Industrial Water Conservation and EPA s Effluent Guidelines

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Industrial Water Conservation and EPA s Effluent Guidelines 14 May 2009 ASME Water Conservation Conference Washington, DC

Topic Overview Overview of the importance water conservation and its relationship to pollution prevention and environmental protection. Overview of how EPA incorporates water conservation in its regulation of industrial i facilities. Summarize examples of industrial water conservation Answer questions. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 2 of 20

Water Efficiency will Grow in Importance A recent GAO survey of state water managers indicated that, even under normal or non-drought water conditions (GAO-03-514): 36 states anticipate water shortages in localities, regions or statewide within the next 10 years; and Under drought conditions 46 states expect shortages over the next decade. The World Water Council predicts that between 1995 and 2025, U.S. residential water consumption will increase 100 percent, while industrial water use will increase by 33 percent. The quality and quantity of surface water and groundwater, as well as the overall integrity of the hydrologic cycle, are diminished by human activities on the land throughout the watershed (e.g., increased urbanization of watershed). 14 May 2009 ASME Water Conservation Conference Wash. DC Page 3 of 20

Water Conservation Incentives Economics Lower energy usage and operating costs (e.g., water bills, wastewater treatment and sludge disposal costs) Increased opportunities for maintaining or expanding production Water source restrictions Widespread d regional droughts Increasingly stricter standards for both withdrawal and discharge of water (water conservation lowers pollutant discharges) More rigorously enforced water rights limitations Increasing water demands of urban populations Water quality considerations can restrict use 14 May 2009 ASME Water Conservation Conference Wash. DC Page 4 of 20

Water Conservation Incentives Reduced Wastewater Pollution EPA's rulemaking records supports the finding that for a variety of industrial sectors, well-operated and designed treatment systems treat wastewater with varying influent pollutant concentrations to the same effluent concentrations across a wide range of flows. Wastewater treatment technologies operating within their design specifications are often limited solely by physical/chemical properties of the pollutants in the wastewater, and not necessarily by influent concentrations. Increasing influent pollutant concentrations to a properly designed and operated wastewater treatment system generally leads to increased wastewater treatment efficiency. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 5 of 20

Industrial Water Conservation: Example Tools & Technologies In general, water re-use and reduction technologies and pollution prevention practices fall into one of two general classes: Technologies and pollution prevention practices that only reduce the wastewater volume discharged from an industrial operation (i.e., no decrease in the mass of wastewater pollutants resulting from an industrial operation); and Technologies and pollution prevention practices that reduce the amount of wastewater volume and mass of wastewater pollutants resulting from an industrial operation. In order to identify and optimize water conservation planning a systematic tool like a water pinch analysis should first be conducted. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 6 of 20

Water Conservation Needs Conducted Systematically Step 1 Establish Leadership and Commitment. Organize a project team and obtain management support. Step 2 Frame the Problem. Select candidate process units for water-saving projects. Step 3 Identify the Baseline and Develop Alternatives. Gather data on process line current water use (flow, key pollutants). Step 4 Select a Course of Action. Use techniques such as costbenefit and water-pinch to identify the preferred options. Step 5 Implement Water Conservation. Step 6 Monitor Effectiveness of Actions and Conduct Periodic Review and Improvements. Modified from: AIChE, Industrial Water Management: A Systems Approach and Water-System Optimization Chemical Engineering (January 2004). 14 May 2009 ASME Water Conservation Conference Wash. DC Page 7 of 20

Water Pinch Analysis A water pinch analysis integrates the use of water resources to maximize water reuse, minimize wastewater generation and reduce effluent treatment. In its simplest form, this methodology treats a given water-using operation as a problem of mass transfer from a contaminant-rich process stream to a contaminant-lean water stream. Water-reuse process integration seeks to identify a pinch point, called the fresh water pinch, based on the concentration of a key contaminant. Within a given process plant, water-using operations that can tolerate contaminant levels above that concentration do not require fresh water; they can instead reuse water streams from elsewhere in the process. Analogously, plant water streams with contaminant levels below that "pinch concentration" do not need to be sent for disposal, but can be reused elsewhere in the plant. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 8 of 20

Water Conservation Application: Counter Current Rinsing Countercurrent cascade rinsing refers to a series of consecutive rinse tanks that are plumbed to cause water to flow from one tank to another in the direction opposite of the work flow. Countercurrent cascade rinsing can reduce water consumption by 50 to 90 percent. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 9 of 20

How does EPA promote water conservation? EPA promotes industrial water conservation through education, coordination, and industry voluntary participation programs. Sector Strategies Program - www.epa.gov/sectors EPA also identifies technology-based standards termed effluent guidelines - which for some industries can include an assessment of water conservation. Effluent Guidelines Program - www.epa.gov/guide 14 May 2009 ASME Water Conservation Conference Wash. DC Page 10 of 20

Industrial Water Conservation: Case Studies EPA s voluntary initiative program, the Strategic Goals Program, tracked some of these success in this industrial sector. Between 1998 and 2002, more than 500 metal finishers, 20 states, and 80 local regulatory agencies (primarily publicly owned treatment works) participated with EPA in the Strategic Goals Program. Participating metal finishers pursued facility-specific environmental targets for resource inputs and waste outputs, including: (1) 25% reduction in energy use; (2) 50% reduction in water use (107 facilities); (3) 50% reduction in land disposal of hazardous sludge; (4) 50% reduction in emissions of metals to water; and (5) 90% reduction in organic chemical releases reported to EPA s Toxics Release Inventory (TRI) 14 May 2009 ASME Water Conservation Conference Wash. DC Page 11 of 20

