Environmental Assessment
for the
Final Effluent Limitations Guidelines,
Pretreatment Standards for New and Existing Sources and
New Source Performance Standards
for the Centralized Waste Treatment Point Source Category
August 2000
EP A-821 -R-00-022
U.S. Environmental Protection Agency
Office of Science and Technology
Standards and Applied Science Division
401 M Street, S.W.
Washington, D.C. 20460
Charles Tamulonis
Task Manager

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ACKNOWLEDGMENTS AND DISCLAIMER
The Engineering and Analysis Division, of the Office of Science and Technology, has reviewed
and approved this report for publication. The Office of Science and Technology directed,
managed, and reviewed the work of ERG in preparing this report. Neither the United States
Government nor any of its employees, contractors, subcontractors (Tetra Tech, Inc.), or their
employees make any warranty, expressed or implied, or assumes any legal liability or
responsibility for any third party's use of or the results of such use of any information, apparatus,
product, or process discussed in this report, or represents that its use by such party would not
infringe on privately owned rights.

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Executive Summary
This report assesses the water quality related benefits that would be expected from adoption by the U.S.
Environmental Protection Agency (EPA) of final effluent limitations, guidelines and pretreatment standards for
the Centralized Waste Treatment (C WT) Point Source Category. EPA estimates that under baseline conditions
205 CWT facilities discharge approximately 8.6 million lbs/year of metal and organic pollutants. The final rule,
in EPA's assessment, will reduce this pollutant loading by 50%, to 4.3 million lbs/year (see Table ES-1).
Summary of Non-Scaled Environmental Effects
(a)	Ambient Water Quality Effects
EPA analyzed the environmental effects associated with discharges from 113 of the 205 CWT facilities.
The analysis compared modeled instream pollutant levels to Ambient Water Quality Criteria (AWQC). This
review found estimates that current discharge loadings contribute to in-stream concentrations in excess of
AWQCs in 252 cases at 43 receiving water locations. The final rule would reduce the number of in-stream
concentrations exceeding AWQCs to 156 at 38 receiving water locations.
(b)	Human Health Effects
EPA estimates that CWT loadings from the 113 CWT facilities are responsible for 0.18 cancer cases per
year. The final rule would reduce this to 0.14 cases per year. In addition, the rule reduces lead exposure
and related health effects for an estimated 101,000 persons. EPA estimates the final rule will reduce lead
uptake enough to prevent the IQ loss of 60 points in children of recreational and subsistent anglers. EPA
also estimates that the IQs of 0.2 angler children would not drop below 70.
(c)	POTW Effects
EPA estimates that six of the 69 Publically Owned Treatment Works (POTWs) considered for this
assessment experience inhibition problems due to CWT wastes. The final rule would decrease this number
by two. The final rule will also improve biosolids quality of 3,900 metric tons.

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(d) Basis of Conclusions
The report bases its conclusion about these benefits on site-specific analyses of current conditions and the
expected changes from compliance with the final CWT Best Available Technology (BAT) economically
achievable effluent limitations and Pretreatment Standards for Existing Sources (PSES). The final
regulations limits the discharges of pollutants into navigable waters of the United States and the introduction
of pollutants into POTWs from existing sources and from new sources in three CWT subcategories. These
categories are Metal-Bearing Waste Treatment and Recovery Operations (metals), Used/Waste Oil
Treatment and Recovery Operations (oils), and Organic Waste Treatment (organics). Many CWT facilities
treat or recover wastes in more than one category.1
' "able ES-1. Summary of Non-Scaled Environmental Effects of 113 CWT Facilities a

Cunvnl
1'null Rule
Summan of IJenelils olTmal Rule
Loadings (million lbs/yr)b'c
8.6
4.3
50% reduction
Number of In-Stream
Concentrations for
Pollutants that Exceed
AWQC
252 at 43 streams
156 at 38 streams
5 streams become "contaminant free" e
Additional Cancer Cases/yrd
0.18
0.14
0.04 cases reduced each year
Population potentially at risk
to lead exposured
101,000
101,000
Annual benefits are:
•	Reduction of 1.5 cases of hypertension
•	Protection of 60 IQ points
•	Prevention of lowering of 0.2 children's
IQs below 70
Population potentially
exposed to other non-cancer
health risksd
1,880
none
Health effects to exposed population are
completely reduced
POTWs experiencing
inhibition
6 of 69
4 of 69
Potential inhibition eliminated at 2
POTWs
Improved Biosolid Quality
0 metric tons
3,900 metric tons
3,900 metric tons improved
a.	Modeled results which are not scaled represent 12 direct and 101 indirect CWT waste water dischargers.
b.	104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; conventional pollutants are
not included in the analysis.
c.	Loadings are scaled to represent all 205 facilities. Loadings account for POTW removals.
d.	Through consumption of contaminated fish tissue.
e.	"Contaminant free" from CWT discharges; however potential contamination from other point source discharges and non-point
sources is still possible.
1 Many CWT facilities treat wastes from multiple subcategories. Therefore, EPA aggregated loadings
from each subcategory to estimate the combined environmental effects of the final rule.
ES-2

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Final Treatment Options
EPA selected the treatment technologies which form the basis for the final rule from a larger set of
technology options based on several criteria, including efficiency of pollutant removal and the economic
achievability of these removals. Chapter 9 of the technical development document discusses the technology
basis of each of the selected technologies for each of the final subcategories. Table ES-2 provides a
summary of the technology basis for the final rule.
Table ES-2. Technology Basis for Selected Options
\lclals SulxalCLMiN
Oils SulxalegoiN
OiL-anics SulxalCL-niN
IJI'T IJCT
NSPS
IJI'T IK'T IJAT
PSES
IJI'T IK I IJAT
BAT i>si:s

PSNS/NSPS

psi;s i's\s \si's
PSNS b




Option 4:
Precipitation,
liquid solid
separation,
secondary
precipitation and
sand filtration
(sand filters for
directs only).
Option 3:
Selective metals
precipitation, liquid-
solid separation,
secondary (sulfide)
precipitation, liquid-
solid tertiary
precipitation,
clarification.
Option 9:
Emulsion
breaking, gravity
separation,
secondary gravity
separation and
dissolved air
flotation
Option 8:
Emulsion
breaking,
gravity
separation,
and
dissolved
air flotation
Option 4:
Equalization, and
biological treatment
a.	For facilities in the cyanide subset of the metals subcategory, the technology basis is alkaline chlorination at specific operating
conditions.
b.	Direct dischargers are covered by BPT / BAT. Indirect dischargers are covered by PSES
Modeling Techniques
EPA employed modeling techniques to assess the potential benefits of the final limitations and standards.
First, EPA estimated pollutant concentrations in receiving water bodies for priority and nonconventional
pollutants under current (baseline) and final treatment levels. Chapter 12 of the Technical Development
Document explains more about these estimates. Second, EPA estimated water quality effects associated
ES-3

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with direct and indirect discharges for the three subcategories of CWT facilities using stream dilution
modeling.2 EPA analyzed the effects from direct and indirect discharge operations separately. EPA had
sufficient data to analyze water quality impacts for 113 of the 205 CWT facilities. Third, EPA combined
the impacts for each of the subcategories to estimate water quality effects as a result of the rule.
EPA then analyzed benefits in terms of effects on aquatic life, human health, and POTW operations. EPA
projected the benefits to aquatic life by comparing the modeled instream pollutant concentrations to EPA
aquatic life criteria and toxicity values (acute and chronic ambient water quality criteria). EPA projected
human health benefits by comparing estimated instream pollutant concentrations to health-based toxic effect
values derived using standard EPA methodology (referred to as human health ambient water quality
criteria). In addition, EPA projected potential carcinogenic and noncarcinogenic hazards to the recreational
and subsistence angler populations due to the consumption of fish.
The environmental assessment also assesses the potential inhibition of POTW operations and potential
sewage biosolids contamination (thereby, limiting its use for land application) based on current and final
pretreatment levels. EPA estimated inhibition of POTW operations by comparing modeled POTW influent
concentrations to available inhibition levels. EPA assessed the potential contamination of sewage biosolids is
estimated by comparing projected pollutant concentrations in sewage biosolids to available EPA sewage
biosolids regulatory standards.
Documented Impacts
The Environmental Assessment also summarizes documented environmental impacts on water quality and
POTW operations from centralized waste treatment facilities. EPA based the summary data on
information obtained from State 304(1) Short Lists and EPA Regional and State Pretreatment Coordinators
on the quality of receiving waters and impacts on POTW facilities. Effects included seven cases of
impairment to POTW operations due to cyanide, nitrate/nitrite, sodium, zinc, and ammonia, and one case of
an effect on the quality of water due to organics. In addition, several states have identified four direct CWT
facilities and eight POTWs, which receive discharges from 13 facilities as point sources causing water
quality problems.
2 The model employed was a simple dilution model that does not account for fate processes.
ES-4

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1. Introduction
This report presents the result of the water quality assessment performed by the U.S. Environmental
Protection Agency (EPA) as part of its effort to develop effluent limitations guidelines and pretreatment
standards for centralized waste treatment (CWT) facilities. EPA based effluent limitations guidelines and
pretreatment standards upon the treatment technologies described below (see Table 1-1). The report also
explains how EPA prepared its assessment.
Table. 1-1. Technology Basis for Selected Options
\lclals SulxalCLMiN
Oils SulxalegoiN
OiL-anics SulxalCL-niN
IJI'T IJCT
BAT i>si:s
PSNS b
NSPS
IJI'T IJCT IJAT
PSNS/NSPS
PSES
IJI'T IK I IJAT
psi;s i's\s \si's
Option 4:
Option 3:
Option 9:
Option 8:
Option 4:
Precipitation,
liquid solid
separation,
secondary
precipitation and
sand filtration
(sand filters for
directs only).
Selective metals
precipitation, liquid-
solid separation,
secondary (sulfide)
precipitation, liquid-
solid tertiary
precipitation,
clarification.
Emulsion
breaking, gravity
separation,
secondary gravity
separation and
dissolved air
flotation
Emulsion
breaking,
gravity
separation,
and
dissolved
air flotation
Equalization, and
biological treatment
a.	For facilities in the cyanide subset of the metals subcategory, the technology basis is alkaline chlorination at
specific operating conditions.
b.	Direct dischargers are covered by BPT / BAT. Indirect dischargers are covered by PSES.
1-1

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EPA estimated the potential effects on aquatic life and human health resulting from exposure to effluent
discharges from centralized waste treatment (CWT) facilities and from publicly owned treatment works
(POTWs) which receive and treat waste from CWT facilities and then discharge to surface waters. EPA
has also used the results of this assessment in the final economic analysis of the final CWT effluent
guidelines. This report first projects effects associated with current (baseline) conditions and then evaluates
potential effects expected from adoption of the final limitations and standards. Evaluations of the
environmental benefit of meeting the final limits and standards are then presented.
EPA recognizes that its estimation of benefits is probably incomplete. At the present time, EPA cannot
evaluate in a quantitative manner all human health and ecosystem benefits associated with water quality
improvements. For example, the analyses have considered the effects of certain toxic pollutants but do not
evaluate the effects of other pollutants (such as five-day biochemical oxygen demand (BOD5), chemical
oxygen demand (COD), and total suspended solids (TSS)), all of which may produce significant adverse
environmental effects. Additionally, EPA has identified 205 CWT facilities, but because it lacks receiving
stream flow information, EPA only modeled aquatic life and human health effects for 113 facilities.
With these limitations, EPA has analyzed the effects of current water discharges and assessed the benefits
of reductions in these discharges resulting from this final rule. EPA evaluated water quality benefits of
controlling the discharge from CWT facilities to surface waters and POTWs for direct and indirect
dischargers located throughout the United States. CWT industry waste effluents contain pollutants that
when discharged into freshwater and estuarine ecosystems may alter aquatic habitats, affect aquatic life, and
adversely affect human health. In fact, all 104 pollutants included in this analysis (see Table 4-1) have at
least one toxic effect. Each is a human health carcinogen and/or human health systemic toxicant or aquatic
toxicant. Many of these pollutants are persistent and bioaccumulate in aquatic organisms. In addition,
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many of these pollutants may also adversely affect POTW operations and/or cause POTW sludge
contamination. These effects are widely documented. For example, State 304(1) lists detail adverse effects
on aquatic life, human health, and POTW operations.
EPA has organized this report into five sections. Section 2 describes the methodology EPA used to evaluate
water quality effects from direct and indirect discharging facilities and effects on POTW operations from
indirect discharging facilities. Section 3 describes the data sources used for evaluating water quality effects
such as facility-specific data, POTW operational data, water quality criteria, and documented environmental
impact data. Section 4 presents a summary of the results of this analysis. Section 5 provides a complete list
of references cited. Appendices A through C provide additional detail on the specific information addressed
in the main report.
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2. Methodology
EPA evaluates potential water quality effects of direct discharges on receiving streams and of indirect
discharges on POTW operations and their receiving streams using stream modeling techniques, as described
in Sections 2.1.1 and 2.1.2. Direct discharge facilities are those which discharge directly into water bodies
usually following on-site wastewater treatment. Indirect discharge facilities are those which discharge
facility effluent into a publicly owned treatment works (POTWs), which provides subsequent treatment of
the facility effluent.
EPA evaluated potential aquatic life and human health effects resulting from current and projected
contaminant releases separately for the three final subcategories of CWT operations. The categories are as
follows: Metal-Bearing Waste Treatment and Recovery Operations (metals), Used/Waste Oil Treatment and
Recovery Operations (oils), and Organic Waste Treatment (organics). Many facilities fall into multiple
subcategory combinations.1 EPA also assessed the effects on POTWs that treat effluent from CWT
facilities (Section 2.2). These effects may include biological upset of treatment processes and sewage
biosolids toxicity.
EPA assessed potential effects on aquatic life by comparing modeled in-stream concentrations to EPA's
aquatic life ambient water quality criteria (AWQCs). Where EPA has not developed water quality criteria,
EPA uses other values representative of that chemical's aquatic toxicity. The Agency compares modeled in-
stream concentrations to both acute and chronic AWQCs when available.
EPA estimates potential effects on human health in the following manner. EPA first compares modeled in-
stream contaminant concentrations for each facility by subcategory under baseline conditions and for the
final limitations and standards. EPA compares these instream concentrations to health-based toxic effect
values derived using standard EPA methodology. Next, EPA estimates potential carcinogenic risks and
noncarcinogenic hazards to the recreational and subsistence angler populations and their households due to
the consumption of contaminated fish. EPA also estimates exposure to contaminants through the water
1 Many CWT facilities treat wastes from multiple subcategories. Therefore, EPA aggregated loadings from
each subcategory to estimate the combined environmental effects of the final rule.
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pathway by comparing modeled in-stream contaminant concentrations to health-based AWQCs for the
ingestion of water and organisms.
2.1 Estimating In-Stream Concentrations
EPA estimates in-stream contaminant concentrations for various flow conditions as the first step in
evaluating effects on aquatic life and human health. EPA uses treatment data collected from industry and
EPA sampling data to estimate contaminant loadings discharged at each facility under baseline conditions
and under the final rule. Chapter 12 of the final technical development document (EPA 821-R-00-023) for
the final rule explains the methodology EPA used to estimate current and post-compliance pollutant
loadings. The following subsections describe the methodology and assumptions EPA uses to evaluate
effects of direct and indirect discharging facilities on human health and aquatic life.
2.1.1 Direct Discharge Facilities
EPA projects in-stream concentrations for current and final rule BPT/BAT treatment levels using a simple
stream dilution model that does not account for fate and transport processes (see Equation l).2
_ LlOD
C. =	x CF	(1)
* FF+SF	y '
where:
C1S = in stream pollutant concentration (|ig/L):
L = facility pollutant loading (lb/year);
OD = facility operation (days/year);
FF = facility flow (million gallons per day (MGD));
SF = receiving stream flow (MGD); and
CF = conversion factor 120 (|ig MG / L lbs) = 0.2642 (gal/L) x 0.4536 (kg/lbs) x 103
(|ig MG / kg gal).
2 Equations used to estimate instream concentrations are adapted from methodology presented in "Technical
Support Document for Water Quality-Based Toxics Control, EPA, March 1991.
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EPA obtains the facility-specific data (i.e., pollutant loading, operating days, and facility flow) used in
Equation 1 from the sources described in Section 3.1 of this report. In all, EPA uses three different values
for receiving stream flow rate (1Q10 low flow, 7Q10 low flow, and harmonic mean flow (HMF)) for the
current and final regulatory options. The 1Q10 and 7Q10 low flows are used to evaluate the potential for
acute and chronic aquatic toxicity, respectively, in receiving streams, as recommended in the Technical
Support Document for Water Quality-based Toxics Control (USEPA, 1991a).3 EPA uses the HMF to
estimate the potential for human health effects.4 Neither the 1Q10 nor 7Q10 flow is appropriate for
assessing potential human health effects because neither has a consistent relationship with the long-term
mean dilution.
Because EPA is not able to obtain stream flows for hydrologically complex waters such as bays, estuaries
and oceans, EPA uses site-specific critical dilution factors (CDFs) with Equation 2 to predict pollutant
concentrations for facilities discharging to these complex water bodies. EPA uses site-specific CDFs
developed from a 1992 survey of states and EPA Regions conducted by EPA's Office of Pollution
Prevention and Toxics (OPPT).
a. =
i^)
X CF
/ CDF
(2)
where:
r
^es
estuary pollutant concentration (|ig/L):
L
facility pollutant loadings (lb/year);
OD
facility operation (days/year);
FF
facility flow (MGD);
CDF =
critical dilution factor (unitless); and
CF
conversion factor =120 (|ig MG / L lbs).
3	The 1Q10 and 7Q10 flows, respectively, are the lowest 1-day and lowest consecutive 7-day average flow during
any 10-year period.
4	The harmonic means are determined by taking the reciprocal of the mean value of the reciprocal of individual
values. EPA recommends that the long-term harmonic mean flow be used for assessing potential human health
effects because it provides a more conservative estimate than the arithmetic mean flow.
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When EPA cannot obtain CDFs directly, EPA uses dissolved concentration potentials (DCPs) with Equation
3 to calculate the CDF. EPA obtains DCPs from the Strategic Assessment Branch of the National Oceanic
and Atmospheric Administration's (NOAA) Ocean Assessments Division. NOAA developed DCPs based
on freshwater inflow and salinity gradients to predict pollutant concentrations in each estuary in the National
Estuarine Inventory (NEI) Data Atlas. These DCPs are applied to predict concentrations of nonreactive
dissolved substances. In addition, the DCPs reflect the predicted estuary-wide response and might not be
indicative of site-specific locations. If neither DCPs nor CDFs are available for an estuary receiving
discharges from CWT facilities, EPA estimates a CDF based on best professional judgement of the size,
depth, and location of the receiving water body. Appendix A provides DCP values used for specific water
bodies.
__ _	BL x CF
CDF = 		(3)
DCP x OD x FF	K '
where:
CDF =
critical dilution factor (unitless);
BL
benchmark load = 10,000 (tons/yr);
DCP =
dissolved concentration potential (mg/L);
OD
facility operation (days/year);
FF
facility flow (MG / day); and
CF
conversion factor = 239.68 (mg MG/ ton L) = 907.2 (kg/ton) 106 (mg/kg) x 10

