Document 6w0X0oj1MLewoYzVNGXNd1OVg

REGULATORY ASPECTS OF THE CONOCO ABERDEEN PVC PLANT AQAT STUDY Federal Water Polution Control Act of 1972 Passage of the Federal Water Pollution Control Act of 1972, was the principle motivating force in the current effluent treatment programs. The regulatory focus of the U.S. Environmental Protection Agency (EPA) was shifted by the 1972 amendments from effluent limitations derived solely from water quality standards to single number technology-based effluent limitations on an industryby-industry basis. These technology-based effluent limitations provided the base level treatment to be met by all dischargers. These effluent limitations were to be achieved in several steps. By July 1, 1977, existing dischargers are required to apply the "best practicable control technology currently available" (BPT) and by July 1, 1984, existing dischargers are required to apply the "best available technology economically achievable" (BAT). By July 1, 1984, existing dischargers are required to apply "best conventional pollutant control technology" (BCT). In addition, "new source performance standards" (NSPS) are to be met if the new point source's construction commenced after promulgation of the standards. At first it appeared EPA was going to establish effluent limitations in phases by first issuing guidelines under Section 304 of the Act followed by issuing limitations under Section 301. However, EPA combined the phased approach and issued regulations known as "Effluent Limitations Guidelines" for each regulated industry. The organic chemicals industry was one of these designated industries to be regulated. The 1972 amendments included a timetable for issuing these effluent limitations. By 1976, EPA had not met most of the deadlines and consequently was sued by sev eral environmental groups. The lawsuit resulted in a "Settlement Agreement" (NRDC vs. Train) requiring EPA to develop a program and adhere to a schedule in promulgating effluent limitations guidelines and standards for 65 toxic pollutants (126 priority pollutants) for 21 industrial categories. Many of the basic elements of the Settlement Agreement program were incorporated into the Clean Water Act 1977. Plastics and Synthetics Point Source Category Effluent Limitations Guidelines The Aberdeen PVC AQAT study was conducted between September and December of 1980. At this time, promulgated effluent limitations for PVC plants are found under 40CFR 416 Subpart A-Polyvinyl Chloride Subcategory. The only effluent character istic for which limits are set is pH within the range of 6.0 to 9.0 standard units. SAL 000084563 Organic Chemicals and Plastics and Synthetic Fibers Category Effluent Limitations Guidelines On March 21, 1983 EPA proposed the effluent limitations guidelines for BPT, BCT, BAT and NSPS for the organic chemicals and plastics and synthetic fibers (OCPSF) industry point source category in the Federal Register (48 Fed. Reg. 11828-11867). According to the EPA Regulatory Agenda published in October 17, 1983 (48 Fed. Reg. 47883) EPA expects to promulgate these regulations by March 1984. However, accord ing to EPA, this rulemaking may not take place before early 1985 due to the enormous response EPA received on their proposal. In addition, industry requested EPA to update their economic data base from 1976-1977 data used in the proposal to more current data. The Conoco Aberdeen PVC Plant is considered in the Plastics Only Subcategory. The proposed effluent limitation guidelines for this subcategory are provided in Table I and