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Textile Process Wastewater Permits:An Update And Strategies

Note:-(Michael L. Leonas is affiliated withM. R. Chasman & Assoc.. Athens. GA.)

IntroductionOver the past twenty years in-

creased attention has been directedtoward the environment. Efforts toclean up the environment and keep itclean have been made by governmentagencies at national, state and locallevels by establishing guidances andregulations. Industries and individualsare also more aware of those condi-tions that negatively impact the envi-ronment. One of the primary concernsis water quality. Because of the highquantity of water and the number ofmetals used in the processing of tex-tiles, the textile industry will be signifi-cantly impacted by the recent regula-tions.

1990 EPA issued a technical guid-ance document for use in water qualitycontrol. These guidelines more thantripled the number of toxic pollutantsof interest and include chemical con-

stituents commonly found in textileprocessing. To successfully complywith these regulations, those in thetextile industry must be knowledgeableof permitting strategies and participatein the process before the issuance ofthe permit.

Historical perspectiveThe Clean Water Act (CWA) was

passed as public law in 1972 and the

National Pollutant Discharge Elimina-tion System (NPDES) permit system

was established to ensure that indus-tries and Publicly Owned Treatmentworks (POTW) were monitoring andcomplying with the stipulations of thislegislation. Since 1972 the public hasbeen requesting federal and state reg-ulatory agencies to increase the scopeof environmental protection and con-trol to provide a more pristine environ-ment.

All states were to incorporate thecriteria into their water quality rules byMarch 1990. This forced many statesto adopt the criteria without investiga-tion or adjustment of the natural crite-ria.2 One primary area of concern forthe textile industry is the increasednumber of metals now identified by thenew criteria.

In response to public demand, theWater Quality Act (WQA) was autho-rized by Congress in 1987. The pur-pose of the water quality act focused

Across all industries, the cost tocomply with treatment for the metals isoverwhelming and has been estimatedat 90 to 105 billion dollars. It has beenestimated that 6000 to 8000 U.S. dis-chargers will receive stringent metalslimitations if historical application ofEPAs metal criteria continues. In addi-

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By Karen K. Leonas, Ph.D, Michael L.Leonas, P.E.* The Univ. of Georgia,

Athens, GA

on the control of substances toxic toaquatic and human life. This differeddrastically from the CWA which wasprimarily concerned with maintaining a

minimum dissolved oxygen level in re-ceiving waters. The WQA was exten-sive and the United States Environ-mental Protection Agency (EPA) wascharged with implementing guidelinesfor state and local regulatory agenciesto follow.

EPA, pursuant to its authority under

Section 304(a) of the Clean Water Act,has published water quality criteria tohelp develop permit conditions for toxicpollutants. These criteria are intendedfor national application but may be re-placed, when appropriate by site spe-cific criteria.

The guidance document, EPA Quali-ty Criteria for Water issued in 1987 by

EPA, significantly altered the permitwriting process.1 The NPDES permittingsystem originally introduced in 1972still remains as the method for controlof discharges. The 1987 documentidentified 129 chemical constituents tobe monitored where previously therehad been only approximately 30. In ad-dition, thus document specified detec-tion limits, test methods to be usedand utilized stream models for the de-termination of discharge limits.

tion, approximately 30 to 50% of the

dischargers will need to install alternateprocesses (i.e. reverse osmosis and tonexchange) to meet the new limitations.

Impact on the IndustryFactors that make the textile indus-

try extremely susceptible to significantchanges include the high quantity ofdischarge, metals used in textile pro-cessing and metals found inherently in

the natural fibers. A number of metalsnow identified the 129 chemical con-stituents are used in textile processing,therefore textile facilities will be particu-larly impacted. Whether the mill oper-ates its own treatment system or dis-charges to a POTW facility, they will beheld accountable for their dischargesas everyone struggles to comply withthe new regulations.

Prior to 1990 NPDES permits con-trolled items such as pH. temperature,sulfides, chromium, etc. for the textileindustries. With the implementation ofthe WQA via the 1987 criteria, textilefacilities will particularly be Impacteddue to the high quantity of discharge,the metals used in typical texti leprocesses and metals inherent in nat-ural fibers.

