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Effluent Guidelines
Chapter 6: Conducting the Treatability Test (Summary)
Information on how to conduct a treatability test, including instructions and an example for completing treatability test tables to aid in making compliance decisions.
The final PFPR rule allows facilities the choice of achieving zero discharge or complying with the P2 alternative. Zero discharge can be achieved through reuse, off-site disposal of wastewater, or discharge of treated wastewater with pesticide active ingredients at levels below detection. [If a facility chooses to meet zero discharge through discharge of wastewater with pesticide active ingredients below detection, all pesticide active ingredients that are formulated, packaged, or repackaged at the facility must have analytical methods for use in wastewater.] The P2 alternative allows PFPR facilities to discharge their wastewater after implementing listed P2 practices and, in some cases, wastewater treatment. Facilities that treat wastewater to comply with the P2 alternative or to reuse their wastewater must use a technology that provides effective wastewater treatment.
Treatability Test Components
- Identification of Wastewater Sources and Treatment Technologies;
- Preparing the Test Plan; and
- Summary and Evaluation of Test Results.
Chapter 4 describes how facilities can use the P2 audit to identify wastewater sources and applicable P2 practices, and make an initial compliance decision for each wastewater source. Chapter 5 describes the most cost-effective wastewater treatment technologies that are demonstrated to reduce the pesticide active ingredients present in PFPR wastewater. Chapter 6 describes the three components of a treatability test and provides guidance to facilities on selecting and testing appropriate wastewater treatment technologies to determine if they are effective for a facility's specific wastewater streams.
The first component of a treatability test is identifying the wastewater streams that remain after implementation of the P2 practices and require treatment prior to discharge. As discussed in Chapter 4, the facility can use the results of the P2 audit as documented on Table C to identify the sources that will be zero discharge or that will comply with the P2 alternative. As part of this first component, the facility also needs to identify the wastewater technologies appropriate to treat the constituents present in the waste streams requiring treatment (including characteristics that may hinder treatment of the waste streams), and then construct potential treatment trains. Table D, which is described later in this chapter, can be used by facilities to identify the sources that require treatment under the P2 alternative, the constituents in those wastewater sources, and appropriate treatment technology(ies).
Based on this information, the facility can decide whether a treatability test is necessary. A treatability test may be used by a facility to determine whether a particular technology can treat the wastewater, identify analytical or design and operating parameters to act as surrogates for pesticide active ingredient analyses, comply with permitting requirements, or optimize treatment performance.
If a test is warranted, the second component is preparing the test plan. The facility's first step in writing a test plan is determining the size and scope of the test and the sequence of treatment steps. The test plan also specifies the written procedures of how to conduct the test, discusses the design and operating parameters to be evaluated for the specific treatment technologies, determines the equipment and chemicals necessary to conduct the test, and describes the samples to be collected and analyzed (including a discussion of the quality assurance/quality control procedures).
The final component is evaluating the test results, which consists of calculating performance measures, comparing technology results, and evaluating the cost-effectiveness of the individual treatment technologies.
The guidance presented in this chapter for conducting a wastewater treatability test is based on EPA's procedures used during the development of the PFPR effluent limitations guidelines and standards. The treatability test tables discussed in this chapter (Tables D and E) are offered as one way to conduct the test and/or document the test results. It is not required that facilities, permitters, or other auditors use Tables D and E; however, these tables summarize the types of information that are useful in conducting a treatability test. Since it is very difficult to construct one table or checklist with a format useful for all PFPR facilities, EPA considers the tables presented in this manual as a tool to be adapted in whatever way the user feels is appropriate. Example pages of the treatability test tables are shown throughout this chapter to illustrate the types of information captured on the tables. The blank tables are presented in their entirety in Appendix B. [109K PDF file, 25 pages]
Treatability Test Tables Table Title Purpose Table D Identification of Wastewater Sources Helps users list wastewater sources requiring and Technologies treatment, the potential constituents, and the appropriate treatment technologies. Table E Summary and Evaluation of Test Results Helps users summarize and evaluate the test results for each technology and the final treatment train.
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