ASSESSMENT OF THE IMPACTS
OF INDUSTRIAL DISCHARGES
ON PUBLICLY OWNED TREATMENT WORKS
FINAL REPORT
Submitted to the Environmental Protection Agency
) ASSOCIATES, INC.
A Subsidiary of Science Applications, Inc.
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?5585
ASSESSMENT OF THE IMPACTS
OF INDUSTRIAL DISCHARGES
ON PUBLICLY OWNED TREATMENT WORKS
FINAL REPORT
November 20, 1981
This document has been prepared pursuant to
Directive of Work No. 54 for the
U.S. Environmental Protection Agency
Office of Water Enforcement
401 M Street, S.W.
Washington, D.C.
Prepared by:
JRB Associates
8400 Westpark Drive
McLean, Virginia 22102
Assisted by:
AEPCO, Inc.
Sobotka, Inc.
With Support From:
SCS Engineers
ETC, Inc.
Burns and Roe
EPA Contract No. 68-01-5052, DOW No. 54
JRB Project No. 2-817-03-587-37
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JRB Associates 8400 Westpark Drive, McLean. Virginia 22102 (703)821-4600
A Company of Science Applications. Inc
November 20, 1981
Mr. Thomas O'Farrell
Office of Water Regulations and Standards
Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Dear Mr. O'Farrell:
Enclosed is our final report and accompanying appendices on the impacts
of industrial discharges on POTWs. The document provides a thorough dis-
cussion of the data and methods used in and findings of the project. The
comments of the EPA staff who reviewed the earlier drafts are addressed in
this report.
I think that the modifications we made provide a better framework than
earlier drafts for understanding the complexity of pretreatment issues.
Still, the report is a technical submission. It is not intended to be a
complete Regulatory Impact Analysis although the report addresses most of the
elements of OMB13 RIA directive.
If I can be of any further assistance to you, please call on me. It has
been a pleasure working on this project with you and the other members of the
EPA working group.
Sincerely,
Edward R. Saltzberg, Ph.D.
Business Area Manager
ERS:wd
Enclosure
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TABLE OF CONTENTS
STATEMENT OF THE PURPOSE OF THE PROJECT
1. INTRODUCTION
1.1 COMPARISON OF DIRECT AND INDIRECT DISCHARGES OF
TOXIC POLLUTANTS 1-2
1.2 POTW DEMOGRAPHICS 1-6
1.2.1 Wastewater Flow 1-6
1.2.2 Type of Treatment 1-7
1.2.3 Conclusions 1-11
1.3 DESCRIPTION OF THE NATIONAL PRETREATMENT PROGRAM 1-11
1.3.1 Evolution and Scope of the National Pretreatment
Program 1-12
1.3.2 General Pretreacment Provisions Under 40 C5R 403 1-13
1.3.3. National Categorical Standards for Industry 1-14
1.3.4 Applicability of the Program 1-15
1.3.5 Other Environmental Provisions and Laws Affecting
The National Pretreatment Program 1-16
1.4 AMOUNT OF AND MOTIVATION FOR INDUSTRIAL WASTE CONTROL
CURRENTLY IN PLACE AT POTWs 1-19
1.4.1 Amount of Industrial Waste Control Currently in
Place at POTWs 1-20
1.4.2 Motivation of Industrial Waste Control Currently
in Place 1-21
1.5 STATUS OF PRETREATMENT IMPLEMENTATION 1-22
1.5.1 Municipal Efforts 1-22
1.5.2 State Efforts 1-24
1.5.3 Federal Efforts 1-24
1.6 SUMMARY 1-26
1.7 OVERVIEW OF THE PROJECT 1-28
1.7.1 Purpose 1-28
1.7.2 General Technical Approach 1-29
1.7.3 Limitations of This Assessment 1-35
2. DETAILED ANALYTICAL APPROACH 2-1
2.1 CRITERIA FOR ASSESSING THE IMPACTS OF DISCHARGES FROM
INDUSTRIAL USERS 2-1
2.1.1 Pass-Through and Water Quality 2-2
2.1.2 Interference and Upsets 2-7
2.1.3 Sludge Contamination 2-9
2.1.4 Worker Health and Safety 2-10
2.1.5 Air Pollution 2-11
2.1.6 Groundwater 2-11
•JRB Associates*
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TABLE OF CONTENTS (Continued)
Page
2.2 METHODS OF ANALYSIS 2-11
2.2.1 Analysis of Data Bases Depicting POTW Operations 2-12
2.2.2 Summary of Information from Data Bases 2-21
2.2.3 POTW Modeling Effort 2-25
2.3 BENEFITS INVESTIGATION 2-35
2.3.1 Introduction 2-35
2.3.2 Methodology 2-36
3. ASSESSMENT OF THE NEED FOR CONTROL OF INDUSTRIAL DISCHARGES
TO POTWs 3-1
3.1 WATER POLLUTION 3-2
3.1.1 NPDES Penult Violators 3-2
3.1.2 Exceedances of Water Quality Criteria 3-3
3.1.3 Effluent Improvement Comparison 3-12
3.1.4 Bypass (and Overflow) 3-12
3.2 INTERFERENCE AND UPSETS 3-14
3.3 SLUDGE CONTAMINATION 3-17
3.4 ENVIRONMENTAL AND HEALTH CONSIDERATIONS 3-24
3.4.1 Worker Health and Safety 3-24
3.4.2 Air Pollution 3-27
3.4.3 Groundwater 3-29
3.5 SUMMARY 3-30
4. ANALYSIS OF PRETREATMENT OPTIONS 4-1
4.1 KEY DESIGN CHOICES 4-4
4.1.1 Targeted Versus Untargeted Requirements 4-4
4.1.2 Technology Based-Requirements Versus Water
Quality-Based Requirements 4-4
4.1.3 Regulation of Industry Versus Regulation of POTWs 4-5
4.1.4 Persumptive Versus Back-up Federal Requirements 4-5
4.2 OPTIONS EVALUATED 4-6
4.2.1 The Existing Program 4-6
4.2.2 The Existing Program, But Reduced Scope 4-7
4.2.3 Technology-Based Limits for POTWs 4-8
4.2.4 Water Quality Based Limits for POTWs 4-9
4.2.5 Pretreatnent Required to Address Documented Problems 4-10
4.2.6 Guidance Only 4-10
4.2.7 Waivers 4-11
•JRB Associates.
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TABLE OF CONTENTS (Continued)
Page
4.3 SIMILARITIES AND DIFFERENCES BETWEEN THE OPTIONS 4-11
4.3.1 The Basic 403 Program 4-12
4.3.2 Comparison of Key Design Features 4-12
4.3.3 Coses and Environmental Impacts 4-15
4.4 ENVIRONMENTAL EFFECTS OF THE OPTIONS 4-16
4.4.1 Bypasses, Interference and Upsets 4-16
4.4.2 Removal of Pollutants 4-16
4.4.3 Effectiveness in Reducing Water Quality Violations 4-18
4.5 COST, COST-EFFECTIVENESS AND BENEFITS 4-19
4.5.1 Cost 4-21
4.5.2 Cost-Effectiveness 4-21
4.6 LOCAL BENEFITS OF PRETREATMEOT 4-24
4.6.1 Benefits of Control That Were Not Analyzed 4-27
4.6.2 Benefits Where Exceedances are Eliminated 4-29
4.7 FEASIBILITY ISSUES FOR IMPLIMENTINC PRETREATMENT 4-30
4.7.1 Water Quality Waiver System for Toxics 4-31
4.7.2 Technology-based Toxic Limits for POTWs 4-33
4.7.3 Water Quality-Based Approach for Toxics 4-34
4.7.4 Design Variations for Option 5 4-35
4.8 OTHER CONSIDERATIONS 4-36
4.8.1 Administrative Constraints 4-36
4.8.2 Effectiveness 4-37
4.8.3 Economic Efficiency/MaximizinR Net Benefits 4-37
•JRB Associates*
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LIST OF TABLES
Page
l-l COMPARISON OF DIRECT VERSUS INDIRECT DISCHARGES 1-3
1-2 COMPARISON OF DIRECT AND INDIRECT DISCHARGES OF TOTAL
HEAVY METAL 1-5
1-3 DISTRIBUTION OF POTWs 1-8
1-4 AMOUNT OF FLOW PROCESSED BY POTWs 1-9
1-5 POTW SLUDGE DISPOSAL METHODS 1-10
1-6 CONSTRUCTION GRANTS FUNDS OBLIGATED FOR PRETREATMENT 1-16
1-7 INDUSTRIAL WASTE CONTROL PROGRAMS IN PLACE AT POTWs 1-20
1-8 MOTIVATION FOR IMPLEMENTING A PRETREATMENT PROGRAM 1-21
1-9 POTW PRETREATMENT PROGRAM STATUS 1-23
1-10 STATUS OF STATE PRETREATMENT PROGRAM DEVELOPMENT 1-25
l-ll FEDERAL PRETREATMENT PROGRAM RESOURCE EXPENDITURES 1-27
2-1 STATES AOUATIC HEALTH STANDARDS 2-5 & 2-6
2-2 MAJOR DATA SOURCES USED BY THE COMPUTER MODEL 2-30
3-1 MODEL INDICATORS OF WATER DUALITY VIOLATIONS 3-5
3-2 THRESHOLD DILUTION RATIOS 3-8
3-3 RELATIVE CONTRIBUTION OF INDUSTRIAL AND NOW-INDUSTRIAL
SOURCES TO POTW INFLUENTS 3-10
3-4 DISTRIBUTION OF POTWs BY DILUTION RATIOS 3-11
3-5 PERCENT IMPROVEMENT IN POTW EFFLUENT QUALITY WITH PRETREATMENT
PROGRAM 3-13
3-6 CONCENTRATION OF SELECTED METAL IN SECONDARY SLUDGE FROM
40 POTW STUDY 3-19
3-7 SLUDGE QUALITY WITH AND WITHOUT PRETREATMENT FROM
MODELING EXERCISE 3-20
3-8 PERCENT IMPROVEMENT IN SLUDGE WITH PRETREATMENT PROGRAM 3-21
3-9 REPORTED INCIDENTS OF SLUDGE CONTAMINATION AT 77 POTWs 3-22
-JRB Associates-
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LIST OF TABLES (Continued)
Page
3-10 AVERAGE CONCENTRATIONS OF 11 COMPOUNDS 3-25
3-11 VOLATILES WITH HIGHEST INFLUENT CONCENTRATIONS 3-26
3-12 EXPOSURE CRITERIA FOR HEAVY METALS 3-28
4-1 SUMMARY OF OPTIONS ANALYZED 4-13
4-2 IMPACT OF THE OPTIONS ON ENVIRONMENTAL RESIDUALS 4-17
4-3 EFFECTIVENESS OF THE OPTIONS IN REDUCING EXCEEDANCES 4-20
4-4 TOTAL COST OF THE OPTIONS FOR POTW AND INDUSTRY 4-22
4-5 COST OF THE OPTIONS FOR POTWs EXPERIENCING DIFFERENT
WATER QUALITY PROBLEMS
4~25 & *-2
-JRB Associates.
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LIST OF FIGURES
Page
1-1 WASTESTREAMS AND ULTIMATE REGULATORY ENVIRONMENT 1-38
2-1 COMPARISON OF 132 POTW SUBGROUP TO 2000 POTWs 2-15
2-2 COMPARISON OF 132 POTW SUBGROUP TO 2000 POTWs 2-16
2-3 COMPARISON OF 132 FOTW SUBGROUP TO 2000 POTWs 2-17
2-4 SIMPLIFIED FLOW CHART OF COMPUTER MODEL 2-29
3-1 PERCENTAGE OF POTWs REPORTING MONTHLY SEWAGE BYPASSES
BY AVERAGE DAILY FLOW CATEGORIES 3-15
•JRB Associates.
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STATEMENT OF THE PURPOSE OF THE PROJECT
Scone
The purpose of this project is to evaluate the General Pretreatment
Regulations (40 CFR 403) and a range of possible alternative regulatory strate-
gies in a manner consistent with the intent of Executive Order 1229L. ^In this
evaluation, we examine the need to protect the operations of publicly owned
treatment works (POTWs) from industrial discharges, the potential contamination
of POTW sludge, and the need to control the pass-through of toxic pollutants
specifically included in EPA categorical pretreatment standards for industries.
The General Pretreatment Regulations have two primary coraponencs. The
basic provisions of the regulations direct municipalities to control discharges
which interfere with, bypass or pass-through the POTW.J In addition, they
cover administrative procedures, surveys of industries which use the POTW,
enforcement, and reporting requirements. {The other component of the Regulations
cover delegation to the POTW of Che federal authority to enforce EPA-set toxic
limits for categorical industries^! These two components of the Regulations are
separate and distinct.
Problems related to upset and bypass resulting from industrial discharges
were examined in this study. We were able to analyze the extent of these
operational problems using POTW inspection reports and the findings of visits to
municipalities in other projects. Operational problems can cause the discharge
of untreated wastes into receiving waters and can increase operating costs to
POTWs. These problems were found to be pervasive and a significant motivation
for the development of industrial waste control programs in existence today.
The causes of upset and bypass are highly variable, case specific, and therefore
very difficult to address on a national level. The basic provisions of the
General Pretreatment Regulations require that local programs be developed to
address problems affecting the integrity of POTW operation. Since this basic
403 program calls for a miriimal and flexible local response to address these
operational problems, no alternatives to the basic provisions were evaluated.
(i)
•JRB Associates*
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The emphasis of this study was on Che analysis of Che second component of
the General Pretreatment Regulations — the control of pass-through and sludge
contamination through the application of categorical pretreatment standards to
industries by POTWs. This study focused on four major questions:
1) Does the pass-through of toxic pollutants pose pervasive water
quality problems?
2) Is the uniform application of categorical pretreatment standards
needed to address these water quality concerns?
3) Can a reduced program of categorical pretreatment standards achieve
much of the benefits of the full program at a lower cost?
4) Is the contamination of POTW sludge by toxics a significant problem?
After determining the nature of the environmental problems, alternatives
to the current program were developed. The options range from being based on
national uniform requirements to options whose requirements reflect local
problems and solutions. The options vary in terras of whether Che control
point is at the industry or at the POTW. The options also vary in terms of
the level of federal involvement and reliance on local initiative. Within
the limits of the available data, the costs and benefits of each option were
estimated.
Pretreatment is not an independent environmental program. In itself it
does not directly regulate environmental problems. What it regulates is the
pollution loads in the discharge of industrial users of sewers. Other provi-
sions of the Clean Water Act and the Resource Conservation and Recovery Act
were developed by Congress to regulate environmental quality; mainly through
sludge and water quality criteria and standards. The fact Chat these standards
are not widely accepted in some cases, or have not been finalized in others
is a limitation of this analysis. It is very difficult to assess the environ-
mental benefits of pretreatment without the compliance boundaries established
by other programs being in place.
(ii)
m° Associates.
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1-1
1. INTRODUCTION
Industries may discharge wastewacer into Che Nation's surface waters in
one of two ways - either directly into navigable waters or through publicly
owned treatment works (POTWs). The former are termed direct dischargers; the
latter are called indirect dischargers (or industrial users). POTWs which
receive industrial wastes employ treatment processes in an effort to remove
pollutants and then themselves discharge effluent to surface waters. Congress,
in the Federal Water Pollution Control Act of 1972, and the Clean Water Act of
1977 established separate regulatory mechanisms for these two classes of point
source dischargers. Direct dischargers are subject to effluent standards and
water quality standards applied in limitations set in each firm's NPDES permit.
Indirect waste dischargers are regulated by the General Pretreatment Regulations
(40 CFR 403) and Pretreatment Standards for New and Existing Sources which are
enforced by POTWs receiving industrial wastes or by State or Federal authorities.
This second regulatory program - to control the indirect discharge of industrial
wastes into Che Nation's waters - also known as the National Pretreatment Pro-
gram, is the program under evaluation in this report. Table 1-1 list the 22
categorical industries which are known to discharge toxic pollutants. It is
these industries which are the objects of the program under evaluation.
Pursuant to the recently issued Executive Order 12291, major pending
regulations (among others) must be analyzed to ensure that underlying strategies
chosen maximize net benefits to society. To meet this goal, Regulatory Impact
Analyses (RIAs) are to be prepared which evaluate the costs and benefits of the
alternative strategies examined by the regulations. The General Pretreatment
Regulations, issued on June 26, 1978 and amended on January 28, 1981, were
identified by the President's Task Force on Regulatory Relief/The Office of
Management and Budget for evaluation by the Environmental Protection Agency.
As categorical pretreatment standards and the General Pretreatment Regulations
are mutually interdependent, the focus of this analysis was expanded to encompass
a review of the full National Pretreatment Program with particular emphasis on
che control of toxic pollutants. This document reports the findings of a
•JR8 Associates.
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1-2
project by contractors to provide EPA with technical information important co
the preparation of this RIA. The remainder of this Chapter covers basic
information on 1) The magnitude of the indirect water pollution problem;
2) The characteristics of POTWs receiving industrial wastes and the degree of
toxics control at POTWs; 3) How the National Pretreatment Program regulates
indirect discharge and POTVs; and 4) An overview of the approach used in this
project to evaluate the National Pretreatment Program. Chapter 2 introduces
the criteria for assessing the impacts of indirect discharges and discusses
analytical methodologies used in the project to investigace environmental
impacts, costs, and benefits. Chapter 3 presents findings of the assessment of
the need for control of industrial dischargers to POTWs. Finally, Chapter 4
contains an analysis of the pretreataent alternatives evaluated in this study.
1.1 COMPARISON OF DIRECT AND INDIRECT DISCHARGES OF TOXIC POLLUTANTS
A major rationale for the regulation of both direct and indirect discharges
is their discharge of toxic pollutants - primarily metals and. organic chemicals
- into waters. Table 1-1 provides a perspective of the magnitude of toxic
pollutants discharged by both classes of discharges. It was compiled from data
provided by the Effluent Guidelines Division of the Environmental Protection
Agency (EPA). The table shows annual national estimates of raw wasteloads,
current wasteloads (with the amount of partial controls in place estimated by
EPA), and ultimate wasteloads if all regulations are met [Best Available Tech-
nology, (BAT) regulations for direct dischargers and Pretreatment Standards
for indirect dischargers] for the major industrial sources of toxic water pol-
lutants. Table 1-1, shows that indirect dischargers are responsible for the
generation of 35 percent of the combined industrial output of raw total metal
and organic wastes nationally — 34 percent of the raw wasteload of metals and
36 percent of raw total toxic organlcs. When these calculations are performed
on EGD estimates of the levels of current control In place, indirect dischargers
account for 60 percent of the total metals and toxic organlcs discharges for in-
dustry - 61 percent of all metals and 59 percent of all toxic organic discharges.
At. full controls, indirect dischargers generate 54 percent of total metals and
toxics.
100 Associates.
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1-3
Table 1-1. Comparison of Direct Versus Indirect Discharges*
Indirect Discharge**
Tutai Tout Metals (PoundsiYeerl
M«ta! finishing*
Electroplating
lion and Steal
leattier Tanning
Aluminum Forming
Pulp. Pacer,
PaQerDoard
Inorganic 1 6 II
Porcelain Enameling
Cooper Forming
Organic* 6 Pinna
Textiles
Petroleum defining
Foundries
Cod Coating
Electrical
Benny
MOn Ferrous
Peim
Steam 6r Bactnc
Pesticides
Timber
Ink
P nfl rmscouticBis
Totals
Raw
120.000000
12.000 000f
5. 700.000
8.400000
3.800.000
3.300000
1.400000
970.000
790.000
580000
360.000
1.700.000
360.000
160.000
2.300.000
-
610.000
20000
24.000
8.500
2.000
S3 000
160.000000
Current BAT
32.000000 3.500000
3.100.000 72000
5 700.000 430,000
4.300.000 0
3.800.000 3.800.000
1.400.000 50.000
1.300.000 0
970.000 20.000
707000 79.000
580000 570000
560.000 550.000
330.000 0
210 000 Z10.000
160.000 160 ODD
150,000 0
130.000 10.000
130000 130.000
20,000 2.000
16.000 0
6.200 6.200
1.900 600
-
56.000.000 9.500.000
Direct Discharge
Total Toxic Matali iPoundsrYaar)
Industry
Metai FinohmgS
Electroplating
Iron end Steel
Leatnet Tanning
Aluminum Fonning
Pulo. Paner,
Paparboard
Inorganic 1 & II
PoiuBflin enameling
Copper forming
Organica Gr Planes
Textiles
Petroleum Refining
Foundries
Coil Coanng
Bectncal
Senary
Non Ferrous 1
Paint Forming
Steam & Etectnc
Pesticides
i fniwr
Ink
Pharmaceuticals
Totals
Raw
44.000.000
18.000.000?
530.000
4.500.000
4603.000
7,900000
170.000
580.000
154000.000
470000
1.300.000
11,000,000
4*3.000
82.000
680,000
63,003,000
21.000
700.000
21.000
-
-
23.000
310.000.000
Current BAT
1.500.000 1.500,000
2.400.000 580.000
33.000 18.000
2.800.000 0
2.600.000 2.600,000
700,000 140.000
260,000 0
590,000 20.000
7, tOO 000 2.700,000
380,000 220,000
560000 280000
1,700,000 0
260,000 0
62000 62.000
200,000 —
14.000.000 0
3.900 500
700.000 20.000
11,000 1.000
- -
-
11.000
38.000.000 8.100.000
Total Toxic Organic* (Pounds/Year)
Raw
98000000
2S.OOO.OOO
532.900
1. 000,000
-
-
-
171.000000
1,050.000
2.000,000
220.000
3.300
313.000
103
1.600
300,000
-
240,000
110.000
8.900
-
300.000.000
Total Taxi
Raw
33.000.000
25.000.000
90000
-
8.600,000
-
-
-
447.000.0CO
710.000
5.900000
1. 400.000
4.000
104.000
77
i9.ooo.om
33.000
-
320.000
—
-
-
S40.000.000
Current
26.100.000
7.200.000
580.000
210
1,000.000
—
—
-
154.000000
1,050,000
2.000.000
60000
t.900
230,000
90
630
40.000
-
240.000
15,000
1300
-
t90.000.000
BAT
12.100 000
1.3X000
580.000
to
1,000.000
—
—
—
43.000000
t. 050.000
2.000.000
—
1 900
60.000
1
620
39000
-
30,000
45 COO
1.300
—
61000.000
« Organic* (Pounds/ VearJ
Currant
9600000
4.800.000
15.000
410
620.000
-
—
-
112.000000
85 000
20.000
390,000
2.400
99,000
73
6.300,000
1,300
-
15.000
—
-
-
130000.000
BAT
4000.000
260.000
4.000
250
520.000
—
—
—
45.000 000
52.000
10.000
0
0
19.000
0
600.000
1300
—
1.000
"•
—
-
50000000
•Does not ineiuaa Peragraoh 8 subcategones. and based on EPA oroiections
"Loadings are estimation ot pounds discharged
TRerers to 1972 discharge
into sewers prior 10 treatment at ihe POTW
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1-4
Table 1-1 also demons traces that, la gross terms, the metal finishing/
electroplating industry Is the greatest contributor of toxic pollutants vis-a-
vis other indirect dischargers. This fact was the basis Ear EPA's promulgation
of categorical standards for the electroplating industry as the first pretreat-
aent standard to be issued. It is also the reason for the Agency's selection
of a "metal finishers only" pcetreatment option for evaluation later in this
report.
The discharge from industrial users receives further treatment by the FOTW.
Although municipal treatment works are rarely designed to process toxic pollu-
tants, there is a significant amount of incidental removal of toxics by POTWs.
Metals removed from the Influent of POTWs concentrate in the sludge and toxic
organics volitalize or are decomposed by the facility's biological treatment
processes. At secondary treatment plants a representative removal efficiency
for metals is 60 percent and 79 percent for toxics (see Appendix C-2). Accord-
ingly, much of the mass of metals and organics in the discharge from industrial
users does not reach surface waters. Table 1-2 reports the actual fate of
metals generated by indirect dischargers* It was prepared by applying the
representative secondary treatment removal efficiency for metals to the data
In Table 1-1. (For comparison, Table 1-2 also lists the fate of metals generated
by direct dischargers.)
As pretreatment implementation advances to full controls under 40 CFR 403
the metals discharged to surface water through POTWs and concentrated in muni-
cipal sludge decreases drastically. Metal concentrations in industrial sludges
increase a like amount. In many respects the value of pretreatment is determined
by the relative importance of the distribution and fate of pollutants generated
by industrial dischargers.
.JRB Associates.
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1-5
TABLE 1-2
COMPARISON OF DIRECT AND INDIRECT DISCHARGES
OF TOTAL HEAVY METAL
Degree of Industrial Treatment
(Ibs/yr x 1,000,000)
Fate of
Pollutant
Industrial Waste-
water
Waterbody
Industrial Sludge
Municipal Sludge
Industrial Waste-
water
Industrial Sludge
Raw Current
Indirect Contributions*
160 56
64 22
104
96 34
Direct Contribution
312 35
277
403
9
4
151
5
(BAT)
8
304
* Assumes that POTW removes 602 of the metals from the industrial wastewater
which is concentrated In the municipal sludge.
•JRB Associates.
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1-6
Tables l-l and 1-2 provide an overview of the magnitude and relative impor-
tance of toxics contributions from indirect dischargers but do not allow mean-
ingful estimates to be derived for the environmental impacts of these wasteloads.
The volume and relative mix of toxic wastes from indirect discharges received
by POTWs varies from plant to plant, as does the POTW's removal efficiency,
its level of wastewater treatment (primary, secondary, tertiary) and the char-
acteristics of the POTW's receiving waters. These variables are the key deter-
minants of the environmental impacts of indirect toxic discharges. The majority
of our effort on this project has been to collect data and develop modeling
tools which allocate these pounds of toxic pollutants to POTWs in a realistic
manner to allow an estimation of the impacts they have on water and sludge
quality at municipalities. These impacts were then aggregated back to the
national level to allow conclusions to be made on the National Pretreatment
Program and other regulatory alternatives to control the indirect discharge or
t oxic po 1 lut ant s .
1.2 POTW DEMOGRAPHICS
The preceding discussion introduced the industrial waste component of the
pretreatment program. The second major group of regulatees under the general
Pretreatment Regulations are the POTWs which receive industrial wastes. The
following section presents basic information on Publicly Owned Treatment Works
to provide a background understanding of their aggregate physical characteris-
tics and the impacts that industrial wastes may have. These characteristics
include wastewacer flow, industrial flow, sludge handling methods and level of
treatment.
1.2.1 Wastewater Flow
There are 15,250 complete wastewater treatment facilities1 in the U.S.
today. These 15,250 POTWs have a total influent flow of approximately 26
1 Although there are 32,000 municipal waste handling systems in the coun-
try, only 15,250 treat wastewater and produce a sludge. The remaining include
septic systems, pumping stations or sludge handling facilities.
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1-7
billion gallons per day (bgd) and a total industrial flow of 4.4 (bgd). The
2,000 POTWs estimated by EPA to need pretreatment programs treat 81 percent
(21.1 bgd) of the total national flow and 91 percent (4 bgd) of the national
industrial flow to POTWs. Sixtj^ pejreent oLthe industrial flow is frora _cate-
go_rjxa-t—industries, the rest of the industries flow is attributed to non-cate-
gorical or commercial sources. Most of Che industries in the country subject
to the categorical pretreatment standards discharge to the POTWs regulated
by the General Pretreatment Regulations. Table 1-3 summarizes key physical
charateriscics of the POTWs subject to the pretreatment regulations.
