ML19221A827
| ML19221A827 | |
| Person / Time | |
|---|---|
| Issue date: | 02/28/1979 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-0555, NUREG-0555-09.3.3, NUREG-555, NUREG-555-9.3.3, SRP-09.03.03, SRP-9.03.03, NUDOCS 7907090204 | |
| Download: ML19221A827 (17) | |
Text
Section 9.3.3 February 1979 ENVIRONMENTAL STANDARD REVIEW PLAN FOR ES SECTION 9.3.3 ALTERNATIVE PLANT AND TRANSMISSION SYSTEMS:
NONRADI0 ACTIVE-WASTE-TREATMENT SYSTEMS REVIEW INPUTS Environmental Report Sections 3.3 Station Water Use 3.4 Heat Dissipation System 10.4 Station Design Alternatives: Chemical Waste Treatment 10.5 Station Design Alternatives: Biocide Treatment 10.6 Station Design Alternatives. Sanitary Waste Syste'a Environmental Reviews 2.2.1 Land: The Site and sicinity 2.3 Water 2.4 Ecology 3.3.2 Plart Water Use: Water Treatment 3.6 Nonradioactive Waste Systems 4.6 Measures and Controls to Limit Adverse Impacts During Construction 5.5 Nonradioactivellaste-System Impacts (Operation) 5.10 Measures and Controls to Limit Adverse Impacts During Operation Standards and Guidec Federal, State, and local regulations on land use, water quality, and effluent discharge limitetions Federal Water Pollution Control Act Amendments of 1972 Second Memorandum of Understanding Between NRC and EPA, December 1975 Other The site visit Responses to requests for additional information Consultation with local, State, and Federal agencies REVIEW OUTPUTS Environmental Statement Sections 9.3.3 Alternative Plant and Transmission Systems: Nonradioactive-Waste-Treatment Systems 109 i93
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February 1979 Other Environmental Reviews 4.6 Measures and Controls to Limit Adverse l'.ipacts During Construction 5.10 Measures and Controls to Limit Adverse impats During Operation 10.1 Unavoidabh Adverse Environmental Impacts 10.4 Benefit-Cost Balance I.
PURPOSE AND SCOPE The purpose of this environmental stancard review plan (ESRP) is to direct the staf f's analysis of alternatives to the applicant's proposed nonradioactive waste-treatment-systems.
This includes evaluation of these alternatives, ia comparison with the proposed systems, to identify those systems that are (1) environmentally preferable to the proposed system and (2) environmentally equivalent to the proposed system.
Environmtatally preferable alternatives will be compared with the proposed system on a benefit / cost basis to determine if any such system should be recommendei for consideration as a preferred alternative to the proposed system.*
O The scope of the review directed by this plan will be limited to alterna-tive sy stems for the treatment of chemical wastes (including biocides) and sanitary wastes that can be constructed and operated at the proposed plant site and that (1) are not prohibited by local, State, or Federal regulations, (2) are ccnsistent with any FWPCA findings, and (3) can be judged as practical from a technical stanc' point with respect to the proposed dates of plant construction and operation. This review will also include the investigation of alternatives proposed by other reviewers to mitigate impacts associated with con 3Lruction and operation of the proposed nonradioactive waste-treatment-systems.
A The review of environmentally preferable nonradioactive waste-treatment-systems will include both environmental and economic considerations The activities and inputs of two or more reviewers will be required in conducting this portion of the review.
I 9.3.3-2
February 1979 This plan provides the basis for the staff conclusions with respect to the enviranmental preference or equivalence of alternative nonradioactive waste-treatment-systems; and for environmentally preferable systems, Lanclusions and recommendations for consideration of any such systems having an equivalent or better benefit-cost balance than the proposed system.
II.
REQUIRED DATA AND INFORMATION The kinds of data and information required will be af fected by site-and station-specific factors, and the degree of detail will be modified according to the anticipated magnitude of potential impacts of the proposed systems and to the practicability of adapting the reviewed alternative to the proposed site. The following data or information will usually be required:
A.
Alternative systems fo,' ultimate disposal of wastes from treatment of incoming (makeup) circulating water.
1.
Description and purpcse of system (from the ER) 2.
Quantity and composition of discharged wastes (from the ER) 3.
Operating cycles (f rom the ER) 4.
Discharge point (s) (f rom the ER) 5.
