-------
SECONDARY LEAD SUBCATEGORY
SECT - VI
TABLE VI-2
TOXIC POLLUTANTS NEVER DETECTED
1. acenaphthene
2* acrolein
3. acrylonitrile
5. benzidene
6. carbon tetrachloride (tetrachloromethane)
7. chlorobenzene
8. 1,2,4-trichlorobenzene
9. hexachlorobenzene
10. lf2-dichloroethane
12. hexachlorethane
13. 1,1-dichloroethane
14. 1,1,2-trichloroethane
15. 1,1,2,2-tetrachloroethane
16. chloroethane
17. DELETED
18. bis(2-chloroethyl)ether
19. 2-chloroethyl vinyl ether (mixed)
20. 2-chloronaphthalene
22. parachlorometa cresol
24. 2-chlorophenol
25. 1,2-dichlorobenzene
26. 1,3-dichlorobenzene
27. 1,4-dichlorobenzene
28. 3,3'-dichlorobenzidine
29. 1,1-dichloroethylene
30. 1,2-trans-dichloroethylene
32. 1,2-dichloropropane
33. 1,2-dichloropropylene (1,3-dichloropropene)
34. 2,4-dimethylphenol
35. 2,4-dinitrotoluene
36. 2,6-dinitrotoluene
37. 1,2-diphenylhydrazine
38. ethylbenzene f
41. 4-bromophenyl phenyl ether
42. bis(2-chloroisopropyl)ether
43. bis(2-chloroethoxy)methane
45. methyl chloride (chloromethane)
46. methyl bromide (bromoraethane)
48. dichlorobromomethane
49. DELETED
50. DELETED
51. chlorodibromomethane
52. hexachlorobutadiene
53. hexachlorocyclopentadiene
54. isophorone
55. naphthalene
1955
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SECONDARY LEAD SUBCATEGORY
SECT - VI
TABLE VI-2 (Continued)
TOXIC POLLUTANTS NEVER DETECTED
58. 4-nitrophenol
59. 2,4-dinitrophenol
60. 4,6-dinitro-o-cresol
61. N-nitrosodimethylamine
62. N-nitrosodiphenylamine
63. N-nitrosodi-n-propylamine
64. pentachlorophenol
70. diethyl phthalate
73. benzo(a)pyrene
74. 3,4-benzofluoranthene
75. benzo(k)fluoranthene
79. benzo(ghi)perylene
82. dibenzo(a,h)anthracene
83. indeno(l,2,3-cd)pyrene
85. tetrachloroethylene
87. trichloroethylene
88. vinyl chloride
95. alpha-endosulfan
105. delta-BHC
113. toxaphene
116. asbestos
129. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
1956
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SECONDARY LEAD SUBCATEGORY
SECT - VI
TOXIC
TABLE VI-3
POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL
QUANTIFICATION LIMIT
4. benzene
11. 1,1/1-trichloroethane
21. 2,4,6-trichlorophenol
31. 2,4-dichlorophenol
40. 4-chlorophenyl phenyl ether
44. methylene chloride
57. 2-nitrophenol
72. benzo(a)anthracene (1,2-benzanthracene)
78. anthracene (a)
80. fluorene
81. phenanthrene (a)
86. toluene
89. aldrin
90. dieldrin
91. chlordane
92. 4,4'-DDT
93. 4,4'-DDE
94. 4,4'-DDD
96. beta-endosulfan
97. endosulfan sulfate
98. endrin
99. endrin aldehyde
100. heptachlor
101. heptachlor epoxide
102. a-BHC-Alpha
103. b-BHC-Beta
104. r-BHC (lindane)-Gamma
106. PCB-1242 (Arochlor
107. PCB-1254 (Arochlor
108. PCB-1221 (Arochlor
109. PCB-1232 (Arochlor
110. PCB-1248 (Arochlor
111. PCB-1260 (Arochlor
112. PCB-1016 (Arochlor
(a), (b), (c) Reported together, as a combined value
1242)
1254)
1221)
1232)
1248)
1260)
1016)
(b)
(b)
(b)
(c)
(c)
(c)
(c)
1957
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SECONDARY LEAD SUBCATEGORY
SECT - VI
THIS PAGE INTENTIONALLY LEFT BLANK
1958
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SECONDARY LEAD SUBCATEGORY SECT - VII
SECTION VII
CONTROL AND TREATMENT TECHNOLOGIES
The preceding sections of this supplement discussed the
wastewater sources, flows, and characteristics of the wastewaters
from secondary lead plants. This section summarizes the
description of these wastewaters and indicates the level of
treatment which is currently practiced by the secondary lead
subcategory for each waste stream.
CURRENT CONTROL AND TREATMENT PRACTICES
This section presents a summary of the control and treatment
technologies that are currently applied to each of the sources
generating wastewater in this subcategory. As discussed in
Section V, wastewater associated with the secondary lead
subcategory is characterized by the presence of the toxic metal
pollutants and suspended solids. This analysis is supported by
the raw (untreated) wastewater data presented for specific
sources as well as combined waste streams in Section V.
Generally, these pollutants are present in each of the waste
streams at concentrations above treatability, so these waste
streams are commonly combined for treatment to reduce the
concentrations of these pollutants. Construction of one
wastewater treatment system for combined treatment allows plants
to take advantage of economies of scale and, in some instances,
to combine streams of differing alkalinity to reduce treatment
chemical requirements. Twenty-four plants in this subcategory
currently have lime precipitation and sedimentation or caustic
precipitation and sedimentation treatment, and seven have lime
precipitation, sedimentation and filtration. As such, three
options have been selected for consideration for BPT, BAT, BDT,
and pretreatment in this subcategory, based on combined treatment
of these compatible waste streams.
BATTERY CRACKING
Wastewater from the battery cracking operation may result from
the following sources: ,
1. Waste battery electrolyte,
2. Saw or breaker cooling water, and
3. Area washdown.
The combined wastewater from these sources has, the
characteristics of the battery electrolyte; pollutant
concentrations are strongly dependent on the amount of dilution
from the other water sources. In general, this wastewater is
characterized , by treatable concentrations of suspended and
dissolved solids, toxic metals, and arsenic. Of the 35 plants
with battery cracking surveyed, four do not currently have any
1959
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SECONDARY LEAD SUBCATEGORY SECT - VII
control on this wastewater stream; they either discharge it or
use contract disposal. The majority neutralize the spent acid
using various neutralizing agents. Ammonia, lime, and caustic
are the most common chemicals used to raise the wastewater pH.
Thirty-one plants provide for settling of solids after
neutralization with sedimentation equipment (e.g., clarifiers).
Seven plants filter the treated wastewater; in two of these
plants the filtration step occurs after sedimentation, and in the
others filtration is used alone to remove suspended soii^s.
Several plants add polymer to enhance the settling of this
wastewater. One plant combines battery cracking wastewater with
stormwater runoff, noncontact cooling water, water softener
backflush and sanitary wastes after preliminary treatment,
consisting of neutralization with ammonia and sedimentation.
Approximately 20 percent of the combined wastewater is evaporated
in a cooling tower and recycled to the plant process. Cooling
tower blowdown is treated by ion exchange and then discharged.
This allows the plant to effectively recycle or evaporate 90
percent of its wastewater. Treated water is recycled in four of
the plants; others send it to ponds, or discharge it either
directly or to a POTW.
BLAST, REVERBERATORY, AND ROTARY FURNACE WET AIR POLLUTION
CONTROL
Air emissions from the blast, rotary, and reverberatory furnaces
contain particulate matter and sulfur oxides (SOX) which must be
removed to meet air emissions standards. Either dry or wet
methods may be used for particulate control; of the 48 plants
surveyed which have blast, rotary, or reverberatory furnaces, 41
utilize baghouses or dry scrubbers, while seven plants have wet
lime or sodium scrubbers to control sulfur oxide emissions. One
of the seven plants operates two scrubbers on two different
smelting furnaces. Furnace scrubbing solution contains treatable
concentrations of suspended solids and lead. All of the seven
plants with wet scrubbers recycle a portion of the scrubber
water; the average recycle ratio is 94 percent. Two Plants
indicate they recycle 100 percent of the scrubber water. All
seven plants use an alkaline scrubbing solution to neutralize
the sulfur oxide fumes. The neutralizing agents used are lime
(two plants), ammonia (one plant), and soda ash (one plant).
Three plants also settle or filter the scrubber liquor before
recycle. Treated wastewater is discharged to a POTW in the plants
not practicing total recycle.
KETTLE WET AIR POLLUTION CONTROL
Kettles used in the refining and alloying operation may produce a
gaseous stream which may require control, primarily to reduce
particulate emissions. Of the plants surveyed, 14 do not control
kettle emissions, 18 use dry controls (baghouses), and the
remaining 10 use wet scrubbers. Kettle scrubber effluent
contains lead, arsenic, other alloying metals, and suspended
solids at treatable concentrations. Nine of the 10 plants with
wet scrubbers recycle the scrubber water; the average recycle
1960
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SECONDARY LEAD SUBCATEGORY SECT - VII
ratio is over 98 percent, with six plants reporting 100 percent
recycle. However, in conversations with the Secondary Lead
Smelters Association, the Agency has learned that these six 100
percent recycling plants discharge their scrubber liquor on a
batch basis. Although- these discharges were not quantified at
five of the six plants, some are as infrequent as one time per
month. These plants did not report the treatment practiced (if
any) on the batch discharge. The remaining plant utilizes the
scrubber wastewater in the battery cracking operation. Of the
two plants not using 100 percent recycle, one treats the blowdown
using sodium carbonate, sedimentation and filtration, while the
other does not treat the blowdown. Both plants discharge the
blowdown to a POTW.
LEAD PASTE DESULFURIZATION
As discussed in Section V,' one plant operates a process to
convert lead sulfate paste into lead oxide using ammonium
carbonate. This process is designed for zero discharge of
wastewater, with all product streams being recycled or recovered
for sale. No wastewater treatment is needed.
CASTING CONTACT COOLING WATER
Water may be used in the casting operation to accelerate the
cooling of the cast metal. Of the plants surveyed, only nine use
direct contact cooling. One plant uses total recycle of the
cooling water, two rely on total or partial evaporation to
eliminate the wastewater, and one of these also practices
recycle. The remaining plants discharge wastewater with no
treatment.
TRUCK WASH
Most of the 35 plants which crack batteries wash the trucks used
to haul the raw material. Only four plants report treating the
waste wash water. One plant evaporates the wastewater
completely. Another plant treats the wastewater in its central
treatment system consisting of lime, polymer addition, and
sedimentation. A third plant neutralizes the wastewater with
soda ash and settles in a concrete pit; the pit effluent is
reused for truck washing. Solids are recycled to the smelting
furnace. The fourth plant neutralizes the wastewater with
caustic and settles in a clarifier.
FACILITY WASHDOWN
Of the nine plants reporting the use of water for equipment and
floor wash to control fugitive lead emissions, eight treat the
water before reuse or discharge. The following treatment schemes
are currently practiced:
1. Neutralization with ammonia, polyelectrolyte addition,
.sedimentation and reuse;
1961
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SECONDARY LEAD SUBCATEGORY SECT - VII
2. Wash water is mixed with treated sanitary waste and
discharged to a septic lagoon;
3. Neutralization with soda ash, sedimentation, and reuse;
4. Neutralization with caustic, sedimentation with a
clarifier and reuse;
5. Neutralization with caustic, sedimentation, followed by
lime and settle treatment;
6. Sedimentation, pH adjustment (chemical not specified),
sedimentation, filtration, and discharge to a
percolation pond;
7. Cooling tower followed by ion-exchange before discharge;
and
8. Sedimentation, pH adjustment (chemical not specified),
and final sedimentation followed by reuse.
BATTERY CASE CLASSIFICATION
Eiaht plants use water for a flotation medium during
SlsLfiStion of scrap battery materials. All eight plants
?rSat thiS wLtewater before recycle or discharge. The following
treatment schemes are currently in places
1. Neutralization with ammonia and sedimentation - one
plant,
2. Lime neutralization and sedimentation - two plants,
3. Neutralization with soda ash and sedimentation followed
by reuse — one plant,
4. Neutralization with caustic and sedimentation - one
plant,
5. Sedimentation, pH adjustment (chemical unspecified), and
final sedimentation followed by reuse - one plant;
6. Sedimentation, pH adjustment (chemical unspecified),
sedimentation, filtration and discharge to a percolation
pond. Reuse of water from pond - one plant; and
7. Neutralization with ammonia, polyelectrolyte addition,
and clarification followed by reuse.
WASTEWATER FROM INDUSTRIAL HYGIENE COMPLIANCE
Most secondary lead smelters are required to reduce occupational
lead exposures by laundering employee uniforms, washing employee
respirators and Insuring that employees use hand wash facilities
Through wastewater sampling efforts after proposal, the Agency
1962
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SECONDARY LEAD SUBCATEGORY SECT - VII
determined that these wastewaters are contaminated and warrant
treatment. All plants did not report these wastewater streams
present. The Agency assumed that all plants operating smelting
furnaces would be required to comply with applicable industrial
hygiene regulations. Most plants reporting these wastewater
streams do not treat the discharge, but segregate this wastewater
from other process wastewater and discharge it to POTW. One
plant reports settling laundry water before discharge to a POTW.
Another plant neutralizes laundry water with ammonia, along with
other process water. Neutralization is followed by
sedimentation.
CONTROL AND TREATMENT OPTIONS CONSIDERED
As the sampling and analytical data in Section V indicate, the
wastewaters from the secondary lead subcatego'ry contain various
types of contaminants. The primary constituents of concern are
dissolved metals, suspended solids, dissolved solids, and pH
extremes or fluctuations. The Agency examined three control and
treatment technology options since proposal that are applicable
to the wastewaters from the secondary lead subcategory.
OPTION A
Option A for the secondary lead subcategory requires treatment
technologies to reduce pollutant mass. The Option A treatment
scheme consists of lime and settle treatment (chemical
precipitation and sedimentation) applied to the combined streams
of battery cracking wastewater, furnace air pollution scrubbing
wastewater, casting contact cooling water, kettle air pollution
scrubbing wastewater, truck wash, facility washdown, battery case
classification wastewater, and industrial hygiene wastewater.
Treatment is followed by the complete recycle of facility
washdown and battery case classification wastewater. Preliminary
treatment with oil skimming is also required for waste streams
containing treatable concentrations of oil and grease. Chemical
precipitation is used to remove metals by the addition of lime,
followed by gravity sedimentation. Suspended solids is also
removed in the process. At proposal, this option also required
dry control methods to control air emissions from kettle refining
or alternately, 100 percent recycle of kettle scrubber liquor.
However, data gathered through Section 308 requests indicate that
a periodic blowdown is needed, and so a discharge allowance now
is provided. Although a specific mass limitation is not provided
for oil and grease, oil skimming is needed for battery cracking,
furnace wet air pollution control, truck wash, laundry, handwash,
and respirator wash wastewater to ensure proper metals removal.
Oil and grease interferes with the chemical addition and mixing
required for chemical precipitation treatment.
1963
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SECONDARY LEAD SUBCATEGORY SECT - VII
OPTION B
Option B for the secondary lead subcategory requires control and
treatment to reduce the discharge of wastewater volume and
pollutant mass. Option B includes preliminary treatment with oil
skimming (where required), chemical precipitation and
sedimentation, total recycle of treated facility washdown and
battery case classification wastewater, plus wastewater flow
reduction to reduce the volume of wastewater discharged. Water
recycle and reuse are the principal control mechanisms for flow
reduction.
OPTION C
Option C for the secondary lead subcategory consists of Option B,
(in-process flow reduction, oil skimming (where required), lime
precipitation, sedimentation, and total recycle of treated
facility washdown and battery case classification wastewater)
with the addition of multimedia filtration at the end of Option
B treatment. Multimedia filtration is used to remove suspended
solids, including precipitated metals, below the concentration
attainable by gravity sedimentation. The filter suggested_is of
the gravity, mixed-media type, although other forms of filters
such as rapid sand filters or .pressure filters would perform
satisfactorily. The addition of filters also provides for
consistent removal during periods when there are rapid increases
in flows or loadings of pollutants to the treatment system.
CONTROL AND TREATMENT OPTIONS REJECTED
Two additional treatment technologies were considered prior to
proposing effluent limitations for this subcategory as discussed
below. Activated alumina and reverse osmosis were rejected
because they were not demonstrated in the nonferrous metals
manufacturing category nor were they readily transferable from
other categories.
None of the toxic organic pollutants were selected for further
consideration in establishing limitations for the secondary lead
subcategory. Therefore, Option E, which includes activated
carbon adsorption for organic removal, was not applicable to this
subcategory.
OPTION D
Option D for the secondary lead subcategory corisists of Option C,
(in-process flow reduction, lime precipitation, sedimentation,
multimedia filtration) with the addition of activated alumina
technology at the end of Option C treatment. The activated
alumina process is used to remove dissolved arsenic which remains
after lime precipitation.
1964
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SECONDARY LEAD SUBCATEGORY
SECT - VII
OPTION F
Option F for the secondary lead subcategory consists of Option C,
(in-process flow reduction, lime precipitation, sedimentation,
multimedia filtration) with the addition of reverse osmosis and
multiple-effect evaporation technology at the end of Option C
treatment. Option F is used for complete recycle of the treated
water by controlling the concentration of dissolved solids.
Multiple-effect evaporation is used to dewater brines rejected
from reverse osmosis.
1965
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SECONDARY LEAD SUBCATEGORY SECT - VII
THIS PAGE INTENTIONALLY LEFT BLANK
1966
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SECONDARY LEAD SUBCATEGORY
SECT - VIII
SECTION VIII
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS
This section describes the method used to develop the costs
associated with the control and treatment technologies discussed
in Section VII for wastewaters from secondary lead plants. The
energy requirements of the considered options as well as solid
waste and air pollution aspects are also discussed in this
section.
TREATMENT OPTIONS COSTED FOR EXISTING SOURCES
As discussed in Section VII, three control arid treatment options
are considered for treating wastewater from the secondary lead
subcategory. Cost estimates have been developed for each of
these control and treatment options. The control and treatment
options are presented schematically in Figures X-l through X-3
(pages 2009 - 2011), and summarized below.
OPTION A
Option A for the secondary lead subcategory consists of
preliminary treatment with oil skimming (where required), lime
precipitation and sedimentation end-of-pipe technology. Total
recycle of facility washdown and battery case classification
wastewater is also required for Option A.
OPTION B
Option B for the secondary lead subcategory requires control and
treatment technologies to reduce the discharge of wastewater
volume and pollutant mass. The recycle of casting contact
cooling water through cooling towers and the recycle of wet air
pollution control water through holding tanks are the control
mechanisms for flow reduction. The Option B end-of-pipe
treatment technology consists of preliminary treatment with oil
skimming (where required), plus lime precipitation and
sedimentation with total recycle of facility washdown and battery
case classification wastewater.
OPTION C
Option C for the secondary lead subcategory consists of all the
control and treatment technologies of Option B (in-process flow
reduction through cooling towers and holding tanks; lime
precipitation and sedimentation and total recycle of facility
washdown, and battery case classification wastewater end-of-
pipe treatment, and preliminary treatment with oil skimming
(where required)) with the addition of multimedia filtration to
the end-of-pipe treatment scheme.
1967
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SECONDARY LEAD SUBCATEGORY
SECT - VIII
COST METHODOLOGY
A detailed discussion of the methodology used to develop the
compliance costs is presented in Section VIII of the General
Development Document. -Plant-by-plant compliance costs have been
estimated for the nonferrous metals manufacturing category and
are presented in the administrative record supporting this
regulation. A comparison of the proposal and the revised costs
for the final regulation are presented in Tables VIII-1 and VIII-
2 (page!973) for the direct and indirect dischargers,
respectively.
Each of the major assumptions used to develop compliance costs
are presented in Section VIII of Vol. 1. Each subcategory
contains a unique set of waste streams requiring certain
subcategory-specific assumptions to develop compliance costs.
Seven major assumptions are discussed briefly below.
(1)
(2)
(3)
(4)
For plants having existing treatment of insufficient
capacity, the required capital costs are based on
providing the incremental capacity needed and annual
costs are based on operation of a single system at the
expanded capacity.
Information available to the Agency is not detailed
enough to determine if all industrial hygiene waste
streams, truck wash, and floor wash, are present at
each plant. Therefore, where EPA had no information
on these wastewater sources, the Agency assumed all of
these are present at the regulatory flow rate.
Although a discharge allowance for floor wash is not
necessary, EPA included extra treatment capacity to
accommodate this need. Acceptable floor wash water may
be obtained from recycling treated wastewater.
Therefore, costs are included for a holding tank after
chemical precipitation and settling to recycle water
for floor wash use under all options.
Lime addition is" used in most cases throughout the
secondary lead subcategory in estimating costs for
chemical precipitation. However, if a plant currently
uses ammonia, soda ash, or caustic as the chemical
precipitant, the costs are based on caustic addition.
Annual costs for contract hauling are not included when
sludge from existing treatment is recycled either to a
smelter or back to a process. If a plant has a lagoon
for sedimentation and sludge storage, the investment
costs for sedimentation and vacuum filtration are not
included since these technologies would probably not be
installed to comply with the effluent limitations.
However, operation and maintenance costs for these
technologies (and contract hauling) were included as an
estimate of the cost likely to be incurred by the plant
to ultimately dispose of the sludge. All sludges
1968
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SECONDARY LEAD SUBCATEGORY
SECT - VIII
produced through wastewater treatment are considered to
be nonhazardous in estimating costs. However, the
EPA cost for solid waste disposal is equivalent to
hazardous waste disposal. In addition, the Agency
performed a •sensitivity analysis in which sludge
disposal costs were doubled without an increase in
plant closures.
(5) Compliance costs for three plants that are integrated
with battery manufacturing operations are estimated
only for multimedia filtration of the amount of waste
water associated with secondary lead operations. Costs
were developed for a treatment configuration assuming
filtration of an amount of wastewater equal to the
secondary lead subcategory flow, following centralized
lime and settle treatment of combined flows. At two
plants the secondary lead flow consists only of
wastewater from industrial hygiene practices. The
third plant produces battery cracking, furnace
scrubber, and kettle scrubber wastewater but
at rates lower than the BPT regulatory
discharge flows (see Section IX). The Agency adopted
this method of costing because the plants are battery
manufacturing plants, and the wastewater from the
manufacturing operations is very large in comparison to
the secondary lead wastewater flow. Therefore, all
other compliance costs are attributed to the battery
manufacturing regulation.
(6) The costs of holding tanks to achieve recycle of
.; furnace scrubber liquor and kettle scrubber liquor were
not included in compliance costs since the holding
tanks are an integral part of the air pollution control
system and are not the basis of wastewater treatment.
All 17 plants operating furnace or kettle scrubbers
practice recycle exceeding 83 percent.
(7) Recycle of casting contact cooling water is based on
recycle through cooling towers. Annual costs associated
with maintenance and chemicals to prevent biological
growth, corrosion, and scale formation are included
in the estimated compliance costs. If a plant
currently recycles casting contact cooling water,
capital costs of the recycled equipment (piping, pumps,
and cooling towers) were not included in the
compliance costs.