POTWs handle their treated effluent discharge in the following manner:
• 83.6 percent of the total flow or 17.6 bgd goes to surface waterbodies,
• Of those planes discharging to surface waterbodies, 36 percent or 15.1
bgd goes to rivers and streams, the rest to lakes and bays,
• 12.1 percent of the total flow or 2.5 bgd is discharged to the ocean,
• The remaining discharge is distributed among a number of disposal
alterations, including:
- groundwater recharge and deep well injection
- irrigation and land disposal
- recycling and holding ponds.
• 60% of plants (1189) have less than 15 percent industrial flow.
1.2.2 Type of Treatment
Three types of treatment systems are commonly used at POTWs. Primary
treatment is a physical sedimentation process for removing settleable solids,
secondary treatment is a physical/biological process for removing solids, BOD,
and pH, and tertiary treatment is a process which accomplishes secondary treat-
ment with an additional capability to remove or alter other pollutants.
Table 1-4 shows the amount of flow processed by POTWs and indicates the
average efficiency of primary, secondary and tertiary treatment. Most municipal
waste receives secondary treatment.
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TABLE 1-3. DISTRIBUTION OF POTWS 3Y AVERAGE DAILY FLOW
iVER.
3AILY
0-1
MCD
1-5
MCD
5-20
MCD
20-50
».G3
50-100
".CD
> 100
.MCD
TOTAL FLOW
INDUSTRIAL FLOW
SO. OF PLANTS
TOTAL nOW
INDUSTRIAL FLOW
SO. OF PLANTS
TOTAL nOW
INDUSTRIAL FLOW
:io. OF PLAHTS
TOTAL now
INDUSTRIAL FLOW
HO. OF PLANTS
TOTAL nOW
INDUSTRIAL nOW
SO. OF PLANTS
TOTAL FLOW
INDUSTRIAL FLOW
SO. OF PLANTS
0-15
153
3
373
1.070
41
422
2.717
123
292
1.690
116
37
1.609
108
22
2,366
192
13
13- iO
16
3
32
134
23
59
439
79
43
249
43
10
313
56
5
1.436
235
4
: s D c
:o-30
19
-
37
ISO
4}
73
633
174
57
628
157
19
:39
68
4
1.752
i04
7
3 i X I •
30—0
15
5
30
116
41
47
567
200
53
306
111
11
352
119
5
1.153
394
6
4J-50
6
3
16
113
51
42
263
120
25
279
126
9
' 293
123
»
122
49
•
F L 0 «
so-ioo
17
12
34
213
148
36
321
225
36
526
356
17
32
52
L
—
—
0
TABLE 1-3 (Continued) DISTRIBUTION OF POTWS BY LEVEL OF TREATMENT
PERCENT
INDUSTRIAL
FLOW
0-15
15-20
20-30
30-40
40-50
> 50
F
NO. OF
PLANTS
228
26
25
16
16
32
R I M A R V
TOTAL PLOW
(MGO)
2960
786
761
187
388
La&
INDUSTRIAL
?LOU
(MCO)
198
131
201
64
167
13S
S E
NO. OF
PLANTS
914
119
166
131
78
133
c o a o A R
TOTAL T.OU
IMCD)
6831
1720
2597
2201
667
379
Y
INDUSTRIAL
F10W
(HGD)
360
292
628
765
297
597
T
NO OF
PLANTS
47
3
16
5
3
lŁ
E R T I A R \
TOTAL FLOW
(MCD)
fcLB
34
93
119
lit
96
INDUSTKl
FLOW
(MCD)
25
16
23
41
12
al
"•
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Table 1-4
Z of Flow Flow (bgd)
Primary 25 5.3
Secondary and 71 15.0
Advanced Secondary
Tertiary 4 0.8
The cable shows Chat although secondary treatment is most common, much of the
nation's industrial flow only receives primary treatment. Twenty-five percent
of the total flow is processed by primary treatment plants. This is significant
because secondary plants remove 70 percent of the toxic pollutants on average
by incidental removal, while at primary plants only 35 percent of the toxics are
removed.
Five major sludge disposal technologies are commonly used by POTWs; incin-
eration, landfilling, land spreading, trenching and ocean dumping. Table 1-5
depicts the amount (in tons/year) of sludge disposed by primary, secondary and
tertiary treatment facilities for each disposal method. Sludge quality numbers
vary tremendously from one plant to another, making it difficult to estimate a
representative sludge concentration value for each type of treatment. However,
because of the differences in removal efficiences, the sludge generated at sec-
ondary plants will contain more toxic pollutants than that generated at primary
facilities. Five times as much sludge is generated at secondary plants than
at primary plants.
The aggregate characteristics of POTWs measured by total flow, percent
industrial flow and level of treatment do not vary significantly among EPA
regions. Where this similarity ends is in sludge disposal methods and method
of liquid effluent disposal. Ocean dumping of sludge and effluent is confined
to coastal States. Irrigation occurs mostly in Arizona, Nevada, New Mexico
and California.
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TABLE 1-5
POTW SLUDGE DISPOSAL METHODS
Tons/Year
Incineration
Landfill
Land Spread
Trenching
Ocean Dumping
Total
(Number of
Plants)
(230)
(1163)
(481)
(4)
(300)
Primary
193,791
250,849
15,445
794
133,567
594,446
Secondary
772,915
1,463,593
254,638
18,386
256,384
2,776,866
Tertiary
100,726
164,607
30,221
-
-
295,554
Total
1,121,132
1,879,049
300,304
19,630
400,451
3,666,866
*Some plants use more than one disposal method, this is reflected in double
accounting of the disposal alternatives.
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1.2.3 Conclusions
The following conclusions can be drawn from assessing POTW demographics
for the 2,000 POTWs estimated to need pretreatment:
• The 2,000 POTWs estimated to have pretreatment account for 81 percent
of the total POTW flow in the nation and 91 percent of the total
POTW industrial flow.
• Most of the industries subject to categorical pretreatment standards
discharge to the 2,000 POTWs.
• 1,441 of the 2,000 POTWs are at secondary treatment.
• Primary treatment plants process 25 percent of the total flow for the
2,000 POTWs.
• 84 percent of the total flow from the 2,000 POTWs is discharged to
non-marine surface water bodies.
• The total volume of sludge generated by secondary treatment plants
is 5 times the amount generated by primary plants.
• In general, sludge generated at secondary plants contain more toxics
than that generated by primary treatment facilities.
o -49 percent of the total flow from the 2,000 POTWs falls in the range
of 0 to 15 percent industrial flow. Although this range seems low,
it is strongly influenced by the largest cities (>200 mgd) which
have a low percentage of industrial flow even though they have a
large number of industrial discharges. Support for this finding
appears in Appendix A (under separate cover).
• Small plants (those under 5 mgd) typically have more than 25 percent
Industrial flow.
1.3 DESCRIPTION OF THE NATIONAL PRETREATMENT PROGRAM
In 1972, Congress cited the need for a national mechanism to protect POTWs
and the environment from various problems associated with industrial wastewater
discharges to municipal sewers. Through Section 307 of the Federal Water Pollu-
tion Control Act, Congress directed the EPA Administrator to establish waste-
water discharge standards for Industrial users of publicly owned treatment works
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(POTWs) "to prevent Che discharge of any pollutant through treatment works...
which pollutant interferes with, passes through, or is otherwise incompatible
with such treatment works." Incompatibility applies to both wastewater dis-
charge quality and the sludge. The following discussion examines the evolution
and workings of the current federal regulatory approach for the control of
industrial wastes at POTWs receiving industrial wastes which constitutes the
National Pretreatment Program. The requirements and procedures of the General
Pretreatment Regulations (40 CFR403), and Categorical Pretreatment Standards,
are presented in this section along with the interrelationships of these regula-
tions with other Clean Water Act provisions and environmental statutes. This
section is intended to establish the regulatory backdrop for the subsequent
analyses of alternative pretreatment programs, and define the method of analysis
used in this study. More detailed legal and programmatic information is avail-
able in Appendices A-2 and A-4.
1.3.1 Evolution and Scope of the National Pretreatment Program
The initial strategy to control industrial discharges to POTWs was detailed
by EPA in the original pretreatment regulations (40 CFR 128 in 1973). These
provisions required major industrial dischargers to comply with effluent guide-
lines (established by EPA) defining best practicable treatment for the removal
of pollutants incompatible with the operation of POTWs. Technological uncer-
tainties and administrative delays hindered EPA's promulgation of guidelines
and standards and in 1976 EPA was sued by several environmental groups. The
Toxics Settlement Agreement^ which—resulted from this suit (NRDC v. Train 12
ERC 1833) required EPA to develop a program and adhere to a schedule for pro-
mulgation of Best Available Technology (BAT) effluent limitations and pretreat-
ment standards for 21 major categories of industries covering 65 "priority"
toxic pollutants. This national and uniform approach for the control of
toxic pollutants was incorporated into the Clean Water Act (CWA) of 1977,
which amended the Federal Water Pollution Control Act.
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The 1978 General Pretreatment Regulations (40 CFR 403) revised Che 1973
provisions and were issued Co provide a framework and delineate responsibilities
Cor Che application of pretreatraent standards. A range of alternative pretreat-
menc strategies were considered during this regulations-developtnene process.
The alcernatives varied in terms of Che extent to which industrial users of POTWs
would be controlled by national technology-based pretreacment standards, the
amount of local flexibility allowed, and the relative roles of the federal,
State, and local governments. The approach finally selected in the General Pre-
treatment Regulation (40 CFR403, June 26, 1978, amended January 28, 1981) places
principal authority for implementation and enforcement with municipalities.
Municipal responsibilities under the General Pretreatment Regulations are
essentially two-fold:
• General responsibilities to protect plant operations and local envi-
ronmental quality.
• Specific respoasibiiites to implement and enforce national categorical
standards.
These responsibilities which are separate and distinct, are discussed in the
following two sections.
1.3.2 General Pretreatmetit Provisions Under 40 CFR 403
This responsibility entails the development and implementation of an admin-
istrative program to deal with the site-specific and unique problems that the
POTW experiences due to non-domestic contributions of conventional and other
pollutants which interfere with or upset the operation of the POTW. The 403
Regulations contain generic "prohibited discharge standards" for such parameters
as pH, corrosivity, flammabiiity, and heat to assist POTWs in protecting plant
operations. Under the 403 program, municipalities are required to survey
industrial users and identify the types and volumes of industrial pollution
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chey receive. Industrial waste-related plant problems are to be analyzed and ef-
fluent limitations are to be developed to .protect the POTW from prohibited dis-
charge. Mechanisms for permitting, monitoring, and enforcement must be designed
and administered to implement controls on industrial discharges of detrimental
conventional wastes. POTWs then work with existing industrial users to bring
about the installation of pretreatmenc technologies, process changes, or the
like to control deleterious discharges. (In contrast, categorical industries
must comply with Federally-set pretreatment standards.) New industrial con-
tributors may be required to incorporate pretreatment in the facility design
before being allowed to connect to the POTW system. Monitoring is performed
to assure compliance. Where violations are found, enforcement actions are to
be brought.
1.3.3 National Categorical Standards for Industry
Two separate regulatory mechanisms were established for indirect discharg-
ers in the CWA. Section 307(b) of the Act requires EPA to promulgate pretreat-
ment standards for existing sources (PSES) which must be met within three years
of promulgation. Section 307(c) requires pretreatment standards for new sources
(PSNS). Both sets of standards deal primarily with toxic pollutants and are
to prevent the discharge of pollutants which pass-through, interfere .with, or
are otherwise incompatible with the operation of POTWs.
The Settlement Agreement and .§307 of the Clean Water Act establish a parity
between direct and indirect dischargers in the control of priority pollutants.
Categorical pretreacment standards require pollution reduction such that the
combination of industrial pretreatment and treatment at the POTW are equal to
the pollution reduction attained by a direct discharger meeting BAT standards.
The designation of industries for which standards must be developed was recate-
gorized by EPA to cover 34 industries.
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Firms In these categorical industries are believed by EPA to be the major
sources of toxic pollutants. They contribute about 60 percent of the volume of
industrial wastes to POTWs. EPA does not establish specific discharge standards
for firms in non-categorical industries because they are not major sources of
toxics. However, these firms can be regulated locally under the general prohibi-
tions of the General Pretreatment Regulations.
To date, two sets of pretreatment standards have been developed — one for
the electroplating industry and the the other for the timber products processing
Industries. The electroplating standards (40 CFR 413) were first issued on
September 7, 1979, have gone through three revisions, and were amended on
January 28, 1981. Certain portions of the electroplater regulations pertain-
ing to captive facilities, as opposed to the smaller job shops, are not yet
in effect. The timber products processing pretreatment standards (40 CFR 429)
were issued on January 26, 1981.
A major role for municipalities required to have 403 programs is to imple-
ment and enforce PSES's and PSNS's for categorical industries discharging to
their POTWs. Categorical industrial users, identified in the industrial waste
survey, must be apprised of the existence of national pretreatment standards
by the control authority. The administrative devices of local pretreatment
programs discussed above may then be applied to assure compliance. In addition,
POTWs may apply for removal credits which, if approved by EPA, may be passed
on to categorical industrial users.
1.3.4. Applicability of the Program
Two groups of POTWs must develop programs under the General Pretreatment
Regulations. POTVs with total flows greater than 5 million gallons per day
(mgd) and which receive wastes from industries subject to national pretreatment
standards must develop and operate pretreatment programs. Compliance schedules
have been inserted into the discharge permits issued to these POTWs to ensure
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Chat they will have programs Ln place by July 1, 1983. These permits are issued
under EPA's National Pollutant Discharge Elimination System (NPDES). POTWs with
total flows less than five ragd may also be required by EPA to establish programs
where warranted by special problems with industrial discharges. NPDES States
(with EPA approval to issue NPDES permits) which develop approvable State pre-
treatraent programs receive full NPDES delegation to oversee pretreatment activ-
ities in their States. NPDES States may also choose to operate State-wide pro-
grams and assume implementation and enforcement authority in lieu of municipal-
ities. EPA Regional offices will implement and enforce pretreatment in non-
NPDES States and in NPDES States rejecting pretreatment delegation.
1.3.5 Other Environmental Provisions and Laws Affecting The National Pre-
treatment Program
Categorical pretreatment standards afford a mechanism for the control of
the pass-through of toxics at POTWs, while the 403 program regulates conventional
pollutants and provides an overall administrative framework for implementation
and enforcement of the National Pretreatment Program. Other Clean Water Act
provisions and environmental statutes provide further financial or environmental
incentives for the control of industrial wastes by pretreatment. These provi-
sions are discussed below.
1.3.5.1 Financial Incentives under the Clean Water Act
The Federal government provides financial incentives to POTWs for develop-
ment of pretreatment programs by underwriting 75 percent of development costs
in §201 construction grants. As shown in Table 1-6, almost 40 million dollars
has been obligated in municipal construction grants for pretreatment since 1977.
TABLE 1-6
CONSTRUCTION GRANTS FUNDS OBLIGATED FOR PRETREATMENT ($THOUSANDS)
(See Appendix A-4 for Data Sources)
EPA Region I II III IV V
Grant $ Total 2,500 11,221 4,874 1,245 9,240
EPA Region VI VII 7TII IX X
Grant $ Total 3,352 2,041 . 331 2,348 1,800
TOTAL: $38,952
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States may also be eligible for §201 grants for pretreatment. In addition,
§106 grants and §205(g) allotments may be used to administer State pretreatment
programs.
1.3.5.2 Performance Standards for POTWs
A variety of standard setting and enforcement provisions in the Clean Water
Act encourage the application of pretreatment to control industrial wastes at
POTWs. The NPDES program, §402 of Che CWA, requires Chat poinc sources, includ-
ing POTWs which discharge to navigable waters, must obtain permits. Written
into POTW NPDES permits are plant-specific effluent limitations to assure
that the facility complies with applicable technology-based performance stan-
dards [Secondary Treatment by 1977 and Best Practical Waste Treatment Technology
by 1983 §§201(g)(2)(A), 301(b), and 304(a)] as well as pretreatmenr standards.
In addition, the NPDES permit is the vehicle for imposition of limits to meet
stream-based State or federal water quality standards. These two sets of
standards, applied in a POTW's permit, dictate the level of pollution reduction
which must be achieved by a municipality. To date, however, the focus of
these standards has been on conventional pollutants, very few POTWs have toxic
effluent limits in their NPDES permits. Data from a study of 132 POTWs by JRB
suggests that between 70 to 80 percent of POTWs subject to 40 CFR 403 do not
have NPDES permit limits for heavy metals or toxic organic chemicals (see
Appendix B-2).
1.3.5.3 Provisions to Control Sludge Quality Under the Clean Water Act (CWA)
and Resource Conservation and Recovery Act (RCSA)
Categorical pretreatment standards and the National Pretreatment Program
have also been intended to prevent sludge contamination at POTWs, and are there-
fore closely tied to municipal sludge disposal requirements established under
§405 of the Clean Water Act and §4004 of the Resource Conservation and Recovery
Act (RCRA). Any industry discharging pollutants which would interfere with a
POTWs ability to meet §405 disposal guidelines must pretreat its wastes. The
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issuance of removal credits is also tied to the POTW's ability to comply
wich §405 criteria.
Under joint authority of the Resource Conservation and Recovery Act (RCRA)
and §405, limits have been set on the amounts of cadmium and PCBs which may
be in solid wastes intended for application on lands used for production of
food chain crops. These regulations at 40 CFR 257 also provide guidelines for
disposal of sludge incinerator ash and sludge in landfills, surface impound-
ments, and by land spreading. EPA has also issued a preproposal draft under
§405 to regulate the distribution and marketing of sludge and sludge products
as fertilizer or a soil conditioner. Extensive development remains to be done
to define Che safe limits and regulate the disposal of sludge containing any of
the other 129 priority pollutants. Pretreatment is the principal means for
reducing toxicity levels in municipal sludges.
1.3.5.5 Constraints Imposed by Other Statutes
Reduction of industrial wastes at POTWs by requiring pretreatment is also
intended to ease POTW compliance burdens vis-a-vis other environmental statutes.
The Clean Air Act requires POTWs choosing tc incinerate or dry their sludge to
meet National Ambient Air Quality Standards (NAAQS) and New Source Performance
Standards (NSPS) for sulfur dioxides, particulate matter, carbon monoxide,
hydrocarbons, nitrogen dioxide, ozone and lead, and National Emission Standards
for Hazardous Air Pollutants (NESHAPS) for mercury. Further, the Toxic Sub-
stances stances Control Act under the PCB regulations specifies incineration
practices for sludges containing certain levels of PCBs. As sludge quality
improves as the result of a pretreatment program, the cost and efforts needed
Co meet air standards should decline.
The ban on ocean dumping.of municipal sludges, for cities not meeting dis-
posal criteria, to take effect in December of 1981 under the Marine Protection
ResearehTnd^§anctuaries Act, has had the effect of forcing municipalities to
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find alternate sludge disposal methods. The improvement of sludge quality af-
forded by pretreatment has eased this transition for cities such as Philadelphia.
The Safe Drinking Water Act establishes maximum contaminant levels for sub-
stances ,such_as heavy metals in drinking water. POTWs may affect drinking water
sources in a number of ways. A considerable portion of the Nation's drinking
water sources are surface waters into which POTWs discharge. Reduction in
toxics discharged to these waters should ease the water treatment obligations
of municipalities. Leaching of toxic pollutants from municipal sludges to
groundwater will also be reduced as sludge quality is improved.
An area lacking any regulatory protection ouC3.ide_the pretreatraent program
is wo_rker_health_and safety at the POTW. The Occupational Safety and Health
Act specifically exempts national, State, and local governments from its defini-
tion of an employer. Thus POTW workers are not protected from job-related
health or safety hazards under OSHA. Similarly, State OSHA laws do not provide
any mechanism affording sewage treatment workers protection from industrial
slug loads of toxic chemicals. The pretreatment program may play an important
role in the absjence__of _other xwrprker_health_and safety protection. This issue
is further addressed in Appendix B-4.
1.4 AMOUNT OF AND MOTIVATION FOR INDUSTRIAL WASTE CONTROL CURRENTLY IN PLACE
AT POTWs
As mentioned above, EPA has identified approximately 2,000 POTWs which
either receive categorical industrial wastes or are experiencing other in-
dustrial waste related problems, and therefore will be required to develop
local pretreatment programs under the General Pretreatment Regulations. To
understand the magnitude of the compliance burden the General Pretreatment
Regulations impose on these 2,000 POTWs, and to evaluate the need for federal
regulatory stimulation to achieve waste control at POTWs a study was performed
of 132 municipalities (statistically representative of the 2,000) to determine
the extent to which industrial waste control programs are already in place.
Additionally, the motivation for the development of local programs already in
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existence was explored. The section presents summary results on these ques-
tions. Further information is provided in Appendix B-3.
1.4.1 Amount of Industrial Waste Control Currently in Place at POTWs
Table 1-7 summarizes data based on a study of 132 POTWs which are repre-
sentative of the 2,000 POTWs and indicates that only 25% of these 2,000 munici-
palities have the essential mechanisms in place to control industrial wastes.
These mechanisms defined by JRB as essential to a basic POTW industrial waste
control program include (1) the existence of a sewer use ordinance with specific
effluent limits, (2) some form of permitting mechanism, and (3) a monitoring
and enforcement program. (It should be noted that this 252 figure does not
represent formal pretreatment programs under the 403 program, but rather muni-
cipalities having the three fundamental elements of a control program. Section
1.5 presents estimates of the number of federally or State-approved 403 programs
in place today.)
TABLE 1-7
INDUSTRIAL WASTE CONTROL PROGRAMS IN PLACE AT POTWS
Item
POTWs with
>5 MGD Flow
POTWs with
<5 MGD Flow
Total
Pretreatment In
Place (ordinance,
permits and enforcement)
Yes
No
Unknown
a - 65
312
66%
n •
67
18Z
75Z
7Z
n » 132
25S
70%
5%
Other indicators of the extent of and motivation for effective industrial
waste control programs may be drawn from the 132 POTW study. For instance, in
order to control industrial influents, a POTW must first identify the sources,
magnitudes, and characteristics of Che industrial wastes it receives. The 132
Study further indicates that (as of March 1981) 64 percent of the POTWs have
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conducted an industrial waste survey (IWS). However, a majority of these cities
completed their IWS within the last three years. This suggests that the federal
pretreatment program is a primary motivation for two reasons. First, an IWS is
required in the 403 program. Second, 403 provides financial incentives for local
program development. Additionally, sixty-six percent of the POTWs examined do
not monitor for heavy metals in their influent and 69 percent do not monitor
for the presence of toxic organics. A study by JRB of 77 POTWs (See Appendix B)
reinforces these findings. Sixty-eight percent of these POTWs have no indus-
trial monitoring programs. Of those that do monitor, only 12 percent monitor
for metals and I percent for toxic organics. Finally, 30 percent have no
knowledge of the quality of their sludge.
1.4.2 Motivation of Industrial Waste Control Currently in Place
As estimated above, about 25% of the 2,000 POTWs subject to the General
Pretreatment Regulations have industrial waste control mechanisms in place.
Table 1-8 presents reasons cited by municipalities for instituting this indus-
trial control. (Multiple responses were given by some cities and others did
not respond.) The primary reason given by POTWs was that the program was
required either by the State or Federal Government. The second most frequently
cited reason was to protect the POTW from harmful wastes. Sixty-five percent
of the programs were motivated by these two reasons.
TABLE 1-8
MOTIVATIOH FOR IMPLEMENTING A PRETREATMENT PROGRAM
Motivation
POTW cost recovery
POTW protection
Sludge Quality Improvement
Water Quality Improvement
Required by State/Fed Authority
POTW Worker H & S
No response
n - 81
13 Z
24%
9%
9%
38Z
IZ
6%
= 43 n • 124 responses
^^•^•^•B ^Biaai^pi^^^^^^^^HMMaA^^BB^^H^^
0 8%
30% 27%
2% 6%
7% 8%
37% 38%
0 IZ
24% 12%
Where pass through and operational problems at POTWs contribute to a water
quality problem, control of toxics from industrial users may be necessary. The
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relative significance of government intervention in bringing about controls
suggest the importance of some form of government involvement to stimulate
toxics control where environmental problems exist. The determination of this
need and an assessment of alternatives programs to meet it is the subject of
Chapters 2, 3 and 4 of this report.
1.5 STATUS OF PRETREATMENT IMPLEMENTATION
As discussed above, The National Pretreatment Program relies on an inter-
governmental, three-tiered administrative system involving the Federal govern-
ment, States, and municipalities for the development and enforcement of
categorical and prohibited pretreatmenC standards. The following section
summarizes the progress that has been made by each in implementing these
responsibilities to date.
1.5.1 Municipal Efforts
First line responsibility rests with municipalities required to develop
and operate programs under the General Pretreatment Regulations. Approximately
2,000 POTWs have been identified by EPA as requiring formal programs. Table 1-9
estimates the implementation progress that has been achieved to date by
these municipalities. The table shows that 138 POTWs or 9 percent of the muni-
cipalities subject to the Regulations have applied for approval or are imple-
menting formal pretreatment programs. Further, substantial progress toward
approval has been made by 79 percent of POTWs larger than 5 mgd and 45 percent
of chose POTWs under 5 mgd which oust develop programs.
Municipalities have spent about 34.9 million dollars in local revenues
and Construction Grants to reach this point. (Table 1-6 indicates that 38.9
million dollars have been obligated for pretreatment. This figure also includes
funds spent by States from S201 grants.) A liberal estimate of the total money
needed to develop municipal pretreatment programs is 45.8 million dollars (see
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CD
TABLE 1-9. POTW PRETREATMENT PROGRAM STATUS
PRETREATMENT PROGRAM STATUS
DESIGN TOTAL 0 tf POTW'S # POTW'S * POTW'S APPLIED FOR # POTW'S EST. DEV'T COSTS
FLOW (MOD) POTW'S NO ACTION PLANNING DEVELOPING APPROVAL IMPLEMENTING NO DATA TO DATE ($ MILLIONS)
0<5 1261 714 301 76 38 38 94 5.696
5 > 735 143 245 2J6 79 33 19 29.204
TOTAL 1996 857 546 292 117 71 113
h-
1
34.900 "
PERCENTAGE 100 43 27 15 6 3 6
See Appendix A-4 for sources.
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Appendix A-2 for estimation techniques). Accordingly, municipalities have
spent 76 percent of the funds necessary to develop pretreatment programs.
1.5.2 State Efforts
NPDES States may assume responsibility for development and operation of a
State-wide pretreacment program, by submitting a program plan and having it
approved by EPA. NPDES pretreatment delegation entitles the State to identify
POTWs needing programs, review and approve local programs, conduct compliance
monitoring, and initiate enforcement actions. Of the 33 NPDES States, 32 could
currently receive delegation for State pretreatment programs. (The Virgin
Islands was deemed by EPA not to need a pretreatment program.) Table 1-10
shows that to date 8 States or 25 percent of the total have had their programs
approved, and 12 others have made substantial progress in obtaining programs
and are close to receiving delegation, comprising almost 63 percent of eligible
States.
New Jersey, West Virginia, and Puerto Rico are currently applying for
overall NPDES delegation and are developing pretreatment plans as a part of
their applications. Hence, twenty-three of the soon to be thirty-five eligible
States have received or are in the process of applying for NPDES pretreatment
delegation. Collectively, eligible States have spent $3.4 million out of an
estimated total of $5.9 million or 58 percent of the amount that would be
required for full State assumption of pretreatment responsibilities. (For-
greater detail, see Appendix A-4).