Dilution of wastes (if any) (from the ER) 6.
Estimated environmental ef fects of dischar ged wastes (from ER and general literature) a.
At point of discharge b.
Af ter dilution (if any) 7.
Land-use impacts and costs associated with system construction of the proposed plant site (from the ER) 8.
Capital, operating, and maintenance cost estimate. (from the ER and general literature).
B.
Alternative systems for treatment and ultimate disposal of blowdown from closed cycle cooling systems.
g 109 195 9.3.3-3
February 1979 1.
Description and purpose of system, including treatment (if any) of wastes (from the ER) 2.
Composition of discharged wastes (from tha ER) 3.
Operating cycles (f rom the ER) 4.
Discharge point (s) (from the ER) 5.
Dilution (if any) (from the ER) 6.
Estimated environmental ef fects of discharged wates (from the ER and general literature) a.
At point of discharge b.
Af ter dilution (if any) 7.
Land-use impacts and costs associated with system construction at the proposed plant site (from the ER) 8.
Capital, operating, and maintenance cost estimates (from general lite-ature).
C.
Alternative systems for treatment and ultimate disposal of chemical wastes from other plant-related operations.
O 1.
Des iption and purpose, including treatment of wastes (f rom the ER) 2.
Composition of discharged wastes (from the ER) 3.
Operating cycles (from the ER) 4.
Discharge point (s) (f rom the ER) 5.
Dilution of wastes (if any) (from the ER) 6.
Esti;aated environmental ef fects of wastes (f rom the ER and general literature) a.
At point of discharge b.
Af ter dilution 7.
Capital, operating, and maintenance cost estimates (f rom the ER ana general literature).
D.
Alternative sanitary waste systems.
1.
System description, including chemical additives (f rom the ER)
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February 1979 9
2.
Comparison with EPA municipal waste treatment guidelines (f rom the ER and consultation with Federal agencies) 3.
Discharge point (s) (from the ER) 4.
Estimated environmental effects of discharged wastes (from the ER and general literature) 5.
Capital, operating, and mainurance cost estimates (from the ER and general literature).
E.
Other data.
1.
Site and vicinity land use (f rom E5xP 2 ?.1) 2.
Site and vicinity water use (froni ESRP 2.z,.2) 3.
Site and vicinity water quality criteria (from ESRP 2.3.3) 4.
Site and vicinity ecology (from ESRPs 2.4.1 and 2.4.2) 5.
Proposed r.onradioactive waste systems (from ESRPs 3.6.1, 3.6.2, and 3.6.3) 6.
Predicted impacts of proposed nonradioactive waste systems (from ESRP 5.5) 7.
Capital, maintenance and operating cons of proposed nonradio-active waste systems (from the ER).
III.
ANALYSIS PROCEDllRE The principal objectives of this analysis procedure are (1) to provide assistance to the reviewer for ES Cection 5.5 in identifying and verifying means to mitigate adverse impacts associated with the proposed nonradioactive waste-treatment-systems and (2) to identify and analyze reasonable alternatives to the applicants proposed systems to the extent needed to rank them f rom an environmental standpoint as preferable, equivalent, or inferior to the proposad system.
The depth of the analysis will be governed by the nature and magnitude of proposed nonradioactive waste-treatment-system impacts predicted by the ES Section 5.5 reviewer, When adverse impacts are predicted, the reviewer will 109 19,7 9.3.3-5
February 1979 cooperate with this reviewer in identifying and analyzing means to mitigate these impacts.
The proposed systens with any verified mitigation schemes (i.e., measures and controls to limit adverse impacts) will be the baseline systems against which alternative nonradioactive waste-treatment-systems will be compared.
The nature and adversity of the remaining unmitigated impacts for these baseline systems will establish the level of analysis required in the review of alternative systems to permit staf f evaluation and conclusions with respect to the environmental preference or equivalence of these alternatives.
When no adverse impacts have been predicted for the proposed systems, the review will be limited to an analysis of alternative systems in the depth necessary to judge their environmental equivalence to the applicant's proposed system.
When environmentally preferable alternatives have been identified (see the Evaluation section of this ESRP), the review will be expanded to consider the economic costs of any such alternative. The reviewer will estimate the capital, operating, and maintenance costs for each nonradiological waste treatment system considered.