Quantity of Discharge

In North Carolina the textile industryis the largest water user and waste-

water producer.4 The historical data ofwater usage and discharge has beenpresented and discussed by Smith. Alarge mill could produce over two mil-lion gallons of wastewater per day,which is discharged into treatmentsystems then to the environment.

Use of Metals

Metals are used in a variety of pro-cessing techniques throughout thetextile industry, Including oxidizers forvat and sulfur dyes, aftertreatment ofdirect dyes, metal catalyst used for

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curing resins, finishes (i.e., flame retar-dant, soil release, and water repellent),dye stripping agents, and variousclasses of dyes.5

Of the six common dye classes,acid, basic, direct, disperse, fiber re-active and vat all contain metals in-cluding chromium, arsenic, cadmium,mercury, copper, lead and zinc, all ofwhich are now targeted by the newcriteria. Prior to 1990 these chemicalsmay have been subcategory specific,however today they are equally appliedto all subcategories. Table I lists vari-ous dye categories which contain met-als that are controlled via the new wa-ter quality criteria.6

Metals Inherent in natura/ fibers

In some cases the greige goodsalso contain metals; this is from metalsinherent in the fibers (Table II).4 Of the36 elements found in cotton, half aretargeted by the new water quality cri-

teria. Although it is not a metal, chlo-rine was also detected and is con-trolled by the NPDES permits.

Given the potential for substantialimpacts to textile facilities from the pa-rameters controlled in the NPDES per-mits, it is important for permit appli- /

Table I: Average metal content of selected dyes (ppm).

Dye ClassFiber

Metal Acid Basic Direct Disperse Reactive Vat

Arsenic

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tion should be given to whether themodel assumptions reflect expectedconditions in the receiving stream.

The use of probablistic modeling inits new water quality criteria has been

promoted by EPA. However, appli-cants must ensure that these proce-

dures are allowed in state rules andused in calculating the permit limita-

tions.

Designated use also influences thedetermination of permit limits. Desig-

nated use classifications include drink-ing water, wild and scenic, recreation,

and fish reserves, which have varyingwater quality criteria.

Characterization of discharge waterIdentifying the sources in the plant

that produce discharge waters and de-termining the approximate quantity

discharged from each source is criti-cal. Identifying those chemicals thatare used in various processes is criti-

cal in evaluating the discharge.

Effluent monitoring

Data collected up to 18 months pri-or to the permit application can besubmitted with the application. It istypical to submit only one data pointand then the permit is prepared basedon that information. However, with themore stringent limitations it is advanta-

geous to provide a mean value fromwhich the permit limit is established.

The location of sample collectionshould be reviewed to ensure that it

reflects what is being discharged afterall treatment processes. Sometimes it

may also be appropriate to collect thesample downstream of the mixingzone but within the established regula-tory guidelines.

Site Specific standards

Sample analysisIt is critical to use approved analyti-

cal methods and laboratory (some-times referred to as a contract lab) asspecified by the regulatory agency. In

some cases the test methods do notaccurately simulate site conditions,therefore, it is advantageous to pro-

vide additional data to correct skew-ness inherent in the methods by the

permitting agency.

Where one or more assumptions

underlying the standard are not applic-able to the receiving stream, applica-

tion for site specific standards may beappropriate. EPA has issued guidanceon how to derive site-specific stan-dards.g Using one of the three method-

ologies approved in that guidanceshould be acceptable to the regulatoryagency.

Review results

In developing site-specific stan-dards, it is first necessary to review

the receiving streams designated use,which defines the receiving streamsactual and potential beneficial uses.Water-quality criteria and standards

are intended to protect the uses identi-fied. Applicants may find that thestates designated use is outdated orotherwise inadequate. The applicantshould then consider providing addi-tional information.

Test results should be reviewed for This information could include iden-accuracy prior to submission to the tification of current uses, causes ofpermitting agency. Evaluation to deter- use impairment, and potential usesmine if additional testing is necessary given the chemical, physical and bio-can be completed, and it may be ap- logical characteristics of the stream.propriate to apply for a site specific EPA then recommends the importantdischarge request. chemical, physical, and biologlcal fac-

An example presented by Hall,Raider and Grafton is a situation where

elevated hardness or TOC are present,the pH and temperature vary signifi-cantly from the EPA laboratory condi-tions used to develop the water-quality

criteria.g In this situation, the receivingand effluent stream may be allowed asuse as the test water.

tors that should be considered when

establishing site-speclfic standards.