1.5.3 Federal Efforts
Federal activities in the National Pretreatment Program range from cate-
gorical standard development by the Effluent Guidelines Division of the Office
of Water Regulations and Standards, program implementation and assistance by
the Permits Division of the Office of Water Enforcement, financial support from
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TABLE 1-10
STATUS OF STATE PRETREATMENT PROGRAM DEVELOPMENT
Program Approved (AL, MN, WI, GA, OR, MO, IA, CT) 3
Reviewed in Headquarters by Permits and OGC - further action delayed by 4
issues referred to State (MS, NV, SC, VT)
Submitted to Region
- Program changes needed by the State (TN, NB, KS, IL, NY) 5
- Changes needed in MOA - Program complete (NC) 1
Draft submission received - formal submission to Region anticipated soon 2
(HA, MI)
Submission awaiting finalization of amendments to 40 CFR Part 403 (PA) 1
States working on draft submission (IN, OH, DE) 3
Problems delaying State program delegation
- Resource shortages in State (VA, CA) 2
- Other problems in State delaying development 6
(MD, CO, WY, MD, MT, WA)
32 MPDES
State
States working on NPDES submissions which include pretreatment programs 3
(WV, PR, NJ)
35 State
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Che Municipal Construction Grants Division of the Office of Water Program opera-
Clous, co day-to-day administration by Che tea EPA regional offices. Table 1-L1
provides a breakdown of the federal pretreatment expenditures by office since
1977.
1.6 SUMMARY
In sum, progress towards implementation of the National Pretreatment Pro-
gram has been substantial. Roughly two thirds of eligible States have developed
(or are close co completing development of) the capabilities necessary to control
indirect dischargers in their States. One out of ten municipalities is operating
(or has applied for approval to operate) a local pretreatment program with work
towards program development begun at 1,147 POTWs (57 percent of all municipali-
ties obligated to develop programs). The Federal government has issued and
amended regulations for two of the thirty-four categorical industries.
In the four years since affirmation in the Clean Water Act of pretreatment
as a means to control toxic water pollution and to protect POTWs, the nation has
spent almost 72 million dollars to develop and carry out the 403 program (this
includes all Federal expenditures plus monies spent by municipalities and
states). The nation has spent almost 39 million dollars in construction grants
funds for pretreatment to protect the larger investment made in overall funding
of municipal treatment works.
The actual extent of controls on industrial users is, however, unclear. EPA
data, summarized in Table 1-1, indicates that over 652 of the metals and 372 of
the toxic organics from indirect dischargers have already been controlled. How-
ever, the analysis in Section 1.4.1 estimates that only 25 percent of the 2,000
POTWs are implementing controls on industrial users. This result is based on
a study of 132 municipalities in which municipal officials were questioned
about the extent to which they were controlling industrial wastes. Likewise,
the results of visits to 77 POTWs indicates that electroplaters are controlling
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TABLE 1-11
FEDERAL PRETREATMENT PROGRAM RESOURCE EXPENDITURES
($ Thousands)
UQ Permits Division
Personnel
Contracts
UQ Effluent Guidelines Division
Personnel
Contracts
lin Municipal Construction Division
Personnel
Grants
Regional Personnel
(Including all I'retreatment
' FISCAL
1977 1978 1979
317 317 200
100 1 , 706
273 273 273
2,340 2,340 2,340
40
390
YEAR
1980
200
1,862
273
2,340
40
390
1981
200
1,419
273
2,340
40
390
TOTAL
1,234
5,087
1,365
11,700
120
38,952
1,170
59,628
I
Nl
-J
related personnel)
3J
oa
B>
S
CONSTKUCflON GRANTS FUNDS OBLIGATED TO POTMs AND STATES FOR PRITFREATHKNT ($ Thousands)
Total for
Region I II HI IV V VI VII VHl IX X all Keg Jons
flrant Total 2,500 11,221 4.874 1,245 9.240 3,352 2,041 331 2,348 1,800 38,952
Note: These figures have not been adjusted to 1981 dollars. Also Included in the perfaonnel figures is a
$5.000 per fiscal year total travel cost estimate; no other costs were Included.
Totals for each area are: Personnel 3,889
Contracts 16,787
Grants 38.952
Total 59,628
Source: Survey of EPA Headquarters and Regional Office Staff
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50 percent of Che metal3 they generate racher Chan the 65 percent indicated on
Table 1-1. The analysis of toxic discharges from industry la this project is
based on the data supplied by EPA. Accordingly, if EFA's estimates of the
amount of pretreatment la place are, la fact, high then the extent of water
quality impacts estimated in this report are low.
1.7 OVERVIEW OF THE PROJECT
1.7.1 Purpose
EPA issued amendments to Che General Pretreatment Regulations on January
28, 1981, which were to have taken effect on March 13, 1981. The Agency decided
that these amendments did not have "major economic consequence" and, therefore,
an economic impact statement as required by Executive Order 12044, was not
prepared. On January 29, 1981, President Reagan froze a number of regulations
including the General Pretreatment Regulations (GPR) and postponed their effec-
tive dates. On February 17, 1981, Executive Order 12291 was issued replacing
Executive Order 12044 and altering the procedural and substantive review
requirements incumbent on federal agencies Cor new, existing and pending regu-
lations. Executive Order 12291 was invoked on March 27, 1981, to indefinitely
suspend the applicability of the GPR until a regulatory impact analysis was
prepared by EPA.
The purpose of this project Is to provide technical information in support
of EPA's preparation of this Regulatory Impact Analysis (RIA) of the General
Pretreatment Regulations.
The Office of Management and Budget has identified five elements essential
to a regulatory impact analysis;
1) A statement of the need for and consequences of the regulatory action;
2) The examination of alternative approaches;
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3) An analysis of benefits and costs;
4) The rationale for choosing Che proposed regulatory action; and
5) The statutory authority.
JRB Associates' work over the last several months has focused on identifica-
tion of key policy issues and relevant data, and the development and use of
analytical techniques to assist EPA in evaluating the General Pretreatment
Regulations, and preparing an RIA which fulfills OMB requirements. This report
presents information collected, the analyses conducted, and significant findings
of this effort. In addition, more detailed information is provided on the data
and discrete analyses which support this report in an accompanying Appendix.
An extensive bibliography is included in the Appendix which catalogues the
numerous data sources used in this projects. Finally, a discrete computer
model has been developed and is currently operational on the EPA computer
which generates data valuable to the assessment of regulatory options for the
control of industrial wastes at POTWs.
The following section briefly describes the approaches utilized to analyze
the impacts of the National Pretreatment Program and the proposed alternatives.
Far greater detail is provided in Chapter 2.
1.7.2 General Technical Approach
.JRB and EPA worked together in formulating a three-phased approach to
study the necessity of metal and toxic organic industrial pollution control at
POTWs. Phase I consisted of an initial data collection and evaluation effort
aimed at identifying all relevant data, data weaknesses, and potential applica-
tion to subsequent pretreatment program analyses. In addition, intitial work
was performed to develop candidate methodologies for ultimate use in the analysis
phase. In Phase II of the study, techniques were designed to fill remaining data
gaps, and final analytical methodologies were chosen. In Phase III, component
analyses were performed and this report was prepared. This staged approach al-
lowed a periodic reevaluation of data and methods to ensure that solutions
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were feasible within Che time constraints of this study and tied to the central
purpose of measuring the impact of the existing pretreatment program and proposed
alternatives.
The elements of the analysis are described in the following subsections.
1.7.2.1 Selection of Environmental Impacts to be Analyzed
This study analyzed the central environmental problems which the existing
National Pretreatment Program was intended to reduce:
• Water Pollution - which can occur as a result of improper operations and
maintenance of the POTW. It can also occur as a result of indirect
discharges through by-pass, pass-through and upsets.
• Sludge Contamination - which can occur if indirect dischargers fail to
remove metals from their discharges. As a result, the municipality
may be limited in its disposal options.
• Air Pollution - which can occur from volatilization at the POTW or
through the incineration of sludges that cannot be disposed of through
other means because of contamination.
» Worker Health and Safety - which can be jeopardized by indirect dis-
charges through resulting explosions and worker exposure to toxics in
the waatewacer, fumes or sludge.
• Overall POTW Operation - which may be adversely affected due to upset
and interference problems caused by industrial discharges.
• Groundwater Pollution which may occur due to POTW exfiltration and
leachate from municipal sludge.
The determination of the relative effectiveness and cost of each pretreat-
ment regulatory option in controlling the above problems is the principal
focus of this study.
1.7.2.2 Analytical Methods
Having specified the above problems as the central issues behind the pre-
treatment regulatory impact analysis, it remained to be decided which measures
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could and should be employed to quantify the magnitude of these impacts. The
availability of data and applicability of legal standards largely determined
which measures were used. Almost no data existed on the volume of toxic air
emissions attributable to the incineration of municpal sludges or from influent
volatilization. Nor were any nationwide statistics found on the frequency of
worker injuries or deaths at POTWs as a result of industrial discharges of
toxic pollutants. Data inadequancies 1) forced a more qualitative, case-study
evaluation of groundwater, worker health and safety, and POTW operational
problems and 2) dictated the development of a mass-balance computer model to
forecast water pollution, sludge contamination and air pollution impacts asso-
ciated with alternative regulatory strategies.
The mass-balance computer model of a POTW system was the primary tool for
quantifying the environmental benefits and costs for any alternative pretreat-
raenc program. JRB developed this mathematical model for the 2000 POTWs across
the country required to implement local pretreatment programs under the General
Pretreatment Regulations. The model simulates the operation of a single POTW,
distributes pounds of priority pollutants from industry among POTWs to allow
an assessment of water quality and sludge impacts, and allows aggregration of
individual results to national or regional totals. It consists of eleven data
sources, including Dun and Bradstreet industrial lists, EPA's Permit Compliance
System, STORET, USGS, and EPA's NEEDS Survey, among others. The types of
outputs of the model are discussed in the following subsections.
1.7.2.3 Environmental Measures
The POTW model estimates the following quantitative environmental measures
for alternative pretreatment options for each of the 2000 POTWs:
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PROBLEM MEASURE
Water PoLIucion Exceedances of Water Quality Criteria
Violation of NPDES Permits
Mass of Pollutants
Volume of Pollutants Discharged
Net Change in Effluent Quality
Sludge Contamination Volume and Contamination of Municipal Sludge
Volume and Contamination of Industrial Sludge
Air Pollution Mass of Volatile Priority Pollutants
Discharged to Air
Most of these measures quantify for comparison among pretreatmenc options,
the volume of pollution reduced, the volume that continues to be discharged
and the concentration of toxics in the POTW effluent and in sludges.
While measures of pollutant volume and concentration are useful indicators,
they do not necessarily reflect the significance of their impacts to the environ-
ment. Therefore, the impact of the POTW effluent discharge on the concentration
of toxic pollutants in the POTW receiving waters was also estimated. For these
concentration estimates to be most useful, they were compared to benchmark con-
centration levels that indicate whether the resulting concentration represents
a water quality problem. When the concentration of a toxic in the receiving
stream was greater than that threshold, it was termed an "exceedance" — an
indicator of potential water quality problems.
Unfortunately, there are few well-established environmental standards in
place which provide a basis for establishing the threshold for an exceedance.
Only 30 States have set State water quality standards for one or more toxic
organic pollutants and 29 have standards for one or more heavy metals. Efforts
were made to calculate representative average values for State water quality
standards for the critical parameters to fill in these considerable voids and
to facilitate a national impact assessment. However, the results of this
exercise were not felc to be either manageable or a better indicator of actual
conditions. Moreover, very few POTWs have toxic pollutant limits in their
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NPDES permits, thereby eliminating the use of these levels as thresholds (as
well as the significance of permit violations to this analysis). The decision
was made, therefore, to use federal water quality criteria as the benchmark
for exceedances and, therefore, potential water quality problems.
As a final component to the estimation of exceedances, a significant effort
was made to gather ambient water quality information on the level of toxics in
receiving streams. However, this data was severely inadequate. Therefore, the
water quality impacts of POTW discharges are measured as if the POTWs were dis-
charging to pristine water, obviously not the case in the real world. To offset
this assumption, this report provides a sensitivity analysis that predicts
exceedances for three levels of ambient concentrations in the receiving waters.
A parallel effort was made to analyze the significance of changes in the
concentration of priority pollutants in municipal sludge resulting from indirect
industrial discharges. Unfortunately, few sludge disposal guidelines have yet
been issued by EPA under Section 405 of the Clean Water Act or Section 4004 of
the Resource Conservation and Recovery Act. The most relevant of these, the
limits on cadmium in municipal^sludgeto be landspread, requires a knowledge
of soil cation exchange capacities, and the type of crops to be cultivated, in
addition to the cadmium concentration level in the sludge. This information
could not be collected and analyzed in the time frame of this study. State
solid waste disposal rules vary considerably as to their coverage of the numerous
disposal options used by POTWs and very few contain specific limitations on
pollutant concentrations in sludge. Food and Drug Administration (FDA) and
the Department of Agriculture foodchain related guidance were deemed inadequate.
Even regulations of foreign countries were evaluated for possible use. Com-
pounding these regulatory difficulties, it proved impossible to develop meaning-
ful predictors of a municipality's ability to switch between disposal methods.
Costs for the same disposal option vary dramatically between cities, affected
by the availability and proximity of disposal sites, agricultural land, and
other site-specific factors. JRB and EPA eventually decided that given time
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constraints, no meaningful sludge criteria could be constructed for this study.
The report makes predictions on sludge quantity and quality both for industry
and municipalities but, given the lack of regulatory triggers, assumes that
all industrial sludge is hazardous (although some industrial sludges are no
longer classified as hazardous by EPA) and all municipal sludge is nonhazard-
ous in calculating associated disposal costs, regardless of sludge quality
improvement or degradation under the various options.
1.7.2.4 Cost Assessment
Having identified the central environmental problems to be controlled
under any pretreatment program and having chosen key criteria used to measure
the environmental impacts of alternative programs, it was necessary to identi-
fy where the costs of compliance would be sustained so that data could be
collected and impacts estimated. The principal actors under any pretreatment
strategy are industry, POTWs, States and the federal government. A decision
was made to limit the cost assessment on this project to the following direct
costs:
• Industrial Impacts
Pretreatment Technology Costs
Sludge Disposal Costs
• Municipal Impacts
POTW Pretreatment Program Development Costs
POTW Pretreatmeat Program Operational Costs
POTW Sludge Disposal Costs
• State Imoacts
State Pretreatment Program Development Costs
State pretreatment Program Operational Costs
• Federal Impacts
EPA Administrative Costs
Construction Grants for Pretreatment Program Development
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The POTW Model provided treatment and sludge disposal costs. Administra-
tive costs for municipalities, States and to the federal government were based
on historical estimates and case study extrapolations.
A number of coat factors had to be excluded due to the lack of adequate
data or as a result of regulatory assumptions made above. For example, municpal
costs were not reduced to account for savings experienced by POTWs due to the
fewer operational problems attributable to an effective pretreatment program.
Sludge disposal cost savings similarly could not be passed on to cities where
the improvement in sludge quality due to pretreatment facilitate use of a less
expensive disposal option.
1.7.3 Limitations of This Assessment
The data collected and analyses performed in support of EPA's pretreatment
regulatory impact analysis and presented in this report should provide mean-
ingful decision-making tools and information for the ultimate resolution of
the complex issues inherent to the assessment of this major regulatory program.
Nonetheless, a number of caveats oust be presented which place the findings in
perspective.
1.7.3.1 Data Limitations
Our ability to analyze the existing pretreatment program and possible
alternatives in a logical and complete manner was often hindered by the lack
of available health and environmental data. Solutions were designed to over-
come these data deficiencies where possible, but some gaps could not be filled
in the time frame of this study. For instance, no single data source had
complete data on the number and type of categorical industries discharging to
individual POTWs. This information is critical for constructing the raw
wasteloads entering POTWs as a result of industrial users. To surmount this
inadequacy, Dun and Bradstreet computer lists were searched by SIC codes to
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identify Che universe of categorical industries in Che vicinity of a POTW.
The Permit Compliance System Data Base was then used to back out direct
dischargers holding NPDES permit from this total and these were assigned to
the appropriate municipality according to the city name of the POTW as stated
on the NEEDS Survey.
In fact, every component variable in the assessment of water quality impacts
for this project required assumptions in order to achieve results. The mass and
volume of discharge of priority pollutants from all lUs in an industrial category
were all assumed to be the same — equal to those of an average firm. The POTW
receiving these wastes was assumed to attain average treatability levels. Per-
haps the greatest frustration with data weaknesses was experienced with data
on receiving stream characteristics. Stream flows were available for less than
half of the stream segments on which the 2000 POTWs are sited. Ambient water
quality for all eleven toxic pollutant parameters (nine metals, total toxic
organics and cyanide) were almost uniformly unavailable resulting in the
assumption that POTWs are discharging to pristine waters; and the unavailability
of State water quality standards resulted in our use of federal water quality
criteria. Most of these data limitations work to understate the magnitude of
water quality violations associated with indirect industrial discharges but
simply could not be avoided. As the assumptions necessary to overcome these
weaknesses are uniform for all the pretreatment options evaluated, findings
are still meaningful for comparative purposes. In absolute terms, however,
higher water quality violations should be expected without industrial waste
control than those predicted in this project.
Data inadequacies were found to be much worse for the health effects of
toxic pollutants in air, groundwater and sludge, and findings could only be
presented in terms of volumes and mass discharged to the environment either
directly or concentrated in sludge. Thus, no final judgements could be made as
to the beneficial effects of improving sludge quality by roughly 50 percent as
our report predicts if the pretreatment program is implemented either in terms
of reduced costs or a safer environment.
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1.7.3.2 Limitations Due To Inability To Evaluate Interaction With Other Programs
Pretreatment under §307 of Che Clean Water Act only regulates discharges to
municipal sewers. Alone, it does not guarantee that water quality or sludge
goals will be met. Moreover, its effectiveness can only be measured against the
environmental standards established Ln other regulatory programs. As Figure
1-1 illustrates, these standards are set under §402, 208, 405 of CWA and §3004
of RCRA.
Pretreatmenc is, in fact, one of several regulatory tools available to
control agencies to meet the environmental standards set up under the provisions
which directly control environmental quality. The fact that water quality
criteria are not widely accepted, municipal sludge criteria have not been set
and the rules governing the classification of industrial sludge have only
recently been established create major short comings in this analysis. Without
the compliance boundaries established by other environmental programs, the
improvements in environmental quality attributed to pretreatment are very
difficult to evaluate.
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Figure 1-1
WASTESTREAMS and ULTIMATE REGULATORY ENVIRONMENT
I I
[ Sludge ] RCRA 3004
[ ] RCRA 4004
Industry
X CWA 307
WASTEWATER
Scream
§208 CWA
Runoff
CWA 402
CWA 405
RCRA - Resource Conservation and Recovery Act
§3004 Hazardous and Non-Hazardous
§4004 Waste Disposal Critria
CWA - Clean Water Act
§307 Pretreatment Standards
§402 NPDES Permitting
§405 Municipal Sludge Disposal Guidelines
§303 Water Quality Standards
§208 Nonpoint Source Control
CWA 303
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2. DETAILED ANALYTICAL APPROACH
This chapter discusses the criteria used in this study to measure environ-
mental and cost impacts of industrial discharges to POTWs and the methods used
Co analyze these impacts.
2.1 CRITERIA FOR ASSESSING THE IMPACTS OF DISCHARGES FROM INDUSTRIAL USERS
Industrial wastes can cause a variety of problems at POTWs. The most
direct impact is on the operation of the POTW itself. The generation of con-
taminated municipal sludge and the discharge of partially treated wastewaters to
receiving bodies are additional impacts that can, in many instances, be tied
to industry. Additionally, groundwater can be contaminated by leachate from
landfills used to dispose of POTW sludges and agricultural lands may be con-
taminated by direct application of municipal sludges. Further, the atmosphere
in the vicinity of municipal treatment plants can become contaminated from
toxics which volatilize, affecting not only the health of POTW workers but
also those living and working near these facilities. This section describes
the criteria used in this analysis to define and measure the impact of industrial
dischargers on POTW operations and environmental quality.
This project is designed to analyze impacts which result from the indirect
discharge of industrial wastes. When possible, these impacts are measured quan-
titatively. However, some impacts cannot be quantified from the data available.
In these cases the extent of the impacts are described and examples of the im-
pacts from case study reports are used to document their occurrence. The impacts
are organized into six categories: pass-through and water quality, interference
and upsets, sludge contamination, worker health and safety, air pollution and
ground water pollution. The following section introduces each of the impacts
with a preliminary overview of the data sources and their findings, and the
methods and criteria used to measure these impacts.
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2.1.1 Pass-Through and Water Quality
Some pollutants pass-through a POTW untreated or partially treated to
the receiving vaterbody. The most common reasons for pass-through are that:
• POTWs are not designed for the removal of certain pollutants.
• Interference of the POTW system occurs which reduces the POTWs treat-
ment capability
• Slug loadings, hydraulic overload and operator errors upset plant
operations.
The pass-through of pollutants has no significant impact on the POTW's
collection and treatment system. However, pollutants which pass-through can
degrade the quality of the receiving waters. This degradation may violate
water quality standards thereby restricting the use of the waterbody and
potentially affecting the health of humans and aquatic organisms. For exam-
ple, a contaminated river may no longer be adequate as a drinking water supply
or for recreational purposes.
The most direct way to measure the extent of pass-through at POTWs would
be to count NPDES permit violations. However, few POTW permits include toxic
limits. For most POTWs in the U.S., NPDES discharge limits have been estab-
lished for conventional pollutants based on technological capabilities and
reflect a level of secondary treatment as required by the Clean Water Act
(CWA). Many POTWs have NPDES limits which are more stringent than secondary
treatment. These limits are usually set to protect the quality of receiving
waters rather than solely to meet a specific technology-based removal effi-
ciency. Limits established for this purpose are said to be "water quality
limited." Since toxic pollutants are not addressed in the CWA definition of
secondary treatment, toxic pollutant limits incorporated into POTW permits are
generally water-quality based.
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In general, daca on NPDES permit violations exist for conventional pollu-
tants [biochemical oxygen demand (BOD), suspended solids (SS)J. However, few
POTW permits contain water-quality based limits for toxic pollutants. Even in
those case where limits have been set, there is only limited monitoring data
for toxic pollutants in POTW effluents. Accordingly, NPDES permit violations
are not currently a good indicator of toxic water quality problems.
Because of the limited number of POTW permits with toxic limits and insuf-
ficient monitoring data for toxic pollutants, our approach to assessing water
quality impacts from POTW discharges was to estimate the amount of pass-through
at each POTW using a mathematical model. This model was relied upon to predict
the quantity and quality of toxic discharges from each POTW. Using measured
stream flow data, the model predicts the concentration of toxic pollutants
in the receiving water body contributed by POTWs.
These predicted toxic pollutant concentrations from the model can be com-
pared to environmental standards as a way to measure water quality. If the
standard is exceeded, than a water quality problem has been identified. The
question is what environmental standard to use. The comparison should be con-
sistent with the way water quality based NPDES permit limits are established.
Generally, State water pollution control agencies set these limits as part of
a water quality management process as outlined below.
• First, the use of the water body is designated by the State agency
(e.g., water supply, contact recreation).
• Second, the State derives water quality standards to protect the
designated use. The basis for State standards are the National Water
Quality Criteria which EPA is developing for toxic pollutants. Water
quality standards can differ from National criteria because of site-
specific chemical, physical and biological conditions.
• Third, NPDES permit limits are set for each point source and other
water management plans are implemented to ensure that water quality
standards are met in the receiving body.
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Clearly, che most appropriate way to evaluate water quality impacts is
to directly compare modeled effluent concentrations to established State water
quality standards. However, few State water quality standards have been estab-
lished to date. Table 2-1 lists the values of State standards for metals.
Those with more stringent values are reported separately from the less strin-
gent values. In addition, the number of States with standards for each para-
meter is listed at the bottom of the table. The greatest number of standards
have been established for lead, cyanide, and cadmium. However, only 16 States
have values for these pollutants. Only six States have standards for silver.
Since we were interested in comparing ambient water quality for eleven toxic
parameters for all 50 States, the State water quality standards are too limited
for determining the National water quality impacts of industrial users.
The next best benchmark for counting water quality problems caused by
POTWs are the National Water Quality Criteria themselves. The use of national
criteria enables the analysis to address all toxics of interest and also conform
to the national scope of this study. Accordingly, these criteria were adopted
in this project. There are two kinds of National criteria: (1) concentrations
estimated to be protective of aquatic life and wildlife; and (2) concentrations
relevant to the protection of human health. They are prepared according to the
procedures in the revised guidelines issued in 45 FR 79318 (November 28, 1980).
These criteria are simply the best estimate of the concentration-effect rela-
tionship informed scientists are able to make, based on the information from
published studies. Specific numerical concentration limitations are estab-
lished for most pollutants. When data limitations preclude a numerical deter-
mination, the criteria is given qualitatively.
EPA develops both chronic (long-term) and acute (short-term) water quality
criteria. In this analysis, chronic toxicity criteria for human health and
aquatic organisms are used along with average stream flows, to measure water
quality impacts of the POTW effluents computed by the model. The criteria
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TABLE 2-1
STATES WITH STRICTER AQUATIC HEALTH
STANDARDS THAN NATIONAL CRITERIA
(mg/1)
State
CN
Ag
Cd
Cr
Cu
Hg
Ni
Pb
Zn
California
Colorado
Florida
Indiana
Kentucky
Missouri
Montana*
N. Carolina
Ohio*
Oregon*
Pennsylvania
Utah
Virginia
.00005
.005 .00005 .05
.00005
.00005
.01 .00005
.001
.00005
.02 .005
.01
(96LC50)
.00005
.00005 .01
(96LC50)
.01
(96LC50)
.01
.01
(96LC50)
.005
.01
(96LC50)
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TABLE 2-1 (Continued)
STA1ES WITH EQUIVALENT OR LESS STRINGENT AQUATIC HEALTH
STANDARDS THAN NATIONAL CRITERIA
(mg/1)
State
Arizona
California*
Colorado
Florida
Illinois**
Indiana
Iowa
Kentucky
Missouri
Montana*
Nebraska*
Nevada*
New Jersey
New York*
N. Carolina
N. Dakota
Ohio*
Oregon*
Pennsylvania
Tennessee
Utah
Virginia
W. Virginia
Qi Ag
.1 .05
.005 .001
.005
.1 .005
.01
.005 .05
.005
.005
.01
.005
.05
.1
.005
.005
.1
(96LC50)
.005 .05
.005
.025 .05
Cd Cr
.01 .05
.0004
.0008 .05
.01 .3
.05
.0012 .05
.004 .1
.012
.05
.05
.01 .05
.3
.004
.01
.003
.05
Cu Hg Ni
.05 .005
.5 .0002 .1
1.0 .0005 1.0
.05 .1
Pb
.05
.004
.05
.1
.5
1.0
Zn
1.0
.01 .01
(96LCso> (96LC50)
.02 .1
.005
.2
.1
.002
.1
.1 .1 .1 .1
(96LC50) (96LC50) (96LC50) (96LC50)
.004 .1
.1
.01 .05
.01
.1
(96LC30)
.1 .1
(96LC50) (96LC50)
.05
.05
.05
.03
.05
.05
.1
(96LC50)
.05
.1
(96LC50)
.05
.1
.1
.3
.1
(96LC50)
.1
(96LC50)
Total No. States
with Standards 16
16
15
14
15
16
11
* At certain discharge points
** Have State criteria for all 9 pollutants
+ For fresh water discharge
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were chosen over acute toxicity criteria and 7-day/10-year low flow conditions
because the POTW model incorporates yearly average data. It does not predict
short-term events because industrial effluent and POTW influent data was most
complete and readily available as annual averages. Therefore, chronic water
quality criteria are the appropriate standards in this analysis. A shortcoming
oŁ this analysis is that all regulators and scientists do not agree that the
National Water Quality Criteria are set at the optimal level. Some argue that
the data base used to establish the standards is flawed; others criticize the
methods used by EPA to analyze the data. Nonetheless, these values are the
best available for a national assessment of water quality impacts. At a mini-
mum, they enable the relative impacts among pretreatment alternatives to be
compared.