The reviewer will use these data to estimate total annual costs for each system, and will use these annual costs for economic cost com-parisons.
The reviewer will determine if there are any site-specific factors that might af fect the costs of any alternative, and will f actor these additional costs into the. comparison.
This analysis will be done in consultation with appropriate ES Section 10.4 reviewers. Assistance from these reviewers will be needed to establish the economic cost data that will be used to develop a benefit-cost comparison with the baseline (proposed) nonradioactive waste-treatment-system.
In this analysis, the reviewer will consider alternatives for treatment of the following nonradiological wastes:
A.
Wastes f rom circulating water system pretreatment B.
Blowdown from closed-cycle cooling systems C.
Other chemical wastes G
C.
Sanitary wastes.
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February 1979 The analysis will consider only those alternatives applicable at the proposed site and that are compatible with the applicant's proposed heat dissipation and circulating water systems and with those alternative heat dissipation and circulating water systems selected for consideration by the reviewers for ES Sections 9.3.1 and 9.3.2.
When the reviewers for these sections select systems that would involve waste treatment systems other than those proposed, the reviewer for this plan will provide assistance in identifying appropriate waste treatment systems and will analyze and assess those systems for their environ-mental impacts.
The reviewer will conduct an initial environnental screening of each alternative waste treatment system to eliminate those systems that are obviously unsuitable for use at the proposed site.
Factors to be considered in this initial screening include terrain and land use, water use (including water availability c.nd water quality), and legislative restrictions. Working through the NRC Environmental Project Manager (EPM), the reviewer may consult with appropriate Federal and state agencies when needed to conduct this screening.
The reviewer will also consult (through the EPM) with the Environmental Protec-tion Agency (EPA) or with those agencies responsible for FWPCA determinations or waste treatment guidelines to screen alternatives that will not meet these requirements.
This consultation will be guided by the provisions of the Second Memorandum of Understanding between NRC and EPA.
The reviewer may establish other justifiable bases for rejection of a given alternative. When the reviewer rejects an alternative, that alternative needs no further consideration other than the preparation (for Section V of this ESRP) of the reasons and justifica-tion for the rejection.
The following procedure for developing the analysis of alternative non-radioactive waste-treatment-systems considers both environmental and economic cost factors.
In following this procedure, the reviewer will ini tially con-sider only the environmental factors and will repeat the procedure for economic factors only for those alternatives shown to be environmentally preferable by the evaluation procedures of this ESRP.
The analysis of those alternative systems not eliminated by the inital screening process will be based on the environmental and economic factors shown in Table 9.3.3-1.
The reviewer will 9.3.3-7 b9 f
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February 1979 prepare a similar table for each waste treatment system under consideration, comparing each of the environmen*-1 and economic cost and benefit factors with those of the proposed system.
Information for this table may be prepared either in terms of absolute environmental and economic costs and benefits or as incre-mental costs and benefits referenced to the proposed system. Additional factors may be included when needed on a site-cr system-specific basis.
The reviewer's analysis of alternative nonrad',ological waste-treatment sys-tems will be closely linked with the review of alternative water treatment systems (ES Section 9.3.2) to avoid duplication in the e reviews. In this analysis, the reviewer will consider alternative treatment and disposal of plant generated wastes, including the following:
A.
Wastes Resulting from Pretreatment of Water for use in the Circu-lating Water System For those proposed plants where incoming makeup water for closed-cycle cooling requires pretreatment before addition to the system, the reviewer will consider alternative means of pretreatment, handling, and disposing of the wastes from the treatment process.
The reviewer will consider those factors listed in part II.A of this ESRP.
Principal environmental factors to consider are waste composition, added chemicals (e.g., for thickening), operating cycles or rates of discharge, discharge points (e.g., e aporation ponds, discharge to waterbodies with or without dilution), and land-use data.
The reviewer will estimate the environmental impacts associated with these factors, and will compare them with the factors and impacts of the proposed system. The use of a format similar to that shown in Table 9.3.3-1 is recommended.
Information for this table may be prepared either in terms of absolute impacts / costs and benefits or as incremental impacts / costs and benefits referenced to the proposed waste treatment system. The reviewer may include additional factors on a site-or system-specific basis.
B.
