6287 800R83101
ASSESSMENT OF
PROJECTED WAITER QUALITY BENEFITS FROM
IMPIEMENTATICN OF THE
REGULATIONS DEFINING BEST AVAILABLE
TECHNOLOGY ECONOMICALLY
ACHIEVABLE FOR THE ORGANIC CHEMICALS,
PLASTICS, AND SYNTHETICS INDUSTRY
OFFICE OF WATER REGULATIONS AND STANDARDS
FEBRUARY 10, 1983
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on
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Section 1 Executive Summary and Introduction
Section 2 Ambient Dilution Analysis
Section 3 Expanded Water Quality Analysis
Section 4 Indirect Dischargers Analysis
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This report is a compilation and summary of information from
the following documents:
Environmental Assessment of Fifty Facilities in the Organic
Chemicals, Plastics, and Synthetics Industry Using a Simplified
Water Quality Dilution Model.
U.S. E.P.A., Office of Water Regulations and Standards,
Washington, D.C., Draft Report,
Monitoring and Data Support Division. January 1983.
Environmental Assessment of Indirects Dischargers in the Organic
Chemicals, Plastics, and Synthetics Industry.
U.S. E.P.A., Office of Water Regulations and Standards,
Washington, D.C., Draft Report, Monitoring and Data Support Division
January 1983
Detailed Water Quality Analysis for the Organic Chemicals and
Plastics Industry on the Greens Bayou and Houston Ship Channel.
U.S. E.P.A., Office of Water Regulations and Standards,
Washington, D.C., Draft Report, Monitoring and Data Support Division
January 1983
Detailed Water Quality Analysis for the Organic Chemicals and
Plastics Industry on the Kanawha River.
U.S. E.P.A., Office of Water Regulations and Standards,
Washington, D.C., Draft Report, Monitoring and Data Support Division
January 1983
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EXECUTIVE SUMMARY
The water quality assessment presented in this report
indicates that implementation of the proposed regulation defining
best practicable control technology currently available (BPT) and
best available technology economically achievable (BAT) for the
organic chemicals, plastics, and synthetics industry will likely
result in significant improvements in water quality and are
likely to result in increased recreational opportunities and
reduced health risks.
Analytical Approaches
The assessment includes two levels of analysis for direct
dischargers. The first level consists of simplified water quality
modeling of the impact of discharges from 50 organic chemical
facilities on receiving stream concentrations of each facility's
major toxic pollutants. This analysis provides a general indication
of the extent to which the 41 stream segments receiving wastes
from those 50 facilities will be affected under different control
alternatives.
The second level of analysis consists of a summary of more
comprehensive water quality studies of two streams: the Houston
Ship Channel in Texas and the Kanawha River in West Virginia.
These studies included more complex water quality modeling efforts
1-1
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and evaluations of biological conditions in each of the streams.
Indirect dischargers are assessed by modeling the impacts of
organic chemicals discharges on receiving stream water quality
after treatment by POTWs, both with and without pretreatment.
Actual plant flow, POTW flow, and receiving stream flow were
obtained for three facilities, while four model plants were used
to provide the range of potential impacts for indirects.
Results of the Analyses
The simplified modeling analysis of 41 stream segments
indicates that the projected number of violations of EPA water
quality criteria will be substantially reduced if BAT controls
are implemented. For example, at current discharge levels,
25 of 50 organic chemical facilities would cause violations of
EPA water quality criteria under low flow conditions. At BPT
discharge levels, 17 facilities would cause violations, and
at BAT discharge levels, only 5 facilities would cause violations
of water quality criteria.
The results from the two more comprehensive assessments are
limited in scope. In the Houston Ship Channel the organic chemicals
industry does not represent the major source of pollution within
the area. Simple dilution calculations predict that instream
1-2
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water quality criteria violations to both freshwater and saltwater
aquatic life will decrease as the degree of treatment is improved
(current, BPT, BAT). For the Kanawha River system water
quality improvements have been observed in the past decade; however
direct correlation between improvements in water quality and
upgraded treatment levels for the organic chemical and plastics
industry cannot be proven. Although present biological quality
of the area appears to be relatively good, further reductions in
pollution loads from all sources including organic chemicals
facilities will likely result in further increases in the number
of high preference game fish.
The models of both the actual indirect dischargers and the
possible ranges of indirect dischargers indicate that the
application of pretreatment before discharge to a POTW will
benefit both the POTW and the receiving stream.
1-3
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INTRODUCTION
The following analysis is an assessment of the water quality
benefits which are projected to result from implementation of the
proposed effluent guidelines regulations for the organic chemicals
industry. This type of assessment is part of the requirement
for a Regulatory Impact Analysis, which Executive Order 12291
directs be prepared for all major regulations.
The BAT regulations cover primarily the specific toxic
priority pollutants identified by the 1977 Clean Water Act.
Therefore, this analysis focuses on those pollutants, although
reduction in other pollutants such as total suspended solids
(TSS) and biochemcial oxygen demand (BOD) have also been considered
in some cases.
The water quality benefits assessment included two analyses
for direct dischargers. The first analysis provides projections
of ambient water quality conditions corresponding to different
treatment levels for organic chemicals industry discharges.
These projections, which are made using simplified modeling
procedures, cover 41 stream segments and 50 organic chemicals
plants. These plants, which account for approximately 11 percent
of the total U.S. organic chemicals production, were selected
on the basis of having adequate stream flow data and sufficient
facility data to predict discharge levels. This analysis provides
1-4
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projections for the "Best Available Technology (BAT) discharge
levels, for the "Best Practicable Control Technology" (BPT)
discharge levels, and current effluent levels.
The second analysis consists of detailed water quality
analyses of two stream segments under different treatment technology
assumptions. These stream segments (the Houston Ship Channel in
Texas and the Kanawha River in West Virginia) are evaluated in
terms of current water quality conditions, including biological
conditions, and in terms of the changes which are projected to
occur in those two segments with implementation of higher treatment
levels for organic chemical industry discharges. In addition,
these analyses provide qualitative discussions of what the changes
in water quality conditions might mean in terms of increased
recreational opportunities, improved aesthetics, and reduced
human health impacts. The targeted BAT limitations used in
both analyses are long term averages ranging from 25 to 75 ppb
for all pollutants, and are not the exact BAT limitations proposed.
All updates to these analyses will include the proposed BAT
limitations.
The agency anticipates expanding the scope of this report for
promulgation of the regulation to include the potential impact
on drinking water sources, the comparison of in-stream
concentrations with state standards, and an informal survey of
the state and local officials familiar with the streams studied
1-5
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for their perceptions of how the organic chemicals industry
discharges are affecting water quality.
The assessment of indirect discharges provides a comparison
of the potential impacts of organic chemical plants discharging
their effluents to POTWs, both with and without treatment. The
benefits derived from the application of pretreatment technologies
are only presented in terms of the reduced impact of this industry
on the receiving stream, but it is also likely that reduced
inhibition problems would provide secondary benefits from more
efficient treatment of the total POTW discharge to the receiving
stream.
In a separate study now underway, EPA is attempting to
express the environmental benefits of this regulation in monetary
terms. The study will attempt to place dollar values on the
specific benefits described in the two detailed water quality
analyses discussed above.
1-6
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AMBIENT DILUTION ANALYSIS
*
Introduction
To project the environmental benefits from the implementation
of the effluent guidelines regulations, a simplified water quality
model was used to determine the potential impacts of priority
pollutants discharged from 50 organic chemicals and plastics
facilities in terms of increases in receiving stream pollutant
concentrations. This analysis provided a general indication of
the extent to which the 41 stream segments receiving the wastes
from those facilities could be affected under different control
alternatives. The facilities for this analysis were selected on
the basis of available facility data to predict discharge levels
and adequate stream flow data. Since this analysis requires
stream dilution calculations, facilities on hydrologically complex
waters such as bays, estuaries, lakes, and oceans are not included,
This analysis provides projections for the BAT discharge level,
for the BPT discharge level, for current effluent levels, and
for base case or raw waste levels.
2-1
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Modeled Plant Concentration Data
For the plants studied (see Table 2.1), the concentration
data for raw waste, current discharge, BPT discharge, and BAT
discharge were projected using a computer model. The computer
model estimates the concentration of the priority pollutants in
each plants' total effluent based on the products and processes
for each plant and on the assumed treatment level.
The model was developed from the Generalized Plant Configu-
rations (GPCs) for major sectors of the organic chemicals,
plastics, and synthetics industry. The GPCs provide a typical
process configuration, material and pollutant flow, and manufacturing
cost structure for average manufacturing facilities which can then
be combined and tailored to describe specific plants.
The model also includes data which describes the removal
efficiency and cost for a variety of effluent control devices,
including single and double stage activated sludge systems,
filtration, ion exchange, steam stripping, carbon adsorption and
others. The model can place these controls, both alone and in
various feasible combinations, into process-specific, multi-process,
or total plant effluent streams. The exact configuration of
controls can be specified or the model can determine the most
cost effective controls to use in order to meet specified effluent
mass or concentration limits. Information about the current
2-2
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Table 2-1
The Fifty Plants Assessed Using the
Simplified Water Quality Dilution Model
Plant NPOES Hunter
Plant Name
AL0003026
CT0000086
CT0003131
IA0000191
IA0000205
IL0001929
KY0001112
KY0002305
KY0002780
KY0024643
LA0000191
LA0000281
LA0000761
LA0000692
LA0002933
LA0003689
LA0005762
LA0005924
LA0029%3
HI0000540
HI0000868
M00003140
NC0003760
N00000256
OH0002283
PA0012769
SC0001791
SC0002305
SC0004162
TN0000442
TX0004669
TX0004839
TX0005835
TX0006068
TX0006297
TX0007536
TX0053813
Courtauldo N. America - Mobile
American Cyanamide Co.