In addition to pass-through, POTWs can also affect water quality through
by-passing of raw wastes directly to the receiving body. Causes for by-pass
include (1) extensive infiltration, (2) storm water runoff, and (3) operational
problems. Periodic by-pass can degrade water quality. Data from EPA's Opera-
tion and Maintenance File can and is used in this study to estimate Che extent
of bypass at POTWs.
As a final component of this water quality equation, a signficant effort
was made to gather ambient water quality information on the level of toxics in
receiving streams. However, this data was severely inadequate. Therefore, the
water quality impacts of POTW discharges are measured as if the POTWs were
discharging to pristine water, obviously not the case in the real world. To
offset this assumption, the model was used to predict exceedances of three
increments of the applicable water quality criteria (for 25, 50 and 100 percent
of the water quality criteria) rather than actual water quality violations.
2.1.2 Interference and Upsets
Interference is defined as the inhibition or disruption of the POTW, its
treatment processes or operations, its sludge processes, its sludge use or
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disposal. Interference may be caused by high volumes or concentrations of
pollutants which can adversely impact the proper operation of a POTW, thus
causing it to treat its wastes less efficiently than normal. Conventional
pollutants are the principle cause for interference problems. The most common
types of interference are:
• Corrosion of POTW equipment and materials due to low pH.
• Obstruction of flow or interference with operations due to solid or
viscous pollutants.
• Creation of a fire or explosion due to discharge of volatile materials
• Unit process upsets caused by the discharge of any pollutant (including
BOD and SS).
• Inhibition of biological activity or increase in POTW influent temp-
erature due to heat discharges.
• Inhibition of biological activity due to toxic pollutants.
A way to assess the impact of interference is by examining operation and
maintenance problems at POTWs as well as increased POTW expenditures, and
additional POTW protection equipment attributable to interference. Documenta-
tion of the number, type, and extent of interference is not kept by all POTWs.
Although precise measures of industrial-related interference problems are not
available for all POTWs, quantitative and qualitative information does exist
for some. Our method of analyzing interference problems is based on statistical
summaries of data on interference from EPA's Operation and Maintenance File,
the results from field visits to 77 POTWs conducted by JRB, and from case
study findings reported in the literature. However, pass-through due to inter-
ference is not incorporated into the POTW model. As a result, the model only
predicts persistent water quality effects. Chapter 3 discusses this in
greater detail. Actual impacts would be higher.
There are many causes of POTW upsets, including inadequate design and
plant obsolescence. However, industrial waste has been identified by POTWs as a
major cause of O&M problems and poor plant performance. Upsets from industrial
waste can have a number of different adverse effects on a POTW including:
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• Upsets from slug discharges of toxic pollutants (e.g., unexpected
batch dumps);
• Digester upsets which can lead to reduced POTW efficiency;
• Upset from slug discharges of conventional pollutants (high BOD).
Upsets are, again, not addressed by the computer model and are another contri-
buting source of water quality violations. The extent of these impacts are
addressed in Chapter 3.
2.1.3 Sludge Contamination
Many toxic pollutants, especially metals, are removed from the influent to
a POTW and are deposited in the POTW's sludge. This removal is incidental and
occurs through normal secondary treatment. The contamination of the POTW sludge
with toxic pollutants can limit sludge disposal alternatives as follows:
• Land spreading of sludge may be restricted because toxic pollutants
can result in uptake into crops and into the human food chain or
cause surface/ground water contamination.
• Storage of sludge on land may be restricted for the above reasons.
• Sludge may not be'permitted in conventional landfills due to the
potential contamination of ground water as a result of leaching.
• Selling sludge as a soil conditioner may not be an option due to
toxics contamination.
• Unknown environmental effects of toxics on municipal sludges has
led some State agencies to restrict land disposal of these sludges.
Sometimes, POTWs with potential contamination problems conduct sludge
sampling and analysis. This data is also available as a result of several
EPA studies which included special analyses of POTW sludges for industrial
contaminants. The literature, EPA studies, and case studies provide further
information on disposal, ground water, and surface water problems caused by
contaminated POTW sludge. This information is an important part of our
analysis of sludge contamination.
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As in the case of pass-through, quantitative sludge contamination, and dis-
posal data do not exist for all POTWs. Since improved municipal sludge quality
is an important aspect of a pretreatoent program, quantifying this data was
accessary for our analysis. Again, the mathematical model was used as a pre-
dictive tool. Based on actual data for selected POTWs, the model was used to
estimate the amount of sludge generated, pollutant concentrations, disposal
methods, and related costs. The model was used to estimate both POTW sludge
and sludges generated by industrial pretreatment systems.
A parallel effort was made to impose meaningful regulatory limits on
priority pollutants in municipal sludge resulting from indirect Industrial
discharges. Few sludge disposal guidelines have yet been issued by EPA
under {405 of the Clean Water Act and Section 4004 of Resource Conservation
and Recovery Act. State solid waste disposal rules vary considerably as Co
their coverage oC the numerous disposal options used by POTWs and very few
contain specific limitations on pollutant concentrations in sludge. Food and
Drug Administration (FDA) and the Department of Agriculture food chain-related
guidance were deemed Inadequate. Even regulations of foreign countries were
evaluated for possible use. JHB and EPA eventually decided that given time
constraints, no meaningful sludge criteria could be constructed for this study.
The report makes predictions on sludge quantity and quality both for industry
and municipalities but, given the lack of regulatory triggers, assumes chat
all industrial sludge is hazardous and all municipal sludge is non-hazardous
in calculating associated disposal costs, regardless of sludge quality improve-
ment or degradation under the various options.
2.1.4 Worker Health and Safety
POTW workers can be exposed to chemical substances caused by or related to
the discharge of industrial effluents. The principal concerns are:
• Exposure to airborne chemical contaminants.
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• Skin contact with industrial effluents.
• Handling of strong acids and bases used as pH control reagents for
wastestreams with variable pH.
• Explosions caused by industrial wastes in the POTW collection or
treatment system.
The toxicological properties and exposure criteria are known for many
toxic industrial pollutants. However, only a limited amount of data exist
related to airborne industrial contaminants in the vicinity of POTWs. The
limited data available were collected in this project and compared to the
toxicological criteria. The analysis of worker health/safety focuses on case
studies of problems at various POTWs.
2.1.5 Air Pollution
Air pollution problems from the incineration or pyrolysis of municipal
sludge is assessed qualitatively in this analysis. Although some evidence of
adverse health effects and violation of air emission standards are found in the
literature, there is not enough information to perform a quantitative assess-
ment. The results of the analysis of air pollution problems from municipal
sludge incineration is discussed in Chapter 3.
2.1.6 Ground Water
Ground water problems from indirect discharges is handled qualitatively in
this analysis. Although the literature contains evidence of exfiltration from
sewer pipes, the data does not lend itself to incorporation into the modeling
efforts. The results from this literaure search are summarized in Chapter 3.
2.2 METHODS OF ANALYSIS
Two types of analyses were performed during this project. The first was
an analysis of available information to assess four of the six impacts described
above; (1) interference and upsets, (2) worker health and safety, (3) air
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pollution, and (4) groundwater. The second type of analysis was the development
and use of the mathematical model to examine the remaining two impacts, pass-
through and water quality, and sludge generation. Data from the first analysis
were also used in the modelling effort. The two analyses are described below.
2.2.1 Analysis of Data Bases Depicting POTW Operations
Seven data sources were used in this study to develop profiles of POTW
operations. These data sources provide the means to carry out quantitative and
qualitative analyses of actual conditions encountered at municipal facilities.
The purpose of these analyses is to determine:
• The frequency of occurrence of operational problems.
• Persistent operational problems which are linked to industrial dis-
charges and lead to environmental degradation.
• The impact of pretreatment on POTW effluents before and after imple-
mentation of pretreatment.
• The motivation for the development of pretreatment programs by munici-
palities.
• Other information regarding specific POTW operations and environ-
mental conditions and problems.
The data sources presented in this section are used in Chapter 3 to document
and exemplify industrial discharges and treatment facility operations. Complete
analyses of each data source are provided in Appendix B.
2.2.1.1 40 POTW Study
The Effluent Guidelines Division (EGD) of EPA carried out a two-year study
at 40 POTWs to determine the fate and occurrence of both conventional pollutants
and the 129 priority pollutants. The 40 POTWs selected for study were distribu-
ted according to geographic location, average daily flow, percentage industrial
flow, and the treatment processes utilized. The study represents a profile of
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well operated POTWs receiving more than 5 mgd average daily flow which are
required to implement local pretreatment programs.
At each of the 40 POTWs, an intensive, week long priority pollutant sampling
and analysis program was conducted of various operations. Sampling points in-
cluded the POTW influent, secondary effluent, primary and/or tertiary effluent,
primary or combined sludge, and secondary sludge. Six 24-hour samples were
normally collected at each POTW.
Detailed results of this analysis are presented ia Appendix B-4.
2.2.1.2 EPA 4-City Study
During 1978 and 1979 the Monitoring and Data Support Division of EPA con-
ducted a source sampling survey of 4 POTW collection systems. Sampling in all
4 cities was conducted in interceptors from domestic, commercial, and industrial
users, and at the POTW influent. The industrial component of this study was
not used in the RIA because the four collection systems did not include a
sufficient variety of EPA's categorical industries. However, the domestic and
commercial results were used in the model as a second measure of nonindustrial
contribution. It is important to note that two of the four cities in this
study were the two plants from the 40 POTW study that had little industry.
All four cities were included in the 40 POTW sampling.
2.2.1.3 132 Study
In 1981, the EPA Office of Water Enforcement engaged in a statistical
assessment of selected municipalities to estimate the progress made in con-
trolling industrial waste discharges to POTWs. The analysis included a deter-
mination of the control programs developed through local initiatives, and
those developed in response to the requirements of the National Pretreatment
Program. The assessment of local control programs consisted of a study of 132
randomly selected municipal authorities, operating 294 plants made in conjunc-
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Cion with a technical assessment project managed by JRB. The data sought in
the study were:
• General facility data,
• Industrial waste survey information,
• Industrial users information and regulated industries,
• Legal authority,
• Formal pretreatment programs, including motivation for program deve-
lopment, sewer ordinance limits, and monitoring,
• Industrial controls,
• POTW NPDES permit information, including permit violations.
The POTWs included in the assessment were chosen using a random number
generator and proved to be a statistically representative sample of the 2,000
POTWs required to develop local pretreatment programs for key measurements.
Figures 2-1 to 2-3 present a graphical comparison of the 132 data base with
the complete 2,000 POTW data base for three important measurements:
• Total Flow
• Percent Industrial Flow
• Number of Metal Finishers and Percent Industrial Flow
These figures indicate that the 132 subgroup have similar trends as the entire
population of 2,000 POTWs.
The results of this analysis are presented in Appendix B-2.
2.2.1.4 The Operation and Maintenance Data Base (O&M)
The Operation and Maintenance (O&M) data base was compiled and computerized
by EPA from reports of POTW inspections conducted by EPA and the States. The
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1200-
1000 -
800 -
600-
400 -
200
33
CD
Figure 2-1
COMPARISON OF 132 POTW. SUBCKOUP TO 2000
NUMBER POTWS vs. POTW EX 1ST INC FLOW
O Needs 132
Needs 2000
to
H
u.
*
j()
~r~
40 SO 60 70
POTW Existing Flow (MfiD)
90
100
-------
1200-
in
S
o
o
[25
800-
600-
2-2. COMPARISON 01- 132 I'OTW SUBCKOIII' TO 2000 I'OTW
NUM15KR I'OTWS vs. I'HkCKNI' INDUSTRIAL KI.OW
HK)0-
— Noeds 132
Needs 2000
—JRB Survey 132
3)
CD
AOO-
200-
100
% Existing lihtuMiri.il
-------
Figure 2-3.
COMPARISON OF 132 POTW SUBGROUP TO 2000 I'OTW
NUMBER OF POTWS WITH ELECTROPLATES vs. PERCENT INDUSTRIAL FLOW
250-
(•) Needs 132
•Needs 2000
3J
CD
12
01
p.
O
u
O
0)
w
.C
B
O
PU
200-
150-
100-
50-
0--
r
T
10
1
20
~^r r
30 AO 50 60 70
% Existing Industrial Flow
100
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purpose of these inspections is Co check on POTW compliance with che requirements
of NPDES permits and Construction Grants and to assess staffing and training
needs. These inspections are required by §210 of the Clean Water Act and the
results are summarized by EPA and reported to Congress annually. Inspection
frequency is determined by the requirements of the State and the degree and
type of problems encountered at each facility.
Information is collected on EPA Form 7500-5 (4-72), "Report on Operation
and Maintenance of Wastewater Treatment Plant." Inspectors obtain information
to complete the form from on-site reviews of facility records, such as labora-
tory records, maintenance records, and daily logs of operation, and by examining
equipment, interviewing staff, and observing procedures. Four generic categor-
ies of data addressed by the inspections are represented in the data base:
• Identification information
• Facility data
• Pollution load data
• Facility operations assessments
The O&M inspections are performed at the discretion of State and EPA
Regional offices. Generally they contain reports of upset and by-pass and
their duration, as well as NPDES permit violations and identification of the
causes of operational problems including industrial sources. Complete inspec-
tions and assessments are usually made if problems have been reported, • while
more routine inspections are made if no problems have been encountered. In
the latter case, only an overall assessment of plant operation is performed,
and portions of the inspection form related to problems are left blank. The
data used in the analysis come from 1500 inspections conducted in 1980.
Detailed results of this analysis are presented in Appendix B-l.
2.2.1.5 77 POTW Study
The 77 POTW Study was conducted by JRB Associates and subcontractors in
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1979 to 1980. Under this sCudy, technical assistance was provided to 77 POTWs
with design flow less than 5 ragd. Candidate POTWs were selected after screening
from a list identified by EPA Regional Offices and HPDES States. The POTWs
covered in this assistance program were distributed over 22 States and nine of
the ten EPA Regions. A report was prepared on each POTW, describing plant
operations, performance data, and operating conditions and problems. Major
nondomestic users of each POTW were visited to determine the quantity and
origin of pollutants entering the POTW. An analysis of these data was performed
Co examine:
• POTW operational problems,
• Distribution of categorical and noncategorical industries discharging
to these POTWs,
• The impact of specific industries discharges to these POTWa, and
• Industrial discharge limit setting and monitoring/enforcement prac-
tices.
The results of this analysis are presented in Appendix B-3.
2.2.1.6 Literature Search Case Study
JRB compiled data on nineteen municipalities with industrial waste control
programs to assess differences in POTW operating parameters before and after
program initiation. The sources of information included academic and trade
literature, published reports and papers by the municipalities and EPA, and a
telephone survey of nine POTWs conducted by JRB. Eight municipalities had
sufficient documentation regarding pretreatment to be included as an infor-
mation source for this study. The eight municipalities are representative of
a variety of population sizes and service areas, average daily flows, types of
industries, and quantities of industrial flow.
The case study analysis is presented in Appendix B-5.
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2.2.1.7 NEED'S Survey
Since 1969, EPA has assessed POTW construction requirements through the
HEED's Survey. The results of the survey are summarized and computerized by
EPA and used for appropriating Construction Grant funds to the States. The
1980 survey includes estimates of the present needs to fulfill NPDES require-
ments, and cost predictions to meet the 1990 needs. Various means were used by
EPA to make these estimates, such as engineering estimates, comparison with
previous costs, EPA cost estimating procedures, and rough estimates. The 1990
predictions are based on projections of future populations and the present
value of future construction costs.
The data for the 1980 HEED's Survey was developed by updating the 1978
HEED's Survey on a facility-by-facility basis. Information from previous HEED's
Surveys is recorded on the HEED's Survey form and updated using information in:
• 1978 NEED's Survey
• Regional files
- NPDES permits and applications
- Construction grants
- O&M data
'- Facility and/or regional plan (201 and 208)
- State water quality files
• State and locally supplied data
Five generic data categories are represented in the survey:
• Identification information
o Pollution load data
• Pollution control data
• Facility status information
• Construction needs information.
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All communities with populations greater than 10,000, and all communities
within Standard Metropolitan Statistical Areas (SMSAs), are included in the
survey. States decide how many of their communities with populations of less
than 10,000 would also be surveyed, but at least 20 percent of these communities
are included. Twenty-nine States and territories included 100 percent sampling
of the small communities. All 2,000 municipalities subject to the General
Pretreatment Regulations are included in the NEEDs Survey.
2.2.1.8 Permit Compliance System
The Permit Compliance System (PCS) is designed to track construction and
monitoring events detailed in NPDES permits. Inspections of POTW facilities
are made by the State or EPA Region to verify that the construction requirements
scheduled in the permits have been completed.
The PCS, a computerized system, contains no technical data. Regional EPA
offices keep the technical data separately in NPDES files which are generally
not computerized. These data include pollution loadings, waste treatment
components, and proposed construction information, and discharge monitoring
reports, which contain the results of periodic self-monitoring required in
each NPDES permit. Although this technical information is not entered into
PCS, portions are extracted and compiled in the NEED'S Survey data base.
•The information contained in PCS is entirely descriptive and used for
enforcement and compliance purposes. It is continually updated by EPA as a
current source of descriptive information on compliance. In this project,
PCS data is used soley to estimate the number of industrial users discharging
directly to receiving water bodies.
2.2.2 Summary of Information from Data Bases
The data bases that measure POTW problems tend to verify that common
problems exist at POTWs. Many of the problems are national in scope and cover
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plants with a full range of flow and industrial contributors. The following
discussion details some of the findings from the major data bases. These
findings are presented here in order to highlight the generic problems common
to POTtfs. In Chapter 3 of this report, these data bases are further analyzed
as part of our evaluation of industrial impacts on FOTWs.
O&M and Process Upsets
A high percentage of O&M and process upset problems at POTWs are associated
with nondomestic (industrial) flows entering the POTW. From a review of the
O&M data base and the 77 POTW visits, it can be concluded that industrial waste
control will reduce the O&M and process upsets and improve POTW operation.
• Approximately 79 percent of the POTWs with O&M problems receive
industrial wastes and are of a design capacity less than 5 mgd (O&M
Data Base).
• Over 70 percent of POTWs that report receiving industrial wastes cite
O&M problems associated with their industrial flow (O&M Data Base).
• Of POTWs with overloads, 77 percent report hydraulic overload problems
and 42 percent report organic overload problems (O&M Data Base).
• O&M problems associated with industrial waste and O&M problems associ-
ated with sludge handling and processing are the most frequenctly
reported problems other than plant obsolescence (O&M Data Base).
• The most commonly listed problem industries for POTWS <_ 5 mgd are:
food, electroplating, mechanical products, and textiles (77 POTW
Study).
Permit Problems
A high percentage of POTWs violate their NPDES permit. For most POTWs,
NPDES permits include limits on conventional pollutants only. The data pre-
sented in these analyses and summarized below indicate that industrial users
are signficant contributors to POTW permit problems.
• More than 60 percent of the POTWs in the O&M data base chat report O&M
problems associated with industrial wastes violate their NPDES permit.
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• Of the POTWs in the 77 POTW data base with permit violations, 65
percent of the operators at plants with permit violations attributed
those violations to industrial discharges.
• Almost 70 percent of all POTWs violate their NPDES permit with
approximately 50 percent of then in violation 10 percent or more of
the time (132 POTW Study).
• Approximately 80 percent of all permits address only conventional
pollutants with 30-40 percent of current permits having been issued
prior to 1977 (132 POTW Study).
t Approximately 50 percent of the POTWs have some level of control
(ordinance, permit, etc.) on all industrial users in their system,
but approximately 70 percent do not monitor industries on a regular
basis (132 POTW Study).
Sludge Problems
The multiple data base analyses indicate that sludge contamination is
usually associated with the concentration of metals in the POTW sludge. As
more POTWs select land-based disposal options, metal concentrations in POTW
sludges will become a more serious concern and will need to be decreased prior
to sludge disposal.
• Heavy metals removed at POTWs are incorporated into the sludge of the
POTWs (40 POTW Study).
• Nearly all of the POTWs in the O&M data base that were evaluated for
sludge problems reported dissatisfaction with their sludge disposal
practices and/or costs.
• Of the POTWs in the 77 POTW data base, 87 percent report sludge
contamination contributed by industrial wastes.
• The 77 POTW data base indicates that 30 percent of the POTWs have not
sampled their sludge.
Pass-Through. Bv-paaa and Combined Sever Overflow (CSO) Problems
The data available from the literature and other studies are insufficient
for an analysis of pass-through of toxic pollutants. In by-pass situations
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some pollutants are discharged into Che receiving waters untreated. The O&M
data base yields the following:
• Approximately 35 percent of the POTWs bypass monthly for varying time
periods of up to 24 hours per month (O&M Data Base).
• The highest reported instances of bypass occur in Regions II and V
which are heavily industrialized. The potential exists for signfi-
cant industrial pollution due to bypassing in these regions (O&M
Data Base).
• The 40 POTW study found increased heavy metal concentrations in com-
bined sewer systems due to wet conditions. This may be due to flushing
of metals that settle during dry conditions.
General
POTWs have operational problems that are influenced by the industrial
flows entering their systems. A number of POTWs do not report industrial flows
because they do not know the volume. However, they do report industrial wastes
as contributors to their O&M, sludge and permit problems.
• In the 40 POTW Study, industry was found to be the major contributor
of the priority pollutants to POTWa. Variations in priority pollutant
concentrations can be attributed to the types and sizes of industries
discharging into the POTW.
• Approximately 15 organics, 8 heavy metals, and cyanide are normally
found in POTW influent (40 POTW Study).
• A number of POTWs report O&M problems due to industrial wastes but do
not know the industrial flow contributors into their facility (O&M
Data Base).
• POTWs meeting secondary treatment requirements also remove priority
pollutants. Generally, these POTWs remove 70-80 percent or more of
the heavy metals, 80 percent of the total volatile organics, and 70
percent of the total acid-base-neutral organic pollutants (40 POTW
Study).
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• Sixty-eight (68) percent of the POTWs do not monitor their industrial
users or enforce their industrial requirements on a regular basis
(at least once per year); and of the remaining 32 percent that do
monitor, only 12 percent monitor metals and 1 percent monitor for
toxics (132 POTW Study).
• POTWs that have existing pretreatraent programs have lower concentra-
tions of priority pollutants in the POTW influent and effluent. Based
on the 40 POTW Study, for example, total metals were 28 percent
higher in the influents of POTWs that did not have a pretreatraent
program. This trend carried through to the acid-base-neutrals which
were 76 percent higher in the influent; and the volatile organic
priority pollutants which were 315 percent higher.
2.2.3 POTW Modeling Effort
The data sources examined above are valuable to assess the general degree
and extent of environmental, health and cost impacts of pollution from indirect
dischargers. However, they are insufficient to adequately measure these impacts
for alternative pretreatment programs. Moreover, there is little actual data
that precisely or systematically relates indirect discharges of toxic pollutants
to environmental effects such as industrial sludge quality and quantity, POTW
influent and effluent quality, water quality impacts on receiving streams and
pretreatment related costs. To provide EPA with a precise decision-making tool,
JRB developed a mathematical model of a POTW system to help quantify these envi-
ronmental impacts and costs of pretreatment program alternatives at individual
POTWs.
To measure water pollution and sludge contamination, the discharge of ele-
ven pollutant parameters — nine heavy metals, cyanide, and total toxic organics
— were quantified. These choices once again required balancing of what was
available with what would be most meaningful for the analysis of toxics control
at POTWs. To provide a comparative baseline, volumes and mass of discharges
for silver, arsenic, cadmium, chronium, copper, mercury, nickel, lead, zinc,
cyanide and total organics released into the water or concentrated in sludge
were calculated. For obvious reasons, only volatile toxic organics were
measured in air emissions.
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The resulting information on total mass of priority pollutants released to
the environment under each regulatory strategy is used in Chapter 4 to compare
the costs and effectiveness of alternative pretreatment programs. The modeling
effort was computerized because:
• It would facilitate data input from sources that were already compu-
terized (e.g. STORET, NEEDs Survey, D&B etc.) and would quickly
handle the sheer magnitude of the input data required to thoroughly
simulate the interactions of industry, the POTW and the environment.
• It would allow a microanalysis for a large number of POTW systems,
providing a better basis for analyzing national impacts.
• It could easily perform the number of simulation runs necessary to
analyze the sensitivity of the key assumptions made in the project.
• It would permit a precise analysis that includes all of the 2000
POTW3 for which data could be obtained.
• It would be easy to make modifications and changes in assumptions
or data elements in order to rapidly test additional alternatives.
The model can calculate coat and environmental results at each of the
2000 POTWs subject to the General Pretreatment Program and aggregate national
totals of these impacts for comparison. At the time of this report, some data
elements were lacking for all 2,000 POTWs. For example, 1,583 POTWs discharge
to receiving streams, however, stream flow data was available for only 703
POTWs. Brief details of the model development are provided below. Appendix
C provides a thorough description of the model.
2.2.3.1 Central Approach
The approach of the modeling effort was to collect as much specific data
as possible for each of the 2,000 POTWs subject to the General Pretreatment
Regulations. The model relies heavily on the centralized data bases (NEEDs, Dun
and Bradstreet, PCS) and projects average data characteristics where specific
data were not available. The model has three conceptual modules:
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1. Selection of a regulatory alternative and designation of major baseline
assumptions.
2. Effects on industry; including environmental effects such as sludge
quality and quantity, and effluent quality; and financial effects
such as pretreatment related costs, sludge disposal costs, etc.
3. Effects on POTWs — including environmental effects such as influent
and effluent concentrations, receiving scream flow and water quality
impact, sludge quality and air emissions of volatile toxic pollutants;
and cost factors such as municipal pretreatment program costs.
The computer model performed the following key computations after receiving the
input data:
1. Identification of all industrial users (Ills) served by a POTW.
2. Prediction of the average effluent flow and characteristics and pre-
treatment cost for each IU.
3. Addition of a baseline concentration of toxic pollutants to account
for domestic and commercial contributions.
4. Adjustment of each IU flow to reflect the actual industrial flow at
that POTW (normalization).
5. Application of an average POTW removal efficiency for each pollutant
depending on its level of treatment.
6. Calculation of toxic pollutant concentrations in the POTW influent,
effluent, and sludge and summation of appropriate costs.
7. Effects of the POTW effluent on stream quality and contribution of
the POTW to potential water quality violations.
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The model uses a variety of adjustments to account for discrepancies among data
sources and to fill in missing data. These factors are discussed in detail in
Appendix C-3. A simplified flow diagram of the model is presented in Figure
2-4.
2.2.3.2 Data Sources
Table 2-2 identifies the major data elements required to operate the model
and the sources for each element. The principal data sources are identified
below.
1. Dun and Bradstreet's (D&B) marketing service provided the information
which identified a count of IU's in each POTW1 s jurisdiction by SIC
Code. This data is on a computer tape.
2. The Permit Compliance System (PCS) data base provided the number of
direct dischargers in each POTW. These are subtracted from the D&B
listings to arrive at the number of indirect dischargers at each
POTW. We then normalized that information to the total' industrial
flow.
3. EPA Effluent Guidelines Division (EGO) supplied the effluent flow
and pollutant concentrations for each of the 34 categorical industries
included in the model. EGD also supplied the removal efficiency for
each pollutant required by PSES, the associated pretreatment technology
costs, and the SIC code definition of each industry.