Closed-Cycle Cooling System Blowdown The reviewer will consider alternatives to the proposed method of cooling system blowdown disposal, including both alternative systems for treatment and q G,J 9.3.3-8 sO(
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February 1979 disposal of blowdown and alternative operation of the proposed closed-cycle system.
The reviewer will consider those factors listed in part II.B of this ESRP.
Principal environmental factors tc consider are blowdown composition and chemical / mechanical means of blowdown treatment prior to discharge; operating cycles or rates of blowdown discharge; discharge point or points and the environ-ment discharged to (e.g.,
waterbody, evaporation pond); dilution prior to discharge; and land-use data. The r eviewer will consult with the reviewer for ES Section 5.3.2.2 to determine the need for alternative biocides or treatment of biocide residuas.
The reviewer will estimate the environmental impacts associated with these factors and will compare them with the factors and impacts of the proposed system. A tabular format (see the instruction for item A above) is recommended.
C.
Chemical Wastes (Other Than Cooling System Wastes)
The reviewer will consider alternative treatment and disposal of chemical wastes other than cooling system wastes (e.g., laboratory wastes) only when the proposed use of chemicals is such that their proposed treatment or discharge could result in environmental impacts.
When this is the case, the rc'.icwer will consider alternative treatments and/or discharge points for these chemical wastes using the factors ' listed in Section II.C of this plan.
The reviewer will ensure that any such alternatives will comply with applicable standards and regulations.
A tabular form?t (see the instruction for item A) is recommended.
D.
Sanitary Wastes
,he reviewer will consult with the reviewers for ES Sections 3.6.2 and 5.5 tc determine if the proposed sanitary waste system (1) meets EPA guide-line-for unicipal waste treatment ef fluent quality standards and State or local standards and (2) is not predicted to cause environmental impacts. When this is the case, no analysis of alternative sanitary waste treatment systems will be required. When the reviewer for ES Section 5.5 predicts environmental 109 20 9.3.3-9
February 1979 impacts fo,' the proposed system, the reviewer will consider alternative sani-tary wast 3 treatment systems and will compare them with the proposed system using the factors listed in Section II.D of this ESRP.
A tabular format (see the instruction for item A) is recort, mended.
IV.
EVALUATION Tne reviewer will ensure that each nonradioactive waste-treatment system alternative has been described in sufficient detail to enable the reviewer to meke an effettive analysis and comparison of environmental inipacts leading to a staff conclustion that the alternative system is environmentally preferable, equivalent or inferior to the proposed system.
For those alternatives deter-ained to be environmentally preferable, the reviewer will ensure that economic cost data are available in sufficient detail to enable the reviewer to conduct benefit-cost analyses and comparisons with the proposed system leading to a final staff recommendation for waste-treatment system consideration.
The reviewer will also ensure that all comparisons were made on the basis of t;ie proposed system as supplemented with those measures and controls to limit adverse impacts proposed by the applicant and recommended by the staff.
For those alternatives eliminated from consideration on the basis of land use, water use, or legislative restrictions, the reviewer wilI ensure that adequate documented justification for this action has been prepared.
A.
General Considerations If a mitigation measure or alternative waste-treatment system is to be recommended for consideration, the reviewer must determine that the measure or system being evaluated has a lesser overall environmental impact than the proposed system, i. e., is environmentally preferable.
When this is true, the economic costs of mitigation or of the alternative must result in an equivalent or improved project benefit-cost balance.
When these criteria are met, the reviewer will verify those mitigation measures proposed by the reviewers for pm 9.3.3-10
February 1979 ES Sections 4 and ' 5 or will recommend consideration of an alternative waste-treatment system.
The reviewer will be guided by the following general considerations:
1.
The reviewer must keep in mind that an environmental review of alternative waste treatment systems,
.f conducted in the depth applied to the review of the proposed system, would be expected to find additional impacts and/or increased severity of the impacts already predicted for the alternative.
The reviewer will allow for this when evaleating the comparative environmental impacts of each proposed alternative with those of the proposed system.
2.
Tho reviewer will ensure that tne level of detail provided for each econemic, environmentai, and social cost estimate is commensurate vith the level of importance of the related environmental impact.
3.
The reviewer will adjust the economic costs of each alternative system on the basis of equivalent generating capacity.
4.
