Industrial Wastewater Study

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2 Industrial Wastewater Study Executive Summary Effluent of six industrial wastewater facilities, including a variety of industrial practices and covering a wide range of discharge flow rate, was sampled a total of three times during June of Five of them are located in Harris County and the other one is located in Waller County. Samples were analyzed for Escherichia coli, fecal coliform, enterococci. The samples from two facilities were always within the in-stream water quality standards, while samples from one facility exceeded the in-stream water quality standards in all three sampling events. The other three facilities were found to discharge high bacteria level effluents at times. The results indicate that there are industrial facilities in Harris County and surrounding areas that discharge high bacteria level effluent into the receiving waters occasionally or often. The U.S. EPA NPDES database shows that most of these facilities do not have any monitoring records for fecal bacteria in their effluent. It is recommended that TCEQ consider requiring those industrial facilities which comingle the sanitary or storm water sewer generated from their sites with their processing water to monitor and report the fecal bacteria data when they renew their TPDES permits Sample Collection During June of 2008, the effluent of six industrial wastewater facilities was sampled a total of three times, on June 10 th, 17 th and 24 th, all under dry weather conditions. The samples were analyzed for fecal coliform, E. coli and enterococci. Flows were measured at the time of sampling. The field sampling procedures, techniques, and preservation requirements used in this project strictly followed Texas Commission on Environmental Quality s (TCEQ s) Surface Water Quality Monitoring Procedures Manual, Volume I (TCEQ 2003). A QAPP was developed before the sampling efforts began. This QAPP details the procedures related to sample collection, handling and analyses in this project. Exhibit 1 shows the sampling locations for these facilities. Information for the six facilities obtained from the U.S. EPA NPDES database (U.S. EPA 2008) is presented in Table 1. The six facilities include a variety of industrial practices ranging from utility services and lodging to plastics production, etc. (Table 1). The permitted daily average flows for these facilities cover a wide range from MGD (10.4 GPM) to 3.95 MGD (2,743 GPM). These facilities were chosen due to the likelihood of combining sanitary waste with process wastewater. All effluents were collected at the end of pipes (i.e. the outfall to the receiving water), which are considered to be the mixture of various types of wastewater generated at the facilities. It is noted that effluents from five of the six facilities are reported to contain sanitary waste. The other one (Shell Chemical) is likely to mix storm water with process wastewater (Table 1). Harris County provided the contact information of the operators of these facilities. Information on the effluent treatment techniques used at these facilities was collected via phone calls using the contact information and included in Table 1. 1

3 Industrial Wastewater Study Results and Discussion In Texas, the TCEQ has adopted an in-stream E. coli standard of 126 units per 100 ml for the geometric mean and 394 units per 100 ml for the single sample maximum in waters designated for primary recreations; and 605 units per 100 ml for the geometric mean in waters designated for secondary recreation. The in-stream fecal coliform standard is 200 units per 100 ml for the geometric mean and 400 units per 100 ml for the single sample maximum in receiving water bodies, with no designation for primary or secondary recreation. The State of Texas also has an enterococci standard for tidal waters, which is 35 units per 100 ml for the geometric mean and 89 units per 100 ml for the single sample maximum in tidal waters designated for primary recreation, and 168 units per 100 ml for geometric mean in tidal waters designated for secondary recreation (TCEQ 2000). The observed bacteria levels in effluent samples varied by site. The bacteria levels in the effluents were compared with the corresponding in-stream standards. Those samples containing bacteria higher than the in-stream single sample maximum standard for primary recreation are considered to have a high level of bacteria. Three different categories were established for classifying the sample results. One category is defined by no occurrences of high bacteria levels found in any of the three sampling events, while another is the occurrence of high bacteria levels in all three sampling events. A third situation is the occasional high bacteria level found in any of the samples. The monitoring data and loading calculations are presented in Table No Occurrence of High Bacteria Level in Effluent Igloo Products and Shell Chemical Samples taken from two industrial wastewater facilities: Igloo Products and Shell Chemical, each resulted in low bacterial values (lower than the laboratory minimum detection limits for all three types of bacteria) for all three sampling events (Table 2). The U.S. EPA database (U.S. EPA 2008) indicates that both of these facilities are required to monitor fecal coliform levels in their effluents; no fecal coliform data is reported at Igloo Products; and Shell Chemical reported eleven monitoring events conducted from November 30, 2007 to September 30, 2008 and both average and maximum values for all eleven events are reported to be 1 unit per 100 ml. 2. High Bacteria Level in Effluent Found in All Three Sampling Events Pegasus Polymers High levels of bacteria occurred in samples taken from Pegasus Polymers during all three sampling events. The first sampling event resulted in a high value for enterococci (1,860 cfu per 100 ml), approximately times higher than the standard for single sample maximum. Although the fecal coliform and E. coli concentrations (300 cfu per 100 ml and 132 mpn per 100 ml, respectively) in the first sampling event did not exceed the corresponding in-stream standard for single sample maximum, they did exceed the in-stream standard for geometric mean. All three types of bacteria were found in high numbers during the second sampling event; fecal 2