DOW Chemical - Allyn's Point
Chemplex Co. - Clinton
Monsanto Co. - Muscatine
Borg-Warner Corp. - Linbar Plant
Borden Chem. - Louisville
Rohm and Haas - Louisville
Stauffer Chem. Co. - Louisville
Custom Resins - Henderson
Union Carbide - Hahnville
Borden Chem. - Geismar
PPG Inc. - Lake Charles
Rubicon Chem.
Vulcan Materials
Hercules Inc. - Lake Charles
Shell Norco
Dupont - La Place
Gulf Oil
BASF - Wyandotte
DOW - Midland
Cook Paint & Varnish Co. - KC
Dupont - Kinston
Union Carbide Corp.
General Tire Rubber Co.
Rohm and Haas - Bristol
American Hoechst Corp.
Fiber Industries - Greenville
Fiber Industries - Palmetto
Alpha Chem - Colliersvilie
E.I. Dupont DeNemours - Beaumont
Gulf Oil - Orange
Texaco Inc. - Port Arthur
Arco/Polymers Inc. - Houston
Arco/Polymers Inc. - Port Arthur
Phillips Petroleum Co. - Sweeny
Shintech
2-3
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Table 2-1
(continued)
The Fifty Plants Assessed Using the
Simplified Water Quality Dilution Model
Plant NPDES Number
Plant Name
TX0059447
VA0001601
VA0001856
VA0002208
VA0005312
WV0000132
WV0000370
WV0000787
WV0001112
WV0001678
WV0002313
WV0002399
WV0005169
DOW Chemical - Freeport
Oupont - Martinsvilie
Thiokol Fibers Div.
Avtex Fibers, Inc.
Allied Chem. Corp. - Chesterfield
Goodyear Tire & Rubber Co. - Point Pleasant
Pantasote Co. of New York Inc.
American Cyanamide - Willow PI.
Novamont Corp.
Avtex Fibers, Inc.
Diamond Shamrock - Belle
Dupont - Belle
hobay Chem. Co. - New Martin
2-4
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controls in place at the actual plants of interest was obtained
from EPA permit files and from discussions with EPA and state
personnel.
Receiving Stream Flow, Plant Discharge Flow, and Ambient Water
Quality Data for Reaches Studied
Receiving stream flow data were obtained from a W.E. Gates
study which contains calculated mean and low flow statistics
based on best available flow data for reaches throughout the
United States.
The discharge flow for the plants studies in this analysis
were obtained from the Industrial Facilities Discharge (IFD) data
base.
Water quality data were obtained from EPA's STORET water
quality data base. All available monitoring data for priority
pollutants, hardness, pH, and temperature were obtained from the
water quality stations located upstream and/or downstream of the
studied plants. The water quality data obtained from the upstream
stations of the plants under study were used to determine the
ambient background concentration of the priority pollutants
detected in the effluents.
2-5
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Decay Rates for Selected Priority Pollutants
Decay constants (or coefficients) were developed for 18
priority pollutants as shown in Table 2-2. These decay constants
were based on the estimated or measured half-lives for the dominant
processes affecting the pollutant's fate and distribution in an
industrialized reach into which effluents from more than one
source are discharged. The data for the half-lives and the
information for deriving the dominant processes in an industrialized
reach were obtained from the document "Water-Related Environmental
Fate of 129 Priority Pollutants" by Callahan et. al (1979).
In projecting the decay constants for a selected pollutant
it was assumed that, in a polluted industrial reach, molecular
sites of sorption for the pollutants on suspended and bed sediments
will have been saturated; thus, preventing any further effect that
the bed sediment would have in removing the pollutants. Other
processes such as photolysis and oxidation will be negligible in
their effect on the environmental fate in a polluted industrial
river, and hydrolysis for all the organic pollutants selected
would be a very slow process.
Water Quality Criteria
Ambient water quality criteria (WQC) for the protection of
aquatic life from both acute and chronic effects and for the
2-6
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Table 2-2
Estimated Decay Constants (K) for Nineteen Priority Pollutants
Dominant Fate Process
Pollutant (Industrialized Reach)
Arsenic
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Zinc
Phenol
2,4,6-Trichlorophenol
1,2, 4-Tri chl orobenzene
Bi s (2-ethyl hexyl Jphthalate
Di-n-butyl ph thai ate
Tet rach 1 oroethy 1 ene
Tri chl oroethy 1 ene
Chloroform
1,1, 1-Trichloroethane
Acenaphthylene
Dilution
Dilution
Precipitation
Dilution/Sorption
to Detritus
Volatilization
Dilution/Sorption
to Detritus
Sorption to Suspended
and Bed Sediment
Dilution
Sorption to Suspended
and Bed Sediment
Biodegradation
Dilution/Sorption
to Detritus
Volatilization
Dilution
Dilution
Volatilization
Volatilization
Volatilization
Volatilization
Dilution
Half-lives
(davs)
4.7
4.7
0.01-1.0
4.7
0.5-1.2
4.7
2.4-4.7
4.7
2.4-4.7
0.09-0.17
4.7
0.04
4.7
4.7
0.02
0.014
0.014
0.04
0.02
Degree
Decay of
Constant Confidence
0.15
0.15
0.69-69
0.15
0.58-1.39
0.15
0.15-0.29
0.15
0.15-0.29
4.1-7.7
0.15
17.3
0.15
0.15
34.6
49.5
49.5
17.3
34.6
Medium
Medium
Low
Low
High
Low
Low
Medium
Low
Medium
Low
Medium
High
Medium
Medium
Medium
Medium
Medium
Low
2-7
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protection of human health were developed and published by the
Criteria and Standards Division (CSD) in November 1980. For
mercury and beryllium, revised ambient water quality criteria,
as listed in 46 FR 40919 (August 13, 1981), were used. The
ambient water quality criteria may be subject to revision on a
local, site-specific basis; however, the national criteria were
used in this assessment as the basis for determining the environ-
mental significance of each pollutant. Where the criteria levels
vary with hardness, local hardness data were used to establish
the appropriate level.
If a pollutant had no established ambient water quality
criteria, then toxicity level values based on the lowest acute
and chronic toxic concentrations for freshwater organisms reported
in the November 1980 Ambient Water Quality Document were used to
assess the potential toxic effect on aquatic life.
Calculations and Assumptions Used in Stream Dilution Analysis
The priority pollutants discharged from the organic chemicals,
plastics, and synthetics industry were analyzed using a simplified
stream dilution computer model for the following scenarios at
both mean and low stream flow conditions:
2-8
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• raw waste
• current discharge
• BPT discharge
• BAT discharge
The following calculations and assumptions were used in the
simplified dilution model:
1. It is assumed that there is complete mixing of discharge flow
and stream flow across the stream at the discharge point.
This results in calculation of an "average stream" concentration
even though actual concentrations vary across the width of
the stream.
2. To calculate the diluted in-stream concentrations below the
first discharge or the only discharger studied on a reach,
the analysis considered two scenarios: a) the upstream
concentrations for all the pollutants analyzed equal to zero,
and b) the upstream concentrations for the pollutant analyzed
equal to the ambient concentration data where available or
equal to zero.
3. For all plants studied, it was assumed that the process water
was obtained from a source other than the receiving stream.
2-9
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4. The in-stream dilution concentration at mean and low stream
flow was calculated as follows:
CDX = (CSV) (On) + (CPV) (Qp) (2-1)
(Ql + Qp)
CDX = instream concentration (ug/1) of pollutant x,
CSX = ambient concentration (ug/1) of pollutant x upstream
of outfall
Qj^ = stream flow (low or mean in MGD)
CPX = plant concentration of (ug/1) pollutant x
Op = plant flow (MGD)
5. For multi-plant stream reaches, the initial background
concentration is either equal to the ambient data available
or equal to zero. The in-stream dilution concentration
for the initial plant is calculated as shown in equation
2-1. For all subsequent plants on the stream reach, the
in-stream values for the upstream plant are used
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as the background values in the next downstream plant (unless
a decay coefficient is available in which case it is applied)
and the stream flow (mean or low) is increased by the previous
plant's discharge flow.
6. If the decay coefficient is not available for a pollutant,
the pollutant is assumed to remain in the water column for the
length of the evaluated stream reach.
7. If the decay coefficient value is available, a secondary
calculation involving exponential decay is used to determine
background concentrations for all downstream plants on a
river reach. The equation used for determining the background
concentration at the downstream plant for the pollutants with
decay coefficient data is as follows:
CRx (ug/1) = CDx e exP (~K (A miles/velocity) (2-2)
where, CRX = the decayed in-stream concentration (ug/1) at a
specific distance from the point of outfall,
CDX = the initial in-stream concentration (ug/1) of
the pollutant
x as determined by equation 2-1.
2-11
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K = decay coefficient (Table 2-2)
A miles = the distance between the initial outfall of
pollutant x and the point at which the decayed in-
streara concentration of pollutant x is to be determined.
Velocity = velocity of river (miles/day). For this
study, the velocity of all reaches studied was assumed
to be 8 miles/day.
Summary of Results
Table 2-3 summarizes the number of pollutants which exceed
criteria in the individual plant studies and in the multi-plant
reach studies, respectively. Tables 2-4 and 2-5 summarize the
results of the dilution analysis model for the individual plant
studies and for the multi-plant reach studies.
