather Co.
Brighau Hill Road
Grafton, HA  01519

Highland Leather Corp.
Box 248
Sebring, FL  33870

Horween Leather Co.
2015 Elston Avenue
Chicago, IL  60614

E. F. Houghton & Co.
303 W. Lehigh Avenue
Philadelphia, PA  19133

Howes Leather Co., Inc.
Curwensville, PA  16833
 and Frank, WV   24937

Hoty & Worthen Tanning Corp.
Railroad
Haverhill, HA  01830

Huch Leather Co.
H. Homer
Chicago, IL  60622
 Ideal Finishing Co.
 55-61 Boston
 Salem, MA  01970

 Ideal Leather  Finishers
 92-94 Spring
 Gloversville,  NY   12078

 Independent Leather  Mfg.,
  Corp.
 315-329  S.  Main
 Gloversville,  NY   12078
                             204

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Irving Tanning Co.
Main
Hartland, MA  04943
JEC Tanning Co.
Ill Foster
Peabody, MA  01960

J. B. F. Industries, INc.
41 w. Eleventh Avenue
Gloversville, NY  12078

J. P. Tanning Co.
373 River Road
Haverhill, MA  01830

Jansha Tanning Co.
1355 State Avenue
Marysville, WA  98270

Johnstown Leather, Inc.
Railroad
Johnstown, NY  12095

S. Jonas Leather Mfg., Co.
174 Broadway
Brooklyn, NY  11211

R. Jones & Co., Inc.
5 Burr
Gloversville, NY  12078

Jones & Naudin Leather Corp.
87 S. Main Street
Gloversville. NY  12078

Jonish Leather Mfg., Co.
55 Mercer
New York, NY  10013
Karg Bros.
6-20 E. Fulton
Johnstown, NY  12095

Kirstein Leather Co.
72 Main
Saco, ME  04072

Kroy Tanning Co., Inc.
18 Goodhue
Salem, MA  01970
The Lackawanna Leather Co.
Richard Mine Road
Wharton, NJ  07885

The Lackawanna Leather Co.
California

The Lackawanna Leather Co.
North Carolina

Lackawanna of Omaha
2420  Z Street
Omaha, NB   68107

Lannon Mfg.  Co.,  Inc.
W. Lincoln
Tullahoma,  TN   37388

Law  Tanning Co.
401  S. 74th Street
Milwaukee,  WI  53204

A. C. Lawrence
 (Div. of Estech)
 25 & Central Avenue
Ashland, KY  41101
  & Rt. 128,
  Peabody, MA  01960
  & Winchester, NH  03270
  6 Hazelwood, NC  28738
  6 Newport, TN  37821
  & S. Paris, ME  04281

 Lawrence Leather Finishing
  Corp.
 15 Union
 Lawrence, MA  01840

 Leach-Heckel Leather Co.
 72 Flint
 Salem,  MA   01970

 Leather Finishers,  Inc.
 222  Verona Avenue
 Newark, NJ  07104

 Leather Finishing Corp.
 2615 W. Greves
 Milwaukee,   WI  53233

 The Leather Group, Inc.
  10  Burr
 Gloversville,  NY  12078
                              253

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Leather Line Co.
122 S. Main
Gloversvllle, NY  12078

Leavitt-Berner Tanning Corp.
114 N. Perry
Johnstown, NY  12095

Legallet Tanning Co.
1099 Quesada Avenue
San Francisco, CA  94124

Liberty Dressing, Corp.
Harrison Street
Gloversville, NY  12078

Liberty Rawhide
663 W. Hobble
Chicago, IL  60610

Loewengart 6 Co. * Inc..
Mercersburg, PA  17236

S. Lojko & Sons, Inc.
23 Oak
Peabody, MA  01960

Lomelis Bros. Splitting Co.
Shetland.Industrial Park
Salem, MA  01970

Los Angeles Tanning Co.
4101 Whiteside
Los Angeles, CA  90063
     M
Masassee-Block Tanning Co.
1300 4th Street
Berkeley, CA  94710

Maro Leather Company
831 Broadway
Newark, NJ  07104

Marshall Leather Finishing
 Co., Inc.
45 Wooster
New York, NY  10013

Masino Leather Co.
41 Hardy
Peabody, MA  01960
Mason Tanning Co., Inc.
4 Water
Salem, MA  01970

Mass Split, Inc.
55 Walnut
Peabody, MA  01960

Master Inc.
287 E. 6th
St. Paul, MN  55101

N. H. Mats Leather Co.,
 Inc.
119 Foster
Peabody, MA  01960

McAdoo & Allen, Inc.
S. Hellertown
Quakertown, PA  18951

McLeod Leather 6 Belting
 Co., inc.
P. O. Box 2310
910 Scott Avenue
Greensboro, NC  27402

Meeten & Beghardt, Inc.
1775 Egbert Avenue
San Francisco, CA  94124

R. E. Meyer t Sons,  Inc.
5009 Grand Avenue
N. Bergen, NJ  07047

Michael*s Finishing  Co.
9 Howley
Peabody, MA  01960

Mid-Tenn Tanning Co.
Industrial Parkway
Shelbyville, TN  37160

Middlesboro Tanning  Co.
 of Del., Inc.
P. O. Box 189
Middlesboro, KY  40965

Middletown Leather Co.,
 Inc.
200 Valentine Street
Hackettstown, NJ  07840
                             206

