Document qm9emBpJppzX8GeXjpbdR6Opx

SP am ii. ji p ;VWi h iiip ip iip p p p p p m w p w p p ^ LIA14397 - -. .-^ a oorr . i RQP08AL roa ISWKTSIAI VASTS fTtBT st4jr Group 9, aoarXBKKB MRAU (tSCKSIGAL KOTOVAl) TO rami. Hun QUAtm Aaaramxxm mxaaoastAi vsoncnov Aonar n HSKMBI TO arr *. v a n - 53* iiamaa bt GUaSAX AID ASSOCIATE), DC. 223 Vsst Jackson Boulrvard Chicago, Illinois 60606 Talapbooa 312-939-0568 BCCBOO 12, 1970 r w.iPAW* y^npsppwianiM)ii.. 1 iij w w h iii mi 11 sjpm mmmm .^ u~S-<b. :V ._ LIA1A398 ... -------- STATPCXT or Bg PROBLEM Ths m4 to establish regulatory standard* aad requirements for Industrial vutivtttr effluents bu been detailed la tba 'Introduction* aad tha "Statement of tba Problem" aactlona of tTf Ho. VA 71 - 33k; It la somarlied below fc ordar to Indicate that GURQtAM AXD A880CUIM, XHC. (OfcA) understands tba nature of tba problaa and tba scope of tba proposed study. lbs approximately 300,000 water-using factories in tba Cblted States diecharge each day from three to four times as much oxygen-consuming wastes as all of tba sewered population of tba united States; futbernore, tba output from this primary source of smter pollution Is growing at a rata several times t faster than tba relume of sanitary sewage, bitting State-federal water quality standards require that all significant waste discharges recalve the beat practicable treatment; for industrial wastes this has been defined as "at least the equivalent of secondary treatment.* However, Interpretation of this requirement has been difficult because of the wide diversity of Industrial vestas. To retard the rapid deterioration of our streams and waterways, tba fWQg has provided for the establishment of effluent requirements within Its legislative proposals. To carry out this ciwltnent. It Is necessary that tba FVQd develop guidelines for such requirements tblcb can be passed on to end Incorporated Into State effluent standards. lbe prlnary purposes of this proposed Industrial waste study are: a) to atandardise the evaluation of effluents from tba subject Industry; and b) to provlds guidelines to establish effluent criteria for the Industry. In order to achieve these goals and to develop quantifiable, enforceable, and technically reasonable standards, It is necessary that tba Industry be elasslfled according to Its standard manufacturing processes, that the standard raw vasts load be determined for each of tbase standard manufacturing processes, and that the mmmmma mrmm mm*' I rnmmmmmm PW L IA14399 -- " ~x-^---- ---'lili i nfr HHmamStii ft but level of treatment and th beat available level of treatment be defined. In addition. It la neceiaery that, where currant data ara not auffleiant, a plan for future atudjr be developed to aaaura that tha final effluent atandaxda ara quitahla. Tha TW^l haa proposed that criteria oa thlch tha affluent standards are to he based ahall be aatahllahad by February 25, 1971. Becauae of thla severe tla reatrletloo, the contractor will be forced to rely on available data; there can be no opportunity vlthin thla tine achedule to develop nee data. Therefore, tha eoetractor aunt vtiliae hia beet ability to Identify valid data aoircaa and to czerciia aound Judgement in aelectinc and analysing that data. Such Judgement must be baaed on hia own experience vlthin the industry, and on hla experience in induatrlal wastewater treatment. ft The apeciflc entrees of information and the approachea thick OLX vill uae lx thla propoaed atudy are detailed in eubaequent aectiona of thla dociaaot. However, becauae tine restrictions and tha very nature of tha atudy do not permit tha development of unique or novel approachea, tha flrm'a quali fication* nd experience, deeerlbed in tha pre-propoaal docunanta aubnltted on December 2 and amended oa December *, 1970, aunt be coo*liered a* tha major portion of tha entire proposal. * km 9 up Mb wmrnmmmmmmmmmmmmmmm LI A14400 siATPoarr or want - OM's proposed plan of operation for this study involves fir* major atop*, aa follow*i 1. Definition of the industry. 2. Definition of standard manufacturing processes. 