The water quality projections indicate that the reduction
in effluent concentrations achieved by going from current to BPT
and from BPT to BAT discharge levels will result in substantially
reduced violations of EPA water quality criteria. Violations
have been calculated on an individual plant basis to indicate
the number of situations where a single facility is projected to
exceed the water quality criteria. For example, at current
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discharge levels, 25 of 50 organic chemical facilities would
cause violation of EPA water quality criteria under low flow
conditions. At BPT discharge limits, 17 facilities would cause
violations, and at BAT discharge limits, only 5 facilities would
cause violations of water quality criteria.
In addition to the priority pollutants studied, there are a
large number of other toxic pollutants found in the effluents of
the organic chemicals, plastics, and synthetics plants; however,
these were not included in this analysis because they were generally
found only in low concentrations or because there was insufficient
toxicity data to evaluate their potential effects on human health
or aquatic life.
The simplified water quality dilution model requires stream
dilution calculations; therefore, facilities on hydrologically
complex waters such as bays, estuaries, and lakes were not included.
2-13
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TABLE 2-3
Number of Pollutants Which Exceeded Criteria in the
Dilution Analysis Study Completed with the Initial Background
Concentrations Equal to Zero for the Fifty Plants in the
Organic Chemicals, Plastics, and Synthetics Industry
Number of Pollutants
Plant Code
7-01
2-02
3-10
3-12
3-15
3-16
7-18
5-19
5-20
3-22
7-31
7-33
7-36
1-37
7-40
5-41
7-47
7-50
6-51
7-53
1-55
7-56
3-59
6460
1675
CURRENT
Mean
1
1
1
_
_
_
_
3
_
1
1
_
1
2
1
_
3
2
1
-
_
5
2
2
2
LOW
1
1
1
2
3
2
1
4
1
3
1
1
2
3
4
2
8
5
3
2
3
13
4
4
5
Which Exceed Criteria
BPT
Mean
_
_
-
-
-
_
3
-
1
-
- .
-
1
-
_
-
1
_
_
_
_
2
1
-
Low
_
_
1
1
2
-
4
1
3
-
-
1
2
2
2
4
4
2
-
1
5
4
2
—
BAT
Mean Low
_ _
_ _
- -
1
_ _
_ _
1 2
- _
_ _
_ _
- -
_
_ _
_ -
_ _
1
_ —
_ _
_ _
_ _
1
_ -
1
— —
hhe following twenty-five plants did not have any pollutants which exceeded
criteria: 6-03, 2-05, 7-08, 3-09, 3-11, 3-13, 5-17, 7-21, 7-23, 3-24, 2-25,
2-26, 1-27, 3-30, 6-32, 3-34, 2-38, 1-61, 1-62, 1-69, 3-70, 6771, 5-72, 1-73,
1674.
2-14
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EXPANDED WATER QUALITY ANALYSIS
Two stream segments (the Houston Ship Channel in Texas and
the Kanawha River in West Virginia) were selected for analysis in
a detailed assessment. The major criteria for selection were
based upon the availability of an adequate data base and the
number of modeled organic chemical plants within the study area.
The general approach followed in these analyses was to assess the
impacts of the organic chemical industry within the study areas,
and included effects on water quality conditions, biological
conditions, human health, and recreational activity based upon
current, BPT, and BAT scenario results.
3-1
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The Houston Ship Channel
Background
The general study area consists of the lower Houston Ship
Channel, (the segment extending from Morgans Point (RM 0) to
the confluence with the San Jacinto River), and the bays
lateral to the lower 9 miles of the channel (Scott, Tabbs, the
upper and lower San Jacinto River (Figure 1). The entire area
lies in the east central Texas coastal prairies with the
channel and bays located in Chambers and Harris Counties and
the San Jacinto River in Harris County.
The Houston Ship Channel is a narrow ship passage about 50
miles long, 400 feet wide and 40 feet deep. The ship canal is
a man-made seaport which was originally a 12 foot channel
dredged through Galveston Bay to the San Jacinto River by the
Army Corps of Engineers. It is currently ranked as the third
largest seaport in the United States behind New Orleans and New
York. The dimensions of the lateral bays vary in area and
little in depth. Upper San Jacinto Bay has a surface area of
1,174 acres and mean depth of 5.84 feet. The lower San Jacinto
Bay is smaller with an area of 185 acres and depth of 5.58
feet. Burnett Bay has the largest surface area and is also
the deepest, estimated to be about 1,276 acres and 8.67 feet
respectively. The lower and upper Black Duck Bays range in
area from 183 to 205 acres, with an average depth of 5.58 feet.
3-2
-------
Figure 1
Houston Ship Channel General Study Area
Upper San Jacir.lo )*
Lover S,in Jot. into C:
:TI>-.- Poini
3-3
-------
Tabbs Bay is 806 acres in area and is 4.75 feet deep.
The San Jacinto River flows 19.1 miles from its origin at
Lake Houston to its confluence with the Houston Ship Channel.
Over this distance, the river has a surface area of approximately
2,880 acres and an average depth of approximately 12 feet.
There is no saltwater barrier (dams) protecting the river from
the channel, thereby causing saline water to run freely into
the river.
It is reported that the San Jacinto River, for most of the
year, provides 60% of the total fresh water discharge to the
lower channel. The flow on the river averages 2,609 cubic feet
per second and is almost entirely from Lake Houston. The lake's
discharge to the river is regulated by a dam which accommodates
fluctuations in precipitation, evaporation and drawdown.
The major point source discharges influencing water quality
in the channel, major tributaries, and lateral bays are
presented in Table 1 and summarized in Table 2. The channel
and its tributaries above the confluence with the San Jacinto
River (the upper channel) receive most of the point source
flow to the channel. In the upper channel and tributaries the
municipal flow is greater than industrial flow. In the lower
channel, the opposite occurs and industrial flow is much greater
than municipal flow.
3-4
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3-7
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The inorganic chemical industry is the largest industrial
point source discharger in the upper channel (29% of the total
industrial source) while the organic chemical industry accounts
for only seven percent of the total industrial point source in
the upper channel (see Table 2). In the lower portion of the
channel the petroleum refining and the organic chemical industries
dominate with forty-five and twenty-two percent of the total
point source flow, respectively.
Based upon organic chemicals and metals loadings along the
channel, the organic chemical industry does not appear to be
the major source of pollution within the area. Table 3
illustrates the discharge loadings under various treatment
levels for the organic chemical industry versus the total
industrial sources along the channel. In general, this
industry accounts for 12-15% of the organic discharge and
7-12% of the metals and inorganics.
Sufficient data were available to model the water quality
impact for nine of the eighteen organic chemical plants in the
area. Table 4 illustrates the end of pipe treatment under
current, BPT and BAT control for these nine plants. The
location of these nine facilities are shown in Figure 2.
Table 5 indicates the plant type, the type of facility and the
number of waste streams at each plant.
3-8
-------
TABLE 3
Organics & Phenol (kg/day)
Treatment Levels
Current BPT
BAT
OC & P
972
262
242
Total Industry
6570
2180
2050
15
12
12
Metals & Inorganics (kg/day)
Treatment Levels
Current BPT
BAT
OC & P
312
304
Total Industry
2960
2560
140
10
12
3-9
-------
FIGURE 2. Location of Modeled Organic Chemical and Plastics
Plants on the Houston Ship Channel and Greens Bayou,
12040104
MODELED ORGANIC CHEMICAL PLANTS
A. Reichold Chemicals, Inc.
B. Ethyl Corporation
C. Tenneco Chemicals, Inc.
D. Shell Chemical Company
E. Diamond Shamrock Corporation
F. Rohm and Haas-Texas, Inc.
G. Celanese (Soltex Polymers)
H. The Upjohn Company
I. Exxon Corporation
J. National Distillers
RIVER MILE*
17.0
15.3
14.1
11.5
11.5
10.9
7.0
2.9
2.9
2.9
'River Mile defined as miles upstream of Morgans Point.
3-10
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-------
Chemical Water Quality Conditions
The Houston Ship Channel area has had a long history of
pollution problems from the two primary point pollution
sources-industrial and municipal. Non-point source waste
loads except for dredging and sediment bed load present no
significant water quality problems in the channel.
In terms of a general water quality indicator, point source
discharges in the lower channel contribute significantly less
flow than the point source dischargers in the upper channel.
However, in the lower segment, the industrial flow is
greater than the municipal flow.
Figure 3 illustrates the location of the 18 Organic Plants
and the eight available STORET ambient water quality stations
along the Houston Ship Channel. Within the study area, three
organic plants and one monitoring station are located on Greens
Bayou (RM 18.22-16.1), eight organic plants and three monitoring
stations along Buffalo Bayou (RM 22.3-11.5), and seven organic
plants and four monitoring stations along the lower Houston
Ship Channel (RM 10.9-2.9).
Tables 6, 7, and 8 report the exceedances of EPA water
quality criteria for both freshwater and saltwater organisms
3-13
-------
Figure 3. Location of the Organic Chemical and Plastics Plants and
Ambient Water quality Monitoring Stations on the Houston
Ship Channel and Greens Bayou
C-D
Monitoring Stations
1. 21TXWQB/10050100
2. 11POX06/TOX004
3. 11POX06/TOX001
4. 21TXWQB/10050200
5. 21TXWQB/10060100
6. 21TEXWR/10060100
7. 21TXWQB/10060200
8. 21TXWQB/10060220
River Mile
1.7
1.8
3.2
8.3
10.2
10.2
16.1
19.8
t
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5 miles
Organic Chemical Plants
River Mile*
A.
B.
C.
D.
E.
F.
H.
G.
I.
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L.
M.
N.
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P.
Q.
R.
Denka Chemical Corporation
Chemical Exchange Process
Merichem Corporation
Pennwalt Corporation
Reichold Chemicals, Inc.