NONWATER QUALITY ASPECTS
Nonwater quality impacts specific to the secondary lead
subcategory including energy requirements, solid waste and air
pollution are discussed below.
1969
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SECONDARY LEAD SUBCATEGORY
SECT - VIII
ENERGY REQUIREMENTS
The methodology used for determining the energy requirements for
the various options is discussed in Section VIII of Vol. 1.
Enerqy requirements for the three options considered are
esUmlted at 5.17 MW-hr/yr, ' 5.23 MW-hr/yr, and 5.42 MW-hr/yr for
Options A, B, and C respectively. Option C represents roughly
two percent of a typical plant's electrical usage. It is
therefore concluded that the energy requirements of the treatment
options considered will have no significant impact on total plant
energy consumption. Option C would increase energy
requirements over Option A by approximately 4.8 percent.
SOLID WASTE
Sludges associated with the secondary lead subcategory will
necessarily contain additional quantities (and concentrations) of
toxic metal pollutants.
wastes generated by secondary metal industries can be regulated
as hazardous. However, the Agency examined the solid wastes that
would be generated at secondary lead plants by the suggested
treatment technologies and believes they are not hazardous wastes
under the Agency's regulations implementing Section 3001 of the
^source Conservation and Recovery Act. None of these wastes are
listed specifically as hazardous, nor are they likely to exhibit
a characteristic of hazardous waste. This judgment is made based
on the recommended technology of lime precipitation,
s:
recommended technology is applied.
The Aaency received several comments from the secondary lead
subcategory claiming sludges generated through the use of lime as
a wastewater treatment chemical were hazardous due to lead. To
properly evaluate these comments, the Agency requested specific
data and information from the commenters. From the material
received, it appears lime sludges at two secondary lead and
battery manufacturing plants sometimes exhibit toxicity due to
lead (six of the 19 samples exhibited EP toxicity in the data
submitted). The Agency contends these sludges would not have
been classified as hazardous under RCRA if a small amount (5-10
percent) of excess lime had been used during wastewater
treatment. (The Agency's trip reports for these facilities
* »
w-astewa
treatment system affects sludge quality
1970
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SECONDARY LEAD SUBCATEGORY
SECT - VIII
It is also the Agency's understanding, based on comments, that
one of the facilities disposing of lime sludges as a hazardous
waste has entered into an agreement with a local landfill at
preferential rates. The Agency contends that if this plant did
not have a local disposal site to dispose of its lime sludge as
hazardous, it could operate its treatment system using excess
lime, which would make the sludges nonhazardous.
The Agency has recalculated the compliance costs for the
secondary lead subcategory on a plant-by-plant basis. In the
cost model, a contract hauling fee of $90 per ton (as
nonhazardous waste) was used in estimating annual costs. The
Agency solicited data on sludge disposal costs and only received
information from one corporation. Data submitted by the
commenter show the contract hauling costs ' when sludges are
disposed of as hazardous wastes ranging from $90 to $110 per ton.
This would indicate that the Agency's sludge disposal costs are
conservative when lime sludges are disposed of as nonhazardous
wastes. In addition, the Agency doubled the contract hauling
costs for secondary lead sludge from $90 per ton to $180 per ton
and found no economic impacts for this subcategory.
The Agency also received comments stating it had not accounted
for additional costs of sludge disposal in states where hazardous
waste disposal is more stringent than the federal requirements.
The Agency is not aware of any state regulations more stringent
than the federal EP toxicity test, except for the state of
California. However, California only requires additional
paperwork for wastes that fail their procedure but pass the
federal EP toxicity test, and does not impose additional disposal
costs or requirements.
Although it is the Agency's view that solid wastes generated as a
result of these guidelines are not expected to be hazardous,
generators of these wastes must test the waste to determine if
the wastes meet any of the characteristics of hazardous waste
(see 40 CFR 262.11) .
If these wastes should be identified or are listed as hazardous,
they will come within the scope of RCRA's "cradle to grave"
hazardous waste management program, requiring regulation from the
point of generation to point of final disposition. EPA's
generator standards would require generators of hazardous
nonferrous metals manufacturing wastes to meet containerization,
labeling, recordkeeping, and reporting requirements; if plants
dispose of hazardous wastes off-site, they would have to prepare
a manifest which would track the movement of the wastes from the
generator's premises to a permitted off-site treatment, storage,
or disposal facility. See 40 CFR 262.20 45 FR 33142 (May 19,
1980), as amended at 45 FR 86973 (December 31, 1980). The
transporter regulations require transporters of hazardous
wastes to comply with the manifest system to assure that the
wastes are delivered to a permitted facility. See 40 CFR 263.20
45 FR 33151 (May 19, 1980), as amended at 45 FR 86973 (December
1971
-------
SECONDARY LEAD SUBCATEGORY
SECT - VIII
31 1980). Finally, RCRA Regulations establish standards for
hazardous waste treatment, storage, and disposal facilities
allowed to receive such wastes. See 40 CFR Part 464 46 FR 2802
(January 12, 1981), 47 FR 32274 (July 26, 1982).
Even if these wastes are not identified as hazardous, they still
must be disposed of in compliance with the Subtitle D open
dumping standards, implementing 4004 of RCRA. See 44 FR 53438
(September 13, 1979). The Agency has calculated as part of the
costs for wastewater treatment the cost of hauling and disposing
of these wastes. EPA estimates that implementation of Hme,
settle, and filter technology will produce approximately .5,100
tons of sludge per year at 20 percent solids. Multimedia
filtration technology will not result in any significant amount
of sludge over that generated by lime precipitation.
AIR POLLUTION
There is no reason to believe that any substantial air pollution
problems will result from implementation of chemical
precipitation, sedimentation, and multimedia filtration. These
technologies transfer pollutants to solid waste and do not
involve air stripping or any other physical process likely to
transfer pollutants to air. Water vapor containing some
particulate matter will be released in the drift from cooling
tower systems; however, the Agency does not consider this impact
to be significant.
1972
-------
SECONDARY LEAD SUBCATEGORY
SECT - VIII
TABLE VIII-1
COST OP COMPLIANCE FOR THE SECONDARY LEAD SUBCATEGORY
DIRECT DISCHARGERS
(March, 1982 Dollars)
Proposal Costs
Promulgation Costs
Option
A
B
C
Capital
639000
639000
2880000
Annual
310000
310000
1850000
Capital
1630000
1630000
1860000
Annual
1120000
1120000
1240000
TABLE VII1-2
COST OP COMPLIANCE FOR THE SECONDARY LEAD SUBCATEGORY
INDIRECT DISCHARGERS
(March, 1982 Dollars)
Proposal Costs
Promulgation Costs
Option
A
B
C
Capital
1660000
2020000
4130000
Annual
758000
760000
2640000
Capital
3690000
3720000
4260000
Annual
2240000
2240000
2510000
1973
-------
SECONDARY LEAD SUBCATEGORY
SECT - VIII
THIS PAGE INTENTIONALLY LEFT BLANK
1974
-------
SECONDARY LEAD SUBCATEGORY SECT - IX
SECTION IX
BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE
This section defines the effluent characteristics attainable
through the application of best practicable control technology
currently available (BPT), Section 301(b)(a)(A). BPT reflects
the existing performance by plants of various sizes, ages, and
manufacturing processes within the secondary lead subcategory, as
well as the established performance of the recommended BPT
systems. Particular consideration is given to the treatment
already in place at plants within the data base.
The factors considered in identifying BPT include the total cost
of applying the technology in relation to the effluent reduction
benefits from such application, the age of equipment and
facilities involved, the manufacturing processes used, nonwater
quality environmental impacts (including energy requirements),
and other factors the Administrator considers appropriate. In
general, the BPT level represents the average of the existing
performances of plants of various ages, sizes, processes, or
other common characteristics. Where existing performance is
uniformly inadequate, BPT may be transferred from a different
subcategory or category. Limitations based on transfer of
technology are supported by a rationale concluding that the
technology is, indeed, transfer able, and a reasonable prediction
that it will be capable of achieving the prescribed effluent
limits (see Tanner's Council of America v. Train, 540 F.2d 1188
(4th Cir. 1176). BPT focuses on end-of-pipe treatment rather than
process changes or internal controls, except where such practices
are common subcategory practice.
TECHNICAL APPROACH TO BPT
The Agency studied the nonferrous metals manufacturing category
to identify the processes used, the wastewaters generated, and
the treatment processes installed. Information was collected
from industry using data collection portfolios, and specific
plants were sampled and the wastewaters analyzed. Additional
data used in the final rule were obtained through comments, new
dcp, and specific data requests. Some of the factors which must
be considered in establishing effluent limitations based on BPT
have already been discussed. The age of equipment and
facilities, processes used, and raw materials were taken into
account in subcategorization and subdivision and are discussed
fully in Section IV. Nonwater quality impacts and energy
requirements are considered in Section VIII.
As explained in Section IV, the secondary lead subcategory has
been segmented into 11 building blocks each of which is a
potential wastewater sources. Since the water use, discharge
rates, and pollutant characteristics of each of these wastewaters
1975
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
is potentially unique, effluent limitations will be developed for
each of the 11 building blocks.
For each of the segments, a specific approach was followed for
the development of BPT mass limitations. To account for
production and flow variability from plant to plant, a unit of
production or production normalizing parameter (PNP) was
determined for each waste stream which could then be related_ to
the flow from the process to determine a production normalized
flow. Selection of the PNP for each process element is discussed
in Section IV. Each process within the subcategory was then
analyzed to determine (1) whether or not operations included
generated wastewater, (2) specific flow rates generated, and (3)
the specific production normalized flows for each process. This
analysis is discussed in detail in Section V. Nonprocess
wastewater such as rainfall runoff and noncontact cooling water
is not considered in the analysis.
Normalized flows were analyzed to determine which flow was to be
used as part of the basis for BPT mass limitations. The selected
flow (sometimes referred to as a BPT regulatory flow or BPT
discharge rate) reflects the water use controls which are common
practices within the subcategory. The BPT normalized flow is
based on the average of all applicable data. Plants with
normalized flows above the average may have to implement some
method of flow reduction to achieve the BPT limitations. In most
cases, this will involve improving housekeeping practices,
better maintenance to limit water leakage, or reducing excess
flow by turning down a flow valve. It is not believed that these
modifications would incur any costs for the plants.
For the development of effluent limitations, mass limitations
were calculated for each wastewater source or subdivision._ This
calculation was made on a stream-by-stream basis, primarily
because plants in this category may perform one or more of the
operations in various combinations. The mass limitations
(milligrams of pollutant per kilogram of production unit —
mg/kg) were calculated by multiplying the BPT normalized flow
(1/kkg) by the concentration achievable using the BPT treatment
system (mg/1) for each pollutant parameter to be limited under
BPT.
The mass limitations which are allowed under BPT for each plant
will be the sum of the individual mass loadings for the various
wastewater sources which are found at particular plants.
Accordingly, all the wastewater generated within a plant may be
combined for treatment in a single or common treatment system.,
but the effluent limitations for these combined wastewaters_ are
based on the various wastewater sources which actually contribute
to the combined flow. This method accounts for the variety of
combinations of wastewater sources and production processes which
may be found at secondary lead plants.
The Agency usually establishes wastewater limitations in terms of
mass rather than concentration. This approach prevents the use
1976
-------
SECONDARY LEAD SUBCATEGORY
SECT
IX
of dilution as a treatment method (except for controlling pH).
The production normalized wastewater flow (1/kkg) is a link
between the production operations and the effluent limitations.
The pollutant discharge attributable to each operation can be
calculated from the normalized flow and effluent concentration
achievable by the treatment technology and summed to derive an
appropriate limitation for each subcategory.
BPT effluent limitations are based on the average of the
wastewater discharge flows for each building block combined with
the commonly used treatment methods in the subcategory. Section
VII discusses the various treatment technologies which are
currently in place for each wastewater source. In most cases, the
current treatment levels consist of chemical precipitation and
sedimentation (lime and settle technology) and a combination of
reuse and recycle to reduce flow.
The overall effectiveness of end-of-pipe treatment for the
removal of wastewater pollutants is improved by the application
of water flow controls within the process to limit the volume of
wastewater requiring treatment. The controls or in-process
technologies recommended under BPT include only those measures
which are commonly practiced within the subcategory and which
reduce flows to meet the production normalized flow for each
operation.
In making technical assessments of data, reviewing manufacturing
processes, and assessing wastewater treatment technology options,
both indirect and direct dischargers have been considered as a
single group. An examination of plants and processes did not
indicate any process differences based on the type of discharge,
whether it be direct or indirect.
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES
In balancing costs in relation to pollutant removal estimates,
EPA considers the volume and nature of existing discharges, the
volume and nature of discharges expected after application of
BPT, the general environmental effects of the pollutants, and the
cost and economic impacts of the required pollution control
level. The Act does not require or permit consideration of water
quality problems attributable to particular point sources or
industries, or water, quality improvements in particular water
quality bodies. Accordingly, water quality considerations were
not the basis for selecting BPT. See Weyerhaeuser Company v.
Costle, 590 F.2d 1011 (D.C. Cir. 1978).
The methodology for calculating pollutant removal estimates and
plant compliance costs is discussed in Section X. Table X-2
(page 2002) shows the estimated pollutant removals for each
treatment option for direct dischargers. Compliance costs for
direct dischargers are presented in Table VIII-1 (page 1973).
1977
-------
SECONDARY, LEAD SUBCATEGORY SECT - IX
BPT OPTION SELECTION
The BPT treatment scheme (Figure IX-1 page 1992) consists of
complete recycle of facility washdown and battery case
classification wastewater following chemical precipitation and
sedimentation (lime and settle) end-of-pipe technology. Although
a specific mass limitation is not provided for oil and grease,
oil skimming is included in EPA cost estimates for battery
cracking, furnace wet air pollution control, truck wash, laundry,
hand wash, and respirator wash wastewater to ensure proper metals
removal. Oil and grease interferes with the chemical addition
and mixing required for chemical precipitation treatment. The
BPT treatment is equivalent to Option A described in Section VII.
The promulgated technology is equivalent to the proposed
technology with the addition of oil skimming and the omission of
complete recycle of kettle scrubbing wastewater. The promulgated
BPT will result in the removal of approximately 25,354 kg/yr of
toxic metal pollutants and 2,852,000 kg/yr of conventional
pollutants from the estimated raw discharge. The estimated
capital cost of BPT is $1,630,000 (March, 1982 dollars) and the
estimated annual cost is $1,120,000 (March, 1982 dollars).
In the proposed limitations, ammonia was given a discharge
allowance of zero to prevent the discharge of kettle scrubber
liquor. Data gathered through special requests have shown those
plants previously thought to be recycling kettle scrubber liquor
100 percent do actually have a periodic discharge. EPA is
promulgating a discharge allowance of zero for ammonia for
secondary lead plants. Ammonia in secondary lead wastewaters is
the result of its use as a wastewater treatment chemical.
Effluent data from a secondary lead plant were found to have
ammonia in its treated effluent at an average concentration of
6,500 mg/1. It is the Agency's understanding that ammonia is
used because it reduces the amount of sludge generated and
produces a sludge more amenable for reuse as a raw material than
lime sludges. However, the use of caustic as a wastewater
treatment chemical is also widely demonstrated in the secondary
lead subcategory. Caustic is as applicable as ammonia for
reducing sludge generation and producing sludges that can be
recycled. . In developing plant-by-plant costs, the Agency
provided costs for substituting neutralization with caustic for
neutralization with lime or ammonia. This will eliminate the
discharge of ammonia and still produce a sludge acceptable for
recycling. However, if a plant chooses to continue using ammonia
as a treatment chemical, it will have to maintain zero discharge
of ammonia.
WASTEWATER DISCHARGE RATES
A BPT discharge rate is calculated for each subdivision based on
the average of the flows of the existing plants, as determined
from analysis of the dcp. The discharge rate is used with the
achievable treatment concentrations to determine BPT effluent
limitations. Since the discharge rate may be different for each
wastewater source, separate production normalized discharge rates
1978
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
for each of the 11 wastewater sources are discussed below and
summarized in Table IX-1 (page 1985). The discharge rates
generally are normalized on a production basis by relating _the
amount of wastewater generated to the mass of the intermediate
product which is produced by the process associated with_ the
waste stream in question. These production normalizing
parameters, or PNP's, are also listed in Table IX-1.
In light of the comments received on the flow allowances
used in the 1983 proposal, the Agency reviewed existing flow and
production information from data collection portfolios and
solicited additional information through specific data requests.
The Agency also performed engineering site visits at two
integrated secondary lead and battery manufacturing plants.
These additional data have been used by the Agency to develop
flow allowances for five waste streams not considered at
proposal. Three of these wastewater streams — hand wash,
respirator wash, and laundries — result from occupational
hygiene needs. Flow allowances have also been developed for
truck washing. The Agency also considered whether to provide
allowances for three other streams, facility washdown, lead paste
desulfurization, and battery case classification, but determined
that no allowance required because treated effluent can be used
as makeup water or because complete recycle and reuse is
practiced. Flow allowances for each of the 11 wastewater streams
identified in the secondary lead subcategory are discussed below.
BATTERY CRACKING
The BPT wastewater discharge rate used
cracking was 940 1/kkg (225 gal/ton) of
the plants with this process discharged
ranging from 80.5 to 5,086 1/kkg (19.3
of the plants practiced recycle of this
BPT rate was the average discharge rate
at proposal for battery
lead produced. All 32 of
this wastewater -at rates
to 1,220 gal/ton). None
wastewater, therefore the
of 32 plants.
The BPT wastewater discharge rate for battery cracking is 673
1/kkg (161 gal/ton) of lead scrap produced. This rate is based
on the average of the discharge flows from 30 plants with this
process. Water use and discharge rates are presented in Table V-
1. The promulgated BPT allowance is different from the proposed
BPT allowance because two plants included in the calculation of
the allowance at proposal were deleted from the average at
promulgation. Plants 266 and 272 were excluded from the average
because of excessive water use compared to the other 30 plants.
The Agency believes there is no technical justification for such
high water usage. Data from five plants which submitted new dcps
subsequent to proposal further support the promulgated BPT
allowance. Inclusion of the new data in the calculation of the
regulatory flow allowance could have resulted in a difference of
less than four percent from the promulgated allowance (673
1/kkg). The Agency received no comments requesting
differentiation in flow allowances based on battery breaking
methods.
1979
-------
SECONDARY LEAD SUBCATEGORY SECT - IX
Since the new data support the promulgated flow allowance, the
new data were not included in the regulatory flow calculation.
Twenty of the 35 plants with this wastewater stream meet the BPT
discharge rate.
BLAST, REVERBERATORY, OR ROTARY FURNACE WET AIR POLLUTION CONTROL
The BPT regulatory wastewater discharge rate for blast and
reverberatory furnace wet air pollution control was 3,380 1/kkg
(811 gal/ton) of lead produced. This rate was allocated only for
those plants having wet air pollution control for smelting
operations. Of the 47 plants with this process, seven used wet
air scrubbing devices. One of the seven plants did not report
sufficient production data to calculate a discharge rate but
reported a recycle rate of 97.8 percent. One' plant discharged
with no recycle. Two plants practiced partial recycle, ranging
from 83.3 to 93.3 percent. (One plant operates two separate
scrubbers on different smelting furnaces.) Two of the seven
plants achieved zero discharge by 100 percent recycle. Extensive
recycling is possible for this wastewater stream, but a zero
discharge may not be technically feasible unless a recycle
system controls dissolved solids build-up, the wastewater is
evaporated, or there is a production operation that can accept
the quality of treated wastewater. Some of these zero discharge
possibilities are site-specific and, therefore, are not
applicable to the secondary lead subcategory as a whole. The
discharge rates from the four discharging scrubbers ranged from
1,776 to 6,587 1/kkg (426 to 1,580 gal/ton). The average of
these four discharges was the basis for the BPT rate. Wastewater
rates for blast and reverberatory furnace wet air pollution
control are presented in Table V-3 of the proposed secondary lead
supplemental development document.
The BPT regulatory wastewater discharge rate for furnace wet air
pollution control is 2,610 1/kkg (626 gal/ton) of lead produced
from smelting. This rate is based on 90 percent recycle of the
average water use for three scrubbers at Plants 265 and 272.
(One plant operates separate scrubbers on two smelting furnaces).
The actual recycle rates of the three scrubbers range from 83.3
to 93.3 percent. Recycle exceeding 83 percent is demonstrated
for all eight furnace scrubbers currently operated in the
subcategory. Water use and discharge rates are presented in
Table V-3 (page 1889). The final BPT regulatory discharge
allowance differs from the proposed BPT discharge allowance. As
discussed above, the proposed allowance was based on the average
wastewater discharge from four scrubbers at three plants. One of
these plants did not practice recycle and has since shut down its
scrubber. This plant (#266) was not included in the calculation
of the promulgated discharge allowance because no recycle was
practiced at this plant and the allowance is based on widely
demonstrated recycle. Data from new dcps received subsequent to
proposal were also excluded from calculation of the discharge
allowance. One plant reports recycling 99.8 percent of its
scrubber water but does not provide sufficient information to
1980
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
calculate production normalized water use. A second plant
(#6602), which practices 95 percent recycle, was excluded from
the calculation of the discharge allowance because of excessive
water use. The water use at this plant is almost four times that
of the highest water user included in the calculation. The
Agency believes there is no technical justification for such high
water use. All seven plants operating furnace scrubbers use
alkaline scrubber solutions to neutralize the sulfur oxides (SOX)
removed from the furnace off-gases. Neutralizing agents used are
lime, caustic, soda ash, and ammonia. The Agency received no
comments requesting differentiation in flow allowances based on
type of scrubber solution. Three of the five plants reporting
sufficient information to calculate discharge rates meet the
promulgated BPT discharge rate.
KETTLE WET AIR POLLUTION CONTROL
No BPT regulatory wastewater discharge allowance was provided for
kettle scrubbing wastewater at proposal. Twenty-eight plants
reported controlling kettle air emissions; 19 used dry
controls (baghouses), and nine used scrubbers. Six plants
reported practicing complete recycle of the scrubber liquor and
one plant used the liquor in the battery cracking and decasing
operation. The remaining two plants practiced recycle of 91.7
and 96 percent. Since complete recycle of kettle scrubber
wastewater was so widely demonstrated in this subcategory, the
Agency believed that zero discharge of wastewater pollutants was
feasible for all secondary lead kettle wet air pollution control.
The BPT regulatory wastewater discharge allowance is 45 1/kkg (11
gal/ton) of lead produced from refining. Data gathered through
specific data requests after proposal have shown those plants
previously thought to practice 100 percent recycle of kettle
scrubber liquor actually have a periodic discharge. As shown in
Table V-5 (page 1894), only three plants reported sufficient
information to calculate production normalized discharge rates.
The BPT regulatory discharge rate is based on the discharge from
Plant 224, which practices 99.2 percent recycle if the periodic
discharge is normalized on a continuous basis. Plants 264 and
273 were excluded because of excessively high discharge rates
compared to Plant 224. The discharge rate for Plants 264 and 273
are approximately two times and 40 times higher, respectively,
than the discharge rate for Plant 224. The Agency can find no
technical reason for such variation in discharge practices at
these plants.