3. Determination of standard nx vaat* load* (UHL). h. Evaluation of applicable wastewater traataenta and control*, a Specification of baa* levels of tr*atmmt. (Kff). 1 b Specification of beat available lrral* of trestaaot (Uf), > 5. Preparation of final report. Sadi of thee* atepa ia daacribed in detail belov, including the aeurcea of lnforaatlon, and evaluation of the validity and applicability ot the data. Manpower allocation* are prelected in a later section. * It la planned that Step* 1 to h, as liated above and described , in the following paragraph*, will have been carried far enough for a verbal i presentation by February 23, 1971. 1 Definition cf the Industry. As the initial atage of this project, the industry itself most be defined to the mutual satitfactlon of the FVqA teen and the investigator. Belated Industrie* and certain specific segneate of this Industry will be excluded fron the study; for exanple, it will not be realistic to all minor segnents. this lection nist be a natter of Judgement - primarily GAA' judgement, but should he agreed upon at a very early stage. i The industry itself nay he divided Into a nuabar of segnents, each significant of itself, and each differing from the others ia t certain wastewater-related aspects. 3 I II ilJjlllU.LIlllJ.:iJlUllipi.iS iiimm iPinPNPP m LIA14401 t-r'A;S~ * > Dggrmog or na rouenr - study orwa 9 A. Br specific metal. 1. Aluminum 8. Copper 3. line k lead 3 Allay*: Iriu Celt: (a) because need primarily la ferroalloy*: winmH, rhrcmlas. nickel, molybdenum, cobalt, ranadlf. (b) because too snail a segment of tba Industry: eodlae, tin, magneelia, uraalxa, antimony, titanium, tungsten, silver, cadmium, mercury, bismuth, columblim, tantalm, tborlsa, rare earth*, and preclou* metals. B. Br process. 1. Primary smelting and refining. 2. Secondary ameltl^ end refining. 3* Bolling, dreeing, extruding, and other forming; and ancillary processes, fc. foundry operations. (felt: Mining, Including leaching. fabrication by other than forming operations; e.g., asseafcllng, electroplating, and costing. t */ Pf wmmmmmimmmm bk. 'Mmljfri mmrnrnmmmmm*. LIA14402 A tentative but probable outllna la given la Tabla X, on tba following page. The primary sources of Information and data for definition of the Industry (a* mall aa for Btapa 2, 3. end 4) will be the peraooal experience of O&A's principal. Dr. C. Fred Ournhaa, and at tba Aaaoeiatea. Thia will be supplsmented bp eeoaultatioo with otbera experienced in thia lndustiy, oat of whom are personally known to QiiA'a principal and Aaaoeiatea, aad ic m at whom are specifically and in Part A of Table XX, on page 6. Thoee narked with as asterisk () bare agreed to mrk with QU on this study} the otbera bare not all been contacted, but are peraooal friends and will probably cooperate. Otbera nay be added to the list aa the study progresses. further information and data will be obtained fron the appropriate federal agencies (notably FVQi) and fron pertinent State authorities} bet It is not possible to name ell of these at this tine. Significant additional data will come to tbs project fron Industry or trade eseociatlons, which will play an important role la the study. Bi more obvious of these era nmwd In Part S of Table H, eo page 6; there nay be others that can and will contribute. Contacts have been initiated with these associations - in stoat instances a revival of previous cooperation; but the tine schedule for preparation of this proposal does not permit details. finally, the ulttaste source of data will be the Individual cooperating Manufacturers. These will be selected with the advice of CIA's Associates tad of federal and State regulatory authorities, full cooperation fron tba buslnmss associations la anticipated. Epical companies for this contact are listed in Part C of Table XI, on page 6, but there will be several nore. lfcoae listed in fart C have had previous (or have present) contacts with OAA or Its principal. 