4 Industrial Wastewater Study coliform (730 cfu per 100 ml), E. coli (441 mpn per 100 ml), and enterococci (1,430 cfu per 100 ml). The same occurred during the third sampling event, but at much higher levels; fecal coliform (3,800 cfu per 100 ml, 9.5 times higher than the instream standard for single sample maximum), E. coli (3,654 mpn per 100 ml, approximately 9.27 times higher than the in-stream standard for single sample maximum), and enterococci (4,600 cfu per 100 ml, approximately times higher than the in-stream standard for single sample maximum). The highest value of 4,600 cfu per 100 ml for enterococci in this study occurred during the third event at this facility. The U.S. EPA database indicates that this facility is not required to monitor bacteria levels in its effluent and no bacteria data is reported. 3. Some High Bacteria Level in Effluent Found in Three Sampling Events NRG Texas Power, Ashbrook Corp. and Haliburton Energy Services Samples from NRG Texas Power and Ashbrook Corporation each had relatively low bacterial values for the majority of the samples. The exceptions occurred during the first sampling event, when both sites resulted in high enterococci numbers; 1,030 cfu per100 ml (approximately times higher than the in-stream standard for single sample maximum) at NRG and 100 cfu per 100 ml at Ashbrook. Halliburton Energy also exhibited some low bacteria levels, with the exception of the second sampling event, which resulted in high levels for all three bacteria; fecal coliform (8,800 cfu per100 ml, 22 times higher than the in-stream standard for single sample maximum), E. coli (6,488 mpn per 100 ml, approximately times higher than the in-stream standard for single sample maximum), and enterococci (200 cfu per 100 ml, approximately 2.25 times higher than the in-stream standard for single sample maximum). Although Halliburton Energy Services did not always discharge high levels of bacteria in its effluents, the highest values for fecal coliform and E. coli (i.e. 8,800 cfu per 100 ml and 6,488 mpn per 100 ml, respectively) during the study occurred at this facility. The U.S. EPA database indicates that these three facilities are not required to monitor bacteria levels in their effluent and no bacteria data is reported. The effluent treatment at these facilities usually includes some types of secondary biological treatment and effluent disinfection using either UV lamps or chlorine (Table 1). However, the U.S. EPA database shows most of these facilities do not have any monitoring records for fecal bacteria in their effluent. Therefore, the bacteria levels in their effluent are unknown from the self-reported data. This study shows that there are possibilities that the effluent from industrial facilities could contain high level of bacteria but these high levels are not recorded and reported. The operators of these facilities may not be aware of the existence of high bacteria levels in their effluents. By calculating the Daily Load for each bacteria, the first sampling event at NRG resulted in the highest numbers for all three types of bacteria; fecal coliform (2.47E+10 per day), E. coli (1.86E+10 per day), and enterococci (9.43E+10 per day) due to the high volume of effluent flows. The standard deviations for each of the bacteria sampled in this study are as follows; 2,186 cfu per 100 ml for fecal coliform, 1,695 mpn per 100 ml for E. coli 3

5 Industrial Wastewater Study and 1,161 cfu per 100 ml for enterococci. The geometric mean for fecal coliform (42 cfu per 100 ml) and E. coli (31 mpn per 100 ml) are both within the water quality standard. The geometric mean for enterococci is 39 cfu per 100 ml, which exceed the water quality in-stream standard of 35 units per 100 ml. Note that one-half of the laboratory minimum detection limits were used in the statistical analysis and loading calculations for those samples less than the detection limits as a conservative assumption. Daily loads may be less than the calculated values if the actual concentrations in the samples were less than one-half of the detection limits. Figures 1 3 plot the effluent flow rates from these facilities versus the levels of the three indicator bacteria in the corresponding effluent. Note that if the bacteria concentration is less that the laboratory minimum detection limit, one-half of the limit was used to represent the bacteria concentration in the plots. In all three plots, the dots are scattered showing no linear or any other forms of correlation, indicating there is no noticeable correlation between the bacteria levels and the flow rates. Overall, the samples taken from two of the six facilities in this study were always within the water quality in-stream standards, while samples from one facility exceeded the instream water quality standards in all three sampling events. The other three facilities were also found to discharge high bacteria level effluents at times. This study indicates there are industrial facilities within the county that discharge high bacteria level effluent into their receiving waters occasionally or often, and the bacteria levels in the effluent are independent of discharge flow rates. Therefore, high bacteria level effluent could occur at an industrial facility of any size. Currently, monitoring and/or reporting of fecal bacteria in the effluents are not performed at many industrial facilities. It is recommended that TCEQ consider requiring those industrial facilities which comingle the sanitary or storm water sewer generated from their sites with their processing water to monitor and report the fecal bacteria data when they renew their TPDES permits. 4

