United States
Environmental Protection
Agency
Office of Water
Office of Pollution Prevention and Toxics
Washington, DC 20460
EPA-821-B-97-003
August 1997
>EPA Draft Final
Pollution Prevention (P2)
Guidance Manual for the
Pesticide Formulating,
Packaging, and
Repackaging Industry:
Implementing the
P2 Alternative
Printed on paper that contains at least
20 percent postconsumer fiber.
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EPA-821-B-97-003
August 1997
Draft Final
Pollution Prevention Guidance Manual
for the
Pesticide Formulating, Packaging,
and Repackaging Industry
Office of Water
and
Office of Pollution Prevention and Toxics
U.S Environmental Protection Agency
Washington, DC 20460
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Notice
This manual has been subjected to U S. Environmental Protection
Agency peer review and approved for publication. Mention of trade
names or commercial products does not constitute endorsement or
recommendation for use. The policies set forth m this guidance are not
final Agency actions but are intended solely as guidance. They are not
intended, nor can they be relied upon, to create rights enforceable by any
party in litigation with the United States. EPA officials may deode to
follow the guidance provided herein, or to act at variance with the
guidance, based on an analysis of source-specific circumstances. The
Agency also reserves the right to change this guidance at any time.
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Foreword
PFPR Subcategories
This Pollution Prevention (P2) manual discusses the applicability and
implementation of effluent limitations guidelines and standards covering
the pesticide formulating, packaging, and repackaging (PFPR) industry
The main purpose of the manual is to provide guidance to industry and
permitters in the process of complying with this rule, in particular, com-
plying with the P2 Alternative Option. EPA has received numerous re-
quests from refilling establishments questioning how the final rule applies
to them. This foreword is an aid to facilities m determining if the informa-
tion contained in this manual is applicable to them.
The final rule is applicable to
two subcategones of new and
existing PFPR operations In
general, because refilling estab-
lishments covered under Sub-
category E must achieve zero
discharge, this P2 alternative
guidance provided in this
manual is not applicable. How-
ever, if a refilling establishment
also performs PFPR operations
covered under Subcategory C,
for which the P2 alternative is
an option, that facility may be
interested in obtaining a copy
of this manual, as they could
commingle their Subcategory
E wastewater with their Sub-
category C wastewater and
choose to follow the Subcat-
egory C regulations (1 e., zero
discharge or the Pollution Pre-
vention Alternative)
More specifically the final rule for Subcategory C facilities requires either
zero discharge of pollutants or a pollution prevention (P2) alternative,
which allows a discharge of pollutants if certain P2 practices are lmple-
Subcategory & Pesticide formulating, packaging, and
repackaging (PFPR), including pesticide formulating,
packaging, and repackaging occurring at pesticide
manufacturing facilities (PFPR/Manufacturers) and at stand-
alone PFPR facilities (does not include research and
development operations)
Subcategory E: Repackaging of agricultural pesticide
products at refilling establishments. Refilling establishments
are defined as establishments where the pesticide product
is repackaged into refiilable containers The limitations and
standards of the rule covered under Subcategory E apply
only to the repackaging of pesticide products performed by
refilling establishments, (a) that repackage agricultural
pesticides; (b) whose primary business is wholesale or
retail sales, and (c) where no pesticide manufacturing,
formulating, or packaging occurs Custom application and
custom blending operations are not covered under
Subcategory E.
111
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merited, followed by treatment as necessary. Facilities can choose the P2
alternative on a facility-wide basis or by product family/process line/
process unit.
The final rule for Subcategory E facilities requires zero discharge of pol-
lutants; there is no option for an allowable discharge after implementing
approved P2 practices. The zero discharge limitation is based on collec-
tion and storage of process wastewaters, including rinsates from clean-
ing mirubulk contamers and their ancillary equipment and wastewaters
from secondary containment and loading pads, with the exception of
contaminated storm water In most cases, refilling establishments hold
wastewater until it can be applied as pesticide in accordance with the
product label or reused as make-up water in an application of pesticide
chemical to an appropriate site. Data collected by EPA show that 98% of
all refilling establishments already achieve zero discharge, primarily by
holding contaminated wastewater and reusing it as make-up water.
IV
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Table of Contents
Chapter 1 Introduction 1
Chapter 2 PFPR Operations 7
Chapter 3 Pollution Prevention Glossary 15
Chapter 4 Conducting the P2 Audit 23
Chapter 5 Wastewater Treatment Technologies 41
Chapter 6 Conducting the Treatability Test 47
Chapter 7 Regulatory Compliance Documentation 77
Chapter 8 Case Studies 87
Chapter 9 Where to Get Additional P2 Help 97
Feedback Survey 103
Appendix A PFPR Final Regulation (40 CFR Part 455) 105
Appendix B PFPR Compliance Documentation (Sample Forms) 157
Appendix C Example Treatability Test Procedures 185
v
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Acknowledgments
Shari Zuskin of the U.S. Environmental Protection Agency (EPA), Office of
Water, Engineering and Analysis Division, was the work assignment man-
ager responsible for the preparation and review of this guide. Holly Elwood
of EPA's Office of Pollution Prevention and Toxics, Pollution Prevention
Division, also contributed heavily to the preparation and review of this
manual. This manual was prepared with the support of Eastern Research
Group (Contract No. 68-C5-0023) under the direction and review of the
Office of Science and Technology.
vi
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CHAPTER 1
Introduction
This manual is designed to provide guidance on how to assess pollution
prevention (P2) opportunities at pesticide formulating, packaging, and
repackaging (PFPR) facilities and to assess compliance with the P2 Al-
ternative Option of the effluent limitations guidelines and standards for the
PFPR industry (61 FR 57517). The opportunities and compliance methodolo-
gies discussed in this manual specifically relate to water use and reuse, waste-
water generation, and wastewater treatment and disposal. The manual is
intended for use by PFPR facility managers, publicly owned treatment works
(POTWs), permit wnters and other regulatory agency representatives, fed-
eral and state auditors, and consultants.
Why Implement P2?
Effective P2 programs offer several benefits, summa-
rized in Table 1-1, when incorporated as part of facil-
ity operations. Although this manual concentrates on
water management practices, a P2 assessment and the
resulting operation changes often lead to overall im-
provements in the efficiency of PFPR process opera-
tions through decreasing the loss of raw materials and
minimizing waste disposal costs.
Information contained in the manual is not meant to
represent an exhaustive list of P2 opportunities that
may exist or should be put to use at any one facility;
rather, it is intended to identify P2 practices currently
in use in the industry and to provide additional infor-
mation on how to implement these and other prac-
tices as well as aid in the compliance with the PFPR
effluent guidelines and standards The Environmen-
tal Protection Agency's (EPA's) Office of Research and
Development previously published P2 guides for the
pesticide formulating industry and for nonagricultural pesticide users. These
guides evaluated waste minimization options for formulating facilities, and
were not specifically focused on water management practices.
In addition, many states have developed P2 guidance applicable to PFPR
facilities Members of the PFPR industry and their trade associations have
also spent time and money evaluating the incorporation of P2 into facility
operations and have developed effective tools to assist that process.
1
Table 1-1
Examples of Benefits of Pollution
Prevention
Cost Benefits of Pollution Prevention
¦ Cost savings from recovery of active
ingredients
¦ Cost savings from recovery of water
¦ Reduction in cost of waste disposal
¦ Reduction in permitting costs
Other Advantages of Pollution Prevention
¦ Improved corporate image
¦ Improved worker and community safety
¦ Compliance with effluent guidelines
¦ Assistance with environmental programs
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CHAPTER 1 Introduction
Pollution Prevention Guidance Manual for the PFPR Industry
What is P2?
The Pollution Prevention Act of 1990 established a national policy to prevent
or reduce pollution at the source whenever feasible as the first and preferred
choice for environmental management. This policy is referred to as pollution
prevention, or source reduction, and may include in-process recycling prac-
tices. Table 1-2 shows EPA's preferred hierarchy of environmental manage-
ment options, of which pollution prevention is the first choice Table 1-2 also
presents a definition of source reduction/pollution prevention as it pertains
to the environmental hierarchy.
Table 1-2
Environmental Management Hierarchy
1.
Pollution should be prevented or reduced at the source whenever feasible ("source reduction");
2.
Pollution that cannot be prevented should be recycled in an environmentally safe manner whenever
feasible;
3.
Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner
whenever feasible, and
4.
Disposal or other release into the environment should be employed only as a last resort and should
be conducted in an environmentally safe manner.
Source Reduction u Any practice which reduces the amount of any hazardous substance,
pollutant, or contaminant entering any waste stream or otherwise released
into the environment prior to recycling, treatment, or disposal;
¦ Any practice which reduces the hazards to public health and the
environment associated with the release of such substances, pollutants, or
contaminants; and
¦ Equipment or technology modifications, process or procedure
modifications, reformulation or redesign of products, substitution of raw
materials, and improvements in housekeeping, maintenance, training, or
inventory control
EPA is required by the Pollution Prevention Act of 1990 to incorporate P2 into
all of EPA's activities, including rulemaking and implementation. The Source
Reduction Review Project was established in 1992 to instill the tenets of the
Pollution Prevention Act into every phase of EPA's rulemaking process As a
part of this effort, EPA has focused on incorporating P2 practices, specifically
the reuse and recycle of process wastewaters, into effluent limitations guide-
lines and standards for the PFPR industry.
PFPR Pollution Prevention Alternative
On September 30, 1996, EPA promulgated effluent limitations guidelines and
standards for the PFPR industry. The final rule covers process wastewater
discharges from PFPR operations occurring at facilities in two subcategories,
as defined in Table 1-3. The formulation, packaging, and/or repackaging of
all pesticide products fall within the rule's applicability, with the exception of
the six groups of products listed in Table 1-4 (Definitions of these excluded
pesticide products can be found starting on page 57548 of the final rule FR
notice, m Appendix A of this manual)
2
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CHAPTER 1 Introduction
Pollution Prevention Guidance Manual for the PFPR Industry
A flow chart depicting
the process to deter-
mine whether a facility
is subject to the PFPR
effluent guidelines or
pretreatment standards
is shown in Figure 1-1.
The first step is to de-
termine if the facility
formulates, packages,
and/or repackages reg-
istered pesticide prod-
ucts based on the
industry definitions pre-
sented in Table 1-3 If
the answer is no, the
facility is not subject to
this rule. If the answer
to any of these ques-
tions is yes, the next
step is to determine
whether the pesticide
products contain active
ingredients that are within the scope of the
rule based on the exemptions listed in Table
1-4. If they do, the facility must operate in
compliance with the PFPR effluent guidelines.
The final rule requires facilities to meet zero dis-
charge of process wastewater pollutants The
rule also offers the option of a Pollution Pre-
vention Alternative to Subcategory C facilities
that agree to implement certain P2, reuse, and
recycle practices (and treatment when neces-
sary) These facilities receive a discharge allow-
ance referred to as the P2 allowable discharge.
As shown in Figure 1-1, if the facility does
not generate any wastewater from their PFPR
operations, they are in compliance with the zero discharge portion of the
rule. If they generate a pesticide-containing wastewater, a determination must
be made of whether the wastewater is covered under the final rule; the rule
does exempt from regulation certain wastewater sources, which are discussed
in Chapter 4
If it is determined that the facility generates a wastewater covered under the
rule, but does not discharge this wastewater, again they are in compliance
with zero discharge If they wish to discharge that wastewater, they must
comply with the P2 alternative. A copy of the final rule is contained in Appen-
dix A.
Each facility subject to the rule will need to make an initial choice of how to
comply with the regulation They will need to choose to either comply with
the zero discharge effluent limitation/pretreatment standard or agree to con-
Table 1-3
PFPR Industry Definitions
Subcategories
Subcategory C Pesticide formulating, packaging, and repackaging (PFPR),
including PFPR operations at pesticide manufacturing facilities
and at standalone PFPR facilities (Note: does not include
research and development operations).
Subcategory E: Repackaging of agricultural pesticide products at refilling
establishments (Note, does not include custom application).
PFPR Operations
Formulating: The process of mixing, blending, or diluting one or more
pesticide active ingredients with one or more active
ingredients, without an intended chemical reaction, to obtain a
manufacturing use product or end use product.
Packaging: The process of enclosing or placing formulated pesticide
product into a marketable container.
Repackaging: The direct transference of a pesticide active ingredient or
formulated product from any marketable container into another
marketable container, without a change in composition of the
formulation or the labeling content, for sale or distribution
Table 1-4
Excluded Pesticide Products
¦ Sanitizer products;
¦ Microorganisms,
¦ Group 1 and Croup 2 mixtures;
¦ Inorganic wastewater treatment chemicals;
¦ Chemicals that do not pass through POTWs; and
¦ Certain liquid chemical sterilants.
3
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CHAPTER 1 Introduction Pollution Prevention Guidance Manual for the PFPR Industry
Determining Applicability of Rule
NO
NO
Facility
Formulates
Pesticide
Products
Facility
Packages
Pesticide
Products
Facility
Repackages
Pesticide
Products
NO
Not Within
Scops of Rule
K
I
YES
I
YES
I
YES
Pesticide Products
Containing
Active Ingredients
within Scope
NO
i
YES
Facility Must Comply
with PFPR Effluent Guideline
Facility
Generates
Pesticide-containing
Wastewater
no In Compliance
with Zero Discharge
I
YES
Wastewater Generated
is Defined as a
Pesticide-containing
Process Wastewater
in Rule
NO
4
YES
Facility Discharges
Pesticide-containing
Process Wastewaters
NO
I
YES
Facility is Candidate
for P2 Alternative
Figure 1-1. Determining Applicability of Rule
duct the P2 practices listed in Table 8 of the rule (and conduct treatment
where necessary) The facility can also use a variation of a listed practice
based on modifications listed in Table 8 of the final rule or those agreed to by
the permitting/control authority. Facilities will also need to agree to make the
practices and the P2 discharge allowance enforceable, for example,
4
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CHAPTER 1 Introduction
Pollution Prevention Guidance Manual for the PFPR Industry
the facility would agree to include them in their NPDES permit for direct
discharges or in an individual control mechanism with the control authority
for indirect discharges (see Appendix A for the definition of P2 allowable
discharge). This choice can be made either on a facility-wide basis or on a
process basis (i.e, product family/process line/process unit). Each of the P2
practices listed in Table 8 of the rule will be described more fully in Chapter 3
of this manual.
EPA's Office of Water and Office of Pollution Prevention and Toxics have
created this guidance manual to facilitate compliance with this rule. P2 prac-
tices that are required as part of compliance with the P2 alternative form the
basis of the manual; however, other noniequired P2 opportunities that a fa-
cility may choose to implement are also presented Because the manual fo-
cuses on water use and wastewater generation, it is not intended to offer
guidance on the development of state P2 plans; however, P2 opportunities
discussed here may also be incorporated into PFPR facility state P2 plans. The
manual does not include an exhaustive list of all possible P2 opportunities,
but provides a framework for an initial assessment of PFPR operations as
they pertain to water use and wastewater generation and to compliance with
the P2 alternative
How to Use This Manual
This manual is organized into nine chapters and three appendices.
¦ Chapter 2 provides basic descriptions of PFPR operations (e.g, dry formu-
lating, aerosol packaging, and drum rinsing) for those readers unfamiliar
with this industry;
¦ Chapter 3 provides a glossary of the specific P2 practices and equipment
required to implement the P2 alternative, including illustrations and ben-
efits of use,
¦ Chapter 4 presents instructions and an example for conducting P2 audits
to evaluate water management practices at PFPR facilities and to aid in
making compliance decisions;
¦ Chapter 5 discusses wastewater treatment technologies,
¦ Chapter 6 presents information on how to conduct a treatability test,
¦ Chapter 7 discusses evaluation of wastewater treatment system perfor-
mance, compliance with the PFPR effluent guidelines rule, and certifica-
tion paperwork;
¦ Chapter 8 presents case studies to provide guidance to the user in comply-
ing with the PFPR regulation,
¦ Chapter 9 provides a list of resources for additional help in complying
with the regulation,
¦ Appendix A presents the final rule for the PFPR industry;
¦ Appendix B presents tables that can be used to document the results of P2
audits, wastewater treatment tests, and compliance decisions related to
the final PFPR rule, and
5
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CHAPTER 1 Introduction
Pollution Prevention Guidance Manual for the PFPR Industry
¦ Appendix C provides an excerpt on test procedures for an EPA-sponsored
treatability test.
This is the first time that EPA has written a P2 Guidance Manual in conjunc-
tion with a rule, and we would like your valuable input on how useful this
document is to you At the end of the manual, you will find a short survey
requesting your input. Please take a moment to evaluate the manual's useful-
ness in describing P2 opportunities for the PFPR industry and evaluating com-
pliance with the PFPR effluent guidelines rule, and whether you thought the
manual was "user friendly."
6
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CHAPTER 2
PFPR Operations
D
This chapter describes seven types of basic operations, shown in Table
2-1, used in the PFPR industry The descriptions presented are simpli-
fied and will be most useful for those readers unfamiliar with the
industry. They are intended to be used in conjunction with the P2 glossary
located in Chapter 3 to help identify and implement specific P2 opportunities.
Facilities in the PFPR industry formulate, package,
and repackage a variety of pesticide products, includ-
ing herbicides, insecticides, and fungicides These fa-
cilities typically have physical divisions between
formulating and packaging operations, and between
dry and liquid operations.
Because of the large number of pesticide products a
facility may handle, most PFPR facilities operate on
the principle of "just-in-time" production. This prin-
ciple basically dictates that products are made on cus-
tomer demand to reduce the space needed to keep
large inventories on hand However, because produc-
tion is tied to customer orders, the specific products
that are formulated, packaged, or repackaged can vary
from day to day and hour to hour. Therefore, facilities often use an equip-
ment line (e.g, a liquid formulating line) to make multiple products over the
course of a day, or week, or month.
Facilities typically formulate, package, or repackage these products in batches.
They also usually have the flexibility to "mix and match" equipment as needed.
For example, a facility may have two formulation mix tanks, Tank A with a
capacity of 100 gallons, and Tank B with a capacity if 500 gallons Both mix
tanks have piping connections to a product storage tank (Tank C) with a
capacity of 500 gallons The facility can configure these tanks two ways, de-
pending on the amount of product to be formulated. If 100 gallons of product
or less are scheduled to be made, the facility connects Tank A with Tank C
and uses Tank A to formulate the product. If more than 100 gallons of prod-
uct are scheduled to be made, the facility connects Tank B with Tank C and
uses Tank B to formulate the product In both cases, the facility is attempting
to maximize their production while minimizing the amount of equipment
that will need to be cleaned prior to formulating a new product.
Table 2-1
PFPR Operations
¦ Liquid Formulating
¦ Dry Formulating
¦ Liquid Packaging
¦ Dry Packaging
¦ Aerosol Packaging
¦ Pressurized Gas Formulating and Packaging
¦ Repackaging
7
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Liquid Formulating
Liquid formulations contain mixtures of several raw mate-
rials, including pesticide active ingredients, inert ingredi-
ents, and a base solvent, and may also contain emulsifiers
or surfactants. The solvent may be water or an organic
chemical, such as isopropyl alcohol or petroleum distillate.
In some cases, the formulation is an emulsion and contains both water and
an organic solvent. Solid materials, such as powders or granules, may also be
used as part of a liquid formulation by dissolving or emulsifying the dry ma-
terials to form a liquid or suspension. The formulated product may be in a
concentrated form requiring dilution before application, or may be ready to
apply.
An example of a liquid-based formulating line is shown in Figure 2-1. Typical
liquid formulating lines consist of storage tanks or containers to hold active
and inert raw materials, and a mixing tank for formulating the pesticide prod-
uct. A storage tank may also be used on the formulating line to hold the
formulated pesticide product, prior to a packaging step. Facilities may re-
ceive their raw materials in bulk and store them in bulk storage tanks, or they
may receive the raw materials in smaller quantities, such as 55-gallon drums,
50-pound bags, or 250-gallon minibulk containers or "totes" (smaller, refill-
able containers). These raw materials are either piped to the formulation ves-
sel from bulk storage tanks, or added directly to the vessel from drums, bags,
or minibulks. Typically, water or the base solvent is added to the formulation
vessel in bulk quantities.
The formulating line may also include piping and pumps for moving the raw
material from the storage tanks to the mixing tank, and for moving formu-
lated pesticide product to the packaging line. Other items that may be part of
the line are premixing tanks, stirrers, heaters, bottle washers, and air pollu-
tion control equipment. Some lines may also contain refrigeration units for
formulation, storage units, scales, and other equipment.
WATER OR BASE
SOLVENT
BULK
TANK
DRUMS
FORMULATED
PRODUCT
STORAGE
FORMULATION
VESSEL
Figure 2-1. Liquid-Based Formulation Line
8
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
CYCLONE
FINAL
PRODUCT BIN
Dry Formulating
Dry formulations contain active and inert in-
gredients; the final product may be in many
different forms, such as powders, dusts,
granules, blocks, solid objects impregnated
with pesticide (e.g., flea collars), pesticides
formed into a solid shape (e.g., pressed tab-
lets), or microencapsulated dusts or granules. They are formu-
lated in various ways, including mixing powdered or granular
actives with dry inert carriers, spraying or mixing a liquid active
ingredient onto a dry carrier, soaking or using pressure and heat
to force active ingredients into a solid matrix, mixing active in-
gredients with a monomer and allowing the mixture to poly-
merize into a solid, and drying or hardening an active ingredient
solution into a solid form. These dry pesticide products may be
designed for application in solid form or to be dissolved or emul-
sified in water or solvent prior to application.
Because of the many types of dry pesticide products, dry
pesticide formulating lines can vary considerably. Figures
2-2 and 2-3 are examples of granular and dry spray-coated
formulation lines. Dry formulating lines typically have tanks
or containers to hold the active ingredients and inert raw
materials, and may include mixing tanks, ribbon blenders,
extruding equipment, high-pres-
sure and temperature tanks for
impregnating solids with active
ingredient, vacuum or other
type of drying equipment, tanks
or bins for storage of the formu-
lated pesticide product, pelletiz-
ers, presses, milling equipment,
sieves, and sifters.
Raw materials for dry pesticide
products may be liquid or solid.
Liquid raw materials may be
stored in rail tank cars, tank
trucks, minibulks, drums, or
bottles. Dry raw materials may be
stored in silos, rail cars, tank
trucks, minibulks, supersacks,
metal drums, fiber drums, bags, or
boxes. Liquid raw materials may
be pumped, poured, or sprayed
into formulation vessels, while dry
raw materials are frequently trans-
ferred to formulation equipment
by screw conveyors (consisting of
a helix mounted on a shaft and
turning in a trough), through el-
evators, or by pouring.
Figure 2-3. Dry Spray-Coated Formulation Line
BAGS
RIBBON
MIXER
FORMULATED
PRODUCT
STORAGE
Figure 2-2. Granular Formulation Line
9
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Dry formulating lines may also include piping and pumps for moving raw
materials from storage tanks to the formulation equipment, and for moving
formulated pesticide product to the packaging equipment. Other items that
may be included in the dry pesticide formulating line are premixing tanks,
tanks for storing formulated product prior to packaging, stirrers, heaters, re-
frigeration units on formulation and storage equipment, scales, and air pollu-
tion control equipment (e.g., cyclones, filters, or baghouses). Dry pesticide
products may be packaged into rail tank cars, tank trucks, totes, minibulks,
and water-soluble packaging, but are typically packaged into bags, boxes, or
drums.
1
r©\
Liquid Packaging
Many liquid formulations are packaged by simply
transferring the final product into containers. Fig-
ure 2-4 depicts a liquid packaging line. Small quan-
tities of product are often manually packaged by
gravity feeding the product directly from the formulation tank into
the product container. For larger quantities, the process is often auto-
mated. Formulated product is transferred to the packaging line through
pipes or hoses, or is received from a separate formulating facility, and placed
in a filler tank. A conveyor belt is used to carry product containers, such as
jugs, bottles, cans, or drums, through the filling unit, where nozzles dispense
the appropriate volume of product. The belt then carries the containers to a
capper, which may be automated or manual, and then to a labeling unit.
Finally, the containers are packed into shipping cases.
Dry Packaging
Dry formulations are also pack-
aged by simply transferring the
final product into boxes, drums,
jugs, or bags. Figure 2-5 depicts a
dry packaging line. Again, small
quantities or bags are typically
packaged manually using a gravity feed to carry
the product from the formulating unit into the con-
tainers or bags. Larger quantities may be packaged
on an automated line, similar to liquid packaging
lines.
Figure 2-4. Liquid
Packaging Line
Figure 2-5. Dry Packaging Line
10
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
Aerosol Packaging
Some water- or solvent-based liquid pesticide products are
packaged as aerosols. Figure 2-6 is an example of an aerosol
packaging line. The product is placed in spray cans that are
put under pressure, and a propellant is added. When the end
user sprays the aerosol, the propellent forces the product out
of the can and allows the product to be applied to surfaces or to be dispersed in
the air. An aerosol packaging line typically includes a filler, a capper, a propel-
lant injector, and a U.S. Department of Transportation (DOT) test bath. In the
filler, formulated pesticide product is dispensed into empty aerosol cans, in much
the same way that the liquid packaging lines fill containers. The cans are then
sent to the capper, where a cap with nozzle is placed on the can. The can enters
a separate room, where the propellent is injected into the can, a vacuum is pulled,
and the cap is crimped to make the can airtight. In order to comply with DOT
regulations on the transport of pressurized containers, each can must then be
tested for leaks and rupturing in a DOT test bath. The DOT test bath is a 130°F
hot water bath into which cans are submerged and observed for leaks or rup-
tures. The aerosol packaging line may also include a can washer to remove resi-
due from can exteriors prior to entering the test bath (to reduce contaminant
buildup in the bath), a dryer to dry can exteriors, and machinery to package
aerosol cans into boxes for shipment.
FORMULATED
PRODUCT
PROPELLANT
INJECTOR
DOT
TEST BATH
AEROSOL
PRODUCT
Figure 2-6. Aerosol Packaging Line
Pressurized Gas Formulating and Packaging
Some pesticide products are formulated and packaged as
pressurized gases. Figure 2-7 depicts a pressurized gas pro-
duction line. The active and inert ingredients are received
as liquids, pressurized liquids, or gases, and are stored in
tanks, tank trucks, rail cars, or minibulk storage contain-
ers. Liquid ingredients are placed in a holding tank prior to formulation. For-
mulating and packaging operations for these products typically occur in one
11
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
METER
FILL
TANK
TANK
TRUCK
FILLED
CYLINDER
Figure 2-7. Pressurized Gas Formulating and Packaging Line
step in a closed-loop system. The ingredients are metered by weight through
pressurized transfer lines into DOT-approved steel application cylinders. Other
equipment that may be included in a pressurized gas line includes pumps,
piping, and heating and refrigerating units to maintain gas pressures and
temperatures in storage.
The cylinders may be refilled at a later date, after they have been tested to
ensure that they are still capable of containing pressurized fluids. DOT requires
hydrostatic pressure testing, as well as visual examination of the cylinder. Hy-
drostatic pressure testing involves filling the tank with water to a specified
pressure and volume. If more water can be held in the cylinder than its original
volume, or if the cylinder weighs less than 10% of its original weight, it is
possible the cylinder walls are deformed, and the cylinder fails the test. Visual
inspection entails purging the cylinder of its vapors using an inert gas such as
nitrogen, and inspecting the inside for pitting and other defects with a fiber
optic probe. The cylinder is then rinsed with water and dried.
Repackaging
Repackaging operations are similar to packaging opera-
tions, except the "raw material" is an already formulated
product that has been packaged for sale. Repackagers of-
ten purchase formulated pesticide products, transfer the
product to new containers with customer-specific labeling,
and sell them to distributors.
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CHAPTER 2 PFPR Operations
Pollution Prevention Guidance Manual for the PFPR Industry
A separate type of repackaging, called refilling, is usually performed by
a gn chemical facilities that transfer pesticide products from bulk storage tanks
into mirubulks These refillable containers are constructed of plastic and typi-
cally have capacities ranging from 100 to 500 gallons. Minibulks may be owned
by the refilling establishment, the pesticide registrant, or by the end user. Pro-
duction lines usually consist of a bulk storage tank, a minibulk tank into which
the product is repackaged, and any interconnecting hoses or piping. The bulk
storage tanks are usually dedicated by product and clustered together in a
diked area. The products are dispensed to the minibulks either manually or
by using a computer-regulated system of pumps and meters The mirubulks
are typically reused by farmers or custom applicators and returned to the refill-
ing establishment
13
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CHAPTER 3
Pollution Prevention Glossary
Many PFPR facilities use P2 practices that conserve water, reduce the
amount of pollutants in wastewater, or eliminate wastewater gen-
eration altogether. This chapter presents alphabetic glossaries for
two basic types of P2 techniques: (1) implementation of P2 practices: and (2)
use of P2 equipment. For the P2 equipment, a picture or illustration and de-
scription of the equipment is provided. For the P2 practices, a description of the
practice and its benefits and an icon representing the practice are provided.
Throughout the manual, terms defined in this glossary will be shown in itali-
cized bold print.
The techniques presented in this chapter have been identi-
fied through site visits to almost 60 PFPR facilities, where
EPA observed the techniques in use. By implementing these
P2 techniques (e.g., use of flow reduction equipment), many
PFPR facilities generate less wastewater volume. By con-
trolling the volume of wastewater generated, facilities can
often reuse a larger overall percentage of their wastewa-
ter. Additionally, facilities can achieve optimal P2 benefits
by combining P2 techniques (e.g., use of flow reduction
equipment, dedication of equipment, and interior storage
and reuse) to reduce or eliminate waste- water generation and to increase the
level of reuse and recycle [Note: This P2 glossary presents not only those
practices listed in Table 8 of the final PFPR rule, but also many other P2
techniques that were observed in the industry.]
P2 Practices
These practices reduce the amount of
active ingredients and other raw materials
lost in wastewater discharges, and may
also decrease the volume of PFPR
process wastewater generated
Pollution Prevention Practices
Dedication of Equipment
PFPR facilities use production lines to formulate, package, and repackage a
wide range of products When switching one production line from one prod-
uct to another (i.e, product changeover), the facility cleans the equipment
(typically with water) to prevent cross contamination of products. Dedicat-
ing equipment on formulating and/or packaging lmes to the production of
one product or product type can reduce or eliminate the need to clean that
piece of equipment for product changeover In addition, because of the elimi-
nation of cross-contamination concerns, routine cleaning typically uses less
water
Use For
Herbicides Only
V J
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CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry
Some facilities dedicate just their formulation tanks, thereby eliminating one
of the most highly concentrated wastewater streams generated at their facil-
ity. Other facilities have dedicated storage tanks or entire formulating, pack-
aging, or repackaging lines, if they produce large quantities of that product
over long periods of time Still other facilities dedicate transfer hoses, pumps,
and other miscellaneous equipment. These PFPR facilities have implemented
this practice by using equipment that is:
• Dedicated to one product—a piece of equipment, or an entire formulating
or packaging line, that is used to produce only one specific product. This
type of dedication eliminates product changeover cleaning, and signifi-
cantly reduces routine cleaning. In addition, most cleaning rmsates can be
reused directly into the process (see Interior Rinsate Storage and Reuse).
• Dedicated to a product family—a piece of equipment, or an entire formu-
lating or packaging line, that is used to make products that have common
ingredients (such as s-triazine pesticides) or similar uses (such as herbi-
cides used on corn crops). This type of dedication can significantly reduce
product changeover cleaning and routine cleaning In addition, most clean-
ing nnsates can be reused directly into the process (see Interior Rinsate
Storage and Reuse)
• Dedicated to solvent-based versus water-based products—a piece of
equipment, or an entire formulating or packaging line, that is used for prod-
ucts that have a common base solvent (e.g., water, isopropyl alcohol). This
type of dedication eliminates water-contaminated solvent rinses and sol-
vent-contaminated water rinses that are generated during product
changeover from water-based to solvent-based products and solvent-based
to water-based products. Dedicating equipment to a common base can
eliminate solvent-water nnsates, which typically cannot be reused, and
can significantly reduce product changeover cleaning and routine clean-
ing. In addition, most cleaning nnsates from common-base-dedicated equip-
ment can be reused directly into the process for future formulation of the
same or compatible product (see Interior Rinsate Storage and Reuse).
Direct Reuse of Drum Rinsate
PFPR facilities frequently receive raw materials in drums, such as 55-gallon
steel or 30-gallon fiber drums. Empty drums may be returned to the supplier,
or the facility may by responsible for disposal. To prepare the drums for re-
use, facilities "triple rinse" the drum (i.e, nnse out the inside of the drum
with water three times) or pressure nnse the drum according to procedures
provided in 40 CFR, Part 165. A "tnple rinse" is defined in Part 165 as flush-
ing the container three times, using a volume of the diluent equal to approxi-
mately 10% of the container's capacity. When preparing drums for disposal
that contained nonhazardous materials, facilities should consult 40 CFR, Part
165.9 to determine if a triple nnse is required.
If the drum contained a material that is a listed hazardous waste, facilities
must also follow procedures provided in 40 CFR, Part 261.7(b) to empty the
container and dispose of or recycle it as nonhazardous. For example, "U"
listed wastes (40 CFR, Part 261 33(f)) must be removed so that no more than
2.5 centimeters (or one inch) of residue remains on the bottom of the con-
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CHAPTER 3 Pollution Prevention Glossary
Pollution Prevention Guidance Manual for the PFPR Industry
tainer, no more than 3% by weight of the container capacity remains in con-
tainers less than or equal to 110 gallons, and no more than 0.3% by weight of
the container capacity remains in containers larger than 110 gallons. It may
not be necessary to rinse the container if the material can be sufficiently re-
moved by draining, pouring, pumping, or aspirating, unless rinsing is re-
quired by 40 CFR, Part 165. Other wastes, such as "P" listed wastes (40 CFR,
Part 261.33(e)), must be removed by triple rinsing the container using a sol-
vent capable of removing the material.
The simplest, most cost-effective method of handling the subsequent rinsate
is to reuse it directly in the product formulation at the time of formulation.
This method eliminates the water from the facility's waste stream and recov-
ers the remaining raw material in the drum without the costs and space needed
for storage of the rinsate. If the product is a solvent-based product, the drums
can be rinsed with the base solvent of the product instead of water to prevent
creating a rinsate that cannot be added directly to the formulation.
In addition to reusing rinsate, some PFPR facilities use flow reduction equip-
ment, such as high-pressure washers, to effectively clean drums, while mini-
mizing the amount of rinsate generated (generally 5 to 15 gallons of rinsate
per drum).
Formulating and Packaging Small Batches in Containers
Facilities that generate small quantities of product may formulate that prod-
uct directly in the final shipping container (e.g., 55-gallon drum or minibulk
tank) to eliminate the use of a separate formulation tank. Facilities may also
package products directly from the formulation tank or blender into the final
shipping container to eliminate using interim storage tanks, packaging tanks,
and transfer hoses. These practices eliminate the need to use and clean cer-
tain formulating and packaging equipment, thereby reducing the amount of
rinsates generated during cleaning.
Good Housekeeping Practices
Good housekeeping practices are simple, straightforward operating practices
that can significantly reduce wastes. These practices include performing pre-
ventive maintenance on all valves, fittings, and pumps; placing drip pans
under valves and fittings where hoses or lines are routinely connected and
disconnected; and cleaning up spills and leaks in outdoor bulk storage and
process areas to prevent contamination of stormwater or exterior rinsewaters.
Other good housekeeping practices include repairing leaky valves and fit-
tings in a timely manner and reusing the material collected in drip pans.
Interior Rinsate Storage and Reuse
PFPR facilities use production lines to formulate, package, or repackage a
wide range of products. When switching a production line from one product
to another, the facility cleans the equipment (typically with water) to ensure
product quality. This interior equipment rinsate (either water or base solvent)
can be collected and stored in 55-gallon drums or small tanks for reuse as
make-up water in the next batch of that formulation or a compatible formu-
lation (e.g., product with same ingredients but at varying concentrations). In
CYCLE
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CHAPTER 3 Pollution Prevention Glossary
Pollution Prevention Guidance Manual for the PFPR Industry
some cases, the rinsate can be reused immediately in the product if additional
water or solvent is needed for the final product (e.g., refilling establishments
preparing the product for application on fields).
When facilities combine this practice with the use of flow reduction equip-
ment, dedication of equipment, and other production practices, they can mini-
mize the volume of rinsates generated during production of pesticide products
and are often able to reuse all interior equipment cleaning rinsates. Benefits
from these practices include reduced costs for raw materials and waste dis-
posal or treatment.
Inventory Management
Many PFPR facilities operate inventory management systems to track raw
materials, finished products, and waste products. These systems are also use-
ful for tracking cleaning rinsates that can be reused at a later date in product
formulations. Some facilities log these rinsates into their inventory as raw
materials to ensure reuse as soon as possible and to eliminate the possibility of
forgetting about them once they are stored. In addition, quick reuse can re-
duce shelf-life expiration problems. These inventory systems may be manual
(for smaller operations) or computerized (for larger operations), and may
also contain other environmental data, such as waste disposal information.
Non-Water Interior Equipment Cleaning
PFPR facilities can use several cleaning techniques in addition to dry process
cleaning equipment to reduce or eliminate wastewater generation. After for-
mulating or packaging, dry carriers used in the final product (e.g., clay) are
often used to initially clean the equipment. These materials are run through
the equipment to absorb residual product that may be present and stored for
use in a future batch of that product. A production line may also be "blown"
clean by forcing air through the equipment and collecting the material that
exits the system for reuse. Hoses and transfer piping may be cleaned in this
manner. A water rinse may follow this procedure. Cleaning a line with dry
materials increases recovery of raw materials and reduces the amount of water
used during cleaning operations.
Operation of Air Pollution Control Devices
Air pollution control devices, including baghouses, cyclones, filters, and wet scrub-
bers are sometimes installed on formulating or packaging lines to control the
release of volatile or dust emissions.
• "Dry" Devices—Baghouses, filters, or cyclones reduce air pollution with-
out the use of water by collecting dust and other particles generated dur-
ing production, particularly on dry product lines. Some facilities are able to
reuse the solid materials collected from those devices in the pesticide pro-
duction process.
• "Wet" Devices—Wet scrubbers also reduce air pollution by simultaneously
removing soluble and wettable particulates and soluble gases from an air
stream. To minimize wastewater generation from wet scrubbers, facilities
can either operate them with continuously recycled water until replace-
ment of the contaminated water is necessary, or with a bleed stream
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CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry
(blowdown) on a continuous basis. However, facilities should not reduce
their flow to the point where it hinders their ability to meet Clean Air Act
or other requirements. In some cases, if a wet scrubber is dedicated to a line
that formulates a water-based product, the blowdown from the scrubber
can be reused in that formulation.
Operation of Department of Transportation (DOT) Test Baths
DOT test baths are used to test aerosol cans for leaks or weaknesses under
pressure. The cans are visually examined for leaks while in the test bath.
Because drips on the outside of cans, or occasionally exploding cans, can
contaminate the water bath, the water in batch baths must be changed peri-
odically to ensure visibility and to reduce the presence of residues that may
adhere to cans leaving the bath. Facilities operating DOT test baths with con-
tinuous overflow can recirculate the water for reuse. If necessary for visual
clarity, PFPR facilities can recirculate the water through a filter (e.g., diato-
maceous earth or activated carbon) to remove dirt and oils. The use of filters
allows water to be recirculated for longer periods of time before changeout is
necessary.
Production Scheduling
If a facility is not able to practice dedication of equipment, they often can
manage their production schedules to minimize product changeover clean-
ing operations. To do so, facility personnel can develop cleaning procedures
specific to each potential changeover. They can examine which products can
be formulated in succession without the need for cleaning (e.g., they contain
the same ingredients but in varying concentrations) or with a minimal clean-
ing. On any given day, production can be scheduled to minimize the cleaning
efforts and therefore the wastes that are generated during cleaning. In some
cases, facilities are able to schedule production so that the cleaning rinsates
generated are able to be reused in subsequent processes.
Training and Written Standard Operating Procedures
Employee training and well-written standard operating procedures (SOPs)
are an integral part of any pollution prevention program. Training will en-
sure that all employees are aware of the goals of current pollution prevention
initiatives and how the initiatives will improve operations. Written SOPs will
reinforce operator training and ensure that all functions are performed effi-
ciently. It is important to obtain both management and employee buy-in to
the program, and to view pollution prevention as a way of doing business.
Some PFPR facilities have formed pollution prevention teams or coordinators
to develop SOPs for cleaning procedures and for reuse of cleaning rinsates
into formulations. Some facilities have also integrated an evaluation of an
employee's adoption of P2 practices into performance reviews or provided
awards or incentives for innovative P2 ideas.
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CHAPTER 3 Pollution Prevention Glossary Pollution Prevention Guidance Manual for the PFPR Industry
Pollution Prevention Equipment
Drum Rinsing Station
A drum rinsing station consists of a series of three
cells that are used to triple rinse drums. A typical
station uses a spray nozzle to shoot water at high
pressure into a drum that is inverted over the cell.
The rinsate flows out of the drum into the cell, the
drum is moved to the next cell, and the process is
repeated. The first cell is used for the first rinse, which
results in the most removal of pollutants and the most
contaminated rinsewater. The second cell is used for
the second rinse, which removes additional pollut-
ants, but the rinsewater is not as contaminated as
the first cell. The third cell is used for the final rinse, at which point most of
the pollutants have been removed by prior rinses and the rinsewater is the
least polluted of the three cells.
By rinsing the drum in stages (i.e., cells), the volume of rinsewater is reduced.
The rinse water in the first cell is reused until it is visibly too contaminated to
be used further. At that time, it is removed from the cell and treated or dis-
posed of. The cleaner rinsewater from the second cell is transferred into the
first cell and the cleanest rinsewater from the third cell is moved to the second
cell. Fresh water is added only to the third cell. As a result, two cells of water
are recycled, only one cell is filled with new water, and the quantity of water
used is reduced by about two thirds. Some PFPR facilities using a drum rins-
ing station with 100-gallon water cells have cleaned as many as 70 drums
before changing water.
Dry Process Cleaning Equipment
Dry process formulating and packaging lines, which do not generate waste-
water, are often cleaned using equipment such as brushes, scrapers, and vacu-
ums. This cleaning equipment will physically remove solids that have adhered
to process equipment during the formulating or packaging step. Examples of
dry process cleaning equipment include the following:
• Brushes/Scrapers—Wire brushes and scrapers are used to remove packed
or dried materials from the equipment that would not be removed with
vacuuming alone. This material can then be vacuumed or swept up for
reuse.
• Vacuums—A standard industrial shop vacuum (with appropriate electri-
cal classification and exhaust filtration) can be used to collect solids and
dusts that have settled on dry formulating and packaging equipment dur-
ing processing. It can also be used to clean floors in the dry process area
and to collect spilled product. The collected material can often be reused in
the formulating process.
Cleaning the equipment with brushes, scrapers, or vacuums may result in
recovery of dry product that can be reused in the process, and significantly
reduce or eliminate the need for water washes and the subsequent water
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CHAPTER 3 Pollution Prevention Glossary
Pollution Prevention Guidance Manual for the PFPR Industry
rinsates that cannot be directly reused. For example, a facility may initially
scrape off dried material from the process line equipment, vacuum loosened
materials, and finally perform a quick water rinse. The rinsate will contain
significantly less contaminants than if the facility had relied upon only water
to clean the equipment.
Floor Scrubbers
Floor scrubbers are mechanical devices that continually recirculate cleaning
water to clean flat, smooth surfaces with circulating brushes. They come in a
variety of shapes and sizes. During operation, the scrubber collects the clean-
ing water in a collection tank, which is easily emptied after the cleaning pro-
cess, or at a later date.
Cleaning floors by other methods, such as a mop and bucket or garden hose,
require larger amounts of water. Floor scrubbers will significantly reduce the
amount of water used for floor cleaning while increasing the effectiveness of
the cleaning operation. A typical floor scrubber can clean large processing
areas in one hour but use only 10 to 20 gallons of water. The use of floor
scrubbers also reduces labor costs and water costs.
Flow Reduction Equipment
Flow reduction equipment includes simple mechanical devices that control
how water is sprayed during cleaning operations. The use of flow reduction
equipment reduces the volume of water generated during cleaning opera-
tions, as well as increased efficiency in the cleaning process. Examples of
flow reduction equipment are:
• Spray Nozzles—Nozzles are the most common form of flow reduction equip-
ment used in the PFPR industry. Spray nozzles are used to regulate the
amount of water used to clean both the interior and exterior of process
equipment. They also direct the water at a higher pressure than from an
unequipped hose, resulting in a more effective cleaning stream.
• High-pressure, low-volume washers—These washers provide a higher degree
of cleaning than a spray nozzle. Typical pressures range from 500 to 3,000
pounds per square inch (psi).
• Spray balls—These balls direct water through multiple nozzles or drilled holes
to efficiently clean the inner surfaces of closed or open tanks or trucks. Typi-
cal water pressures range from 45 to 75 psi; flow rates range from 10 to 48
gallons per minute (gpm), depending on the size of the spray ball and the
size of the tank to be cleaned.
• Hot water/steam cleaners—These cleaners are similar to high-pressure, low-
volume washers except they use steam or hot water. They are useful for
hard-to-clean products, such as emulsified formulations or highly viscous
materials. Typical operating pressures range from 230 to 3,000 psi; flow rates
range from 1 to 6 gpm.
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Pollution Prevention Guidance Manual for the PFPR Industry
Without the use of this equipment, facilities may generate more wastewater,
particularly interior equipment rinsates, during the cleaning process than can
possibly be reused in product formulation. Other benefits to the use of flow
reduction equipment include lower water costs, increased cleanliness, and
reduced storage, treatment, or disposal costs. In addition, use of flow reduc-
tion equipment aids in avoiding free flow of water from unattended hoses.
Solvent Recovery Equipment
Solvent recovery equipment primarily consists of flash distillation units, which
use the difference in boiling points to physically separate organic solvent from
wastewaters. Some facilities may generate solvent-contaminated wastewa-
ters during cleaning operations that are unable to be reused in water-based
products; other facilities generate water-contaminated solvent wastes that
are unable to be reused in solvent-based products. These wastes are fed through
the distillation unit at a temperature where the solvent is vaporized from the
waste stream. The solvent vapor is then condensed to liquid. These efficient
units recover high yields of spent solvent for reuse in later formulations.
The use of solvent recovery equipment can reduce raw material (i.e., solvent)
usage and cost. In addition, this equipment can reduce disposal costs by recov-
ering solvent for reuse and reducing the quantity of solvent-aqueous
changeover water that is disposed of as waste.
22
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CHAPTER 4
Conducting the P2 Audit
One way facilities subject to the final PFPR rule can determine which
compliance option to choose is to use a four-part process: (1) conduct
a P2 audit, (2) make preliminary compliance decisions, (3) evaluate
wastewater treatment technologies, and (4) make and document final
compliance decisions. This chapter discusses the P2 audit and how a facility
can use that tool to make preliminary decisions on which compliance strategy to
choose. Chapters 5 and 6 present the ways m which a facility can treat the
wastewater remaining after the P2 practices have been implemented and evaluate
the economic impacts of wastewater treatment
compared to contract hauling Chapter 7 presents
ways for facilities to make and document their final
compliance decisions. The P2 Audit
A comprehensive P2 opportunities assessment (or
audit) is the first step in implementing an effec-
tive P2 program and in determining compliance
with the final rule. However, this P2 audit is
not required by the rule and is not mandatory.
The P2 audit described in this chapter focuses
on water use and wastewater generation. This
audit is not designed to be a comprehensive P2
audit, as it does not fully evaluate solid waste
and air emissions; however, it will assist users in
identifying PFPR wastewater sources and P2,
recycle, and reuse practices and m making com-
pliance decisions for the PFPR effluent guidelines
and standards For information on P2 audit tools
that will help you analyze your solid waste and
air emissions, see the resources listed in Chapter
9.
Each PFPR facility will need to make an initial
choice of how to comply with the regulation. A
facility may choose to either comply with the
zero discharge effluent limitahon/pretreatment
standard or implement the P2 alternative (prac-
tices listed in Table 8 of the final rule plus waste-
water treatment when necessary). The choice of
zero discharge or the P2 alternative can be made
on either a facility-wide basis or on a process
Completing a P2 audit Is not mandatory, but
may be helpful to:
¦ Decide whether to comply with the P2
alternative or the zero-discharge option,
¦ Assess whether a facility is in compliance with
the P2 alternative;
¦ Identify production changes that could result in
savings;
¦ Identify P2, recycle, and reuse opportunities for
wastewater discharges, and
¦ Organize paperwork documenting compliance
with the P2 alternative.
P2 Alternative
The P2 alternative permits a "P2 allowable discharge"
as an alternative to zero discharge of process
wastewater when facilities implement the specific P2
practices listed in Table 8 of Appendix A of this
manual and wastewater treatment when necessary
These practices reduce the amount of active
ingredients and other raw materials lost in wastewater
discharges, and may also decrease the volume of
PFPR process wastewater generated
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
basis (i.e., product family/process line/process urut) Facilities that imple-
ment the P2 alternative will also need to agree to make the practices and the
P2 discharge allowance enforceable
The tools presented in this chapter to conduct a P2 audit are based on the
practices included in the effluent limitations guidelines and standards for the
PFPR industry as well as other P2 practices that are in use m the PFPR indus-
try. The audit may be used to identify waste sources at the point of generation
and to match each source with applicable P2, recycle, and reuse practices
Identifying these P2 opportunities can help facilities reduce costs even when
not choosing to comply with the P2 alternative.
The P2 audit tables discussed in this chapter (Tables A through C) and the
wastewater treatment tables presented in Chapter 6 (Tables D and E) are
offered as one way to conduct an audit and/or to demonstrate compliance
with the P2 alternative. It is not required that facilities, permitters, or other
auditors use these tables. However, the tables discussed in this chapter
summarize the types of information that are useful in conducting a P2 oppor-
tunities assessment. Since it is very difficult to construct one table or checklist
with a format useful for all PFPR facilities, EPA hopes that the tables pre-
sented in this manual are a useful tool as they are, or can be adapted in
whatever way the user feels is appropriate. P2 Audit Tables are available in
an electronic format in Excel 5.0 and may be requested from Shan Zuskin of
EPA's Engineering and Analysis Division (see Chapter 9 for fax, E-mail, and/
or mailing address).
The information necessary to complete the tables may be collected in a vari-
ety of ways. Much of the information may already be available in production
records, state P2 plans, stormwater plans, inventory management systems,
or facility permits. In addition, the information gathered for the checklist may
also be used to help complete other types of plans (e g., stormwater or state
P2 plans) in the future
PZ Audit Components
Table
Title
Purpose
Table A
Identification of
Helps users create a detailed summary
Wastewater Sources
of potential wastewater sources that is
developed through review of process
operations.
Table B
Evaluation of PFPR P2.
Helps users create a detailed summary
Recycle, and Reuse
of P2. recycle, and reusepractices, and
Practices
an evaluation of their current use.
whether they can be implemented by the
facility, and any required modifications.
Table C
Summary of PFPR
Helps users create a summary of the
Compliance Decisions
compliance decision for each wastewater
source identified in Table A The
completion of the P2 audit results in a
preliminary compliance decision for each
source.
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Nonpestidde Operations and Industries
A P2 audit is also useful in identifying wastewater P2 opportunities
in other industries, such as those industries listed to the right. In
fact, many PFPR facilities also engage in formulating and packaging
of these nonpestidde products. Although the P2 audit tables are
designed specifically for the PFPR industry, the P2 opportunities
listed may be advantageous for other operations and industries.
Other chemicals
formulating, packaging,
and repackaging;
Pharmaceuticals;
Animal feed products,
Cosmetics; and
Fertilizers
The P2 audit tables are designed for use by PFPR facility managers, POTWs,
permit writers and other regulatory agency representatives, federal and state
auditors, and consultants (referred to as the "user" throughout this chapter)
Example pages of the audit tables (completed for a fictitious facility) are shown
throughout this chapter to illustrate the types of information captured on the
tables. The blank tables are presented in their entirety in Appendix B. Specific
P2 equipment and practices listed on the table instructions in italicized,
bold print are defined in the P2 glossary in Chapter 3.
Conducting The Audit
In order to thoroughly assess P2, recycle, and reuse opportunities, detailed
information pertaining to all source identification and P2, recycle, and reuse
practices must be available to the user. This information is best obtained
through interviews with facility personnel, review of facility records, and
first-hand observation via a plant tour. The user can also incorporate, where
applicable, any personal knowledge of or experience with the facility. It is
helpful to review all information with facility personnel so that data gaps
may be filled, and to discuss facility-specific benefits or problems associated
with implementation of different P2, recycle, and reuse practices Some of the
information, such as wastewater generation volumes and frequency, may not
be readily available the first time such an audit is completed; however, over
time a facility may implement systems to track these types of data to facilitate
future P2 assessments.
Each page of the P2 audit tables has space to enter the name and location of
the facility, the name of the user, and the date the audit is completed.
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR. Industry
Table A: Identification of Wastewater Sources
Table A of the P2 Audit is not only the starting point but also the focal point of
the P2 audit. The wastewater streams and sources identified on Table A will
be linked to potential P2 opportunities on Table B and waste management
options in Chapter 6. Completing this table will enable facility personnel to begin
assessing whether to choose to comply with the P2 alternative, and if so, to
comply on a facility-wide basis or on a product family/process line/process unit
basis.
Table A is used to identify all PFPR wastewater sources at the facility and to
gather general operations and treatment information (e.g., frequency of waste-
water generation) about each source. The table includes a comprehensive list
of the wastewater streams and sources found m the PFPR industry; however,
space is also included for additional wastewater streams that may be identi-
fied for a specific facility. Three steps that can be used to complete Table A are
detailed below
Table A
i
Step 1: Identify Wastewater Stream Types and Sources
The user should take time to accurately and completely identify all PFPR
wastewater stream types and sources at the facility Figure 4-1 presents an
example of the types of information collected while completing Step 1 In
particular, the unshaded columns "Stream Type", "Source", and "Com-
ments" illustrate this example.
Table A Identification of Wastewater Sources
Facility Location
Date Prepared by
Stream Type
Source
Bafcbor
CMtfaaota
Volume
Gemratrd
Ceoerattoo
Freqococjr
Active
lozrvdkoa
Wtstrwatrr
Malrfa*
Wstewjler
Muaxsaeot
Comments
1 Shipping Container/ Drum
Cleaning* *ateror solvent nnsej
of the containers used to ship ran
material finished products and/or
*asie products prior to reuse or
disposal of the containers
1 a.
oirazwe
meioiochlor and
men drums
20 drums of atropine 5 drums of
metolachlor and 5 drums of mens
used each neck
1 b
copper naphthenaie
and solvent drums
5 drums of copper naphthenate and 5
drums of sohent used each *erL
Tank Rinsate • cleaning
of ti&iqtenor of an > bulk stonge
tank contttiwig ru* materials
intermediate ukjidyvr finished
products as#xdtetf\ith PFPR
operation^
2a.
Stream r\pe not generated at this
factlm
2b
Stream tvpe not generated at this
facility
i Formulaling Equipment
Interior Cleaning routine
cleaning cleaning due to product
changeover or special cleaning of
the interior of an\ formulating
equipment including formulaiton
and/or storage tanks, pipes and
hoses Cleaning materials ma\
include %ater detrrgrnt or
solvent
3 a.
liquid formulation
tank * I
Herb 01/02 tail nmed */*ater 1TD>
Fungicide tank rinsed nith solvent (REl
then * aier tTD)
3b
liquid formulation
tank 0 2
Herb 01/02 tail nnsed */*ater (TV)
hingicidr tank rrnstd sohetf (Rh!
then *aier (TD1
3c
liquid formulaiton
fctnl. 9 }
Herb'1/02 tank nnsed */*oter(TD)
h ungiade tank rinsed m uti soherj iRE)
then »ater lTD)
3d.
dr\ formulaiton tank
On. process line nnsed monthl\ cfter
sleeping
' lncns(cc cmutsiucrs suriaaams) solio. dacrccnt ac
REeTCusc TR=ireaimcru and reuse TD=trcauncn: and discharge Dl=indtrcct discharge DDsdirea discharge IN=incineraiion DP=cff site disposal
Figure 4-1. Identifying Wastewater Stream Types and Sources
26
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
The "Stream Type" column lists potential wastewater stream types. An en-
try of "Other" is also provided at the end of Table A for facility-specific waste
stream types It is most useful for the user and facility personnel to discuss
each stream type to decide whether it exists at the facility After consider-
ation, if it is determined that a wastewater stream does not exist at the facil-
ity, the user can draw an "X" through the box in the "Stream Type" column.
Any pertinent information (e.g , stream type not generated at facility, opera-
tion not performed at facility) can be noted in the "Comments" column. In
the example shown in Figure 4-1, the facility does not have bulk tanks; there-
fore, bulk tank nnsate has been crossed off as a source.
If it is determined that the stream type does exist at the facility, the source of
each stream type can be noted m the "Sources" column. In the example in
Figure 4-1, it is noted in Box 3a that one source of wastewater from formulat-
ing equipment interior cleaning is a liquid formulation tank identified as
Tank #1. In the "Comments" column, the user has also provided details on
the number of times the tank is used in production and some details on the
cleaning process.
Space is provided on Table A to mclude multiple sources of a single wastewater
stream type. For example, Figure 4-1 presents information on two types of
shipping container and drum rinsing operations that occur at the facility. If
the checklist or similar form is being used to demonstrate compliance with
the P2 alternative, the user should be as clear as possible when identifying
sources of wastewater stream types. If abbreviations, process line numbers,
production line codes, or other notations are used on the form to designate
sources, the user should ensure that supporting information (e g., process
diagrams, process line names or products, and a key to the abbreviations) is
attached to the table
The "Stream Type" and "Sources" columns can be initially completed in the
office prior to a plant tour by using prior knowledge of the facility and its
operations. The stream types and sources listed can then be refined through
discussions with facility personnel during a plant tour.
Table A
27
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 2: Collect Operations Data
Operations information (e g., how a wastewater is generated) should be
weighed heavily when evaluating potential P2 opportunities. For example, if
a waste stream is only generated in small volumes one time per year at the
facility, then examining P2 practices for that waste stream may be a lower
priority than a waste stream that is generated every day. Figure 4-2 presents
an example of the types of information collected when completing Step 2.
The unshaded portions of columns "Batch or Continuous", "Volume Gen-
erated", and "Generation Frequency" illustrate this example
For each stream type and source identified, enter operations data on Table A.
Indicate whether the waste stream is generated from a batch or continuous
process by entering either a "B" for batch or a "C" for continuous under the
"Batch or Continuous" column. Enter the volume (either batch volume or daily
volume), including measurement units, generated in the "Volume Generated"
column. Enter how often the wastewater is produced (e.g., once per day, once
per year) in the "Generation Frequency" column. For example, in Figure 4-2,
the user noted that the facility has a wastewater stream generated from a batch
cleaning process for 55-gallon drums that contained atrazine. Five gallons of
wastewater are generated per drum and 20 drums are cleaned weekly.
The accuracy of the operations information may vary from source to source.
Many times, facility personnel may only have approximate waste stream vol-
umes available Through continued use of the P2 audit, however, the waste
stream data should become more accurate, since operations data play an
important role in deciding the most cost-effective compliance strategy
Record pertinent information regarding operations data in the "Comments"
column and, if necessary, attach to the form the key to any abbreviations or
notations
Table A Identification of Wastewater Sources
Table A
I
|
|
i i
Facility Locattuo
Date Prepared by
Si ma Type
^OOTft
Batch or
Continuous
Noliint
Groe rated
CtHntwn
1 rcqurnn
Act he
iBjcmlienti
ttafitwtfrr
Matrb1
W«
KOiausl, finuhrd product] aid/ot
+aue prvAtfti pner to tew or
disposal of the cDtuauten
1 •
atraztte
mftoiacfilor etJ
inert drums
B
S gal/drum
25 drums
ptr *eek
20 drums of atrazine 5 drums of
metolachlor and S drums of mens
used each
1 b
copper AapftihcACtr
aaJiOhrnidrunj
B
5 xaUdrum
10 drum
perueek
* drums of copper naphthenale and S
drums of solvent used each *eet
fcsJutt Tmk Riamc ikaniyif
of thhqttnrr of cm vtmlk swvjff
cca* roroqtqt raw t»cf/ncU
MfrmrditrfhtjjdyCrfuuitied
producti PFPR
opcrstx>yr N.
2.1
Stream r\pe not tereratcd ai this
facihrt
:b
Stream t\pe not generated at this
facihn
J frcrnudafaK Lqatporal
Inlnkoi OruiaK • tuuUAe
dear.mjc cteatunj dot tn product
changeover or ipettaldfttMtg nf
rtc tMrnor of aa\formula!
rtfuipnunl. i
include *wr drvr unetctde tarjt rtnsed *tlh iohent (Rit
ihen noierlTD)
'd
dn fomtiUuio* lank
B
100 ?al
Kfonihh
i)r\ process line rinsed rr.onitils afier
s*eepmt
1 Incrta (c c cnulsjftcrN surfactants) solids deterrent etc
RE^rcusc TR=trcatmcfU and reuse TDatraintni and discharge D!auxlircct discharge DD=ducci discharge IN^mcmcrairon DP=off site disposal
Figure 4-2. Collecting Operations Data
28
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 3: Collect Waste Characterization Data
The quality and composition of the waste stream is directly related to the
potential P2, recycle, and reuse practices that may be implemented by the
facility Therefore, the next step of a P2 audit is to collect waste characteriza-
tion information (e g., the constituents in the wastewater) This information
may also be useful when exploring wastewater treatment technologies, as
described in Chapter 5. As shown in Figure 4-3, the facility generates an
interior equipment cleaning rinsate containing carbaryl, listed in Box 3d, from
rinsing a dry formulation tank with water once per month. The facility is
unable to reuse this wastewater in the formulation because the product is
dry However, they do sweep out the equipment prior to the water rinse to
minimize the presence of pesticide m the wastewater.
The user should try to identify waste characterization data for each stream
type and source identified on Table A Enter the name or abbreviation for the
active ingredients present in the waste stream m the "Active Ingredients"
column. In some instances, the facility may use more active ingredients than
can be listed m the space provided. In those cases, the user can attach a sepa-
rate sheet listing additional active ingredients present in the waste stream.
Next, record the other constituents (e.g., solids, solvents, detergents, emulsifi-
ers) in the wastewater that may affect reuse or implementation of a P2 initia-
tive under the "Wastewater Matrix" column Finally, enter wastewater
management and treatment information using the codes provided in the foot-
note m the "Wastewater Management" column. As shown in Figure 4-3, the
facility discharges the carbaryl wastewater to a POTW without pretreatment.
Again, record any pertinent information regarding operations data in the
"Comments" column and attach the key to any abbreviations or notations
(e.g, process line #1) used on the table. The "Comments" column may also
be used to note any unique aspects in the generation or handling of each
source, including multiple discharge practices for the same source.
Table A Identification of Wastewater Sources
labile A
i i
facility Location
Pate Prepared b>
Strewn Type
J-oarre
Bsteb or
Combiootti
\otenr
(jtwntrd
GcMntkM
Irrqonq
Actl*e
Ingredients
VNsstrwatrr
Matrix1
Uatfrtialrr
Management
Comarots
1 Shfpptag CoaLalarr/ Drum
(.Vinlajt • water or solvent rivet
of the comamrrt wed to tfup raw
mairnci Jmuhed products, andAjr
•aite product* pnor io root or
ittpoial of the eontamert,
1 a
straw
metotaetthv and
uun dnuaj
B
5 $aVdrum
2S drums
per week
airajne
meiolechlor
naier tnens
Rh
20 drums of atrazuv 5 drums of
metolachlor andi drvruof mens
Uird euch neek
1 t>
copper naphtftenate
aaJ iOtvev drums
B
$ talMrwn
10 drum
per wrek
copper
naphthenate
jo/i ent
1)1
5 drums of copper naphthenau OAd 5
dntmjj of ined each *crk
^s&atk Tank Rhmtc •
iy (hbqttrwr of ga\ bulk its/atf
um* ro» mapUak.
intermediate oHqdyGr finished
products PFPR
operator
Li.
Stream r\pe not generated
3d
dry (wmuSalion UjaI
B
lOOjral
MtniMy
carbon 1
%ater solids
1)1
I)r\ pnx.ru hne rvisedmixiUih after
SMrrj>tn$
1 ]ncfis (c c cmultihcrs oulacums) solids determent etc
RE=reu« TRstrcauncnt and reuse TD=ireauncm and discharge DI=uxJircci discharge DDsdircet discharge 1S=incm<-ration DP=ofl %ac disposal
Figure 4-3. Collecting Waste Characterization Data
29
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Table B: Evaluation of PFPR P2, Recycle, and Reuse
Practices
Table B of the P2 audit is used to evaluate the P2, recycle, and reuse practices
in place at the facility and to consider the feasibility of implementing addi-
tional P2, recycle, and reuse practices at the facility Each facility subject to
the final PFPR rule will have three options in choosing how to comply with
the regulation- (1) comply with the zero discharge effluent limitation/pre-
treatment standard, (2) incorporate the P2 practices listed in Table 8 of the
final rule with wastewater treatment when necessary, or, (3) if the facility has
an approved justification, incorporate the P2 practices with modifications
and wastewater treatment when necessary. The column "Table 8 Listed Prac-
tice" lists the P2, recycle, and reuse practices found in the final rule (see Ap-
pendix A). A facility that wishes to discharge wastewater must incorporate
these P2, recycle, and reuse practices into their process. The column entitled
"Practice" describes recycle and reuse practices that are demonstrated m the
PFPR industry. These practices mclude P2, recycle, and reuse practices from
Table 8 of the final regulation and other recycle and reuse practices that PFPR
facilities can choose to incorporate. The "Comments" column should be used
to note any unique circumstances surrounding the facility-specific applica-
tion of a particular P2 practice.
It is helpful if the person(s) conducting the P2 audit and completing Table B
reads and understands the instructions for the intended use of Table B, and is
familiar with the available P2 equipment and practices presented in Chapter
3 Table B will not only aid in deciding to choose the P2 alternative and in
documenting current practices at the facility, but will also be a guide to imple-
menting successful P2 practices. Four steps that can be used to complete Table
B are detailed below
Table B
30
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 1: Identify Practices Reported by Facility
Figure 4-4 presents an example of the types of information recorded when
completing Step 1. Page 3 of Table B is shown so that the P2 practices match
the source codes from Page 1 of Table A (shown in Figure 4-1 through 4-3).
The unshaded columns "Practice", "Source Code from Table A", and "Does
Facility Use This Practice?" illustrate this example. The P2, recycle, and re-
use practices listed in the "Practice" column m Table B should be discussed
with plant personnel to identify if they are utilized by the facility. For each P2
practice the facility uses, note which facility operation implements the prac-
tice by transferring the source code from Table A into the "Source Code"
column. In the "Does Facility Use this Practice?" column, answer "Yes" or
"No " The "Table 8 Listed Practice" column indicates which one of the prac-
tices on Table B corresponds to the practices on Table 8 of the final regulation
If there is no corresponding practice in the final regulation, "NA" appears in
the "Table 8 Listed Practice" column
Table B
1
Table B Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility
Date
Uauw
Pirptrrd by
Taftfc*
Lb»4
Pnrtkt'
fiwtita
Dih
Uac
tU*
rvwtk**
^«rt« Cadi
fm
Tab** A
h»ttk>ObKT»id D«rto|
Aotfll
C'«aU t'irility
(fab
FiKtnblki
Fat***"*
Rtqafrt*
jutfolM Fbr
Medifksdee'
1, !¦¦¦>
7 Ikdnbd hqaipcnmt far Setvrnt* and Hairr*Hned Product*
7 1
9
Facility dedicates PFPR production
equipment «? waicx-bascd « solvent
bawd product* Dedicated solvent based
or «ver based equipment may be used oe
a noQ roandc turn for noo-dcdicaicd
operation i. twt facility may oot discharge
Lbu aqueoos tiuogcova name ts pan of
ibeir P2 allowable discharge
So
in
9 Interior Kau
rStorafraod Rrair
8-1
10
Interior nruatc is uored tot feme in tuture
fonsuljuons of tte urn or
conpuiblc product (note doei not
include dnimtonpptrig coauncr nnuie)
Yts
3
So
J
S-2
i
Dry earner material is stored and reused ir
future fomutaaon of (he same or
convni&ic prodci or disposed of as sobd
>»wtt
Yes
3
e-i
4
ImcnortOl ort formulation eqwpnuit an.
cleaned wttn dr> earner pnor to water
rinse
So
3d
•iOCFR JSS t>7
tsicn u* following modificaicn codes in tftc column uilcd 'Required Justificuion for Modification"
ALTUISPOSE.BIOCROW.TH BREAkCAA. DETERCEVT DROP ISERT SARROV. PACKAGE RECOVERY REFURB SPACE. OTHER
(Modification Code Sheet ai cod of table eneiajo* a detailed explanation of each code )
Figure 4-4. Identifying P2 Practices
31
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 2: Identify Practices In Use
During the plant tour, note in the column entitled "Extent of Use of this
Practice Observed During Audit" the locations and operations where each
practice has been implemented. Figure 4-5 presents an example of the types
of information a user may note while touring a facility. If a particular practice
is not used (such as low-volume/high-pressure rinsing equipment or other
flow reduction devices), answer "NA" in the "Extent of Use of this Practice
Observed During Audit" column.
Table B Evaluation of PFPR P2, Recycle, and Reuse Practices
Table B
l
Fftdlit)-
patr
looiiaa.
hrjund by
Tabte 8
Listed
Practice*
Pwtkt
Um
V*Uty Uw
Otb
PMtk»*
htonrCodt
(Ma
Table A
of Uw of this
PlKUuOtwrmHWan
Audit
KmJdtactiiqr
I'tir1*"—* ttb
ftidkrlttU*
t*wv*
Jtlflmlnn frc
Modification*
7 U
wOftwd hqstpnm for and Watcr-EUsed Pndocts
NA
7 I
9
Faaiify ifcdtotci FWR prodoatoo
equipment b> »?ter-based vw wtveot
hoed pratoctv Dedrated toKnt^ued
or wato hwd ojogxanu may t* mcd m
s GOfrialtat bua lor noMMcikd
opfliunm. m firilfay my awdbdaqtc
ibe fciwan ctaofcunr raasc »pvtof
ibe> P2 tfiowifak dtsdurtE.
Ho
I $4
L tn
•trior Rtaal* Storarcand Rrasr
huagiade Jormulntnn tani
\oh em rtasaie is sored for
mat
H
10
b> tenor ncuie b uofcd for reaie id Aiun
kvothom <4 (fee moc or
ooopaMt prodoa (aotr doo boi
nctode drunVktippbii cnoufaxr nsvie)
Yes
i
No
5
flA
8 2
4
Dry earner outcmJ b ttortd aid raord k
("mere tmnatettoo at tbe one or
eompoflfrfc. pnxtod or dspoaed af a wild
waste.
Yet
{
Ifn materia! is rtuud at
product
bWMnof
-------
CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR. Industry
Step 3: Identify Practices That Could Be Implemented
In The Future
During the plant tour, identify locations and operations where each practice
could be implemented. Indicate "Yes" or "No" for each practice in the col-
umn entitled "Could Facility Implement this Practice in the Future?" If a
particular practice is already in use at the facility answer "NA" in this col-
umn. A facility may choose to implement a modification to a P2 practice
listed in Table 8 of the final rule. In this case, the facility must write in the
"Required Justification for Modification" column the appropriate code for
the modification from Footnote 2. The list of codes and their explanations
appears at the end of Table B. Use the "OTHER" code if the modification is
not one that is listed in the final rule and describe the modification in the
"Comments" column. Note that if the selected modification is not listed in
the final rule, a facility must submit a request to the control authority or per-
mitting authority for the modification and have it approved prior to imple-
menting the modification Figure 4-6 presents an example of these answers.
