1
OCPSF
Detailed
Study
Plan
­
Revised
December
29,
2003
ORGANIC
CHEMICALS,
PLASTICS,
AND
SYNTHETIC
FIBERS
(
OCPSF)
DETAILED
STUDY
PLAN
December
29,
2003
General
Steps
1.
Gather
Information
°
Industry
demographics
(
profiles)
°
Identify
pollutants
of
concern
and
product/
process
sources
°
Identify
focus
industries
°
Baseline
pollutant
loads
for
focus
industries
°
Applicable
control
technologies
for
focus
industries
(
includes
wastewater
treatment
and
pollution
reduction
alternatives)

2.
Develop
Model
Facilities
and
Scale­
Up
Procedures
3.
Develop
Control
Options
°
Estimate
costs
­
Capital
and
operating
costs
­
Regulatory
costs
°
Estimate
pollutant
reductions
4.
Prepare
Report
and
Documentation
1.
Gather
Information
Information
Needs
°
Identify
focus
industries:
those
which
generate
wastewater
containing
the
pollutants
of
concern
(
aniline,
benzo(
a)
pyrene,
benzo(
b)
fluoranthene,
benzo(
a)
anthracene,
dioxin
and
dioxin­
like
compounds,
polycyclic
aromatic
compounds,
and
sodium
nitrite);
°
For
the
focus
industries,
identify
the
number
of
OCPSF
facilities
by
product
type
(
use
http://
www.
census.
gov/
prod/
ec97/
97m3251d.
pdf);
and
°
Identify
pollution
reduction
technologies,
their
costs,
and
pollutant
reduction
potential
for
focus
industry
wastestreams.

Industry
Profile
and
Identification
of
Pollutants
of
Concern
°
Review
NPDES
permits
and
fact
sheets
from
states,
EPA
regions,
and
on­
line
sources.
2
OCPSF
Detailed
Study
Plan
­
Revised
December
29,
2003
°
Continue
contacting
select
sites
to
determine
if
the
processes
generating
certain
pollutants
(
e.
g.
dioxin)
fall
within
the
scope
of
the
OCPSF
Category
and
to
confirm
assumptions
regarding
TRI
reporting.

Questions
to
address:

°
Which
facilities
fall
in
the
focus
industries?
How
many
facilities
are
in
each
industry
in
the
1997
U.
S.
Census?
Do
they
report
to
TRI?
If
yes,
how
many
are
direct,
indirect,
or
zero
discharge?

°
What
are
the
reported
discharges
to
TRI
and
PCS,
in
pounds
per
year
and
toxic
weighted
pound
equivalents
(
TWPE)
per
year
for
2000?

°
Are
the
TWPE
mostly
from
directs
or
indirects?

°
What
is
the
TWPE
discharged
per
facility?

°
Are
production
data
available?

Baseline
Pollutant
Loads
°
Revise
baseline
loads
and
assumptions
used
for
the
first
analysis
based
on
additional
information
for
the
focus
industries.

°
Sort
out
the
toxic­
weighted
pounds
for
sites
that
are
not
representative
of
typical
OCPSF
sites
and
consider
them
separately
from
the
OCPSF
total
(
e.
g.,
dioxins
from
Dow
Chemical
in
Freeport,
Texas
and
Dow
Chemical
in
Plaquemine,
Louisiana).

°
Sort
out
the
toxic­
weighted
pounds
from
sites
when
the
process
generating
the
pollutant
is
not
regulated
by
OCPSF
and
consider
them
in
the
proper
point
source
category
(
e.
g.,
dioxins
from
chlor­
alkali
producers).

°
Use
data
from
the
Chlorine
Chemistry
Council
(
http://
www.
c3.
org)
and
the
Vinyl
Institute
on
dioxin
for
the
EDC/
VCM/
PVC
manufacturers.

°
Use
available
site­
specific
data
on
polycyclic
aromatic
compounds
to
better
characterize
the
specific
chemicals
discharged
and
then
apply
a
more
industryspecific
toxic­
weighting
factor
to
TRI
data
for
discharges
from
coal
tar
refiners.

°
Use
the
background
documents
to
the
Dyes
and/
or
Pigment
Production
Wastes
Hazardous
Waste
Proposed
Rule
dated
November
25,
2003
to
better
characterize
wastewater
discharges
from
dye
manufacturers.
3
OCPSF
Detailed
Study
Plan
­
Revised
December
29,
2003
°
Identify
additional
data
sources
to
better
characterize
wastewater
discharges
from
dye
manufacturers.

Questions
to
address:

°
What
pollutants
are
discharged
and
how
much
(
base
year
is
2000)?

°
How
can
the
pollutant
loadings
be
scaled
to
the
whole
focus
industry?

°
Where
do
the
discharged
pollutants
come
from
(
i.
e.,
is
there
a
process/
product
combination
of
the
focus
industry
that
is
responsible
for
the
certain
high
toxic
loads,
such
as
diazo
dye
manufacturing)?

Applicable
Control
Technology
°
Identify
pollution
prevention
and
treatment
technologies.
Use
data
from
EPA's
Office
of
Pollution
Prevention
and
Toxics
(
OPPT)
to
identify
potential
process
changes,
feedstock
replacements,
or
other
means
of
pollution
prevention.
Identify
any
treatment
technologies
that
can
be
added
to
the
current
treatment­
in­
place.
Perform
a
literature
search
and
talk
to
treatment
technology
vendors.