LEAD PASTE DESULFURIZATION
No BPT wastewater discharge allowance is provided for lead paste
desulfurization. Only one plant currently operates this process
and no wastewater is discharged.
1981
-------
SECONDARY LEAD SUBCATEGORY SECT - IX
CASTING CONTACT COOLING WATER
The BPT wastewater discharge rate used at proposal for casting
contact cooling water was 221 1/kkg (53.1 gal/ton) of lead cast.
At proposal, 11 of the -66 secondary lead plants with casting
operations, generated wastewater from the process. Three plants
practiced total recycle and two plants reported discharging
"insignificant" amounts of wastewater. Six plants were once-
through dischargers, with flow rates ranging from 5 to 963 1/kkg
(1 to 231 gal/ton). Wastewater rates for casting contact cooling
are presented in Table V-7 (page 1896). The BPT discharge rate
was based on the average of the six discharging plants.
The BPT regulatory discharge allowance for casting contact
cooling is 221 1/kkg (53.1 gal/ton) of lead cast. This is
equivalent to the proposed flow allowance. The Agency received
no new flow data for casting contact cooling and thus sees no
reason to change the proposed allowance.
TRUCK WASH
The BPT regulatory wastewater discharge rate for truck wash is 21
1/kkg (5 gal/ton) of lead produced from smelting. This allowance
includes wastewater discharge from washing pallets on which scrap
batteries are transported. Although many plants which crack
batteries generate wastewater from truck and pallet washing, the
Agency measured flow data from only two plants. However, there
is no reason to think that truck and pallet washing varies
appreciably from plant to plant. Truck wash flows were
calculated by measuring the water flow rate from hoses used for
washing and the time required to wash a truck. The pallet
washing flow was calculated by multiplying the average number of
pallets per truck by the average flow rate from the hoses used to
wash the trucks and an assumed time needed to wash one pallet.
The number of pallets contained in a truck was calculated from
average truck dimensions and was determined to be 20. The
washing of one pallet was assumed to take 10 seconds. The pallet
flow was calculated as 125 liters (33 gallons) per truck. Truck
wash at two facilities was measured at 151 liters (40 gallons)
and 125 liters (33 gallons) per truck. The production normalized
flow rates for combined truck and pallet wash are presented in
Table V-8 (page 1896). The BPT regulatory flow rate is the
average production normalized discharge at the two plants with
the addition of pallet washing.
FACILITY WASHDOWN
No BPT wastewater discharge allowance is provided for facility
washdown. The Agency believes this wastewater can be treated and
reused as wash water. Recycle or reuse of this wastewater after
treatment is currently demonstrated in four of the nine plants
reporting this wastewater. Compliance costs include the larger
size treatment equipment needed to accommodate this wastewater
stream.
1982
-------
SECONDARY LEAD SUBCATEGORY SECT - IX
BATTERY CASE CLASSIFICATION
No BPT wastewater discharge allowance is provided for battery
case classification wastewater. The Agency believes this
wastewater can be treated and reused in this process based on
demonstrated practices. Four of the eight plants with this
wastewater stream currently reuse battery case classification
wastewater after treatment. Compliance costs include the larger
size treatment equipment needed to accommodate this waste stream.
EMPLOYEE HAND WASH
The BPT regulatory wastewater discharge allowance for employee
hand wash is 27 1/kkg (6.5 gal/ton) of lead produced from
smelting. This allowance is needed for plants to jneet industrial
hygiene requirements. Since flow data were not available for all
but two plants in the subcategory, the discharge allowance was
determined in the following manner. Available production data
and number of employees at each plant (taken from the dcp) were
used to calculate a factor of 0.0217 employees per year per ton
of smelting production. From sampling efforts at two integrated
secondary lead battery manufacturing plants, it was determined
that the average employee uses 1,132.5 liters (300 gallons) per
year of water for hand wash (based on three washes per day, 250
days per year). This results in the production normalized flow
of 27 1/kkg (6.5 gal/ton).
EMPLOYEE RESPIRATOR WASH
The BPT wastewater discharge allowance for employee respirator
wash is 44 1/kkg (10.5 gal/ton) of lead produced from smelting.
This allowance is needed for plants to meet industrial hygiene
requirements. This allowance was determined with the same method
used for employee hand wash. The production factor of 0.0217
employees per year per ton of production was multiplied by the
average water use per employee at two plants (1,836 liters or 485
gallons per year).
LAUNDERING OF UNIFORMS
The BPT regulatory wastewater discharge allowance for laundering
of uniforms is 128 1/kkg (30.7 gal/ton) of lead produced from
smelting. This allowance is needed for plants to meet industrial
hygiene requirements. The methodology used to determine this
rate is the same as employee handwash. From the sampling effort,
it was found that the average water use per employee is 5,356
liters (1,415 gallon) per year. The production factor is 0.0217
employees per year per ton of production. This results in the
allowance of 129 1/kkg (30.7 gal/ton). This allowance is only
intended for those plants that launder uniforms on-site.
REGULATED POLLUTANT PARAMETERS
The raw wastewater concentrations from individual operations and
the subcategory as a whole were examined to select certain
1983
-------
SECONDARY LEAD SUBCATEGORY SECT -IX
pollutants and pollutant parameters for consideration for
limitation. This examination and evaluation was presented in
Section VI. A total of seven pollutants or pollutant parameters
are selected for limitation under BPT and are listed below:
114. antimony
115. arsenic
122. lead
128. zinc
ammonia
total suspended solids (TSS)
pH
EFFLUENT LIMITATIONS
The treatable concentrations achievable by the proposed BPT
treatment scheme are explained in Section VII of Vol. 1 and
summarized there in Table VII-21 (page 248). The treatable
concentrations (both one day maximum and monthly average values)
are multiplied by the BPT normalized discharge flows summarized
in Table IX-1 to calculate the mass of pollutants allowed to be
discharged per mass of product. The results of these
calculations in milligrams of pollutant per kilogram of product
represent the BPT effluent limitations and are presented in Table
IX-2 (page 1986) for each individual waste stream.
1984
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
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1985
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
TABLE IX-2
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(a) Battery Cracking BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg of lead scrap produced
Ibs/million Ibs of lead scrap produced
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
1
1
.932
.407
0.229
0.296
1.279
0.283
1.292
0.276
1.380
0.983
0.000
27.590
0.861
0.579
0.101
0.121
0.673
0.135
0.855
0.114
0.612
0.411
0.000
13.120
Within the range of 7.5 to 10.0
at all times
Blast, Reverberatory, or Rotary Furnace Wet Air
Pollution Control BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
7.491 3.341
, 5.455 2.245
0.887 0.392
1.148 0.470
4.959 2.610
1.096 0.522
5.011 3.315
1.070 0.444
5.351 ' 2.375
3.811 1.592
0.000 0.000
107.000 50.900
Within the range of 7.5 to 10.0
at all times
*Regulated Pollutant
1986
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
TABLE IX-2 (Continued)
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(c) Kettle Wet Air Pollution Control BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from refining
English Units - Ibs/million Ibs of lead produced from refining
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.129 0.058
0.094 0.039
0.015 0.007
0.020 0.008
0.086 0.045
0.016 0.009
0.086 0.057
0.013 0.008
0.092 0.041
0.066 0.027
0.000 0.000
1.845 0.878
Within the range of 7.5 to 10.0
at all times
(d) Lead Paste Desulfurization BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced through desulfurization
English Units - Ibs/million Ibs of lead produced through
desulfurization
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
'• 0.000 0.000
0.000 ' 0.000
0.000 0.000
0.000 0.000
0.000 0.000
Within the range of 7.5 to 10.0
at all times
*Regulated Pollutant
1987
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
TABLE IX-2 (Continued)
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(e) Casting Contact Cooling. BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead cast
English Units - Ibs/million Ibs of lead cast
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*zinc
*Ammonia (as N)
*TSS
*pH
0.634 0.283
0.462 0.190
0.075 0.033
0.097 0.040
0.420 0.221
0.093 0.044
0.424 0.281
0.091 0.038
0.453 0.201
0.323 0.135
0.000 0.000
9.061 4.310
Within the range of 7.5 to 10.0
at all times
(f) Truck Wash BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.060 0.027
0.044 0.018
0.007 0.003
0.009 0.004
0.040 0.021
0.009 0.004
0.040 0.027
0.009 0.004
0.043 0.019
0.031 0.013
0.000 0.000
0.861 0.410
Within the range of 7.5 to 10.0
at all times
*Regulated Pollutant
1988
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
TABLE IX-2 (Continued)
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(g) Facility Washdown BPT .
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
Within the range of 7.5 to 10.0
at all times
(h) Battery Case Classification BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
mg/kg of lead scrap produced
Ibs/million Ibs of lead scrap produced
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
• o.ooo o.ooo
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 ' 0.000
0.000 0.000
0.000 0.000
Within the range of 7.5 to 10.0
at all times
*Regulated Pollutant
1989
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
TABLE IX-2 (Continued)
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(i) Employee Handwash BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.077 0.035
0.056 0.023
0.009 0.004
0.012 0.005
0.051 0.027
0.011 0.005
0.052 0.034
0.011 0.005
0.055 0.025
0.039 0.016
0.000 0.000
1.107 0.527
Within the range of 7.5 to 10.0
at all times
(i) Employee Respirator Wash BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.126
0.092
0.015
0.019
0.084
0.018
0.084
0.018
0.090
0.064
0.000
1.804
0.056
0.038
0.007
0.008
0.044
0.009
0.056
0.007
0.040
0.027
0.000
0.858
Within the range of 7.5 to 10.0
at all times
*Regulated Pollutant
1990
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
TABLE IX-2 (Continued)
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(j) Laundering Uniforms BPT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.367 0.164
0.268 0.110
0.044 0.019
0.056 0.023
0.243 0.128
0.054 0.026
0.246 0.163
0.052 0.022
0.262 0.116
0.187 0.078
0.000 0.000
5.248 2.496
Within the range of 7.5 to 10.0
at all times
*Regulated Pollutant
1991
-------
SECONDARY LEAD SUBCATEGORY
SECT - IX
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1992
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SECONDARY LEAD SUBCATEGORY SECT - X
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SECTION X
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
These effluent limitations are based on the best control and
treatment technology used by a specific point source within the
industrial category or subcategory, or by another category where
it is transferable. Emphasis is placed on additional treatment
techniques applied at the end of the treatment systems currently
used, as well as reduction of the amount of water used and
discharged, process control, and treatment technology
optimization.
The factors considered in assessing best available technology
economically achievable (BAT) include the age of equipment and
facilities involved, the process used, process changes, nonwater
quality environmental impacts (including energy requirements),
and the costs of application of such technology (Section 304(b)
(2){B) of the Clean Water Act). BAT represents the best
available technology economically achievable at plants of various
ages, sizes, processes, or other characteristics. Where the
Agency has found the existing performance to be uniformly
inadequate, BAT may be. transferred from a different subcategory
or category. BAT may include process changes or internal
controls, even when not in common subcategory practice.
The statutory assessment of BAT considers costs, but does not
require a balancing of costs against effluent reduction benefits
(see Weyerhaeuser v. Costle, 590 F.2d 1011 (D.C. Cir. 1978)).
However, in assessing BAT, the Agency has given substantial
weight to the economic achievability of the technology.
TECHNICAL APPROACH TO BAT
The Agency reviewed and evaluated a wide range of technology
options to ensure that the most effective and beneficial
technologies were used as the basis of BAT. The Agency examined
three technology options which could be applied to the secondary
lead subcategory as alternatives for the basis of BAT effluent
limitations.
In summary, the treatment technologies considered for BAT are
presented below:
Option A is based on:
o Preliminary treatment with oil skimming (where required),
o Chemical precipitation and sedimentation, and
o Complete recycle of facility washdown and battery case
classification wastewater after treatment.
1993
-------
SECONDARY LEAD SUBCATEGORY SECT - X
Option B is based on:
o In-process flow reduction of casting contact cooling
water,
o Preliminary treatment with oil skimming (where required),
o Chemical precipitation and sedimentation, and
o Complete recycle of facility washdown and battery
classification wastewater after treatment.
Option C is based on:
o In-process flow reduction of casting contact cooling
water,
o Preliminary treatment with oil skimming (where required),
o Chemical precipitation and sedimentation,
o Complete recycle of facility washdown and battery case
classification wastewater after treatment, and
o Multimedia filtration.
The three options examined for BAT are discussed in greater
detail below. The first option considered (Option A) is the same
as the BPT treatment technology which was presented in the
previous section.
OPTION A
Option A for the secondary lead subcategory is equivalent to the
control and treatment technologies which were analyzed for BPT in
Section IX. The BPT end-of-pipe treatment scheme consists of
preliminary treatment with oil skimming (where required),
chemical precipitation, and sedimentation (lime and settle) end-
of-pipe technology (see Figure X-l page 2009). Although a
specific mass limitation is not provided for oil and grease at
BAT, oil skimming is needed to remove oil and grease from battery
cracking, furnace wet air pollution control, truck wash, laundry,
hand wash, and respirator wash wastewater to ensure proper metals
removal. Oil and grease interferes with chemical addition and
mixing required for chemical precipitation treatment. The
discharge rates for Option A are equal to the discharge rates
allocated to each stream as a BPT discharge flow.
OPTION B
Option B for the secondary lead subcategory achieves lower
pollutant discharge by building upon the Option A end-of-pipe
treatment technology. In-process flow reduction measures are
added to the Option A treatment consisting of oil skimming,
chemical precipitation and sedimentation (see Figure X-2 page
2010). These flow reduction measures result in concentration of
pollutants in other effluents. As previously explained,
treatment of a more concentrated effluent allows achievement of a
greater net pollutant removal and introduces possible economic
benefits associated with treating a lower volume of wastewater.
1994
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
The following method is used in Option B to reduce process waste
water generation and discharge rates:
Recycle of_ Casting Contact Cooling Water Through Cooling Towers
The function of casting contact cooling water is to quickly
remove heat from the newly formed lead ingots. Therefore, the
principal requirements of the water are that it be cool and not
contain dissolved solids at a concentration that would cause
water marks or other surface imperfections. There is sufficient
experience within the category with the cooling and recycling of
casting contact cooling wastewater to assure the success of this
technology using cooling towers or heat exchangers. Recycle is
currently practiced at two of the eight plants in the secondary
lead subcategory reporting data for casting contact cooling. A
blowdown or periodic cleaning is likely to be heeded to prevent a
build-up of dissolved and suspended solids. EPA has determined
that a blowdown of 10 percent of the water applied in a process
is adequate.
OPTION C
Option C for the secondary lead subcategory consists of the
Option B treatment in-process flow reduction, oil skimming (where
required), chemical precipitation, sedimentation, and complete
recycle of treated facility washdown and battery case
classification wastewater plus multimedia filtration technology
added at the end of Option B treatment (see Figure X-3 page
2011). Multimedia filtration is used to remove suspended solids,
including precipitates of toxic metals, beyond the concentration
attainable by gravity sedimentation. The filter suggested is of
the gravity, mixed media type, although other filters, such as
rapid sand filters or pressure filters, would perform
satisfactorily.
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES
As a means of evaluating each technology option, EPA developed
estimates of the pollutant removal estimates and the compliance
costs associated with each option. The methodologies are
described below.
POLLUTANT REMOVAL ESTIMATES
A complete description of the methodology used to calculate the
estimated pollutant removal achieved by the application of the
various treatment options is presented in Section X of Vol. I.
The pollutant removal estimates have been revised from proposal
based on comments and new data. However, the methodology for
calculating pollutant removals was not changed. The data used
for estimating pollutant removals are the same as those used to
revise the compliance costs.
Sampling data collected during the field sampling program were
used to characterize the major wastewater streams considered for
1995
-------
SECONDARY LEAD SUBCATEGORY SECT - X
regulation. At each sampled facility, the sampling data were
production normalized for each building block (i.e., mass of
pollutant generated per mass of product manufactured). This
value, referred to as the raw waste, was used to estimate the
mass of toxic pollutants generated within the secondary lead
subcategory. By multiplying the total subcategory production for
a unit operation by the corresponding raw waste value, the mass
of pollutant generated for that unit operation was estimated.
The volume of wastewater discharged after the application of each
treatment option was estimated for each operation at each plant
by comparing the actual discharge to the regulatory flow. The
smaller of the two values was selected and summed with the other
plant flows. The mass of pollutant discharged was then estimated
by multiplying the achievable concentration values attainable by
the option (mg/1) by the estimated volume of process wastewater
discharged by the subcategory. The mass of pollutant removed is
simply the ditfersnce between the estimated mass of pollutant
generated within the subcategory and the mass of pollutant
discharged after application of the treatment option.
The pollutant removal estimates for direct discharges in the
secondary lead subcategory are presented in Table X-l (page
2001).
COMPLIANCE COSTS
Compliance costs presented at proposal were estimated using cost
curves, which related the total costs associated with
installation and operation of wastewater treatment technologies
to plant process wastewater discharge. EPA applied these curves
on a per plant basis, a plant's costs — both capital, and
operating and maintenance — being determined by what treatment
it has in place and by its individual process wastewater
discharge (from dcp). The final step was to annualize the capital
costs, and to sum the annualized capital costs, and the operating
and maintenance costs, yielding the total annual cost of
compliance for the subcategory.
Since proposal, the cost estimation methodology has been changed
as discussed in Section VIII of this supplement. A design model
and plant specific information were used to size a wastewater
treatment system for each discharging facility. After completion
of the design, capital and annual costs were estimated for each
unit of the wastewater treatment system. Capital costs rely on
vendor quotes, while annual costs were developed from the
literature. The revised compliance costs for direct dischargers
are presented in Table VIII-1 (page 1973).
BAT OPTION SELECTION - PROPOSAL
At proposal, EPA selected both Option B and Option C as the basis
for alternative BAT effluent limitations for the secondary lead
subcategory due to current adverse structural economic changes
that were not reflected in the Agency's economic analysis. These
1996
-------
SECONDARY LEAD SUBCATEGORY SECT - X
alternative limitations were based on lime precipitation,
sedimentation, and in-process control technologies to reduce the
volume of process wastewater discharged for Option B and the
addition of multimedia filtration for Option C.
Activated alumina (Option D) was considered; however, this
technology was rejected because it was not demonstrated in this
subcategory nor was it clearly transferable to nonferrous
wastewater. Reverse osmosis (Option F) was considered for the
purpose of achieving zero discharge of process wastewater;
however, the Agency ultimately rejected this technology because
it was determined that its performance for this specific purpose
was not adequately demonstrated in this subcategory nor was it
clearly transferable from another subcategory or category.
BAT OPTION SELECTION - PROMULGATION
After proposal the Agency obtained data through special requests,
dcp submittals, and telephone contacts. Additionally, two
secondary lead facilities were sampled to further characterize
wastewater. The new data were used to recalculate compliance
costs and pollutant removal estimates and evaluate regulatory
flow allowances where appropriate.
EPA is promulgating BAT effluent mass limitations based on the
promulgated BPT treatment with additional reduction in pollutant
discharge achieved through in-process flow reduction over BPT
levels and the use of multimedia filtration as an effluent
polishing st'ep. The BAT treatment consists of preliminary
treatment with oil skimming (where required), in-process flow
reduction, lime precipitation, sedimentation, and multimedia
filtration. Wastewater flow reduction over BPT levels is based
on recycle of casting contact cooling water through cooling
towers. The promulgated BAT flow allowances are identical to the
promulgated BPT flow allowances except for casting contact
cooling. The end-of-pipe treatment technology basis for BAT
limitations being promulgated is the same as that for the
proposed Alternative B limitations. The Agency has revised the
compliance costs and economic analysis. Results of this analysis
indicate filtration as an end-of-pipe polishing step is
economically achievable.
Implementation of the promulgated BAT would remove 25,700 kg of
toxic metals annually. The promulgated BAT effluent mass
limitations will result in the removal of 350 kg/yr of toxic
pollutants above the estimated BPT discharge. The selected
option is economically achievable. The Agency believes this
incremental removal justifies selection of filtration as part of
BAT model technology. In addition, filtration is demonstrated at
seven secondary lead plants. The estimated capital investment
cost of BAT is $1.86 million (March, 1982 dollars) and the
estimated annual cost is $1.24 million (March, 1982 dollars).
As discussed in the BPT Option Selection, EPA is promulgating
zero discharge of ammonia for secondary lead plants. Ammonia in
1997
-------
SECONDARY LEAD SUBCATEGORY SECT - X
secondary lead wastewaters is the result of its use as a
wastewater treatment chemical.
It is the Agency's understanding that ammonia is used because it
reduces the amount of sludge generated and produces a sludge more
amenable for reuse as a raw material than lime sludges. However,
the use of caustic as a wastewater treatment chemical is also
widely demonstrated in the secondary lead subcategory. Caustic
is as applicable as ammonia for reducing sludge generation and
producing sludges that can be recycled. In developing plant-by-
plant costs, the Agency evaluated costs for substituting
neutralization with caustic for neutralization with lime or
ammonia. This will eliminate the discharge of ammonia and still
produce a sludge acceptable for recycling. However, if a plant
chooses to continue using ammonia as a treatment chemical, it
will have to maintain zero discharge of ammonia.
WASTEWATER DISCHARGE RATES
A BAT discharge rate was calculated for each subdivision based
upon the flows of the existing plants, as determined from
analysis of the data collection portfolios. The discharge rate
is used with the achievable treatment concentration to determine
BAT effluent limitations. Since the discharge rate may be
different for each wastewater source, separate production
normalized discharge rates for each of the 11 wastewater sources
were determined and are summarized in Table X-2 (page 2002). The
discharge rates are normalized on a production basis by relating
the amount of wastewater generated to the mass of the
intermediate product which is produced by the process associated
with the waste stream in question. These production normalizing
parameters (PNP) are also listed in Table X-2.
The BAT wastewater discharge rate equals the BPT wastewater
discharge rate for all waste streams except casting contact
cooling water. This stream is discussed below.
The Agency proposed zero discharge of wastewater pollutants from
kettle scrubbers and flow reduction over BPT levels for furnace
scrubbers. As discussed in Section IX, data gathered through
specific data requests have shown those plants thought to
practice 100 percent recycle of kettle scrubber liquor actually
have a periodic discharge. A wastewater discharge allowance is
provided for kettle scrubbers at BPT. However, the proposed
BPT discharge allowance has been changed for promulgation and is
now based on 90 percent recycle. Further flow reduction is not
demonstrated in the subcategory. The allowance is based on 90
percent recycle of scrubber liquor and is equal to the BPT
discharge allowance.
CASTING CONTACT COOLING WATER
The BAT wastewater regulatory discharge, allowance is 22 1/kkg
(5.3 gal/ton), based on 90 percent recycle of the BPT discharge
allowance. Ten of the 46 plants currently reporting casting
1998
-------
SECONDARY LEAD SUBCATEGORY SECT - X
operations use contact cooling water. Two plants achieve zero
discharge through 100 percent recycle or evaporation. Six plants
are once-through dischargers with flow rates ranging from 5 to
963 1/kkg (1 to 231 gal/ton). Four of the eight plants reporting
flow data meet the BAT discharge allowance.
REGULATED POLLUTANT PARAMETERS
In implementing the terms of the Consent Agreement in NRDC v.