TableB Evaluation ofPFPRP2, Recycle, and Reuse Practices
Table B
i
FudUly
Dale
Location
Prepared by
TaMa 8
LfaUd
Prttlfcv'
Pndln
Doo
Padttty U«
(fcfc
Practka*
Soarca Coda
Tabb A
htaMoruN«rait
PmUu Otainiil Dwtajt
AodU
lo«bd tacitMy
tsylaanltbb
Pnoka to (hi
KstviV
Raqatrad
JwtUkatkn far
Modlflortton'
Ceoont)
7 D*dkMd hqutcmrnl for Sotvrrt* ind W>lir«Brad frwfadt
NA
Yes
Factlm could dedicate one of the tanks
to sol\ eni based products
? 1
9
Factiity dcdMRft PFPR prodqeaoo
cqmpoaM to v* loftcn
based product*. Dedicated wfrcnt baaed
water bawd eoupmou say be tned
J
tiA
So
BIOOROWTH
For the neier based herbiades faetlih
hasdtmonaratedt^idtncr of biological
Wrth oxer a typical aoru^eperiod
8 2
4
Dry amei bubuI rv uond aad reined t&
fotwe formuUuoa of the sane or
cocnpauMc protect or dspowd of u td>4
WWC
Yfi
J
Dn wtaunol it rrgtrJ in
prodaa
A/4
lattnon of Cry fannidaoao cqcrpncnt arc
13
4
ckwd witb dry carrier prior to water
So
J4
SA
A'p
nate
' 40CFR455 67
Inscri the following modification codes in tlx, culumn wlcd "Required Justification for ModiOcauon'
ALTDJSPOSE, biocrowth breakcaa. detergent drop inert narrow package, recovery refurb space other
(Modification Cod. Sbcet ai uxJ of able contain* a detailed txplanaboo of ocb cwk )
Figure 4-6. Identifying Future P2 Practices
33
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Step 4: Identify Information for the "Comments" Column
For each practice listed on Table B, additional information may be collected
by the user to further evaluate implementing P2 at the facility
Information for the Comments Column
¦ Suggest practice-specific implementation and compliance demonstration
methodologies,
¦ Differentiate between similar practices within the same general heading
(such as under "Reuse of Drum Rinsate") in place at the facility,
¦ Discuss modification justifications; and
¦ Provide additional information for specific practices.
Table B
1
The following instructions contain suggested ways to use Table B, special items
or information that can be sought out by the user, and important follow-up
ideas, such as review of facility documentation. Where a P2 term has been de-
fined and/or described in Chapter 3, the term is in italicized bold print
1. Water Conservation
Examine how all rinsing operations are conducted at the facility, and determine
whether the facility is taking any measures to minimize rinse-water flow
• 1-1: Interior Equipment Rinsing—Note the use of spray nozzles or other
flow reduction equipment (high-pressure/low-volume washers, spray balls,
or steam cleaners) that are used to rmse PFPR equipment interiors Iden-
tify and note cases in which the facility would not be able to reuse rinsate,
and if the facility has a wastewater treatment system that can treat small-
volume interior rmsate discharges
P2 Alternative Compliance
A modification to this practice is allowed if the facility is rinsing narrow transfer
lines or piping where cleaning is better achieved by a water flush.
• 1-2: Floor Cleaning—Identify the facility's floor-washing procedures (e g.,
if a floor scrubber is used) and identify and record the chemicals used to
clean floors (e.g., water, detergent) m the "Comments" column
• 1-3: Dry Process Cleaning Equipment—Identify how dry production ar-
eas are cleaned. In particular, note the type of dry process cleaning equip-
ment used, whether the production areas are swept or vacuumed prior to
rinsing with water, or if the dry production areas are cleaned with water
at all
34
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
2. Good Housekeeping Practices
Identify and record all preventive maintenance, leak control, spill cleanup
and other good housekeeping practices used at the facility
• 2-1: Preventive Maintenance—Identify if the facility has written proce-
dures regarding the maintenance schedule for each major valve and fit-
ting, and whether they have documented the performance of the
maintenance checks.
• 2-2: Valves/Fittings—Identify if valves and leaky fittings have some form
of containment (e.g., drip pans) to enable the reuse or disposal of collected
product or wastewater.
• 2-3: Spill Clean-up—Identify if the facility has prepared training and writ-
ten standard operating procedures for cleanup of leaks and spills, and if
the facility has records demonstrating quick cleanup of actual leaks and
spills in outdoor bulk storage or process areas.
Table B
P2 Alternative Compliance
All records documenting training programs and preventive maintenance
schedules should be attached to the completed P2 audit form.
3. Department of Transportation (DOT) Test Bath
If the facility produces aerosols that require the operation of DOT test baths,
identify how the bath is operated. Note m the "Comments" column if the
DOT test bath is operated as batch discharge If the DOT test bath is operated
in a continuous overflow mode, identify and note if the facility recirculates
water back to the bath.
4. Air Pollution Controls
Identify if wet air scrubbers are operated with recirculation. Note the percent
blowdown of the system in the "Comments" column.
5. Reuse of Drum Rinsate of Water-Based Products
Identify how empty drums or shipping containers are cleaned and handled
at the facility Note the ultimate disposal of the drums in the "Comments"
column.
• 5-1: Direct Reuse of Drum Rinsate—Note if the facility has implemented
direct reuse of drum rinsate into product formulations from the triple-rins-
mg of drums
• 5-2: Storage and Reuse of Drum Rinsate—Note if the facility collected drum
and/or shipping container rinsate for reuse in subsequent formulations.
35
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
P2 Alternative Compliance
A modification to practices 5-1 and 5-2 is allowed if the facility is using a staged
drum rinsing station that minimizes wastewater volume required for drum
cleaning (typically 100 gallons for every 70 drums).
A modification is also allowed in a case where the drum/shipping container
holds an inert ingredient(s) only, and 1) the facility can demonstrate that, even
after using water conservation practices, there is more volume of water
generated from rinsing the drums than can be reused in the formulation, or 2)
the facility can demonstrate that the concentration of the inert ingredient in the
formulation is so small (e.g., perfume) that the amount of inert ingredient in the
rinsate is more than can be reused in the formulation without exceeding the
ranges allowed in the Confidential Statement of Formula (CSF) (40 CFR 68.155).
Note whether the facility reused as much rinsate as possible and whether the
documentation on the formulation ingredients substantiates this modification.
Table B
i
• 5-3: Staged Drum Rinsing Station—If the facility is using a staged drum
rinsing station, briefly describe the system, including the amount of water
contained in each cell and the frequency with which the water is changed.
The facility may use more than one drum rinsate P2 practice; discuss these
practices in the "Comments" column
6. Drum Rinsing for Formulation of Solvent-Based Products
This practice is similar to the practices detailed in Section 5 above, but it ap-
plies to the rinsing of drums or shipping containers containing solvents or
solvent-based materials. Note the ultimate disposal of the drums or shipping
containers m the "Comments" column.
• 6-1: Direct Reuse of Drum Solvent Rinsate—Note if the facility has
implemented direct reuse of drum rinsate into solvent-based product
formulations.
P2 Alternative Compliance
A modification to these practices is allowed if the facility sends the drums and/or
shipping containers to a refurbisher or recyder that only accepts drums triple-
rinsed with water Note whether the facility has documentation from the drum
recyder to substantiate this modification.
A modification is also allowed in a case where the drum/shipping container
holds an inert ingredient(s) only, and I) the facility can demonstrate that, even
after using water conservation practices, there is more volume of base solvent
generated from rinsing the drums than can be reused in the formulation, or 2)
the facility can demonstrate that the concentration of the inert ingredient in the
formulation is so small (e g , perfume) that the amount of inert ingredient in the
rinsate is more than can be reused in the formulation without exceeding the
ranges allowed in the Confidential Statement of Formula (CSF) (40 CFR 158.155)
Note whether the facility reused as much rinsate as possible and whether the
documentation on the formulation ingredients substantiates this modification
36
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
• 6-2: Cleaning Material—Note the material used to clean the drums and if
the material is the base solvent in one of the facility's formulations
• 6-3: Storage and Reuse of Drum Solvent Rinsate—Note if the facility
collected drum solvent rinsate for reuse in subsequent formulations.
It is possible that the facility uses several different drum rinsate practices
Note each of these practices in the "Comments" column.
7. Dedicated Equipment for Solvent- and Water-Based Products
Determine if water-based and solvent-based products are formulated and
packaged using process equipment dedicated by water-based and solvent-
based production.
Table B
i
P2 Alternative Compliance
A modification to this practice is allowed if the product is only sporadically
produced, such that the expense of dedicated equipment outweighs the P2
benefit. The facility should be able to demonstrate sporadic production through
the use of production records. Note in the "Comments" column whether the
documentation supports any claims of sporadic production. Another
modification to this practice is allowed if the facility has installed and is
operating a solvent recovery system
8. Interior Rinsate Storage and Reuse
Identify if the facility uses interior rinsate storage and reuse, specifically not-
ing if the rinsate is reused immediately in the next batch or is reused after
bemg stored while other products are formulated and packaged.
P2 Alternative Compliance
Several modifications to the practice of storing and reusing interior rinsate are
listed by code in Footnote 2 on Table B. List all reasons why the facility would
not be able to reuse interior rinsate, and obtain documentation supporting these
claims. Examples of this documentation include data demonstrating biological
growth in stored rinsate, site plans illustrating space limitations precluding
storage containers, manufacturer or original formulator directions requiring a
specific form of disposal, or facility plans to drop the registration or production
of a particular formulation. Document other reasons in the "Comments"
column.
9. Dedicated Process Equipment (non-Table 8 practice)
If the facility is unable to reuse all intenor rinsate (as identified by the user in
Section 8 of the "Practices" column), mdicate if the facility has used dedica-
tion of process equipment and production scheduling practices
• 9-1: Equipment Dedication—Identify if the facility has dedicated some
equipment (e.g., mix tank or agitator) to (1) the top production formula-
tion, (2) products that are hard to clean up after production, or (3) product
families. Identify and record in the "Comments" column what pieces of
process equipment are dedicated
37
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
• 9-2: Production Sequencing—Review production records to identify
whether production sequencing is implemented and whether it reduces or
eliminates the generation of equipment cleaning nnsates
10. Inventory Management (non-Table 8 practice)
Inventory management systems for raw materials, finished products, and
waste products typically include centralized sheltered storage, access con-
trols (e g., locked storage areas), and, in some cases, computerized inventory
control. These systems increase wastewater reuse opportunities. Most, if not
all, PFPR facilities have some degree of inventory management, although the
increased use of "just-in-time" production may have decreased the need for
inventory management at some facilities. However, an inventory manage-
ment system is a key to using the P2 practice of interior rinsate storage and
reuse.
• 10-1: Inventory Management System—Identify if an inventory manage-
ment system is in place at the facility
• 10-2: System Control—Identify which of the system controls listed in Sec-
tion 10 of the "Practices" column are in place at the facility, and how these
controls have benefited P2 at the facility. Also identify potential applica-
tions of inventory management to facilitate additional wastewater reuse.
11. Training and Written Standard Operating Procedures (non-
Table 8 practice)
Employee training and written standard operating procedures and incentive
programs have been shown to be useful tools in identifying and implement-
ing P2 opportunities.
• 11-1: Training—Identify if the facility has a formal P2 training program.
The facility should be able to provide training materials and records of
attendance to document that the program is operational.
• 11-2: Incentive Program—Identify if the facility has employee incentive
programs in place that encourage P2
• 11-3: Implementation of P2—Note if the facility has documentation of the
implementation of the P2 practices summarized on Table B.
12. Other P2 Practices/Equipment
List and describe innovative or otherwise unique P2 techniques m the "Com-
ments" column when these practices are not claimed as confidential When
the user is a permitting official or a facility with multiple locations, provide
enough detail to determine if these practices could be used by other PFPR
facilities.
Table B
38
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CHAPTER 4 Conducting the P2 Audit
Pollution Prevention Guidance Manual for the PFPR Industry
Table C: Summary of PFPR Compliance Decisions
After completing Tables A and B, the user has the information necessary to make
a preliminary compliance decision for each waste stream identified in Table A
The compliance options include zero discharge, P2 alternative, and P2 alterna-
tive with modification. Wastewater that is completely reused or recycled on or
off site or is contract hauled for off-site disposal is considered zero discharge 1
Waste streams that will be discharged to a POTW or receiving stream must com-
ply with either the P2 alternative or the P2 alternative with modification.
The user should copy all of the sources for all stream types from Table A to
Table C ("Source" column). Based on the information in Table A, the user can
make the preliminary decision on whether the source is zero discharge. If the
source is not zero discharge, then the user should evaluate the information in
Table B to decide whether the P2 alternative can be implemented, with or
without modification. In the column entitled "Preliminary Compliance De-
cision", write "P2 alternative", "P2 alternative with mod", or "Zero dis-
charge."1 If "P2 alternative with mod" is selected, write the applicable
modification code in the "Comments" column. Figure 4-7 presents an ex-
ample of the preliminary compliance decisions for the example sources pre-
sented previously in Table A.
If the preliminary compliance decision is zero discharge for all waste streams
at the facility, and the facility is not interested m implementing the P2 alterna-
tive, the user can skip to Chapter 7 for the discussion on compliance paper-
work If the facility decides to implement the P2 alternative or P2 alternative
with modification for any of its waste streams, the user should continue to
Chapters 5 and 6 to evaluate treatment technologies appropriate for the al-
lowable discharge. The remammg columns will be discussed in Chapters 6
and 7, as facilities will need to assess their need for treatment and the associ-
ated costs prior to making their final compliance decision.
Table C Summary of PFPR Compliance Decisions
Table C
|
1
|
I
lacikt) Locsboa
Date Prepared br
Vr»»«Typ.
Nu«rc*
HnUbAm)
C«^U»k«
Mm
> fmtlU »
Wmli'iilrf
to
TratotT
Ymo 1
ferNarihMd
1 ^hippoi t Cotttajatr/ Dram
Cleaaiag mulrror toheni nnsei
of thr containers atrd to shtp ram
T^tenaL finished products and/or
matte products prior to rruir or
disposal of the container*.
1A
elrtijw metoloeUor and
lAtn dntno
Zfroduehorft
1J>
copper neptuhrnaie end
sohritt drams
P2 ahmvlne
mllh
nediftcawn
ftEFURB Drum refurbuhrt
»iU not aertpt lobrent
nnsed drwns
^NJoliTtnk Risutt elfaniAy'
if iAr>vrrwr of am bull noeOgr
tail contn}\nj ram me,eKals.
Mtrmrdwtr bbodydr finished
product! auof^u^\th PFPR
operator N.
2-3
lb
3 tormsboog Lqaipmrnt
Jotmor Oamii| rotautr
Hewunr clrjnuij dt* 10prcd^-i
rhmieeiT' or ipefial cteanutf of
the ustrnor of orit /brvu/vir;
ryutprwnr tar ludu*i formulation
andJor %iore%t tanks, pipes, and
hart. Cleaning rotrriols mn
include malrr Jrtrrjrn] or
3a
Zajmrf formulation
I0lU « /
/rro discharge
Dedicate rint 11 lo
Fimgieide production
ib
lu/uidformula ion
tnnl $ 2
P2 ahertulnr
¦Tlh mod
BtOGRQV>7H
Drdtcv t Tenl t 2 aid # J tr>
herbtnde production
3c
bquidformulaiion
raid m t
P2 alitrmtrvr
milh mod
BfOGftO*7H
Drdmie Tail ' 2 atd t ' n
krrbmde production
3 J
dn fortnalolito tori
P2 alirrminr
AlTOrOOtL BW« BOWTX SRIW.C/WN DUlftCtNT DROf MIT NARROW P*Ck.*bF UCOSUtY RLH.RO OTlLt*
• MtafefiUanCaJr Strrt ir emd oi uM tiinataJ rtpboara cf t«.kcnfe i
Figure 4-7. Making Preliminary Compliance Decisions
1 Note This convention was chosen to aid in determining when wastewater streams may be discharged
and, therefore, may require treatment Alternatively, wastewater that is completely recycled or reused
could be recorded as "P2 Alternative "
39
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CHAPTER 5
Wastewater Treatment Technologies
Wastewater treatment technologies are used by PFPR facilities to re-
move or destroy pesticide acbve ingredients and other pollutants
in facility wastewater. The treated effluent may be reused in PFPR
operations or may be discharged to a receiving stream or treatment facility
(such as a publicly owned treatment works (POTW)) This chapter describes
five cost-effective technologies that remove or destroy pesticide acbve ingre-
dients and priority pollutants, and references other technologies that also
effectively treat PFPR wastewaters. A list of documents that contam more de-
tailed information on these technologies is included at the end of this chapter
The technologies presented in this chapter have been identified through sam-
pling visits to PFPR and pesticide manufacturing facilities and through EPA-
sponsored treatability tests. The implementation of these, or equivalent,
technologies has allowed PFPR facilities to reuse a greater percentage of waste-
water m their operations without risking the quality of their final products.
Additionally, by implementing these technologies, these facilities are able to
discharge effluents that might otherwise require disposal
Pretreatment Technologies
Emulsion Breaking
Many pesticide products are formulated by mixing pesticide active ingredi-
ents with inert materials (e.g., surfactants, emulsihers, petroleum hydrocar-
bons) to achieve specific application characteristics. When these "inerts" rrux
with water, emulsions may form. These emulsions reduce the performance
efficiency of many treatment unit operations, such as chemical oxidation and
activated carbon adsorption In many situations, emulsion breaking is a nec-
essary pretreatment step to facilitate the removal of pollutants from PFPR
wastewaters Although emulsion breaking is a pre-
treatment step, its importance in the treatment of PFPR
wastewaters can make it a major part of the technol-
ogy train for treating PFPR wastewaters.
Facilities can break these emulsions through several
methods. Temperature control and acid addition are
common in the PFPR industry and are discussed in
more detail below Other methods of emulsion break-
ing, such as chemically assisted clarification, are not
Types of Emulsions
¦ O/W Emulsion - a hydrophobic solvent, such
as oil. dispersed in an aqueous medium
¦ W/O Emulsion - an aqueous medium
dispersed in a hydrophobic solvent, such as
oil
41
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CHAPTER 5 Wastewater Treatment Technologies
Pollution Prevention Guidance Manual for the PFPR Industry
discussed in this manual. Additional information on these methods may be
found in the Final PFPR Technical Development Document (EPA 821-R-96-
019).
Temperature control and acid addition are simple, inexpensive methods of
breaking emulsions in a variety of PFPR wastewaters. Acid (e.g., sulfuric acid)
added to emulsified wastewater dissolves the solid materials that hold the
emulsions together. The demulsified oil floats because of its lower specific
gravity and can be skimmed off the surface, leaving the wastewater ready for
subsequent treatment. The demulsification also causes suspended solids with
a higher specific gravity to settle out of the wastewater. Heating the emulsion
lowers the viscosities of the oil and water and increases their apparent spe-
cific gravity differential. The oil, with a significantly lower apparent specific
gravity, nses to the surface of the wastewater Heating the wastewater also
increases the kinetic energy of the individual molecules in the wastewater,
causmg the molecules to collide with each other more frequently. The mcreased
number of molecule collisions aids in breaking the film present between the
oil and the water. Once freed from the water, the oil rises, where it can be
skimmed from the surface of the wastewater. Emulsion breaking on PFPR
wastewater has been effective in EPA-sponsored treatability tests when con-
ducted at pH 2 and 60°C.
Other Pretreatment Technologies
In addition to emulsion breaking, a variety of other technologies effectively
pretreat PFPR wastewater, including membrane filtration (ultrafiltration),
chemically assisted clarification, and settling Although these technologies
are not discussed here, additional information on the treatment tests con-
ducted by EPA using these technologies can be found in the Final PFPR Tech-
nical Development Document (EPA 821-R-96-019) and in the administrative
record supporting the final PFPR rulemaking
Treatment Technologies
Activated Carbon Adsorption
Activated carbon effectively removes organic constituents from wastewater
through the process of adsorption The term "activated carbon" refers to car-
bon materials, such as coal or wood, that are processed through dehydration,
carbonization, and oxidation to yield a material that is highly adsorbent due
to a large surface area and high number of internal pores per unit mass. As
wastewater flows through a bed of carbon matenals, molecules that are dis-
solved in the water may become trapped in these pores
In general, organic constituents (including many pesticide active ingredients)
with certain chemical structures (such as aromatic functional groups), high
molecular weights, and low water solubilities are amenable to activated car-
bon adsorption These constituents adhere to the stationary carbon material,
so the wastewater leaving the carbon bed has a lower concentration of pesti-
cide than the wastewater entering the carbon bed Eventually, as the pore
spaces in the carbon become filled, the carbon becomes exhausted and ceases
a
i
i
42
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CHAPTER S Wastewater Treatment Technologies
Pollution Prevention Guidance Manual for the PFPR Industry
to adsorb contaminants. Spent carbon may be regenerated or disposed of; the
choice is generally determined by cost and/or other regulatory factors (e.g.,
RCRA).
Carbon adsorption depends on process conditions such as temperature and
pH and process design factors such as carbon/wastewater contact time and
the number of the carbon columns. If performed under the right conditions,
activated carbon adsorption can be an effective treatment technology for PFPR
industry wastewaters Carbon adsorption capacity depends on the charac-
teristics of the adsorbed compounds, the types of compounds competing for
adsorption, and characteristics of the carbon itself. If several constituents that
are amenable to activated carbon adsorption are present in the wastewater,
they may compete with each other for carbon adsorption capacity. This com-
petition may result in low adsorption or even desorption of some constitu-
ents.
Activated carbon comes in two sizes: powdered carbon has a diameter of less
than 200 mesh, while granular carbon has a diameter greater than 0.1 milli-
meter. Granular carbon is more commonly used in wastewater treatment;
powdered carbon is used less frequently because the small particle size cre-
ates regeneration and design problems. Activated carbon is obtained from
vendors in bulk or in a variety of container sizes At smaller facilities, the
container in which the carbon is sold is intended to be used as the carbon bed,
with influent wastewater passing into one end of the container and treated
effluent water passing out of the opposite end. At larger facilities, carbon is
purchased and added to a column that is installed at the facility.
Carbon is regenerated by removing the adsorbed organic compounds through
steam, thermal, or physical/chemical methods Thermal and steam regen-
eration are the most common methods to regenerate carbon used for waste-
water treatment. These method^ volatilize the organic compounds that have
adsorbed onto the carbon Afterburners are required to ensure destruction of
the organic vapors, a scrubber may also be necessary to remove particulates
from the air stream Physical/chemical regeneration uses a solvent, which
can be a water solution, to remove the organic compounds Carbon is usually
shipped back to the vendor for regeneration, although some facilities with
larger carbon beds may find it economical to regenerate carbon on site
Chemical Oxidation
Chemical oxidation modifies the structure of pollutants in wastewater to simi-
lar, but less harmful, compounds through the addition of an oxidizing agent
During chemical oxidation, one or more electrons transfer from the oxidant
to the targeted pollutant, causing its destruction.
One common method of chemical oxidation, referred to as alkaline
chlonnation, uses chlorine (usually in the form of sodium hypochlorite) under
alkaline conditions to destroy pollutants such as cyanide and some pesticide
active ingredients. However, facilities treating wastewater using alkaline
chlonnation should be aware that the chemical oxidation reaction may
generate toxic chlorinated organic compounds, including chloroform,
bromodichloromethane, and dibromochloromethane, as byproducts
cr
43
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CHAPTER 5 Wastewater Treatment Technologies
Pollution Prevention Guidance Manual for the PFPR Industry
Adjustments to the design and operating parameters may alleviate this
problem, or an additional treatment step (e.g., steam stripping, air stripping,
or activated carbon adsorption) may be required to remove these byproducts.
Chemical oxidation can also be performed with other oxidants (e g, hydro-
gen peroxide, ozone, and potassium permanganate) or with the use of ultra-
violet light. Although these other methods of chemical oxidation can effectively
treat PFPR wastewaters, they typically entail higher capital and/or operat-
ing and maintenance costs, greater operator expertise, and/or more exten-
sive wastewater pretreatment than alkaline chlorination. Additional
information about these other methods can be found in the Final PFPR Tech-
nical Development Document (EPA 821-R-96-019).
Chemical Precipitation
Chemical precipitation is a treatment technology in which chemicals (e.g,
sulfides, hydroxides, and carbonates) react with organic and inorganic pol-
lutants present in wastewater to form insoluble precipitates. This separation
treatment technology is generally carried out in the following four phases:
1. Addition of the chemical to the wastewater;
2. Rapid (flash) mixing to distribute the chemical homogeneously through-
out the wastewater;
3. Slow mixing to encourage flocculation (formation of the insoluble solid
precipitate);
4. Filtration, settling, or decanting to remove the flocculated solid particles.
These four steps can be performed at ambient conditions and are well suited
to automatic control
Hydrogen sulfide or soluble sulfide salts (e.g., sodium sulfate) are chemicals
commonly used in the PFPR industry during chemical precipitation. These
sulfides are particularly effective in removing complexed metals and heavy
metals (e.g., mercury, lead, and silver) from industrial wastewaters. Hydrox-
ide and carbonate precipitation can also be used to remove metals from PFPR
wastewaters, but these technologies tend to be effective on a narrower range
of contaminants.
Hydrolysis
Hydrolysis is a chemical reaction in which organic constituents react with
water and break into smaller (and less toxic) compounds. Basically, hydroly-
sis is a destructive technology in which the original molecule forms two or
more new molecules In some cases, the reaction continues and other prod-
ucts are formed. Because some pesticide active ingredients react through this
mechanism, hydrolysis can be an effective treatment technology for PFPR
wastewater
The primary design parameter considered for hydrolysis is the half-life, which
is the time required to react 50% of the original compound The half-life of a
reaction generally depends on the reaction pH and temperature and
the reactant molecule (e g., the pesticide active ingredient). Hydrolysis reac-
OH"
- ¦ »
44
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CHAPTER 5 Wastewater Treatment Technologies
Pollution Prevention Outdance Manual for the PFPR Industry
tions can be catalyzed at low pH, high pH, or both, depending on the reac-
tant molecule. In general, increasing the temperature increases the rate of
hydrolysis.
Identifying the best conditions for the hydrolysis reaction results in a shorter
half-life, thereby reducing both the size of the reaction vessel required and
the treatment time required A more thorough discussion of hydrolysis of
pesticide active ingredients can be found in the Final Pesticides Formulators,
Packagers, and Repackagers Treatability Database Report (DCN F7185) or the
Final Pesticide Manufacturing Technical Development Document (DCN F6442).
Other Treatment Technologies
In addition to the technologies listed above, a variety of other technologies
effectively treat PFPR wastewater, including reverse osmosis and ultraviolet
light assisted ozonation. Although these technologies are not discussed here,
additional information on the treatment tests conducted by EPA can be found
in the Final PFPR Technical Development Document (EPA 821-R-96-019) and
in the administrative record supporting the final PFPR rulemaking.
45
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CHAPTER 5 Wastewater Treatment Technologies
Pollution Prevention Guidance Manual for the PFPR Industry
Additional Treatability Documents (available through EPA's Office of Water)
General References
Development Document for Best Available Technology. Pretreatment Technology,
and New Source Performance Technology for the Pesticide Formulating,
Packaging, and Repackaging Industry—Final, EPA 821 -R-96-019, September
1996
Development Document for Effluent Limitations Guidelines, Pretreatment
Standards, and New Source Performance Standards for the Pesticide
Chemicals Manufacturing Point Source Category, EPA 821 -R-93-016,
September 1993 (DCN F6442)
Final Pesticides Formulators, Packagers, and Repackagers Treatability Database
Report, March 1994 (DCN F7185)
Pesticide Formulators, Packagers, and Repackagers Treatability Database Report
Addendum, September 1995 (DCN F7700)
Pilot-Scale Tests of the Universal Treatment System for the Pesticides
Formulating, Packaging, and Repackaging Industry, September 1996 (DCN
F7938)
Evaluation of the Universal Treatment System of Pesticide Formulator/Packager
Wastewater, September 1993 (DCN F6446)
Membrane Technologies
Membrane Filtration Treatability Study, July 1991 (DCN F5541)
Membrane Separation Study for the Pesticide Formulator Packager Project, 1994
(DCN F6445)
Final Pilot-Scale Membrane Separation Study, August 1996 (DCN F7939)
Hydrolysis
Hydrolysis
Treatability ofPAIs by Hydrolysis - Bench-Scale Tests, November 1990 (DCN
F5544)
Hydrolysis Treatability Field Study, September 1990 (DCN F5546)
Pyrethrin Wastewater Treatability Report. June 1993 (DCN F6167)
Activated Carbon
Activated Carbon Isotherms for Pesticides, October 1989 (DCN F5885)
Activated Column Testing - Pesticide Manufacturing Wastewaters - Phase 2,
September 1991 (DCN F5884)
Carbon Adsorption Isotherms for Toxic Organics, April 1980 (DCN F5786)
Emulsion Breaking
Emulsion Breaking Performance Study - Final Report. August 1996 (DCN F7937)
Note These documents can be found in the administrative record supporting the
final PFPR rulemaking, which can be accessed through EPA's Office of Water The
EPA Water Docket is open from 9am to 3-30 p m and can be reached at
(202)260-3027 The document control number (DCN) is included in parentheses at
the end of the reference Reasonable fees may be charged for copying
See Chapter 9 for a list of contacts
46
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CHAPTER 6
Conducting the Treatability Test
The final PFPR rule allows facilities the choice of achieving zero discharge or
complying with the P2 alternative Zero discharge can be achieved through
reuse, off-site disposal of wastewater, or discharge of treated wastewater with
pesticide active ingredients at levels below detection.1 The P2 alternative al-
lows PFPR facilities to discharge their wastewater after implementing listed
P2 practices and, in some cases, wastewater treatment. Facilities that treat
wastewater to comply with the P2 alternative or to reuse their wastewater
must use a technology that provides effective wastewater treatment.
Chapter 4 describes how facilities can use the P2 audit to
identify wastewater sources and applicable P2 practices,
and make an initial compliance decision for each waste-
water source. Chapter 5 describes the most cost-effective
wastewater treatment technologies that are demonstrated
to reduce the pesticide active ingredients present in PFPR
wastewater. Chapter 6 describes the three components
of a treatability test and provides guidance to facilities
on selecting and testing appropriate wastewater treat-
ment technologies to determine if they are effective for
the facility's specific wastewater streams.
The first component of a treatability test is identifying the wastewater streams
that remain after implementation of the P2 practices and require treatment
prior to discharge. As discussed in Chapter 4, the facility can use the results
of the P2 audit as documented on Table C to identify the sources that will be
zero discharge or will comply with the P2 alternative. As part of this first
component, the facility also needs to identify the wastewater technologies
appropriate to treat the constituents present in the waste streams requiring
treatment (including characteristics that may hinder treatment of the waste
streams), and then construct potential treatment trains Table D, which will
be described later in this chapter, can be used by facilities to identify the sources
that require treatment under the P2 alternative, the constituents in those
wastewater sources, and appropriate treatment technology(ies)
Based on this information, the facility can decide whether a treatability test is
necessary A treatability test may be used by a facility to determine whether a
particular technology can treat the wastewater, identify analytical or design
'If a facility chooses to meet zero discharge through discharge of wastewater with pesticide active
ingredients below detection, all pesticide active ingredients that are formulated, packaged, or repack-
aged at the facility must ha\e analytical methods for use in wastewater
Treatability Test Components
¦ Identification of Wastewater Sources and
Technologies;
¦ Preparing the Test Plan, and
¦ Evaluation of Test Results.
47
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
and operating parameters to act as surrogates for pesticide active ingredient
analyses, comply with permitting requirements, or optimize treatment per-
formance.
If a test is warranted, the second component is preparing the test plan. The
facility should begin by determining the size and scope of the test and the
sequence of treatment steps. The test plan also specifies the written proce-
dures of how to conduct the test, discusses the design and operating param-
eters to be evaluated for the specific treatment technologies, determines the
equipment and chemicals necessary to conduct the test, and presents a de-
scription of the samples to be collected and analyzed (including a discussion
of the quality assurance/quality control procedures).
The final component is evaluating the test results, which consists of calculat-
ing performance measures, comparing technology results, and evaluating the
cost-effectiveness of the individual treatment technologies.
The guidance presented in this chapter for conducting a wastewater
treatability test is based on EPA's procedures used during the development of
the PFPR effluent limitations guidelines and standards The treatability test
tables discussed in this chapter (Tables D and E) are offered as one way to
conduct the test and/or document the test results. It is not required that fa-
cilities, permitters, or other auditors use Tables D and E; however, these tables
summarize the types of information that are useful in conducting a treatability
test Since it is very difficult to construct one table or checklist with a format
useful for all PFPR facilities, EPA considers the tables presented in this manual
as a tool to be adapted in whatever way the user feels is appropriate. Ex-
ample pages of the treatability test tables are shown throughout this chapter
to illustrate the types of information captured on the tables. The blank tables
are presented in their entirety in Appendix B.
Treatability Test Tables
Table
Title
Purpose
Table D
Identification of Wastewater Sources
Provides a list of wastewater sources requiring
and Technologies
treatment, the potential constituents, and the
appropriate treatment technologies.
Table E
Summary and Evaluation of Test Results
Provides a summary and evaluation of the test
results for each technology and the final
treatment train
Table D: Identification of Wastewater Sources and
Treatment Technologies
Before a treatability test is undertaken, the facility should identify the waste-
water sources that require treatment. These sources may include wastewater
to be reused in PFPR operations or wastewater to be discharged under the P2
alternative Table D is the starting point for identifying these sources and the
potential treatment technologies to effectively treat them Completing this
table will enable facility personnel to begin identifying the wastewater sources
Table D
I 1 I
1 1 1
1 1 1
i i I -
48
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Table D
i
to include and potential treatment technologies to evaluate in a treatability
test. Five steps that can be used to complete Table D and decide whether to
conduct a treatability test are detailed below.
Step 1: Identify Wastewater Sources
The user should transfer from Table C to Table D all wastewater sources that
will potentially require treatment, poor to either reuse or discharge. In addi-
tion, the user should transfer from Table A to Table D a list of the pesticide
active ingredients or other constituents present in those wastewater sources.
Table D. Identification of Wastewater Sources and Treatment Technologies
Facility
Location
Date
Prepared by
Potential Pollutants
Wastewater Treatment Information
Stream Type
Source
Active
Ingredients
Other
Pollutants
Table 10
Technology1
Alternate
Treatment
Technology1
Source for
Alternative Technology
Characteristics Thai
Hinder Treatment
1 Shipping Container/Dram
Cleaning - *ater or solvent rinses
of the containers used to ship ran
materia! finished products and/or
1 a
naste products prior to reuse or
disposal of the containers
) b
2. Bulk Tank Rinsaie • cleaning
of the interior of an\ bulk storage
tank containing ran materials
intermediate blends or finished
2a
products associated Htth PFPR
operations
2b
3 Formulating Equipment
Interior Cleaning • routine
cleaning cleaning due to product
3a
liquid formulation
tank 8 2
Metolachlor
Pendimfiiwltn
Psrethnn //
BOD.
TOC TSS
AC
AC
HD
HD
Treatability testing Literature
changeover or special cleaning of
the interior of urn formulating
equipment including formulation
3b
liquid formulation
tank #3
Metolachlor
Pendimetlmhn
Psrethnn II
BOD,
TOC TSS
AC
AC
HD
HD
Treuiahihr\ testing Literature
and/or storage tanks pipes and
how Cleaning materials ma\
include *ater detergent or
3 C
dr\ formulation lank
Unalool
Pendtmetfutltn
BOD,
TOC TSS
AC
AC
HD
Treatability tetiwg Literature
High st)ltdti.ontrnl
when'
3d
I HD = h>drolvsis. AC = activated carbon PT = precipitation CO = chemical cwdauon P2 = pollution prevention OT = other.
Figure 6-1. Identifying Wastewater Sources
Wastewater Sources Requiring Treatment Prior to a PI Allowable Discharge
Direct Discharge
¦ All process wastewater
Indirect Discharge'
¦ Interior equipment rinsate. including drum, bulk tank, and shipping container
rinsate;
¦ Leak and spill cleanup water; and
¦ Floor wash water.
'in individual cases, the requirement of wastevvater pretreatment prior to Indirect discharge may
be removed for floor vvrash or the final rinse of non-reusable triple rinse by the control authority
when pollutant levels are too low to be effectively pretreated and those pollutants do not pass
through or Interfere with POTW operations.
49
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
Figure 6-1 presents an example of the types of information transferred while
completing this step The unshaded columns "Stream Type", "Source", and
"Potential Pollutants" to illustrate this example
Step 2: Identify Wastewater Treatment Technologies
The user should identify treatment technologies that could effectively treat
each potential pollutant listed in Step 1 Pollution control technologies for
many pesticide active ingredients are presented in Table 10 to Part 455 of the
final rule (located in Appendix A). These control technologies include acti-
vated carbon adsorption, chemical oxidation, chemical precipitation, hydroly-
sis, and pollution prevention. EPA selected these technologies based on their
applicability to a broad spectrum of pesticides and their relative cost and
availability The user should list the technology for each pesticide active in-
gredient present in their wastewater m the "Table 10 Technology" column
Alternate technologies, such as membrane filtration, may also effec-
tively treat pesticide active ingredients present m the facility's waste-
water. In specific cases, these other technologies may be more
cost-effective than the technologies listed in Table 10 of the rule. Facili-
ties may choose to evaluate these other technologies in a treatability test
to determine whether they are equivalent in performance to the Table
10 technologies (Chapter 7 of this manual discusses equivalent tech-
nologies in more detail). Facilities may also need to identify treatment
technologies for pollutants other than pesticide active ingredients. For
example, wastewaters that contain emulsions may require an emulsion
breaking pretreatment step before using another technology (e g., acti-
vated carbon adsorption or hydrolysis) to remove pesticide active ingredi-
ents Other wastewaters may require activated carbon adsorption to remove
organic priority pollutants in addition to pesticide active ingredients
If information is not available for a particular pollutant, it may be necessary
for the facility to identify a treatment technology based on their knowledge of
the pollutant. For example, a technology that is effective on one pesticide
active ingredient is often effective on other pesticide active ingredients with
similar chemical properties and structures However, treatment effectiveness
should be verified through a treatability test Table 6-1 provides sources of
information on identifying treatment technologies using similarities in chemi-
cal properties and structures.
Treatment technologies can be identified from a variety of sources, including
technical literature, treatability databases, and treatment vendors. A review
of technical literature may reveal information that is not contained in the
sources listed in Table 6-1. Treatability testing conducted on similar wastewa-
ters in the PFPR industry or in other industries may provide clues on how to
treat a particular wastewater. And treatment technology vendors should have
information on the capabilities of their treatment systems. A facility should
use all available information as well as knowledge of the various technologies
and wastewater to be treated to identify appropriate treatment technologies.
Alternate technologies to treat pesticide active ingredients or other pollutants
can be listed in the "Alternate Wastewater Technology" column The source
for identification of those alternative technologies (e.g., literature, treatability
tests, or other sources) can be specified in the "Source for Alternative Tech-
Table D
1
1
i
Appropriate Technologies
¦
Table 10 listed technology
[§455.10(g)]
¦
Equivalent system
[§455.10(h)J
¦
Pesticide manufacturer
treatment system
50
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Outdance Manual for the PFPR Industry
Table D
Table D. Identification of Wastewater Sources and Treatment Technologies
Facility
Location
Date
Prepared by
Potential Pollutants
Wastewater Treatment Information
Stream Type
Source
Actlvr
Ingredients
Other
Pollutants
Table 10
Technology1
Alternate
Treatment
Technology1
Source for
Alternative Technology
Characteristics That
Hinder Treatment
1 Shipping Container/ Drum
Cleaning - water or sohent rinses
of the contumers used to ship raw
muiertal finished products and/or
1 u
waste products pnor to reuse or
disposal of the containers
I h.
2. Bulk Tank Rinsate • cleaning
of the interior of an v bulk storage
tank containing raw materials
intermediate blends, or finished
2a
products associated hith PFPR
operations
2b
3 Formula ting Equipment
Interior Cleaning • raunne
cleanmg cleaning due to product
3a
liquid formulation
tank* 2
Metolaehlor
Peniimeihtitm
P>rethnn U
B0D<
TOC TSS
AC
AC
HD
HD
Treatability testing Literatun
chanxeoier or special cleaning of
the interior of ant formulating
equipment including formulation
3b
liiptid formulation
tank 0 1
Metolaehlor
Pendimethulm
P\rethnn 11
80Di
TOC, TSS
AC
AC
HD
HD
Treaiabthr\ testing Literatun
and/or ttorage tank* pipes and
ho ws Cleaning material r ma)
incluilr wufcr detergent or
3 i
tfn formulation tank
Ltnalool
Pendmrtfiahn
BOD,
TOC TSS
AC
AC
HD
Treatabiltn resting Literature
High Kohdi content
wl\ ent
3d
1 HD = hydrolysis, AC = ocuvaicd carbon PT = precipitation CO = chemical oxidauon P2 = pollution prc\cnuon OT = other
Figure 6-2. Identifying Wastewater Treatment Technologies
Table 6-1
Sources of Treatment Technology Information
EPA Treatability Database1
The U.S. EPA National Risk Management Research Engineering Laboratory in
Cincinnati. Ohio maintains a Pesticide Treatability Database that contains
information on over 1,600 pesticides that are currently in use in the United States
or have been removed from the market in the past 20 years. For each compound,
the database contains the following information (where available).
¦ physical and chemical property data
¦ treatability data
¦ Fruendlich isotherm (carbon adsorption) data
EPA/EAD Treatability Database Report and Addendum2
During the development of the PFPR rule, EPA conducted extensive research into
the treatment of PAIs, including gathering information from technical literature,
analyzing data on treatability tests conducted by PFPR and pesticide manufacturing
facilities, sampling existing treatment trains at PFPR and pesticide manufacturing
facilities, and conducting bench- and pilot-scale treatability tests These documents
summarize the treatability data collected and describe how treatability data can be
transferred to other pesticide active ingredients
'US EPA. Risk Reduction Engineering Laboratory. 26 West Martin Luther King Drive. Cincinnati,
OH. 45268
2Final Pesticides Formulators. Packagers, and Repackages Treatability Database Report (DCN
F7I85) and the Pesticide Formulators, Packagers, and Repackages Treatability Database Report
Addendum (DCN F7700)
51
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Outdance Manual for the PFPR Industry
nology" column Figure 6-2 presents an example of the types of information
collected when completing Step 2. The unshaded columns under "Waste-
water Treatment Information" illustrate this example.
Step 3: Identify Characteristics That Hinder Treatment
Throughout the pesticide industry, many products may be formulated, pack-
aged, or repackaged using different types of equipment This variety m prod-
ucts and equipment results in variable wastewater characteristics, which m
turn affects the treatability of those wastewaters. For example, a wastewater
with a high amount of organic compounds may be difficult to treat with
chemical oxidation, as the organic compounds may compete with the pesti-
cide active ingredients for the available oxidizing agent.
The application of treatment technologies to variable PFPR wastewater must
be tailored to the specific characteristics of the wastewater. Table 6-2 presents
some wastewater characteristics that may interfere with emulsion breaking,
activated carbon adsorption, hydrolysis, chemical oxidation, and chemical
precipitation technologies; however, these characteristics do not necessarily
preclude use of the technology. The degree to which a wastewater exhibits a
characteristic will affect the degree to which the technology is adversely af-
fected. In many cases, a wastewater displaying an adverse characteristic can
still be effectively treated through modifications of the treatment technology
or the addition of a pretreatment step. For example, a wastewater may be
difficult to treat using activated carbon adsorption if it has a high suspended
solids content, because the suspended solids may plug the carbon column
However, it may be possible to remove the suspended solids through settling
or filtration before activated carbon treatment.
Table 6-2
Wastewater Characteristics That Adversely Impact Treatment Effectiveness
Technology
Wastewater
Activated Carbon
Chemical
Chemical
Characteristic Emulsion Breaking
Adsorption Hydrolysis
Oxidation
Precipitation
Organics
~
~
Suspended Solids
~
~
Buffered Solution ~
~
~
Temperature
~
~
pH
~
~
Detergents/ Surfactants ~
~
~
~
Oil and Grease
~
~
The most common pretreatment technologies used for PFPR wastewaters are
settling, filtration, emulsion breaking, chemically assisted clarification, neu-
tralization, and ultrafiltration Table 6-3 lists the types of wastewater charac-
teristics that can be effectively treated by these pretreatment methods EPA
conducted treatability tests to evaluate emulsion breaking, chemically assisted
clarification, and ultrafiltration of as part of the development of the PFPR
rule See Chapter 5 for more information on these technologies.
Table D
1
1
52
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Wastewater characteristics that hinder treatment can be listed in the "Char-
acteristics That Hinder Treatment" column of Table D. Figure 6-3 presents
an example of the types of information that may be documented during the
completion of Step 3.
Table D
Table 6-3
Pretreatment Technologies for Adverse Wastewater Characteristics
Technology
Neutralization
Chemical
Wastewater
Emulsion
or pH
Assisted
Characteristic
Settling nitration
Breaking
Ad|ustment
Clarification
Ultrafiltration
Organ ics
~
~
~
Suspended Solids
~ ~
~
~
~
Buffered Solution
~
pH
~
Detergents/ Surfactants
~
~
~
Oil and Crease
~
~
~
Table D. Identification of Wastewater Sources and Treatment Technologies
Facility
Date
Location
Prepared by
Stream Type
Source
Potent)
al Pollutant*
Wastewater Treatment Information
Characteristics That
Hinder Treatment
Active
Ingredients
Other
Pollutants
Table 10
Technology'
Alternate
Treatment
Technology1
Source for
Alternative Technology
1. Shipping Container/ Dram
Cleaning • water or soh ent rtnsts
of the containers usrd to thip raw
materia] finished products and/or
waste produce prxor to reu\e or
disposal of the containers
I a
1 b
2. Bulk Tank Rinsate - cleaning
of the interior of an\ bulk storage
tank containing raw material*,
intermediate blends or finished
products associated with PFPR
operations.
2a
2b
3 Formulating Equipment
Interior Cleaning - routine
cleaning cleaning due to product
changeover or special ileaning of
thf interior of any formulating
equipment, including formulation
and/or storage tanks pipes and
hoses. Cleaning miteruilsma\
include water detergent or
wlvetu
3a
liquid formulation
tank 0 2
Metolachlor
Pendtmeihalm
P\ rethrxn It
BODt
TOC TSS
AC
AC
HD
HD
Trrasubihr, testing Literature
3 b
liquid formulation
tank 03
Metolai hlor
Pendimethalin
P\reihnn 11
BOD\
TOC TSS
AC
AC
HD
HD
Treatability testing Literature
3c
dry formulation tank
Unalool
Pendimeihfiitn
BOD-.
TOC TSS
AC
AC
HD
Treatability truing Literature
High solids content
3d
| I HD = hsdrolysis. AC = activated carbon PT = precipitation CO = chemical oxidation P2 = pollution prevention OT = oihcr_
Figure 6-3. Identifying Characteristics That Hinder Treatment
53
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
Step 4: Construct Potential Treatment Trains
Often the wastewater at a PFPR facility contains more than one pesticide
active ingredient and may also have characteristics that require a pretreat-
ment step. In these situations, several technologies may be necessary to com-
pletely treat the wastewater. These technologies can be used m series m what
is called a treatment train
For example, a facility generates wastewater from floor washing that con-
tains several pesticide active ingredients, including atrazine, metolachlor, and
copper naphthanate. In order to effectively treat this wastewater, the facility
may construct a treatment tram, shown in Figure 6-4, which consists of emul-
sion breaking to remove oil and grease and suspended solids picked up from
the floor during floor washing, chemical precipitation to remove the copper
naphthanate, hydrolysis to treat the atrazine, and activated carbon adsorp-
tion to remove the metolachlor and other priority pollutants contained in the
wastewater
Table D
i
Untreated
PFPR
Wastewater
Emulsion
Breaking
Pretreatment
Chemical
Precipitation
Hydrolysis
Activated
Carbon
Adsorption
Final
Treated
Effluent
Figure 6-4. Example Treatment Train
When conducting a treatability test, facilities may only test the individual
unit operations. However, if a facility mtends to implement the entire treat-
ment train, testing the entire train may reveal important information about
how the wastewater characteristics change with each treatment step. Testing
the wastewater through the entire treatment train can help troubleshoot the
system and determine whether pretreatment steps are adequate to prevent
malfunctioning of other unit operations in the treatment train.
Step 5: Determine Whether to Conduct a
Treatability Test
After identifying wastewater streams that require treat-
ment and the appropriate technologies for the constitu-
ents in those streams, a facility should determine
whether a test is warranted for their circumstances
Several factors should be considered in making this
determination A treatability test can help a facility to
evaluate whether the selected technologies effectively
treat their wastewater and whether additional treat-
ment steps are necessary. If a facility chooses different
technologies than the ones listed in Table 10 of the final
rule for the treatment or removal of pesticide active in-
gredients, a treatability test can be used to demonstrate
that treatment is equivalent (demonstration of equiva-
lent treatment is discussed more fully in Chapter 7).
The test can also be used to determine the optimum treatment conditions, or
may be required by permit writers or control authorities to evaluate treat-
ment effectiveness before they allow PFPR wastewater to be discharged
54
WHY CONDUCT A TREATABILITY TEST?
¦ Find out what technologies work best for
your wastewater and optimize treatment
performance.
¦ Show that an alternative technology is
equivalent to a technology listed in Table 10
to Part 455
¦ Meet the requirements of your NPDES
permit writer or control authority prior to
discharging PFPR wastewater.
¦ Identify surrogate parameters as an
alternative to traditional laboratory analysis.
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
A treatability test may also allow a facility to identify surrogate parameters
(e.g, total organic carbon) that will indicate the treatment effectiveness of their
system without analyzing the wastewater for each individual constituent
Because of the number of pesticide active ingredients handled by some facili-
ties, surrogate parameters can reduce the analytical costs associated with
compliance. In addition, EPA-approved methods do not exist for all pesticide
active ingredients, while other chemicals may be difficult to quantify because
contaminants m the wastewater interfere with the analysis; in these cases,
surrogate parameters allow some measure of treatment effectiveness to be
quantified. To use surrogate parameters for any of these reasons, a facility
may be required to perform a treatability test to establish the relationship
between the surrogate parameter and the constituents it is meant to repre-
sent The use of surrogates is not required by the rule.
Preparing The Test Plan
Once the decision to conduct a treatability test is made, the facility should
prepare a written test plan. A test plan contains a set of predetermined proce-
dures designed to ensure the
test's success The test plan helps
facility personnel organize and
prepare for the test, ensure that
the test is conducted properly,
provide documentation of the
test, and troubleshoot treatment
systems and procedures.
The test plan should be suffi-
ciently detailed and clearly writ-
ten instructions so that treatment
system operators can easily con-
duct the test as specified. The
plan should first of all clearly
state the goals that are to be ac-
complished through performing
the treatability test and the technologies to be evaluated. The plan should
then delineate the size of the test, the target design and operating parameters
for each treatment step, detailed instructions on how to perform each treat-
ment step (including who is to perform the action, when the action should be
performed, and the equipment and materials to be used), and samplmg and
analysis procedures.
After the goals of the test are set, the facility can follow the following five
steps in prepanng a test plan for conducting a treatability test
Step 1: Determine the Size of the Test
Full-scale treatment systems at PFPR facilities vary in size from very small
systems (treating 100 gallons or less per year) to very large systems (treating
millions of gallons per year) When performing a treatability test, it is not
always necessary to treat a large volume of wastewater, and often valuable
information can be acquired from smaller scale tests. Treatability tests are
typically categorized based on size as bench-, pilot-, and full-scale tests.
55
Components of the Treatability Test Plan
¦ Coals of test and the treatment technologies to be evaluated
(including the sequence of treatment steps);
¦ Size of the test;
¦ Target design and operating parameters;
¦ Written instructions for each step of the test, including the date,
time, location, and personnel involved in the test;
¦ Equipment and materials required for the test; and
¦ Sampling plan specifying sample points, times, and procedures,
sample analyses, sample preservation and shipping, and quality
assurance/quality control procedures
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CHAPTER 6 Conducting Treatability Test
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A bench-scale test is useful to screen treatment technologies or determine
initial design and operating parameters, and is typically conducted on one
gallon or less of wastewater. Bench-scale tests use laboratory equipment (e.g.,
beakers, hot plates, and stirring rods), and may be conducted on synthetic
wastewater (i.e., distilled water spiked with a known concentration of con-
taminant). A bench-scale test requires less cost and effort because of the smaller
volume of wastewater tested and the basic equipment used. In addition, a
bench-scale treatability test may involve less sophisticated sampling and analy-
sis, and may use mdicator parameters (e.g., turbidity) or visual appearance of
the wastewater instead of laboratory analysis to gauge test results
A pilot-scale test is conducted on actual wastewater, and is used to optimize
design and operating parameters and to troubleshoot treatment problems
before constructing a full-scale treatment system. Actual wastewater may
contam surfactants, inerts, solvents, or other impurities that may interfere
with treatment. The test is intermediate in size, although for many PFPR fa-
cilities that generate small volumes of water, a pilot-scale system is equivalent
in size to a full-scale system. Pilot-scale tests typically use smaller and simpler
equipment than would be found in a full-scale system, such as buckets or
drums instead of treatment tanks; portable rruxers and pumps instead of
built-in mixers and pumps, and flexible hoses instead of hard piping. These
systems may also use temporary equipment that can be placed in storage or
disposed of after the test instead of permanently installed equipment
A full-scale treatability test is conducted on actual wastewater using the ac-
tual size and type of equipment to be used for routine treatment
Step 2: Determine the Design and Operating Parameters
The effectiveness of a treatment step is related to cer-
tain design and operating parameters that determine
how well the treatment system functions The spe-
cific design and operating parameters differ for each
type of technology. Table 6-4 presents a list of com-
mon parameters used for wastewater treatment tech-
nologies. For the treatment of PFPR wastewater,
design and operating parameters typically include
the amount of chemicals and/or materials used, tem-
perature, pH, and wastewater flow rates.
Usually, a treatment technology will operate within
a range of design and operating parameters. The
point within that range at which the treatment sys-
tem performance and cost are optimized will depend
on site-specific factors such as wastewater charac-
teristics and volume
Prior to the treatment test, target design and operating parameters appropri-
ate for each treatment technology should be identified in the test plan. Be-
cause it is difficult to control some parameters precisely, a range of values
(e g, pH 2 to 12) to be evaluated during the test should also be identified.
During the treatability test, treatment system operators should record the
actual design and operating parameter values to identify at what values the
optimum treatment performance of the system was achieved '
Table 6-4
Common Design and Operating Parameters
¦
Temperature
¦
PH
¦
Pressure
¦
Treatment time
¦
Flow rate
¦
Amount of treatment chemicals/materials
¦
Mixing
¦
Visual appearance of wastewater
56
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CHAPTER 6 Conducting Treatability Test
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Identify relevant design and operating parameters
Treatment technologies for PFPR wastewaters use a variety of mechanisms to
achieve treatment These mechanisms include physical separation of contami-
nants from wastewater, chemical reactions, phase separations, or a combina-
tion. With each technology, a unique set of design and operating parameters
relevant to that technology needs to be monitored to ensure that the treat-
ment technology is functioning properly. In some cases, the relevant design
and operating parameters to be monitored may depend upon the specific
characteristics of the wastewater to be treated as well as the treatment
technology.
Table 6-5 presents the design and operating parameters that are typically
monitored for the five technologies used by EPA in developing industry com-
pliance costs for the PFPR rule. These technologies are described more fully in
Chapter 5. Design and operating parameters are listed for these technologies
because they are the technologies that are most frequently used in on-site
Table 6-5
Treatment Technology Design and Operating Parameters
Activated Carbon Adsorption
Emulsion Breaking Parameters
Parameters
Temperature
¦
¦ Wastewater flow rate
¦
PH
¦ Type and amount of carbon used
¦
Mixing
¦ Saturation loading
¦
Amount and type of chemicals
a Temperature
added
¦ pH
¦
Turbidity
¦ Carbon bed dimensions
Chemical Oxidation Parameters
Hydrolysis Parameters
¦ Temperature
¦
pH
¦ pH
¦
Temperature
¦ Amount and type of chemicals
¦
Mixing
added
¦
Amount and type of chemicals
¦ Free chlorine, peroxide, or other
added
chlorinating agent concentration
¦
Treatment time or wastewater flow
¦ Treatment time or wastewater flow
rate
rate
Precipitation Parameters
¦ Temperature
¦ pH
¦ Amount and type of chemicals added
¦ Mixing
¦ Treatment time or wastewater flow rate
57
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
treatment of PFPR wastewaters arid are the technologies for which EPA has
the greatest amount of information. Note that these are not the only treat-
ment technologies that can be successfully applied to PFPR wastewaters. In
some cases, facilities may wish to monitor other design and operating param-
eters in addition to the ones listed below Technical literature on the selected
technology to be tested and previous wastewater treatability tests can help in
identifying relevant operating parameters.
-»¦ Select design and operating parameter values
After identifying the appropriate design and operating parameters, facilities
should set a range of values to be evaluated during the test. These values can
be estimated from several sources:
¦ Previous treatment tests on the same or similar chemicals or wastewaters;
¦ Technical literature on the treatment technology, and
¦ Technology vendors.
The first time a wastewater is treated through a particular technology, PFPR
facilities may wish to set the target design and operating parameter values at
conservative levels that will over-treat the wastewater Because PFPR waste-
waters tend to be highly variable, and equipment and procedures may also
vary from test to test, a parameter value that proved to be effective in previ-
ous tests on different wastewaters may not be an appropriate value for a
specific facility's wastewater. By setting conservative parameter values dur-
ing an initial test, facilities will not wrongly conclude that a particular treat-
ment technology is ineffective when all that is necessary to achieve effective
treatment is to adjust the design and operating parameter values
For example, if technical literature indicates that a chemical oxidation time of
six hours will effectively treat a chemical, a PFPR facility conducting an ini-
tial treatability test may wish to perform chemical oxidation for 8 or 12 hours.
By sampling the wastewater at one- or two-hour intervals, the facility can
ensure that effective treatment occurs during the test while also identifying
how much treatment time is needed for their particular wastewater.
-* Optimize treatment performance through design and
operating parameters
Once a facility has performed a treatability test and identified an effective
technology, the design and operating parameters used in that test can be used
as a basis for future testing, provided the wastewater characteristics do not
significantly change However, facilities may wish to increase treatment per-
formance, decrease treatment time, and reduce the cost of treatment. By op-
timizing design and operating parameters, facilities can achieve these
objectives
A properly run and well-documented treatability test will give indicators as
to how to optimize treatment system performance By reviewing the design
and operating parameters achieved during treatability testing in conjunction
with treatment system operator observations and laboratory analyses, facili-
ties can determine what changes are likely to result in treatment system
optimization
58
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
By reviewing the design and operating parameter measurements, adjustments
can be made either during the treatability test or in subsequent tests to opti-
mize performance. In some cases, facilities can monitor design and operating
parameters instead of using costly laboratory analyses to verify treatment
effectiveness For example, facilities can monitor the pH, temperature, and
treatment time for a hydrolysis urut instead of having the treated wastewater
analyzed to verify that hydrolyzable chemicals are removed. However, sub-
stituting laboratory analyses with design and operating parameter monitor-
ing to demonstrate compliance will ultimately ned to be approved by the
control authority. Occasional laboratory analyses may be required to confirm
that design and operating parameter monitoring accurately predicts treat-
ment effectiveness.
If one of the goals of a treatability test is to optimize the treatment system, the
facility may choose to monitor design and operating parameters and sample
the system for laboratory analyses more frequently than is necessary to deter-
mine treatment system performance. For example, during an emulsion break-
ing pretst, the facility may collect samples under both acidic and alkaline
conditions or at various temperatures to determine what conditions result in
the greatest degree of separation. Facilities may also optimize treatment sys-
tem performance by changing wastewater management methods. For ex-
ample, by segregating certain wastewaters with characteristics that make
them hard to treat, treatment system performance can be improved. In some
cases, exterior equipment cleaning or floor wash water may contribute large
amounts of suspended solids to a wastewater By segregating the floor wash
and exterior cleaning waters from other wastewaters, the facility may elimi-
nate the need for emulsion breaking or other pretreatment for nonexterior
waters, thereby reducing the cost of pretreatment by reducing the volume of
wastewater requiring pretreatment. Alternatively, the facility may find that it
is less expensive to dispose of some wastewaters rather than treat them. For
example, off-site disposal of floor wash water may cost less for some facilities
than adding an emulsion breaking step to a treatment tram
As discussed in Chapter 7, the final PFPR rule requires that facilities choosing
the P2 alternative must demonstrate, as part of their on-site compliance pa-
perwork, that the treatment technologies they are choosing are well-oper-
ated and maintained. By documenting the optimal design and operating
parameters that reflect the appropriate level of treatment for each treatment
technology, a facility can demonstrate that its treatment system is well-oper-
ated and maintained The section of this chapter on evaluation of test results
and Chapter 7 discuss how Tables D and E can provide the documentation
for demonstrated effectiveness of a facility's treatment system
Step 3: Prepare Detailed Instructions
Clear and detailed written procedures will not only help ensure that treatability
testing is successful, but can also help in troubleshooting treatment systems
that are not performing as well as expected and in optimizing treatment per-
formance See the references listed at the end of Chapter 5 and/or the ex-
ample in Appendix C for descriptions of treatability test procedures used for
EPA-sponsored tests
59
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CHAPTER 6 Conducting Treatability Test
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If a treatability test shows poor results, a review of the test plan, deviations
from the test plan, and observations made during the treatability test may
help identify whether the poor results are due to test procedures or whether
the selected treatment technology is not appropriate for the wastewater be-
ing treated. This review can also help facilities determine whether additional
pretreatment is necessary to allow treatment technologies to function properly.
Step 4: Identify Equipment and Chemicals
Equipment and chemicals are necessary in conducting the treatability test,
collecting and analyzing the samples, and monitoring the design and operat-
ing parameters. When performing a treatability test, the equipment used should
be cleaned to avoid introducing outside contaminants that may skew test
results. Facilities should also use equipment constructed of materials that are
compatible with the wastewater, contaminants, and treatment chemicals to
be used in the test.
The types and sizes of equipment and chemicals needed to perform treatability
tests to evaluate emulsion breaking, hydrolysis, activated carbon adsorption,
chemical oxidation, and chemical precipitation are discussed below. These
technologies, described in Chapter 5, are the most cost-effective technologies
that remove or destroy pesticide active ingredients and priority pollutants in
PFPR wastewater.
Emulsion Breaking
Facilities performing an emulsion breaking test should use a tank sized for
the volume of wastewater to be tested. If the tank has an open top, the facility
should cover the tank to minimize evaporative and heat losses. If the tank
does not have graduated markings, an additional container may be neces-
sary to measure the volume of the wastewater. A pump may also be required
to transfer the wastewater to and from the tank.
Acid lowers the pH of the wastewater and encourages emulsion breaking. A
variety of acids can be used for this purpose, including sulfuric and hydro-
chloric acid. To further encourage emulsion breaking, the facility may heat
the wastewater in the tank. Heating equipment includes hot plates, electric
band heaters, immersion heaters, and steam jackets.
Emulsion breaking also requires stirring to mix treatment chemicals and to
encourage the breaking of the emulsion. Rapid and turbulent mixing may be
used initially to mix the treatment chemicals, but may cause contaminants to
remain emulsified in the wastewater if used throughout the test. It is recom-
mended that the facility use low-speed mixing and low-shear mixers such as
paddle mixers.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple. The facility may also
wish to neutralize the pH of the wastewater after emulsion breaking if other
portions of the treatment train are not compatible with a low pH.
60
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Outdance Manual for the PFPR Industry
Hydrolysis
Facilities performing a hydrolysis test should use a tank sized for the volume
of wastewater to be tested If the tank has an open top, the facility may cover
the tank to minimize evaporative and heat losses If the tank does not have
graduated markings, an additional container may be necessary to measure
the volume of the wastewater. A pump may be required to transfer the waste-
water to and from the tank, and a mixer is typically used during hydrolysis to
homogenize the wastewater.
Hydrolysis reactions typically occur more rapidly in acidic or basic environ-
ments. A variety of bases and acids are acceptable to raise or lower the pH of
the wastewater. To further encourage the hydrolysis reaction, the facility may
heat the wastewater in the tank. Heating equipment includes hot plates, elec-
tric band heaters, immersion heaters, and steam jackets.
The pH of the wastewater can be determined with disposable pH stnps or
with an electronic pH meter. The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple The facility may choose
to neutralize the wastewater after the treatability test; a variety of acids and
bases can be used for this purpose.
-*¦ Activated Carbon Adsorption
Facilities performing an activated carbon adsorption test must use a carbon
bed or column sized for the volume of wastewater to be tested. Flexible tub-
ing or hard piping may be used to convey water to the column and remove
treated wastewater. The facility will need a pump to move the wastewater
through the bed or column. Many carbon treatment systems use several beds
in series. As the first bed becomes saturated, it is removed from the system.
The influent is then directed to the second bed in the series, and an additional
bed is added to the end of the series to replace the saturated bed that was
removed
The facility may use prefilled carbon beds from a vendor or prepare its own
bed or column If the facility is packing a carbon bed or column itself, it will
be necessary to prepare the carbon. A scale should be used to weigh the car-
bon used to pack the column. It may also be necessary to rinse the carbon to
remove fines and to deaerate the carbon
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple.
Chemical Oxidation (Alkaline Chlorination)
Facilities performing a chemical oxidation test via alkaline chlorination should
use a tank sized for the volume of wastewater to be tested. If the tank has an
open top, the facility may cover the tank to minimize evaporative and heat
losses. If the tank does not have graduated markings, an additional container
may be necessary to measure the volume of the wastewater. A pump may be
required to transfer the wastewater to and from the tank An electric rruxer or
a magnetic stirring bar is typically used to mix the wastewater during chemi-
cal oxidation
llir - . i-iL.
fi
ci
61
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR Industry
Chemical oxidation occurs more readily m an alkaline environment. While a
variety of bases are acceptable, sodium hydroxide is most commonly used to
raise the pH of the wastewater A variety of chlorine-containing chemicals
are available to initiate chlorination; sodium hypochlorite is commonly used
during chemical oxidation A facility may choose to neutralize the wastewa-
ter with an acid following treatment, or add sodium thiosulfate or other free
chlorine scavenger following treatment to reduce residual free chlorine in the
wastewater
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple. The level of free chlo-
rine or other oxidant can be determined using readily available test kits. Facilities
should contact laboratory equipment vendors for information on such test
kits.
-~ Chemical Precipitation (Sulfide Precipitation)
Facilities performing a chemical precipitation test should use a tank sized for
the volume of wastewater to be tested. If the tank does not have graduated
markings, an additional container may be necessary to measure the volume
of the wastewater. A pump may be required to transfer the wastewater to
and from the tank
A facility can use a variety of chemicals to initiate sulfide precipitation, in-
cluding sodium sulfate. Mixing the wastewater will encourage flocculation
of the metal precipitates. Although rapid and turbulent mixing may be used
initially to mix the treatment chemicals, such mixing may cause precipitates
to defloculate. It is recommended that the facility use low-speed mixing and
low-shear mixers such as paddle mixers A filter or vacuum pump may be
used to remove the flocculated solid particles from the wastewater, or the
facility may decant the wastewater.
The pH of the wastewater can be determined with disposable pH strips or
with an electronic pH meter The temperature of the wastewater can be de-
termined with a thermometer or with a thermocouple.
Step 5: Prepare the Sampling Plan
During and after the test, the facility will need to sample the wastewater to
ensure that the technology selected to treat the wastewater is performing
adequately. Prior to the start of the test, the facility should pre-
pare a sampling plan to describe the planned data collection,
field measurements, and sample analyses. Table 6-6 lists the
main components of a comprehensive sampling plan.
¦» Select Sampling Points
Facility-specific sampling points should be identified so that the
samples collected will represent the following types of streams
¦ Influent to the treatment system (e.g., commingled waste-
water from PFPR operations and pretreatment steps),
¦ Influent to the individual treatment units;
Table 6-6
Components of a Sampling Plan
¦ Selection of sampling points
¦ Field measurements and operating
parameters
¦ Sample analyses
¦ Sample preservation and shipping
¦ Quality assurance/quality control
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CHAPTER 6 Conducting Treatability Test
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m Effluent from individual treatment units (e.g, hydrolysis effluent), and
¦ Final effluent from the treatment system
Sample point selection should be designed for the specific system. Typically,
wastewater samples are collected from the influent and effluent of each treat-
ment unit operation to evaluate the performance of the individual unit. The
initial influent and final effluent samples from the whole treatment system
are collected to evaluate the system's overall performance
If the facility chooses to investigate whether individual wastewater streams
(e.g., floor wash) require pretreatment, the selected sampling points should
include those individual raw wastewater streams The commingled influent
to the treatment system would then consist of the pretreatment unit effluent
and the raw wastewater streams that do not require pretreatment.
The facility may also wish to collect multiple samples during a treatment step
to better calculate technology-specific performance measures (described in
the Evaluation of Test Results section). Table 6-7 presents examples of the
sampling frequency and analysis that irught be performed for various tech-
nologies on a pilot scale. Sample frequency should account for the variability
of the wastewater generated from the various processes at the facility.
Table 6-7
Example Sample Collection for Pilot-Scale Study
Technology
Performance Measure
Sampling Frequency
Typical Sample Analyses
Any technology
Destruction and removal
Collect influent and final effluent
Arty constituent
efficiency
samples
Activated Carbon
Carbon breakthrough
Collect effluent samples after every
Pesticides
curve
60 liters has passed through the
Oiganics
carbon bed
Total organic carbon
Activated Carbon
Saturation loading/carbon
Treat a set volume (e.g.. one liter) of
Pesticides
isotherm
wastewater through varying amounts
Oiganics
of carbon and collect effluent samples
Total organic carbon
Emulsion
Time for phase separation
Visually inspect samples hourly for
Turbidity
Breaking
phase separation
Total suspended solids
Oil and grease
Hydrolysis
Half-life calculation
Collect effluent samples every 2-6
Pesticides
hours of treatment
Field Measurements and Operating Parameters
As part of the test documentation, facilities should prepare field logs for each
sample point. Typically, these logs will contain the types of information listed
in Table 6-8 and be mcluded in the report documenting the test results.
Typical field sampling equipment includes pH meters or indicator paper, ther-
mometers, scoops or shovels, and bottle dippers. Noncontarrunating pH indi-
cator papers are often used during sampling and preservation; however, if a
more precise pH determination is required, a pH meter, calibrated each day
in the field, can be used The pH electrode should be decontaminated prior to
sampling by rinsing the probe in deionized water. Temperature can be mea-
sured from either an aliquot collection jar or from the process stream after
63
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Outdance Manual for the PFPR Industry
sample collection to ensure that the thermometers
do not contaminate samples Other sampling equip-
ment that directly contacts the sample, such as
scoops, shovels, and bottle dippers, should be
precleaned and dedicated to each sample point or
cleaned prior to reuse. Table 6-9 lists the typical
decontamination procedures for sample collection
containers.
Sample Analyses
Wastewater samples may be analyzed for conven-
tional and selected nonconventional parameters,
priority pollutants, and nonprionty organic and
metal pollutants For the PFPR industry, the no-
table nonconventional pollutants expected to con-
tribute a significant toxic loading to PFPR facility
wastewaters are the pesticide active ingredients
used in formulating, packaging, or repackaging
operations. PFPR wastewater may also contain
specific organic and metal pollutants used in the
facility's pesticide formulations or high levels of
oils or solids.
At a minimum, samples should be analyzed for
the facility's pesticide active ingredients (if a
method is available) and for priority pollutants.
A number of pesticide active ingredient methods
can be found in the Methods for the Determination
of Nonconventional Pesticides in Municipal and In-
dustrial Wastewater (EPA 821-R-93-010). It is also
helpful to analyze the samples for the classical
wet chemistry parameters listed in Table 6-10.