(MG/gal) x 0.2642 (gal/L).
In summary, EPA estimates in-stream (Equation 1) or estuary (Equation 2 or 3) pollutant concentrations for
direct discharge facilities to evaluate whether either human health criteria or ambient water quality criteria
are exceeded. EPA sums pollutant loadings for individual subcategories before calculating concentrations
from multiple subcategory CWTs. When evaluating the combined effects, (combinations of the treatment
technology that form the basis for each of the final subcategories), EPA determines water body
concentrations by first summing pollutant loadings from all CWT facilities.
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2.1.2 Indirect Discharge Facilities
EPA estimates in-stream concentrations for current and final PSES requirements using a simple stream
dilution model that does not account for fate processes but does account for POTW influences (see
Equation 4). Note that Equation 4 and Equation 1 differ to account for the additional dilution provided by
the POTW flow and the removal of pollutants by POTW treatment processes. Sections 3.1 and 3.2 of this
report describes the sources the facility-specific data used in Equation 4.
a . (fjoa,, V-™1)"(4)
*	PF * SP	1 '
where:
r
Ms
in stream pollutant concentration (|ig/L):
L
facility pollutant loading (lb/year);
OD
facility operation (days/year);
TMT =
POTW treatment removal efficiency (unitless);
PF
POTW flow (MGD);
SF
receiving stream flow (MGD); and
CF
conversion factor =120 (|ig MG / L lbs).
EPA predicts pollutant concentrations of hydrologically complex water bodies, such as bays, estuaries, and
oceans, that received POTW discharges using Equation 5 and site-specific CDFs.
a. =
L/OD X	x cp
PF I
/ CDF	(5)
Where:
Ces	=	estuary pollutant concentration (fj.g/L);
L	=	facility pollutant loading (lb/year);
OD	=	facility operation (days/year);
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PF
CF
TMT
CDF
POTW treatment removal efficiency (unitless);
POTW flow (MGD);
critical dilution factor (unitless); and
conversion factor =120 (|ig MG / L lbs).
When EPA cannot obtain a CDF directly, EPA uses estuarine DCPs with Equation 4 to calculate that CDF.
If neither DCPs nor CDFs are available for estuaries receiving discharges from CWT facilities, EPA
estimates a CDF based on best professional judgment of the size, depth, and location of the receiving water
body. Appendix A provides the DCP values used for specific water bodies.
EPA sums pollutant loadings for individual subcategories before calculating concentrations for POTWs
receiving effluent from multiple subcategory CWT facilities. When evaluating the combined effects
(combinations of the treatment technologies basis for each of the final subcategories), EPA determines water
body concentrations by first summing contaminant loadings from all CWT facilities discharging to each
POTW.
2.2 Estimating POTW Effects
EPA calculates effects on POTW operations based either on inhibition of POTW processes (i.e., inhibition
of activated sludge or biological treatment), or contamination of POTW sewage biosolids (thereby limiting a
POTW's ability to use the biosolids for land application). EPA determines inhibition of POTW operations
by comparing calculated POTW influent levels (Equation 6) with available inhibition levels (see Table 3-1).

(6)
PF
where:
PF
L
OD
average POTW influent concentration with load contribution of facility
average POTW influent concentration for chemical j due to other sources (jx/L);
facility pollutant loading (lb/year);
number of operating days for each facility (days/year);
POTW flow (MGD); and
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CF = conversion factor =120 (|ig MG / lbs L).
The term Cdj in Equation 6 represents the contribution of other sources (non-CWT pollutant loads) to the
average POTW concentration—a contribution that varies among POTWs. In the absence of specific
knowledge of each POTW, EPA conservatively estimates Cdj by multiplying the reported chemical-specific
upset criterion by 0.75.5
EPA evaluates potential contamination of sewage biosolids by comparing projected pollutant concentrations
in the biosolids (Equation 7) with regulatory values for land application of sewage biosolids. EPA uses two
sets of regulatory criteria to characterize projected POTW biosolids concentrations (see Table 3-2).
_ _ . L	TMT
C = C.+ (	 X 	X CF)	
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2.3 Assumptions and Caveats
EPA makes the following assumptions in this analysis:
EPA models CWT facilities if the receiving streams or the POTWs to which they discharge could
be identified (113 of the 205 facilities).
Aquatic life and human health effects were estimated based on 113 facilities for which facility -
specific data are available.
CWT facilities operate 260 days per year.
Discharges from CWT contribute produce only a small portion of the total POTW (domestic)
biosolids.
The process water at each facility and the water discharged to a POTW are obtained from a source
other than the receiving stream.
The pollutant load to the receiving stream is continuous and representative of long-term facility
operations. This assumption might overestimate risks to human health and aquatic life.
Complete mixing of discharge flow and stream flow occurs across the stream at the discharge point.
This mixing results in the calculation of an "average stream" concentration even though the actual
concentration might vary across the width and depth of the stream.
EPA did not consider pollutant fate processes such as sediment adsorption, volatilization, and
hydrolysis. This approach might result in estimated in-stream concentrations that are
environmentally conservative (higher).
The study only evaluates the potential for metal contamination of sewage biosolids to levels that
would prohibit its land application as a fertilizer or soil conditioner. Biosolids criteria levels are only
available for 7 pollutants: arsenic, cadmium, copper, lead, mercury, selenium & zinc.
The analysis dilutes pollutant loadings in 1,400 pounds of primary sludge per million gallons treated.
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The 1Q10 and 7Q10 receiving stream flow rates are used to estimate aquatic life effects, and
harmonic mean flow rates to estimate human health effects. The analysis estimates 1Q10 low
flows using the results of a regression analysis of 1Q10 and 7Q10 flows from representative U.S.
rivers and streams conducted by Versar Inc. for EPA's OPPT (Versar, 1992). The analysis
estimates harmonic mean flows from the mean and 7Q10 flows as recommended in the Technical
Support Document for Water-Quality-based Toxics Control (USEPA, 1991a). These flows might
not be the same as those used by specific states to assess effects.
The analysis uses an exposure duration of 365 days to determine the likelihood that human health
criteria or toxic effect levels will be exceeded.
The analysis uses water quality criteria or toxic effect levels developed for freshwater organisms to
analyze facilities discharging to estuaries or bays.
2.4	Compiling Documented Environmental Effects
During the months of June through September 1997, EPA contacted EPA Regional and State Pretreatment
Coordinators regarding effects of CWT discharges on POTWs and surface waters (see Table 4-27). EPA
reviewed State 304(1) Short Lists (USEPA, 1991b) for evidence of documented environmental effects on
aquatic life, human health, POTW operations, and the quality of receiving water due to discharges of
pollutants from CWT facilities (see Tables 4-28 and 4-29). EPA also reviewed the Permit Compliance
System (PCS) data.
2.5	Estimating Toxic Effects
2.5.1 Estimating Effects on Aquatic Life
EPA evaluates potential effects on aquatic life on a site-specific basis by comparing modeled in-stream
contaminant concentrations under baseline conditions and following adoption of the final rule using aquatic
life criteria and toxicity values (acute and chronic AWQCs). EPA compares the in-stream concentrations
for each chemical discharged from each facility under 1Q10 and 7Q10 flow conditions to acute and chronic
AWQCs, respectively. EPA first determines whether the discharge of any of the 104 pollutants will exceed
the AWQC for that pollutant in a given stream. Next, EPA totals these to obtain the number of in-stream
concentrations that exceed one or more AWQC for the 41 water bodies examined.
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2.5.2 Estimating Effects on Human Health
EPA estimates potential effects on human health in the following manner. EPA first compares modeled in-
stream contaminant concentrations for each subcategory under baseline conditions and following adoption of
the final limitations and standards. EPA compares these instream concentrations to health-based toxic effect
values6 derived using standard EPA methodology. Next EPA estimates potential carcinogenic risks and
noncarcinogenic hazards to the recreational and subsistence angler population due to the consumption of
contaminated fish. Finally, EPA estimates both the annual incidence of cancer and potential lead related
health effects in the potentially exposed angler population. Each of these techniques is discussed in more
detail below.
(a)	Human Health AWQCs
EPA uses the modeled in-stream HMF concentration for estimation of human health AWQ. It is more
reflective of average water body conditions then 1Q10 or 7Q10 flow conditions, because health-based
AWQCs are derived for lifetime exposure conditions rather than for subchronic or acute conditions. EPA
first determines whether the discharge of any of the 104 pollutants will exceed the health based AWQC for
that pollutant in a given stream. Next, EPA totals these to obtain the number of in-stream concentrations
that exceed one or more of the health based AWQC for the 87 water bodies examined. EPA divides the
predicted in-stream concentration under HMF conditions by the health-based AWQC for each chemical
discharged from each facility under the final rule and baseline conditions. The sum of these represents in-
stream concentrations of specific pollutants that exceed AWQCs as a result of CWT discharges to 87 water
bodies from the 113 facilities examined.
(b)	Carcinogenic Risks and Noncarcinogenic Hazards
Next, EPA evaluates potential effects on human health by estimating potential carcinogenic risks and
noncarcinogenic hazards. EPA performs this assessment in accordance with available EPA guidance
including Risk Assessment Guidance for Superfund (USEPA, 1989a) and Assessing Human Health Risks
from Chemically Contaminated Fish and Shellfish: A Guidance Manual (USEPA, 1989b). As outlined in
EPA guidance, the technical approach for conducting a risk assessment involves a three-step process:
6 The report refers to these either as human health ambient water quality criteria, or health-based AWQCs.
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(1)	Toxicity Assessment. EPA uses available human health toxic effect values for the
contaminants of potential concern derived from data sources such as IRIS (USEPA, 1997a),
and HEAST (USEPA, 1996). The list of chemicals of potential concern, with their available
reference dose values (RfD) and cancer slope factors (SF) arejn Appendix B.
(2)	Exposure Assessment. The exposure assessment involves identifying exposure pathways of
concern, estimating exposure point concentrations, and estimating chronic daily intakes.
•	Identifying Exposure Pathways of Concern. EPA identifies water-related exposure
pathways and target populations. Pathways quantitatively evaluated include only the
ingestion of fish by recreational and subsistence anglers.
•	Estimating Exposure Point Concentrations. The exposure point concentration (EPC)
is the average concentration contacted over the duration of the exposure period. For
the fish ingestion pathway, EPA calculates fish tissue EPCs by multiplying the
contaminant-specific BCF by the estimated in-stream concentration under HMF
conditions using the simple dilution model.
•	Estimating Chronic Daily Intakes. EPA estimates chronic daily intakes (CDIs) using
exposure models from EPA guidance for each chemical discharged from a facility
under each regulatory option and baseline conditions. EPA expresses CDIs in terms
of milligrams of contaminant contacted per kilogram of body weight per day
(mg/kg/day). EPA calculates a CDI by combining the EPC and exposure parameter
estimates (e.g., ingestion rate, exposure frequency, exposure duration, body weight,
averaging time) using a chemical intake equation. EPA estimates CDIs for evaluating
both carcinogenic risks (based on a lifetime average daily dose) and noncarcinogenic
hazards (based on an average daily dose during the exposure period). EPA estimates
CDIs for both baseline conditions and final regulatory options.
The equation and exposure parameter values used to estimate CDIs for ingestion of fish is
presented below:
EPCxBCFxCFxlRxEFxED
CDI = 		(8)
BW*AT	y '
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where:
CDI	=	chronic daily intake (mg/kg/day);
EPC	=	exposure point concentration (in-stream
concentration under HMF conditions, in
Hg/L);
CF	=	conversion facto r= 10"6 (kg mg / g |ig)
BCF	=	bioconcentration factor (liters/kg)
IR	=	ingestion rate (for the recreational and subsistence anglers, EPA
assumes fish consumption rates of at 16.6 grams/day and 140
grams/day, respectively);
EF	=	exposure frequency (365 days/year);
ED	=	exposure duration (70 years);
BW	=	body weight (70 kg); and
AT	=	averaging time = 25,500 (days) = (70 years x 365 days/year).
(3) Risk Characterization. EPA assesses carcinogenic risks and noncarcinogenic hazards for
chemicals using available toxicity criteria for the pathways quantitatively evaluated in this study.
Carcinogenic Risk Calculations
EPA expresses the potential carcinogenic risks associated with the discharges as an increased
probability of developing cancer over a lifetime (e.g., excess individual lifetime cancer risk)(USEPA,
1989a). EPA estimates carcinogenic risks using the equation below:
Cancer riskt = CDIt x SFt
(9)
where:
Cancer risk =
CDI,
potential carcinogenic risk associated with exposure to chemical I
(unitless);
chronic daily intake for chemical I (mg/kg/day); and
2-12