Other data derived from EPA estimates include:
• Sludge disposal costs
• Applicable stream quality criteria
• Adjustments to D&B to match the number of Ill's nationwide counted
by EPA
• POTW removal efficiencies (40 POTW Study)
• Nonindustrial contribution to POTWs (40 POTW Study and 4 City Study)
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FIGURE 2-4; Simplified Flow Chart of Che Computer Model
D & B
PCS
Needs Survey
Stream Flows
EGD CAtegorical Data
Cost Data
PTOW Efficiency Data
Water Quality Criteria
Compute Ills
and Industrial
Flow per POTW
Normalize if
necessary
Calculate Industrial
Sludge Quality/Quantity
Calculate POTW
Influent
Quantify Environmental
Effects
• Water Quality Violations
• Emission to Air
• POTW Sludge Quality
• POTW Effluent Quality
Quantify Option
Costs
• Industrial Sludge Disposal
• Industrial Pretreatment Techology
• Pretreatment Program Costs
• POTW Sludge Disposal Costs
Output Summary
of Results
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TABLE 2-2. MAJOR DATA SOURCES USED BY THE COMPUTER MODEL
DATA GROUP DATA XHPUT ELEMENT
POTW Data
Daca On
Industrial
Users
Sludge
Generation/
Water
Quality
Data
Cose Daca
Miscellaneous
Data
POTW ID & Location
POTW Flow
POTW Level of Treatment
Methods of Sludge Dispodal Used by POTW
POTW Removal Efficiency of Priority Pollutants
Industrial Flow to POTW
Number of ID's per Category
Total dumber of Direct lU's per Category
Total Number of Industrial Planes per Category in U.S.
Total Number of Direct Industrial Dischargers Per Category in US
Average Model Industrial Plane Flow per Category
Raw Wasce Concentrations
Raw Waste Concent. Assuming No Pretreatment In Place (Baseline)
Industrial Sludge Generation Races
Municipal Sludge Generation Rates
Average Receiving Stream Flows
Low Receiving Stream Flows
Receiving Stream Water Quality Criteria for Aquatic Life
Receiving Stream Water Quality Criteria for Public Health
Volatilization Rate of Volatile Toxic Organics
Unit Cose for Pretreacmenc Technology
Cost Estimate for Development of Local Pretreatment Programs
Cose Estimate for Implementation of Local Prerreaemenc Programs
Unit Industrial Sludge Disposal Coat
Unit Municipal Sludge Disposal Cose Per Method
Pollutant Concen. Contrib. by Non- Indus. Sources u Model POTW
Matching between SIC Codes and Category Codes
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4. The EPA NEEDs Survey provided the total flow, industrial flow and
sludge disposal method(s) for each POTW. The NEEDS Survey was also
used for generating descriptive statistics on the POTW population.
5. STORE! and USGS data bases were used to determine the applicable stream
flow for POTW discharges.
2.2.3.3 Weaknesses of the Modeling Effort
The model was designed to simulate the interactions of industry, the POTW
and the environment at each municipality. However, the model was designed
primarily to indicate specific differences between various pretreatment options.
Accordingly, the results calculated for any particular POTW are often inaccurate
because of the generalizations and normalization assumptions needed to design
the model and because of certain data deficiencies. Nonetheless, the aggregate
results closely represent the actual cost and environmental effects expected
from pretreatment. The major omissions and assumptions of the modeling exer-
cise that affect the conclusions are:
POTW Module Weakness
• Conventional pollutants are not addressed, except as they affect sludge
generation. EPA data for each of the categorical industries does not
always include treatability of conventionals and removal by pretreatment
technologies to be incorporated into the model. This could be taken
into account in future analyses.
• The POTW removal efficiency for each pollutant in the model is identical
for all POTWs within a given level of treatment. The most representa-
tive data on priority pollutant removal by a POTW is the EPA 40 POTW
study which only includes well operating plants. The median removals
from this study are used in the model. As a result, the estimates of
possible water quality violations are probably a minimum.
• Municipal sludge was defined to be non-hazardous. The cost of municipal
sludge disposal is, therefore, not a function of level of contamination
with toxic pollutants from industry — no matter how severe the contam-
ination. Consequently, improved sludge quality will not have any
quantifiable economic effect in the model. If EPA issued new sludge
criteria, then certain sludge disposal options utilized by POTWs might
need to be replaced by more costly options. This result could increase
the cost effectiveness of some pretreatment options.
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Ambient water quality data for toxic pollutants is not available for
most water bodies. Therefore, Che model could not calculate the incre-
mental degradation caused by the POTW discharge. As a result the
actual number of violations are likely to be substantially higher than
those calculated by the model, especially when several POTWs and other
direct dischargers are on one stretch of a stream. The model could be
modified to take into account other discharges so that the marginal
water quality impacts of each POTW can be calculated.
Industrial Module Weaknesses
The only common denominator between the NEEDS Survey information of POTWs
and D&B identification of lUs is the city name. Consequently, Ills
within a POTW service area but in a suburb or different city will not
be counted in this method. This affects the distribution of industry
in each POTW simulation. The model uses EPA waste load data for each
of the categorical industries to construct the influent to the POTW.
Accordingly, errors in the identification of industrial users' impacts
the environmental and costs outputs from the model for individual POTWs.
However, these errors have only minimal effect on the aggregate results.
Within cities with multiple POTWs, D&B cannot distinguish which POTW
services each III discharger. This error is minimized by the flow
normalization procedure described in Appendix C-3.
Each IU is assumed to have the characteristics of the EGD model plant.
As a result, the characteristics of an individual POTW will contain
errors related to the degree to which actual ITTs in that system vary
from the national composite. Again, this assumption leads to an under-
statement of water quality impacts.
SGD has not entirely verified all organic priority pollutant discharge
data from industry categories. Model plant data are especially suspect
for the organics and plastics industry due to diversity within the
industry. Consequently total toxic organics had to be treated as a
group in the model rather than individually. Therefore, the model
does not now estimate water quality criteria exceedences for toxic
organic pollutants.
EGD has not entirely verified the amount of metal pollutant discharge
from industrial categories.
Industrial sludge was defined to be hazardous. In light of the current
delisting of certain industrial wastes of hazardous this assumption results
in an overstatement of disposal costs.
Overall Data Weaknesses
The bench mark for water quality impacts of POTW discharges on the
model is the Federal Water Criteria, and Drinking Water Standards.
State standards were evaluated but were not found to be better for use
in the model.
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• Scream flow data is only available for 703 screams from computerized
data bases and other readily accessible information. However, both
the 132 POTW Data Base and Che 703 stream flows available for Che
2,000 POTWs show similar Crends. For boch groups, the average scream
flow is approximately 10,000 cfs, influenced by a small number of very
large screams. The median scream flow from Che 703 streams is approxi-
mately 500 cfs. versus 400 cfs. for Che 132 POTWs. Since Che character-
istics of Che 132 POTWs are nearly idencical Co chose of Che encire
sec of POTWs (chis is documented in SecCion 2.2.1.2), it is likely that
Che 703 scream flows are also representative of Che distribution of
screams servicing Che 2,000 POTWs. EPA is currendy reviewing Che rep-
resenciveness of Che stream flows and dilution ratios used in Che model.
2.2.3.4 Aggregation of Che Modeling Results For Comparison of Options
As explained previously, Che model calculates a variety of cosC and environ-
mental quality data for each POTW. The last step in Che modeling exercise is
preparation of an aggregate summary cable, presenting the national costs, and
Che net improvemenC in waCer, air and sludge qualiCy. The aggregation output
can be used Co compare Che results of various pretreatment options. Items
that appear on the aggregation summary include:
• Industrial sludge quantity and quality
• POTW sludge quanticy and qualiCy
• POTW influenC and effluenC quality
• Applicable Water Quality and Health Criteria
• Ambient stream concenCration (POTW effluenC concentration/dilution
ratio)
• Average Incremental Percenc of Water Quality criteria consumed by the
POTW discharged
• Number of POTWs exceeding water qualiCy criCeria.
The aggregace results closely match available EPA national projections and mea-
surements. A detailed analysis of Che model's accuracy is presented in Appendix
C-4, and Che model results are summarized in Chapter 4. In general, Che model
appears Co be a credible simulation of a POTW system and a reasonable analytical
cool for quantifying che nacional impacts of alternative pretreatment programs.
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Aggregate results are more representative of national cost and environ-
mental impact than is the result for a particular POTW. Inaccuracies in
individual POTWs could be greatly minimized by improving the quality of the
input data. For example, by contacting the POTW to determine its actual service
area, the accuracy of local industrial pretreatment costs and industry dis-
charge calculations could be improved greatly. Thus, the model is a useful
predictive tool for local POTWs and States having accurate municipal data.
Moreover, the use of local site specific water quality and local sludge criteria
would enable the model to be used to optimize the levels of industrial waste
control needed to meet local environmental goals at specific POTWs.
2.2.3.5 Sensitivity of the Model
The measure used by the model to assess water quality criteria is
exceedances, which are defined to be an incremental stream concentration for
any pollutant contributed by a POTW that exceeded the National Water Quality
criteria. This measure, although useful is limited in that the number of
exceedances is primarily driven by the ratio of stream flow to POTH flow—the
dilution ratio. Combined with the very low criteria for some pollutants, this
caused the exceedances to be fairly insensitive to industrial flow characteris-
tics. The example below serves to illustrate the problems.
E SAMPLE 1
Cadmium has an aquatic life chronic toxicity of 25 ug/1. The model
projects a cadmium contribution of 3 ug/1 from non-industrial sources
of which 50 percent (1.5 ug/1) will pass through a secondary POTW.
Consequently, any POTW with a dilution ratio of 60 to 1 (1.5 ug/1
t 0.025 ug/1), or less will exceed the cadmium limit if no industries
are present. Pretreatment in any cities in this dilution range will
not prevent the discharge from causing exceedance.
E X AMPLE
Conversely, at POTWs with very large stream dilution ratios even a
large industrial flow with no pretreatment may not cause a violation.
Using cadmium, a POTW with 10 percent of its flow from metal finishing
operations would expect influent cadmium levels to increase by 24
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ug/1, with 12 ug/1 passing through the plant. Added to the 1.5 ug/1
effluent concentration from non-industrial sources, an exceedance would
be caused only if the dilution ratio for that POTW was less than 540
to 1 (13.5 ug/1 * 0.25 ug/1). The median dilution ratios at the 703
municipalities for which flow data were available is only 110.
Consequently, for a signficant number of POTWs with small or large
dilution ratios, the level of pretreatment has no effect on the number
of exceedances.
To increase the sensitivity somewhat, the model also indicates POTWs that
exceed 50 percent and 25 percent of the water quality criteria. These numbers
implicity assume that the POTW is not the only discharger on a stream, and set
the other sources of pollutant equal to the POTW concentration or three times
the POTW concentration respectively.
The model is much more sensitive to pretreatment options where it predicts
absolute values, such as POTW influent concentration, effluent concentration or
sludge concentrations. These values are directly calculated from the input
conditions and can be used to indicate the absolute and percentage differences
between pretreatment options. These results and sensitivities are discussed in
more detail in Appendix C-4.
2.3 Benefits Investigation
2.3.1 Introduction
In this report the benefits of pretreatment are described both qualita-
tively and quantitatively. Three quantitative measures of water related bene-
fits are: 1) changes in effluent pollution loadings resulting from pretreatment;
2) improvements in water quality as indicated by the elimination of exceedances
of federal water quality criteria; and 3) dollar values of water based recrea-
tion activities, such as boating, fishing, and swimming which could be expected
to occur given improved water quality. This section briefly describes the
methods used to monetize recreation benefits. The assumptions of the approaches
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used, and their limitations are also discussed. The resales of the analysis
are given in Chapter 4. A more detailed discussion of the estimation techniques
is provided in Appendix E.
2.3.2 Approaches to Benefits Estimation
Methodology
A methodology that could be used within the tine and resource conataints
of this study was developed for monetizing the benefits of pretreacment. This
methodology was used to estimate recreation benefits for 17 municipalities
in which the model estimates that exceedances of federal water quality criteria
are all eliminated as a result of pretreatment. Benefits associated with boat-
ing, fishing, and swimming are monetized for each of these cases by combining
local information on affected stream area and its capacity for recreation use,
with estimates of the values attached to the different forms of recreation by
Individuals. These values, or benefits "factors" were developed (in conjunction
with EPA) from several national and case specific studies of the benefits of
water pollution control.
Two different approaches to estimating benefits were used for each case
where exceedances are eliminated. One approach estimates total user benefits
resulting from boating and fishing which are assumed to occur only after all
exceedances are eliminated. This is done by first estimating the number of
individuals that could participate in these activities (based on the full use
capacity of the area of water made cleaner and on the number of recreation
days available In a year), and then multiplying the number of participants by
the value per person per day of activity. The estimates of fishing and boating
capacity are made using recreation planning standards adopted by the State of
Ohio in its State Comprehensive Recreation Plan.
The other approach monetizes the user benefits associated with achieving
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water of swimmable (and therefore boatable and fishable) quality. These esti-
mates are made by estimating the number of households living in the county or
counties containing or adjoining the affected area of water, and multiplying
that number by the value per household of having swimmable water nearby. This
approach differs from the above approach in two ways. First, while the other
method only measures fishing and boating benefits, this method measures fishing,
boating, and swimming benefits. Second, while the first approach attempts to
estimate use capacity based on the area of water available, this approach
measures benefits based on the population available to recreate in or on the
water, without considering whether the area of water available is sufficient
to support the local population. Neither approach measures non-user benefits,
which include existence, or option value, and aesthetics. Assumptions and
limitations of these approaches are discussed next.
Assumptions and Limitations
The approaches used here monetize only user recreation benefits. But
health effects, and reduced water treatment costs may be significant for toxics,
and non-user benefits from cleaner water can be a substantial fraction of total
benefits. This limitation contributes to an underestimation of total benefits.
The underlying assumption basic to both approaches is that recreation
uses are achieved only in cases where all exceedances are eliminated by pretreat-
ment. Implicit in this assumption is a base case scenario in which no recrea-
tion uses of water occurs if one or more of the federal water quality criteria
(regardless of which criteria) is exceeded on the segment of water affected by
the POTW. Achieving recreation uses is thus assumed to be a threshold effect.
In general, this assumption probably leads to overstated benefits, as some
boating, fishing, or swimming may occur in areas having exceedances.
Another assumption common to both estimation methods is that the POTW
is the only source of pollution discharges. And as a result, all benefits of
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cleaner water are attributed to cleaner POTW effluents. While this assumption
contributes to an overestimation of benefits in those cases where exceedances
are eliminated, it does not capture the contribution of POTWs to attaining
uses where pretreatment alone does not eliminate all exceedances.
Finally, the accuracy of the estimates of total benefits is limited to the
accuracy of the estimates of affected stream area, population, number of recrea-
tion days available, and the national benefits factors, which may or may not
reflect local recreation values. Other assumptions and limitations are dis-
cussed in Appendix E.
Testa of Reliability
Both of the approaches described above have been tested by applying them
to three EPA case studies which used significantly more complex estimation
techniques to monetize recreation benefits. Comparison of the results indicates
that the use of simple benefits factors, planning standards, and population
estimates produces monetized benefits in the same range as those calculated
using the more sophisticated methods (see Appendix E Table E-6). Of course,
it is uncertain whether the performance of the simpler approaches in these
cases is representative of their performance in general.
Use of Results
The results for the 17 POTWs can provide a useful indication of whether
the aggregate benefits and costs are roughly commensurate for the POTWs analyzed,
but probably should not be relied on for making program tradeoffs. Conclusions
for the individual cases studied are likely to be valid in those instances where
benefits greatly exceeded costs or where costs greatly exceeded benefits.
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3. ASSESSMENT OF THE MEED FOR CONTROL OF INDUSTRIAL DISCHARGES TO POTWs
This chapter summarizes findings on problems experienced by POTWs receiving
industrial wastes. Data supporting this analysis were drawn from the studies
discussed in Chapter 2 and presented in Appendix B. Modeling results from
Appendix C for two pretreatment alternatives are also utilized for comparative
purposes to assess the effectiveness of pretreatment in controlling industrial
wastes. These alternatives are:
(1) Current level of pretreatment in place;
(2) Estimated level with the current 40 CFR 403 program including all
categorical standards.
Appendices B and C should be consulted for information or additional details
on research methodologies, data sources, assumptions, and weaknesses in the
analysis.
The purpose of this discussion is to quantify the need to control indirect
discharges of toxic pollutants. To a large extent the interpretation of this
analysis depends on statutory or regulatory triggers which define the accepta-
bility of levels of toxic discharges to the environment. Unfortunately, spe-
cific toxic limits for ambient water quality are not universally accepted and
the development of sludge criteria is in its infancy. As a result, it is not
possible to report on the severity of an environmental impact with confidence.
However, the relative impacts can be compared among options. In addition, the
amount of pollutants which pass through POTWs to the environment has been
calculated and are reported in this chapter.
In this analysis indicators of the magnitude of environmental problems
are examined and estimates of improvement that would be afforded by pretreat-
ment are made. The central emphasis of this analysis is on the need to control
toxic pollutants discharged to POTWs by industry. In addition, the need for a
general S403-type program to establish the impact of industry on POTW operations
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and Co control prohibited discharges is addressed in this chapter. The environ-
mental problems examined in this section are principally those which the pre-
treatment program was designed to prevent, namely: water quality degradation
from toxic pass-through, interference and by-passes, operational problems
caused by toxic interference, and contamination of sludges by toxic pollutants.
In addition, qualitative results are presented on worker health and safety,
air pollution, and groundwater contamination problems which occur at POTWs
that receive industrial wastes.
3.1 WATER POLLUTION
The measures of water pollution detailed in the previous chapter are
NPDES violations and instances where water quality standards are exceeded. In
this section, documentation of exceedances and NPDES violations are evaluated
to determine the extent and severity of water pollution problems caused by
industrial dischargers. For several reasons the data compiled on exceedances
of water quality criteria should be viewed as minimum values. First, they
do not include the impact of by-passing of raw waste by the POTW on water
quality. This impact ia potentially severe. Second, the data on ambient
water quality is weak and no allowance is made in this analysis for background
levels of toxics. One would expect additional exceedances of water quality
criteria without pretreatment if background levels of toxics could be specified
accurately. Thus, the normalization assumptions discussed in Section 2.3
lead to under-estimates of the number of water quality violations.
3.1.1 NPDES Permit Violators
Priority pollutants from industrial and nonindustrial sources are often
discharged through POTWs to the environment. The release of toxic pollutants
in POTW effluents is termed "pass through" and may cause the facility to vio-
late its NPDES permit, or cause water quality standards (which protect the
use intended for the receiving body) to be exceeded. A simple way to measure
the need for pretreatment is to count violations of NPDES permit limits and
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water quality standards for POTWs with and without pretreatment in place.
Unfortunately, very few POTWs have toxic limits in their NPDES permits. The
132 Study (representative of the 2,000 POTWs requiring pretreatment programs)
revealed that 87 percent of POTWs do not have metals limits and 85 percent do
not have toxic limits in their NPDES permits. Accordingly, NPDES violations
are not a good indicator of toxic pass-through problems at POTWs. Because the
number of POTWs in the 132 Study that have NPDES permit limits specified for
metal and toxic pollutants is so small, an analysis of violations for these
pollutants is not significant. However, because 94 percent of the POTWs in
the 132 Study have NPDES permit limits specified for conventional pollutants,
the analysis of violations for these pollutants is signficant. Of the POTWs
with limits for conventional pollutants specified in their permits, 40 percent
report violations for these pollutants. The average frequency of violations
for these POTWs is reported as occurring 39 percent of the time.
The 77 POTW Study, which focused on POTWs treating less than 5 mgd,
indicates that 66 percent experience permit violations, and almost two thirds
of these violations are attributed to industrial contributions. Many of the
plants violated monthly as well as daily discharge limits. This finding is
corroborated by data in the O&M File that show 60 percent of POTWs reporting
O&M problems associated with industrial waste were in violation of NPDES per-
mits. Violation of conventional limits may be indicative of upset and inter-
ference problems which are likely to cause reduced incidental removal and high
amounts of pass-through of toxics at these POTWs.
3.1.2 Exceedances of Water Quality Criteria
There is little data on the water quality impacts of POTWs in the litera-
ture. In this project the POTW model was used to simulate the interaction
among industrial users, POTWs, and receiving bodies. The analysis was conducted
on the 665 POTWs for which the stream flow data is complete. Results were scaled
up to cover 1,839 POTWs out of the population of 2,000 POTWs estimated by EPA and
the States to need pretreatment programs. (The remaining 161 POTWs were found
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to have no flow according to Che Needs Survey—attributable either to file er-
ror or that the plant is currently under construction—and were therefore ex-
cluded from this analysis. For the same reason the 703 POTWs for which we had
stream flow data were scaled down to 665.) Nine toxic metals, cyanide, and
total organics were modelled in the project. The model uses the POTW-to-stream
dilution ratio to calculate the concentration of each pollutant in the receiving
water body discharged from the POTtf. This concentration is compared to Federal
water quality criteria as a measure of water quality impacts. Table 3-1 sum-
marizes the percentage of plants which would violate the Federal water quality
criteria for each pollutant, assuming the current level of pretreatment in place.
3.1.2.1 Results of Modeling Analysis
Results of this analysis are presented in Table 3-1 for two pretreatment
options:
(1) Current level of pretreatment in place, and
(2) The current 40 CFR 403 pretreatment program with categorical
standards.
The data shows that nearly half of the POTWs (46 percent or 845 out of
1,839 plants) exceeded 100 percent of the the cadmium criteria. Data set D on
Table 3-1 compiles these data. However, few POTWs exceed the criteria for
many of the other pollutants. In every case that another criteria is exceeded,
the cadmium value is also exceeded. The exceedances in Data set D were calcu-
lated assuming that background levels of pollution are zero and that the POTW
is discharging into pristine waters. In short, the POTW is the sole source of
water pollution.
Perhaps a more realistic way to measure the impact of indirect users is
to tabulate the number of POTWs exceeding 50 percent of the water quality cri-
teria. This approach assumes that other sources are accounting for a level of
pollution equal to half of each criteria. If the marginal contribution of the
POTW is at or above the remaining portion of the criteria, then an exceedance
will occur. Data set C compiles the results of modeling this assumption.
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TABLE 3-1. MODEL INDICATORS OF WATER QUALITY VIOLATIONS
(A) AVERAGE PERCENT OF AQUATIC WATER QUALITY CRITERIA USAGE BY POTWs
(Based on Chronic Aquatic Life Criteria Values and Mean Annual Stream Flow)
With Current Amount With Full
of Pretreatment in Place Precreatment
Silver (Ag) 127 120
Cadmium (Cd) 972 732
Chromium (Cr) 7 2
Copper (Cu) 26 12
Mercury (Hg) 6 5
Nickel (Hi) 5 1
Lead (Pb) 25 19
Zinc (Zn) 7 3
Cyanide (Cn) 58 20
(B) PERCENT OF POTWS EXCEEDING 25% OF AQUATIC LIFE WATER QUALITY CRITERIA
Silver (Ag) 39 38 1
Cadmium (Cd) 66 62 4
Chromium (Cr) 6 0.8 5
Copper (Cu) 18 11 7
Mercury (Hg) 5 41
Nickel (Ni) 4 0.3 4
Lead (Pb) 18 16 2
Zinc (Zn) 7 34
Cyanide (Cn) 25 16 9
(C) PERCENT OF POTWS EXCEEDING 50% OF AQUATIC LIFE WATER QUALITY CRITERIA
Silver (Ag) 29 28 1
Cadmium (Cd) 57 53 4
Chromium (Cr) 3 0.2 3
Copper (Cu) 12 66
Mercury (Hg) 2 20
Nickel (Ni) 2 0.2 2
Lead (Pb) 11 10 1
Zinc (Zn) 2 1 1
Cyanide (Cn) 18 10 8
(D) PERCENT OF POTWS EXCEEDING 100% of AQUATIC LIFE WATER QUALITY CRITERIA
Silver (Ag) 19 18 1
Cadmium (Cd) 46 43 3
Chromium (Cr) 2 02
Copper (Cu) 7 34
Mercury (Hg) 1 0.3 1
Nickel (Ni) 1 0 1
Lead (Pb) 6 5 1
Zinc (Zn) 1 0.2 1
Cyanide (Cn) 11 6 5
•JRB Associates*
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3-6
Almost 60 percent of the POTWs would violate the cadmium criteria. Additionally,
a few other criteria are becoming important (silver at 29 percent and cyanide
at 18 percent).
If the background level is assumed to be 75 percent of the water quality
criteria, then POTWs contributing 25 percent or more will cause exceedances.
Data set B shows that two-thirds of the POTWs will exceed the cadmium criteria,
and 40 percent will exceed the silver criteria. In addition to cyanide (at 25
percent) and copper (at 18 percent), lead is also being exceeded routinely (at
18 percent) under this assumption.
Data set A shows the average percentage of the water quality criteria for
each pollutant attributed to the POTWs modeled. Not surprisingly, the largest
values, for cadmium and silver, in data set A are greater than 100 percent. The
values reflect the low criteria for these parameters. The data shows that
chromium, mercury, nickel, and zinc criteria are not likely to be exceeded
because, at an average POTW, other sources would have to contribute more than
90 percent of the water quality criteria to cause exceedances for these para-
meters.
The model was also used to measure the impact that categorical standards
would have on reducing water quality exceedances from their current level.
Table 3-1 includes these data. The improvement is not dramatic. Categorical
standards only reduce by a few percent the number of POTWs with exceedances.
Assuming pristine conditions, exceedances at only 61 POTWs were eliminated
entirely. The reason for so few reductions in exceedances is that the water
quality criteria for the pollutants are relatively low. When industry pretreats
at these POTWs, the residual pollutant levels in the POTW effluent contributed
by non-domestic sources are still high enough to cause the criteria to be ex-
ceeded. Generally, the dilution ratio (stream flow to POTW flow) at the POTWs
causing exceedances is low. However, as discussed in the next subsection, the
fact that an exceedance is not eliminated does not mean that pretreatment has
not had a beneficial effect on water quality.
-JRB Associates.
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3-7
3.1.2.2 Explanation of Results
The five critical variables which determine whether POTW discharges would
cause water quality criteria exceedances are:
1) Toxics contribution from industrial and non-industrial sources to
POTW influent
2) POTW removal efficiency
3) Stream flow and dilution ratio
4) Background (ambient) water quality applicable
5) Water quality criteria
Each of these variables can significantly affect the number of exceedances.
However, because of the actual range of their values, some variables are more
critical than others. For example, POTW removal efficiency is not very critical
because (in the model) constant efficiencies were assumed for each type of
treatment (primary, secondary and tertiary). The removal across treatment
types for copper is representative. It varies by a factor of about 4; from 82
percent for tertiary treatment to 19 percent for primary treatment. This
variation is hardly signficant when compared to the variation in dilution
ratio.
Dilution ratio is an index of POTW flow to stream flow below the POTW.
These ratios can vary greatly. For the 665 POTWs the range is from 1 to 1 up
to 30,000 to 1. Clearly, the dilution ratio can cause water quality to vary by
several orders of magnitude. Accordingly, it is a major determinant of
exceedances.
The value of the water quality criteria also has a signficant impact on
exceedances. Table 3-2 lists the aquatic life criteria for the pollutants
analyzed in this study. Notice that the value for nickel is about 4 thousand
times larger than for cadmium. Obviously, exceedances for cadmium are more
likely than for any of the other pollutants. The data on Table 3-1 discussed
•JRB Associates.
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3-8
TABLE 3-2. THRESHOLD DILUTION RATIOS
Pollutant
Ag
As»
Cd
Cr
Cu
Hg
Ni
Pb
Zn
Cn
Aquatic Life
Water Quality
Criteria
(ug/1)
0.12
440.0
0.025"
44.0
5.6
0.2
96.0"
3.8"
47.0
3.5
The Critical**
Mean POTW Ratio Based
Effluent on Medium
(ug/l)0 Effluent Concentrations
1.0 8/1
1.0 None
3.0 120/1
33.0 1/1
38.0 7/1
0.13 1/1
56.0 1/1
12.0 3/1
145.0 3/1
151.0 43/1
9 SOURCE: 40 POTW Study
09 Critical dilution ratio': The ratio at or below which a water quality
exceedance would be expected to occur at half of the POTWs.