These parameters can sometimes be correlated to
the level of treatment achieved during a particu-
lar unit operation For example, total organic car-
bon (TOC) is often used as an indicator for
activated carbon adsorption. During a treatability
test or during an initial monitoring period for a
full-scale treatment system, the samples should
be analyzed for both TOC and the specific pesticide active ingredients. If the
test results show a correlation between the two, then TOC can be used as a
surrogate monitoring parameter during normal treatment operations. If met-
als are not used in the facility's operations, samples for metals analyses may
be collected only at the treatment system influent and the final effluent to
evaluate the overall system removals for those constituents
Facilities may also wish to analyze the samples for other parameters that may
affect the performance of the selected treatment technologies. For example, a
treatability test for activated carbon might include analysis of total suspended
solids, since solids can plug the carbon bed and reduce overall performance
of the system
64
Table 6-8
Typical Field Log Data
¦ Sampling point description;
¦ Date and time of sample collection,
¦ Name or initials of sampler;
¦ Deviations from the sampling plans or test plan;
¦ Field measurements.
¦ Flow data;
¦ Production data;
¦ Observations; and
¦ Other comments
Table 6-9
Decontamination Procedures
For samples in which Inorganic constituents are to be
analyzed, the following decontamination procedures
are effective:
¦ Wash in a nonphosphate detergent and water
solution;
¦ Rinse with dilute hydrochloric acid;
¦ Rinse with tap water; and
¦ Rinse with Type II reagent grade water.
For samples in which organic constituents are to be
analyzed, the following decontamination procedures
are effective.
¦ Wash with detergent;
¦ Rinse with tap water;
¦ Rinse with distilled water;
¦ Rinse with acetone, and
¦ Rinse with laboratory-grade hexane.
Equipment blanks should be collected as necessary to
verify adequate decontamination procedures.
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Different types of analyses are conducted using separate
analytical methods that have specific preservation meth-
ods. These analyses may also be conducted by separate
laboratories. As a result, wastewater collected at each
sample point is separated into one or more containers,
called a sample "fraction," for each analysis or set of simi-
lar analyses. A comprehensive water sample set typically
consists of the eight fractions, listed in Table 6-11. The
pesticide active ingredients analyzed will be facility-spe-
cific. Some pesticides are analyzed by the same method;
a separate pesticide fraction is required for each analyti-
cal method As mentioned previously, it may not be nec-
essary for the facility to analyze the wastewater for all
parameters.
¦» Sample Preservation
Individual sample fractions must be preserved accord-
ing to the appropriate analytical method. Table 6-12 lists
the typical analytical fractions, along with the typical
sample volume, sample container, and on-site preserva-
tion for each fraction.
Sample volume, container type, preservation, and stor-
age requirements for each analytical method are speci-
fied in the Handbook for Sampling and Sample Preservation
of Water and Wastewater (U.S. Environmental Protection
Agency, EPA-600/4-82-029, Cincinnati, Ohio, Septem-
ber 1982). During sample collection, facilities should fol-
low good housekeeping and health and safety practices
by avoiding cross-contamination of samples and leaks
and spills
Table 6-11
Typical Sample Fractions
¦ Specific pesticide active ingredlent(s)
¦ Volatile organic pollutants
¦ Semi-volatile organic pollutants
¦ Metals
¦ Croup I classical parameters (BOD, TSS,
TDS, pH, and fluoride)
¦ Group II classical parameters (TOC. COD,
ammonia nitrogen, nitrate/nitrite nitrogen)
¦ Hexane extractable material
¦ Total cyanide
Table 6-10
Classical Wet Chemistry Parameters
¦ Ammonia as nitrogen
¦ Biochemical oxygen demand (BOD)
¦ Chemical oxygen demand (COD)
¦ Cyanide, total
¦ Fluoride
¦ Hexane-extractable material (HEM)
¦ Nitrate/nitrite nitrogen
¦ pH
¦ Total dissolved solids (TDS)
¦ Total organic carbon (TOC)
¦ Total suspended solids (TSS)
Table 6-12
Typical Sample Fractions and Preservation
Sample Fraction
Sample Volume
Sample Container
On-Slte Preservation
Typical Pesticide Method
2 Liters
1 Liter Amber Narrow-
4°C; pH 5-7 with NaOH or HCI
Mouth Glass
Volatile Organics
80 mL
40 mL VOA Vial
4°C
Semi-volatile Organics
2 Liters
1 Liter Amber Narrow-
4°C
Mouth Glass
Metals
1 Liter
1 Liter Narrow-Mouth Plastic
pH 2 with HNO?
Group 1 Parameters'
1 Liter
1 Liter Narrow-Mouth Plastic
4°C
Group II Parameters2
1 Liter
1 Liter Narrow-Mouth Glass
4°C; pH 2 with H SO
2 4
Total Cyanide
1 Liter
1 Liter Narrow-Mouth Plastic
4°C, pH 12 with NaOH
Hexane Ex tractable
1 Liter
1 Liter W ide-Mouth Glass
4°C. pH 2 with HCI
Material
'Group 1 parameters include BOD^ pH. Fluoride, TDS. and TSS
'Croup 11 parameters include ammonia nitrogen, nitrate/nitrite nitrogen. COD, and TOC
65
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CHAPTER 6 Conducting Treatability Test
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-~ Quality Assurance/Quality Control
To ensure the accuracy of the data collected during the treatability test, it is
critical that proper quality assurance/quality control (QA/QC) procedures
be followed throughout the entire treatability test and during sampling and
analysis. The sample plan should identify the following three components of
the facility's QA/QC plan
(1) Specify procedures to ensure that data quality is within prescribed limits
of acceptability,
(2) Provide QC data that may be used to assess data quality in terms of pre-
cision and accuracy; and
(3) List analytical methods to be used.
Appropriate QA/QC procedures should be followed by the facility and the
laboratory that the facility selects to analyze the samples.
For example, when collecting samples, the facility should also collect QA/
QC samples, including field duplicate samples, field blanks, equipment blanks,
and trip blanks.
• Field duplicate samples are two successive samples from the same sam-
pling point. Results of the field duplicate analyses are used to evaluate
overall precision and cover all sources of data variability, including sample
collection, handling, preparabon, and analysis Field duplicates are sub-
mitted to the laboratory as blind duplicates
• Field blanks are samples of an analyte-free matrix (e.g., HPLC water), which
are prepared at the sampling site by pouring the HPLC water directly into
the sample bottles Results are used to evaluate potential volatile organics
contamination from the ambient air arising during sample collection.
• Equipment blanks are samples of an analyte-free matrix that have been
used to rinse samplmg equipment prior to samplmg. The results are used
to evaluate contamination arising from contact with sampling equipment,
and to verify the effectiveness of equipment decontamination procedures.
• Trip blanks are samples of an analyte-free matrix that have been trans-
ported unopened from a controlled area to the sampling site and finally to
the laboratory Trip blanks are used to monitor volatile organics contami-
nation of samples during transport, field handlmg, and storage.
Duplicate samples are typically collected at a
frequency of 10%, or at least once per sampled
media. Duplicate samples are best collected
at sample points with very high or very low
pollutant concentrations The various blank
samples are also typically collected with a com-
bined frequency of approximately 10 percent
The primary objective of establishing QA/QC
procedures is to ensure that data are of the
quality necessary to demonstrate that the
treatment technologies selected and tested
comply with the PFPR rule. Table 6-13 lists the
Table 6-13
Overall Quality Objectives
¦ Obtain all the critical data necessary to support
decision-making,
¦ Collect representative samples according to the
procedures established in the sampling and analysis
plan;
¦ Ensure data comparability by using standard methods
and controlled systems to collect and analyze
samples; and
¦ Provide analytical results of known and acceptable
precision and accuracy
66
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CHAPTER 6 Conducting Treatability Test Pollution Prevention Guidance Manual for the PFPR. Industry
overall quality objectives that should be met Both the facility and the labora-
tory performing the analyses are responsible for ensuring that the data qual-
ity objectives are met
Table E: Summary and Evaluation of Test Results
Following the treatability test, the facility should summarize and evaluate the
results to determine whether the test goals were achieved. The facility can
use Table E as the starting point for compiling and evaluating the test results,
including all analytical data, records of design and operating parameters
achieved during the test, and treatability test operator observations Com-
pleting this table will enable facility personnel to assess which treatment tech-
nologies were effective in reducing specific
constituents in the wastewater, and determine the
optimum operating parameters for each treatment
unit. Four steps that can be used to evaluate the
treatability test results are detailed below.
Step 1: Document Test Results
The purpose of the treatment system is to reduce
contaminant levels in PFPR wastewaters. The pri-
mary constituents of concern for the PFPR industry
are the pesticide active ingredients used in the
facility's products. Other constituents, such as sol-
vents or inert ingredients, may also be a concern,
depending on site-speafic criteria.
To evaluate the effectiveness of the treatment system, a facility should first
document all test results on Table E Figure 6-5 is an example of a completed
Table E that presents the types of data collected during the treatability test
The unshaded "Technology", "Primary Constituents", "Design and Oper-
ating Parameters", and "Constituent Concentration" columns illustrate this
example Note that test results can be documented for each technology, as
well as for the entire treatment system.
Step 2: Calculate Performance Measures
The effectiveness of a treatment step can be evaluated through performance
measures that look at how much contaminant is removed from the wastewa-
ter, the amount of other waste generated by the treatment step, and the cost
of the treatment The most common measure of treatment effectiveness is the
destruction and removal efficiency (DRE), also known as a percent removal,
which measures the amount of contaminant removed from the waste stream
In addition to DREs, treatment effectiveness may be measured with technol-
ogy-specific measures, such as a hydrolysis half-life. These measures are of-
ten useful in comparing the results of different treatment tests using the same
technology
As shown in Figure 6-6, facilities can use the "Performance Measures" col-
umns on Table E to document these measures. Once the treatment perfor-
mance is calculated, facilities can determine whether that technology was
successful in removing or destroying that constituent and document the re-
Table E
l
i
peatability Test Goals
¦ Determine treatment effectiveness;
¦ Identify analytical parameters to act as
surrogates for pesticide active ingredient
analyses;
¦ identify design and operating parameters to act
as indicators for treatment effectiveness.
¦ Comply with permitting requirements; and
¦ Optimize treatment performance.
67
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Table E: Summary and Evaluation of Test Results
Facility
Date
Location _
Prepared bv_
liwfrt vwir optimal liralnwnl train and ontrahny nnramrlpn in U» nrovtrtH hHn».
EmuJsion
Actuated
raw ^
breaking
H\drol\ns
carbon
^ discharge
wasmwrer ^
W
w
adsorption
W
pH = 2
pH = 12
pH = 7
T = 60* C
T ~ 60'C
T = 25'C
sloh mix
slow mix
flow rate = 87 mL/mm
24 hour settling time
24 hour settling time
empty bed residence time - 15 mm
Comtnunrt CwicTiitnitwn
Design and Operating Parameters
Performance Measures
Other
Other
StBlm
Otter
Etotnsn
Other
Hrdrtthtu
Effectively
Treatment
Influent
(ujj/L)
Enhient
(ug/L>
Primary
Treated;
UsUddc
Emulsion
Samnfs rnntmned oil the emuluon.
24 hn"r<
rtffltrir
breakint
hrenhno ron 99.79s
IMtourn
l">nlnol
74 noun
ffl.ff mm
Memlnchlor
24 hours
59.6 hours
H\drol\sts
Pendimethalm
24 hour?
P\rerhrm II
24 hour*
7 4f> hnurr
Rinloptrnl On Pen Demand (ROD <)
24 hours
He-tare Frimrtobfe Mnirrml (HFM)
24 hourr
Total Orpnnir Carhnn (TDCl
74 tfiurx
Total impended Solid* /7TTI
74
1 NA=not analyzed NC* = not calculated
Figure 6-5. Documenting Test Results
suits in the last column, "Effectively Treated?" A facility should evaluate
three measures to determine if the technology effectively removed that con-
stituent.
¦ Percent removal;
¦ Final effluent concentration, and
¦ Mmimum detection limit
For example, if 95% or more of a constituent is removed by a technology, that
technology would be considered effective. Conversely, if a technology only
removes 30% of a constituent, but the constituent is removed to below its
detection limit, the constituent is effectively treated
For cost purposes, the facility should also evaluate the technology-specific
performance measures For example, as shown in Figure 6-6, metolachlor is
somewhat reduced by the hydrolysis step, however, the half-life is almost 60
hours. Hydrolysis alone would not be a cost-effective treatment technology
for metolachlor in this wastewater
In addition to the DRE calculation, a discusion of several technology-specific
measures typically used to evaluate hydrolysis and activated carbon adsorp-
tion treatability test results are described below Requirements for measuring
treatment effectiveness for other technologies may be identified through re-
view of technical literature
Table E
1 I
68
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
Table E: Summary and Evaluation of Test Results
Faalit)
Date
Location _
Prepared b\_
Insert 'our nnlimal IrratmcH tmm nntl norratim, nnramHrrs in I he
74 hours
tnmnrhim
I hmir
14 himn
c 16.5
Total Ommw Cnrhon (TOT)
2£JujUi
m
mmm
WIMMm
WMml
Qfliumac
24 ht>tirx
>99,7*
2.R4 hot/rt
24 hourt
5.7M
Ltnaiool
75.79c
hours
MrmtKhit
24 hour*
:9.d hom
H\drolvsv
Psnthmrzhahn
24 hour*
8.16%
f\mhnn 11
^4 htntn
7.4ft hours
Hioinficnl f?n Pen Demand (BOD«)
74
He rrme Frtmrtahfe Marenri! iHFM)
?¦* twin
^2Jflu2c2iIBIt£flufl2£LlZ3CCi
24 noun
Tntal Sumended Sol,Hi tTSSl
24hain
NA=nnt analv7ed NC = not calculated
Figure 6-6. Calculating Performance Measures
Destruction and Removal Efficiency Calculation
The DRE is an overall measure of the effectiveness of a treatment While some
technologies, such as hydrolysis and chemical oxidation, destroy contami-
nants by breaking chemical bonds joining the atoms in a molecule, other tech-
nologies, such as activated carbon adsorption and emulsion breaking, remove
contaminants by separating the contaminants from the wastewater. Other
technologies may use a combination of destruction and removal.
The DRE of a particular technology is based on the sum of the destruction
and removal achieved by a technology and does not differentiate between
the two. Some facilities may need to differentiate between destruction and
removal technologies for practical purposes. Since destruction technologies
(e.g., hydrolysis) eliminate a contaminant, they typically do not generate a
residue that must be further disposed of, or if they do generate a residue, it is
generally of a smaller volume than removal technologies. Removal technolo-
gies (e g., activated carbon adsorption) separate the contaminants from the
wastewater, but the separated contaminants then require additional man-
agement, such as reuse, recycling, or disposal.
As shown in Figure 6-7, the DRE is equal to the mass of contaminant in the
treatment system influent minus the mass of contaminant in the effluent,
divided by the mass of contaminant m the influent This measure may also be
referred to as the percent removal when expressed as a percentage
Table E
I l
1
I
i
69
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CHAPTER 6 Conducting Treatability Test
Pollution Prevention Guidance Manual for the PFPR Industry
DRE = (MaSS,nfuJ ~ (MaSSrffluen)
(MaSSmflueJ
Figure 6-7. Destruction and Removal Efficiency Calculation
A mass balance constructed for the treatment system may help facilities iden-
tify areas of wastewater and contaminant gain and loss. Constructing a mass
balance requires listing all of the influent streams and all of the effluent streams
of a system and listing their masses. Using the law of conservation of mass,
the total system influent mass should equal the total system effluent mass
plus any mass that may have been destroyed through a chemical reaction. If
the mass does not balance, then it is Likely that some influent or effluent stream
(e.g, adsorption to treatment system components or evaporation) has been
overlooked. A mass balance can be conducted on mdividual unit operations
or on an entire treatment train; it can also be performed on the entire waste-
water volume treated or on one specific contaminant. When the volume of
the wastewater does not significantly change during treatment, the DRE can
be calculated using the contaminant concentration rather than mass
Determining the DRE may be difficult if contaminant concentrations are less
than the analytical detection limit, or if contaminants in the wastewater in-
terfere with laboratory analysis and cause a high detection limit. Table 6-14
contains some general rules of thumb to follow when estimating the DRE m
these circumstances.
When determining treatment efficiency, it may be helpful to calculate DREs
for each unit operation as well as for the entire treatment system. Informa-
tion on DREs for individual unit operations may help facilities identify which
unit operations in a treatment tram are not performing optimally In some
cases, it may even be possible to exclude individual unit operations from the
treatment train if the treatment effectiveness for one particular operation is
insignificant.
Table 6-14
Calculation of DREs When Constituents Are Below the Level of Detection
The DRE can be calculated, using the formula in Figure 6-7, if the following conditions apply:
¦ Both the influent and effluent concentrations are greater than the reported detection limits, and the influent
concentration is greater than the effluent concentration; and
¦ The influent concentration is greater than the reported detection limit, and the effluent concentration is less
than the reported detection limit The DRE can be calculated using the reported detection limit for the
effluent concentration in the calculation in Figure 6-7. The percent removals calculated should be shown in
the test report with the "greater than" (">") symbol
The DRE cannot be calculated if the following conditions apply:
¦ Both the influent and effluent concentrations are greater than the reported detection limits, and the influent
concentration is less than the effluent concentration;
¦ The influent concentration is less than the reported detection limit, and the effluent concentration is
detected; and
¦ Both the influent and effluent concentrations are less than the reported detection limits.
70
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CHAPTER 6 Conducting Treatability Test
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Hydrolysis Half-Life Calculation
Hydrolysis is an aqueous chemical reaction in which a molecule is broken
into two or more organic molecules Hydrolysis of most pesticide active ingre-
dients takes place at an elevated pH and temperature, although some pesti-
cides may be amenable to acid hydrolysis.
To evaluate the effectiveness of hydrolysis on PFPR wastewater, half-lives are
typically calculated for each pesticide active ingredient. The hydrolysis half-
life is defined as the time required for the reactant concentration to decrease
to half the initial concentration. When hydrolysis occurs in alkaline condi-
tions (e g., pH = 12), the reaction can be modeled with a first-order rate equa-
tion, as shown in Figure 6-8.
1/2 " *,
tw = half-life (minutes)
kt = pseudo first-order rate constant (minutes'1)
Figure 6-8. Hydrolysis Half-Life Equation
For alkaline hydrolysis, the half-life is de-
termined using the procedure detailed in
Table 6-15. For further information on hy-
drolysis rate reactions and the calculation
of half-lives under different treatment con-
ditions, consult a hydrolysis text
or see the references listed at the end of
Chapter 5
Activated Carbon Adsorption
Performance Measures
Activated carbon adsorption is a treatment
technology that removes certain organic constituents from wastewater through
physical and chemical forces that bind the constituents to the carbon surface.
The adsorption of pesticide active ingredients typically takes place at neutral
pH and ambient temperatures Two performance measures are used to evalu-
ate the effectiveness of activated carbon adsorption on PFPR wastewater
carbon saturation loadings and carbon breakthrough curves.
The carbon saturation loading is the mass of organic constituents that can be
adsorbed onto a unit mass of activated carbon As wastewater is processed
through a carbon bed, organic constituents are adsorbed onto the activated
carbon At the same time, other constituents may be desorbed from the car-
bon When the rate of sorption and desorption reach equilibrium, the carbon
is said to be saturated, and no further removal of organic constituents is
achieved
The saturation loading varies with the concentration of the compounds being
adsorbed, the wastewater pH and temperature, and the presence of other
adsorbable compounds A carbon adsorption isotherm is typically constructed
Table 6-15
Alkaline Hydrolysis Half-Life Determination
1) Plot the natural logarithm of the constituent concentration
versus time
2} Draw a trend line to linearly fit the data.
3) Calculate the slope of the line, which is equal to the
hydrolysis rate constant, k .
4) Calculate the half-life using the equation in Figure 6-8
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Pollution Prevention Guidance Manual for the PFPR Industry
to show the relationship between the saturation loading and the pollutant
equilibrium concentration at a given temperature. This information can be
used to determine how much carbon is necessary to remove a constituent to a
set effluent concentration Figure 6-9 presents an example of a carbon ad-
sorption isotherm for metolachlor, a pesticide active ingredient
Carbon Adsorption Isotherm
X/M= 135Ce034
irvmn
0 1 1 10 100 1000
Equilibrium Concentration, C.
(rrtg/L Metolachlor)
Figure 6-9. Carbon Adsorption Isotherm.
Carbon isotherms can be found in literature for many pesticide active ingre-
dients; however, a facility may also conduct a separate treatability test to
construct their own isotherms, since precise saturation loadings are specific
to a facility's individual wastewater stream One experimental technique for
determining saturation loadings is presented m Carbon Adsorption Isotherms
for Toxic Organics, listed in the references at the end of Chapter 5. For further
information on activated carbon treatment and the construction of adsorp-
tion isotherms, consult a wastewater treatment text or see the references listed
at the end of Chapter 5
Carbon breakthrough curves are another useful measure of the performance
of an activated carbon system. Breakthrough curves are often used to esti-
mate how much wastewater can be treated through an activated carbon unit
before it is necessary to replace or regenerate the activated carbon. The curve
is constructed by plotting contaminant concentration in the effluent versus
volume of wastewater treated. When wastewater is first treated through a
bed of fresh carbon, the concentration of contaminant in the effluent is at a
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Pollution Prevention Guidance Manual for the PFPR Industry
minimum level At some later time during treatment, the carbon becomes
saturated and the contaminant is no longer adsorbed completely The con-
centration of the contaminant in the effluent increases as more wastewater
passes through the unit and more of the available pore space in the carbon
becomes filled with contaminant. At the point where no additional contami-
nant is being adsorbed, the carbon is said to be exhausted Figure 6-10 pre-
sents an example of a breakthrough curve for a general pesticide active
ingredient. As seen in this example, carbon breakthrough occurred after about
10 liters of wastewater were treated through the carbon bed.
Example Carbon Breakthrough Curve
6000
5000
tS> 4000
3000
2000
1000
10
15
20
0
5
25
30
35
Volume of Feed (Liters)
Figure 6-10. Carbon Breakthrough Curve
Step 3: Compare Treatment Technology Results
To identify the most appropriate treatment train, the facility needs to com-
pare the results of their treatability tests to previous treatability tests, either
conducted by the facility or contamed in the technical literature The facility
may wish to consider aspects other than overall treatment effectiveness, in-
cluding cost, reliability, residuals generated, and need for highly skilled op-
erators. When comparing treatability tests conducted using the same
technology, the comparison is more straightforward than when comparing
treatability tests usmg different technologies.
When comparing the same technologies, the facility can evaluate treatment
effectiveness measures, such as effluent concentrations and DREs, but they
can also compare technology-specific measures, such as hydrolysis half-lives.
The facility may also be able to compare factors other than treatment effec-
tiveness (e g, reliability and cost) more directly
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When comparing different technologies, the compansons may be more diffi-
cult. Although the facility can still compare final effluent concentrations and
DREs, technology-specific criteria are not directly comparable In addition, it
may be more difficult to compare technologies on bases other than treatment
effectiveness, such as reliability and cost.
Facilities should exercise caution when comparing test results from different
wastewaters. Because of the high degree of variability of PFPR wastewaters,
treatment that is effective on some wastewaters might not be effective on
other wastewaters that are similar. For example, two separate facilities have
metolachlor in their wastewater, but one facility has a low TOC loading in
their wastewater, while the second facility has a high TOC loading. Acti-
vated carbon may effectively remove the metolachlor from the wastewater
with low TOC levels; however, the wastewater with high TOC levels may
have other orgamc constituents that compete with the metolchlor for adsorp-
tion, resulting in reduced removal of metolachlor.
Therefore, when comparing treatability test results from different facilities,
from EPA-sponsored treatability tests, or from technical literature, facilities
should take mto account how their wastewater differs from the wastewater
tested Differences m contaminant concentrations, combinations of contami-
nants, and levels of suspended solids, dissolved solids, TOC, surfactant, de-
tergents, and solvents may cause wastewater differences that can affect the
performance, cost, and/or reliability of a treatment technology.
Step 4: Evaluate Cost-Effectiveness of Treatment
As discussed in Step 3, facilities should compare the treatment technology
test results to choose the technology(ies) that will treat their wastewater to
the level required to comply with the final rule and that will be the most cost-
effective for them to use. In determining cost-effectiveness, facilities need to
examine factors such as the cost of installing new technologies and the an-
nual operation and maintenance costs for those technologies, as well as
whether the technologies will meet the regulatory requirements of the rule
In evaluating the cost-effectiveness of different treatment technologies, facili-
ties should consider whether wastewater treatment is the most cost-effective
method for them to comply with the rule. One of the factors that should be
taken into consideration is the volume of wastewater generated A facility
may be able to treat its wastewater adequately using available technologies,
however, because the facility's volume of wastewater is so small, it may be
less expensive for the facility to dispose of the wastewater off site than to pay
for installation of a treatment system.
After conducting the treatability test to determine the most effective treat-
ment method, the facility may determine that the technologies they have tested
and compared simply are not cost-effective For example, the facility has de-
termined through treatabilty testing that its floor wash water can be adequately
treated using activated carbon adsorption, preceded by an emulsion break-
ing pretreatment step. However, the cost of installing and operating this treat-
ment train is more than what the facility would pay to have the floor wash
water contract hauled off site for disposal. In this case, it would be more cost-
effective for the facility to segregate its floor wash water and store it until it
can be transferred for off-site disposal. Note that cost-effectiveness may not
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be the only factor considered by facilities when choosing to install treatment
or contract off site for disposal. Some facilities may choose to limit the pos-
sible cross media impacts associated with off-site disposal.
As discussed in Chapter 4, the facility can use Table C to reach a preliminary
decision on how to comply with the final rule for each wastewater stream
(i.e, zero discharge or wastewater treatment and discharge after implement-
ing approved P2 practices). For those wastewater streams for which the facil-
ity chose the P2 alternative and that would require treatment prior to discharge,
the facility now has the information necessary to make the final compliance
choice In some cases, the facility may change its preliminary compliance
decision from the P2 alternative (including on-site wastewater treatment) to
contract hauling of its wastewater, based on its evaluation of its wastewater
treatment options. The final compliance decision and Table C are discussed
in more detail in the on-site compliance paperwork section of Chapter 7.
Step 5: Prepare the Test Report
For each treatability test, facilities should prepare
a final test report that presents the information
gathered during the test and the analysis of test
results The report can serve as documentation
of the test and as a reference for future testing.
As mentioned previously in this chapter, Tables
D and E are tables that can be used by facilities to
identify the wastewaters and contaminants that
will be treated at the facility and the treatment
technologies within the facility's treatment tram
that are expected to treat each contaminant.
Many facilities will find it helpful to use a block diagram to draw each treat-
ment step of a treatment tram. In such a diagram, facilities can list the influ-
ent wastewater streams to each unit operation in a treatment train, the
contaminants within each wastewater stream, and the contaminants treated
within each unit operation block
Tables D and E can also be used as compliance documentation to show that
appropnate treatment technologies are being used to treat each wastewater
stream Chapter 7 discusses in detail the documentation needed to show com-
pliance with the final rule.
Test Report Components
¦ Recorded design and operating parameters
¦ Observations made by treatability test personnel
¦ Deviations from the sampling and analysis plan
¦ Analytical results
¦ Calculations of DREs and other treatment criteria
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CHAPTER 7
Regulatory Compliance Documentation
Each facility subject to the PFPR effluent guidelines and standards is re-
quired to keep certain paperwork on site to demonstrate compliance
with the rule. This paperwork must be available to the permitting agen-
cies, control authorities, and enforcement officials and must document the
compliance options chosen by the facility. As part of the on-site compliance
paperwork, the PFPR rule requires a one-time initial certification statement
and penodic certification statements to be submitted to the permitting agency
or control authority The permitting agency or control authority may also
choose to require submittal of additional paperwork for approval, including
the supporting documentation for the facility's selected P2 practices and
wastewater treatment technologies. Facilities must also meet the paperwork
requirements for categorical users under the General Pretreatment Regula-
tion (40 CFR 403), such as submittal of a baseline monitoring report (40 CFR
403 12(b)).
As stated previously in this manual, each facility subject
to the rule must make an initial choice of how to comply
with the rule This choice is documented in the initial
certification statement. The facility periodically reviews
those choices and makes any necessary adjustment m
the periodic certification statement. Chapter 4 discusses
the P2 audit and how a facility can use that tool to de-
termine which compliance strategy to choose (i.e, zero
discharge or P2 alternative). Chapter 6 discusses how to
choose appropriate wastewater treatment technologies
and make a final compliance decision after weighing
the economic impacts of treatment. The information in these two chapters pro-
vides the means with which a facility can choose its method of complying with
the PFPR regulation This chapter discusses the way in which a facility docu-
ments its compliance decisions
Initial Certification Statement
The initial certification statement required for PFPR facilities includes four items
As shown in Table 7-1, the requirements under these items can be met by com-
pleting Tables A through E (shown in Chapters 4 and 6) As discussed in Chap-
ter 4, Tables A and B walk the user through conducting a P2 audit Table A
prompts the facility to identify its wastewater sources and Table B identifies P2
practices that are in use or potentially could be used to comply with the P2
altemabve for those sources (Item 2). Tables B and C also provide a column for
listing modifications to the listed P2 practices (Item 3). After completing Tables A
Necessary Paperwork for the P2 Alternative
¦ One-time initial certification statement
(40 CFR 455.41 (a)).
¦ Periodic certification statement
(40 CFR 455.41(b)); and
¦ On-site compliance paperwork
(40 CFR 455.41(c)).
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CHAPTER 7 Regulatory Compliance Paperwork
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Table 7-1 Initial Certification Statement Requirements
One-time submission to the appropriate control authority or permit writer including the following: Table
(1) List and description of those product families, process lines, and/or process units for which the C
PFPR facility is implementing the P2 alternative and those for which it chooses to achieve zero
discharge,
(2) Description of the PFPR facility-specific practices for each product line/process line/process unit A, B
which are to be practiced as part of the P2 alternative,
(3) Description of any justification allowing modification to the practices listed on Table 8 of the final B, C
rule;
(4) Description of the treatment system being used to obtain a P2 allowable discharge (as defined by D, E
the final rule).
and B, the facility can complete Table C through the preliminary compliance
decision (Item 1), which includes any modifications to listed P2 practices cho-
sen by the facility. Note that Table C has a column to list the approval date for
modifications to any P2 practices chosen by a facility that are not listed in
Table 8 of the final rule. The facility will need to obtain approval for all
nonlisted modifications, and the on-site compliance paperwork should re-
flect this approval, prior to the facility implementing these modifications.
The fourth requirement for completing of the initial certification statement
can be met by filling out Tables D and E, as discussed in Chapter 6. Table D
identifies the treatment technologies that a facility will choose to treat its waste-
water remaining after implementation of P2 practices in order to meet the
allowable discharge requirement. Table E presents the results of the treatability
tests for the technologies identified in Table D. Once the facility has chosen
the best treatment options for its remaining wastewater (i e., treatment and
discharge or contract haul), final compliance decisions can then be docu-
mented on Table C.
The initial certification statement must be submitted to the permitting
agency at the time of issuance, renewal, or modification of an NPDES
permit for direct dischargers and to the control authority (e g, POTW)
prior to the November 6, 1999 compliance deadline for indirect discharg-
ers. The statement must be signed by the appropriate manager in charge
of overall operations at the site to ensure that information provided is
true, accurate, and complete to the best of his/her knowledge This man-
ager should be the same person who signs the compliance status reports
as required by 40 CFR 403.12(1) or 40 CFR 122.22 The initial certification
statement should also be kept on file at the facility as part of the required
on-site compliance paperwork for as long as the facility is in operation.
Periodic Certification Statement
The periodic certification statement required for PFPR facilities consists of a
written submission to the appropriate permitting agency or control authority
This submission states that the P2 alternative is being implemented in the
manner set forth in the local control mechanism/pretreatment agreement
(for indirect dischargers) or NPDES permit (for direct dischargers), as well as
the initial certification, or states that a listed justification from Table 8 of the
final regulation has been implemented at the facility allowing modification of
their P2 practices.
Periodic
Initial
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CHAPTER 7 Regulatory Compliance Paperwork
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If the information contained in the facility's permit or pretreatment agree-
ment and initial certification statement is still applicable, a facility may sim-
ply state that in a letter to the permitting authority, and that letter will constitute
the periodic statement. However, if the facility has modified their P2 prac-
tices in any way or is deciding to change their compliance status for one of
their product lines/process lines/process units (i.e., going from zero discharge
to a P2 practice followed by allowable discharge), they must include such
information in their periodic statement. To comply with this requirement, the
facility may submit a revised Table C, indicating the change on the table. To
modify a listed P2 practice for which a justification is not listed in the final
regulation, the facility must request the modification from the permitting
agency or the control authority (e g., POTW). The permit writer/control au-
thority is expected to use Best Engineering Judgment/Best Professional Judg-
ment (BEJ/BPJ) to approve the modification.
The periodic certification statement must be submitted to the permitting
agency once a year for direct dischargers and to the control authority
twice a year for indirect dischargers. The statement must be signed by the
appropriate manager in charge of overall operations at the site to ensure
that information provided is true, accurate, and complete to the best of
his/her knowledge. Again, this manager should be the same person who
signs compliance status reports as required by 40 CFR 403.12(1) or 40 CFR
122.22. The periodic certification statements should also be kept on file at
the facility as part of the required on-site compliance paperwork for as
long as the facility is in operation. An example of a periodic certification
statement is shown in Figure 7-1
Periodic
jKnEroRnyLATmiKc.
1 July 1997
Anyiown POTW
1 Main Street
Anyiown VA0I110
RE PFPR Periodic Certification for ACME Formulating, Inc.
Dear Sir/Madam
Please be advised that the facility located at 1234 Main Street has initiated production of two
new pesticide products ACME Lawn and Garden Insect Control (dry) and ACME Lawn and
Garden Insect Spray (liquid) Both of these products contain diazmon, a pesticide active
ingredient not previously used at our facility Attached please find a hsung of the new
wastewater sources associated with the production of these products, and whether we intend to
comply wnb the zero discharge regulation or the P2 alternative
As you wUJ see from the attached list, our facility will generate two new sources of wastewater
containing diazmon that will be discharged to your POTW No additional modifications to the
listed practices will be made Our cunent treatment system consists of emulsion breaking,
followed by hydrolysis and activated carbon Table 10 to Part 455 lists hydrolysis as the
appropriate treatment technology for diazmon. therefore we do not intend to make any changes
to our treatment system As stated in our pretreatment agreement, we will monitor our treatment
system effluent for chazinon for 60 days and provide you with copies of all results
Please feel free to contact me at (703) 555-5555 if you have any questions or comments regarding
our changes in operation
Sincerely,
jk&t
John Doe
President, ACME Formulating, Inc
Figure 7-1. Example of a Periodic Certification Statement
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CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry
On-Site Compliance Paperwork
In addition to the initial and periodic certification statements, the on-site com-
pliance paperwork should include the four items listed in Table 7-2. This pa-
perwork must be available for review at any time by the permitting agency or
control authority. As discussed under the section describing the initial certifi-
cation statement, the on-site paperwork require-
ments may mclude the information documented on
Tables A through E, as described in Chapters 4 and
6 These tables document the wastewater sources,
P2 practices and modifications, if any, and waste-
water treatment technologies/disposal options cho-
sen by the facility.
The on-site paperwork should also mclude more de-
tailed materials supporting the decisions m the ini-
tial and periodic certification statements. The
appropriate documentation for each of these deci-
sions is discussed in more detail below.
P2 Modification Documentation
If a facility chooses to comply with the P2 alternative usmg a modification
listed in Table 8 of the final rule for any wastewater source, the facility must
detail those modifications in their on-site compliance paperwork. Table 7-3
presents the practices from the
rule that have listed modifica-
tions. Each of these listed modifi-
cations requires supporting
documentation, as described in
Table 8 of the final rule. For ex-
ample, a facility has determined
that they cannot store and reuse
the interior equipment rinsate
from a specific product because
the rinsate exhibits biological
growth that would affect the
product quality if reused in a sub-
sequent formulation. The facility lists "BIOGROWTH" as their modification
to Practice 10 for that product, and includes as documentation a picture of
the rinsate after growth has occurred and/or a copy of the product QA test
results showing unacceptable constituents present
If a facility wishes to modify any P2 practice using a new justification
that is not listed in Table 8, the facility must submit to the control author-
ity or permit writer the appropriate documentation stating their reasons
for modifying the practice This documentation must be approved by the
permit writer or control authority prior to implementation by the facility.
Both the supporting documentation and the approval must be included
in the on-site compliance paperwork.
On-site
Paperwork
Table 7-2
On-Site Compliance Paperwork Components
(1) Supporting documentation for P2
modifications,
(2) Discussion of treatment system
demonstrating removal of PAIs;
(3) Method for ensuring treatment system is
well operated and maintained; and
(4) Rationale for method shown in Item 3.
Table 7-3
P2 Practices With Listed Modifications Requiring Documentation
Practice 1 - Water Conservation
Practice 2 - Good Housekeeping
Practice 6 - Air Pollution Control Scrubbers
Practice 7 - Drum/Shipping Container Rinsing (water-based)
Practice 8 - Drum/Shipping Container Rinsing (solvent-based)
Practice 9 - Production Equipment Dedication
Practice 10 - Reuse of Interior Rinsate
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CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry
Treatment System Discussion
If a facility chooses to install a wastewater treatment system to treat PFPR
wastewater prior to direct or indirect discharge, the facility must include a
complete description of the system in their on-site compliance paperwork.
This description should include the information listed in Table 7-4, as well as
any documentation necessary to support the conclusions drawn by the facility.
Following completion of a P2 audit (de-
scribed in Chapter 4), the facility should
be able to identify the wastewater sources
that require treatment prior to discharge
under the P2 alternative. In the on-site
compliance paperwork, the facility must
list the specific pesticide active ingredients
expected to be present in the facility waste-
water. Facilities may use production
records or product labels listing the pesti-
cide active ingredients used at the facility
or wastewater monitoring data that spe-
cifically identifies the constituents. The fa-
cility should review the production and monitoring data covering a sufficient
time period to accurately capture all possible pesticide active ingredients
present m the wastewater.
Next, the facility must describe the treatment system, including a list of the
technologies and operating conditions, and document that the technologies
do, in fact, remove the pesticide active ingredients from the wastewater prior
to discharge. This documentation may simply state that the technology(ies) is
listed in Table 10 to Part 455 of the final rule as the appropriate technology(ies)
for the specific pesticide active ingredients present in the facility's wastewa-
ter or that the technology(ies) removes the specific pesticide active ingredi-
ents from their pesticide manufacturing wastewater. Chapters 5 and 6 discuss
the test methods available to identify the specific pesticide active ingredients
present in the wastewater and the appropriate treatment technologies for
their removal. Chapter 6 also described how to document those results on
Tables D and E An example of a treatment system description using Tables D
and E is shown in Figure 7-2.
If the facility chooses to use different tech-
nologies than those listed in the final rule,
they must include treatability test results
or sampling test results (described in
Chapter 6) to show the system is equiva-
lent. The technologies listed in the final
rule were chosen because of their effec-
tiveness in removing or reducing pesticide
active ingredients Following sufficient
pretreatment of PFPR wastewater to break emulsions and/or remove solids,
these listed technologies were generally successful m removing more than
95% of the pesticide active ingredients, typically to below detection limits To
determine whether a different technology or set of technologies is equivalent
to the listed technologies, the facility should evaluate three measures:
Table 7-4
Treatment System Description
(1) List of pesticide active ingredients belived present in
wastewater to be treated,
(2) List of treatment technology(ies) believed effective at
removing each Pesticide active ingredients listed in Item 1;
and
(3) Treatability test results supporting Item 2 or indication
that the treatment appears in 40 CFR 455, Table 10 as the
"appropriate treatment" for pesticide active ingredient(s)
Equivalent System (40 CFR 455.10)
A wastewater treatment system that is demonstrated in
literature, treatability tests, or self-monitoring data to
remove a similar level of pesticide active ingredient or
priority pollutants as the applicable appropriate pollution
control technology listed in Table 10 to Part 455
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Table D: Treatment of PFPR Wastewater
Facility
Date
Location
Prepared b>
Stream Type
Source
Potential Pollutants
Wastewater Treatmeir
Information
Characteristic* That
Hinder Treatment
Active
Ingredients
Other
Pollutant*
Table 10
Technology1
Alternate
Treatment
Technology'
Source for
Alternative Technology
hsShipping Container/ Drum,/
Clearhqg - v.aier or solvenj^nscs
of the containers usedt0/stup ran
material fmishedpwducts and/or
h aste produetyprxbrjo reuse or
disposal gfihe coniairibs.
1 a
1 b
isBulk Tank Rinsaie - cleanmg'
of th&viterior of an\ bulk Mirage
tank cont&mmg /-99 9%
\ /
Y
Lmalool
v
5760
< 100
>9S3%
V /
Y
Metolachlor
15700
999%
\
Y
Pendimethahn
--
110
<05
>99 6%
\/
Y
Ox erall
Purethnn 11
X
SI 1
<5
>93 S9fc
X
V
rffectweness
Biological Ox\gen Demand (BOD <)
< I0S
31
<71 3%
/\
Y
Hexane Extractahle Material (HEM)
56
<5
>91 ]%
Y
Total Organic Carbon (TOC)
"s
534
63
SS2S
/ V
Y
Total Suspended Sohds (TSS)
334
< 4
>9S S^-
/ \
Y
Figure 7-2. Example of a Treatment System Description
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CHAPTER 7 Regulatory Compliance Paperwork
Pollution Prevention Guidance Manual for the PFPR Industry
¦ Percent removal of the pesticide active ingredient;
¦ Final effluent concentration of the pesticide active ingredi-
ent; and
¦ Minimum detection limit of the pesticide active ingredient.
These methods are not exclusive and are not ranked in order of
importance. All three methods may be useful when determin-
ing equivalency.
Percent removals and effluent
concentrations discussed in the final
PFPR effluent guidelines and
standards are shown for guidance
only
Treatment System Operation and Maintenance
Facilities that treat PFPR wastewater prior to discharge must also choose a
method to demonstrate that their treatment system is well operated and main-
tained. This method should be stated and the rationale for choosing it dis-
cussed in the on-site compliance paperwork
Proper operation and maintenance of a system includes a qualified person to
operate the system, use of the correct treatment chemicals in appropriate
quantities, and operation of the system within the stated design parameters
(e.g., temperature and pressure) For example, if the facility is operating a
On-site
Paperwork
Table 7-6
Operation and Maintenance Records
Emulsion Breaking
Hydrolysis Treatment
¦ Temperature and pH of the
¦ Temperature and pH of
emulsion breaking step
hydrolysis step
¦ Duration of the emulsion
¦ Duration of hydrolysis step
breaking step
¦ Physical characteristics of
¦ Physical characteristics of
wastewater before and after
wastewater before and after
hydrolysis
emulsion breaking
Activated Carbon Treatment
¦ Dates and volumes of carbon changeouts
¦ Amount of carbon used in system
¦ Flow rate through the carbon system and /or volume of wastewater treated
since last carbon changeout
treatment system that consists of emulsion breaking, hydrolysis, and acti-
vated carbon, as described in Figure 7-2, the types of operation and mainte-
nance records detailed m Table 7-6 should be kept on site. The method for
determining whether the system is well operated can be as simple as keeping
the types of records shown in Table 7-6, or as complex as monitoring the
treated effluent for specific parameters (such as pesticide active ingredients,
priority pollutants, or other local parameters of concern)
The decision to use one method over another is connected to the consistency
of the facility's wastewater. If the facility formulates, packages, or repackages
the same or similar products for long periods of time, it is reasonable to expect
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CHAPTER 7 Regulatory Compliance Paperwork Pollution Prevention Guidance Manual for the PFPR Industry
that a treatment system designed for the wastewater generated during those
production operations will be effective if operated and maintained as de-
signed In these cases, the facility may monitor the effluent from the treat-
ment system for an initial period of time (typically set by the permit writer or
control authority) to establish the typical effluent concentration or load for
the pollutants of concern. During the monitoring period, the facility may also
document the information detailed in Table 7-6 to establish the normal oper-
ating procedures. Following the momtonng period, the facility would only be
required to document the operating and maintenance information and may
periodically monitor the effluent for the pollutants of concern
If a facility begins producing new products containing one or more pollut-
ants of concern, the typical concentration or load for those pollutants may
need to be revised through another monitoring period, as determined by the
permit writer or control authority.
Additional Considerations for Permit Writers and
Control Authorities/POTWs1
Permit writers and control authorities must use best professional judgement
when evaluating certification statements and reviewing on-site compliance
paperwork from PFPR facilities. Factors that may influence their decisions
include previous experience with the facility, the facility management's com-
mitment to program implementation, and the thoroughness and accuracy of
the supporting documentation.
One area subject to interpretation is the determination of treatment system
equivalency. When reviewing treatment system performance data, the per-
mit writer or control authority should review the source of the data, the time
period during which it was collected, and the type of data collected. The level
of performance should also be evaluated through one or more of the follow-
ing methods.
Calculate percent removals
The percent removal, as discussed in Chapter 6, is equal to the difference
between the influent and effluent values The percent removal can be calcu-
lated on concentrations or on mass loadings It is important to note that the
percent removal is highly dependent on the quantity of pollutant in the influ-
ent For example, an activated carbon system removes bromacil to its target
effluent concentration of 0.431 mg/L If the influent concentration was 100
mg/L, the percent removal is 99 6%, whereas if the influent concentration
was 5 mg/L, the percent removal is 91.4 percent.
Evaluate the final effluent concentrations
During development of the PFPR rule, EPA identified target effluent concen-
trations for pesticide active mgredients treated in systems using appropriate
treatment technologies, as specified m Table 10 of the final rule These con-
centrations are not effluent limitations and do not account for the variability
that may occur in PFPR wastewaters and in treatment systems Permit wnt-
1 The term control authority refers to a publicly owned treatment works (POTW) when the POTW has an
approved pretreatment program Otherwise, the control authority is the State or EPA Region
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ers and control authorities have the authority to request additional treatability
test results or monitoring to better evaluate the variability of the treatment
system effluent.
¦+ Review the minimum detection limit
It is important to note the minimum detection limit achieved by the analytical
laboratory that completed the analyses. If the laboratory neglects to perform
an appropriate number of dilutions, the results may be inconclusive. For ex-
ample, if the influent concentration of a pollutant is 100 mg/L and the efflu-
ent concentration is reported as <100 mg/L, it is impossible to conclude what
level of pollutant removal has been achieved by the treatment system.
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Case Studies
This chapter describes the P2 practices implemented by two PFPR facili-
ties. The first facility, operated by Ennis Agrotech and located in Ervrus,
Texas, is a formulator and packager of agricultural products. Ennis
Agrotech uses a variety of P2 techniques, such as reuse of treated wastewaters,
to achieve zero discharge of PFPR process wastewaters. The second facility,
operated by MGK (McLaughlin Gormley King Company), was constructed in
1992 in Chaska, Minnesota, and illustrates how new facilities can incorpo-
rate P2 opportunities into their design.
In each case study, the following information is presented:
• An overview of the facility;
• A description of the PFPR operations, including wastewater generation; and
• A discussion of the P2 techniques implemented by the facility.
Each case study was prepared from information collected during site visits and
through follow-up telephone calls with facility personnel. This information
was correct at the time of development of the final rule, but operations may
have changed since that time. The P2 practices implemented and their ben-
efits are solely based on the opmions of the facilities presented here. Specific
P2 practices and equipment presented in the case studies in italicized bold
print are defined in the P2 glossary in Chapter 3
Case Study 1: Ennis Agrotech, Ennis, Texas
Facility Overview
Ennis Agrotech, formerly Agriculture Warehouse, operates a contract (or toll)
PFPR facility that does not produce or market its own labeled products. In-
stead, the facility formulates registered pesticide products for about 20 domes-
tic and foreign companies These companies supply Ennis Agrotech with the
necessary raw materials, product recipes, and packaging and labels required to
make the final product. Enras Agrotech assembles a production line using the
customer's bench-scale process as a guide, formulates and packages the prod-
uct, and then turns the product over to the customer's marketing division The
production line consists of equipment from Ennis Agrotech's inventory as well
as custom-designed equipment manufactured as needed by a local machine shop.
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PFPR Operations
The facility operates eight independent process lines to formulate and pack-
age both liquid and solid pesticide products. The list of formulated products
varies over time due to changing contracts, however, Ennis Agrotech attempts
to schedule formulating and packaging contracts such that only compatible
pesticide products are being produced at the same time.
The eight production areas operated at the facility (termed "manufacturing
modules" by Enrus Agrotech) are individually configured to handle a certain
type, or formulation, of pesticide product. The equipment setup in each of the
process areas can be reconfigured to formulate new products. New formula-
tion and packaging lines usually consist of a combination of existing and new
custom-designed equipment. Existing equipment is refurbished, pressure-
washed m a curbed area (if necessary), and stored in a warehouse building
(called the machine shop) when it is not being used on one of the process
lines. At the time this manual was written, Ennis Agrotech was conducting
formulating, packaging, and repackaging operations in the following eight
production areas:
•-~•The first manufacturing module is used to formulate and package
mosquito growth-regulator briquets. To produce the briquets, an
insecticide is mixed with carbon and gypsum cement, poured into
plastic trays with numerous quarter-sized molds, cured, and pack-
aged.
"~The second manufacturing module is a serru-automated line used
to produce various dry animal health products containing car-
baryl and/or phosmet. The products are formulated m grinding
and milling equipment, stored in tote bags, sampled and analyzed
to assure compliance with product specifications, and packaged.
»^The third manufacturing module is a pilot plant configured to for-
mulate and package a product that is used on cow ear tags. A
liquid active ingredient is combined with other raw ingredients in
a mixer and then sprayed onto a clay or granular carrier in a
Munson blender.
™^The fourth manufacturing module is used to formulate and pack-
age a fire ant control product Liquid active ingredient is mixed in
a kettle and sprayed onto granulated clay material in a Continen-
tal blender. The product is then lifted by an elevator into a hopper,
screened to filter out oversized particles, and packaged into bags
¦¦~The fifth manufacturing module, called the "Pellet Mill System,"
is used to produce pelletized aquatic and pasture herbicides Ac-
tive ingredients mixed with water, binding agents, and dispersion
agents are sprayed onto a solid earner as it is mixed in a Marion
paddle blender. The formulated product is transferred via a con-
veyor to a mill where it is pelletized. The pellets are either pack-
aged "raw" or coated with sulfonates (a pulp and paper industry
byproduct) that act as a water-soluble coating to minimize dust
generation during pellet handling. The raw or coated pellets are
gravity fed through an elevator to a hopper and then packaged
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into bags Due to the large volume of water incorporated into the
product during the formulating and pelletizing process, the facil-
ity uses a combination of city water and treated water, which is
stored in a 5,000-gallon tank located outside of the laboratory. The
finished product contains 15 to 18% water.
<°*The sixth manufacturing module is used to repackage a finished
dry product supplied by the client company from bulk containers
to smaller containers. The product is removed from 2,000-pound
tote bags, agitated if necessary, and packaged into smaller con-
tainers, such as 2-pound application packs.
"¦^The seventh manufacturing module is used to produce a green-
house insecticide product that controls spider mites. The active
ingredient is mixed with three solvents in the first of three steel
formulation vessels operated in series. The product is transferred
to the second vessel where it is tested. Necessary formulation ad-
justments are made in this vessel if the product is found to be off-
spec. The product is then transferred to the third vessel where it is
held for packaging.
-¦*The eighth manufacturing module is the facility's primary liquid
production area The line is currently configured to formulate and
package a solvent-based insecticide for use on cotton crops.
P2 Practices
Enrus Agrotech generates pesticide-containing wastewater from four sources
(1) interior equipment cleaning, (2) exterior equipment cleaning and floor wash-
ing; (3) drum and shipping container rinsing; and (4) spill and leak cleanups.
The facility uses a local Texas-certified laboratory to analyze all raw materials,
products, and wastes; as a result, no laboratory wastewater is generated on
site. The facility has a stormwater runoff contingency plan, but does not cur-
rently collect precipitation
Ennis Agrotech achieves zero discharge of all PFPR process wastewater through
a variety of P2 practices and wastewater management techniques The benefits
associated with these practices include*
1 Enhanced reputation with their customers, due to the reduction of cross-
contamination liability,
2 Reduced raw material (1 e , active and inert formulation ingredients) costs
due to the recovery of these materials during equipment cleanouts, and
3 Positive relationships with local community and with state and federal
regulatory agencies.
Specifically, Enrus Agrotech uses the following P2 practices-
Interior Equipment Cleaning—Process wastewater associated with the for-
mulating and packaging of a given product is minimized through the dedica-
tion of equipment, the use of dry process cleaning equipment, and water
washes using flow reduction equipment In addition, effective inventory man-
agement practices enable the facility to maximize interior rinsate storage and
reuse.
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Ennis Agrotech dedicates manufacturing modules to specific pesticide classes,
such as fungicides, herbicides, and insecticides, in order to minimize the po-
tential for cross-contarrunation between pesticide classes and to minimize the
number of product changeover cleaning operations In addition, when mak-
ing products within the same pesticide class, formulating and packaging equip-
ment is cleaned before product changeover occurs to allay cross-contamination
concerns, and at set intervals dunng production, if needed. Typically, equip-
ment used to formulate water-dispersible granular products only requires
vacuum cleaning, while equipment used to formulate pellet products usually
requires water washes. The cleaning processes depend on the compatibility
of the pesticide products, and range in scope from multiple rinses to breaking
down all equipment and cleaning to nondetect levels for active ingredients.
Interior equipment cleaning due to a product changeover within a pesticide
class consists of scraping with wire brushes, flushing with the formulation
carrier (such as sand, limestone, or clay) or a solvent wash, and if product
residue or other buildup remains m the equipment, washing with water us-
ing high-pressure (3,500 pounds per square inch)/low-volume (1 gallon per
minute) equipment. About 70 to 80% of the changeovers only require dry
cleaning. The flushed formulation carrier is stored and reused in the next
formulation. If the high-pressure wash step is required, approximately 30 to
35 gallons of water are used to clean the interior of the mixing system. In
some cases, nnsates from interior equipment cleaning operations are collected
and stored for reuse in a subsequent batch of the product.
Ennis Agrotech manages wastewater (and solid
waste) reuse with the same computerized inventory
management control system used to track the stor-
age and use of all raw materials. This system is main-
tained by management personnel assisted by a
"waste movement" consultant Equipment cleanouts
are documented on "Pre-Cleanout and Decontami-
nation Checklists" (shown in Figure 8-1). Separate
forms are used for each unit and product Wastes
generated during these cleanouts (including wash
water, solvents, and dry formulation carriers) are col-
lected, weighed, labeled, and stored in the manufac-
turing module, the information is entered into the
computer system. When that product is formulated,
the computer generates a production sheet for that
batch, which tells the operator how much raw ma-
terial to use, including the amount of stored cleaning
material.
For example, production in the Pellet Mill system (Fig-
ure 8-2) uses a large amount of dry carrier left from
cleaning as raw formulation materials, as well as
cleaning nnsates The Pellet Mill cleanout procedures
are documented on a checklist (Figure 8-3) that
clearly indicates how each piece of equipment is
cleaned, the type of cleaning materials used, and how
the residual cleaning materials are to be handled.
AGRICULTURE WAREHOUSE, INC.
IWVMtwitllWnnnmMtwi HwrHwt
Room # Dal
1 Sactrtcd loctoua/tagoul procedures have been reviewed
By
2. Confined space srrtry procedures have been renewed
By
3 Proper procedures far containing, dnimmtng. and labeling tor
disposal of all rinse water have been reviewed
By
4 Proper procedures for packaging, labeSng, and sampfing (if
necessary) of all solid material collected have been reviewed
By
5 The Mowing special instructions and/or procedures were covered:
By
Management Approval By
Figure 8-1. General Pre-Cleanout/
Decontamination Checklist
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CHAPTER 8 Case Studies
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s ftoom #2 flow Chart
Hwbvioe Only
L
«. <
Figure 8-2 Pellet Mill System
Cleaning water from the Pellet Mill production area
is stored in a 5,000-gallon bulk tank
and treated prior to the next production run
of the same product. The cleaning water is
treated using a microfiltration unit followed
by an activated carbon filter system The
microfiltration unit is a vertical, poly-type,
cross-flow filtration system manufactured by
EPOC Water Systems of Fresno, California.
The Pellet Mill System uses approximately
12,000 gallons of water during each produc-
tion campaign, of which up to 4,000 gallons
is recycled wastewater; the balance is fresh
make-up water.
The Pellet Mill system cleaning material reuse
"cycle" is illustrated in Figure 8-4.
Exterior Equipment Cleaning—Extenor equipment cleaning wash water and
floor wash water are controlled m the same way as the interior equipment
cleaning rinsates. These wash waters are generated during product changeover
(the facility vacuums the floors and walls at all other times). The floors and
walls are washed with water from a high-pressure hose. The entire cleaning
process (including both interior and exterior cleaning) usually requires be-
tween 30 and 75 gallons of water. Wastewater generated during product
changeover is collected in a sump and ultimately pumped back into the next
product batch (solids, if present, are strained out). For example, four drums
of marked "rinsate" were present in the mosquito
growth-regulator briquets process area at the time of
an EPA plant visit. This water was reused in the next
formulation batch of the bnquets.
Drum and Shipping Container Cleaning—Ennis
Agrotech operated a drum rinsing station to mini-
mize the generation of water from drum rinsing op-
erations Recently, however, the facility has
implemented direct reuse of drum rinsate into prod-
uct formulations Drum shipping containers are
triple-rinsed with the same solvent that is used m
the formulation to which the drummed ingredient is
being added. The solvent rinsate is added to the for-
mulation at the time of the formulation. The drums
are then disposed of according to the customer's in-
structions
AGRICULTURE WAREHOUSE. INC.
b? _
by_
by_
°*_
by _
t>y _
&y_
b?_
by.
t>f _
by _
by_
by_
by _
by
Room 2 Pellet MIS Oct & Rush
1 PRC-CLEAN
_ a Scrape A oui
_ b Scrap* A swoop out Mandin 41 ft #8
e Scrap* A •«•*» out ttovators
_ d Scrap* A awaap ou) alB bopp*r and auger
_ c Disassaiable shafcsr and acraam
f Dtsmtnfl* duel work to dryar
_ g Ouai down an duct wort pipaa
h Pull bob froca dun alavasoc
_l Pull bud at a from chain afavatnr
3 WASH
t oiart at •tavatora en top of bulUnp, dual A era
_ b Wash dawn aQ duct nrt
_ t Wash down aid hoppw A auger
_ d Wash and acrapa Sprain waidon
_ • Waah too o! dryor
_ f wasn down all platforms and walkways
_ o Wash down blandsrs #' and #2
_ n Wash down oscillator and baft
_ I Wash down drysr ov»n, b*lt and brush
_ j Wash down pto-mber
_ k Wash down shior
I Wash small Munsort
m wasn »ii ponabl* hoppacs
_ n Waah down tram* work in awtore
o Waah down boartng housing
p Rlnsa all sraaa a o
AO matmtat to bm b+td
fOf t/f
/Bsagpmm+at LmGot
mta smutrwrwp emm
oot for <9# tn fvtttfw
Tout vtpbt
to £m tatertxf taro
irrvntofy
AM troa ***&
to b* atut
etorctf to EPOC
SfSttm This mms/t
sttovte o* Of
mtuMffOMoar prior to
er
Spill and Leak Cleanup—Ennis Agrotech uses good
housekeeping practices to reduce waste Spills and
leaks that may occur are cleaned up with adsorbent
material, which is disposed of off site
Other—Any wastewater that cannot be reused at
Ennis Agrotech is disposed of off site at the direction
of the client Ennis Agrotech arranges for disposal
based on the client s direction, pays the disposal bill, figure 8-3. Pellet Mill System Cleanout Procedures
by
by_
Of-
by_
by_
by_
by _
by _
a PROBLEM AREAS
_ a Ribbon In pra aba*, ratals shaft tor inapacOon
_ b Blades and olansp* In paddta Msndsrs rorato 0)«ts for faapactloo
_ c Elovnor housings top to bono*
0 Mill hoppsrs sugar rafll fao* FtoA!tfispociion of &0
a Osdislor and b*lt 0^tHpamat smf
' 1 uai pjurortn ,ccjcht>e otcu** out
6 oryai mnKS wss* ^owrt
h Shake* icieons
All areas aiust M lotSJty cloanod and chockad by supervisor tor shift
on Unai inspections
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Active Ingredients & Inert Formulation
Ingredients
PRODUCTA
TO CUSTOMER
Water
CUSTOMER
ORDER
FOR PRODUCT A
WEIGHING AND STORAGE
OF DRY CLEANING MATERIAL
AND
TREATMENT AND STORAGE
OF CLEANING WATER R IN SATE
Figure 8-4. Pellet Mill System Cleaning Material Reuse Cycle
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and then invoices the client. In some cases, Ennis Agrotech returns the waste-
water to the client for ultimate disposal. For example, nnsate from tank trucks
used to transport active mgredients is sometimes returned to the client
Case Study 2: MGK, Chaska, Minnesota
Facility Overview
MGK operates a combination pesticide manufacturing and PFPR facility that
produces manufacturing-use concentrates These concentrates are sold to cus-
tomers who formulate them into consumer products for household and lawn
and garden use The Chaska facility, constructed m 1992, currently includes one
active ingredient manufacturing line dedicated to the production of MGK 264
(n-2-ethylhexyl bicycloheptene dicarboxirrude), although the facility plans to
move additional manufacturing lines to this location in the future.
In addition, the facility operates several production lines used to formulate,
package, and repackage products containing MGK 264, MGK 326, pyrethnns,
and DEET The PFPR portion of the Chaska plant consists of a formulating
room, three packaging lines, and a warehousing area. MGK currently holds
approximately 400 product registrations and typically formulates and packages
150 of those products in any one year.
PFPR Operations
The MGK Chaska facility uses MGK 264, as well as other active ingredients
obtained from off-site sources, in the products formulated and packaged on
site. Active ingredients used in formulations that are not manufactured on site
are received in liquid and powder form. Liquid active ingredients are received
m drums and are placed in a heated storage room to ensure the ingredient's
flowability until needed for a formulation. Powders are stored in a separate,
enclosed dry formulations area for dust control Solvent and inert ingredients
are stored in a tank farm located behind the facility.
In the formulating area, raw material active ingredients are stored in dedicated
day tanks with dedicated supply lines. The tanks are connected to two mixing
stations equipped with weigh scales. When a custom formulation order is re-
ceived, the required active ingredient is gravity fed through a dedicated line
into a drum which is positioned on one of the weigh cells. The appropriate
amount of active ingredient, by weight, is pumped from the drum to a formula-
tion tank, along with water or solvent, and any inert ingredients. The formula-
tion tanks range from a volume of 55 gallons to 6,500 gallons If the volume of
an order is small enough, it may be custom formulated in the appropriate size
shipping container at the mixing station, instead of in a formulation tank.
MGK's formulation tanks are dedicated to specific products or product groups
based on estimated product volume requirements, product similarity, or prod-
uct compatibility Dedication of tanks minimizes the need for equipment clean-
ing between product formulations and maximizes the flexibility of operations.
Formulated product is pumped directly from the tank to the packaging line
MGK operates three packaging lines for formulated product Product is pack-
aged into bags, 5-gallon pails, 55-gallon drums, and tote bins MGK also pro-
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vides packaging in bulk form, and is considering 1-gallon packaging MGK
has the flexibility to reconfigure operations to meet the requirements of any
custom formulation.
The solvent used in the MGK's formulations is methylene chloride. In the
formulations area, a solvent recovery unit (still) is operated to recover meth-
ylene chloride used to clean equipment interiors and raw active ingredient
drums.
Equipment for formulation of dry product is dedicated by chemical type, which
eliminates the need for interior equipment cleaning. Methylene chloride is also
used in this area to clean raw material tanks and drums, as necessary
P2 Practices
MGK generates pesticide-containing wastewater associated with PFPR opera-
tions from three sources: (1) floor wash water; (2) exterior equipment cleaning
nnsate; and (3) spill and leak cleanup. MGK also generates pesticide-contain-
ing solvent from two sources: (1) interior equipment cleaning; and (2) drum
and shipping container nnsate. Noncontact wastewaters generated at the
Chaska facility and stormwater are collected in a 40,000-gallon stormwater
settling basin. These wastewaters are discharged without treatment to the
local POTW through a dedicated sewer line separate from the wastewater
sewer line that handles wastewater discharged from the pesticide manufac-
turing and PFPR areas.
MGK incorporated P2 into the original design of the facility and follows cer-
tain wastewater management techniques to achieve P2 at their facility. The
benefits associated with these practices include:
1. Reduced raw material (i.e, active and inert formulation ingredient) costs
due to recovery of these materials in rinsates.
2. Reduced disposal costs due to recovery of solvent used for cleaning formu-
lation equipment and raw material drums.
3. Reduced water use; reduced hazards from slips, falls, and chemical resi-
dues; and decreased labor costs associated with floor cleaning through the
use of a floor scrubber
4. Enhanced corporate image with the local community due to the implementa-
tion of practices that prevent or reduce pollution
5. Reduced air emissions, leaks, and the need for drip pans through the use of
welded joints instead of flanges in process piping.
Specifically, MGK uses the following P2 practices:
Interior Equipment Cleaning Rinsate—Although MGK product formula-
tions include both solvent-based and water-based formulations, methylene
chloride solvent is used for all interior equipment cleaning operations. The
PFPR operations do not generate any interior equipment cleaning wastewa-
ter A solvent recovery unit is operated in the PFPR area to recover methylene
chloride for reuse in the formulating processes. The heel from the distillation
unit is disposed of as hazardous waste.
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In addition, waste associated with the formulating and packaging of a given
product is minimized through the dedication of equipment, production sched-
uling, and formulating and packaging small batches in containers. MGK
Chaska also uses effective inventory management systems to maximize inte-
rior rinsate storage and reuse.
MGK's Chaska facility uses dedication of equipment in a number of areas to
reduce the need for cleaning equipment, thus reducing waste solvent from
cleaning. Dry formulation equipment is dedicated, which eliminates the need
to clean dry formulation equipment interiors. Many of the bulk raw material
tanks and the piping leading from these tanks to formulating equipment are
dedicated to a specific active ingredient, eliminating the need to clean these
tanks and associated piping. Also, formulating equipment is dedicated by prod-
uct family to reduce the need to clean these tanks and to reduce the possibility
of cross-contamination between incompatible products. The facility also dedi-
cates totes used for special formulations to the specific customer and formula-
tion.
The facility also schedules production runs to minimize the need to clean for-
mulation equipment. For example, the facility may schedule the production of
two different products containing the same active ingredients but at different
concentrations to immediately follow each other, eliminating the need to clean
formulation equipment between the production runs.
MGK formulates small batches of product directly into 55-gallon drums Piping
that is dedicated by active ingredient feeds to a scale upon which 55-gallon
drums can be placed The appropriate weight of each active ingredient and
inert is measured directly into the drum. This practice eliminates the use of a
formulation tank and any associated formulation tank cleaning
The facility also maintains an inventory management system for raw materials,
products, and solvents that are recovered for reuse. A computerized system is
used to keep track of raw materials and products, and to optimize production
runs to minimize cleanings for product changeovers. The facility also maintains
water meters throughout the facility, so that the amount of water used by the
facility used for specific purposes, such as sanitary waters or cleaning water,
can be determined
Drum/Shipping Container Rinsate—Active ingredient drums are triple-rinsed
with methylene chloride, and the methylene chloride is recovered in the solvent
recovery unit for reuse in PFPR operations. How reduction equipment (i.e,
spray guns) are used to rinse drums to improve the level of cleaning and to
reduce the amount of solvent used in cleaning operations.
Floor Wash Water—The MGK Chaska facility was specifically designed to
allow enough clearance to use a floor scrubber. This mechanical floor washer,
which operates on a 5-gallon recycled reservoir containing water and detergent,
is used to clean the floors in the PFPR area. When this reservoir is replaced with
new water and detergent, the spent cleaning solution is dumped in the floor
drains in the MGK 264 or PFPR process area. In MGK's older facilities, the
floors, which are sloped to a center drain, are sprayed down with water and
soap. Facility personnel stated that this method takes longer and has more
labor cost associated with it, and the floors tend to be more slippery.
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Exterior Equipment Cleaning Rinsate—In addition, when deemed neces-
sary by plant personnel, a complete floor and equipment wash is conducted
by spraying walls, floors, and equipment exteriors with water from a hose
equipped with a spray nozzle. This cleanmg is typically conducted once per
month. The MGK 264 floor drains, as well as the floor drains in the PFPR
area, feed into an equalization tank, located in the MGK 264 area, which is
ultimately discharged to the local POTW
Spill and Leak Cleanup—Incorporation of good housekeeping practices at
the facility provides the facility with additional pollution prevention as well
as other benefits. Daily inspection of tanks and equipment for leaks is con-
ducted, and leaks and spills are cleaned up as quickly as possible after being
discovered In addition, the facility incorporated welded joints instead of
flanges into the facility's design wherever possible to reduce the potential for
leaks and to reduce air emissions. Regularly scheduled maintenance is per-
formed on valves and fittings. The facility was also designed as a closed facil-
ity to minimize the accumulation of dust When appropriate, material from
spill and leak cleanup operations are processed through the solvent recovery
unit.
Other—MGK Chaska has incorporated training and written standard opera-
tion procedures into PFPR operations. Facility employees are provided with
initial training as well as yearly refresher training, which mcludes training m
pollution prevention and waste minimization. In addition, the facility conducts
bi-monthly meetings at which pollution prevention topics are emphasized
Records of employee training are maintained at the facility. In addition, the
facility has an employee incentive program that bases employee bonuses, m
part, on adherence to pollution prevention procedures
Documentation of P2 practices include written P2 plans and procedures,
records of facility maintenance and inspections, such as floor washes, and daily
inspections for leaks and spills
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CHAPTER 9
Where to Get Additional P2 Help
This chapter presents additional sources of information, as well as EPA
contacts, that may help the user obtain additional information related
to P2 implementation Specifically, the chapter presents a list of selected
federal P2 programs, a list of EPA regional P2 contacts, and a list of selected
periodicals and directories relating to P2 These lists also include information
on how to reach EPA program personnel and how to access periodicals and
directories.
For copies of documents directly related to the PFPR effluent guidelines, such
as the Technical Development Document (EPA 821-R-96-019), the Economic
Analysis (EPA 821-R-96-017), the Cost Effectiveness Analysis (EPA 821-R-96-
018), or additional copies of this guidance manual (EPA 821-R-97-002), con-
tact the Office of Water Resource Center at (202)260-7786 or by E-mail at:
waterpubs@epamail.epa.gov or fax- (202) 260-0386
Questions specifically related to the effluent limitations guidelines and stan-
dards for the PFPR industry, including the P2 Alternative Option, should be
directed to:
Ms ShanZuskin
Engineering and Analysis Division
Office of Water
U.S. EPA (4303)
401M Street, SW
Washington, DC 20460
Tel (202) 260-7130
Fax (202)260-7185
E-Mail- zuskin shari@epamail.epa gov
Federal P2 Programs and Contacts
Enviro$en$e
EnviroSenSe is EPA's new electronic library of information on pollution preven-
tion, technical assistance, and environmental compliance With free public ac-
cess to the system, EnviroSenSe is aimed at facilitating the sharing of
technologies and experience across private and public sectors, and encourag-
ing pollution prevention technologies suitable for export A list of topics
EnviroSenSe contains information on includes
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CHAPTER 9 Where to Get Additional Help
Pollution Prevention Guidance Manual for the PFPR Industry
¦ Contracts, training opportunities, and news
¦ Federal regulations, executive orders, and laws
¦ Pollution prevention technical information, databases, initiatives
¦ Federal agency and facility information
¦ Technology information, databases, and initiatives
¦ Funding, grants, and contracts information
¦ International resources
Other features include E-mail with thousands of environmental professionals
world-wide, electronic registration for EPA training courses, and key word
searching of full text or abstracts.