The Water Quality Standards Hand-book identifies three alternate ap-proaches for developing site-specificwater-quality standards. The appropri-ate approach will depend on whether itis the biological, chemical, or physicalassumptions of the state-wide stan-

dards that should not apply to the re-ceiving stream.

Another concern is whether the testspecies could reasonably inhabit the

receiving stream. Temperature, pH, orother chemical and physical limitationsof the receiving stream may be suchthat the test species is not likely topopulate the stream. In this case, theapplicant should use a substitutespecies that probably populate the re-

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ceiving stream.For each of the three protocols,

EPA has provided guidelines to identifywhen each is appropriate and the im-plementation of that protocol. Each

approach requires the permittee to as-semble sitespecific data and to recal-culate a water-quality standard. Oncethe standard is recalculated and ap-

proved, the regulatory agency mustapply the permitting rules to translate

the water-quality standard into effluentlimitations.

The site specific discharge requestmust include data sufficient to calcu-late a reasonable alternate limit and in-formation showing the requested limit

will result in no degradation of the wa-ter quality. This effort should be coor-dinated with the permitting agency pri-

or to the submission to prevent delaysand misunderstandings.

The implementation of the waterquality criteria has been difficult forvarious reasons. Some of those in-

clude inadequacies in test methods,calculation of limits, inadequacy oftechnology to monitor and control. Themethodologies commonly used by per--nit writers drastically overstate thebioavailable fraction of heavy metals ineffluent and receiving waters. As a re-

Table III: Industrial Subcategory as in40CFR 410 Textile Mills Point SourceCategorya. Wool scouringb. Wool finishingc. Low water use

processingd. Woven fabric finishing

e. Knit fabric finishing

f. Carpet finishing

g, Stock and yarn finishing

i. Felted fabric processing

suit, the permit restricts the dischargeof metals that could pose no threat tohe environment. The permit limitationsare intended to regulate only bioavail-

able metals. However, many state per-mitting authorities and EPA regions donot reflect this.

Due to increased public awarenessof environmental issues and public de-mand for a cleaner environment, future

environmental regulations are in-evitable. One example would be issuespertaining to the reauthorization of theclean Water Act.g.1O There continues tobe advocates in the U.S. Senate andU.S. House of Representatives asdemonstrated by the Senate Bill enti-

32

tled Water Pollution Prevention anControl Act of 1993 introduced iJune, 1993.11 In November 1992, thEPA proposed the National ToxicRule that would implement water qualty criteria for states which have noadopted such criteria.1 This could result in the imposition of further limitations and conditions on NPDES Permits. Recently, legislation was introduced, H.R. 2199, that proposes a tax

ranging from 6 cents to $63 per poundon discharges of 307 different chemicals.

The cost is based on the toxicity othe chemical. Industrial and commercial consumers would pay a tax o

1.95 cents for each 1000 gallons owater used.12

All taxes collected would be con-tributed to a clean water trust fundMajor areas of concern include waterpollution prevention, water quality science, toxic water pollutant control, ac-curate assessment of compliance and

water pollution control funding.EPA continues to set water en-

forcement records in convictions, ad-ministrative orders, and civil and crimi-nal penalties. This includes companyofficials serving prison sentences andmonetary assessments in the millionsof dollars. The enforcement office hasstepped up its efforts to crack downon polluters earlier in the enforcemenlcycle and are developing a criminal en-forcement program that will include alarger staff of criminal investigatorswho will be better trained in investiga-

ive techniques.According to LaJuana Wilcher of

EPA the states tell us that 75% ofheir waters meet water quality stan-dards. That is not enough. This yearwere going after the remaining 25%using all of our tools.