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Sfz
slope factor for chemical / ((mg/kg/day)1).
If the carcinogenic risk exceeds 10"2, EPA guidance (USEPA, 1989a) recommends using the
following equation to estimate carcinogenic risk:
EPA sums chemical-specific cancer risks in accordance with EPA guidance (USEPA, 1989a) to
estimate the combined cancer risks associated with exposure to a chemical mixture. EPA
estimates the total potential carcinogenic risk for each exposure pathway, for each facility, and
for each regulatory option and baseline conditions.
Noncarcinogenic Hazard Calculations
EPA evaluates noncarcinogenic hazards by comparing the estimated dose (e.g., CDI) with a
reference dose (RfD). EPA calculates the hazard quotient, which is used to estimate the
potential for an adverse noncarcinogenic effect to occur, using the following equation:
Cancer nskt = 1 - «'-cnr'
(10)
where:
Cancer risk,
potential carcinogenic risk associated with exposure to chemical /
(unitless);
chronic daily intake for chemical I (mg/kg/day); and
slope factor for chemical / ((mg/kg/day)"1)
CDI,.
Sf,
(11)
where:
Hq,
CDI;
hazard quotient for chemical / (unitless);
chronic daily intake for chemical I (mg/kg/day); and
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reference dose for chemical I (mg/kg/day).
If the hazard quotient exceeds unity (1), an adverse effect might occur. The higher the hazard
quotient, the more likely that an adverse noncarcinogenic effect will occur as a result of
exposure to the chemical. If the estimated hazard quotient is less than unity, an adverse
noncarcinogenic effect is highly unlikely to occur.
EPA recommends summing chemical-specific hazard quotients for contaminants with similar
endpoints to evaluate the combined noncarcinogenic hazard from exposure to a chemical
mixture (USEPA, 1989a). The sum of the chemical-specific hazard quotients is called the
hazard index. Using this approach assumes that chemical-specific noncarcinogenic hazards are
additive. Limited data are available for actually estimating the potential synergistic and/or
antagonistic relationships between chemicals in a chemical mixture. This assessment sums,
only the hazard quotients that have similar target organs and toxicological mechanisms.
2.6 Estimating Human Health Risks Associated with Consumption of Lead-
Contaminated Fish
Because discharges from several CWT metals and oils facilities contain significant quantities of lead, EPA
separately analyzes potential human health risks associated with the consumption of lead-contaminated fish
by recreational and subsistence anglers. Ingestion of lead has been shown to cause adverse health effects in
both child and adult populations. Elevated blood lead levels in children may impair intellectual development
as measured by reduced IQ levels. Adult ingestion of lead may cause numerous cardiovascular problems,
including hypertension, coronary heart disease, and strokes. These ailments may cause premature death,
particularly in adults aged 40-75 years old. In addition, elevated blood lead levels in pregnant women may
increase of the risk of neonatal mortality. EPA estimates the potential for such effects by adapting
methodologies developed for assessing human health risks from lead at CERCLA/RCRA sites and for
estimating the benefits of the Clean Air Act.
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EPA estimates blood lead levels in children using EPA's "Integrated Exposure Uptake Biokinetic Model for
Lead in Children" (IEUBK-USEPA, 1994a). This PC-based model allows the user to estimate the geometric
mean blood lead concentration for a hypothetical child or population of children. Using information on
children's exposure to lead, the model estimates a plausible distribution of blood lead concentrations
centered on the geometric mean blood lead concentration.
To use the IEUBK model, EPA must first estimate the in-stream lead concentration (based on the
methodology described in section 2.1). EPA then projects the daily ingestion of lead based upon the
instream concentration, bioconcentration factor for lead, and fish consumptions rates for children.7 The
IEUBK model then estimates the geometric mean blood lead level. Although, the model can estimate blood
lead concentrations from multi-pathway exposure (air, soil, diet, water), all other pathway exposures other
than diet were "zeroed out" in order to isolate blood lead levels solely attributable to consumption of lead-
contaminated fish.
As noted above, children are primarily adversely affected through intellectual impairment as measured by
changes in IQ. EPA estimates the health and monetary benefits from decreasing risks for reduced IQ
potential in at-risk populations using the equations used in Lead Benefits Analysis performed for the
Retrospective Study of the Clean Air Act (EPA, 1997c). The specific steps used to estimate the health
effects benefits based on estimated changes in blood levels is described below:
•	EPA uses the "1997 Statistical Abstract of the US" to estimate the percentage of the total US
population between 0 and 72 months equal to 0.1031 percent. For each reach, EPA estimates
exposed child population by multiplying the total exposed population for each reach (recreation
and subsistence) by the corresponding percentage of children.
•	EPA estimates the change in children's IQ using equation (5) from Appendix G of the
Retrospective Study of the Clean Air Act.
(Total Lost IQ\ = AQMk x 1.117 x 0.25 x Pop^jl	(12)
7 Volume II- Food Ingestion Factors, Exposure Factors Handbook, EPA, August 1997 (USEPA, 1997b).
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where:
(Total Lost IQ)k =	Total Reduction of IQ points in Affected Population
AGMk	=	Change in the Geometric Mean of Affected Population's Blood
Lead Level
For adult populations, EPA estimates health effects using methodology contained in its interim approach for
assessing risks associated with adult exposure to lead in soil (Interim Guidance, USEPA 1996a).8
The approach described in the Interim Guidance estimates the effects of ingestion of lead contaminated soil
on blood lead levels of women of child-bearing age. The analysis looks at this subpopulation group in order
to derive risk-based remediation goals (RBRG) that would be protective of the developing fetus of adult
women having site exposure. Although the Interim Guidance equation is based on a scenario quite different
from that analyzed in the CWT environmental assessment (i.e.; consumption of contaminated fish by
recreational and subsistence anglers), the exposure pathways are essentially the same. The main difference
being the matrices which contain the lead contaminant (i.e., soil versus fish). The applicable equation
(Interim Guidance, pg.2. Equation 1) is as follows:
= KB,*** x PbS x BKSF x IRt xAFt x EFJAT	(13)
where:
PbBadult central = Central estimate of blood lead level concentration (|ig/dL) in adults (i.e.
women of child-bearing age) that have site exposure to soil lead at
concentration, PbS.
PbBadl]lt 0 = Typical blood lead concentration in adults in absence of exposures to the
site that is being assessed (The TRW Interim Guidance uses a background
blood lead level of 2 |ig/dL).
8 Recommendations of the Technical Workgroup for Lead for Interim Approach to Assessing Risks Associated
with Adult Exposures to Lead in Soil, USEPA, December 1996.
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PbS	= Soil lead concentration (|ig/g) (appropriate average concentration for
individual).
BKSF	= Biokinetic Slope Factor relating (quasi-steady state) increase in typical
adult blood lead concentrations to average daily uptake (|ig/dL blood lead
increase per (ig/day lead uptake).(The TRW Interim Guidance uses a
BKSF of 0.4)
Irs	= Intake rate of soil, including both outdoor soil and indoor soil-derived dust
(g/day).
Afs	= Absolute gastrointestinal absorption factor for ingested lead in soil and lead
in dust derived from soil (dimension less).
Efs	= Exposure frequency for contact with assessed soils and/or dust derived in
part from these soils (days of exposure during the averaging period); may
be taken as days per year for continuing, long-term exposure.
AT	= Averaging time; the total period during which soil contact may occur; 365
day/year for continuing exposures.
EPA has modified the above equation to estimate adult blood lead levels from consuming lead-contaminated
fish consumption by modifying the equation as follows:
+ ISe x BCF x HJQf yAFt x BKSF x EFt xCFIAT (U)
where:
PbB,ldllll LCIIIIlll = Central estimate of blood lead level concentration (|ig/dL) in adults (i.e.,
adults consuming fish contaminated with lead attributable to CWT
discharges.
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PbBadult o = Typical blood lead concentration in adults in absence of exposures to
contaminated fish. (2 |ig/dL).
Isc	= In stream Concentration of lead (|ig/L) (Affected receiving water bodies
had in stream concentrations of lead ranging from 0.5 |ig/L to
approximately 7.7 |ig/L).
BCF	= Bioconcentration Factor for lead ( 49
L/kg).
INGf	= Average daily consumption of fish (16.5g/day for recreational anglers and
140 g/day for subsistence anglers).
Afs	= Absolute gastrointestinal absorption factor for ingested lead in fish (.06
dimensionless).9
BKSF	= Biokinetic Slope Factor relating (quasi-steady state) increase in typical
adult blood lead concentrations to average daily uptake (|ig/dL blood lead
increase per |i g/day lead uptake). (EPA uses the 0.4 slope factor as
presented in the Interim Guidance).
Efs =	Exposure frequency for ingestion of contaminated fish; (days of exposure
during the averaging period); may be taken as days per year for continuing,
long-term exposure (365 days).
CF =	Conversion Factor 10~3 (kg/g).
9 For both the proposed and final CWT rules EPA used 0.06. However based upon a review ofMeasurement of
Soil-Borne Lead Bioavailability in Human Adults, and its Application to Biokinetic Modeling (Maddaloni,
1998) and consultation with the author, EPA now believes that a value of 0.03 may be more appropriate. EPA
notes that this lower value would reduce the estimated lead health effect in adults for the CWT final rule making
(monetized at $258,000 to $1,358,000 based on the value of 0.06). This reduction of lead health effects in adults
may reduce the total estimated monetized benefits of this rule by up to 17 percent.
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AT =	Averaging time; the total period during which food is consumed; 365
day/year for continuing exposures.
EPA modifies the equation presented in the Interim Guidance to account for ingestion of lead contained in
fish tissue rather than ingestion of lead contained in a soil matrix. The primary source of uncertainty in
applying the Interim Guidance equation to the affected CWT population is:
• Using soil lead bioavailability factor to estimate fish lead bioavailability.
The bioavailability of lead ingested in a soil matrix is likely to be different from the ingestion of lead
contained in fish tissue. Studies conducted by Maddaloni and others that are cited in the Interim Guidance
indicate that lead ingested with food is absorbed at a significantly lower rate than when lead is ingested
without food in a soil matrix. It has been suggested that these lower absorption rates may be due to the
presence of chelating substances in food products as well as the fact that readily absorbed food may serve
as a physical barrier to absorption of less soluble substances such as lead. To account for the these
differences, EPA has modified the absorption rate presented in the Interim Guidance (12 percent), which
used a "meal weighted average" rate. For purposes of this analysis, EPA uses an absorption factor of six
percent. In all other aspects, the equation for soil and for fish ingestion are consistent and require no
modification.
Using the Equation to Estimate Benefits to the Affected Adult Population
By using the results of the CWT Modeling efforts and adapting methodology from the Interim Guidance
EPA conservatively estimates changes in adult blood lead levels for the affected population. The procedure
involves a four- step process which estimates:
1.	In stream concentration of lead using CWT models described in Section 2.1
2.	Lead uptake in affected adult population using the established bioconcentration factor for lead
and fish consumption rates for recreational and subsistence anglers.
3.	Changes in blood lead levels using Interim Guidance methodology described above
4.	Changes in health status from final regulations using methodology cited in the CAA Study.
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3. Data Sources
EPA uses readily available Agency and other databases, models, and reports to evaluate water quality
effects. The following sections describe the various data sources that EPA used in this analysis.
3.1 Facility-Specific Data
EPA uses various sources for collecting data on CWT facilities. EPA obtains data through EPA site visits
and sampling, responses to CWT questionnaires, comments to the 1995 proposal and 1996 Notice of Data
Availability, and contacts with industry sources, regions and states. EPA uses this information to estimate
many of the facility-specific parameters required for this analysis such as annual discharge volume, current
pollutant loadings, and loadings associated with each regulatory option. EPA's data collection procedure is
described in detail in Chapter 2 of the technical development document.
For the CWT facilities which were identified through the WTI Questionnaire, EPA has discharge location
information. For the others, EPA had to make some assumptions about their discharge locations. For direct
dischargers, EPA assumes the adjacent water body is the receiving water. For indirect dischargers, EPA
conducts an analysis to identify the appropriate publicly owned treatment works (POTW) that may receive
the facility discharge. For others, EPA identifies the locations of CWT facilities or POTWs on receiving
water bodies using USGS cataloging units and EPA stream segment (reach) numbers contained in either
EPA's Permit Compliance System (PCS) or Industrial Facilities Discharge (IFD) database. If a reach
number is not available in the EPA databases, EPA uses facility latitude/longitude coordinates to locate
facility discharge points using EPA's Reach File 1 (RF1). For any indirect discharge facilities (those
discharging to a POTW, not directly to a water body), EPA obtains the name, location, and design flow data
for each affected POTW from a variety of sources including EPA's 1996 Clean Water Needs Survey
database, IFD, and PCS.
EPA obtains the raw receiving water flow data from the USGS Daily Flow File. In all cases, EPA uses the
closest flow gauge to estimate the flow rate at the point of facility discharge. EPA determines the average
and low-flow statistics (e.g., the 7Q10 low flow) using the Water Quality Analysis System residing on the
3-1

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Agency's NCC mainframe computer. EPA obtains Dissolved Concentration Potentials (DCPs) for
estuaries and bays from the Strategic Assessment Branch of NOAA's Ocean Assessments Division (see
Appendix A). EPA uses Critical dilution factors (CDFs) from the Mixing Zone Dilution Factors for New
Chemical Exposure Assessments (USEPA, 1992b). If neither DCPs nor CDFs are available for a particular
facility, EPA estimates a CDF based on best professional judgment and the dimensions, depth, and general
flushing characteristics of the bay or estuary.
3.2 Information Used to Evaluate POTW Operations
As detailed in the Chapter 7 of technical development document, EPA estimates the average percent
removal for each pollutant of concern at well-operated POTWs (those meeting secondary treatment
requirements) using data from a study of 50 well-operated POTWs and data from the Risk Reduction
Engineering Laboratory (RREL). EPA uses inhibition values obtained from the Guidance Manual for
Preventing Interference at POTWs (USEPA, 1987a) and from CERCLA Site Discharges to POTWs:
Guidance Manual (USEPA, 1990) (see Table 3-1).
Whenever a range of values are obtained, EPA uses the most conservative value reported for activated
sludge-based POTWs. For pollutants with no specific inhibition value, EPA uses a value based on
compound type (e.g., aromatics).
EPA uses sewage biosolids regulatory levels1, if available for the pollutants of concern (see Table 3-2).
EPA uses pollutant limits established for the final use or disposal of sewage biosolids applied to agricultural
and nonagricultural land (see Table 3-2). For predicting biosolids generation, EPA assumes that 1,400
pounds of biosolids are generated for each million gallons of wastewater processed (Metcalf & Eddy, 1972).
1 40 CFR Part 503, Standards for the Use or Disposal of Sewage Sludge, Final Rule (February 19, 1993).
3-2

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Table 3-1. POTW Removals and Biological Inhibition Concentrations
Pollutant
% POTW
Removal '
Biological
Inhibition
Concentration
(mg/L)1'
Pollutant
% POTW
Removal '
Biological
Inhibition
Concentration
(mg/L)1'
aluminum
17
N/A
acetophenone
95
N/A
antimony
71
N/A
alpha-terpinol
94
1000
arsenic
91
0.04
anthracene
96
5
barium
90
N/A
benzene
95
5
boron
70
10
benzo(a)anthracene
98
500
cadmium
90
0.5
benzo(a)pyrene
95
500
calcium
52
N/A
benzo(b)fluoranthene
95
500
chromium
93
0.1
benzo(k)fluoranthene
95
500
cobalt
4.8
N/A
benzoic acid
81
5
copper
88
0.1
benzyl alcohol
78
1000
iodine
39
N/A
biphenyl
96
N/A
iron
83
5
bis(2-ethylhexyl) phthalate
60
10
lead
92
0.1
bromodichloromethane
92
N/A
lithium
26
N/A
butanone
97
150
magnesium
32
N/A
butyl benzyl phthalate
94
10
manganese
41
10
carbazole
85
1
mercury
92
0.1
carbon disulfide
84
N/A
molybdenum
52
N/A
chlorobenzene
97
5
nickel
58
1
chloroform
77
150
phosphorus
69
N/A
chrysene
97
500
potassium
20
N/A
di-n-butyl phthalate
79
10
selenium
34
N/A
dibenzofuran
85
500
silicon
27
N/A
dibenzothiopene
85
500
sodium
52
N/A
diethyl ether
7
N/A
strontium
15
N/A
diethyl phthalate
60
10
sulfur
14
N/A
diphenyl ether
98
1
tin
65
N/A
diphenylamine
79
1
titanium
69
N/A
ether
52
1000
zinc
79
0.3
ethyl benzene
94
5
1,1,1,2-tetrachloroethane
23
N/A
fluoranthene
42
500
1,1,1 -trichloroethane
92
150
fluorene
70
5
1,1,2-trichloroethane
75
N/A
hexanoic acid
84
N/A
1,1-dichloroethane
81
N/A
isophorone
62
N/A
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Table 3-1. POTW Removals and Biological Inhibition Concentrations (Continued)
Pollutant
% POTW
Removal '
Biological
Inhibition
Concentration
(mg/L)b
Pollutant
% POTW
Removal'
Biological
Inhibition
Concentration
(mg/L)1'
1,1-dichloroethene
89
150
m-xylene
99
5
1,2,3-trichloropropane
5
N/A
methylene chloride
55
150
1,2,4-trichlorobenzene
92
0.1
n-decane
9
150
1,2-dibromoethane
17
N/A
n-dodecane
95
150
1,2-dichlorobenzene
89
0.1
n-eicosane
92
150
1,2-dichloroethane
89
150
n-hexadecane
71
150
1,3-dichlorobenzene
89
0.1
n-octadecane
71
150
1,4-dichlorobenzene
52
0.1
n-tetradecane
71
150
1-methyl fluorene
88
5
N.N-dimethylformamide
85
150
1-methylphenanthrene
88
5
naphthalene
96
5
2,3,4,6-tetra chlorophenol
33
N/A
o+p xylene
95
5
2,3-benzofluorene
88
500
o-cresol
53
N/A
2,3-dichloroaniline
41
N/A
p-cresol
72
N/A
2,4,5-trichlorophenol
28
N/A
p-cymene
99
5
2,4,6-trichlorophenol
65
N/A
pentachlorophenol
14
N/A
2,4-dimethylphenol
99
N/A
pentamethylbenzene
92
5
2-butanone
92
150
phenanthrene
95
5
2-chlorophenol
85
N/A
phenol
97
90
2-hexanone
88
N/A
pyrene
84
500
2-methylnaphthalene
28
5
pyridine
95
1
2-phenylnaphthalene
88
5
tetrachloroethene
83
150
2-picoline
85
N/A
tetra chloromethane
92
N/A
2-propanone
84
150
toluene
97
5
3,6-dimethyl
phenanthrene
88
5
trans-1,2-dichloroethene
79
N/A
4-chloro-3-methylphenol
63
N/A
trichloroethene
93
150
4-methyl-2-pentanone
88
150
trichlorofluoromethane
98
N/A
acenaphthylene
99
5
tripropyleneglycolmethyl
52
1,000
acenapthene
98
5
vinyl chloride
93
N/A
a. Calculation is detailed in Chapter 7 of the technical development document.
b. The lowest reported concentration at which the activated sludge process is inhibited. EPA evaluated POTW operations using
facility-specific data and information derived from the sources described in Sections 3.1 and 3.2. The individual loadings from
CWT facilities that discharge to the same POTW were summed before the POTW influent and biosolids concentrations are
calculated.
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3.3 Water Quality Criteria (WQC)
EPA obtains the ambient criteria (or toxic effect levels) for the protection of aquatic life and human health
from a variety of sources including EPA criteria documents, EPA's Assessment Tools for the
Evaluation of Risk (ASTER), and EPA's Integrated Risk Information System (IRIS, USEPA 1997a) uses
ecological toxicity estimations when there are no available published values. The following subsections
describe the hierarchies used to select the appropriate aquatic life and human health values.
Table 3-2. POTW Biosolids Pollutant Concentration Criteriad
I'ollulanl
I'ollulanl Ceiling Values 1
(ni»/k»)
I'ollulanl ( oneen 1 ration Limit Values1'
(m»/k»)
Arsenic
75
41
Cadmium
85
39
Copper
4,300
1,500
Lead
840
300
Mercury
57
17
Molybdenum0
75
35c
Nickel
420
420
Selenium
100
36
Zinc
7,500
2,800
a.	Maximum concentration permitted for land application of biosolids.
b.	Concentration limit for continuous unlimited land application of biosolids.
c.	The standard used for molybdenum is 35 mg/kg (59 Federal Register 9095, February 18, 1994). EPA notes that the PCL
value for molybdenum was deleted from Part 503 effective February 19,1994. EPA will consider establishing a limit at a later
date.
d.	Referenced from 40 CFR Part 503 3-3.
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3.3.1 Aquatic Life
EPA has established water quality criteria for many pollutants for the protection of freshwater aquatic life
(acute and chronic criteria). The acute value represents a maximum allowable 1-hour average concentration
of a pollutant at any time and can be related to acute toxic effects on aquatic life. The chronic value
represents the average allowable concentration of a toxic pollutant over a 4-day period at which a diverse
group of aquatic organisms and their uses should not be unacceptably affected, provided that these levels
are not exceeded more than once every 3 years.
EPA uses specific toxicity values2 for pollutants for which no water quality criteria have been developed.
In selecting values from the literature, EPA prefers measured concentrations from flow-through studies
under typical pH and temperature conditions. The test organism must be a North American resident species
of fish or invertebrate. The hierarchies used to select the appropriate acute and chronic values are listed
below in descending order of priority.
Acute Aquatic Life Values:
National acute freshwater quality criteria
Lowest reported acute test values (96-hour LC50 for fish and 48-hour EC50/LC50 for daphnids)
Lowest reported LC50 test value of longer duration, adjusted to estimate a 96-hour exposure period
Lowest reported LC50 test value of longer duration, up to a maximum of 2 weeks exposure
• Estimated 96-hour LC50 from the ASTER QSAR model
2 Acute and chronic effect concentrations reported in published literature or estimated using various application
techniques.
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Chronic Aquatic Life Values:
National chronic freshwater quality criteria
Lowest reported maximum allowable toxic concentration (MATC), lowest observable effect
concentration (LOEC), or no observable effect concentration (NOEC)
Lowest reported chronic growth or reproductive toxicity test concentration
Estimated chronic toxicity concentration from a measured acute chronic ratio for a less sensitive
species, quantitative structure activity relationship (QSAR) model, or default acute: chronic ratio of
10:1
3.3.2 Human Health
EPA has established water quality criteria for the protection of human health based on a pollutant's toxic
effects, including carcinogenic potential. EPA has developed these human health criteria values for two
exposure routes: (1) ingesting the pollutant via contaminated aquatic organisms only, and (2) ingesting the
pollutant via both contaminated water and aquatic organisms. These equations are as follows:
For Toxicity Protection (ingestion of organisms only)
jjjj =	CF
~ ~ IRjX BCF
(12)
Where:
IR,
HH,
BCF
RfD
CF
00
human health value (jag/L);
reference dose (mg/day);
fish ingestion rate (0.0065 kg/day);
bioconcentration factor (L/kg); and
conversion factor (1,000 |ig/mg).
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For Carcinogenicity Protection (ingestion of organisms only)
Where:
HHm =
BWx RL x CF