« The acute number is presented since there is no chronic water quality
criteria value for arsenic.
" Based on hardness of 100 mg/1 CaC03.
•JR8 Associates.
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3-9
in the previous section bears this out. The most exceedances occurred for
cadmium.
Water quality criteria can be used to calcuate a "critical" dilution ratio
for each contaminant. This is done by dividing the criteria into the mean POTW
effluent concentration of the contaminant. Table 3-2 lists critical dilution
ratios using mean effluent concentrations from the 40 POTW Study. As expected,
the highest value is for cadmium. This means that even at a dilution as large
as 120 to 1 that cadmium exceedances are expected. Since the critical dilution
ratios are calculated using mean effluent values, half the plants facing the
critical dilution ratio should exceed the criteria. Again, the data from the
model presented in the previous subsection supports this analysis. The average
dilution ratio for the 665 POTWs is 110 to 1. This is close to the critical
dilution ratio for cadmium (120 to 1), and nearly half of the POTWs (46 percent)
violate the cadmium criteria.
Critical dilution ratios can probably be used as a preliminary method Co
spot likely water quality problems caused by POTWs. The only data it requires
is stream flow and the applicable water quality criteria.
Although nearly half of the POTWa modeled cause water quality to be ex-
ceeded, very few (only 61) had their exceedances eliminated through categorical
standards. The reason for this is that the contribution of pollutants from
nonindustrial sources plus the residual discharge from industry are often suf-
ficient to trigger exceedances.
Table 3-3 lists the mean contribution of pollutants from industrial and non-
industrial sources in POTW influents. Clearly, most of the contribution is from
industry. However, domestic sources alone will cause an exceedance if the water
quality criteria is low. For example, the removal efficiency for cadmium by
POTWs at secondary treatments is 50Z so that non-industrial sources contribute
an average of 1.5 mg/1 of cadmium to receiving bodies (.50 x 3.0 mg/1). The
•JR8 Associates-
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TABLE 3-3. RELATIVE CONTRIBUTION OF INDUSTRIAL AND NON-INDUSTRIAL
SOURCES TO POTW INFLUENTS
Influent Concentration
Pollutant
Ag
Cd
Cr
Cu
Hg
Ni
Pb
Za
Ca
Mean
Non-Industrial
Sources
(ucr/1)
5.Q
3.0
50.0
61.0
0.3
21.0
49.0
175.0
41.0
Average*
Influent
Concentration
JRB Associates.
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3-11
threshhold dilution ratio for non-industrial sources Co trigger an exceedance
for cadmium is 60 to 1. Over 25 percent of the POTWs modeled would exceed the
cadmium criteria just from non-domestic sources.
The above analysis does not mean that industrial pollution control is not
important. It does mean that at many municipalities in the nation, other pol-
lution control programs, in addition to controls on industrial users, are needed
to meet water quality goals.
3.1.2.3 Characteristics of POTWs Causing Exceedances
From the previous discussion one would expect to find exceedances at POTWs
with low dilution ratios and large industrial flows. Table 3-4 supports this
premise.
TABLE 3-4. DISTRIBUTION OF POTWS BY DILUTION RATIOS
PERCENT OF POTWS IN EACH DILUTION RANGE
Dilution Ratios
0^5050-100100-200200-500500-1000
All POTWs 36.8 10.5 10.2 13.6 8.3
POTWs Currently 52.0 22.2 19.3 5.2 1.3
with Exceedance
The cable lists the percentage of firms in a range of dilution ratios for all
POTWa as well as for the POTWs currently estimated to have exceedances. Not
surprisingly, POTWs with exceedances are concentrated in the low dilution
ratio range. Very few of these POTWs have dilution ratios greater than 200 to
1 (the average for POTWs with exceedences is 110 to 1). Conversely, the dis-
tribution of all POTWs is more uniform across the dilution ratio ranges. It
is highest at the lower end of the range and nearly constant in the middle
ranges. At the upper range, the concentration is again high, indicative of
the overriding effect that dilution has on exceedances. None of the plants in
this range showed any exceedances.
• JRB Associates*
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3.1.2.4 Limitations of Che Results
A number of inherent weaknesses in the analysis need consideration when
examining the significance of these findings. First, limitations in industrial
raw waste-load data prevented the measure of toxic organics violations although
they are probably occurring. Second, the modelling exercise forces averages to
be employed for such variables as industrial influent and stream flow. Also
data on the ambient water quality of receiving streams was incomplete so that
variation in background levels of pollutants could not be accurately assessed.
In actuality, industrial slug loads and low flow stream conditions make addi-
tional water quality exceedances possible. Nonetheless, these model results
are useful for comparative purposes.
3.1.3 Effluent Improvement Comparisons
Several data sources demonstrate that industrial users constitute a major
source of toxic pollutant contributions to POTWs. Table 3-5 shows the percen-
tage of improvement in POTW effluent quality experienced (or projected) fo'r
cities with and without precreatmenc. These data were taken from case studies
of six municipalities and from a comparison of effluents from cities without
pretreatment programs to similar cities with pretreatment programs from the
40 POTW Study. As would be expected, pretreatment significantly reduces- the
concentrations of toxic pollutants in POTW effluent for all but two parameters.
An anomaly in the data occurs for cyanide and copper, which increased in concen-
tration.
3.1.4 Bypass (and Overflow)
Bypass occurs when flow to a POTW is diverted either before it reaches the
treatment works or within the treatment works, and is subsequently discharged
to receiving waters with only partial treatment or with no treatment. These
events may be intentional or unintentional, usually resulting from a combination
-JR8 Associates.
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3-13
TABLE 3-5
PERCENT IMPROVEMENT IN POTW EFFLUENT QUALITY WITH PRETREATMENT PROGRAM
Pollutant
Parameter
Silver (Ag)
Arsenic (As)
Cadmium (Cd)
Chromium (Cr)
Copper (Cu)
Mercury (Hg)
Nickel (Ni)
Lead (Pb)
Zinc (Zn)
Cyanide (Cn)
Total Metals
Toxic Organics
POTW Study(l) Model
0 6
NA 26
33 26
33 81
(7) 57
NA 29
(9) 74
59 21
51 U7
16 NA
26 63
75 70
Selected
Case Studies
NA
66
53
62
(56)
65
28
74
64
(30)
36
99
Mean
1.5
36
39
58
-2
49
32
49
52
-7
40
82
(1) percent improvements are derived from different cities with and without
pretreatment programs.
Data Sources: Appendices B-4, B-5, and C-3
•JRB Associates.
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3-14
of sewer overflows, precipitation, equipment failure, or in some instances,
industrial overloads. Even though the bypass may not have been caused by indus-
try, the industrial toxics which are present in the POTWs influent at the time of
bypass are discharged directly into the environment without treatment. Thus,
the occurence of bypass may cause toxics pass-through.
Bypassing does not significantly increase the yearly amount of pollutants
entering receiving bodies. A calculation using the data reported above verifies
this conclusion. The maximum bypassing (10 hours per month of all raw wastewater
by 35 percent of the POTWs) would increase pollutions loads by only 3 percent
per year. Since this loading occurs over short durations, they are acute rather
than chronic occurences. Acute water quality criteria are much higher values
than chronic criteria. As a result, only the most extreme by-passing events
will cause acute water quality standards to be exceeded. Moreover, bypassing
is often necessitated by heavy rain fall which overloads the sewers. Accord-
ingly, industrial wastes which are bypassed are diluted by runoff which mini-
mizes their impact on stream water quality.
Information from Che O&M Data Base shows the occurrence of bypass at POTWs.
Figure 3-1 shows that monthly bypasses occur across the full spectrum of POTW
flow categories and levels of treatment. Overall, 35 percent of POTWs in the
O&M File receiving industrial wastes experienced monthly bypass (33 percent of
all POTWs in the data base had monthly bypass). A majority of these bypasses
last for less than 10 hours, with durations reported ranging from 1 to over 24
hours per bypass.
3.2 INTERFERENCE AND UPSETS
Another major problem is interference with the operation of treatment
plants resulting from industrial waste contributions. Interference occurs
when high volumes or concentrations of pollutants inhibit or interfere with
the normal operation of POTW processes, thereby hindering adequate treatment
of domestic and industrial wastes coming into the plant. Upsets are an extreme
•JRB Associates.
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100
V.
H
O
(J
h-l
H
•C
CJ
o
80
70
(>()
c
PH C/i
w
^ CO / f,
o en 40
w &<
u P
<; co
H ,,,
^ U4 Jl
14 C.
U Ul
10
5-20 20-50
AVKKAOIC DAILY ri.OW (MCI))
SO-100
100-200
X
x
x
x
x
x
>200
3-1. PERCENTAnK OF POTWs KKI'OKTING MONTHLY
SEWAflF. BYPASSES BY AVKKACK DAILY FLOW CATKCOKIES
n
= I'KIMAKY
= SlilXINIJAKY
= TKKTIAUV
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3-16
type of interference where slug loads of pollutants destroy plant functions,
and cause wastewater influent to passthrough untreated.
There is documentation on Che prevalence of interference upsets, and opera-
tions and maintenance (O&M) problems at POTWs caused by industrial wastes. The
77 POTW Study reported a high incidence of interference upsets attributable
to the food and electroplating industries. The O&M data base reveals that 72
percent of the 330 POTWs receiving industrial waste report an O&M problem as-
sociated with that waste. Thirty-eight percent of the 330 POTWs reported
treatment process equipment failure as the O&M problem, and 42 percent reported
sludge handling equipment failure as the problem.
O&M problems associated with industrial waste have no apparent correlation
to POTW average daily flow. While most of the 330 POTWs reporting O&M problems
receive less than 5 MGD, most of the POTWs in the O&M data base also receive
less than 5 MGD average flow.
The data from the O&M file are bolstered by results of the 77 POTW Study
which report that one-quarter of POTWs experienced one or more types of process
upsets. Of those sustaining upsets, 84 percent claimed that industrial wastes
contributed to the upsets. Additionally, 45 percent of the municipalities
examined in the literature case studies reported that the key motivation for
implementing a pretreatment program was the need to protect POTW operations
and equipment from industrial slug loads. (The 132 study reported POTW protec-
tion as the motivation at 27 percent of the plants.) Prohibited discharge
standards are the principal mechanism within the Pretreatment Program for
control of interference. These standards are locally set and vary greatly
from municipality to municipality, depending on local conditions. No attempt
was made to forecast the effectiveness of pretreatment in eliminating interfer-
ence in the modeling effort, because EPA does not have extensive verified data
on conventional pollutants from the categorical industries.
•JRB Associates.
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3.3 SLUDGE CONTAMINATION
Few regulations for control of the disposal of contaminated sludges have
been promulgated, so it is difficult Co assess the constraints that cities will
be faced with in disposing of their sewage sludges. Under current guidelines
all municipal sludges may be treated as non-hazardous wastes.
Sludge contamination results from the incidental removal of toxic pollu-
tants from Che POTW wastevaeer influent in the course of treatment. Munici-
palities already face limited choices and high costs in disposing of POTW
residuals. The contamination of these sludges with high concentrations of
heavy metals and other toxic chemicals can further constrain sludge management
options. Increased toxicity levels in municipal sludge may preclude cheaper
disposal options such as use as a fertilizer or a soil conditioner. In addition,
improper handling of contaminated sludges may lead to the leaching of toxic
pollutants into groundwacer, the introduction of metals into the food chain,
and hazardous air emissions from sludge incineration.
The 40 POTW study showed that virtually all of the metal priority pollutants
removed by Che POTW collect in the resulting sludge stream. The concentration
factors in both primary, secondary and combined sludges vary greatly, depending
on the solids content and other factors, but metals usually ranged between
10 and 1,000. Volatile priority pollutants that were frequently present and
sufficiently above their detection limits had concentration factors of between
less than one and 10. The non-volatile organic priority pollutants had concen-
tration factors between the two other groups.
Several priority pollutants which were reported below their detection
limits in most POTW influents regularly were quantified in sludge streams.
Pollutants exhibiting this tendency include antimony, arsenic, silver, selenium,
phenanthracene/anthracene and pyrene. For example, arsenic was measured above
its detection limit in 15 percent of all influent samples, but in 94 percent of
.JRB Associates*
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all sludge screams. Table 3-6 presents concentration values for metals which
the 40 POTW study found to accumulate in municipal sludges. It suggests that
the ranges of toxicity in municipal sludges are considerable. Table 3-7 shows
that the 2,000 POTW model produced similar concentrations for toxics in munici-
pal sludge. Table 3-7 also demonstrates the effectiveness of pretreatment in
reducing toxicity levels for most heavy metals and toxic organics in sewage
sludge. For instance, pretreatment reduces total metals in sludge by 52 percent
and total organics by 67 percent.
Dramatic improvements in sludge quality have been recorded by cities which
have implemented pretreatment programs. For example, in Muncie, Indiana, a
city with a large contribution of metal platers, sludge concentration (mg/kg-dry
basis) of chromium went from 2,000 before pretreatment to 9.5 after pretreatment.
Copper went from 1,750 to 700; nickel from 8,500 to 150, and zinc from 5,800 to
2,700. Table 3-8 compares the percent of improvement for sludge realized by
selected case study cities against those predicted by our model. The results
are remarkably consistent.
Results of the 77 POTW study further indicate the extent of contamination
of categorical POTW sludge. Table 3-9 indicates that 25 percent of these small
POTWs were either known1 or suspected to have contaminated sludges. Of those
identified as having contaminated sludge, 87 percent of the municipalities
attribute this contamination to industry and 67 percent reported that this
contamination affected their disposal options. Contamination is not clearly
defined by the POTWs, but this analysis assumes it to be the presence of heavy
metals in those sludges that have been analyzed for pollutants. Contamination
findings might even be higher given the high percentage of municipalities
which have not analyzed sludges for the presence of priority pollutants.
Several factors affect the selection of disposal methods at the munici-
pality level.
•JRB Associates*
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TABLE 3-6
CONCENTRATION OF SELECTED METALS IN SECONDARY SLUDGE
FROM 40 POTW STUDY (mg/kg)
Range Average Median
Cadmium 1 - 1622 157 14
Chromium 125 - 1762 730 422
Copper 150 - 3160 894 553
Nickel 13 - 803 240 121
Zinc 420 - 8468 2874 2167
Lead 40 - 1169
Metal mg/kg
SOURCE: Federal Register
•JRB Associates.
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TABLE 3-7
SLUDGE QUALITY WITH AND WITHOUT PRETREATMENT
FROM MODELING EXERCISE
AVERAGE POTW SLUDGE QUALITY (mg/tcg dry wt)
Without
Pretreatmenc
With
Pretreatmenc
Percent
Improvement
Silver (Ag)
Cadmium (Cd)
Chromium (Cr)
Copper (Cu)
Mercury (Hg)
Nickel (Hi)
Lead (Pb)
Zinc (Za)
Total Metals
Cyanide (CJJ)
Toxic Organics
32
26
831
563
1.3
181
147
923
2704
913
32
21
222
274
1.0
60
132
547
1296
306
OZ
19%
73Z
51Z
23Z
67Z
10Z
41Z
52Z
67Z
•JRB Associates*
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TABLE 3-8
PERCENT IMPROVEMENT IN SLUDGE WITH PRETREATMENT PROGRAM
Pollutant
Parameter Case Studies Model Mean
Arsenic (As) MA 00
Cadmium (Cd) 20 28 24
Chromium (Cr) 74 75 75
Copper (Cu) 51 50 51
Mercury (Hg) - 13 7
Nickel (Ni) 75 68 72
Lead (Pb) 71 5 38
Zinc (Zn) 51 35 43
Total Metals 49 51 50
Total Organics NA 70 70
Data Sources: Appendices B-5 and C-3.
-JRB Associates-
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TABLE 3-9
REPORTED INCIDENTS OF SLUDGE CONTAMINATION AT THE 77 POTWS
Sludge Contami-
Needs nation
Analysis Suspected
Known Contarn.
Reportedly
Caused by
Industry
Contain. Practice
Affects Land
Disposal Spread
Method of Sludge
if of
POTWS
22
15
13
10
27
% of
Total
(77)
29%
7. of POTWs -
Experi-
encing
Problem
Listed
23%
of POTWS
that need
analysis
19%
17%
87%
of POTWs
with known
13%
67%
of POTWs
with known
35%
contamination contamination
Source: Appendix B-3
•JRB Associates.
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Landfilling: Currently, 85 percent of municipalities dispose of their
sludges by landfilling. Landfilling is regulated by §4004 of the RCRA Regula-
tion. The following issues affect the future use of landfilling as a sludge
disposal alternative:
• Typically, landfilling costs are ?80/ton dry solids.
• Increased land costs and public opposition to siting of landfills
could decrease their use.
• Increase landfill costs by forcing contaminated sludge to be disposed
in §3000 secured RCRA landfills. This could have as much as a ten-fold
effect on the cost of sludge disposal.
Landspreading; As a disposal alternative for municipal sludge, land-
spreading has seen decreased use in recent years. The following factors
influence the use of landspreading for municipal sluge disposal:
• Landspreading today typically costs ?60/ton dry solids.
• Cadmium criteria prohibits many municipalities from using landspreading
as an alternative.
• Public opinion is typically adverse Co landspreading.
• .Decreased land availability and increased land costs could hamper
future use of this alternative.
Incineration; Incineration/pyrolysis handles one million tons of sludge
per year from the 2,000 municipalities which are subject to the General Pretreat-
ment Regulations. The following factors could potentially influence the use
of incineration as a municipal sludge disposal alternative.
• The typical cost of incineration today is $150/ton dry solids.
• High fuel costs, particularly where sludges are laden with heavy
metals, have already forced many municipalities to go back to land-
filling as a disposal method.
• Localities, such a Phildelphia, have no alternative to incineration
since land availability is poor and shipping costs are high. In time,
these restraints could force other municipalities to incinerate
despite fuel costs.
•JRB Associates-
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3-24
• New technology is being developed (starved-air) which would appreci-
ably lower incineration costs in the future.
Sludge handling coats vary significantly among the various disposal op-
tions. They range from $60/ton for landspreading to $150/ton for incineration.
Excluding a low cost disposal option because of sludge contamination, can have
a very significant impact on municipal sludge management costs.
3.4 ENVIRONMENTAL AND HEALTH CONSIDERATIONS
Three additional areas of concern in a discussion of environmental and
health considerations as they relate to industrial discharge to POTWs are
worker health and safety, air pollution and groundwater contamination. Un-
fortunately, they have received little attention in the technical literature.
However, a few case studies have demonstrated the importance of these three
subject areas in assessing industrial discharges to wastewater treatment facil-
ties.
3.4.1 Worker Health and Safety
Exposure of POTW workers to airborne chemical hazards is the principal-
occupational health concern related to municipal wastewater treatment. The
major source of these constituents are volatile organic compounds discharged
to the public sewer from industrial sources.
In a recent study of 40 POTW facilities, volatile organic compounds were
measured in the wastewater influent. Table 3-10 shows the average concentra-
tions and detection frequencies of 11 compounds that are commonly found in
POTW influent. An attempt was made to compare the presence of these compounds
to airborne compounds which typcially cause health and safety problems.
Table 3-11 briefly describes the airborne concentrations of these compounds in
POTWs. It also shows the applicable exposure criteria, toxicological char-
acteristics, physical properties and industrial sources of these chemicals.
•JRB Associates.
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TABLE 3-]0
Avern -e rnnrpnlrarlnns of 11 Compounds , .
(Concern rations (
Volatile Organic Lom|.ui.nd Actually T| v
benzene 1°
chloroform 5 10
1.2-dlcliloroelliune 10
ethyl benzene 100
melliyl chloride 100
mechlene chloride SO1
perctilorocthylene 5 100
toluene 37 100
I.I. l-irlUiloioeihone 180 350
crlchloroelhylenu 20 SO1
vinyl chloride 5
3) ,
CO ',. , , .1 IV II.,. I...I.I 1 ln.ll .'...
> J
j/j 'at Jll C mm llg
? 3dl 25 C rail UK
n ppm) Heal Ih KfftrlH
P^l' UM .1 1 -at nlc Sysirmlc uculu
1 skin Irrlcanc CNS dtpreasunt
SO liver damage
CNS effects
5 eye and reuplra- naicoclc effects
tory Irritant
100 eyus, nose,
throat "and bkln
Irritant
100 CNS depressant
SOO narcotic
100 olid eye, none CNS depressant
and throat auiy cause hepa-
Irrllant tic Injury
200 eye, respiratory CHS depressant
and skin Irritant
350 eye and dermal narcotic
Irritant
100 eye. nose and CNS depressant
throat Irritant
1 skin Irritant CNS depressant
Phyilc.il P
CD runic VI'2
carcinogen of 75mm
blood forming
tissue
has caused can- 160mm
cer in humans
when adminis-
tered at high
doses
bJnun
7.1mm
CNS effects 4. But in
350mm
|4nm
22mm
100mm
58mio
atrniig coupe la- 2600mm1
t Ion with CNS,
respiratory.
hepatic, and
lymphatic LUII-
cer in hiinuius
ropertleb
ludublrlal Use
UP
176F Solvent, const ItnenL
of motor fuels
I42F Solvent In pharmaceutical
manufacture
IB3P Solvent, an tl -knock
compound
277P Solvent, ant I -knock
compound
-12F extractant, solvent
used in organic chemical
manufacture U>
M
I04F solvent <-"
250F solvent, dry cleaning
231 F feed for chemical
production, solvents
fuel constituent
16SF Industrial solvent
1B8F degreaslng solvent
6.98F used In the muimf.icLure
of polyvlny Ichlurlde ,
solvent, and chemical
aunufactnrliiB 1 uterine -
rt 1 ur ft
ai ate
n '•Somi.u: NIDSII. Interim He-ports 1 k 2. Health Hazards Reports, I9HI. Unpuhl Islied
'l(IO in HOO |i|ih LiuiLuiit rat Inns ULTU measured
1 1 I'. . 1. I . i'n
above the aural Inn hasln of a UWTP. Source:
Pursiin.il ciiuvurs.it Inn. I'nul Manner - KrA/MUKI.
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TABLE 3-11
VOLATILES WITH HIGHEST INFLUENT CONCENTRATIONS
Average Percent of Time
Organic Compound (in ug/1) Detected
Benzene 585 14.4
Chloroform 516 94.1
1,2-Dichloride 223 87.3
Methylchloride 218 97.9
Methlene Chloride 727 94.9
Perchloroethylene 77 92.4
Toluene 46 7.2
1,1,1-Trichloroethane 21 13.1
Trichloroethylene 21 59.3
Vinyl Chloride 17 90.3
SOURCE: EPA 40 POTW Study
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Recently in Louisville, Kentucky, a catalytic converter of an automobile ignited
explosive gases in a manhole causing significant damage to the sewer. This is
only an example of what types of accidents can occur with the presence of
volatile organics in a wastewater treatment facility. There are also case
histories of sewer workers who have been overcome in manholes by toxic volatile
pollutants, even after protecting themselves against normal sewer gas hazards.
(See Appendix B6-1)
Heavy mecals such as lead, mercury, cadmium, chromium, and nickel, from
industrial sources are also contained in the wastewaters which reach the POTW.
In the aeration basin of a typical sewage treatment plant, the heavy metals
may be absorbed onto particulate natter and emitted to the air as aerosols.
These metal-containing aerosols can be inhaled by workers during POTW opera-
tions. The toxicological properties and exposure criteria for heavy metals
commonly found in POTW influent are shown in Table 3-12. The general provisions
of the 403 program are meant to control some of these problems.
3.4.2 Air Pollution
Approximately 400 POTWs incinerate or pyrolyze 1,067,432 tons of municipal
sludge per year. This number is continually 'increasing as landfill space
decreases and incinerator technology expands and becomes more versatile in
meeting the municipalities' needs.
During the combustion of municipal sludges, emissions to the atmosphere
occur in the form of particulates, toxic organics and metals. The majority of
the sludge which is incinerated is generated at secondary level treatment
facilities. These plants generally remove 75 percent of toxic metal pollutants
which accumulate in the sludge. In the incineration or pyrolytic process, a
number of chemical processes can occur, allowing for emission to the atmosphere
of many complex organmetallic and hydrocarbon compounds. Many of these emis-
sions are known health hazards.
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TABLE 3-12
Exposure Criteria for Heavy Metals
CuiicLMicr.il liinu
M..lnls nrl,,.illy
miMiurcd TL
(In mB/m3)
V PKI.
r.,ilmluD I.S7 x 10 .OS .lu.Mi : 0.2
fume. O.I
Chromium 3 x 10* 0.5 O.I
Copper 2.1 x 10"* 0. 1
fume: 0.1
dusti 1.0
II u
local-ill ui e
nsplr.iiury
irrli'int
Iracheo-
bronchlal
irrll.int
akin irritant
n 1 1 h B f r .• r t a
n-s|ilr»iory
Injury, lung
djnage
clumilc
SII-.|ICClud
t.arL inikgun,
kldnuy damage
Industrial
IKe
priiLi * 1 1 VL*
coal Ing u|>|>! led
by elcclropl.il Ing
carcinogen of
lung and nasal
Liivlty (hexa-
valent ihromlum
form only)
respiratory tract
Irritant
___
electrical
Industry, pesti-
cides
Lead
Nickel
Silver
6.1 x I0~
1 x 10'3
O.li
1.0
0.01
0.05
1.0
0.01
skin bcnsltlzer
grayish pigmenta-
tion of akin dnd
membranes
kidney damage, battery manufac-
CNS damage lure, antiknock
compound
carcinogen of electroplating,
nasal cavity. met.il working
lungs, paranasal
sinus
photographic
films. Jewelry,
catalysts
ro
CO
*Theee measurements were taken at an activated sludge plant.
Source: Hortlirop. el ol, 1980. Health Effects of Aerosols Emitted from an Activated Sludgu Plant. Vkisteualer Aerosols
and Disease, EPA Health Effects Research Laboratory. EPA-600/9-80-028.
00
>
&
o
n
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As time progresses a number of things are occuring which will only increase
the atmospheric loading of air pollutants. These items are:
• Increase in the number of POTWs that are incinerating
their sludge
• Increase in POTWs that meet secondary treatment; this
results in a proportional increase of toxics in municipal
sludge.
Air pollution is not considered in the model although the amount of volatiliza-
tion of organics is calculated.
3.4.3 Groundwater
Fifty percent of the nation's groundwater is used as a drinking water
source. Contamination of these groundwater sources has become an increased
concern in recent years. Wastewater treatment facilities are often sources of
groundwater contamination. Approximately five percent of the total volume of
flow which passes through a POTW is estimated to exftitrate, much of it to
groundwater sources. Exfiltration accounts for approximately 750 million gal-
lons per day from broken pipes and cracked liners in holding ponds.
The rate and manner in which a pollutant moves from the source to the
groundwater depends on several complex physical processes. However, many of
the metals and organics found in wastewater generally migrate more rapidly
through soil to a groundwater source.
POTWs as a source of groundwater contamination becomes more critical in
light of the trend of industries to discharge more wastewater to POTWs while
POTWs are not increasing their capacity to handle these increased volumes or
to remove toxic pollutants. Overall, however, little attention has been
given to this problem and data does not exist to quantify the extent to which
industrial pretreatment will mitigate groundwater contamination. Groundwater
impacts are not considered in the modeling exercise.
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3.5 SUMMARY — The Need for Control of Industrial Discharges to POTWs
The extent of upseta and NPDES violations at POTWs indicate a need
for municipalities to identify and survey wastewater sources and take other
measures to characterize their operational and environmental problems. This
need is evident for several reasons.
First, a significant number of the POTWs experience upset and bypass prob-
lems on a persistent basis. The following findings demonstrate this problem:
• The O&M file reports that 72 percent of POTWs receiving industrial
wastes experience operation and maintenance problems associated with
that waste.