To access Enviro$en$e
Via Internet
The address is-
http://es inel gov/index html
The World Wide Web hotline number is (208) 526-6956
Via Modem
Set communications to 8, N, 1; Emulation- ANSI or VT-100.
Telephone Number: (703) 908-2092
EPA Headquarters Information Resource Center
The EPA Headquarters Information Resource Center provides information
support services to EPA staff and maintains a varied collection of environ-
mental resources, including CD-ROMs, an online catalog, and other program-
specific services. The library provides services to the general public and develops
several publications, including newsletters and brochures Library hours are
8:00 a.m. to 5.00 p m ET, Monday through Friday. EPA's Online Library Ser-
vice (OLS) is available through telnet: "epaibm.rtpnc.epa gov". (See Pollu-
tion Prevention Information Clearinghouse (PPIC) and EPA on the World
Wide Web)
EPA on the World Wide Web
EPA's webserver is the primary public access mechanism on the Internet for
EPA. The webserver provides a range of EPA-generated information in elec-
tronic format, and also offers access to OLS, the national online catalog of the
EPA library network It includes the catalogs of the Headquarters Informa-
tion Resource Center and all the Regional libraries The special collection of
the PPIC is cataloged on OLS and is recognized with the call letters "PPC"
Via Internet
EPA's home page on the world wide web:
http.//wwwepa gov
EPA's P2 home page on the world wide web
http //wwwepa gov/opptintr/p2home/
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CHAPTER 9 Where to Get Additional Help
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EPA's Pollution Prevention Research Branch Program
The Pollution Prevention Research Branch at EPA's National Risk Manage-
ment Research Laboratory supports projects and provides technical assis-
tance to encourage the development and adoption of technologies, products,
and P2 techniques to reduce environmental pollution. Pollution prevention
resources developed by the lab are available through the Technology Transfer
and Support Division at:
Technology Transfer and Support Division
26 West Martin Luther King Drive
Cincinnati, Ohio 45268
Phone (513) 569-7562
Fax. (513) 569-7566
A compilation of summaries of current Branch Projects is available from:
Current Projects. Tomasma Bayliss
National Risk Management Research Laboratory
U S. Environmental Protection Agency
26 West MArtin Luther King Drive
Cincinnati, Ohio 45268
Phone (513) 569-7748
Fax (513) 569-7566
National Technical Information Service (NTIS)
Located in the U.S Department of Commerce, the National Technical Informa-
tion Service (NTIS) is the central source for the public sale of U.S Government-
sponsored research, development, and engineering reports It is also a central
source for federally generated machine processible data files. It contains re-
ports on air pollution, acid rain, water pollution, marine pollution, marine eco-
systems, land use planning, fisheries management, solar energy, offshore oil
drilling, solid wastes, traffic noise, and radiation monitoring.
For more information, contact-
Chief, Order Processing Branch
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
Tel: (703) 487-4650
Fax:(703)321-8547
Pollution Prevention Division (PPD)
The Pollution Prevention Division (PPD) within EPA's Office of Pollution Pre-
vention and Toxics was established in 1988 to integrate a multimedia P2 ethic
within EPA and its developing programs, as well as to provide outreach sup-
port to the public and other government departments Its primary role is to
ensure that EPA incorporates P2 into rulemaking efforts and to support P2
efforts by EPA's program offices, EPA Regions, state and local governments,
industry, and the public, m keeping with the Pollution Prevention Act of 1990
99
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CHAPTER 9 Where to Get Additional Help
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PPD staff are involved with or assist EPA offices in a variety of ongoing
projects, including the Source Reduction Review Project, the Common Sense
Initiative, and Design for the Environment. PPD oversees the Pollution Pre-
vention Information Clearinghouse (see related listing), manages the Pollu-
tion Prevention Incentives for State grants program, and manages EPA's
Environmental Accounting project. In addition, PPD coordinates EPA's work
on environmental labeling issues, the development of guidance for environ-
mentally preferable products, and International Standards, and is a collabo-
rator on EPA's life cycle assessment work.
For more information, contact:
Pollution Prevention Division
Office of Pollution Prevention and Toxics
U.S. EPA (7409)
401M Street, SW
Washington, DC 20460
Tel: (202) 260-3557
Pollution Prevention Information Clearinghouse (PPIC)
The Pollution Prevention Information Clearinghouse (PPIC) was established by
EPA in response to the Pollution Prevention Act of 1990 to promote source
reduction. It is a free service containing technical, policy, program, and legisla-
tive information relating to P2 and source reduction. PPIC has three primary
functions: (1) acting as a distribution center for documents; (2) maintaining a
telephone hotline to take document orders and refer callers to other EPA infor-
mation resources, and (3) maintaining a library collection of documents and
publications relating to P2, waste minimization, and alternative technologies.
The library collection is available for browsing in the EPA Office of Pollution
Prevention and Toxics (OPPT) Library during visitor hours (8:30 a.m. to 4:00
p.m. ET) and through EPA's Online Library System (OLS) (See EPA HQ In-
formation Resource Center above). PPIC currently publishes a list of avail-
able P2 resources that they distribute free of charge
Some highlights of the resources available from PPIC.
Pollution Prevention Directory. Directory of publicly sponsored pollution
prevention sources and state contacts available across the United States
Pollution Prevention Publications List. EPA fact sheet, updated periodically,
including forms for ordering documents. Available through PPIC, (202) 260-
1023.
Pollution Prevention News. Free bimonthly newsletter on pollution preven-
tion topics, including reports from EPA offices, people and places in the news,
state programs, and calendar of conferences and events
Also available through PPIC are environmental accounting documents and
software, particularly spreadsheet software for "P2/FINANCE" (Pollution
Prevention Financial Analysis Cost Evaluation). This is a spreadsheet system
for conducting financial evaluations of current and potential investments
P2/FINANCE differs from conventional capital budgeting tools because it
expressly addresses traditional obstacles to the financial justification of pollu-
tion prevention (P2) investments Specifically, it expands the cost and savings
inventory to include indirect and less tangible environmental costs, and uses
100
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CHAPTER 9 Where to Get Additional Help
Pollution Prevention Guidance Manual for the PFPR Industry
profitability indicators and time horizons that capture the longer-term sav-
ings typical of pollution prevention investments. It runs with either Lotus
1-2-3 Version 3 4a for DOS or Microsoft Excel Version 5.0 for Windows. (EPA
742-C-96-001/002)
For more information, contact:
Pollution Prevention Information Clearinghouse
U.S. EPA (MC 7409)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-1023, Fax: (202) 260-4659, E-Mail: ppic@epamail.epa.gov
EPA Regional P2 Contacts
Contacts* for general P2 assistance are
listed by each EPA Regional Office:
Region
Address
Name
Telephone
Fax
1
JFK Federal Building
1 Congress Street
(617) 565-3420
Abby Swaine
Mark Mahon^
(617) 565-4523
(617) 565-1155
(617) 565-3346
2
(2-OPM-PPI)
290 Broadway
New York. NY 1007-1886
(212) 637-3000
Janet Sapadin
(212) 637-3584
(212) 637-5045
3
841 Chestnut Building
Philadelphia, PA 19107
(215) 566-5000
Jeff Burke
Catty Libertz
(215) 597-8327
(215) 597-0765
(215) 597-7906
4
345 Courtland Street, NE
Atlanta, GA 30365
(404) 562-8357
Connie Roberts
(404) 562-9084
(404) 562-9066
5
(HRP-8J)
77 W. Jackson Boulevard
Chicago, IL 60604-3590
(312) 353-2000
Phil Kaplan
(312) 353-4669
(312) 353-5374
6
1445 Ross Avenue, Suite 1200
Dallas, TX 75270
(214) 665-6444
Robert Lawrence
Linda Thompson
(214) 665-6568
(214) 665-6568
(214) 665-7446
7
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7000
Marc Matthews
(913) 551-7517
(913) 551-7065
8
999 18th Street, Suite 500
Denver. CO 80202-2405
(303) 312-6312
Linda Walters
(303) 312-6385
(303) 312-6339
9
75 Hawthorne Street, (H-l-B)
San Francisco. CA 94105
(415) 744-1305
Bill Wilson (waste
minimization)
Eileen Sheehan (water)
(415) 744-2192
(415) 744-2190
(415) 744-1796
10
1299 Sixth Avenue (MD-142)
Seattle. WA 98101
(206) 553-1200
Carolyn Gangmark
(206) 399-4072
(206) 553-4957
"Individual contacts may change over time In such an event, call the main region phone number listed under the address
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CHAPTER 9 Where to Get Additional Help
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Periodicals and Directories
Access EPA. Directory published by EPA's Office of Information Resources
Management. Includes public information tools, major EPA dockets, clear-
inghouses and hotlines, library and information services, state environmental
libraries, and EPA acronyms. 1993 edition, EPA 220-B-008. Available from
the EPA HQ Information Resource Center, U.S. EPA (3404), 401 M Street SW,
Washington, DC 20460. Superintendent of documents, PO. Box 371954, Pitts-
burgh, PA 15250-7954, Cost $24
Guide to Pollution Prevention Funding Organizations. Directory of public
and private organizations that fund pollution prevention research Available
from Pacific Northwest Pollution Prevention Research Center, 1218 Third Av-
enue #1205, Seattle, WA 98101. Tel: (206) 223-1151.
Pollution Prevention Review. Quarterly journal on source reduction and waste
minimization, with emphasis on technical and institutional issues encountered
in industrial settings. Available from Executive Enterprises, Inc., 22 West 21st
Street, New York, NY 10010-6990. Tel: (800) 332-8804.
Pollution Prevention Update. Highlights federal legislation, EPA initiatives,
roundtable activities, and state pollution prevention program achvibes Avail-
able from the National Pollution Prevention Roundtable, 218 D Street SE, Wash-
ington, DC 20003. Tel. (202) 543-7272.
Pollution Prevention Yellow Pages. Lists and describes state and local pollu-
tion prevention programs. Available from National Pollution Prevention
Roundtable, 218 D Street SE, Washington, DC 20003. Tel: (202) 543-7272
Public Information Center Publications List. List of publications available
from the EPA HQ Information Resource Center, U.S. EPA (3404), 401 M
Street SW, Washington, DC 20460.
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P2 Guidance Manual Feedback Survey
1. Please rate each of the following chapters:
Chapter—Title
1—Introduction
2—PFPR Operations
3—P2 Glossary
4—Conducting the P2 Audit
5—Wastewater Treatment Technologies
6—Conducting the Treatability Test
7—Regulatory Compliance Documentation
8—Case Studies
9—Where to Get Additional Help
More Detail
Needed
Right Amount
of Detail
Less Detail
Needed
~
a
a
a
a
~
~
a
~
~
a
~
~
~
~
~
a
~
~
a
~
~
~
~
~
~
~
2. What is the most useful part of the manual?
3. Please list any specfic changes you would suggest.
4. Are there any parts of the promulgated rule that are still unclear?
5. How can this manual be improved to relate the specifics of the rule?
6. Do you feel EPA has communicated guidance information pertaining to this rule
in an effective manner?
~ yes ~ no (please elaborate)
7. If you are from a PFPR facility, whether or not you decide to implement the P2
Alternative Option, are you planning to implement any new P2 practices as a
result of reading this manual and/or attending an EPA PFPR P2 workshop? If so,
which one(s)?
103
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P2 Guidance Manual Feedback Survey
Pollution Prevention Guidance Manual for the PFPR Industry
8. What additional information could EPA provide to make implementing:
• the P2 practices easier:
• the P2 Alternative Option easier
9. Do you find this guidance manual useful for:
Yes No
• Determining compliance with PFPR rule7 ~ ~
• Evaluating PFPR process(es) for P2 opportunities? ~ ~
• Evaluating treatment technologies7 ~ ~
10. Please check the box which most closely describes your company:
~ Pesticide manufactunng/PFPR facility
~ PFPR facility
~ Trade association
~ POTW
~ State or regional EPA perautter
~ Other
11. Please check the box which most closely describes your familiarity with the
following topics prior to this guidance:
Very Somewhat Not at all
Familiar Familiar Familiar
PFPR Operations ~ ~ ~
Effluent Guidelines ~ ~ ~
P2 Alternative Option ~ ~ ~
Pollution Prevention ~ ~ ~
Wastewater Treatment Technologies ~ ~ ~
(fold here to mail)
Ms. Shari Zuskin
U.S. Environmental Protection Agency
Engineering and Analysis Division (4303)
401 M Street, SW
Washington, DC 20460
Place
Stamp
Here
104
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APPENDIX A
PFPR Final Regulation
(40 CFR Part 455)
105
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Wednesday
November 6, 1996
Part II
Environmental
Protection Agency
40 CFR Part 455
Pesticide Chemicals Category,
Formulating, Packaging and Repackaging
Effluent Limitations Guidelines,
Pretreatment Standards, and New Source
Performance Standards; Final Rule
57517
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57518 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CFR Part 455
[FRL-5630-9]
RIN 2040-AC21
Pesticide Chemicals Category,
Formulating, Packaging and
Repackaging Effluent Limitations
Guidelines, Pretreatment Standards,
and New Source Performance
Standards
AGENCY: Environmental Protection
Agency
ACTION: Final rule
SUMMARY: This final regulation limits
the discharge of pollutants into
navigable waters of the United States
and into publicly owned treatment
works (POTWs) by existing and new
facilities that formulate, package and
repackage pesticide products This
regulation covers two subcategories of
the Pesticide Chemicals Point Source
Category—Subcategory C Pesticide
Formulating, Packaging and
Repackaging (PFPR) which includes
PFPR facilities that also manufacture
pesticide active ingredients (PFPR/
Manufacturers) and Subcategory E
Agricultural Refilling Establishments
EPA estimates that there are
approximately 2,600 facilities in the
industry This regulation establishes
effluent limitations guidelines and
standards under the Clean Water Act
including "best conventional pollutant
control technology (BCT), and "best
available technology economically
achievable (BAT)" for existing direct
dischargers, "new source performance
standards (NSPS)" for new direct
dischargers and "pretreatment standards
for existing and new indirect
dischargers (PSES and PSNS)" This
regulation also amends and clarifies the
limitations based on "best practicable
control technology (BPT)" for direct
discharging facilities
Under the final rule refilling
establishments (Subcategory E) will be
required to achieve zero discharge of
wastewater pollutants The final
regulation provides Subcategory C
facilities (herein referred to as "PFPR
facilities") a choice between zero
discharge and the "Pollution Prevention
Alternative " This compliance
alternative was developed in response
to comments on the proposed rule from
the industry and has received a large
amount of industry support in
comments on the supplemental notice
This structure provides a compliance
option to facilities who agree to
implement certain pollution prevention,
recycle and reuse practices Facilities
choosing and implementing the
pollution prevention alternative will
receive a discharge allowance
The final rule will benefit the
environment by removing toxic
pollutants (pesticide active ingredients
and priority pollutants) from water
discharges that have adverse effects on
human health and aquatic life EPA has
estimated the compliance costs and
economic impacts expected to result
from the Zero Discharge/Pollution
Prevention Alternative (1 e , Zero/P2
Alternative) The Agency has
determined that the Zero/P2 Alternative
will result in a similar removal of toxic
pound equivalents per year
(approximately 7 6 million toxic pound
equivalents) as the zero discharge
option alone At the same time, the
Zero/P2 Alternative is expected to result
in a reduced annualized cost ($29 9
million in 1995), no facility closures
and 150 moderate impacts EPA has
determined that both Zero Discharge
and the Zero/P2 Alternative are
economically achievable However,
EPA's addition of the pollution
prevention alternative to achieving zero
discharge provides benefits to the
environment by minimizing the
potential cross-media impacts that
would otherwise occur from hauling
and incinerating the non-reusable
portion of PFPR wastewaters The
provision of an alternative compliance
method also provides flexibility to
industry in meeting the effluent
limitations guidelines and standards
DATES: This regulation shall become
effective January 6, 1997 The
information collection requirements
contained in this rule are included in
two separate Information Collection
Request (ICR) documents The NPDES/
Compliance Assessment/Certification
ICR (No 1427 05) and the National
Pretreatment Program (40 CFR pan 403)
ICR (No 0002 08) OMB has not yet
approved these ICRs, therefore, the
information collection requirements
contained in this rule are not effective
until OMB has approved them Once
OMB has approved the ICRs, EPA will
publish another notice in the Federal
Register to announce OMB's approval
and to amend 40 CFR Part 9 to indicate
the OMB approval number The
compliance date for §§ 455 46 and
455 66 (PSES) is as soon as possible, but
no later than November 6, 1999 The
compliance dates for §§455 45 and
455 65 (NSPS) and §§455 47 and 455 67
(PSNS) are the dates the new sources
commence discharging Deadlines or
compliance with §§455 42 and 455 62
(BPT). §§455 43 and 455 63 (BCT). and
§§455 44 and 455 64 (BAT) are
established in the National Pollutant
Discharge Elimination System (NPDES)
permits
ADDRESSES: For additional technical
information write to Ms Shari H
Zuskin, Engineering & Analysis Division
(4303), U S EPA, 401 M Street SW.
Washington, D C 20460 or send e-mail
to zuskin shari@epamail epa gov or call
at (202) 260-7130 For additional
economic information contact Dr Lynne
Tudor at the address above or by calling
(202) 260-5834
The complete record (excluding
confidential business information) for
this rulemaking is available for review
at EPA's Water Docket. 401 M Street.
SW, Washington, DC 20460 For access
to Docket materials, call (202) 260-3027
between 9am and 3 30 p m for an
appointment The EPA public
information regulation (40 CFR part 2)
provides that a reasonable fee may be
charged for copying
The Technical Development
Document [EPA-821-R-96-019).
Economic Analysis [EPA-821-R-96-
017) and Cost-Effectiveness Analysis
[EPA-821-R-96-018] supporting
today's final rule may be obtained by
writing to the EPA Office of Water
Resource Center (RC-4100), 401 M
Street SW . Washington, DC 20460. or
calling (202) 260-7786
FOR FURTHER INFORMATION CONTACT: For
additional technical information write
or call Ms Zuskin at (202) 260-7130
For additional information on the
economic impact analyses contact Dr
Lynne G Tudor at the above address or
by calling (202) 260-5834
EPA is preparing a PFPR Pollution
Prevention Alternative Guidance
Manual and a series of regional
workshops to aid industry, permit
writers and control authorities in
implementing the final rule A public
announcement will be published in
Federal Register regarding availability
of the guidance manual and the dates
and locations of the regional workshops
SUPPLEMENTARY INFORMATION:
Regulated Entities
Entities potentially regulated by this
action are (1) Those which generate
process wastewater from the
formulation, packaging and/or
repackaging of pesticide products
(excluding those pesticide active
ingredients not covered by the rule), or
(2) those which are agricultural refilling
establishments Regulated categories
and entities include
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57519
Category
Examples of regulated entities
Industry
• Pesticide formulating, pack-
aging and repackaging
(PFPR) facilities,
• PFPR facilities that also
manufacture pesticide ac-
tive ingredients,
• Agricultural refilling estab-
lishments
This table is not intended to be
exhaustive, but rather provides a guide
for readers regarding entities likely to be
regulated by this action This table lists
the types of entities that EPA is now
aware could potentially be regulated by
this action Other types of entities not
listed in the table could also be
regulated To determine whether your
facility is regulated by this action, you
should carefully examine the
applicability criteria in §455 40 and
§ 455 60 of the rule If you have
questions regarding the applicability of
this action to a particular entity, consult
the person listed in the preceding FOR
FURTHER INFORMATION CONTACT section
Preamble Outline
I Legal Authority
II Background
A Clean Water Act
B Pollution Prevention Act
C Updated Industry Overview
D Final Rule
E The Proposed Rule
F The Supplemental Notice
III Summary of Most Significant Changes
from Proposal
A Scope
1 Pesticide Active Ingredients (PAIs)
a Sanitizer Active Ingredients and Pool
Chemicals
b Other Pesticide Active Ingredients
c Liquid Chemical Stenlants
2 Wastewater Sources
B Zero Discharge/Pollution Prevention
Alternative Option
1 Cross Media Impacts and Incineration
Issues
2 Cross-Contamination Policy
3 Request for De Minimis Discharge
4 Pollution Prevention Alternative
C Applicability to On-Site and Stand-
alone Research & Development (R&D)
Laboratories
D Clarification of Issues Concerning PFPR/
Manufacturers
1 Stabilizing versus Formulating
2 On-site Incineration as Zero Discharge
3 Amending and Clarifying of BPT
E Clarification of Refilling Establishments
F RCRA Issues
1"V The Final Regulation
A Pretreatment Standards for Existing
Sources (PSES)
1 Pesticide Formulating Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
B Best Practicable Control Technology
Currently Available (BPT)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
C Best Available Technology
Economically Achievable (BAT)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
D New Source Performance Standards
(NSPS)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
E Pretreatment Standards for New Sources
(PSNS)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
F Best Conventional Pollutant Control
Technology (BCT)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
V Economic Considerations
A Introduction
B Review of the Proposed Regulation
1 Subcategory C PFPR and PFPR/
Manufacturers
2 Subcategory E Refilling Establishments
C Changes to the EIA Since Proposal
Issuance of the June 1995 Supplemental
Notice
D Assessment of Costs and Impacts for the
Final PFPR Regulations
1 Summary of Economic Impact Analysis
Methodology and Data
2 Estimated Facility Economic Impacts
a Subcategory C PFPR and PFPR/
Manufacturers
b Subcategory E Refilling Establishments
4 Regulatory Effects Not Re-Estimated
5 Impacts of Pretreatment Standards for
New Sources (PSNS) and New Source
Performance Standards (NSPS)
a Subcategory C PFPR and PFPR/
Manufacturers
(1) PSNS
(2) NSPS
b Subcategory E Refilling Establishments
6 Cost-Effectiveness Analysis
a Subcategory C PFPR and PFPR/
Manufacturers
b Subcategory E Refilling Establishments
E Regulatory Flexibility Act
1 Analysis of Impacts on Small Business
Entities
2 Analysis of Impacts on Other Small
Entities
VI Unfunded Mandates Reform Act
VII Executive Order 12866
VIII Small Business Regulatory Enforcement
Fairness Act of 1996 (SBREFA)
IX Paperwork Reduction Act
X Water Quality Analysis
XI Non-Water Quality Environmental
Impacts
A Air Pollution
B Solid Waste
C Energy Requirements
XII Regulatory Implementation
A Implementation of the Limitations and
Standards
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
2 Refilling Establishments (Subcategory E)
B Upset and Bypass Provisions
C Variances and Modifications
1 Fundamentally Different Factors
Variances
2 Removal Credits
D Analytical Methods
Appendix A—List of Abbreviations,
Acronyms and Other Terms Used In This
Document
I Legal Authority
This final regulation establishes
effluent guidelines and standards of
performance for the Pesticide
Formulating, Packaging and
Repackaging Subcategories of the
Pesticide Chemicals Point Source
Category under the authorities of
sections 301, 304, 306, 307, and 501 of
the Clean Water Act ("the Act"), 33
USC 1311, 1314, 1316, 1317, and
1361
In accordance with 40 CFR part 23,
this regulation shall be considered
promulgated for purposes of judicial
review at 1 p m Eastern time on
November 20, 1996 Under section
509(b)(1) of the Act, judicial review of
this regulation can be had only by filing
a petition for review in the United
States Court of Appeals within 120 days
after the regulation is considered
promulgated for purposes of judicial
review Under section 509 (b)(2) of the
Act, the requirements in this regulation
may not be challenged later in civil or
criminal proceedings brought by EPA to
enforce these requirements
II Background
A. Clean Water Act
The Federal Water Pollution Control
Act Amendments of 1972 established a
comprehensive program to "restore and
maintain the chemical, physical, and
biological integrity of the Nation's
waters," (section 101(a)) To implement
the Act, EPA is to issue effluent
limitations guidelines, pretreatment
standards and new source performance
standards for industrial dischargers
These guidelines and standards are
summarized in the proposed regulation
at 59 FR 17850, 17851-52 (April 14,
1994)
Section 304 (m) of the Clean Water Act
(33 U S C 1314(m)), added by the Water
Quality Act of 1987, requires EPA to
establish schedules for (1) reviewing
and revising existing effluent limitations
guidelines and standards ("effluent
guidelines '), and (2) promulgating new
effluent guidelines On January 2, 1990,
EPA published an Effluent Guidelines
Plan (55 FR 80), in which schedules
were established for developing new
and revised effluent guidelines for
several industry categories One of the
industries for which the Agency
established a schedule was the Pesticide
Chemicals Point Source Category
Natural Resources Defense Council,
Inc (NRDC) and Public Citizen, Inc .
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57520 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
challenged the Effluent Guidelines Plan
in a suit filed in U S District Court for
the District of Columbia (NRDC et al v
Reilly, Civ No 89-2980) The plaintiffs
charged that EPA's plan did not meet
the requirements of sec 304(m) A
Consent Decree in this litigation was
entered by the Court on January 31,
1992 The terms of the Consent Decree
are reflected in the Effluent Guidelines
Plan published on September 8, 1992
(57 FR 41000) This plan states, among
other things, that EPA will propose and
take final action on effluent guidelines
for the formulating, packaging and
repackaging subcategories of the
pesticide chemicals category by dates
certain
B The Pollution Prevention Act
The Pollution Prevention Act of 1990
(PPA) (42 U S C 13101 etseq , Pub L
101-508, November 5, 1990) "declares it
to be the national policy of the United
States that pollution should be
prevented or reduced whenever feasible,
pollution that cannot be prevented
should be recycled in an
environmentally safe manner, whenever
feasible, pollution that cannot be
prevented or recycled should be treated
in an environmentally safe manner
whenever feasible, and disposal or
release into the environment should be
employed only as a last resort* * *"
(Sec 6602, 42 USC 13101(b) In short,
preventing pollution before it is created
is preferable to trying to manage, treat
or dispose of it after it is created This
effluent guideline was reviewed for its
incorporation of pollution prevention as
part of this Agency effort
According to the PPA, source
reduction reduces the generation and
release of hazardous substances,
pollutants, wastes, contaminants or
residuals at the source, usually within a
process The term source reduction
"include[s] equipment or technology
modifications, process or procedure
modifications, reformulation or redesign
of products, substitution of raw
materials, and improvements in
housekeeping, maintenance, training, or
inventory control " The term "source
reduction" does not include any
practice which alters the physical,
chemical, or biological characteristics or
the volume of a hazardous substance,
pollutant, or contaminant through a
process or activity which itself is not
integral to or necessary for the
production of a product or the providing
of a service " 42 U S C 13102(5) In
effect, source reduction means reducing
the amount of a pollutant that enters a
waste stream or that is otherwise
released into the environment prior to
out-of-process recycling, treatment, or
disposal
The PPA directs the Agency to, among
other things, "review regulations of the
Agency prior and subsequent to their
proposal to determine their effect on
source reduction" (Sec 6604, 42 U S C
13103(b)(2) This directive led the
Agency to implement a pilot project
called the Source Reduction Review
Project that would facilitate the
integration of source reduction in the
Agency's regulations, including the
technology-based effluent guidelines
and standards
C Updated Industry Overview
The pesticide formulating, packaging
and repackaging industry is made up of
two distinct types of activities These
activities result in subcategorization for
purposes of this rulemaking The two
subcategories are referred to as
• Subcategory C Pesticides
formulating, packaging and repackaging
(PFPR) including pesticides
formulating, packaging and repackaging
occurring at pesticides manufacturing
facilities (PFPR/Manufacturer) and at
stand-alone PFPR facilities, and
• Subcategory E Repackaging of
agricultural chemicals at refilling
establishments (Refilling
Establishments)
The pesticide formulating, packaging
and repackaging industry covered by
this rulemaking is made up of an
estimated 2.631 m-scope facilities
These facilities are located throughout
the country, with greater concentrations
of refilling establishments located in the
Midwestern and southeastern states to
serve the agricultural market
The Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) requires
that any substance intended to prevent,
destroy, repel or mitigate any pest must
be registered with EPA and bear a label
directing the safe use of the product 7
USC 136a In addition, production of
all pesticide products must be reported
annually to EPA 7 U S C 136e Thus,
EPA has extensive data on the contents
of pesticide products, their annual
production who formulates, packages
or repackages these products and the
uses for which these products are
registered EPA s Office of Water made
extensive use of this data in its analysis
of the pesticide formulating, packaging
and repackaging industry
Based on 1988 FIFRA establishment
registration data EPA identified the
pesticide formulating, packaging, and
repackaging facilities in the United
States that were using one or more of
the active ingredients that were the
focus of the Pesticide Manufacturing
rulemaking These pesticide active
ingredients are referred to as the "272
PAIs" and were the focus of the survey
questionnaire for the PFPR rule 1988
data collection 1 EPA sent out
approximately 700 questionnaires using
a stratified random sample of these
facilities Based on these survey results,
EPA estimates that for all of the PAIs
covered by the final rule (m-scope 272
and non-272 PAIs), that in 1988 there
were approximately 1,497 facilities
involved in formulating, packaging and
repackaging pesticide products (of
which 413 facilities processed non-272
PAIs only) and approximately 1,134
refilling establishments2
Included in the 1,497 PFPR facilities,
there were 48 pesticide manufacturing
facilities in the pesticide chemicals
manufacturing rulemaking survey
database (58 FR 50637, September 28,
1993) that also formulated and packaged
pesticide products containing any of the
272 PAIs which were the focus of that
rulemaking A detailed description of
the development of this profile is
contained in Section 3 of the Technical
Development Document [EPA-821-R-
96-019) for this final rule
Pesticide formulating is the mixing/
diluting of one or more PAIs with active
or inert ingredients, without a chemical
reaction, to obtain a manufacturing use
or end use product (see § 455 10 of the
final regulation for the definitions of
formulating, packaging, repackaging and
refilling establishment) Pesticide
formulations take all forms Water-based
liquid, organic solvent-based liquid, dry
products in granular, powder, solid
forms, pressurized gases, and aerosols
The formulations can be in a
concentrated form requiring dilution
before application or can be ready to
apply. The packaging of the formulated
pesticide product is dependent on the
type of formulation Liquids generally
are packaged into jugs, cans, or drums,
dry formulations generally are packaged
into bags, boxes, drums, or jugs
Pressurized gases are packaged into
cylinders Some formulations are
packaged into aerosol cans
As described above, the formulating,
packaging and repackaging industry
produces products in different forms
EPA has observed formulating,
packaging or repackaging performed a
number of different ways ranging from
very sophisticated and automated
1 All remaining pesticide active ingredients are
referred to in today s notice as the 'non-272 PAIs
In addition, not all non-272 PAIs are in the scope
of this rulemaking
- EPA has not re-estimaied the number of
refilling establishments based on both 272 PAIs and
non-272 PAIs because EPA believes that there
would not be any refilling establishments that use
only non-272 PAIs
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57521
formulation and packaging lines to
completely manual lines In general, for
liquid products the process involves
mixing the active ingredient with liquid
inert ingredients in a tank and then
transferring the product to containers
For dry products, the active ingredient
may be sprayed in liquid form onto a
dry substrate or it may be mixed in dry
form Dry products may undergo
processes for mixing, grinding, sifting
and finally packaging The formulating
process for aerosol products is the same
as for liquid products, but the packaging
is more complex and involves filling the
container, capping it, drawing a vacuum
on the container, adding propellant
under pressure, and sealing the
container
Some other types of pesticide
products include collars to repel and
kill fleas and ticks, pesticides that are
micro-encapsulated, and pesticides that
are formed into solid shapes
The pesticide industry is changing
and efforts are being made to improve
products to meet demands of consumers
for less toxic and safer pesticides For
example, water-based solutions are
gradually replacing organic solvents in
liquid pesticide formulations
Developments in packaging also are
underway For example, the growing
use of water soluble packages can
reduce worker exposure to pesticides
and minimize problems with disposal of
packaging
The refilling establishments represent
a newer population of facilities that was
identified in the Agency's Survey of
Pesticide Producing EstaDlishments
EPA discovered a significant population
of facilities that reported repackaging
only These facilities are retail and
wholesale dealers of agricultural
chemicals and farm supplies These
facilities repackage pesticides, usually
herbicides, into refillable containers
which are used to transport the
pesticide to the site where it is applied
The use of refillable containers began
to grow during the 1980's (and became
widespread in the 1990 s) to reduce the
number of empty pesticide containers
needing to be disposed of by farmers In
general registrants distribute large
undivided quantities of pesticides to
dealerships (refilling establishments)
where the products are stored in large
bulk tanks The dealer then repackages
the pesticide from the bulk storage tanks
to portable minibulk containers that
generally have capacities of about 110
gallons The increased use of refillable
containers led to an increased amount of
herbicide stored in bulk quantities and
the need to have a secondary
containment system built around the
bulk storage tanks Separate from this
rulemaking, EPA has proposed a
regulation under F1FRA that sets
standards for such secondary
containment structures (59 FR 6712,
February 11, 1994) In addition, many
states (22 have/are developing
secondary containment regulations)
now require secondary containment for
bulk pesticide storage and dispensing
operations
D Final Rule
Today's final rule sets forth an
innovative and flexible, yet
environmentally protective, approach
for the establishment of effluent
limitations and pretreatment standards
under the Act For Subcategory C—
facilities that formulate, package, or
repackage pesticides—EPA is
establishing effluent limitations and
pretreatment standards which allow
each facility to choose to meet a zero
discharge limitation or comply with a
pollution prevention alternative that
authorizes discharge of PAI and priority
pollutants after various pollution
prevention practices are followed and
treatment is conducted as needed (now
characterized as the Zero/P2 Alternative
option) This rule also establishes a zero
discharge limitation and pretreatment
standard for agricultural pesticide
refilling establishments (Subcategory E)
EPA had originally proposed a zero
discharge limitation and pretreatment
standard for PFPR facilities 59 FR
17850 (April 14, 1994) EPA received
comment which argued that the
proposed zero discharge limitation and
pretreatment standard would result in
adverse non-water quality
environmental impacts and that the
scope of the proposed rule should be
refined in a variety of ways Various
members of the PFPR community
commented that the Agency should
adopt a final rule which would require
facilities to engage in pollution
prevention practices and thereafter
discharge de minimis levels of PAI and
priority pollutants in the process
wastewaters Upon receiving these
comments, EPA published a
Supplemental Notice which desctibed
the Zero/P2 alternative option m
addition to some potential changes in
the scope of the rule 60 FR 30217 (June
8. 1995)
Today's rule adopts the Zero/P2
alternative option for PFPR facilities
and changes the scope by reducing the
number of PAIs and wastewater sources
which are addressed Under the Zero/P2
option each owner or operator of a PFPR
facility in Subcategory C will make an
initial choice of whether the facility will
meet zero discharge or comply with the
P2 Alternative This choice can be made
on a product family/process line/
process unit basis rather than a facility
wide basis If the zero discharge option
is chosen, the facility owner/operator
will need to do whatever is necessary,
e g, wastewater reuse or recycle, either
with or without treatment, incineration
on-site or haul the wastewater for
incineration off-site or underground
injection, so that zero discharge of PAIs
and priority pollutants in the
wastewater is achieved
If the P2 Alternative portion of the
option is chosen for a particular PAI
product family/process line/process
unit, then the owner/operator of the
facility must agree to comply with the
P2 practices identified in Table 8 to Part
455 of today's rule for that PFPR family/
line/unit This agreement to comply
with the P2 practices and any necessary
treatment would be contained in the
NPDES permit for direct discharging
PFPR facilities or in an individual
control mechanism with the control
authority, i e , the POTW, for indirect
discharging PFPR facilities (see
403 12(a) for the definition of control
authority) In general. PFPR facilities
choosing the P2 Alternative need only
to submit a small portion of the
paperwork to a permitting or control
authority (e g . initial and periodic
certification statements) The on-site
compliance paperwork is described in
Part XII A 1 of today's notice
Today's rule changes the scope of the
proposed rule in the following ways
First, the rule does not cover PAIs
which are sanitizers, including pool
chemicals Also certain liquid chemical
sterilants that are used on critical or
semi-critical medical devices are not
covered Second, the rule does not
apply to PAIs that are microorganisms,
such as Bacillus thunngiensis (B t)
Third, the rule does not apply to two
groups of PAIs that are mixtures—Group
1 Mixtures include substances which
pose no risks and Group 2 Mixtures
include substances whose treatment
technology has not been identified
Fourth, the pretreatment standards
portion of the rule does not apply to one
PAI and three priority pollutants which
EPA has determined will not pass
through or interfere with POTWs
Today s rule also does not cover
inorganic wastewater treatment
chemicals With regard to wastewater
sources, EPA has decided not to cover
storm water at PFPR facilities or at
refilling establishments through this
rule In addition, there are a few other
wastewater sources such employee
showers, on-site laundries, fire
equipment test water, eye washes and
safety showers, certain Department of
Transportation (DOT) aerosol leak test
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57522 Federal Register / Vol 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
bath water and laboratory water that are
not considered process wastewater
under the final rule
EPA believes that this rule is an
important example of how the Agency
is re-inventing environmental
regulation The Zero/P2 alternative
option being promulgated today is
cheaper for the regulated community to
comply with than the proposed zero
discharge standard The Zero/P2
alternative option is smarter than the
proposed zero discharge standard
because it incorporates flexibility in
choosing which option is best for a
particular product line The Zero/P2
alternative option is cleaner than the
proposed zero discharge standard
because the P2 Alternative reduces
cross-media impacts to the environment
while still achieving, virtually, the same
level of pollutant removal from
discharges of PFPR process wastewaters
(see Section XI for a discussion on the
non-water quality impacts associated
with the final rule)
E The Proposed Rule
On April 14. 1994 (59 FR 17850), EPA
proposed effluent limitations guidelines
and standards for the control of
wastewater pollutants from the
Pesticide Formulating, Packaging and
Repackaging (PFPR) Industry The
proposed rulemaking covered two
subcategories Subcategory C included
stand-alone PFPR facilities as weil as
formulating, packaging and repackaging
at pesticide manufacturing facilities
(PFPR/Manufacturers) Subcategory E,
as proposed, included repackagers of
agricultural pesticides at refilling
establishments ("refilling
establishments") These proposed
guidelines were not intended to apply to
the production of pesticide products
through an intended chemical reaction
(i e , pesticide manufacturing) (For
definitions used in the final rule, see
§455 10 of the final regulation of this
notice ) Furthermore, as discussed in
Section 1 of the proposal Technical
Development Document [EPA-821-R-
94-002], Subcategory E (refilling
establishments) of these guidelines was
not intended to apply to wastewaters
generated by custom blending or custom
application operations when performed
independently or at refilling
establishments The proposed
rulemaking would have established a
zero discharge limitation for wastewater
pollutants from the formulating,
packaging and repackaging of almost all
pesticide active ingredients for both
subcategories covered by this regulation
Only a small number of PAIs were not
completely covered by the proposed
zero discharge, as a result of
disproportionate economic impacts to
small facilities
Due to these impacts, EPA proposed
a partial exemption from these
guidelines for the exterior wastewaters3
from small sanitizer facilities Small
sanitizer facilities were defined as those
facilities which formulate, package or
repackage 265,000 lbs/yr or less of all
registered products containing one or
more sanitizer active ingredients (listed
in Table 8 of the proposed regulation)
on sanitizer-only production lines The
production cutoff of 265,000 lbs/yr
represents the production level (of these
sanitizer products) at the largest facility
that would experience economic
impacts if there was no exemption for
non-interior wastewater sources (See
Section 111 A 1 of this notice for a
description of revisions made to this
exemption)
In addition to the partial exemption
given to "small sanitizers," EPA
proposed to exempt sodium
hypochlorite from coverage under the
pretreatment standards for new and
existing sources (PSES and PSNS) (See
Section III A 1 of this notice for a
description of revisions made to this
exemption) EPA also proposed to
exempt wastewater generated by on-site
employee showers and laundries and
from the testing of fire protection
equipment from the applicability of
these effluent guidelines and standards
In general, these wastewater sources
were excluded from the proposed
regulation because of worker health and
safety concerns (See Section IX A of the
proposed rule or Section 5 of the Final
Technical Development Document
(TDD) [EPA-821-R-96-019] for a more
detailed discussion of wastewater
sources excluded from regulation)
EPA based the proposed zero
discharge limitation for Subcategory C
on pollution prevention, recycle/reuse
and, when necessary, treatment through
the Universal Treatment System (UTS)
for reuse EPA visualized the UTS as a
flexible system consisting of a variety of
treatment technologies that have been
determined to be effective for treating
PFPR wastewaters In calculating
compliance costs, EPA included costs
for various combinations of treatment
technologies consisting of emulsion
breaking, hydrolysis, chemical
oxidation, metals precipitation and
carbon adsorption EPA also included
costs for contract hauling treatment
3 At the time of proposal exterior wastewaters
included Exterior equipment cleaning water floor
wash leak and spill cleanup water safety
equipment cleaning water DOT (Department of
Transportation) aerosol test bath water air
pollution control scrubber water laboratory nnsate
and contaminated precipitation runoff
residuals (sludges) from the UTS for
incineration Because of the estimates of
reduced wastewater volumes based on
the increase in reuse/recycle practices,
the overall volume of wastewaters being
contract hauled off-site for incineration
was not expected to increase Thus, EPA
did not include additional costs for
contract hauling of PFPR wastewaters in
the original proposal Based on
comments, revised costs for the
proposed zero discharge option were
estimated for the Supplemental Notice
(60 FR 30217, June 8, 1995) (Seethe
Final Cost and Loadings Report
(September 1996) in the public record
for a discussion on the changes to the
costing methodology)
EPA based the zero discharge
limitation for Subcategory E on reuse of
wastewater as makeup water for
application to fields, in accordance with
the product label
The subject of the comments on the
proposed rule spanned a variety of
topics, including changes to the scope of
the regulation, EPA's pesticide cross-
contamination policy and its effect on
the industry's ability to meet zero
discharge, increased cross-media
impacts due to contract hauling of
wastewater for incineration to meet zero
discharge, perceived conflicts with the
Resource Conservation and Recovery
Act (RCRA) requirements, and requests
for a discharge allowance when
following specific pollution prevention
practices See Section III of today's
notice for a summary of the changes that
were made to the proposal in response
to comment
F The Supplemental Notice
In response to many of the comments
on the proposed rule, EPA published a
supplemental notice (60 FR 30217) in
the Federal Register on June 8, 1995
EPA published the Supplemental Notice
to obtain public comment on two major
topics and several smaller issues The
first major topic for which EPA
requested comments was related to the
scope and applicability of the
rulemaking Commenters on the
proposed rule had requested that EPA
exempt certain pesticide active
ingredients (PAIs) and certain
wastewater sources from the scope of
the final rule
EPA requested comment on
expansion of the "sanitizer exemption"
to exempt additional sanitizer active
ingredients, remove the exemption's
production limit, and to include both
interior and exterior wastewater sources
in the revised exemption EPA also
requested comment on the exclusion of
some other chemicals including pool
chemicals, microorganisms, mixtures
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and pollutants that have been
determined to not pass through a
POTW (See Section III A 1 of today's
notice for a discussion of these
exemptions, also see Comment
Response Document in the public
record)
In addition to the exclusion of certain
pesticide active ingredients, EPA
solicited comment on the partial or full
exclusion of certain wastewater sources
These wastewater sources included
aerosol leak test bath water, safety
equipment cleaning water, laboratory
equipment rinse water, and storm water
The second major topic for which
EPA solicited comments was a
regulatory option comprised of two
alternatives between which industry
could choose (1) Achieving zero
discharge or (2) incorporating specific
pollution prevention practices and
treatment technologies at the facility
and allowing a discharge of very small
quantities of pollutants This combined
regulatory approach is referred to as the
Zero Discharge/Pollution Prevention
Alternative (Zero/P2 Alternative)
In particular, the supplemental notice
requested comments on the structure of
the Zero/P2 Alternative, the extent of
best professional judgement (BPJ)
allowed, the specific practices included,
the modifications allowed and the
details of regulatory implementation
Overall, the comments received on the
Supplemental Notice were
overwhelmingly supportive of the Zero/
P2 Alternative Furthermore, EPA has
incorporated many of the suggestions
offered in the comments into the Zero/
P2 Alternative found in today's notice
(see Section XII of today's notice for a
discussion of regulatory
implementation)
The other issues for which EPA
solicited comments in the supplemental
notice included the applicability of the
rule to PFPR research and development
facilities and stand alone direct
discharging facilities, the concentrations
found in second and third rinses of a
triple rinse, and the expected burden to
the permitting authorities
III Summary of Most Significant
Changes from Proposal
This section describes the most
significant changes to the rule since
proposal Many of these changes have
resulted from the comments that are
discussed in more detail in the
Comment Response Document which is
contained in the record for this
rulemaking This section will
summarize the changes in the rule
concerning The scope of the rule, the
addition of the Zero/P2 Alternative,
applicability of the rule to research and
development facilities, clarification of
issues for PFPR/Manufacturers,
modification of the existing BPT for
direct dischargers, clarification of the
definition and applicability for refilling
establishments, and RCRA issues
The major comments received on the
supplemental notice are described in
detail in the Comment Response
Document in the public record Those
comments included Support for the
pollution prevention alternative,
requests for self-certification as the
method of implementation for the final
rule comments on the specific practices
listed in the P2 Alternative, and support
for the use of Best Professional or
Engineering Judgement (BPJ or BEJ) by
the permitting or control authority,
respectively
A Scope
At the time of proposal, the scope of
the rule would have included the
formulating, packaging and repackaging
of all pesticide active ingredients (with
the exception of sodium hypochlorite
and the partial exemption of small
sanitizers) and a wide variety of
associated wastewater sources Since
the proposal, EPA has refined the scope
concerning pesticide active ingredients
(PAls) and wastewater sources in
response to comments on both the
proposed rule and the supplemental
notice. The following discussion
summarizes these revisions See the
Comment Response Document in the
rulemaking record for a more detailed
discussion on the changes
1 Pesticide Active Ingredients (PAIs)
a Sanitizer Active Ingredients and Pool
Chemicals
Several changes have been made to
the original "sanitizer exemption," as
proposed In the proposed rule EPA
placed small sanitizer facilities in their
own subgroup within Subcategory C
However, for the final rule, most
sanitizer products have been excluded
from Subcategory C (see § 455 10 of the
final regulation of today's rule for the
definition of sanitizer products) This
exclusion is based on a number of
factors The partial exemption for small
sanitizer facilities that was included in
the proposal was largely based on
disproportionate economic impacts
However, based on comments EPA has
expanded the sanitizer exemption to
include additional chemicals for the
following reasons (1) Sanitizer products
are formulated for the purposes of their
labeled end use to "go down the drain,"
(2) sanitizer active ingredients are more
likely to be sent to POTWs in greater
concentrations and volumes from their
labeled end use than from rinsing
formulating equipment at the PFPR
facility, (3) biodegradation data received
with comments on some of these
sanitizer active ingredients supports the
hypothesis that they do not pass
through POTWs, (4) these sanitizer
active ingredients represent a large
portion of the low toxicity PAIs
considered for regulation at the time of
proposal, and (5) many sanitizer
solutions containing these active
ingredients are cleared by the Food &
Drug Administration (FDA) as indirect
food additives under 21 CFR 178 1010
The exemption now covers both
interior and exterior wastewater
sources In addition, the proposed list of
28 sanitizer active ingredients has been
expanded to incorporate the pool
chemicals exemption as well as to
include home use, institutional and
most commercial antimicrobial active
ingredients, with the exception of liquid
chemical sterilants (including
sponcidals). industrial preservatives
and water treatment micro biocides
other than pool chemicals (as defined in
§455 10 of today's regulation) Certain
liquid chemical sterilant products are
exempt from today's rule, as discussed
in Section III A 1 c Furthermore, based
on comments, EPA has eliminated the
use of a list to define the exempted
sanitizer active ingredients and is
employing a written definition (see
§455 10 of the final regulation for the
definition used in today's final rule)
As mentioned above, EPA has
combined the pool chemicals exemption
into the sanitizer exemption This was
based on comments on the
Supplemental Notice and information
gathered in post-proposal site visits (60
FR 30219) EPA believes that a large
portion of the pool chemicals that were
being reviewed for exemption can and
should also be classified as sanitizer
active ingredients In order to avoid
possible confusion, EPA has decided to
combine these two groups and has
incorporated pool chemicals into the
definition for sanitizer active
ingredients In addition to this change,
the pool chemicals exemption has
undergone another refinement Under
the proposed rule, the only pool
chemical that was exempt was sodium
hypochlorite Under the final rule, EPA
has added several other chemicals to the
exemption These chemicals include
calcium hypochlorite, lithium
hypochlorite, potassium hypochlorite,
chlorinated isocyanurate compounds
and halogenated hydantoins As with
the sanitizer chemicals, these chemicals
are not exempted via a list, but are
instead exempted by definition See
§ 455 10 of the final regulation
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57524 Federal Register / Vol 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations
b Other Pesticide Active Ingredients
EPA has excluded several other
groups of active ingredients from the
final regulation As discussed in the
Supplemental Notice and in the
Comment Response Document,
microorganisms that are considered
PAIs under FIFRA will not be covered
by this regulation and will be excluded
by definition Based on the available
information on the formulation,
packaging and repackaging of such
microorganisms and the generation and
characteristics of wastewaters from such
operations, EPA believes these
pesticides are not formulated in a
similar fashion as other PAIs covered by
this rule Microorganisms which have
registered pesticidal uses are generally
created through a fermentation process,
similar to those found in some food
processing or pharmaceutical plants
Fermentation is a biological process,
whereas other pesticides are
manufactured and formulated through
chemical and physical processes
In addition, almost all the
microorganisms registered as pesticide
products are exempt from the
requirement of obtaining a (residue)
tolerance for pesticides in or on raw
agricultural commodities (40 CFR
180 1001) Under Part 180 Subpart D—
Exemptions From Tolerance—it states
that "an exemption from a tolerance
shall be granted when it appears that the
total quantity of the pesticide chemical
in oi on all raw agricultural
commodities for which it is useful
undei conditions of use currently
prevailing or proposed will involve no
hazard to the public health "
EPA has also excluded a group of
chemicals, referred to in today's notice
as "Group 1 mixtures " This group
includes many herbs and spices (e g ,
rosemary, thyme, peppermint cloves ;,
foods/food constituents plants/plant
extracts (excluding pyrethrins) and
many chemicals that are considered to
be GRAS (generally recognized as safe)
by the Food and Drug Administration as
well as those products exempt from
FIFRA under 40 CFR 152 25 (61 FR
8876, March 6, 1996)(see§ 455 10 of the
final regulation of today's notice lor the
definition of Group 1 mixtures)
There is a second group of mixtures,
Group 2 mixtures," that are being
excluded from the regulation EPA has
not been able to transfer treatability data
for many of these mixtures because the
characteristics that EPA uses for
technology transfer are not easily
identified (e g . molecular weights,
solubilities and aromaticity) For
example, within a given structural
group, PAIs that are aromatic, have high
molecular weights or low solubility m
water have been found to be amenable
to activated carbon adsorption
However, when such characteristics
cannot be identified, EPA cannot
transfer treatability data for carbon
adsorption
EPA previously considered reserving
this group of chemicals for regulation at
a later time, however, after further
research EPA has decided to exclude
these chemicals from the scope of the
final rule One reason, as mentioned
above, is that the treatability data is
insufficient and to obtain treatment
performance data on these mixtures
would be very difficult due to the
inability to transfer data Also, most of
these chemicals in pesticide products
are used as inert ingredients rather than
active ingredients and the total volume
of these mixtures in use in pesticide
products is very small (1 e , Group 2
Mixture PAIs only represent
approximately eight percent of all of
pesticide products) EPA was not able to
develop a definition to cover all the
chemicals in this group due to the lack
of homogeneity between the chemicals
Therefore, Group 2 mixtures will be
excluded from the scope of the final rule
by list as opposed to definition (see
Table 9 to Part 455 of the final
regulation)
There are two other groups of
chemicals that are being excluded from
the final rule Inorganic wastewater
treatment chemicals and chemicals that
do not pass through POTWS Based on
comments and data collected for the
Treatability Database Report and its
Addendum (see the public record for
the rulemaking), EPA has decided to
exclude, from the scope of the final
regulation, inorganic chemicals that are
commonly used as wastewater treatment
chemicals (e g , ferric sulfate, potassium
permanganate, sulfuric acid, carbon,
chlorine, etc ) See Comment Response
Document for a discussion on the
rationale behind this exclusion Many of
these chemicals are also excluded under
the saniuzer/pool chemicals exemption
Again, the use of a definition will be
employed to exclude these chemicals
(See § 455 10 of today's final rule for the
definition) The four chemicals which
are excluded from the pretreatment
standards because EPA determined that
they do not pass through POTWs are
phenol, 2-chlorophenol, 2,4-
dichlorophenol and 2.4-
dimethyiphenol Phenol, as a
constituent in sanitizer products, is
excluded from the rule as it was
excluded under the proposed sanitizer
exemption due to disproportionate
economic impacts See the Comment
Response Document in the rulemaking
record for a further discussion on the
decision to exclude these wastewater
treatment chemicals and the chemicals
that do not pass through
c Liquid Chemical Sterilants
Section 221 of the Food Quality
Protection Act of 1996 (Pub L 104-170)
amended the definition of "pesticide"
in FIFRA to exclude liquid chemical
sterilant products (including any
sterilant or subordinate disinfectant
claims on such products) which are
used on a critical or semi-critical device
(as defined in section 201 of the Federal
Food. Drug, and Cosmetic Act
("FFDCA") (21 U S C 321) See 7 U S C
136(u), as amended Because Congress
has chosen to exclude such sterilant
products from the definition of
"pesticide", EPA has modified the
applicability provisions of this rule so
that the effluent limitations and
pretreatment standards do not cover the
wastewater discharges from the
formulation, packaging, and/or
repackaging of liquid chemical sterilants
for use on critical devices or semi-
critical devices as these terms are now
defined in FFDCA section 201 and
FIFRA section 2(u) See 40 CFR
455 40(0 However, facilities which
formulate, package, or repackage
products containing liquid chemical
sterilants into other types of products,
e g . pesticide products which are not
used on critical or semi-critical devices
introduced directly into the human
body, should be aware that the
wastewaters resulting from the
formulating, packaging, and repackaging
activities are covered by this rule
2 Wastewater Sources
In the proposal, EPA excluded water
from on-site employee showers,
laundries and testing of fire protection
equipment (59 FR 17903) EPA has
added several other wastewater sources
to the exclusion These include Storm
water,4 water used for testing and
emergency operation of safety showers
and eye washes, DOT leak test bath
water from non-continuous overflow
baths (i e , batch baths) where no cans
have burst from the time of the last
water change out, and water used for
cleaning analytical equipment and
glassware and for rinsing the retain
sample container in on-site laboratories
However, the initial rinse of the retain
sample container is considered a
process wastewater source for the final
regulation (See the Comment Response
4 Storm water at PFPR facilities and Refilling
Establishments is covered by the Storm water
Regulations Phase I and II respectively
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57525
Document for a discussion on the
exclusion of these wastewaters)
B The Zero Discharge/Pollution
Prevention Alternative Option
Commenters submitted a variety of
comments which prompted the Agency
to consider the Zero/P2 Alternative
option The most significant are
summarized below (See the Comment
Response Document in the public
record for additional summary of
comment responses and responses to
individual comments)
1 Cross Media Impacts and Incineration
Issues
Commenters on the proposed rule
believe that the zero discharge standard,
as proposed, would lead to a large
increase in cross-media impacts because
the majority of facilities would be forced
to contract haul dilute non-reusable
wastewaters off-site for incineration (or
other off-site disposal) Commenters
questioned the goal of achieving zero
discharge when it leads to an increase
in cross-media impacts
At the time of the proposed rule, EPA
believed that the proposed approach to
achieving "zero discharge" of
wastewater pollutants from PFPR
facilities would result in increasing the
recycling, reuse and recovery of
wastewater pollutants In addition, EPA
based the requirements on the best
practices observed at PFPR facilities
studied as part of the development of
the rule However, based on the
concerns raised by commenters about
the potential cross-media impacts EPA
decided to seek comment on the
pollution prevention (P2) alternative to
zero discharge in order to reduce these
impacts (60 FR 30217) The P2
Alternative to the zero discharge
standard will allow a discharge of
wastewater after waste discharge
reductions are achieved using certain
flow conservation, recycle or reuse and,
under certain circumstances,
wastewater treatment practices Should
a facility choose to comply with the
regulation through the P2 Alternative
the need for off-site disposal is reduced,
thus, the cross-media effects are
reduced
For those facilities that choose to
comply with the final rule by achieving
zero discharge, EPA has revised the cost
model The revisions add costs to
account for increased volumes of non-
reusable wastewaters being contract
hauled for off-site incineration (see the
Final Cost and Loadings Report
(September 1996) for a discussion on
changes to the costing methodology)
The revised cost estimates for the
industry to achieve zero discharge of
wastewater pollutants, including the
additional contract hauling costs, are
still found to be economically
achievable for the industry (See Section
V of today's notice for a discussion on
the economic achievability of the final
regulation)
Commenters also commented that a
significant decrease in incineration
capacity and an increased cost would
result from EPA's combustion policy
which may limit the permitting of new
incinerators or the expansion of
capacity of existing incinerators EPA
has addressed this concern in two ways
First, through the use of the P2
Alternative to zero discharge, this final
rule will allow for the discharge of
much of the non-reusable PFPR
wastewaters that might otherwise be
contract hauled for incineration
Second, as mentioned above. EPA has
revised its costing methodology for the
zero discharge option to include off-site
incineration of these additional non-
reusable wastewaters and has still found
the rule to be economically achievable
by the industry In addition, EPA does
not believe an additional burden will be
placed on incineration capacity This is
supported by a survey, "Hazardous
Waste Incineration 1994," published in
the EI Digest, June 1994 which showed
that while there is increasing demand
for incineration there is still great
untapped capacity The surveyed
commercial incinerators believe that
market saturation, competition with
cement kilns and successful waste
minimization efforts by industry
account for the unused capacity and the
decline in the average price for
incineration [See the memo in the
record entitled Incineration Costs for
PFP Facilities, September 30, 1994 1
2 Cross-Contamination Policy
Commenters also stated that complete
reuse, as proposed, is not achievable
because of EPA's existing policy on
cross-contamination of pesticide
products At the time of proposal EPA
was using a standard of zero for cross-
contamination This meant that an
active ingredient may not be present at
any concentration in a FIFRA registeied
product where it is not listed on the
confidential statement of formula (CSF)
of that product or reported to EPA as an
impurity During the study phase for the
development of the proposal, the
industry practice was to triple rinse
containers and equipment Because of
recent EPA enforcement actions,
industry commented that additional
rinsing is being used to comply with the
cross-contamination policy
Commenters believe that more
aggressive enforcement of a zero-
standard cross-contamination policy
would increase wastewater volumes to
the point that it would not be feasible
to reuse these volumes The commenters
also believe that these factors were not
taken into account when the proposed
zero discharge regulation was
developed According to commenters. a
facility that performs a triple rinse of the
equipment interiors when changing
from formulating one product to
another, may have to perform additional
rinses (e g . a five times rinse) to ensure
a level of zero cross-contamination
Commenters stated that even in cases
where the rinsate from the "triple rinse"
could be stored for use in a future
formulation, the additional rinses create
more rinsewater than could be reused
and that these very dilute wastewaters
would have to be contract hauled for
off-site disposal to achieve zero
discharge Commenters believe this
additional contract hauling of
wastewater not only makes the
proposed regulation economically
unachievable, but increases the
opportunity for cross-media impacts
At the time of the supplemental
notice EPA was reviewing the pesticide
cross-contamination policy EPA has
since published a Notice of Availability
on a more risk-based draft policy in the
Federal Register for public comment (61
FR 1928, January 24, 1996) and expects
publication of the final policy by the
end of 1996 In addition, EPA has
created the P2 Alternative to zero
discharge in this rulemaking which
would allow formulators, packagers and
repackagers to discharge these dilute
non-reusable rinses following the use of
specified pollution prevention practices
3 Request for De Minimis Discharge
Due to the concerns described above,
many commenters requested a discharge
allowance for these excess or non-
reusable wastewaters Commenters
suggested that they would be willing to
agree to use specified pollution
prevention practices and pointed to the
pollution prevention, recycle and reuse
practices described in the preamble to
the proposal (59 FR 17866) and the
technical development document for the
proposal [EPA S821-R-94-0021 In some
cases commenters provided examples of
possible additional practices they would
be willing to agree to use EPA believes
that a discharge allowance ("pollution
prevention allowable discharge") may
provide an added incentive to increase
the use of pollution prevention and
recycle practices, while ensuring that
facilities are maximizing pollutant
reductions in the wastewater while
minimizing cross-media effects
Therefore, in response to the request for
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57526 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
a "de minimis" discharge alternative,
EPA has incorporated the P2 Alternative
into the zero discharge standard for the
final regulation
4 Pollution Prevention Alternative
Several changes have been made to
the P2 Alternative since it was first
presented in the Supplemental Notice
The most significant revision is that a
facility will be able to choose between
achieving zero discharge or an allowable
discharge (using the P2 Alternative) on
a product family/process line/process
unit basis
In the supplemental notice, this
choice was to be made on a facility wide
basis However, based on comments.