SF x IRjX BCF
HH00
human health value (|ig/L):
BW
body weight (70 kg);
RL
risk level (10 6);
SF
cancer slope factor (mg/kg/day)"1;
IRf
fish ingestion rate (0.0065 kg/day);
BCF
bioconcentration factor (L/kg); and
CF
conversion factor (1,000 |ig/mg).
For Toxicity Protection (ingestion of water and organisms)
XX = Rf2>X CF
w>~ IR^ + (IRj x BCF)
where:
HHW0	=	human health value (|ig/L):
RfD	=	reference dose (mg/day);
IRW	=	water ingestion rate (2 liters/day);
IRf	=	fish ingestion rate (0.0065 kg/day);
BCF	=	bioconcentration factor (L/kg); and
CF	=	conversion factor (1,000 (ig/mg).
3-8

-------
For Carcinogenic Protection (ingestion of water and organisms)
HH„
BWx RLxCF
wo SF x [ IR^ + (IlijX BCF) ]
(15)
where:
SF
Rw
BCF
IR,
RL
HH,
BW
CF
"WO
human health value (|ig/L):
body weight (70 kg);
risk level (10 6);
cancer slope factor (mg/kg/day)"1;
water ingestion rate (2 L/day);
fish ingestion rate (0.0065 kg/day);
bioconcentration factor (L/kg); and
conversion factor (1,000 |ig/mg).
EPA derives the values for ingesting specific pollutants by drinking contaminated water and/or eating
contaminated aquatic organisms by assuming an average daily ingestion of 2 liters of water, an average daily
fish consumption rate (16.6 and 140 grams per day of fish products for recreational and subsistence anglers,
respectively), and an average adult body weight of 70 kilograms (USEPA, 1989 a).
If a pollutant of concern has a cancer slope factor, then EPA uses values protective of carcinogenicity to
assess the pollutant's potential effects on human health. EPA develops protective concentration levels for
carcinogens in terms of non-threshold lifetime risk level. This analysis relies on criteria at a risk level of 10"
6. This risk level indicates a probability of one additional case of cancer for every 1,000,000 persons
exposed. Toxic effects criteria for non-carcinogens include systemic effects (e.g., reproductive,
immunological, neurological, circulatory, or respiratory toxicity), organ-specific toxicity, developmental
toxicity, mutagenesis, and lethality.
The hierarchy used to select the most appropriate human health criteria values is presented below in
descending order of priority:
3-9

-------
Calculated human health criteria values using EPA's IRIS RfDs or SFs used in conjunction with
adjusted 3 percent lipid BCF values derived from Ambient Water Quality Criteria Documents
(USEPA, 1987b); 3 percent is the mean lipid content of fish tissue reported in the study from which
the average daily fish consumption rates are derived.
Calculated human health criteria values using current IRIS RfDs or SFs and representative BCF
values for common North American species of fish or invertebrates or estimated BCF values.
Calculated human health criteria values using RfDs or SFs from EPA's Health Effects Assessment
Summary Tables (HEAST) used in conjunction with adjusted 3 percent lipid BCF values derived
from Ambient Water Quality Criteria Documents (USEPA, 1987b).
Calculated human health criteria values using current RfDs or SFs from HEAST and representative
BCF values for common North American species of fish or invertebrates or estimated BCF values.
• Criteria from the Ambient Water Quality Criteria Documents (USEPA, 1987b).
Calculated human health values using RfDs or SFs from data sources other than IRIS or HEAST.
This hierarchy is based on Section 2.4.6 of the Technical Support Document for Water Quality-based
Toxics Control (USEPA, 1991a). This document recommends using the most current risk information
from IRIS when estimating human health risks. In cases where chemicals have both RfDs and cancer SFs
from the same level of the hierarchy, EPA calculates human health values using the formulas for
carcinogenicity, which always results in the more stringent value of the two given the risk levels employed.
3-10

-------
4. Results
4.1 Projected Water Quality Effects
This section presents the results of the analysis of the environmental effects of the CWT discharges at both
baseline and following the adoption of final limits and standards. The first subsection, Environmental
Effects of 113 CWT facilities at Baseline and with Final Limits and standards, presents the non-scaled
environmental effects of 113 of the 205 CWT facilities that EPA has identified. Specifically, EPA analyzed
12 direct and 101 indirect wastewater dischargers discharging up to 104 pollutants (see Table 4-1). The 92
CWT facilities not evaluated either are zero dischargers (42) or have insufficient data to conduct the water
quality analysis.
The following subsections present analysis results for each CWT subcategory (metals, oils, and organics).
Each subsection begins with a general overview and then presents results for both the direct and indirect
wastewater discharges analyzed. Many facilities have operations in multiple subcategories, and therefore the
sum of the number of facilities presented in the metals, oils, and organics subcategories is greater than the
total (113). To prevent double counting of loadings at multiple subcategory facilities, EPA only includes
wastes from metals, oils, and organic waste treatment trains in the metals, oils, and organics subcategories,
respectively.
As previously explained, EPA estimates the potential benefits of controlling discharges from CWT facilities
by using modeling techniques to quantify impacts on water quality in receiving water bodies (i.e., potential
impacts on human health and aquatic life), and POTW operations (i.e., biological inhibition and biosolid
contamination). Specifically, EPA compares under current and final requirements estimated pollutant
concentrations to water quality criteria or toxic effect levels for both aquatic life and human health. EPA
analyzes direct and indirect dischargers separately. The study did not evaluate the effects of the final
technologies on discharging conventional pollutants (e.g., BOD, COD, TSS). For example, although under
baseline conditions, CWT facilities discharge 21.5 million pounds per year of conventional pollutants, the
benefits analysis focuses entirely on reductions in metals and organic pollutants. Finally, EPA assesses the
effects of indirect discharges on POTW operations and biosolids contamination.
4-1

-------
Table 4-1. The 104 Pollutants Evaluated for the CWT Industry3
Pollutants
POLLUTANT
M
E
T
A
L
S
0
1
L
s
0
R
G
A
N
1
C
s
POLLUTANT
M
E
T
A
L
S
0
1
L
s
0
R
G
A
N
1
C
s
POLLLTAM
M
E
T
A
L
S
0
1
L
s
CJ
R
G
A
N
I
C
s
4-Chloro-3-Methylphenol

X

Butyl Benzyl
Phthalate

X

Dichloroethane, 1,2-

X
X
4-Methyl-2-Pentanone

X
X
Cadmium
X
X

Dichloroethene, 1,1-
X
X
X
Acenaphthene

X

Carbazole

X

Dichloroethene, trans 1,
2-


X
Acetophenone


X
Carbon disulfide
X
X

Diethyl ether


X
Alpha-terpineol

X

Chlorobenzene

X

Diethyl phthalate

X

Aluminum
X
X
X
Chloroform

X
X
Dimethylformamide, N, N-
X
X
X
Anthracene

X

Chromium
X
X
X
Dimethyl phenanthrene, 3,6-

X

Antimony
X
X
X
Chrysene

X

Dimethyl phenol, 2,4-

X

Arsenic
X
X

Cobalt
X
X
X
Diphenyl ether

X

Barium

X
X
Copper
X
X
X
Ethylbenzene

X

Benzene

X
X
Cresol, o-

X
X
Fluoranthene

X

Benzo(a)anthracene

X

Cresol, p-

X
X
Fluorene

X

Benzofluorene, 2,3-

X

Di-n-butyl
phthalate

X

Hexanoic acid

X
X
Benzoic acid
X
X
X
Dibenzofuran

X

Iron
X
X
X
Benzyl alcohol

X

Dibenzothiophene

X

Lead
X
X

Biphenyl

X

Dibromochloromethane
X


Lithium
X

X
Bis(2-ethylhexyl)
phthalate

X

Dibromoethane,
1,2-


X
Manganese
X
X
X
Boron
X
X
X
Dichloroaniline


X
Mercury
X
X

Butanone, 2-
X

X
Dichlorobenzene, 1,4-

X

Methylene Chloride
X

X
4-2

-------
' "able 4-1. The 104 Pollutants Evaluated for the CWT Industry" (Continued)
Pollutants
POLLUTANT
M
E
T
A
L
S
0
1
L
S
0
R
G
A
N
1
C
s
POLLUTANT
M
E
T
A
L
S
0
1
L
s
0
R
G
A
N
1
C
s
POLLUTANT
M
E
T
A
L
S
0
1
L
S
0
R
G
A
N
1
C
s
Methylfluorene, 1-

X

Phenanthrene

X

Tin
X
X
X
Methylnaphthalene, 2-

X

Phenol

X
X
Titanium
X
X

Methylphenanthrene,
1-

X

Phenylnaphthalene,
2-

X

Toluene
X
X
X
Molybdenum
X
X
X
Phosphorus
X
X
X
T richlorobenzene,
1,2,4-

X

N-Decane

X

Propanone, 2-
X
X
X
T richloroethane, 1,1,1-
X
X
X
N-Docosane

X

Pyrene

X

T richloroethane, 1,1,2-


X
N-Dodecane

X

Pyridine
X
X
X
Trichloroethene

X
X
N-Eicosane

X

Selenium
X
X

Trichlorophenol, 2,4,5-


X
N-Hexadecane

X

Silicon
X
X
X
Trichloropropane,
1,2,3-


X
N-Octadecane

X

Silver
X
X

Tripropyleneglycol
methylether
X
X

N-Tetradecane

X

Strontium
X
X
X
Vanadium
X


Naphthalene

X

Styrene

X

Vinyl chloride


X
Nickel
X
X
X
Sulfur
X
X
X
Xylene, m-

X
X
P-Cymene

X

T etrachloroethene

X
X
Zinc
X
X
X
Pentachlorophenol


X
Tetrachloroethane,
U,l,2-


X
Zirconium
X


Pentamethylbenzene

X

T etrachloromethane


X




a.	EPA details the pollutants evaluated in chapter six of the technical development document. This analysis only includes a portion
of the pollutants identified in Chapter 6.
b.	Pollutant counts for each CWT industry subcategory are as follows: 38 metals; 86 oils; and 50 organics.
c.	The POCs considered in this analysis are presented, by subcategory, in Appendix C.
4-3

-------
4.1.1 Combined Environmental Effects of 113 CWT Facilities at Baseline and with Final Limits
EPA estimates that under baseline, 205 CWT facilities discharge approximately 8.6 million lbs/year of
metals and organic pollutants. Under the final rule, pollutant loadings would be reduced by 50 percent or to
4.3 million lbs/year. The analysis comparing non-scaled (113 of the 205 facilities) modeled instream
pollutant levels to Ambient Water Quality Criteria (AWQC) estimates that current discharge loadings will
result in 252 concentrations in excess of criteria at 43 receiving water locations. As seen in Table 4-2, the
final rule would reduce this number of concentrations in excess of AWQC to 156 at 38 receiving water
locations. EPA estimates that CWT discharges to surface waters are responsible for approximately 0.18
cancer cases per year, but this would be reduced to 0.14 cases per year under the final rule. In addition, an
estimated 101,000 persons would have reduced lead exposure and related health effects. EPA also
estimates the final rule would reduce lead uptake enough to prevent the IQ loss of 60 points in angler
children (i.e., children living in a recreational angler's household), and that the IQs of 0.2 fewer children
would drop below 70 (see Table 4-3). EPA estimates that six of the 69 POTWs analyzed
"able 4-2. Summary of Non-Scalec
Environmental Effects of 113 CWT Facilities3

Cunvnl
I'inal
SummaiA
Loadings (million lbs/yr)b,c
8.6
4.3
50% reduction
AWQC Excedences
252 at
43
streams
156 at
38 streams
5 streams become "CWT industry
contaminant free"
Additional Cancer Cases/yrd
0.18
0.14
0.04 cases reduced each year
Population potentially at risk to lead
exposure d
101,000
101,000
Annual benefits are:
•	Reduction of 1.5 cases of hypertension
•	Protection of 60 IQ points
•	Prevention of lowering of 0.2 children's IQs
below 70
Population exposed to other non-
cancer effects0
1,880
None
Health effects to exposed population are reduced
POTWs experiencing inhibition
6 of 69
4 of 69
Potential inhibition eliminated at 2 POTWs
Biosolid Quality


3,900 metric tons improved
a.	Modeled results represent 12 direct and 101 indirect waste water dischargers.
b.	104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in the analysis.
c.	Loadings are scaled to represent all 205 facilities. Loadings for indirects are adjusted to account for POTW removals.
d.	Through consumption of contaminated fish tissue.
4-4

-------
Table 4-3. Annual Reductions in Lead Related Health Effects From Reducing Lead Exposure of
101.000 People Potentially Affected by CWT Dischargers at 10 Reaches3
Lead Health l-.ITccl
Men
I'emale
C hi Id
\eo-\alal Total
Hypertension (Cases)
1.5
NA
NA
NA
1.5
Coronary Heart Disease (Cases)
0.09
<0.01
NA
NA
0.1
Cerebral Accidents (cases)
<0.01
<0.01
NA
NA
<0.01
Brain Infarction (cases)
<0.01
<0.01
NA
NA
<0.01
Premature Mortality (cases)
0.09
<0.01
NA
0.01
0.1
IQ point reduction (IQ points)
NAb
NA
60
NA
60
Children with IQ < 70 (cases)
NA
NA
0.2
NA
0.2
a.	Oil and metal dischargers are included. Organic dischargers do not have lead in waste stream.
b.	Not Applicable (NA).
experience inhibition problems due to CWT wastes. Under the final rule inhibition problems would be
eliminated at two POTWs. The final rule would also improve the quality of 3,900 metric tons of biosolids
and allow two facilities to switch to less expensive land disposal practices.
4.1.2 Metals Subcategory
EPA estimates that 69 metal CWT facilities discharge at baseline approximately 2.56 million lbs/year of
metals and organics to surface waters (see Table 4-4). Under the final rule, this pollutant loading would be
reduced by 85 percent or to approximately 0.39 million lbs/year.
EPA analyzed the environmental effects of 49 of the 69 metal CWT facilities (17 facilities are zero
dischargers, and three facilities had missing data). EPA estimates that the final rule would reduce lead
health-related effects and prevent the IQ loss of approximately 49 points in angler children (see Table 4-5).
4-5