• The 77 POTW Study reports that 84 percent of POTWs experiencing process
upsets do so because of industrial discharge to the POTW.
• In the literative case studies, 43 percent of the municipalities cite
protection of the POTW as the key motivation for implementing a pre-
treatment program.
Second, in many instances POTWs do not know if pollutants are passing
through the plant or what causes interferences episodes. Moreover, many plants
have not measured contamination levels of their sludges. Likewise, until
recently very few POTWs had precisely identified the industries discharging
to their treatment facilities. The 132 Study indicates that 36 percent of the
POTWs had not conducted an industrial waste survey (IWS). Of those that had
conducted an IWS, 73 percent reported that they have taken action toward estab-
lishing a formal pretreatment program in accordance with the federal regula-
tions. A majority of cities which have conducted an IWS completed it within
the last three years, suggesting that federal pretreatment program was the
motivation.
The 132 Study contains other data suggesting that many municipalities and
POTWs have not examined the extent of environmental problems at POTWs. Sixty-
six percent of the POTWs studied do not monitor for heavy metals in their influ-
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ent and 69 percent do ooc monitor for the presence oŁ toxic organics. The 77
POTW Study reinforces these findings. Sixty-eight percent of these POTWs have
no industrial monitoring programs. Of those that do monitor, only 12 percent
monitor for metals and 1 percent for toxic organics. Finally, 30 percent do
not have knowledge of the quality of their sludge.
These two findings indicate that many POTWs without pretreatment programs
are potentially subject to industrial - related problems, yet do not know the
source or extent of their problems. These findings indicate the need for a
program, like the General Provisions of the 403 program, which provides a
system for identifying industrial dischargers through waste surveys, monitoring
and control of problem discharges.
Toxic discharges from many POTWs are significant, based on the results of
the modeling exercises. Key findings about toxics from the model are:
• Almost half of Che POTWs exceed water quality standards for at least
one pollutant assuming the POTW is the only discharge to the stream.
• Exceedances of water quality criteria for cadmium and silver occur
with the greatest frequency but cyanide, lead, and copper can also
present water quality problems.
• The impact of the discharge from POTWa on stream water quality depends
on local water quality conditions, stream size and the impact of other
dischargers to that stream.
The number of water quality exceedances reported by the model represent a
minimum number that would be anticipated from POTW discharges because of the
assumptions used in developing the model. The lack of data on ambient stream
quality, dilution ratios and the presence of other dischargers to stream segments
also serve to decrease the occurance of exceedances estimated by the model.
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4. ANALYSIS OF PRETREATMENT OPTIONS
This chapter evaluates a wide range of pretreatment options designed to
address the key findings in Chapter 3. These findings are:
• In the absence of any additional pretreatment requirements,
POTWs are relatively significant dischargers of toxics, con-
tributing about 60% of the total discharge of toxics by in-
direct and direct discharges.
• in the absence of any additional pretreatment requirements,
toxic water quality problems resulting from POTW effluent dis-
charges for at least one of the nine pollutants analyzed are
expected for about 46% of the POTWs and 19% for at least two
pollutants.
• in almost all cases where water quality problems are expected,
POTWs are likely to need more toxic effluent reduction than can
be achieved by categorical pretreatment standards for industry
alone; and
• upsets, bypass, interference and sludge contamination are
site-specific problems with site-specific solutions.
All of the options analyzed (except for the no program option — guidance
only) use the same mechanism to identify, prevent or remedy problems of upset,
bypass, interference and sludge contamination. Each option requires municipal-
ities to implement basic industrial waste control programs along the lines
envisioned in the General Provisions of the 403 Regulations (hereinafter
referred to as the "basic" 403 program requirement). The basic 403 program
calls for a minimal and flexible effort by localities to identify Industrial
users, develop effluent limits for problem discharges and perform permitting,
monitoring and enforcement activities to reduce Industrial discharges harmful
to the POTW or the environment.
The options differ in their strategy for reducing the pass-through of indus-
trial toxic pollutants into the POTWs' receiving waters. The most significant
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difference between the options with regard to reducing pass-through is whether
they are "targeted" or "untargeted." "Targeted" options require controls only
where they are needed to achieve water quality; and "untargeted" options require
uniform controls regardless of the status of local water quality problems.
This analysis has quantified the cost and environmental differences between
targeted and untargeted options. To quantify the differences, the POTW model
was used to estimate the cost of each option to industry and to municipalities.
In addition, the POTW model was used tp quantify a number of indicators of
environmental benefits, including the amounts of toxic pollution removed and
the extent to which each option may reduce water quality violations. Finally,
some of the benefits associated with the options have been monetized.
There are other differences between the options that can have a less
significant effect on cost or environmental impacts, but have important
programmatic implications. These differences include whether the control point
is at the industrial level or at the POTW, whether the requirements are
technology-based or water quality-based, the level of federal involvement
and the reliance on local initiative. The significance of these differences
among the options is qualitatively discussed. However, it was not possible
within the time frame and resources of this study to quantify the cost and
environmental impacts of these differences. For example, it was not possible
to quantify the potential cost savings associated with regulating the POTW
instead of regulating the industries discharging into the POTW. This cost
saving is likely to be small compared to the cost savings associated with
targeting requirements.
This chapter also identifies key implementation and design issues. These
include issues regarding the technical feasibility of developing technology-
based toxic limits for POTWs, water quality waivers and water quality-based
limits. It was not feasible within the time and resource constraints of this
study to develop approaches for overcoming the problems identified.
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Finally, there are additional variations to the options that were not ana-
lyzed. This does not mean that these potential improvements are not important,
but rather that they were less significant considerations from either an impact
or a programmatic standpoint than the design parameters identified above. For
example, two additional potential improvements for the options that are based
on categorical standards include: removal credits allowing industry to meet
less stringent pretreatment standards to the extent that the POTW provides
removal; and equivalency waivers (or grandfathering) for those POTWs whose
existing program is designed differently from federal requirements but has
essentially the same effect. While both of these potential improvements will
likely result in coat savings to either industry or to POTWs, they are likely
to be small compared to the cost differences between targeted and untargeted
options. Further, these modifications are adjustments to the existing program
rather than program alternatives.
This chapter is organized as follows:
• Section 1 describes the key design choices for the options.
• Section 2 describes the options that have been analyzed.
• Section 3 discusses the key differences and similarities between the
options.
• Section 4 presents the environmental impact of each of the options.
• Section 5 presents the options' costs and coat-effectiveness.
• Section 6 discusses the benefits of the options.
• Section 7 discusses feasibility and design issues of the options.
• Section 8 discusses other considerations such as administrative issues.
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4.1 KEY DESIGN CHOICES
There are four key design choices for the options analyzed in this
report:
• Targeted vs. untargeted requirements
• Technology based-standards versus water quality based standards
• Regulation of industry vs. regulation of POTWs
• Presumptive federal requirements vs. back-up federal requirements
These design features are introduced below and discussed in greater detail
later in this chapter.
4.1.1 Targeted Versus Untargeted Requirements
Targeted options require control actions only where there are water quality
problems, whereas options that are untargeted require control actions regardless
of local environmental conditions. All options with water quality-based stan-
dards are targeted. Options with technology-based standards are untargeted
unless they include a water quality waiver.
By definition, targeted options should be more cost-effective than untar-
geted options. However, targeted options may be technically more difficult and
expensive to implement and may require greater federal Involvement than do un-
targeted options. As a result, targeted options may not be as effective in
the near term as untargeted options.
4.1.2 Technology Based-Requirements Versus Water Quality-Based Requirements
Technology-based requirements are typically uniform for categories of
dischargers and require that certain control levels be achieved regardless of
the water quality of the receiving waters. If the objective is to achieve
water quality, then these standards can result in overcontrol or undercontrol.
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In cases where the full control levels are not necessary to achieve water
quality, overcontrol can be avoided by providing for waivers. However, in
cases where there is undercontrol, technology-based requirements alone will
be inadequate to achieve the desired water quality.
Ideally, water quality-based standards should never overcontrol or under-
control. However, they are typically more difficult to develop, requiring
more resources and expertise than technology based-standards. In addition,
they may require more time to be effective.
4.1.3 Regulation of Industry Versus Regulation of POTWs
Regulation of the POTW provides the opportunity for the POTW to meet its
effluent limitations (whether water quality-based or technology-based) in the
most cost-effective manner. this could include the reduction of pollution
discharges from nonindustrlal sources, the enhancement of POTW treatment capa-
bilities, the use of categorical pretreatment standards for industrial sources,
and the use of economic approaches such as effluent charges for industrial
dischargers.
Direct federal regulation of industry reduces the options that POTWs
may consider in addressing their water quality problems. Therefore, federal
regulation of POTWs should be more cost-effective than directly regulating
individual industries. However, as discussed later in this chapter, regulations
for POTWs can be technically more difficult to develop than regulations for
industry.
4.1.4 Presumptive Versus Back-up Federal Requirements
Presumptive federal requirements establish specific effluent limitations
and deadlines. Federal back-up requirements allow POTWs to identify and
solve their problems without federal intervention, but provide for specific
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federal intervention if the problems remain after a set period of time. With
guidance, there is only information provided with no presumptive federal
requirement and no federal back-up.
4.2 OPTIONS EVALUATED
Nine options are evaluated in this report. These options were selected
to represent the most important combinations of the key design features. The
starting point for each of the options (except for Guidance Only) is the basic
403 program. The options differ ia the way they deal with the pass-through
of industrial toxic discharges is dealt with.
The options and the circumstances in which each option is best suited
are described below.
4.2.1. The Existing Program
This option requires full implementation of the existing program as des-
cribed in Chapter 1 and assumes for the purposes of analysis, that this has
been accomplished. Two thousand (2000) municipalities are required to implement
a basic 403 program to control industrial wastes and must apply and enforce
categorical pretreatment standards for all 34 industries discharging any of
the 129 priority pollutants. Under this option, municipalities are assigned the
lead role in implementing and enforcing pretreatment standards. NPDES States
may also play a substantial role if they chose. Otherwise, the federal govern-
ment will oversee compliance efforts. While the administration of this approach
is shared by all levels of government, the federal government is responsible
for the development and promulgation of technology-based toxic pretreatment
standards for industry, thereby creating national uniformity. However, the
pretreatment requirements may be reduced where municipalities apply for removal
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credits for industry where POTW removal efficiencies are high enough to protect
water and sludge quality. [For purposes of this analysis, the impact oŁ removal
credits on the cost to industry or on water quality was not evaluated.] Thus,
the key differentiating feature of this option is the control of pass-through
of toxics by nationally uniform, technology-based standards applied to all
indirect dischargers within industrial categories by all POTWs receiving regu-
lated wastes.
This approach is most applicable if it is believed 1) that uniform indus-
trial performance standards are needed because toxic pollutants from industry
are a significant problem to any POTW receiving them, and 2) that the pass-
through of toxic pollutants should be reduced regardless of the status of
local water quality.
4.2.2 The Existing Program. But Reduced Scope
This option requires the basic 403 program for the 2000 municipalities but
categorical standards would be developed only for selected industries. Alter-
natively, effluent limits might be developed for selected problem pollutants
such as specific heavy metals (cadmium was shown to be the major cause of
water quality exceedances in Chapter 3) or cyanide. Categorical standards for
the remaining industries would be published as guidance. While the administra-
tive scheme would be the same as the existing program, the administrative
burden would be reduced for all three levels of government. This interim
analysis has focused on the impact of using categorical standards for metal
finishers only because metal finishers typically account for over 56 percent of
the metals loadings to POTWs.
The rationale for this option is identical to Option 1, but a majority of
the toxic problems at POTWs are attributed to discharges from the metal finishing
industry. Thus, by regulating that industry alone, much of the environmental
problems caused by indirect dischargers could be abated.
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4.2.3 Technology-Based Limits for POTWs
In addition to requiring basic 403 programs to protect POTWs from industry-
caused problems, this option controls pass-through of toxic pollutants by the
application of technology-based performance standards to POTWs. The essence
of this option is to impose toxic limits on the end-of-pipe effluent of POTWs
while allowing municipalities to select any control strategy they wish in
order to comply with the applicable limits. These toxic limits for POTWs would
be inserted as a condition in the POTW NPDES permit. Categorical standards
would be published as guidance. POTWs could use the guidance to impose indus-
trial effluent limits that would assure compliance with the toxic limits in its
NPDES permit. These limits could be established in two ways: 1) the development
of case-by-case toxic effluent limitations equivalent to the effect of applying
categorical standards or 2) the development of national, uniform toxic effluent
limitations. (For quantitative analysis, this analysis assumes that POTW toxic
limits would be set to be equivalent to applying categorical standards.) If
limits were not met after a fixed period of time, a federal back-up program
(such as the existing program) could become effective.
This option shifts the responsibility for controlling toxics entirely to
POTWs while enhancing local flexibility. For example, if a municipality wished,
it could meet its toxic limits by installing advanced wastewater treatment
technologies instead of regulating industrial discharges, or it could implement
user charges for industry instead of using categorical pretreatment standards.
However, given the increased responsibilities placed with municipalities, finan-
cial incentives and/or technical assistance to POTWs may be needed to make
this type of program effective.
This strategy relies once again on a national and uniform means of reducing
toxics from POTWs but rejects the rationale that categorical pretreatment
standards are the most efficient means to control toxic discharges from POTWs.
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Instead, it is believed that municipalities are best situated to design cost-
effective solutions and that other sources of toxic pollutants coning to POTWs
are important. It also assumes that federally toxic limits for POTWs are
feasible to develop.
4.2.4 Water Quality-Based Limits for POTWs
This option parallels the preceding option but utilizes a different basis
for establishing effluent limits on POTWs. Municipalities are required to
acquire basic 403 program capabilities to prevent industry-related operational
and environmental problems, but would only be subjected to toxic discharge
standards where water quality standards are violated. As with the technology-
based performance standard approach, principle responsibility for the pass-
through of toxic pollutants from POTWs would be placed with those POTWs and
site-specific solutions for toxics reduction could be pursued either at the
treatment works or by regulating industry. Limits based on either federal
water quality criteria or State water quality standards (where available for
toxics) would be used to derive limits for specific POTWs in their NPDES permits.
Control of toxics would be required at fewer POTWs, but when necessary, would
impose first-line responsibility on the POTW as in the previous option. If
State water quality standards were employed, the State role in determining
levels of toxic treatment to be achieved would be significantly increased. The
federal role would again be as back-up, enforcing categorical pretreatment stan-
dards where POTW compliance is inadequate, and potentially providing financial
and technical assistance.
This option would be most applicable 1) if uniform technology-based
requirements are not believed to be the best approach for solving most water
quality problems and 2} as in the previous option, the POTW is believed to be
the best control point and is expected to institute whatever pretreatment
measures (or any other steps) that are appropriate and cost-effective. How-
ever, it is also believed that a federal back-up may be needed in some cases.
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4.2.5 Pretreatment Required To Address Documented Problems
This option is essentially the 403 Regulations without mandatory categor-
ical pretreatment standards or other control requirements. Municipalities
vill be required to develop basic 403 programs to determine whether they have
any problems and to implement a locally designed toxic pretreatment program only
where necessary to eliminate documented problems at the FOTU. These problems
would include the problems typically addressed by the basic 403 program but
will emphasize violation of water quality standards. However, no specific
control technique for toxics would be mandatory. If the municipality is not
successful in correcting its particular problems within a specific period of
time, the municipality could be required to implement categorical pretreatment
standards.
This option would be most applicable where the problems to be addressed are
believed to be variable and as a result, uniform requirements of any type are
not considered to be the best solution in mast cases. As in Option 4, it is
believed that locally designed programs are the best way to address problems
and that municipalities have sufficient resources to address their problems.
Unlike Option 1, it is not believed that presumptive requirements are neces-
sary, although it is felt that federal intervention as a back-up may be needed
to ensure that the required steps are taken.
4.2.6 Guidance Only
The 403 Regulations and categorical standards would serve as guidance with
no further federal involvement. This option is most applicable where munici-
palities have the motivation and resources to solve their own problems, and
only require guidance to do so.
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4.2.7 Waivers
The use of waivers is not a stand-alone approach, but is used in conjunc-
tion with the other options. The use of waivers (instead of changes in regula-
tions or the development of more complex regulations) is especially appropriate
where the problems to be addressed are not believed to be widespread.
There are a number of different types of waivers that could be considered.
The existing program includes two major waiver mechanisms for industrial dis-
chargers: 1} removal credits allow industrial dischargers to meet less stringent
pretreatment levels to the extent that complementary removals are achieved by
the POTW and 2) variances from pretreatment requirements are provided in those
instances where the industrial discharger is fundamentally different (from a
pretreatment standpoint) than the other firms in the same industrial category.
Additional waivers for some or all of the requirements of the existing program
(or any other option) could be granted where POTWs show that: 1) additional
measures are not needed to achieve water quality or 2) the existing POTW program
is equivalent to the national program.
This study has evaluated waivers that apply in those cases where the munici-
pality demonstrates that the full requirements are not needed to achieve water
quality. These waivers would be most applicable for options with technology-
based requirements (such as Options 1, 2, and 3) and, as shown later in this
chapter, have significant cost implications. This study includes Options 1, 2
and 3 with waivers as three separate options in addition to the six options
described above*
4.3 SIMILARITIES AND DIFFERENCES BETWEEN THE OPTIONS
Many of these options will have similar effects and costs, differing pri-
marily in terms of their administration or the degree of federal involvement.
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As a result, it was only accessary to specifically model Che environmental and
cost impacts of some of Che options because Che same outputs could be used to
fully or partially characterize the impacts of the remaining options. This
section highlights the key similarities and differences among the options, and
the extent to which some options could be considered to have equivalent effects
for the purpose of using model outputs.
4.3.1 The Basic 403 Program
The basic 403 program (the general provisions of the 403 regulations with-
out categorical standards) is the starting point for every option excepC for
guidance. There are two reasons for this. First, the general provisions are
the only means by which some problems are specifically addressed in the options.
These problems, described in Chapter 3, include: upsets, bypass, sludge disposal
problems, worker health and safety. The basic 403 program also encourages
municipalities to address toxic problems resulting from pass through. The
general provisions of the 403 regulations appeared to be the most cost-effective
approach to these problems since they only require that problems be identified
and that locally designed solutions be implemented.
Second, many of the options contain a federal back-up that allows federal
implementation and enforcement of national standards if the POTW fails to
solve its problems or if it fails to implement or enforce a required national
program. The current 403 regulations include provision for federal back-up.
However, if federal back-up is not desired, any option could be revised to
exclude it. Similarly, mechanisms other than the 403 regulations could be used
to provide federal back-up if it is desired.
4.3.2 Comparison of Key Design Features
Table 4-1 provides a summary listing of the options that are analyzed
in this report. Waivers have been added to Options L, 2, and 3 to provide
three additional options (lb, 2b, and 3b) for a total of nine options.
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OPTION
4-13
TABLE 4-1
SUMMARY OF OPTIONS ANALYZED
TYPE OF CONTROL FEDERAL
TARGETED* STANDARD * POINT REQUIREMENTS
L.a Existing Program
l.b. l.a. with waiver
2.a Existing Program,
Reduced Scope{
2.b. 2.a. with waiver
3.a. Tech-Based Limits
for POTW
3.b. 3.a. with waiver
4. Water Quality Limits
for POTW
Local Program for
Documented Problems
Guidance Only
NO TECH-BASED INDUSTRY PRESUMPTIVE
YES TECH-BASED INDUSTRY PRESUMPTIVE
NO
YES
NO
YES
TECH-BASED INDUSTRY PRESUMPTIVE
TECH-BASED INDUSTRY PRESUMPTIVE
TECH-BASED POTW PRESUMPTIVE*
TECH-BASED POTW PRESUMPTIVE*
YES WQ-BASED POTW PRESUMPTIVE*
YES
YES
WQ-BASED POTW BACK-UP OR NONE
N/A
N/A
NONE
Targeted programs require action only where there is a local need.
Technology-based or water quality-based standards.
Controls metal finishes only. Assume all POTWs have metal finishes.
Could also include federal back-up, such as categorical pretreatment standard
for industry, if the presumptive requirements are act met.
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As can be seen la Table 4-1, the options cover a vide range of combinations
of Che key design choices. Nevertheless, as discussed below, many of the
options can have similar costs and environmental impacts even though they
differ in terms of the key design features.
4.3.2.1 Option 1 versus Option 3
Option 1 (Che existing program) would be equivalent to Option 3 (technology
based toxic standards for POTHs), except that Option 3 transfers responsibility
to the POTW, Increases the POTW's implementation costs, but allows localities
the opportunity to develop local, cost-effective solutions. Both of these
options could achieve controls in excess of those needed to achieve water
quality standards; similarly both of these options could be inadequate to achieve
water quality standards. If Option 1 (the existing program) were combined
with a waiver that allowed substitution of equivalent programs, then Option 1
would be entirely equivalent to Option 3 (this type of waiver has been termed
"grandfathering").
4.3.2.2 Option 4 versus Option 5
Option. 4 addresses all of the problems covered in the other options, but
uses the presumptive application of limitations to ensure that water quality
standards are met. Option 5 (pretreatment to address documented problems)
also addresses all of the problems, but relies on local initiative to solve
the problems and provides for a federal back-up if the municipality falls to
take adequate steps.
4.3.2.3 Options I & 3 versus Option 445
Option 1 (the existing program) and Option 3 (technology based toxic stan-
dards for POTUs) with water-quality waivers would be equivalent to Option 4
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(water quality standards for POTWs) in those cases where the categorical stan-
dards are more than adequate to allow POTWs to achieve water quality standards;
where technology-based standards are inadequate to achieve water quality
standards, then Option 4 would be more stringent. If water quality waivers
are not provided for in conjunction with Options 1 and 3 then these options
will be more stringent than Option 4 where they provide controls in excess of
those needed to achieve water quality.
4.3.3 Costs and Environmental Impacts
This study has estimated the costs associated with the implementation of
categorical standards and water quality waivers (Options 1, la, 2, and 2a).
It was not feasible within the time and resource constraints of this study to
estimate the cost of achieving reductions beyond categorical standard levels.
Nevertheless, the costs associated with full categorical standards (Options 1
and la) represent a useful upper or lower bound for the other options depending
on the option analyzed:
• The untargeted options (Options 1 and 3, but not 2) are represented
by the costs and environmental Impacts of categorical standards
(Option 1). However, the cost estimates are probably upper bounds
for Option 3, since it is expected that POIUs will be able to achieve
their requirements at a lower cost.
of the targeted options (Options Ib, 3b, 4, 5 and 6, but not 2a)
are represented by the costs and environmental impacts for categorical
standards (Option Ib). However, the costs estimates are upper bounds
for Option 3a since it is expected that POTWs will be able to achieve
their requirements at a lower cost. The cost estimates are likely to
be lower bounds for the water quality-based requirements (Options 4,
5 and 6) since, as shown in Chapter 3, the control levels needed to
attain water quality for some pollutants often exceed the control
levels achieved by categorical standards. However, option 5 (and
Option 6) may be further limited by the costs associated with cate-
gorical standards (Option Ib), since they are assumed to be the federal
back-up where municipalities fail to take adequate action to solve
their problems.
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4.4 ENVIRONMENTAL EFFECTS OF THE OPTIONS
This section describes Che environmental effects of the options. As
discussed in Chapter 2, the results for the 2000 POTWs are currently based on
modeling the impacts of the options on 1839 POTWs. The remaining 161 POTWs were
not included because all of the available information showed that they either
had no industrial contribution or that they discharged into other POTWs. Thus,
the results for the 1839 POTWs should reasonably represent the total impacts.
This section focuses on the impact of the options on the pass-through
of pollutants and the resulting effects on water quality as measured by
exceedances.
4.4.1 Bypasses. Interference and Upsets
The impact of the options on reducing the number or severity of bypasses
and upsets has not been quantified in the model. Chapter 3 provided a detailed
discussion of the prevalence of these problems and their significance. All of
the options, except for guidance, ensures that these problems are dealt with
because they all include the basic 403 program.
4.4.2 Removal of Pollutants
The environmental effects that have been quantified include: pounds of
toxic organlcs and toxic metals removed, percent reduction of toxic pollutants
in POTW effluent, and the percent reduction of toxic contaminants in effluent
sludge. These estimates are shown in Table 4-2. Available in Chapter 3 are
additional data on incremental consumption of water quality criteria and a
comparison of BAT removals with POTW efficiencies.
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TABLE 4-2
OPTION
l.a Existing Program
l.b. l.a. with waiver
IMPACT OF THE OPTIONS ON ENVIRONMENTAL RESIDUALS
PERCENT PERCENT
ANNUAL TONS REMOVED IMPROVEMENT IMPROVEMENT
POTWs IN POTW EFFLUENT IN POTW
AFFECTED ORGANICS METALS ORGANICS METALS SLUDGE
1839 36,435 25,820 702 63% 562
846} 16,760 11,877 702 632 <56
2.a Existing Program,
Reduced Scope 1839
2.b. 2.a. with waiver 846}
0
0
18,733
8,617
0
0
46
<46
28
<28
3.a. Tech-Based Limits
for POTW 1839 36,435
3.b. 3.a. with waiver 846} 16,760
25,820 70 63 56
11,877 <70 <63 <56
4. Water Quality Limits
for POTW 846}
N/A
N/A N/A
N/A
N/A
5. Local Program for
Documented Problems 846}} <16,760
<11,877 <70
<63
<56
6. Guidance Only
1839 0-36,435 0-25,820 0-70 0-63 0-56
N/A Not Available
} Assuming no ambient concentration of toxic pollutants.
}} Only includes those options that have water quality problems.
Does not include those POTWs that have upset or bypass problems, but no chronic
water problem.
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The numbers of POTWs affected strongly influences the volumes of pollutants
removed and the total coat of treatment. Where the application of the option
does not depend on vater quality conditions, then all 1839 of the POTWs are
affected. If requirements only apply where there are water quality problems,
then the number of POTWs affected is reduced to the model estimate of 346.
These estimates are based on the numbers of exceedances as discussed in more
detail in Chapter 3 and later in this section.
All of the uniform national programs have the largest impacts on reducing
the volume of pollutants discharged into waterbodies. This is primarily because
the requirements apply to more POTWs than do the other options. Option 2
(categorical pretreatment standards for metal finishers only) has a relatively
significant impact on the reduction of toxic metal discharges as well as an
reducing toxic organic discharges. The uniform, national programs also signi-
ficantly improve (on a percentage basis) the quality of the ?OTW effluent
discharge and the quality of the sludge.
While the options significantly affect the volume of the pass-through
of toxic pollutants, the importance of these reductions depends on the resulting
impacts to water quality. In the following subsection, the immediate impacts
to water quality have been analyzed using exeedences as an indicator. However,
there can be important water quality impacts even where there are no immediate
exceedances because the reduction in pollutant discharge can lower ambient
pollutant levels, facilitating the attainment of water quality objectives
downstream. In addition, exceedances are thresholds, and (as discussed later
in this chapter) there can be benefits associated with reducing pollution
even where there are no exceedances or where exceedances persist in spite of
controls.
4.4.3 Effectiveness In Reducing Water Quality Violations
As discussed in Chapter 2, an exceedance is a rough indicator of the
possibility that there may be a water quality violation for a pollutant. The
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baseline analysis indicates that there could be 846 POTWs currently that have
at least one exceedance. The estimate of 846 is low because it does not take
into account ambient levels of toxics in the receiving water or the contribution
to water quality degradation due to upsets or bypass at the POTW. In addition,
the normalizing assumptions used in modeling industrial discharge loadings
and POTW removal efficiencies also tend to minimize the estimate of water
quality exceedances.