EPA believes that the zero/P2
alternative option will be most practical
if facilities can choose zero discharge for
those processes/process units at their
facility that are most amenable to zero
discharge, while choosing the P2
Alternative for other portions of the
facility for which the pollution
prevention practices are most suited
EPA believes that this change will also
reduce burden
In addition. EPA has made some
changes to the listed pollution
prevention practices First, the two
tables of listed practices, as found in
Appendix B of the Supplemental
Notice, have been combined into one
table In addition, based on comments,
revisions have been made to the
language used on the table of listed
practices Under the final rule, any
practice may be modified with an
adequate justification When no
justification is listed for the specific
practice it can be modified via best
professional or engineeringjudgement
(BPJ or BEJ. respectively) EPA believes
this is appropriate due to the unique
and individual situations that may arise
at a particular facility (see the Comment
Response Document in the rulemaking
record or the P2 Guidance Manual for
the PFPR Industry for examples of such
situations) However, for listed practices
where nojustification is listed on the
table a facility will initially have to
submit a request for a modification to
the permitting/control authority for
review and approval The permitting/
control authority is expected to use BPJ
or BEJ to decide if the justification
provided is adequate In addition, the
permitting/control authority will be able
to add or replace practices specified by
the rule with new or innovative
practices that are more effective at
reducing the pollutant loadings from a
specific facility to the environment
EPA has also added some additional
justifications to the table of listed
practices based on comments For
example, EPA will allow facilities to
modify the practice of reusing and/or
storing and reusing rinsates generated
by rinsing of drums containing only
mens when a facility can demonstrate
that the large concentration of the inert
in the formulation creates more volume,
after using water conservation practices,
than could feasibly be reused or when
the concentration of the inert is so small
(i e , perfumes) that the reuse would
cause a formulation to exceed the ranges
allowed in the Confidential Statement of
Formula (CSF)
Based on comment, EPA has also
combined, added and removed other
practices For example, EPA has added
a practice concerning dry formulation
interior equipment cleaning that
specifies that facilities must cleanout
such interiors with dry carrier prior to
any water rinse and that this carrier
material should preferably be stored and
reused in future formulation of the same
or compatible product (or, as a last
resort, properly disposed of as solid
waste) EPA has combined many of the
water conservation practices, such as
use of flow reduction on hoses, use of
low volume/high pressure rinsing
equipment and floor scrubbing
machines, into one listed practice
Finally, EPA has removed the provision
for dedicated equipment that was
contingent on the inability to reuse
interior rinsates Instead, this practice
will be discussed in the P2 Guidance
Manual for the PFPR Industry (See
Table 8 to Part 455 of the final
regulation, for the listed practices and
listed justifications)
Furthermore, EPA has refined the
definition of P2 allowable discharge In
response to comment, this definition
states that "appropriate pollution
control technologies" include not only
those technologies listed on Table 10 of
the regulation, but also include a
pesticide manufacturer s treatment
system or an equivalent system, used
individually or in any combination to
achieve the level of pollutant reduction
determined by the permitting authority
or control authority An equivalent
system is a wastewater treatment system
that is demonstrated in literature,
treatability tests or self-monitoring data
to remove a similar level of pesticide
active ingredient (PAI) or priority
pollutants as the applicable treatment
technology listed in Table 10 to part 455
of the final regulation
Finally. EPA has decided to allow the
control authority to use best engineering
judgement to waive pretreatment at the
PFPR facility prior to discharge to the
POTW under certain circumstances
Under the final P2 Alternative to zero
discharge, an indirect discharger must
pretreat the portion of their allowable
P2 discharge that includes interior
equipment rinsates (including drum
rinsates), leak and spill cleanup water
and floor wash prior to discharge to the
POTW However, EPA will allow the
control authority to waive the
pretreatment requirements for floor
wash and the final interior rinse of a
triple rinse that has been demonstrated
to be non-reusable when the facility
demonstrates that the level of PAls and
priority pollutants in such wastewaters
are at a level that is too low to be
effectively pretreated at the facility and
have been shown to neither pass
through or interfere with the operations
of the POTW The control authority
should also take into account whether
or not the facility has employed water
conservation when generating such a
non-reusable wastewater
C Applicability to On-Site and Stand-
alone Research & Development (R&D)
Laboratories
EPA has clarified the applicability of
the final PFPR regulations to on-site and
stand-alone R&D laboratories (i e , no
PFPR on-site) The final PFPR effluent
guidelines and standards do not apply
to wastewater generated from the
development of new formulations of
pesticide products and the associated
efficacy and field testing (where
resulting product is not manufactured
for sale) This includes such
wastewaters generated at stand-alone
R&D laboratories as well as at R&D
laboratories located on-site at PFPR
facilities EPA received many comments
describing the operations at both on-site
and stand-alone R&D facilities
Commenters believe that wastewaters
generated at these R&D laboratories have
extremely limited reuse potential due to
their experimental nature, as such
formulations may only be produced
once or, at most, for one set of trials
Therefore, commenters believe that the
pollution prevention practices listed in
the Supplemental Notice (for example,
reuse of interior rinsates in future
formulation) are not amenable to these
one-time wastewaters In addition,
experiments require the use of
experimental controls According to
commenters, the addition of rinsates
into the "experimental design could
alter the results of the experiment and
render the data obtained useless " EPA
has taken the above information into
account, in addition to the typically low
quantities discharged from these
operations and believes that the
wastewaters generated by experimental
formulation, efficacy and field testing
can be adequately addressed in permits
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Federal Register / Vol. 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57527
and pretreatment agreements through
BPJ and BEJ, respectively
D Clarification of Issues Concerning
PFPR/Manufacturers
Pesticide Manufacturing is covered by
40 CFR part 455 subparts A and B
However, close to 50 pesticide
manufacturers also perform pesticide
formulating, packaging and repackaging
at their facility (called "PFPR/
Manufacturers") EPA has included a
discussion, below, to aid in clarifying
how the final rule applies to the PFPR/
Manufacturers in regard to three specific
issues First, EPA will clarify the
difference between adding a solvent to
stabilize an active ingredient and adding
a solvent (or other inert ingredients) to
formulate a pesticide product, and
which practice constitutes
manufacturing and which constitutes
formulation Second, EPA will discuss
whether on-site incineration can be
considered as achieving zero discharge
under the PFPR final rule Finally, EPA
will amend and clarify the
interpretation of the 1978 zero discharge
BPT rule for direct discharging PFPR/
Manufacturers and PFPR stand-alone
facilities
1 Stabilizing versus Formulating
Pesticide manufacturers may
sometimes add a solvent (organic or
aqueous) to a manufactured PAI or
intermediate for the purpose of
stabilizing the product (e g , for
transport or storage) The Pesticide
Manufacturing Final Technical
Development Document [EPA-821-R-
93-016, page 1-9] states that dilution of
the manufactured active ingredient is
only covered by the Pesticide
Manufacturing rule when it is "a
necessary step following a chemical
reaction to stabilize the product' Thus,
EPA would like to clarify that
manufacturers can perform such
operations without being subject to the
PFPR effluent guidelines as long as it is
a necessary step to stabilize the product
following a chemical reaction
Typically, such operations are
performed without placing the pesticide
in a marketable container (1 e , they are
shipped in bulk via tank truck, rail car
or tote tank) However, PFPR facilities
should not conclude that they can
receive PAIs (that they do not
manufacture), even in bulk quantities,
and dilute it with solvent or other
carrier without being subject to the
PFPR effluent guidelines, as this would
be considered formulating under
§455 10
2 On-site Incineration as Zero
Discharge
Although EPA proposed zero
discharge limitations based on pollution
prevention, recycle/reuse and treatment
for reuse, facilities may meet this zero
discharge requirement through a
number of other practices These
practices include hauling wastewater to
off-site destinations, such as sites which
have incineration, deep well injection
disposal and centralized (commercial)
wastewater treatment and subsequent
discharge In some cases, wastewaters
are returned to the registrant or
manufacturer In a few instances, on-site
incineration of PFPR wastewaters is
being conducted
EPA received comment requesting
clarification of whether on-site
incineration is an acceptable means of
achieving zero discharge For purposes
of this rule, EPA considers on-site
incineration a valid option for achieving
zero discharge of PFPR process
wastewaters Wet scrubbing devices
used for air pollution control on existing
on-site incinerators at PFPR facilities are
not subject to the PFPR effluent
guidelines The only existing on-site
incinerators at facilities covered by the
PFPR regulation are at facilities which
also manufacture pesticide active
ingredients (PFPR/Manufacturers)
Scrubber wastewater discharges from
these incineration activities are
currently regulated under the pesticide
manufacturing effluent guidelines (40
CFR part 455, subparts A and B, see 58
FR 50638, September 28, 1993) for the
PAIs manufactured at these facilities
On-site incineration at new sources
(i e , NSPS and PSNS), would also
qualify as meeting zero discharge under
the PFPR regulation and scrubber water
discharges from these on-site
incinerators would be covered by the
pesticide manufacturing new source
standards However, scrubber
wastewater discharges from the on-site
incineration of PAIs not regulated by the
pesticide manufacturing rule would
have to be controlled using a BPJ or BEJ
basis
3 Amending and Clarifying of BPT
The 1978 BPT regulation (43 FR
44846, September 29, 1978) established
a zero discharge limitation for direct
discharges from pesticide formulating
and packaging5 facilities This included
pesticide formulating, packaging and
repackaging that occurred at direct
discharge pesticide manufacturing
3 In 1978 repackaging was noi included in the
uile of Subcategory C but was covered by the BPT
regulation and therefore will be included in the
title for the final rule
facilities as well as stand-alone PFPR
facilities 6 The basis for the 1978 zero
discharge BPT limitation was water
conservation, reuse and recycle
practices, with any residual water being
evaporated or hauled off-site to a
landfill However, many facilities that
were direct dischargers in 1978
switched to indirect discharge of
wastewaters through POTWs instead of
achieving zero discharge via recycle and
land filling or evaporation Due to the
1978 BPT regulation, presently, there
should be no direct discharging PFPR
facilities However, the zero discharge
limitation was not interpreted or
implemented in the same way for PFPR/
Manufacturers as it was for stand-alone
PFPR facilities
It is EPA's understanding that
permitting authorities incorporated the
BPT zero discharge standard for PFPR
wastewaters into the pesticide
manufacturers' NPDES permits as a
"zero allowance " A zero allowance
would let a PFPR/Manufacturer
discharge PFPR wastewaters along with
their pesticide manufacturing
wastewaters as long as they did not
exceed the pesticide limitations in the
Pesticide Manufacturing rule The 1978
pesticide manufacturing BPT limitations
were presented as a total pesticides
limit for 49 specific PAIs However, the
more recent BAT and NSPS limitations
(58 FR 50638, September 28, 1993) do
not set a total pesticides limit but,
instead set individual production-based
limitations Since the pesticide
manufacturing limits are based solely on
the manufacturing production and do
not include the PFPR production,
permits could still use a zero allowance
approach to allow discharges of PFPR
wastewater from these combined
facilities
At the time of proposal, EPA did not
believe it was necessary to amend the
1978 BPT because the zero discharge
limitation was comparable to the
proposed standard of zero discharge 7
EPA recognized that the bases for the
1978 BPT and proposed rule were not
identical and that land filling and
evaporation were no longer the best
options for achieving zero discharge (59
FR 17870) However, EPA believed that
6 A stand-alone PFPR facility is a PFPR facility
where either (1) No pesticide manufacturing
occurs, or (2) where pesticide manufacturing
process wastewaters are not commingled with PFPR
process wastewaters Such facilities may formulate
package or repackage or manufacture other non-
pesuade chemical products and be considered a
stand-alone PFPR facility
7 EPA proposed a zero discharge standard for
PSES based on pollution prevention recycle/reuse
and when necessary treatment and reuse and
expected it to be implemented via no flow of
process wastewater
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575E8 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
since both the 1978 BPT and the
proposed rule were largely based on
water conservation, recycle and reuse
practices, facilities could meet BPT in a
manner similar to the proposed rule
Following proposal, EPA received
many comments on and requests for
revision of the BPT regulation from the
PFPR/Manufacturing facilities and trade
associations Commenters raised issues
related to the technical feasibility of
zero discharge for both the proposed
rule and the 1978 BPT rule
Commenters believed that, because
not all wastewaters were reusable as
EPA had assumed, the potential
increase in cross-media impacts
associated with a zero discharge
regulation in addition to the large costs
associated with contract hauling for
incineration made any zero discharge
regulation infeasible The commenters
requested numeric discharge limitations
and/or a "de minimis" discharge
allowance (associated with pollution
prevention practices) for their PFPR
wastewaters and that BPT be revised
accordingly Based on these and other
comments on the proposed rule, EPA
developed the Zero/P2 Alternative for
PSES and BAT (for Subcategory C
facilities) which was discussed in the
Supplemental Notice and revised based
on additional comment for today's final
rule
Commenters also specifically
commented on the need for revision of
the 1978 BPT due to (1) Certain
practices on which the 1978 BPT was
based (for example, land filling and
evaporation) are no longer desirable
because they may cause cross-media
impacts or may no longer be available,
and (2) the changes in PAIs and
pesticide formulation chemistries since
1978 For example, many pesticide
products have been reformulated from
an organic solvent-based product to a
water-based product to avoid the
generation of volatile organic
compounds (VOCs) This has, in many
cases, caused an increase in the volume
of wastewater generated by this
industry In addition, many facilities are
switching to safer, more
"environmentally friendly pesticide
active ingredients which would change
the characteristics of the wastewaters
from those determined in 1978
Commenters believe that EPA must
revise BPT or account for the additional
costs associated with the current
practices that would be utilized to meet
the zero discharge limitation (i e , off-
site incineration)
Based on the comments discussed
above, EPA has decided to amend BPT
for both the existing direct discharging
PFPR/Manufacturers and stand-alone
PFPR facilities to allow them to choose
between zero discharge and the P2
Alternative EPA believes that although
the stand-alone PFPR facilities are
already achieving zero discharge, in
compliance with the 1978 BPT, the
methods they are employing may
potentially result in cross-media
impacts that the use of the P2
Alternative would potentially reduce
Also, these changes will make BPT
consistent with BAT (and PSES) while
essentially achieving the same pollutant
removals and potentially decreasing
cross-media impacts associated with
various off-site disposal methods In
addition, the change to the BPT
limitation that is being promulgated
today for PFPR/Manufacturers will
clarify that the method by which the
zero discharge limitation has been
implemented (i e , use of a zero
allowance) is appropriate
The final PFPR rule will allow
discharge of PFPR wastewaters from
PFPR/Manufacturing facilities in two
specific ways For those facilities
choosing to comply with zero discharge
(as opposed to the P2 Alternative), their
permits should incorporate the "zero
allowance' approach for the PFPR
portion of their operations for the PAIs
that they manufacture For those PAIs
formulated and not manufactured at the
facility, the permit should apply a strict
zero discharge In part, this is because
their pesticide manufacturing
wastewater treatment system may not
consist of the appropriate treatment
technologies for such PAIs or the
treatment system may not be designed
to treat the additional volumes and/or
concentrations of the "non-
manufactured" PAIs
However, PFPR/Manufacturers can
choose the P2 Alternative to zero
discharge Such facilities would not
have to achieve zero discharge or zero
allowance of their PFPR wastewaters
Instead, these facilities would comply
with the practices specified in the P2
Alternative and would receive a "P2
discharge allowance" following
treatment (see § 455 41 of the final
regulation for the definition of P2
allowable discharge) The P2 discharge
allowance can be applied to both
pesticides that are formulated/
packaged/repackaged and manufactured
as well as those that are not
manufactured on-site [Note Facilities
can choose between zero discharge and
the P2 Alternative on a product family/
process line/process unit basis |
The treatment system used to treat the
combined PFPR and pesticide
manufacturing wastewaters must
incorporate treatment that is appropriate
for those PAIs which are not also
manufactured on-site (i e , those PAIs
for which individual pesticide
manufacturing production-based
limitations are not contained in the
NPDES permit) Treatment is deemed
appropriate through the use of
treatability studies found in literature or
performed by the facility, long-term
monitoring data, or Table 10 of the final
rule
As discussed above. EPA is also
amending BPT for stand-alone PFPR
facilities Stand-alone facilities that do
not send their wastewaters to POTWs
can choose to comply with the P2
Alternative or can remain as zero
discharge Facilities choosing the P2
Alternative may have to apply for an
NPDES permit if they do not already
have a permit
E Clarification of Refilling
Establishments
EPA has decided to use the same
general definition for "refilling
establishment" as in the proposed
effluent guideline and the proposed
FIFRA Standards for Pesticide
Containers and Containment rule (i e .
an establishment where the activity of
repackaging pesticide product into
refillable containers occurs) However,
EPA will use different applicability
statements in each of the regulations to
further define the term as appropriate
for the particular regulation (See the
Comment Response Document for
additional discussion) The limitations
and standards of Subpart E of the PFPR
final rule apply to the repackaging of
pesticide products performed by
refilling establishments (a) That
repackage agricultural pesticides, (b)
whose primary business is wholesale or
retail sales, and (c) where no pesticide
manufacturing, formulating or
packaging occurs Subpart E (Refilling
Establishments) is not applicable to
wastewater generated from custom
application or custom blending
F RCRA Issues
A number of commenters requested
clarification concerning the potential for
conflict between the proposed zero
discharge effluent guidelines limitations
and standards and certain requirements
under the Resource Conservation and
Recovery Act (RCRA) Specifically,
commenters requested that EPA explain,
in the final rule, its interpretation of the
wastewater treatment unit exemption
under RCRA (40 CFR 264 1(g)(6),
265 1 (c)(10)) with respect to facilities
regulated by a national effluent
guideline requirement of zero discharge
and how such an exemption would
apply to the Universal Treatment
System (UTS) They also requested
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57529
clarification on the 90-day RCRA
hazardous waste storage limitation
In general, owners and operators of
hazardous waste treatment, storage, and
disposal (TSD) facilities must meet the
standards outlined in 40 CFR part 264
(and part 265 for interim status)
However, the wastewater treatment unit
exemption (40 CFR 264 1(g)(6), 40 CFR
265 1(c) (10)) is intended to exempt,
from certain RCRA requirements,
wastewater treatment units at facilities
that are subject to the NPDES or
pretreatment requirements under the
Clean Water Act8 (for example, PFPR
facilities) The specific definition of
wastewater treatment units that are
exempt from certain RCRA requirements
is found in 40 CFR 260 10 The RCRA
wastewater treatment unit exemption
does not exempt hazardous wastewaters
at these facilities from RCRA
requirements, but does exempt the
facilities from obtaining a TSD permit
for wastewater treatment systems
treating, storing, or generating listed (40
CFR 261 30-33) or characteristic (40
CFR 261 20-24) hazardous wastes EPA
points out that many pesticide active
ingredients are not RCRA listed
hazardous wastes and most PFPR
wastewaters do not exhibit hazardous
waste characteristics, therefore, such
non-hazardous wastewaters would not
be covered by the RCRA Subtitle C
requirements
As mentioned above, many
commenters requested that EPA clarify
whether or not the wastewater treatment
unit exemption can be applied to
facilities that are not discharging their
treated wastewater effluent due to a zero
discharge limitation in a national
effluent guideline Facilities subject to
an effluent guideline which sets a zero
discharge or other limitations or
standards (such as the P2 Alternative)
can, in fact, be eligible for the RCRA
wastewater treatment unit exemption,
assuming that they also satisfy the
exemption's other criteria
Commenters also requested
clarification on how the RCRA 90-day
limit on the storage of hazardous wastes
(40 CFR 262 34) applies to rinsates
being stored for subsequent reuse in
accordance with the PFPR effluent
guidelines Generally, RCRA TSD
permits (or interim status) are required
for facilities that store hazardous waste
on site However, the RCRA regulations
allow facilities that generate hazardous
waste to store the waste without a
permit or interim status provided that
certain criteria, including a 90-day limit
8 Section 402 of the Clean Water Act addresses
the NPDES requirements while Section 307(b)
addresses the pretreatment standards
on storage for large quantity generators,
are satisfied (these criteria are outlined
in 40 CFR 262 34) As mentioned earlier
in this section, most PFPR wastewaters
would not be defined as RCRA
hazardous waste, either because the
wastewater does not meet a RCRA
listing, or does not exhibit any
hazardous characteristic, of course,
generators are still required to make this
determination with respect to their own
wastes (40 CFR 262 11) If a material is
not a hazardous waste, the RCRA
regulations, including storage
requirements, do not apply
For any rinsewaters that potentially
meet a RCRA listing or exhibit a RCRA
characteristic, such rinsewaters being
stored for direct reuse as outlined under
today's final PFPR effluent guidelines
and standards would not be considered
wastes by the Agency (see 40 CFR
261 2(e)(1)) As described elsewhere in
today's rulemaking, these rinsewaters
do not require treatment prior to reuse
and, due to stringent product
specifications, do not contain
constituents that are not needed in the
product being formulated In these
situations where the rinsewaters are not
classified as a waste, the RCRA
regulations (including the generator
requirements and storage requirements)
do not apply However, the RCRA
regulations do require that materials
being stored for reuse not be
accumulated speculatively
(speculatively accumulated materials
are classified as wastes) A material is
not accumulated speculatively if the
person accumulating it shows that the
material is recyclable, has a feasible
means of being recycled, and that
during the calendar year, the amount of
material recycled equals at least 75
percent by weight or volume of the
amount of that material accumulated at
the beginning of the period See 40 CFR
261 1(c)(8) and 261 2(e) (2)(111)
IV The Final Regulation
A Pretreatment Standards for Existing
Sources (PSES)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
Under the final rule. EPA is
establishing a zero discharge
pretreatment standard with a P2
Alternative which allows a discharge to
POTWs The zero discharge standard is
based on pollution prevention, recycle
and reuse practices and, when
necessary, treatment (through the
Universal Treatment System) for reuse
The basis also includes some amount of
contract hauling for off-site incineration
which may be necessary to achieve zero
discharge Compliance with the
alternative (P2 Alternative) is based on
performing specific pollution
prevention, recycle, reuse and water
conservation practices (as listed in
Table 8 to part 455 of the final rule)
followed by a P2 allowable discharge
which requires treatment of interior
wastewater sources (including drum
rinsates), leak/spill cleanup water and
floor wash prior to discharge to a
POTW f
EPA visualized the Universal
Treatment System (UTS) as a flexible
system consisting of a variety of
treatment technologies that have been
determined to be effective for treating
PFPR wastewaters The UTS can
include various combinations of
treatment technologies consisting of
emulsion breaking, hydrolysis, chemical
oxidation, metals precipitation and
carbon adsorption See Section 7 of the
Final Technical Development Document
[EPA-821-R-96-019] for the PFPR
effluent guideline and the proposal (59
FR 17873) for a detail description of the
UTS
EPA determines which pollutants to
regulate in PSES on the basis of whether
or not they pass through, interfere with,
or are incompatible with the operation
of POTWs (including interference with
sludge practices) A pollutant is deemed
to pass through when the average
percentage removed nationwide by
well-operated POTWs (those meeting
secondary treatment requirements) is
less than the percentage removed by
directly discharging facilities applying
BAT for that pollutant In the pesticide
chemical manufacturing final rule,
phenol, 2-chlorophenol, 2,4-
dichlorophenol and 2,4-dimethylphenol
were found to not pass through POTWs
(58 FR 50649, September 28 1993)
Phenol is a PAI that is exempted from
this final rule under the sanitizer
exemption while the remaining three
chemicals are priority pollutants
As discussed in Section III A 1. based
on comments and the addition of the
pollution prevention alternative to the
zero discharge standard for the final
rule, EPA believes it is appropriate to
exempt phenol from the final PFPR
effluent guidelines and standards, and
to exclude 2-chlorophenol. 2,4-
dichlorophenol and 2,4-dimethylphenol
from regulation in the final categoi ical
pretreatment standards (PSES and
9 In individual cases the requirement of
wastewater pretreatmeni pnor to discharge to the
POTW may be removed for floor wash or the final
rinse of a non-reusable triple rinse by the control
authority when the facility has demonstrated that
the levels of PAb and priority pollutants in such
wastewaters are at a level that is too low to be
effectively pretreated at the facility and have been
shown to neither pass through or interfere with the
operations of the POTW
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PSNS) because these three pollutants
have been determined not to pass
through POTWs
EPA has estimated the compliance
cost for the industry to achieve the
pretreatment standards (PSES)
contained in the final rule at $29 9
million annually ($1995) The current
PAI pollutant loading to POTWs is
estimated at 192,789 pounds with PAI
removals achieved by the final
regulation estimated at 189,908 pounds
(assuming zero removals by POTWs
currently—see Cost-Effectiveness
Analysis in Section V D 6) This means
that compliance with the final rule
would remove almost 99% of the
current pollutant loading Due to the
toxic nature of the majority of PAIs, the
equivalent toxic weighted pollutant
removals are 7 6 million pound
equivalents 10
2 Refilling Establishments (Subcategory
E)
EPA is establishing pretreatment
standards for existing refilling
establishments at zero discharge of
pollutants in process wastewaters to
POTWs This standard is based on
collection and storage of process
wastewaters followed by reuse of the
wastewaters as make-up water for
application to fields in accordance with
the product label Based on the PFPR
1988 questionnaire survey, 98 percent of
the existing refilling establishments
achieve zero discharge
Only a small number of refilling
establishments are indirect dischargers
and EPA has estimated that they can
comply with the final pretreatment
standards at nearly zero cost EPA has
estimated that only 19 facilities (of the
1134) do not achieve zero discharge and
they currently discharge to POTWs EPA
estimates a capital cost of only $500
(i e . the approximate cost of a minibulk
tank to store water for reuse) for each
the 19 facilities to meet the zero
discharge PSES standard
10The toxic weighted pollutant removals (in
pound-equivalents) for the final rule are not directly
comparable to the toxic weighted pollutant
removals piesented in the proposal or supplemental
notice This is because (1) The method used to
convert acute toxicity values to chronic value was
revised from a 1 100 rauo to a 1 10 ratio and
reduces the toxic weighting factor for many PAIs
(2) the toxic weighting factor for the pyrethnns was
revised and (3) EPA is using an average non-272
PAI toxic weighting factor based on values for 91
non-272 PAIs instead of using the current loading-
weighted average of the toxic weighting factors for
the 272 PAIs
B Best Practicable Control Technology
Currently Available (BPT)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
As discussed in Section III D 3 of
today s notice, EPA has amended and
clarified the BPT limitations for the
PFPR/Manufacturers and established
BPT limitations for the stand-alone
PFPR facilities (le , PFPR facilities
where no pesticide manufacturing
occurs or where pesticide
manufacturing process wastewaters are
not commingled with PFPR process
wastewaters) In addition to clarifying
the use of "zero allowance" for zero
discharge for PFPR/Manufacturers. EPA
is providing both the PFPR/
Manufacturers and the stand-alone
PFPRs with the opportunity to use the
P2 Alternative
Under the final rule, EPA is amending
the 1978 BPT standard by establishing
a zero discharge limitation with a
compliance alternative which provides
for P2 allowable discharge to surface
waters EPA is also establishing a zero
discharge limitation (without the use of
a "zero allowance" permitting
mechanism) with a compliance
alternative for a P2 allowable discharge
for the stand-alone PFPR facilities (See
Section III D 3 for additional
discussion)
The zero discharge limitation is based
on pollution prevention, recycle and
reuse practices and, when necessary,
treatment and reuse for those PAIs that
are formulated, packaged and/or
repackaged but are not also
manufactured at the facility The basis
also includes some amount of contract
hauling for off-site incineration
Zero allowance is established for
PFPR/Manufacturers for those
pesticides that are formulated, packaged
and/or repackaged and manufactured at
the facility Zero allowance is based on
pollution prevention, recycle and reuse
practices and treatment and discharge
through the manufacturer's wastewater
treatment system within the pesticide
manufacturing production-based
numeric limitations (i e , giving no
allowance for the PFPR wastewater or
its production) This is consistent with
how the existing 1978 BPT zero
discharge requirements have been
implemented by permit writers
The compliance alternative (P2
Alternative) is based on performing
specific pollution prevention, recycle,
reuse and water conservation practices
(as listed in Table 8 to part 455 of the
final rule) followed by a P2 allowable
discharge which requires treatment of
all process wastewaters prior to direct
discharge to surface waters
EPA has estimated that there are no
additional costs or pollutant removals
associated with the BPT limitation for
the PFPR/Manufacturers, as these costs
have already been absorbed by the
industry over the past 18 years as a
result of the 1978 BPT regulation (See
Section IV CI for a discussion on BAT
and the associated costs of compliance)
EPA has not assigned any additional
costs to the stand-alone PFPR facilities
as they are also currently achieving zero
discharge However, facilities may
choose to take advantage of the P2
Alternative in order to achieve a
decrease in cross-media impacts
Depending on the current means of
achieving zero discharge, a facility's
costs may increase or decrease when
switching to the P2 Alternative The
costs may increase initially due to the
cost of installing a wastewater treatment
system due to the associated capitol
costs, however, EPA believes that over
the long term, the annual costs for those
facilities which select the P2 Alternative
would be lower EPA assumes that
facilities will make the choice, to
continue to comply with zero discharge
or to move to the P2 Alternative based,
in significant part, on economic
considerations Therefore. EPA believes
that if the costs associated with the P2
Alternative were significantly higher,
the facility would not alter their current
means of compliance Accordingly, EPA
has assumed no incremental costs as a
result of the addition of the P2
Alternative to BPT for stand-alone PFPR
facilities
2 Refilling Establishments (Subcategory
E)
The existing BPT regulations did not
cover refilling establishments As
discussed in the proposal (59 FR 17870),
the practice of refilling minibulks did
not begin until the late 1980 s, i e , after
the original BPT regulation was
promulgated in 1978 Based on the
PFPR survey. 98 percent of the existing
refilling establishments achieve zero
discharge EPA proposed zero discharge
of process wastewater pollutants as the
BPT limitations for refilling
establishments
In the final regulation EPA is
establishing a BPT limitation for
existing refilling establishments at zero
discharge of pollutants in process
wastewaters to waters of the U S This
limitation is based on collection and
storage of process wastewaters,
including rinsates from cleaning
minibulk containers and their ancillary
equipment, and wastewaters from
secondary containment and loading
pads The collected process wastewater
would be reused as make-up water for
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application to fields in accordance with
the product label Since greater the 98%
of these facilities already achieve zero
discharge and the remaining facilities
discharge to POTWs, the costs
associated for BPT have been estimated
to be nearly zero
C Best Available Technology
Economically Achievable (BAT)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA has established BAT limitations
that are equivalent to the limitations
established for BPT for PFPR/
Manufacturers and stand-alone PFPR
facilities (see Section IV B 1 for
discussion of BPT limitations)
Under the proposal, existing direct
discharge PFPR/Manufacturers were
expected to treat (for reuse) their PFPR
wastewaters in a separate treatment
system from their pesticide
manufacturing wastewater treatment
systems EPA estimated the compliance
costs for these facilities by costing them
for separate PFPR universal treatment
systems
Under the final rule, existing direct
discharging Subcategory C facilities will
have a choice of either complying with
a zero discharge limitation or the P2
Alternative (see Section III D 3 for a
discussion on amending and clarifying
BPT) However, the rule clarifies that in
meeting the zero discharge limitation,
permitting authorities may authorize the
commingling of pesticide manufacturing
and PFPR process wastewaters to meet
the pertinent BAT limitations for
pesticide manufacturers with a zero
allowance for PAIs in PFPR
wastewaters EPA has revised the cost
model to account for changes in the
final rule due to updated analytical
data, changes in scope and the addition
of the P2 Alternative However, EPA
believes that an overestimate of the
costs would result if EPA included costs
for separate UTS systems when the
facilities' current controls, used for
treating PFPR wastewaters (1 e , prior to
commingling with pesticide
manufacturing wastewater) and/or
treating commingled wastewater (: e ,
their pesticide manufacturing treatment
systems), already achieve the BAT
limitation of zero discharge or "zero
allowance "
Thus, EPA is not including these costs
and removals in the total industry
estimate However, EPA has made a
determination of economic achievability
even if these costs would be incurred,
and is presenting the costs and pollutant
removals associated with the (17) direct
discharging PFPR/Manufacturers for
informational purposes When current
treatment in place is not accounted for,
the estimated compliance cost for the
PFPR/Manufacturers to comply with
BAT is $2 8 million ($1995) and is
estimated to remove greater than 99% of
the pollutants This equals 50,248 lbs
(or 71 6 million lb-eq ") of PAIs Again,
EPA believes this cost is economically
achievable
2 Refilling Establishments (Subcategory
E)
EPA is establishing BAT limitations
for this subcategory that are equivalent
to the limitations established for BPT
Since BPT requires zero discharge of
process wastewater pollutants and 98
percent of the existing refilling
establishments already achieve zero
discharge. EPA believes the same
technology basis and discharge
prohibition is appropriate and
economically achievable for BAT
D New Source Performance Standards
(NSPS)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA has set the new source
performance standards for PFPR/
Manufacturers and stand-alone PFPRs
the same as BPT and BAT The new
source standards are established as
follows
EPA has established NSPS limitations
equivalent to the limitations that are
established for BPT and BAT Since
EPA found the Zero/P2 alternative to be
economically achievable for existing
facilities under BPT and BAT on a
facility basis and since new facilities
will be able to choose between zero
discharge and the P2 Alternative on a
product family/process line/process
unit basis, EPA believes that this NSPS
standard does not create a barrier to
entry
2 Refilling Establishments (Subcategory
E)
EPA is establishing NSPS standards
for this subcategory that are equivalent
to the limitation established for BPT and
BAT Since BPT requires zero discharge
of process wastewater pollutants and 98
percent of the existing refilling
establishments already achieve zero
discharge, EPA believes an equivalent
technology basis is appropriate for
NSPS and will not create a barrier to
entry
11 The large number of ioxjc weighted pound
equivalents is driven by a large PFPR production
value reported from a single PFPR/Manufacturer
using coumaphos with a toxic weighting factor =
5 6 x 103
E Pretreatment Standards for New
Sources (PSNS)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA is establishing PSNS standards
for this subcategory that are equivalent
to the standards established for PSES
(i e , zero discharge with a compliance
alternative for a P2 allowable discharge)
EPA believes that the standards
established for PSNS will not create a
barrier to entry as they are equivalent to
PSES which were found to be
economically achievable
EPA did not propose to set PSNS (or
NSPS) equal to PSES (or BAT)
Although the PSNS Zero/P2 Alternative
standard discussed above is a change
from the proposed PSNS, it is consistent
with the Supplemental Notice and
comments submitted. At proposal. PSES
included a partial exemption for
exterior wastewater sources from small
sanitizer facilities (see Section II E of
today's notice for a discussion of the
proposed partial sanitizer exemption),
however, the proposed PSNS did not
include such an exemption and was
found not to create a barrier to entry for
new facilities The partial sanitizer
exemption no longer effects the
economic achievability of the standards
because in response to comments,
sanitizer products are no longer
included in the scope of the PFPR
effluent guidelines Based on the
addition of the P2 Alternative option to
these effluent guidelines and standards
and the associated estimated reductions
in cross-media impacts, EPA believes
that it is appropriate to give new
facilities the opportunity to use the P2
Alternative to meet PSNS
2 Refilling Establishments (Subcategory
E)
EPA is establishing PSNS standards
for this subcategory that are equivalent
to the limitations established for PSES
(i e , zero discharge) In addition, BPT,
BAT and NSPS also require zero
discharge of process wastewater
pollutants, and 98 percent of the
existing refilling establishments already
achieve zero discharge, thus, EPA
believes an equivalent technology basis
is appropriate for PSNS and will not
create a barrier to entry
F Best Conventional Pollutant Control
Technology (BCT)
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
EPA has established BCT limitations
that are equivalent to the limitations
established for BPT This is because
BPT and BAT establish zero discharge
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with a compliance alternative for a P2
allowable discharge and BCT can be no
less stringent than BPT and no more
stringent that BAT EPA believes there
are no additional costs associated with
these limitations
2 Refilling Establishments (Subcategory
E)
EPA is establishing BCT limitations
for this subcategory that are equivalent
to the limitations established for BPT
Since BPT requires zero discharge of
process wastewater pollutants and 98
percent of the existing refilling
establishments already achieve zero
discharge. EPA believes an equivalent
technology basis is appropriate for BCT
V Economic Considerations
A Introduction
Promulgation of the final PFPR rule
requires that the discharge limitations
be both technically and economically
achievable This section of today's
notice reviews EPA's analysis of the
economic impacts of the regulation and
presents EPA's finding that the
limitations are economically achievable
EPA's detailed economic impact
assessment can be found in the report
titled "Economic Analysis of Final
Effluent Limitations Guidelines and
Standards for the Pesticide Formulating,
Packaging, and Repackaging Industry"
(hereafter "final EA") [EPA-821-R-96-
017] The report estimates the economic
effect on the industry of compliance
with the regulation in terms of facility
closures (severe impacts), and
conversions of production lines to
alternate activities and/or compliance
costs exceeding five percent of facility
revenues (moderate impacts) The report
also includes Analysis of the effects of
the regulation on new pesticide
formulating, packaging, and repackaging
facilities and a Regulatory Flexibility
Analysis detailing impacts on small
businesses and small entities A
separate report, "Cost-Effectiveness
Analysis of Final Effluent Limitations
Guidelines and Standards for the
Pesticide Formulating, Packaging, and
Repackaging Industry," presents an
analysis of the cost-effectiveness of the
final regulation All of these analyses
support the conclusion that the effluent
limitations guidelines and standards
contained in the final PFPR regulation
are economically achievable by the
PFPR industry
The discussion of economic
achievability is organized in three
sections, as follows Section V B
summarizes the economic findings for
the regulation as proposed in April
1994 Section V C reviews certain
changes in the regulation since proposal
that were the basis of a supplemental
notice issued in June 1995. and Section
V D presents the economic analysis of
the final regulation, as delineated in the
preceding sections of this preamble
B Review of the Proposed Regulation
The April 14, 1994 notice of proposed
rulemaking (59 FR 17850) included a
description of the anticipated economic
impacts of proposed effluent limitations
guidelines and standards for the PFPR
industry These economic impacts are
briefly reviewed below (See Section
II E for a review of the proposed
regulation)
At proposal, BCT and BAT
requirements were proposed to be
equivalent to the 1978 BPT
requirements, therefore, no additional
costs were expected for compliance
with the BCT and BAT limitations
Accordingly, the EIA focused on
analyzing alternative PSES options for
the two industry subcategories
1 Subcategory C PFPR and PFPR/
Manufacturers
Since completion of the proposal EIA,
EPA has continued to review its
information regarding the structure of
the PFPR industry and has increased its
estimates of the numbers of facilities
using only non-272 PAIs that would
potentially be subject to the Subcategory
C regulation As a result. EPA's
estimates of the number of affected
facilities and the impacts and costs of
the proposed regulation are higher than
those presented at proposal For
example, at proposal, EPA estimated
that Subcategory C included 1,479
water-using facilities that were
potentially subject to regulation Using
the newer population estimates, EPA
now estimates that under the proposal
a total of 2,018 water-using facilities
would have been potentially subject to
regulation The increase in this estimate
comes entirely from the increased
estimate of the number of facilities
using only non-272 PAIs 12 The
following discussion of the proposed
Subcategory C regulation reflects these
updated estimates of the numbers of
facilities, costs, and impacts
For the re-estimated proposed rule,
EPA estimates that 2,018 Subcategory C,
water-using facilities were potentially
subject to regulation Of these 2.018
facilities, 943 used the 272 PAIs that
EPA originally considered for
regulation13 and 1,075 used only the
12 Due to changes in scope for the final regulation
1411 water using facilities will be potentially
subject to the final regulation
13 Many of these facilities also used non-272 PAIs
in addition to the 272 PAIs
additional non-272 PAIs EPA estimates
that 1,142 of these facilities would incur
total annualized compliance costs of
$719 million in 1995 dollars14 under
the proposed rule of zero discharge
The EIA for the proposed regulation
used three primary impact measures
• Severe impacts, which were defined
as facility closures,
• Moderate impacts or facility
impacts short of closure, which were
defined as line conversions or
incurrence of annualized compliance
costs exceeding five percent of facility
revenue, and
• Employment losses, which, for the
impact analysis, were assumed to
accompany facility closures and line
conversions (but not incurrence of
annualized compliance costs exceeding
5 percent of facility revenue)
Under the proposed PSES
requirements and using the updated
estimate for the number of non-272 PAI-
using facilities. EPA estimates that three
facilities would close as a result of
proposed regulation, while 327 facilities
would incur moderate impacts In
addition, under the proposed zero
discharge rule, EPA conservatively
estimates total job losses at facilities
incurring impacts at 890 full-time
employment positions EPA judges the
proposed regulation as economically
achievable using these updated impact
values that are based on the higher
number of non-272 PAI-using facilities
In addition to the facility impact
analysis, EPA analyzed the cost-
effectiveness of the proposed regulation
for Subcategory C facilities Cost-
effectiveness is calculated as the ratio of
the incremental annual costs in 1981
dollars to the incremental pounds-
equivalent of pollutants removed for
each option Using the updated
estimates of costs and removals for the
proposed regulation. EPA estimates total
pollutant removals of 505,235 pounds,
or 38 9 million pounds-equivalent on a
toxic weighted basis, and an average
cost-effectiveness value of $1 65 per
pound-equivalent 15 10 EPA considers
the proposed option to be cost-effective
14 The costs of regulatory compliance are ail
reported in 1995 dollars In the EIA and the Federal
Register Notice for the reguldtion at proposal and
in the Supplemental Nonce regulatory compliance
were reported in 1988 dollars, the base year of the
PFPR industry survey All cost estimates including
the proposal and the supplemental notice have been
brought forward to 1995
,sThe toxicity of the non-272 PAIs used in
generaung this cost-effecuveness value was
estimated as the average pre-compliancc loading-
weighted average toxicity of the 272 PAIs
,GAt proposal EPA reported an average cost-
effectiveness, or the cost-effecuveness value
calculated relauve to the baseline of no regulation,
and an incremental cost-effecuveness or the cost-
effecuveness relauve to the next less stnngeni
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57533
For analysis of the final regulation,
EPA revised the toxic weighting factors
to reflect additional information on the
toxicity of the PAIs In general, the
revisions reduced the estimated toxicity
of the PAIs subject to regulation (see
Section V D 6, below, which contains
the discussion of the cost-effectiveness
analysis for the final regulation) Using
these revised toxic weighting factors
and also taking into account the
updated estimates of costs and pollutant
removals for non-272 PAI-using
facilities, EPA estimates that the
proposed regulation would remove an
estimated 23 2 million pounds-
equivalent, yielding a cost-effectiveness
value of $2 77 per pound-equivalent
($1981)
2 Subcategory E Refilling
Establishments
At proposal, an estimated 1.134
refilling establishments (Subcategory E
PFPR facilities) were potentially subject
to regulation EPA estimates that 98
percent of these facilities, were already
in compliance with the proposed
Subcategory E limitations and
pretreatment standards All but 19 of the
1,134 existing facilities were expected to
incur no costs to comply with the
proposed option The remaining 19
facilities were expected to achieve
compliance with no significant
additional cost17 (See Section VI B 2)
No economic impacts were estimated to
occur due to compliance with the
proposed rule
C Changes to the EIA Since Proposal
Issuance of the June 1995 Supplemental
Notice
In response to public comments on
the regulation, EPA issued a
Supplemental Notice (60 FR 30217) on
June 8, 1995 that solicited comment on
proposed changes in the scope of the
PFPR regulation for Subcategory C
facilities and on the Zero/P2
Alternative In addition, EPA revised
the cost estimating methodology and
economic impact estimates
As discussed in Section III B 4 of
today's notice. EPA estimated
compliance costs for each facility to
comply with the Zero/P2 Alternative
option Each facility was assumed to
choose either zero discharge or the P2
Alternative for compliance, depending
regulatory ophon considered However the
incremental calculation and the comparison are no
longer relevant as the alternative options at
proposal are no longer under consideration For this
reason in the current discussion EPA is reporting
only the cosi-effecuveness value calculated relative
to the baseline of no regulation
17 A capital investment of approximately $500
was estimated for each of these facilities
on which alternative would impose the
lower annualized costs on the facility
For the Supplemental Notice. EPA
estimated total annualized compliance
costs for facilities covered under PSES
at $43 4 million, in 1995 dollars, or 40
percent less than the costs for the
proposed regulation Under the Zero/P2
Alternative option, no facilities were
assessed as closures as the result of the
compliance requirements, while 208
facilities were assessed as incurring
moderate impacts 18 The comparable
values for the regulation for the
proposal (re-estimated using the revised
cost previously discussed) are 3 facility
closuies and 327 facilities with
moderate impacts
D Assessment of Costs and Impacts for
the Final PFPR Regulations
This section describes the impact
measures used in the Economic
Analysis, the estimated impacts
associated with the final rule, impacts
on new sources, and the cost-
effectiveness analysis As discussed
below, EPA is promulgating the
regulation for Subcategory E facilities as
presented at proposal with storm water
now exempted, but the analysis of costs
and impacts for the Subcategory E
regulation remain the same as presented
at proposal Accordingly, the following
discussion focuses on the Pretreatment
Standards for Existing Sources (PSES)
regulation for Subcategory C facilities
1 Summary of Economic Analysis
Methodology and Data
The data sources and methodology for
analyzing economic impacts remain the
same as used at proposal and for the
Supplemental Notice For a more
detailed discussion of the methodology
used in the economic impact analysis,
see the preamble for the PFPR
regulation at proposal (59 FR 17850),
the proposal EIA report and final EA
report
The economic impact analysis
measures three types of primary
impacts severe impacts (facility
closures), moderate impacts (facility
impacts short of closure), and job losses
Each impact analysis measure is
reviewed briefly below
• Severe Impacts Severe impacts,
defined as facility closures, were
assessed on the finding that the
regulation would be expected to cause
a facility to incur, on average, negative
after-tax cash flow over the three-year
period of analysis This analysis was
performed for PFPR/Manufacturers and
l8The cost and impact values for the
Supplemental Nonce regulation reflect updaung of
the estimates of non-272 PAI-using facilities
for facilities that do not manufacture
PAIs, but receive at least 25 percent of
their revenue from PFPR activities
Facilities with relatively low reliance on
PFPR activities as a source of revenue
(i e , less than 25 percent of revenue)
were excluded from this analysis
because EPA does not anticipate that
such facilities would close in entirety
because of costs of regulatory
compliance associated with PFPR
activities EPA also did not include
PFPR facilities from Subcategory E
(refilling establishments) in this analysis
largely because of their relatively low
reliance on PFPR activities as a source
of revenue (an average of 15 percent)
• Moderate Impacts Moderate
impacts were defined as a financial
impact short of entire facility closure
and were analyzed in two ways First.
PFPR facilities subject to the
Subcategory C regulation and with less
than 25 percent of revenue from PFPR
activities were assessed for line
conversions by comparing the after-tax
return on assets (ROA) from PFPR
activities after regulation with the ROA
estimated to be achievable in an
alternative line of business Facilities for
which the post-compliance ROA for
PFPR activities was found to be less
than the return achievable in an
alternative line of business were
assumed to switch out of PFPR
operations Second, all Subcategory C
and E facilities, regardless of PFPR
revenue reliance, were assessed for the
incurrence of total annualized
compliance costs exceeding five percent
of facility revenue
• Employment losses Possible
employment losses were assessed for
facilities estimated to close as a result of
regulation and for facilities estimated to
convert PFPR lines to an alternative
business activity EPA believes that the
estimates of employment loss resulting
from this analysis are highly
conservative because of the assumption
that line conversions would result in
loss of employment for a facility's PFPR-
related employment More realistically,
EPA expects that line conversions will
not generally lead to full loss of PFPR-
related employment
As in the economic impact analysis
for the proposed PFPR regulation, these
analyses for the final regulation assume
that PFPR facilities would not be able to
pass the costs of compliance on to their
customers through price increases
Analysis of pesticide product markets
and the likely response of pesticide
product customers to price increases (as
discussed in the proposal EIA),
indicates that a substantial number of
facilities should recover some part of
their compliance costs through price
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57534 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
increases Thus, the analyses of
compliance cost and impacts overstate
the seventy of the regulation's financial
burden on the PFPR industry
EPA extrapolated information on
compliance costs, pollutant loadings,
and the frequency of facility-level
compliance impacts from data on
facilities in the original PFPR mdustiy
survey to analyze the technical and
economic impacts of regulating the
additional non-272 PAIs 19 In the
following discussion, EPA has not
separated the estimated costs or impacts
according to which set of PAIs facilities
are estimated to use Additional details
of the analysis of costs and impacts for
the facilities using the different sets of
PAIs may be found in the final EA
Although the impact analysis
methodology for the final regulation is
unchanged from proposal (see the
Proposal EI A), its application has been
changed for analyzing the Zero/P2
Alternative This regulatory option was
analyzed for each sample facility as part
of two separate compliance approaches
(1) Zero discharge and (2) pollution
prevention in combination with
treatment followed by discharge (see
Section IV A 1) Facilities were assumed
to adopt the compliance approach with
the lower total annualized compliance
cost including both annual operating
and maintenance costs and an annual
allowance for capital outlays Although
most facilities were estimated to achieve
compliance by pollution prevention and
treatment, some were estimated to
comply by zero discharge Thus, the
combination of the analyses for the two
separate compliance approaches yields
the aggregate analysis for the final
regulation for Subcategory C facilities
''Although the PFPR industry survey focused on
facilities using the original 272 PAIs. some of these
facilities were also found to use one or more of the
additional non-272 PAIs in their PFPR acuvities
Dunng site visits EPA also observed PFPR
operations at several facilities that process both
original 272 and non-272 PAIs Thus, the set of
facilities used for extrapolating financial and
technical information to facilities using the non-272
PAI chemicals and the impacts of bringing these
addiuonal PAIs under regulation also includes
informauon on facilities that use these non-272
P\Is
EPA believes this methodology provides
a realistic appraisal of the costs and
impacts of the final regulation as it
embodies the compliance decision that
facility management is expected to face
in deciding whether to comply by zero
discharge or by pollution prevention in
combination with treatment followed by
discharge In addition, because EPA's
analysis considers both capital and
operating costs, EPA believes that the
findings from the compliance decision
analysis will reasonably approximate
facility managements' findings
regarding choice of the less financially
burdensome compliance approach In
addition, under the final rule, facilities
will be able to make the choice between
zero discharge and the P2 Alternative on
a product family/process line/process
unit basis, which will give them even
more flexibility in their compliance
choice
2 Estimated Facility Economic Impacts
a Subcategory C PFPR and PFPR/
Manufacturers
The costs and impacts for the final
regulation applicable to PSES
Subcategory C facilities are discussed in
this section and are compared with the
values estimated for the proposed and
supplemental notice regulations In
addition, the cost and impacts for the
final regulation are compared with those
that EPA estimates would occur if
facilities were not provided the
flexibility to choose the preferred
compliance approach from the zero
discharge and pollution prevention
allowable discharge alternatives These
comparisons show that the final
regulation provides a more economical
and less financially burdensome
approach to achieving desired discharge
reductions than the proposed, and
otherwise previously noticed,
requirements considered
The following comparisons with the
proposed regulation are relative to the
cost and impact values based on the
new estimates of the number of facilities
using only non-272 PAIs As noted
previously, these revisions increased the
costs and impacts estimated for the
proposed regulation The following
discussion will show that the costs and
impacts for the final regulation are
substantially less than the updated
estimates for the proposed regulation
Although this discussion will not
include comparisons with the values for
the proposed regulation as originally
published. EPA points out that the costs
and impacts for the final regulation are
also markedly less than the original
estimates of costs and impacts for the
proposed regulation
Of the 2.018 water-using Subcategory
C facilities re-estimated to be subject to
the regulation at proposal. EPA
estimates that 506 facilities, or 25
percent, including baseline failures, will
incur costs in complying with the final
Subcategory C PSES regulation Total
annualized compliance costs for these
facilities are estimated at $29 9 million,
in 1995 dollars (see Table 1, below)
Excluding baseline closures from the
cost analysis reduces the number of
facilities expected to incur costs to 421
facilities and total annual costs to $24 2
million, in 1995 dollars In estimating
the costs of the final regulation,
facilities were assigned to the
compliance option—zero discharge or
the pollution prevention alternative—
with the lower total annualized
compliance cost From this analysis, 69
percent of the cost-incurring facilities
(including baseline failures) were
expected to select the P2 Alternative
with the remaining 31 percent selecting
zero discharge
No facilities are projected to close
under the final regulation. A total of 150
possible line conversions (a moderate
impact) are estimated EPA does not
generally expect that line conversions
will result in employment losses
However, to be conservative in its
analysis, EPA estimated the maximum
potential employment loss associated
with the regulation by assuming that all
PFPR employment would be lost in
facilities with line conversions From
this assumption, the upper bound
employment loss for the final regulation
is estimated at 458 full-time
employment positions (FTEs)
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57535
Table 1 —Estimated Costs and Impacts of the Final, Proposed and Supplemental Notice PSES Regulation
for Subcategory C Facilities
Number of fa-
cilities incur-
ring costs
Total
annualized
compliance
cost ($1995,
millions)
Severe
impacts t
Moderate
impacts"
Maximum po-
tential employ-
ment loss+t
Proposed Regulation
1,142
$71 9
3
327
890
Supplemental Notice
709
43 4
0
208
634
Final Regulation—Costs Including Baseline Closures
506
29 9
0
150
458
Rnal Regulation—Costs Excluding Baseline Closures
421
24 2
t Severe impacts are defined as facility closures All facility employment is assumed to be lost as the result of a facility closure
" Moderate impacts are defined as line conversions and/or total annual compliance costs exceeding 5 percent of total facility revenue EPA
does not expect that employment losses would generally accompany line conversions, however, for this analysis, EPA assessed the maximum
potential loss based on the assumption that all employment associated with PFPR activities would be lost as a result of a line conversion
Tf Employment loss for the proposed regulation includes the estimated employment loss in facility closures and the worst case estimate of em-
ployment loss in facilities with line conversions The reported employment loss for the Supplemental Notice and Final Regulation reflects no facil-
ity closures and includes only the worst case employment loss in facilities with line conversions
In addition to presenting the
estimated costs and impacts for the final
regulation. Table 1 also presents the
comparable values for the proposal (re-
estimated) and the supplemental notice.
As shown in the table, the expected
burden of the regulation has fallen
considerably from proposal through
supplemental notice to the final
regulation From proposal (re-estimated)
to final, the number of Subcategory C
facilities expected to incur costs has
fallen from 1,142 to 506 facilities, or 56
percent20. This can be attributed to the
reduction in scope of certain PAIs and
wastewater sources as well as to the
addition of the P2 Alternative as a
compliance option to zero discharge
The estimated drop in total annual
compliance cost, from $71 9 million to
$29 9 million ($1995), represents an
even greater reduction from proposal, at
58 percent As noted above, no severe
impacts are assessed for the final
regulation while 3 facility closures were
estimated for the proposed regulation
Finally, the number of moderate
impacts and potential employment
losses are also substantially reduced
from proposal, falling by 54 percent and
49 percent, respectively In summary,
under the final regulation, the number
of facilities estimated to incur costs, the
expected cost, and the facility impacts
are considerably less than estimated for
the proposed regulation
EPA also believes that the final
regulation is superior to the other
options considered because of the
flexibility it provides to facilities in
deciding how to achieve compliance In
particular, by allowing facilities to
choose the less expensive compliance
approach—the pollution prevention
alternative or zero discharge—the
20 All comparisons with the proposed regulation
and supplemental notice arc based on the analyses
including baseline closures
regulation achieves substantial
pollution reductions but at substantially
lower costs and economic impacts than
would occur if the regulation allowed
compliance by only one of the possible
approaches 21 Moreover, EPA notes that,
by encouraging consideration and use of
pollution prevention as a compliance
approach, the final regulation will
reduce the potential for cross-media
impacts that would occur under a strict
zero discharge requirement The
regulation achieves these benefits with
only a very modest reduction in the
expected pollutant removals that would
be achieved under a zero discharge
regulation Specifically, EPA estimates
that the final regulation will remove
189.908 pounds or 98 5 percent, of the
estimated 192.789 pounds of pollutant
discharges subject to control by the final
regulation (assuming zero removals by
POTWs currently—see Cost-
Effectiveness Analysis in Section V D 6)
EPA estimates that only 2,881 pounds,
or about 1 5 percent of the pollutant
loadings subject to the final regulation
will continue to be discharged to
POTWs
Finding of Economic Achievabihty
The final regulation achieves
substantial reductions in harmful
pollutant discharges at very modest
economic burden to the PFPR industry
Under a conservative assumption that
facilities will recover none of their
compliance costs through price
increases, the regulation is estimated to
impose no severe impacts (i e , facility
closures), 150 moderate impacts (i e ,
line conversion or annualized
compliance cost exceeding 5 percent of
21 EPA has worded the final regulation to allow
facilities to make the choice between zero discharge
and the pollution pre\enuon alternative on a
product family/process unit/process line basis (as
opposed to a full facility basis) However EPA
could not esumaie costs on this basis
facility revenue), and a worst-case
employment loss of 458 FTEs In
addition, the final regulation provides
industry with considerable latitude in
deciding how to comply with the
regulation—that is. by zero discharge or
pollution prevention and treatment In
this regard, EPA's analyses of the
selected compliance approach may
overstate compliance costs because the
analyses assume application of one
approach throughout the facility instead
of a more customized choice of
compliance approach by PFPR line
Also, EPA estimates that a relatively
small fraction—25 percent—of the
facilities potentially subject to the
proposed regulation are likely to incur
costs in complying with the final
regulation That such a small fraction of
the industry is expected to incur costs
reflects in large part EPA s decision to
exclude additional PAIs and
wastestreams from coverage under the
final regulation Finally, EPA notes that
the aggregate costs and impacts
estimated for the final regulation are
substantially less than those estimated
for the proposed regulation, both as
analyzed for the original proposal and
as analyzed on the basis of the higher
estimate of non-272 PAI-using facilities
In light of these very modest impacts
estimated for the final regulation, EPA
finds that the final PSES regulation for
Subcategory C facilities is economically
achievable
b Subcategory E Refilling
Establishments
The regulatory approach and costing
methodology for Subcategory F facilities
is unchanged from that presented at
proposal with the exception that storm
water is no longer considered a process
wastewater subject to this regulation
The analysis of costs, loadings, and
economic methodology at proposal
stands as previously presented
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57536 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
EPA is establishing BPT and BAT
regulations for Subcategory E facilities
set to zero discharge (equivalent to
PSES) EPA's survey of the PFPR
industry indicated that no Subcategory
E facilities are direct dischargers
Accordingly. EPA estimates that the
Subcategory E portion of the PFPR
industry will incur no costs for
complying with the BPT or BAT
requirements
4 Regulatory Effects Not Re-Estimated
Because the aggregate compliance
costs and facility impacts estimated
under the final regulation are
substantially less than those estimated
for the regulation as presented at
proposal, EPA did not re-evaluate the
following economic measures for the
final regulation community impacts,
foreign trade effects, impacts on firms
owning PFPR facilities, the direct
economic benefits to facilities of
pollution prevention practices, and the
labor requirements The analysis of
these additional impact categories
depends on the estimated aggregate
costs for the regulation and on the
results of the facility impact analysis
With the final regulation estimated to
impose aggregate compliance costs that
are 56 percent less than originally
estimated for the proposed regulation
and to cause no facility closures
(compared to the 2 closures originally
estimated at proposal), EPA concluded
that the analysis for these additional
impact categories under the final
regulation would find less
consequential effects than had been
originally estimated at proposal
Because EPA had judged the slight
impacts estimated at proposal for the
additional impact categories to be
consistent with an economically
achievable regulation, EPA, therefore,
concluded that the impacts under the
final regulation for these additional
impact categories would also be found
consistent with an economically
achievable regulation As a result, EPA
decided not to expend the resources that
would be necessary to re-estimate and
re-document the lower impact levels for
these additional impact categories
5 Impacts of Pretreatment Standards for
New Sources (PSNS) and New Source
Performance Standards (NSPS)
a Subcategory C PFPR and PFPR/
Manufacturers
(1) PSNS
EPA is setting PSNS (Pretreatment
Standards for New Sources) for
Subcategory C facilities equal to PSES
limitations for existing sources In
general, EPA believes that new sources
will be able to comply at costs that are
similar to or less than the costs for
existing sources, because new sources
can apply control technologies and P2
practices (including dedicated lines and
pressurized hoses for equipment
cleaning) more efficiently than sources
that need to retrofit for those
technologies and P2 practices As a
result, given EPA's finding of economic
achievability for the final PSES
regulation for Subcategory C facilities,
EPA also finds that the PSNS regulation
will be economically achievable and
will not constitute a barrier to entry for
new sources
(2) NSPS
EPA has established NSPS limitations
equivalent to the limitations that are
established for BPT and BAT BPT and
BAT limitations allow facilities to use
the Zero/P2 Alternative and were found
to be economically achievable,
therefore, NSPS limitations will not
present a barrier to entry for new
facilities
b Subcategory E Refilling
Establishments
EPA is setting NSPS/PSNS for
Subcategory E facilities equal to BAT/
PSES limitations for existing sources
EPA estimates that compliance with
BAT/PSES will impose no costs on
existing facilities Likewise, new
facilities are not expected to incur
additional annual costs due to the
regulation Because EPA found
compliance with the final regulation to
be economically achievable for existing
facilities, EPA determined that
compliance with NSPS/PSNS will also
be economically achievable and not a
barrier to entry for new sources
6 Cost-Effectiveness Analysis
EPA also performed a cost-
effectiveness analysis of the final PSES
regulation for Subcategory C facilities
(A more detailed discussion can be
found in the final Cost-Effectiveness
Analysis (September 1996) [EPA-821-
R—96—018] The cost-effectiveness
analysis compares the total annualized
cost incurred for a regulatory option to
the corresponding effectiveness of that
option in reducing the discharge of
pollutants
Cost-effectiveness calculations are
used during the development of effluent
limitations guidelines and standards to
compare the efficiency of one regulatory
option in removing pollutants to
anothei regulatory option Cost-
effectiveness is defined as the
incremental annual cost of a pollution
control option in an industry
subcategory per incremental pollutant
removal The increments are considered
relative to another option or to a
benchmark, such as existing treatment
In cost-effectiveness analysis, pollutant
removals are measured in toxicity
normalized units called "pounds-
equivalent ' The cost-effectiveness
value, therefore, represents the unit cost
of removing an additional pound-
equivalent (lb eq ) of pollutants In
general, the lower the cost-effectiveness
value, the more cost-efficient the
regulation will be in removing
pollutants, taking into account their
toxicity While not required by the
Clean Water Act, cost-effectiveness
analysis is a useful tool for evaluating
regulatory options for the removal of
toxic pollutants Cost-effectiveness
analysis does not analyze the removal of
conventional pollutants (e g , oil and
grease, bio-chemical oxygen demand,
and total suspended solids)
For the cost-effectiveness analysis, the
estimated pounds-equivalent of
pollutants removed were calculated by
multiplying the number of pounds of
each pollutant removed by the toxic
weighting factor for each pollutant The
more toxic the pollutant, the higher will
be the pollutant's toxic weighting factor,
accordingly, the use of pounds-
equivalent gives correspondingly more
weight to pollutants with higher
toxicity Thus, for a given expenditure
and pounds of pollutants removed, the
cost per pound-equivalent removed
would be lower when more highly toxic
pollutants are removed than if
pollutants of lesser toxicity are
removed Annual costs for all cost-
effectiveness analyses are reported in
1981 dollars so that comparisons of
cost-effectiveness may be made with
regulations for other industries that
were issued at different times
a Subcategory C PFPR and PFPR/
Manufacturers
Table 2 provides estimates of the total
annualized compliance costs, in 1981
dollars, the total pollutant removals in
pounds and pounds-equivalent, and the
cost-effectiveness of the final PSES
regulation for Subcategory C facilities
with estimates of various POTW
removals EPA has estimated the
pollutant removals and the cost-
effectiveness value for the final rule
using the same methodology as used in
the proposed rule and supplemental
notice (and the Pesticide Manufacturing
effluent guideline) This methodology
assumes that all PAJs pass through the
POTW (i e , no removal by the POTW),
as there is little field data on the
effectiveness of POTWs removing PAJs
However, EPA has developed
laboratory estimates for the percent
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57537
removals of a large number of pollutants
(including some PAIs) which were
published in the Domestic Sewage
Study (DSS). February 1986 (EPA/530-
SW-86-004] For each pollutant
studied, two estimates were developed,
an "acclimated" removal percentage,
which might be achieved by a well-run
treatment facility with a constant flow
rate of the pollutant in question, and an
"unacclimated" removal percentage,
adjusted to account for the slug loadings
and batch discharges which POTWs
experience in everyday operation While
the unacclimated removals were
intended to more accurately reflect real
world operating conditions, a limited
amount of test data on non-PAI
pollutants indicates that POTWs may
achieve or even exceed the acclimated
removal estimates in practice Thus it is
not clear whether the acclimated or
unacclimated estimates more accurately
represent the removal percentages
achieved in practice for PAIs EPA has
thus developed a range of cost-
effectiveness and total removals using
three different assumptions about the
removal efficiency of POTWs zero
removals (this most conservative
estimate is included because of the lack
of actual data), unacclimated removals
(which range from 30% to 90% and
average 48%), and acclimated removals
(which range from 80% to 95%)
Using this range of POTW removals,
EPA has estimated the range of removal
to be between 18,991 and 189,908
pounds of pollutants, or 760,000 to 7 6
million toxic pounds-equivalent with
cost-effectiveness ranging from $2 74 to
$27 35 per pound-equivalent when
compliance costs are held constant at
S20 9 million22 in 1981 dollars EPA
considers even the high end of this
range to be cost effective In order to be
consistent with the proposed rule and
supplemental notice (and because of the
lack of actual POTW removal data for
PAIs), EPA is presenting the cost-
effectiveness and total removals for the
final rule as $2 74 per pound-equivalent
and 189,908 pounds or 7 6 million
pounds-equivalent, respectively
Table 2 —National Estimates of Total Annualized Costs. Removals and Cost-Effectiveness Values for
Subcategory C PSES Facilities Under the Final Regulation
POTW removal assumption used
Total
annualized
compliance
costs (millions
of $, 1981)
Pollutant
removals,
pounds
Pollutant removals,
(pounds-equiva-
lent)
Cost-effective-
ness
($/lb -eq)
No POTW Removals
$20 9
189,908
7 6 million
S2 74
POTW Removals per DSS
20 9
165,460
5 8 million
3 60
90 Percent Removal Efficiency
20 9
18,991
760,000
27 35
Notes
1 Includes estimated baseline failures
2 Toxic weighting factors used in the analyses reflect more recent toxicological information and are generally lower than the factors used at
proposal and supplemental
EPA has also estimated the removals,
annual compliance cost, and cost-
effectiveness excluding baseline
closures (when zero removal at POTWs
is assumed) Excluding estimated
baseline failures lowers the costs and
removals to S17 1 million ($1981) and
156,592 pounds (5 8 million pounds-
equivalent) The cost-effectiveness value
excluding baseline failures is $2 93 per
pound-equivalent, which EPA considers
to be cost-effective
The cost-effectiveness value
(assuming no POTW removal) for the
final regulation is not directly
comparable to the values presented in
the previous Federal Register notices
for the proposed regulation and the
supplemental notice for two reasons
First, the scope of the regulation has
changed with fewer PAIs and waste
streams covered under the final
regulation As a result, the baseline
pollutant discharges and pollutant
removals estimated for the final
regulation are lower than the values
estimated for the proposed regulation
Second, the toxic weighting factors
(TWFs) used by EPA for calculating the
cost-effectiveness of the Final regulation
reflect more recent toxicological data
and, in general, are lower than the
values used for the proposal and
supplemental notice analyses To
provide a consistent comparison of the
proposed, supplemental, and final
regulations, EPA re-calcuiated the toxic-
weighted baseline discharges, pollutant
removals, and cost-effectiveness values
for the proposed and supplemental
notice regulations using the more recent
toxic weighting factors (see Table 3) 23
The calculations for the final regulation
also embody the changes in regulatory
scope
Table 3 —Estimated Cost-Effectiveness of the Final PSES Regulation for Subcategory C Facilities
Compared with the Proposed and Supplemental Notice Regulations
[All toxic-weighted values based on toxic weighting factors developed for the Final Regulation]
Proposed regulation
Zero discharge with
sanitizer exemption
(Option 3/S 1)
Supplemental notice
Zero discharge/pollu-
tion prevention alter-
native
Final regulation Zero
discharge/pollution
prevention alternative
Total Annualized Cost, S1981
$64 1 million
$32 7 million
$20 9 million
Pollutant Discharges Subject to Regulation, pounds
505,235
337,995
192,789
Pollutant Loadings Subject to Regulation, pounds-equivalent
23 2 million
15 4 million
7 7 million
Pollutant Removal, pounds
503,114
333,731
189,908
22 EPA believes that if POTWs are removing PAIs
the cost of compliance of the industry would be
lower than £20 9 million ($1981) due to the
reduction in operating and maintenance costs
associated with the treatment system used to
pretreat PFPR wastewaters prior to discharge to the
POTW
23 The re-calculated cost-effectiveness values for
the proposed regulation also reflect the updated
estimates of the number of facilities using non-272
PAIs
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57538 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 3—Estimated Cost-Effectiveness of the Final PSES Regulation for Subcategory C Facilities
Compared with the Proposed and Supplemental Notice Regulations—Continued
[All toxic-weighted values based on toxic weighting factors developed for the Final Regulation]
Proposed regulation
Zero discharge with
samtizer exemption
(Option 3/S 1)
Supplemental notice
Zero discharge/pollu-
t'on prevention alter-
native
Final regulation Zero
discharge/pollution
prevention alternative
Pollutant Removals, pounds-equivalent
Cost-Effectiveness:
23 2 million
S2 77/lb-eq
15 3 million
$2 14/1 b-eq
7 6 million
$2 74/lb-eq
AAAiCost-effectiveness analysis is conventionally calculated on an incremental basis that is, the costs and removals of a given option are
calculated as the differences from the values for the next less stringent option At proposal, the cost-effectiveness of Option 3/S 1 was calculated
on an incremental basis relative to the next less stnngent option, Option 3/S However, the cost-effectiveness values for the supplemental notice
and final regulations are relative to a next less stnngent option of no regulation To permit consistent comparison of the three regulations, the
cost-effectiveness of the proposed regulation has been restated relative to a no-regulation baseline
The effect of the regulation's reduced
scope is seen by the reductions in
pollutant loadings subject to regulation
in pounds and pounds-equivalent (see
Table 3, lines 2 and 3) These results
show the pollutant loadings subject to
the rule at proposal to be 505,235
pounds, and on a toxic-weighted basis,
23 2 million pounds-equivalent, under
the final regulation, the pollutant
loadings within the scope of the
regulation fall to 192,789 pounds and
7 7 million pounds-equivalent on a
toxic-weighted basis The cost-
effectiveness values of the regulations
using the current set of weighting
factors are $2 77 per pound-equivalent
for the proposed regulation, $2 14 per
pound-equivalent for the supplemental
notice, and $2 74 per pound-equivalent
for the final regulation The cost-
efTectiveness value for the final
regulation is low in relation to the
values calculated for other effluent
limitations guidelines and standards
recently promulgated by EPA
b Subcategory E Refilling
Establishments
Estimates of compliance costs and
pollutant removals associated with
Subcategory E facilities have not
changed since the proposed regulation
EPA believes that the final regulation
can be implemented at a minimal cost
(1 e . a capital investment of
approximately $500 for a mini-bulk tank
to store water for reuse) at the 19
facilities not currently in compliance
Therefore. EPA determines the final
regulation to be cost-effective for
Subcategory E Facilities
E Regulatory Flexibility Act
Pursuant to section 605(b) of the
Regulatory Flexibility Act. 5 U S C
605(b), the Administrator certifies that
this rule will not have a significant
economic impact on a substantial
number of small entities EPA analyzed
the potential impact of the rule on both
small businesses and small local
governments
Under the Regulatory Flexibility Act,
an agency is not required to prepare a
regulatory flexibility analysis for a rule
that the agency head certifies will not
have a significant economic impact on
a substantial number of small entities
While the Administrator has so certified
today's rule, the Agency nonetheless
prepared a regulatory flexibility
assessment equivalent to that required
by the Regulatory Flexibility Act as
modified by the Small Business
Regulatory Enforcement Fairness Act of
1996 The assessment for this rule is
detailed in the "Economic Analysis of
Final Effluent Limitations Guidelines
and Standards for the Pesticide
Formulating, Packaging, and
Repackaging Industry" IEPA-821-R-
96-017]
EPA received many comments
regarding the rule (see Section 15 6 of
the technical record and Section IV in
the economic record for the
rulemaking) A number of commenters
raised issues concerning small business
impacts and the need to reduce the
regulation's burden on small businesses
Specifically, as a way of reducing
possible adverse impacts on smaller
businesses, some commenters requested
that EPA broaden its exemption from
the regulation to include all small
businesses In addition, some
commenters argued that EPA did not
need to regulate the discharges of small
PFPR businesses because the pollutant
discharges of such facilities were not
likely to have a consequential
environmental impact
EPA disagrees with this claim and
believes it is inappropriate to set small-
business and/or small-production
exemptions for all small businesses and/
or production volumes because of the
substantial toxicity of many of the PAIs
The size of the business and/or the
volume of PAIs processed annually are
not a sufficient basis for determining
that a facility should be exempted from
regulation Because of the high toxicity
of many of the PAIs, the processing of
even very small quantities of such PAIs
can result in pollutant discharges of
substantial toxicity In addition, small
business size does not necessarily
equate with small pesticide production
volume, particularly in terms of toxicity
Some small-business PFPR facilities
process a substantial volume of PAIs
and have the potential to discharge
substantial volumes of toxic pollutants
unless discharges are limited by the
PFPR regulation (see the Comment
Response Documents in the rulemaking
record for more information on these
comments and EPA's response to them )
Taking into account commenters"
concerns regarding possible impacts on
small entities, EPA introduced the Zero/
P2 Alternative Option and made
numerous changes to the rule designed
to reduce the burden upon all PFPR
facilities, particularly small business
entities As previously discussed, the
final rule expands the samtizer
exemption to exempt additional lower
toxicity PAIs from regulatory coverage
and gives facilities a Zero/P2
compliance choice on a line by line or
process by process basis
The factual analysis and basis for the
"no significant impact" certification is
contained in Chapter 4 of the final EA
report referenced previously and is
summarized below
1 Analysis of Impacts on Small
Business Entities
To gauge the impact of the final
regulation on small business, EPA
analyzed the impact of the final
regulation on Subcategory C facilities
according to the business size of the
owning firms and compared the
findings for the final regulation with
those for the proposed regulation Given
the large presence of small business-
owned entities in the PFPR industry,
EPA exercised substantial care at
proposal and throughout development
of the final regulation, to ensure that the
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57539
final regulation would not impose a
significant impact on a substantial
number of small business-owned
facilities This effort results in the
modest incurrence of both costs and
impacts by small business entities under
the final regulation
EPA estimates that 1,513 (75 0
percent) of the 2,018 PFPR facilities
potentially subject to a Subcategory C
PSES regulation are owned by small
entities Of the 506 facilities estimated
to potentially incur compliance costs
under the final rule (including baseline
failures), 357 (70 6 percent) are
estimated to be owned by small entities
Excluding projected baseline failures,
421 facilities are expected to incur costs,
of which 274, or 65 1 percent are small
business-owned facilities
No small business-owned facilities are
estimated to close as a result of
regulation Less than 10 percent of small
business-owned facilities (137 facilities)
are estimated to incur a moderate
impact " that is, a line conversion or
annualized compliance cost exceeding 5
percent of facility revenue The average
compliance cost burden among small
business-owned facilities is also small
in relation to facility revenue on
average, annualized compliance costs
amount to 2 7 percent of facility revenue
for small business-owned facilities
Finally, the number of small business-
facilities incurring costs, and the
numbers of small business-facilities
incurring severe or moderate impacts
are substantially less than estimated for
the proposed regulation For the
proposed regulation (re-estimated), 859
small business-facilities were estimated
to incur costs, 3 facilities were assessed
as potential closures (severe impacts),
and 275 facilities were assessed as
moderate impacts, the comparable
values for the final regulation are 357
small-business facilities incurring costs,
zero severe impacts, and 137 moderate
impacts The substantial reduction in
impacts among small business-owned
facilities from proposed to final
regulation reflects EPA's efforts to
moderate the burden of the regulation
by introducing a new option which
gives facilities the two compliance
alternatives, by reducing the PAIs and
wastestreams subject to the regulation,
and by providing facilities with greater
flexibility in deciding how to achieve
regulatory compliance In light of these
findings, EPA certifies that the final
regulation does not impose significant
impacts on a substantial number of
small business-owned facilities
2 Analysis of Impacts on Other Small
Entities
In addition to considering the impact
of the final regulation on small
business-owned facilities. EPA also
considered the regulation's likely effects
on two other categories of small entities
that will be affected by the regulation
(1) Publicly Owned Treatment Works
operated by small governments, which
may be responsible for implementing
the regulation at the local level, and (2)
small communities, which may contain
businesses that are adversely affected by
the regulation EPA concluded that the
final regulation would not impose
significant impacts on either of these
additional small entity categories
In the course of developing the final
regulation, EPA solicited comments on
regulatory implementation issues from
over 76 POTWs that had been identified
as receiving PFPR facility discharges
Fifteen of these are POTWs are
considered small—that is. POTWs that
are located in smaller jurisdictions (less
than 50,000 population) or that are
small POTWs on the basis of daily
treatment volume (less than or equal to
1 million gallons per day) Comments
were requested on such matters as the
burden of implementing the pollution
prevention/treatment alternative
element of the regulation Although
small entity POTWs were afforded the
opportunity to comment on the
implementation requirements of the
proposed regulation, none chose to do
so However, in response to the request
for comment on the supplemental
notice, EPA received responses from
eight POTWs Several of these
comments indicated that POTWs might
face modestly higher burdens from
administering a regulation with the
compliance flexibility offered by the P2
Alternative than from administering a
regulation strictly based on zero
discharge However, none indicated that
such a regulation would be expected to
impose a significant additional burden
beyond the requirements that POTWs
already face in administering permits
and compliance programs for industrial
facilities In addition, POTWs also
indicated that the modest additional
burden seemed reasonable given the
regulation's expected discharge
reductions and its innovative structure,
which gives facilities greater flexibility
in designing a compliance approach and
which encourages use of pollution
prevention as a compliance method In
view of these responses and given the
fact that no small entity POTWs
responded to the request for comments,
EPA certifies that the regulation will not
impose a significant impact on a
substantial number of small entity
POTWs
In addition to the analysis required by
the Regulatory Flexibility Act. EPA also
considered the regulation's effect on
small communities in which PFPR
facilities might be located Specifically,
in the community impact analysis
performed for the proposed PFPR
regulation, EPA examined the impact of
possible employment losses, including
multiplier effects, in communities in
which PFPR facilities with moderate or
severe impacts were located Using the
criterion that an estimated aggregate
employment loss exceeding one percent
of community employment is
significant, EPA found no significant
community employment impacts for the
proposed regulation as originally
analyzed At the same time, the final
regulation is estimated to have
substantially fewer facility and
employment impacts than those
estimated for the original proposed
regulation Given that no significant
community impacts were found among
any communities for the original
proposed regulation—regardless of
community size—5and that the final
regulation's impacts are expected to be
substantially less than those of the
proposed regulation, the final regulation
will not impose a significant burden on
small communities
VI Unfunded Mandates Reform Act
Title II of the Unfunded Mandates
Reform Act of 1995 (UMRA), Pub L
104-4 establishes requirements for
Federal agencies to assess the effects of
their regulatory actions on State, local,
and tribal governments and the private
sector Under Section 202 of the UMRA,
EPA generally must prepare a written
statement, including a cost-benefit
analysis, for proposed and final rules
with "Federal mandates" that may
result in expenditures to State, local,
and tribal governments, in the aggregate,
or to the private sector, of $100 million
or more in any one year Before
promulgating an EPA rule for which a
written statement is needed, Section 205
of the UMRA generally requires EPA to
identify and consider a reasonable
number of regulatory alternatives and
adopt the least costly, most cost-
effective or least burdensome alternative
that achieves the objectives of the rule
The provisions of Section 205 do not
apply when they are inconsistent with
applicable law Moreover, Section 205
allows EPA to adopt an alternative other
than the least costly, most cost-effective
or least burdensome alternative if the
Administrator publishes with the final
rule an explanation why that alternative
was not adopted Before EPA establishes
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57540 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
any regulatory requirements that may
significantly or uniquely affect small
governments, including tribal
governments, it must have developed
under Section 203 of the UMRA a small
government agency plan The plan must
provide for notifying potentially
affected small governments, enabling
officials of affected small governments
to have meaningful and timely input in
the development of EPA regulatory
proposals with significant Federal
intergovernmental mandates, and
informing, educating, and advising
small governments on compliance with
the regulatory requirements
EPA has determined that this rule
does not contain a Federal mandate that
may result in expenditures of $100
million or more for State, local, and
tribal governments, in the aggregate, or
the private sector in any one year Thus,
today's rule is not subject to the
requirements of Sections 202 and 205 of
the UMRA
Although not subject to the UMRA
because the cost of the rule to all parties
that would be effected is well below
S100 million, EPA has complied with
numerous provisions of the UMRA
Today's rule is the least costly, least
burdensome alternative that was
considered
Consistent with the intergovernmental
consultation provisions, EPA has
already initiated consultations with the
Publicly Owned Treatment Works
(POTWs) that will be affected by the
rule and sought their input as part of the
regulation development process
Specifically, after publication of the
Supplemental Notice (60 FR 30217).