What are Effluent Limitations Guidelines and Standards (ELGs)? National industrial wastewater regulations for both direct and indirect dischargers Industry Specific (e.g., metal finishing, iron and steel) Technology-based limitations and standards (however, specific c technology ogy not mandated) Economically Achievable ELGs are incorporated into NPDES permits (direct dischargers) or into controls set by POTWs (indirect dischargers) 14 May 2009 ASME Water Conservation Conference Wash. DC Page 12 of 20

What are ELGs and Where are they Applied? Indirect Discharger Direct Discharger Pretreatment Treatment Sewage Treatment Plant ELGs regulate indirect and direct dischargers Surface Waters 14 May 2009 ASME Water Conservation Conference Wash. DC Page 13 of 20

What are ELGs? EPA has published effluent guidelines for 56 major industrial categories (over 450 subcategories) since the passage of the 1972 Clean Water Act These national industrial regulations are estimated to result in the removal of over 690 billion pounds of pollutants each year, and substantially contribute to improvements in the quality of water nationwide Limits it on industrial i indirect dischargers designed d to prevent the discharge of pollutants that pass through, interfere with, or are otherwise incompatible with the operation of publicly owned treatment works (POTW) EPA can directly correlate water conservation and production in some industrial sectors. In such cases it is possible to directly incorporate water conservation into the calculation of production-based effluent guidelines. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 14 of 20

What are ELGs? EPA uses a production normalized flow (volume of wastewater/unit of production) and the concentration of the regulated pollutant in the discharged wastewater that corresponds to the performance of available technology to calculate the applicable production normalized massbased effluent guidelines. Production normalized mass-based ELGs = (mass-pollutant/ t/ production unit) Available technology pollutant concentration X (mass-pollutant/ t/ vol. wastewater discharged) Production normalized flow (vol. wastewater discharged/ production unit) For example, EPA set the daily maximum limit for ammonia (as N) in the cokemaking iron and steel manufacturing operation at: 0.00293 Pounds of ammonia (as N) per thousand pounds of product 14 May 2009 ASME Water Conservation Conference Wash. DC Page 15 of 20

What are ELGs? EPA summarizes its data collection on best practices for pollution prevention, effluent treatment, and water conservation in documents titled, Technical Development Documents. In particular, these documents identify the water conservation practices used in develop its effluent guidelines. These water conservation practices are included in EPA s incremental costs of its regulations. Additionally, as part of its Climate Change Action Plan EPA is soliciting specific information on industrial sectors and facilities that use model water efficiency practices that promote water efficiency, re-use, or recycling. See final 2008 Effluent Guidelines Program Plan. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 16 of 20

Industrial Water Conservation: Case Studies Harley-Davidson Motor Company (York, PA) Using this philosophy and a zero-discharge goal, Harley-Davidson installed a new nickel/chrome plating machine in 1995. Re-use of water in the plating operation has resulted in a 75 percent decrease in the amount of city water used. Control of rinse water flows and re-use of rinses has resulted in a 60 percent drop in average daily flow to the on-site industrial wastewater treatment system. Hazardous wastes shipped off-site for treatment and disposal have been reduced by 80 percent - a 45,000 gallon reduction. Many of these wastes are generated during wastewater treatment; therefore, a reduction in waste generation indicates a reduction in pollutant loading from the facility. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 17 of 20

Industrial Water Conservation: Case Studies Poly-Plating, Inc. (Chicopee, MA) Poly-Plating designed and installed integral repurification equipment which filters, recycles and concentrates wastes for reclamation. Small business that employees 16 people. This equipment reduced acid purchases to 1% of 1989 levels. Reclaiming and recycling has cut disposal costs by 98%. Additionally, water use has been reduced to 880 gallons per day, down from 78,000 gallons per day. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 18 of 20

Industrial Water Conservation: Case Studies The Robbins Company (Attleboro, MA) The company replaced its traditional wastewater treatment system with a state-of-the-art closed-loop reverse osmosis system that uses minimal quantities of maintenance chemicals and produces less waste. To eliminate the use of chlorinated solvents, Robbins switched in 1993 to a closed-loop loop aqueous cleaning system. The new system uses ultrafiltration to recycle and extend the life of cleaning baths by 300%, reducing costs associated with the purchase and disposal of the cleaner. Through these changes and other toxics use reduction strategies, Robbins has reduced chemical use in wastewater treatment by 99%, reduced hazardous waste generation by 99% and cut water use by 98.5%. All told, these reductions have created an annual savings of more than $100,000. 14 May 2009 ASME Water Conservation Conference Wash. DC Page 19 of 20

For Further Information Websites: Water Use Efficiency Program www.epa.gov/owm/water-efficiency/ Effluent Guidelines www.epa.gov/guide/ g Contact: Carey A. Johnston, P.E. ph: 202.566.1014 johnston.carey@epa.gov Questions? 14 May 2009 ASME Water Conservation Conference Wash. DC Page 20 of 20