ACHIEVING COMPLIANCE WITH WASTEWATER PROVISIONS OF PHARMACEUTICAL MACT REGULATIONS

Pharmaceutical MACT regulations specify requirements for reduction of emissions of soluble hazardous air pollutants (SHAPs) and partially soluble hazardous air pollutants (PHAPs) from pharmaceutical manufacturing facilities. One of Abbott Laboratories' (Abbott) facilities opted to comply with the requirements by demonstration of the removal of 95% of the regulated compounds in onsite wastewater treatment facilities that discharge to POTWs. The objective was to demonstrate compliance of the facility with the MACT regulations. The project was conducted in five phases.The first phase involved identification of SHAP and PSHAP compounds and conservative loadings of these compounds in the WWTP influent. Biodegradation rate coefficients for the regulated compounds were determined using the BOX Test in the second phase. In the third phase, SHAP and PSHAP destruction and removal efficiency in off-gas control devices were evaluated. Overall removal of the SHAP and PSHAP compounds in the WWTP were determined in the fourth phase using tools like Toxchem+. The fifth and the final phase involved identifying and quantifying the critical WWTP operating parameters that would ensure continued compliance with the 95% SHAP and PSHAP removal requirement by the regulation.Compliance of the facility was demonstrated by developing a WWTP operating range. MLSS concentrations developed for the anticipated (WWTP) influent flow range from 1.0 MGD to 3.0 MGD and temperature range from 20.0 °C to 42.2 °C met the 95% SHAP and PSHAP destruction and removal requirements of MACT.