Train, Op. Cit., and 33 U.S.C. 1314(b)(2)(A and B) (1976), the
Agency placed particular emphasis on the toxic pollutants. The
raw wastewater concentrations from individual operations and the
subcategory as a whole were examined to select certain pollutants
and pollutant parameters for consideration for limitation. This
examination and evaluation, presented in Section VI, concluded
that 13 pollutants or pollutant parameters' are present in
secondary lead wastewaters at concentrations that can be
effectively reduced by identified treatment technologies.
The high cost associated with analysis for toxic metal pollutants
has prompted EPA to develop an alternative method for regulating
and monitoring toxic pollutant discharges from the nonferrous
metals manufacturing category. Rather than developing specific
effluent mass limitations and standards for each of the toxic
metals found in treatable concentrations in the raw wastewater
from a given subcategory, the Agency is promulgating effluent
mass limitations only for those pollutants generated in the
greatest quantities as shown by the pollutant removal analysis.
The pollutants selected for specific limitation are listed below:
114. antimony
115. arsenic
122. lead
128. zinc
ammonia (as N)
By establishing limitations and standards for certain toxic metal
pollutants, dischargers will attain the same degree of control
over toxic metal pollutants as they would have been required to
achieve had all the toxic metal pollutants been directly limited.
This approach is justified technically since the treatment
effectiveness concentrations used for lime precipitation and
sedimentation technology are based on optimized treatment for
concomitant multiple metals removal. Thus, even though metals
have somewhat different theoretical solubilities, they will be
removed at very nearly the same rate in a lime precipitation and
sedimentation treatment system operated for multiple metals
removal. Filtration as part of the technology basis is likewise
justified because this technology removes metals non-
preferential ly.
The toxic metal pollutants selected for specific limitation in
the secondary lead subcategory to control the discharges of toxic
metal pollutants are antimony, arsenic, lead, and zinc. The
1999
-------
SECONDARY LEAD SUBCATEGORY SECT - X
following toxic pollutants are excluded from limitation on the
basis that they are effectively controlled by the limitations
developed for the selected toxic metalss
118. cadmium
119. chromium (Total)
120. copper
124. nickel
126. silver
127. thallium
Effluent mass limitations are promulgated to eliminate the
discharge of ammonia. Ammonia is used by some plants in the
secondary lead subcategory as a wastewater treatment chemical.
Monitoring and analysis for ammonia is not necessary if ammonia
is not used. Plants must demonstrate to the permit and control
authority that ammonia is not used in the plant as a process or
wastewater treatment chemical.
EFFLUENT LIMITATIONS
The concentrations, achievable by application of the BAT
technology (Option C) are summarized in Table VII-21 (page
248) of Vol. 1. These treatment effectiveness concentrations
(both one day maximum and monthly average) are multiplied by the
BAT normalized discharge flows summarized in Table X-2 to
calculate the mass of pollutants allowed to be discharged per
mass of product. The results of these calculations in milligrams
of pollutant per kilogram of product represent the BAT effluent
limitations for the secondary lead subcategory. The BAT effluent
limitations are presented in Table X-3 (page 2003) for each waste
stream.
2000
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
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SECONDARY LEAD SUBCATEGORY
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-------
SECONDARY LEAD SUBCATEGORY
SECT - X
TABLE X-3
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(a) Battery Cracking BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead scrap produced
English Units - Ibs/million Ibs of lead scrap produced
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
1.299
0.935
0.135
0.249
0.861
0.188
1.370
0.195
0.942
0.686
0.000
0.579
0.384
0.054
0.101
0.411
0.087
0.249
0.081
0.411
0.283
0.000
(b) Blast, Reverberatory, or Rotary Furnace Wet Air
Pollution Control BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
* Antimony
*Arsenic
Cadmium
Chromium
Coppe r
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
5.037
3.628
0.522
0.966
3.341
0.731
1.436
0.757
3.654
2.662
0.000
2.245
1.488
0.209
0.392
1.592
0.339
0.966
0.313
1.592
1.096
0.000
^Regulated Pollutant
2003
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
TABLE X-3 (Continued)
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(c) Kettle Wet Air Pollution Control BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from refining
English Units - Ibs/million Ibs of lead produced from refining
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.087
0.063
0.009
0.017
0.058
0.013
0.025
0.013
0.063
0.046
0.000
0.039
0.026
0.004
0.007
0.027
0.006
0.017
0.005
0.027
0.019
0.000
(d) Lead Paste Desulfurization BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced through desulfurization
English Units - Ibs/million Ibs of lead produced through
desulfurization
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
*Regulated Pollutant
2004
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
TABLE X-3 (Continued)
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(e) Casting Contact Cooling BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead cast
English Units - Ibs/million Ibs of lead cast
* Antimony
*Arsenic
Cadmium
Chromium
Coppe r
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.042
0.031
0.004
0.008
0.028
0.006
0.012
0.006
0.031
0.022
0.000
0.019
0.013
0.002
0.003
0.013
0.003
0.008
0.003
0.013
0.009
0.000
(f) Truck Wash BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from
smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.041
0.029
0.004
0.008
0.027
0.006
0.012
0.006
0.029
0.021
0.000
0.018
0.012
0.002
0.003
0.013
0.003
0.008
0.003
0.013
0.009
0.000
^Regulated Pollutant
2005
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
TABLE X-3 (Continued)
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(g) Facility Washdown BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
(h) Battery Case Classification BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
mg/kg of lead scrap produced
Ibs/million Ibs of lead scrap produced
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
*Regulated Pollutant
2006
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
TABLE X-3 (Continued)
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(i) Employee Handwash BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.052
0.038
0.005
0.010
0.035
0.008
0.015
0.008
0.038
0.028
0.000
0.023
0.015
0.002
0.004
0.016
0.004
0.010
0.003
0.016
0.011
0.000
*Regulated Pollutant
2007
-------
SECONDARY LEAD SUBCATEGORY SECT - X
TABLE X-3 (Continued)
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(i) Employee Respirator Wash BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.085
0.061
0.009
0.016
0.056
0.012
0.024
0.013
0.062
0.045
0.000
0.038
0.025
0.004
0.007
0.027
0.006
0.016
0.005
0.027
0.018
0.000
(j) Laundering Uniforms BAT
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.247
0.178
0.026
0.047
0.164
0.036
0.070
0.037
0.179
0.131
0.000
0.110
0.073
0.010
0.019
0.078
0.017
0.047
0.015
0.078
0.054
0.000
*Regulated Pollutant
2008
-------
SECONDARY LEAD SUBCATEGORY
SECT - X
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-------
SECONDARY LEAD SUBCATEGORY
SECT - X
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SECONDARY LEAD SUBCATEGORY
SECT - X
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SECONDARY LEAD SUBCATEGORY SECT - X
THIS PAGE INTENTIONALLY LEFT BLANK
2012
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
SECTION XI ,
NEW .SOURCE PERFORMANCE STANDARDS
The basis for new source performance standards (NSPS) under
Section 306 of the Act is the best available demonstrated
technology (BDT). New plants have the opportunity to design the
best and most efficient production processes and wastewater
treatment technologies, without facing the added costs and
restrictions encountered in retrofitting an existing plant.
Therefore, Congress directed EPA to consider the best
demonstrated process changes, in-plant controls, and end-of-pipe
treatment technologies which reduce pollution to the maximum
extent feasible.
This section describes the control technology for treatment of
wastewater from new sources and presents mass discharge
limitations of regulatory pollutants for NSPS in the secondary
lead subcategory, based on the described control technology.
TECHNICAL APPROACH TO BDT
All of the treatment technology options applicable to a new
source were previously considered for the BAT options. For this
reason, three options were considered for BDT, which are all
identical, with one exception, to the BAT options discussed in
Section X. The kettle wet air pollution control discharge
allowance is .eliminated under BDT through use of dry air
pollution control. Dry scrubbing is widely demonstrated for
controlling emissions from kettle refining. Of the 28 plants
with kettle air pollution control, 19 use dry scrubbing. The
Agency also considered proposing dry scrubbing for controlling
emissions from blast and reverberatory furnaces, but the nature
of these emissions precludes the use of dry scrubbing. Exhaust
gases from blast and reverberatory furnaces contain sulfur
dioxide fumes, which require wet air pollution scrubbing.
The treatment technologies used for the three BDT options are:
OPTION A
o
o
o
Preliminary treatment.with oil skimming (where required),
Chemical precipitation and sedimentation,
Dry air pollution control of kettle refining, or alter-
nately, complete recycle of kettle scrubber liquor, and
Complete recycle of facility washdown and battery case
classification wastewater after treatment.
OPTION B
o In-process flow reduction of casting contact cooling
water,
•o Preliminary treatment with oil skimming (where required),
2013
-------
SECONDARY LEAD SUBCATEGORY SECT - XI
o Chemical precipitation and sedimentation,
o Dry air pollution control of kettle refining, or alter-
nately, complete recycle of kettle scrubber liquor, and
o Complete recycle of facility washdown and battery
classification wastewater after treatment.
OPTION C
o In-process flow reduction of casting contact cooling
water,
o Preliminary treatment with oil skimming (where required),
o Chemical precipitation and sedimentation,
o Dry air pollution control of kettle refining, or alter-
nately, complete recycle of kettle scrubber liquor,
o Complete recycle of facility washdown and battery case
classification wastewater after treatment, and
o Multimedia filtration.
Partial or complete reuse and recycle of wastewater is an
essential part of each option. Reuse and recycle can precede or
follow end-of-pipe treatment. A more detailed discussion of
these treatment options is presented in Section X.
BDT OPTION SELECTION
EPA is promulgating NSPS for the secondary lead subcategory equal
to the technology basis of BAT and is requiring additional flow
reduction over BPT levels by using dry scrubbing to control
emissions from kettle refining. Existing wet scrubbers are used
to control emissions and prevent baghouse fires caused by
sparking when sawdust and phosphorus are applied to the surface
of the metal while in the kettle. Dry scrubbers can be used for
this purpose if spark arresters and settling chambers are
installed to trap sparks. According to the Secondary Lead
Smelters Association, this is a demonstrated and viable
technology option. Dry scrubbing is not required at BAT because
of the extensive retrofit costs of switching from wet to dry
scrubbing.
The Agency recognizes that new sources have the opportunity to
implement more advanced levels of treatment without incurring the
costs of retrofit equipment, the costs of partial or complete
Shutdown necessary for installation of the new equipment, and the
costs of startup and stabilization of the treatment system that
existing plants would have. Specifically, the design of new
plants can be based on recycle of contact cooling waters, recycle
of air pollution control scrubber liquor, and use of dry air
pollution equipment.
REGULATED POLLUTANT PARAMETERS
The Agency has no reason to believe that the pollutants that will
be found in treatable concentrations in processes within new
sources will be any different than with existing sources.
Accordingly, pollutants and pollutant parameters selected for
2014
-------
SECONDARY LEAD SUBCATEGORY
SECT
XI
limitation under NSPS, in accordance with the rationale of
Sections VI and X, are identical to those selected for BAT. The
conventional pollutant parameters TSS and pH are also selected
for limitation.
NEW SOURCE PERFORMANCE STANDARDS
The NSPS discharge flows for each wastewater source are the same
as the discharge rates for BAT except for kettle wet air
pollution control and are presented in Table XI-1 (page 2016).
The mass of pollutant allowed to be discharged per mass of
product is calculated by multiplying the appropriate treatment
effectiveness concentration by the production normalized
wastewater discharge flows (1/kkg). These concentrations are
listed in Table VII-21 {page 248) of Vol. I. New source
performance standards are presented in Table XI-2 (page 2017).
2015
-------
SECONDARY LEAD SUBCATEGORY
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2016
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
TABLE XI-2
NSPS FOR THE SECONDARY LEAD SUBCATEGORY
(a) Battery Cracking NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead scrap produced
English Units - Ibs/million Ibs of lead scrap produced
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
1.299 0.579
0.935 0.384
0.135 0.054
0.249 0.101
0.861 0.411
0.188 0.087
1.370 0.249
0.195 0.081
0.942 0.411
0.686 0.283
0.000 0.000
10.100 8.076
Within the range 7.5 to 10.0
at all times
Blast, Reverberatory, or Rotary Furnace Wet Air
Pollution Control NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for .-
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
5.037 2.245
3.628 1.488
0.522 0.209
0.966 0.392
3.341 1.592
0.731 0.339
1.436 0.966
0.757 0.313
3.654 ' 1.592
2.662 1.096
0.000 0.000
39.150 31.320
Within the range 7.5 to 10.0
at all times
*Regulated Pollutant
2017
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
TABLE XI-2 (Continued)
NSPS FOR THE SECONDARY LEAD SUBCATEGORY
(c) Kettle Wet Air Pollution Control NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from refining
English Units - Ibs/million Ibs of lead produced from refining
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
Within the range 7.5 to 10.0
at all times
(d) Lead Paste Desulfurization NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Ayerage
Metric Units - mg/kg of lead produced through desulfurization
English Units - Ibs/million Ibs of lead produced through
desulfurization
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 ' 0.000
0.000 0.000
0.000 0.000
0.000 ' 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
Within the range 7.5 to 10.0
at all times
*Regulated Pollutant
2018
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
TABLE XI-2 (Continued)
NSPS FOR THE SECONDARY LEAD SUBCATEGORY
(e) Casting Contact Cooling NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead cast
English Units - Ibs/million Ibs of lead cast
*Antimony
*Arsenic
Cadmium
Chromium
Coppe r
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.042 0.019
0.031 0.013
0.004 0.002
0.008 0.003
0.028 0.013
0.006 0.003
0.012 0.008
0.006 0.003
0.031 0.013
0.022 0.009
0.000 0.000
0.330 0.264
Within the range 7.5 to 10.0
at all times
(f) Truck Wash NSPS
Pollutant or
Pollutant . Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Coppe r
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia {as N)
*TSS .
*pH
0.041 0.018
0.029 0.012
0.004 0.002
0.008 0.003
0.027 0.013
0.006 0.003
0.012 0.008
0.006 0.003
0.029 0.013
0.021 0.009
0.000 0.000
0.315 0.252
Within the range 7.5 to 10.0
at all times
^Regulated "Pollutant"
2019
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
TABLE XI-2 (Continued)
NSPS FOR THE SECONDARY LEAD SUBCATEGORY
(g) Facility Washdown NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
Within the range 7.5 to 10.0
at all times
(h) Battery Case Classification NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
mg/kg of lead scrap produced
Ibs/million Ibs of lead scrap produced
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 0.000
0.000 ' 0.000
0.000 0.000
0.000 0.000
0.000 0.000
Within the range 7.5 to 10.0
at all times
*Regulated Pollutant
2020
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
TABLE XI-2 (Continued)
NSPS FOR THE SECONDARY LEAD SUBCATEGORY
i) Employee Handwash NSPS.
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
^Antimony
*Arsenic
Cadmium,
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.052 0.023
0.038 0.015
0.005 0.002
0.010 0.004
0.035 0.016
0.008 0.004
0.015 0.010
0.008 0.003
0.038 0.016
0.028 0.011
0.000 0.000
0.405 0.324
Within the range 7.5 to 10.0
at all times
(i) Employee Respirator Wash NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.085 0.038
0.061 0.025
0.009 0.004
0.016 0.007
0.056 0.027
0.012 0.006
0.024 0.016
0.013 0.005
0.062 0.027
0.045 0.018
0.000 0.000
0.660 0.528
Within the range 7.5 to 10.0
at all times
*Regulated Pollutant
2021
-------
SECONDARY LEAD SUBCATEGORY
SECT - XI
TABLE XI-2 (Continued)
NSPS FOR THE SECONDARY LEAD SUBCATEGORY
(j) Laundering Uniforms 'NSPS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*TSS
*pH
0.247 0.110
0.178 0.073
0.026 0.010
0.047 0.019
0.164 0.078
0.036 0.017
0.070 0.047
0.037 0.015
0.179 0.078
0.131 0.054
0.000 0.000
1.920 1.536
Within the range 7.5 to 10.0
at all times
* Regulated Pollutant
2022
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
SECTION XII
PRETREATMENT STANDARDS
PSES are designed to prevent the discharge of pollutants which
pass through, interfere with, or are otherwise incompatible' with
the operation of publicly owned treatment works (POTW). The
Clean Water Act of 1977 requires pretreatment for pollutants,
such as toxic metals, that limit POTW sludge management
alternatives. Section 307(c) of the Act requires EPA to
promulgate pretreatment standards for new sources (PSNS) at the
same time that it promulgates NSPS. New indirect discharge
facilities, like new direct discharge facilities, have the
opportunity to incorporate the best available demonstrated
technologies, including process changes, in-plant controls, and
end-of-pipe treatment technologies, and to use plant site
selection to ensure adequate treatment system installation.
Pretreatment standards are to be technology based, analogous to
the best available technology for removal of toxic pollutants.
This section describes the .control and treatment technologies for
pretreatment of process wastewaters from existing sources and new
sources in the secondary lead subcategory. Pre.treatment
standards for regulated pollutants are presented based on the
selected control and treatment technologies.
TECHNICAL APPROACH TO PRETREATMENT ,
Before promulgating pretreatment standards, the Agency examines
whether the pollutants discharged by the industry pass through
the POTW or interfere with the POTW operation or its chosen
sludge disposal practices. In determining whether pollutants
pass through a well-operated POTW achieving secondary treatment,
the Agency compares the percentage of a pollutant removed by POTW
with the percentage removed by direct dischargers applying the
best available technology economically achievable. A pollutant
is deemed to pass through the POTW when the average
removed nationwide by well-operated POTW meeting
percentage
secondary
treatment requirements, is less than the percentage removed by
direct dischargers complying with BAT effluent limitations
for that pollutant.
This definition of pass through satisfies two competing
objectives set by Congress: (1) that standards for indirect
dischargers be equivalent to standards for direct dischargers,
while at the same time, (2) that the treatment capability and
performance of the POTW be recognized and taken into account in
regulating the discharge of pollutants from indirect dischargers.
The Agency compares percentage removal rather than the mass or
concentration of pollutants discharged because the latter would
not take into account the mass of pollutants discharged to the
POTW from non-industrial sources nor the dilution of the
pollutants in the POTW effluent to lower concentrations due to
2023
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
the addition of large amounts of non-industrial wastewater.
PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES
The treatment technology options for PSES and PSNS are the same
as the BAT Options discussed in Section X. For promulgation PSNS
requires that the kettle furnace air scrubbing waste stream be
eliminated through the use of dry air pollution control. A more
detailed discussion, including pollutants controlled by each
treatment process and achievable treatment concentration for each
option, is presented in Section VII of Vol. 1.
Treatment technologies considered for PSES:
OPTION A
o
o
Chemical precipitation and sedimentation,
Complete recycle of facility washdown and battery case
classification wastewater after treatment.
OPTION B
o
o
In-process flow reduction of casting contact cooling
water,
Chemical precipitation and sedimentation,
Complete recycle of facility washdown and battery case
classification wastewater after treatment.
OPTION C
o In-process flow reduction of casting contact cooling
water,
o Chemical precipitation and sedimentation,
o Complete recycle of facility washdown and battery case
classification wastewater after treatment, and
o Multimedia filtration.
COST AND POLLUTANT REMOVAL ESTIMATES
The cost and pollutant removal estimates of each treatment
option were used to determine the most cost-effective option.
The methodology applied in calculating pollutant removal
estimates and plant compliance costs is discussed in Section X.
Table XII-1 (page 2027) shows the estimated pollutant removals
for indirect dischargers. Compliance costs are presented in
Table VIII-2 (page 1973).
2024
-------
SECONDARY LEAD SDBCATEGORY
SECT - XII
PSES OPTION SELECTION
EPA has selected Option C as the basis for PSES for the secondary
lead subcategory. This technology is- equivalent to , the
promulgated BAT. The Option C treatment consists of in-process
flow ' reduction, chemical precipitation, sedimentation, and
multimedia filtration. This selection follows the rationale used
in the selection of BAT. This option prevents pass-through and
equals promulgated BAT.
Implementation of the promulgated PSES limitations would .remove
annually an. estimated 15,531 kg of toxic pollutants over
estimated current discharge. Removals based on estimated raw
discharge are approximately 46,500 kg of toxic pollutants. The
final PSES effluent mass limitations will remove 620 kg/yr of
toxic metals over the intermediate PSES option considered, which
lacks filtration. Both options are economically achievable. The
Agency believes the incremental removal justifies selection of
filtration as part of PSES model technology. Filtration is
currently demonstrated by five indirect discharging secondary
lead plants. The estimated capital cost for achieving promulgated
PSES is $4.26 million (March, 1982 dollars), and the estimated
annual cost is $2.51 million.
PSNS OPTION SELECTION
The technology basis for promulgated PSNS is identical to NSPS.
The PSNS treatment consists of in-process flow reduction,
chemical precipitation, sedimentation, and multimedia filtration.
The Agency recognizes that new sources have the opportunity to
implement more advanced levels of treatment without incurring the
costs of retrofitting and the costs of partial or complete
shutdown necessary for installation of the new equipment that
existing plants should have.
Promulgated PSNS prevents pass through and equals promulgated
NSPS. The PSNS flow allowances are based on minimization of
process wastewater wherever possible through use of cooling
towers to recycling casting contact cooling water. Complete
recycle of treated facility washdown and battery case
classification wastewater is also included. Dry scrubbing is
required for kettle air pollution control for the reasons
provided in NSPS.
REGULATED POLLUTANT PARAMETERS
Pollutants and pollutant parameters selected for limitation in
accordance with the rationale of Sections VI and X, are identical
to those selected for limitation for BAT. EPA is promulgating
PSES and PSNS for ammonia, antimony, arsenic, lead, and zinc to
prevent pass-through. The conventional pollutants are not
limited under PSES and PSNS because they are effectively
controlled by POTW.
2025
-------
r
SECONDARY LEAD SUBCATEGORY
SECT - XII
PRETREATMENT STANDARDS
The PSES and PSNS discharge flows are identical to the BAT
discharge flows for all processes except PSNS for kettle air
pollution control. These discharge flows are listed in Tables
XII-2 and XII-3 (pages 2027 and 2028). The mass of pollutant
allowed to be discharged per mass of product is calculated by
multiplying the achievable treatment concentration (mg/1) by the
normalized wastewater discharge flow (1/kkg). The achievable
treatment concentrations are presented in Table VII-21 of Vol. I
(page 248). Pretreatment standards for existing and new sources,
as determined from the above procedure, are shown in Tables XII-4
and XII-5 (pages 2030 and 2036) for each waste stream.
2026
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
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SECONDARY LEAD SUBCATEGORY
SECT - XII
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2028
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
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2029
-------
SECONDARY LEAD SUBCATEGORY
SECT
XII
TABLE XI1-4
PSES FOR THE SECONDARY LEAD SUBCATEGORY
(a) Battery Cracking P'SES.