Ethyl Corporation
Rohm & Haas, Inc.
Tenneco Chemicals, Inc.
Lubrizol Corporation
Shell Chemical Company
Diamomd Shamrock Corporation
Rohm and Haas-Texas, Inc.
Diamond Shamrock Corporation
Syngas Company
Noramont Corporation
The Upjohn Company
Exxon Corporation
National Distillers
22.3
20.29
18.22
18.22
17.0**
15.3**
13.76
14.1**
12.98
11.5**
11 .5**
10.9**
6.75
5.66
5.66
2.9
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*-River Mile defined as miles upstream of Morgans Point
**- Modeled Organic Chemical Plants
3-14
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based upon the available inorganic metals data for five of the
eight STORET stations. For all five data stations worst case
assumptions were made, that is, data reported as less than a
certain value were set equal to that value. For all stations
there were exceedances of the criteria.
Assuming downstream river flow within the channel (especially
at mean flow conditions), water quality criteria violations
upstream along Buffalo and Greens Bayou are certain to affect
or increase water quality impacts along the downstream areas
(upper and lower San Jacinto Bay and Morgans Point). Under
low flow periods where tidal action (flushing) is more predominant,
discharged pollutants in the water column could remain within
the discharge zone for longer periods of time causing greater
localized (near plant discharge sites) pollution problems.
Sufficient ambient data are not available to determine
whether or not potential water quality impacts from current
level discharges of toxic organic chemicals are actually occurring
in the channel. Based upon other available data sources [the
State of Texas Water Quality Inventory, 1982, 305(b)], the
entire study area is classified as water quality limited.
Along the upper portions of the channel (Buffalo Bayou) organic
carbon levels and fecal coliform bacteria levels are high.
Elevated levels of nickel, mercury, lead, cadmium, arsenic,
and manganese, as well as the insecticide lindane, have been
3-18
-------
reported in the water column. Sediments contain elevated
levels of lead, cadmium, copper, chromium, nickel, silver,
zinc, and oil and grease, as well as aldrin, DDT, DDE, DDD,
and PCB.
Along the lower portion of the channel from the San Jacinto
River to Morgans Point, elevated concentrations of nickel,
mercury, lead, arsenic, and manganese have occurred in the water.
High levels of silver, nickel, lead, zinc, and cadmium have
been reported in the sediments, as well as aldrin, DDT, and
DDE. No specific locations regarding these toxic problems were
mentioned in the 305(b) report; however, Burnett Bay has been
reported to have a toxic sediment problem. No organic plants
discharge within Burnett Bay.
Dilution Analysis
Information provided on process wastewater discharges from
nine direct discharging plants served as a basis for assessing
impacts of toxic pollutants discharged by the Organic Chemicals
and Plastics Industry on water quality in the study area. This
information consists of pollutant loadings and effluent
concentrations resulting from modeling plant product-processes
at raw (Base Case) and three levels of wastewater treatment:
current, proposed BPT, and proposed BAT. The results of the
model plant study are shown in detail in the report entitled
3-19
-------
"Detailed Water Quality Analysis for the Organics Chemicals &
Plastics Industry on the Greens Bayou and Houston Ship Channel",
January, 1983.
The "base case" represents raw untreated process wastewater,
which is not normally discharged to receiving water. This level
is included for comparison purposes only. "Current" represents
the treatment technology currently in place at a plant. Proposed
BPT and BAT technology levels represent additional treatment
required to bring effluent concentrations in line with proposed
BPT and BAT limitations for this industry.
Comparisons between the modeled current discharge con-
centrations and proposed BPT effluent limitations are presented
in Table 9. Based on these comparisons, all but the Diamond
Shamrock and Shell plants are treating effluents to levels more
stringent than that proposed for BPT BOD and BPT TSS limitations.
Current treatment at the remaining seven plants achieves a
discharge concentration level better than the proposed BPT
effluent limitations for conventional pollutants. Based on
model projections of current discharges, only the Tenneco plant
complies with proposed BAT longterm average concentrations for
toxic pollutants (50 ug/1 for volatile organic compounds, 25
ug/1 for acid toxic organic compounds, 50 ug/1 for base/neutral
toxic organic compounds, and 75 ug/1 for toxic metals).
3-20
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3-21
-------
Instream concentrations of toxic pollutants discharged by
the plants at each treatment level were also estimated for
analysis of ambient (instream) water quality impacts from
wastewater discharges. These concentrations were derived as
follows. First, the study area was divided into segments based
on plant location and river mile position of reach segments
(Table 10). These river segments provided a basis for calculation
of receiving water flows used to estimate instream concentrations
of toxic pollutants from plant discharges.
Receiving stream flows for each segment are derived by
adding the model discharge flow from each of the nine plants to
the mean and low flow for the segment which receives its
discharge, and accumulating the plant flows to the farthest
segment downstream. This assumes that process water discharges
from the modeled plants are not included in the flow estimates
in Table 11. This assumption is suggested because it is unlikely
that the plants use the saltwater from the Channel as process
water. Furthermore, the primary source of freshwater in the
study area is from groundwater wells or Lake Houston. Data
were not available at the time this analysis was completed to
verify this assumption.
3-22
-------
Table 10. FLOWS USED TO ESTIMATE INSTREAM CONCENTRATIONS
OF POLLUTANTS DISCHARGED TO GREENS BAYOU AND THE
HOUSTON SHIP CHANNEL BY MODELED PLANTS IN THE
ORGANIC CHEMICALS AND PLASTICS INDUSTRY
Channel
Segment Low flow conditions Mean flow conditions
(river miles) (CFS) (CFS)
0-2.9 51.64 3,859.64
2.9-7.0 36.15 3,844.15
7.0-8.9 33.25 3,841.25
8.9-9.0 16.45 1,227.25
9.0-10.9 16.25 1,136.25
10.9-11.5 13.06 1,133.06
11.5-14.1 4.59 1,124.59
14.1-15.3 4.38 1,124.38
15.3-15.5 3.85 1,123.85
15.5-17.0 1.55 228.85
3-23
-------
Table 11. DISCHARGE FLOW FOR REACHES
IN THE HOUSTON SHIP CHANNEL STUDY AREA
(W.E. Gates & Associates, 1982)
Reach
Reach number
Mean Low
flow flow
(CFS) (CFS)
White Oak Bayou
Buffalo Bayou
Buffalo Bayou/Upper Houston
Ship Channel
Upper Houston Ship Channel
Greens Bayou
Upper Houston Ship Channel
Carpenters Bayou
Upper Houston Ship Channel
San Jacinto River
Lower Houston Ship Channel
Lower Houston Ship Channel
Burnett Bay
Mouth of Burnett Bay
Scotts Bay
San Jacinto Bay
San Jacinto River/Lower
Houston Ship Channel
Goose Creek3
12040104-019 97 0.5
12040104-020 480 1.1
12040104-018 624 1.7
12040104-017 855 2.2
12040104-016 228 0.7
12040104-015 1,123 3.0
12040104-010 83 0.2
12040104-009 1,214 3.2
12040104-008 2,609 16.8
12040104-007 3,828 20.0
12040104-004 3,828 20.0
12040104-006
12040104-005 4.0 0.0
12040104-003
12040104-028
12040104-029
12040203-002 370 1.3
a Discharges to Tabbs Bay on Upper Galveston Bay.
3-24
-------
Instream concentrations of pollutants discharged by the
nine plants were estimated assuming that no other sources
discharged these pollutants to the study area. Detailed effluent
data on other point sources in the area were unavailable to
test this assumption. Modeled plant flows and discharge
concentrations were accumulated in a downstream direction with
only simple dilution and plant discharge determining instream
concentration.
This "worst case" analysis approach does not take into
consideration factors which would tend to reduce ambient
pollutant concentrations below levels determined by simple
dilution. These fate process factors include volatilization,
sedimentation, biodegradation, bioaccumulation, photolysis, and
other physical and chemical processes which affect the fate of
chemical in a water environment. Decay rate constants associated
with these fate processes were unavailable for the study area
for use in the development of instream pollutant concentrations
used in this analysis.
Calculated instream toxic pollutant concentrations were
compared to EPA Water Quality Criteria and lowest reported
toxicity concentrations to estimate the extent of water quality
impacts from diluted process wastewater discharges from the
nine plants.
3-25
-------
In this analysis, a number of assumptions were required to
use the EPA Water Quality Criteria. The criterion for trivalent
chromium was used to evaluate chromium discharges. For hardness-
dependent metal criteria, an ambient hardness level of 112
mg/1 CaC03 was used based upon actual data. Since there are
no drinking water intakes in the study area, the only human
health criteria applicable to this analysis are those for
ingestion of aquatic organisms. Finally, where available,
lowest reported toxic concentrations were used in the analysis
when a water quality criterion had not been developed for a
pollutant.
In the case where a water quality criterion was exceeded,
the corresponding water quality effect was assumed to occur
over the full length of the river segment. Using this assumption,
the total length of river miles impacted by a wastewater discharge
could be estimated by summing the lengths of the individual
river segments where a water quality criterion for a pollutant
was exceeded.
Figures 4, 5, and Table 12 summarize the river miles from
Morgans Point at the mouth of the Houston Ship Channel affected
by discharges by the nine plants under the three levels of
treatment.