EPA solicited comments from over 70
POTWs that had been identified as
receiving discharges from PFPR
facilities This request sought input on
several aspects of the PSES regulation,
including allowance of self-certification
of compliance by PFPR facilities, use of
Best Professional Judgment to revise or
modify the pollution prevention
practices listed in the Supplemental
Notice, and the burden on POTWs from
administering the pollution prevention
compliance alternative as part of the
regulation proposed in the
Supplemental Notice
In response to this request, EPA
received comments from eight POTWs
Four of these included comment on the
expected burden to POTWs from
administering the pollution prevention
and treatment compliance alternative
The general thrust of these comments is
that administering the pollution
prevention/treatment alternative will
impose somewhat higher burdens on
POTWs than administering a regulation
requiring compliance strictly by zero
discharge POTWs stated that inspection
requirements for verification of
compliance will be more difficult and
time-consuming because inspectors will
have to review technical plans,
equipment, and processes to verify that
the specified pollution prevention and
treatment measures have been properly
implemented, maintained, and operated
by PFPR facilities In contrast,
verification of compliance with a zero
discharge regulation would be more
straightforward POTWs also stated that
the option of relying on Best
Engineering Judgment to alter
requirements on facilities would
increase, rather than reduce,
implementation burdens However, at
the same time, POTWs also noted that
the burden of administering the PFPR
regulation did not seem unreasonable in
comparison to requirements for other
regulations and that the regulation's
implementation requirements are
necessary if the regulation is to be
effective
In keeping with the provisions to
inform, educate, and advise small
governments, EPA will publish a
Guidance Manual prior to the
compliance deadline of the rule to
inform, educate, and advise interested
facilities, permit writers, and POTWs on
pollution prevention processes and
procedures applicable to the PFPR
industry It will also serve as guidance
for the implementation of and
compliance with the P2 Alternative
requirements
VII Executive Order 12866
Under Executive Order 12866, (58 FR
51735 (October 4, 1993)) the Agency
must determine whether the regulatory
action is "significant" and therefore
subject to OMB review and the
requirements of the Executive Order
The Order defines "significant
regulatory action" as one that is likely
to result in a regulation that may
(1) Have an annual effect on the
economy of $100 million or more or
adversely affect in a material way the
economy, a sector of the economy,
productivity, competition, jobs, the
environment, public health or safety, or
State, local, or tribal governments or
communities,
(2) Create a serious inconsistency or
otherwise interfere with an action taken
or planned by another agency,
(3) Materially alter the budgetary
impact of entitlements, grants, user fees,
oi loan programs or the rights and
obligations of recipients thereof, or
(4) Raise novel legal or policy issues
arising out of legal mandates, the
President's priorities, or the principles
set forth in the Executive Order
Pursuant to the terms of Executive
Order 12866, it has been determined
that this rule is a "significant regulatory
action " As such, this action was
submitted to OMB for review Changes
made in response to OMB suggestions or
recommendations will be documented
in the public record for this rulemaking
VIII Small Business Regulatory
Enforcement Fairness Act of 1996
(SBREFA)
Under 5USC 801(a)(1)(A) as added
by the Small Business Regulatory
Enforcement Fairness Act of 1996, EPA
submitted a report containing this rule
and other required information to the
U S Senate, the U S House of
Representatives and the Comptroller
General of the General Accounting
Office prior to publication of the rule in
today's Federal Register This rule is
not a "major rule" as defined by 5
USC 804(2)
IX Paperwork Reduction Act
The information collection
requirements :n this rule have been
submitted for approval to the Office of
Management and Budget (OMB) under
the Paperwork Reduction Act, 44. U S C
3501 etseq Two separate Information
Collection Request (ICR) documents
have been prepared by EPA Burden
estimates for PFPR direct dischargers to
comply with their NPDES permits and
the P2 Alternative are contained in the
"National Pollutant Discharge
Elimination System (NPDES)/
Compliance Assessment/Certification
Information" ICR (No 1427 05) Burden
estimates for indirect discharging PFPR
facilities to comply with 40 CFR part
403 and the P2 Alternative are included
in the "National Pretreatment Program
(40 CFR part 403)" ICR (No 0002 08)
The approval of these ICRs is stil!
pending, therefore, the information
requirements contained in this rule are
not effective until OMB approves them
A copy of these ICRs may be obtained
from Sandy Farmer, OPPE Regulatory
Information Division, U S
Environmental Protection Agency
(2136), 401 M St NW , Washington. DC
20460, by calling (202) 260-2740, or
electron.cally by sending an e-mail
message to
"farmer sandy@epamail epa gov"
Burden means the total time, effort, or
financial resources expended by persons
to generate, maintain, retain, or disclose
or provide information to or for a
Federal agency This includes the time
needed to review instructions, develop,
acquire, install, and utilize technology
and systems for the purposes of
collecting, validating, and verifying
information, processing and
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Federal Register / Vol 61, No. 216 / Wednesday, November 6, 1996 / Rules and Regulations 57541
maintaining information, and disclosing
and providing information, adjust the
existing ways to comply with any
previously applicable instructions and
requirements, train personnel to be able
to respond to a collection of
information, search data sources,
complete and review the collection of
information, and transmit or otherwise
disclose the information
EPA estimates that each water using
facility is expected to spend an average
of 20 to 60 hours preparing the initial
certification statement (including brief
descriptions) for submittal to the
permitting/control authority as well as
preparing the paperwork to be kept on-
site (i e , treatment information,
supporting documentation for
modifications, etc ) EPA has
estimated less hours for direct
dischargers than for the indirect
dischargers (i e , 20 hours versus 60
hours) because the direct dischargers are
typically also pesticide manufacturers
with treatment systems in place that are
well documented while most indirect
dischargers do not have treatment in
place and have less technical expertise
in the area of wastewater treatment
However, some indirect dischargers will
use less than the 60 hours because they
are also pesticide manufacturers or they
may be able to reuse all of their
wastewater that would otherwise have
to be pretreated prior to discharge to the
POTW (1 e , interior wastewater sources,
floor wash and/or leak and spill cleanup
water)
Note Although most indirect dischargers
will not implement the P2 Alternative prior
to the compliance deadline (3 years following
promulgation) and, therefore would not be
covered by the Pretreatment ICR (No
0002 08) which expires in three years. EPA
has estimated that approximately ten percent
of the 1500 water-using PFPR facilities/new
facilities (i e , 150 facilities) would
implement the P2 Alternative prior to the
compliance deadline Therefore the burden
presented in the Pretreatment ICR concerning
the P2 Alternative is estimated for 150
facilities over the 3 years of the ICR EPA will
include burden for the remainder of the
water using PFPR facilities in the subsequent
Pretreatment ICR in 1999
Beyond the initial submittal, a PFPR
facility is expected to spend 15 minutes
to prepare and sign the periodic
certification statement to be submitted
to the permitting authority once per year
and to the control authority twice per
year If a facility has made changes in
the P2 practices they are using or in the
choice of zero discharge or P2
Alternative for a process line/product
family that was initially specified in the
initial certification (or previous period),
they must provide a brief description
with their periodic certification
statement EPA assumes that ten percent
of facilities will have to prepare such a
description each year and that the
associated burden/facility is four hours
for direct dischargers and 10 hours for
indirect dischargers EPA has also
included four hours per facility for
direct dischargers and 10 hours for
indirect dischargers for the burden
associated with a request for approval of
modifications where the justification is
not listed on Table 8 to part 455 of the
final regulation Again, EPA has used
the assumption that ten percent of
facilities per year will have to prepare
such a request for modification
An Agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
unless it displays a currently valid OMB
control number The OMB control
numbers for EPA's regulations are listed
in 40 CFR part 9 and 48 CFR Chapter
15
Send comments on the burden
estimates and any suggested methods
for minimizing respondent burden,
including through the use of automated
collection techniques to EPA at the
address provided above, with a copy to
the Office of Information and Regulatory
Affairs, Office of Management and
Budget. 725 17th St. NW , Washington,
DC 20503, marked "Attention Desk
Officer for EPA " Please remember to
include the ICR number in any
correspondence
X Water Quality Analysis
Most of the PAIs being regulated have
at least one toxic effect (e g , human
health carcinogen and/or systemic
toxicant or aquatic toxicant) Many of
these pollutants have the potential to
bioaccumulate and persist in the
environment Various studies have
demonstrated the bioaccumulation of
pesticides in aquatic life and
accumulation of pesticides in
sediments Documented human health
impacts at pesticide formulating,
packaging, and repackaging (PFPR)
facilities include respiratory disease and
impaired liver function, primarily
through worker exposure
For example, 137 of the original 272
PAIs are known to be highly or
moderately toxic to aquatic life, 25 have
carcinogenic effects, 149 are known to
have systemic or other health effects, 24
have an established concentration limit
under the Safe Drinking Water Act and
134 have a high or moderate potential
to bioaccumulate in the environment
(See the "Potential Fate and Toxicity
Categorization of Pollutants Associated
with PFPR Wastewater' Report,
September 1996 in the rulemaking
record)
Numerous incidents of groundwater
and soil contamination at refilling
establishments, largely due to spills, are
identified in the Office of Pesticide
Programs proposed "Standards for
Pesticide Containers and Containment'
(59 FR 6712. February 11. 1994) Several
examples cited in the Standards for
Pesticide Containers and Containment
proposed rule are summarized below
Based on the 1991 study. "Report on
Wisconsin Pesticide Mixing and
Loading Site Study," an estimated 45 to
75 percent of the commercial
agrichemical facilities in Wisconsin will
require soil remediation and 29 to 63
percent of these sites potentially exceed
the State's groundwater standards for
pesticides In the "Environmental
Cleanup of Fertilizer and Agricultural
Chemical Dealer Sites' report, the Iowa
Fertilizer and Chemical Association
estimates that 40 to 50 percent of
refilling establishments in Iowa may
require groundwater remediation A
1992 letter from the National
Agricultural Retailers Association
(formerly NARA. now ARA) stated that
70 to 80 percent of the detections of
pesticides in groundwater in Kansas
could be traced back to refilling
establishments Groundwater
contamination by pesticides is also
documented at numerous refilling
establishments in Michigan, Minnesota.
Illinois, and Utah
The water quality benefits of
controlling the indirect discharges from
PFPR facilities are evaluated by
modeling the impact of those discharges
on receiving streams This model
assumes that no additional removal
occurs at the POTW EPA believes this
to be a valid assumption because the
PAIs that are still covered by the scope
of the final pretreatment standards
(PSES) are expected to pass-through
POTWs The effects of POTW
wastewater discharges of 139 PAIs are
evaluated at current and post-
compliance (e g , zero/P2 Alternative)
levels for 85 indirect discharging PFPR
facilities which discharge to 79 POTWs
on 77 receiving streams Water quality
models are used to project pollutant
instream concentrations based on
estimated releases at current and zero/
P2 Alternative levels, the instream
concentrations are then compared to
EPA published water quality criteria or
to documented toxic effect levels
The instream pollutant concentration
for one PAI is projected to exceed
human health criteria in two receiving
streams at current discharge levels Both
excursions are projected to be
eliminated under the zero/P2
Alternative The number of pollutants
with receiving streams projected to
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57542 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
exceed aquatic life criteria or aquatic
toxic effect levels would be reduced
from 21 PAIs in 23 streams at current
discharge levels to four PAIs in six
streams at zero/P2 Alternative levels
The potential impacts of these
indirect discharging PFPR facilities are
also evaluated in terms of inhibition of
POTW operation and contamination of
sludge Potential biological inhibition
problems are projected to occur for
current discharges at four POTWs for
three PAIs, sludge criteria are
unavailable for PAIs No potential
biological inhibition problems are
projected to occur for the Zero/P2
Alternative option The POTW
inhibition values used in this analysis
are not, in general, regulatory values
They are based upon engineering and
health estimates contained in guidance
or guidelines published by EPA and
other sources Thus, EPA is not basing
its regulatory approach for pretreatment
discharge levels upon the finding that
some pollutants interfere with POTWs
by impairing their treatment
effectiveness However, the values used
in the analysis do help indicate the
potential benefits for POTW operation
that may result from the compliance
with the final regulation
In addition, the water quality benefits
of controlling the direct discharges from
PFPR facilities were evaluated by
modeling the impact of direct
wastewater discharges on receiving
stream water quality However, as
described in Section IV C 1 of today 's
notice, EPA's estimates of costs and
current pollutant loadings for direct
discharges did not include pollutant
removals for treatment already in place
(i e , pesticide manufacturing treatment
systems) Therefore, an estimate of the
water quality impacts resulting from
current direct discharges would result
in an overestimation of the current
water quality impacts because these
facilities do have treatment in place and
are already meeting zero discharge or
zero allowance (i e , no additional
discharge allowance in the pesticide
manufacturers' limitations for PFPR
wastewaters) Thus, EPA is presenting
only those water quality impacts
associated with the final rule
Seventeen (17) direct discharging
PFPR facilities, which discharge 61 PAIs
to 16 receiving streams, were evaluated
Water quality models are used to project
pollutant instream concentrations based
on estimated releases at post-
compliance (e g . zero/P2 Alternative)
levels, the instream concentrations are
then compared to EPA published water
quality criteria or to documented toxic
effect levels where EPA water quality
criteria are not available for certain
PAIs The zero/P2 Alternative option is
projected to result in aquatic life
exceedances of three PAIs in two
receiving streams No exceedances of
human health criteria are projected to
occur for the zero/P2 Alternative option
XI Non-Water Quality Environmental
Impacts
The elimination or reduction of one
form of pollution may create or
aggravate other environmental
problems Therefore, Sections 304(b)
and 306 of the Act call for EPA to
consider the non-water quality
environmental impacts of effluent
limitations guidelines and standards
Accordingly, EPA has considered the
effect of these regulations on air
pollution, solid waste generation, and
energy consumption As discussed
throughout today's notice, EPA selected
to promulgate the Zero/P2 Alternative
option due to the cross-media impacts
that could occur under a zero discharge
regulation due to contract hauling to off-
site incineration of potentially large
volumes of non-reusable wastewaters
EPA has estimated the non-water
quality impacts associated with the
selected option, i e , the Zero/P2
Alternative, as well as a zero discharge
option As discussed previously in this
notice, under the Zero/P2 Alternative,
facilities will be able to choose between
complying with zero discharge or the P2
Alternative on a line-by-line basis
However, for the purposes of estimating
compliance costs and non-water quality
impacts, EPA has assumed that a facility
will choose between these compliance
options on a whole-facility basis
Therefore, the non-water quality
estimates for the Zero/P2 Alternative
represent those cross-media impacts
associated with a percentage of the
facilities choosing to comply with the
P2 Alternative and others choosing to
comply with zero discharge
EPA has used the assumption that,
under the zero discharge option,
facilities would recycle and reuse some
wastewaters while hauling the
remaining wastewaters off-site for
incineration Under the P2 Alternative
portion of the Zero/P2 Alternative, some
facilities may be able to avoid the need
for wastewater treatment by
comprehensively applying source
reduction practices to all their
wastewater sources, however, it is more
likely that, following the use of recycle
and reuse practices, facilities will need
to employ some pollution control
treatment technologies prior to
discharging their wastewaters
There are some cross-media impacts
that are associated with the Zero/P2
Alternative and its use of a wastewater
treatment system that are not associated
with a zero discharge option since
treatment is not utilized under the zero
discharge option These cross-media
impacts include sludge generation and
energy consumption and air emissions
of criteria air pollutants24 from the
trucks that transport spent activated
carbon for regeneration However, the
zero discharge option relies heavily on
the contract hauling of wastewater for
incineration which significantly
increases the cross-media impacts due
to air emissions of criteria an pollutants
from the trucks that transport the
wastewater to incineration and from the
incineration of the wastewater itself
EPA believes that selecting the Zero/
P2 Alternative option will minimize
these cross-media impacts, overall, as
compared to the zero discharge option
In particular, the Zero/P2 Alternative
has a significantly lower cross-media
impact on air emissions of criteria air
pollutants than the zero discharge
option while still preventing the
discharge of 98 5 percent of the
pesticide active ingredients (PAIs) from
being discharged to the water The
following sections present the estimates
for air emissions, solid waste generation
and energy consumption for the final
rule
A Air Pollution
For the purpose of preparing a cross-
media impact analysis, the air pollution
effects are divided into two separate
types of air emissions generated as a
result of the final rule First, there are
air emissions estimated for the Zero/P2
Alternative based on the treatment of
wastewater through a treatment system,
such as the Universal Treatment
System, discussed in Section II E of
today's preamble These emissions
consist mainly of volatile priority
pollutants EPA does not anticipate that
there will be any significant losses of
PAIs into the atmosphere under the
Zero/P2 alternative, because most PAIs
have low volatility The second type of
air emissions are those generated from
the transport (1 e , air emissions from the
trucks exhaust and gasoline) of both
wastewater and spent activated carbon
as well as emissions from the
incineration of wastewater that is
hauled off-site for disposal Estimates of
both types of air emissions are
presented on Table 4 of today's
preamble for the Zero/P2 Alternative
and for zero discharge As seen on Table
" Criteria air pollutants include Volatile organic
compounds (VOCs) nitrogen oxides (NOx) sulfur
dioxide (S02) particulate matter (PM) and carbon
monoxide (CO) Criteria air pollutants can injure
health harm the environment and cause property
damage
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57543
4, the emissions for criteria air and from the incineration of the non- significant cross-media impact as
pollutants from the transport of reusable wastewaters under the zero compared to the Zero/P2 Alternative
wastewaters and spent activated carbon discharge option would create a
Table 4- Criteria Air Pollutant Emissions (lb/yr)
Emission source
VOCs
NO,
PM
CO
so.
Wastewater Transportation
Zero/P2 Alternative
14,720
121,200
6,800
175,400
Zero Discharge
87,600
720,000
40,400
1,044,000
Wastewater Incineration
Zero/P2 Alternative
5
1,838
10
133
2
Zero Discharge
264
94,600
530
6,880
106
Spent Activated Carbon Transportation
Zero/P2 Alternative
1,692
13,920
780
20,200
Zero Discharge!
NA
NA
NA
NA
Wastewater Treatment ;
Zero/P2 Alternative
84,700
NA
NA
NA
NA
Zero Discharge
52,500
NA
NA
NA
NA
NA=not applicable
a EPA estimates that under the Zero/P2 Alternative 69% of facilities incurring costs will choose the P2 Alternative and 31% will choose to
comply with zero discharge
- There is no wastewater treatment system used under the zero discharge option and, therefore, no spent activated carbon to transport for re-
generation
i Air emissions estimates from wastewater treatment include only volatile pnonty pollutants
EPA also estimates the reduction of
volatile priority pollutants emissions
that would occur under the Zero/P2
Alternative and under zero discharge
EPA estimates that in addition to the
192,789 lbs of PAIs that are currently
(i e , prior to today's regulation) being
discharged to water, 381,000 pounds of
volatile priority pollutant are currently
emitted when wastewater is discharged
to POTWs or are emitted to the air from
the wastewater treatment process at the
POTWs EPA estimates that under the
Zero/P2 Alternative, the air emissions
from wastewater reuse, treatment and
discharge to POTWs will be reduced to
84,700 pounds of volatile priority
pollutants This means that
implementing the Zero/P2 Alternative
will reduce air emissions of volatile
priority pollutants from wastewater
reuse, treatment and discharge by
296,300 pounds annually In addition,
the remaining emissions are localized
and in many cases may be more likely
to be captured and treated by the UTS
The loss of priority pollutants to the
atmosphere is likely to occur during
reuse of wastewater and particularly
from the emulsion breaking, hydrolysis,
and/or chemical oxidation treatment
steps where the addition of heat is likely
to promote their release25 It is also
25 EPA believes that use of closed vessels in the
treatment system will additionally control the
release of volatile pnonty pollutants to the air and
therefore, has used the costs associated with closed
vessels when estimating costs for the regulauon
However for the analysis of the air pollution
emissions estimates for this rule estimates on
volatile pnonty pollutant emissions from closed
vessels were not available Therefore the volatile
pnonty pollutant emissions estimate assumes the
possible that some emissions of priority
pollutants could occur during the
cleaning of equipment or containers,
particularly if high-pressure cleaning or
steam cleaning is used Under the zero
discharge option, 52,500 pounds of
volatile priority pollutants are expected
to be emitted during the recycle and
reuse of wastewaters
B Solid Waste
EPA estimates that under the Zero/P2
Alternative there will be 856,000
pounds of sludge generated from
emulsion breaking and sulfide
precipitation treatment annually EPA
has assumed that the sludge generated
via emulsion breaking and sulfide
precipitation will be hauled to
hazardous waste incinerators In
addition to the sludge generated,
treatment of wastewater through the
Universal Treatment System will
generate 3,830,000 pounds annually of
spent activated carbon It is assumed
that the activated carbon will be sent
off-site for regeneration, which means
that it is reused and would not become
a waste See Section XI A for the
estimate of air emissions from
transporting the spent activated carbon
for regeneration and from the hauling of
wastewater/sludge to incineration as
well as the air emissions associated with
incineration
EPA believes the Zero/P2 Alternative
is consistent with the goals established
for EPA's Hazardous Waste
Minimization and Combustion Strategy
(November, 1994) This draft
use of open vessels during treatment which may
overestimate the emissions
combustion strategy establishes the goal
of a strong preference for source
reduction over waste management,
thereby reducing the long-term demand
for combustion and other waste
management facilities In addition, the
strategy states that combustion does
have an appropriate role and that EPA
wants to ensure that combustion
facilities (such as incinerators and
boilers and industrial furnaces (BIFs))
are designed in a manner to protect
public health
C Energy Requirements
EPA estimates that compliance with
the final regulation will increase energy
consumption by a small increment over
present industry use The main energy
requirement is the generation of steam
that is used in the wastewater treatment
system to accomplish emulsion breaking
and hydrolysis Steam provides the heat
energy to assist with the separation of
emulsified phases and increases the rate
at which active ingredients hydrotyze It
is estimated that about 6 28 x 107
pounds per year of steam would be
required by the Universal Treatment
System This would require
approximately 13,581 barrels of oil
annually This is, relatively, very small
compared to the 18 million barrels per
day that the United States currently
consumes
Additionally, EPA estimates that the
operation of the Universal Treatment
System will consume 811,000 kilowatt
hours per year This is expended by the
pumps and agitators used in treatment
and associated with the storage of water
until it can be reused
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57544 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
XII Regulatory Implementation
The purpose of this section is to
provide assistance and direction to
permit writers and control authorities to
aid in their implementation of this
regulation and its unique compliance
alternative This section also discusses
the relationship of upset and bypass
provisions, variances and modifications,
and analytical methods to the final
limitations and standards
A Implementation of the Limitations
and Standards
1 Pesticide Formulating, Packaging and
Repackaging (Subcategory C)
Each PFPR facility subject to this
regulation will need to make an initial
choice on either a facility-wide basis or
on a process basis (i e , product family/
process line/process unit) They will
need to choose to either comply with
the zero discharge effluent limitation/
pretreatment standard or choose to agree
to conduct the listed pollution
prevenuon practices (or a variation of
the listed practices based on self-
implemented modifications or those
agreed to by the permit/control
authority) and also agree to make the
practices and the pollution prevention
discharge allowance enforceable (see
§ 455 41 of the final rule for the
definition of P2 allowable discharge)
However, beyond this initial choice,
much of the continued implementation
of the Zero/P2 Alternative will differ for
direct and indirect dischargers
Direct Dischargers
For direct dischargers, the Zero/P2
Alternative will be implemented
through the NPDES permitting process
For each new or existing direct
discharging facility, the facility would
need to make the initial choice at the
permitting stage or at the time for permit
modification or renewal, respectively
Facilities that do not choose the P2
Alternative (or zero discharge) for the
facility in its entirety will be required to
clearly state in their NPDES permit each
product family, process unit or process
line and the option selected for each
For those processes for which a direct
discharge facility chooses the P2
Alternative over the zero discharge
limitation, the permitting authority
would include all of the P2 practices
and any specified treatment
technologies in the facility's NPDES
permit The definition of P2 allowable
discharge for direct dischargers requires
the appropriate treatment of all process
wastewater prior to discharge
Therefore, permit writers may want to
include in the permit the method
chosen by the facility to demonstrate
that the treatment system (1) Is
appropriate for the PAls in their process
wastewaters (that are not also being
manufactured), and (2) is properly
operated and maintained, or the permit
writer can set numerical limitations
based on BPJ for any additional PAIs, as
necessary
Today's final regulations do not
require facilities to submit all of the
necessary compliance paperwork to the
NPDES permit writer, but instead
require the facility choosing the P2
Alternative to keep the paperwork on-
site and available for the permitting
authority and enforcement officials
However, EPA is requiring the submittal
of an initial certification statement at
the time of issuance, renewal, or
modification of an NPDES permit for
direct dischargers In addition, as
suggested by a commenter, EPA is also
requiring the submittal of a periodic
certification statement to be submitted
every year to the NPDES permit writer
The pollution prevention practices and
treatment technologies included in such
a NPDES permit would be enforceable
under CWA sections 309 and 505
For those processes where a new or
existing direct discharge PFPR/
Manufacturer has chosen to comply
with zero discharge, the permit would
include (1) The pesticide
manufacturing limitations (40 CFR part
455, subparts A and B) with no
additional allowance for the PFPR
wastewaters for those PAIs that are also
manufactured, and (2) limitations set
equal to the detection limit of the PAIs
expected to be in the wastewater (or no
PFPR process wastewater flow) for PAIs
that are not also manufactured at the
facility The NPDES permits for new or
existing stand-alone direct discharging
facilities that choose to achieve zero
discharge from specified processes will
include either limitations set equal to
the detection limit of the analytical
method for the PAIs expected to be in
the wastewater or will allow no process
wastewater flow
Indirect Dischargers
Existing and new PFPR facilities
(including PFPR/Manufacturers) which
are indirect dischargers would also need
to make an initial choice on a process
basis of meeting the zero discharge
pretreatment standard or adopting and
implementing the P2 practices and the
treatment technologies (if so specified)
Facilities that choose the zero discharge
option for specified processes (or for the
entire facility) would agree in their
control mechanism or pretreatment
agreement to demonstrate zero
discharge through no process
wastewater flow or compliance by
meeting a numerical standard be set
equal to the detection limit of the
analytical method for the PAIs expected
in the wastewater
If the indirect discharging PFPR
facility chooses the P2 Alternative for
any or all processes/hnes/product
families, the facility would need to
notify the Control Authority of its
intention by submitting an initial
certification statement as described in
§ 455 41 (a) of the final regulation
Facilities that do not choose the P2
Alternative for the facility in its entirety
will be required to include a brief
description of each product family,
process unit or process line and the
option selected for each with the initial
certification statement In addition, the
facility must include all of the P2
practices (or modifications) and any
specified treatment technologies that
will be implemented to meet the
requirements of the practices listed in
Table 8 to part 455 for those processes
which the P2 Alternative was chosen
For indirect dischargers appropriate
pretreatment is required for any interior
equipment cleaning wastewater
(including drums), floor wash26 or leak/
spill cleanup water that is part of the P2
allowable discharge Other wastewater
sources can be discharged to the POTW
without pretreatment The initial
certification statement to be submitted
requires a signature by the appropriate
manager in charge of overall operations
of the facility to assure that information
provided is true, accurate, and complete
to the best of his or her knowledge
Other required paperwork can be kept
on-site (e g , supporting documentation
for any modifications, treatment
technologies used that are not listed on
Table 10 to part 455 of the regulation,
the method chosen and supporting
documentation for demonstrating that
appropriate treatment is well operated
and maintained and the rationale for
choosing the method of demonstration)
Any modifications for a reason not
listed on Table 8 to part 455 of the
regulation must be submitted to the
control authority for approval
Once an individual control
mechanism (or pretreatment agreement)
is in place, facilities need to submit a
26 In individual cases the requirement of
wastewater pretreatment prior to discharge iO the
POTW may be removed by the control authority for
floor wash or the final rinse of a non-reusable triple
rinse when the facility has demonstrated that the
levels of PAIs and priority pollutants in such
wastewaters are at a level that is too low to be
effectively pretreated at the facility and have been
shown to neither pass through or interfere with the
operations of the POTW The control authority
should also take into account whether or not the
facility has employed water conservation when
generaung such a non-reusable wastewater
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57545
periodic certification statement to the
control authority indicating that the P2
Alternative is being implemented as in
the previous period or that a
modification to the individual control
mechanism is needed The certification
statement is to be submitted to the
control authority on the same time table,
i e , twice per year (June and December),
as the reporting required by 40 CFR
403 12(e) The control authority, as part
of its approved pretreatment program,
must have the authority to ensure
compliance with a pretreatment
standard (40 CFR 403 8(f)(l)(n)) and to
carry out inspections of the indirect
dischargers' self-certifications and of the
paperwork described below 40 CFR
403 8(f)(l)(v)
Necessary Paperwork for the P2
Alternative
As briefly mentioned above, both
direct and indirect discharging facilities
are required to keep certain paperwork
on-site and available for permitting/
control authorities and enforcement
officials
Note Although EPA is not requiring
submittal of all the paperwork for approval
in these national regulations NPDES
programs and control authorities may choose
to require submittal of any of the paperwork
for approval
The paperwork which is required to
be submitted includes the one-time
initial certification statement (see
§455 41(a) of the final rule) and the
periodic certification statements (see
§ 455 41 (b) of the final rule) The
paperwork which can be kept on-site is
referred to in this final rule as the "On
site Compliance Paperwork'' (see
§ 455 41 (c)) Each of these is described
below
For each PFPR facility, the initial
certification statement would include, at
a minimum, a listing of and descriptions
of the processes (i e , product families/
process lines/process units) for which it
chooses the P2 Alternative and those for
which it chooses to achieve zero
discharge, descriptions of the P2
practices (from Table 8 to part 455 of the
regulation) that are being employed and
how they are being implemented,
description of any justifications
allowing modification to the practices
listed on Table 8 to part 455, and a
description of the treatment system
being used to obtain a P2 allowable
discharge (as defined in §455 4!) The
initial certification statement must be
signed by the responsible corporate
officer as defined in 40 CFR 403 12(1) or
40 CFR 122 22
The periodic certification statement is
to be submitted twice per year for
indirect discharging facilities and once
pei year for direct discharging facilities
and should indicate whether the P2
Alternative is being implemented as set
forth in the NPDES permit/control
mechanism or that a justification
allowing modification of the listed
practices has been implemented
resulting in a change in the P2 practices
conducted at the facility If the
modification needed is not listed on
Table 8 of part 455, the facility should
request a modification from their
permitting/control authority if it has not
already done so
The on-site compliance paperwork
should include the information from the
initial and periodic certifications but
must also include (1) The supporting
documentation for any modifications
that have been made to the listed P2
practices (including records that
indicate/demonstrate, for example,
microbial growth, specific directions for
other disposal from the manufacturer,
use of a solvent recovery system, etc),
(2) a written discussion demonstrating
that the treatment system being used
contains the appropriate treatment
technologies (i e , listed by PAI in the
Table 10 to Part 455 of the final
regulation, equivalent system as defined
in §455 10(h), or pesticide
manufacturing system) for removing
PAIs that are used in production at their
facility and could be in their
wastewater, (3) a method for
demonstrating that the treatment system
is well operated and maintained, and (4)
a discussion of the rationale for
choosing the method of demonstration
For example, a facility may utilize a
surrogate method for determining
breakthrough of their carbon adsorption
unit This method could be used instead
of performing analytical testing for all or
any of the PAIs that may have been in
production at the facility over a specific
period of time The facility could
possibly use records of carbon change
out/purchase to demonstrate that the
system is properly operated and
maintained and could describe the
initial testing and/or vendor information
used to determine the useful life of the
activated carbon
Control authorities, at or any time
after entering into an individual control
mechanism, or permitting authorities, at
or any time after issuing, reissuing, or
modifying the NPDES permit, could
inspect the PFPR facility to see that the
listed practices are being employed, that
the treatment system is well operated
and maintained and that the necessary
paperwork provides sufficient
justification for any modifications
When facilities need to modify a listed
P2 practice for which ajustification is
not listed in the final regulation, the
facility must make a request for the
modification from the NPDES
permitting authority or the control
authority The permit writer/control
authority is expected to use BPJ/BEJ to
approve the modification
Note EPA is preparing a guidance manual
to aid permit writers/control authorities as
well as PFPR facilities
Compliance Dates
EPA has established a three-year
deadline for compliance with the PFPR
pretreatment standards for existing
sources (PSES) Under the zero/P2
alternative facilities will need time to
assess which process lines are amenable
to the P2 alternative and which lines
will have to comply with zero
discharge This decision will most likely
be based on economics as well as the
characteristics of the individual process
line In addition, facilities will have to
determine the treatment necessary for
the PAIs expected to be found in the
wastewater at their facility and they will
need time to design and install these
systems Finally, facilities will need
time to prepare the on-site compliance
paperwork necessary to support the P2
alternative Thus, EPA believes that a
full three-year compliance period is
appropriate
Existing direct dischargers must
comply by the date of issue, reissue or
modification of the NPDES permit New
source standards and limitations (PSNS
and NSPS) must be complied with when
a facility commences the discharging of
wastewater
Note For this rule, a direct discharge
facility is considered a new source if its
construction commenced following
promulgation of the final rule (40 CFR 122 2),
while an indirect discharge facility is
considered a new source if construction
commenced after proposal (April 1994) of the
pretreatment standards (40 CFR 403 3)
Direct dischargers may be subject to
the establishment, by the permitting
authority, of more stringent effluent
limitations based on applicable water
quality standards See 40 CFR 122 44 In
addition, those PFPR facilities that are
indirect dischargers remain subject to
the Pass-Through and Interference
prohibitions contained in the general
pretreatment regulations 40 CFR
403 5(a)(1) Indirect dischargers could
also be subject to local limits
established by the control authority
receiving the facility's wastewater 40
CFR 403 5(c)
The Agency emphasizes that although
the Clean Water Act is a strict liability
statute, EPA can initiate enforcement
proceedings at its discretion EPA has
exercised and intends to exercise that
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57546 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
discretion in a manner that recognizes
and promotes good faith compliance
2 Refilling Establishments (Subcategory
E)
The limitations and standards for
existing and new refilling
establishments are set as zero discharge
In addition, many states (with national
regulations soon to follow) require these
facilities to have secondary containment
systems and loading pads for their bulk
pesticide and pesticide dispensing
operations Under these state and
eventual national secondary
containment regulations under FIFRA,
facilities are collecting process
wastewaters that were formerly
contaminating soil and groundwater
Since the majority of these facilities
are not located in an area where direct
or indirect discharge is feasible, EPA
believes that the zero discharge can be
implemented as seen on site visits
Typically, these facilities collect their
process wastewaters (including interior
equipment cleaning of minibulks, bulk
tanks and related ancillary equipment
and leak/spill cleanup water) and store
these collected rinsates for reuse The
stored rinsates are then used as product
make-up water in future custom
application activities Facilities that do
not operate their own custom
application services or that are located
in states where the purchase of make-up
water for reuse in applications is
prohibited have been known to give
away these rinsates to custom
applicators or directly to farmers A
small number of facilities in such a
situation may choose some means of off-
site disposal, such as contract hauling to
incineration
B Upset and Bypass Provisions
A recurring issue is whether industry
limitations and standards should
include provisions authorizing
noncompliance with effluent limitations
during periods of "upset' or "bypass"
An upset, sometimes called an
"excursion,1 is an unintentional and
temporary noncompliance with
technology-based effluent limitations
occurring for reasons beyond the
reasonable control of the permittee EPA
believes that upset provisions are
necessary to recognize an affirmative
defense for an exceptional incident
including "Acts of God" Because
technology-based limitations can
require only what properly designed,
maintained and operated technology
can achieve, it is claimed that liability
for such situations is improper
While an upset is an unintentional
episode during which effluent
limitations are exceeded, a bypass is an
act of intentional noncompliance during
which wastewater treatment facilities
are circumvented in emergency
situations
EPA has both upset and bypass
provisions in NPDES permits, and has
promulgated NPDES and pretreatment
regulations which include upset and
bypass permit provisions (40 CFR
122 41(m), 122 41(n) and 40 CFR 403 16
and 403 17 ) The upset provision
establishes an upset as an affirmative
defense to prosecution for violation of
technology-based effluent limitations
The bypass provision authorizes
bypassing to prevent loss of life,
personal injury, or severe property
damage Since there are already upset
and bypass provisions in NPDES
permits and pretreatment regulations,
EPA will let local permit and control
authorities deal with individual upsets
or requests for bypass
C Variances and Modifications
Upon the promulgation of these
regulations, the effluent limitations for
the appropriate subcategory must be
applied in all Federal and State NPDES
permits issued to direct dischargers in
the pesticide formulating, packaging or
repackaging industry In addition, the
pretreatment standards are directly
applicable to indirect dischargers
1 Fundamentally Different Factors
Variances
For the BPT effluent limitations, the
only exception to the binding
limitations is EPA's "fundamentally
different factors ("FDF') variance (40
CFR part 125, subpart D) This variance
recognizes factors concerning a
particular discharger which are
fundamentally different from the factors
considered in this rulemaking Although
this variance clause was set forth in
EPA's 1973-1976 effluent guidelines, it
is now included in the NPDES
regulations and not the specific industry
regulations (See 44 FR 32854, 32893
Dune 7, 1979] for an explanation of the
"fundamentally different factors"
variance) The procedures for
application for a BPT FDF variance are
set forth at 40 CFR 122 21 (m)(l)(I)(A)
Dischargers subject to the BAT
limitations in these final regulations
may also apply for an FDF variance,
under the provisions of section 301(n) of
the Act, which regulates BAT, BCT, and
pretreatment FDFs In addition, BAT
limitations for nonconventional
pollutants may be modified under
section 301(c) (for economic reasons)
and 301(g) (for water quality reasons) of
the Act These latter two statutory
modifications are not applicable to
toxic' or conventional pollutants
Dischargers subject to pretreatment
standards for existing sources (PSES) are
also subject to the "fundamentally
different factors" variance provision (40
CFR 403 13) and credits for pollutants
removed by POTWs, as discussed in
Section XII C 2 Dischargers subject to
pretreatment standards for new sources
(PSNS) are subject only to the removal
credit provision (see Section XII C 2)
New sources subject to NSPS are not
eligible for EPA's "fundamentally
different factors" variance or any
statutory or regulatory variances See
EI Du Pont v Tram. 430 U S 112
(1977)
2 Removal Credits
Congress, in enacting Section 307(b)
of the CWA, recognized that, in certain
instances, POTWs could provide some
or all of the treatment of an industrial
user's wastestream that would be
required pursuant to the pretreatment
standard Consequently, Congress
established a discretionary program for
POTWs to grant "removal credits" to
their indirect dischargers The credit, in
the form of a less stringent pretreatment
standard, allows an increased amount of
pollutants to flow from the indirect
discharger's facility to the POTW
Section 307(b) of the CWA establishes
a three-part test for obtaining removal
credit authority for a given pollutant
Removal credits may be authorized only
if (1) the POTW "removes21 all or any
part of such toxic pollutant," (2) the
POTW's ultimate discharge would "not
violate that effluent limitation, or
standard which would be applicable to
that toxic pollutant if it were
discharged" directly rather than through
a POTW and (3) the POTW s discharge
would "not prevent sludge use and
disposal by such [POTW] in accordance
with section [405] " Section
307(b)
EPA has promulgated removal credit
regulations in 40 CFR 403 7 The United
States Court of Appeals for the Third
Circuit has interpreted the statute to
require EPA to promulgate
comprehensive sewage sludge
regulations before any removal credits
could be authorized NRDCv EPA, 790
F 2d 289, 292 (3rd Cir 1986) cert
denied 479 U S 1084 (1987) Congress
made this explicit in the Water Quality
Act of 1987 which provided that EPA
27 In 40 CFR 403 7 removal is defined to mean
a reduction in the amount of a pollutant in the
POTW s effluent or alteration of the nature of a
pollutant dunng treatment at the POTW The
reduction or alteration can be obtained by physical
chemical or biological means and may be the result
of specifically designed POTW capabihues or may
be incidental to the operation of the treatment
system Removal as used (in § 403 7) shall not mean
dilution of a pollutant in the POTW
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57547
could not authorize any removal credits
until it issued the sewage sludge use
and disposal regulations required by
section 405 (d) (2) (a) (n)
Section 405 of the CWA requires EPA
to promulgate regulations which
establish standards for sewage sludge
when used or disposed for various
purposes These standards must include
sewage sludge management standards as
well as numerical limits for pollutants
which may be present in sewage sludge
in concentrations which may adversely
affect public health and the
environment Section 405 requires EPA
to develop these standards in two
phases On November 25, 1992, EPA
promulgated the Round One sewage
sludge regulations establishing
standards, including numerical
pollutant limits, for the use and disposal
of sewage sludge 58 FR 9248 EPA
established pollutant limits for ten
metals when sewage sludge is applied to
land, for three metals when it is
disposed of at surface disposal sites and
for seven metals and total hydrocarbons,
a surrogate for organic pollutant
emissions, when sewage sludge is
incinerated These requirements are
codified at 40 CFR part 503
At the same time EPA promulgated
the Round One regulations, EPA also
amended its pretreatment regulations to
provide that removal credits would be
available for certain pollutants regulated
in the sewage sludge regulations See 58
FR at 9386 The amendments to Part 403
provide that removal credits may be
made potentially available for the
following pollutants
(1) If a POTW applies its sewage
sludge to the land for beneficial uses,
disposes of it on surface disposal sites
or incinerates it, removal credits may be
available, depending on which use or
disposal method is selected (so long as
the POTW complies with the
requirements in part 503) When sewage
sludge is applied to land, removal
credits may be available for ten metals
When sewage sludge is disposed of on
a surface disposal site, removal credits
may be available for three metals When
the sewage sludge is incinerated,
removal credits may be available for
seven metals and for 57 organic
pollutants See 40 CFR
403 7(a)(3)(iv) (A)
(2) In addition, when sewage sludge is
used on land or disposed of on a surface
disposal site or incinerated, removal
credits may also be available for
additional pollutants so long as the
concentration of the pollutant in sludge
does not exceed a concentration level
established in part 403 When sewage
sludge is applied to land, removal
credits may be available for two
additional metals and 14 organic
pollutants When the sewage sludge is
disposed of on a surface disposal site,
removal credits may be available for
seven additional metals and 13 organic
pollutants When the sewage sludge is
incinerated, removal credits may be
available for three other metals See 40
CFR 403 7(a) (3) (iv)(B)
(3) When a POTW disposes of its
sewage sludge in a municipal solid
waste land fill that meets the criteria of
40 CFR part 258 (MSWLF), removal
credits may be available for any
pollutant in sewage sludge See 40 CFR
403 7 (a) (3) (iv) (C)
Thus, given compliance with the
requirements of EPA's removal credit
regulations,28 following promulgation of
the pretreatment standards being
proposed here, removal credits may be
authorized for any pollutant subject to
pretreatment standards if the applying
POTW disposes of its sewage sludge in
a MSWLF that meets the requirements
of 40 CFR part 258 If the POTW uses
or disposes of its sewage sludge by land
application, surface disposal or
incineration, removal credits may be
available for the following metal
pollutants (depending on the method of
use or disposal) Arsenic, cadmium,
chromium, copper, lead, mercury,
molybdenum, nickel, selenium and
zinc Given compliance with § 403 7,
removal credits may be available for the
following organic pollutants (depending
on the method of use or disposal)
acrylonitrile, aldrin/dieldrin (total),
benzene, benzidine. benzo(a)pyrene.
bis(2-chloroethyl)ether, bis(2-
ethylhexyl)phthalate,
bromodichloromethane, bromoethane,
bromoform, carbon tetrachloride,
chlordane, chloroform, chloromethane,
DDD, DDE, DDT.
dibromochloromethane, dibutyl
phthalate, 1,2-dichloroethane, 1.1-
dichloroethylene, 2,4-dichlorophenol,
1.3-dichloropropene, diethyl phthalate,
2.4-dinitrophenol, 1 2-
diphenvlhydrazine, di-n-butyl
phthalate, endosulfan, endrin.
ehtylbenzene, heptachlor, heptachlor
epoxide, hexachlorobutadiene,
alphahexachlorocyclohexane,
betahexachlorocyclohexane,
hexachlorocyclopentadiene,
hexachloroethane, hydrogen cyanide,
isophorone, lindane, methylene
chloride, nitrobenzene, n-
!S Under § 403 7 a POTW is authorized to give
removal credits only under certain condiuons
These include applying for and obtaining approval
from the Regional Administrator (or Director of a
State NPDES program with an approved
pretreatment program) a showing of consistent
pollutant removal and an approved pretreatment
program See 40 CFR 403 7(a) (3) (I) (11) and (in)
nitrosodimethylamine. n-nitrosodi-n-
propylamine, pentachlorophenol,
phenol, polychlorinated biphenyls,
2,3,7,8-tetrachlorodibenzo-p-dioxin,
1,1,2,2-tetrachloroethane,
tetrachloroethylene, toluene, toxaphene,
trichloroethylene. 1.2,4-
trichlorobenzene, 1,1,1 -trichloroethane,
1,1,2-trichloroethane and 2,4,6-
trichlorophenol
With regard to the use of removal
credit authority for any pollutant subject
to these pretreatment standards, a
POTW (once compliance with 40 CFR
403 7 is shown and removal credit
authority is granted) may be able to
effectively authorize the waiving of
what otherwise would be required
treatment of the PFPR wastewaters by
authorizing a removal credit to the PFPR
industrial user to the extent of any
pollutants remaining in its discharge
after all applicable pollution prevention
practices have been complied with
However, removal credits could only be
granted to the extent that granting of
such credits would not result in pass
through or interference at the POTW as
defined in 40 CFR 403 3 and in
accordance with the provisions of
§ 403 5, and EPA would expect that the
PFPR industrial user would have to
continue to comply with the pollution
prevention practices as specified in the
P2 Alternative even if a removal credit
had been provided
D Analytical Methods
Section 304(h) of the Act directs EPA
to promulgate guidelines establishing
test methods for the analysis of
pollutants These methods are used to
determine the presence and
concentration of pollutants in
wastewater, and are used for
compliance monitoring and for filing
applications for the NPDES program
under 40 CFR 122 21, 122 41, 122 44
and 123 25, and for the implementation
of the pretreatment standards under 40
CFR 403 10 and 403 12 To date, EPA
has promulgated methods for
conventional pollutants, toxic
pollutants, and for some non-
conventional pollutants The five
conventional pollutants are defined at
40 CFR 401 16 Table I-B at 40 CFR part
136 lists the analytical methods
approved for these pollutants The 65
toxic metals and organic pollutants and
classes of pollutants are defined at 40
CFR 401 15 From the list of 65 classes
of toxic pollutants EPA identified a list
of 126 "Priority Pollutants " This list of
Priority Pollutants is shown, for
example, at 40 CFR part 423, appendix
A The list includes non-pesticide
organic pollutants, metal pollutants,
cyanide, asbestos, and pesticide
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57548 Federal Register / Vol. 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
pollutants Currently approved methods
for metals and cyanide are included in
the table of approved inorganic test
procedures at 40 CFR 136 3, Table 1-B
Table I-C at 40 CFR 136 3 lists approved
methods for measurement of non-
pesticide organic pollutants, and Table
I-D lists approved methods for the toxic
pesticide pollutants and for other
pesticide pollutants
EPA believes that the analytical
methods for pesticide active ingredients
contained in the promulgated pesticide
manufacturing effluent guidelines and
standards (see Methods for the
Determination of Nonconventional
Pesticides m Municipal and Industrial
Wastewater, Volumes I & II, EPA 821 —
R-93-010-A&B, August 1993, Revision
1) will perform equally well on treated
pesticide formulating, packaging or
repackaging wastewaters as on pesticide
manufacturing wastewaters Raw
wastewater samples may on occasion
require some separation prior to
analysis, analogous to the emulsion
breaking pretreatment included in
EPA's costed BAT technology Many of
these methods have in fact been used on
the PFPR sampled wastewaters All of
the active ingredient pollutant data that
supports the proposed effluent
limitations were generated using
analytical methods that employ the
approved methods or are based upon
the approved methods at 40 CFR part
136 or contained m Methods for the
Determination of Nonconventional
Pesticides m Municipal and Industrial
Wastewater For PAI's that have no
EPA-approved analytical methods,
PFPR facilities may utilize alternative
sampling and analysis methods as
specified in 40 CFR 136 4 and
403 12(g)(4) At some future date, EPA
may transfer the analytical methods
promulgated at part 455 to part 136 as
a pait of EPA's effort to consolidate
analytical methods and streamline
promulgation of new methods As
discussed in Section XII A 1, EPA
believes that those facilities choosing
zero discharge will either demonstrate
zero discharge through no process
wastewater flow or will demonstrate
compliance using the analytical
methods to show PAIs levels are at or
below detection (or meeting pesticide
manufacturing limitations with no
allowance given to PFPR wastewater)
Facilities choosing to demonstrate that
they are in compliance with the P2
Alternative will use submittal of
certification statements, inspections,
and demonstrated implementation of
the listed P2 practices to assure
compliance with the final rule
However, some facilities, although not
required, may use analytical methods to
demonstrate that their treatment system
are "well operated and maintained," as
explained in the P2 Alternative In
addition, permitting/control authorities
can set numerical limitations using BPJ/
BEJ which may rely on the use of
analytical methods for demonstrating
compliance
List of Subjects in 40 CFR Part 455
Environmental protection, Chemicals,
Packaging and containers. Pesticides
and pests, Pollution prevention, Waste
treatment and disposal, Water pollution
control
Dated September 30 1996
Carol M Browner,
Administrator
Appendix A to the Preamble-
Abbreviations, Acronyms, and Other
Terms Used in This Document
B t —Bacillus thuringiensis
BAT—Best Available Control Technology
Economically Achievable
BCT—Best Conventional Pollutant Control
Technology
BEJ—Best Engineering Judgement
B1F—Boilers and Industrial Furnaces
BOD—Biochemical Oxygen Demand
BPJ—Best Professional Judgement
BPT—Best Practicable Control Technology
Currently Available
CAA—Clean Air Act
CO—Carbon Monoxide
CSF—Confidential Statement of Formula
CWA—Clean Water Act
DOT—Department of Transportation
FATES—FIFRA and TSCA Enforcement
System
FDA—Food and Drug Administration
FDF—Fundamentally Different Factors
FIFRA—Federal Insecticide. Fungicide
Rodenticide Act
GMPs—Good Manufacturing Practices
GRAS—Generally Recognized As Safe
ICR—Information Collection Request
NOx—Nitrogen oxides
NPDES—National Pollutant Discharge
Elimination System
NSPS—New Source Performance Standards
P2—Pollution Prevention
PAI—Pesticide Active Ingredient
PFPR—Pesticide Formulating, Packaging and
Repackaging
PM—Particulate Matter
POTW—Publicly Owned Treatment Works
PPA—Pollution Prevention Act
PSES—Pretreatment Standards for Existing
Sources
PSNS—Pretreatment Standards for New
Sources
RCRA—Resource Conservation and Recovery
Act
R & D—Research and Development
SBREFA—Small Business Regulatory
Enforcement Fairness Act
SOj—Sulfur dioxide
SRRP—Source Reduction Review Project
TDD—Technical Development Document
TSCA—Toxic Substances Control Act
TSD—Treatment. Storage and Disposal
TSS—Total Suspended Solids
UMRA—Unfunded Mandate Reform Act
UTS—Universal Treatment System
VOCs—Volatile Organic Compounds
Zero/P2 Alternative—Zero Discharge/
Pollution Prevention Alternative Option
For the reasons set out in the
preamble, title 40, chapter I of the Code
of Federal Regulations is amended as
follows
PART 455—PESTICIDE CHEMICALS
1 The authority citation for part 455
continues to read as follows
Authority Sees 301, 304, 306, 307, and
501, Pub L 92-500, 86 Stat 816. Pub L 95-
217. 91 Stat 156, and Pub L 100-4, 101 Stat
7 (33 USC 1311, 1314, 1316, 1317, and
1361)
la Section 455 10 is amended by
adding paragraphs (g) through (u) to
read as follows
§455.10 General definitions.
*****
(g) Appropriate pollution control
technology means the wastewater
treatment technology listed in Table 10
to this part 455 for a particular PAI(s)
including an emulsion breaking step
prior to the listed technology when
emulsions are present in the wastewater
to be treated
(h) Equivalent system means a
wastewater treatment system that is
demonstrated in literature, treatability
tests or self-monitoring data to remove
a similar level of pesticide active
ingredient (PAI) or priority pollutants as
the applicable appropriate pollution
control technology listed in Table 10 to
this Part 455
(i) Formulation of pesticide products
means the process of mixing, blending
or diluting one or more pesticide active
ingredients (PAIs) with one or more
active or inert ingredients, without an
intended chemical reaction to obtain a
manufacturing use product or an end
use product
(j) Group 1 mixtures means any
product whose only pesticidal active
ingredient(s) is a common food/food
constituent or non-toxic household
item, or is a substance that is generally
recognized as safe (GRAS) by the Food
and Drug Administration (21 CFR
170 30, 182, 184, and 186) in
accordance with good manufacturing
practices, as defined by 21 CFR part
182, or is exempt from FIFRA under 40
CFR 152 25
(k) Group 2 mixtures means those
chemicals listed in Table 9 to this part
455
(1) Inorganic wastewater Treatment
chemicals means inorganic chemicals
that are commonly used in wastewater
treatment systems to aid in the removal
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57549
of pollutants through physical/chemical
technologies such as chemical
precipitation, flocculation,
neutralization, chemical oxidation,
hydrolysis and/or adsorption
(m) Interior wastewater sources means
wastewater that is generated from
cleaning or rinsing the interior of
pesticide formulating, packaging or
repackaging equipment, or from rinsing
the interior of raw material drums,
shipping containers or bulk storage
tanks, or cooling water that comes in
direct contact with pesticide active
ingredients (PAIs) during the
formulating, packaging or repackaging
process
(n) Microorganisms means registered
pesticide active ingredients that are
biological control agents listed in 40
CFR 152 20(a)(3) including Eucaryotes
(protozoa, algae, fungi), Procaryotes
(bacteria), and Viruses
(o) Packaging of pesticide products
means enclosing or placing a formulated
pesticide product into a marketable
container
(p) PFPR/Manufacturer means a
pesticide formulating, packaging and
repackaging facility that also performs
pesticide manufacturing on-site and
commingles their PFPR process
wastewaters and pesticide
manufacturing process wastewaters
(q) Pool chemicals means pesticide
products that are intended to disinfect
or sanitize, reducing or mitigating
growth or development of
microbiological organisms including
bacteria, algae, fungi or viruses in the
water of swimming pools, hot tubs, spas
or other such areas, in the household
and/or institutional environment, as
provided in the directions for use on the
product label
(r) Refilling establishment means an
establishment where the activity of
repackaging pesticide product into
refillable containers occurs
(s) Repackaging of pesticide products
means the transfer of a pesticide
formulation (or PAD from one container
to another without a change in
composition of the formulation or the
labeling content, for sale or distribution
(t) Samtizerproducts means pesticide
products that are intended to disinfect
or sanitize, reducing or mitigating
growth or development of
microbiological organisms including
bacteria, fungi or viruses on inanimate
surfaces in the household, institutional,
and/or commercial environment and
whose labeled directions for use result
in the product being discharged to
Publiciy Owned Treatment Works
(POTWs) This definition shall also
include samtizer solutions as defined by
21 CFR 178 1010 and pool chemicals as
defined in this section (455 10(q)) This
definition does not include liquid
chemical sterilants (including
sponcidals) exempted by §455 40(0 or
otherwise, industrial preservatives, and
water treatment microbiocides other
than pool chemicals
(u) Stand-alone PFPR facility means a
PFPR facility where either No pesticide
manufacturing occurs, or where
pesticide manufacturing process
wastewaters are not commingled with
PFPR process wastewaters Such
facilities may formulate, package or
repackage or manufacture other non-
pesticide chemical products and be
considered a "stand-alone" PFPR
facility
lb Section 455 11 is revised to read
as follows
§ 455.11 Compliance date for pretreatment
standards for existing sources (PSES)
All discharges subject to pretreatment
standards for existing sources (PSES) m
subparts A and B of this part must
comply with the standards no later than
September 28. 1993
Subpart C—Pesticide Formulating,
Packaging and Repackaging (PFPR)
Subcategory
2 Section 455 40 is revised as to read
as follows
§ 455 40 Applicability; description of the
pesticide formulating, packaging and
repackaging subcategory.
(a) The provisions of this subpart are
applicable to discharges resulting from
all pesticide formulating, packaging and
repackaging operations except as
provided in paragraphs (b). (c). (d), (e)
and (0 of this section
(b) The provisions of this subpart do
not apply to repackaging of agricultural
pesticides performed at refilling
establishments, as described in §455 60
(c) The provisions of this subpart do
not apply to wastewater discharges
from the operation of employee
showers and laundry facilities, the
testing of fire protection equipment, the
testing and emergency operation of
safety showers and eye washes, storm
water, Department of Transportation
(DOT) aerosol leak test bath water from
non-continuous overflow baths (batch
baths) where no cans have burst from
the time of the last water change-out,
and on-site laboratories from cleaning
analytical equipment and glassware and
rinsing the retain sample container
(except for the initial rinse of the retain
sample container which is considered a
process wastewater souice for this
subpart)
(d) The provisions of this subpart do
not apply to wastewater discharges from
the formulation, packaging and/or
repackaging of sanmzer products
(including pool chemicals),
microorganisms, inorganic wastewater
treatment chemicals, group 1 mixtures
and group 2 mixtures, as defined under
§455 10
(e) The provisions of this subpart do
not apply to wastewater discharges from
the development of new formulations of
pesticide products and the associated
efficacy and field testing at on-site or
stand-alone research and development
laboratories where the resulting
pesticide product is not produced for
sale
(0 The provisions of this subpart do
not apply to wastewater discharges from
the formulation, packaging and/or
repackaging of liquid chemical sterilant
products (including any sterilant or
subordinate disinfectant claims on such
products) for use oil a critical or semi-
critical device, as defined in Section 201
of the Federal Food, Drug and Cosmetic
Act and in Section 2(u) of the Federal
Insecticide, Fungicide and Rodenticide
Act
3 Section 455 41 is added to Subpart
C to read as follows
§455.41 Special definitions.
(a) Initial Certification Statement for
this subpart means a written submission
to the appropriate permitting authority,
e g, the local Control Authority (the
POTW) or NPDES permit writer which
must be signed by the responsible
corporate officer as defined in 40 CFR
403 12(1) or 40 CFR 122 22 and which
(1) Lists and describes those product
families, process lines and/or process
units for which the PFPR facility is
implementing the Pollution Prevention
Alternative ("P2 Alternative"),
(2) Describes the PFPR facility
specific practices for each product
family/process line/process unit which
are to be practiced as part of the P2
Alternative,
(3) Describes any justification
allowing modification to the practices
listed in Table 8 to this part 455, and
(4) Lists the treatment system being
used to obtain a P2 allowable discharge
(as defined in 455 41)
(b) Periodic CertiHcation Statement
for this subpart means a written
submission to the appropriate
permitting authority, e g , the local
Control Authority (the POTW) or
NPDES permit writer, which states that
the P2 Alternative is being implemented
in the manner set forth in the control
mechanism (for indirect dischargers) or
NPDES permit (for direct dischargers) or
that a justification allowing
modification of the practices listed in
Table 8 to this part 455 has been
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57550 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
implemented resulting in a change in
the pollution prevention practices
conducted at the facility The Periodic
Certification Statement must be signed
by the responsible corporate officer as
defined in 40 CFR 403 12(1) or 40 CFR
122 22
(c) On-site Compliance Paperwork for
this subpart means data or information
maintained in the offices of the PFPR
facility which supports the initial and
periodic certification statements as
follows
(1) Lists and describes those product
families, process lines and/or process
units for which the facility is
implementing the P2 Alternative,
(2) Describes the facility specific
practices for each product family/
process line/process unit which are to
be practiced as part of the P2
Alternative,
(3) Describes any justification
allowing modification to the practices
listed in Table 8 to this part 455,
(4) Includes a written discussion
demonstrating that the treatment system
being used contains the appropriate
pollution control technologies (or
equivalent systems/pesticide
manufacturing systems) for removing
the PAJs which may be found in the
wastewater,
(5) Establishes a method for
demonstrating to the permitting/control
authority that the treatment system is
well operated and maintained, and
(6) Includes a discussion of the
rationale for choosing the method of
demonstration
(d) For Indirect Dischargers
Pollution prevention (P2) allowable
discharge (excluding interior wastewater
sources, leak and spill clean-up water,
and floor wash) for this subpart means
the quantity of/concentrations of
pollutants in PFPR process wastewaters
that remain after a facility has
demonstrated that it is using the
specified practices of the Pollution
Prevention Alternative as listed in Table
8 to this part 455
Pollution prevention (P2) allowable
discharge for interior wastewater
sources, leak and spill cleanup water,
and floor wash for this subpart means
the quantity of/concentrations of
pollutants in PFPR process wastewaters
that remain after a facility has
demonstrated that it is using the
specified practices of the Pollution
Prevention Alternative as listed in Table
8 to this part 455 and that have been
pretreated using appropriate pollution
control technologies, as defined in
§455 10(g), or a pesticide
manufacturer s treatment system, or an
equivalent system, used individually, or
in any combination to achieve a
sufficient level of pollutant reduction
Pretreatment requirements may be
modified or waived by the Control
Authority (POTW) to the extent that
removal credits have been granted by
the POTW in accordance with 40 CFR
403 7, provided the granting of such
credits does not result in pass through
or interference as defined in 40 CFR
403 3 and complies with the provisions
of 40 CFR 403 5 The facility must
demonstrate that the appropriate
pollution control technology is properly
maintained and operated
(e) For Direct Dischargers
Pollution prevention (P2) allowable
discharge for this subpart means the
quantity of/concentrations of pollutants
in PFPR process wastewaters that
remain after a facility has demonstrated
that it is using the specified practices of
the Pollution Prevention Alternative as
listed in Table 8 to this part 455 and
that have been treated using appropriate
pollution control technologies, as
defined in §455 10(g). or a pesticide
manufacturer's treatment system, or an
equivalent system, used individually, or
in any combination to achieve a
sufficient level of pollutant reduction
The facility must demonstrate that the
appropriate pollution control
technology is properly maintained and
operated
(f) Process wastewater, for this
subpart, means all wastewater
associated with pesticide formulating,
packaging and repackaging except for
sanitary water, non-contact cooling
water and those wastewaters excluded
from the applicability of the rule in
§455 40
4 Section 455 42 is revised to read as
follows
§455.42 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best practicable control technology
currently available, (BPT).
Except as provided in 40 CFR 125 30
through 125 32, any existing point
source subject to this subpart shall
achieve the following effluent
limitations representing the degree of
effluent reduction attainable by the
application of the best practicable
control technology currently available
(a) Except as provided in paragraph
(b) of this section, the following
limitations establish the quantity or
quality of pollutants or pollutant
properties controlled by this paragraph
which may be discharged from the
formulation, packaging or repackaging
of pesticides There shall be no
discharge of process wastewater
pollutants to navigable waters
Note For existing PFPR/Manufacturer
facilities as defined in § 455 10(p) which are
also subject to the provisions of § 455 22 or
§455 32, "zero discharge means that
permitting authorities shall provide no
additional discharge allowance for those
pesticide active ingredients (PAIs) in the
pesticide formulating, packaging and
repackaging wastewaters when those PAIs
are also manufactured at the same facility
(b) Any existing facility subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455 41(e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
in Table 8 of this Part 455),
(2) The discharger will notify its
NPDES permit writer at the time of
renewal or modification of its permit, of
its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455 41(a),
(3) The discharger will submit to its
NPDES permitting authority a periodic
certification statements as described in
§455 41(b) once each year of operation,
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in § 455 41 (c)
5 New §§ 455 43 through 455 47 are
added to subpart C to read as follows
§455.43 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application o(
the best conventional pollutant control
technology (BCT).
Except as provided in 40 CFR 125 30
through 125 32. any existing point
source subject to this subpart must
achieve the effluent limitations
representing the degree of effluent
reduction attainable by the application
of the best conventional pollutant
control technology
(a) Except as provided in paragraph
(b) of this section, the BCT limitations
are established as follows There shall
be no discharge of process wastewater
pollutants to navigable waters
Note For existing PFPR/Manufacturer
facilities, as defined in §455 I0(p) which are
also subject to the provisions of §§455 23.
zero discharge means that permitting
authorities shall provide no discharge
additional discharge allowance for those
pesticide active ingredients (PAIs) in the
pesticide formulating, packaging and
repackaging wastewaters when those PAIs
are also manufactured at the same facility
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57551
(b) Any existing facility subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455 41(e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
in Table 8 of this Part 455),
(2) The discharger will notify its
NPDES permit writer at the time of
renewal or modification of its permit, of
its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455 41(a),
(3) The discharger will submit to its
NPDES permitting authority a periodic
certification statement as described in
§455 41(b) once each year of operation,
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in § 4 55 41 (c)
§455.44 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best available control technology
economically achievable (BAT).
Except as provided in 40 CFR 125 30
through 125 32, any existing point
source subject to this subpart must
achieve the effluent limitations
representing the degree of effluent
reduction attainable by the application
of the best available technology (BAT)
(a) Except as provided in paragraph
(b) of this section, the BAT limitations
are established as follows There shall
be no discharge of process wastewater
pollutants to navigable waters
Note For existing PFPR/Manufacturer
facilities, as defined in §455 10(p), which are
also subject to the provisions of §§455 24
zero discharge means that permitting
authorities shall provide no additional
discharge allowance for those pesticide
active ingredients (PAIs) in the pesticide
formulating packaging and repackaging
wastewaters when those PAIs are also
manufactured at the same facility
(b) Any existing facility subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455 41(e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
on Table 8 of this Part 455),
(2) The discharger will notify its
NPDES permitting authority at the time
of renewal or modification of its permit,
of its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455 41(a),
(3) The discharger will submit to its
NPDES permit writer a periodic
certification statement as described in
§455 41(b) once each year of operation,
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in §455 41(c)
§455.45 New Source Performance
Standards (NSPS).
(a) Any new source, except as
provided in paragraph (b) of this
section, subject to this subpart which
discharges process wastewater must
meet the following standards There
shall be no discharge of process
wastewater pollutants to navigable
waters
Note For new PFPR/Manufacturer
facilities, as defined in § 455 10(p). which are
also subject to the provisions of §§455 25,
zero discharge means that permitting
authorities shall provide no additional
discharge allowance for those pesticide
active ingredients (PAIs) in the pesticide
formulating, packaging and repackaging
wastewaters when those PAIs are also
manufactured at the same facility
(b) Any new source subject to
paragraph (a) of this section may have
a pollution prevention allowable
discharge, as defined in §455 41(e), of
wastewater pollutants to navigable
waters if the discharger agrees to NPDES
permit conditions as follows
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Professional
Judgement for modifications not listed
in Table 8 of this Part 455),
(2) The discharger will notify its
NPDES permit writer at the time of
submitting its application for a permit,
of its intent to utilize the Pollution
Prevention Alternative by submitting to
the NPDES permit writer an initial
certification statement as described in
§455 41(a),
(3) The discharger will submit to its
NPDES permitting authority a periodic
certification statement as described in
§ 455 41 (b) once each year of operation,
and
(4) The discharger will maintain at the
office of the facility and make available
for inspection the on-site compliance
paperwork as described in §455 41(c)
§ 455.46 Pretreatment standards for
existing sources (PSES)
(a) Except as provided in 40 CFR
403 7 and 403 13 or in paragraph (b) of
this section, no later than November 6.
1999, any existing source subject to this
subpart which introduces pollutants
into a publicly owned treatment works
must comply with 40 CFR part 403 and
achieve PSES as follows There shall be
no discharge of process wastewater
pollutants
(b) Except as provided in 40 CFR
403 7 and 403 13, any existing source
subject to paragraph (a) of this section
which introduces pollutants into a
publicly owned treatment works must
comply with 40 CFR part 403 and may
have a pollution prevention allowable
discharge of wastewatei pollutants, as
defined in §455 41(d), if the discharger
agrees to control mechanism or
pretreatment agreement conditions as
follows
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Pan 455 (or received a
modification by Best Engineering
Judgement for modifications not listed
in Table 8 to this Part 455),
(2) The discharger will notify its local
Control Authority at the time of
renewing or modifying its individual
control mechanism or pretreatment
agreement of its intent to utilize the
Pollution Prevention Alternative by
submitting to the local Control
Authority an initial certification
statement as described in §455 41(a),
(3) The discharger will submit to its
local Control Authority a periodic
certification statement as described in
§ 455 41 (b) during the months of June
and December of each year of operation,
and
(4) The discharger will maintain at the
offices of the facility and make available
for inspection the on-site compliance
paperwork as described in §455 41(c)
(c) Except as provided in 40 CFR
403 7 and 403 13, any existing source
subject to §455 46(b) which introduces
pollutants into a publicly owned
treatment works must comply with 40
CFR part 403 and may submit a request
to its Control Authority to waive
pretreatment of floor wash, and/or a
non-reusable final rinse of a triple rinse,
if the concentrations of pesticide active
ingredients and priority pollutants in
those wastewater sources have been
demonstrated to be too low to be
effectively pretreated at the facility The
Control Authority may waive
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57552 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
pretreatment for these two wastewaters
only if the existing source makes the
demonstrations and is in compliance
with 40 CFR 403 5
§ 455.47 Pretreatment Standards for New
Sources (PSNS).
(a) Except as provided in 40 CFR
403 7 and 403 13 or in paragraph (b) of
this section, any new source subject to
this subpart which introduces
pollutants into a publicly owned
treatment works must comply with 40
CFR part 403 and achieve PSNS as
follows There shall be no discharge of
process wastewater pollutants
(b) Except as provided in 40 CFR
403 7 and 403 13, any new source
subject to paragraph (a) of this section
which introduces pollutants into a
publicly owned treatment works must
comply with 40 CFR part 403 and may
have a pollution prevention allowable
discharge of wastewater pollutants, as
defined in §455 41(d), if the discharger
agrees to control mechanism or
pretreatment agreement conditions as
follows
(1) The discharger will meet the
requirements of the Pollution
Prevention Alternative listed in Table 8
to this Part 455 (or received a
modification by Best Engineering
Judgement for modifications not listed
in Table 8 to this Part 455),
(2) The discharger will notify its local
Control Authority at the time of
submitting its application for an
individual control mechanism or
pretreatment agreement of its intent to
utilize the Pollution Prevention
Alternative by submitting to the local
Control Authority an initial certification
statement as described in §455 41(a),
(3) The discharger will submit to its
local Control Authority a periodic
certification statement as described in
§ 455 41 (b) during the months of June
and December of each year of operation,
and
(4) The discharger will maintain at the
offices of the facility and make available
for inspection the on-site compliance
paperwork as described in §455 41(c)
(c) Except as provided in 40 CFR
403 7 and 403 13. any new source
subject to paragraph (b) of this section
which introduces pollutants into a
publicly owned treatment works must
comply with 40 CFR part 403 and may
submit a request to its Control Authority
to waive pretreatment of floor wash,
and/or a non-reusable final rinse of a
triple rinse, if the concentrations of
pesticide active ingredients and priority
pollutants in those wastewater sources
have been demonstrated to be too low
to be effectively pretreated at the
facility The Control Authority may
waive pretreatment for these two
wastewaters only if the new source
makes the demonstrations and is in
compliance with 40 CFR 403 5
6 A new subpart E consisting of
§§455 60 through 455 67 is added to
read as follows
Subpart E—Repackaging of Agricultural
Pesticides Performed at Refilling
Establishments
Sec
455 60 Applicability, description of the
repackaging of agricultural pesticides
performed by refilling establishments
subcategory
455 61 Special Definitions
455 62 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best practicable pollutant control
technology (BPT)
455 63 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best conventional pollutant control
technology (BCT)
455 64 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best available technology
economically achievable (BAT)
455 65 New source performance standards
(NSPS)
455 66 Pretreatment standards for existing
sources (PSES)
455 67 Pretreatment standards for new
sources (PSNS)
Subpart E—Repackaging of
Agricultural Pesticides Performed at
Refilling Establishments
§455.60 Applicability; description of
repackaging of agricultural pesticides
performed by refilling establishments
subcategory.
(a) The provisions of this subpart are
applicable to discharges resulting from
all repackaging of agricultural pesticides
performed by refilling establishments,
as defined in §455 10, whose primary
business is wholesale or retail sales, and
where no pesticide manufacturing,
formulating or packaging occurs, except
as provided in paragraphs (b). (c) and
(d) of this section
(b) The provisions of this subpart do
not apply to wastewater discharges from
custom application or custom blending,
as defined in 40 CFR 167 3
(c) The provisions of this subpart do
not apply to wastewater discharges
from the operation of employee
showers and laundry facilities, the
testing of fire protection equipment, the
testing and emergency operation of
safety showers and eye washes, or storm
water
(d) The provisions of this subpart do
not apply to wastewater discharges from
the repackaging of microorganisms or
Group 1 Mixtures as defined under
§455 10, or non-agricultural pesticide
products
§455.61 Special definitions.