Pollutant or
Ppllutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead scrap produced
English Units - Ibs/million Ibs of lead scrap produced
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
1.299
0.935
0.135
0.249
0.861
0.188
1.370
0.195
0.942
0.686
0.000
0.579
0.384
0.054
0.101
0.411
0.087
0.249
0.081
0.411
0.283
0.000
(b) Blast, Reverberatory, or Rotary Furnace Wet Air
Pollution Control PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
'Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
5.037
3.628
0.522
0.966
3.341
0.731
1.436
0.757
3.654
2.662
0.000
2.245
1.488
0.209
0.392
1.592
0.339
0.966
0.313
1.592
1.096
0.000
*Regulated Pollutant
2030
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XII-4 (.Continued)
PSES FOR THE SECONDARY LEAD SUBCATEGORY
(c) Kettle Wet Air Pollution Control PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from refining
English Units - Ibs/million Ibs of lead produced from refining
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.087
0.063
0.009
0.017
0.058
0.013
0.025
0.013
0.063
0.046
0.000
0.039
0.026 '-
0.004
0.007
0.027 ,
0.006
0.017
0.005
0.027
0.019, ,
0.000
(d) Lead Paste Desulfurization PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced through desulfurization
English Units - Ibs/million Ibs of lead produced through
desulfurization
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Amrnonia (as N)
0
0
0
0
0
0
0
0
0
0
0
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
000,
000
000
000
000
000
000
000
000
000
000
*Regulated Pollutant
2031
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XII-4 (Continued)
PSES FOR THE SECONDARY LEAD SUBCATEGORY
(e) Casting Contact Cooling. PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead cast
English Units - Ibs/million Ibs of lead cast
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.042
0.031
0.004
0.008
0.028
0.006
0.012
0.006
0.031
0.022
0.000
0.019
0.013
0.002
0.003
0.013
0.003
0.008
0.003
0.013
0.009
0.000
(f) Truck Wash PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Anlimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
I
I
(as N)
0
0
0
0
0
0
0
0
0
0
0
.041
.029
.004
.008
.027
.006
.012
.006
.029
.021
.000
0.
0.
0.
0.
0.
0.
0.
0.
0,
0.
0.
018
012
002
003
013
003
008
003
013
009
000
*Regulated Pollutant
2032
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XI1-4 (Continued)
PSES FOR THE SECONDARY LEAD SUBCATEGORY
(g) Facility Washdown PSES-
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
(h) Battery Case Classification PSES.
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead scrap produced
English Units - Ibs/million Ibs of lead scrap produced.
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0
0
0
0
• o
0
0
0
0
0
0
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
.000
0.000
0.000
o.ooo . ,
o.ooo :
0.000
o.ooo V
0.000 .'.. '
o.ooo . ;
0.000
0.000 ,
0.000
*Regulated Pollutant
2033
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XII-4 (Continued)
PSES FOR THE SECONDARY LEAD SUBCATEGORY
(i) Employee Handwash PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.052
0.038
0.005
0.010
0.035
0.008
0.015
0.008
0.038
0.028
0.000
0.023
0.015
0.002
0.004
0.016
0.004
0.010
0.003
0.016
0.011
0.000
(i) Employee Respirator Wash PSES
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.085
0.061
0.009
0.016
0.056
0.012
0.024
0.013
0.062
0.045
0.000
0.038
0.025
0.004
0.007
0.027
0.006
0.016
0.005
0.027
0.018
0.000
*Regulated Pollutant
2034
-------
SECONDARY LEAD SUBCATEGORY,
SECT - XII
TABLE XI1-4 (Continued)
PSES FOR THE SECONDARY LEAD SUBCATEGORY
(j) Laundering Uniforms PSES
Pollutant or
Pollutant Property
^aximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.247
0.178
0.026
0.047
0.164
0.036
0.070
0.037
0.179
0.131
0.000
0.110
0.073
0.010
0.019
0.078
0.017
0.047
0.015
0.078
0.054
0.000
* Regulated Pollutant
2035
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XII-5
PSNS FOR THE SECONDARY LEAD SUBCATEGORY
Battery Cracking PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
mg/kg of lead scrap produced
Ibs/million Ibs of lead scrap produced
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
1.299
0.935
0.135
0.249
0.861
0.188
1.370
0.195
0.942
0.686
0.000
0.579
0.384
0.054
0.101
0.411
0.087
0.249
0.081
0.411
0.283
0.000
(b) Blast, Reverberatory, or Rotary Furnace Wet Air
Pollution Control PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
mg/kg of lead produced from smelting
Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
5.037
3.628
0.522
0.966
3.341
0.731
1.436
0.757
3.654
2.662
0.000
2.245
1.488
0.209
0.392
1.592
0.339
0.966
0.313
1.592
1.096
OoOOO
*Regulated Pollutant
2036
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XII-5. (Continued)
PSNS FOR THE SECONDARY LEAD SUBCATEGORY
(c) Kettle Wet Air Pollution Control PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
mg/kg of lead produced from refining
Ibs/million Ibs of lead produced from refining
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
(d) Lead Paste Desulfurizafcion PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum fo.r
Monthly Average
Metric Units
English Units
mg/kg of lead produced through
desulfurization
Ibs/million Ibs of lead produced through
desulfurization
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0 . 000
0.000
0.000
0.000
0.000
^Regulated Pollutant
2037
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XI1-5 (Continued)
PSNS FOR THE SECONDARY LEAD SUBCATEGORY
(e) Casting Contact Cooling. PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
mg/kg of lead cast
Ibs/million Ibs of lead cast
* Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.042
0.031
0.004
0.008
0.028
0.006
0.012
0.006
0.031
0.022
0.000
0.019
0.013
0.002
0.003
0.013
0.003
0.008
0.003
0.013
0.009
0.000
TABLE XII-5 (Continued)
PSNS EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
(f) Truck Wash PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units - mg/kg of lead produced from smelting
English Units - Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
- Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.041
0.029
0.004
0.008
0.027
0.006
0.012
0.006
0.029
0.021
0.000
0.018
0.012
0.002
0.003
0.013
0.003
0.008
0.003
0.013
0.009
0.000
*Regulated Pollutant
2038
-------
SECONDARY LEAD SUBCATEGORY
SECT - XIX
TABLE XII-5 (Continued)
PSNS FOR THE SECONDARY LEAD SUBCATEGORY
(g) Facility Washdown PSNS.
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
tag/kg of lead produced from smelting
Ibs/million Ibs of lead produced from smelting
0.000
0.000
0.000
0.000
0.000
0.000
0.000
o.'ooo
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
(h) Battery Case Classification PSNS
Pollutant or
Pollutant Property
Maximum, for
Any One Day
Maximum for
Monthly. Average
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
*Regulated Pollutant
mg/kg of lead scrap produced
Ibs/million.Ibs of lead scrap produced
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000 :
0.000
0.000
0.000
0.000
0.000
0.000
0.000
2039
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XI1-5 (Continued)
PSNS FOR THE SECONDARY LEAD SUBCATEGORY
(i) Employee Handwash P'SNS.
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
mg/kg of lead produced from smelting
Ibs/million Ibs of lead produced from smelting
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
0.052
0.038
0.005
0.010
0.035
0.008
0.015
0.008
0.038
0.028
0.000
0.023
0.015
0.002
0.004
0.016
0.004
0.010
0.003
0.016
0.011
0.000
(i) Employee Respirator Wash PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
mg/kg of lead produced from smelting
Ibs/million Ibs of lead produced from
smelting
0.085
0.061
0.009
0.016
0.056
0.012
0.024
0.013
0.062
0.045
0.000
0.038
0.025
0.004
0.007
0.027
0.006
0.016
0.005
0.027
0.018
0.000
*Regulated Pollutant
2040
-------
SECONDARY LEAD SUBCATEGORY
SECT - XII
TABLE XI1-5 (Continued)
PSNS FOR THE SECONDARY LEAD SUBCATEGORY
(J) Laundering Uniforms 'PSNS
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
Metric Units
English Units
*Antimony
*Arsenic
Cadmium
Chromium
Copper
*Lead
Nickel
Silver
Thallium
*Zinc
*Ammonia (as N)
mg/kg of lead produced from smelting
Ibs/million Ibs of lead produced from smelting
0.247
0.178
0.026
0.047
0.164
0.036
0.070
0.037
0.179
0.131
0.000
0.110
0.073
0.010
0.019
0.078
0.017
0.047
0.015
0.078
0.054
0.000
*Regulated Pollutant
2041
-------
SECONDARY LEAD SUBCATEGORY SECT - XII
THIS PAGE INTENTIONALLY LEFT BLANK
2042
-------
SECONDARY LEAD SUBCATEGORY SECT - XIII
SECTION XIII
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
EPA is not promulgating best conventional pollutant control
technology (BCT) for the secondary lead subcategory at this time.
2043
-------
SECONDARY LEAD SUBCATEGORY SECT - XIII
THIS PAGE INTENTIONALLY LEFT BLANK
2044
-------
NONPERROUS METALS MANUFACTURING POINT SOURCE CATEGORY
DEVELOPMENT DOCUMENT SUPPLEMENT
for the
Primary Antimony Subcategory
William K. Reilly
Administrator
Rebecca Hanmer
Acting Assistant Administrator for Water
Martha Prothro, Director
Office of Water Regulations and Standards
Thomas P. O'Farrell, Director
Industrial Technology Division
Ernst P. Hall, P.E., Chief
Metals Industry Branch
and
Technical Project Officer
May 1989
U.S. Environmental Protection Agency
Office of Water
Office of Water Regulations and Standards
Industrial Technology Division
Washington, D. C. 20460
2045
-------
-------
PRIMARY ANTIMONY SUBCATEGORY
Section
I
I-I
III
IV
V
VI
TABLE OP CONTENTS
SUMMARY
CONCLUSIONS
SUBCATEGORY PROFILE -
Description of Primary Antimony Production
Raw Materials
Pyrometallurgical Processes
Leaching
Autoclaving
Electrowinning
Conversion to Antimony Trioxide
Process Wastewater Sources
Other Wastewater Sources
Age, Production, and Process Profile
SUBCATEGORIZATION
Factors Considered in Subcategorization
Factors Considered in Subdividing the Primary
Antimony Subcategory
Other Factors
Production Normalizing Parameters
WATER USE AND WASTEWATER CHARACTERISTICS
Wastewater Flow Rates
Wastewater Characteristics Data
Data Collection Portfolios
Field Sampling Data
Wastewater Characteristics and Flows by
Subdivision
Sodium Antimonate Autoclave Wastewater
Fouled Anolyte
Cathode Antimony Wash Water
SELECTION OF POLLUTANT PARAMETERS
Conventional and Nonconventional Pollutant
Parameters
Conventional Pollutant Parameters Selected
Priority Pollutants
Priority Pollutants Never Detected
Priority Pollutants Selected for Further
Consideration in Limitations and Standards
2061
2062
2062
2062
2062
2063
2063
2063
2064
2064
2071
2071
2071
2072
2072
2073
2074
2075
2075
2075
2075
2076
2076
2077
2083
2083
2083
2084
2084
2084
2047
-------
PRIMARY ANTIMONY SUBCATEGORY
Section
VII
VIII
IX
TABLE OF CONTENTS (Continued)
Page
CONTROL AND TREATMENT TECHNOLOGIES 2091
Current Control and Treatment Practices 2091
Sodium Antimonate Autoclave Wastewater 2091
Fouled Anolyte 2091
Cathode Antimony Wash Water 2092
Control and Treatment Options 2092
Option A 2092
Option C 2092
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS 2093
Treatment Options for Existing Sources 2093
Option A 2093
Option C 2093
Cost Methodology 2093
Nonwater Quality Aspects 2094
Energy Requirements 2094
Solid Waste 2094
Air Pollution 2095
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY 2097
AVAILABLE
Technical Approach to BPT 2097
Industry Cost and Pollutant Removal Estimates 2099
BPT Option Selection 2099
Wastewater Discharge Rates 2100
Sodium Antimonate Autoclave Wastewater 2100
Fouled Anolyte 2101
Cathode Antimony Wash Water 2101
Regulated Pollutant Parameters 2101
Effluent Limitations 2102
BEST AVAILABLE TECHNOLOGY ECONOMICALLY 2107
ACHIEVABLE
Technical Approach to BAT 2107
Option A 2108
Option C 2108
Industry Cost and Pollutant Removal Estimates 2108
Pollutant Removal Estimates 2109
Compliance Costs 2109
BAT Option Selection - Proposal 2110
BAT Option Selection - Promulgation 2110
Wastewater Discharge Rates 2111
Regulated Pollutant Parameters 2111
Effluent Limitations 2112
2048
-------
PRIMARY ANTIMONY SUBCATEGORY
Section
XI
XII
TABLE OF CONTENTS (Continued)
NEW SOURCE PERFORMANCE STANDARDS
Technical Approach to NSPS
NSPS Option Selection - Proposal
NSPS Option Selection - Promulgation
Regulated Pollutant Parameters
New Source Performance Standards
PRETREATMENT STANDARDS
Technical Approach to Pretreatment
Pretreatment Standards for New Sources
PSNS Option Selection - Proposal
PSNS Option Selection - Promulgation
Regulated Pollutant Parameters
Pretreatment Standards for New Sources
2121
2122
2122
2122
2122
2127
2127
2128
2128
2128
2129
2129
XIII
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY 2133
2049
-------
PRIMARY ANTIMONY SUBCATEGORY
LIST OF TABLES
Table Title Page
III-l Initial Operating .Year (Range) Summary of 2065
Plants in the Primary Antimony Subcategory
By Discharge Type
III-2 Production Ranges for the Primary Antimony 2066
Subcategory
III-3 Summary of Primary Antimony Subcategory and 2067
Associated Waste Streams
V-l Water Use and Discharge Rate for Sodium 2078
Antimonate Autoclave Wastewater
V-2 Water Use and Discharge Rate for Fouled 2078
Anolyte
V-3 Water Use and Discharge Rate for Cathode 2078
Antimony Wash Water
V-4 Primary Antimony Sampling Data Fouled Anolyte 2078
Autoclave Discharge Raw Wastewater
V-5 Post-Proposal Self sampling Data 2080
V-6 Presence of Toxic Metal Pollutants, dcp Data 2081
VI-1 Frequency of Occurrence of Priority Pollutants 2086
Primary Antimony Raw Wastewater
VI-2 Priority Pollutants Never Detected 2087
VIII-1 Cost of Compliance for the Primary Antimony 2096
Subcategory Direct Dischargers
IX-1 BPT Wastewater Discharge Rates for the 2103
Primary Antimony Subcategory
IX-2 BPT Mass Limitations for the Primary 2104
Antimony Subcategory
2050
-------
PRIMARY ANTIMONY SUBCATEGORY
LIST OF TABLES (Continued)
Table Title Page
X-^l Pollutant Removal.Estimates for Direct 2113
Dischargers in the Primary Antimony Subcategory
X-2 Cost of Compliance for the Primary Antimony 2114
Subcategory Direct Dischargers
X-3 BAT Wastewater Discharge Rates for the Primary 2115
Antimony Subcategory
X-4 BAT Limitations for the Primary Antimony 2116
Subcategory
XI-1 NSPS Wastewater Discharge Rates for the Primary 2123
Antimony Subcategory
XI-2 NSPS for the Primary Antimony Subcategory 2124
XII-1 PSNS Wastewater Discharge Rates for the Primary 2130
Antimony Subcategory
XII-2 PSNS for the Primary Antimony Subcategory 2131
2051
-------
PRIMARY ANTIMONY SUBCATEGORY
LIST OF FIGURES
Figure Title Page
III-l Primary Antimony Production Process 2068
(Pyrometallurgical)
III-2 Primary Antimony Production Process 2069
(Hydrometallurgical)
III-3 Geographic Locations of the Primary Antimony 2072
Subcategory Plants
IX-1 BPT Treatment Scheme for the Primary Antimony 2106
Subcategory
X-l BAT Treatment Scheme for Option A 2118
X-2 BAT Treatment Scheme for Option C 2119
2052
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - I
SECTION I
SUMMARY
This document and the administrative record provide the technical
basis for promulgating effluent limitations based on best
practicable technology (BPT) and best available technology (BAT)
for existing direct dischargers, pretreatment standards for new
indirect dischargers (PSNS), and standards of performance for new
source direct dischargers (NSPS) for plants in the primary
antimony subcategory.
The primary antimony subcategory is comprised of eight plants. Of
the eight plants, one discharges directly to a river, four plants
achieve zero discharge of process wastewater, and three plants
generate no process wastewater.
EPA first studied the primary antimony subcategory to determine
whether differences in raw materials, final. products,
manufacturing processes, equipment, age and size of plants, or
water usage, required the development of separate effluent
limitations and standards for different segments of the
subcategory. This involved a detailed analysis of wastewater
discharge and treated effluent characteristics, including ,(1) the
sources and volume of water used, the processes used, and .the
sources of pollutants and wastewaters in the plant; and (2) the
constituents of wastewaters, including priority pollutants. As a
result, three subdivisions, or building blocks, have been
identified for this subcategory that warrant separate effluent
limitations. These include:
o Sodium antimonate autoclave wastewater,
o Fouled anolyte, and
o Cathode antimony wash water.
Several distinct control and treatment technologies (both in-
plant and end-of-pipe) applicable to the primary antimony
subcategory were identified. The Agency analyzed both historical
and newly generated data on the performance of these
technologies, including their nonwater quality environmental
impacts and air quality, solid waste generation, and energy
requirements. EPA also studied various flow reduction techniques
reported in the data collection portfolios (dcp) and plant
visits.
Engineering costs were prepared for each of the control and
treatment options considered for the subcategory. These costs
were then used by the Agency to estimate the impact of
implementing the various options on the subcategory. For each
control and treatment option that the Agency found to be most
effective and technically feasible in controlling the discharge
of pollutants, the number of potential closures, number of
2053
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - I
employees affected, and impact on price were estimated. These
results are reported in a separate document entitled "The
Economic Impact Analysis of Effluent Limitations and Standards
for the Nonferrous Metals Manufacturing Industry."
After examining the various treatment technologies/ the Agency
has identified BPT as the average of the best existing
technology. Metals removal based on chemical precipitation and
sedimentation technology, with sulfide precipitation preliminary
pretreatment, is the basis for the BPT limitations. To meet the
BPT effluent limitations based on this technology, the primary
antimony subcategory is expected to incur an estimated capital
cost of $146,350 and an annual cost of $554,180.
For BAT, filtration is added as an effluent polishing step to the
model BPT end-of-pipe technology To meet the BAT effluent
limitations based on this technology, the primary antimony
subcategory is estimated to incur a capital cost of $208,300 and
an annual cost of $560,400.
NSPS is equivalent to BAT. In selecting NSPS, EPA recognized
that new plants have the opportunity to implement the best and
most efficient manufacturing processes and treatment technology.
As such, the technology basis of BAT has been determined as the
best demonstrated technology.
PSES is not being promulgated for this subcategory because there
are no existing indirect dischargers in the primary antimony
subcategory. For PSNS, the Agency selected end-of-pipe treatment
technology equivalent to BAT.
The best conventional technology (BCT) replaces BAT for the
control of conventional pollutants. BCT is not being promulgated
at this time because the methodology for BCT has not yet been
finalized.
The mass limitations and standards for BPT, BAT, NSPS, and PSNS
are presented in Section II.
2054
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - II
SECTION II
CONCLUSIONS
EPA has divided the primary antimony subcategory into three
subdivisions or building blocks for the purpose of effluent
limitations and standards. These subdivisions are:
(a) Sodium antimonate autoclave wastewater,
(b) Fouled anolyte, and
(c) Cathode antimony wash water.
BPT is promulgated based on the performance achievable by the
application of chemical precipitation and sedimentation
technology, and sulfide precipitation preliminary treatment.
The following BPT effluent limitations are promulgated:
BPT LIMITATIONS FOR THE PRIMARY ANTIMONY SUBCATEGORY
(a) Sodium Antimonate Autoclave Wastewater
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony contained in
sodium antimonate product
Antimony
Arsenic
Mercury
Total suspended
solids
PH
44.840
32.650
3.906
640.600
20.000
14.530
1.562
304.700
Within the range of 7.5 to 10.0
at all times
2055
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - II
(b) Fouled Anolyte
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
Total suspended
solids
pH
44.840
32.650
3.906
640.600
20.000
14.530
1.562
304.700
Within the range of 7.5 to 10.0
at all times
(c) Cathode Antimony Wash Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
Total suspended
solids
pH
89.680
65.310
7.812
1,281.000
40.000
29.060
3.125
609.300
Within the range of 7.5 to 10.0
at all times
BAT is promulgated based on the performance achievable by the
application of chemical precipitation, sedimentation, and
multimedia filtration technology, and sulfide precipitation
pretreatment. The following BAT effluent limitations are
promulgated:
2056
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - II
BAT LIMITATIONS FOR THE PRIMARY ANTIMONY SUBCATEGORY
(a) Sodium Antimonate Autoclave Wastewater
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony contained in
sodium antimonate product
Antimony
Arsenic
Mercury
30.150
21.720
2.344
13.440
9.687
0.937
(b) Fouled Anolyte
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
(lb/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
30.150
21.720
2.344
13.440
9.687
0.937
(c) Cathode Antimony Wash Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
rag/kg (lb/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
60.310
43.430
4.687
26.870
19.370
1.875
NSPS are promulgated based on the performance achievable by
the application of chemical precipitation, sedimentation, and
multimedia filtration technology, and sulfide precipitation
2057
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - II
preliminary pretreatment. The following effluent standards
are promulgated for new sources:
NSPS FOR THE PRIMARY ANTIMONY SUBCATEGORY
(a) Sodium Antimonate Autoclave Wastewater
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony contained in
sodium antimonate product
Antimony
Arsenic
Mercury
Total suspended
solids
pH
30.150
21.720
2.344
234.400
13.440
9.687
0.937
187.500
Within the range of 7.5 to 10.0
at all times
(b) Fouled Anolyte
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
Total suspended
• solids
PH
30.150
21.720
2.344
234.400
13.440
9.687
0.937
187.500
Within the range of 7.5 to 10.0
at all times
2058
-------
PRIMARY ANTIMONY SUBGATEGORY
SECT - II
(c) Cathode Antimony Wash Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
Total suspended
solids
pH
60.310
43.430
4.687
468.700
26.870
19.370
1.875
375.000
Within the range of 7.5 to 10.0
at all times
PSES are not being promulgated for the primary antimony
subcategory at this time because there are no existing indirect
dischargers in the primary antimony subcategory.
PSNS are promulgated based on the performance achievable by
the application of chemical precipitation, sedimentation,, and
multimedia filtration technology, with sulfide precipitation
preliminary treatment. The following pretreatment standards
are promulgated for new sources:
PSNS FOR THE PRIMARY ANTIMONY SUBCATEGORY
(a) Sodium Antimonate Autoclave Wastewater
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony contained in
sodium antimonate product
Antimony
Arsenic
Mercury
30.150
21.720
2.344
13.440
9.687
0.937
2059
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - II
(b) ' Fouled Anolyte
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
mg/kg (Ib/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
30.150
21.720
2.344
13.440
9.687
0.937
(c) Cathode Antimony Wash Water
Pollutant or
Pollutant Property
Maximum for
Any One Day
Maximum for
Monthly Average
(Ib/million Ibs) of antimony metal produced
by electrowinning
Antimony
Arsenic
Mercury
60.310
43.430
4.687
26.870
19.370
1.875
EPA is not promulgating BCT at this time for the primary
antimony subcategory.
