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A common by-product in the pesticide manufacturing industry is hydrochloric acid. Product also flows continuously out of the reactor. Analytical methods are unavailable for 14 other PAIs, so the Agency d,703 not gather data.

These data are aggregated to include all sampling episodes, and, therefore, the minimum and maximum concentrations may have been reported for wastewater samples collected at different facilities.

These two types of operations are part of the Pesticide Chemicals Formulating and Packaging Subcategory which will be covered under a separate rulemaking at a later date.

Figure presents a flow chart of the methodology for ratasheet which PAIs were included datasneet the Pesticide Manufacturing Facility Census of Accidents are very infrequent and these showers are therefore seldom used. Included for consideration with the data submitted with the EPA surveys were selected data obtained from these EPA short-term sampling efforts conducted at pesticide manufacturing facilities between and Twenty-two facilities reported that no priority pollutants would be expected datasheett their pesticide manufacturing process wastewaters, and the other 21 facilities did not know whether priority pollutants would be present.

The primary product of a manufacturing establishment is determined by the value of production.

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The hydrolysis studies used PAIs selected in part based on the existence of hydrolysis data gathered from a literature survey for comparison with EPA treatability study resultsand in part based on the lack of any literature data, datasyeet as to fill in those data gaps. Commingling of untreated waste streams contaminates much larger volumes of wastewater, which could then be more difficult and costly to treat. Four PAIs were evaluated as part of these tests which use bench scale results to estimate full-scale carbon system performance, design and cost.

In some cases, this was because EPA did not sample at the facility reporting the priority pollutant, and in other cases, the PAI process associated with the reported priority pollutant was not in operation during EPA sampling at that facility. An operating establishment is assigned an industry code on the basis of its primary activity, which is determined by its principal product or datasueet of products.


The category also includes a large variety of manufacturing processes and wastewater characteristics. Responses to the questionnaire by these facilities indicated that 90 facilities manufactured pesticides in Interim Final BPT Guidelines The interim final BPT effluent limitations datadheet promulgated November 1, for the pesticide chemicals point source category established five subcategories: The long-term data submitted by daatsheet contained mostly PAI data.

None of the pesticide plants sampled or visited have any petroleum oil problems in wastewater; the oil and grease measurements reflect only gross levels of organics and are poor measures of priority pollutants and PAIs because there are much more accurate pollutant-specific methods for these parameters. That is, EPA collected wastewater samples at 23 of the 32 facilities visited. Thermal and steam regeneration are most commonly used for carbon from wastewater treatment.

In addition, the available bench scale treatability data are inadequate and there are no structurally similar PAIs with data which could be transferred. EPA promulgated interim final BPT guidelines for the pesticide point source category establishing a subcategorization approach which included five subcategories. A PAI is manufactured by the chemical reaction of two or more raw materials often in the presence of solvents, catalysts, and acidic or basic reagents.

In many cases, the PAI was reported above the detection limit in every sample that was analyzed.

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The purpose of this procedure was to minimize any potential degradation reactions, including biological activity, that could occur in the samples prior to analysis. The economic analysis evaluating whether attainment of these limitations is economically achievable by pesticides manufacturers has been performed independently as part of today’s proposed rulemaking. The Agency found that the pesticide chemicals manufacturing industry primarily selects in-plant controls for the removal of highly concentrated pollutants from process wastewaters.

Facilities located in urban areas have higher land costs for treatment facilities. Four of these seven were among the 20 facilities sampled in order to characterize process discharges and treatment system performance.

Either the plants do not monitor for the PAI or the available data are inadequate to demonstrate that the technology in use is the best available technology. The other four priority pollutants being proposed for regulation today were not regulated under OCPSF and there are no treatment performance data for these four specific pollutants.


In addition to the data submitted in response to the survey, the Agency reviewed and considered long-term data from six plants from the earlier EPA survey containing data from the mid- to late s. Liquid and solid wastes include hazardous and nonhazardous organic and inorganic wastes as well as wastewater.

Similar to the data submitted for the conventional pollutants, the industry data indicate widely-scattered COD levels in in-plant process streams, but consistently low COD levels in end-of-pipe discharge are summarized in Figure Following the visit, a draft sampling plan was prepared which provided the rationale for the selection of sampling locations as well as the procedures to be followed during sampling.

A Notice of Availability NOA appeared in the June 13,Federal Register, which presented on alternative subcategorization approach of three subcategories.


As discussed in Section 5. EPA used its experience with previous questionnaires, including the questionnaires distributed ddl703 the pesticides industry for the remanded regulation, to develop a draft questionnaire for this study. Pesticide active ingredients may also be used as raw materials in manufacturing derivative PAIs typically through the formation of various salts and esters. During continuous processes, raw materials and reagents flow continuously into the reactor and are converted into product while they reside in dataheet reactor.

The organic PAI regulation also limited total pesticides in wastewaters resulting from the manufacturing of 49 specific organics PAIs. The plaintiffs charged that EPA’s plan did not meet the requirements of Section m.

Total solids in wastewater is defined as the residue remaining upon evaporation at just above the boiling point. Continuous Processes Batch processes are those in which raw materials and reagents are added to a reactor, a reaction occurs, and then product is removed from the reactor. BPT effluent limitations guidelines are generally based on the average of the best existing performance by plants of various sizes, ages, and unit processes within the category or subcategory for control of pollutants.

For more details, see 52 FRNovember 5, The Amendments added Section b 2 E to the Act establishing BCT for discharges of conventional pollutants from existing industrial point sources.