Table 4-3 shows the reduction in the number of exceedances due to the
application of each of the options. About 61 exceedances are eliminated by
most of the options, except for Option 2 (the existing program with categorical
standards for metal finishing only) where 50 exceedances are eliminated. It
is not known how effective Option 4 (water quality-based limits tor POTWs) would
be. At least 61 violations would be eliminated through this option; however,
there are limits to the extent that exceedances can be reduced through more
stringent controls on industry because in many cases non-industrial sources
are significant contributors. Since the federal back-up for Option 5 is the
application of categorical pretreatment standards, it is assumed that munici-
palities will reduce at least 61 of the exceedances (as in Option 1).
Sensitivity analysis was performed for a broad range of factors, such
as changes in ambient conditions and federal water quality criteria. Even
under sensitivity analysis, the ability of the options to reduce the number of
exceedances remained stable, indicating that where water quality problems
exist they are generally severe.
4.5 COST, COST-EFFECTIVENESS AND BENEFITS
This section first summarizes the cost of the options to industry and to
POTWs and then examines the cost-effectiveness of the options. The benefits
that are obtained from eliminating exeedences are also discussed. It was not
practical to include analysis of economic impacts (such as industrial plant
closures) in this report because of data limitations.
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TABLE 4-3
EFFECTIVENESS OF THE OPTIONS IN REDUCING EXCEEDANCES}
(Based on a total of 1,839 POTWs)
OPTION
INITIAL)}
EXCEEDANCES
EXCEEDANCES
ELIMINATED
EXCEEDANCES
REMAINING
l.a Existing Program
l.b. l.a. with waiver
846
846
61
61
785
785
2. a Existing Program,
Reduced Scope
2.b. 2.a. with waiver
846
846
50
50
796
796
3.a. Tech-Based Limits for
POTW
3.b. 3.a. with waiver
846
846
61
61
785
785
4. Water Quality Limits
for POTW
846
<785
5. Local Program for
Documented Problems
846
»785
6.
Guidance Only
846
0-846
} An exceedance is defined to be when a POTW causes at least one water
quality criteria to be surpassed. POTWs causing more than one criteria
to be exceeded are still counted only once.
}} It is assumed that there is no ambient concentration of toxic pollu-
tants. If there is an ambient concentration of toxic pollutants, then
the number of initial exceedences will be higher. For example, if
other sources of pollution account for 50% of the aquatic lifewater
of quality criteria, then the initial exceedeaces would increase
from 846 (46%) to 1048 (572). See Table 3-1.
{ Assumed to be limited to the effectiveness of the federal back-up
(Option la). However, the actual effectiveness could be as high
as for Option 4 depending on the steps taken by the POTWs.
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4.5.1 Cost
Table 4-4 shows the total annual compliance cost to industry as a result
of each option. The industrial cost is divided into two components: the addi-
tional cost of pretreatment and the cost of disposing of the additional hazard-
ous waste that is generated. The total cost depends significantly on Che number
of POTWs affected by each option. Excluding the Guidance Option, the total
annual cost ranges from about 0.5 billion dollars for categorical standards
for metal finishers including water quality waivers to about 1.9 billion dollars
for the existing program.
The total municipal cost contains two components: the program development
cost (a one-time cost) and the annual cost of operating the program. Sludge
disposal costs for the POTWs are not affected by the improvement in sludge
quality because municipal sludges are not now subject to federal regulations
that require more costly disposal. If there were sludge criteria that resulted
in more expensive disposal, then some of the options could lower the POTW cost
(and possibly the net total cost for both POTWs and industry), potentially
significantly affecting the relative cost-effectiveness of the options.
4.5.2 Cost-Effectiveness
Some observations about the cost-effectiveness of the options can be made
based on two series of assumptions regarding the effectiveness of the options:
• First, each of the options (other than Option 6, guidance only) includes
the general provisions of the 403 program that provide for addressing
problems of upsets, bypass, and passthrough. If it can be assumed
that each of the eight options is equally effective In implementing
these provisions, then these nonqualified environmental benefits are
not a factor in differentiating among the options.
• Second, the most relevant environmental difference between the options
that can be measured is their effectiveness in reducing exceedances. Use
of this measure involves two assumptions: L) that the benefits of reducing
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TABLE 4-4
TOTAL COST OF THE OPTIONS FOR POTWS AND INDUSTRY
( Millions of 1981 dollars)
(Based on a total of 1,839 POTW3)
OPTION
l.a Existing Program
l.b. l.a. with waiver
2.a Existing Program,
Reduced Scope
2.b. 2.a. with waiver
3.a. Tech-Based Limits
for POTW
3.b. 3.a. with waiver
ANNUAL
POTW
DEVELOPMENT
35-91
16-55
35-91
16-55
35-91
16-55
COST
ANNUAL
51-101
23-46
51-101
23-46
51-101
23-46
INDUSTRY
PRE-
TREATMENT
1,292
594
725
334
<1,292
<594
COST
SLUDGE
485
223
252
116
<485
<223
TOTAL ANNUAL
COST
1,829-1,878
841-864*
1,027-1,077
472-495*
<1, 829-1, 878
<841-864*
4. Water Quality
Limits for POTW
16-55
23-46
>594 >223 >841-864*
5. Local Program for
Documented Problems)? 16-55
23-46
<594 <223 <841-864*
6. Guidance
0-55
0-46
0-594 0-223
0-864*
# Assumed to be limited to the cost of the federal backup. Actually, the costs
could be higher depending on the local programs.
?// The extent of local action in the absence of a federal backup is not known.
While the range reflects a maximum cost equivalent to the existing program
with waivers (l.b.), the cost could be higher depending on local action.
* Assumes no ambient toxic pollutant levels.
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pollution discharges where there are no water quality problems are in-
significant and 2) that the benefits of reducing pollution discharges
even where there are water quality problems are insignificant unless
the exceedance is eliminated.
Under these assumptions, the most cost-effective option would be the option with
the lowest cost per exceedance eliminated. Thus, those options that require
uniform action irrespective of local conditions (untargeted options) are likely
to be less cost-effective than those options that take local conditions into
account (targeted options). This conclusion is most apparant for Option La
(the existing program) which requires about one half of the POTWs to implement
categorical standards even though they have no exceedances; the result is that
it costs twice as much as Option Ib (the existing program with waivers) to
have the same effect on exceedances. The cost per exceedance eliminated for
all of the options based on categorical standards is shown below.
COST PER EXCEEDAHCE ELIMINATED FOR CATEGORICAL STANDARDS
(Millions of Dollars)
ALL INDUSTRIES METAL FINISHING ONLY
UNTARGETED 30 - 31 20.5 - 21.5
TARGETED (WAIVERS) 13.8 - 14.2 9.4 - 9.9
On this basis, Option 2a, categorical standards for metal finishing only with
water quality waivers appears to be most cost-effective of the options that
rely on categorical standards.
It is not possible in this report to analyze the cost-per-exceedance
of the water quality-based options because it is not known how many exceedances
would be eliminated or what the total cost would be. Presumably, however,
the costs would be in line with the benefits because the States would always
have the option of downgrading the designated stream use if the costs outweighed
the benefits of attaining water quality standards.
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The costs per exceedance eliminated for categorical standards may appear
to be high because the costs of all of the FOTWs affected have been loaded onto
the smaller number of POTWs where exceedances are actually eliminated. This
is illustrated in Table 4-5A which allocates the total costs for each option
into three categories: cases where there are no exceedances in the first place,
cases where there are exceedances but they are not eliminated and cases where
exceedances are eliminated. As shown in the table, the actual mean cost per
exceedance eliminated is about 5 million dollars, and the median cost is 350,000
dollars. Table 4-SB shows the effect that ambient levels of toxics can have on
the elimination exceedances and on the incidence of cost across the three
categories. For an ambient level of 50%, the number of initial exceedences
would Increase to 57% from 462 and the number of exceedances eliminated would
increase to about 80 from 61. The importance of reducing POTW toxic discharges
increases as the ambient levels come down to the aquatic water quality criteria.
Tables 4-5 A and B raise three important questions: 1) to what extent
should costs be borne in cases where there are no immediate water quality
problems, 2) to what extent should costs be borne in cases where there are
immediate water quality problems, but where the problems persist in spite of
control measures and 3) is it worth the cost to eliminate the exceedances at
all? These questions are discussed in the following section on benefits.
4.6 LOCAL BENEFITS OF PRETREATMEST
This report monetizes some benefits of the pretreatment program. Analysis
was first limited to recreation benefits, which past studies have indicated
are most Important. Because it was not clear how to relate degrees of recrea-
tion activity to ambient toxics levels, the analysis was next limited to cases
in which all exceedances of federal water quality criteria for toxics were elim-
inated by control options. The basic assumption is that eliminating exceedances
makes valuable recreation uses feasible. Finally, analysis was limited to a
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TABLE 4-SA
COST OF THE OPTIONS FOR POTWS EXPERIENCING DIFFERENT WATER QUALITY PROBLEMS*
( Millions of 1981 dollars)
TOTAL ANNUAL COST FOR POTWS WITH
l.a
l.b.
2. a
2.b.
3. a.
3.b.
OPTION
Existing Program
l.a. with valver
Existing Program,
Reduced Scope
2. a. with waiver
Tech-Based Limits
for POTW
3. a. with waiver
TOTAL ANNUAL
COST
1,829-1,878
841-864
1,027-1,077
472-495
<1, 829-1, 878
<84 1-864
NO
EXCEED ANCES
988-1,014
0
555-582
0
<988-l,014
0
EXCEEDANCES
REMAINING
531-548
531-548
218-236
218-236
<53l-548
<531-548
EXCEEDANCES
ELIMINATED
310-316
310-316
254-259
254-259
<310-316
O10-316
4. Water Quality
Limits for POTW
>841-864
>531-548
<310-316
5. Local Program for
Documented Problems)? <841-864
6. Guidance Only 9$
0-864
0
N/A
<531-548
N/A
<310-316
N/A
* Assumes no ambient toxic pollutant levels.
$ Assumed to be limited to the cost of the federal backup. Actually, the costs
could be higher depending on the local programs.
# The extent of local action in the absence of a federal backup is not known.
While the range reflects a maximum cost equivalent to the existing program
with waivers (l.b.), the cost could be higher depending on local action.
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TABLE 4-5B
COST OF THE OPTIONS FOR POTWS EXPERIENCING DIFFERENT WATER QUALITY PROBLEMS*
(Millions of 1981 dollars)
(Based on a total of 1,839 POTWs)
OPTION
TOTAL ANNUAL COST FOR POTWS WITH
TOTAL ANNUAL NO EXCEEDANCES EXCEEDANCES+
COST EXCEEDANCES REMAINING ELIMINATED
l.a Existing Program 1,829-1,878 787-808 629-649 413-421
l.b. l.a. with waiver 1042-1070 0 629-649 413-421
2.a Existing Program,
Reduced Scope
2.b. 2.a. with waiver
1,027-1,077
472-495
a/a
a/a
a/a
a/a
a/a
a/a
3.a. Tech-Based Limits
for POTW
3.b. 3.a. with waiver
«1,829-1,878 <707-808
<1042-1070 0
<629-649 <413-421
<629-649 <413-421
Water Quality
Limits for POTW
>1042-1070
>629-649
<413-421
Local Program for
Documented Problems? <1042-1070
6. Guidance Only##
0-1070
0
N/A
<629-649
N/A
<413-421
N/A
* Assumes no ambient toxic pollutant level of 50Z of aquatic life vater
quality criteria.
# Assumed to be limited to the cost of the federal backup. Actually, the costs
could be higher depending on the local programs.
H The extent of local action in the absence of a federal backup is not known.
While the range reflects a maximum cost equivalent to the existing program
with waivers (l.b.), the cost could be higher depending on local action.
+ About 80 exceedances eliminated, with an assumed average cost of $5 million
per exceedance.
n/a Not Available.
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Subsectioa 4.6.1. below discuss the kinds of benefits that exist, but were
not studied in the cases examined in this project. Subsection 4.6.2 presents
the results of benefits analysis for the cases and categories of benefits that
were examained. These benefits measures are compared to costs for the same
cases.
4.6.1 Benefits of Control That Were Not Analyzed
Toxics control is likely to produce benefits in Che cases where no exceed-
ances are indicated by the FOTW model, and in cases where controls do not elim-
inate exceedances. Because no attempt is made here to measure or monetize
benefits in these cases, it is not known whether these benefits are significant
enough to warrant the costs of control in these cases. The significance of
four factors that affect benefits in these cases is discussed below.
Toxics control will produce benefits other than recreation benefits; these
other kinds of benefits are neglected in this analysis. Examples of neglected.
benefits include health effects, effects on treatments costs when water is
withdrawn for use, and the value placed on cleaner water by those who do not
actually use that water for recreation ("nonuser" benefits). Health effects
and aonuser benefits may be significant in the case of toxic discharges. If
water is used for drinking, health effects will always matter; if not they will
be more significant when water is useable for recreation. Nonuser benefits
are likely to be more significant when high levels of water quality are already
being achieved, because small improvements in very polluted water are not
likely to be highly valued by local residents.
Another class of benefits that is neglected here are those that accrue in
stream reaches other than the single ones examined for each POTW. Even if
exceedances are not eliminated in the stream reach examined, control may con-
tribute to their elimination in down stream segments. Alternatively, control
where there are no exceedances nay prevent the creation of exceedances by
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subsequent dischargers. la either case, control may create recreation oppor-
tunities in stream segments that were not examined. This class of benefits is
likely to be significant. The existence of exceedances is strongly affected
by stream and POTW flow, which suggests that background ambient levels may
have a significant effect on the ability of treatment program to eliminate
exceedances in the real world. The neglect of downstream benefits extends to
categories of benefits other than recreation as well.
Recreation benefits that are not monetized here exist in cases where
exceedances do not occur or are not eliminated. This analysis treats recrea-
tion as a threshold phenomena, when in fact changes in toxic concentrations
that do not cross thresholds may induce changes in recreation levels or in
the enjoyment people receive from their activities. Some types of boating
occur to a significant extent in water where toxics concentrations exceed
federal standards; the level of this activity is probably affected to some
degree by toxics concentrations. Fishing may also occur in water with toxics
exceedances, although the enjoyablity of the experience may be limited if some
species are not present, are not edible, or are edible only after unusually
careful preparation. This effect is probably most important for waters
where exceedances remain. Once all federal standards have been met, it is
less likely that improvements in water quality will contribute significantly
to recreation values.
Finally, pretreatment programs produce benefits that are unrelated to the
discharge of toxic pollutants into receiving waters. By preventing upsets, pre-
treatment reduces discharges of conventional pollutants. This may create sig-
nificant benefits, because local authorities may prevent certain uses of water
where such uses cannot always be safely undertaken: it is simpler to ban swim-
ming, for example, than to prevent it only when an upset caused pollution
event occurs.
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4.6.2 Benefits Where Exceedences Are Eliminated
A benefits analysis, described in Chapter 2 aad Appendix E, was performed
for the majority of the POTWs where exceedances were eliminated. As discussed
in Chapter 2, adequate information was available to analyze the water quality
impacts for 665 of the 1839 POTWs modeled. The model results were scaled up
by the factor 1839/665. For the 665 POTWs, exceedances were eliminated for 22
POTWs. Due to anomalies, the benefits analysis was performed for 17 of the 22
POTWs and compared to the cost of the existing program (Option 1) for each of
the 17 POTWs.
Two different approaches were used to estimate the recreation benefits
for boating, fishing and swimming. The first approach looks to capacity for
boating and fishing use, but ignores the number of potential users in the
vicinity of the stream reach affected by the POTW. (This approach fails to
measure swimming benefits, but these benefits are believed to be small relative
to boating and fishing benefits in most cases.) The second approach looks to
population in the counties contiguous to the affected stream reach, but ignores
the capacity of the reach to support this volume of potential users.
\
Because the first approach presumes maximum use and the second adequate
capacity, regardless of demand, each will overstate benefits in some situations.
Therefore, the table below also reports aggregate benefits based on the lower of
the two estimates for each stream reach, as well as reporting the aggregate
estimates reached using each approach separately. The total annual costs and
total annual benefits are shown below in millions of 1981 dollars:
TOTAL COST BENEFIT ESTIMATE 1 BENEFIT ESTIMATE 2 BENEFIT ESTIMATE 3
(based on capacity) (based on population) (lower of 1 or 2)
$ 86 - 88 $ 43 - 82 $ 84 - 114 $ 33 - 55
It is likely that the best estimate of the value of benefits is provided
by Benefit Estimate 3, although this may still be an over-estimation. While
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aggregate costs appear to be greater than aggregate benefits If this estimate
is used, the precision of the costs and benefits estimation methods is probably
not sufficient to strongly support such a conclusion.
For Benefit Estimate 3, costs and benefits were substantially identical
(i.e., within a factor of 2 of each other) in only three of 17 cases. In five
of the remaining cases costs substantially exceeded benefits, and in eight
cases benefits substantially exceeded costs. In five cases differences were
greater than an order of magnitude — and in all five oE these cases benefits
exceeded costs. These cases of very large differences between benefits and
costs may indicate that a water quality-based option that results in higher
costs than categorical standards to eliminate exceedances may be justified in
a number of the 785-796 cases where categorical standards were inadequate.
There is also support for an inference that the downgrading of the designated
uses for some stream segments may be necessary where the costs for eliminating
water quality problems substantially exceed the benefits to be gained.
4.7 FEASIBILITY ISSUES FOR IMPLEMENTING THE OPTIONS
The options have been discussed in terms of their effectiveness, their
costs, their cost-effectiveness and their benefits. However, there are addi-
tional considerations regarding the feasibility and detailed design of the
options that could effect the practicality or the attractiveness of the options.
For example, waivers based on water quality can be difficult to design and
cumbersome to administer; categorical toxic effluent limits may not be feasible
to develop; water quality standards for toxics are difficult to develop as is
determining the required effluent limitations needed for direct dischargers to
achieve the standards; and implementing Option 5 (Local Program for Documented
Problems) will require the development of effective procedures for federal,
State, and local interaction. Other implementation issues include: the way in
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which it would be determined that a local program is equivalent to the national
program to qualify for a "grandfather" or "equivalence" waiver and the design
of removal credits.
These feasiblity and design issues have not been analyzed in this report.
However several of the more significant issues are discussed briefly below:
water quality waivers for toxics, POTW toxic effluent limitations, water quality
standards for toxics and design issues for Option 5 (Local Program for Documented
Problems).
4.7.1 Water Quality Waiver Systems For Toxics
Any waiver system must be able to determine when adequate levels of water
quality have been achieved, i.e., when waivers for toxics can be granted without
adversely affecting the environment. As indicated below, although much has
been learned, information on toxics and toxic effects continues to be limited.
In addition, available methods for determining the effects of toxic pollutants
on water quality are imprecise at best. More rigorous techniques are not
likely to be readily available for several more years.
4.7.1.1 Possible Approaches for a Waiver System
There are several methods that could be used to waive technology-based
requirements for toxics where they are determined to be unnecessary to achieve
desired water quality levels. All would require time and substantial EPA and
State resources to properly administer.
Methods for measuring the effects of a waiver on water quality include
performing a waste load allocation (considered to be the most rigorous nodeling
approach), mixing zone calculations, and bioassay testing. The baseline used
to determine whether or not waivers should be granted could be either the
achievement of State-specified water quality standards, or where State standards
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are not yet In place, federally-specified water quality criteria. Regardless
of the baseline, there will likely be very difficult economic and equity deci-
sions to be made regarding the allocation of limited waivers among dischargers
on a stream segment.
4.7.1.2 Current State of the Art
There is still only limited information concerning toxic pollutants, their
effects over time, and their effects in combination with one another. This
makes it extremely difficult and costly to perform waste load allocations for
toxic pollutants. While waste load allocations are viewed as the best, most
comprehensive analysis of toxic effects, EPA estimates that it will be at
least 3-5 years before these models are readily available for use for toxics.
Even then their reliability will be questionable and they may be unable to
take into account long term or synerglstic effects of the toxic pollutants.
The inadequacy of data on toxics means that the results of mixing zone calcu-
lations are also extremely uncertain. While bioassay tests can provide a
check of an effluent's acute or immediate toxicity, they are unable to measure
long term or chronic toxicity and provide no indication of a pollutant's
effects downstream.
Few States have water quality standards in place for toxics, and, in
general, States appear reluctant to develop toxic standards. While there are
federal water quality criteria in place for most toxics, most States have not
adopted them. Therefore, while it is likely that waivers could be applied to
more pollutants if federal criteria were used, waivers would be more restric-
tive than they would be if based on State standards.
Therefore, waivers may be difficult to apply in the near term in order
to avoid the installation of controls where they are not needed because of the
difficulty of making that determination.
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4.7.2 Technology-based Toxic Limits for POTWs
As described earlier in this chapter, technology-based toxic effluent
limits for POTWa could be developed in two ways: 1) the development of case-
by-case toxic effluent limitations equivalent to the effect of applying cate-
gorical standards or 2) the development of national, uniform toxic effluent
limitations. Issues regarding the feasibility of these two approaches is
discussed below.
Under the first approach, the permit writer would develop toxic effluent
limits based on the type of POTW treatment system, amount and type of industrial
contribution, and recommended industrial pretreatment limitations. As a result,
the toxic effluent limits determined by the permit writer would be the same as
those attained by the POTW following the application of categorical standards.
This approach would require the development of categorical standards, completion
of industrial surveys and estimates of the removal efficiency of the POTW. The
major shortcoming of this option is the additional resoucres required to develop
the 2,000 effluent limitations and the degree of dependence on the permit writer.
If it can be assumed that generating these POTW limitations would be equivalent
to developing a direct discharge permit, it could require an additional 32-80
fulltime employees over and above EPA's current resource commitments to pre-
treatment. Based on EPA estimates, this could cost an additional $1.6-4 mil-
lion/year (400 permits per year X 20-50 person-days per permit X $50,000 per
person per year/250 person days per year).
Technically, the second approach is far more difficult to implement than
the first approach. There is only limited data available to develop different
effluent limits that reflect the type of POTW treatment and the amount and
type of industrial contribution. Available data indicate that the influent
to POTWs is highly variable and does not appear to be reliably related to the
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presence of industrial dischargers alone. As a result, even tf better data
were available, it would still be difficult to categorize POTWs according to
their ability to reliably meet effluent limitations Eor all toxic pollutants.
Because of variability and Inconsistent occurences, national limits for toxic
organics do not appear to be feasible at all. Effluent limits for certain
heavy metals (chromium, copper, nickel, lead, zinc and cadmium) may be possible:
of the six heavy metals, high concentrations of chromium, nickel and cadmium
in POTW effluents can be traced to industrial dischargers. Siace national
limits would be set so that all POTWs in a category could achieve them, it is
likely that the effluent limits would be set "high" and would in actuality
only effect POTWs with high discharges from metals-related Industries.
4.7.3 Water Quality-Based Approaches For Toxics
The options represent several passible strategies Eor reliance on water
quality considerations in establishing effluent limitations for toxic pollu-
tants. The success of these approaches depend on the state of the art in
developing water quality-based effluent limits and technical capability of the
States to administer the program. These issues are extensions of the problems
associated with granting water quality waivers.
In addition to the requirement that States have the technical capability
to administer such programs, there are two key factors that determine the feas-
ibility of using a water quality-based approach for toxics: knowing how ouch
control ia needed (or when to stop controlling); and knowing how to allocate
control requirements among dischargers. Traditional water quality approaches
rely on threshold ambient levels and the use of models to determine the level
of control that is necessary and how this level of control should be distributed
among sources. This approach is potentially adaptable to toxics as models and
data are improved, but it may require several years before there Is adequate
improvement. However, this delay may not be so significant when compared wich
the delays that are occurring in the development of technology-based require-
ments for some Industries under the present program.
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As an alternative to traditional approaches, effluent charges or a market-
able permit system could be used to induce or allocate controls among sources
and bioassay monitoring could be used to determine when to stop requiring fur-
ther reductions. Although bioassay monitoring does not provide complete assur-
ance that all toxic effects have been accounted for, it may be an acceptable
measure for the short term until more rigorous techniques (e.g., vaste load
allocations) are readily available. In this way, steady reductions of toxic
pollutants can be achieved without complex modeling.
4.7.4 Design Variations for Option 5
Each of the options requires careful analysis of a number of design consid-
erations. This discussion uses Option 5, Fretreatment Required To Address Docu-
mented Problems, as an example of the number of ways in which a basic option
can be designed. The key design decisions are: Che criteria for identifying
problems, and the local/federal interaction and extent of federal involvement.
Documented problems are most easily specified as violations of permit con-
ditions. These could include NFDES permit violations and violations of avail-
able State water quality standards. As new water quality standards are adopted
by the State, the POTW would be responsible for achieving them. Additional
problems, such as violations of sludge criteria could also be included.
These criteria could be very specific or they could be stated in general terms.
Where problems are identified, the POTW could be required to notify EPA
immediately. The POTW could also be required to submit a plan for addressing
the problem. The plan would include specific actions to be taken by the POTW
and specific milestones. The plan could be subject to EPA comment; as an
alternative the plan could be subject to EPA approval. As an additional
alternative, the POTW could be required to notify EPA if the problem is not
solved by a. specific time in the future.
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If the problems are aot resolved according co the schedule submitted
by the POTW (or by the deadline established by the federal government), then
the POTW could be required to submit a new plan, as above, for remedying the
problem. If there is a federal back-up, EPA could elect to activate the back-
up requirements. The federal back-up requirements could be categorical pre-
treatment standards or other requirements developed on a case-by-case basis.
4.8 OTHER CONSIDERATIONS
This section briefly discusses administrative considerations, effectiveness
issues and statutory constraints.
4.8.1 Administrative Considerations
The different resource implications and impacts to local and State govern-
ments of the water quality-based options have not been analyzed in this report.
However, as the federal role declines, there is increasing reliance on local
and State governments. While a uniform, national program may be less cost-
effective overall on a national basis, the costs to individual municipalities
and States for developing individual programs could be higher.
The results of the analysis to date do not provide clear direction regarding
the most administratively desirable approaches for federal roles in options
that reflect local water quality conditions. There are basically two types of
federal Involvement for these options. The first type is exemplified by Options
Ib, 2b, and 3b, where federal requirements are imposed presumptively but waivers
from those requirements are allowed. The second type is exemplified by Options
4 and 5 where the local program is presumed to be adequate but federal require-
ments stand ready as a back-up if the local program fails to achieve the required
goals within an adequate timeframe. Administratively, the first type is easiest
to administer if the number of waivers is relatively small and the second type
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is easier Co administer if che number of local programs needed is small* How-
ever, Che model results iadicate that about half of Che POTWs would either
require variances or local programs. Thus, 1C is unclear from an administrative
standpoint which type of federal involvement vould be easiest to implement
based on this criteria.
4.8.2 Effectiveness
Moat of the options are either federally driven or assumed to have a Federal
back-up that ensures that action will be taken on the part of POTWs to address
their problems. The options could be designed without a Federal backup. The
question of whether or not a federal back-up is needed is not specifically
addressed in this study. However, the findings from the study of 132 munici-
palities reported earlier in this document indicates that the primary reason
for che controls now in place at POTWs is federal (or State) requirements.
The issues regarding feasibility that have been raised in this scudy are
important when considering the effectiveness of the options. These feasibility
issues are primarily related to timing and resource requirements rather than
the absolute effectiveness of che options.
4.8.3 Economic Efficiency/Maximizing Net Benefits
Conceptually, the targeted options are likely to come closer to maximizing
net benefits Chan the untargeted options because they only apply la Chose cases
where controls are needed to achieve water quality standards. In addition,
where the cost of achieving the water quality standards exceeds the benefits,
the designated uses can be downgraded until local decision-makers believe that
che costs and potential benefits have been brought into an acceptable balance.
In these cases, che requirements of che targeted approaches would automatically
be adjusted to reflect the new water quality standards.
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