Process wastewater, for this subpart,
means all wastewater except for sanitary
water and those wastewaters excluded
from the applicability of the rule in
§455 60
§455.62 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best practicable pollutant control
technology (BPT).
Except as provided in 40 CFR 125 30
through 125 32, any existing point
source subject to this subpart must
achieve effluent limitations representing
the degree of effluent reduction
attainable by the application of the best
practicable pollutant control
technology There shall be no discharge
of process wastewater pollutants
§455.63 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best conventional pollutant control
technology (BCT).
Except as provided in 40 CFR 125 30
through 125 32, any existing point
source subject to this subpart must
achieve effluent limitations representing
the degree of effluent reduction
attainable by the application of the best
conventional pollution control
technology There shall be no discharge
of process wastewater pollutants
§455.64 Effluent limitations guidelines
representing the degree of effluent
reduction attainable by the application of
the best available technology economically
achievable (BAT).
Except as provided in 40 CFR 125 30
through 125 32, any existing point
source subject to this subpart must
achieve effluent limitations representing
the degree of effluent reduction
attainable by the application of the best
available technology economically
achievable There shall be no discharge
of process wastewater pollutants
§455.65 New source performance
standards (NSPS).
Any new source subject to this
subpart which discharges process
wastewater pollutants must meet the
following standards There shall be no
discharge of process wastewater
pollutants
§455.66 Pretreatment standards for
existing sources (PSES).
Except as provided in 40 CFR 403 7
and 403 13. no later than November 6,
1999 subpart which introduces
pollutants into a publicly owned
treatment works must comply with 40
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57553
CFR part 403 and achieve the
pretreatment standards for existing
sources as follows There shall be no
discharge of process wastewater
pollutants
§ 455.67 Pretreatment standards for new
sources (PSNS).
Except as provided in 40 CFR 403 7
and 403 13, any new source subject to
this subpart which introduces
pollutants into a publicly owned
treatment works must comply with 40
CFR part 403 and achieve the
pretreatment standards for existing
sources as follows There shall be no
discharge of process wastewater
pollutants
7 Tables 8, 9, and 10 are added to
part 455 to read as follows
Table 8 to Part 455—List of Pollution
Prevention Alternative Practices
A modification to the list of practices
on this table that an individual facility
must comply with to be eligible for the
pollution prevention alternative is
allowed with acceptable justification as
listed on this table as approved by the
permit writer or control authority (using
BPJ/BEJ) after submittal by the facility of
a request for modification A
modification, for purposes of this table,
means that a facility would no longer
have to perform a listed practice or
would need to comply with a modified
practice However, the modification
only applies to the specific practice for
which the modification has been
justified and to no other listed practices
Facilities are required to thoroughly
discuss all modifications in the on-site
compliance paperwork as described
above in the limitations and standards
(§455 41(c))
1 Must use water conservation
practices These practices may include,
but are not limited to using spray
nozzles or flow reduction devices on
hoses, low volume/high pressure rinsing
equipment, floor scrubbing machines,
mop(s) and bucket(s), and counter
current staged drum rinsing stations
[Modification allowed when Rinsing
narrow transfer lines or piping where
sufficient rinsing is better achieved by
flushing with water ]
2 Must practice good housekeeping
(a) Perform preventative maintenance
on all valves and fittings and repair
leaky valves and fittings in a timely
manner,
(b) Use drip pans under any valves or
fittings where hoses or lines are
routinely connected and disconnected,
collect for reuse when possible, and
(c) Perform quick cleanup of leaks and
spills in outdoor bulk storage or process
areas
3 Must sweep or vacuum dry
production areas prior to rinsing with
water
4 Must clean interiors of dry
formulation equipment with dry carrier
prior to any water rinse The carrier
material must be stored and reused in
future formulation of the same or
compatible product or properly
disposed of as solid waste
5 If operating continuous overflow
Department of Transportation (DOT)
aerosol leak test baths—>
Must operate with some recirculation
6 If operating air pollution control
wet scrubbers—>
Must operate as recirculating
scrubbers (periodic blowdown is
allowed as needed)
[Modification allowed when Facility
demonstrates that they would not be
able to meet Resource Conservation
Recovery Act or Clean Air Act (CAA)
requirements)
7 When performing rinsing of raw
material drums, storage drums, and/or
shipping containers that contained
liquid PAl(s) and/or inert ingredients for
the formulation of water-based
products—>
Must reuse the drum/shipping
container rinsate DIRECTLY into the
formulation at the time of formulation,
or store for use in future formulation of
same or compatible product, or use a
staged drum rinsing station (counter
current rinsing)
[Modification allowed when the drum/
shipping container holds inert
mgredient(s) only and (1) the facility
can demonstrate that, after using water
conservation practices, the large
concentration of inert ingredient in the
formulation creates more volume than
could feasibly be reused, or (2) the
facility can demonstrate that the
concentration of the inert in the
formulation is so small that the reuse
would cause a formulation to exceed the
ranges allowed in the Confidential
Statement of Formula (CSF) (40 CFR
158 155) |
8 When performing rinsing of raw
material drums, storage drums, and/or
shipping containers that contained
liquid PAI(s) and/or inert ingredients for
the formulation of solvent-based
products—>
Must reuse the drum/shipping
container rinsate DIRECTLY into the
formulation at the time of formulation
or store for use in future formulation of
same or compatible product
[Modification allowed when
(a) The drum/shipping container
holds inert mgredient(s) only and (1)
The facility can demonstrate that, after
using water conservation practices, the
large concentration of inert ingredient in
the formulation creates more volume
than could feasibly be reused, or (2) the
facility can demonstrate that the
concentration of the inert in the
formulation is so small that the reuse
would cause a formulation to exceed the
ranges allowed in the Confidential
Statement of Formula (CSF) (40 CFR
158 155), or
(b) Drums/shipping containers are
going to a drum refurbisher/recycler
who will only accept drums rinsed with
water ]
9 Must dedicate PFPR production
equipment by water-based versus
solvent-based products Dedicated
solvent-based or water-based equipment
may be used on a non-routine basis for
non-dedicated operations, however the
facility may not discharge the solvent/
aqueous changeover rinsate as part of
their P2 allowable discharge (i e . the
facility must achieve zero discharge of
those process wastewater pollutants)
[Modification allowed when Facility
has installed and is using a solvent
recovery system for the changeover
rinsate (can also be used for other
solvent recovery) ]
10 Must store the rinsate from
interior rinsing (does not include drum/
shipping container rinsate) for reuse in
future formulation of same or
compatible product
[Modification allowed when
(a) Facility has evidence of biological
growth or other product deterioration
over a typical storage period,
(b) Facility has space limitations. BUT
must still store rinsates for most
frequently produced products,
(c) Manufacturer (or formulator
contracting for toll formulating) has
directed otherwise (i e . send back to
them or send for off-site disposal),
(d) Facility is dropping registration or
proauction of the formulation and there
is no compatible formulation for reuse
of the rinsates or facility can provide
reasonable explanation of why it does
not anticipate formulation of same or
compatible formulation within the next
12 months,
(e) Facility only performs packaging
of the pesticide product from which
interior rinsate is generated, or
(f) Facility has demonstrated that it
must use a detergent to clean the
equipment ]
Notes
For indirect dischargers After following
the practices above, some wastewaters may
require pretreatment prior to discharge to
POTWs See definition of pollution
prevention allowable discharge for indirect
dischargers (§455 41(d))
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57554 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
For direct dischargers After following the
practices above all wastewaters require
treatment prior to discharge directly to the
nation's waters See definition of pollution
prevention allowable discharge for direct
dischargers (§455 41(e))
Additional information and guidance on
implementing these P2 practices as well as
evaluating compliance with these practices
will be available in a P2 Guidance Manual for
the PFPR Industry
Table 9 to Part 455.—Group 2
Mixtures
Shaughnessey
code
Chemical name1
002201
Sabadilla alkaloids
006501
Aromatic petroleum denva-
tive solvent
006602
Heavy aromatic naphtha
0166012
Dry ice
022003
Coal tar
025001
Coal tar neutral oils
025003
Creosote oil (Note Derived
from any source)
025004
Coal tar creosote
031801
Ammonium salts of C8-18
and C18' fatty acids
055601
BNOA
063501
Kerosene
063502
Mineral oil—includes paraffin
oil from 063503
063503
Petroleum distillate, oils, sol-
vent, or hydrocarbons, also
063506
P
Mineral spirits
067003
Terpineols (unspec )
067205
Pine tar oil
067207
Ester gum
067302
Amines, N-coco
alkyltrimelhylenedi-, ace-
tates
069152
Amines, coco alky).
hydrochlorides
070801
Red Squill glycoside
Table 9 to Part 455—Group 2
Mixtures—Continued
Shaughnessey
code
Chemical name1
071004
Cube Resins other than rote-
none
071501
Ryania speciosa, powdered
stems of
0726022
Silica gel
0726052
Silicon dioxide
079014
Turkey red oil
079021
Potassium salts of fatty
acids
079029
Fatty alcohols (52-61% C10,
39-46% C8, 0-3% C6, 0-
3% C12)
079034
Methyl esters of fatty acids
(100% C8-C12)
079059
Fatty alcohols (54 5% C10,
45 1% C8, 0 4% C6)
086803
Xylene range aromatic sol-
vent
107302
Polyhedral inclusion bodies
of Douglas fir tussock
moth nucl
107303
Polyhedral inclusion bodies
of gypsy moth
nucleopolyhedrosis
107304
Polyhedral inclusion bodies
of n sertifer
116902
Gibberellin A4 mixt with
Gibberellin A7
117001
Nosema locustae
128888
Lac'ofen (ANSI)
1289342
Nitrogen, liquid
129029
Bergamot Oil
224600
Diethanolamides of the fatty
acids of coconut oil (coded
079)
505200
Isoparaffinic hydrocarbons
1 Shaughnessey codes and chemical names
are taken directly from the FATES database
Several chemical names are truncated be-
cause the chemical names listed in the
FATES database are limited to 60 characters
2 EPA does not believe this PAI will persist
in sanitary streams long enough to reach a
POTW
Table 10 to Part 455—List of
Appropriate Pollution Control
Technologies
This table contains those pollutant
control technologies, such as hydrolysis,
chemical oxidation, precipitation and
activated carbon adsorption, which have
been used for estimating compliance
costs on a PAI specific basis In general,
these treatment technologies have been
determined to be effective in treating
pesticide containing wastewaters in
literature, in bench or pilot scale
treatability studies or in the Pesticide
Manufacturing effluent guidelines
These are the same technologies that are
presented as part of the Universal
Treatment System However, these
technologies are PAI specific and may
need to be used m conjunction with one
another to provide treatment for all PAIs
used at a facility over a period of time
In addition, facilities may experience
difficulties treating wastewaters that
contain emulsions, therefore,
"appropriate" treatment for emulsified
wastewaters must include an emulsion
breaking step For PAIs whose
technology is listed as "Pollution
Prevention", the permitting authority/
control authority can determine if
additional treatment is necessary
through best professional judgement/
best engineeringjudgement,
respectively
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies1
PAI name2
PAI
code3
Shaughnessy
code4
Structural group 5
Treatment technology
Dicofol
001
10501
DDT
Hydrolysis
Maleic Hydrazide
002
51501
Hydrazide
Activated Carton
EDB
003
42002
EDB
Activated Carbon
Vancide TH
004
82901
s-Triazine
Activated Carbon
1,3-Dichloropropene
005
29001
EDB
Hydrolysis
Thenarsazine Oxide
006
12601
Organoarsenic
Precipitation
Dowicil 75
007
17901
NR4
Activated Carbon
Tnadimefon
008
109901
s-Tnazine
Activated Carbon
Hexachlorophene
009
44901
Chlorophene
Activated Carbon
Tetrachlorophene
010
Chlorophene
Activated Carbon
Dichlorophene
011
55001
Chiorophene
Activated Carbon
Dichlorvos
012
84001
Phosphate
Hydrolysis
Landrin-2
013
Carbamate
Activated Carbon
2,3,6-T, S&E or Fenac
014
82605
2,4-D
Activated Carbon
2,4,5-T and 2,4,5-T, S&E
015
n
2,4-D
Activated Carbon
2,4-D (2,4-D, S&E)
016
n
2,4-D
Chemical Oxidation
2,4-DB, S&E
017
o
2,4-D
Activated Carbon
Dyrene or Anilazine
018
80811
s-Tnazine
Activated Carbon
Dinocap
019
36001
Phenylcrotonate
Actvated Carbon
Dichloran or DCNA
020
31301
Aryl Halide
Activated Carbon
Busan 90
021
8707
Miscellaneous Organic
Activated Carbon
Mevinphos
022
15801
Phosphate
Hydrolysis
Sulfallate
023
Dithiocarbamate
Activated Carbon
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Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57555
Table 10 to Part 455—List of Appropriate Pollution Control Technologies1—Continued
PAI name2
PAI
code3
Shaughnessy
code"
Structural group5
Treatment technology
Chlorfenvinphos
024
84101
Phosphate
Activated Carbon
Cyanazine or Bladex
025
100101
s-Tnazine
Activated Carbon
Propachlor
026
19101
Acetanilide
Activated Carbon
MCPA, S&E
027
(*)
2,4-D
Activated Carbon
Octhilinone
028
99901
Heterocyclic
Activated Carbon
Pindone
029
67703
Miscellaneous Organic
Activated Carbon
Dichlorprop, S&E
030
(*)
2,4-D
Activated Carbon
MCPP, S&E or Mecoprop
031
C)
2,4-D
Activated Carbon
Thiabendazole
032
60101
Heterocyclic
Activated Carbon
Belclene 310
033
80815
s-Tnazine
Activated Carbon
Chlorprop, S&E
034
21202
2,4-D
Activated Carbon
Busan 72 or TCMTB
035
35603
Heterocyclic
Hydrolysis
Chlorophacinone
037
67707
Miscellaneous Organic
Activated Carbon
Landnn-1
038
Carbamate
Activated Carbon
Pronamide
039
101701
Chlorobenzamide
Activated Carbon
Methiocarb or Mesurol
040
100501
Carbamate
Hydrolysis
Propanil
041
28201
Chloropropionanilide
Activated Carbon
Polyphase 6
042
107801
Carbamate
Activated Carbon
Coumafuryl or Fumann
043
86001
Coumarin
Activated Carbon
DNOC
044
Phenol
Activated Carbon
Metnbuzin
045
101101
Tnazathione
Activated Carbon
CPA, S&E
046
(")
2,4-D
Activated Carbon
MCPB, S&E
047
19202
2,4-D
Activated Carbon
Aminocarb
048
Carbamate
Hydrolysis
Etndiazole
049
84701
Heterocyclic
Activated Carbon
Ethoxyquin
050
55501
Quinolin
Activated Carbon
Acephate or Orthene
052
103301
Phosphoroamidothioate
Activated Carbon
Acifluorfen
053
114402
Benzoic Acid
Activated Carbon
Alachlor
054
90501
Acetanilide
Activated Carbon
Aldicarb
055
98301
Carbamate
Hydrolysis
Allethnn
057
(')
Pyrethnn
Activated Carbon
Ametryn
058
80801
s-Tnazine
Activated Carbon
Amitraz
059
106201
Iminamide
Activated Carbon
Atrazine
060
80803
s-Tnazine
Hydrolysis
Bendiocarb
061
105201
Carbamate
Hydrolysis
Benomyl
062
99101
Carbamate
Hydrolysis
BHC
063
Lindane
Hydrolysis
Benzyl Benzoate
064
9501
Ester
Activated Carbon
Lethane 60
065
Thiocyanate
Activated Carbon
Bifenox
066
104301
Nitrobenzoate
Activated Carbon
Biphenyl
067
17002
Aryl
Activated Carbon
Bromacil (Uthium Salt)
068
C)
Uracil
Activated Carbon
Bromoxynil
069
D
Benzomtnle
Activated Carbon
Butachlor
070
Acetanilide
Activated Carbon
Giv-gard
071
101401
Miscellaneous Organic
Activated Carbon
Cacodylic Acid
072
o
Organoarsenic
Precipitation
Captafol
073
Phthalimide
Hydrolysis
Captan
074
81301
Phthalimide
Hydrolysis
Carbaryl
075
56801
Carbamate
Hydrolysis
Carbofuran
076
90601
Carbamate
Hydrolysis
Carbosulfan
077
Carbamate
Activated Carbon
Chloramben
078
n
Benzoic Acid
Activated Carbon
Chlordane
079
58201
Tricyclic
Activated Carbon
Chloroneb
080
27301
Aryl Halide
Chemical Oxidation
Chloropicnn
081
81501
Alkyl Halide
Chemical Oxidation
Chlorothaloml
082
81901
Chloropropionaniliae
Activated Carbon
Chloroxuron
083
Urea
Activated Carbon
Stirofos
084
83701
Phosphate
Hydrolysis
Chlorpynfos Methyl
085
59102
Phosphorothioate
Hydrolysis
Chlorpynfos
086
59101
Phosphorothioate
Chemical Oxidation
Mancozeb
087
14504
Dithiocarbamate
Activated Carbon
Bioquin (Copper)
088
24002
Organocopper
Precipitation
Copper EDTA
089
39105
Organocopper
Precipitation
Pydrin or Fenvalerate
090
109301
Pyrethrin
Activated Carbon
Cycloheximide
091
Cyclic Ketone
Activated Carbon
Dalapon
092
O
Alkyl Halide
Activated Carbon
Dienochlor
093
27501
HCp
Activated Carbon
Demeton
094
Phosphorothioate
Hydrolysis
Desmedipham
095
104801
Carbamate
Hydrolysis
Amobam
096
Miscellaneous Organic
Activated Carbon
DBCP
097
EDB
Activated Carbon
-------
57556 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 10 to Part 455—List of Appropriate Pollution Control Technologies1—Continued
PAI name2
PAI
code3
Shaughnessy
code4
Structural group5
Treatment technology
Dicamba
098
n
Aryl Halide
Activated Carbon
Dichlone
099
29601
Quinone
Activated Carbon
Thiophanate Ethyl
100
103401
Carbamate
Hydrolysis
Perthane
101
DDT
Activated Carbon
EXD
102
Dithiocarbamate
Activated Carbon
Diazinon
103
57801
Phosphorothioate
Hydrolysis
Diflubenzuron
104
108201
Urea
Activated Carbon
Dimethoate
106
35001
Phosphorodithioate
Hydrolysis
Parathion Methyl
107
53501
Phosphorothioate
Hydrolysis
Dicrotophos
108
35201
Phosphate
Activated Carbon
Crotoxyphos
109
58801
Phosphate
Activated Carbon
DCPA
110
78701
Aryl Halide
Activated Carbon
Tnchlorofon
111
57901
Phosphonate
Activated Carbon
Dinoseb
112
37505
Phenol
Activated Carbon
Dioxathion
113
37801
Phosphorodithioate
Hydrolysis
Diphacinone
114
67701
Indandione
Activated Carbon
Diphenamide
115
36601
Acetamide
Activated Carbon
Diphenylamine
116
38501
Aryl Amine
Activated Carbon
MGK 326
117
47201
Ester
Activated Carbon
Nabonate
118
63301
Isocyanate
Chemical Oxidation
Diuron
119
35505
Urea
Activated Carbon
Metasol DGH
120
44303
NR4
Activated Carbon
Dodine
121
44301
NR4
Activated Carbon
Endosulfan
122
79401
Tricyclic
Activated Carbon
Endothall (Endothall S&E)
123
o
Bicyclic
Activated Carbon
Endnn
124
41601
Tncyclic
Activated Carbon
Ethalfluralin
125
113101
Toluidine
Activated Carbon
Ethion
126
58401
Phosphorodithioate
Hydrolysis
Ethoprop
127
41101
Phosphorodithioate
Activated Carbon
Fenamiphos
128
100601
Phosphoroamidate
Activated Carbon
Chlorobenzilate
129
28801
Aryl Halide
Activated Carbon
Butylate
130
41405
Thiocarbamate
Activated Carbon
Famphur
131
Phosphorothioate
Hydrolysis
Fenarimol
132
206600
Pynmidine
Activated Carbon
Fenthion or Baytex
133
53301
Phosphorothioate
Hydrolysis
Ferbam
134
34801
Dithiocarbamate
Activated Carbon
Fluometuron
135
35503
Urea
Activated Carbon
Fluoroacetamide
136
Acetamide
Activated Carbon
Folpet
137
81601
Phthalimide
Hydrolysis
Glyphosate (Glyphosate S&E)
138
(")
Phosphoroamidate
Chemical Oxidation
Glyphosine
139
Phosphoroamidate
Activated Carbon
Heptachlor
140
44801
Tncyclic
Activated Carbon
Cycloprate
141
Thiocarbamate
Activated Carbon
Hexazinone
142
107201
s-Tnazine
Activated Carbon
Isofenphos
143
109401
Phosphoroamidothioate
Activated Carbon
Isopropalin
144
100201
Toluidine
Activated Carbon
Propham
145
Carbamate
Hydrolysis
Karabutilate
146
97401
Carbamate
Hydrolysis
Lindane
147
9001
Lindane
Activated Carbon
Linuron
148
35506
Urea
Chemical Oxidation
Malachite Green
149
39504
NR4
Activated Carbon
Malathion
150
57701
Phosphorodithioate
Hydrolysis
Maneb
151
14505
Dithiocarbamate
Activated Carbon
Manam
152
Dithiocarbamate
Activated Carbon
Mefluidide
153
114002
Carbamate
Activated Carbon
Methamidophos
154
1012C1
Phosphoroamidothioate
Activated Carbon
Methidathion
155
100301
Phosphorodithioate
Activated Carbon
Methomyl
156
90301
Carbamate
Hydrolysis
Methoprene
157
(*)
Ester
Activated Carbon
Methoxychlor
158
34001
DDT
Hydrolysis
Methyl Bromide
160
53201
Alkyl Halide
Activated Carbon
Moriosodium Methyl Arsenate
161
(*)
Organoarsenic
Precipitation
Nalco D-2303
163
68102
Thiocyanate
Activated Carbon
Quinomethionate
164
54101
Miscellaneous Organic
Activated Carbon
Metolachlor
165
108801
Acetanilide
Activated Carbon
Mexacarbate
166
Carbamate
Hydrolysis
Metiram
167
14601
D,thiocarbamate
Activated Carbon
Monuron TCA
168
35502
Urea
Activated Carbon
Monuron
169
35501
Urea
Activated Carbon
Napropamide
170
103001
Carbamate
Activated Carbon
Deet
171
80301
Toiuamide
Activated Carbon
-------
Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57557
Table 10 to Part 455—List of Appropriate Pollution Control Technologies1—Continued
PAI name2
PAI
code3
Shaughnessy
code"
Structural group 5
Treatment technology
Nabam
172
14503
Dithiocarbamate
Chemical Oxidation
Naled
173
34401
Phosphate
Hydrolysis
Norea
174
Urea
Activated Carbon
Norflurazon
175
105801
Heterocyclic
Activated Carbon
Naptalam or Neptalam
176
30703
Phthalamide
Activated Carbon
MGK 264
177
57001
Bicyclic
Activated Carbon
Benfluralin
178
84301
Toluidine
Activated Carbon
Sulfotepp
179
79501
Phosphorothioate
Activated Carbon
Aspon
180
Phosphorothioate
Activated Carbon
Coumaphos
181
36501
Phosphorothioate
Hydrolysis
Fensulfothion
182
32701
Phosphorothioate
Hydrolysis
Disulfoton
183
32501
Phosphorodithioate
Hydrolysis
Fenitrothion
184
105901
Phosphorothioate
Hydrolysis
Phosmet
185
59201
Phosphorodithioate
Hydrolysis
Azinphos Methyl (Guthion)
186
58001
Phosphorodithioate
Hydrolysis
Oxydemeton Methyl
187
58702
Phosphorothioate
Activated Carbon
Organo-Arsenic Pesticides
188
Orgarioarsenic
Precipitation
Organo-Cadmium Pesticides
189
Organocadmium
Precipitation
Organo-Copper Pesticides
190
(')
Organocopper
Precipitation
Organo-Mercury Pesticides
191
C)
Organomercury
Precipitation
Organo-Tin Pesticides
192
O
Organotn
Precipitation
o-Dichlorobenzene
193
59401
Aryl Halide
Activated Carbon
Oryzalin
194
104201
Sulfanilamide
Activated Carbon
Oxamyl
195
103801
Carbamate
Hydrolysis
Oxyfluorfen
196
111601
Miscellaneous Organic
Activated Carbon
Bolstar
197
111501
Phosphorodithioate
Activated Carbon
Sulprofos Oxon
198
Phosphorothioate
Hydrolysis
Santox (EPN)
199
41801
Phosphorodithioate
Hydrolysis
Fonofos
200
41701
Phosphorodithioate
Hydrolysis
Propoxur
201
47802
Carbamate
Hydrolysis
p-Dichlorobenzene
202
61501
Aryl Halide
Activated Carbon
Parathion Ethyl
203
57501
Phosphorothioate
Hydrolysis
Pendimethalin
204
108501
Benzeneamine
Activated Carbon
PCNB
205
56502
Aryl Halide
Activated Carbon
POP or Penta
206
(*)
Phenol
Activated Carbon
Perfluidone
207
Sulfonamide
Activated Carbon
Permethrm
208
109701
Pyrethnn
Activated Carbon
Phenmedipham
209
9S701
Carbamate
Hydrolysis
Nemazine
210
64501
Heterocyclic
Activated Carbon
Phorate
212
57201
Phosphorodithioate
Hydrolysis
Phosalone
213
97701
Phosphorodithioate
Hydrolysis
Phosphamidon
214
18201
Phosphate
Hydrolysis
Picloram
215
(*)
Pyndine
Activated Carbon
Piperonyl Butoxide
216
67501
Ester
Activated Carbon
PBED or WSCP (Busan 77)
217
69183
NR4
Activated Carbon
Busan 85 or Arylane
218
34803
Dithiocarbamate
Chemical Oxidation
Busan 40
219
102901
Dithiocarbamate
Chemical Oxidation
KN Methyl
220
39002
Dithiocarbamate
Chemical Oxidation
Metasol J26
221
101301
Miscellaneous Organic
Activated Carbon
Profenofos
222
111401
Phosphorothioate
Activated Carbon
Prometon or Caparol
223
80804
s-Tnazine
Chemical Oxidation
Prometryn
224
80805
s-Tnazine
Activated Carbon
Propargite
225
97601
Miscellaneous Organic
Activated Carbon
Propamine
226
80808
s-Tnazine
Activated Carbon
Propionic Acid
227
77702
Alky I Acid
Activated Carbon
Previcur N
228
119301
Carbamate
Hydrolysis
Pyrethnn Coils
229
69004
Pyrethnn
Activated Carbon
Pyretnrum I
230
69001
Pyrethnn
Hydrolysis
Pyrethrum II
231
69002
Pyrethnn
Hydrolysis
Pyrethnns
232
C)
Pyrethnn
Hydrolysis
Resmethnn
233
(')
Pyrethnn
Activated Carbon
Fenchlorphos or Ronnel
234
58301
Phosphorothioate
Hydrolysis
Mexide or Rotenone
235
71003
Miscellaneous Organic
Activated Carbon
DEF
236
74801
Phosphorotrithioate
Activated Carbon
Siduron or Tupersan
237
35509
Urea
Activated Carbon
Silvex
238
(*)
2,4-D
Activated Carbon
Simazine
239
80807
s-Triazine
Activated Carbon
Sodium Bentazon
240
103901
Heterocyclic
Chemical Oxidation
Carbam-S or Sodam
241
34804
Dithiocarbamate
Chemical Oxidation
Sodium Fluoroacetate
242
75003
Acetamide
Activated Carbon
Vapam or Metham Sodium
243
39003
Dithiocarbamate
Chemical Oxidation
-------
57558 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies1—Continued
PAI name2
PAI
code3
Shaughnessy
code4
Structural group5
Treatment technology
Sulfoxide
244
57101
Miscellaneous Organic
Activated Carbon
Cycloate or Ro-Neet
245
41301
Thiocarbamate
Activated Carbon
EPrecipitationC or Eptam
246
41401
Thiocarbamate
Activated Carbon
Molinate
247
41402
Thiocarbamate
Activated Carbon
Pebulate or Tillman
248
41403
Thiocaibamate
Activated Carbon
Vemolate or Vernam
249
41404
Thiocarbamate
Activated Carbon
HPrecipitationMS
250
35604
Thiosulphonate
Activated Carbon
Bensulide or Betesan
251
9801
Phosphorodithioate
Activated Carbon
Tebuthiuron
252
105501
Urea
Activated Carbon
Temephos
253
59001
Phosphorothioate
Hydrolysis
Terbacil
254
12701
Uracil
Activated Carbon
Terbufos or Counter
255
105001
Phosphorodithioate
Activated Carbon
Terbuthylazine
256
80814
s-Tnazine
Activated Carbon
Terbutryn
257
80813
s-Tnazine
Activated Carbon
Tetrachlorophenol
258
63004
Phenol
Activated Carbon
Dazomet
259
35602
Heterocyclic
Chemical Oxidation
Thiophanate Methyl
260
102001
Carbamate
Hydrolysis
Thiram
261
79801
Dithiocarbamate
Activated Carbon
Toxaphene
262
80501
Bicyclic
Activated Carbon
Merphos
263
74901
Phosphorotrithioate
Hydrolysis
Tnfluralin orTreflan
264
36101
Toluidine
Activated Carbon
Warfarin
265
O
Coumann
Activated Carbon
Zinc MBT
266
51705
Organozinc
Precipitation
Zineb
267
14506
Dithiocarbamate
Activated Carbon
Ziram
268
34805
Dithiocarbamate
Activated Carbon
Tnallate
269
78802
Thiocarbamate
Activated Carbon
Phenothnn
270
69005
Pyrethnn
Activated Carbon
Tetramethnn
271
69003
Pyrethnn
Activated Carbon
Chloropropham
272
18301
Carbamate
Hydrolysis
Non-272 PAIs
CFC 11
13
Alkyl Halide
Activated Carbon
CFC 12
14
Alkyl Halide
Activated Carbon
Polyethylene
152
Polymer
Activated Carbon
Acrolein
701
Alcohol
Activated Carbon
Dimethyl-m-dioxan-4-ol acetate
1001
Heterocyclic
Activated Carbon
Dodecyl alcohol
1509
Alcohol
Activated Carbon
Tetradecyl alcohol
1510
Alcohol
Activated Carbon
Rosin amine D acetate
4201
Alkyl Acid
Activated Carbon
Dihydroabietylamine acetate
4213
Alkyl Acid
Activated Carbon
Amitrole
4401
Heterocyclic
Activated Carbon
Ally) isothiocyanate
4901
Thiocyanate
Activated Carbon
AMS
5501
Inorganic
Pollution Prevention
Calcium sulfate
5602
Inorganic
Pollution Prevention
Tartar emetic
6201
Inorganic
Pollution Prevention
Diphenylstibene 2-ethy)hexanoate
6202
Aryl
Activated Carbon
Streptomycin
6306
Heterocyclic
Activated Carbon
Oxytetracycline hydrochloride
6308
Phthalamide
Activated Carbon
Streptomycin sesquisulfate
6310
Heterocyclic
Activated Carbon
Neomycin sulfate
6313
Benzeneamine
Activated Carbon
Antimycin A
6314
Heterocyclic
Activated Carbon
Calcium oxytetracycline
6321
Phthalamide
Activated Carbon
Espesol 3A
6601
Phosphorothioate
Activated Carbon
Arsenic acid
6801
Metallic
Precipitation
Arsenic acid anhydride
6802
Metallic
Precipitation
Arsenous acid anhydride
7001
Metallic
Precipitation
Copper oxychlonde
8001
Metallic
Precipitation
Basic cupnc sulfate
8101
Metallic
Precipitation
Basic copper III—zinc sulfate complex (De-
8102
Metallic
Precipitation
clare copper and
Bromophos
8706
Phosphorothioate
Activated Carbon
Benzyl bromoacetate
8710
Benzoic acid
Activated Carbon
Benzoic acid
9101
Benzoic acid
Activated Carbon
Benzyl diethyl ((2,6-xylylcarbamoyl)rnethyl)
9106
NR4
Activated Carbon
ammonium benzoate
Benzyl alcohol
9502
Aryl
Activated Carbon
3-Chloro-p-toluidine hydrochlonde
9901
Chloropropionanilide
Activated Carbon
Butoxyethoxy)ethyl thiocyanate
10002
Thiocyanate
Activated Carbon
2-Naphthol
10301
Phenol
Activated Carbon
Bone acid
11001
Inorganic
Pollution Prevention
Banum metaborate
11101
Inorganic
Pollution Prevention
-------
Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57559
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies 1— Continued
PAI name2
PAI
code3
Shaughnessy
code4
Structural group5
Treatment technology
Boron sodium oxide (B8Na2013), tetra-
11103
Inorganic
Pollution Prevention
hydrate (12280-03-4)
Sodium metaborate (NaB02)
11104
Inorganic
Pollution Prevention
Boron sodium oxide (B8Na2013) (12008-
11107
Inorganic
Pollution Prevention
*f 1 t j
Boron sodium oxide (B4Na207),
11110
Inorganic
Pollution Prevention
pentahydrate (12179-04-3)
Boron sodium oxide (B4Na207) (1330-43-
11112
Inorganic
Pollution Prevention
i)
Polybutene
11402
Polymer
Activated Carbon
Polyisobutytene
11403
Polymer
Activated Carbon
Butyl cellosolve
11501
Alcohol
Activated Carbon
Butoxypolypropylene glycol
11901
Polymer
Activated Carbon
Neburon (ANSI)
12001
Chloropropionanilide
Activated Carbon
Methyltrimethylenedioxy)bis(4-methyl-l,3,2-
12401
Bicyclic
Activated Carbon
dioxabonnane)
0xybis(4,4,6-tnmethyl-1,3,2-dioxabonnane)
12402
Bicyclic
Activated Carbon
Cadmium chtonde
12902
Metallic
Precipitation
Lead arsenate, basic
13502
Metallic
Precipitation
Lead arsenate
13503
Metallic
Precipitation
Sodium arsenate
13505
Metallic
Precipitation
Sodium arsenite
13603
Metallic
Precipitation
Potassium bromide
13903
Inorganic
Pollution Prevention
Camphor
15602
Bicyclic
Actvated Carbon
Carbon disulfide
16401
Inorganic
Pollution Prevention
Carbon tetrachloride
16501
Alkyl Halide
Activated Carbon
Barban (ANSI)
17601
Carbamate
Activated Carbon
Chloro-2-propenyl)-3,5,7,tnaza-1-azo
17902
Tncyclic
Actvated Carbon
niatncyclo(3 3 1 1)sup
Chlormequat chlonde
18101
NR4
Actvated Carton
Chloromethoxypropylmercunc acetate
18401
Metallic
Precipitation
Allidochlor
19301
Acetanilide
Actvated Carbon
Chromic acid
21101
Metallic
Precipitation
Chromic oxide
21103
Metallic
Precipitation
Cresol (unspec) (Cresylic acid)
22101
Phenol
Actvated Carbon
Cresol
22102
Phenol
Activated Carbon
Copper (metallic)
22501
Metallic
Precipitation
Copper ammonium carbonate
22703
Metallic
Precipitation
Copper carbonate
22901
Metallic
Precipitation
Copper hydroxide
23401
Metallic
Precipitation
Copper chlonde hydroxide (Cu2CI(0H)3)
23501
Metallic
Precipitation
Copper oxychlonde sulfate
23503
Metallic
Precipitation
Copper sulfate
24401
Metallic
Precipitation
Copper (from tnethanolamine complex)
24403
Metallic
Precipitation
Copper as metallic (in the form of chelates
24405
Metallic
Precipitation
of copper citrat)
Copper as elemental from copper—ethyl-
24407
Metallic
Precipitation
enediamine complex
Copper sulfate (anhydrous)
24408
Metallic
Precipitation
Copper(l) oxide
25601
Metallic
Precipitation
Cuprous thiocyanate
25602
Metallic
Precipitation
Cyclohexane
25901
Aryl
Actvated Carbon
Cyclohexanone
25902
Cyclic Ketone
Actvated Carbon
Dichlobenil
27401
Chloropropionanilide
Actvated Carbon
Diquat dibromide
32201
NR4
Actvated Carbon
Dimethnn (ANSI)
34101
Pyrethnn
Activated Carbon
Dicapthon
34502
Phosphorothioate
Actvated Carbon
Ziram, cyclohexylamine complex
34806
Dithiocarbamate
Actvated Carbon
Butyl dimethyltrithioperoxycarbamate
34807
Dithiocarbamate
Activated Carbon
Daminozide
35101
Acetanilide
Actvated Carbon
Bis(tnchloromethyl) sulfone
35601
Miscellaneous Organic
Actvated Carbon
Bis(bromoacetoxy)-2-butene
35605
Alkyl Halide
Actvated Carbon
Dazomet, sodium salt
35607
Heterocyclic
Actvated Carbon
Butonate
35701
Phosphonate
Actvated Carbon
T nfluoro-4-nitro-m-cre-
6201
Phenol
Actvated Carbon
sol(")=alpha,alpha,alpha-
Trielhariolamine dinoseb (2-sec-Buty1-4,6-
37506
Phenol
Actvated Carbon
dinitrophenol)
Sodium 4,6-dinitro-o-cresylate
37508
Phenol
Actvated Carbon
Dmitrophenol
37509
Phenol
Activated Carbon
-------
57560 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies ^Continued
PAI name2
PAI
code3
Shaughnessy
code"
Structural group5
Treatment technology
Alkanol" amine dinoseb (2-sec-butyl-4,6-
37511
Phenol
Activated Carbon
ainitrophenol) *(s
Sodium dinoseb (2-sec-Butyl-4,6-
37512
Phenol
Activated Carbon
dimtrophenol)
Nitnlotriacetic acid, tnsodium salt
39106
Acetamide
Activated Carbon
T nsodium(2-hydroxyethyl)ethylene
39109
Acetamlide
Activated Carbon
diaminetriacetate
Ammonium ethylenediaminetetraacetate
39117
Acetamide
Activated Carbon
Pentasodium
39120
Acetamlide
Activated Carbon
diethylenelnaminepentaacetate
Etfiyt-l,3-hexanediol
41001
Alcohol
Activated Carbon
Ethylene
41901
Miscellaneous Organic
Pollution Prevention
EDC
42003
EDB
Activated Carbon
Methylene chlonde
42004
Alkyl Halide
Activated Carton
Methoxyethanol
42202
Alcohol
Activated Carbon
Ethylene glycol
42203
Alcohol
Activated Carbon
Butylene glycol
42205
Alcohol
Activated Carbon
Ethylene oxide
42301
Miscellaneous Organic
Pollution Prevention
Copper(ll) oxide
42401
Metallic
Precipitation
Cuprous and cupnc oxide, mixed
42403
Metallic
Precipitation
Propylene oxide
42501
Miscellaneous Organic
Pollution Prevention
Formaldehyde
43001
Miscellaneous Organic
Pollution Prevention
Paraformaldehyde
43002
Polymer
Activated Carbon
Bis(2-butylene) tetrahydro-2-furaldehyde
43302
T ncyclic
Activated Carbon
Giberellic acid
43801
T ncyclic
Activated Carbon
Potassium gibberellate
43802
Tncyclic
Activated Carbon
Glutaral
43901
Alcohol
Activated Carbon
Copper citrate
44005
Metallic
Precipitation
Methyl nonyl ketone
44102
Miscellaneous Organic
Activated Carbon
Methyl-2-pentanone
44105
Miscellaneous Organic
Activated Carbon
Monosodium 2,2'-methylenebis (3,4,6-tn-
44902
Chlorophene
Activated Carbon
chlorophenate)
Potassium 2,2'-methylenebis (3,4,6-tri-
44904
Chlorophene
Activated Carbon
chlorophenate)
Hexachloroepoxyoctahydro-endo, exo-
45001
Tncyclic
Actvated Carbon
dimethanoaphthalene 85%
Chlorhexidme diacetate
45502
Chloropropionanihde
Activated Carbon
Hydrocyanic acid
45801
Inorganic
Activated Carbon
Hydroxyethyl octyl sulfide
46301
Alcohol
Actvated Carbon
Heptadecenyl-2-(2-hydroxyethyl)-2-i
46608
NR4
Activated Carbon
midazolmium chlonde
Hydroxyettiyl)-2-alkyl-2-imidazoline (as in
45609
NR4
Activated Carbon
fatty acids of t
IBA
46701
Bicyclic
Activated Carbon
Dihydropyrone
46801
Cyclic ketone
Actvated Carbon
Butoxypolypropoxypolyethoxyethanol-iodine
46901
Polymer
Actvated Carbon
complex
Polyethoxypolypropoxyethanol-iodine com-
46904
Polymer
Actvated Carbon
plex
Use code no 046904
46909
Polymer
Actvated Carbon
(polyethoxypolypropoxy ethanol-iodine
complex)
lod'ne-potassium iodide complex
46917
Inorganic
Pollution Prevention
Alkyl-omega-hydroxypoly(oxyethylen e)-io-
46921
Polymer
Activated Carbon
dine complex *(100%
Lead acetate
48001
Metallic
Precipitation
Nickel sulfate hexahydrate
50505
Metallic
Precipitation
Maleic hydrazide, diethanolamine salt
51502
Hydrazide
Activated Carbon
Maleic hydrazide, potassium salt
51503
Hydrazide
Activated Carbon
Sodium 2-mercaptobenzothiolate
51704
Heterocyclic
Activated Carbon
Mercuric chloride
52001
Metallic
Precipitation
Mercurous chlonde
52201
Metallic
Precipitation
Metaldehyde
53001
Miscellaneous Organic
Activated Carbon
Methylated naphthalenes
54002
Aryl
Activated Carbon
Sodium 2,2'-methylenebis(4-chlorophenate)
55005
Chlorophene
Actvated Carbon
Naphthalene
55801
Aryl
Actvated Carbon
NAD
56001
Benzoic Acid
Actvated Carbon
NAA (1-Naphthaleneacetic Acid)
56002
Benzoic Acid
Actvated Carbon
Potassium 1-naphthaleneacetate
56003
Benzoic Acid
Actvated Carbon
Ammonium 1-naphthaleneacetate
56004
Benzoic Acid
Actvated Carbon
Sodium 1-naphthaleneacetate
56007
Benzoic Acid
Actvated Carbon
-------
Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57561
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies Continued
PAI name2
PAI
code3
Shaughnessy
code"
Structural group5
Treatment technology
Ethyl 1-naphthaleneacetate
56008
Benzoic Acid
Activated Carbon
Nitrophenol
56301
Phenol
Activated Carbon
Nicotine
56702
Pyridine
Activated Carbon
Carbophenothion (ANSI)
58102
Phosphorodithioate
Activated Carbon
Sodium 5-chloro-2-(4-chloro-2-(3-(3,4-
58802
Aryl Halide
Activated Carbon
dichlorophenyl)ureido)
Monocrotophos
58901
Phosphate
Activated Carbon
Chlordimeform
59701
Chloropropionanilide
Activated Carbon
Chlordimeform hydrochloride
59702
Chloropropionanilide
Activated Carbon
Thiabendazole hypophosphite
60102
Hydrazide
Actvated Carbon
Hexachlorobenzene
61001
Lindane
Activated Carbon
Butyl paraben
61205
Phenol
Activated Carbon
Paraquat dichloride
61601
Pyndine
Actvated Carbon
Chloro-4-phenylphenol
62206
Chlorophene
Actvated Carbon
Chloro-2-phenylphenol
62208
Chlorophene
Actvated Carbon
Chloro-2-biphenylol, potassium salt
62209
Chlorophene
Actvated Carbon
Chloro-2-phenylphenol
62210
Chlorophene
Actvated Carbon
Chloro-2-phenylphenol, potassium salt
62211
Chlorophene
Actvated Carbon
Sodium phenate
64002
Phenol
Actvated Carbon
Butylphenol, sodium salt
64115
Phenol
Actvated Carbon
Ammonium 2-phenylphenate
64116
Phenol
Actvated Carbon
Chloro-2-cyclopentylphenol
64202
Chlorophene
Actvated Carbon
Bithionolate sodium
64203
Chlorophene
Actvated Carbon
Chloro-3-cresoI
64206
Chlorophene
Actvated Carbon
Sodium 2,4,5-tnchlorophenate
64217
Chlorophene
Actvated Carbon
Aluminum phosphide
66501
Inorganic
Pollution Prevention
Phosphorus
66502
Inorganic
Pollution Prevention
Magnesium phosphide
66504
Inorganic
Pollution Prevention
1 -(A!kyl"amino)-3-ammopropane" (Fatty
67301
Iminamide
Actvated Carbon
acids of coconut oil)
Alkyl" amino)-3-aminopropane *(53%C12,
67305
Iminamide
Actvated Carbon
19%C14, 8 5%C16, 7%C8
Alkyramino)-3-aminopropane
67307
Iminamide
Actvated Carbon
benzoate*(fatty acids of coconut
Alkyl* dipropoxyamine "(47% C12, 18%
67308
Iminamide
Actvated Carbon
CI4, 10% C18, 9% C10, 8
Alkyl"amino)-3-aminopropane
67309
Iminamide
Actvated Carbon
hydroxyacetate* (aads of coconut
Alkyl* amino)-3-aminopropane *(42%C12,
67310
Iminamide
Actvated Carbon
26%C18, 15%C14, 8%C16
Alkyl"amino)-3-aminopropane diacetate"
67313
Iminamide
Actvated Carbon
(fatty acids of coconut
Octadecenyl-1,3-propanediamine
67316
Acetamide
Activated Carbon
monogluconate
Alkyl" amine acetate *(5%C8, 7%C10,
67329
Iminamide
Actvated Carbon
54%C12, 19%C14, 8%C16,
Pmdone sodium salt
67704
Indandione
Actvated Carbon
Diphacinone, sodium salt
67705
Indandione
Actvated Carbon
lsovaleryl-1,3-indandione, calcium salt
67706
Indandione
Actvated Carbon
Methyl isothiocyanate
68103
Thiocyanate
Pollution Prevention
Potassium dichromate
68302
Inorganic
Pollution Prevention
Sodium chromate
68303
Inorganic
Pollution Prevention
Sodium dichromate
68304
Metallic
Precipitation
Alkenyl" dimethyl ethyl ammonium bromide
69102
NR4
Actvated Carbon
*(90%C18', 10%C16')
Alkyr-N-ethyl morpholinium etnyl sulfate
69113
Heterocyclic
Actvated Carbon
*(92%C18, 8%C1S)
Alkyl" isoquinolinium bromide "(50% C12,
69115
Ouinolin
Actvated Carbon
30% C14, 17% C16, 3)
Alkyl" methyl isoquinolinium chlonde
69116
Quinolin
Actvated Carbon
*(55%C14, 12%C12, 17%C)
Cety1 tnmethyl ammonium bromide
69117
NR4
Actvated Carbon
Cetyl pyndinium bromide
69118
Pyridine
Actvated Carbon
Dodecyl dimethyl benzyl ammonium
69127
NR4
Achvated Carbon
naphthenate
Alkyl" dimethyl ethylbenzyl ammonium
69135
NR4
Actvated Carbon
cyclohexylsulfamate "(5)
Alkyr-N-ethyl morpholinium ethyl sulfate
69147
Heterocyclic
Activated Carbon
•(66%C18, 25%C16)
Alkyl" tnmethyl ammonium bromide
69153
NR4
Activated Carbon
*(95%C14, 5%C16)
-------
57562 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies 1—Continued
PAI name2
PAI
code3
Shaughnessy
code4
Structural groups
Treatment technology
Benzyl((dodecylcarbamoyl) methyl)di methyl
69159
NR4
Activated Carbon
ammonium chloride
Cetyl pyndimum chloride
69160
Pyridine
Activated Carbon
Alkyl" dimethyl ethyl ammonium bromide
69186
NR4
Activated Carbon
*(85%C16, 15%C18)
Cetyl-N-ethylmorpholinium ethyl sulfate
69187
Heterocyclic
Activated Carbon
Use code no 069102 (Alkenyl* Dimethyl
69198
NR4
Activated Carbon
Ethyl Ammonium bromide)
p-Aminopyndine
69201
Pyridine
Activated Carbon
Nitrapynn (ANSI)
69203
Pyridine
Activated Carbon
Alkyl pyridines
69205
Pyridine
Activated Carbon
Pyrazon (ANSI)
69601
Heterocyclic
Activated Carbon
Capsaicin (in oleoresin of capsicum)
70701
Phenol
Activated Carbon
Ryanodine
71502
Tricyclic
Activated Carbon
Silver
72501
Inorganic
Pollution Prevention
Silver chloride
72506
Inorganic
Pollution Prevention
Silver thiuronium acrylate co-polymer
72701
Polymer
Activated Carbon
Sodium chlorate
73301
Inorganic
Pollution Prevention
Calcium cyanide
74001
Inorganic
Pollution Prevention
Sodium cyanide
74002
Inorganic
Pollution Prevention
Cryolite
75101
Inorganic
Pollution Prevention
Sodium fluoride
75202
Inorganic
Pollution Prevention
Ammonium fluosilicate
75301
Inorganic
Pollution Prevention
Sodium fluosilicate
75306
Inorganic
Pollution Prevention
Potassium iodide
75701
Inorganic
Pollution Prevention
Potassium tetrathionate
75903
Inorganic
Pollution Prevention
Potassium nitrate
76103
Inorganic
Pollution Prevention
Sodium nitrate
76104
Inorganic
Pollution Prevention
Sodium nitnte
76204
Inorganic
Pollution Prevention
Benzenesulfonamide, N-chloro-, sodium salt
76501
Sulfonamide
Activated Carbon
Salicyclic acid
76202
Benzoic Acid
Activated Carbon
Ethoxyethyl p-methoxycinnamate
76604
Aryl
Activated Carbon
Calcium polysulfide
76702
Polymer
Activated Carbon
Strychnine
76901
Tncyclic
Activated Carbon
Strychnine sulfate
76902
Tncyclic
Activated Carbon
Niclosamide
77401
Chlorobenzamide
Activated Carbon
Dibromosalicylamilide
77402
Chlorobenzamide
Activated Carbon
Tnbromsalan
77404
Chlorobenzamide
Activated Carbon
Dibromosalicylanilide
77405
Chlorobenzamide
Activated Carbon
Chlorosalicylanilide
77406
Chlorobenzamide
Activated Carbon
Sulfur
77501
Inorganic
Pollution Prevention
Sulfaquinoxaline
77901
Sulfanilamide
Activated Carbon
Sulfacetamide
77904
Sulfanilamide
Activated Carbon
Sulfuryl fluoride
78003
Inorganic
Pollution Prevention
Sodium bisulfite
78201
Inorganic
Pollution Prevention
T etrachloroethylene
78501
EDB
Activated Carbon
Ethoxylated isooctylphenoi
79004
Phenol
Activated Carbon
Launc diethanolamide
79018
Acetamhde
Activated Carbon
Tnethanolamine oleate
79025
NR4
Activated Carbon
Dioctyl sodium sulfosuccinate
79027
Thiosulfonate
Activated Carbon
Use code no 069179 (alkyl"mono-
79036
Miscellaneous Organic
Activated Carbon
ethanolamide)
Alkyl" diethanolamide *(70%C12, 30%C14)
79045
Miscellaneous Organic
Activated Carbon
Tetradecyl formate
79069
Alkyl Acid
Activated Carbon
Polyoxyethylene sorbitol oleate-laurate
79075
Polymer
Activated Carbon
Polyethoxylated stearylamine
79094
Polymer
Activated Carbon
Capnc diethanolamide
79099
Acetanilide
Activated Carbon
Calcium thiosulfate
80101
Inorganic
Pollution Prevention
Ammonium thiosulfate
80103
Inorganic
Pollution Prevention
Thymoxydichloroacetic acid
80401
Benzoic Acid
Activated Carbon
Thymol
80402
Phenol
Activated Carbon
Sodium tnchloroacetate
81001
Alkyl Halide
Activated Carbon
Tnchloroacetic acid
81002
Alkyl Halide
Activated Carbon
Hexahydro-1,3,5-tns(2-hydroxyethyl)-s-tri-
a7ino
83301
s-Tnazine
Activated Carbon
etc II IC
2-(Hydroxymethyl)-2-nitro-l,3-propanediol
83902
Alcohol
Activated Carbon
Bomyl
84201
Phosphate
Activated Carbon
Turpentine
84501
Miscellaneous Organic
Activated Carbon
Chloro-1 -(2,5-dichlorophenyl)vinyl) 0,0-
84901
Phosphorothioafe
Activated Carbon
diethyl phosphorothi
Zinc chloride
87801
Metallic
Precipitation
-------
Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57563
Table 10 to Part 455—List of Appropriate Pollution Control Technologies1—Continued
PAI name 2
PAI
code3
Shaughnessy
code"
Structural group 5
Treatment technology
Zinc 2-pyndinethiol-1-oxide
88002
Metallic
Precipitation
Hydroxy-2-(1H)-pyndinethione, sodium salt
88004
Pyridine
Activated Carbon
Omadine TBAO
88005
Pyridine
Activated Carbon
Zinc naphthenate
88301
Metallic
Precipitation
Zinc oxide
88502
Metallic
Precipitation
Zinc phosphide (Zn3P2)
88601
Metallic
Precipitation
Zinc phenol sulfonate
89002
Metallic
Precipitation
Zinc sulfate, basic
89101
Metallic
Precipitation
Dimetilan
90101
Carbamate
Activated Carbon
Carboxin
90201
Heterocyclic
Activated Carbon
Oxycarboxin
90202
Heterocyclic
Activated Carbon
Benzocaine
97001
Benzeneamine
Activated Carbon
Piperalin
97003
2,4-D
Actvated Carbon
Tetracaine hydrochlonde
97005
Benzeneamine
Activated Cartoon
Formetanate hydrochlonde
97301
Toluamide
Actvated Carbon
Azacosterol HCl
98101
Tncyclic
Activated Carbon
Use code no 039502 (gentian violet)
98401
NR4
Activated Carbon
Ammonium alum
98501
Inorganic
Pollution Prevention
Bismuth subgallate
98601
Metallic
Precipitation
Chlorflurenol, methyl ester
98801
Aryl Halide
Activated Carbon
Benzisothiazolin-3-one
98901
Heterocyclic
Activated Carbon
Methyl 2-benzimidazolecarbamate phos-
99102
Carbamate
Activated Carbon
phate
Ethephon
99801
Phosphate
Activated Carbon
Pentanethiol
100701
Miscellaneous Organic
Activated Carbon
Nitrobutyl)morpholine
100801
Heterocyclic
Activated Carbon
Ethyl-2-nitrotnmethylene)dimorpholine
100802
Heterocyclic
Activated Carbon
Tolyl dnodomethyl sulfone
101002
Thiosulfonate
Activated Carbon
Isobutync acid
101502
Alkyl Acid
Activated Carbon
Dibromo-3-nitnlopropionamide
101801
Acetamide
Activated Carbon
Polyethoxylated oleylamine
101901
Acetamide
Activated Carbon
Dinitramine (ANSI)
102301
Nitrobenzoate
Activated Carbon
Phenylethyl propionate
102601
Phenylcrotonate
Activated Carbon
Eugenol
102701
Phenol
Actvated Carbon
Tricosene
103201
Miscellaneous Organic
Actvated Carbon
Tricosene
103202
Miscellaneous Organic
Actvated Carbon
Sodium 1,4',5'-tnchloro-2'-(2,4,5-
104101
2,4-D
Actvated Carbon
tnchlorophenoxy)methanes
Hexahydro-1,3,5-tns(2-hydroxypropyl)-s-tn-
105601
s-Tnazine
Activated Carbon
CUIIIC
Methazole
106001
Hydrazide
Activated Carbon
Difenzoquat methyl sulfate
106401
Hydrazide
Actvated Carbon
Butralin
106501
Benzeneamine
Actvated Carbon
Fosamine ammonium
106701
Carbamate
Actvated Carbon
Asulam
106901
Carbamate
Activated Carbon
Sodium asulam
106902
Carbamate
Actvated Carbon
Hydroxymethoxymethyl-1 -aza-3,7-dioxabicy-
107001
Bicyclic
Actvated Carbon
clo(3 3 0)octane
Hydroxymethyl-1-aza-3,7-dioxabicy-
107002
Bicyclic
Activated Carbon
clo(3 3 0)octane
Hydroxypoly(methyleneoxy)" methyl-1 -aza-
107003
Bicyclic
Actvated Carbon
3,7-dioxabicyclo(3 3)
Chloro-2-methyl-3(2H)-isothiazo!one
107103
Heterocyclic
Actvated Carbon
Methyl-3(2H)-isothiazolone
107104
Heterocyclic
Actvated Carbon
Tnmethoxysilyl)propyl dimethyl octadecyl
107401
NR4
Actvated Carbon
ammonium chloride
Kinoprene
107502
Ester
Activated Carbon
Tnfonne (ANSI)
107901
Hydrazide
Actvated Carbon
Pinmiphos-methyl (ANSI)
108102
Phosphorothioate
Activated Carbon
Thiobencarb
108401
Thiocarbamate
Actvated Carbon
Ancymidol (ANSI)
108601
Pynmidine
Activated Carbon
Oxadiazon (ANSI)
105001
Hydrazide
Activated Carbon
Mepiquat chlonde
109101
NR4
Activated Carbon
Fluvalinate
109302
Toluamide
Activated Carbon
Chioro-N-(hydroxymethyl)acetamide
109501
Acetamide
Activated Carbon
Dikegulac sodium
109601
Tricyclic
Actvated Carbon
Iprodione (ANSI)
109801
Hydrazide
Actvated Carbon
Phenylmethyl)-9-(tetrahydro-2H-pyran-2-yl)-
110001
Pynmidine
Activated Carbon
9H-punn-6-arnme
Prodiamine
110201
Benzeneamine
Actvated Carbon
Erioglaucine
110301
Benzeneamine
Activated Carbon
-------
57564 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 10 to Part 455 —List of Appropriate Pollution Control Technologies 1—Continued
PAI name2
PAI
code3
Shaughnessy
code"
Structural group5
Treatment technology
Tartrazine
110302
Hydrazide
Activated Carbon
Dodemorph acetate
110401
Heterocyclic
Activated Carbon
Ethofumesate (ANSI)
110601
Bicyclic
Activated Carbon
Aldoxycarb (ANSI)
110801
Carbamate
Activated Carbon
Diclofop-methyl
1 10902
Aryl Halide
Activated Carbon
Bromo-1 -(bromomethyl)-l ,3-
111001
Isocyanate
Activated Carbon
propanediCarbon itnle
Poly (imino imidocar-
111801
Polymer
Activated Carbon
bonyliminoimidocar-
bonyliminohexamethylene)
Imazahl
111901
Aryl Halide
Activated Carbon
Bromadiolone
112001
Coumann
Activated Carbon
Brodifacoum
112701
Coumann
Activated Carbon
Bromethalin (ANSI)
112802
Aryl Amine
Activated Carbon
Rundone (ANSI)
112900
Aryl Halide
Activated Carbon
Vinclozolin
113201
Aryl Halide
Activated Carbon
Metalaxyl
113501
Benzeneamine
Activated Carbon
Propetamphos (ANSI)
113601
Phosphoroamidothioate
Activated Carbon
Methyl-1 -naphthyl)maleimide
113701
Phthalamide
Activated Carbon
Hexadecadien-1-yl acetate
114101
Ester
Activated Carbon
Hexadecadien-1-yl acetate
114102
Ester
Activated Carbon
Epoxy-2-methyloctadecane
114301
Heterocyclic
Activated Carbon
Thiodicarb (ANSI)
114501
Thiocarbamate
Activated Carton
Dimethyloxazolidine (8CA & 9CA)
114801
Heterocyclic
Activated Carbon
Tnmethyloxazolidine
114802
Heterocyclic
Activated Carbon
Hydroxyphenyl)oxoacetohydroximic chloride
114901
Phenol
Activated Carbon
eeebc
115001
Carbamate
Activated Carbon
MDM Hydantoin
115501
Hydrazide
Activated Carbon
DMDM Hydantoin
115502
Hydrazide
Activated Carbon
Tnclopyr (ANSI)
116001
Pyridine
Activated Carbon
Tnethylamine tnclopyr
116002
Pyndine
Activated Carbon
Butoxyethyl tnclopyr
116004
Pyridine
Activated Carbon
Decenyl )dihydro-2(3H)-furanone
116501
Ester
Activated Carbon
Cytokinins
116801
Toluidine
Activated Carbon
Benzyladenine
116901
Pynmidine
Activated Carbon
Clopyralid, monoethanolamine salt
117401
Pyndine
Activated Carbon
Clopyralid (ANSI)
117403
Pyndine
Activated Carbon
Flucythrinate (ANSI)
118301
Pyrethnn
Activated Carbon
Hydramethylnon (ANSI)
118401
Iminimide
Activated Carbon
Chlorsulfuron
118601
s-Tnazine
Activated Carbon
Oimethipin
118901
Heterocyclic
Activated Carbon
Hexadecenal
120001
Miscellaneous Organic
Activated Carbon
Tetradecenal
120002
Miscellaneous Organic
Activated Carbon
Thidiazuron
120301
Urea
Activated Carbon
Metronidazole
120401
Hydrazide
Activated Carbon
Erythrosine B
120901
Tncyclic
Activated Carbon
Sethoxydim
121001
Cyclic Ketone
Activated Carbon
Clethodim
121011
Heterocyclic
Activated Carbon
Cyromazine
121301
s-Tnazine
Activated Carbon
Tralomethnn
121501
Pyrethnn
Activated Carbon
Azadirachtin
121701
Tncyclic
Activated Carbon
Tridecen-1-yl acetate
121901
Ester
Activated Carbon
Tndecen-1-yl acetate
121902
Ester
Activated Carbon
Sulfometuron methyl
122001
Pynmidine
Activated Carbon
Metsulfuron-methyl
122010
s-T nazine
Activated Carbon
Propiconazole
122101
Aryl Halide
Activated Carbon
Furanone, dihydro-5-pentyl
122301
Cyclic Ketone
Activated Carbon
Furanone, 5-heptyldihydro-
122302
Cyclic Ketone
Activated Carbon
Abamectin (ANSI)
122804
Tncyclic
Activated Carbon
Fluazifop-butyl
122805
Pyndine
Activated Carbon
Ruazifop-R-butyl
122809
Pyridine
Activated Carbon
Rumetralin
123001
Nitrobenzoate
Activated Carbon
Fosetyl-AI
123301
Phosphate
Activated Carbon
Methanol, (((2-(dihydro-5-methyl-3(2H)-
123702
Heterocyclic
Activated Carbon
oxazolyl)-1-methyl)et
Fomesaten
123802
Nitrobenzoate
Activated Carbon
Tndiphane
123901
Aryl Halide
Activated Carbon
POE isooctadecanol
124601
Alcohol
Activated Carbon
Penplanone B
124801
Bicyclic
Activated Carbon
Fenoxycarb
125301
Carbamate
Activated Carbon
Clomazone
125401
Aryl Halide
Activated Carbon
-------
Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations 57565
Table 10 to Part 455—List of Appropriate Pollution Control Technologies1—Continued
PAI name2
PAI
code3
Shaughnessy
code"
Structural group 5
Treatment technology
Clofente2ine
125501
Aryl Halide
Activated Carbon
Paclobutrazol
125601
Hydrazide
Activated Carbon
Flurpnmidol
125701
Pynmidine
Activated Carbon
'soxaben
125851
Heterocyclic
Activated Carbon
Isazofos
126901
Phosphorothioate
Activated Carbon
Tnadimenol
127201
Hydrazide
Activated Carbon
Fenpropathrin
127901
Pyrethnn
Activated Carbon
Sulfosate
128501
Phosphorothioate
Activated Carbon
Fenoxaprop-ethyl
128701
Heterocyclic
Activated Carbon
Quizalofop-ethyl
128711
Phthalimide
Activated Carbon
Bensulfuron-methyl
128820
Pynmidine
Activated Carbon
Imazapyr
128821
Hydrazide
Activated Carbon
Bifenlhnn
128825
Pyrethnn
Activated Carbon
Imazapyr, isopropylamine salt
128829
Hydrazide
Activated Carbon
Sodium salt of 1 -carboxymethyl-3,5,7-tnaza-
128832
s-Tnazine
Activated Carbon
1-azoniatncyclo
Linalool
128838
Alcohol
Activated Carbon
Imazaquin, monoammonium salt
128840
Pynmidine
Activated Carbon
Imazethabenz
128842
Pynmidine
Activated Carbon
Thifensulfuron methyl
128845
s-Tnazine
Activated Carbon
Imazaquin
128848
Pynmidine
Activated Carbon
Myclobutanil (ANSI)
128857
s-Tnazine
Activated Carbon
Zinc borate (3ZnO, 2B03, 3 5H20, mw
128859
Metallic
Precipitation
434 66)
Cyhalothnn
128867
Pyrethnn
Activated Carbon
Potassium cresylate
128870
Phenol
Activated Carbon
Tnflumizole
128879
Toluidine
Activated Carbon
Tnbenuron methyl
128887
s-T nazine
Activated Carbon
Cyhalothnn
128897
Pyrethnn
Activated Carbon
Chlonmuron-ethyl
128901
Pynmidine
Activated Carbon
Dodecen-1-yl acetate
128906
Ester
Activated Carbon
Dodecen-1-yi acetate
128907
Ester
Activated Carbon
DDOL
128908
Alcohol
Activated Carbon
Famesol
128910
Alcohol
Activated Carbon
Nerolidol
12B911
Alcohol
Activated Carbon
Tefluthnn
128912
Pyrethnn
Activated Carbon
Bromoxynil heptanoate
128920
Chloropropionanilide
Activated Carbon
Imazethapyr
128922
Pynmidine
Activated Carbon
Imazethapyr, ammonium salt
128923
Pynmidine
Activated Carbon
Chitosan
128930
Polymer
Activated Carbon
Sulfuric acid, monourea adduct
128961
Urea
Activated Carbon
Hydroprene
128966
Miscellaneous Organic
Activated Carbon
Tnasulfuron
128969
Urea
Activated Carbon
Pnmisulfuron-methyl
128973
Urea
Activated Carbon
Uniconazole (ANSI)
128976
s-Tnazine
Activated Carbon
Tetradecenyl acetate
128980
Miscellaneous Organic
Activated Carbon
Chitin
128991
Polymer
Activated Carbon
Sulfluramid
128992
Sulfonamide
Activated Carbon
Dithiopyr (ANSI)
128994
Pyndine
Activated Carbon
Nicosulturon
129008
Pynmidine
Activated Carbon
Zinc
129015
Metallic
Precipitation
Tetradecen-1-ol, acetate, (E)-
129019
Alkyl Acid
Activated Carbon
Imazaquin, sodium salt
129023
Pynmidine
Activated Carbon
Dodecadien-1-ol
129028
Alcohol
Activated Carbon
lonone
129030
Miscellaneous Organic
Activated Carbon
Dicamba, aluminum salt
129042
Aryl Halide
Activated Carbon
Benzenemethanaminium, N-(2-((2,6-
129045
NR4
Activated Carbon
dimethylphenyl)amino)-2-oxo
Fenoxaprop-p-Ethyl
129092
Tncyclic
Activated Carbon
Alkyl" bis(2-hydroxyethyl) ammonium ace-
169103
NR4
Activated Carbon
tate "(as in fatty ac
Alkenyl* dimethyl ammonium acetate "(75%
169104
NR4
Activated Carbon
C18', 25% C16')
Amines, N-coco alkyltnmethylenedi-,
169109
Iminamide
Activated Carbon
adipates
Dialkyl" dimethyl ammonium bentonite "(as
169111
NR4
Activated Carbon
in fatty acids of
Alkyl" bis(2-hydroxyethyl) amine acetate
169125
Acetamide
Activated Carbon
"(65% C18, 30% C16,
Dodecyl bis(hydroxy ethyl) dioctyl ammo-
169154
NR4
Activated Carbon
nium phosphate
-------
57566 Federal Register / Vol 61, No 216 / Wednesday, November 6, 1996 / Rules and Regulations
Table 10 to Part 455.—List of Appropriate Pollution Control Technologies1—Continued
PAI name2
PAI
code3
Shaughnessy
code4
Structural group s
Treatment technology
Dodecyl bis(2-hydroxyethyl) octyl hydrogen
169155
NR4
Activated Carbon
ammonium phosphat
Didecyl-N-methyl-3-
169160
NR4
Activated Carbon
(tnmethoxysilyl)propanaminium chloride
Cholecalciferol
202901
Bicyclic
Activated Carbon
Use code no 202901 (Vitamin D3)
208700
Bicyclic
Activated Carbon
Alkyl* N,N-bis(2-hydroxyethyl)amine *(100%
210900
NR4
Activated Carbon
C8-C18)
Bromo-2-nitropropane-1,3-diol
216400
Alcohol
Activated Carbon
Use code no 114601 (cyclohexyl-4, 5-
229300
Heterocyclic
Activated Carbon
dichloro- 4-isothioazolin-3-one)
Diethatyl ethyl
279500
Toluidine
Activated Carbon
Hydroprene (ANSI)
486300
Miscellaneous Organic
Activated Carbon
Zinc sulfate monohydrate
527200
Metallic
Precipitation
Geraniol
597501
Alcohol
Activated Carbon
'The 272 Pesticide Active Ingredients (PAIs) are listed first, by PAI code, followed by the non-272 PAIs from the 1988 FIFRA and TSCA En-
forcement System (FATES) Database, which are listed in Shaughnessy code order PAIs that were exempted or reserved from the PFPR efflu-
ent guidelines are not listed in the table
2 The non-272 PAI names are taken directly from the 1988 FATES database Several of the PAI names are truncated because the PAI names
listed in the FATES database are limited to 60 characters
3 The non-272 PAIs do not have PAI codes
4 All Shaughnessy codes are taken from the 1988 FATES database Some of the 272 PAIs are not listed in the 1988 FATES database, there-
fore, no Shaughnessy codes are listed for these PAIs
5 Structural groups are based on an analysis of the chemical structures of each PAI
6 EPA has also received data indicating that acid hydrolysis may also be effective in treating this PAI
'This PAI code represents a category or group of PAIs, therefore, it has multiple Shaughnessy codes
[FR Doc 96-25771 Filed 11-5-96, 8 45 am]
BILLING CODE 6560-50-P
-------
APPENDIX B
PFPR Compliance Documentation
(Sample Forms)
Table A Identification of Wastewater Sources
Table B Evaluation of PFPR P2, Recycle, and Reuse Practices
Table C Summary of PFPR Compliance Decisions
Table D Identification of Wastewater Sources and Treatment
Technologies
Table E Summary and Evaluation of Test Results
157
-------
Table A: Identification of Wastewater Sources
Facility: Location:
Date: Prepared by:
Stream Type
Source
Batch or
Continuous
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management3
Comments -
1. Shipping Container/ Drum
Cleaning - wafer or solvent iinses
of the containers used to ship taw
matei tal, finished pi oducts, and/oi
waste pioducts puoi to tense ot
disposal of the containeis
1 a
1 b
2. Bulk Tank Rinsate - cleaning of
the intei ioi of any bulk stoiage tank
containing uiw mate)tats,
intei mediate blends, oi finished
pioducts associated with PFPR
ope unions
2a
2b
3. Formulating Equipment
Interior Cleaning - tontine
cleaning, cleaning due to pioduct
changeovei, oi special cleaning of
the intei ioi of any foi initiating
equipment, including for initiation
and/oi stoiage tanks, pipes, and
hoses Cleaning materials may
include water, deteigent, or
solvent
3 a
3 b
3 c
3 d
' Ineits (e e , einulsifiers, surfactants), solids, detergent, etc
2 RE=reuse, TR=treatment and teuse, TD=treatment and discharge, DI=indnect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
159
-------
Table A: Identification of Wastewater Sources
Facility: Location:
Date: Prepared by:
Stream Type
Source
Batch or
Continuous
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management3
Comments
4. Packaging Equipment Interior
Cleaning - routine cleaning,
cleaning due to product
changeover, oi special cleaning
of the interior of any packaging
equipment, including filling or
stoiage tanks.pipes, and lioses
Cleaning materials may include
watet, deteigent, oi solvent
4 a
4 b
4 c
5. Repackaging Equipment
Interior Cleaning - loutine
cleaning, cleaning due to product
changeovei, oi special cleaning of
the intenor of any lepackagmg
equipment, including filling
oi stotagc tanks, pipes, and lioses
Cleaning mater lals may include
water, detergent, or solvent
5 a
5 b
5 c
5 d
6. Aerosol (DOT) Leak Testing -
water used to pcifoirn aerosol leak
tests for Depar tment of
Transportation (DOT) lequiiernciits
(when cans have burst)
6 a
6b
1 Ineits (c g , cmulsifieis, suifactants), solids, detergent, etc
2 RE=rcuse, TR=iiealiricni and reuse, TD=treatment and discharge, DI=indirect discharge, DD=direcl discharge, IN=incineration, DP=off-sile disposal
'^0
-------
Table A: Identification of Wastewater Sources
Facility: Location:
Date: Prepared by:
Stream Type
Source
Batch or
Continuous
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management2
Comments
7. Exterior Equipment Cleaning -
cleaning of the extenoi of any
foi mutating, packaging, or
lepackagmg equipment, including
tanks, pipes, lioses, conveyoii, etc
Cleaning matenah may include
watei, detergent, oi solvent
7 a
7 b
7 c
8. Exterior Wall Cleaning -
cleaning of walls in the PFPR
opeiations aieas
8 a
8 b
9. Floor Washing - cleaning of
Poois in the PFPR operations
aieas
9 a
9b
9 c
1 Ineils (e g , emulsifiets, surfactants'), solids, detergent, etc
2 RE=rcuse, TR=lrcatment and reuse, TD=treatment and discharge, DI=indircct discharge, DD=dircct discharge, IN=incineration, DP=off-site disposal
161
-------
Table A: Identification of Wastewater Sources
Facility: Location:
Date: Prepared by:
Stream Type
Source
Batch or
Continuous
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management2
Comments
10. Leaks and Spills • cleaning of
leaks aitd/oi spills which occm
dining PFPR opeiations
10a
10b
11. Safety Equipment Cleaning -
cleaning of peisonal piotective
equipment (eg, gloves, splash
apions, boots, icspiiatois)
worn by employees in PFPR
opeiations aieas
11 a
11 b
12. Air Pollution Control
Scrubbers - wet set ubbei ? used to
contiol an emissions fiom PFPR
opeiations
12 a
13. Laboratory Equipment
Cleaning - Initial imse of the ictain
sample tontainei
13 a
1 Incits (e g , emulsilicis, surfactants), solids, detergent, etc
2 RC=reuse, TR=treatment and reuse, TD=treatment and discharge, DI=indnect discharge, DD=direct discharge, IN=incineration, DP=off-sitc disposal
»
-------
Table A: Identification of Wastewater Sources
Facility: Location:
Date: Prepared by:
Stream Type
Source
Batch or
Continuous
Volume
Generated
Generation
Frequency
Active
Ingredients
Wastewater
Matrix1
Wastewater
Management2
Comments
Other streams not specifically included in the P2 Alternative
14. Contaminated Precipitation
Runoff - tunofffiom raw material
storage, loading pads, final pioduct
sloiagc, anil outdooi
pioductton aieas
14 a
14 b
IS. Laboratory Equipment
Cleaning - Watei used to clean
analytical equipment and
slasswaie
15 a
16. Aerosol (DOT) Leak Testing -
Watei used in non-continuous
oveiflow baths to peifoim aeiosol
leak tests foi DOT tequuements
when no cans have buist fiom the
last watei change out
16 a
16b
17. Other Sources - othei souices
of waste not specifically mentioned
(please specify)
17 a
17 b
17 c
1 Incrts (c g , cmulsifiers, surfactants), solids, detergent, etc
2 RE=rcusc, TR=ticatment and icusc, TD=ttcatmcnt and discharge, DI=indirect discharge, DD=direct discharge, IN=incineration, DP=off-site disposal
163
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Dale:
Location:
Prepared by:
Table 8
Listed
Practice1
Practice
Does
Facility Use
this
Practice?