-------
"able 4-4. Metals Subcategor
y - Summary of Pollutant Loadings

Direct Dischargers
Indirect Dischargers '
Total
Current (million lbs/yr)
2.18
0.38
2.56
Final (Option 4)
BPT/BAT/PSES
0.30
0.09
0.39
No. of Pollutants Evaluated
38
38
38
No. of Facilities Evaluated"1
9
40
49
a. Consists of 38 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only
conventional pollutants are not included in this analysis.
b.	Loadings are scaled to represent all 69 metal facilities.
c.	For Indirect dischargers, loading estimates have been adjusted to account for POTW removals.
d.	The total universe consists of 69 facilities (9 directs, 40 indirects, 17 zero dischargers, and 3 with missing information).
"able 4-5. Metals Subcategory - Estimated Annual Reduction o
' Lead Related Hea
th Effects
Lead Health l-.ITecl
Direct
Dischargers (4)
Indirect
Dischargers (2 )
Total
Hypertension (Cases)
0.13
0.72
0.85
Coronary Heart Disease (Cases)
<0.1
<0.1
<0.1
Cerebral Accidents (cases)
<0.1
<0.1
<0.1
Brain Infarction
<0.1
<0.1
<0.1
Premature Mortality (cases)
<0.1
<0.1
<0.1
IQ Point Reduction in Children (IQ points)
11
38
49
Children with IQ < 70 (cases)
0.03
0.12
0.15
(a) Metals Subcategory - Direct Dischargers
EPA estimates that 12 direct discharging CWT facilities discharge at baseline approximately 2.18 million
lbs/year of metals and organics (see Table 4-6). The final BAT/BPT (Option 4) levels would reduce this
pollutant loading by 86 percent, or to 0.30 million lbs/year.
EPA analyzed the modeled environmental effects of nine of the 12 direct discharging CWT facilities. The
analysis comparing modeled instream pollutant levels to AWQC estimates that 42 excedences in eight
streams would be reduced to 18 in five streams (see Table 4-6). Most of the concentrations in excess of
AWQC are for chronic aquatic life criteria (see Table 4-7 and Table 4-8).
4-6

-------
' "able 4-6. Metals Subcategory - Environmental Effects of Nine Direct Dischargers3

Cunviil
I'inal
Summar\
Loadings (million lbs/yr)11
2.18
0.30
86% Reduction
AWQC Excedences
42 at 8 streams
18 at 5 streams
All excedences eliminated at 3 streams
Additional Cancer Cases/y c
<0.1
<0.1
Reduction of <0.1
Population of 44,000 individuals
exposed to lead health effects0


Annual benefits are:
•	Reduction of 0.13 cases of hypertension
•	Protection of 11 IQ points
•	Prevention of lowering of 0.03 children's
IQs below 70
Population exposed to other non-
cancer effects0
1,040
None
Reduction of exposed population by 1,040
a.	Modeled results represent nine of twelve direct waste water dischargers. Loadings are scaled to represent all 12 facilities.
b.	38 of 104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
c.	Through consumption of contaminated fish tissue.
' "able 4-7. Metals Subcategory - Projected Criteria Excedences for Nine Direct Dischargers

Auik' A(|ii;ilk

lluiiiiiii 1 K;il 111
lllllll;ill Ik'iillh
loUll'

l.il'i-
(li ionic A(|ii;ilk
(Onanisms
(Wsik-r iiiul



l.ik-
Onl\)
()r^;inisins)

Current
Streams (No.)b
5
8
2
4
8
Pollutants(No)c
5
14
1
2
15

Final Option
Streams (No.)
3
5
1
2
5
Pollutants (No.)
2
7
1
1
8
a.	Pollutants may exceed criteria on a number of streams, therefore, total does not equal sum of pollutants exceeding criteria.
b.	Number of receiving streams is nine.
c.	Number of the 38 different pollutants analyzed that exceed ambient water quality and human heath-based criteria.
EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. EPA also
projects that 1,040 persons are exposed to pollutants that could result in non-cancer effects under current
treatment levels. However, EPA estimates that six facilities discharge lead at levels which potentially could
cause adverse health effects in recreational and subsistence angler populations totaling approximately 44,000
individuals. The final discharge levels would prevent the IQ loss of 11 points in angler children.
4-7

-------
able 4-8. Metals Subcategory - Po
liitants Projected to Exceed Criteria for Nine Direct Dischargers

Auik' A(|ii;ilii l.il'i'1 ''
(lironk A(|ii;ilk l.il'i'1 ''
Human Ik-alilr'''
1 lunian 1 k-alllv' ''
Pollulanls




(wak-r and
organisms)
(organisms mil\)









C'll ITl-lll
I'inal
Cuiivnl
Final
(u iivnl
I'inal Option
(uiivnl
I'inal


Option

Option



Option
'Yrsenic




4(0-0.84 y
2(0-0 48)
2(0-0 84 V
^v-
1(0.48)
Aluminum
—
—
1(93.7)
—
—
—
—
—
3oron
—
—
2(4.5-81)
1(28.5)
—
—
—
—
Cadmium
2(4-23)
—
2(4-23)
—
1(23)
—
—
—
Chromium
—
—
2(23-65)
—
—
—
—
—
Copper
1(38)
—
1(38)
—
—
—
—
—
^ead
—
—
2(1-2.4)
1(0.58)
—
—
—
—
VIolybdenum
—
—
1(10.4)
1(5.9)
—
—
—
—
Nickel
—
—
1(8.1)
—
—
—
—
—
3hosphorus
5(4.2-3911)
3(0.6-84)
8(0.1-3911)
5(0.6-84)
—
—
—
—
selenium
1(2.0)
1(1.8)
1(2.0)
1(1.8)
—
—
—
—
silver
—
—
1(0.3)
1(0.09)
—
—
—
—
Tin
—
—
1(24.8)
—
—
—
—
—
One
1(27.8)
—
1(27.8)
—
—
—
—
—
Zirconium


1(4.5)
1(4.4)




Total
5
2
14
7
2
1
1
1
Pollutants








a.	Number(s) in parentheses represent instream concentration (ng/L).
b.	Numbers outside of parentheses represent the number of occurrence(s) of a pollutant; however different pollutants may be
discharged from the same water body so the total number of occurrences is not the sum of the water bodies where excedences
occur.
c.	Arsenic at 0.84(ig/L is estimated to exceed human health criteria for both organisms only (HHO0 (As) = 0.16 ng/L) and water and
organisms (HHW0(As) = 0.02 ng/L)
(b) Metals Subcategory - Indirect Dischargers
EPA estimates that 42 indirect discharging CWT facilities currently discharge 0.38 million lbs/year of metals
and organics (see Table 4-9). The final PSES (Option 4) treatment level would reduce pollutant loadings by
77 percent, or to 0.09 million lbs/year.
EPA modeled the environmental effects of 40 of the 42 indirect discharging CWT facilities. The analysis
comparing modeled instream pollutant levels to AWQC estimates that 82 excedences in 19 streams would
be reduced to 50 excedences in 16 streams (see Table 4-9). Most of the concentrations in excess of AWQC
are for chronic aquatic life criteria (see Table 4-10 and Table 4-11).
4-8

-------
"able 4-9. Metals Subcategory - Environmental
Effects of 40 Indirect Dischargers3 b

Cunviil
1'inal
Summai'\
Loadings (million lbs/yr)1
0.38
0.09
77% Reduction
AWQC Excedences
82 at 19 streams
50 at 16 streams
3 streams became "contaminant-free"
Additional Cancer Cases/yrd
<0.1
<0.1
Reduction of <0.1
Population of 21,000 individuals
exposed to lead health effects4


Annual benefits are:
•	Reduction of 0.72 cases of
hypertension
•	Protection of 38 IQ points
•	Prevention of lowering of 0.12
children's IQs below 70
Population exposed to other non-
cancer effects4
840
None
Affected population reduced by 840
POTWs experiencing inhibition6
2 POTWs with three
pollutants
1 POTW with one
pollutant
Potential inhibition reduced at one
POTW
Biosolid Quality
1 POTW
0 POTWs
1 POTW able to switch from incineration
to surface disposal
a.	Modeled results represent 40 of 42 indirect waste water dischargers. Loadings are scaled to represent all 42 indirects
b.	For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
c.	38 of 104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; conventional
pollutants such as Chemical Oxygen Demand (COD), BOD5 and Total Suspended Solids (TSS); Total Phenols, hexanoic acid
and Hexane Extractable Material are not representative of the loadings.
d.	Through consumption of contaminated fish tissue.
e.	Total number of POTWs receiving discharges from Metal subcategory CWTs is 41.
' "able 4-10. Metals Subcategory - Projected Criteria Excedences for 40 Indirect Dischargers

AuiU'
(limnk
llllllKlll 1 K'llll ll
1 luni;iii 1 k-;illh
l ol:il'

A(|ii;ilk
A(|ii;ilk
(W;ikT ;ill(l
(Onanisms Onl\)


1 .i IV.-
l.ili-
Onanisms)


Current
Streams (No.)b
12
19
8
1
19
Pollutants (No.)c
9
14
4
1
19

Final Option
Streams (No.)
10
16
7
1
16
Pollutants (No.)
3
9
1
1
10
a.	Pollutants may exceed criteria on a number of streams, therefore, the total does not equal the sum of pollutants exceeding
criteria.
b.	Number of receiving streams is 33 (19 rivers and 14 estuaries).
c.	Number of different pollutants that exceed ambient water quality and human heath based criteria.
EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. However, EPA
estimates that two facilities discharge lead at levels which potentially could cause adverse health effects in
4-9

-------
recreational and subsistence angler populations totaling approximately 21,000 individuals (see Table 4-9).
The final discharge levels would prevent the IQ loss of 38 points in angler children. EPA also estimates a
decreased risk of non-cancer effects to an additional 840 anglers.
able 4-11. Metals Subcategory - Pollutants Projected to Exceed Criteria for 40 Indirect Dischargers

AuiU' A(|ii;ilk
('liniiik' A(|ii;ilk
Human Ik-alllr''
Human Ik-alllr'1,

l.ili."
. 1)
l.ili.
il.l)
(WIlkT
ind ur»s.)
(or»s. onl\)

ClIITl'lll
Final
Ciirmil
Final
(iirmil
Final
(unviil
filial
Piilliil.inls

Oplion

Option

Option

Opt ion
Aluminum
—
—
1(47.7)
—
—
—
—
—
Antimony
—
—
—
—
1(26.9)
—
—
—
Arsenic c
—
—
—
—
8(0-1)
7(0-1)
1(1.2)
1(0.95)
Boron
—
—
10(7.3-522)
2(4.4-125)
—
—
—
—
Cadmium
2(0.5-0.5)
—
2(0.5-0.5)
—
—
—
—
—
Chromium
1(2.6)
—
2(2.6-15.3)
—
—
—
—
—
Vw/UUdll
Copper
2(0.1-5.5)
2(0.1-2.3)
1(5.54)
1(2.3)
—
—
—
—
dibromo-
—
—
—
—
1(0.4)
—
—
—
chloromethane








dichloro-
—
—
—
—
1(0.8)
—
—
—
ethene, 1,1-








Lead
1(8.4)
—
1(8.4)
1(0.8)
—
—
—
—
Lithium
—
—
1(516.7)
—
—
—
—
—
Molybdenum
—
—
2(1.7-92.3)
2(1-27.6)
—
—
—
—
Nickel
1(190.4)
—
1(190.4)
1(10.6)
—
—
—
—
Phosphorus
12(0.8-297)
10(2-148)
19(0.03-297)
16(0.1-148)
—
—
—
—
Selenium
2(0.3-3.6)
2(0.2-3.6)
2(0.3-3.6)
2(0.2-3.6)
—
—
—
—
Silver
1(0.51)
—
1(0.51)
1(0.06)
—
—
—
—
Tin
—
—
1(26.9)
—
—
—
—
—
Zinc
2(0.3-9.9)
—
—
—
—
—
—
—
Zirconium
—
—
2(0.4-16.3)
2(0.4-11.3)
—
—
—
—
Total
9
3
14
9
4
1
1
1
Pollutants








a.	Number(s) in parentheses represent instream concentrations (ng/L).
b.	Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be
discharged from the same water body. Therefore the total number of occurrences are not the sum of the waterbodies where
excedences occur.
EPA estimates that two of the 39 POTWs (39 of 41 POTWs analyzed) receiving CWT waste waters
experience inhibition problems due to three pollutants in CWT wastes (see Table 4-12). The final
rule would decrease the number of adversely affected facilities to one. The final rule would also allow one
POTW to switch its biosolids disposal from incineration to surface disposal.
4-10

-------
Table 4-12. Metals Subcategory - Projected POTW Inhibition Problems from 40 Indirect
dischargers

Biological Inhibition
Current
POTWs (No.) 3
2
Pollutants (No.)b
3C
Total Problems
2

Final Option
POTWs (No.)
1
Pollutants (No.)
ld
Total Problems
1
a.	42 CWT facilities discharge to 41 POTWs
b.	23 of 104 pollutants are analyzed
c.	chromium, boron, nickel
d.	boron
4.13. Oils Subcategory
EPA estimates that 125 oil CWT facilities discharge at baseline approximately 1.83 million lbs/year of metals
and organics to surface waters (see Table 4-13). Under the final rule, pollutant loadings would be reduced
by 42 percent or to 1.05 million lbs/year.
' "able 4-13. Oils Subcategory - Summary of Pollutant Loadings
L
oadings (million po
Direct
Dischargers
uiuls/year) '
Indirect
Dischargers1'
Total
Current
0.03
1.80
1.83
Final (BPT/BAT- Option 9)
(PSES - Option 8)
0.02
1.03
1.05
No. of Pollutants Evaluated
86
86
86
No. of Facilities Evaluated0
3
72
75
a.	Consists of 86 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only
conventional pollutants are not included in this analysis.
b.	Loadings are scaled to represent all 125 oil facilities.
c.	For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
d.	The total universe consists of 125 facilities (3 directs, 72 indirects, 10 with missing information, and 40 zero dischargers).
4-11

-------
EPA analyzed the environmental effects of 75 of the 125 oil CWT facilities (3 directs, 72 indirects, 10 with
missing information, and 40 zero dischargers). EPA estimates that the final limits would reduce additional
annual cancer cases from approximately 0.07 under baseline conditions to 0.06. EPA also estimates the
final rule would reduce lead health related effects and prevent the IQ loss of approximately 11 points in
angler children, and the IQs of 4 children from dropping below 70 (see Table 4-14).
' "able 4-14. Oils Subcategory - Estimated Annual Reduction of Lead Related Health Effects
Lead Health l-.ITecl
Total
Direct (2)
Indirect Dischargers (3)
Hypertension (Cases)
0.62
0.20
0.42
Coronary Heart Disease (Cases)
<0.1
<0.1
<0.1
Cerebral Accidents (cases)
<0.1
<0.1
<0.1
Brain Infarction
<0.1
<0.1
<0.1
Premature Mortality (cases)
<0.1
<0.1
<0.1
IQ Point Reduction in Children
(IQ points)
11
11
0
Children with IQ < 70 (cases)
0.03
0.03
0
(a) Oils Subcategory - Direct Dischargers
EPA estimates that under baseline conditions three direct discharging CWT oils subcategory facilities
discharge approximately 30,900 lbs/year of metals and organics (see Table 4-15). Under the final
BAT/BPT (Option 9) levels, pollutant loadings would be reduced by 31 percent, or to 21,400 lbs/year.
EPA modeled the environmental effects of the three direct discharging oil CWT facilities. The analysis
comparing modeled instream pollutant levels to AWQC estimates that 36 concentrations in excess of AWQC
in two streams would be reduced to 28 excedences in two streams (see Tables 4-15, 4-16, and 4-17). None
of the facilities discharge at levels that could cause adverse health effects from noncarcinogens.
4-12

-------
' "able 4-15. Oils Subcategory - Environmental Effects of 3 Direct Discharging CWT Facilities

( unvnl
I'llKll
Summaiy
Loadings (lbs/yr);l
30,900
21400
31% Reduction
AWQC Excedences
36 at 2
28 at 2
22% Reduction
Additional Cancer Cases/yrc
<0.1
<0.1
Reduction of <0.1
Population exposed to non-cancer effects'
None
None

a.	Modeled results represent three direct waste water dischargers.
b.	86 of 104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants only.
c.	Through consumption of contaminated fish tissue.
"able 4-16. Oils Su
jcategory - Projected Criteria
ixcedences for 3 Direct Dischargers

.Willi-
A(|ii;ilii l.il'i-
Chroiiii' A(|ii;ilk
l.ik-
1 luni;iii 1 kill 111
(W:ikT ;iihI ()r»s.)
lllllll;ill lk-;illh
(Or»s. Onl\ )
Tiihil 1
Current
Streams (No.)
2
2
2
2
2
Pollutants (No.)b
7
15
3
3
16

Final Options (9)
Streams (No.)
2
2
2
2
2
Pollutants (No.)
5
13
2
2
14
a.	Pollutants may exceed criteria on a number of streams, therefore the total does not equal the sum of pollutants exceeding criteria.
b.	86 pollutants of 104 (see Table 4-1).
EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per year. EPA also
estimates that the final limits would reduce lead health related effects and prevent the IQ loss of
approximately 11 points in angler children.
4-13

-------
' "able 4-17. Oils Subcategory - Pollutants Projected to Exceed Criteria for 3 Direct Dischargers"b

\uilr 1 ill'
( liioiiii
V(|ii:ili>' 1 ill-
1 Milium 1 It'iillh
(\\ iili-i" iintl (IrjM
1 liiiiiiin 1 It'iillh (< < >nl\ i