calculated effluent limits are given in Table 2. Aberdeen PVC Plant NPDES Permit On May 1, 1974 Mississippi obtained approval from EPA to administer their own llPDES program. The current NPDES permit was issued on September 1, 1981 and will expire March 31, 1986. The effluent limits for this permit are provided in Table 3. Sev eral unique features of this plant's permit are the seasonal limits set for BOD5 and COD in Winter and Summer and the bioassay requirements to determine if the plant's waste stream is toxic to the receiving stream. The primary reasons for conducting the AQAT study centered on the plant's plans to increase manufacturing capacity which would result in an increased load on the treat ment system. In addition, the plant's NPDES permit had been altered by the State to include Winter and Summer limits for BOD5 and COD. Daily average discharges for BOD5 and COD were reduced by 18 percent and daily maximums were reduced by 8 percent for the Summer (i.e. May 1 through November 30). Mississippi Water Quality Standards and Waste Load Allocations The Aberdeen PVC plant discharges into the James Creek which flows into the Tombigee River. The designated use for the James Creek is fish and wildlife propagation. Water quality criteria for the creek are: a. Bacteria: Fecal coliform shall not exceed a geometric mean of 2000/100 ml, nor shall more than ten percent (10%) of the samples examined during any month exceed 4000/100 ml. b. Specific Conductance: There shall be no substances added to in crease the conductivity above 1000 micromhos/cm for fresh water streams. SAL Q0G064564 -2- TABLE 1 PROPOSED OCPSF EFFLUENT LIMITATIONS GUIDELINES PLASTICS ONLY SUBCATEGORY Technology BCT & BCT BOD5 (mg/1) TSS (mg/1) pH (S.U.) BAT (ug/1) bis (2-ethylhexyl) phthalate Chromium Vinyl Chloride Max. For Any 1 Day Max. For Monthly Avg. Avg. of Daily Values for 4 Consecutive Monitoring Days 49 22 117 36 Within the range of 6.0 to 9.0 at all times. (--) (--) 100 (--) 110 (--) 50 (--) 50 60 (--) Source: 48 Fed. Reg. 11862 - 11863 Note: A dash (--) signifies no limitation. 00008*565 -3- S TABLE 2 CALCULATED EFFLUENT LIMITATIONS FOR THE ABERDEEN PVC PLANT BASED ON THE 1983 PROPOSED OCPSF EFFLUENT LIMITATIONS GUIDELINES Effluent Characteristics BOD5 TSS pH bis(2-ethylhexyl) phthalate Chromium Vinyl Chloride BPT & BCT Limitations-*- Max. For Any One Day lbs/day Max. For Mon. Avg. lbs/day 588 264 1404 432 Within the range of 6.0 to 9.0 at all times. BAT Limitations-*- Max. For Any One Day lbs/day Avg.of Daily Values for 4 Consecutive Monitoring Days lbs/day (~)2 (--) (--) (--) <--) (--) (--) (--) (") (--) (--) (--) 1.2 1.32 0.6 0.6 0.72 (--) Notes: 1. Calculated effluent limits based on 1000 gpm flow rate. 2. A dash (--) signifies no limitations have been set. -4- &AL 0000^S6S TABLE 3 M IS S IS S IP P I NPDES PERMIT ABERDEEN PVC PLANT (EXPIRES MARCH 3 1 , 1 9 8 6 ) vT O O X 30 oc mE --CI C >N oo -6 -- (A XI < .-m CM o o << -N* zz << zz << zz X /-V co --< -- oc CO E C-> I CO flj 'O--C -O O U5 CO X o <r O CO c 3 XO CM r- <f uo ^ co r- CM CO co >3" << zz << zz --o O -^M CM cm co --' CM CM UO --i CM --< CM Xi -m <t r -m CM oo oo mm CM X) <r-f OX' X co <--. x< zz < < < < ">* -*. uo Z Z Z Z CO < < <<U "M M, V. --. Z Z Z Z uo << '--. -- zz < < < < (J M.V M.V.