3-26
-------
Figure 4. Freshwater Aquatic Life Impacts Expected from Wastewater
Discharges to the Houston Ship Channel Bayou at Low Flow
by Nine Modeled Organic Chemical and Plastics Plants
Water quality
Treatment effect
level (impact) Pollutant
River miles impacted
Current Acute
Toxicity
Criterion
Lowest
Reported
Acute
Toxicity
Chronic
Toxicity
Criterion
Lowest
Reported
Chronic
Toxicity
BPT Acute
Toxicity
Criterion
Lowest
Reported
Acute
Toxicity
Chronic
Toxicity
Criterion
Lowest
• Reported
Chronic
Toxicity
BAT Acute
Toxicity
Criterion
Chronic
Toxicity
Criterion
Copper
Acrolein
Cadmiun Q' ^'9
Selenium
Zinc 0 z'°
Acrolein 0 2 9
Chronium*
Silver °— . 2'9
Copper
Acrolein
0 2.9
Cadmium p
Selenium
Zinc ° Z*9
terolein o 2 9
311lr.r 0 _2.9
Copper
CotDDcr ° •
8.9 11.5 15,5 }7
11.5 17
17
JJT3
8.9 11.5
8.9 17
8.9 11.5
8.J _11.5 15.5 17
l\,j 17
17
iSr1
8.9 11.5
8.9 17
8.9 11. S
S..9 11.5 15.5 17
17
0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Mouth Houston Ship Channel Greens
River Miles Bayou
Potential impacts based on exceedances of protection/toxicity levels by estimated instream
concentrations.
Trivalent.
3-27
-------
Figure 5. Saltwater Aquatic life Iirpacts Expected from Wastewater
Discharges to the Houston Ship Channel and Greens
Bayou at Lew Flow by Nine Modeled Organic Chemicals
and Plastics Plants
Hater quality
Treatment effect
River Biles iroaeted^
Current Acute
Toxicity
Criterion
Lowest
Reported
Acute
Toxicity
Chronic
Toxicity
Criterion
Lowest
Reported
Chronic
Toxicity
BPT Acute
Toxicity
Criterion
Lowest
Reported
Acute
Toxicity
Chronic
Toxieity
Criterion
Lowest
Reported
Chronic
Toxieity
BAT Acute
Toxicity
Criterion
Chronic
Toxicity
Criterion
Copper
Acrolein
CDDD.I °
Nickel 2 2*2.
Zinc 2 Li
2S ° 2'9
Copper
Acrolein
Nickel ° fif
Tlnr " **"
L«.d Q L£
Copper
Cotmar °
3*3 Lii s 1S.S 17
11-5 17
11. S
17
JJ5.3
fli2 !!•? 15-5 17
11.5 17
11.5
17
15.3
8.2 n.5 15.5 17
17
0 1 2 3 4 5 « 7 8 9 10 11 12 13 14 15 16 17
Mouth Houston Ship Channel Greens
River Miles Bayou
Potential impacts based on exceedances of protection/toxieity levels by estimated instream
concentrations.
* Hexavalent.
3-28
-------
Table 12. Human Health Impacts Expected fron Wastewater Discharges
to the Houston Ship Channel and Greens Bayou by Nine
Modeled Organic Chemicals and Plastics Plants at Mean
and Low Flow
Pollutant
Arsenic
Methyl chloride
Methylene chloride
Chloroform
1,2 Dichloroethane
Vinylidene chloride
Benzene
Acrylonitrite
Anthracene
Benxo(a) anthracene
Benzo(k) f luoranthene
Benzo (ghi) perylene
Benzol a) pyrene
Chrysene
Fluorene
Indeno(l,2,3,-cd)pyrene
Phenanthrene
Pyrene
Total PAHs
Treatment
technology
level
Currentl
BPT |
BAT
Current
Current
BPT
Current!
BPT f
Current
Current
BPT \
BAT )
Current
BPT
Current
Current
Current |
BPT \
BAT )
Current }
BPT >
BAT )
Current!
BPT \
BAT )
Current)
BPT J
BAT
Current)
BPT >
BAT )
Current}
BPT f
Current
Current
Current
Current)
BPT (
BAT
Low Flow Mean Plow
RC (Risk Levels) HC (Risk Levels)
10"5 1CT6 10"7 HH (o) 10"5 10~6 10'7
0-2.9
2.9-11.5
2.9-11.5.
15.5-17
15.5-17
0-11.5
0-11.5 11.5-15.3 8.9-11.5
8.9-11.5 11.5-15.3.
0-8.9
0-2.9
8.9-11.5
0-2.9,
8.9-11.5— »
2.9-8.9
n-11 S _ „ 0-11.'!
0-11.5 0-11.5 •
HH (o) - EPA water quality criterion for human health toxicity protection fron ingesting organisms.
HC (risk level) - EPA water quality criterion for carcinogenicity protection from ingesting organisms at a risk level
given in parentheses.
3-29
-------
Figures 4 and 5 show the types of aquatic life impacts
expected in the Houston Ship Channel from wastewater discharges
by the nine modeled plants. At current treatment levels,
acute impacts on freshwater aquatic organisms are expected
under low flow conditions from copper and acrolein discharges.
Under the same conditions of flow and treatment level, impacts
on freshwater aquatic organisms related to exceedances of
chronic toxicity thresholds are expected to occur from cadmium,
copper, cyanide, lead, selenium, zinc, acrolein, chromium, and
silver.
Impacts on freshwater organisms are likely to be signi-
ficantly reduced under low flow conditions when plants currently
treating their wastewater at less than BPT upgrade their
treatment to comply with proposed BPT effluent limitations.
Referring to Figure 4, impacts related to acute toxic effects
are expected only from copper and acrolein discharges. Expected
freshwater aquatic life impacts from chronic toxicity effects
at the proposed BPT will be expected from only cadmium, copper,
cyanide, lead, zinc, selenium, silver, chromium, and acrolein
discharges. The total river miles impacted by both types of
effects is also reduced under BPT. Once the plants upgrade
wastewater treatment to meet the proposed BAT limitations, all
impacts on freshwater organisms under low flow conditions are
expected to be eliminated except those from cadmium and copper.
3-30
-------
Expected impacts on freshwater organisms under mean flow
conditions at current treatment levels do not occur due to
additional dilution.
Because the study area may be used for recreational and
subsistence fishing, potential human health impacts from ingesting
fish are considered in this analysis. Table 12 presents human
health impacts expected from wastewater discharges to the
Houston Ship Channel and Greens Bayou by the nine plants at low
and mean flow conditions.
Current discharges are likely to present the potential for
human health due to toxicity from eating fish contaminated with
acrolein during low flow conditions. The potential for this
impact is eliminated at both BPT and BAT.
The threat of human carcinogenicity from eating contami-
nated fish is present at current discharge levels from seventeen
organic pollutants under low flow conditions, from eleven at BPT
levels, and from eight pollutants at BAT levels (Table 13). The
extent of the area where the impact may occur also decreases
under conditions representing compliance with the more stringent
effluent limitations at the proposed BPT and BAT levels.
3-31
-------
Biological Conditions
Available data indicate that present fish harvests from
Galveston Bay are very high. The Houston Ship Channel has also
experienced a significant upswing in the species and abundance
of each found there. Species found on the lower segment of
the channel between 1973 and 1977 include: croaker, sand seatrout,
bass, menhaden, bluegill, butterfish, catfish, sheepshead, drum
and flounder. Recent biological survey results (1982) from
Scott & Burnett Bay have also found a number of important species
(See table 14).
The lower Ship Channel and Galveston Bay have seen a return
of fish species that have been absent from this area for many
years. A sampling survey two miles above the confluence of
the San Jacinto with the channel bears this out. Samples taken
in 1972 revealed a total of 18 species but by 1978, the number
had almost doubled to 33 species. As a result, sportfishing
has increased around the shoreline of the lower channel and the
inner bays have developed as productive nursery areas for larval
shrimp and crabs.
Several different species of fish including large numbers
of blue crabs, white and brown shrimp are observed on the San
Jacinto River. Blue crabs are plentiful from Lake Houston to
the Houston Ship Channel while the shrimp are most abundant in
the lower segment of the river.
3-32
-------
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3-33
-------
Table 14. Recent Biological Survey Results from
Scott and Burnett Bays(1982)
Burnett Bay
Scott Bay Lower Upper
Species 4/1/82 5/19/82 6/13/82 8/3/82
White shrimp, Penaeus setiferus 84 34 8 127
Brown shrimp, Penaeus aztecus 1 — — 45
Blue crab, Callinectes sapidus 14 48 33 26
Black drum, Poqonias cromius 1
Bay anchovy, Anchoa mitchilli 1 -- — --
Largescale menhaden, Brevoortia patronus 42 2
Atlantic croaker, Micropogon undulatus 11 11 17
Southern fluke, Paralichthys lethostigma — 1
Gaff-topsail catfish, Eagre marinus — — — 7
Sand seatrout, Cvnoscion arenarius — — 44
Blue catfish, Ictalurus furcatus — — 2
River shrimp, Macrobrachium ohione — — 1
3-34
-------
Despite these improvements, fish kills caused by a drop
in oxygen due to aerobic bacterial decomposition of pollutants
still occur in the channel. Further reductions in the BOD
loading should result in even greater increases in marine
productivity throughout the area. There is no vegetation
problem stemming from water quality on the river. However,
the low concentrations of dissolved oxygen and high levels of
chlorides in the lower stretches (below RM 4.95) are a threat
to fish population and have been responsible for fish kills in
the past.
Table 15 presents results of benthic macroinvertebrate
surveys at three locations on the Houston Ship Channel by the
Texas Department of Water Resources. The number of species is
highest in the two most recent years of sampling, suggesting
improving conditions. The number of species also increases in
samples collected downstream at river miles 9.0 (San Jacinto
Monument Station) and 0.0 (Morgans Point Station), suggesting
reduced pollution impacts as Upper Galveston Bay is approached.