( lll'ivill
Muni
( lll'IVIll
liiiiil
( lll ll lll
liiiiil

liiiiil


()|ili|)Mm|I
( lll'IVIll
(>|>l i< >i i
Polliihinls








anthracene
1(0.1)
1(0.1)
1(0.1)
1(0.1)
—
—
	
—
benzo (a) anthracene
—
—
1(0.1)
1(0.1)
2(0.02-0.1)
2(0.02-0.1)
2(0.02-0.1)
2(0.02-0.1)
arsenic
—
—
—
—
2(0.07-0.3)
2(0.07-0.3)
1(0.3)
1(0.3)
aluminum
1(186)
1(62)
2(41-186)
1(62)
—
—
—
—
boron
—
—
2(101-461)
2(80-363)
—
—
—
—
cadmium
—
—
1(0.1)
—
—
—
—
—
carbon disulfide
—
—
1(0.1)
1(0.1)
—
—
—
—
cobalt
—
—
1(7.8)
1(7.8)
—
—
—
—
copper
1(3.2)
1(0.5)
1(3.2)
1(0.5)
—
—
—
—
iron
—
—
1(212)
1(103)
—
—
—
—
lead
1(3.7)
—
2(0.8-3.7)
1(0.4)
—
—
—
—
mercury
1(0.1)
—
1(0.1)
—
1(0.1)
—
1(0.1)
—
molybdenum
—
—
1(17.4)
1(6.8)
—
—
—
—
nickel
—
—
1(4.4)
1(4.4)
—
—
—
—
phosphorus
2(19-86)
2(19-86)
2(19-86)
2(19-86)
—
—
—
—
zinc
1(54)
1(9)
1(54)
1(9)
—
—
—
—
Total
7
5
15
13
3
2
3
2
Pollutants








a.	Number(s) in parentheses represent instream concentrations (ng/L).
b.	Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be discharged from the same water body. Therefore the
total number of occurrences are not the sum of the waterbodies where exceedences occur.
4-14

-------
(b) Oils Subcategory - Indirect Dischargers
EPA estimates that 86 indirect discharging CWT facilities currently discharge 1.80 million lbs/year of metals
and organics (see Table 4-18). Under the final PSES (Option 8) treatment level, pollutant loadings would
be reduced by 43 percent or to 1.03 million lbs/year.
EPA modeled the environmental effects of 72 of the 86 indirect discharging oil CWT facilities. The analysis
comparing modeled instream pollutant levels to AWQC estimates that 66 concentrations in excess of AWQC
in 19 streams would be reduced to 50 excedences in 19 streams (see Tables 4-18, 4-19, and 4-20).
' "able 4-18. Oils Subcategory - Environmental Effects of 72 Indirect Dischargers3

Cunvnl
Final
Summaiy
Loadings (million lbs/yr)b
1.80
1.03
43% Reduction
AWQC Excedences
66 at 19 streams
50 at 19
streams
24% Reduction
Additional Cancer Cases/yrc
<0.1
<0.1
Reduction of <0.1
Population of 42,000 individuals
exposed to lead health effects c

Health effects
are reduced
Annual benefits are:
•	Reduction of 0.42 cases of hypertension
•	Protection of 0 IQ points
•	Prevention of lowering of 0 children's
IQs below 70
Population of individuals exposed
to other non-cancer effects0
None
None
None
POTWs experiencing inhibitiond
5 POTWs with one
pollutant.
Potential inhibition
reduced by one POTW
3 POTWs with
one pollutant
Potential inhibition reduced by 2 POTWs
Biosolid Quality
1 POTW
0 POTWs
1 POTW able to switch from incineration to
surface disposal
a.	Modeled non-scaled results represent 72 indirect waste water dischargers.
b.	86 of 104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; conventional
pollutants such as Chemical Oxygen. Demand (COD), BOD5 and Total Suspended Solids (TSS); Total Phenols, hexanoic acid and
Hexane Extractable Material are not representative of the loadings. Loadings are scaled to represent all 86 facilities. Loadings
are adjusted for POTW removals.
c.	Through consumption of contaminated fish tissue.
d.	Total number of POTWs receiving discharges from Oil subcategory CWTs is 56.
4-15

-------
"able 4-19. Oils Subcategory - Projected Criteria
ixcedences for 72
ndirect Dischar
gers

.Willi-
A(|ii;ilii
l.il'i-
Chmnk'
A(|ii;ilii
l.il'i-
lluni;in lk-;illh
(\\;ili-r ;iihI Or»s.)
lluniiin lk-;illh
(Or»s. ()nl\)
luiiil1
Current
Streams (No.)b
10
19
5
4
19
Pollutants (No.)c
4
9
3
3
13

Final Options (8)
Streams (No.)
10
19
4
3
19
Pollutants (No.)
2
5
2
2
8
a.	Pollutants may exceed criteria on a number of streams, therefore the total does not equal the sum of pollutants exceeding criteria.
b.	56 POTWs discharge into 56 waterbodies (32 rivers and 24 estuaries).
c.	86 pollutants of 104 (see Table 4-1).
EPA estimates that under the final rule, annual cancer cases from consumption of contaminated fish from
water bodies receiving oils indirect dischargers would be less than 0.1 cases per year. EPA estimates that
under the final rules, there would be no effect on the IQ of the children of anglers, although there would be
a small reduction in adult cases of hypertension.
EPA estimates that five of the 54 POTWs analyzed experience inhibition problems due to one pollutant in
CWT wastes (see Table 4-21). The final rule would decrease the number of affected POTWs to three.
The final rule would also allow one POTW to switch its biosolids disposal from incineration to surface
disposal.
4-16

-------
' "able 4-20. Oils Subcategory - Pollutants Projected to Exceed Criteria for 72 Indirect Dischargers3 b

Wuic Vi|iiiiii>' 1 ilr
( IllMllii A(|ll;ilii 1 ilr
1 liiiiiiin 1 It'iilih
\\ iiliT iinil C )r«s. i
1 llllllilll 1 ll'llllll l< ( >lll\ l

( III ICIll
liiiiil ()|ilinii
( UlTCllI
liiiiil
( lll'IVIII
liiiiil

liiiiil
Plllllllilllls



()|ilin
( lll'IVIII
(>|>l i< >i i
benzo (a) anthracene
	
	
	
	
4(0.003-0.007)
3(0.003-0.005)
4(0.003-0.007)
3(0.003-0.005)
bis(2-ethylhexyl
—
—
—
—
2(5.2-8.5)
—
1(8.5)
—
jhthalate








arsenic
—
—
—
—
5(0.02-0.2)
4(0.02-0.2)
1(0.2)
1(0.2)
aluminum
1(3.6)
—
1(3.6)
1(2.0)
—
—
—
—
boron
—
—
7(2.5-179)
6(5.1-120)
—
—
—
—
lead
—
—
3(0.2-0.6)
—
—
—
—
—
molybdenum
—
—
2(3.1-7.2)
1(2.1)
—
—
—
—
zinc
1(2.5)
1(1.1)
1(2.5)
—
—
—
—
—
copper
1(0.1)
—
—
—
—
—
—
—
phosphorus
10(0.2-13.4)
10(0.2-13.4)
19(0.02-13.4)
19(0.02-13.4)
—
—
—
—
carbon disulfide
—
—
1(0.044)
—
—
—
—
—
cobalt
—
—
1(1.6)
1(1.6)
—
—
—
—
N-hexadecane
—
—
1(25)
—
—
—
—
—
Total
4
2
9
5
3
2
3
2
Pollutants








a.	Number(s) in parentheses represent instream concentrations (ng/L).
b.	Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be discharged from the same water body. Therefore the
total number of occurrences are not the sum of the waterbodies where excedences occur.
4-17

-------
"able 4-21. Oils Subcategory - Projected POTW Inhibition Problems from 72 Indirect Dischargers

liiiilo^iial Inhibition
Current
POTWs (No.)b
5
Pollutants (No.)c
la
Total Problems
4
Final Option 9
POTWs (No.)
3
Pollutants (No.)
1
Total Problems
3
a.	boron
b.	56 POTWs discharge into 56 waterbodies (32 rivers and 24 estuaries).
c.	86 pollutants of 104 (see Table 4-1).
4.1.4 Organics Subcategory
EPA estimates that 43 organic CWT facilities discharge at baseline approximately 4.18 million lbs/year of
metals and organics to surface waters (see Table 4-22). Under the final rule, pollutant loadings would be
reduced by 33 percent or to 28.2 million lbs/year. EPA analyzed the environmental effects of 19 of 43 (24
zero dischargers) organic subcategory CWT facilities.
' "able 4-22. Organics Subcategory - Pollutant Loadings for 19 Dischargers
Loadings (millions pounds/year) ' ''

Direct
Dischargers
Indirect
Dischargers
Total
Current
0.95
3.23
4.18
Final (Option 4)
BPT/BAT/PSES
0.95
1.87
2.82
No. of Pollutants Evaluated
49
49
49
No. of Facilities Evaluated1
4
15
19
a.	Consists of 49 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis. Loadings are scaled to represent 43 facilities.
b.	The total universe consists of 43 facilities (24 are zero dischargers).
4-18

-------
(a) Organics Subcategory - Direct Dischargers
EPA estimates that under baseline conditions four direct discharging CWT facilities discharge approximately
0.95 million lbs/year of metals and organics facilities (see Table 4-23). Under the final BAT/BPT (Option 4)
levels, pollutant loadings would remain at about 0.95 million lbs/year.
' "able 4-23. Organics Subcategory - Environmental Effects of Four Direct Dischargers"

Cur mi l
l-'inal
Summary
Loadings (million lbs/yr)b
0.95
0.95
No Reduction
AWQC Excedences
two at one stream
two at one stream
No Reduction
Additional Cancer Cases/yrc
<0.1
<0.1
Reduction of <0.1
Population exposed to non-cancer effects0
None
None
No Reduction
a.	Modeled results and loadings represent all of the four direct waste water dischargers.
b.	49 of 104 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
c.	Through consumption of contaminated fish tissue.
EPA modeled the environmental effects of four organic direct discharging CWTs. The analysis comparing
modeled instream pollutant levels to AWQC estimates that two excedences in one stream would still occur
under the final rule. EPA estimates cancer risk from fish consumption to be much less than 0.1 cases per
year. EPA also projects that no human populations are exposed to pollutants that could result in non-cancer
effects under current or final treatment levels.
(b) Organics Subcategory - Indirect Dischargers
EPA estimates that 15 indirect discharging CWT facilities currently discharge 3.23 million lbs/year of metals
and organics (see Table 4-24). Under the final PSES (Option 4) treatment level, pollutant loadings would be
reduced by 42 percent, or to 1.87 million lbs/year.
EPA modeled the environmental effects of 15 organic indirect discharging CWT facilities. The analysis
comparing modeled instream pollutant levels to AWQC estimates that 46 concentrations in excess of AWQC
in 11 streams would be reduced to 29 concentrations in excess of AWQC in eight streams (see Tables 4-24,
4-25, and 4-26).
4-19

-------
EPA estimates cancer risk from fish consumption would be reduced from approximately 0.09 cases per year
to 0.08 cases per year. EPA also estimates that organic indirect discharges do not substantially increase risk
of non-cancer effects to local anglers. No POTWs are estimated to be affected by CWT organic discharges.
' "able 4-24. Organics Subcategory - Environmental Effects of 15 Indirect Dischargers3 b

(ll ITl'lll
Final
Siimmarx
Loadings (million lbs/yr)0
3.23
1.87
42% Reduction
AWQC Excedences
46 at 11 streams
29 at 8 streams
3 streams become "CWT contaminant-
free"
Additional Cancer Cases/yrd
0.09
0.08
Reduction of 0.01
Population exposed to non-cancer
effects d
None
None
No Reduction
POTWs experiencing inhibition6
None
None
No Reduction
Biosolid Quality
None
None
No Reduction
a.	Modeled results represent 15 indirect waste water dischargers (five facilities are zero dischargers).
b.	For indirect dischargers, loading estimates have been adjusted to account for POTW removals.
c.	Consists of 49 pollutants (see Table 4-1); Loadings are representative of metals and organic pollutants evaluated; only conventional
pollutants are not included in this analysis.
d.	Through consumption of contaminated fish tissue.
e.	Total number of POTWs receiving discharges from organic subcategory CWTs is 15.
able 4-25. Organics Subcategory - Projected Criteria Excedences for 15 Indirect Dischargers
Aiuli-
A(|ii;ilk' l.ili-
('liniiik' A(|ii:ilii'
I .i IV.-
Iliiiiiiin Ik;il111
(Wak-r ;ind ()r»s.)
Human I k-:illh
(Or»s. Onl\)
loliil1
Current
Streams (No.)
11
11
Pollutants (No.)b
Final Option
Streams (No.)
2
3
8
3
Pollutants (No.)
2
3
5
1
a.	Pollutants may exceed criteria on a number of streams, therefore, the total does not equal the sum of pollutants exceeding criteria.
b.	Number of different pollutants that exceed ambient water quality and human heath based criteria.
4-20

-------
Table 4-26.
Organics Subcategory - Pollutants Pro.jecte<
to Exceed Criteria for Indirect Discharger

.Willi- A(|ii;ilk
Chronic Acpmlii
1 liiman 1 k-allh
1 liinian 1 k-allh

Mil
il. 1)
l.il'i'
il. 1)
(Wali-rand Or»s. )¦' 11
(Or»s. Onl\ )¦'11
Pollutants
(lllTl'lll
Final
(lllTl'lll
Final
(lllTl'lll
Filial

Filial


Option

Option

Option
(lllTl'lll
Option
Boron
	
—
2(9.3-14.3)
1(9.3)
—
—
—
—
Methylene
	
—
—
—
5(34.4-350)
3(34.4-284)
—
—
chloride








Vinyl
	
—
—
—
5(0.03-0.3)
3(0.03-0.2)
—
—
chloride








Tetrachloro-
	
—
—
—
2(0.5-0.7)
1(0.5)
—
—
methane








Phosphorus
3(0.3-0.8)
2(0.3-0.5)
5(0.1-0.8)
3(0.1-0.5)
—
—
—
—
Pentachloro-
2(2.2-2.7)
1(2.2)
2(2.2-2.7)
1(2.2)
4(0.43-2.7)
3(0.3-2.2)
—
—
phenol








Dibromo-
—
—
—
—
11(0-1.1)
8(0-0.9)
5(0.1-1)
3(0.1-1)
ethane, 1, 2-








Total
2
2
3
3
5
5
1
1
Pollutants








a.	Number(s) in parentheses represent instream concentrations (jj.g/1).
b.	Numbers outside of parentheses represent the number of occurrence(s) of a pollutant, however different pollutants may be
discharged from the same water body. Therefore the total number of occurrences are not the sum of the water bodies where
excedences occur.
4.2 Documented Environmental Effects
4.2.1 Permit Violations of CWT Facilities
EPA Regional personnel and the corresponding State Pretreatment Coordinators identified a total of 35
facilities which have had various permit violations (see Appendix D, Table D-l). Of the 35 facilities that
have reported violations, only five continue to have discharge violations or continue to present problems for
the receiving POTW. Violations may take the form of exceeding permit limits or other, local limit pass
through problem for receiving POTW, negative effect on surface water quality, or negative effect on water
odor. The most commonly cited violations involve metal discharges.
4-21

-------
4.2.2 Effects of CWT Wastes on POTW Operations and Water Quality
EPA identified environmental effects on POTW operations and water quality due to discharges of pollutants
from nine indirect CWT facilities. Effects include seven cases of impairment to POTW operations due to
cyanide, nitrate/nitrite, sodium, zinc and ammonia, and one case of an effect on the quality of receiving water
due to organics (Table 4-27). In addition, the states identified four direct centralized waste treatment
facilities and eight POTWs, which receive the discharge from 13 facilities, as point sources causing water
quality problems included on state 304(1) Short Lists (see Tables 4-28 and 4-29).
Pollutants of concern include cadmium, copper, cyanide, lead, mercury, nickel, selenium, silver, zinc, and
organics. Section 304(1) of the Water Quality Act of 1987 requires States to identify water bodies impaired
by the presence of toxic substances, to identify point source discharges of these toxics, and to develop
Individual Control Strategies (ICSs) for these discharges. The Short List is a list of waters for which a State
does not expect achievement of the applicable water quality standards (numeric or narrative) to be achieved
after technology-based requirements have been met due entirely or substantially to point source discharges of
Section 307(a) toxics.
4-22

-------
"able 4-27. Documented Environmental Effects of CWT Wastes on POTW Operations and Water Quality
POTW
hk'lllil'k'd lni|);Kis
Case #1
High concentrations of nitrate, nitrate and sodium in CWT's batch discharges responsible for interference of POTW
operations (1993/1994). High chlorine demand of discharges caused loss of chlorine residual and resulted in POTW fecal
coliform violations; $5000 fine is pending.
Case #2
Permit violations for phosphorus and total cyanide (1992/1993). Discharge of high levels of cyanide caused interference of
POTW operations and results in $10,000 fine.
Case #3
Municipality below POTW developed drinking water taste and odor problems. Organics discharged by CWT identified as
source.
Case #4
Permit violations of Total Toxic Organics(TTO), cyanide, nickel, fats, oils and grease (FOG), lead, zinc and mercury
(1989-1990). Resulted in $60,000 fine.
Case #5
Zinc and Ammonia pass-through events from CWT discharges caused POTW NPDES violations in 1991 and 1996,
respectively.
Case #6
Ammonia-nitrate pass-through from CWT discharge caused POTW NPDES violations due to nitrification inhibition
(1991/1992). POTW fined CWT facility $3,450 for violation.
Case #7
Zinc pass-through from CWT discharge caused POTW NPDES violations on 3 occasions (1993). Since CWT receives
both wastewater and hazardous wastes, under CFR section 261.4, they claim they do not need a RCRA permit. In 1997
a law suit between the CWT and both the POTW and Citizens was settled. The CWT paid $650,000 and $300,000 to the
POTW and citizens, respectively.
Case #8
High strength ammonia discharge from CWT caused inhibitions problems resulting in low pH POTW NPDES violations
on 3 occasions (1991).
Case #9
POTW permit violations of copper and cyanide resulted in a pass-through event. CWT fined cost of all analytic and
administrative work needed to be performed subsequent to the violations. This order expired in 1998, and now the POTW
is collecting new compliance data.
Source: EPA Regions and State Pretreatment Coordinators.
4-23