2 -0
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - III
SECTION III
SUBCATEGORY PROFILE
This section of the primary antimony supplement describes the raw
materials and processes used in producing primary antimony and
presents a profile of the primary antimony plants identified in
this study. For a discussion of the purpose, authority, and
methodology for this study and for a general description of the
nonferrous metals manufacturing category, refer to Section III of
the General Development Document.
Although there are about 112 minerals of antimony, the principal
ore mineral is stibnite, the sulfide of antimony. Antimony also
occurs in other metal ores, including gold-quartz deposits and
copper-lead-zinc deposits. The major use of antimony metal is as
an alloying constituent which increases the strength and inhibits
the corrosion of lead and other metals.
Industrial applications of antimony are primarily as an alloying
agent and include use as a hardener in lead storage batteries,
tank linings, and chemical pumps and pipes. Of the many antimony
compounds available commercially, the most important is antimony
trioxide (Sb2C>3). Antimony trioxide is used for flameproof ing
plastics, paints, vinyls, fabrics, and chemicals. It is also
used in ceramics to impart hardness and acid resistance to enamel
coverings.
DESCRIPTION OF PRIMARY ANTIMONY PRODUCTION
There are two general types of methods of manufacturing antimony
and its compounds: hydrometallurgical methods and
pyrometallurgical methods. Antimony metal is produced from
antimony minerals or ore by smelting. Antimony trioxide is
produced from antimony metal or ore concentrates by roasting or
burning. These pyrometallurgical processes, practiced at five, of
the eight antimony plants identified in this subcategory,
generate no process wastewater.
Hydrometallurgical processing, practiced at the remaining three
antimony plants, can be used to produce antimony metal, antimony
trioxide, and sodium antimonate (NaSbO^). Hydrometallurgical
processing can be divided into four distinct stages: leaching,
autoclaving, electrowinning, and conversion to antimony trioxide.
The actual processes used at each plant vary with the type .and
purity of the raw materials used as well as with the type of
antimony product manufactured. The primary antimony production
processes, both pyrometallurgical and hydrometallurgical, are
presented in Figures III-l and III-2 (pages 2068 and 2069) and
described below.
2061
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PRIMARY ANTIMONY SUBCATEGORY SECT - III
RAW MATERIALS
The principal source of antimony is the sulfide mineral stibnite.
Stibnite, the sulfide of antimony together with its oxidized
equivalents, is mined •in several countries including Mexico,
China, Peru, Yugoslavia, and Algeria. Virtually all domestic
production of primary antimony metal is a by-product of the
refining of base metal and silver ores. Antimony trioxide is
produced from imported ores, antimony metal, and crude antimony
oxide from South Africa.
PYROMETALLURGICAL PROCESSES
Antimony metal can be produced by smelting antimony minerals or
ore with appropriate fluxes. Metal of 99 percent purity can be
manufactured by this process with no generation of wastewater.
Antimony trioxide can be produced by burning or roasting ore
concentrates or antimony metal. Burning converts the sulfide ore
to volatile antimony trioxide. Evaporation separates the slag
from the trioxide which two plants reported is collected in a
baghouse and packaged for sale. One plant practices wet air
pollution control to recover antimony from the gases leaving the
baghouse. Because the scrubber liquor from this product recovery
step is completely recycled in order to recover antimony, the
final emissions scrubber is not considered to be a wastewater
source in this subcategory. No plants in this subcategory
reported sulfur dioxide (S02) emissions from the antimony
trioxide production process.
LEACHING
A variety of antimony compounds can be produced from ore
concentrates by hydrometallurgical processes. Leaching of the
concentrate is conducted batchwise in a heated, pressurized vat.
Some concentrates are blended with coke, sodium sulfate, and
sodium carbonate and melted in a furnace before leaching with a
sodium hydroxide solution. Other concentrates are combined with
sodium sulfide ' and sulfur and leached with a sodium hydroxide
solution without prior melting. In either case, the leaching
process produces soluble Na3SbS3 and Na3AsS3.
Solids are separated from the leaching solution by thickening and
filtration. The residue, which contains compounds such as
pyrite, silica, stibnite, soluble arsenic, and NaAsS3, is either
disposed of or further processed to recover other metals.
Antimony is recovered from the leaching solution either by
autoclaving or by electrowinning, depending on the product
desired.
AUTOCLAVING
Sodi
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - III
of oxygen. The elevated temperature and pressure drive the
oxidation reaction resulting in the formation of insoluble sodium
antimonate which is separated from the remaining liquid. After
drying, the product is packaged and sold. The autoclave
discharge is the only wastewater generated by this process.
ELECTROWINNING
Antimony metal is recovered from the pregnant solution from the
leaching process by electrowinning. Antimony is deposited on the
cathode as a brittle, non-adherent layer which is periodically
stripped and washed. It is then either sold or further processed
to antimony trioxide. The wash water is discharged.
Because the products of oxidation at the anode interfere with the
deposition of antimony at the cathode, two different and
physically separated solutions are used. The catholyte, which in
this case is the pregnant solution from the leaching process,
surrounds the cathode and the anolyte surrounds the anode.
Intermingling of the two solutions is minimized by a canvas
barrier. Small pores in the canvas allow the solutions to contact
maintaining the integrity of the electrical circuit.
After the antimony has been removed, the barren catholyte is
recycled to the process using one of two methods. At the plant
which reports melting of the ore before leaching, spent
electrolyte is spray dried. The dried salts are captured in a
baghouse and recycled to the blending step. At the two plants
which leach concentrates without first melting them, barren
catholyte solution is recycled directly to the leaching process.
One of those two plants removes the fouled anolyte and treats it
by autoclaving to recover sodium antimonate for recycle to the
leaching process. The fouled anolyte discharge is the only
wastewater generated by the electrowinning process. The
subsequent autoclaving of this stream is considered to be a
preliminary wastewater treatment process and is distinguished
from autoclaving to produce sodium antimonate as a final product.
CONVERSION TO ANTIMONY TRIOXIDE
Antimony metal produced by electrowinning or purchased antimony
metal can be converted to antimony trioxide in a fuming furnace.
The product of this process is captured in a baghouse and sold.
There is no generation of wastewater during this conversion
process.
PROCESS WASTEWATER SOURCES
Although a variety of processes are involved in primary antimony
production, the process wastewater sources can be subdivided as
follows:
1. Sodium antimonate autoclave wastewater,
2. Fouled anolyte, and
3. Cathode antimony wash water.
2063
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - III
The cathode antimony wash water waste stream was not given a
discharge allowance at proposal because the one plant in the
subcategory which reported this waste stream did not supply
information in its dcp to quantify the wastewater discharge from
this operation, leading EPA to believe that it was insignificant.
Since proposal, the Agency has received information which allowed
EPA to calculate water use and discharge rates for this waste
stream. Therefore, the Agency has added this new building block
to the subcategory.
OTHER WASTEWATER SOURCES
There are other waste streams associated with the primary
antimony subcategory. These waste streams include stormwater
runoff, and maintenance and cleanup water. These waste streams
are not considered as a part of this rulemaking. EPA believes
that the flows and pollutant loadings associated with these waste
streams are insignificant relative to the waste streams selected,
and are best handled by the appropriate permit authority on a
case-by-case basis under authority of Section 402 of the Clean
Water Act.
AGE, PRODUCTION, AND PROCESS PROFILE
Figure III-3 (page 2070) shows the location of the eight primary
antimony plants operating in the United States. The plants are
geographically scattered, located in seven states across the
country.
Table III-l (page 2065) shows the relative age and discharge
status of the antimony plants. The oldest plant was built in the
1880's, and three others are more than 30 years old. Two new
plants have been built within the last 10 years. From Table III-
2 (page 2066), it can be seen that six of the seven plants that
provided production information produced less than 300 kkg/yr of
antimony and antimony compounds. The one remaining plant
produced more than 2,000 kkg/yr of antimony in the form of
antimony trioxide.
Table III-3 (page 2067) provides a summary of the number of
plants using specific manufacturing processes and the number ^of
plants generating wastewater for the streams associated with
those processes.
2064
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - III
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PRIMARY ANTIMONY SUBCATEGORY
SECT - III
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2066
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - III
TABLE II1-3
SUMMARY OF PRIMARY ANTIMONY SUBCATEGORY PROCESSES
AND ASSOCIATED WASTE STREAMS
Process or Waste Stream
Number of Plants
With Process or
Waste Stream
Number of Plants
Reporting Generation
of Wastewater
Pyrometallurgical Processes
Leaching
Autoclaving
Sodium antimonate autoclave
wastewater
Electrowinning
Fouled anolyte
Cathode antimony wash water
Conversion to antimony trioxide
5
3
2
2
3
2
1
1
* - Through reuse or evaporative practices, a plant may generate
a wastewater from a particular process but not discharge it.
206"
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - III
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2068
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PRIMARY ANTIMONY SUBCATEGORY
SECT - III
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PRIMARY ANTIMONY SUBCATEGORY SECT - IV
SECTION IV
SUBCATEGORIZATION
^ ' . \
This section summarizes the factors considered" during the
designation of the primary antimony subcategory and its related
subdivisions. Production normalizing parameters for each
building block are also discussed.
FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY ANTIMONY
SUBCATEGORY
The factors listed for general subcategorization were each
evaluated when considering subdivision of the primary antimony
subcategory. In the discussion that follows, the factors will be
described as they pertain to this particular subcategory.
The rationale for considering segmentation of the primary
antimony subcategory is based primarily on differences in the
production processes and raw materials used. Within this
subcategory, a number of different operations . are performed,
which may or may not have a water use or discharge, and which may
require the establishment of separate effluent limitations.
While primary antimony is still considered a single subcategory,
a more thorough examination of the production processes has
illustrated the need for limitations and standards based on a
specific set of waste streams. Limitations will be based on
specific flow allowances for the following building blocks.
1. Sodium antimonate autoclave wastewater,
2. Fouled anolyte, and
3. Cathode antimony wash water.
These building blocks represent the only reported sources of
wastewater in this subcategory and follow directly from
differences in the production states of primary antimony.
The plant which manufactures sodium antimonate autoclaves the
antimony bearing solution from the leaching process. The first
building block is associated with the wastewater discharged from
this autoclaving operation.
When fouled anolyte is removed from the electrowinning operation
and autoclaved for sodium antimonate recovery, a wastewater
stream is produced at one plant. Other plants recycle the
electrolyte with no reported wastewater discharge. Thus, the
second building block accounts for operational differences in the
electrowinning state of antimony production.
The third building block results from washing of antimony product
as reported by one plant in the subcategory. Subsequent to
electrowinning, antimony metal is stripped from the host cathode
2071
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IV
and washed with water prior to sale. A once-through flow is
employed to maximize cleansing of the final product.
OTHER FACTORS
The other factors considered in this evaluation were shown to be
inappropriate bases for further segmentation. Air pollution
control methods, treatment costs, and total energy requirements
are functions of the selected subcategorization factors, namely
metal product, raw materials, and production processes,,
Therefore, they are not independent factors and do not affect the
subcategorization which has been developed. As discussed in
Section IV of Vol. I, certain other factors, such as plant age,
plant size, and the number of employees, were also evaluated and
determined to be inappropriate for use as bases for subdivision
of nonferrous metals plants.
PRODUCTION NORMALIZING PARAMETERS
As discussed previously, the effluent limitations and standards
developed in this document establish mass limitations for the
discharge of specific pollutant parameters. To allow these
regulations to be applied to plants with various production
capacities, the mass of pollutant discharged must be related to a
unit of production. This factor is known as the production
normalizing parameter (PNP).
In general, for each production process which has a wastewater
associated with it, the mass of antimony contained in the product
is used as the PNP. Thus, the PNPs for the three building blocks
are as follows:
Building Block
1. Sodium antimonate autoclave
wastewater
2. Fouled anolyte
3. Cathode antimony wash water
PNP
antimony contained in sodium
antimonate product
antimony metal produced by
electrowinning
antimony metal produced by
electrowinning
2072
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
SECTION V
WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of the wastewaters
associated with the primary antimony subcategory. Water use arid
discharge rates are explained and then summarized in Tables V-l
through V-4 {pages 2078 - 2079). Data used to characterize the
wastewaters are presented. Finally, the specific source, water
use and discharge flows, and wastewater characteristics for each
separate wastewater source are discussed.
In the development of effluent limitations and standards for this
subcategory, two principal data sources were used: data
collection portfolios (dcp). and field sampling results. Data
collection portfolios contain information regarding wastewater
flows and production levels.
In order to conduct an analysis of the primary antimony
subcategory waste streams and quantify the pollutant discharge
from plants in this subcategory, the levels of priority
pollutants in the wastewaters must be known. Although data were
riot obtained by sampling a primary antimony plant, one plant
submitted sampling data of their wastewater in the dcp. The data
consist of analyses for two classes of pollutants: priority
metal pollutants, and conventional pollutants. Samples were not
analyzed for priority organic pollutants because there was no
reason to believe that organic pollutants would be present in
wastewaters generated by the primary antimony subcategory.
Because the analytical standard for TCDD was judged to be too
hazardous to be made generally available, samples were never
analyzed for this pollutant. Samples were also not analyzed for
asbestos or cyanide. There is no reason to expect that TCDD,
asbestos, or cyanide would be present in primary antimony
wastewater.
Additional wastewater characteristics and flow and production
data were received through industry comments between proposal and
promulgation. This aided EPA in recalculating regulatory flows,
and in promulgating discharge allowances which had not previously
been proposed for cathode antimony wash water. These data were
submitted as confidential and are maintained in that status.
After proposal, EPA gathered additional wastewater sampling data
for the sodium antimonate autoclave wastewater and the cathode
antimony wash water building blocks. These data were acquired
through a self-sampling program conducted by the industry at the
specific request of EPA. These data are displayed in Table •V-5
(page 2080). These data support the assumptions which EPA had
made concerning the presence and concentrations of pollutants in
those subdivisions where we did not have analytical data for
specific pollutants. For this reason, the selection of pollutant
parameters for limitation in this subcategory (Section VI) has
2073
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
not been revised based on this new data.
As described in Section IV of this supplement, the primary
antimony subcategory has been divided into three building blocks,
so that the promulgated regulation contains mass discharge
limitations and standards for three processes discharging process
wastewater. Differences in the wastewater characteristics
associated with these processes are to be expected. For this
reason, wastewater streams corresponding to each segment are
addressed separately in the discussions that follow. These
wastewater sources are:
1. Sodium antimonate autoclave wastewater,
2. Fouled anolyte, and
3. Cathode antimony wash water.
WASTEWATER FLOW RATES
Data supplied by dcp responses were evaluated, and two flow-to-
production ratios, water use and wastewater discharge flow, were
calculated for each stream. The two ratios are differentiated by
the flow value used in calculation. Water use is defined as the
volume of water or other fluid required for a given process per
mass of antimony produced and is therefore based on the sum of
recycle and makeup flows to a given process. Wastewater flow
discharged after pretreatment or recycle (if these are present)
is used in calculating the production normalized flow — the
volume of wastewater discharged from a given process to further
treatment, disposal, or discharge per mass of antimony produced.
Differences between the water use and wastewater flows associated
with a given stream result from recycle, evaporation, and
carryover on the product. The production values used in
calculation correspond to the production normalizing parameter,
PNP, assigned to each stream, as outlined in Section IV. As an
example, sodium antimonate autoclave wastewater is related to the
production of antimony contained in the sodium antimonate
product. As such, the discharge rate is expressed in liters of
autoclave wastewater per metric ton of antimony contained in the
sodium antimonate product (gallons of wastewater per ton of
antimony contained in the sodium antimonate product). The
production normalized discharge flows were compiled by stream
type. These production normalized water use and discharge flows
are presented in Tables V-l through V-3 (page 2078). Where
appropriate, an attempt was made to identify factors that could
account for variations in water use and discharge rates. • These
variations are discussed later in this section. A similar
analysis of factors affecting the wastewater flows is presented
in Sections X, XI, and XII where representative BAT, NSPS, and
pretreatment flows are selected for use in calculating the
effluent limitations.
The water use and discharge rates shown do not include nonprocess
wastewater, such as rainfall runoff and noncontact cooling water.
2074
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
WASTEWATER CHARACTERISTICS DATA
Data used to characterize the various wastewaters associated with
primary antimony production come from various sources: data
collection portfolios, -analytical data from field sampling,
comments on the proposal and self-sampling information.
DATA COLLECTION PORTFOLIOS
In the data collection portfolios, the antimony plants that
generate wastewater were asked to specify the presence of
priority pollutants in their wastewater. Of the five primary
antimony plants that generate wastewater, three responded to this
portion of the questionnaire. No plant responding to the
questionnaire reported the presence of any priority organic
pollutants. The responses for the priority metals and cyanide
are summarized in Table V-6 (page 2081).
FIELD SAMPLING DATA
Sampling data for the primary antimony subcategory were provided
by one company in its dcp and by one company through a self-
sampling effort.
Raw wastewater data are summarized in Table V-4 (page 2079).
Analytical results for eight samples of the fouled anolyte
autoclave discharge were provided in one dcp. The data included
results for several priority metals and two conventional
pollutant parameters. No priority organic, cyanide or source
water data were provided.
Table V-4 includes some samples measured at concentrations
considered not quantifiable. The detection limits shown on the
data tables are not the same in all cases as the published
detection limits for these pollutants by the same analytical
methods. The detection limits used were reported with the
analytical data and hence are the appropriate limits to apply to
the data. Detection limit variation can occur as a result of a
number of laboratory-specific, equipment-specific, and daily
operator-specific factors. These factors can include day-to-day
differences in machine calibration, variation in stock solutions,
and variation in operators.
Second, the analysis of data includes some samples measured at
concentrations considered not quantifiable. If a pollutant is
reported as not detected, a value of zero is used in calculating
the average. Priority metal values reported as less than a
certain value are considered as not quantifiable and a value of
zero is used in the calculation of the average.
WASTEWATER CHARACTERISTICS AND FLOWS
Since primary antimony production involves three principal
sources of wastewater and each has potentially different
2075
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
characteristics and flows, the wastewater characteristics and
discharge rates corresponding to each subdivision will be
described separately. A brief description of why the associated
production processes generate a wastewater and explanations for
variations of water use within each subdivision will also be
discussed.
SODIUM ANTIMONATE AUTOCLAVE WASTEWATER
Sodium antimonate (NaSb03) is produced by autoclaving the
antimony-bearing solution from the leaching process with oxygen.
The autoclave wastewater is discharged. The production
normalized water use and discharge rates for sodium antimonate
autoclave wastewater are given in Table V-l (page 2078) in
liters per metric ton of antimony contained in sodium antimonate
product.
The one company which reports this wastewater stream did not
provide flow rate information. It is assumed that the amount of
wastewater generated by autoclaving the leaching solution is the
same as the amount of wastewater generated by electrowinning a
solution containing the same amount of antimony. Therefore, the
production normalized discharge flow for sodium antimonate
autoclave discharge water is assumed to be equal to that for the
fouled anolyte using the antimony content of the product as the
production normalizing parameter.
No sampling data are available for this stream, but it is
expected to be similar in composition to the fouled anolyte
autoclave discharge for which data are present in Table V-4. The
fouled anolyte wastewater is essentially the same as the sodium
antimonate autoclave wastewater except that the influent to the
fouled anolyte autoclave has had much of the antimony removed.
The sodium antimonate autoclave wastewater is therefore expected
to contain treatable concentrations of suspended solids and toxic
metals, including antimony, arsenic, and mercury.
FOULED ANOLYTE
Antimony metal is produced by electrowinning the pregnant
solution from the leaching process. Barren electrowinning
solution is recycled to the process by various means at three
plants. One of those plants removes a portion of the barren
'electrolyte, referred to as the fouled anolyte, and treats it by
autoclaving with oxygen to recover sodium antimonate and
discharges the remaining stream. The production normalized water
use and discharge rates for fouled anolyte are given in Table V-2
(page 2078) in liters per metric ton of antimony metal produced
by electrowinning.
At proposal, no sampling data were available for this stream, but
it was expected to be similar in composition to the fouled
anolyte autoclave discharge for which data are presented in Table
V-4. Autoclaving is used as a treatment process to remove
antimony as sodium antimonate from the fouled anolyte, but it is
2076
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
not expected to greatly affect other components of the
wastewater. The fouled anolyte stream was therefore expected to
be Sacterized by treatable concentrations of suspended solids
and toxic metals, including antimony, arsenic, and mercury.
Followinq proposal, sampling data were acquired for this
sSd?vislonP through a self-sampling effort. These data are
presented in Table V-5 (page 2080) . These data show <-«atable
concentrations of antimony, arsenic and mercury, thus
corroborating the data used at proposal.
CATHODE ANTIMONY WASH WATER
Antimony metal produced by electrowinning collection a host
cathode The cathode is periodically stripped of metal and the
pure alimony product is wished with water. This^ashing ^J the
final cleansing operation in the antimony production process at
the" one plant ?epo?ting this waste stream. Production normalized
£ate? use and discharge rates for cathode antimony wash water are
gfven in Table V-3 (page 2078) in liters per metric ton of
antimony metal produced by electrowinning.
Field sampling data for cathode antimony wash water were obtained
from industry but are considered confidential.. These data
characterize the waste stream as containing treatable
concentrations of toxic metals such as antimony, arsenic, lead,
and Sopper. Data for conventional and nonconventional pollutants
were not provided.
ss:
and. a
teatable concentrations of antimony
quantifiable concentration of copper.
and arsenic
2077
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - V
TABLE V-l
WATER USE AND DISCHARGE RATE FOR
SODIUM ANTIMONATE AUTOCLAVE WASTEWATER
(1/kkg of antimony contained in sodium antimonate product)
Plant Code
1157
Percent' Production Normalized Production Normalized
Recycle Water Use Discharge Flow
NR
NR
15624*
NR - Data not reported in dcp
* - Assumed value (see text)
TABLE V-2
WATER USE AND DISCHARGE RATE FOR
FOULED ANOLYTE
(1/kkg of antimony metal produced by electrowinning)
Plant Code
1159
Percent
Recycle
0
Production Normalized Production Normalized
Water Use Discharge Flow
15624
15624
TABLE V-3
WATER USE AND DISCHARGE RATE FOR
FOULED ANOLYTE
(1/kkg of antimony metal produced by electrowinning)
Plant Code
1159
Percent
Recycle
0
Production Normalized Production Normalized
Water Use Discharge Flow
31248
31248
2078
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - V
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2079
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
TABLE V-5
PRIMARY ANTIMONY SAMPLING DATA
RAW WASTEWATER — SELF SAMPLING (mg/1)
POLLUTANT
Sample Number
Toxic Pollutants
114. Antimony
115. Arsenic
117. Beryllium
118. Cadmium
119. Chromium
120. Copper
122. Lead
123. Mercury
124. Nickel
128. Zinc
FOULED
ANOLYTE
88148
217.0
2430.0
<0.5
0.07
<5.0
<0.1
<2.0
22.3
<0.2
<0.2
CATHODE ANTIMONY
WASH WATER
88149
31.0
4.887
<0.05
<0.05
<0.10
0.33
<0.20
<0.0002
<0.20
<0.05
Nonconventional Pollutants
Aluminum
Cobalt
Iron
Manganese
Molybdenum
Tin
Titanium
Vanadium
<5.0
<5.0
5.8
<0.5
<5.0
<50.0
(20.0
25.0
<0.50
<5.0
4.13
<0.05
<0.50
<5.0
<0.20
2080
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
TABLE V-6
PRESENCE OF TOXIC METAL POLLUTANTS - DCP DATA
Pollutant
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Cyanide
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc
Known Present
2
2
0
1
0
0
0
1
1
0
1
0
1
1
Believed Present
(Based on Raw Materials and
Process Chemicals Used)
0
1
0
0
0
0
0
0
0
0
0
0
0
0
208 .