°
Target
technologies
that
will
reduce
toxic
loads.
Evaluate
the
cost
per
pound
of
toxic
load
removed.

°
One
candidate
add­
on
end­
of­
pipe
technology
is
granulated
activated
carbon
(
GAC).
Use
data
from
vendors
and/
or
previous
effluent
guidelines
for
cost
and
performance
data.

°
Identify
the
treatment
in
place
at
manufacturers
of
diazo
dyes
reporting
aniline
discharges
to
TRI.

°
Identify
any
additional
control
technologies
that
can
be
applied
to
other
OCPSF
focus
industries.
Perform
a
literature
search
and
talk
with
treatment
control
technology
vendors.

Questions
to
address:

°
What
pollution
prevention
and
treatment
technologies
can
be
applied
to
the
focus
industry?

°
What
pollutants
(
in
addition
to
the
pollutants
of
concern)
will
these
technologies
help
control?
4
OCPSF
Detailed
Study
Plan
­
Revised
December
29,
2003
2.
Develop
Model
OCPSF
Sites
and
Scale­
up
Procedures
°
Identify
representative
discharging
facilities
from
each
focus
industry
and
gather
all
available
data.

°
Develop
"
model
sites"
based
on
the
representative
facilities.

°
Develop
a
scheme
to
scale
up
models
to
full
industry
(
i.
e.,
develop
the
weights
or
scale­
up
factors
that
will
be
applied
to
each
model).

°
To
the
extent
possible
validate
the
model.
This
may
be
limited
to
pollutant
discharges
(
e.
g.,
do
baseline
model
discharges,
extrapolated
by
scale­
up
procedure,
result
in
the
total
reported
discharges
from
PCS2000
and
the
2000
TRI?).

°
Search
for
literature
(
e.
g.,
from
vendors)
or
case
studies
for
potential
use
in
validating
model
costs.

3.
Develop
Control
Options
Including
Estimating
Costs
and
Pollutant
Reductions
°
Identify
feasible
pollution
reduction
technologies.
Investigate:


Whether
any
of
the
focus
industries
do
not
have
biological
treatment
in
place.
For
example,
if
dye
manufacturers
do
not
have
biological
treatment,
evaluate
if
adding
it
would
be
cost
effective.


Process
changes
that
will
eliminate
or
reduce:

S
wastewater
discharge
volume;
or
S
amount
of
pollutants
discharged
to
wastewater
(
recycle
and/
or
reuse
of
feedstock).


Granular
activated
carbon
as
an
add­
on
technology
for
end­
of­
pipe
or
inprocess
wastestream.

°
Collect
capital
and
operating
cost
and
performance
information
for
relevant
model
site
applications.
Also
collect
information
on
monitoring
and
reporting
requirements.
Data
sources
include
previous
effluent
guidelines,
literature
reviews,
and
contacting
equipment
vendors
(
get
prices
for
sizes
that
reflect
the
model
sites).

°
Estimate
costs
and
pollutant
reductions
achievable
by
implementing
the
control
options
at
each
model
site
and
scale­
up
to
estimate
the
costs
and
reductions
5
OCPSF
Detailed
Study
Plan
­
Revised
December
29,
2003
achievable
for
the
entire
industry.
Format
of
output
must
be
useable
by
economists
for
analyzing
economic
impact
and
cost
effectiveness.

°
Consider
nonwater
quality
impacts,
particularly
air
emissions
and
Resource
Conservation
and
Recovery
Act
(
RCRA)
hazardous
waste
regulations
(
i.
e.,
would
any
of
the
residues
created
by
wastewater
treatment
be
hazardous
wastes?).
Note:
Some
wastes
from
azo
dye
production
(
e.
g.
aniline
distillation
bottoms)
are
listed
hazardous
wastes.

Questions
to
address:

°
Are
there
control
technologies
used
by
the
industry
in
addition
to
biological
treatment
for
control
of
organic
pollutants?

°
Do
dye
manufacturers
use
biological
treatment?

°
Should
other
technologies
be
applied
to
the
industry
to
control
discharge
of
organics
(
e.
g.,
GAC)?
What
will
they
cost?

°
Do
publicly­
owned
treatment
works
(
POTWs)
adequately
treat
wastewater
from
indirect
dischargers
(
i.
e.,
control
discharge
of
toxic
organics
and
color)?

°
How
much
will
implementing
these
solutions
reduce
pollutant
discharges
from
direct
and
indirect
dischargers?
Eliminate
technologies
that
have
high
costs
and
low
pollutant
removal
from
further
analysis.

4.
Prepare
Report
and
Documentation
Draft
study
report
will
include:

°
Industry
profile;
°
Rationale
for
selection
of
focus
industries;
°
Baseline
pollutant
loads
(
including
TWPE);
°
Descriptions
of
pollution
control
options;
°
Costs
&
removals
for
each
analyzed
option;
°
Documentation
of
the
methodology
used
to
estimate
costs
and
pollutant
reductions;
and
°
Discussion
of
the
quality
of
the
data
used
for
these
estimates,
including
"
data
gaps."