The evaluation of alternative waste-treatment systems may require consultation and coordination with those agencies responsible for the determina-tions specified in the Federal Water Pollution Control Act (FWPCA). Following the procedures described in the Analysis section of this ESRP, tL2 reviewer will coordinate the evaluation of measures and controls to limit adverse impacts or of alternatives to avoid adverse impacts with the appropriate agency respon-sible for the FWPCA determinations.
When consulting with tne EPA or with agencies of States having NRC/ State memoranda of understanding, the reviewer will ensure ' hat the staff analyses, evaluations, and recommendations (1) are consistent with the details of these memoranda and (2) will serve the environ-mental impact statement needs of these agencies. The reviewer will ensure that any staff recommendations for measures and controls to limit adverse impacts or for alternative waste-treatment systems that avoid adverse impacts are consistent with the FWPCA determinations.
9.3.3-11
February 1979 B.
Measures and Controls to Limit Adverse Impacts When considerin! measures recommended by the reviewers for ES Sec-tions 4 and 5 to mitigat - adverse environmental impacts predicted for the proposed waste-treatment tystems, the revie,:er's verification of the desirabil-ity of the measure will require the following conclusions:
1.
The measure provides the desired mitigation and does not introduce other adverse environmental impacts not predicted for the proposed system.
2.
The measure will result in an overall benefit / cost balance equi-valent to or better than that of the proposed project.
3.
The measure is not precluded by Federal, State, or local regula-tions or ordinances.
4.
The measure is consistent with any FWPCA requirements.
C.
Alternative Nonradioactive Waste-Treatment Systems
'1.
The initial step in the evaluation of those alternative waste-treatment systems identified by the analysis procedure of this ESRP will be to categorize these systems as environmentally preferable, equivalent, or inferior to the proposed ' / stems as modified by measures and controls to limit adverse impacts. The fol sowing criteria will be applied to this evaluation:
a.
When the reviewer determines that the proposed system (with mitigation measures, if necessary) will have no unavoidable adverse impacts and the system will comply with the requirements of the FWPCA, the reviewer will conclude that there can be no environmentally preferable alternative.
When this conclusion is reached, the reviewer will evaluate the alternatives to identify those that may be considered environmentally equivalent.
For this condition, environmental equivalence will require that an alternative have no unavoidable adverse impacts and meet FWPCA requirements. The reviewgewill not L"
\\D 9.3.3-12
February 1979 indicate a preference between environmentally equivalent alternatives nor will a benefit-cost analysis be made when this condition prevails.
Alternatives having unavoidable adverse environmental impacts or that do not meet FWPCA requirements will be judged environmentally inferior to proposed waste-treatment systems meeting these conditions.
b.
When the reviewer determines that a proposed waste-treatment system will meet FWPCA requirements but is predictt-d to have unavoidable adverse environmental impacts, the reviewer will evaluate the identified alternative systems for potential environmental preference to the proposed system.
The scope and extent of this evaluation will depe an the nature and magnitude of the proposed system's environmental impccts.
An environmental review may be required for the alternatives following the analysis and evaluation procedures of the appropriate ES Section 4 and 5 ESRPs. The following criteria apply to this evaluation:
(1) Environmental preference will be established when an 9
alternative can be shown to have no unavoidable adverse impacts and will meet FWPCA requirements.
(2)
Environmental preference may be established when an alternative that mcets FWPCA requirements can be shown to have unavoidable adverse impacts that are less severe in both nature and magnitude than those of the proposed system.
Determination of environmental preference under these conditions will require consultation with the NRC Environmental Project Manager and the appropriate ES Section 4 and 5 reviewers.
This consultation will result in a joint determination of the status of any such alternative.
(3) Environmental equivalence will be established when an alternative that meets FWPCA requirements can be shown to have unavoidable adverse impacts of the same or equivalent nature and magnitude as those of the proposed system.
(4) Environmental inferiority will be established when an alternative can be shown to have unavoidable adverIs$,9 z 03 impgcts that are more 9.3.3-13
February 1979 severe in both nature and magnitude than those of the proposed system, or tnat will not meet FWPCA requirements.
When the reviewer determines that there are environmentally prefer-able alternatives to a proposed waste-treatment system, the revicwer will conduct those portions of the analysis instructions of this ESRP that deal with the economic costs of the alternative systems.
2.
When environmentally preferable alternative waste-treatment systems have been identified, the reviewer will ensure that economic cost data have been developed for the alternatives, and that these data are adequate for a benefit-cost analysis and comparison with the proposed system.
