REFINEMENT OF THE EPA'S POTW PASSTHROUGH ANALYSIS METHOD FOR APPLICATION TO THE PHARMACEUTICAL MANUFACTURING INDUSTRY

摘要

The U.S. Environmental Protection Agency (EPA) is required by the Clean Water Actrnto establish industrial pretreatment standards for pollutants that may "pass-through" orrninterfere with publicly owned treatment works (POTW). Through the years EPA hasrnused a pass-through analysis method that compares the percent removals ofrnpollutants by industry plants with treatment that represented best available technologyrneconomically achievable (BAT) to percent removals of the same pollutants by a set ofrnwell designed and operated POTWs. Pass-through is determined if the percentrnremoval of a pollutant by a BAT plant is greater than the percent removal of thatrnpollutant at a POTW. Pass-through is also identified if a pollutant is predicted tornvolatilize in the POTW sewer or treatment units, because this volatilization is notrnconsidered treatment.rnWhen EPA began the revision of the pharmaceutical manufacturing effluentrnlimitations guidelines and standards in 1991, it identified a number of pollutants that itrnhad not regulated in previous rules. A number of these pollutants were oxygenatedrnchemicals such as acetone, methanol, ethanol, and isopropanol. Because thesernchemicals are semi-volatile but also highly soluble and are biodegradable, the POTWrnpass-through methodology was revisited to assure that it would be a technicallydefensiblernapproach for identifying those pollutants requiring pretreatment standards.rnThis paper describes the efforts that were undertaken by EPA, in cooperation with thernPharmaceutical Research and Manufacturers of America (PhRMA), to develop thernnecessary data and information for refining the POTW pass-through methodology forrnuse in the development of the pharmaceutical manufacturing effluent guidelines andrnstandards, which were promulgated on September 21, 1998. This successful effortrnhas resulted in an approach to pass-through analysis that considers multiplernproperties of a chemical, including volatility, solubility, and biodegradability.