-------
able 4-28. CWT Facilities Included on State 304(L) Short Lists
M'DI.S
l';nilil\ Viiik-
Citv
W;iUtI>ihI\
.NiiihIkt
l.isu-d Piilliiliinls
AL0003247
Sloss Industries
Birmingham
Five Mile Creek
03160111006
Cadmium, Copper, Cyanide, Lead,
Zinc
CT0001376
Pratt & Whitney
East Hartford
Willow Brook (Connecticut
River)
01080205024
Copper, Nickel, Zinc
NJ0003867
CP Chemicals
Sewaren
Woodbridge Creek (Arthur
Kill)
02030104003
Copper, Lead, Nickel, Zinc
PA0027715
Mill Service
Yukon
Sewickley Creek
05020006045
Copper, Lead, Silver
Source: Compiled from OW files dated April/May 1991.
4-24

-------
"able 4-29. POTWs Which Receive
)ischarge From CWT Facilities and are Included on State 304(L) Short Lists
huililx N.iiik-
City
ins
POIW
POIW
\pdi:s
W;iIitI)ihI\
NiiihIkt
Piillul;inls
Clean Harbors
Baltimore
Back River WWTP
MD0021555
Back River to Curtis Bay
18050004002
Lead, Mercury, Selenium
Environmental Waste
Control
Inkster
Detroit WWTP
MI0022802
Detroit River
04090004009
Cadmium, Copper, Lead,
Mercury, PCBs
Edwards Oil
Detroit
Detroit WWTP
MI0022802
Detroit River
04090004009
Cadmium, Copper, Lead,
Mercury, PCBs
DYNECOL
Detroit
Detroit WWTP
MI0022802
Detroit River
04090004009
Cadmium, Copper, Lead,
Mercury, PCBs
American Tank Service
Ferndale
Detroit WWTP
MI0022802
Detroit River
04090004009
Cadmium, Copper, Lead,
Mercury, PCBs
American Waste Oil
Belleville
Detroit WWTP
MI0022802
Detroit River
04090004009
Cadmium, Copper, Lead,
Mercury, PCBs
CYANOKEM
Detroit
Detroit WWTP
MI0022802
Detroit River
04090004009
Cadmium, Copper, Lead,
Mercury, PCBs
Chemical Waste
Management
Newark
Passaic Valley Sewage
Comm.
NJ0021016
Upper New York Bay
02030104001
Cadmium, Lead, Mercury
Waste Conversion
Hatfield
Hatfield TWP
Mun. Authority
PA0026247
W.B. Neshaminy Creek to
Neshaminy River
02040201011
27 Organics
Envirite
York
Spiingettsbury TWP
PA0026808
Codorus Creek
02050306066
-
ETICAM
Warwick
Warwick WWTP
RIO100234
Pawtuxet River
0109004029
Lead, Silver
Belpar Environmental
Prince George
Hopewell POTW
VA0066630
Gravelly Run to James
River
02080206041
Copper, Lead, Zinc
Crosby and Overton
Kent
Metro (Renton STP)
WA0029581
Green River
17110013004
-
Source: Compiled From OW Files Dated April/May 1991.
4-25

-------
5.0 References
Code of Federal Regulations, Title 40 part 131 section 36. 1993. Criteria for Priority Toxic Pollutants.
Karnovitz, Alan, Donahoe, Sean, Collins, Jim 1998a. Assessing Potential Risks to Exposed Adult Populations from
Consuming Lead-Contaminated Fish. Memo to Tony Donigian. August.
Karnovitz, Alan, Donahoe, Sean, Collins, Jim 1998b. Assessing Potential Risks to Exposed Populations from
Consuming Lead-Contaminated Fish. Memo to Tony Donigian. July.
Leggeir, Richard W. 1993. An Age-specific Kinetic Model of Lead Metabolism inHumans in Research Advances.
Volume 101 Number 7, December.
Maddaloni, M. A. 1998. Measurement of Soil-Born Lead Bioavailability in Human Adults, and its Application in
Biokinetic Modeling. Ph.D. Dissertation. School of Public Health, Columbian University, New York.
Metcalf & Eddy, Inc. 1972. Wastewater Engineering. McGraw-Hill Book Company, New York
Sherlock, J., Smart, G., Forbes, G.I., Moore, M.R., Patterson, W.J., Richards, W.N., Wilson, T.S. 1982. Assessment
Of Lead Lntakes And Dose-response for a Population in Ayr Exposed to a Plumbosolvent Water Supply.
The Macmillan Press Ltd.
Society of Toxicology. 1998. Toxicological Sciences, Formerly Fundamental and Applied Toxicology. An
Official Journal of the Society of Toxicology Supplement. Volume 42, Number 1-S, March 1998.
Tetra Tech Inc. 1998a. Appendix 1, Cancer Risk & Non-Cancer Systemic Hazard Calculations & Assumptions.
Tetra Tech Inc. 1998b. CWT Raw Data and Modeling Outputs. On one diskette.
USEPA. 1982. Fate of Priority Pollutants in Publicly Owned Treatment Works. Final Report, Volume I. EPA
440/1-82/303. U.S. Environmental Protection Agency, Effluent Guidelines Division, Washington, DC.
USEPA. 1987a. Guidance Manual for Preventing Interference at POTWs. U.S. Environmental Protection Agency,
Office of Solid Waste and Emergency Response, Washington, DC.
USEPA. 1987b. Quality Criteria for Water. U.S. Environmental Protection Agency, Office of Water. EPA 440/5-
86-001. [Also refers series EPA 440/5-80 and to any updated criteria documents (EPA 440/5-85 and EPA
440/5-87 Series)].
USEPA. 1989a. Risk Assessment Guidance for Superfund. Volume I: Human Health Evaluation Manual (Part A).
Interim final. OSWER Directive 9285.7-01a. U.S. Environmental Protection Agency, Offce of Solid Waste
and Emergency Response, Washington, DC. December.
USEPA. 1989b. Assessing Human Health Risks for Chemically Contaminated Fish and Shellfish: A Guidance
Manual. EPA-503/8-89-002. U.S. Environmental Protection Agency, Office of Water Regulations and
Standarda, Washington, DC. September.
USEPA. 1989c. Supplemental Risk Assessment Guidance for the Superfund Program. Draft Final. U.S.
Environmental Protection Agency Region 1 Risk Assessment Work Group. June.
5-1

-------
USEPA. 1989d. Risk Assessment Guidance For Superfund-Environmental Evaluation Manual. Interim Final.
EPA/540/1 -89/001A. OSWER Directive 9285.7-01. U.S. Environmental Protection Agency Office of
Emergency And Remedial Response. Washington, DC. March.
USEPA. 1990. CERCLA Site Discharges to POTWs: Guidance Manuals. EPA-540/G-90-005. U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response, Washington, DC.
USEPA. 1991a. Technical Support Document for Water Quality-based Toxics Control. EPA/505/2-90-001. U.S.
Environmental Protection Agency, Office of Water, Washington, DC.
USEPA. 1991b. Documented Environmental Effects. Compiled from Office of Water files dated April/May 1991.
U.S. Environmental Protection Agency, Washington, DC.
USEPA. 1991c. Technical Support Document for Water Quality-based Toxics Control. United States
Environmental Protection Agency, Office of Water. EPA/505/2-90-001, March 1991.
USEPA. 1994a. Integrated Exposure Uptake Biokinetic Model for Leadin Children (IEUBK) Version 0.99D (for
microcomputers). Computer Product Information Sheet.
USEPA. 1994b. Land Application of Sewage Sludge. EPA/83 l-B-93-002b. U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance. December.
USEPA. 1995. User's guide for the Industrial Source Complex (ISC3) Dispersion Models Volume I - User
Instructions. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards
Emissions, Monitoring, and Analysis Division. EPA 454/B-95-003a. September 1995.
USEPA. 1996a. Health Effects Assessment Summary Tables (HEAST). FY-1996. U.S. Environmental Protection
Agency, Office of Solid Waste and Emergency Response, Washington, DC.
USEPA. 1996b. Recommendations of the Technical Review Workgroup for Lead for an Interim Approach to
Assessing Risks Associated with Adult Exposures to Lead in Soil. Technical Review Workgroup for Lead.
December
USEPA. 1996c. Toxic and Pollutant Weighting Factors for Pesticide Formulating, Packaging, and Repackaging
Industry Final Effluent Guidelines. Final Report. U.S. Environmental Protection Agency Office of Science
and Technology Standards and Applied Science Division. March.
USEPA. 1997a. Integrated Risk Information System (IRIS). U.S. Environmental Protection Agency, Health Criteria
and Assessment Office, Washington, DC.
USEPA. 1997b. Volume II-Food Ingestion Factors. Exposure Factors Handbook. Update to Exposure Factors
Handbook. EPA/600/P-95/002Fb. U.S. Environmental Protection Agency Office of Research &
Development National Center for Env. Assessment. August 1997.
USEPA. 1997c. Appendix G: Lead Benefits Analysis. The Benefits and Costs of the Clean Air Act, 1970 to 1990.
U.S. Environmental Protection agency.
USEPA. 1998a. Risk Assessment Guidance for Superfund: Volume 1 - Human Health Evaluation Manual (Part D,
Standardized Planning, Reporting, and Review of Superfund Risk Assessments). Interim. U.S. Environmental
Protection Agency Solid Waste and Emergency Response. EPA 540-R-97-033. OSWER 9285.7-01D.
January.
USEPA. 1998. Environmental Assessment for the Proposed Effluent Guidelines, Pretreatment Standards, and
New Source for the Centralized Waste Treatment Industry. EPA 821-R-98-017. December.
5-2

-------
USEPA. 2000. Toxic and Pollutant Weighting Factors For Final Effluent Guidelines For The Centralized Waste
Treater 's Industry. August
Versar, Inc. 1992. Upgrade of Flow Statistics Used to Estimate Surface Water Chemical Concentrations for
Aquatic and Human Exposure Assessment. Report prepared by Versar, Inc., for U.S. Environmental
Protection Agency, Office of Pollution Prevention and Toxics, Washington, DC.
Versar, Inc. 1992. Mixing Zone Dilution Factors for New Chemical Exposure Assessments. Draft Report.
Contract No. 68-D9-0166. Task No. 3-35
Versar, Inc. 1994. Toxic and Pollutant Weighting Factors for the Centralized Waste Treatment Industry Proposed
Effluent Guidelines. Final Report. Prepared for U.S. Environmental Protection Agency Office of Science
and Technology Standards and Applied Science Division. December.
Versar, Inc. 1997. Development of Mixing Zone Dilution Factors. EPA/68-D3-0013. Prepared for U.S.
Environmental Protection Agency, Economics, Exposure and Technology Division. Washington, DC.
Versar, Inc., Memo to Charles Tamulonis, USEPA. 1998. PCS Analysis - Enforcement Violations - CWT Industry.
May 18
5-3

-------
APPENDIX A
DILUTION CONCENTRATION POTENTIAL (DCP) VALUES

-------
Appendix A. Dilution Concentration Potential (DCP) Values for Specific Water
Bodies
Receiving Water Body
Dilution Concentration Potential
Detroit River, MI
0.2
Pacific Ocean (Vernon, CA)
0.685
James River, VA (Chesapeake Bay)
0.072
Puget Sound, WA
0.039
Niagra River, NY
0.2
Lake Michigan, IL
0.0042
South Oyster Bay, NY
0.054
Upper New York Bay, NJ
0.233
Curtis Bay, MD (Chesapeake Bay)
0.072
Alameda Creek, CA
0.048
Arthur Kill, NJ
0.223
Pacific Ocean (Long Beach, CA)
0.685
Green River, WA
0.2
Carney's Point, NJ
0.2
Clear Creek, TX
0.41
Corpus Cristi Bay, TX
4.67
San Francisco Bay, CA
0.048
Tucker Bayou, TX
0.41
Neches River, TX
0.38
Pacific Ocean (Los Angeles, CA)
0.685
Pacific Ocean (Honolulu, HI)
1.5
Calcasieu, LA
1.18
Delaware River, NJ
0.14
San Francisco Bay (E. Palo Alto), CA
0.104
Pacific Ocean (Santa Fe Springs, CA)
0.685
Tallaboa Bay, PR
1.371
Bayou Sara, AL
0.08
Lake Erie, OH
0.2
Casco Bay, ME
0.061
Atlantic Ocean (Miami, FL)
0.4
Pacific Ocean (Compton, CA)
0.685
Holmes Run/Cameron Run, VA (Chesapeake Bay)
0.072
Charles River, MA
0.27
St. Johns River, FL
0.83
Mobile Bay, AL
0.08
Mississippi River, LA
0.01
Atlantic Ocean (Pompano Beach, FL)
1.0
A-2

-------
Appendix A. Dilution Concentration Potential (DCP) Values for Specific Water
Bodies
Receiving Water Body
Dilution Concentration Potential
Elizabeth River, VA
0.14
Cedar Bayou, TX
0.41
Pensacola Bay, FL
0.46
Lake Michigan, WI
0.3
Alamitos Creek, CA
0.192
Pascagoula River, MS
0.17
Boston Bay, MA
0.27
A-3

-------
APPENDIX B
TOXICOLOGICAL INFORMATION

-------
Appendix B. Toxicity Values for the Contaminants Analyzed in the Centralized Waste Treatment Industry




Acute
Chronic
Human Health
Human Health
Chemical
RfD
SF
BCF
AWQC
AWQC
Organism
Water and Organism
4-Chloro-3-methylphenol
2

79
4050
1300
270000
56000
4-Methyl-2-pentanone
0.08

2.4
505000
50445
360000
2800
Acenaphthene
0.06

242
580
208
2700
1200
Acetophenone
0.1

11
162000
31094
98000
3400
Alpha-terpineol


48
12742
4879


Aluminum
1

231
750
87
47000
20000
Anthracene
0.3

478
2.78
2.2
6800
4100
Antimony
0.000
4

1
3500
1600
4300
14
Arsenic
0.000
3
1.5
44
340
150
0.16
0.02
Barium
0.07


410000
2813

1000
Benzene
0.003
0.029
5.21
5300
530
71
1.2
Benzo (a) anthracene

0.73
4620
10
1
0.0032
0.003
Benzofluorene, 2,3-


10100
588
36


Benzoic acid
4

15
180000
17178
2900000
130000
Benzyl alcohol
0.3

4
10000
1000
810000
10000
Biphenyl
0.05

436
360
230
1200
720
Bis(2-ethylhexyl) phthalate
0.02
0.014
130


5.9
1.8
Boron
0.09



31.6


Butanone, 2-
0.6

1
3220000
233550
6500000
21000
Butyl benzyl phthalate
0.2

414
820
260
5200
3000
Cadmium
0.000
5

64
4.3
2.2
84
14
Carbazole

0.02
251
930
893
2.1
0.96
Carbon disulfide
0.1

11.5
2100
2
94000
3400
B-2

-------
Chemical
RfD
SF
BCF
Acute
AWQC
Chronic
AWQC
Human Health
Organism
Human Health
Water and Organism
Chlorobenzene
0.02

10.3
2370
2100
21000
680
Chloroform
0.01
0.006
1
3.75
13300
6300
470
5.7
Chromium
1.5

16
570
74
1000000
50000
Chrysene

0.007
3
4620
592
16
0.32
0.3
Cobalt
0.06


1620
49


Copper
0.04

360
13
9
1200
650
Cresol, o-
0.05

18
14000
2251
30000
1700
Cresol, p-
0.005

17.6
7500
2570
3100
170
Di-n-butyl phthalate
0.1

89
850
500
12000
2700
Dibenzofuran
0.000
4

1349
1050
280
32
26
Dibenzothiophene


1100
420
122


Dibromochloromethane
0.02
0.084
29
34000
14607
4.4
0.38
Dibromoethane, 1,2-

85
10
106050
35485
0.013
0.0004
Dichloraniline


29
7170
717


Dichlorobenzene, 1,4-
0.03
0.024
55.6
1120
763
8.1
1.2
Dichloroethane, 1,2-
0.03
0.091
1.2
116000
11000
99
0.38
Dichloroethene, 1,1-
0.009
0.6
5.6
11600
5114
3.2
0.057
Dichloroethene, trans, 1,2-
0.02

1.6
20000
110000
130000
70
Diethyl ether
0.2

2.8
2560000
79833
770000
6900
Diethyl phthalate
0.8

73
31800
10000
120000
23000
Dimethylformamide, N,N-
0.1

0.005
7100000
710000
220000000
3500
Dimethylphenanthrene, 3,6-


33000
543
21


Dimethylphenol, 2,4-
0.02

94
2120
1970
2300
540
B-3

-------




Acute
Chronic
Human Health
Human Health
Chemical
RfD
SF
BCF
AWQC
AWQC
Organism
Water and Organism
Diphenyl ether


930
4000
213


Ethylbenzene
0.1

37.5
9090
4600
29000
3100
Fluoranthene
0.04

1150
45
7.1
370
300
Fluorene
0.04

30
212
8
14000
1300
Hexanoic acid


16
320000
15170


Iron
0.3



1000

300
Lead


49
65
2.5


Lithium
0.02



464


Manganese
0.14



388
100
50
Mercury


5500
1.4
0.77
0.051
0.05
Methylene Chloride
0.06
0.0075
0.91
330000
82500
1600
4.7
Methylfluorene, 1-