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - V
THIS PAGE INTENTIONALLY LEFT BLANK
2082
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VI
SECTION VI
SELECTION OF POLLUTANT PARAMETERS
This section examines chemical analysis data presented in Section
V and discusses the selection or exclusion of pollutants for
potential limitation. The basis for the regulation of toxic and
other pollutants, along with a discussion of each pollutant
selected for potential limitation, is discussed in Section VI of
Vol. 1. That discussion provides information concerning the
nature of the pollutant (i.e., whether it is a naturally
occurring substance, processed metal, or a manufactured
compound); general physical properties and the form of the
pollutant; toxic effects of the pollutant in humans and other
animals: and behavior of the pollutant in POTW at the
concentrations expected in industrial discharges.
The discussion that follows presents and briefly discusses the
selection of conventional pollutants and pollutant parameters for
effluent limitations. Also described is the analysis that was
performed to exclude or select for further consideration priority
pollutants for limitations and standards. Pollutants will be
considered for limitation if they are present in concentrations
treatable by the technologies considered in this analysis. The
treatable concentrations used for the priority metals were the
long-term performance values achievable by chemical
precipitation, sedimentation, and filtration. The treatable
concentrations used for the priority organics were the long-term
performance values achievable by carbon adsorption.
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS
This study examined samples from the primary antimony subcategory
for two conventional pollutant parameters (total suspended solids
and pH).
CONVENTIONAL POLLUTANT PARAMETERS SELECTED.
The conventional pollutants or pollutant parameters selected for
limitation in this subcategory are:
total suspended solids (TSS)
PH
Nonconventional pollutant parameters were not selected for
limitation in this subcategory.
TSS concentrations ranging from 348 to 1,256 mg/1 were observed
in the five raw waste samples analyzed for TSS in this study. All
five concentrations were well above the 2.6 mg/1 treatment
effectiveness concentration. Most of the specific methods used
to remove toxic metals from a wastewater do so by converting them
to precipitates. Meeting a limit on total suspended solids
2083
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VI
ensures that removal of these precipitated toxic metals has been
effective. For this reason, total suspended solids is selected
for limitation in this subcategory.
The eight pH values observed during this study ranged from 12.85
to 13.40, all outside the 7.5 to 10.0 range considered desirable
for discharge to receiving waters. Effective removal of toxic
metals by chemical precipitation requires careful control of pH.
Therefore, pH is selected for limitation in this subeategory.
PRIORITY POLLUTANTS
The frequency of occurrence of the priority pollutants in the raw
wastewater samples is presented in Table VI-1 (page 2086). Table
VI-1 is based on the raw wastewater data provided for the fouled
anolyte autoclave discharge (see Section V). These data provide
the basis for the categorization of specific pollutants, as
discussed below.
PRIORITY POLLUTANTS NEVER DETECTED
The priority pollutants listed in Table VI-2 (page 2087) were not
detected in any raw wastewater samples from this subcategory.
Therefore, they are not selected for consideration in
establishing limitations.
PRIORITY POLLUTANTS SELECTED FOR FURTHER CONSIDERATION
ESTABLISHING LIMITATIONS AND STANDARDS
IN
The priority pollutants listed below are selected for further
consideration in establishing limitations and standards for this
subcategory. The priority pollutants selected for ' further
consideration for limitation are each discussed following the
list.
114.
115.
118.
120.
122.
123.
128.
antimony
arsenic
cadmium
copper
lead
mercury
zinc
Antimony was found in eight samples at concentrations ranging
from 3.7 to 120 mg/1. All eight concentrations were above the
0.47 mg/1 concentration considered achievable by identified
treatment technology. Therefore, antimony is selected for
further consideration for limitation in this subcategory.
Arsenic was detected in eight samples at concentrations ranging
from 260 to 3,700 mg/1. All eight concentrations were above the
0.34 mg/1 treatability concentration. Therefore, arsenic is
selected for further consideration for limitation.
2084
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VI
Cadmium was detected in quantifiable concentrations in two of
eight samples (0.21 and 0.30 mg/1). Both of these samples were
above the 0.049 mg/1 treatability concentration. Therefore,
cadmium is selected for further consideration for limitation.
Copper was detected in eight samples at concentrations ranging
from 0.20 to 0.8 mg/1. Three of those samples were above the
0.39 mg/1 treatability concentration. Therefore, copper is
selected for further consideration for limitation.
Lead was found in one of eight samples above quantification, at a
concentration of 3.05 mg/1. That sample was above the 0.08 mg/1
treatability concentration. Furthermore, antimony is often
recovered from lead-copper-zinc ores. Therefore, lead is
selected for further consideration for limitation.
Mercury was detected in seven samples at concentrations ranging
from 0.015 to 12.6 mg/1. Six of those samples were above the
0.036 mg/1 treatability concentration. Therefore, mercury is
selected for further consideration for limitation.
Zinc was found in two of eight samples at quantifiable
concentrations (0.10 and 0.27 mg/1). One of those samples was
above the 0.23 mg/1 concentration considered achievable by
identified treatment technology. Furthermore, antimony is often
recovered from copper-lead-zinc ores. Therefore, zinc is
selected for further consideration for limitation in this
subcategory.
2085
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - VI
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2086
-------
PRIMARY ANTIMONY SUBCATEGORY gECT - VI
TABLE VI-2
PRIORITY POLLUTANTS NEVER DETECTED
1. acenaphthene*'
2. acrolein*
3. acrylonitrile*
4. benzene*
5. benzidine*
6. carbon tetrachloride (tetrachloromethane)*
7. chlorobenzene*
8. 1,3,4-trichlorobenzene*
9. hexachlorobenzene*
10. 1,2-dichloroethane*
11. 1,1,1-trichloroethane*
12. hexachloroethane*
13. 1,1-dichloroethane*
14. 1,1,2-trichloroethane*
15. 1,1,2,2-tetrachloroethane*
16. chloroethane*
17. bis (chloromethyl) ether (DELETED)*
18. bis {2-chloroethyl) ether*
19. 2-chloroethyl vinyl ether (mixed)*
20. 2-chloronaphthalene*
21. 2,4,6-trichlorophenol*
22. parachlorometa cresol*
23. chloroform (trichloromethane)*
24. 2-chlorophenol*
25. 1,2-dichlorobenzene*
26. 1,3-dichlorobenzene*
27. 1,4-dichlorobenzene*
28. 3,3'-dichlorobenzidine*
29. 1,1-dichloroethylene*
30. 1,2-trans-dichloroethylene*
31. 2,4-dichlorophenol*
32. 1,2-dichloropropane*
33. 1,2-dichloropropylene (1,3-dichloropropene)*
3?. 2,4-dimethylphenol*
35. 2,4-dinitrotoluene*
36. 2,6-dinitrotoluene*
37. 1,2-diphenylhydrazine*
38. ethylbenzene*
39. fluoranthene*
40. 4-chlorophenyl phenyl ether*
41. 4-bromophenyl phenyl ether*
42. bis (2-chloroisopropyl) ether*
43. bis (2-choroethoxy) methane*
44. methylene chloride (dichloromethane)*
45. methyl chloride (chloromethane)*
46. methyl bromide (bromomethane)*
47. bromoform (tribromomethane)*
2087
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VI
48.
49.
50.
51.
52.
53.
54.
55.
56.
57.
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
TABLE VI-2 (Continued)
PRIORITY POLLUTANTS NEVER DETECTED
dichlorobromomethane*
trichlorofluoromethane (DELETED)*
dichlorofluoromethane (DELETED)*
chlorodibromomethane*
hexachlorobutadiene*
hexachlorocyclopentadiene*
isophorone*
naphthalene*
nitrobenzene*
2-nitrophenol*
4-nitrophenol*
2,4-dinitrophenol*
4,6-dinitro-o-cresol*
N-nitrosodimethylamine*
N-nitrosodiphenylamine*
N-nitrosodi-n-propylamine*
pentachlorophenol*
phenol*
bis(2-ethylhexyl) phthalate*
butyl benzyl phthalate*
di-n-butyl phthalate*
di-n-octyl phthalate*
diethyl phthalate*
dimethyl phthalate*
benzo (a)anthracene (1,2-benzanthracene)*
benzo (a)pyrene (3,4-benzopyrene)*
3,4-benzofluoranthene*
benzo(k)fluoranthane (11,12-benzofluoranthene)*
chrysene*
acenaphthylene*
anthracene*
benzo(ghi)perylene (1,11-benzoperylene)*
fluorene*
(1,2,5,6-dibenzanthracene)*
(w,e,-o-phenylenepyrene)*
phenanthrene*
dibenzo (a,h)anthracene
indeno (l,2,3-cd)pyrene
pyrene*
tetrachloroethylene*
toluene*
trichloroethylene*
vinyl chloride (chloroethylene)*
aldrin*
dieldrin*
chlordane (technical mixture and metabolites)*
4,4'-DDT*
4,4'-DDE(p,p'DDX)*
4,4'-DDD(p,p'TDE)*
Alpha-endosulfan*
,2038
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - VI
TABLE VI-2 (Continued)
PRIORITY POLLUTANTS NEVER DETECTED
96. Beta-endosultan*
97. endosulfan sulfate*
98. endrin*
99. endrin aldehyde*
100. heptachlor*
101. heptachlor epoxide*
102. Alpha-BHC*
103. Beta-BHC*
104. Gamma-BHC (lindane)*
105. Delta-BHC*
106. PCB-1242 (Arochlor 1242)*
107. PCB-1254 (Arochlor 1254)*
108. PCB-1221 (Arochlor 1221)*
109. PCB-1232 (Arochlor 1232)*
110. PCB-1248 (Arochlor 1248)*
111. PCB-1260 (Arochlor 1260)*
112. PCB-1016 (Arochlor 1016)*
113. toxaphene*
116. asbestos (Fibrous)
117. beryllium*
119. chromium (Total)*
121. cyanide (Total)*
124. nickel*
125. selenium*
126. silver*
127. thallium*
129. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
*We did not analyze for these pollutants in samples of raw
wastewater from this subcategory. These pollutants are not
believed to be present based on the Agency's best engineering
judgement which includes consideration of raw materials and
process operations.
2089
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VI
THIS PAGE INTENTIONALLY LEFT BLANK
2090
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VII
SECTION VII
CONTROL AND TREATMENT TECHNOLOGIES
The preceding sections of this supplement discussed the sources,
flows, and. characteristics of the wastewaters from primary
antimony plants. This section summarizes the description of
these wastewaters and indicates the treatment technologies which
are currently practiced in the primary antimony subcategory for
each waste stream. Secondly, this section presents the control
and treatment technology options which were examined by the
Agency for possible application to the primary antimony
subcategory.
CURRENT CONTROL AND TREATMENT PRACTICES
This section presents a summary of the control and treatment
technologies that are currently being applied to each of the
sources generating wastewater in this subcategory. As discussed
in Section V, wastewater associated with the primary antimony
subcategory is characterized by the presence of the toxic metal
pollutants and suspended solids. Generally, these pollutants are
present at concentrations above the long term average
concentration achievable by the treatment technologies
considered. This analysis is supported by the raw (untreated)
wastewater data presented in Section V. These wastewater streams
may be combined to allow plants to take advantage of economies of
scale. The options selected for consideration for BPT, BAT,
NSPS, _and pretreatment based on combined treatment of these
compatible waste streams are summarized later in this section.
SODIUM ANTIMONATE AUTOCLAVE WASTEWATER
Sodium antimonate (NaSb03) is manufactured by autoclaving the
antimony-bearing solution from the leaching process with oxygen.
The autoclave wastewater is expected to contain treatable
concentrations of suspended solids and toxic metals. One plant
which manufactures sodium antimonate achieves zero discharge of
this stream using evaporation ponds.
Another _ plant recovers sodium antimonate from spent
electrowinning solution by autoclaving. The recovered sodium
antimonate is recycled to the leaching process. This product
recovery process is considered to be a wastewater treatment step
and is distinguished from autoclaving to produce sodium
antimonate as a product.
FOULED ANOLYTE
Antimony metal.is recovered from the pregnant solution from the
leaching process by electrowinning. All three of the plants
which practice electrowinning recycle the barren electrolyte
solution to leaching. One plant reports total recycle of the
2091
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VII
spent electrowinning solution. The second plant spray dries thja
solution and recycles the dried salts. The third plant recycle^,
some of the electrolyte but discharges the fouled anoly'te"
portion. Fouled anolyte contains toxic metals and suspended
solids. Sodium antimonate is recovered from the stream by
autoclaving, and the autoclave wastewater is treated in a
chemical precipitation and sedimentation system before discharge
to a river.
CATHODE ANTIMONY WASH WATER
In the electrowinning process/ antimony metal is plated onto a
host cathode. The cathode is stripped and the antimony product
is ready for sale or further processing. One plant processes the
cathode antimony in a fuming furnace to produce antimony
trioxide. Two other plants market the antimony metal produced
from electrowinning. One reported washing of the product
antimony prior to packaging, but the second plant did not. Wash
water from cathode antimony washing contains treatable
concentrations of toxic metals. The plant reporting this stream
treats it in a chemical precipitation and sedimentation system
before discharging to a river.
CONTROL AND TREATMENT OPTIONS
The Agency examined two control and treatment technology options
that are applicable to the primary antimony subcategory. The
options selected for evaluation represent applicable end-of-pipe
treatment technologies.
OPTION A
The Option A treatment scheme for the primary antimony
subcategory consists of chemical precipitation and sedimentation
along with sulfide precipitation preliminary treatment for all
waste^streams. Chemical precipitation and sedimentation consists
of lime addition to precipitate metals followed by gravity
sedimentation for the removal of suspended solids, including the
metal precipitates. Vacuum filtration is used to dewater the
sludge.
OPTION C
Option C for the primary antimony subcategory consists of all
control and treatment requirements of Option A (sulfide
precipitation preliminary treatment, chemical'precipitation and
sedimentation) plus multimedia filtration technology added at the
end of the Option A treatment scheme. Multimedia filtration is
used to remove suspended solids, including precipitates of toxic
metals, below the concentration attainable by gravity
sedimentation. The model filter is of the gravity, mixed-media
type, although other filters, such as rapid sand filters, would
perform satisfactorily.
2092
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VIII
SECTION VIII
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS
This section presents a summary of compliance costs for the
primary antimony subcategory and a description of the treatment
options and subcategory-specific assumptions used to develop
these estimates. Together with the estimated pollutant removal
performance presented in Sections X and XII of this supplement,
these cost estimates provide a basis for evaluating each
regulatory option. These cost estimates are also used in
determining the probable economic impact of regulation on the
subcategory at different pollutant discharge levels. In
addition, this section addresses nonwater quality environmental
impacts of wastewater treatment and control alternatives,
including air pollution, solid wastes, and energy requirements,
which are specific to the primary antimony subcategory.
TREATMENT OPTIONS FOR EXISTING SOURCES
As discussed in Section VII, two treatment options have been
developed and considered in promulgating limitations and
standards for the primary antimony subcategory. These options
are summarized below and schematically presented in Figures X-l
and X-2 (pages 2118 and 2119).
OPTION A
The Option A treatment scheme consists of lime precipitation and
sedimentation technology along with sulfide precipitation
preliminary treatment.
OPTION C
Option C for the primary antimony subcategory consists of all
control and treatment requirements of Option A (sulfide
precipitation preliminary treatment, lime precipitation and
sedimentation) plus multimedia filtration technology added at the
end of the Option A treatment scheme.
COST METHODOLOGY
A detailed discussion of the methodology used to develop the
compliance costs is presented in Section VIII Of Vol. I. Plant-
by-plant compliance costs for the nonferrous metals manufacturing
category have been revised as necessary following proposal.
These revisions calculate incremental costs, above treatment
already in place, necessary to comply with the promulgated
effluent limitations and standards and are presented in the
administrative record supporting this regulation. A comparison
of the costs developed for pr .sposal and the revised costs for the
final regulation are presented in Table VIII-1 (page 2096) for
the direct discharger in this subcategory.
2093
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VIII
Each of the general assumptions used to develop compliance costs
is presented in Section VIII of Vol. 1. No subcategory-specific
assumptions were used in developing compliance costs for the
primary antimony subcategory.
NONWATER QUALITY ASPECTS
Nonwater quality impacts specific to the primary antimony
subcategory, including energy requirements, solid waste and air
pollution are discussed below.
ENERGY REQUIREMENTS
Energy requirements for Option A are estimated at 409,000 kWh/yr,
and for Option C the estimated requirement is 413,000 kWh/yr.
Option C energy requirements increase over those for Option A
because filtration is being added as an end-of-pipe treatment
technology. The energy requirements of both options represent
less than 10 percent of the total energy presently consumed at
the discharging plant. It is, therefore, concluded that the
energy requirements of the treatment options considered will have
no significant impact on total plant energy consumption.
SOLID WASTE
Sludge generated in the primary antimony subcategory is due to
the precipitation of metal sulfides using sulfide precipitation
and metal hydroxides and carbonates using lime. Sludges
associated with the primary antimony subcategory will necessarily
contain quantities of toxic metal pollutants. These lime sludges
are not subject to regulation as hazardous wastes since wastes
generated by primary smelters and refiners are currently exempt
from regulation by Act of Congress (Resource Conservation and
Recovery Act (RCRA), Section 3001 (b)), as interpreted by EPA. If
a small (5-10%) excess of lime is added during treatment, the
Agency does not believe these sludges would be identified as
hazardous under RCRA in any case. (Compliance costs include this
amount of lime.) This judgment is based on the results of
Extraction Procedure (EP) toxicity tests performed on similar
sludges (toxic metal-bearing sludges) generated by other
industries such as the iron and steel industry. A small amount
of excess lime was added during treatment, and the sludges
subsequently generated passed the toxicty test. See CPR $261.24.
Thus, the Agency believes that the wastewater sludges will
similarly not be EP toxic if the recommended technology is
applied.
Sludges generated by sulfide precipitation preliminary treatment
are expected to be hazardous, and were treated as such in the
compliance cost estimates.
Although it is the Agency's view that solid wastes generated as a
result of these guidelines are not expected to be hazardous,
generators of these wastes must test the waste to determine if
2094
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - VIII
the wastes meet any of the characteristics of
(see 40 CFR 262.11).
hazardous waste
If these wastes should be identified or are listed as hazardous,
they will come within- the scope of RCRA's "cradle to grave"
hazardous waste management program, requiring regulation from,
the point of generation to point of final disposition. EPA's
generator standards would require generators of hazardous
nonferrous metals manufacturing wastes to meet containerization,
labeling, recordkeeping, and reporting requirements; if plants
dispose of hazardous wastes off-site, they would have to prepare
a manifest, which would track the movement of the wastes from the
generator's premises to a permitted off-site treatment, storage,
or disposal facility. See 40 CFR 262.20 45 FR 33142 (May 19,
1980), as amended at 45 FR 86973 (December 31, 1980). The
transporter regulations require transporters of hazardous wastes
to comply with the manifest system to assure that the wastes are
delivered to a permitted facility. See 40 CFR 263.20 (45 FR
33151, May 19, 1980), as amended at 45 FR 86973 (December 31,
1980). Finally, RCRA regulations establish standards for
hazardous waste treatment, storage, and disposal facilities
allowed to receive such wastes. See 40 CFR Part 464 (46 FR 2802,
January 12, 1981 and 47 FR 32274, July 26, 1982).
Even if these wastes are not identified as hazardous, they still
must be disposed of in compliance with the Subtitle D open
dumping standards, implementing 4004 of RCRA. See 44 FR 53438
(September 13, 1979).
It is estimated that the primary antimony subcategory will
generate 3,260 metric tons of sludge per year when implementing
the promulgated BPT treatment technology. The Agency has
calculated as part of the costs for wastewater treatment the cost
of hauling and disposing of these wastes. For more details, see
Section VIII of the General Development Document.
AIR POLLUTION
There is no reason to believe that any substantial air. pollution
problems will result from implementation of sulfide
precipitation, chemical precipitation, sedimentation, and
multimedia filtration. These technologies transfer pollutants to
solid waste and are not likely to transfer pollutants to air.
2095
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - VIII
TABLE VIII-1
COST OF COMPLIANCE FOR THE PRIMARY ANTIMONY SUBCATEGORY
DIRECT DISCHARGERS
(March, 1982 Dollars)
Proposal Costs
Capital Annual
Promulgation Costs
Capital Annual
Option
A
C
Cost
34200
41250
Cost
17300
21183
Cost
196400
208300
Cost
554200
560400
2096
-------
PRIMARY-ANTIMONY SUBCATEGORY SECT - IX
SECTION IX
BEST PRACTICABLE CONTROL TECHNOLOGY
CURRENTLY AVAILABLE
This section defines the effluent characteristics attainable
through the application of best practicable control technology
currently available (BPT). BPT reflects the existing performance
by plants of various sizes, ages, and manufacturing processes
within the primary antimony subcategory, as well as the
established performance of the recommended BPT systems.
Particular consideration is given to the treatment already in
place at plants within the data base.
The factors considered in identifying BPT include the total cost
of applying the technology in relation to the effluent reduction
benefits from such application, the age of equipment and
facilities involved, the manufacturing processes used, nonwater
quality environmental impacts (including energy requirements),
and other factors the Administrator considers appropriate. In
general, the BPT level represents the average of the existing
performances of plants of various ages, sizes, processes, or
other common characteristics. Where existing performance is
uniformly inadequate, BPT may be transferred from a different
subcategory or category. Limitations based on transfer of
technology are supported by a rationale concluding that the
technology is, indeed, transferable, and a reasonable prediction
that it will be capable of achieving the prescribed effluent
limits. BPT focuses on end-of-pipe treatment rather than process
changes or internal controls, except where such practices are
common industry practice.
TECHNICAL APPROACH TO BPT
The Agency studied the nonferrous metals category to identify the
processes used, the wastewaters generated, and the treatment
processes installed. Information was collected from industry
using data collection portfolios, and specific plants were
sampled and the wastewaters analyzed. In making technical
assessments of data, reviewing manufacturing processes, and
assessing wastewater treatment technology options, both indirect
and direct dischargers have been considered as a single group.
An examination of plants and processes did not indicate any
process differences based on the type of discharge, whether it be
direct or indirect.
As explained in Section IV, the primary antimony subcategory has
been subdivided into three potential wastewater sources. Since
the water use, discharge rates, and pollutant characteristics of
each of these wastewaters is potentially unique, effluent
limitations will be developed for each of the three segments.