9 ...... . '"""a o 1 I W yu .. -yiimi iiaimMiHi mmmmmmr** UIA14403 --------- -- - - ---- ---------- TABU n s o u r c e or mroRmno* - study group 9 A Individuals *bo may be consulted. Iliaa, B.E. (braaa and eoppar) * Butfle, M. (altmlnoa) Oodca, B.F. (braaa aged eoppar) Bupfer, M.K. (braaa aad eoppar) * Parker, AA (saeltlac) TaUaadpe, J.A. (braaa aad eoppar) Walker, C.A. (braaa aad eoppar) I Technical eaeociatlano. Aluial raa Association. Almlma halters Keseerch institute. fc American line Institute Oopper Development Association (fomerlgr Oopper end trui liMttcIl Association). Lead Industries Association. United !Uti Copper Association (fomerljr Oopper Institute} affiliated vltta Americas Bureau of Netal Btatletlea). C Possible eooperatlns cnyaulH. Aluel rum Ccnpany of Aaerica. Aaerieaa SBeltlaf and fteflnlnc Company. Anaconda American Braaa Oonpsngr. Chaaa Braaa and Copper Ooapaagr. Sade-Plcber Industries, Inc. Sc o t 111 Kamifacturine Ooapaagr. 6 m ilHKl t i lin LIA14404 _Ufljass&Jfeaf:c-r: -3 ,agF 6 t 2 Definition of standard manufacturing processes. Standard manufacturing processes will be defined for each major segment of the Industry, as noted In Stop 1, abort. Each mamifacturing plant bu it* own individual system of operation* and processes; It will ba necessary to classify th*e Into a (sail but realistic number of units that are cannon to nost producer*. Xach unit may be a single Manufacturing operation, or It may be a series of such operations that follow naturally la sequence. Ibis classification aust be a Matter of the Investigator's Judgement; it will be based on the waste flows fro* each unit, and specifically on the raw waste loads. Included in the classification scheae will be auxiliary or supporting activities that are cnaamm to a significant portion of the Industry, Including but not limited to water pretreatMent, power generation, and Material handling and storage. The classification will specifically Include ln-plant Material recovery and salvage frcaa waste itresms prior to Its discharge with the plant effluent, when such recovery is standard practice In the Industry. In developing the standard manufacturing processes, primary consideration will be given to existing plants of modern technology. Older plants employing obsolescent processes will be noted but generally disregarded, trends in the Industry, Including foreseeable new technologies, will be taken Into account. Utilizing the above classification of standard manufacturing processes for the Industry as a whole, It will be possible for any Individual producer to Indicate which units are alloyed In his plant, and to quantify them in terms of some standard measure of production. Preparation of the class1flcatlon plan requires detailed knowledge of the Induetry; this is among the capabilities of G&A's principal and Associates, and will be enhanced by tbe additional sources of Information described earlier la 8tep 1 end In Table II on page 6. t y y -v -'-O i % - y-s^i; 3 Determination of atandard raw vut load* (8RVL), Etch atandard manufacturing proceaa, defined in 8tp 2 abort, j produce* a certain quantity of rav vaate per unit of production or throughput and per unit of auxiliary activity, the algnlflcant parameter* for the aubject induatry will be ielected (the** vlll include both hydraulic and quality characteriatlca); and the quantity of each parameter will be expreaeed aa a numerical valua - for example. In pounda of vaate material per pound of production (SSVL). Iheae value* will, in fact, be range* rather than *Ingle number*; where average* or modified average* have significance, in the invectigator's Judgment, thi* will be reported. The range of value* 1* itaelf, to scee degree, a measure of the variability la proceaa control employed In the vaxloua plant*, as well a* a result of differences in plant housekeeping, operating variables, alxe of units, and product parity requirement*. Thl* study will indicate which process controls, tn/QwiUng material recovery and salvage, are normal to the Industry or could become so with reasonable modification of the manufacturing proceaa. The study : will further report, for processes there insufficient data are available, recommended procedures for the future