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Midwest Tanning Co.
1200 Davis Avenue
S. Milwaukee, WI  53172

Missouri Belting
1021 S. Grand Blvd.
St. Louis, MO  63104

Moench Tanning Co., Inc.
P. O. Box 389
Gloversville, NY  12078

G. Moser Leather Co.
Silver
New Albany, IN  47150

Mucci Bros , Inc.
605 N. Third
Newark, NJ  07107

Muir & McDonald
100 Levens
Dallas, OR  97338

Murray Bros Tanning Co., Inc.
215 Salem
Woburn, MA  01801
     N
National Leather Co.
465 E. 147th Street
Bronx, NY  10455

National Rawhide Mfg. Co.
1464 W. Webster Avenue
Chicago  IL  60614

Nelson & Sons, Inc.
625 Humble Avenue
San Antonio, TX  78225

R. Newmann & Co.
300 Observer Highway
Hoboken, NJ  07030

S. Newmann Tannery
91 Golden
Newark, NJ  07103

New Braunfels Leather Co., Inc.
197 S. Seguin Avenue
New Braunfels, TX  78130
                            207
                                     Newbury Tanning Corp.
                                     12 Federal
                                     Newburyport,  MA  01950

                                     N. J.  Tanning Co., Inc.
                                     410 Frelinghuysen Avenue
                                     Newark, NJ  07114

                                     Norwich Leather Co.
                                     70 Brookside Avenue
                                     Borckton, MA  02403

                                     Nuco Leather Finishing
                                      Co.,  Inc.
                                     646 Grove, Rt. 1
                                     Elizabeth, NJ  07200
                                          O
                                     Ocean Leather Corp.
                                     42 Garden Street
                                     Rahway, NJ  07065

                                     Osmo Tanning & Mfg.
                                     (Div. of Ranred Corp)
                                     Box 151
                                     Spartansburg, PA  16434
                                     Page Belting Co.
                                     Commercial
                                     Concord, NH  03301

                                     E. W. Parks Co.
                                     70 Beacon
                                     Worcester, MA  01608

                                     Parsons Tanning Co.
                                     Parsons, WV   26287

                                     Pearse Leather Co., Inc.
                                     7 Kershaw Avenue
                                     Hampton, NH  03842

                                     Peerless Tanning Co.
                                     24 Briggs
                                     Johnstown, NY  12095

                                     Pfister & Vogel Tanning Co,
                                     1531 N. Water Street
                                     Milwaukee, WI  53201

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Phenny-Smidt Leather Co.
21 Caller
Peabody, MA  01960

Pierini Tanning & Dyeing  Corp.
28 Paris
Rahway, NJ  07105

Pioneer Tanning Co., Inc
3 Tremont Place
Salem, MA  01970

W. B. Place & Co.
368 W. Sumner
Hartford, WI  53027

Plumer Leather Finishing Co.
1678 Leonard
Cleveland, OH  44113

Poetsch & Peterson
325 S. Maple Avenue
San Francisco, CA  94080

Pownal Tanning Co.
N. Pownal, VT  05260

Prime Tanning Co., Inc.
Sullivan
Berwick, MA  03901

Printz Tanning Co., Inc.
1530 Chestnut
Philadelphia, PA   19102

Progressive Leather Co.
16 Fowle
Woburn, MA  01801
Renco Leather Finishing
 Co., Inc.
Harris Street
Gloversville, NY  12078

Rex Leather Finishing
 Corp.
119 Foster
Peabody, MA  01960

Richard Leather Co., Inc,
9 Webb
Salem, MA  09170

J. J. Riley Co.
228 Salem
Woburn, MA  01801

Risedorph, Inc
14o W. 8th Avenue
Gloversville, NY  12078

Jos. Roller Co., Inc.
500 Chancellor Avenue
Irvington, NJ  07111

A. H. Ross & Son Co.
1229 N. North Branch
Chicago, IL  60622

R. Rueping Leather Co.
96 Doty
Fond du Lac, WI  54935

R. Rulison & Son, Inc.
Charles Street
Johnstown, NY  12095
Rapco Leather Co.
1010 Davis Road
S. Milwaukee, WI   53172

Raser Tanning Co.
757 Prospect Road
Ashtabula, OH  44004

Remis Industries
 (Div. of  Beggs & Cobb)
22-24 Johnson
Rahway, NJ   07105
 Salem Embossing Co.
 12  Hanson
 Salem, MA   01970

 Salem Suede,  Inc.
 9 Irving
 Salem, MA   01970

 Salz Leather
 1040 River  Street
 Santa Cruz, CA  95060
                              20R

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Schaffell Tanning Corp.
W. Fulton
Gloversville, NY  12078