6 Industrial Wastewater Study Reference: Texas Commission on Environmental Quality (TCEQ) Texas Surface Water Quality Standards , Texas Administrative Code (TAC) Chapter 307. Austin, Texas. Texas Commission on Environmental Quality (TCEQ) Surface Water Quality Monitoring Procedures Manual, Volume I (December 2003). U.S. EPA, query_java.html. (accessed Nov. 24, 2008). 5

7 Table 1. Information of the Selected Industrial Facilities Facility Name NPDES ID Address Permitted* Average Flow (MGD) SIC Code Receiving Stream Types of Wastewater Discharged Treatment Technology Disinfection Method Igloo Products, Corp Shell Chemical, LP and Equilon Enterprises, LLC TX TX Katy- Brookshire Rd, Waller, TX Hwy 6 S. Houston, TX (10.4) (330) Plastics foam products Commercial physical research Willow Fork of Buffalo Bayou HCFCD Drainage Ditch Utility wastewater, sanitary waste Process wastewater, storm water, 24- hour acute freshwater Wastewater goes through a treatment plant for biological treatment Activated sludge biological treatment chlorination UV lamps Pegasus Polymers TX Almeda Rd, Houston, TX (13.4) Custom compounding purchased plastics resins Drainage ditch, Sims Bayou Process wastewater, storm water, sanitary waste Wastewater goes through a package plant for biological treatment chlorination NRG Texas Power TX Tomball Pky, Houston, TX (2,743) Electrical services Facility drainage ditch, Greens Bayou Utility wastewater, sanitary waste, metal cleaning waste, 24-hr acute freshwater, 7-day chronic freshwater Treatment includes clarification with the addition of polymers to drop out solids and ph adjustment; Wastewater goes through a small package plant for biological treatment chlorination Ashbrook Corp. Haliburton Energy Services TX TX E. Hardy, Houston, TX N. Sam Houston Pkwy, Houston, TX (142) 0.07 (48.6) Pumps and pumping equipment Organization hotels and lodging houses, on membership basis Seg. No San Jacinto River Basin Greens Bayou Sanitary waste, utility wastewater Sanitary waste Facility has a small assembly plant and has municipal waste only; Wastewater goes to a package plant Aerobic contact stabilization chlorination chlorination * Numbers in parentheses are the permitted flows in GPM.

8 Table 2. Raw Data and Calculations Site Lab ID Date Time Samplers Velocity (f/s) Pipe Diameter (in) Water Height (in) Ditch Width (in) Water Volume (qt) Water Volume (gal) Time (sec) Time (min) Flow (gpm) Flow (cfs) Fecal Coliform (cfu/100ml) Fecal Coliform Daily Load (# bacteria/day) E. coli (mpn/100ml) E. coli Daily Load (# bacteria/day) Fecal Entero (cfu/100ml) Fecal Entero Daily Load (# bacteria/day) 6/10/08 10:01 RN, JM < E+07 < E+07 < E+07 Igloo Products IG 6/17/08 9:40 RN, LM < E+06 < E+06 < E+06 6/24/08 11:40 RN, LM < E+06 < E+06 < E+06 6/10/08 11:09 RN, JM < E+07 < E+07 < E+07 Shell Chemical SH 6/17/08 10:35 RN, LM < E+08 < E+08 < E+08 6/24/08 13:15 RN, LM < E+07 < E+07 < E+07 6/10/08 12:39 RN, JM E E+07 1, E+08 Pegasus Polymers PP 6/17/08 11:23 RN, LM ditch E E+08 1, E+08 6/24/08 14:10 RN, LM , E+09 3, E+09 4, E+09 6/10/08 14:29 RN, JM , E E+10 1, E+10 NRG Texas Power NRG 6/17/08 13:00 RN, LM 3.36 ditch , E E E+09 6/24/08 8:10 RN, LM , E E E+09 6/10/08 15:16 RN, JM < E+05 < E E+07 Ashbrook Corp. AC 6/17/08 13:40 RN, LM < E+05 < E+05 < E+05 6/24/08 9:10 RN, LM < E+06 < E+06 < E+06 6/10/08 15:45 RN, JM E E E+08 Haliburton Energy HE 6/17/08 14:10 RN, LM , E+10 6, E E+08 6/24/08 9:40 RN, LM E E E+07 Maximum 8, E+10 6, E+10 4, E+10 Geometric Mean E E E+08 Average E E E+09 Standard Deviation 2, E+09 1, E+09 1, E For those bacteria concentrations which are less than the laboratory minimum detection limit, one-half of the limit was used in the statistical and loading analysis. 2. Italic data indicates the value is higher than the geometric mean standard for in-stream primary recreation, but still lower than the single sample maximum standard. 3. Bold data indicates exceedance of the single sample maximum standard.