This portion of the evaluation procedure will be conducted with the assistance of appropriate ES Section 10.4 reviewers.
The reviewer will complete the economic portions of Table 9.3.3-1, and on the basis of the completed table will balance and compare benefits and costs of the environmentally preferable alternative (s) with those of the proposed system. When an environmentally preferable alternative can be shown to have the same benefits as the proposed system with comparable reliabil-ity and at the same or lesser economic costs, the reviewer may conclude that the alternative should be recommended for consideration as an alternative to the proposed system.
For those cases where benefits of the alternative are 1 ss than those of the proposed system (e.g., increased land use or decreased reliability) or where economic costs are greater than those of the proposed system, a conclusion that the alternative is to be recommended will require consultation with the NRC Environmental Project Manager and with the appropriate ES Section 4 and 5 reviewers. If this consultation establishes that the benefit-cost balances of such alternatves are no m;re than equivalent to the proposed system, the alternatives will not be recommended for further consideration.
When alternatives have significantly decreased benefits or increased economic costs, they will be rejected for any further consideration as alternatives to the proposed system.
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February 1979 V.
INPUT TO THE ENVIRONMENTAL STATEMENT This section of the environmental statement should be planned to accomplish the following objectives:
(1) description of alternative nonradioactive-waste-treatment systems considered and results of the staff's analysis of these alternatives, (2) presentation of the basis for the staf f's analysis, and (3) presentation of the staff's conclusions and recommendations relative to alter-native nonradioactive-waste-treatment systems.
The input to the environmental statement will usually describe (1) those alternatives considered by the staff, (2) those alternatives iected by the o
staff as being inappropriate for the proposed site, (3) the s.
f's analysis and comparison of potentially appropriate alternatives to seek ensironmentally pref erable alternatives to the proposed systems, and (4) the staf f's conclusions and recommendations (where applicable) for consideration of alternative non-radioactive waste-treatment systems.
Staff contacts with the EPA or with agencies responsible for FWPCA determinations will be referenced.
The reviewer will discuss briefly those alternatives rejected because of specific deficiencies, and will state why the alternative was rejected.
Tne reviewer will also identify those alternatives judged environmentally equivalent or inferior to the proposed system.
When the reviewer has concluded that an alternative is environmentally preferable and should be considered as the preferred system, sufficient additional detail should be presented to justify the alternative both environmentall; and on a benefit-cost basis.
If desired, separate inputs for treatment of wastes from pretreatment of makeup water, cooling system blowdown, chemical wastes, and sanitary wastes may be prepared.
The reviewer will provide inputs or ensure that inputs will be made to the following ES sections:
A.
Sections 4.6 and 5.10.
The reviewer will provide the reviewers for ES Sections 4.6 and 5.10, as appropriate, with a list of those measures and controls to limit adverse acnradioactive-waste-treatment system impacts that were developed as a result of this environmental review.
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February 1979 B.
Section 10.
When the reviewer has recommended consideration of an alternative nonradioactive waste-treatment system, data and information will be provided to the appropriate ES Section 10 reviewers to permit the inclusion of any such alternatives in the final evaluation of the proposed action.
VI.
REFERENCES 1.
USEPA, " Development Document for Proposed Ef fluent Limitation Guidelines and New Source Performance Standards for the Steam Electric Power Generating Point Source Category," USEPA Publication EPA 440/1-73/029, March 1974.
2.
American Works Association, Water Quality and Treatment, 3rd Edition, McGraw-Hill Book Company, New York, NY, _371.
3.
G. W. Culp and R. L. Culp, New Concepts in Vater Purification, Van Nostrand Reinhold, New York, NY,1974.
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9.3.3-16
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TABLE 9.3.3-1 COMPARIS0N OF ALTERNATIVE NONRADIOLOGICAL WASTE TREATMENT SYSTEMS 1.
Water Pretreatment Wastes
- Proposed Design / Operational Discharge Impact System Alternative Systems M-difications Alternatives Construction Impacts e, Aquatic Impacts L. >
.L w
Water Use Impacts C3
'f) Compliance with Regulations 7,
c:3
'D y
cr Total Annual Costs 2
i,c C
~
- Note: Similar tables will be provided for:
Conling System Blowdown Chemical Wastes
<anitary Wastes.