development of such information. The sources of information and data for Step 3 are aa noted earlier, including Table II. Some data are in the literature and in the files of the investigators; other data will'be obtained from the technical associations and the individual plants studied. H Evaluation of applicable wastevater treatments end controls. :1 The vastewater treatments and controls that are available to the 0 1 ........... - ______ , Industry vill be evaluated fro* the viewpoints of applicability, effective' nee*, end reliability. As a remit of thla evaluation, which vlll Include 4 the experience! of a number of manufacturli^ plants, O&A vlll be able to A speclflfy a base level of treatment (BIS) for the industry, or for each i. standard manufacturing process in the industry. Extension of this evaluation by the investigators vill permit ) specification of a best available treatment (ELI) for the industry or for each process. This extension of the study vlll take Into account, or in addition to the experiences of manufacturers with full-seals plants, the pilot plants and bench-acale studies conducted by manufacturers, equipment makers, universities, and other research organisations. Obviously, there is much responsibility on the investigator for a realistic appraisal of procedures that are still in a developmental stage. Total leyact on the environment vlll be considered, including the * effects on atmospheric pollution and the problems of solid wastes. However, these vill be matters for the investigator's Judgement, and vlll not < necessarily be quantified to the same extent as the vaatevater parameters. In a similar manner, data relating the cost of treatment to the level of performance vill be obtained and taken into account whenever possible; although it is not contemplated that this study will include the development of any new data. The sources of information and data for Step % are as described earlier, including Table IX. 9 I t Using the data accumulated during the firit two Booth* of atudy, and covering Step* 1 to 4, a final report vlll be prepared. The report will Include the following chapter*i 1 Classification* 2 Description of atandard procene*, with flow diagrams i 3 narrative on over-all plant make-up 4 Available ln-plant pollution control* 3 SBWl, with narrative 6 Treatment evaluation, with narrative 7 Effluent criteria* -i * 8 Implementation guidelines 9 Implementation example* 10 Joint Bunlclpal-lnduatrlal waate treatment guideline* 11 Besearch and development need* 12 Bibliography (including only material uaed In thi* etudy). * These lection* will be supplied by IV^A, based on oral reporta on Step* 1 to 4, at a meeting about February 25, 1971. The report will Include the information accumulated In 8teps 1 to 4, plu* a general narrative on the Industry necessary for comprehensive evaluation of the Industry. It will contain a complete explanation of the method* used to arrive at industry guidelines, an explanation of the guidelines, and details of the methods to be used to gather additional data where currently available data are Insufficient to support the establishment of guidelines i*. n.iminair imi for effluent standards. It Is anticipated that, If Steps 1 to 4 are completed according to schedule, the report will he submitted by May 28, 1971. 9 10 ai Y-. I MAKPCWER AJXOCATIM . <f 1 Baaed on the five baalc etept outlined and described la the j preceding aectlon ("Statement of Work"), O&A anticipate! the following ran-day requirements to cccplete the project. The** figure* Include only 1 high-level pertonnel - the principal, Aaioclate*, aad consultants. the dirielon of effort anrag the fire etepe cannot be rigid at thle time; la ` fact. Boat of the effort will be directed simultaneously to acre than a ri tingle step. Thla auasarjr la preaented only aa an add for preparation aad verification of the total budget. Bj s unit uaed la the Ban-day. 1 Step Bo Principal Investigator Associate* EditorCoordinator TOOL 11 00 1 22 6 2 10 3 3 10 5 18 J oi b 5 20 6 31 5 10 10 20 b0 -- ---- -- a 21 U6 33 100 * '1 U . 'I "