This increase in species number may be related to distance
from point sources of wastewater discharges, increasing flow
and tidal action (increases dilution of wastewaters), reduction
in water depth and more habitat which is less impacted by
commercial shipping activities.
3-35
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3-38
-------
KANAWHA RIVER
Background
The Kanawha River flows through the southwest region of West
Virginia. The main body of the Kanawha River is formed at the
confluence of the New and Gauley Rivers at Gauley Bridge, West
Virginia. The mainstem flows northwesterly for 97 miles through
parts of Fayette, Kanawha, Putnam, and Mason counties where it
joins the Ohio River at Point Pleasant, West Virginia. Its major
tributaries are the Greenbrier River, Elk River, Coal River and
Pocatalico River.
A set of four locks and dams, the London (River Mile (RM) 80),
Marmet (RM 67), Winfield (RM 30), and Gallipolis (RM 0), divide the
river into four pools designed to maintain a minimum navigational
depth for barge traffic. The Kanawha River can be characterized as
a large, deep, slow moving, almost lake-like river.
The 74 mile stretch of the Kanawha River from Point Pleasant
to Cheylan is the subject of this analysis (figure 6). A total of
34 industrial and municipal direct discharge facilities affect
water quality in the study area. Six (6) Organic Chemical and
Plastics (OC&P) facilities contribute an estimated 40 percent of
the total process wastewater flow to the segment; the dischargers
from this industry are concentrated between river miles 69.36 and
40.41.
3-39
-------
Figure 6. Location of Organic Chemical and Plastics Plants on the
Kanawha River, West Virginia.
A.
B.
ORGANIC CHEMICAL PLANTS
E.I. DuPont (WV0002399)
South Charleston STP (WV00023116)
(receives discharge flow from Union
Carbide(South Charleston))
Union Carbide(InstitiiJte<}
(WV0000086)
Mason & Dixon Tank Co
(WV0001708)
Mdnsanto Co(WV0000868)
FMC Corp(WV0000400)
C.S.T.-Fike Chem (WV0001678)
RIVER MILE
69.4
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48.9
47.9
41.8
41.5
40.4
A.
River miles (upstream of Pt. Pleasant)
10
20 miles
3-40
-------
Publicly Owned Treatment Works (POTWs) and Inorganic Chemicals
contribute 31 percent and 29 percent, respectively, of the waste-
water to this segment of the river. Coal mining and pesticides
plants contribute less than one (1) percent of the total process
wastewater flow.
The proportional contribution of OC&P loadings to all industrial
loadings of toxic pollutants was estimated on two reaches on the
Kanawha River above Winfield Dam. A total of eighteen (18) pollutants
(nine organics, two inorganics, seven metals) and the two largest
OC&P plants which had data available , FMC Corp. and Union Carbide
(Institute), were selected for analysis.
Table 16 summarizes the results under current, proposed BPT,
and proposed BAT treatment levels. The two OC&P plants contribute
over seventy (70) percent of the total industrial loading of the
pollutants to the reaches. An eighty (80) percent loading reduction
is estimated in upgrading to BAT levels over current treatment for
combined organics, inorganics, and metals removal.
Table 17 lists the six (6) Organic Chemicals and Plastics
facilities with discharge flows to the study area. Table 18 shows
the two (2) OC&P plants (E.I. DuPont and Union Carbide (Institute))
and their treatment technology for which modeled plant effluent
data was available for this study. The two modeled plants in this
analysis contribute 86 percent of the total OC&P discharge flow to
the Kanawha River.
3-41
-------
TABLE 16. ESTIMATION OF LOADINGS OF SELECTED PRIORITY
POLLUTANTS TO THE KANAWHA RIVER FOR TWO PLANTS UNDER VARIOUS
TREATMENT CONTROLS
LOADINGS (Kg/day)
Current BPT BAT
Total Industry 605.04 275.60 123.21
OC & P 437.10 197.99 87.46
(Percent of Total) 72.2 71.8 71.0
REDUCTIONS IN LOADINGS (Percent) FOR
OC & P INDUSTRY
Current BPT BPT BAT Current BAT
54.7 55.8 80.0
3-42
-------
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3-44
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The State of West Virginia has designated the lower Kanawha
River from RM 72 to its mouth (Zone 2) a water quality limited
segment due to the presence of significant pollution problems. The
segment from RM 72 to the river's origin (Zone 1) is considerably
cleaner. Table 19 lists the use classifications designated by the
State and actual uses as reported by the Regional Intergovernmental
Council.
Chemical Water Quality
The Kanawha River has had a long history of pollution problems
from both industrial and municipal sources. Most of the pollution
can be attributed to the upsurge in industrial activity that occurred
at the beginning of World War II and the concomitant increase in
population. In the 40-year period between 1940 and 1980, industry
continued to expand and the population along the Kanawha River
increased by 44% from 195,192 to 281,446.
During the 1950s and early 1960s the water quality of the
Gallipolis, Winfield and Marmet Pools was severely degraded. The
dissolved oxygen level dropped to zero during low flow periods and,
as a result, fish kills were a frequent occurrence, particularly
between Winfield Dam and Charleston. A thick black sludge covered
the banks during this period, and oil, untreated sewage and trash
floated on the surface of the river. In addition, severely elevated
threshold odor levels from sewage and aromatic compounds were reported,
3-45
-------
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3-46
-------
The water quality of the London and Gallipolis Pools was not
as severely impacted by industrial and municipal discharges as the
Marmet and Winfield Pools. According to an official at the Department
of Natural Resources (DNR), industrial discharge into the London
Pool has always been minimal and water quality has been good. A
power facility discharged heat into the London Pool until the early
1970s; however, the impact was reported to be minimal. The water
quality in the Gallipolis Pool, while poor, was generally better
than the Winfield and Marmet Pools. This was due to the absence of
dischargers and the ability of the river to assimilate some of the
wastes as they progressed downstream.
The West Virginia State Water Commission began a three-phase
clean-up program in 1957. During Phase I, primary treatment was
required as a minimum for municipal dischargers, and chemical
manufacturers were required to reduce their 8005 loads by 40% by
June, 1963. Phase II required municipalities to implement secondary
treatment and chemical plants to reduce 8005 loads by 50%. Phase
III requirements were specified in 1971. 8005 reductions to 15%
of 1959 levels were required, with as much reduction of nitrogenous
waste loads as possible.
Monitoring data at several stations document the degraded
water quality conditions prevalent from the early to mid - 1970's
throughout the Kanawha River extending from the Elk River to Winfield
Dam. A lack of ambient data upstream of the Elk River makes it
3-47
-------
difficult to state water quality conditions above this point. West
Virginia water quality standards were frequently exceeded for fecal
coliform levels, copper, and lead. Occassional violations for
cyanide, phenols, iron, and zinc were also reported.
With the absence of major dischargers below Winfield Dam and
the ability of the river to assimilate wastes progressing downstream,
the water quality conditions were not as severely degraded as those
upstream of Winfield Dam. At the mouth of the Kanawha River, at
Henderson, West Virginia, standards violations, while occurring,
were not as numerous compared to those above Winfield Dam. Iron
levels were an exception to this trend with concentrations
frequently exceeding standard levels.
During the period between 1979 and 1981, the West Virginia
Water Quality Status Assessment reported that no standards
violations occurred on the Kanawha mainstem for copper or zinc.
Cyanide, manganese, iron, cadmium, phenols, and lead levels
occasionally exceeded standards. Repeated fecal coliform standard
violations have been reported between the Elk River and Winfield
Dam. No data were available for other organics. Iron and manganese
standards violations have been attributed to the coal mining
industry; fecal coliform violations were attributed to agriculture,
construction, and silviculture.
3-48
-------
Evaluation of Organic Chemicals Plant Effects
Information on modeled process wastewater discharges based on
"generalized plant configurations" (GPCs) from two plants served
as a basis for assessing impacts of toxic pollutants discharged
by the Organic Chemicals and Plastics Industry on Kanawha River
water quality. This information consists of pollutant effluent
concentrations resulting from modeling plant product-processes at
raw discharge (base case) and three levels of wastewater treatment:
current, proposed BPT, and proposed BAT. Table 20 lists the specific
treatment technology at each level for the two plants, E.I. DuPont
and Union Carbide (Institute).
Table 21 compares the GPCs current discharge concentrations
and the proposed BPT effluent limitations for DuPont and Union
Carbide. Both plants are currently exceeding the proposed BPT
limitations for BOD while meeting the BPT TSS limitations. Current
discharges from both plants do not meet proposed BAT concentrations
for all toxic metals (75 ug/1).
Instream concentrations of toxic pollutants discharged by the
plants were estimated for an analysis of water quality impacts
using a simple dilution analysis (See "Detailed Water Quality Analysis
for the Organic Chemicals and Plastics Industry on the Kanawha
River", January, 1983). The dilution analysis was a "worst case"
scenario with respect to aquatic life toxicity effects outside of
3-49
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the mixing zone, as it does not take into account factors which
would tend to reduce ambient pollutant concentrations below levels
determined by simple dilution. These fate process factors include
volatilization, sedimentation, biodegradation, bioaccumulation,
photolysis, and other physical and chemical processes which affect
the fate of a chemical in a water environment.
Instream concentrations within the mixing zones are expected
to be higher than those predicted by the simple dilution analysis.
Estimations of pollutant levels and water quality impacts within
these zones were not performed due to lack of detailed information
on the behavior of the discharge plumes. However, elevated toxic
pollutant concentrations are likely to have at least some local
adverse sublethal, bioaccumulative, physiological, or behavioral
effects on any exposed aquatic organisms.