Scholze Tanning
3100 St. Elmo Avenue
Chattanooga, TN  37408

H. Schwarz Leather Co., Inc.
Garden PI. 6 River Road
Edgewater, NJ  07020

Seakas Leather Co.
4 Eagan Place
Peabody, MA  01960

Seal Tanning
(Div. of Beggs & Cobb)
Commercial Street
Manchester, NH  03101

Seidel Tanning Corp.
602 W. Oregon
Milwaukee, WI  53204

Seton Leather Co.
849 Broadway
Rahway, NJ  07104

Shawmut Tanning Corp,
45 Walnut
Peabody, MA  01960

Sheepskin Lining Co.,  Inc.
10 Cayadutta
Gloversville, NY  12078

Sidney Tanning Co.
218 N. Ohio Avenue
Sidney, OH  45365

Sierra Pine Tanning
3001 Sierra Pine Avenue
Los Angeles, CA  90023

Simco Leather Corp.
99 Pleasant Avenue
Johnstown, NY  12095

Sirois Bros., Inc.
73 Lowell
Peabody, MA  01960
        Slip-Not Belting Corp.
        432 E. Main
        Kingsport, TN  37662

        Spanish-American Skin Co.
        11-13 Cayadutta
        Gloversville, NY  12078

        Stahlbrand Leather Co.
        Rfd. 3
        River Road
        Bow, NH  03301

        Star Leather
        6-8 Division
        Gloversville, NY  12078

        Strauss Tanning Co., Inc.
        145 Lowell
        Peabody, MA  01960

        Suncook Tanning Corp.
        Pittsfield, NH  03263

        Sunnyside Tannery
        12687 S. E. Sunnyside Road
        Clackamas, OR  97015

        Superior Hat Leather Co.
        119 Foster
        Peabody, MA  01960

        Sure-Tan, Inc.
        1470 W. Webster
        Chicago, IL  60614

        C. Swartzburg Leather Co.
        150 Main
        Peabody, MA  01960

        Sweet Home Tanning Co.
        P. O. Box 454
        Sweet Home, OR  97366

        G. Swoboda & Son, Inc.
        1027 N. Bodine
        Philadelphia, PA  19123
209

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Tanners Degreasing Co., Inc.
325 Montvale Avenue
Woburn, MA  01801

Tanzer Leather Co.
4 Union
Peabody, MA  01960

Tennessee Tanning Co., Inc
915 Atlantic
Tullahoma, TN  37388

Thiele Tanning Co.
123 N. 27th
Milwaukee, WI  53208

Thru-Blu, Inc.
501 Maiden
S. St.Paul, MN  55075

Travel Leather Co., Inc.
42 Walnut
Peabody, MA  01960

Twin City Leather Co., Inc,
River Road
Gloversville, NY  12078
     U
Uber Tanning Company
Owatonna, MN  55060

United Rawhide Mfg. Co.
1644 N. Ada
Chicago, IL  60622

United Tanners, Inc,
9 Orchard Street
Dover, NH  03820
     V
Vernon Leather Co., Inc
2890 Sierra Pine Avenue
Los Angeles, CA  90023

Victory Tanning Corp.
123 Upton
Peabody, MA  01960
Virginia Oak Tannery, Inc,
Box 511
Luray, VA  22835

Volunteer Leather Co.
Kefauver Drive
Milan, TN  38258

     W

Walnut Finishing Co.
57 Grove
Salem, MA  01970

Waterboro Co.
Depot Street
Waterboro, ME  04087

Weil & Eisendrath Co.
2221 Elston Avenue
Chicago, IL  60614

Weldon Leather Co.
Benicia Industrial Park
P. O. Box 583
Benicia, CA  94510

Wells Tanning Inc.
633 W. Center Street
N. Salt Lake, UT  84054

Western Leather Products
 Corp.
904 E. Pearson
Milwaukee, WI  53202

Western Tanning Co.
P. O. Box 44
Delta, CO  81416

White Eagle Rawhide Mfg.
 Co.
1652 N. Throop
Chicago, II  60622

Whitehall Leather Co.
Lake
Whitehall, MI  49461
                            210

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R. S. Widen Co.
Ashton Avenue
N. Adams, MA  01247

Wilmington Enameling Co.
P. O. Box 66
Wilmington, DE  19899

Wilton Tanning Co.
Box 55, Rt. 2
E. Wilton, ME  04234

Wisconsin Leather Co.
1830 S. Third Street
Milwaukee, WI  53204

Woburn Degreasing Co.
134 Bedford Road
Woburn, MA  01801

Woverine World Wide Co.
9341 Courtland Drive
Rockford, MI  49341
 & 501 Musser
 Muscantine, IA  52761

Wood & Hyde Leather Co.
69 Wood
Gloversville, NY  12078

Wyaocki Taxidermy & Leather
2451 N.W. 58th Street
Seattle, WA  98107
C. E. Zimmerman & Co.
2756 Toulouse
New Orleans, LA  70119
           211

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                       Appendix B
         Outline of Procedures for Field Visits/
          Sample Collection, and Sample Analysis'


     Development of Field Manual.  Early in the project,
a field manual was developed for use by the project teams
visiting tanneries.  The purpose of the manual was to
provide general direction to field teams prior to, during,
and after their plant visits.  It contained general
instructions, data collection forms, and sample analysis
forms .  This material ensured that the field engineers
collected complete information and enabled presentation
of the information in a uniform manner.