Source Code
from
Table A
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
1. Flow Reduction
l-l
1
Hoses used for rinsing have spray nozzles
or other flow reduction devices
Low-volumc/high-pressure rinsing
equipment is used for rinsing PFPR
equipment interiors (specify type of
equipment) when rinsing with water
1-2
1
A floor scrubbing machine and/or mop
arid bucket is used to clean floors in liquid
production areas
1-3
3
Dry production areas are swept or
vacuumed prior to rinsing with water
Dry production areas are rinsed with
watei
2. Good Housekeeping Practices
2-1
2a
Facility performs preventive maintenance
on valves and fittings and repairs leaks in
a timely manner
2-2
2b
Facility places drip pans under valves and
fittings where hoses and lines arc
routinely connected and disconnected
2-3
2c
Facility immediately cleans up spills and
leaks in outdoor bulk storage and process
areas
3. DOT Test Bath
3-1
5
Facility operates continuous overflow test
baths with some recirculation of water
1 40 CFR 455 67
2 Insert the following modification codes in the column titled "Required Justification for Modification"
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet al end of table contains a detailed explanation of each code )
165
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Location:
Date:
Prepared by:
Table 8
Listed
Practice1
Practice
Does
Facility Use
this
Practice?
Source Code
from
Table A
Extent of Use of this
Practice Observed DuriDg
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification1
Comments
4. Air Pollution Controls
4-1
6
Facility operates wet scrubbers with
recirculation (periodic blowdown is
allowed as needed)
5. Reuse of Drum Rinsatc of Water-Based Products
5-1
7
Facility reuses drum/shipping container
nnsate directly into product formulations
5-2
7
Facility stores drum/shipping container
rinsatc for use in future formulations of
same or compatible products
5-3
1,7
Facility operates a staged drum rinsing
station (countercurrcnt rinsing)
6. Drum Rinsing
for Formulation of Solvent-Based Products
0-1
8
Facility reuses drum/shipping container
nnsate directly into product formulations
6-2
8
Facility stores drum/shipping container
rinsatc for use in future formulations of
same or compatible products
6-3
NA
Facility uses base solvent to rinse drums
1 40 CFR 455 67
2 Insert the following modification codes in the column titled "Required Justification for Modification"
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility
Date:
Location:
Prepared by:
Table 8
Listed
Practice1
Practice
Does
Facility Use
this
Practice?
Source Code
from
Table A
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification1
Comments
7. Dedicated Equipment for Solvent- and Water-Based Products
7-1
9
Facility dedicates PFPR production
equipment to water-based vs solvent-
based products Dedicated solvent-based
or water-based equipment may be used on
a non-routine basis for non-dedicated
operations, but facility may not discharge
the aqueous changeover rinsate as part of
their P2 allowable discharge
8. Interior Rinsate Storage and Reuse
8-1
10
Interior rinsate is stored for reuse in future
formulations of the same or
compatible product (note docs not
include dium/shipping container rinsate)
8-2
4
Dry carrier material is stored and reused in
future foimulation of the same or
compatible product or disposed of as solid
waste
8-3
4
Interiors of dry formulation equipment are
cleaned with dry carrier prior to water
rinse
1 40 CFR 455 67
2 Insert the following modification codes in the column tilled "Required Justification for Modification"
ALTD1SPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of tabic contains a detailed explanation of each code )
167
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date:
Location:
Prepared by:
Table 8
Listed
Practice1
Practice
Does
Facility Use
this
Practice?
Source Code
from
Table A
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification'
Comments
9. Dedicated Process Equipment
9-1
NA
Facility dedicates some portion of
equipment to
i Top production produUs
n Hard-to-clean products
in Product families (attach definition of
product families)
9-2
NA
Facility sequences production on
dedicated process equipment
10. Inventory Management
10-1
NA
Facility has an inventory management
system for raw material, pioduct, and
wastewater rnisatc
10-2
NA
System includes one or more of the
following
i Central storage and access controls
ii Computerised inventory control
in Protection fiom piccipitation
1 40 CFR 455 67
2 Insert (lie following modification codes in the column titled "Required Justification for Modification"
ALTDISPOSE, BIOGROWTI1, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
- ^
-------
Table B: Evaluation of PFPR P2, Recycle, and Reuse Practices
Facility:
Date.
Location:
Prepared by:
Table 8
Listed
Practice'
Practice
Does
Facility Use
this
Practice?
Source Code
from
Table A
Extent of Use of this
Practice Observed During
Audit
Could Facility
Implement this
Practice in the
Future?
Required
Justification for
Modification2
Comments
11. Training and Written Standard Operating Procedures
11-1
NA
Facility provides personnel with P2
training
11-2
NA
Facility lias employee incentive programs
encouraging P2
11-3
NA
Facility has documentation of P2 practices
and procedures
12. Other P2 Practices/Equipment
12-1
NA
12-2
NA
12-3
NA
12-4
NA
12-5
NA
12-6
NA
1 40 CFR 455 67
2 Inscil the following modification codes in the column titled "Required Justification for Modification"
ALTDISPOSE, BIOGROWTII, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of tabic contains a detailed explanation of each code )
169
-------
Modification Code Sheet
Tabic B
Practice
Tabic 8
Listed
Practice
Modification
Code
Description
1-1
1
NARROW
Rinsing narrow transfer lines or piping where sufficient rinsing is better achieved by
flushing with water
4-1
6
BREAKCAA
Facility demonstrates that would not be able to meet Resource Conservation Recovery
Act (RCRA) or Clean Air Act (CAA) requirements
5-1 to 5-3
7
INERT
Drum/shipping container holds inert mgredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused, or
(2) the facility can demonstrate that the concentration of the inert in the formulation is
so small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158 155)
6-1 to 6-3
8
REFURB
INERT
Drums/shipping containers are going to a drum refurbisher/recycler who will only
accept drums rinsed with water
Drum/shipping container holds inert mgredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused, or
(2) the facility can demonstrate that the concentration of the inert in the formulation is
so small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158 155)
7-1
9
RECOVERY
Facility has installed and is using a solvent recovery system for the changeover rinsate
(can also be used for other solvent recovery)
8-1
10
ALTDISPOSE
BIOGROWTH
DETERGENT
DROP
PACKAGE
SPACE
PAI manufacturer (or formulator contracting for toll formulating) has directed otherwise
(1 e , send back to them or send for off-site disposal)
Facility has evidence of biological growth or product deterioration over a typical storage
period (review facility data)
Facility has demonstrated that it must use a detergent to clean equipment
Facility is dropping registration or production of the formulation and there is no
compatible formulation for reuse of the nnsates or facility can provide reasonable
explanation of why it does not anticipate formulation of same or compatible
formulation within the next twelve months
Facility only performs packaging of the pesticide product from which interior rinsate is
generated
Facility has space limitations, BUT must still store nnsates for most frequently produced
products
NA
NA
OTHER1
' Other practices must be approved by the permitting/control authority prior to discharge
170
-------
Table C: Summary of PFPR Compliance Decisions
Facility: Location:
Date: Prepared by:
Stream Type
Source
Preliminary
Compliance
Decision
Comments'
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
1. Shipping Container/ Drum
Cleaning - water or solvent rinses
of the contameis used to ship taw
material, finished products, and/ot
waste ptoducts pi tot to tense oi
disposal of the contameis
1 a
1 b
2. Bulk Tank Rinsate - cleaning of
the mtei ioi of any hulk storage tank
containing taw inateiials,
mtetmediate blends, oi finished
ptoducts associated with PFPR
ope i at ions
2 a
2 b
3. Formulating Equipment
Interior Cleaning - loutme
cleaning, cleaning due to pioduct
changeovei, oi special cleaning of
llie mteiioi of any fomiulattng
equipment, including formulation
and/oi storage tanks, pipes, and
hoses Cleaning niatei lals may
include watei, deteigent, or
solvent
3 a
3 b
3 c
3 d
1 Inscit llic following modification codes in llie column tilled "Comments1
ALTDISPOSE. BIOGROWTH BREAKCAA. DETERGENT. DROP. INERT. NARROW, PACKAGE RECOVERY. REFURB, SPACE. OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
171
-------
Table C: Summary of PFPR Compliance Decisions
Facility: Location:
Date: Prepared by:
Stream Type
Source
Preliminary
Compliance
Decision
Comments1
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
Tor Nonlisted
Modifications
4. Packaging Equipment Interior
Cleaning - routine cleaning,
cleaning clue to pioduct
changeovei, or special cleaning
of the interior of any packaging
equipment, including filling or
stoiage tanks,pipes, and lioses
Cleaning mateiials may include
watei, deteigent, 01 solvent
4 a
4b
4 c
5. Repackaging Equipment
Interior Cleaning - i online
cleaning, cleaning due to pioduct
changeovei, 01 special cleaning of
the intenoi of any lepackagtng
equipment, including filling
oi stoiage tanks, pipes, and hoses
Cleaning mateiials may include
watei, deteigent, 01 solvent
5 a
5b
5 c
5 d
6. Aerosol (DOT) Leak Testing -
watei used to peifoim aerosol leak
tests foi Depaitment of
Transpoitation (DOT) lequiiements
(when cans have bitist)
6 a
6b
' Insert ihc following modification codes 111 ihe column titled "Comments"
Al.TDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
-------
Table C: Summary of PFPR Compliance Decisions
Facility: Location:
Date: Prepared by:
Stream Type
Source
Preliminary
Compliance
Decision
Comments'
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonlisted
Modifications
7. Exterior Equipment Cleaning •
cleaning of the extenoi of any
foi mulating, packaging, oi
lepackagmg equipment, including
tanks, pipes, lioses, conveyors, etc
Cleaning niatenals may include
watei, detergent, oi solvent
7 a
7 b
7c
8. Exterior Wall Cleaning -
cleaning of walls in the PFPR
opciations aieas
8 a
8b
9. Floor Washing - cleaning of
floois in the PFPR opciations
aieas
9 a
9 b
9c
1 Inseii the following modification codes in ihe column tilled "Comments"
A LI DISPOSE, BIOGROWTH. BREAKCAA. DETERGENT, DROP. INERT. NARROW. PACKAGE. RECOVERY. REFURB. SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
173
-------
Table C: Summary of PFPR Compliance Decisions
Facility: Location:
Date: Prepared by:
Stream Type
Source
Preliminary
Compliance
Decision
Comments'
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
Tor Nonlisted
Modifications
10. Leaks and Spills - cleaning of
leaks and/or spills which occui
dm ing PFPR operations
10a
10b
11. Safely Equipment Cleaning -
cleaning of peisonal protective
equipment (eg, gloves, splash
aprons, boots, respirators)
worn by employees in PFPR
opaations areas
11 a
11 b
12. Air Pollution Control
Scrubbers - wet scrubbers used to
conliol an emissions fiom PFPR
opeiations
12a
13. Laboratory Equipment
Cleaning - Initial nine of the retain
sample container
13 a
1 Inscit (lie following modification codes in the column titled "Comments"
ALTDISPOSE, BIOGROWTH, BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REEURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
-------
Table C: Summary of PFPR Compliance Decisions
Facility: Location:
Date: Prepared by:
Stream Type
Source
Preliminary
Compliance
Decision
Comments'
Wastewater
to be
Treated?
Final
Compliance
Decision
Approval Date
for Nonllsted
Modifications
Other streams not specifically included in the P2 Alternative
14. Contaminated Precipitation
Runoff - tunofffiom taw matenal
stoiage, loading pads, final product
stoiage, and outdooi
production areas
14 a
14 b
15. Laboratory Equipment
Cleaning - Waiei used to clean
analytical equipment and
glasswaie
15 a
16. Aerosol (DOT) Leak Testing -
Watei used in non-continuous
oveiflow baths to perfoun aeiosol
leak tests foi DOT i equuements
when no cans have burst fioin the
last watei change out
16 a
16b
17. Other Sources - other souices
of waste not specifically mentioned
(please specify)
17 a
17 b
17c
1 Inscit the following modification codes in the column titled "Comments"
ALTDISPOSC, BIOGROWTH. BREAKCAA, DETERGENT, DROP, INERT, NARROW, PACKAGE, RECOVERY, REFURB, SPACE, OTHER
(Modification Code Sheet at end of table contains a detailed explanation of each code )
175
-------
Modification Code Sheet
Tabic B
Practice
Tabic 8
Listed
Practice
Modification
Code
Description
1-1
1
NARROW
Rinsing narrow transfer lines or piping where sufficient rinsing is better achieved by
flushing with water
4-1
6
BREAKCAA
Facility demonstrates that would not be able to meet Resource Conservation Recovery
Act (RCRA) or Clean Air Act (CAA) requirements
5-1 to 5-3
7
INERT
Drum/shipping container holds inert mgredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused, or
(2) the facility can demonstrate that the concentration of the inert in the formulation is
so small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158 155)
6-1 to 6-3
8
REFURB
INERT
Drums/shipping containers are going to a drum refurbisher/recycler who will only
accept drums rinsed with water
Drum/shipping container holds inert mgredient(s) only and
(1) the facility can demonstrate that, after using water conservation practices, the large
concentration of inert ingredients in the formulation creates more volume than could
feasibly be reused, or
(2) the facility can demonstrate that the concentration of the inert in the formulation is
so small that the reuse would cause a formulation to exceed the ranges allowed in the
Confidential Statement of Formula (CSF) (40 CFR 158 155)
7-1
9
RECOVERY
Facility has installed and is using a solvent recovery system for the changeover rinsate
(can also be used for other solvent recovery)
8-1
10
ALTDISPOSE
BIOGROWTH
DETERGENT
DROP
PACKAGE
SPACE
PAI manufacturer (or formulator contracting for toll formulating) has directed otherwise
(i e , send back to them or send for off-site disposal)
Facility has evidence of biological growth or product deterioration over a typical storage
period (review facility data)
Facility has demonstrated that it must use a detergent to clean equipment
Facility is dropping registration or production of the formulation and there is no
compatible formulation for reuse of the rinsates or facility can provide reasonable
explanation of why it does not anticipate formulation of same or compatible
formulation within the next twelve months
Facility only performs packaging of the pesticide product from which interior rinsate is
generated
Facility has space limitations, BUT must still store rinsates for most frequently produced
products
NA
NA
OTHER1
' Other practices must be approved by the permitting/control authority prior to discharge
176
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Location:
Prepared by:
Stream Type1
Source
Potential Pollutants
Wastew
ater Treatment Information
Characteristics That
Hinder Treatment
Active
Ingredients
Other
Pollutants
Table 10
Technology2
Alternate
Treatment
Technology1
Source for
Alternative Technology
1. Shipping Container/Drum
Cleaning - watei oi solvent imses
of the containeis used to slup taw
mate} tal, finished piodncls, and/oi
waste products pnoi to tense o>
disposal of the containeis
1 a
1 b
2. Bulk Tank Kinsate - cleaning
of the intei ioi of any bulk stoiage
tank containing taw materials,
intei mediate blends, oi finished
pi odncts associated with PFPR
opeiattons
2a
2b
3. Formulating Equipment
Interior Cleaning -1online
cleaning, cleaning due to product
changeovei, oi special cleaning of
the mteiioi of any foi mutating
equipment, including foi initiation
and/oi stoiage tanks, pipes, and
hoses Cleaning mateiials may
include watei, deteigent, oi
solvent
3a
3b
3c
3d
1 Stream types maiked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards, however, facilities may be required to perform pretreatment
by the control authority to meet local limits Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment
2 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
177
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Location:
Prepared by:
Stream Type1
Source
Potential Pollutants
Wastewater Treatment Information
Characteristics That
Hinder Treatment
Active
Ingredients
Other
Pollutants
Table 10
Technology3
Alternate
Treatment
Technology1
Source for
Alternative Technology
4. Packaging Equipment Interior
Cleaning - /online cleaning,
cleaning due lo pioditct
changeovei, oi special cleaning
of the mtei 101 of any packaging
equipment, including filling oi
stoiage tanks,pipes, and hoses
Cleaning mateuals may include
watei, deleigcnt, oi solvent
4 a
4 b
4 c
5. Repackaging Equipment
Interior Cleaning -1 online
cleaning, cleaning due lo pioditct
changeovei, oi special cleaning of
the inlenoi of any tepackagiiig
equipment, including filling
oi stoiage tanks, pipes, and hoses
Cleaning mateuals may include
watei, deteigenl, oi solvent
5 a
5 b
5 c
*6. Aerosol (DOT) Leak Testing -
watei used lo peifoun aeiosol leak
lestffoi Derailment of
Tiaiispoitation (DOT)
leqiiiieinents (when cans have
buisi)
6 a
6b
1 Stream lypcs marked wiih an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR prelrcalment standards, however, facilities may be required to perform pretreatment
by the control authority to meet local limits Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment
2 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
178
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Date:
Location:
Prepared by:
Stream Type1
Source
Potentia
1 Pollutants
Was tew
ater Treatment
Information
Characteristics That
Hinder Treatment
Active
Ingredients
Other
Pollutants
Table 10
Technology2
Alternate
Treatment
Technology1
Source for
Alternative Technology
+7. Exterior Equipment Cleaning
- cleaning of the exlenoi of any
foi ululating, i>ackagmg, oi
lepackagmg equipment, including
tanks, pipes, hoses, conveyois, etc
Cleaning mateiials may include
watei, deteigent, ot solvent
7a
7 b
7c
+8. Exterior Wall Cleaning -
cleaning of walls in the PFPR
opeiations aieas
8 a
8b
9. Floor Washing - cleaning of
(loots in the PFPR opeiations
aieas
9a
9b
9 c
1 Sticam lypcs marked with an asterisk ("*") do not require treatment prior 10 discharge to a POTW under the final PFPR prctrcatment slandards, however, facilities may be required to perform pretrealmenl
hy the control authority to meet local limits Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require prctrcatment
2 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
179
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Location:
Date:
Prepared by:
Potential Pollutants
Wastewater Treatment Information
Stream Type1
Source
Active
Ingredients
Other
Pollutants
Table 10
Technology2
Alternate
Treatment
Technology1
Source for
Alternative Technology
Characteristics That
Hinder Treatment
10. Leaks and Spills - cleaning of
leaks ancl/oi spills which occm
dining PFPR opeialions
10a
10b
*11. Safety Equipment Cleaning -
cleaning of peisonal piotective
equipment (eg, gloves, splash
aprons, boots, icspiiatois)
11 a
woin by employees in PFPR
opeialions aieas
11 b
*12. Air Pollution Control
Scrubbers -1vet sciubbeis used to
conliol an emissionsfioin PFPR
opeialions
12 a
*13. Laboratory Equipment
Cleaning - Initial imse of the
letam sample containei
13 a
' Stream types marked with an asterisk ("*") do not require treatment prior to discharge to a POTW under (he final PFPR pretreatment standards, however, facilities may be required to perform pretreatment
by the control authority to meet local limits Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require pretreatment
2 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention. OT = other
IRQ
-------
Table D: Identification of Wastewater Sources and Treatment Technologies
Facility:
Location:
Dale:
Prepared by:
Potential Pollutants
Wastewater Treatment
Information
Stream Type1
Source
Active
Ingredients
Other
Pollutants
Table 10
Technology1
Alternate
Treatment
Technology1
Source for
Alternative Technology
Characteristics That
Hinder Treatment
Other streams not specifically included in the P2 Alternative
*14. Contaminated Precipitation
Runoff - mnoff fiom taw material
stoiage, loading pads, final
pioduct stoiage, and outdooi
14 a
production aieas
14 b
*15. Laboratory Equipment
Cleaning - Walei used to clean
analytical equipment and
glasswai e
15 a
*16. Aerosol (DOT) Leak Testing
- Watei used m non-continuous
overflow baths to peifoim aeiosol
16 a
leak tests for DOT i equu emails
when no cans have buistpom the
last watei change out
16 b
-
17. Other Sources - othei souices
of waste not specifically mentioned
(please specify)
17 a
17b
17 c
1 Stream types maiked with an asterisk ("*") do not require treatment prior to discharge to a POTW under the final PFPR pretreatment standards, however, facilities may be required to perform pretreatment
by the control authority to meet local limits Stream types marked with a plus ("+") do not require treatment prior to discharge to a POTW if they have not been commingled with stream types that do
require presentment
2 HD = hydrolysis, AC = activated carbon, PT = precipitation, CO = chemical oxidation, P2 = pollution prevention, OT = other
181
-------
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Location:
Prepared by
•
Insert vour ootimal treatment train and oneratine parameters in the snace provided below:
Technology
Primary
Constituents
Desien and Operating Parameters
Constituent Concentration
Performance Measures
Effectively
Treated?
(Y/N)
pH
Temperature
(°C)
Other
Other
Other
Influent
(ugf\S)
Effluent
(ug/L)
Percent
Removal
Other
.
183
-------
Table E: Summary and Evaluation of Test Results
Facility:
Date:
Location:
Prepared bj
Technology
Primary
Constituents
Desizn and Ooeratine Parameters
Constituent Concentration
Performance Measures
Effectively
Treated?
(Y/N)
PH
Temperature
CO
Other
Other
Other
Influent
(ug/L)
Effluent
(ug/L)
Percent
Removal
Other
.
-------
APPENDIX C
Example Treatability Test
Procedures
185
-------
1.0 INTRODUCTION
The following test procedures have been excerpted from the report Pilot-Scale
Tests of the Universal Treatment System for the Pesticides Formulating, Packaging, and
Repackaging Industry, September 1996 (DCN F7938) The report details the results of a series
of pilot-scale treatability tests conducted by the U.S. Environmental Protection Agency during
development of the Pesticide Formulating, Packaging, and Repackaging effluent limitations
guidelines and standards. These tests evaluted the effectiveness of a flexible treatment train that
was referred to as the Universal Treatment System (UTS).
The UTS is simply a term used to describe a simple, flexible system that consists
of standard wastewater treatment equipment: tanks, pumps, piping, and activated carbon
columns that can be purchased individually off-the-shelf from vendors. This equipment can be
used to conduct the following physical/chemical treatment steps: emulsion breaking, hydrolysis,
activated carbon adsorption, chemical oxidation, and precipitation
2.0 TEST PROCEDURES
This section provides a discussion of the equipment, procedures, and operating
parameters used to perform the three pilot-scale UTS treatability tests. Each pilot-scale test
consisted of a bench-scale emulsion-breaking pretest, emulsion breaking (where it was
determined via bench-scale pretesting that emulsion breaking would be effective) or settling,
hydrolysis, and activated carbon adsorption.
To characterize the performance of each UTS treatment step, samples were
collected before and after each step to gather data on the overall effectiveness of the UTS in
treating PFPR wastewater Each of these samples was analyzed for PAIs, volatile organics.
sermvolatile organics, and classical wet chemistry parameters The influent to and effluent from
the UTS system were also analyzed for metals.
186
-------
Samples were also collected throughout hydrolysis treatment; these samples were
analyzed for PAIs and classical wet chemistry parameters. The PAI analytical results were used
to prepare hydrolysis half-life curves, which are presented in Section 6.0. Samples were
collected throughout activated carbon treatment and analyzed for PAIs. The analytical results
were used to prepare carbon breakthrough curves for each of the PAIs, which are also presented
in Section 6.0.
Section 4 1 provides a discussion of the test equipment used in all three UTS
treatability tests. Because each type of wastewater treated in the pilot-scale UTS differed in
composition and treatability, the UTS procedures were modified slightly for each test to achieve
adequate treatment. Sections 4.2 through 4.4 describe the procedures and design and operating
parameters for each UTS test.
4.1 Test Equipment
The pilot-scale UTS treatability tests were conducted at Radian Corporation's
Milwaukee, Wisconsin laboratory facilities. The following subsections describe the equipment
used to perform the pilot-scale tests, as well as the emulsion-breaking pretest.
4.1.1 Emulsion-Breaking Pretest
The bench-scale emulsion breaking pretest was conducted in glass beakers. Hot
plates were used to heat the aliquots. Magnetic stirrers with Teflon®-coated stirring bars mixed
the aliquots.
4.1.2 Tanks
The pilot-scale emulsion-breaking tests and hydrolysis tests were conducted in
two 190-liter stainless steel tanks with open tops These tanks were heated using electric band
187
-------
heaters wrapped around the tanks Aluminum foil was used to cover the tops of the tanks during
portions of the tests to reduce evaporative losses. Several plastic tanks and a 40-liter graduated
plastic tank were used to hold and measure the volume of the wastewater Plastic tanks were
used to hold the supernatant from the emulsion-breaking step while the sludge layers were
measured and washed out of the stainless steel tanks. The graduated plastic tank was used to
measure the volume of wastewater added to the plastic activated carbon feed tank
4.1.3 Mixers
The wastewater tanks used for the pilot-scale emulsion breaking step were mixed
using milk-jug hand mixers, an electrically powered paddle mixer, or an electrically powered
Lightning® mixer. Each milk-jug mixer consisted of a long stainless steel rod attached to the
center of a stainless steel disc with holes punched in it. Mixing was conducted by submerging
the disc m the liquid and moving it up and down. The paddle mixer consisted of an electric
motor that rotated a stainless steel paddle. The motor was clamped to a board placed across the
opening of a tank. The paddle remained submerged in the liquid in the tank. The Lightning®
mixer consisted of an electric motor that rotated a stainless steel rod with a small, warped
stainless steel disc at its tip. The Lightning® mixer was clamped to the side of a tank so that the
rod and the disc remained submerged in the liquid in the tank.
4.1.4 Pumps
Wastewater was transferred into and out of the various tanks and the activated
carbon column either by pouring it or by pumping it through one of three pumps, a sump pump
(submersible pump), a centrifugal pump, and a peristaltic pump. The sump pump consisted of a
motor located in a plastic housing with an open bottom. The motor was attached to a rope and
was lowered into the liquid to be pumped until the open bottom of the housing was submerged in
the liquid The liquid was pumped through a tube at the top of the motor housing The sump
188
-------
pump had the highest flow rate but its speed was not adjustable, and it tended to cause settled
solids to resuspend during pumping.
The centrifugal pump was used by attaching tubes to the pump inlets and outlets
The open end of the tube attached to the inlet was submerged in the liquid to be pumped, and the
open end of the tube attached to the outlet was placed in the empty container. The centrifugal
pump had a variable speed motor, which could be adjusted to minimize the resuspension of
settled solids.
The peristaltic pump was used to pump the wastewater from the activated carbon
feed tank through a length of flexible tubing and into the carbon column. This pump was
operated by wrapping a piece of flexible tubing around a gear. As the gear rotated, the tubing
was compressed, which caused the liquid to flow through the tubing.
4.1.5 Activated Carbon Column
The activated carbon column consisted of a clear glass tube seven feet high and
one inch in diameter. The ends of the column were capped with plastic plugs that had openings
for stainless steel fittings. These fittings were used to attach flexible tubing to the column inlet
and outlet For each UTS test, the column was packed with 680 grams of granular activated
carbon that had been washed and deaerated. The carbon used in each of the three tests was
pulverized Filtrasorb 300, manufactured by Calgon Corporation The carbon had a mesh size of
300 to 400.
The carbon was weighed and washed by measuring a small amount of carbon into
a glass flask. Distilled water was added to the flask and swirled to cause the carbon fines to be
suspended, which generated a black water above the granular carbon. The water was decanted
from the carbon These steps were repeated until the swirling no longer suspended many fines
and the water remained relatively clear after swirling. The carbon was then deaerated by placing
the flask under a vacuum of about seven inches of mercury using a vacuum pump The flask was
189
-------
swirled to help release air bubbles from the carbon. The vacuum and swirling were continued
until the water above the carbon became relatively free of air bubbles The carbon was then
scooped from the flask or washed from the flask using distilled water, and loaded into the carbon
column
4.1.6 Measurements
Measurements of pH were performed using an electronic pH meter, which was
calibrated daily, or using disposable pH strips. Temperature measurements were conducted using
a portable electric thermocouple or a mercury-filled glass thermometer. Prior to use, all
equipment was washed using water, detergent solution, scrubbers, and scouring pads, as needed,
and was triple-rinsed with distilled water.
4.2 Facility A Treatability Test
Facility A is a toll formulator that formulates and packages home insecticides,
insect repellents, and pet-care products such as flea and tick shampoos. Wastewater collected
from Facility A for treatability testing included formulation vessel interior nnsates from the
formulation of four separate products (referred to in this report as Rinsates 1, 2, 3, and 4) and
floor wash water from a mechanical floor scrubbing machine used to clean floors in the facility's
product formulation areas The wastewater was collected between March 27 and March 29, 1995
and placed for transport in one of seven plastic carboys. Table 4-1 provides a summary of the
wastewater collection at Facility A.
Rmsate 1 was generated from the interior cleaning of a tank used to formulate an
insecticide spray that contains the PAIs permethnn and methoprene The operator used about 95
liters of hot water in 10 minutes to clean the tank. Sixty liters of the wastewater were collected
into Carboy #1 from a valve connected to the bottom of the tank The wastewater had an opaque,
milky-white appearance.
190
-------
Table 4-1
Summary of Wastewater Collection for UTS Treatability Testing at
Facility A
Carboy Number
Carboy Contents (Pesticide
Active Ingredients)
Carboy Volume (Liters)
Wastewater Appearance
Carboy #1
Rinsate 1 (permethrin,
methoprene)
60
Milky-white, opaque
Carboy #2
Rinsate 2 (linalool)
60
Light green, translucent
Carboy #3
Rinsate 2 (linalool)
50
Light green, translucent
Carboy #4
Rinsate 3 (pyrethrins, piperonyl
butoxide)
60
Light green, translucent,
foamy
Carboy #5
Rinsate 3 (pyrethrins, piperonyl
butoxide)
60
Light green, translucent,
foamy
Carboy #6
Rinsate 4 (permethrin,
methoprene)
35
Milky-white, opaque,
foamy
Carboy #7
Floor Wash Water (permethrin,
methoprene, linalool, limonene,
pyrethrins, piperonyl butoxide)
20
Black, opaque
Rinsate 2 was generated from the interior cleaning of a tank used to formulate an
msecticidal pet shampoo that contains the PAI linalool. The operator used about 230 liters of hot
water in 20 minutes to clean the tank. Using a hose connected to a valve at the bottom of the
tank, wastewater collection personnel put 60 liters of the wastewater into Carboy #2 and 50 liters
of the wastewater into Carboy #3. The wastewater had a translucent, slightly green hue and
contained surfactants from the raw materials used to formulate the product.
Rinsate 3 was generated from the interior cleaning of a tank used to formulate
another insecticidal pet shampoo that contains the PAIs pyrethnn and piperonyl butoxide. The
operator used about 150 liters of hot water in 10 minutes to clean the tank. Sixty liters of the
wastewater were collected into Carboy #4 and 60 liters were collected into Carboy #5 using a
hose connected to a valve at the bottom of the tank. The wastewater was foamy and had a
translucent, slightly green hue, and contained surfactants from the raw materials used to
formulate the product.
191
-------
Rinsate 4 was generated from the interior cleaning of a tank used to formulate an
insecticide spray that contains the PAIs permethrin and methoprene. The operator used about 35
liters of hot water to clean the tank. Wastewater collection personnel placed all 35 liters of the
wastewater into Carboy #6 using a valve connected to the bottom of the tank. The wastewater
was foamy and had an opaque, nulky-white appearance.
Floor wash water was collected from a mechanical floor scrubber that is used to
clean the floors in the Facility A pesticide products packaging area. The floor in the formulation
area is rarely washed; however, the rest of the facility, including the floors surrounding the
packaging lines, is cleaned periodically. While personnel were on site to collect wastewater, the
floors in the packaging area were cleaned using a mechanical floor scrubber. Wastewater
collection personnel collected 20 liters of wash water into Carboy #7 from the water reservoir in
the floor scrubber This water was generated over two floor washings, with approximately 10
liters generated per washing. The wash water had the potential to contain all of the PAIs used in
the products packaged at the facility, including the PAIs in Rinsates 1 through 4, and the PAI
limonene, which is contained in another product that is packaged at the facility. In addition, the
wash water contained detergents used in the floor scrubber to help clean floors, as well as
surfactants from products that may have leaked or spilled during packaging. The wastewater had
an opaque, black appearance
The wastewater was shipped via air cargo to Radian's Milwaukee, Wisconsin
laboratory facilities and was immediately placed in cold storage (approximately 4°C) The UTS
treatability testing of Facility A wastewater began on March 30, 1995 and was completed by
April 9, 1995. Table 4-2 lists the sample point description, Sample Control Center (SCC) sample
number, date and time of sample collection, pH, and temperature and collection methods for the
samples collected during the Facility A treatability test.
192
-------
Table 4-2
Summary of Wastewater Sampling for UTS Treatability Testing of Facility A
Wastewater
Sample
SCC
Number
Sample
Date
Sample
Time
pH
Temperature
(°C)
Collection Method
Commingled
Influent to
Hydrolysis
27767
04/04/95
10 15
6 10
125
Scooped from tank using glass
measuring cup
Commingled
Influent to
Hydrolysis
(duplicate)
27768
04/04/95
10 15
6 10
125
Scooped from tank using glass
measuring cup
Hydrolysis
(first batch,
6-hour)
27770
04/05/95
19 15
NA
60 7
Scooped from tank using glass
measuring cup
Hydrolysis
(first batch,
12-hour)
27771
04/06/95
1 15
NA
55 1
Scooped from tank using glass
measuring cup
Hydrolysis
(first batch,
24-hour)
27772
04/06/95
13 13
NA
57 9
Scooped from tank using glass
measuring cup
Hydrolysis
(second batch,
24-hour)
27769
04/07/95
19 45
7 46
21
Scooped from tank using glass
measuring cup
Activated
Carbon
(60-liter)
27773
04/07/95
21 30
NA
NA
Collected in 4-L glass jar from
carbon column effluent tubing
Activated
Carbon
(120-liter)
27774
04/08/95
8 15-10 00
NA
NA
Collected in 9 6-L glass jar
from carbon column effluent
tubing
Activated
Carbon
(180-liter)
27775
04/08/95
19 30-21 15
NA
NA
Collected in 4-L glass jar from
carbon column effluent tubing
Activated
Carbon
(240-liter)
27776
04/09/95
8 38-1 30
NA
NA
Collected in stainless steel
tank from carbon column
effluent tubing
NA - Information not available
SCC - Sample Control Center
193
-------
4.2.1
Emulsion-Breaking Pretest
Table 4-3 lists the composition of each aliquot for the emulsion breaking pretest,
including the initial pH and appearance, the volume of acid or base added, the resulting pH, and
the observations of the effects of the emulsion-breaking pretest.
The emulsion-breaking pretest was initially conducted on six 1-liter aliquots, with
five aliquots of the individual wastewater and one aliquot of commingled wastewater from all
carboys. The five aliquots of individual wastewater and the commingled aliquot were lowered to
a pH of approximately 2 and raised to a temperature of 60°C for 1 hour as they were mixed; the
aliquots were then allowed to cool and settle overnight. Observations indicated that emulsion
breaking was not effective on the interior equipment nnsates or on the commingled wastewater
However, emulsion breaking did appear to be effective on the aliquot that consisted only of floor
wash water; a distinct sludge phase settled out following heat and acidification.
To determine whether alkaline conditions increased the effectiveness of emulsion
breaking for the commingled wastewater, a second commingled aliquot was prepared from the
post-emulsion breaking aliquots of the five individual wastewaters. The pH of this second
commingled aliquot was raised to approximately 12 and heated to a temperature of 60°C for 1
hour as it was mixed. This aliquot was then allowed to cool and settle overnight. The emulsion-
breaking pretest results indicated that emulsion-breaking using alkaline conditions was not
effective on the second commingled aliquot. Therefore, pilot-scale emulsion breaking was
performed only on the floor wash water (Carboy #1)
4.2.2 Emulsion Breaking
Based on the results of the emulsion-breaking pretest, the pilot-scale emulsion
breaking step was conducted only on the floor wash water. The 16 liters of floor wash water
194
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Table 4-3
Emulsion-Breaking Pretest Data for UTS Treatability Testing of
Site A Wastewater
Aliquot
Number
Rinsate
Sample Composition
Initial
Appearance
Initi
al
pH
Material
Added To
Adjust pH
Resulti
ng pH
Observations
1
Interior Rinse #1
1,000 ml Carboy #1
Milky-white,
opaque
8 17
04 ml H2S04
(50% w/w)
1 98
No separation
2
Interior Rinse #2
500 ml Carboy #2
500 ml Carboy #3
Light green,
translucent
6 65
0 4 ml H2S04
(50% w/w)
1 95
No separation
3
Interior Rinse #3
500 ml Carboy #4
500 ml Carboy #5
Light green,
translucent
8 19
0 2 ml H2S04
(50% w/w)
1 98
No separation
4
Interior Rinse #4
1,000 ml Carboy #6
Milky-white,
opaque
7 11
0 3 ml H2S04
(50% w/w)
1 98
No separation
5
Floor Wash
1,000 ml Carboy #7
Black,
opaque
7 26
0 5 ml H2S04
(50% w/w)
1 99
Settling of black
sludge
6
First
Commingled
Aliquot
177 ml Carboy #1
165 ml Carboy #2
165 ml Carboy #3
170 ml Carboy #4
170 ml Carboy #5
100 ml Carboy #6
55 ml Carboy #7
Milky-white,
opaque
7 19
1 9 ml H2S04
(50% w/w)
1 98
Minor settling of
black material, may
just be solids from
floor sweepings
7
Second
Commingled
Aliquot
177 ml Beaker #1
330 ml Beaker #2
340 ml Beaker #3
100 ml Beaker #4
55 ml Beaker #5
Milky-white,
opaque
1 99
3 1 ml NaOH
(10N)
12 03
Slight separation,
small amount of
thick, viscous
sludge at bottom
remaining after the emulsion-breaking pretest were poured into a 19-liter stainless steel bucket,
the pH was adjusted to 2 using 70 ml of 50% weight of acid per weight of water (w/w) sulfuric
acid, and the bucket was heated to 60°C as it was stirred with a magnetic stirring bar The bucket
was maintained at 60°C for one hour as the stirring continued. The stirring was then stopped,
and the wastewater was allowed to cool and settle overnight After one hour of cooling, a
noticeable settling began to occur. After 24 hours, the supernatant was pumped into a plastic
tank using the peristaltic pump. The supernatant became progressively darker as the upper layers
were pumped into the plastic tank. However, a distinct sludge layer had settled to the bottom of
the bucket, and this layer began to resuspend as the supernatant was pumped out of the tank and
195
-------
the pump approached the level of the sludge. The volume of the sludge and the supernatant that
could not be pumped out without resuspendmg the sludge was about 3 liters.
4.2.3 Hydrolysis
Following the emulsion breaking of the floor wash water, the contents of Carboys
#1 through #6 were poured into a plastic tank with the floor wash supernatant, and the tank was
mixed with the milk-jug mixers. Influent and influent duplicate samples were collected from the
commingled wastewater in the plastic tank by scooping the water from the tank using a glass
measuring cup and pouring it into the appropriate sample bottles. Approximately 293 liters of
commingled wastewater remained in the tank following sample collection, and was hydrolyzed
in two treatment batches.
Batch 1 - A volume of 171 liters of the well-mixed commingled influent was
pumped into a stainless steel tank using the sump pump. Electric band heaters were used to heat
the tank, and 175 ml of 10 N sodium hydroxide were added to the tank to raise the pH of the
wastewater to 12. Aluminum foil was used to insulate the tank and reduce evaporation during
the heating, and the paddle mixer was used to keep the wastewater mixed throughout the
hydrolysis testing. After about three hours of heating, the tank achieved a temperature of 60°C
The temperature of the tank varied between 51°C and 82°C over the next 24 hours. The
variation in temperature was due to a malfunctioning automatic temperature controller The
temperature had to be checked periodically using an electronic thermocouple or a glass
thermometer. The control knobs on the band heaters were adjusted manually based on these
temperature readings, with the goal of maintaining the temperature at 60°C.
Samples of the hydrolysis wastewater were collected at 6, 12, and 24 hours after
the tank initially reached 60°C. Samples were collected by scooping water from the tank into a
glass measuring cup, and then pouring it into the appropriate sample bottles Approximately 26
196
-------
liters of wastewater were collected for the three sample volumes, an additional 12 liters were lost
due to evaporation and about 133 liters of wastewater remained in the tank.
After the 24-hour hydrolysis sample was collected, the tank was cooled by
submerging a length of stainless steel tubing in the wastewater; noncontact cooling water was
circulated through the tubing while the tank contents were stirred with the paddle mixer. Cooling
the tank from 56°C, its temperature at the time of collection of the 24-hour sample, to 27°C
required about 1.5 hours, at which point the stainless steel cooling coil was removed from the
tank and cleaned for reuse. The pH of the wastewater was adjusted from 11.4 to 7.3 using 62 ml
of 50% (w/w) sulfuric acid. The wastewater, which was originally milky white, turned turbid
yellow during pH adjustment. The wastewater was then pumped from the hydrolysis tank
through a 10-p.m filter to the plastic activated carbon feed tank using the submersible sump
pump. The 10-|im filter was used to remove filterable solids that could cause plugging problems
in the carbon column. The stainless steel tank, paddle mixer, and sump pump were cleaned for
reuse Table A-l in Appendix A lists the operating data for the first hydrolysis treatment batch.
Batch 2 - The remaining wastewater (about 122 liters) that had not been treated
with the first batch was transferred to the cleaned stainless steel tank for hydrolysis treatment.
Electric band heaters were used to heat the tank, and 160 ml of 10 N sodium hydroxide were
added to the tank to raise the pH of the wastewater to 12. Aluminum foil was used to insulate the
tank and to reduce evaporation during the heating, and the paddle mixer was used to keep the
wastewater mixed throughout the hydrolysis testing. After about 2.5 hours of heating, the tank
achieved a temperature of 60°C The temperature of the tank varied between 39°C and 73°C
over the next 24 hours.
A final sample of the hydrolysis wastewater was collected about 24 hours after the
tank initially reached 60°C by scooping water from the tank into a glass measuring cup and then
pouring it into the appropriate sample bottles. No interim samples were collected at 6- and
12-hour intervals as was done for the first batch. Approximately 4 liters of wastewater were
197
-------
collected for the sample and an additional 8 liters were lost due to evaporation, about 110 liters
of wastewater remained in the tank upon completion of the treatment step
Unlike the first hydrolysis batch, the tank was cooled, and the pH of the
wastewater was adjusted to a neutral level prior to collection of the 24-hour sample. The tank
was cooled by submerging a length of stainless steel tubing in the wastewater; non-contact
cooling water was circulated through the tubing while the tank contents were stirred with the
paddle mixer. The cooling of the tank from 62°C to 22°C required about 1.5 hours. The pH of
the wastewater was then adjusted from 11.8 to 7.5 using 50% (w/w) sulfuric acid The
wastewater turned from milky white to a turbid yellow during the pH adjustment. The 24-hour
sample was then collected, and the wastewater was pumped from the hydrolysis tank through a
10-|im filter to the plastic activated carbon feed tank using the sump pump. The stainless steel
tank, paddle mixer, and sump pump were cleaned for reuse Table A-2 of Appendix A lists the
operating data for the second hydrolysis treatment batch.
4.2.4 Activated Carbon Adsorption
Treatment of the wastewater from the first hydrolysis batch through activated
carbon adsorption was initiated during the hydrolysis treatment of the second batch of
wastewater. The wastewater from the activated carbon feed tank was pumped by the peristaltic
pump through flexible tubing into the top of the column. The wastewater passed down through
the column, out the bottom of the column, and into another length of flexible tubing from which
samples were taken. The wastewater flow rate through the column was maintained at a rate of 82
to 88 milliliters per minute throughout the test. Samples were collected after 60, 120, 180. and
240 liters of wastewater had passed through the column by collecting the column effluent into
glass jars and pouring the treated effluent from the glass jars into the appropriate sample bottles.
The wastewater from the second hydrolysis batch was pumped into the activated
carbon feed tank after about 56 liters of water from the first batch had passed through the column
198
-------
and about 76 liters of wastewater from the first batch remained in the feed tank About 100 liters
of wastewater from the second hydrolysis batch were added to the feed tank. The first activated
carbon wastewater sample (i.e., the 60-liter sample) was collected immediately after the
wastewater from the second hydrolysis batch was added to the activated carbon feed tank. The
activated carbon effluent did not have the turbid, yellow color of the influent, but it did have a
milky-white color. In addition, some white deposits were observed on top of the packed carbon
and in the pore spaces between the carbon granules.
4.3 Facility B Treatability Test
Facility B formulates and packages pesticide products primarily for use in the
agricultural market. The wastewater collected from Facility B for treatability testing consisted of
an interior cleaning rinsate from the washing of formulating and packaging equipment dedicated
to a product that contains the PAI tetrachlorvinphos. The product also contained molasses, and
the rinsate was expected to have high BOD5 and TOC levels. The operator cleaned the interior
of the formulation vessel using a hot, high-pressure washer and about 430 liters of water over a
50-minute timeframe. The wastewater was allowed to drain by gravity from the formulation
vessel through the packaging equipment, and it was collected from a hose connected to a
manifold at the bottom of the formulation equipment and from nozzles on the packaging
equipment. Wastewater collection personnel placed about 350 liters of the wastewater into
5-gallon carboys. The wastewater had an opaque, brown appearance.
The wastewater was collected on June 27, 1995, and was transported to Radian's
Milwaukee, Wisconsin laboratory facilities via Federal Express, where it was placed in cold
storage (approximately 4°C). The UTS treatability testing of Facility B wastewater began on
June 29, 1995 and was completed by July 11, 1995 Table 4-4 lists the sample point description,
SCC number, date and time of sample collection, pH, temperature, and collection method for the
samples collected during the Facility B treatability test
199
-------
Table 4-4
Summary of Wastewater Sampling for UTS Treatability Testing of
Facility B Wastewater
Sample
SCC
Number
Sample
Date
Sample
Time
PH
Temperature
(°C)
Collection Method
UTS Influent
28918
06/30/95
11 30
NA
NA
Half of sample volume measured
from each tank using glass
measuring cup
UTS Influent
(duplicate)
28919
06/30/95
11 30
NA
NA
Half of sample volume measured
from each tank using glass
measunng cup
Settling
Supernatant
28920
07/04/95
11 20
5 85
NA
Half of sample volume measured
from each tank using glass
measunng cup
Hydrolysis
(6-hour)
28921
07/05/95
20 00
NA
ST
Half of sample volume measured
from each tank using glass
measunng cup
Hydrolysis
(12-hour)
28922
07/06/95
2 14
NA
64 5a
Half of sample volume measured
from each tank using glass
measuring cup
Hydrolysis
(24-hour)
28923
07/06/95
14 00
10.6a
63a
Half of sample volume measured
from each tank using glass
measunng cup
Activated
Carbon
(60-liter)
28924
07/10/95
8 20-8 45
7 04
NA
Collected in 4-L glass jar from
carbon column effluent tubing
Activated
Carbon
(120-liter)
28925
07/10/95
19 08-20 30
7 02
NA
Collected in 9 6-L glass jar from
carbon column effluent tubing
Activated
Carbon
(180-liter)
28926
07/11/95
7 22-9 47
7 00
NA
Collected in 4-L glass jar from
carbon column effluent tubing
Activated
Carbon
(240-liter)
28927
07/11/95
14 55-19 15
7 05
NA
Collected in stainless steel tank
from carbon column effluent
tubing
"Average of both tanks
NA - Information not available
SCC - Sample Control Center
200
-------
4.3.1
Emulsion-Breaking Pretest
Upon receipt in Milwaukee, the wastewater was poured from the carboys into two
stainless steel tanks, Tank 1 and Tank 2. The wastewater was dark brown, and clumps of solids
had settled to the bottoms of the carboys. After the wastewater was poured into the stainless steel
tanks, the tanks were vigorously mixed using the milk-jug mixers to resuspend the solids, and
two 1-liter aliquots were collected for the emulsion breaking pretest. The tanks were then placed
in a walk-in refrigerator at 4°C to prevent biological growth from occurring. Emulsion breaking
at pH 2 and 60°C was performed on one of the aliquots, and the second aliquot was used as a
control sample.
The first aliquot of wastewater was lowered to a pH of 1.98 by adding 15.8 ml of
36 N sulfuric acid to the wastewater and was raised to a temperature of 60°C for one hour as it
was mixed; the aliquot was then allowed to cool and settle overnight. The aliquot turned a
slightly lighter shade of brown as the pH was adjusted downward The second aliquot was
simply allowed to settle overnight with no heating, mixing, or pH adjustment. The emulsion-
breaking pretest results indicated that emulsion breaking by adding acid and heat did not
significantly improve the settling of the solids or the clarity of the supernatant over the control
sample. However, solids did settle out of both the emulsion-breaking aliquot and the control
aliquot; therefore, a settling step was used instead of an emulsion-breaking step for the pilot-scale
UTS treatment test.
4.3.2 Settling
After the emulsion-breaking pretest, the stainless steel tanks were removed from
the refrigerator and their contents were remixed Tank 1, which contained 156 liters of
wastewater, was mixed using the paddle mixer, and Tank 2, which contained 163 liters of
wastewater, was mixed using the Lightning® mixer Both mixers effectively mixed the contents
201
-------
of the tanks, so the difference in mixer types should not have affected the test results. After
mixing; the influent and influent duplicate samples were collected by scooping the well-mixed
wastewater into a glass measuring cup and pouring it into the appropriate sample bottles. For
each sample bottle, a volume of wastewater equal to half of its capacity was collected from one
tank, and the remainder of the volume was collected from the other tank.
The wastewater was allowed to settle overnight. After settling, the supernatant
from Tank 1 was pumped into a plastic tank using the submersible sump pump The supernatant
volume was about 92% of the original Tank 1 volume. The supernatant from Tank 2 was
pumped into a separate plastic tank. The supernatant volume was about 91% of the original
Tank 2 volume. The stainless steel tanks, sump pump, and Lightning® and paddle mixers were
cleaned for future use.
A sample of the supernatant was collected by scooping water from the plastic
tanks into a glass measuring cup and pouring the wastewater into the appropriate sample bottles.
For each sample bottle, a volume of wastewater equal to half of its capacity was collected from
one tank, and the remainder of the volume was collected from the other tank. The wastewater
was then pumped back into the stainless steel tanks and placed in the walk-in refrigerator
4.3.3 Hydrolysis
A volume of 146 liters of wastewater was contained in each stainless steel tank at
the start of the hydrolysis testing. Electric band heaters were used to heat the tanks, and 5 3 liters
of 40% sodium hydroxide (w/w) were added to the Tank 1 to raise its pH from 5.81 to 12 02
The pH of Tank 2 was raised from 5.78 to 12.04 through the addition of 4 9 L of 40% sodium
hydroxide (w/w) Aluminum foil was used to insulate the tanks and to reduce evaporation during
the heating The Lightning® mixer (Tank 1) and the paddle mixer (Tank 2) were used to mix the
wastewater throughout the hydrolysis test After about five hours of heating, the tanks achieved
202
-------
the target temperature of 60°C. The temperatures of the tanks varied between 52°C and 74°C
over the next 24 hours. Table A-3 of Appendix A lists the operating data for the hydrolysis test.
Samples of the hydrolysis wastewater were collected at 6, 12, and 24 hours after
the tanks initially reached 60°C by scooping the well-mixed wastewater into a glass measuring
cup and pouring it into the appropriate sample bottles. For each sample bottle, a volume of
wastewater equal to half of its capacity was collected from one tank, and the remainder of the
volume was collected from the other tank. Approximately 20 liters of wastewater were collected
for the samples from each tank; about 135 liters of wastewater remained in each tank following
completion of hydrolysis. The volume of wastewater lost due to evaporation during the
hydrolysis step was negligible.
After the 24-hour hydrolysis sample was collected, the pH of Tank 1 was reduced
from 10.6 to 6.4 using 1.22 L of 36 N sulfuric acid, and the pH of Tank 2 was adjusted from 10.8
to 7.2 using 1.22 L of 36 N sulfuric acid. The wastewater was pumped from each of the
hydrolysis tanks through a 10-jim filter into separate plastic tanks using the sump pump The
filter became clogged several times with solids from the wastewater and was replaced twice
during the pumping of each tank. The wastewater was pumped from the plastic tanks back into
the stainless steel tanks, and was then placed in the walk m-refrigerator to prevent biological
growth. The plastic tanks, paddle mixer, and sump pump were cleaned for reuse.
4.3.4 Activated Carbon Adsorption
The wastewater was removed from the walk-in refrigerator and approximately 38
liters were pumped from each tank into the plastic activated carbon feed tank The stainless steel
tanks were then returned to the walk-in refrigerator to prevent biological growth The wastewater
from the activated carbon feed tank was pumped using the peristaltic pump through flexible
tubing into the top of the column. The wastewater passed down through the column, out the
bottom of the column, and into another length of flexible tubing from which samples were taken.
203
-------
The wastewater flow rate through the column was maintained at a rate of 85 to 98 milliliters per
minute throughout the test. Samples were collected after 60, 120, and 180 liters of wastewater
had passed through the column The column effluent was collected into glass jars and poured
from the glass jars into the appropriate sample bottles. A final sample was collected after
240 liters of wastewater had passed through the column. Throughout the test, the activated
carbon effluent had the same brownish color as the influent
Additional wastewater from the stainless steel tanks was pumped into the
activated carbon feed tank after the first 60 liters had been treated and about 12 liters of
wastewater remained in the feed tank. Approximately 38 liters of wastewater were pumped from
each tank into the plastic activated carbon feed tank. The stainless steel tanks were then returned
to the walk-in refrigerator to prevent biological growth. About 27 liters remained in the activated
carbon feed tank following collection of the 120-liter sample. Another 38 liters of wastewater
were pumped from each stainless steel tank into the plastic activated carbon feed tank The
stainless steel tanks were then returned to the walk-in refrigerator to prevent biological growth
About 17 liters of wastewater remained in the feed tank following collection of the 180-liter
sample, and the remaining wastewater in the stainless steel tanks was pumped into the plastic
activated carbon feed tank. About 22 liters were pumped from Tank 1, and about 34 liters were
pumped from Tank 2.
4.4 Facility C Treatability Test
Facility C formulates and packages fertilizer and herbicide products, and toll
formulates products for other companies. The products formulated in the dry formulations area
contain the PAIs ametryn, atrazine, cyanazine, ethalfluralin, metolachlor, and pendimethahn For
four to five weeks prior to sample collection, Facility C accumulated interior cleaning water from
the washing of formulating and packaging equipment for dry products and wash water from floor
washings in the dry formulation area This wastewater was stored on site in a 20,000-gallon
stainless steel tank and based on the odor and scum content, this wastewater supported biological
204
-------
growth. During wastewater collection, the wastewater was allowed to drain by gravity from the
storage tank through a hose connected to a valve at the bottom of the tank into fourteen 30-liter
carboys Approximately 420 liters of wastewater were collected. The wastewater had an opaque,
gray appearance and a strong odor.
The wastewater was collected on July 27, 1995, and was transported by van from
Facility C to Radian's Milwaukee, Wisconsin laboratory facilities The wastewater arrived on
July 27 and was placed in the walk-in refrigerator until treatability testing began The UTS
treatability testing of Facility C wastewater began on July 28, 1995 and was completed by
August 3, 1995. Table 4-5 lists the sample point description, SCC number, date and time of
sample collection, pH, temperature and collection method for the samples collected during the
Facility C treatability test.
4.4.1 Emulsion-Breaking Pretest
On July 28, 1995, the wastewater in twelve of the carboys was poured into two
stainless steel tanks, Tank 1 and Tank 2. The wastewater in the remaining two carboys was held
in reserve. The wastewater was an opaque, gray color. After the wastewater was poured into the
stainless steel tanks, the tanks were vigorously mixed using the milk-jug mixers, and the influent
and influent duplicate samples were collected by scooping the well-mixed wastewater into a
glass measuring cup and pouring it into the appropriate sample bottles. For each sample bottle, a
volume of wastewater equal to half of its capacity was collected from one tank, and the
remainder of the volume was collected from the other tank.
After the influent and influent duplicate samples were collected, three 1 5-liter
aliquots were collected for the emulsion-breaking pretest. The tanks were then placed in a
walk-in refrigerator at 4°C to prevent biological growth
205
-------
Table 4-5
Summary of Wastewater Sampling for UTS Treatability Testing of Facility C
Wastewater
Sample
—1
SCC
Number
Sample
Date
Sample
Time
PH
Temperatu
re
(°C)
Collection Method
UTS Influent
29769
07/28/95
10 30
7
13
Half of sample volume
measured from each tank
using glass measuring cup
UTS Influent
(duplicate)
29770
07/28/95
10 30
7
13
Half of sample volume
measured from each tank
using glass measuring cup
Emulsion-
Breaking
Supernatant
29771
07/30/95
9 30
2 09
33
Half of sample volume
measured from each tank
using glass measuring cup
Hydrolysis
(6-hour)
29772
07/31/95
20 15
12
NA
Half of sample volume
measured from each tank
using glass measuring cup
Hydrolysis
(12-hour)
29773
08/01/95
2 30
NA
NA
Half of sample volume
measured from each tank
using glass measuring cup
Hydrolysis
(24-hour)
29774
08/01/95
200
12
59
Half of sample volume
measured from each tank
using glass measuring cup
Activated
Carbon
(60-1 iter)
29775
08/02/95
7 50-8 40
7
21
Collected in 4-L glass jar
from carbon column effluent
tubing
Activated
Carbon
(120-liter)
29776
08/02/95
22 15-23 00
7
18
Collected in 9 6-L glass jar
from carbon column effluent
tubing
Activated
Carbon
(200-liter)
29778
08/03/95
9 00-14 30
79
NA
Collected in stainless steel
tank from carbon column
effluent tubing
NA - Not available
SCC - Sample Control Center
206
-------
The pH of the first aliquot of wastewater was lowered from 7.38 to 2.01 by adding
1.1 ml of 36 N sulfuric acid. The temperature was raised to 60°C for one hour as it was mixed;
"the aliquot was then allowed to cool and settle overnight. Visible settling of a brown flocculent
began to occur when the mixing was stopped After settling overnight, a compact gray sludge
had settled out of a translucent, yellow supernatant. The sludge occupied approximately 3% of
the original aliquot volume of 1 5 liters.
The pH of the second aliquot of wastewater was raised from 7.07 to 11.74 by
adding 6.1 ml of 10 N sodium hydroxide. The temperature was raised to 60°C for one hour as it
was mixed; the aliquot was then allowed to cool and settle overnight. Visible settling of a brown
flocculent began to occur when the mixing was stopped; however, this settling was not as
dramatic as the settling that occurred in the first aliquot. After settling overnight, a gray sludge
had settled out of an opaque, brown supernatant. The sludge occupied approximately 7% of the
original aliquot volume of 1.5 liters, but was not as compact as the sludge in the first aliquot.
The third aliquot was simply allowed to settle overnight with no heating, mixing, or pH
adjustment. No visible settling occurred immediately; however, after settling overnight, about
750 ml (50% of the original volume) exhibited signs of settling. As with the second aliquot, the
settling that was observed was not as complete and the sludge was not as compact as the first
aliquot.
4.4.2 Emulsion Breaking
Because the pretest of the first aliquot resulted in more complete settling of the
solids and a clearer supernatant, pilot-scale emulsion breaking using heat and acid was conducted
on the Facility C wastewater. Each of the two stainless steel tanks of wastewater, which
contained approximately 170 liters of wastewater, were removed from the walk-m refrigerator
The pH of the tanks was adjusted from 7 2 to 2 1 using 175 ml of 36 N sulfuric acid per tank
The tanks were heated from their initial temperature of 7°C using the band heaters During the
207
-------
heating, Tank 1 was stirred with the paddle mixer and Tank 2 was stirred with the Lightning®
mixer. After about six hours the tanks reached 60°C; the tanks were maintained at a temperature
between 60°C and 70°C for one hour as the stirring was continued. A 50-ml aliquot of Tank 1
wastewater was collected in a 50-ml glass graduated cylinder for the purpose of more accurately
identifying the volume of sludge that would settle out of the wastewater The mixers were then
stopped, and the wastewater was allowed to cool and settle overnight.
A noticeable settling of a brown flocculent in a translucent yellow supernatant
began to occur as soon as the mixers were stopped. After settling overnight the supernatant in
Tank 1 appeared to be a translucent yellow color, while the supernatant in Tank 2 appeared to be
a slightly turbid green color. The 50-ml aliquot taken from Tank 1 contained a translucent,
yellow supernatant with 2 ml (or 4%) of gray sludge.
The emulsion-breaking effluent sample was collected from the tanks by scooping
the supernatant into a glass measuring cup and pouring it into the appropriate sample bottles. For
each sample bottle, a volume of wastewater equal to half of its capacity was collected from one
tank, and the remainder of the volume was collected from the other tank.
The supernatant from Tank 1 was pumped into a plastic tank using the sump
pump. However, turbulence from the sump pump caused the sludge to resuspend The
supernatant was then pumped back into Tank 1, and the emulsion-breaking process was repeated
by heating the tank back to 60°C and stirring its contents with the paddle mixer. While Tank 1
was reheating, the supernatant from Tank 2 was pumped to a plastic tank using a centrifugal
pump, which did not cause the supernatant to resuspend. About 8 liters (or 4 7%) of sludge
remained in the tank after the supernatant was pumped from Tank 2.
Because Tank 1 was already at a pH of about 2, no pH adjustment was required
prior to performing the emulsion-breaking step on Tank 1 a second time The tank was reheated
to 60°C and the temperature was maintained for one hour as the contents of the tank were mixed
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with the paddle mixer. The mixer was then turned off and the tank was allowed to cool and
settle for about three hours. A translucent, yellow supernatant was then pumped from Tank 1,
using the centrifugal pump, into a separate plastic tank, which left about 4 liters (or 2.3%) of gray
sludge in Tank 1. The sludge from both Tank 1 and Tank 2 was disposed of, and the tanks,
mixers, and pumps were cleaned for future use. The plastic tanks of supernatant were cooled
overnight.
4.4.3 Hydrolysis
After cooling overnight, the supernatant from Tank 1 was pumped back into
Tank 1, and the supernatant from Tank 2 was pumped back into Tank 2. Electric band heaters
were used to heat the tanks, and 550 ml of 40% sodium hydroxide (w/w) was added to each tank
to raise the pH. The pH of Tank 1 was raised from 2.05 to 11 33, and the pH of Tank 2 was
raised from 2.05 to 11.43. During the hydrolysis testing, the paddle mixer was used to stir Tank
1, and the Lightning® mixer was used to stir Tank 2. After about five hours of heating, the pH
reading for each tank was approximately 11, therefore, an additional 50 ml of 40% sodium
hydroxide (w/w) was added to each tank to raise its pH to 12. After about five and one-half
hours of heating, the tanks achieved the target temperature of 60°C. The temperatures of the
tanks varied between 50°C and 70°C over the next 24 hours The temperatures of the tank were
not recorded; therefore, no table of operating data is provided for the hydrolysis of wastewater
from Facility C About one hour after the tanks achieved their target temperature, aluminum foil
was placed over the tops of the tanks to insulate the tanks and to reduce evaporation during the
heating.
Samples of the hydrolysis wastewater were collected at 6, 12, and 24 hours after
the tank initially reached 60°C by scooping the well-mixed wastewater into a glass measuring
cup and pouring it into the appropriate sample bottles. For each sample bottle, a volume of
wastewater equal to half of its capacity was collected from one tank, and the remainder of the
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volume was collected from the other tank. The wastewater in both tanks appeared translucent
yellow throughout the hydrolysis testing. Sampling personnel noted that a small amount of
brown sludge settled to the bottoms of the samples. However, this sludge became resuspended in
the samples that were preserved to neutral or acidic pH, resulting in a slightly turbid brown
sample.
After the 24-hour hydrolysis sample was collected, Tanks 1 and 2 were cooled by
submerging a length of stainless steel tubing in the two wastewaters; noncontact cooling water
was circulated through the tubing while the tank contents were stirred with the paddle mixer.
Approximately 45 minutes were required to cool Tank 1 from its temperature of 59°C to 35°C;
Tank 2 required about 40 minutes to lower the temperature from 55°C to 35°C.
4.4.4 Activated Carbon Adsorption
Following hydrolysis, the pH of Tank 1 was adjusted from about 12 to 7 using
100 ml of 36 N sulfuric acid. The pH of Tank 2 was also adjusted using 100 ml of 36 N sulfuric
acid, which lowered its pH from about 12 to 4. An additional 60 ml of 40% sodium hydroxide
(w/w) was added to Tank 2 to raise its pH to 7. The wastewater turned a slightly turbid brown
color during the pH adjustment.
Using the sump pump, 30 liters of wastewater from Tank 1 were pumped through
a 10-|Lim filter into a plastic tank with volume gradations marked on the side of the tank. The
filtered water was then poured into the plastic activated carbon feed tank. This process was
repeated with 30 liters of wastewater from Tank 2; however, the filter became clogged with
solids from the wastewater and was replaced. An additional 30 liters of wastewater were
pumped again from each tank using the same procedures, but again the filter become clogged and
had to be replaced. Yellow-brown solids were caked on the filters when they were replaced. The
total volume of wastewater pumped to the activated carbon feed tank was 120 liters. Tank 1 and
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Tank 2 were then placed in the walk-in refrigerator to prevent biological growth in the
wastewater.
The wastewater from the activated carbon feed tank was pumped by the peristaltic
pump through flexible tubing into the top of the column. The wastewater passed down through
the column, out the bottom of the column, and into another length of flexible tubing from which
samples were taken. The activated carbon effluent was initially clear, but it developed a faint
yellow-green tinge after about 60 liters of wastewater had passed through the column The
wastewater flow rate through the column was maintained at a rate of 82 to 93 milliliters per
minute throughout the test. A sample was collected after 60 liters of wastewater had passed
through the column by collecting the column effluent into a glass jar and pouring the treated
effluent from the glass jar into the appropriate sample bottles
About six hours after the collection of the 60-liter sample, an additional volume
(35 liters) of wastewater from Tank 1 was pumped, using the submersible sump pump, through a
10-|im filter into a plastic tank with volume gradations marked on the side of the tank. The
filtered water was poured into the plastic activated carbon feed tank, and the filter, which had
become caked with yellow-brown solids during the pumping, was replaced This process was
repeated with 35 liters of wastewater from Tank 2 and then with the remaining 8 liters of
wastewater from Tank 1 and the 22 liters from Tank 2.
About one hour after the remaining wastewater was filtered into the activated
carbon feed tank, the flow rate through the carbon column decreased to about 40 milliliters per
minute, and a cake of solids was visible on top of the carbon packed in the column The
wastewater in the activated carbon feed tank was then refiltered using a 5-p.m filter by pumping
the wastewater from the carbon feed tank through the 5-|im filter into a clean plastic tank.
Yellow-brown solids accumulated on the filter during the filtration The activated carbon
column was then backwashed with about 1 liter of distilled water, which caused the caked solids
at the top of the column to break apart. However, some air became entrapped in the column
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during the backwashmg. A vacuum of about 18 centimeters of mercury was applied to the
column for 15 minutes while the column was tapped with a mallet to remove the entrapped air.
Some air bubbles remained in the spaces between the carbon granules following this procedure.
The column was then restarted and the flow rate of wastewater from the activated carbon feed
tank was adjusted to 85 milliliters per minute
A sample was collected after a total of 120 liters of wastewater had passed
through the column by collecting the column effluent into a glass jar and pouring the treated
effluent from the glass jar into the appropriate sample bottles. Two additional samples of the
carbon effluent were planned, one at 180 liters of effluent and one at 240 liters of effluent, but
only a total of about 220 liters of wastewater was available for activated carbon treatment
because wastewater was lost to evaporation during the hydrolysis and emulsion-breaking steps.
Therefore, only one additional sample was taken after 200 liters of wastewater had passed
through the column.
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