Table 22 summarizes the total river miles impacted by dis-
charges from the two plants under the treatment levels at mean and
low flow as a result of the dilution analysis. Seven (7) pollutants
exceed EPA Water Quality Criteria under either mean or low flow
only under base case treatment. All potential violations occur as
a result of discharge from Union Carbide (Institute). Arsenic was
the only pollutant that had potential violations at current and BPT
treatment. No violations were predicted at BAT treatment.
3-52
-------
TABLE 22. TOTAL RIVER MILES ON THE KANAWHA RIVER WHERE
WATER QUALITY IMPACTS ARE EXPECTED BASED ON EXCEEDANCES
OF EPA WATER QUALITY CRITERIA
Model
treatment
Pollutant level
Arsenic B = C = BPT
B = C = BPT
Cyanide Base Case
Base Case
Methyl chloride Base Case
Chloroform Base Case
Carbon Base Case
Tetrachloride
Benzene Base Case
2,4 Dinitrotoluene Base Case
Base Case
Flow Exceeded
condition EPA Criteria
Mean HC (1CT7)
Low HC (ICT6)
Mean FC
Low FA, FC
LOW HC (10~7)
Low HC (10~7)
LOW HC (1CT7)
Low HC (1(T7)
Mean HC (10~7)
Low HC (10~6)
HC (1CT7)
River miles
impacted
0-48.9
0-48.9
0-48.9
0-48.9
0-48.9
38.4-48
0-48.9
0-48.9
45.4-48
38.4-48
0-38.4
.9
.9
.9
FC - Freshwater chronic toxicity
FA - Freshwater acute toxicity
HC - EPA water quality criterion for carcinogenicity protection
from ingesting organisms at risk level given in parenthesis
B - Base Case
C - Current
BPT - Best practicable treatment
3-53
-------
Ambient arsenic data was retrieved to compare to the current
modeled plant discharge concentrations, with discharges assumed to
begin at a time corresponding with the beginning of the current
NPDES plant permit (November 1, 1981).
All values of arsenic concentrations were reported as less
than 2 ug/1, the analytical detection limit, so that meaningful
comparisons with the projected levels which range from 0.007 to
0.08 ug/1 and the EPA criterion of 0.00175 ug/1 for carcino-
genicity protection at the 10~7 risk level are not possible.
Significant improvements in water quality are projected in
going from the base case to current treatment levels. The results
shown in Table 22 indicate that, except for arsenic, current treat-
ment removes all toxic pollutants to levels below the EPA criteria.
The only potential human health impact expected from discharges by
any of the plants is the risk at the 10~7 risk level for the
occurrence of human carcinogenicity from eating fish contaminated
with arsenic. This potential risk is present from below the point
of discharge of the Union Carbide (Institute) plant at river mile
48.9 to the mouth of the Kanawha River. Its discharges currently
do not meet proposed BAT concentration limitations for all toxic
metals (75 ug/1). Modeled BAT effluent concentrations for this
plant indicate that the human health risk associated with arsenic
discharges will be eliminated when the plant complies with the
proposed BAT effluent limitations for metals.
3-54
-------
From the dilution analysis, the modeled plant discharge
concentrations indicate that the two modeled direct dischargers
will not by themselves cause aquatic life effects in the Kanawha
River at their current, BPT, or BAT toxic pollutant discharge
levels. Potential aquatic life effects may occur within the mixing
zone of the effluent plume.
However, although the two modeled plants discussed above
account for 86 percent of the discharge flow to the Kanawha River,
this may not preclude potential impacts from the remaining 14
percent of the OC&P discharge flow. Since GPC data was not available
for plants E, F, and G (figure 7), hypothetical pollutant loadings
were computed at RM 41.5. Loadings to the river were calculated
using average OC&P effluent data at the various treatment levels
for the seven (7) pollutants in Table 22 and the 14 percent discharge
flow contributed by plants E, F, and G.
Table 23 shows the results using the previously discussed
dilution analysis with the hypothetical OC&P plant added at RM
41.5. At current treatment, all seven (7) pollutants are projected
to exceed water quality criteria (particularly at low flow) as a
result of the loading from the hypothetical plant. Table 22 showed
that without this loading, only arsenic was estimated to exceed the
criterion level. Projections in going to BPT treatment show that
in addition to the previous potential arsenic criterion violations,
3-55
-------
TABLE 23. IMPACT PROJECTIONS WITH A HYPOTHETICAL
OC&P PLANT LOCATED ON THE KANAWHA RIVER AT RIVER MILE 41.5
Pollutant
Arsenic
Cyanide
Methyl chloride
Chloroform
Carbon
Tetrachloride
Benzene
Model
treatment
level
Base
Current
BPT
BAT
Base
Current
BPT
Base
Base
Current
Base
Base
Current
BPT
2,4 Dinitrotoluene Base
FC - Freshwater
FA - Freshwater
HC - EPA water c
Current
chronic toxicity
acute toxicity
juality criterion for <
Flow
condition
Mean
Mean
Low
Low
Mean
Mean
Mean
Low
Low
Low
Mean
Mean
Mean
Mean
Low
Mean
Low
Low
Low
Low
Mean
Low
Low
Low
LOW
Mean
Low
Low
Mean
Low
Low
Mean
Mean
Low
LOW
carcinogenicity
Exceeded
EPA Criteria
HC(10r7)
HC(1(T6)
HC(1(T6)
HC(1(T5)
HCUCT7)
HC(1(T6)
HCdcr7)
HC(1(T6)
Hcucr5)
Hcucr6)
Hcucr7)
HC(1(T6)
HC(1(T7)
Hcucr7)
HC(10~6)
FC
FA, FC
FC
FC
HC(10-7)
Hcacr7)
HCdO~7)
HC(10~6)
HCdcr7)
HC(10-7)
HCdCT7)
HCdcr7)
HC( 1(T6 )
HCdO~7)
HC(10~6)
HCdCT7)
HC(10~7)
HC(10~7)
HC(10~6)
HCdcr7)
• protection
River miles
impacted
41.5 - 48.9
0 - 41.5
41.5 - 48.9
0 - 41.5
41.5 - 48.9
11.6 - 41.5
0 - 11.6
41.5 - 48.9
9.2 - 41.5
0 - 9.2
41.5 - 48.9
11.6 - 41.5
0 - 11.6
0 - 41.5
0 - 41.5
0 - 48.9
0 - 48.9
0 - 41.5
0 - 41.5
0 - 48.9
0 - 41.5
41.5 - 48.9
0 - 41.5
0 - 41.5
0 - 48.9
0 - 41.5
41.5 - 48.9
0 - 41.5
0 - 41.5
0 - 41.5
0 - 41.5
45.4 - 48.9
0 - 41.5
0 - 48.9
0 - 41.5
from ingesting organisms at risk level given in parenthesis
3-56
-------
estimated water quality impacts for benzene and cyanide at low
flow will occur from the hypothetical pollutant loadings. The
risk level associated with arsenic increases by an order of mag-
nitude immediately downstream of the hypothetical plant. BAT
effluent concentrations for this plant indicate that the impacts
associated with the discharge of all pollutants except arsenic
will be eliminated with compliance with the proposed BAT effluent
limitations.
Pollutant Fate Analysis
The five (5) organic chemicals that exceeded EPA water quality
criteria at base conditions under the two plant dilution analysis
(Table 22) were modeled using the EXAMS model using site-specific
and chemical-specific data to show the behavior and fate of these
compounds from the point of discharge downstream to the Ohio River.
Under mean flow conditions, over 90% or more of the load of
2,4-dinitrotoluene and benzene volatilize or biodegrade before
being transported out of the study area. For carbon tetrachloride,
methyl chloride, and chloroform these fate processees are not as
significant at mean flow. At low flow, volatilization and bio-
degradation account for over 95% of the fate of all of the above
pollutants with five (5) percent or less being transported out of
the study area.
3-57
-------
Biological Conditions
Biological conditions have generally followed the trend seen
in the chemical water quality of the Kanawha River. Severely
degraded conditions occurred in the 1950's and 1960's and slow
improvement in conditions occurred through the 1970's.
Over the past decade, an improvement in fish population has
occurred at the Winfield Dam where the water quality conditions
had been severely degraded. To evaluate the changes that have
occurred, fish caught were characterized based on angler preference
(Table 24). Table 25 shows the changes in the number of individual
specimens caught by preference class by year. These data indicate
that the quality and quantity of fish species in the area have
increased since 1968. By 1976, white bass and sauger had returned
to the Winfield Pool and walleye returned to the same area in
1980.
During the same sampling periods, the increase in the number
of medium and high preference fish at the London Dam, where water
quality has remained in the good range, was of lesser magnitude,
i.e., from 56 to 97 species. The species sampled in the London
Pool, between 1968 and 1973, included: black and white crappie,
bass (smallmouth, Kentucky spotted and white), longear sunfish,
bluegill, and muskellunge. In contrast, species that were sampled
3-58
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in the London Pool, between 1976 and 1980, included walleye, sauger,
sharpnose darter, logperch, largemouth and rock bass, trout and
perch as well as those found between 1968 and 1973.
Therefore, the biological quality of the area, as indicated by
the fishery data, appears to be in fairly good condition. Fishery
biologists familiar with the area support this conclusion but
suggest that additional reductions in pollution loads from all
sources will result in further improvement in the gamefish (high
preference) population. However, extrapolation to continued im-
provements in fish populations due to reductions in toxic pollutant
loadings from the OC&P industry is difficult. As the Kanawha
River is dredged for navigation, habitats available for organisms
are limited. Dredging, runoff, and point sources contribute to a
high suspended solids load. Consequently, light penetration is
reduced, lessening the significance of rooted aquatic vegetagion,
and preventing development of a diverse, high quality benthic
community available for aquatic organisms. Pollutant loadings
from other industrial or municipal sources may also act in limiting
the growth and diversity of the fish population on the Kanawha
River.