     A plant visit outline was presented in the manual.
It listed the general steps to be followed by field teams
before, during, and after a plant visit.  The outline
ensured that all field teams followed the same general
procedures in arranging for their visits and that all
necessary coordination between SCS, its subcontractors,
and EPA had been accomplished.  The plant visit outline
included the following steps:

     1.  Group the selected plants geographically to
         reduce travel time and costs.

     2.  Telephone the tanneries to reintroduce the project
         (they have already been contacted by TCA), arrange
         for a convenient visit date,  assign a plant code
         number.   Coordinate with TCA when problems arise;
         e.g., an important tannery is reluctant to cooperate.

     3.  Develop travel itineraries and advise EPA and
         TCA of travel plans as soon as possible.   Send
         copies of itineraries to Dr.  Eye and Meryl
         Jackson when appropriate.

     4.  Send a visit confirmation letter or telephone
         the tannery a few days prior  to the planned
         visit to remind  them of  the planned visit.

     5.  Complete the plant visit.   Fill out the plant
         visit data collection form as  well as sampling
         and analysis forms during  the  visit and dictate
         supplementary memorandum for material that does
         not lend itself  to notation on the forms.
         Complete the disposal  site visit  form when a
         disposal site is visited.
                              2;.3   Preceding page blank

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     6.  Send a letter to each plant visited thanking them
         for their cooperation in the project and
         transmitting a typed copy of the plant visit data
         form to the plant for their comments, corrections,
         and for their general information.  Also send
         copies to the EPA Project Officer and TCA.

     7.  If samples were obtained at the plant, send copies
         of the sample analyses to the plant upon receipt
         from the analytical laboratory.

     During each plant visit, the plant visit data collection
form was completed.  Information areas included in the
data form are as follows:

     1.  Identification—plant and field team.

     2.  Processing

            Production information
            General processing block diagram
            Specifics on the various types of operations
             conducted at the plant.  Space was provided
             for detailed block diagrams in order to
             show movement of hides and sources of process
             solid wastes.
            Information concerning by-product handling,
             including a by-product sale summary tabulation.

     3.  Waste material

            A sketch of wastewater pretreatment or treatment
             facilities,  plus methods used by the plant
             to handle wastewater sludges.
            Information concerning air pollution control
             devices.
            A listing  of  chemical containers coming into the
             plant by  chemical type, container size, number
             received  per month,  and method of disposal.
            A lengthy  section concerning solid waste
             handling  and disposal.   It included the
             names and addresses  of  contract services,
             storage and  handling equipment within the
             plant,  energy consumption for solid waste
             handling,  labor  costs,  and equipment and
             land  costs for on-site  treatment and disposal.
            A sampling summary table.
            A process  solid waste summary table (these
             latter  two tables provided a ready reference
             to the  types and quantities of solid waste
             produced  within  the  plant and information
             concerning the samples  collected).

                              71 4

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     A similar form was developed for the collection of
information at disposal sites accepting tannery solid
wastes.  This form includes  the following:

        Identification information

        Description of the disposal site

        The number of tanneries served by the disposal
         site

     .  The number and type of equipment used

        General operating procedures

        Number of workers

        Measures used for environmental pollution control

        Problems and suggestions as to how disposal
         operations could be improved

     Sampling Instructions.  Particular emphasis was placed
on providing complete instruction for sampling tannery
wastes.  By following these instructions, the project could
be assured that the samples would be representative of
tannery wastes within the limitations of the sampling
program and that the samples would have a minimum of
contamination and degradation during storage and shipment
to the laboratory.  Separate sections of the sampling
instruction were devoted to:

        Sampling equipment and materials

        Sampling procedures

        Packing and shipment of samples

     Pages from the field engineer's manual concerning
sampling instructions and the sampling and analysis data
form are included for the benefit of the reader.
                            215

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                        SCS ENGINEERS

                    SAMPLING INSTRUCTIONS
In t roduct i on

The purpose of the field sampling program is to obtain
representative solid waste samples from each of the leather
tanning and/or finishing plants visited.  The accuracy and
care taken during the sampling cannot be overemphasized—•
the accuracy of the analyses depend to a large extent on
the degree to which the sample is representative of the
whole from which it is taken.  Refer to Table 1, Preliminary
Sampling Handling Summary, for examples of sample sources
and handling procedures.

Sampling Equipment and Materials

The following materials will be required by the field
sampling team.

     1.  One copy of "SCS Field Manual"

     2.  Styrofoam-lined corrugated shipping cartons and
         sufficient blue ice for shipping samples requiring
         refrigeration.  The blue ice should be frozen
         prior to obtaining the samples.

     3.  Adequate supply of glass, one liter wide-mouth
         bottles and lids.

     4.  pH paper (wide range and 7-10 and 10-13 ranges)
         to determine the approximate pH of the samples
         taken.