SummaryEPA has recently recognized prob-

ems with the implementation of thetoxic criteria. Many states have notadopted the toxic criteria which EPAimposed. Some states have adopted

toxic criteria but are not fully imple-nenting them. This has created an un-level playing field in which industriesliterally face closure and relocation toother states and in which municipali-ies have been issued NPDES permitswith limits that are unattainable and

innecessary for toxicity control.The EPA-imposed toxic criteria for

metals are an ineffective and detrimen-al tool for eliminating toxicity. Thereare three fundamental problems withthese criteria:

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1. Many of the criteria are belowlaboratory detection limits and con-sequently states cannot determineif rivers are in compliance with stan-dards. Also, NPDES permit effluentlimitations resulting from the stan-dards are below detection limitsand are unenforceable.

2. Achievement of the standardsand resulting effluent limitations areunattainable in many instances. Themetals in municipal effluent come

from plumbing (primarily copper,zinc and lead). Technology is notavailable to reduce the concentra-tions to meet the effluent limits re-sulting from the water quality stan-dards

3. The criteria are over-protec-tive. There are many streams in theSoutheast which have natural metalconcentrations (especially zinc)

which far exceed EPAs criteria, yetalways support a healthy and bala n ce d f is h p op u la t io n . Alsostreams below municipalities andindustries with calculated execeedances of toxic criteria alsosupport fish life. Finally, many of thesupposedly toxic effluents routinelypass acute and chronic bioassays.Fortunately, the Interim Guidance

on lntrepretation and lmplementatiorof Aquatic Life Criteria for Metals is

providing some assistance to all parties in the permitting process. In factthe interim guidance recognized thatcurrent procedures may result in overestimating toxicity.

One solution recommended by EPAis the water-effect ratio. This involve!measuring a pollutants water-effectratio into the receiving water covererby the water quality standard. As a re

sult of the complexity of metal chem-istry, there is not one chemical analyti-cal method that can accurately deter-mine the metals that are bioavailableand toxic. Therefore, EPAs guidanceallows an adjustment in the numericmetals criteria. The water-effect ratiocompares the toxicity of a pollutant in

actual site water to its toxicity in labo-ratory water for two or more aquaticspecies. Since the metals toxicity inlaboratory water is the basis of astates numeric criteria, the water-ef-

fect ratio could be used to derive asite-specific criteria.

In the 1987 Clean Water Amend-ments, Congress anticipated that nu-meric criteria will not be applicable forall streams. Paragraph 303(C)(2)(B)provides that States shall adopt nu-meric criteria for pollutants the dis-charge or presence of which in the af-

fected waters could reasonably be ex-pected to interfere with those desig-nated uses adopted the state.

To date many state permittingagencies have not addressed this con-gressional directive in its water quality

standards. c c c

References

(1) Nichols, A.B. EPA Firm but Flexible onToxics. Water Environment & Technology,Vol. 5, No. 1, January 1993, 60.

(2) Hall, J.C. and Raider, R.L. A Reflectionon Metals Criteria Water Environment &

Technology, Vol. 5. No. 6. June 1993, 63.(3) Nichols, A.B. 1991: A Banner Year forWater Enforcement. Water Environment &Technology, Vol. 4. No. 3, March 1992, 14.(4) Smith, C.B. Reducing Pollution in Warp

Sizing and Desizing. Textile Chemist & Col-orist, Vol. 24, No. 6, June 1992. 30.(5) Smith, C.B. Identification and Reduction

of Pollution Sources in Textile Wet Proces-sing, Pollution Prevention Program, NorthCarolina Department of Environment, Health,and Natural Resources, 1986.(6) Smith, B. Pollutant Source Reduction:

Part II -Chemical Handling. American Dye-stuff Reporter, April, 1989, 26.

(7) Title 40, Code of Federal Regulations,Part 410.

(8) Hall, J.C., Raider, R.L. and Grafton, J.A.EPAs Heavy Metal Criteria, Water Environ-ment & Technology, Vol. 4, No. 3, March1992, 60-63.(9) Bagwell, S. Clean Water Act Reauth-

orization Bill Introduced in Senate. WaterEnvironment & Technology, Vol. 3. No. 8,August 1991, 18-20.(10) Nichols, A.B. CWA ReauthorizationSchedule, Water Environment & Technol-ogy, Vol. 3, No. 8, August 1991, 19.(11) Regulatory Update, Water Environ-ment & Technology, Vol. 5, No. 8, August1993, 11.(12) Polluter Pays The National Environ-mental Journal. Vol. 3. No. 5, September/ Oc-tober 11.

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