Fish Tissue Analysis
A study completed by the U.S. EPA (1981) summarized arsenic
tissue levels in fish caught near Winfield downstream of Union
3-61
-------
Carbide (Institute). These data represent conditions in 1978.
Results from a STORET retrieval are presented in Table 26.
Arsenic tissue concentrations ranged from 0.05 to 0.23 mg/kg
wet weight near Winfield. Reported arsenic tissue levels (U.S.
EPA, 1981) in walleye (Stizostedeum vitreum) and channel catfish
(Ictalurus punctatus) caught near London, upstream of the Union
Carbide (Institute) plant, were 0.10 mg/kg (average) and 0.15 mg/kg
(maximum), but they do not differentiate levels between the two
species. Comparison of arsenic tissue levels in fish caught at
the two locations suggest that downstream specimens carry higher
arsenic body burdens than fish inhabiting locations upstream of
the plant.
The 1981 EPA study estimated an average daily intake of arsenic
through ingestion of fish equal to 0.7 ug/day and a maximum intake
level of 46 ug/day. Human health impacts of these intake levels
were not addressed. Other information presented by U.S. EPA (1980)
indicates that these ingestion rates are well within the range of
normal dietary intake values for arsenic.
3-62
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Indirect Dischargers Analysis
Introduction
To determine potential environmental impacts of indirect
dischargers, seven "model" plants were analyzed. There were no
actual indirect end-of-pipe pollutant data available; therefore,
these model plants were assessed using calculated pollutant
concentrations (average industry-wide, flow-weighted) at the raw
waste level and at the PSES treatment level. For three of seven
"model" plants analyzed, actual plant discharge flow, the discharge
flow of the POTW to which they discharge, and the receiving
stream flow under mean and low flow conditions were used. For
the remaining four "model" plants, it was assumed that the discharge
flow was 10, 16, 25, and 50 percent of a 5 MGD POTW with secondary
treatment, and that the POTWs discharge flow is 10 percent of
the receiving stream's flow.
The industry-wide concentration for raw waste and PSES were
obtained by flow-weighting the concentration data available for
each of the processes under study. The data and method used to
calculate the industry-wide concentrations are presented in the
report entitled "Summary of Priority Pollutant Loadings for the
Organic Chemicals, Plastics, and Synthetics Industry."
4-1
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Methodology Used to Determine Potential Impacts from Indirect
Dischargers
For the indirect dischargers, the potential impacts of
priority pollutants were determined using a computer model to
simulate a POTW.
In the POTW computer model, background levels for the priority
pollutants are assumed equal to zero. The theoretical POTW
influent concentration is calculated by dividing the pollutants
concentrations by the sewer dilution factor (i.e., POTW flow
divided by plant flow). The theoretical POTW effluent concen-
tration is calculated by multiplying the theoretical POTW influent
concentration by the POTW pass-through value for each pollutant.
The theoretical POTW effluent concentrations are then divided
by the receiving stream dilution factors (i.e., stream flow divided
by the POTW flow) to determine the theoretical in-stream
concentrations.
To determine the potential impacts on the operation of the
POTW, the theoretical POTW influent concentrations were compared
to the available inhibition criteria. Pollutants were also
evaluated for sludge contamination by comparing the product of
the theoretical POTW influent concentration, treatment efficiency,
sludge partition factor, and the sludge generation factor with
available data for sludge contamination levels.
4-2
-------
To determine the potential environmental impacts, the
undiluted theoretical POTW effluent concentrations were compared
to the available ambient acute water quality criteria for the
protection of freshwater aquatic life. Also, the projected in-
stream concentrations, based on the diluted POTW effluent
concentrations, were compared to the available ambient chronic
water quality criteria for the protection of freshwater aquatic
life and the human health criteria for ingesting water and organisms,
Summary of Results
Table 4-1 summarizes the pollutants which exceeded the water
quality criteria from the three plants for which actual flow
data were available. Table 4-2 summarizes the pollutants which
exceeded the water quality criteria from the four plants for
which a range of representative flow data were assumed. The
analysis shows that the application of PSES will reduce water
quality criteria violations by between 70 and 100 percent, given
the assumptions listed above.
Inhibition of the POTW treatment system by cyanide in the
raw waste was projected in all seven plants, and by acrylonitrile
in three nlants as was sludge contamination by chromium at two
plants. These projected problems were eliminated after the
application of PSES.
4-3
-------
In a review of five case studies of POTWs that receive
organic chemicals discharges (including the three actual plants
modeled as described above) and that are known to have experienced
operating problems, there are strong indications that the organic
chemical discharges are at least part of the cause of the POTWs
problems. The case studies do not however, provide a clear link
between specific priority pollutants and operational problems.
4-4
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Table 4-1
Summary of Criteria Violations for Three Indirect Dischargers
Based on
Raw Waste Levels
Based on
PSES Treatment
American Color and Chemicals
Mean Flow
Chromium, S
Copper, A
Cyanide, I, A
Benzene, H
2,4 Dimethyl phenol, A
Anthracene, H
Phenanthrene, H
Pyrene, H
Acrylonitrile, I
No violations
American Color and Chemicals Arsenic, H
Chromium, S
Copper, A
Low Flow Cyanide, I, A, C
Dichlorcme thane, H
Trichloromethane, H
1,2-Dichloroethane, H
Benzene, H
2, 4-Di methyl phenol, A
Bis(2-ethylhexyl)
phthalate, C
Anthracene, H
Phenanthrene, H
Pyrene, H
Acrylonitrile, I
Monsanto Cyanide, I, A
Mean Flow
Monsanto
Low Flow Cyanide, I, A
Anthracene, H
No violations
No violations
No violations
KEY: A - Exceeds Acute Aquatic Water Quality Criteria
C - Exceeds Chronic Aquatic Water Quality Criteria
H - Exceeds Human Health Water Quality Criteria for Ingesting Water and
Organisms
I - Exceeds POTW inhibition concentration
S - Exceeds sludge contamination levels
4-5
-------
Table 4-1
(Continued)
Summary of Criteria Violations for Three Indirect Dischargers
Based on Based on
Raw Waste Levels PSES Treatment
Tenneco Cyanide, I, A No violations
Benzene, H
Mean Flow 2,4-Dimethyl phenol, A
Anthracene, H
Phenanthrene, H
Pyrene, H
Tenneco Arsenic, H No violations
Cyanide, I, A, C
Low Flow Dichlorcmethane, H
Trichloromethane, H
1,2-Oichloroethane, H
Benzene, H
2,4-Dimethyl phenol, A
Bis(2-ethylhexy1)phtha1ate, C
Anthracene, H
Phenanthrene, H
Pyrene, H
KEY: A - Exceeds Acute Aquatic Water Quality Criteria
C - Exceeds Chronic Aquatic water Quality Criteria
H - Exceeds Human Health Water Quality Criteria for Ingesting Water and
Organisms
I - Exceeds POTW inhibition concentration
S - Exceeds sludge contamination levels
4-6
-------
Table 4-2
Summary of Criteria Violations for Model Indirect Discharging Plants
Based on
Ran Waste Levels
Based on
PSES Treatment
Model Plant for Industry
SOF = 10
Arsenic, H
Cyanide, I, A, C
Dichloromethane, H
Trichloromethane, H
1,2-Dichloroethane, H
Benzene, H
Anthracene, H
Phenanthrene, H
Pyrene, H
No Violations
Model Plant for Industry
SDF = 6.25
Arsenic, H
Cyanide, I, A, C
Oichloromethane, H
Trichloromethane, H
1,2-Dichloroethane, H
Benzene, H
2,4-Dimethyl phenol, A
Bis(2-ethylhexyl)
phthalate, C
Anthracene, H
Phenanthrene, H
Pyrene, H
No Violations
Model Plant for Industry
SDF = 4
Arsenic, H
Cyanide, I, A, C
Dichloromethane, H
Trichloromethane, H
1,2-Oichloroethane, H
Benzene, H
2,4-Dimethyl phenol, A
Bis(2-ethylhexyl)
phthalate, C
Anthracene, H
Phenanthrene, H
Pyrene, H
Acrylonitrile, I
Arsenic, H
KEY: A - Exceeds Acute Aquatic Water Quality Criteria
C - Exceeds Chronic Aquatic Water Quality Criteria
H - Exceeds Human Health Water Quality Criteria for Ingesting Water and
Organisms
I - Exceeds POTW inhibition concentration
S - Exceeds sludge contamination levels
4-7
-------
Table 4-2
(Continued)
Summary of Criteria Violations for Model Indirect Discharging Plants
Based on Based on
Raw Waste Levels PSES Treatment
Model Plant for Industry Arsenic, H Arsenic, H
SDF = 2 Chromium, S Pyrene, H
Copper, A
Cyanide, I, A, C
Dichloromethane, H
Trichloronethane, H
1,2-Dichloroethane, H
Benzene, A, H
2,4-Oimethyl phenol, A
Bis(2-ethylhexyl)
phthaiate, C
Anthracene, H
Phenanthrene, H
Pyrene, H
Acrylonitrile, I
KEY: A - Exceeds Acute Aquatic Water Quality Criteria
C - Exceeds Chronic Aquatic Water Quality Criteria
H - Exceeds Human Health Water Quality Criteria for Ingesting Water and
Organisms
I - Exceeds POTW inhibition concentration
S - Exceeds sludge contamination levels
4-8
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