     5.  Adhesive mailing labels and black waterproof marking
         pen

     6.  Two rolls of fiber packing (strapping) tape

     7.  Notebooks for field notes and calculations

     8.  Supply of sampling and analysis data forms and
         sample inventory forms

     9.  Some type of rubber footwear or heavy boots

    10.  Half gallon plastic pitcher for taking sludge
         samples

                             216

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                                                   TABLE 1

                                         PRELIMINARY SAMPLING SUMMARY
   Sample Source
  Location/Operation
Type of Sample
Preservation
Analyses to be Conducted
  Hide cellar
Floor sweepings & trimmings
4°C for fresh hides
only, otherwise none
Metals, Pesticides, and Phenols
  Beamhouse
Fleshings
  Fresh hides
  Salted hides
  Limed (unhalred) hides
                              Hair removal
                                Hair-save residue
                                Hair-pulp residue

                              Trimmings
                                Fresh hides
                                Brined or salted hides
                                Limed (unhalred} hides
                              Floor sweepings
                                                                     4°C
                                                                    None
                                                              4°C  1f more  than  48  hrs.
                                                              In transit to  lab
                                        4°C
                                        4°C
                                       None
                                 4°C 1f more than 48 hrs.
                                 In transit to lab

                                       None
                           Metals and Pesticides
                           Metals and Pesticides
                           Metals. Pesticides and Sulfides
                           Metals, Pesticides and Sulfides
                           Metals, Pesticides and Sulfides
                           Metals and Pesticides
                           Metals and Pesticides
                           Metals, Pesticides and Sulfides
                           Metals, Phenols, and Pesticides
Tanhouse
Tanning residue
      None
Metals, Phenols. Cyanides,
Sulfides. and Pesticides
                              Splits and shavings
                                       None
                           Metals

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                                            TABLE I  (Continued)
                                 PREimiNMY SWUNG SUWRY
Sample Source
Location/Operation Type of Sample
Floor sweepings
Retan, color. Residues
fatliquor
Floor sweepings
KJ
oo Finishing F1nsh1ng residues
Buffer dust
Air pollution filters
Floor sweepings
Other Screenings
Treatment plant sludges
Incinerator residue
Preservitlon
None
None
None
None
Hone
None
None
None
None
None
Analyses to be Conducted
Metals, Phenols, and Pesticides
Metals, Phenols, Sul fides, and
Pesticides
Metals and Phenols
Metals, Phenols. Acrylates.
Cyanides, and Sul fides
Metals, Phenols, and Acrylates
Metals, Phenols, and Acrylates
Metals and Phenols
Metals. Phenols. Sul fides, and
Pesticides
Metals. Phenols, Sul fides.
Cyanides, Pesticides, Acrylates
Metals
Source:  SCS Engineers

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    11.   Garden trowel or similar small scoop

    12.   Rubber gloves

    13.   Knife or scissors

    14.   Coveralls,  lab coat,  etc.—optional

Sampling Procedure

1.  Mark carefully on a gummed label, affixed to the outside
    of each sample bottle, the appropriate identifying codes,
    dates and so forth using a black, waterproof marking
    pen (see Figure 1).

2.  Assign a different sample identifier to each sample
    taken at each plant.  Sample identifiers are numbers
    beginning with 1 which identify samples and indicate
    the total number collected at the plant.  The first
    sample taken at a plant will be given sample identifier
    1, and so forth.  In the case of composited samples,
    the identifier is associated with the sample container
    which may contain two or more portions which make up
    the sample.

2.  Utilizing the trowel or pitcher, whichever is appropriate.
    fill the sample container to approximately 80 percent
    of total volume.  Cap the bottle tightly.  Avoid
    spilling the sample material on the outside of the
    containers to help minimize odor during sample
    shipment.

3.  Measure pH of sample

4.  Complete two copies of Sampling and Analysis Data Form,
    Exhibit A, and one copy of Sample Inventory Form, Exhibit
    B.

5.  Samples of fleshings or trimmings from fresh hides and
    samples with a pH less than 12 which are to be analyzed
    for sulfides should be stored and shipped at 3 to 4
    degrees C.  All other samples may be stored and shipped
    at room temperature.

Packing and Shipment of Samples

All samples must be packed in corrugated boxes with adequate
padding material to avoid breakage.  Plenty of crumpled
newspaper or other packing material will be placed below,
above, and around each sample bottle.  Tops of the bottles
should be in the same direction.

                            219

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220

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                                     EXHIBIT A
                                   SCS ENGINEERS
                           LEATHER TANNING AND FINISHING

                          SAMPLING AND ANALYSIS DATA FORM
                          (to be sent with each sample)
 Plant Code
 Sample  Identifier
                                          Name of Sampler
                                          Date Sampled
 Type of hide:  cattle
               pig	
               other
                                  sheep _
                                  buffalo
Source of hide (be specific):    domestic

Type of hide used:  1.  fresh
Sample location
Type of sample:  1.  Hair - save residue
                                                       foreign
                                                brined
tanned
2. summer
salted
winter

(check)
                 2.  Pulped hair residue
                 3.  Fleshings
                 4.  Trimmings
7.  Treatment plant
     sludge
                 5.  Splits and shavings
                 6.  -Tanning sludge	
                                                     8.  Buffer dust 	
                                                     9.  Air pollution control
                                                          device 	
                                                    10.  Screenings
                                                    11.  Floor sweepings
                                                    12.  Other 	
Refrigerated during shipment (circle one):  Yes   No  Sample pH

Appearance:  Color	.	Stratification   __

             Other  	

Other remarks: 	
Plant Code
Sample Identifier

Date received:
                              (cut here)
                             Receipt of Sample
                     (to be completed by laboratory • and returned to SCS)
Condition:  Broken container
            Box open 	
                                         Sample temperature
                                             Odor
                                             Hold
Appearance:  Color