2097
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
For each of the segments, a specific approach was followed for
the development of BPT mass limitations. The first requirement
to calculate these limitations is to account for production and
flow variability from plant to plant. Therefore, a unit of
production or production normalizing parameter (PNP) was
determined for each waste stream which could then be related to
the flow from the process to determine a production normalized
flow. Selection of the PNP for each process element is discussed
in Section IV. Each plant within the subcategory was then
analyzed to determine (1) which segments were present, (2) the
specific flow rates generated for each segments, and (3) the
specific production normalized flows for each subdivision. This
analysis is discussed in detail in Section V. Nonprocess
wastewaters such as rainfall runoff and noncontact cooling water
are not considered in the analysis.
Production normalized flows for each segment were then analyzed
to determine the flow to be used as part of the basis for BPT
mass limitations. The selected flow (sometimes referred to as
the BPT regulatory flow) reflects the water use controls which
are common practices within the category. The BPT regulatory
flow is based on the average of all applicable data. Plants with
normalized flows above the average may have to implement some
method of flow reduction to achieve the BPT limitations.
The second requirement to calculate mass limitations is the set
of concentrations that are achievable by application of the BPT
level of treatment technology. Section VII discusses the various
control and treatment technologies which are currently in place
for each wastewater source. In most cases throughout the
nonferrous metals manufacturing category the current control and
treatment technologies consist of lime precipitation and
sedimentation (lime and settle) technology. For this
subcategory, EPA is adding sulfide precipitation preliminary
treatment for arsenic control to ensure that the level achievable
by lime and settle is met.
Using these regulatory flows and the achievable concentrations,
the next step is to calculate mass loadings for each wastewater
source or building block. This calculation was made on a stream-
by-stream basis, primarily because plants in this subcategory may
perform one or more of the operations in various combinations.
The mass loadings (milligrams of pollutant per metric ton of
production — mg/kkg) were calculated by multiplying the BPT
regulatory flow (1/kkg) by the concentration achievable by the
BPT level of treatment technology (mg/1) for each pollutant
parameter to be limited under BPT.
The mass loadings which are allowed under BPT for each plant will
be the sum of the individual mass loadings for the several
building blocks sources which are found at particular plants.
Accordingly, all the wastewater generated within a plant may be
combined for treatment in a single or common treatment system,
but the effluent limitations for these combined wastewaters are
based on the specific sources which actually contribute to the
2098
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
combined flow. This method accounts for the variety of
combinations of wastewater sources and production processes which
may be found at primary antimony plants.
The Agency usually establishes wastewater limitations in terms of
mass rather than concentration. This approach prevents the use
of dilution as a treatment method (except for controlling pH).
The production normalized wastewater flow (1/kkg) is a link
between the production operations and the effluent limitations.
The pollutant discharge attributable to each operation can be
calculated from the normalized flow and effluent concentration
achievable by the treatment technology and summed to derive an
appropriate limitation for each plant.
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES
In balancing costs in relation to pollutant removal estimates,
EPA considers the volume and nature of existing discharges, the
volume and nature of discharges expected after application of
BPT, the general environmental effects of the pollutants, and the
cost and economic impacts of the required pollution control
level. The Act does not require or permit consideration of water
quality problems attributable to particular point sources or
industries, or water quality improvements in particular water
quality bodies. Accordingly, water quality considerations were
not the basis for selecting the proposed or promulgated BPT. See
Weyerhaeuser Company v. Costle, 590 F.2d 1011 (D.C. Cir. 1978).
The methodology for calculating pollutant removal estimates and
plant compliance costs is discussed in Section X. The pollutant
removal estimates have been revised since proposal based on
comments and on new data. Table X-l (page 2113) shows the
pollutant removal estimates for each treatment option for direct
dischargers. Compliance costs for direct dischargers are
presented in Table X-2 (page 2114).
BPT OPTION SELECTION
The technology basis for the BPT limitations is Option A, sulfide
precipitation preliminary treatment, and alkali precipitation and
sedimentation technology to remove metals and solids from
combined wastewaters and to control pH. The promulgated
technology differs from the proposed technology in that it
includes sulfide precipitation. Chemical precipitation and
sedimentation technology is ih-place at the one discharger in
this subcategory. The BPT model treatment trairi is presented in
Figure IX-1 (page 2103).
Implementation of the promulgated BPT limitations will remove
annually an estimated 17,522 kg of toxic metals and 8,634 kg of
TSS from the raw wastewater generated in primary antimony
production operations. The Agency projects a capital cost of
approximately $196,400 and an annualized cost of approximately
$554,200 for achieving the promulgated BPT.
2099
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
WASTEWATER DISCHARGE RATES
A BPT discharge rate is calculated for each segment based on the
average of the flows of the existing plants, as determined from
analysis of data collection portfolios. The discharge rate is
used with the achievable treatment concentrations to determine
BPT effluent limitations. Since the discharge rate may be
different for each wastewater source, separate production
normalized discharge rates for each of the three wastewater
sources are discussed below and summarized in Table IX-1 (page
2103). The discharge rates are normalized on a production basis
by relating the amount of wastewater generated to the mass of
product which is produced by the process associated with_ the
waste stream in question. These production normalizing
parameters, or PNPs, are also listed in Table IX-1.
Section V of this supplement further describes the discharge flow
rates and presents the water use and discharge flow rates for
each plant by subdivision in Tables V-l through V-3 (page 2078).
SODIUM ANTIMONATE AUTOCLAVE WASTEWATER
The BPT wastewater discharge allowance proposed for sodium
antimonate autoclave wastewater was 7,093 1/kkg (1,700 gal/ton)
of antimony contained in sodium antimonate product. No allowance
is given if sodium antimonate is recovered for recycling by
autoclaving fouled anolyte. In that case, autoclaving is
considered to be a wastewater treatment step for product
recovery. Because the one plant reporting this stream did not
provide flow rate information in the dcp, the BPT discharge
allowance for sodium antimonate autoclave wastewater was assumed
to be equal to the BPT discharge allowance for fouled anolyte
using the antimony content of the product as the production
normalizing parameter.
The BPT wastewater discharge allowance promulgated for sodium
antimonate autoclave wastewater is 15,624 1/kkg (3,744 gal/ton)
of antimony contained in sodium antimonate product. This rate is
allocated to any plant which produces sodium antimonate from a
pregnant leaching solution by an autoclaving operation. No
allowance is given when sodium antimonate is recovered for
recycling by autoclaving fouled anolyte because in that case,
autoclaving is considered to be a wastewater treatment step for
product recovery.
No recycle or reuse of this wastewater is reported at the one
plant that generates this stream. Because that plant did not
provide flow rate information in the dcp, the BPT discharge
allowance for sodium antimonate autoclave wastewater is assumed
to be equivalent to the promulgated BPT discharge allowance for
fouled anolyte, using the antimony content of the product as the
production normalizing parameter. New flow and production data
for the fouled anolyte waste stream resulted in a change from the
proposed value. For this reason and those stated above, the
promulgated discharge allowance for sodium antimonate autoclave
2100
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
wastewater is 15,624 1/kkg.
FOULED ANOLYTE
The BPT wastewater discharge allowance proposed for fouled
anolyte was 7,093 1/kkg (1,700 gal/ton) of antimony metal
produced by electrowinning. The BPT allowance was based on the
discharge rate at the only plant reporting this stream. That
plant recovers and recycles sodium antimonate from the fouled
anolyte before discharging the wastewater stream. Since
proposal, industry comments which included flow and production
information enabled EPA to recalculate production normalized
flows. Based on this data, a new regulatory flow was chosen for
the fouled anolyte wastewater stream.
The BPT wastewater discharge allowance promulgated for fouled
anolyte is 15,624 1/kkg (3,744 gal/ton) of antimony metal
produced by electrowinning. This rate is allocated to any plant
which recovers antimony from a pregnant leaching solution by
electrowinning. The promulgated BPT allowance is based on the
water use rate at the only plant reporting this wastewater
stream.
CATHODE ANTIMONY WASH WATER
A BPT discharge rate for cathode antimony wash water was never
proposed because dcp information used at proposal did not
quantify the wastewater discharge from this operation, leading
EPA to believe that it was insignificant. Comments received from
industry after proposal requesting an allowance for cathode
antimony wash water supplied information which allowed water use
and discharge rates to be calculated.
The BPT wastewater discharge rate for cathode antimony wash water
is 31,248 1/kkg (7,488 gal/ton) of antimony metal produced by
electrowinning. This rate is allocated to those plants which
wash antimony metal produced by electrowinning prior to final
packaging. This BPT flow is based on the discharge from one
plant reporting this stream. Water use and discharge rates are
presented in Table V-3 (page 2078).
REGULATED POLLUTANT PARAMETERS
The raw wastewater concentrations from individual operations and
the subcategory as a whole were examined to select certain
pollutant parameters for limitation. This ' examination and
evaluation is presented in Sections VI and X. A total of five
pollutants or pollutant parameters are selected for limitation
under BPT and are listed below:
2101
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
114. antimony
115. arsenic
123. mercury
TSS
pH
EFFLUENT LIMITATIONS
The treatable concentrations achievable by application of the
promulgated BPT are discussed in Section VII of this supplement.
These treatable concentrations (both one-day maximum and monthly
average values) are multiplied by the BPT normalized discharge
flows summarized in Table IX-1 (page 2103) to calculate the mass
of pollutants allowed to be discharged per mass of product. The
results of these calculations in milligrams of pollutant per
kilogram of product represent the BPT effluent limitations and
are presented in Table IX-2 (page 2104) for each individual waste
stream.
2102
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
TABLE IX-1
BPT WASTEWATER DISCHARGE RATES FOR THE
PRIMARY ANTIMONY SUBCATEGORY
Wastewater Stream
Sodium antimonate
autoclave wastewater
Fouled Anolyte
Cathode antimony
wash water
BPT Normalized
Discharge Rate
(1/kkg) (gal/ton)
Production Normalizing
Parameter (PNP)
15624 3744 Antimony contained in
sodium antimonate
product
15624 3744 Antimony metal produced
by electrowinning
31284 7488 Antimony metal produced
by electrowinning
2103
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
TABLE IX-2
BPT MASS LIMITATIONS FOR THE
PRIMARY ANTIMONY SUBCATEGORY
a) Sodium Anbimonabe Auboclave Wasbewaber BPT
Pollubanb or
pollubanb properby
Maximum for
any one day
Maximum for
monbhly average
mg/kg (Ib/million Ibs) of anbimony conbained
in sodium anbimonabe producb
*Anbimony
*Arsenic
Cadmium
Copper
Lead
*Mercury
Zinc
*TSS
44.840
32.650
5.312
29.690
6.562
3.906
22.810
640.600
20.000
14.530
2.344
15.620
3.125
1.562
9.531
304.700
*pH
Wibhin bhe range of 7.5 bo 10.0 ab all bimes
b) Fouled Anolybe BPT
Pollubanb or
pollubanb properby
Maximum for
any one day
Maximum for
monbhly average
mg/kg (Ib/million Ibs) of anbimony mebal
produced by elecbrowinning
*Anbimony
*Arsenic
Cadmium
Copper
Lead
*Mercury
Zinc
*TSS
*pH
44.840
32.650
5.312
29.690
6.562
3.906
22.810
640.600
20.000
14.530
2.344
15.620
3.125
1.562
' 9.531
304.700
Wibhin bhe range of 7.5 bo 10.0 ab all bimes
*Regulabed Pollubanb
2104
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - IX
TABLE IX-2 (Continued)
BPT MASS LIMITATIONS FOR THE
PRIMARY ANTIMONY SUBCATEGORY
c) Cathode Antimony Wash Water BPT
Maximum for
any one day
Pollutant or
pollutant property
Maximum for
monthly average
mg/kg (Ib/million Ibs) of antimony metal
produced by electrowinning
*Antimony
*Arsenic
Cadmium
Copper
Lead
*Mercury
Zinc
*TSS
89.680
65.310
10.620
59.370
13.120
7.812
45.620
1,281.000
40.000
29.060
4.687
31.250
6.250
3.125
19.060
609.300
Within the range of 7.5 to 10.0 at all times
*Regulated Pollutant
2105
-------
PRIMARY ANTIMONY SUBCATEGORY
SECT - IX
3-s
g
H H
H
2106
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - X
SECTION X
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
Thes.e effluent limitations are based qn the best control and
treatment technology used by a specific point source within the
industrial category or subcategory, or by another category from
which it is transferable. Emphasis is placed on additional
treatment techniques applied at the end of the treatment systems
currently used, as well as reduction of the amount of water used
and discharged, process control, and treatment technology
optimization.
The factors considered in assessing best available technology
economically achievable (BAT) include the age of equipment and
facilities involved, the process used, process changes, nonwater
quality environmental impacts (including energy requirements),
and the costs of application of such technology BAT represents
the best available technology economically achievable at plants
of various ages, sizes, processes, or other characteristics. BAT
may be transferred from a different subcategory or category. BAT
may include feasible process changes or internal controls, even
when not in common industry practice.
The required assessment of BAT considers costs, but does not
require a balancing of costs against pollutant removals (see
Weyerhaeuser v. Costle, 11 ERG 2149 (D.C. Cir. 1978)). However,
in assessing the proposed and promulgated BAT, the Agency has
given substantial weight to the economic achievability of the
technology.
TECHNICAL APPROACH TO BAT
The Agency reviewed a wide range of technology options and
evaluated the available possibilities to ensure that the most
effective and beneficial technologies were used as the basis of
BAT. To accomplish this, the Agency elected to examine two
technology options which could he applied to the primary antimony
subcategory as alternatives for the basis of BAT effluent
limitations. ,
For the development of BAT effluent limitations, mass loadings
were calculated for each wastewater source or subdivision in the
subcategory using the same technical approach as described in
Section IX for BPT limitations development. The differences in
the mass loadings for BPT and BAT are due to increased treatment
effectiveness achievable with the more sophisticated ' BAT
treatment technology.
2107
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - X
The treatment technologies considered for BAT are summarized
below:
Option A (Figure X-l, page 2113):
o Sulfide precipitation preliminary treatment
o Chemical precipitation and sedimentation
Option C (Figure X-2, page 2114):
o Sulfide precipitation preliminary treatment
o Chemical precipitation and sedimentation
o Multimedia filtration
The two options examined for BAT are discussed in greater detail
below. The first option considered (Option A) is the same as
the BPT treatment and control technology which was presented in
the previous section. The second option represents substantial
progress toward the reduction of pollutant discharges above and
beyond the progress achievable by BPT.
OPTION A
Option A for the primary antimony subcategory is equivalent to
the control and treatment technologies which were analyzed for
BPT in Section IX (see Figure X-l). BPT consists of sulfide
precipitation preliminary treatment to control arsenic discharge
and end-of-pipe treatment including chemical precipitation and
sedimentation. The discharge rates for Option A are equal to the
discharge rates allocated to each stream as a BPT discharge flow.
OPTION C
Option C for the primary antimony subcategory consists of all
control and treatment requirements of Option A (sulfide
precipitation, chemical precipitation and sedimentation) plus
multimedia filtration technology added at the end of the Option A
treatment scheme (see Figure X-2). Multimedia filtration is used
to remove suspended solids, including precipitates of toxic
metals, beyond the concentrations attainable bv gravity
sedimentation. The filter suggested is of the gravity, mixed
media type, although other forms of filters, such as rapid sand
filters or pressure filters, would perform satisfactorily.
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES
As one means of evaluating each technology option, EPA developed
estimates of the pollutant removals and the compliance costs
associated with each option. The methodologies are described
below.
2108
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - X
POLLUTANT REMOVAL ESTIMATES
A complete description of the methodology used to calculate the
estimated pollutant removal achieved by the application of the
various treatment options, is presented in Section X of the
Vol. 1. The pollutant removal estimates for this subcategory
were revised between proposal and promulgation based on comments
and new data; however, the methodology for calculating pollutant
removals was not changed. The data used for estimating removals
are the same as those used to revise the compliance costs.
Sampling data collected during the field sampling program were
used to characterize the major waste streams considered for
regulation. At each sampled facility, the sampling data was
production normalized for each unit operation (i.e., mass of
pollutant generated per mass of product manufactured). This
value, referred to as the raw waste, was used to estimate the
mass of toxic pollutants generated within the primary antimony
subcategory. The pollutant removal estimates were calculated for
each plant by first estimating the total mass of each pollutant
in the untreated wastewater. This was calculated by first
multiplying the raw waste values by the corresponding production
value for that stream and then summing these values for each
pollutant for every stream generated by the plant.
Next, the volume of wastewater discharged after the application
of each treatment option was estimated for each operation at each
plant by comparing the actual discharge to the regulatory flow.
The smaller of the two values was selected and summed with the
other plant flows. The mass of pollutant discharged was then
estimated by multiplying the achievable concentration values
attainable with the option (mg/1) by the estimated volume of
process wastewater discharged by the subcategory. The mass of
pollutant removed is the difference between the estimated mass of
pollutant generated within the subcategory and the mass of
pollutant discharged after application of the treatment option.
The pollutant removal estimates for direct dischargers in the
primary antimony subcategory are presented in Table X-l (paqe
2113) .
COMPLIANCE COSTS
In estimating subcategory-wide compliance costs, the first step
was to develop a cost estimation model, relating the total costs
associated with installation and operation of wastewater
treatment technologies to plant process wastewater discharge.
EPA applied the model to each plant. The plant's investment and
operating costs are determined by what treatment it has in place
and by its individual process wastewater discharge flow. As
discussed above, this flow is either the actual or the BAT
regulatory flow, whichever is lesser. The final step was to
annualize the .capital costs, and to sum the annualized capital
costs, and the operating and maintenance costs for each plant,
yielding the cost of compliance for the subcategory. A
comparison of the costs de-. eloped for proposal and the revised
2109
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - X
costs for promulgation are presented in Table X-2 (page 2114) for
direct dischargers in the primary antimony subcategory. These
costs were used in assessing economic achievability.
BAT OPTION SELECTION - PROPOSAL
EPA selected Option C for the proposed BAT which consists of
sulfide precipitation preliminary treatment followed by chemical
precipitation, sedimentation, and multimedia filtration. The
estimated capital cost of proposed BAT was $41,250 (1982 dollars)
and the annual cost was $21,183 (1982 dollars). Implementation
of the proposed BAT technology was estimated to remove 2,644
kilograms of priority metal pollutants from raw wastewater
annually.
BAT OPTION SELECTION z PROMULGATION
After proposal, EPA received comments reporting a waste stream
that had not been included in the proposed rulemaking.
Wastewater flow rates and production data were obtained and used
to calculate production normalized flow rates and mass
limitations. These data were also used for recalculating
pollutant^ removal estimates and for revising compliance costs.
In addition, EPA included sulfide precipitation preliminary
treatment to help insure adequate arsenic removal. Sulfide is
used to precipitate metals such as arsenic at a low pH which can
then be removed with a pressure filter prior to the higher pH
chemical precipitation processes.
EPA is promulgating BAT limitations for this subcategory based on
sulfide precipitation preliminary treatment, chemical
precipitation and sedimentation, and multimedia filtration. The
technology basis for BAT limitations being promulgated differs
from that used for the proposed limitations because it includes
the sulfide precipitation step. However, the treatment
performance concentrations, upon which the mass limitations are
based, are equal to values used to calculate the proposed mass
limitations.
EPA is promulgating multimedia filtration as part of the BAT
technology because this technology results in additional removal
of toxic metals. Filtration is also presently demonstrated at 25
plants throughout the nonferrous metals manufacturing category.
Filtration adds reliability to the treatment system by making it
less susceptible to operator error and to sudden changes in raw
wastewater flow and pollutant concentrations.
Implementation of the control and treatment technologies of
Option C will remove annually an estimated 17,540 kilograms of
priority metal pollutants, which is 18 kilograms of priority
metal pollutants over the estimated BPT removal. The estimated
capital cost for achieving the promulgated BAT is $208,300 (1982
dollars) and the estimated annual cost is $560,400 (1982
dollars).
2110
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - X
WASTEWATER DISCHARGE RATES
.
analysis of the data collection portfolios. The discharoe
a*termlned
summarized in
parameters, or PNPs, are also listed in Table X-3
The BAT discharge allowances reflect no flow reduction
requirements as compared to the promulgated BPT option flows In-
process flow reduction was not considered achievable ?or ' any
?S3 ™ 6r /tf?ams in this subcategory. Consequently? the BAT
and BPT production normalized discharge flows a?e identical?
REGULATED POLLUTANT PARAMETERS
In implementing the terms of the Consent Agreement in NRDC v
Train, Op. Cit., and 33 U.S.C. 1314(b)(2)(A and B) ngftl^ the
Agency placed particular emphasis on the toxic pollutants?5 ' The
raw wastewater concentrations from individual operations and thl
subcategory as a whole were examined to select certain polfStants
evfliiSnin " Parameters _ for limitation. This examination SSd
evaluation was presented in Section VI. The Agency, however haS
£ur^r ^ ^ re?ulate a11 seven. toxic" PollutIntsyrae?SctlS'-fS?
further consideration in this analysis.
The high cost associated with analysis for priority metal
pollutants has prompted EPA to develop an alternative method fSj
nd mo?itorin9 Priority pollutant discharges from the
metals manufacturing category. Rather than
SPecffic effluent mass limitations and s?andLds fSr
the w f10^ty mSfc alS f°Und ln treat^le concentrations in
the raw wastewater from a given subcategory, the Aqencv is
promulgating effluent mass limitations only for those pollStantl
generated in the greatest quantities as shown by the Sollutan?
removal analysis. The pollutants selected for Specific
limitation are listed below: • speciric
114. antimony
115. arsenic
123. mercury
EPA has revised the pollutant selection following proposal hv
eliminating lead from the list of limited Pol?utSntsPbe?ause it
will be controlled by the selected technology. Because it
By establishing limitations and standards for certain priority
nonfrr
nonferrous
2111
-------
PRIMARY ANTIMONY SUBCATEGORY SECT - X
metal pollutants, dischargers are expected to attain the same
degree of control over priority metal pollutants as they would
have been required to achieve had all the priority metal
pollutants been directly limited.
This approach is technically justified since the treatable
concentrations used for chemical precipitation and sedimentation
technology are based on optimized treatment for concomitant
multiple metals removal. Thus, even though metals have somewhat
different theoretical solubilities, they will be removed at very
nearly the same rate in a chemical precipitation and
sedimentation treatment system operated for multiple metals
removal. Filtration as part of the technology basis is likewise
justified because this technology removes metals non-
preferentially.
The priority metal pollutants selected for specific limitation in
the primary antimony subcategory to control the discharges of
priority metal pollutants are antimony, arsenic, and mercury. The
following toxic metal pollutants are excluded from limitation on
the basis that they are effectively controlled by the limitations
developed for antimony, arsenic, and mercury:
118. cadmium
120. copper
122. lead
128. zinc
EFFLUENT LIMITATIONS
The concentrations achievable by application of BAT are discussed
in Section VII of this supplement. The achievable concentrations
(both one day maximum and monthly average values) are multiplied
by the BAT normalized discharge flows summarized in Table X-3
(page 2115) to calculate the mass of pollutants allowed to be
discharged per mass of product. The results of these calculations
in milligrams of pollutant per kilogram of product represent the
promulgated BAT effluent limitations and are presented in Table
X-4 (page 2116) for each waste stream.
2112
-------
PRIMARY ANTIMONY SUBCATEGORY
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