* z z z z uo co co co CO -- CM uO O' co r- X X uo oo r- uo A UO 00 o 4-1 O X O a; 00 c<0 tM V X c X 3 << V M, zz oo CM CM << ZZ << V. V zz uo o o-- uo c o-- X CM < --<. zz CM 04 od Ml <3 cm cm CM CM co <T -3 CM CM -<----<-zz --> MI t >, C --I eO 00 T3 -- - Xtfl --< CM CO CO Mj1 --< O co O Mt 00 CM CO X -m <r r --4 cm /-m X X-- UO -m <1- X r- o*. X CO uo uo uo o O -m I I I X uo -> a C 4-1 ou -aH nUjl MMmM J<Zc W cJ> ag 00 3 6 ai E 00 3 CO E o> E 00 3 <0 E XX C flj ii u ai 4i Q X X -O 60 m/ I Qu i-c >s --I c-M U X 0) >M -- O O ^ X >><"< 3 *j 4J x a> 4j 4) U U > O 10 P-* u CM | -M O CJ v c >> i a J W c in o ..M -H 41 oa a > a H << . --. ZZ << zz << zz oE oo 3 <o E > <0 < se >. >. 41 E 00 3 co l-l -wE4 W 41 > X CO <Z ai c aE, h i oo -h o< o XE >41 X 41 <0 >o X Z <n c :X O | 00 *h 3 4J O cq U 4J ' X M-l 4J g rM U >> O E 41 CO h Q X 4> H* tf) CO 41 u n q ma u C um E 01 T3 T3 -I CQ 1m 3 4) 41 C 10 3 -444 MC CM M00JJ xo UM U-4 UM cf) co 41 (A <n I >. >s ^ u U X 4) 4) i cm m uo x SAL 000084567 c. Dissolved Solids: There shall be no substances added to the waters to cause the dissolved solids to exceed 750 mg/1 as a monthly average value, nor exceed 150 mg/1 at any time for fresh water streams. d. Phenolic Compounds: There shall be no substances added which will cause the phenolic content to exceed 0.05 mg/1 (phenol). The James Creek has a QlO/7 of 0*0 cfs. Due to the lack of EPA effluent limita tion guidelines, with the exception of pH, the organic loading on the creek, lim ited by the permit, was based on the results of the waste load allocation model. The output of this model was used to set limits for BOD5, COD, TSS, Ammonia and dissolved oxygen which are given in Table 3. Future Permit Action According to the Mississippi Wastewater Permit Regulations paragraph 23.(e) Terms and Conditions of Permits: Effluent Standards and Limitations "...The effluent limitations promulgated by ERA ... shall become immediately enforceable as if a duly promulgated regulation of the Commission." Similar language appears in ; Part III A.- Other Requirements of the plant's permit. In short, this language means that once EPA promulgates the Organic Chemicals and Plastics and Synthetic Fibers Category Effluent Limitations Guidelines the plant's NPDES permit shall be modified to reflect the more stringent effluent limits. Table 4 compares the current limits to the proposed 0CPSF limits which if promul gated would become the new permit limits immediately. In addition, the BAT limits have been set on phenol, acrolein, ethylbenzene, cadmium, lead and cyanide. If any o these pollutants are discharged from the plant, effluent limits will be set in the modified permit. Once the OCPSF effluent guidelines have been promulgated a careful review of the effluent limits should be accomplished immediately. According to Hugh Wise (Organic Chemicals Branch, Effluent Guidelines Division, EPA Office of Water Regu lations and Standards), the OCPSF Effluent Guidelines are expected to be promulgated in March 1985. -6SAL 000084568 TABLE 4 COMPARISON OF CURRENT NPDES PERMIT LIMITS TO THE PROPOSED OCPSF EFFLUENT LIMITS Effluent Characteristics BPT & BCT Limitations-- bod5 Daily Average Daily Maximum TSS Daily Average Daily Maximum pH Current (4/30/83- 3/31/86) NPDES Permit Limits Proposed OCPSF Effluent Limits Winter 431 (32) 800 (43) Summer 357 (26.5) 744. (40) 001 674 1396 002 & 003 (100) (200) 6.0 to 8.5 264 588 432 (36) 1404 (117) 6.0 to 9.0 BAT Limitations-- Bis(2-ethy1-hexy1)phthalate Daily Average Daily Maximum Vinyl Chloride Daily Average Daily Maximum Chromium, Total Daily Average Daily Maximum Report Quarterly Report Quarterly Report Quarterly Report Quarterly Report Quarterly Report Quarterly 0.6 1.2 (-) 0.6 0.72 1.32 1. Limits are given in lbs/day (mg/1). 2. Calculated effluent limits based on 1000 gpm flow rate. SAL 0000S4569 -7-