             Other

Other remarks:
                                             Stratification
                                       221

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Sampling and Analysis Data Form                          Plant Code
Page 2                                                   Sample Identifier


                                Laboratory Results
                  (sampler must Indicate analyses To be performed)


Analyses to be
Conducted          Parameter                              Results tops)
                                                     Wet BasisDry Basis
	 All Pesticides                     	

	   Aldrln                           	       	
                    Dieldrin                         •;              HZZZZ
________________   Endrln                           _               _•'
	   Heptachlor                       •	~     • ___
	   Heptachlor Epoxide               "  '            	
                    DDT  (Mixed Isomers)              HZZI       "
	   p.p-DDE                          	       	
	   P. P-TDE                         	       	
	   Methoxychlor                     	      __
	   Chlordane (alpha)                __,	      '"'
	   Toxaphene                        _________               -
	   Strobane                                __              __
                    Llndane (gamma BHC)               .              '
                    Mlrex                            •               ZZUZZ
	   Hexachlorophene                  "      ~_'        _
	   Hexachlorobenzene                	              2"
	   Dacthal                          .               ___I________
	   Perthane                         ________       __——
	   Polychlorinated Biphenyls        	       	.
                  All Metals (by AA)

                    Cd
                    Cr
                    pb

                    "9
                    Be
                 ;   Zr                               •;-   •          HIZII

                  Phenol s                                   __       •  •      ._
                  Cyanides                             ___               ~
                 ; Sul fides                                  _'      -'•
                  Methyl aery late                    ZHHZH                '
                  Ethyl acrylate                     _       '""
                  Acrylic acid                       __________       — — —
                  Moisture                           . _       '______
                  Emission Spec                      Report on Separate Fora

                  Other (specify)
                                      222

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                          EXHIBIT B

                        SCS ENGINEERS
                LEATHER TANNING AND FINISHING

                    SAMPLE INVENTORY FORM
Plant Name
Plant Code	Date(s) Visited

Field Team
              Type of Sample
  Sample      (describe process and sampling
Identifier      situation)	    Remarks
                           223

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Samples requiring refrigeration should be packed, as
described above, in insulated containers.  Styrofoam
sheets or an inexpensive strybfoan ice chest packed in the
corrugated box may be used.  Don't forget to put the blue
ice in with the refrigerated'samples.

Include one copy of the Sampling and Analysis Data Form
for each sample shipped.

Tape the sample boxes securely with strapping tape.  Affix
the mailing .label and mark the box "Fragile" and "This
Side Up" to keep the bottles upright.

Samples should be shipped prepaid to:

          Daylin Laboratories
          2800 Jewel Avenue
          Los Angeles, California  -90058

Shipment of refrigerated samples should be made by air unless
plant is within 2 days of Daylin Labs.  Refrigerated samples
are to be sent such that they will arirve at Oaylin
Laboratory Monday through Friday-check estimated delivery
time.

Other samples should be shipped as soon as possible by
surface carrier if the samples will arrive within one week,
if not* ship by air.  The following carriers are suggestedi

          .  United Parcel Service (UPS)
          .  REA
             REA Air Express
             Emery Air Freight
          .  Various airlines' air freight - check if
              they will deliver

Field personnel should call Mr. Henry Espoy at 213/582-0981
with the following information as soon as possible after
sending the samples:

     A.  Number of samples and boxes shipped
     B.  Date and time shipped
     C.  Carrier used
     D.  Estimated time of delivery
                            224

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     Laboratory Procedures.  Samples were packaged and shipped
by air freight to Daylin Laboratories, Los Angeles, California,
for analysis.  Upon receipt at Daylin, the box of samples
was immediately unpacked, the bottom portion of the first
page of each Sample and Analysis Data Form was filled out
by a Daylin technician, cut from the rest of the form, and
mailed back to SCS in order to verify receipt of samples.
The samples were grouped by code number where possible, and
Daylin job tickets were written up for each sample.  Master
sample sheets were also prepared at this time and distributed
to the various departments to notify them of their work on
a given sample set.

The samples were first transferred to the main laboratory.
At this point, each individual sample was mixed thoroughly
to ensure homogeneity.  Each individual sample was then
divided in sub-samples or portions which were labeled and
distributed to the respective analytical departments.  At
least one sub-sample was frozen as a backup sample.  Upon
receipt in the individual laboratories, the samples were
preserved by refrigeration or by chemical means, where a
specific analysis required preservation.

These samples were then subjected to a variety of chemical
analyses.  The three major types of analytical procedures
used were atomic absorption, gas chromotography, and wet
chemical methods.  The procedures used to prepare the samples
and references to the actual analytical procedures are
outlined below.

     Metal Analysis by Atomic Absorption.

     Sample Preparation.  The method used to prepare samples
for the determination of mercury involved drying all solid
samples in a  60oc oven prior to analysis.  All liquid samples
were held under refrigeration until analyzed.