3300
627
115


Methylnaphthalene, 2-

0.02
2566
1133
417
84
75
Methylphenanthrene, 1-


4790
555
54


Molybdenum
0.005



27.8


N-Decane


8800
18000
1300


N-Docosane


100000
530000
68000


N-Dodecane


14500
18000
1300


N-Eicosane


100000
18000
1300


N-Hexadecane


32300
18000
1300


N-Octadecane


10100
18000
1300


N-Tetradecane


19500
18000
1300


Naphthalene
0.02

10.5
1600
370
21000
680
Nickel
0.02

47
470
52
4600
610
P-Cymene


770
6500
237


B-4

-------




Acute
Chronic
Human Health
Human Health
Chemical
RfD
SF
BCF
AWQC
AWQC
Organism
Water and Organism
Pentachlorophenol
0.03
0.12
11
19
15
8.2
0.28
Pentamethylbenzene


2600
528
102


Phenanthrene


486
180
19


Phenol
0.6

1.4
4200
200
4600000
21000
Phenylnaphthalene, 2-


4470
560
37


Phosphorus



2.4
0.1


Propanone, 2-
0.1

0.39
6210000
1866000
2800000
3500
Pyrene
0.03

1110
591
61
290
230
Pyridine
0.001

2
93800
25000
5400
34.7739692
Selenium
0.005

4.8
12.83
5
11000
170
Silicon







Silver
0.005

0.5
3.4
0.34
110000
170
Strontium
0.6

9.5


680000
20000
Styrene
0.2

13.5
4020
402
160000
6700
Sulfur



10000000
1000000


Tetrachloroethane, 1,1,1, 2-
0.03
0.026
17
20000
10000
24
1.3
T etrachloroethene
0.01
0.052
30.6
4990
510
3500
320
T etrachloromethane
0.000
7
0.13
18.75
41400
3400
4.4
0.25
Tin
0.6



18.6


Titanium
4



191


Toluene
0.2

10.7
5500
1000
200000
6800
Trichlorobenzene, 1,2,4-
0.01

1202
930
286
90
71
Trichloroethane, 1,1,1
0.02

5.6
42300
1300
38000
690
B-5

-------




Acute
Chronic
Human Health
Human Health
Chemical
RfD
SF
BCF
AWQC
AWQC
Organism
Water and Organism
Trichloroethane, 1,1,2
0.004
0.057
4.5
18000
13000
42
0.61
Trichloroethene
0.006
0.011
10.6
40700
14850
92
3.1
Trichlorophenol, 2,4,5
0.1

1905
1549
344
570
490
Trichloropropane, 1,2,3
0.006
7
18.8
33800
17140
3400
200
T ripropyleneglycol-methylether


0.2
2484600
683870


Vanadium
0.007


11200
9


Vinyl Chloride

1.9
1.17
56329
18242
4.8
0.018
Xylene, m-
2

208
16000
3900
100000
42000
Zinc
0.3

47
120
120
69000
9100
Zirconium




10.3


B-6

-------
APPENDIX C
POLLUTANTS EVALUATED

-------
Table C-l. Metals Subcategory - Pollutants Evaluated
Polliilanls '
Aluminum
Copper
Molybdenum
Tin
Antimony
Dibromochloromethane
Nickel
Titanium
Arsenic
Dichloroethene, 1,1-
Phosphorus
Toluene
Benzoic acid
Dimethylformamide, N, N-
Propanone, 2-
Trichloroethane, 1, 1, 1-
Boron
Iron
Pyridine
Tripropyleneglycolmethylethe
r
Butanone, 2-
Lead
Selenium
Vanadium
Cadmium
Lithium
Silicon
Zinc
Carbon disulfide
Manganese
Silver
Zirconium
Chromium
Mercury
Strontium

Cobalt
Methylene Chloride
Sulfur

a. Although the total number of documented metals and organics pollutants is 49, only 38 pollutants were analyzed due to a lack of
information on AWQC and toxicological information.
C-2

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Table C-2. Oils Subcategory - Pollutants Evaluated
| Pollutants'1 |
4-Chloro-3-Methylphenol
Chloroform
Iron
Phosphorus
4-Methyl-2-Pentanone
Chromium
Lead
Propanone, 2-
Acenaphthene
Chrysene
Manganese
Pyrene
Alpha-terpineol
Cobalt
Mercury
Pyridine
Aluminum
Copper
Methylfluorene, 1-
Selenium
Anthracene
Cresol, o-
Methylnaphthalene, 2-
Silicon
Antimony
Cresol, p-
Methylphenanthrene, 1-
Silver
Arsenic
Di-n-butyl phthalate
Molybdenum
Strontium
Barium
Dibenzofuran
N-Decane
Styrene
Benzene
Dibenzothiophene
N-Docosane
Sulfur
Benzo(a)anthracene
Dichlorobenzene, 1,4-
N-Dodecane
T etrachloroethene
Benzofluorene, 2,3-
Dichloroethane, 1,2-
N-Eicosane
Tin
Benzoic acid
Dichloroethene, 1,1-
N-Hexadecane
Titanium
Benzyl alcohol
Diethyl phthalate
N-Octadecane
Toluene
Biphenyl
Dimethylformamide, N, N-
N-Tetradecane
Trichlorobenzene, 1,2,4-
Bis(2-ethylhexyl) phthalate
Dimethylphenanthrene, 3,6-
Naphthalene
Trichloroethane, 1,1,1-
Boron
Dimethylphenol, 2,4-
Nickel
Trichloroethene
Butyl Benzyl Phthalate
Diphenyl ether
P-Cymene
Tripropyleneglycolmethylether
Cadmium
Ethylbenzene
Pentamethylbenzene
Xylene, m-
Carbazole
Fluoranthene
Phenanthrene
Zinc
Carbon disulfide
Fluorene
Phenol

Chlorobenzene
Hexanoic acid
Phenylnaphthalene, 2-

a. Although the total number of documented metals and organics pollutants is 93, only 86 pollutants were analyzed due to a lack of
information on AWQC and toxicological information.
C-3

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Table C-3. Organics Subcategory—Pollutants Evaluated
Pollutants ''
4-methyl-2-pentanone
Dichloroethane, 1, 2-
Silicon
Acetophenone
Dichloroethene, 1,1-
Strontium
Aluminum
Dichloroethene, trans 1, 2-
Sulfur
Antimony
Diethyl ether
Tetrachloroethane, 1,1,1,2-
Barium
Dimethylformamide, N, N-
T etrachloroethene
Benzene
Hexanoic acid
T etrachloromethane
Benzoic acid
Iron
Tin
Boron
Lithium
Toluene
Butanone, 2-
Manganese
Trichloroethane, 1,1,1-
Chloroform
Methylene chloride
Trichloroethane, 1,1,2-
Chromium
Molybdenum
Trichloroethene
Cobalt
Nickel
Trichlorophenol, 2,4,5-
Copper
Pentachlorophenol
Trichloropropane, 1,2,3-
Cresol, o-
Phenol
Vinyl chloride
Cresol, p-
Phosphorus
Xylene, m-
Dibromoethane, 1, 2-
Propanone, 2-
Zinc
Dichloraniline
Pyridine

a. Although the total number of documented metals and organics is 63, only 50 pollutants were analyzed due to a lack of information
on AWQC and toxicological information.
C-4

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APPENDIX D
DOCUMENTED ENVIRONMENTAL EFFECTS

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DOCUMENTED ENVIRONMENTAL EFFECTS
(Excerpts taken from the May 5, 1998 memo prepared by ABT Associates, for Charles
Tamulonis, titled Summary of Documented POTW Problems from Centralized Waste
Treatment Facilities and Potential Monetization of Case Studies).
Problems with CWT facilities were identified through a series of phone conversations
made during the months of June through September 1997 with EPA regional coordinators
regarding 156 CWT facilities nationwide.
A total of 35 facilities were reported as having problems with their discharge. These
problems may take the form of a permit exceedence, local limit exceedence, pass through
problem for receiving POTW, negative impact on surface water quality, or negative impact
on water odor.
The most commonly cited violations involve metals discharge. Permit violations for lead,
silver, arsenic, zinc copper, nickel, mercury, and aluminum were reported by POTWs as
originating from CWT facilities. Other commonly cited violations involved ammonia and
oil and grease. Table 1 below presents the reported violations at 35 facilities in eight
different EPA regions1. Table 1 also lists the impacts of the violations on POTWs, the
actions taken by the facility in response to the violation, and the current violation status of
the facility.
As Table 1 demonstrates, violations at CWT facilities have not been insignificant.
However, of the 35 facilities that have reported violations, only five continue to have
discharge violations or continue to present problems for the receiving POTW. Three
facilities have ceased discharging processed wastewater to the POTW, 16 have remedied
the problem through more stringent quality assurance and quality control (QA/QC)
procedures, and the current status of the remaining 11 facilities is not known.
l Regions 8 and 9 reported no violations.
D-2

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Tabic D.l. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Reported Violation
Impacts on Receiving
Waterbody or POTW
Actions Taken
Current Status
Facility 1
Direct
Violation data were not available;
either this facility does not have
violations or is a minor permittee.



Facility 2
Indirect
High chlorine demand and high
concentrations of nitrate, nitrite,
sodium, lead, silver, and arsenic in
influent to the POTW.
POTW had fecal coliform
violations due to high chlorine
demand. Also potential pass-
through of lead and silver and
arsenic.
Facility was fined $5,000.
POTW was placed on the
RI State 304 list.
Facility improved its QA/QC and
screens every batch of pollutants.
Recent violations are minor and
sporadic.
Facility 3
High cyanide and metal
concentrations in influent flow to the
POTW in the past. Facility has no
non-compliance issues now.


Facility adopted more stringent
QA/QC procedures.
Facility 4
Unacceptably high levels of copper,
lead, nickel and zinc in receiving
water.



Facility 5
Permit violations (specific violation
data were not available.)

Information on steps
taken to remediate the
problem is not available.

Facility 6
Permit violations (specific violation
data were not available.)

Information on steps
taken to remediate the
problem is not available.

Facility 7
High concentration of phosphorus and
cyanide in influent flow to the POTW.
Interference with POTW
operations.
Facility was fined
$10,000.
Facility was required to
upgrade its waste
characterization system.
Facility has not had any
significant violations over the past
3 years.
Facility 8
High concentrations of cadmium, lead
and mercury in influent flow to the
POTW.
Potential impact on surface
water quality (potential pass-
through of cadmium, lead and
mercury).
POTW was placed on the
State 304(L) Short list.
Facility no longer treats waste at
this site.
D- 3

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Tabic D.l. Reported Permit Violations and Other Diseharjje Effects From CWT Faeilities
Site
Reported Violation
Impacts on Receiving
Waterbody or POTW
Actions Taken
Current Status
Facility 9
High concentrations of copper, lead
and silver discharged to the receiving
water.
Potential impact on surface
water quality.
POTW was placed on the
State 304(L) Short list.
Facility has not had any
significant violations since 1991.
Facility 10
High concentrations of copper (0.06
mg/1) and aluminum (1.41 mg/1)
discharged to receiving water.
Potential impact on surface
water quality.


Facility 11
High concentrations of organics in
influent flow to the POTW.
Customers complained about the
taste and odor of the local
drinking water supply.
POTW was placed on the
State 304(L) Short list.
Low level concentrations are still
a concern.
Facility 12
High concentrations of TTO, cyanide,
nickel, fats, oils and grease, lead, zinc,
and mercury.
Potential impact on surface
water quality.
Facility was fined $60,000
for permit violations.
POTW was placed on the
State 304(L) Short list.
Facility has had an excellent
compliance record for the past
few years.
Facility 13
High concentrations of lead and zinc
in influent flow to the POTW.
Potential impact on surface
water quality.
POTW was placed on the
State 304(L) Short list.
The site has not engaged in non-
compliance practices with the
exception of occasional reporting
violations since Waste
Management took over.
Facility 14
A couple of minor, one-time
exceedances in the past.

POTW was placed on the
State 304(L) Short list
The last violation was in 1994.
Facility 15
Monitoring the temperature and
chlorine content of their discharge.



Facility 16
Monitoring of gas extraction
condensate.



Facility 17
High concentrations of cadmium,
copper, cyanide, lead, and zinc
discharged to receiving water.
Potential impact on surface
water quality.
POTW was placed on the
State 304(L) Short list.

Facility 18
High concentrations of oil and grease,
phenols, and ammonia discharged to
receiving water.
Potential impact on surface
water quality.


D-4

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Tabic D.l. Reported Permit Violations and Other Discharge Effects From CWT Facilities
Site
Reported Violation
Impacts on Receiving
Waterbody or POTW
Actions Taken
Current Status
Facility 19
High concentrations of lead, cyanide,
oil and grease dicharged to receiving
water. They also had temperature and
pH problems.
Potential impact on surface
water quality.

Thay are currently involved in a
lawsuit due to which further
information on violations and
remediation processes was not
available.
Facility 20
High concentrations of BOD (50.0
mg/L), TSS (238.0 mg/L), oil and
grease (13.2 mg/L), zinc (320 ng/L) as
well as CBOD, copper, pH and fecal
coliform discharged to receiving
water. The facility also had problems
with boiler blowdown, softener
regeneration backwash, and sanitary
wastes.
Potential impact on surface
water quality.

The facility tied all of its non-
contacting cooling water
processes together and now
discharges to the POTW. They
are only directly discharging
groundwater and storm water.
Facility 21
High concentrations of zinc (2410
Hg/L), fats, oils, and grease (348
mg/L), nickel (1,700 mg/L), and
ammonia (8.92 mg/L) in influent flow
to the POTW.
POTW had NPDES violations
due to zinc pass-through. There
was also an incident with
ammonia pass-through for which
the facility was fined.
For the ammonia there
was a prohibited
discharge surcharge of
$175 and one to two
thousand dollars to
reimburse the POTW.
Facility adopted more stringent
QA/QC procedures.
Facility 22
High concentrations of organics
(including benzene) and metals in
influent flow to the POTW.
Discharged organic waste has
produced health and
environmental hazards and foul
odors.
A civil lawsuit was settled
and the POTW received
$650,000 and the
Citizen's suit received
$300,000.
The facility is now bound by local
limits developed by the POTW
for organics. The facility has not
improved.
Facility 23
High concentrations of ammonia,
cyanide, and oil and grease in influent
flow to the POTW.
POTW had NPDES violations
due to discharge containing
ammonia-nitrate which caused
nitrification inhibition.
The POTW fined the
facility $3,450 for these
violations.
Facility adopted more stringent
QA/QC procedures.
Facility 24
High concentrations of ammonia in
influent flow to the POTW.
POTW had NPDES violations
for low pH causing inhibition
problems.

Facility adopted more stringent
QA/QC procedures and screens
every batch of pollutants.
D- 5

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Tabic D.l. Reported Permit Violations and Other Diseharjje Effects From CWT Faeilities
Site
Reported Violation
Impacts on Receiving
Waterbody or POTW
Actions Taken
Current Status
Facility 25
High concentrations of dissolved
oxygen levels and a sewer overflow
event.

POTW was placed on the
State 304(T) Short list.
The facility has ceased operation.
Facility 26
Slug loading was caused at the
POTW due to the discharge of
malodorous solids into the sewer
system, reducing air flow in the plant's
oxidation dishes.
Interference with POTW
operations.

Facility adopted more stringent
QA/QC procedures.
Facility 27
High concentrations of copper,
cyanide, zinc and lead in influent flow
to the POTW.
Potential impact on surface
water quality.
POTW has fined the
facility for administrative
and analytic work.
Facility adopted more stringent
QA/QC procedures.
Faciliity 28
High concentrations of zinc, copper
and lead in influent flow to the
POTW.
Potential impact on surface
water quality.

Facility adopted more stringent
QA/QC procedures.
Facility 29
High concentrations of zinc and
copper in influent flow to the POTW.


The facility could not comply with
POTW limits and now they haul
waste by truck to Indianapolis.
Facility 30
High concentrations of total
recoverable phenolics, TSS, BOD, pH,
single phenol compound, COD, free
cyanide amenable to chlorination and
bis(2-ethylhexyl)phthalate discharged
to receiving water.
Potential impact on surface
water quality.
The facility has been
subject to administrative
and penalty orders. A
violator may have to pay
$2,000 per violation per
day up to $10,000 for
administrative orders.
The facility has had no significant
violations recently.
Facility 31
High concentrations of organics and
benzene discharged to receiving
water.
Potential impact on surface
water quality.

The facility has not committed
any violations for a number of
years.
Facility 32
Facility had a reporting problem but it
was not a situation of non-compliance.

The issue was resolved
without any major
problems to the POTW.

D-6

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Tabic D.l. Reported Permit Violations and Other Diseharjje Effects From CWT Faeilities
Site
Reported Violation
Impacts on Receiving
Waterbody or POTW
Actions Taken
Current Status
Facility 33
High concentrations of chromium
(7.42 mg/L), nickel (2.97 mg/L), zinc
(5.17 mg/L), and nonpolar fats, oil and
grease (407.3 mg/L) discharged to
receiving water.
Potential impact on surface
water quality. POTW placed on
304 (L) short list.
The facility was fined
$4,840 which covered all
post-violation charges,
including follow-up
inspections, sampling and
analytic tests.
The facility and POTW have
been unable to reach a negotiated
settlement.
Facility 34
High concentrations of copper, zinc,
chromium, lead, nickel and fluoride.
Potential impact on surface
water quality.
A telephone conversation
and a notice of violation.

Facility 35
High concentrations of sulfate,
phenols and pH.
Potential impact on surface
water quality.
Compliance Telephone
Memorandums.
The facility has some equipment
upgrades to improve the
efficiency of the facility, not to
address compliance issues.
D-7

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