9 Figure 1. Fecal Coliform vs. Flow 10,000 1,000 Fecal Coliform (cfu/100ml) 100 Igloo Products Shell Chemical Pegasus Polymers NRG Texas Power Ashbrook Corp. Haliburton Energy Flow (cfs)

10 Figure 2. E. Coli vs Flow 10,000 1,000 E. Coli (mpn/100 ml) 100 Igloo Products Shell Chemical Pegasus Polymers NRG Texas Power Ashbrook Corp. Haliburton Energy Flow (cfs)

11 Figure 3. Fecal Enterococci vs. Flow 10,000 1,000 Fecal Enterococci (cfu/100ml) 100 Igloo Products Shell Chemical Pegasus Polymers NRG Texas Power Ashbrook Corp. Haliburton Energy Flow (cfs)

12 E IH 610 N E BW 8 S S SH 146 FM 1736 FM 362 FM 1488 FM 149 SH 249 FM 2978 IH 45 S IH 45 N FM 1314 LOOP 494 FM 1485 Industrial Outfalls City of Houston FM 362 E MAIN US HIGHWAY 59 Water Body Segment Line US 290 FM 2920 TOMBALL PKWY N IH 45 LP 494 County SH 6 E FM 1960 FM 1960 FM 362 US 290 N US 59 F:\NPDES-Permit1_AllYr\Mon_Scr\JTF Enhanced monitoring\07_field sampling\industrial Wastewater Study\Outfall_Locations.mxd FM 529 FM 359 FM 1489 FM 362 FM 359 SH 36 W FM 529 FM 2855 Igloo Products TX IH 10 SPUR 10 FM 1463 FM 723 Harris County AVE H FM 359 US 90A E FM 1093 GRAND PKWY FM 1464 US 90A NRG Texas Power TX N SH 6 N SH 6 N W IH 10 Shell Chemical TX US 90A SYNOTT SH 6 W BW 8 N S US 59 W BW 8 N W BW 8 S W BW 8 S S US 59 SH 249 S BW 8 W W IH 10 Halliburton Energy TX Ashbrook Corporation TX N BW 8 W WESTHEIMER RD W IH 610 N W IH 610 S N BW 8 W W IH 610 S S IH 610 W N BW 8 E N IH 610 W ALMEDA RD Pegasus Polymers TX FM 521 FM 2234 SH 288 SPUR 527 SH 288 S US 59 CULLEN BLVD N US 59 OLD SPANISH TRAIL HARDY S IH 610 E FM 518 N IH 610 E BROADWAY ST S IH 610 E N MC CARTY TELEPHONE RD E IH 610 N S BW 8 E N MAIN ST E IH 610 S E BW 8 E BROADWAY N BW 8 HOUSTON BLVD S BW 8 E S IH 45 E BW 8 E BW 8 N E BW 8 N E BW 8 S S IH 45 E BW 8 E IH 10 E BW 8 SH 225 GALVESTON RD US 90 FM 2100 BEAUMONT HWY SH 225 SH 330 FM 1942 N SH 146 N SH 146 SH 330 BAYPORT BLVD OLD HWY 146 SH 146 E IH 10 S SH 146 SH SPUR 55 LANIER DR K Miles Miles Industrial Wastewater Study Industrial Discharge Sampling Locations TCB 5757 Woodway Drive, Suite 101W Houston, Texas January 2009