     The method of choice for the preparation of all other
metal samples was a wet digestion.  A representative portion
of the sample is placed in a Griffin Beaker; then 3 mi
of concentrated sulfuric acid, and  10 ml of concentrated
nitric acid are added to the sample.  The acid-sample mixture
is then heated on a hot plate until all organic .natter is
decomposed,  and sample solution is effected.  After digestion,
the sample is cooled, adjusted to a volume of 100 ml and
analyzed.

     Sample  Analysis.  All metal analyses were performed
using the procedures found in Reference 1 with the
exception of zirconium.   Appropriate page numbers in
Reference 1  are included for each metal.

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     .  Cadmium, pg  101-102

     .  Chromium, pg 105-106

     .  Copper, pg 108-109

     .  Lead, pg 112-113

     .  Mercury, pg  134-138

     .  Beryllium, pg 99-1QO

     .  Zinc, pg  155-156

     .  Zirconium, Analytical Method No. 41, Reference 2

     Pesticide Residue Analysis by Gas Chromatography.  The
procedures used cor the determination of pesticide residues
in the submitted samples are referenced below.  Specifically
because of the detailed nature of the procedures, only the
principles of the methods developed by the Pood and Drug
Administration are presented below.3

     Bach sample to be analyzed for pesticide residues was
subjected to an extraction and cleanup procedure following.
Sections 212.1 thru 212.17 of the Pesticides Analytical
Manual, Volume 1.  Where require!due to the fat content of
the sample, procedures 211.1 thru 211.12a were followed to
partition the residues between petroleum ether and
acetonitrile.

     The samples were initially extracted with acetonitrile
by blending at high speed for several minutes.  The extraction
mixture was then filtered and the filtrate diluted with
water in a separatory funnel.  Ten ml of saturated sodium
chloride solution was also added at this point.  The  residues
are then extracted into petroleum ether.

     The concentrated residue obtained from the evaporation
of the sample was then subjected to cleanup on a Florisil
Column.  Where the concentrate appeared to contain an
excessive amount of fatty material, the sample was partitioned
between acetonitrile and petroleum ether to remove excess
fat prior to separation on the Florisil Column.  The  various
residues were then eluted from the Florisil Column with mixed
petroleum and ethyl ethers.  The recovered materials  were
concentrated by evaporation, and analyzed by gas Chromatography.
                               226

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     Chemical Methods of Analysis.

     Sample Preparation.  Upon receipt of the individual
subsamples, portions of the sample were removed for
preservation.  When the cyanide,  sulfide, or phenol analyses
could not be started upon receipt,  the samples were
preserved using the procedures outlined under the methods
chosen.

     Sample Analysis.  The following procedures, except
for selenium, are taken directly from Standard Methods
for the Examination of Water and Waste Water, 13th Edition,
American Public Health Association, New York, 1971.4

     .  Moisture—procedure 224G, Method for the
        determination of total residue by evaporation
        on solid and semi-solid samples.
     .  Arsenic—procedure 104A,  Silver Diethyldithiocarbonate
        Method for the determination of arsenic.
     .  Cyanides—procedure 207,  Method for the determination
        of cyanide in wastes.
        Phenols—procedure 222, Sections A,B, and C for the
        determination of phenols in waste.
     .  Selenium—Cummins, L. M., J. L. Martin and D.D.
        Maag.  "An Improved Method for Determination of
        Selenium in Biological Material," Analytical
        Chemistry, 37, 430-31, 1965.
     .  Hexivalent chromium—procedure 307B, Diphenylcarbazide
        cobrimetric method
        Sulfides—procedure 228A, Titrimetric (Iodine)
        method for the determination of sulfides.
                            227

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                       REFERENCES


1.  Manual of Methods Cor Chemical Analysis of Water and
         Wastes, Environmental Protection Agency, 1974,
         EPA 625/6-74-003.

2.  Atomic Absorption Analytical Methods, Jarrell-Ash
         Division of Fisher Scientific Co., Waltham,
         Massachusetts, March 1972.

3.  Pesticide Analytical Manual, Volume 1, Methods which
         Detect Multiple Residues.  U.S. Department of
         Health Education, and Welfare, Food and Drug
         Administration, revised September 1972.

4.  Standard Methods for the Examination of Water and
         Wastewater, 13th Ed., American Public Health
         Association, New York, 1971.
                            228

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                          Appendix C
                    Private Disposal Sites
                   Accepting Tannery Waste
EPA
Region
III
Name, City, State

Middlesex Disposal Co.
Billerica, HA
Burt Shaffer
(617) 884-3208

Charles George
 Disposal Co.
Tyngsborough, MA
Charlie George

Elam Fox Estate
Oley, PA
Type of Tannery
Waste Accepted   Remarks

    Chrome
    fleshings
                                   All
Buffing dust
  sludge
Land
spreading
on
agricultural
crops
         F. R.  & S.  Landfill       All
         Baumstown,  PA
         Mr. Peiffer

         Christman's Landfill      All
         Lenhardtsville, PA
         Dennis Christxnan

         CID Corporation           All
         Calumet City, IL
         Richard Morehouse

         Lake Landfill, Inc.       All
         (Browning-Ferris Ind.)
         Northfield, IL
         Bill Ketter
         Carl Hansen
         (312)  498-0863
                                       Certified by
                                       IL EPA to
                                       accept
                                       industrial
                                       waste.
                                       Leachate is
                                       collected 6
                                       recirculated
         Northeast Gravel Co.
         Rockford, MI
                      Buffing dust
                      & dewatered
                      primary sludge
                            229

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BPA
Region   Name, City, State

         Lauer Landfill
         Washington County* WX
                               Type of Tannery
                               Waste Accepted

                                   All
VZ1
         Wheeling Disposal
          Service
         St. Joseph, HO
         Clay" Buntrocfc
         (816) 279-0815
Primary
sludge
State
permitted
for industrial
waste

Certified by
State to
accept
tannery waste
(clay-
lined trenches)
i pesticide
containers
(landfill)
XX
         American Canyon
          Landfill
         Vallejo, CA
All
                             230

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                           Appendix D
          Methodology for Projecting Waste Quantities
          on a State, EPA Regional, and National Basis


      During the conduct of this study, the following
 methodology was used in order to develop estimates of the
 quantities of the various types of process solid waste
 generated by the tanning industry.  Visits were conducted
 to 41 tanneries during which information was obtained on
 the quantities and the various types of solid waste produced,
 and on the daily production at each tannery (in units of
 hides per day).   Based on the types, quantities, and
 composition of the waste produced at the tanneries visited,
 the tanning industry was divided into seven categories.
      In order to arrive at quantities of solid waste
 produced within each category on a state,  EPA Regional,
 or national basis,  solid waste generation factors (kg per
 unit of production)  were calculated for each tannery
 visited,  and the resulting values were averaged for each
 type of waste generated within each tannery category.  For
 example,  based on the visits  to 22 complete chrome
 tanneries,  it was determined  that the average complete
 chrome tannery generated 114  (wet)/I00 (dry)  kg of
 unfinished leather trim per 1000 equivalent hides
 processed (see Table 17).     Data to permit conversion
 from "hides processed"  to "equivalent hides processed" was
 provided  by the  Tanners'  Council.
      In order to determine  the quantity of solid waste
 currently generated  on  a state,  EPA Regional,  or national
 basis,  each waste generation  factor (developed as described
 above)  was  multiplied by the  production (in equivalent
 hides  per year)  in each area.   The  result  was  expressed
 in metric tons per year.
     Waste  quantity  data for  tanneries  within  a particular
 category  were  reported  by state, groups of states,  EPA
 Regions,  and groups  of  EPA  Regions  in order  to insure
 confidentiality of tannery  production data.  In all  instances,
 individual  state  quantities were reported  where possible
 with the  exception of situations where  EPA Regions would
 have to be  "split," e.g., reporting New York and then
 including New Jersey with another region.
     For  example, Table 23  reports the waste generated by
 sheepskin tanneries in  1974.  In EPA Region  I, Massachusetts,
 and in  Region ill, Pennsylvania, were reported  individually
 because each has more than three sheepskin tanneries. Maine
 and New Hampshire were grouped together because New Hampshire
 has only two sheepskin tanneries.  Similarly, all  (both)
 states  in Region II were grouped together because New
Jersey has only one while New York has 13.  Regions were

                              231

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•grouped together only when absolutely necessary to insure
confidentiality, e.g., EPA Regions XV and VX were
grouped together because Florida has two sheepskin tanneries
and Texas has one.
     In some areas of the country, some tannery waste earn
be sold as a by-product whereas the same waste is land
disposed in other areas, e.g., blue trim and shavi
are currently sold in the Midwest, and to a lesser
along the Bast Coast.  Thus, state and EPA Regional
generation tables reflect these variations, i.e., they
report only the waste requiring land disposal.
     Both total process and potentially hasardoua waste
were calculated using consistent assumptions and
All national totals reflect the sum of individual entries.
     Xn order to predict the quantity of each type of waste
which will be generated in 1977 and 1903, estimates were
made of the percent change expected for total production
for each category of tannery and for the effects of air
and water pollution control on the quantities of particular
types of waste.  Estimates of the percent change anticipated
by 1977 and 1983 for each type of waste (based on these
three considerations) were then developed as a single
factor, which was multiplied by the quantity produced in
1973 in order to estimate the quantity to be produced
for 1977 and for 1983.  A sample calculation is provided
below.

Sample Calculation—Current Annual Solid waste Generation.

Examples  Quantity of unfinished leather trim destined for
          land disposal in Region XX from complete chrome
          tanneries•
          Generation factors  114(wet)/100(dry) kg/1000
          equivalent hides
          Region XX Productions  1,430,000 eq. hides/year
          114 (wet)/100(dry) x 1,430,000 • l«3(wet)/143(dry)
          metric tons/year
          Unfinished leather trim in EPA Region XXs
          163 (wet)/143 (dry) metric tons/year (see Table 18)

Sample Calculation—1977 Projection.

Examples  Unfinished leather trim from complete chrome
          tanneries in Region XX
          Factors i  air pollution control—no effect
                    water pollution control—no effect
                    pr^uction_increaSie—fc 2% (from TCA)
                    TOTAL Brrm^ri  TO .2%
                             232

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          Calculation:   163/143 x 1.062 - 173 (vet)/I52  (dry)
          Results   173  (wet)/152 (dry) metric tons/year
           (see Table 19).
uo1460
                             233

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